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FXG provided written responses to all violations from the 9/8/17 inspection report and all subsequent amendments, full report dated 9/28/18. FXG initially provided documentation requested by Betty Ho after telephone communication, and believed all items were either addressed or an approved action plan was in place addressing all issues. Upon various review stages, Betty Ho requested additional documentation requests. FXG continued to provide all information requested at such time the information was requested. FXG believes we have, in good faith, submitted written responses within 30 days of receiving the inspection report and continued to provide all information that San Joaquin requested in a timely manner. Earlier today, I have sent pertinent emails supporting the above to Elena for her review. We request that these documents are reviewed and this violation is removed from the inspection report. 201 CCR 2712(b) Failed to maintain alarm logs and/or records of follow up actions. FXG maintains a database that contains all electronic records pertaining to monitoring and maintenance of our fuel system. At the time of the unannounced inspection, the Facility Maintenance Manager that oversees this system was traveling. While other station personnel have access to the database, the staff member that was assisting the inspector was unaware of where this documentation is stored. FXG will work with station personnel to ensure employees are aware of this database and who to contact to obtain appropriate documentation. Requested alarm logs are attached for your review. 204 CCR 2712(i) Current monitoring plan approved by the EHD not found on site. At the time of the unannounced inspection, the Facility Maintenance Manager that oversees this system was traveling and the staff member that was assisting the inspector was unaware of where this documentation is stored. FXG will work with station personnel to ensure employees are aware of who to contact to obtain appropriate documentation. 209 CCR 2715(c) Designated operator did not inspect all required items and/or the inspection reports not completed. Please find the alarm log attached. FXG's vendor, Ryder Fuel Services, had previously reviewed the certification and test date requirements with the Designated Operator. The April 2018 to the present reflect these changes. 211 CCR 2715(f)(2) Designated operator employee training not performed or log not kept. At the time of the unannounced inspection, the Facility Maintenance Manager that oversees this system was traveling and the staff member that was assisting the inspector was unaware of where this documentation is stored. I have attached a copy of the designated operator employee training log. 305 HSC 25290.1(e) VPH monitoring of the interstitial spaces of the UST system is not maintained. FXG's vendor, Ryder Fuel Services, has dispatched work order 388200 to address this issue. FXG was provided a technician date on site as 8/14/18. Additional updates regarding the technician's finding and any associated repairs are attached. 314 HSC 25290.1, 25290.2, 25291 Failed to have secondary containment or secondary containment not tight. FXG's vendor, Ryder Fuel Services, has dispatched work order 388200 to address this issue. FXG was provided a technician date on site as 8/14/18. Additional updates regarding the technician's finding and any associated repairs are attached. 316 25290.1(c3), 25290.2(c3) Secondary containment not constructed to prevent water intrusion (after Jul 2003). FXG's vendor, Ryder Fuel Services, has dispatched work order 388200 to address this issue. FXG was provided a technician date on site as 8/14/18. Additional updates regarding the technician's finding and any associated repairs are attached.. 319 2635(b) No spill bucket, failed to contain five gallons, or failed to provide a means to keep it empty. FXG's vendor, Ryder Fuel Services, has dispatched work order 388522 to address this issue. Additional updates regarding the technician's findings are attached. There appears to be a tear in the spill bucket however the existing bucket is in containment. The spill bucket will require replacement. FXG is working with a vendor to get the appropriate replacement scheduled. I have also attached the Return to Compliance Certification. Please let me know if you have any questions or comments. Thank you, Deb Debra B. Gehm Senior Environmental Compliance Specialist FedEx Ground 1000 FedEx Drive 5