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• RECE 'EDN <br /> 2 61,01j <br /> ENVIRON.ViL v7 HEALTH <br /> Union Pacific Railroad <br /> PERMIT/SERVICES <br /> Environmental Management Group <br /> 9451 Atkinson Street,Suite 100,Roseville,California 95747 <br /> John R.Thomas (916)789-5538 <br /> Manager of Environmental Field Operations Facsimile(402) 997-4389 <br /> Ms. Thuy Tran <br /> San Joaquin County Environmental Health Department <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 <br /> Re: Hazardous Waste Program Inspection Report <br /> Aboveground Petroleum Storage Act (APSA) Program Inspection Report <br /> Union Pacific Railroad, Lathrop Intermodal Facility, September 24, 2010 <br /> Ms.Tran, <br /> The Return to Compliance Certification form addressing your inspection of Union Pacific <br /> Railroad's Lathrop Intermodal Facility in French Camp is attached. <br /> Following are comments regarding the corrections implemented with specific items identified by <br /> the number referred to in the inspection reports. <br /> Hazardous Waste Program Inspection Report <br /> #7 Failed to determine if a waste is a hazardous waste. <br /> The bench grinder that generated the metal fines was taken out of service upon receipt of your <br /> report. A sample of the metal fines was taken and sent to a laboratory for analysis (CAM 17)to <br /> determine whether the fines are hazardous. The TTLC result for one of the metals was above <br /> the regulatory limit. However there was not sufficient sample to conduct an STLC analysis to <br /> determine whether to characterize the waste as hazardous waste. We plan to put the grinder <br /> will be put back in operation and the handle the fines as a hazardous waste until sufficient fines <br /> are collected to run both TTLC and STLC analyses. After these analyses, the waste <br /> characterization will be readdressed. <br /> #60 Failed to keep signed copy for 3 years. <br /> A signed returned copy of manifest 005920245JJK (shipped 11/05/09) is attached to this letter. <br /> The other manifests referred to in the Report, 000123120JJK and 001983327SKS, were not <br /> generated by Union Pacific. <br /> #61 Failed to determine status of hazardous waste when manifest copy not received. <br /> A copy of the returned manifest,00590345JJK, was in Union Pacific's files prior to the <br /> inspection. A copy of this signed manifest was provided to the DTSC in late 2009. The reason <br /> that it was apparently not available at the time of the inspection is not known. <br />