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YRC Freight <br /> 10990 Roe Avenue YW. <br /> Overland Park, KS 66211 <br /> June 19, 2019 <br /> Lydia Baker <br /> REHS <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Avenue <br /> Stockton, CA 95205 <br /> Re: YRC Freight Return to Compliance Statement <br /> Dear Ms. Baker: <br /> This letter is in response to the inspection at the YRC Freight(YRC)terminal located at 1535 <br /> East Pescadero Avenue, Tracy, CA (Terminal) on May 24, 2019. In an effort to rectify the two <br /> violations identified during the inspection,please see below for resolution. Also attached to this <br /> letter is backup documentation as necessary and the Return to Compliance Certification. <br /> Item 619: Failed to train personnel on all discharge prevention details listed in this section. <br /> At the time of inspection, the onsite contact could not locate the Spill Prevention Control and <br /> Countermeasure (SPCC) Plan training records from 2014 to present. The training has been <br /> conducted annually and the records have been placed in the SPCC Plan binder. Additionally, <br /> training was conducted on June 13, 2019 and training documentation can be found in Attachment <br /> A: SPCC Plan Training Roster—2019. <br /> Item 712: Failed to test or inspect each container for integrity based on industry standards. <br /> YRC respectfully disagrees with this violation. In 2010, a certified API 653 inspector performed <br /> an out of service inspection on Tank 3. The certified API 653 inspector prepared a Similar <br /> Service Assessment on Tank 2 in accordance with API 653 Appendix H,using Tank 3 as the <br /> control tank, and concluded that similar service criteria had been met. The Similar Service <br /> Assessment recommended that Tank 2 be scheduled for a formal API 653 Internal Inspection <br /> with an MFL bottom scan(or similar technology) no later than the end of 2030, in similar <br /> fashion to control Tank 3. The Similar Service Assessment report for Tank 2 is included in <br /> Attachment B: API 653 Similar Service Assessment. <br /> The Aboveground Petroleum Storage Act Inspection Report also required updating the SPCC <br /> Plan to discuss the inspection and testing schedule per industry standard and submitting the <br /> updated SPCC Plan to the Environmental Health Department. Section 18.3.6 of the SPCC Plan <br /> was updated to include a discussion of the Terminal's tank integrity testing program. The <br /> updated SPCC Plan can be found in Attachment C: Updated SPCC Plan. <br />