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Ms. Stacy Rivera <br /> San Joaquin County <br /> Environmental Health Department <br /> October 27, 2016 <br /> Page 2 <br /> relevant to railroad operations, including emergency response efforts and capabilities, may be <br /> subject to federal sensitive security information (SSI)regulations under 49 C.F.R. Part 15. Only <br /> authorized federal, state and local emergency response officials are authorized to receive such <br /> information. Accordingly,the Railroad utilizes a centralized"Response Management <br /> Communications Center"to initiate emergency notifications and to verify the identities of <br /> individuals who contact the Railroad for follow-up information. Once identities have been <br /> verified, a direct connection can be made to the on-duty emergency coordinator. <br /> 3. Maintenance of decontamination equipment. The tag on the eyewash stated <br /> inspections should be conducted weekly.The corrective action statement submitted <br /> states "the eyewash station will be tested on a monthly basis going forward." <br /> Consistent with UPRR's February 11,2016 response, Stockton Yard staff changed the inspection <br /> frequency of the eyewash station to monthly,rather than weekly, and revised the tag on the <br /> eyewash to show monthly inspections.Monthly inspections of the eyewash station have been <br /> conducted since February 2016 in compliance with 22 CCR 6626.34(d)(2) and the authorities <br /> referenced therein. UPRR's monthly eyewash station inspection protocol is also consistent with <br /> applicable CalOSHA regulations, which require eyewash equipment to be inspected and <br /> activated monthly to flush the line and verify proper operation. 8 CCR 5162(e). <br /> 4. Complete Professional Engineer(PE) Certification for the SPCC Plan. The PE <br /> certification is conditional,stating "certain corrective action plan items have been <br /> recommended for this facility in Section 2.0." <br /> With respect to this alleged violation (Item#201),the January 11, 2016 inspection report stated: <br /> "The SPCC plan certification was dependent on completion of amendments, including replacing <br /> damaged tank gauges and installing secondary containment." In response,the Stockton Yard <br /> SPCC Plan Version 2.0 was amended and recertified by Professional Engineer Gary Diewald on <br /> February 9, 2016,with no corrective actions listed in Table 2.1 of the SPCC Plan Version 3.0, <br /> and the certification page was included with UPRR's February 11, 2016 submittal. Table 2.1 of <br /> SPCC Plan Version 3.0 is attached for your convenient reference. (Exh. Q. Your September 28, <br /> 2016 letter alleges that the PE certification of the Stockton Yard SPCC Plan Version 3.0 <br /> continues to be conditional and incomplete because it includes the statement"certain corrective <br /> action plan items have been recommended for this facility in Section 2.0." <br /> SPCC regulations allow for the owner or operator of a facility to complete an SPCC plan, and for <br /> the PE to certify the SPCC plan, with"additional facilities or procedures, methods, or equipment <br /> not yet fully operational." 40 CFR 112.7. Consistent with this allowance,the regulations also <br /> provide a six month period to implement any technical changes made in an SPCC amendment. <br /> 40 CFR 112.7 states: "If the Plan calls for additional facilities or procedures, methods, or <br /> equipment not yet fully operational, discuss these items in separate paragraphs and explain <br /> separately the details of installation and operational startup."40 CFR 112.5(a) further states: "An <br /> 3038213.v1 <br />