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Ms. Stacy Rivera <br />San Joaquin Coui <br />Environmental H <br />October 27, 2016 <br />Page 2 <br />relevant to railroad <br />subject to federal si <br />authorized federal, <br />information. Accor <br />Communications C <br />individuals who co <br />verified, a direct cc <br />Department <br />ations, including emergency response efforts and capabilities, may be <br />ve security information (SSI) regulations under 49 C.F.R. Part 15. Only <br />and local emergency response officials are authorized to receive such <br />y, the Railroad utilizes a centralized "Response Management <br />" to initiate emergency notifications and to verify the identities of <br />the Railroad for follow-up information. Once identities have been <br />Lion can be made to the on -duty emergency coordinator. <br />3. Maintenancc of decontamination a ui ment. The tag on the eyewash stated <br />inspections s iould be conducted weekly. The corrective action statement submitted <br />states "the e3 ewash station will be tested on a monthly basis going forward." <br />Consistent with UP 's February 11, 2016 response, Stockton Yard staff changed the inspection <br />frequency of the eyeN lash station to monthly, rather than weekly, and revised the tag on the <br />eyewash to show moi Lthly inspections. Monthly inspections of the eyewash station have been <br />conducted since Febr iary 2016 in compliance with 22 CCR 6626.34(d)(2) and the authorities <br />referenced therein. U IRR's monthly eyewash station inspection protocol is also consistent with <br />applicable CalOSHAregulations, which require eyewash equipment to be inspected and <br />activated monthly to ush the line and verify proper operation. 8 CCR 5162(e). <br />4. Com <br />the SPCC Plan. The PE <br />certificationconditional, stating "certain corrective action plan items have been <br />s <br />recommends for this facility in Section 2.0." <br />With respect to this a <br />"The SPCC plan certi <br />damaged tank gauges <br />SPCC Plan Version 2 <br />February 9, 2016, wit <br />and the certification f <br />SPCC Plan Version 3 <br />2016 letter alleges the <br />continues to be condi- <br />action <br />ondiaction plan items hav, <br />SPCC regulations all <br />the PE to certify the <br />not yet fully operatio <br />provide a six month 1 <br />40 CFR 112.7 states: <br />equipment not yet fu. <br />separately the details <br />leged violation (Item #201), the January 11, 2016 inspection report stated: <br />:kation was dependent on completion of amendments, including replacing <br />and installing secondary containment." In response, the Stockton Yard <br />0 was amended and recertified by Professional Engineer Gary Diewald on <br />1 no corrective actions listed in Table 2.1 of the SPCC Plan Version 3.0, <br />rge was included with UPRR's February 11, 2016 submittal. Table 2.1 of <br />0 is attached for your convenient reference. (Exh. C). Your September 28, <br />t the PE certification of the Stockton Yard SPCC Plan Version 3.0 <br />ional and incomplete because it includes the statement "certain corrective <br />been recommended for this facility in Section 2.0." <br />for the owner or operator of a facility to complete an SPCC plan, and for <br />X plan, with "additional facilities or procedures, methods, or equipment <br />" 40 CFR 112.7. Consistent with this allowance, the regulations also <br />iod to implement any technical changes made in an SPCC amendment. <br />P the Plan calls for additional facilities or procedures, methods, or <br />operational, discuss these items in separate paragraphs and explain <br />installation and operational startup." 40 CFR 112.5(a) further states: "An <br />3038213.0 <br />