SITE INFORMATION AND CORRESPONDENCE

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April 28, 1997 File: Environmental Protection Stockton, California CERTIFIED MAIL/RETURN RECEIPT REQUESTED San Joaquin County Public Health Services Environmental Health Division 304 East Weber Avenue -- 3rd Floor Stockton, California 95202 Re : Hazardous Waste Program Fees/Account No . 0004555 Dear Sir or Madam: We are in receipt of Invoice Nos . 32723 and 32973, totaling $47, 236 . 90, from the San Joaquin County Public Health Services, Environmental Health Division. Enclosed is a check for $42 . 90 for the outstanding balance owed on invoice #32723 . Invoice #32973, totaling $47, 194 . 00, is an assessment for a hazardous waste generator permit based on the alleged tons of hazardous waste generated at the Union Pacific Railroad (UPRR) site located at 833 East Eighth Street, Stockton, California. UPRR does not generate significant quantities of hazardous waste (if any) at this location and, therefore, the fee should be reduced to the appropriate amount for generators of 5, but less than 25 tons/year of hazardous waste . It is our understanding that the County calculates the hazardous waste generator fees based on the quantity of "hazardous waste" generated during the prior year and that the rate is based on the generator fees established annually by the State Board of Equalization (SBE) . UPRR has filed Petitions for Redetermination (or claims for refund, as appropriate) of hazardous waste generator and disposal fees alleged by the SBE to be owed for tax years 1992 through 1995 and also intends to appeal any 1996 fees assessed by the SBE . Among other reasons for the claims, UPRR believes that a large portion of waste generated at its locations, including Stockton, was not and is not "hazardous waste" and, therefore, is not subject to generator or disposal fees . UPRR currently is addressing this issue with the SBE and Department of