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Mr. Doug Wilson <br />Supervising R.E.H.S <br />Environmental Healt <br />San Joaquin County <br />445 N. San Joaquin <br />Stockton, CA 9520 <br />Dear Mr. Wilson: <br />March 16, 1995 <br />File: Environmental Protection <br />California, Stockton <br />VO <br />Division MAR 1 7 1995 <br />treet ENVIRONMENTAL HEALTH <br />PERMIT/SERVICES <br />In response to our conference call on Friday, March 3, 1995 and your letter dated <br />February 28, 1995, I�would like to take this opportunity to address issues involved in Violations <br />1, 3, and 5. <br />Violation #1 - 2252 .4 (HSC) Failed to submit a report to the Department at least every two <br />years. <br />In March of 1994 the California Department of Toxic Substances cancelled their requests <br />for submission of the 1993 Hazardous Waste Report. The U.S. EPA did not cancel submission <br />of this report; thus, in March of 1994 reports* were submitted to the U.S. EPA. The reports <br />submitted to the EPA contain Form GM's which will suffice as the report requested in this <br />violation. These 2 rc ports are currently on site and can be reviewed at the Stockton Facility. <br />Violation #3 - 25244.21(HSC) Failed to retain current (SB -14) review and plan. <br />Below is an utline of activities that have taken place at the Stockton Facility, as well as <br />enclosures* that will show commitment and direction Union Pacific Railroad is undergoing. <br />On October <br />minimization trainin <br />meeting. At this me <br />at this meeting was 1 <br />schedule for the nex <br />which represents all <br />On Novemb <br />minimization plan*, <br />progress with additi <br />achieve goals set foi <br />On Decembi <br />departments within <br />through the Quality <br />report. Ideas for re <br />1994 employees from the Stockton Facility met in Sacramento for waste <br />* and their first Waste Minimization Quality Improvement Team (QIT) <br />ting the team began to draw up process flow diagrams*. Also accomplished <br />ie election of a Team Leader, identification of Team Members and the <br />few meeting dates/agenda. Currently, the QIT consists of a 9 member team <br />lepartments within the Stockton Facility. <br />17, 1994 the team met to discuss the steps in developing a waste <br />iazardous waste report that would reflect changes in volume and toxicity, <br />nal flow charts, develop a problem statement and make assignments to <br />h in the draft plan and/or report. <br />15, 1994 the team met, discussed flow charts and toured several <br />ie Stockton Facility. The team began to look at processes and develop <br />mprovement Process ideas for facility plan and hazardous waste management <br />ycling/reuse were brought up and information was to be gathered for the <br />