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Ms. Stacy Rivera San Joaquin County Environmental Health Department October 27, 2016 Page 3 amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment." (emphasis added). Because there are no outstanding corrective action items at the facility, UPRR has amended the SPCC plan to include a new certification by Gary Diewald, dated October 28, 2016,with all elements required by 40 CFR I I2.3(d)(1)(i)-(v) and without the statement"certain corrective action plan items have been recommended for this facility in Section 2.0." The October 28, 2016 certification for the Stockton Yard SPCC Plan Version 4.0, and Table 2.1 showing no corrective action items, are attached for your reference. (Exh. D). 5. Secondary containment for mobile refuelers. The SPCC Plan states, "one of the DTL trucks is parked full and unattended in the northeast corner of the parking lot southeast of the Locomotive Shop. This location does not provide adequate passive general secondary containment for the largest compartment of the truck." Mobile refuelers parked on site and left unattended do not meet the definition of transportation-related. The February 2016 SPCC plan for the Stockton Yard (version 3.0)was amended to remove the language quoted above, and further amended in response to the SJCEHD's September 28, 2016 letter. Relevant pages of the October 2016 SPCC plan for the Stockton Yard (version 4.0) are attached for your reference. (Exh. E). Two "direct-to-locomotive" (DTL) mobile refuelers/tank trucks transport oil to various UPRR yards, including the Stockton Yard. Because the DTL trucks are not used exclusively within the confines of the Stockton Yard, they fall within the definition of"transportation-related facility" set forth in 40 CFR 112, Appendix A, Section II(2)(D) and are therefore subject only to Department of Transportation jurisdiction. 40 CFR 112,Appendix A, Section II(2)(D)provides, "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." (emphasis added). Of the two DTL trucks, one is filled with fuel offsite and,when present at the yard, staged full on a polymer berm until it is called upon to fuel a locomotive on or off-site. The containment berm is located directly in front and in plain view of the DTL personnel office and is constantly attended. Therefore,the full DTL truck is not subject to SPCC regulation. As a best management practice,the containment berm on which this DTL truck is located has a capacity of 7,405 gallons. 3038213.x1