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Mr. Muniappa N <br />August 11, 200 <br />Page Two <br />#10 Failed tol <br />Based on your <br />question are o <br />not able to pr <br />idu <br />determine if a waste is a hazardous waste <br />_nspection report, it appears that the materials in <br />_ly sand and debris. Our facility personnel were <br />)vide a waste determination. <br />Due to the nat re of our business, the number of facilities we <br />operate and th uniformity of the products we use and the wastes <br />we produce, waste determinations and waste management decisions <br />are not typically made by operating facility personnel. By UPRR <br />policy, our fa ilities are responsible for managing waste as <br />directed by mo e qualified support staff. <br />In the case of these oily wastes at Stockton, attached is an <br />analytical rep rt from samples collected March 7, 2005. This <br />data shows that our oily debris waste is non -hazardous. This <br />data is consistent with analytical testing of similar wastes from <br />other UPRR facilities in California. <br />#12 Facility �ot maintained to minimize the release of a <br />hazardous waste. <br />Several petrol um product stains were observed along the west <br />side of the Di sel Shop. <br />The stained gravel has been removed and replaced with fresh rock. <br />Stained areas on the pavement have been pressure washed to remove <br />as much residual petroleum as is possible. Waste materials from <br />both operations were properly disposed. <br />The oil totes that were the cause of most of these issues have <br />been moved inside the shop. They will be stored and filled in <br />this location where any spill or drips will be captured in the <br />industrial sewer system for treatment at our on-site industrial <br />wastewater treatment system. <br />#15 Spill co trol equipment, and/or decontamination equipment <br />" <br />not prow ded. <br />Items obstructing access to the eye wash station have been <br />removed. <br />