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Muniappa Naidu [EH <br />From: JEE IEL@up.com <br />Sent: Thursday, March 01, 2007 4:17 PM <br />To: Mur iappa Naidu [EH] <br />Cc: LJ AMARI@up.com; JHSILVA@up.com <br />Subject: Clarification of 8/11/2006 Correspondence - Stockton, CA <br />Mr. Naidu: <br />Per our discussion of a few minutes ago, this correspondence is intended to <br />clarify Union Pacific Railroad Company's response to item #12 of our <br />8/11/2006 response to yo r inspection report of 6/27/2006. <br />I believe you asked for larification on three points: <br />1. How were the waste m terials generated from the cleanup properly <br />disposed? <br />Petroleum contaminated g ave and soil were characterized as non -hazardous <br />using generator knowledg . This generator knowledge is based on previous <br />testing of soil, gravel nd sand contaminated with the same petroleum <br />products. This waste w s disposed along with other petroleum contaminated <br />sand and soils from rout'ne facility clean-up activities at Forward <br />Landfill. <br />Oily water generated fro pressure washing the stained pavement was also <br />characterized as non-haz rdous by generator knowledge, collected and <br />processed through our on site industrial wastewater pretreatment plant, <br />which is permitted with he City of Stockton. <br />2. Provide some informa ion about the industrial pretreatment system: <br />Union Pacific owns and o erates an industrial wastewater pretreatment <br />system at Stockton Yard hat is permitted for discharge to the City of <br />Stockton POTW. This sy tem involves primary (gravity separation) and <br />secondary (coagulation a d flocculation) treatment to ensure that the <br />non -hazardous wastewater influent meets the discharge parameters required <br />by our permit for discharge. <br />Used oil is skimmed from the wastewater and sent off site, to <br />Demmeno/Kerdoon in Compt n, CA, for recycling. Settleable solids and <br />sludges are characterizec and properly disposed. <br />3. Explain why the toteE of petroleum that had been previously stored <br />outside were moved insidE the shop: <br />The products in these toes are valuable and are managed to avoid any <br />spills or drips. By mo ing the totes inside the shop, which drains to our <br />industrial sewer and pre reatment plant, we are simply adding a level of <br />protection to ensure tha the products are not released to the environment. <br />Safety is MY choice! <br />James E. Diel <br />MEFO - Union Pacific Railroad Company <br />phone 916.789.5184 fax 402.501.2396 <br />This message and any attachments contain information from Union Pacific which may be <br />confidential and/or privileged. <br />If you are not the intended recipient, be aware that any disclosure, copying, distribution <br />or use of the contents of this message is strictly prohibited by law. If you receive this <br />1 <br />