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RECEIVED AUG G 2 12013 PAGE 2 ENVIRON�VIENTAL HEALTH DEPAR,,,ENT Item 107: "Failed to retain waste analysis on-site for three years..." This finding relates to metal fines from the operation of bench grinders in the drayage tractor maintenance shop. At the time of the inspection, the dust from the occasional metal grinding operations was periodically swept up and placed in the general trash from the shop. A detailed analysis of the grinding process and the resulting wastes was conducted by Union Pacific. Additionally, the Resource Conservation and Recovery Act (RCRA) and 62261.1(c)(9) et. Seq. CHSC were analyzed for relevance. The process flow chart diagram from that analysis is included with this letter. It is the position of the Union Pacific that metal fines produced from metal grinding operations using abrasive stones is exempted from regulation under both RCRA and CHSC as recycled scrap metal as long as it is handled as scrap metal and recycled with the regular scrap metal process. We likewise believe that the metal fines, when treated as scrap metal, are exempt from waste analysis as "Excluded Material" under the plain meaning of the applicable regulations. In accordance with this line of reasoning, the Union Pacific is instructing all it's employees and contractors conducting metal grinding operations similar in nature to the operations at the Lathrop Facility to henceforth dispose of metal fines generated in grinding operations in the scrap metal recycling bin at each facility. Items 404, 605 and 610: (relating to improper handling, storage and labeling of used oil and oil filters by the various contractors at the Lathrop facility. On the day of the inspection, an open topped 20 gallon drum containing what appeared to be used oil was located at the chassis straightening area on the eastern edge of the property. Sid's Mobile Repair was the probable generator of the waste, although the actual person responsible for placing the drum at that location remains unidentified. The drum of used oil was taken to the Drayage Tractor shop and it's contents were placed in the Used Oil collection system for proper disposal. The drum, once it was emptied of all liquid contents, was wiped dry, crushed and placed in the scrap metal recycling bin for appropriate disposal. Line mechanics and supervisors from RTS and TSI were instructed as to the correct handling and disposal of drained used oil filters, and the necessity to keep the used oil filter drums closed except for when drained filters were being added. Additional instruction was provided the day of the inspection to personnel from Sid's Mobile Repair, regarding their responsibilities as UP contractors. Item 305: "Failed to maintain all communication/alarm systems, spill control or decontamination equipment..." This finding relates to a spill pallet for drums that had an accumulation of liquid in the spill pan. After the close of the inspection, the supervisor from RTS emptied the contents of the spill pan on the spill pallet into the used oil collection system for proper disposal. Emphasis on maintaining spill containment equipment free of liquids was part of the UP Standard Environmental Training presented to all contractors and the UP Premium Operations employees who supervise contractor operations at Lathrop in January.