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October 27,2016 <br /> Ms. Stacy Rivera <br /> San Joaquin County <br /> Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton, CA 95205-6232 <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 Railroad Company (UPRR) submits this response to your September 28,2016 letter <br /> regarding UPRR's return to compliance following the San Joaquin County Environmental Health <br /> Department(SJCEHD) 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 violations. <br /> Below are the five violations SJCEDH alleges to be ongoing, each followed by UPRR's further <br /> response. <br /> 1. Supporting documentation 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 were summarized but complete reports were not submitted. <br /> The January 12,2016 inspection report states with respect to this alleged violation(Item# 102): <br /> "Submit a statement and 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#102. 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 for your files. (Exh. A.) <br /> 2. Emergency coordinator information. The contingency plan shall list names, <br /> addresses,and phone numbers of all persons qualified to act as emergency <br /> coordinator.The plan lists an emergency call center,but does not identify any <br /> persons. At all times,there shall be at least one employee either on the facility <br /> premises or on call(i.e.,available to reach the facility within a short period of time) <br /> with the responsibility for coordinating all emergency response measures. <br /> In response to SJCEHD's September 28, 2016 letter, UPRR has amended the Stockton Yard <br /> contingency plan to list the names, addresses, and telephone numbers of all persons qualified to <br /> act as emergency coordinator pursuant to 22 CCR 66265.55. The relevant pages of the revised <br /> contingency plan are attached for your convenient reference. (Exh. B.) Please note, information <br /> 3038213.0 <br />