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COMPLIANCE INFO_PRE 2019
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COMPLIANCE INFO_PRE 2019
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Last modified
3/5/2020 1:03:32 PM
Creation date
3/5/2020 10:17:04 AM
Metadata
Fields
Template:
EHD - Public
ProgramCode
2200 - Hazardous Waste Program
File Section
COMPLIANCE INFO
FileName_PostFix
PRE 2019
RECORD_ID
PR0507077
PE
2229
FACILITY_ID
FA0005303
FACILITY_NAME
HOLT OF CALIFORNIA
STREET_NUMBER
1521
Direction
W
STREET_NAME
CHARTER
STREET_TYPE
WAY
City
STOCKTON
Zip
95206
APN
16337015
CURRENT_STATUS
01
SITE_LOCATION
1521 W CHARTER WAY
P_LOCATION
01
P_DISTRICT
001
QC Status
Approved
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SJGOV\dsedra
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EHD - Public
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In paragraph 6.2.2.2 Probability of a Specific Failure Mode of EEUMA Publication No. 159 is <br />the following text, <br />"The cornerstone of RBI is the assessment of an item's risk classification, since the RBI methodology is <br />risk-based. Generally, risk is defined as the probability of occurrence (likelihood) of harm (failure) and the <br />consequences of that harm... <br />Generally, the RBI method takes into account those degradation mechanisms affecting the tank during <br />normal operations (corrosion, fatigue, etc.). However, failures as a result of excursions outside the defined <br />operating window should also be considered. <br />Many degradation mechanisms are time -dependent (e.g., general corrosion, settlement)... In reality, the <br />degradation rate may vary over time. This aspect should be considered, and `worst case' assumptions made <br />to provide acceptable safety margins. Through inspection, the average rates of degradation may become <br />better defined. <br />Some degradation mechanisms are independent of time, and occur when there are specific conditions <br />present. These conditions may not have been predicted in the original assessment. For this reason, RBI <br />should be applied on a single or individual basis, where tank history and specific experiences with the <br />particular tank are taken into account within the whole RBI process." <br />In paragraph 6.2.2.4 Risk Rating of EEUMA Publication No. 159 is the following text, <br />"Quantification of the risk is generally assessed in a semi -quantitative way by estimating the probability of <br />a (specific) failure mode and a consequence rating for that failure mode which, combined in a risk matrix, <br />leads to a risk class or rating... <br />The main purpose of risk rating is to focus attention on the high risk items..." <br />Risk-based inspections and the SP001 Standard <br />EEUMA Publication No. 159, as well as API Recommended Practice 580, Risk -Based Inspection, <br />and API Publication 581, Risk -Based Inspection, provide the steps necessary to establish a <br />risk-based preventive maintenance program. Likewise, these publications include steps needed <br />to assigning numerical values to both likelihoods and consequences (as described in paragraph <br />6.2.2.4 of EEUMA Publication No. 159). Lastly, it is recommended that users of these <br />publications consult individuals knowledgeable in tank design and RBI methodology in <br />establishing inspection programs based on the RBI principles. <br />4 <br />
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