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James E. Diel <br />Manager, Environmental Field Operations <br />on <br />Union Pacific Railroad <br />Environmental Management Group <br />9451 Atkinson Street, Suite 100 • Roseville, California 95747 <br />December 4, 2003 <br />Dina Abate <br />Environmental Health Department <br />San Joaquin Co my <br />304 E. Weber A enue, 3rd Floor <br />Stockton, CA 5202-2708 <br />SUBJECT: Res <br />Uni <br />S -to <br />833 <br />Dear Ms. Abate <br />>nse to Notice of Violation <br />1 Pacific Railroad Com <br />:ton Yard <br />;asStreet <br />:ton, California <br />nD [ECE�VED <br />DEC 0 5 2003 <br />ENVIRONMENT HEALTH <br />PERMIT/SERVICES <br />(916) 789-5184 <br />Facsimile (916) 789-5185 <br />This letter is Union Pacific Railroad Company's (UPRR) response <br />to the Notice of Violation (NOV) issued 10/28/2003 by San Joaquin <br />County Environmental Health Department following an inspection of <br />our Stockton Yard on 10/27-28/2003. <br />Each specific item noted on the NOV will be discussed using the <br />item number from the NOV for clarity. <br />#10 Failed to determine if a waste is a hazardous waste <br />Used oil nd fuel filters were mixed in the roll off bin <br />near the emote locomotive maintenance. <br />Only usedoil a d diesel fuel filters are being accumulated in <br />the roll off bi UPRR has previously determined that the fuel <br />oil filters fro our operations are non -hazardous. Attachment #1 <br />is a copy of a eport from Laidlaw Environmental Services, dated <br />April 28, 1993, with the data. The used oil filters in the bin <br />are managed thr ugh the recycling exclusion found in CCR 22, <br />section 66266.1 0. We are not aware of any restrictions to <br />putting other, ompatible, non -hazardous wastes in the same <br />container for m nagement in the same fashion. <br />