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Ll <br />K-2ZA-5 <br />i <br />August 7, 2013 <br />Edward P. Phillips <br />Manager Environmental Operations <br />Cal' i 'vis' n <br />EIVED <br />Mr. Jeffrey Wong, REHS <br />San Joaquin County Environmental Health Department <br />1968 East Hazelton Avenue <br />Stockton, California 95205-6232 <br />v <br />BNSF Railway Company <br />740 East Camegie Drive <br />San Bernardino, CA 92408471 <br />Phone 909-386-4082 <br />Fax 909-38614087 <br />edward. Phil Iigs(ccDbnsf. com <br />Via email <br />Re: June 27, 2013 Hazardous Waste Inspection for 801 Diamond Street Facility <br />Mr. Wong, <br />This letter is in response to your hazardous waste inspection conducted June 27, 2013 for <br />the BNSF Railway facility located at 801 Diamond Street in Stockton, California. Mr. <br />Jeremy Quick, P.G. accompanied you on behalf of BNSF. <br />BNSF has a written corporate policy requiring compliance with all applicable laws, <br />regulations, and codes. We remain committed to properly managing our wastes, and <br />complying with all applicable legal standards. <br />The following violations and their resolutions are noted below: <br />1. # 108 — 22 CCR 66262.11; Failed to determine if a waste is a hazardous waste. Of <br />the seven items noted in your report, three were not wastes; the 5 -gallon bucket of <br />oil in the machine shop, the 5 -gallon bucket of oil outside the MOW, and the four <br />containers of oil in the Product Area (one 55 -gallon drum and one 5 -gallon bucket <br />— both marked SAE 15/40, one 1 -gallon container, and one 5 -gallon bucket). <br />Nonetheless, these items have been properly managed per the requirements of 22 <br />CCR 66262.34; manifest attached. Of the remaining four items noted in your <br />report; four aerosol cans, absorbent pads, aerosol cans, and gloves in a 5 -gallon <br />bucket, oily debris and pads in a 55 -gallon drum in the MOW area, and oily liquid <br />in the secondary containment in the MOW area, BNSF has previously made <br />hazardous waste determinations for each waste pursuant to 22 CCR 66262.11. <br />Each of these has been properly managed per the requirements of 22 CCR <br />66262.34; manifest attached. <br />2. # 122 — 22 CCR 66262.40 (a); Failure to keep signed copy of manifests from the <br />designated facility for 3 years. 22 CCR 66262.40 requires that the generator keep <br />a copy of the manifest signed by the destination facility for three years; it does not <br />require the manifests to be kept at the facility (emphasis added). All manifests are <br />kept in our Division Office located in San Bernardino and online. A copy of <br />Manifest No. 008108566 JJK, signed by the TSD, is attached for your review. <br />