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Vicki McCartney [EH] From: Byerley, Ruben <Ruben.Byerley@YRCFreight.com> Sent: Tuesday, March 7, 2017 12:30 PM To: Vicki McCartney [EH] Cc: Catherine Riccomini; Loredo, Joyce; Smith, Richard (Equipment Services) Subject: Return to Compliance - Responses to Violations Cited in Amended 2/7/16 UST Inspection Reportfor YRC Freight, 1535 E. Pesadero Ave., Tracy, CA, CERS ID #10181485 Attachments: DO Monthly Inspection SOAP 07 20 2016.pdf; DO Monthly Inspection 6 Tanks 07 20 2016.pdf; CERS UST Monitoring Plan Facility Information.pdf; CERS UST Monitoring Plan Antifreeze Tank.pdf, CERS UST Monitoring Plan Gear Oil Tank.pdf, CERS UST Monitoring Plan Motor Oil Tank.pdf, CERS UST Monitoring Plan Soap Tank.pdf; CERS UST Montoring Plan Used Oil Tank.pdf, CERS UST Monitoring Plan Used Oil -2 Tank.pdf; CERS UST Monitoring Plan Waste Diesel Tank.pdf; SVC WO 02 02 2017.pdf, Training Forms & Certs.pdf; Amended UST Insp 02 06 2017.pdf, Return to Compliane Cert.pdf; Site Plan.pdf; SVC WO 01 04 2017.pdf Ms. McCartney, Below, are our responses to violations cited in your attached 2/6/16 Underground Storage Tank (UST) Inspection report that was amended 2/7/16 for YRC Freight 1535 E. Pescadero Avenue, Tracy, CA, CERS ID #10181485: Item #105: The UST Monitoring Plan in CERS is not current and/or approved by the EHD. Response: Under the heading, Tank Monitoring is Performed Using the Following Method(s) for USTs: TA0249501 (Soap), TA0249504 (Used Oil), TA0249505 (Gear Oil) Leak Sensor Model #409 was changed to #407. For all seven USTs, under the heading Recordkeeping, Tank Integrity Testing Results were changed from "Yes" to "No". For all USTs, except for TA0249502 (Used Oil), under heading Comments/Additional Information, it was stated, "Mechanical flapper, set at 95 percent of tank capacity, is used for overfill protection." For UST TA0249501 (Soap), under heading Suction Piping Meets Exemption Criteria, it was changed from "Yes" to "No", because it is conventional, not European, safe suction piping for this UST. The updated UST Monitoring Plan with the aforementioned revisions was uploaded to CERS for EHD review. (See attached) Item #107: An accurate UST Monitoring Site Plan was not submitted. Response: An updated UST Monitoring Site Plan was uploaded to CERS for EHD review to now include fill ports/spill buckets, annular risers/sensors, and piping sumps/sensors for all seven USTs. In addition, the newly installed Veeder Root TLS 300-C monitoring panel for the TA0249501 (Soap) UST is now depicted and labeled on the site plan. (See v attached) Item #110: Failed to submit secondary containment test report within 30 days. Secondary containment testing was performed on 4/27/16 and a test report was submitted on 8/9/16 to the EHD. Response: All efforts will be made by recently hired testing company, Confidence UST Services, Inc., who is also providing Designated Operator (DO) services, to mail test reports within 30 days of test date using UPS or similar tracking service to ensure that the EHD receives it on-time. Item #201: Failed to maintain alarm logs and/or records of follow-up items. The facility did not document and address the TA0249502 (Used Oil) piping sump L5 Fuel Alarm on January 4, 2017, and the T-4 Gear Oil Probe Out alarm on February 2, 2017.