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February 24, 2016 REG EIVED Page 4 FEB 2 5 2016 Item # 704: 112.8(c)(2) Dike area not sufficiently impervious to contain discharged oil ENVIROI MENTAI As addressed in Item # 609 above the terminal has demonstrated sufficient imperviousness, wit�i s pe reports. This determination is not altered by the observed cracks in the concrete or wildlife burrows as discussed above. The terminal has, however, repaired the wildlife burrows and will continue preventative maintenance on a regular schedule. Chevron disagrees with the inspection finding and respectfully requests that the Item # 704 violation be rescinded. Item # 706: 112.8(c)(2) Failed to provide and maintain adequate secondary containment As addressed in Item # 609 above the terminal does have adequate secondary containment as certified by a California licensed PE. This certification is not altered by the observed cracks in the concrete or wildlife burrows as discussed above. The terminal has, however, repaired the wildlife burrows and will continue preventative maintenance on a regular schedule. Chevron disagrees with the inspection finding and respectfully requests that the Item # 706 violation be rescinded. Item # 713: CFR 112.8(c)(6) Failed to perform scheduled tank tests and inspections by appropriately qualified personnel Appropriate API 653 inspections for Tanks 23, 131, and 137 were performed as required by the SPCC plan and internal standards. The inspector noted that only an "out of service" integrity test documentation was available for Tank 131, which was operational at the time of inspection. It is important to note that when a Formal Internal API 653 tank inspection is performed, the tank must be at the time taken out of service in preparation for the inspection. Therefore, it is a common industry practice to denote a formal internal tank inspection as an out of service tank inspection. This does not mean that the tank is being managed out of service, nor does it indicate that a full API 653 inspection was not performed. In addition, a certified third -party inspector provided a Suitability For Service report following the last out of service tank inspection (Attachment F). The inspector also noted that no records of completed repairs were available for the action items denoted in the inspection reports of Tanks 23 and 137. It is important to note that there are three classes of API 653 inspection findings that require various levels of response as identified in Chevron's standard procedures. In the Chevron Americas Products Inspections of Large Aboveground Storage Tanks (ILAST) Standard, cited in the SPCC Plan, the classes are defined as follows: Class 1: The tank is not suitable for the intended service. Repairs required before the tank can be placed in service are listed. Class I Repairs require API 653 re -inspection and documentation by the original inspection firm after Class I repairs are complete. Class 2: The tank is suitable for the intended service. Improvements are suggested, but they do not significantly affect suitability for service. Class 3: The tank is suitable for the intended service. Optional improvements are suggested. The Inspector shall use the above classification system in the report. Class I recommendations provided in the recent API 653 inspections for Tanks 23 and 137 were repaired and the appropriate documentation was provided on-site during the inspection and is also provided in this response (Attachment G). The resulting inspections adheres to the standards set forth in API 653 and are performed by certified inspectors. The records provided during the inspection demonstrate Terminal compliance with the API 653 standard for Tanks 23, 131, and 137.