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YRC Freight MC <br /> 10990 Roe Avenue <br /> Overland Park, KS 66211 FREIGHT <br /> February 3, 2016 RECEIVED <br /> Stacy Rivera and Fatinah Zareef FEB 0 4 2016 <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Ave. ENVIRONMENTAL HEALTH <br /> Stockton, CA 95205 PERMIT/SERVICES <br /> Re: YRC Freight Return to Compliance Statement <br /> Dear Ms. Rivera and Ms. Zareef: <br /> This letter is in response to the inspection at YRC Freight(YRC) terminal located at 1535 East <br /> Pescadero Avenue in Tracy, CA on January 4, 2016. In an effort to rectify the eight violations <br /> identified during the inspection,please see below for resolution. Also attached to this letter is the <br /> Return to Compliance Certification form issued by the San Joaquin County Environmental <br /> Health Department(EHD), and backup documentation as necessary. <br /> Item 105: Failed to determine if a waste is a hazardous waste or retain waste analysis onsite <br /> for 3 years. <br /> The metal fines generated during grinding were sent for analysis and determined to fall within <br /> the definition of hazardous waste per 22CCR66262.11 and 22CCR6262.40(c). The facility has <br /> implemented collection of the fines for hazardous waste disposal. The waste analysis will be <br /> maintained onsite for at least 3 years. Please find attached a photo of the hazardous waste <br /> container. <br /> Additionally, five overpack drums containing damaged freight pending disposition were <br /> discovered on the dock. When freight is damaged or arrives damaged, it is placed in an overpack <br /> drum,properly marked and labeled using the YRC HM 106 form, and stored in the hazardous <br /> material storage area. The Facility will then reach out to both the shipper and consignee to <br /> determine ownership of the freight. If the freight is denied by both parties, the Facility will take <br /> ownership. The YRC Hazardous Materials Department will be contacted at this time to <br /> determine if the freight is usable for the company. <br /> Damaged freight is not considered hazardous waste. Freight determined to be hazardous waste is <br /> labeled, stored in the hazardous waste storage area, and disposed appropriately. Below is an <br /> update on the drums identified in the Inspection Report. <br /> • The 20-gallon drum of paint thinner was shipped for repackaging and resale on bill of <br /> lading 482-515240-0 dated 01/28/2016. <br /> • The three 20-gallon drums of paint were disposed on manifest 014378811JJK dated <br /> 01/29/2016. <br /> • The 20-gallon drum of dichloromethane contained an empty 5-gallon pail and the 20- <br /> gallon drum of ethanol flammable liquid contained 3 small containers of antiseptic. Both <br /> drums were disposed on manifest 009608935FLE dated 01/22/2016. <br /> Page l <br />