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ENVI ONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Donna K.Heron,R.E.H.S. Third Floor Carl Borgman,R.E.H.S. <br /> 304 East Weber Avenue, <br /> Direc gr Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen, .E.H.S. Stockton, California 95202-2708 <br /> Douglas W.Wilson,R.E.H.S. <br /> • C9<< R��P• Program anager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> FO <br /> Laurie A.Cotu la,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Manager Mark Barcellos,R.E.H.S. <br /> May 28,2002 <br /> Union Pacific Railroad <br /> Attn: Brok Nelson <br /> Director Environmental I ield Operations <br /> 10031 Foothills Blvd. <br /> Roseville,CA 95747 <br /> Subject: Hazardous'Waste Generator Permit Fees <br /> Re: 833 E.Eigbth St.,Stockton,California <br /> As requested during the meeting of April 25,2002,we have reviewed the Environmental Health Department(EHD) <br /> Hazardous Waste files fo the Union Pacific Railroad(UPRR)facility at 833 E.Eighth Street to identify the <br /> documentation used to determine the hazardous waste generator permit fees invoiced in 1996 and 1997.The fees <br /> billed in November of 19 96 were for the 1997 calendar year permit(January 1 —December 31S)and were based on <br /> the reported quantity of 1.azardous waste generated in 1995. Following a facility inspection by EHD staff in <br /> December of 1996,docu nentation was submitted(see enclosed correspondence of January 2, 1997)indicating that <br /> over 1,488 tons of hazar ous waste was generated in 1995. A revised invoice based on the new fee category, 1,000 <br /> to 2,000 tons,was sent ir January of 1997. Subsequent EHD hazardous waste generator permit fees have been based <br /> on this fee category. <br /> This fee category was su ported by additional documentation obtained by the EHD.During the facility inspection in <br /> December 1996,EHD staff requested that sludge from the on-site wastewater treatment plant be analyzed. The <br /> sample data provided by Union Pacific Railroad(UPRR)showed that this waste was a California hazardous waste <br /> due to its waste oil content alone.Additional documentation from UPRR indicated that the waste had failed a fish <br /> bioassay also classifying it as a California hazardous waste subject to shipment and disposal under a hazardous <br /> waste manifest. A review of the hazardous waste manifests submitted to the Department of Toxic Substance <br /> Control(DTSC)showed that the treatment plant waste was not included in the quantities reported to DTSC. <br /> Therefore,this facility is subject to the hazardous waste generator fees charged for 1997 and 1998. If operations at <br /> the facility have been ch nged or modified,documentation should be submitted to the EHD to support placement of <br /> this facility in a lower quantity fee category. <br /> If you have any further questions,please contact Doug Wilson,Supervising REHS at(209)468-3446. <br /> Donna Heron,Director <br /> Environmental Health Department <br /> Doug W' son,Supervisi g REHS <br /> Environmental Health D partment <br /> Enc: 1 <br /> DW/LC <br /> Union Pacific RR HW Fees <br />