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Betty Ho [EH] Q F=a C: 18 "1= W"", <br /> ww :, <br /> 119 <br /> From: Cameron J. McGovern <cjmcgove@up.com> <br /> Sent: Tuesday, March 13, 2018 10:14 AM MA.R 13 2018 <br /> To: Betty Ho [EH] <br /> Subject: RE: UPRR Stockton - RTC - C00044642 - WR12473ENVIRONMENTAL HEALTH <br /> DEPARTMENT <br /> Betty, <br /> The timeline associated with thi cleanup is listed below. GHD and UPRR are attending a Tittle 22 CA Waste training on <br /> April 24th/25th to further mitigat potential lapses in the profile review phase of the waste management process. <br /> Additionally, with the help of G D, UPRR has began using a :hazardous Waste Criteria" spreadsheet tool, which <br /> automatically characterizes was es based on the analytical results (and clearly identifies Non-RCRA Hazardous wastes <br /> for Corrosive Solids). With thes modifications to our waste management program, UPRR is taking no chances in allowing <br /> a similar incident like this to occur again. <br /> • 9/29/17 -A white powder was discovered by UPRR near their Stockton, CA yard. It was unknown what it was <br /> but based on initial observations believed to be lime/sodium bicarbonate. ePro 1 responded to UPRR and <br /> sampled the material an excavated it into a bin. <br /> • 10/5/17—ePro 1 sampl d the material <br /> • 10/6/17—Sample was r ceived by lab <br /> • 10/20/17— Initial results showed potential hazard for CA-lead and STLC was requested. <br /> • 10/30/17—ePro 1 recei ed final analytical <br /> • 10/31/17—Analytical w+ reviewed by ePro 2 <br /> • 10/31/17—ePro 2 prepa ed profile and submitted for Peer Review. Peer review completed same day. <br /> • 10/31/17—ePro 2 submitted profile to the UPRR Environmental rep for approval, and was approved. <br /> • 10/31/17—The profile w s submitted to the landfill with the analytical (profile showed pH clearly) and it was <br /> approved for receipt. <br /> • ****All constituents in A alytical showed Non-Hazardous except for pH of 12.6. The material is a Solid—which <br /> typically would mean it ould not be regulated under RCRA, however California regulations DO include solids for <br /> the characteristic of Cor sivity. **** <br /> • 11/13/17— Landfill appr ved profile and waste was shipped/received. <br /> • 11/29/17— Final shipme t document was received from Landfill <br /> • 12/21/17 —San Joaquin ounty Environmental Health Department issued Small Quantity Hazardous Waste <br /> Generator Compliance Feview Report. UPRR/GHD began investigating incident and performed corrective action <br /> review. <br /> • 1/17/18—GHD confirms with Forward Landfill that the material cannot be identified after disposal - landfill doesn't <br /> manage waste using gric disposal, The Forward Landfill representative's name was not noted. <br /> • 1/19/18 — UPRR issues Return to Compliance letter after investigating whether or not Forward Landfill could <br /> recover the identified material. Letter documents both company's intended corrective actions to prevent an <br /> incident like this from oc(;urring in the future. <br /> Please let me know if you have a iy questions or comments. <br /> Thank you, <br /> Cameron J.McGovern I Environmental Fi Id Operations <br /> Union Pacific Railroad 11408 Middle Harbor Rd.I Oakland,CA 94607 USA <br /> W:510.268.30281): 510.406.5350 18: 2.997.3845 I®: cimcaove(cpup.com <br /> 1 <br />