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October 27, 2016 <br />Ms. Stacy Rivera <br />San Joaquin County <br />Environmental Healt i Department <br />1868 East Hazelton i venue <br />Stockton, CA 95205 232 <br />Subject: Reply to San Joaquin County Environmental Health Department September <br />28, 2016 Letter regarding UPPR Stockton Yard, 833 East 8th Street, Stockton, <br />California 95206 <br />Dear Ms. Rivera, <br />Union Pacific Railroa I Company (UPRR) submits this response to your September 28, 2016 letter <br />regarding UPRR's rel am to compliance following the San Joaquin County Environmental Health <br />Department (SJCE ) inspection of the UPRR Stockton Yard on January 12, 2016. SJCEHD <br />alleges that the return to compliance documentation submitted by UPRR on February 11, 2016 is <br />incomplete for five vi lations. <br />Below are the five violations SJCEDH alleges to be ongoing, each followed by UPRR's further <br />response. <br />1. Sunnortina d6cumentation for the hazardous waste determinations for Tremco <br />Vulkem 801, Oily solids and debris and oily liquid. Copies of the hazardous waste lab <br />analyses wer summarized but complete reports were not submitted. <br />The January 12, 2016 nspection report states with respect to this alleged violation (Item # 102): <br />"Submit a statement ai id supporting documentation explaining how these wastes [were] managed." <br />On February 11, 2016 UPRR submitted waste determination documentation for all items <br />referenced in Item #1 C 2. In addition, in response to Deputy District Attorney Jane Crue's request, <br />UPRR provided her with the analytical report on August 30, 2016. A copy of those analytical <br />reports are enclosed 4 your files. (Exh. A.) <br />2. <br />addresses, an <br />coordinator.' <br />persons. At a <br />premises or o <br />with the resp <br />In response to SJCE <br />contingency plan to <br />act as emergency co <br />contingency plan are <br />â–ºrdinator information. The contingency plan shall list names, <br />phone numbers of all persons qualified to act as emergency <br />he plan lists an emergency call center, but does not identify any <br />times, there shall be at least one employee either on the facility <br />call (i.e., available to reach the facility within a short period of time) <br />isibility for coordinating all emergency response measures. <br />I's September 28, 2016 letter, UPRR has amended the Stockton Yard <br />the names, addresses, and telephone numbers of all persons qualified to <br />inator pursuant to 22 CCR 66265.55. The relevant pages of the revised <br />ached for your convenient reference. (Exh. B.) Please note, information <br />3038213.x1 <br />