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Barker, Zuna J . From : Debra Gehm < debra . gehm@fedex. com > Sent: Thursday, August 23, 2018 12 :49 PM To : Elena K. Manzo [ EH ] ; Zuna J . Barker [ EH ] Cc: Kevin Eric McTee; Garrett Grebe; Gaylyn Frosini Subject: FXG Tracy - Response to Inspection Report dated July 17, 2018 Attachments : RE Request for an informal discussion; RE Request for an informal discussion; Copy of 953 sensor alarms .xlsx; Tracy Technician ' s Findings and Corrective Actions . doc; 953 . pdf; WO - 388200 . pdf; WO - 388522 . pdf; DO training . pdfs Tracy Return to Compliance . pdf Importance: High Zuna and Elena , I would like to provide responses to the FXG Tracy Underground Storage Tank Program Inspection Report dated July 17, 2018 . 1 would also like to summarize our efforts to respond to these violations . FXG had several questions as to the nature of the violations identified on the report and reached out to Elena on 7 -30- 18, 8 - 6- 18, and 8 -8 - 18 ( email string attached ) for clarification on these questions . FXG also requested an extension for the required response on 8- 13 - 18 and 8 - 2248 ( attached ) until such time that a clarification to our questions could be received from San Joaquin County . Elena contacted FXG on 8-2248 to discuss FXG ' s questions regarding the July 17, 2018 violation report and provided clarification and direction necessary to appropriately respond to the violations . We greatly appreciated the opportunity to speak with Elena as more specific details were conveyed and more specific direction was provided regarding San Joaquin' s expectations regarding these violations . The below is a summary of FXG ' s responses and corrective actions based on clarifications received from Elena during the 8- 22 - 18 phone call . 121 CCR 2712 (f) Failed to submit a written response within 30 days of receiving an inspection report . FXG provided written responses to all violations from the 9/8/17 inspection report and all subsequent amendments , full report dated 9/28/ 18 . FXG initially provided documentation requested by Betty Ho after telephone communication , and believed all items were either addressed or an approved action plan was in place addressing all issues . Upon various review stages , Betty Ho requested additional documentation requests . FXG continued to provide all information requested at such time the information was requested . FXG believes we have , in good faith , submitted written responses within 30 days of receiving the inspection report and continued to provide all information that San Joaquin requested in a timely manner. Earlier today , I have sent pertinent emails supporting the above to Elena for her review. We request that these documents are reviewed and this violation is removed from the inspection report . 201 CCR 2712 (b) Failed to maintain alarm logs and/or records of follow up actions . FXG maintains a database that contains all electronic records pertaining to monitoring and maintenance of our fuel system . At the time of the unannounced inspection , the Facility Maintenance Manager that oversees this system was traveling . While other station personnel have access to the database , the staff member that was assisting the inspector was unaware of where this documentation is stored . FXG will work with station personnel to ensure employees are aware of this database and who to contact to obtain appropriate documentation . Requested alarm logs are attached for your review . 204 CCR 2712 ( i ) Current monitoring plan approved by the EHD not found on site . At the time of the unannounced inspection , the Facility Maintenance Manager that oversees this system was traveling and the staff member that was assisting the inspector was unaware of where this documentation is stored . FXG will work with station personnel to ensure employees are aware of who to contact to obtain appropriate documentation . 209 CCR 2715 ( c) Designated operator did not inspect all required items and /or the inspection reports not completed . Please find the alarm log attached . FXG ' s vendor , Ryder Fuel Services , had previously reviewed the certification and test date requirements with the Designated Operator. The April 2018 to the present reflect these changes . 1