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The following is an itemized list of hazardous waste violations that have not been <br /> addressed for UNION PACIFIC RAILROAD - Stockton as of September 28, 2016. <br /> Open violations from January 12, 2016 inspection <br /> Violation #102— Failed to determine if a waste is a hazardous waste or retain waste analysis on <br /> site for 3 years. <br /> -Tremco Vulkem 801 gray rail car sealant is being disposed of in the garbage when dry and solid. The <br /> safety data sheet for this chemical indicated a petroleum content, but did not indicate whether it is <br /> hazardous waste when solid. <br /> -Oily solids and debris are placed in a roll-off bin and labeled as non-hazardous waste. The waste <br /> streams placed in this bin vary daily, including absorbent pads, contaminated soil, spill clean up wastes, <br /> and "empty" oil containers. This waste is disposed of as non-hazardous solids without making specific <br /> hazardous waste determinations for each disposal. <br /> -The oily solids and debris bin was observed containing an oily liquid. The inspection contacts noted <br /> cracks and holes in the bin lid which would allow rainwater to enter. No hazardous waste determination <br /> has been made for this liquid waste. <br /> Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop <br /> disposal of rail car sealant in the garbage and oily solids as non-hazardous waste, make a hazardous <br /> waste determination for the rail car roof sealant, the oily solids, and the liquid in the oily solids bin, and <br /> manage them according to the Title 22 hazardous waste regulations. Submit a statement and supporting <br /> documentation explaining how these wastes was managed. <br /> Violation #104— No emergency coordinator. <br /> An emergency coordinator is lacking. The contingency plan lists the emergency coordinators as RMCC, <br /> the emergency contact number, but does not list individual people who meet the requirements of an <br /> emergency coordinator. There must be at least one emergency coordinator on site or on call to <br /> coordinate emergency response measures, and the following information must be posted by a phone: the <br /> name and phone number of the emergency coordinator; location of fire extinguishers, spill control <br /> equipment, and if present, fire alarm; and the phone number of the fire department, unless the facility has <br /> a direct alarm. Immediately appoint an emergency coordinator and post the required information by a <br /> phone. A form is provided that can be used for this purpose. <br /> Violation #303 - Failed to maintain all communication or alarm systems, spill control, or <br /> decontamination equipment. <br /> -The fire extinguishers in the locomotive shop were observed with an annual maintenance date of <br /> 12/6/12. <br /> -The eyewash station in the locomotive shop was observed with an expiration date of 3/2015. <br /> -The eyewash near the locomotive shop was last inspected on 10/7/15. The tag on the eyewash stated <br /> inspections should be conducted weekly. <br /> All facility communications or alarm systems, fire protection equipment, spill control equipment, and <br /> decontamination equipment, where required, shall be tested and maintained as necessary to assure its <br /> proper operation in time of emergency. Immediately begin this practice. <br /> Page 3 of 5 <br />