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Memo to Mr. Chris Flower - 2 - 29 July 2021 <br />Joaquin County Environmental Health Department (SJCEHD) initially responded to the <br />release. <br />TREATMENT AREA <br />The treatment area is a portion of CCT track where red dye, a tracer additive to diesel, <br />was visually observed to have stained the soil. UPRR removed 80 feet of track, which <br />extended outside of the impacted area to excavate impacted soils and ballast. UPRR <br />excavated soil and ballast beyond the visually observed impacted area, with the total <br />extent of excavation measuring 45 feet long, 18 feet wide, and 3 feet deep. <br />ACTIONS <br />On 22 July 2020, after the diesel release, Ground Penetrating Radar Systems, <br />LLC conducted a utility locate and found no utilities. Arcadis located and <br />inspected nearby sewer and storm drains. Diesel was not observed in the <br />municipal utilities. <br />On 22 July 2020, vacuum trucks and absorbent pads were used to capture free- <br />phase diesel on the ground surface and between railroad ties. Absorbent pads <br />were left overnight in potholes and trenches to collect additional diesel. Impacted <br />ballast and soil were recovered and stockpiled for waste characterization. <br />On 23 July 2020, 80 feet of track was removed and an area of 45 feet long, 18 <br />feet wide was excavated to approximately 3 feet. A photoionized detector (P ID) <br />was used to screen the soil for volatile organic compounds (VOCs) to determine <br />the extent of excavation. <br />On 23 July 2020, six confirmation samples were taken from the excavation floor <br />and sidewalls. Upon approval of an SJCEHD representative, the excavated area <br />was backfilled with imported crushed rock subbase and new imported ballast. <br />UPRR characterized the approximately 118 tons of waste material to be non- <br />hazardous and disposed of the waste between 21 August 2020 and 25 August <br />2020. Copies of the waste manifests have been provided to the Central Valley <br />Water Board. <br />RATIONALE <br />UPRR and its contractors responded to the release by implementing recovery and <br />control measures immediately and completed source area excavation with confirmation <br />sampling the day after the release. A PID was used to screen for VOCs and ensure any <br />diesel-impacted soil was removed. In addition, the highest detections of Total Petroleum <br />Hydrocarbons as Diesel Range Organics (TPH-DRO) and Oil Range Organics <br />(TPH-ORO) from the six confirmation samples were 9.19 milligrams per kilogram <br />(mg/kg) and 42.6 mg/kg, respectively. The detections of these constituents of concern <br />(COCs) are substantially below the residential shallow exposure Environmental <br />Screening Levels (ESLs) of 260 mg/kg for TPH-DRO and 12,000 mg/kg for TPH-ORO. <br />While the Site is used for commercial operations and is expected to remain as such,