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From: Cameron J. McGovern <cimcgove@up.com> Sent:Tuesday, March 3, 2020 11:16 AM To:Arora,Asha@DTSC<Asha.Arora@dtsc.ca.gov> Cc: Muniappa Naidu <mnaidu@sicehd.com>; Olivia.Deck@ghd.com <Olivia.Deck@ghd.com>; UPRR-WM <UPRR- WM@ghd.com> Subject: Re: URGENT ACTION REQUIRED: Stockton, CA-HazMat-WR23402- DTSC Storage Extension Ms. Arora, In response to your February 28, 2020 email, the DTSC currently classifies the generator status of Union Pacific Railroad's (UPRR) Stockton as a small quantity generator(SQG), exempting it from the 90-day generation to disposal time requirement applicable to a large quantity generator(LQG). UPRR requests this waste storage extension to make the most conservative determination of when UPRR could ship this material offsite to a final treatment, storage, and disposal facility (TSDF), based on receiving the final analytical and coordinating with our waste consultant and a waste transporter. To summarize this waste event: • 12/09/2019-This material was generated on 12/09/2019 and UPRR's Northern California Hazardous Materials Manager contacted Patriot Environmental Services to remediate and containerize the impacted media. • 12/11/2019 - UPRR's waste consultant, GHD, provided a sampling plan to the remediation consultant, Arcadis, who collected samples of the different waste streams generated during this event. • 12/17/2019-GHD received a soil analytical report from the lab, but, due to no fault of UPRR, some of sample containers were compromised during the transit/shipping. • 1/20/2020 - GHD requested that Patriot collect additional sample material for analysis. • 2/11/2020- Laboratory notified GHD, Arcadis, and Patriot of insufficient sample volume to complete required analyses. • 2/20/2020- Patriot collected additional sample of all waste streams. • 2/25/2020- GHD confirmed the lab received the results and requested a rush turn around of the samples. • 2/26/2020-GHD filed a proactive and protective storage extension on behalf of UPRR due to yet unknown hazardous waste determination. • 3/5/2020 - Sample results available. In response to your second bullet point, GHD mistakenly thought that a drum of diesel impacted solids/PPE was missing. However, the diesel impacted PPE/absorbents/solids were consolidated with a 20-cubic yard bin of diesel contaminated solids. On February 28, 2020, 1 corrected GHD's mistaken belief and updated our waste records to reflect that this extra drum was not generated, nor missing. Thank you for your concern regarding our waste management procedures. Cameron J.McGovern I Manager Environmental Field Operations Union Pacific Railroad 11408 Middle Harbor Rd. I Oakland,CA 94607 USA -:510.268.30281): 510.570.6630 I A:402.997.3845 117-1: cimcgove(apup.com From: "Arora,Asha@DTSC"<Asha.AroraQdtsc.ca.gov> To: "Cameron J. McGovern"<cimcgoveCc�up.com> Cc: "Olivia.Deck(aghd.com"<Olivia.Deck(aghd.com>, "UPRR-WM"<UPRR-WM(aghd.com>, "Muniappa Naidu" <mnaidu(osjcehd.com> Date: 02/28/2020 08:13 AM Subject: Re: URGENT ACTION REQUIRED: Stockton, CA-HazMat-WR23402-DTSC Storage Extension 2