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ATTACHMENT A INVESTIGATIVE REPORT ERIC TREVENA, SENIOR R.E.H.S. SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION 304 E. WEBER AVE. THIRD FLOOR STOCKTON CA 95201 (209) 468-0333 On June 7, 1997, PHS-EHD, received an application Submitted by Terranext, for Don Dobbas Inc. to remove an underground storage tank located at 2 N. Sacramento Street in Lodi. The U.S.T. contained waste oil. The application was approved and a permit was issued to remove the U.S.T. on June 10, 1997. The owner/operator, of the U.S.T. identified on the permit was Union Pacific Railroad. The approved permit identified Evergreen Oil as the transporting hazardous waste hauler for the tank residual. The U.S.T. was removed under PHS-EHD inspection on June X1997. 1j On August 13, 1997, PHS-EHD received a U.S.T. closure report submitted by ERM- West, Inc. (previously known as Terranext) on behalf of Union Pacific Railroad Company, for the used oil U.S.T., removed on June 13, 1997. The closure report included an incomplete copy of a California Uniform Hazardous Waste Manifest, #95118111. The manifest was signed by John Cavanaugh (Terranext) as the Generator of the waste. The quantity and description of the waste on the manifest was 180 gallons of "Non-RCRA Haz-Waste Oil #221." On August 14, 1997, 1 contacted Jacque Shoenecker at the San Joaquin Regional Rail Commission in an attempt to acquire the completed manifest #95118111. On September 2, 1997, PHS-EHD, received a letter from Jim Dobbas Inc. regarding the final disposition of the 180 gallons of waste oil removed from the U.S.T. at 2. N. Sacramento Street. Jim Dobbas Inc. is listed as a registered hazardous waste transporter, #2313, by the Department of Toxic Substances Control, Surveillance And Enforcement Branch. The letter was written by Robert Chandler, the on-site foreman representing Dobbas. Chandler explained approximately 180 gallons of waste oil was vacuumed out of the U.S.T., and "after loading and completing the required manifests, a problem arose with the trailer that curtailed transport to the Bay Area." Chandler wrote how the trailer was taken to the Newcastle shop for repairs, and approximately four weeks later, the trailer was taken to the Roseville Yard to secure an oil/water mix. The mix was consolidated with the waste oil that was previously loaded in Lodi, and then taken to, and disposed of at the Union Pacific Waste Water Treatment Plant in Roseville. Chandler further explained the Hazardous Waste Manifest # 95118111 designating Evergreen Oil, Inc. as the disposal facility, was never signed nor completed.