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Schedule Prevention briefings for the Operating personnel are conducted for easily enough to assure adequate understanding of the SPCC plan. YES Describe the briefing program: Once per month, a review of the SPCC plan with operating personnel by a trained individual who has undergone training in compliance with 40 CFR 112, et seq. There is a federal requirement for follow-up 8 hr training per year in conjunction with the regulations of 40 CFR 112. Monthly briefings should be both oral and written. Further department briefing information is SARA Title III, and relevant state local and federal codes. (California Fire Code 2016) 3.7 Annual Inspection Facility personnel perform a more thorough inspection of facility equipment on an annual basis. This annual inspection complements the monthly inspection described above and is performed in June of each year using the checklist provided in Appendix C of this Plan. The annual inspection is preferably performed after a large storm event in order to verify the imperviousness and/or proper functioning of drainage control systems such as the enclosure, drains, facility topography, control valves, and the rainwater run-off drainage. Written annual inspection records are signed by Facility Manager & maintained with this SPCC Plan for a period of 3yrs. Discharge Prevention - General SPCC Provisions The following measures are implemented to prevent oil discharges during the handling, use, or transfer of oil products at the facility. Oil-handling employees have received training in the proper implementation of these measures. 3.8 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) This facility has specific drainage system for rainwater drainage, beyond the topography of this facility. Drainage from the masonry enclosure surrounding the AST storage area is controlled by a block which is manually-operated to prevent a discharge from entering the facility drainage system. The opening is located on the western wall of the enclosure, is to be blocked & kept in the closed position, except when draining the enclosure. Authorized staff determine whether the water being drained has been contaminated (sheen on water) or is pure and can be allowed to enter the facility storm-water drainage system. After determining that only oil- free water will be released the opening is cleared and the accumulated water is released under authorized supervision. If oil is present in the water, it is removed by a licensed cleanup contractor (Donlee Pump). Drainage events are recorded in Appendix C. Facility drainage outside the containment enclosure will flow into a network of drains located at the site. The general flow direction is south or to the middle of the facility. Non-destructive integrity evaluation has not previously been performed on any tanks. The tanks are inspected regularly and following a regular schedule in accordance with STI-SP001 , UL and/or APSA guidelines or manufacturer requirements and/or as required by the methods 26