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RECEIVED <br /> YRC Freight MC_ <br /> FEB 0 4 2016 10990 Roe Avenue �" — - <br /> Overland Park,KS 66211 X X=G R <br /> ENVIRONMENTAL HEALTH <br /> PERMITLSERVICE <br /> Item 609: Failed to provide secondary codftainment, diversionary structures, or equipment <br /> to prevent discharge. <br /> A PE calculated secondary containment dimensions for the two onsite generators using the 25- <br /> year, 24-hour significant rain event calculations. Both containment structures are currently <br /> undergoing construction and concrete pouring is anticipated to be completed today. Attached are <br /> photos of the concrete forms. Additionally,the SPCC Plan was updated to reflect the change and <br /> the Plan was recertified by the PE. <br /> Item 720: Failed to provide sufficient secondary containment capacity for mobile or <br /> portable containers. <br /> All liquid-filled portable containers at the Facility were stored on secondary containment as <br /> required. The stationary generators did not have sufficient secondary containment. Please see <br /> Item 609 above for resolution. <br /> We object to the designation of items 110 and 605 as `Repeat Violations'. We understand the <br /> designation was based on an inspection performed nine years ago, but we do not believe the <br /> conditions observed during this inspection are the same conditions that were cited in the earlier <br /> report. Also, the Facility has undergone numerous inspections by both the EHD and the local <br /> Fire Department in the last nine years with no violations notes for these conditions. Both of these <br /> items have been addressed and we are committed to remaining in compliance moving forward; <br /> however, we do ask that you either revise the inspection report to remove the `repeat violation' <br /> designation, or confirm for us that the items are not, in fact, `repeat violations'. <br /> Thank you for reviewing our response. If additional explanations, documentation, or discussions <br /> are necessary to close out these violations, please don't hesitate to reach me either by email at <br /> ruben.bverleY@3gcfrei hg t.com or telephone at (913) 344-3644. <br /> Sincerely, <br /> gj26)_� <br /> Manager—Environmental Services and Properties <br /> Page 3 <br />