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Chevron RECEIVED fto fto FEB�r� (! L J ZVI6 Our Family of Brands ENVIRONMEN rAl- HEALTH PERMIT/SERVICES Curtis Aman Terminal Manager San Joaquin County Environmental Health Department 1868 East Hazelton Avenue Stockton, CA 95205 Dear Environmental Health Department, Americas Products Banta Terminal 22888 S. Kasson Rd Tracy, CA 95304 +1 408-392-2010 ajcu@chevron.com February 24, 2016 This letter is provided in response to the issues raised during the CUPA Operating Permit Routine Inspection of the Chevron Americas Products Banta Terminal that occurred on January 14, 2016. The information provided in this letter addresses the identified concerns related to the Terminal's Spill Prevention Control and Countermeasures (SPCC) program implemented per 40 CFR 112 and the California Aboveground Petroleum Storage Act. Each item identified in the inspection report is discussed in detail below with documentation of correction actions taken or additional information to dispute any violations. The signed Returned to Compliance Certification, within 30 days of the receipt of the inspection report, is included as Attachment A. Item # 604: No Facility diagram or didn't show location and contents of containers, transfer stations, and pipes. The inspection noted that the Terminal's facility diagram did not meet the specifications of the SPCC Rule, including: 1) identifying the location and contents of each fixed storage containers and the storage area where mobile or portable containers are located; 2) identifying the location of "exempt" underground tanks; and 3) including all transfer stations and connecting pipes, including intra -facility gathering lines. Attached is the Banta Terminal facility diagram from the SPCC plan (Attachment B). Please note the clear indication of all transfer areas (using a circled number 1), hazardous materials storage area (circled 2), and the location of all piping and pipeways denoted with crosshatched shading. In addition, there are no underground tank systems (USTs) per 40 CFR 280 at the Banta Terminal that would need to be marked as "exempt" on the facility diagram. Furthermore, the Terminal's facility diagram also includes a unique identifier for each fixed container and the areas where portable containers may be stored. The unique identifiers are listed in Figure 2.1-2 of the SPCC plan which contains the complete inventory including container contents, shell capacity, release specifications, and secondary containment capacity. This approach is consistent with the 2013 U.S. EPA SPCC Guidance for Regional Inspectors (EPA 550-B-13-001). In section 6.2.1 of the EPA guidance it states, " "The Plan preparer may identify an area on the facility diagram ... and include a separate description of the total number of containers, capacities, and contents in the Plan or reference facility inventories that can be updated by facility personnel." (Pg. 6-2)