|
Manzo, Elena K.[EHD]
<br /> From: Manzo, Elena K.[EHD]
<br /> Sent: Thursday,September 9,2021 7:55 PM
<br /> To: theresa.geijer@shell.com
<br /> Subject: Amended in-office inspection report
<br /> Attachments: RTC for Amended In-office inspection report-Navy Drive_9-9-2021.pdf;Amended In-office inspection report-Navy
<br /> Drive_9-9-2021.pdf
<br /> Hello Theresa,
<br /> Thank you for the additional information submitted to the EHD by your facility on July 22, 2021,August 6, 2021, and
<br /> August 11, 2021, in connection with the in-office compliance review report dated June 30, 2021, issued to your facility
<br /> (issued on July 7, 2021).The in-office inspection report was generated based on tanks API inspections documentation
<br /> that had been received by the EHD in response to the onsite inspection on November 5, 2020.
<br /> The EHD reviewed all your responses and the presented evidence in support of your request to rescind all the violations
<br /> presented in the inspection report dated June 30, 2021, and would like to provide the following comments:
<br /> 1. Violation 102:
<br /> Violation 102 (40 CFR 1112.3; HSC 6.67 25270.4.5(a)) was originally written for not preparing and implementing the
<br /> SPCC plan according to applicable 40 CFR standards, specifically in connection with the implementation of tank
<br /> inspection and testing for tank AG-8. Based on the received evidence, violation 102 was reclassified to violation 711 (40
<br /> CFR 1 112.8(c)(6); HSC 6.67 25270.4.5(a)- "Plan failed to adequately discuss procedures to test or inspect each container
<br /> for integrity"), as more appropriate.The facility pointed out that their SPCC plan lists both API-653 and STI industry
<br /> standards for tank testing. Although both standards are listed in the SPCC plan, SPCC plan doesn't clearly specify which
<br /> standard will be used for which tank and how often all onsite tanks will be tested.
<br /> On page 3-3 of the reviewed SPCC plan indicates, "All internal or external tank inspections are certified in appropriate
<br /> licensing, or meet required industry qualifications such as API-653, STI, or OQ requirements. The frequency of all tank
<br /> and vessel testing and inspection processes/procedures follow applicable API or STI requirements and have been
<br /> reviewed as appropriate by the facility. Please refer to the Shell Pipeline Company LP, (SPLC),Tank and Pressure Vessel I
<br /> & M Manual for further documentation of Shell's policies, procedures and requirements."Table A-2 of the same SPCC
<br /> plan lists the following information for tank AG-8: "Gasoline Additive, [...], Integrity Testing Method - External & Internal
<br /> (Note 1) - Refers to tank integrity testing methods that include recommended industry standards (i.e. API 653, etc.)." No
<br /> additional schedule or standard specifics (including STI reference)was noted on this table in connection with integrity
<br /> inspections/testing specifics. In your response you presented a revised Table A-2 (dated July 2021),which now included
<br /> the reference of STI as an additional industry standard.
<br /> The Shell Pipeline Company LP, (SPLC),Tank and Pressure Vessel I & M Manual (I&MM), as referenced in the SPCC plan,
<br /> details facility policies, procedures, and requirements. Although the facility has a separate table, "Stockton Tank
<br /> Database" (table), which lists past and future tank inspections schedule,this table was not included in the reviewed
<br /> SPCC plan.
<br /> The SPCC Guidance for Regional Inspectors, page 7-14 offers further clarification concerning this issue: "Once the [SPCC]
<br /> Plan preparer selects an inspection schedule for aboveground containers (based on applicable industry standards), it
<br /> must be documented in the SPCC Plan and the owner or operator must conduct inspections according to that schedule".
<br /> Furthermore, Section 112.3(d)(1) specifically states that the PE certifying a Plan attests that"procedures for required
<br /> inspections and testing have been established." Section 112.3(d)(1) also states that the Plan must be prepared in
<br /> accordance with good engineering practice, including consideration of applicable industry standards and with the
<br /> requirements of 40 CFR part 112. Thus, when certifying an SPCC Plan, a PE is also certifying that the inspection program
<br /> 1
<br />
|