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(ACIVEU February 24, 2016 FEB 2 5?016 Page 3 ENVIRONMENTAL which are documented on the Terminal Daily Inspection Form. The inspections for 2014, 2015, akfAAY 26P6RTMrn'_ were provided for review during the 2016 inspection. All of these files remain available for review at the terminal. Unfortunately, due to some recent staffing transitions at the Terminal, complete records of daily inspections for 2013 could not be located during the inspection on January 14`h. However, daily inspections for May to December of 2013 were later found, as well as monthly inspections for all months except June and November 2013. Therefore, the Terminal does have complete coverage for inspections 2013 using both monthly and daily documents, as the daily inspections are complete for June and November 2013 (Attachment E). Based on the Daily/Weekly Assignments Log from January through April 2013 (included in Attachment E), we are confident the daily inspections were performed for those months. However, we have not yet been able to locate the documents in the Terminal's historical files. The Terminal is continuing to review archived materials to identify the misplaced documents for 2013. Item # 614: CFR112.7(1)(1) Failed to train personnel on discharge prevention As stated in 40 CFR 112.7(f)(1) and 40 CFR 112.7(f)(3), the terminal is required to: and "At a minimum, train your oil -handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC. " 112.7(f)(1) "Schedule and conduct discharge prevention briefings for your oil -handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in § 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures. " I I2.7(f)(3) Training in the operation and maintenance of equipment to prevent discharges is addressed in regular operations training for all facility personnel. Oil handlers such as the Terminal Manger and Terminal Mechanic also receive initial and annual SPCC refresher training to ensure adequate understanding of the contents of the SPCC Plan, applicable pollution control regulations, and a discussion of any recent discharges, failures, or malfunctions as well as any new mitigations or controls. Both the Terminal Manager and the Terminal Mechanic did receive initial SPCC training and an annual refresher briefing per 40 CFR 112.7(f)(1) and (3) (Attachment F). The annual SPCC Training for some multi -facility employees may be in some cases be jointly performed at another terminal, as these oil handlers perform work at more than one facility. Documentation of the training is maintained in an electronic training system (iLMS) by the individual employee and is not always documented in hard copy at the specific terminal, however the training material does satisfy all requirements in 40 CFR 112.7(f). The Terminal has elected to maintain a copy of all future SPCC training activities with the SPCC Plan at the Terminal to ensure clarity in the documentation. Additionally, annual SPCC refresher training for the Terminal Manger and Terminal Mechanic staff mentioned in the inspection, as well as for other employees, was also scheduled and implemented on February 11 and 15, 2016 to reinforce SPCC Plan requirements (Attachment F). The standard template used for the instructor led annual SPCC Briefing completed by all oil handlers is also included with the training records for reference. Chevron believes that terminal personnel were fully trained per SPCC requirements at the time of the inspection and respectfully requests that the Item # 614 violation be rescinded.