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Page 2 of 3 <br /> Voice: (209) 953-7699 <br /> From: Steven Chaney [mai Ito:steven.chaney fedex.com] <br /> Sent: Wednesday, February 12, 2014 2:11 PM <br /> To: Elena K. Manzo [EH] <br /> Subject: FW: 3097419102 <br /> On 2/10/2014, Fedex Freight was notified that trailer EMHU296778 was placed in the Union Pacific <br /> Lathrop rail yard hazmat pit due to an unknown product discovered dripping from the trailer. Union <br /> Pacific dispatched NRC Environmental to provide remediation. NRC Environmental recovered 7 <br /> damaged 5 gallon pails of UN1263 paint and overpacked them into 2—55 gallon recovery drums. They <br /> used absorbent to clean up as much of the spilled product as possible and created 3—55 gallon drums <br /> of absorbent containing paint. They washed the trailer and captured the water into 2—55 gallon <br /> drums. <br /> On 2/12/2014, Fedex Freight obtained disposition from the shipper and owner of the product. Lanning <br /> Chemical Co would like the 7 damaged pails of paint returned to them in order to put the remaining <br /> contents back into their process to make more paint. The authorization is below. Fedex will request <br /> NRC Environmental properly label and transport the material to our Stockton facility on a BOL to return <br /> to Lanning Chemical Co as UN1263, Paint, 3, II. <br /> In regards to the 3 drums of absorbent containing paint. These drums contain aprox 95-99%absorbent <br /> and 1-5% paint. These drums will be marked as absorbent containing paint. <br /> Using generator knowledge, these drums do not exhibit a characteristic. <br /> M listed waste? No <br /> Appendix X waste? No <br /> California Hazardous waste? No <br /> In regards to the 2 drums of rinse water that contains traces of paint. These drums contain 1-5%paint <br /> max. Per the MSQS the specific gravity of this particular paint is 1.37, so the paint residue in the water <br /> would sink to the bottom, meaning that this product will not flash. These drums will be marked at rinse <br /> water containing traces of paint. <br /> Using generator knowledge, these drums do not exhibit a characteristic. <br /> M listed waste? No <br /> Appendix X waste? No <br /> California Hazardous waste? No <br /> This is how we are going to classify these products. I am still looking through the regs to see if there is <br /> anything that would prevent the drums of absorbent and rinse water from moving on a BOL to our <br /> closest facility to be held for disposal. This is not something that I have come across before as an issue. <br /> if you have a regulatory reference to assist me that would be greatly appreciated. In the meantime, we <br /> will have NRC Environmental label the non haz drums at the UP railyard to ensure we meet our 10 day <br /> labeling deadline required by the state. <br /> Thank you, <br /> Steven Chaney <br /> FedEx Freight Inc. <br /> Emergency Response Specialist <br /> Southwest Region <br /> 2/18/2014 <br />