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From: Brittani Jacobsen <br /> To: Garcia-Meiia.Gabriela rEHDI <br /> Subject: RE:833 8th St.HW Inspection Report <br /> Date: Tuesday,June 21,2022 9:36:00 AM <br /> Attachments: imaae001.pna <br /> imaae002.pnna <br /> 392832-1 UDS Level 2 Report Final Reoort.r)df <br /> J243510-1 UDS Level 2 Report Final Report.pdf <br /> 1243062-1 UDS Level 2 Report Final Reoort.odf <br /> FINAL Wood Railroad Ties Statistical Analysis Report by GHD.pdf <br /> Importance: High <br /> Hi Gabriela, <br /> Please see requests for clarification below regarding hazardous waste inspection report: <br /> • Finding 103:The business operator does not have hazardous waste determination records <br /> that support the current handling and disposal of the following waste: a. Loads of industrial <br /> wastewater being shipped as non-hazardous waste to the Union Pacific, Roseville water <br /> treatment plant from the 312,000-gallon tank,TNKS-9101. <br /> o Water samples were collected and analyzed in compliance with the City of Stockton <br /> Industrial Wastewater operating permit when the treatment plant was active. Using <br /> these analytical results as process/Generator knowledge, the Stockton wastewater was <br /> determined to be non-hazardous. I have attached the last laboratory results for the <br /> wastewater. Please advise if the County agrees with the waste determination. <br /> • Finding 110: 1 sent the manifests to you on 6/9/2022. Please advise if you did not receive. <br /> • Finding 117:This business did not provide a written response to the inspection report dated <br /> 1/12/2016 within 30 days. The report was delivered to the business on 1/12/2016 and return <br /> to compliance was received 10/28/2016. <br /> o The referenced inspection report is more than 6 years old. It would be impossible at <br /> this time to recreate an accurate, detailed response and "corrective action statement" <br /> to that report at this point. What's more, your file reflects that the matters addressed <br /> in that inspection report were returned to compliance, based on a document received <br /> on October 28, 2016, consequently, we are perplexed by the request. Moreover, any <br /> violations associated with this inspection report or the failure to submit a "corrective <br /> action statement" were resolved in the December 19, 2018, Final Judgment entered in <br /> Placer Co. Superior Court, case number SCV0042203. <br /> • Finding 3030: Several accumulations of unlabeled and uncontained treated wood waste were <br /> not labeled as required by this section: <br /> 1. Two piles of railroad ties north of the locomotive shop. <br /> 2. One pile of railroad ties south of the locomotive shop. <br /> o Union Pacific has performed extensive testing of its rail ties and characterizes them as <br /> non-hazardous by virtue of knowledge of process. A copy of the report detailing the <br /> basis for that characterization is enclosed for your review. Wood waste only constitutes <br /> "treated wood waste" if it is a California hazardous waste, due to its chemical <br /> treatment constituents. <br /> Please advise of any revised findings so I may adequately address. <br /> Thank you, <br />