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Ms.Thuy Tran San Joaquin County Environmental Health Department October 25, 2010 Page 2 of 2 Aboveground Petroleum Storage Act (APSA) Program Inspection Report #16 SPCC Plan lacks full approval of management at a level of authority to commit the necessary resources to implement the Plan. Union Pacific has contracted with an environmental consultant to revise and update all SPCC Plans (approximately 140 Plans) throughout our system. A copy of the updated Plan for this facility with appropriate management approval will be forwarded to you upon completion, per our phone conversation. #18 No facility diagram or diagram failed to show location and contents of each container transfer stations, and connecting pipes. Union Pacific has contracted with an environmental consultant to revise and update all SPCC Plans (approximately 140 Plans) throughout our system. A copy of the updated Plan for this facility with a supplemental diagram showing the above elements will be forwarded to you upon completion, per our phone conversation. A draft of the supplemental diagram showing the connecting pipes that will be included in the updated SPCC Plan is attached to this letter. #24 SPCC Plan failed to include required contact list and phone numbers of the facility's response coordinator, cleanup contractors, and agencies to notify in case of discharge. Union Pacific has contracted with an environmental consultant to revise and update all SPCC Plans (approximately 140 Plans) throughout our system. A copy of the updated Plan for this facility with the updated contact information will be forwarded to you upon completion, per our phone conversation. A copy of the updated contact list that has been included in the current SPCC Plan and will be included in the updated SPCC Plan is attached. #48 Failed to:test each aboveground storage container on a regular schedule or when repairs were made;inspect containers and container supports;or to keep records of inspections and tests, or provide equivalence as allowed by CFR 112.7(a)(2). An inspection program has been implemented wherein a daily visual inspection will be conducted to look for signs of damage, vandalism, leaks, stained ground surface, or storm water contacting the bottom of the tanks. Additionally, an annual inspection will be performed that looks for visible discharges which result in a loss of oil from the container, including, but not limited to seams,gaskets, piping, pumps, piping, valves, welds, rivets, and bolts. Other components inspected include foundations, supports, level gauges, alarms, overfill protection, vents, ladders, secondary containment, and security equipment. Records of these annual inspections will be maintained on site for three years. A copy of the form to be used for the annual inspections is attached. John R.Thomas Manager of Environmental Field Operations Union Pacific Railroad Company Attachments