Laserfiche WebLink
LADONNAIRAMILL0 <br />4.tiOn Nam <br />Manager Environmental Operations <br />y;SantaFe <br />Michael Kith <br />San Joaquin County <br />Public Health Services <br />304 E. Weber Ave., 3rd Floor <br />Stockton, CA 95201-0388 <br />Dear Mr. Kith: <br />The Burlington Northern Santa Fe Railway Company <br />740 East Carnegie Drive <br />San Bernardino, CA 92408-3571 <br />(909) 386-4082 <br />December 11, 1997 <br />File: 01001836 <br />This letter responds to your inspection report dated November 12, <br />California. BNSF has addressed the noted items as follows: <br />mq� <br />Item 20. 66262.34 (CCR) Failed to properly label containers of hazardous waste. During my visit to <br />Stockton on November 13, I provided labels for the drums at the Mormon Section yard. <br />Item 49. 66265.16 (CCR) Personnel training records incomplete. Attached are the job descriptions <br />for the positions at BNSF's Stockton Railyard that require training under the referenced section. I have <br />also attached a copy of the 1997 training record. Most of the employees on the sign -in sheet do not <br />report to the Stockton yard but were at the same training session. All employees at the session receive <br />combined RCRA/Environmental Awareness training covering the topics on the attached outline. The <br />highlighted persons require training pursuant to section 66265.16 and received additional contingency <br />plan training. <br />Item 75. Labeling and warning signs for hazardous waste storage areas. Two hazardous waste <br />storage areas at the Section yard were labeled on November 13. The drums at the northeast corner of the <br />yard were moved into the waste storage building. The orange containment will be picked up during our <br />milkrun waste pickup in January so that this area will no longer be used to accumulate waste. <br />Also attached is analytical of locomotive crankcase oil. I have tested such oil on numerous occasions and <br />have never had the oil exceed statutory limits for toxic characteristics. Therefore, BNSF has applied <br />"knowledge of the hazard characteristics of the waste in light of the materials or processes used," <br />66262.11(c)(2) (CCR), and classified our oily rags and used oil filters as non -hazardous, recyclable <br />waste. Also, BNSF's used oil filters are managed and recycled in accordance with section <br />66266.130(a)(2) (CCR); thus, they are exempted as non -hazardous. <br />If you have any questions concerning this matter, please do not hesitate to call. <br />Sincerely, <br />LaDonna DiCamillo <br />Manager Environmental Operations <br />cc: Mike Harris - Fresno <br />Dave Irwin - Stockton <br />Rudy Sanchez - Stockton <br />