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DocuSign Envelope ID:B7E23BC6-4CD0-4176-91DB-916E1DCCCAC4 Item#210 CCR 2715(c) Failure to provide initial training, train every 12 months, and have a trained employee present. OBSERVATION: The two employees listed on the training records were not on site at the time of the inspection. REGULATION GUIDANCE: The designated operator shall train facility employees in the proper operation and maintenance of the UST system at least once every 12 months. The training shall be conducted before the individual performs the duties of a facility employees. The training shall include, but is not limited to: 1. Operation of the UST system in a manner consistent with the facility's best management practices 2. Employee's role with regard to monitoring equipment as specified in the facility's monitoring plan 3. Employee's role with regard to spills and overfills as specified in the facility's response plan 4. Name of the contact person(s) for emergencies and monitoring equipment alarms Initial training shall also include a site-specific practical demonstration that provides both sharing information and evaluating knowledge for responding to emergencies, leak detection, monitoring alarms, spills and overfills. At least one of the facility employees present during operating hours shall have current training. CORRECTIVE ACTION. Ensure that employees have been trained by the designated operator, maintain the list on site, submit a copy of the training records to the EHD and ensure that at least one trained employee is on site during operating hours. This is a Class II violation. The regulation CCR 2715(c) reads: The designated UST operator(s)shall train facility employees in the proper operation and maintenance of the underground storage tank system at least once every 12 months. For facility employees hired before October 13, 2018, the initial training shall be conducted within 30 days of the date of hire. For individuals assuming the duties of a facility employee on or after October 13, 2018, the initial training shall be conducted before the individual performs the duties of a facility employee. UPS respectfully disagrees with this finding and requests that it be rescinded, as we do have employees trained (see Attachment E as copy of DUSTO training roster.) The employees that are trained are the only employees that fuel vehicles, and their shift begins in the evening. The regulation does not specify that the employee must be on shift 24 hours a day, nor is the UPS facility open 24 hours a day.