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<br />From: Byerley, Ruben rmailto: Ruben. Byerley(cbYRCFreiaht.com]
<br />Sent: Tuesday, March 7, 2017 12:30 PM
<br />To: Vicki McCartney [EH]
<br />Cc: Catherine Riccomini; Loredo, Joyce; Smith, Richard (Equipment Services)
<br />Subject: Return to Compliance - Responses to Violations Cited in Amended 2/7/16 UST Inspection Report for YRC
<br />Freight, 1535 E. Pesadero Ave., Tracy, CA, CERS ID #10181485
<br />Ms. McCartney,
<br />Below, are our responses to violations cited in your attached 2/6/16 Underground Storage Tank (UST) Inspection report
<br />that was amended 2/7/16 for YRC Freight 1535 E. Pescadero Avenue, Tracy, CA, CERS ID #10181485:
<br />Item #105: The UST Monitoring Plan in CERS is not current and/or approved by the EHD.
<br />Response: Under the heading, Tank Monitoring is Performed Using the Following Method(s) for USTs: TA0249501
<br />(Soap), TA0249504 (Used Oil), TA0249505 (Gear Oil) Leak Sensor Model #409 was changed to #407. For all seven USTs,
<br />under the heading Recordkeeping, Tank Integrity Testing Results were changed from "Yes" to "No". For all USTs, except
<br />for TA0249502 (Used Oil), under heading Comments/Additional Information, it was stated, "Mechanical flapper, set at
<br />95 percent of tank capacity, is used for overfill protection." For USTTA0249501 (Soap), under heading Suction Piping
<br />Meets Exemption Criteria, it was changed from "Yes" to "No", because it is conventional, not European, safe suction
<br />piping for this UST. The updated UST Monitoring Plan with the aforementioned revisions was uploaded to CERS for EHD
<br />review. (See attached)
<br />Item #107: An accurate UST Monitoring Site Plan was not submitted.
<br />Response: An updated UST Monitoring Site Plan was uploaded to CERS for EHD review to now include fill ports/spill
<br />buckets, annular risers/sensors, and piping sumps/sensors for all seven USTs. In addition, the newly installed Veeder
<br />Root TLS 300-C monitoring panel for the TA0249501 (Soap) UST is now depicted and labeled on the site plan. (See
<br />attached)
<br />Item #110: Failed to submit secondary containment test report within 30 days. Secondary containment testing was
<br />performed on 4/27/16 and a test report was submitted on 8/9/16 to the EHD.
<br />Response: All efforts will be made by recently hired testing company, Confidence UST Services, Inc., who is also
<br />providing Designated Operator (DO) services, to mail test reports within 30 days of test date using UPS or similar
<br />tracking service to ensure that the EHD receives it on-time.
<br />Item #201: Failed to maintain alarm logs and/or records of follow-up items. The facility did not document and address
<br />the TA0249502 (Used Oil) piping sump L5 Fuel Alarm on January 4, 2017, and the T-4 Gear Oil Probe Out alarm on
<br />February 2, 2017.
<br />Response: The TA0249502 (Used Oil) piping sump L5 sensor that was in alarm was addressed on January 4, 2017, but
<br />was not documented on alarm log. (See attached) The T-4 Gear Oil Probe Out alarm was addressed on February 2,
<br />2017, but not documented on alarm log. (See attached) Going forward, all alarms on the daily alarm log will be
<br />documented, and the actions taken to address these alarms will also be noted.
<br />Item #209: Designated operator did not inspect all required items and/or the inspection reports not completed. During
<br />the monthly inspection, the designated operator shall check that all required testing and maintenance for the UST
<br />system have been completed and document the dates that they were done. Ensure that designated operators
<br />performing monthly inspections at this facility are including all of the required information on the reports.
<br />
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