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Thuy Tran [EH) <br /> From: Byerley, Ruben <Ruben.Byerley@YRCFreight.com> <br /> Sent: Thursday,April 04,2013 3:25 PM <br /> To: Thuy Tran[EH] <br /> Subject: FW: Response and Return Back to Compliance-YRC Freight, 1535 S. Pescadero Ave.,Tracy, CA <br /> Attachments: April 2012 Monthly DO Inspection Report.PDF; March 2013 Monthly DO Inspection Report.docx;3-8-13 <br /> Inspection Report.pdf; Return to Compliance Cert.pdf; Owner Statement of DO.PDF <br /> Ms.Tran, <br /> Per our phone conversation the other day, attached is our Return to Compliance form and in this e-mail I am providing <br /> you with our Corrective Action Response statements for each violation noted in the attached report. <br /> Violation#113: Failed to inform EHD of change of designated operator within 30 days. <br /> Corrective Action Response: Attached is the correct Owner Statement of Designated UST Operator form dated 3/18/13, <br /> which lists Jarrod Cooke as the primary Designated Operator(DO)for the Tracy facility. The alternate DOs are George <br /> Sarkiss Zoumalan and Randall Kirby. (See attached). This form has been submitted to the EHD by Tanknology. In the <br /> future,Tanknology, as YRC Freight's DO at the Tracy,CA facility,will submit a revised Owner Statement of Designated <br /> UST Operator form to the EHD within 30 days anytime that there is a change in regard to the DOs at this facility. Alex <br /> Fast is no longer with Tanknology and is not performing DO inspections at this facility anymore. <br /> Violation#204: Alarms for L6 T2 annular space were NOT documented. The DO failed to document all of the alarms in <br /> the August 2012 DO monthly inspection report and failed to check that they were responded to appropriately. <br /> The DO failed to check and note the correct test dates for the secondary containment testing on ten DO monthly <br /> inspection reports from May 2012 and July 2012-February 2013. <br /> Corrective Action Response: Going forward,the DO has been counseled to review the alarm history from the previous <br /> month,check that each alarm was documented and responded to appropriately,and attach a copy of the alarm history <br /> with documentation taken in response to any alarms to the monthly report. The DO will ensure that all future alarms, <br /> other than low fuel inventory alarms which require no response,to include L6 T2 annular space alarms,are documented <br /> and responded to appropriately before leaving the facility following the monthly inspection. In addition, before leaving <br /> the facility,the DO"must" communicate with on-site personnel in regard to any discrepancies noted between the alarm <br /> history and the responses taken by the facility to address them. If the DO is still unable to resolve these discrepancies by <br /> discussing them with on-site personnel,the DO and his or her operations manager at Tanknology have been instructed <br /> to contact Ruben Byerley, Manager-Environmental at the YRC Freight corporate office,at 913-344-3644 to get <br /> resolution. <br /> The March 2013 DO inspection report notes the correct test date of 10/6/10 for secondary testing at this facility. <br /> (Attached) Going forward,the DO has been counseled to ensure that they are reviewing all documentation,to include <br /> previous test reports and the dates for those reports,to ensure that"ALL" information noted on the DO monthly <br /> inspection reports are complete and accurate. <br /> Violation#205: The April 2012 DO monthly inspection report was not found on-site. DO monthly inspection reports for <br /> the previous twelve months shall be retained on-site. <br /> Corrective Action Response: Going forward,the DO will ensure that copies of the previous twelve months of DO <br /> monthly inspection reports are maintained on-site. Attached is a copy of the April 2012 monthly DO inspection report <br /> that Tanknology is submitting to the EHD along with the Owner Statement of Designated LIST Operator form. <br /> 1 <br />