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RECEIVED YRC Freight roc FEB 0 4 20% 1 990 Roe Avenue Overland Park, KS 66211 FREIGHT ENVIRONMENTAL HEALTH PERMIT/SERVICES • The 95-gallon drum labeled "Misc—Cleanup Warehouse" contained usable motor oil. The material was shipped for repackaging and resale on bill of lading 482-503764-3 dated 01/12/2016. • The two 95-gallon drums labeled"ORM-D" contained universal waste batteries and root beer base. The universal waste batteries were disposed on manifest 009608936FLE dated 01/22/2016. The root beer base was disposed on manifest 014378811JJK dated 01/29/2016. Item 107: Contingency plan is incomplete. The Facility Contingency Plan was updated to include the emergency response equipment capabilities and the Emergency Coordinator information. The Contingency Plan is attached for your review. Item 110: Failed to complete training on hazardous waste management and emergency response procedures. YRC employs many workers; however, not all personnel at the Facility handle hazardous waste. The terminal manager, shop managers, mechanics, operations manager, and a select group of dock supervisors were the only personnel trained per 22CCR66265.16 on hazardous waste management. In order to comply with the regulation and prevent confusion in the future, all dock supervisors and dock personnel that may encounter hazardous waste will be trained by February 22, 2016. Item 111: Failed to maintain complete personnel training records. All employees handling or managing hazardous waste are in the process of being trained. Training records will be maintained at the Facility for the duration of employment for each employee, plus three years following termination of employment, as required by 22CCR66265.16(d). Item 605: Failed to completely label containers or tanks of hazardous waste. The onsite UST was labeled incorrectly as "Waste Oil". The inspection report references 22CCR66262.34(f) for unpermitted facilities. The Facility is permitted every year for the storage of hazardous materials and waste, including tank storage. The referenced regulation requires that containers and tanks at unpermitted facilities are required to be labeled"Hazardous Waste". Used oil is recycled and managed under the used oil regulations of 22CCR66279.21. These regulations state that permitted facilities are required to label used oil containers and tanks as "Used Oil". To return the tank to compliance,the tank has been labeled"Used Oil'and also "Hazardous Waste" at the request of the EHD. Please find attached a photo of the tag. Item 201: Plan Certification by a Professional Engineer(PE) missing or incomplete. The SPCC Plan(Plan) was updated with secondary containment information for the two onsite generators. Once the information was updated and verified by the PE, the Plan was recertified. Page 2