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1 <br /> OWN <br /> November 18, 2020 Reference No. 11183843 <br /> Ms. Laura C. Pollack <br /> Sr. Manager, Environmental Programs <br /> Union Pacific Railroad <br /> 1400 Douglas Street(STOP 1030) <br /> Omaha, NE 68179 <br /> Dear Laura: <br /> Re: Railroad Ties Statistical Analysis for Non-hazardous Determination <br /> Union Pacific Railroad <br /> 1. Introduction <br /> GHD has performed a statistical data analysis on historical wooden rail tie waste characterization results <br /> provided by Union Pacific Railroad (UPRR) representing various locations that have generated such <br /> waste in California. The intent of this data analysis is to establish process knowledge as the basis for <br /> waste characterization of wood rail ties. The analysis demonstrates the stability of this commonly <br /> generated waste stream considering that there is a consistent supply chain for rail ties across UPRR's <br /> network. The statistical data analysis has been conducted consistent with regulatory requirements in <br /> testing for hazardous waste under the United States Environmental Protection Agency(USEPA) method <br /> SW-846. <br /> 2. Scope of Historic Data <br /> UPRR provided GHD with analytical data from 567 Laboratory reports for waste samples including <br /> wooden rail ties collected between 2011 and 2019. After extracting maintenance program activity rail tie <br /> samples from other waste streams (e.g., bridge components, spills, etc.), the data represent over 2000 <br /> individual samples collected from hundreds of different locations throughout California over the past nine <br /> years. This large number of analytical data provides a robust data set for assessing UPRR's waste <br /> generated from removal of wooden rail ties during ongoing maintenance and repair work (maintenance <br /> program ties). The adequacy of the data set is supported by the statistical analysis results presented <br /> below. <br /> In the classification of wooden rail tie wastes in California, the following outcomes are possible: <br /> 1) Resource Conservation and Recovery Act (RCRA) Hazardous— Materials with leachable <br /> concentrations of target analytes that exceed Toxicity Characteristic Leaching Procedure (TCLP) <br /> limits. <br /> 2) California Hazardous— Materials meeting the TCLP limits, but having analyte concentrations <br /> exceeding California Total Threshold Limit Concentration (TTLC) limits (in solid samples), California <br /> GHD ISD 9001 <br /> 6520 Corporate Drive Indianapolis Indiana 46278 USA ExsFh FERiiI{.o[s iGe <br /> T 317 291 7007 F 317 328 2666 W www.ghd.com <br />