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California Reg onal Water Quality CO%,ntrol Board r �° <br /> Central Valley Region ,, <br /> Karl E. Longley,ScD, P.E.,Chair <br /> Linda S. Adams Arnold <br /> Sec-eta�7 for 11020 Sun Center Drive#200.Rancho Cordova.California 9 670-6114 Schwarzenegger <br /> Envonmental Phone(916)464-3291 FAX(916)464-4645 Governor <br /> Prorectton http.//\N,ww.waterboards.ca.gov/central\alley <br /> 16 September 2008 J11 v � <br /> SEP d 6 2008 <br /> Mr. James Diel ENVIROW,1Ed T HEALTH <br /> Manager, Site Remediation I'ER"t11T%SER'v 'ICES <br /> Union Pacific Railroad Company <br /> 9451 Atkinson Street, Suite 100 <br /> Roseville, CA 95747-5528 <br /> 20v-7i?nnQ n►vn Lt 4L MON!TOPING REPORT, UNION PACIFIC RAILROAD COMPANY, <br /> FORMER MAINTENANCE FACILITY, 720 EAST 6TH STREET, TRACY, SAN JOAQUIN <br /> COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) staff has received and reviewed the 2007/2008 Annual Monitoring Report (Report) for <br /> Union Pacific Railroad's (UPRR) former maintenance facility in Tracy. The Report, dated <br /> 16 May 2008, was prepared by Arcadis U.S., Inc. (ARCADIS) on behalf of UPRR. The <br /> Report is a requirement of Monitoring and Reporting Program (MRP) No. R5-2002-0807. The <br /> MRP requires semiannual monitoring of six wells and annual monitoring of 30 wells. <br /> I have the following specific comments on the Report. <br /> 1 . Section 3.1. Remediation System Operation and Maintenance, refers to a Rebound and <br /> Remediation Effectiveness Evaluation Addendum Work Plan (dated 3 January 2006) and <br /> Additional Product Removal Proposal (dated 28 August 2006) submitted to the Regional <br /> Water Board for review. ARCADIS states that UPRR has not received comments from the <br /> Regional Water Board on these documents. I located the comment letter from Steven <br /> Meeks to Jim Levy dated 20 November 2006 that addresses both of these documents. In <br /> it. the Regional Water Board staff specifies revisions to the Work Plan, conditionally <br /> concurs with the application of low vacuum soil vapor extraction and tree product <br /> skimming, and recommends that extraction wells EW-1 through EW-21 be either <br /> abandoned or incorporated into the MRP. I forwarded this letter electronically to Lisa <br /> Teague of ARCADIS on 25 August 2008. Please review the letter against what has been <br /> done or remains to be done from these two proposals, and provide me a status in writing <br /> by 16 October 2008. We would like to resume product removal in the source area, and <br /> begin either well abandonment or monitoring at the extraction wells, as soon as possible. <br /> Please provide me with a proposal for either well abandonment or incorporation of wells <br /> into the MRP by 16 October 2008. <br /> 2 In March 2008, ARCADIS documented an order-of-magnitude increase in total petroleum <br /> hydrocarbons quantified as diesel (TEPHd) in monitoring well MW-8A over March 2006 <br /> concentrations, and detections of TEPHd in wells MW-11 BR and MW-12B, which had <br /> California Environmental Protection Agency, <br /> � Hec.vcIM Paper <br />