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"ECEIVE ® FEB 1 1 2016 ENVIRONMENTAL HEALTH DEPARTMENT locomotive, either onsite or at another facility. These mobile refuelers are not dedicated to this yard, and therefore the trucks fall under the jurisdiction of DOT requirements and not subject to SPCC regulation. See 1971 Memorandum of Understandinq(MOU) between DOT and EPA on Transportation-Related Facilities. The relevant portion of that document states: (2) Transportation-related onshore and offshore facilities means— (D) Highway vehicles and railroad cars which are used for the transport of oil in interstate and intrastate commerce and the equipment and appurtenances related thereto, and equipment used for the fueling of locomotive units, as well as the rights-of-way on which they operate. Excluded are highway vehicles and railroad cars and motive power used exclusively within the confines of a non-transportation related facility or terminal facility and which are not intended for use in interstate or intrastate commerce. Item#717: All liquid level sensing devices will be maintained and tested for proper operation on a periodic basis per manufacturer's recommendations.Union Pacific is currently working on a process to best track this effort. Item#720: This item, related to the two mobile refuelers, references the following citation: CFR 112.8(c) (11) Failed to provide sufficient secondary containment capacity for mobile or portable containers. Mobile refuelers are exempt from the requirements of portable containers such as drums and totes that are subject to sized secondary containment. Refer also to reply for Item#609 above. Small Quantity Hazardous Waste Generator Inspection Report Item#102: On January 21, 2016, Arcadis (a contractor for Union Pacific) collected samples of Vulkem 801 and the oily liquid within the oily solids and debris bin and performed waste determinations on each item (Attachment 4). The Vulkmen 801 (after use as a solid) is a non-hazardous waste and will be managed as such. The oily solids bin was removed the week of February 8, 2016. Prior to its removal, the bin was covered with a tarp to ensure liquids were not infiltrating the bin. The liquid in the bin was sampled on January 21, 2016 and has been determined to be a non-hazardous waste along with the material in the bin. The oily solids bin material was sampled by a Union Pacific employee on January 6, 2016 and a waste determination was performed by Arcadis (Attachment 5).