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Ms. Stacy Rivera San Joaquin County Environmental Heal h Department October 27, 2016 Page 3 amendment made u der this section must be prepared within six months, and implemented as soon as possible, bu not later than six months following preparation of the amendment." (emphasis added). Because there are no outstanding corrective action items at the facility, UPRR has amended the SPCC plan to me ud a new certification by Gary Diewald, dated October 28, 2016, with all elements required by 40 CFR 112.3(d)(1)(i)-(v) and without the statement "certain corrective action plan items ha e been recommended for this facility in Section 2.0." The October 28, 2016 certification for the tockton Yard SPCC Plan Version 4.0, and Table 2.1 showing no corrective action items, are atta hed for your reference. (Exh. D). 5. Secondary c ntainment for mobile refuelers. The SPCC Plan states, "one of the DTL trucks s parked full and unattended in the northeast corner of the parking lot southeast of he Locomotive Shop. This location does not provide adequate passive general seco dary containment for the largest compartment of the truck." Mobile refuelers par ed on site and left unattended do not meet the definition of The February 2016 S] language quoted aboN letter. Relevant page; attached for your refe trucks transport oil to trucks are not used ex definition of "transpo II(2)(D) and are there 112, Appendix A, Sec facilities means:... 0 oil in interstate and in and equipment used f they operate. Exclude exclusively within the which are not intende Of the two DTL truck? a polymer berm until i is located directly in fi attended. Therefore, d. management practice, 7,405 gallons. CC plan for the Stockton Yard (version 3.0) was amended to remove the and further amended in response to the SJCEHD's September 28, 2016 of the October 2016 SPCC plan for the Stockton Yard (version 4.0) are ince. (Exh. E). Two "direct -to -locomotive" (DTL) mobile refuelers/tank carious UPRR yards, including the Stockton Yard. Because the DTL lusively within the confines of the Stockton Yard, they fall within the ration -related facility" set forth in 40 CFR 112, Appendix A, Section ire subject only to Department of Transportation jurisdiction. 40 CFR :ion II(2)(D) provides, "Transportation -related onshore and offshore ) Highway vehicles and railroad cars which are used for the transport of rastate commerce and the equipment and appurtenances related thereto, r the fueling of locomotive units, as well as the rights-of-way on which are highway vehicles and railroad cars and motive power used :onfines of a non -transportation related facility or terminal facility and !for use in interstate or intrastate commerce. " (emphasis added). one is filled with fuel offsite and, when present at the yard, staged full on is called upon to fuel a locomotive on or off-site. The containment berm int and in plain view of the DTL personnel office and is constantly full DTL truck is not subject to SPCC regulation. As a best he containment berm on which this DTL truck is located has a capacity of 3038213.v1