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LOMOND 0, BROWN Jn. oovennon Water Boards MATTHEW RODRIQUEZ SECRETATIY Fon ENVIRONMENTAL PROTECTION Central Valley Regional Water Quality Control Board 25 January 2017 Mr. Mike Makerov, P.G. Manager Environmental Remediation BNSF Railway 740 E. Carnegie Drive San Bernardino, CA 92408-3571 CONDITIONAL CONCURRENCE WITH HIGH RESOLUTION SITE CHARACTERIZATION WORK PLAN, BNSF RAILWAY COMPANY MORMON YARD, 801 DIAMOND STREET, SAN JOAQUIN COUNTY Burlington Northern Santa Fe Railway (BNSF) identified groundwater containing diesel pollutants beneath the location of a 2011 fuel release at its Mormon Yard in Stockton. The soil samples suggested that the groundwater pollutants were unrelated to the fuel release, and in a 25 November 2015 letter, Central Valley Water Board staff requested BNSF demonstrate that the fuel concentrations are decreasing. In a 6 January 2016 meeting, Central Valley Water Board additionally requested that BNSF conduct a groundwater investigation to ascertain if the diesel detections in groundwater represent an unidentified or continuing release of diesel. In response, BNSF provided the 31 March 2016 High Resolution Site Characterization Work Plan (Work Plan) prepared by Kennedy Jenks Consultants. In the Work Plan, BNSF presents documentation of underground fuel tanks removed in 1990 and subsequent excavations of fuel-contaminated soil. Among the findings presented is a subsurface waste oil transfer pipe that failed an integrity test. BNSF proposes to evaluate these potential sources of pollution by using laser induced flourescence (LIF) to semi-quantitatively observe petroleum in the subsurface. In this case, the LIF technology emits an ultra-violet wavelength that excites petroleum particles which emit a longer wavelength when they return to a normal state. The wavelength emitted is recorded and provides an image representing petroleum presence with depth in the borehole. The LIF is advanced in boreholes with a cone penetrometer rig which also records soil types. BNSF proposes four transects of LIF boreholes, with about 15 borings advanced to about 50 feet, Each boring will result in a continuous sequence of wavelength readings. The first two transects are proposed along the waste oil transfer pipe and along the length of the 1995 soil excavations. The last two transects are upgradient and downgradient of the first two, and the location of the borings will be informed by the results of the first two transects of LIF readings. Please transmit a figure with the proposed locations of the final two transects to Central Valley Water Board staff for concurrence prior to proceeding with them. In an 18 January 2017 telephone conversation with staff of BNSF, Central Valley Water Board and Ms.Laura Kennedy of Kennedy/Jenks Associates, Ms. Kennedy suggested that the work could commence in March, weather permitting, and a report of results could be provided about KARL E. LONGLEY ScD, FE., CHAIR I PAMELA C. CREEDON FE., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive 6200, Rancho Cordova, CA 95670 I www waterboards.ca.gov/oentralvalley HEOVOLtU PAPER