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described in the Plan is appropriate for the facility and is consistent with good engineering practices and applicable industry standards have been outlined in the SPCC plan. No such schedule is listed in the reviewed SPCC plan. There appear to be some inconsistencies in connection with integrity testing of tank AG-8.AG-8 was last inspected using API-653 standard on March 2, 2015. Per the API inspection report,the next formal API-653 external inspection should be conducted within 5 years and no later than March 2020 and the ultrasonic(UT) shell testing should be conducted again within 15 years and no later than March 2030.This tank was not inspected as required by March 2020. Instead, the facility indicated that they switched to the STI standard for this tank in 2015, forgoing the required API inspection in March 2020. Furthermore, in his email dated 6-25-2021, Richard Bronson indicated with regards to AG-8 tank testing/inspection standard: "The SPCC incorrect, changed to STI in 2015." This change doesn't appear to have been reflected in the reviewed SPCC plan;the certifying professional engineer must detail in the SPCC plan the frequency and type of testing and inspections based on container size, configuration, and design based on the applicable industry standards. Facility must ensure that the SPCC Plan discusses procedures to test or inspect each aboveground container for integrity in accordance with industry standards: -On a regular schedule. -After material repairs are made. -By qualified personnel. -The frequency and type of testing and inspections outlined in the SPCC plan shall be based on container size, configuration, and design. 2. Violation 705: Based on this review,the facility provided sufficient evidence that indicated that all required repairs for all the onsite tanks had been implemented in the past; as such, violation 705 was removed from the original inspection report. 3. Violation 712 (EHD's checklist was recently updated, now it's violation 713): This violation was written because the facility failed to test or inspect each container for integrity based on industry standards. Specifically,failing to implement a formal inspection for tank AG-8 by March 2020 (per API -653 report recommendation).The facility indicated that this inspection didn't need to be conducted since tank AG-8 was last inspected on March 2, 2015, and using a 20-year inspection frequency for a category 1 tank, per STI standards, the next inspection will be not due until 2035. The Shell Pipeline Company LP, (SPLC),Tank and Pressure Vessel I & M Manual, Page 9.3-2 (referenced in the SPCC plan) lists out the procedure for inspection of small diameter tanks, specifically indicating that the following procedures must be followed: "1. Conduct evaluation to categorize the tank in accordance with STI SP00L 2. Establish the inspection frequency for each tank basis tank type, tank size, corrosion rates and inspection history." Since no inspection by a certified STI inspector was conducted for tank AG-8, it appears that no evaluation to categorize the tank in accordance with STI SP001 standard has been conducted. Furthermore, it appears that no inspection by the STI SP001 inspector was done since 2015 to determine if the API-653 tank inspection, dated March 2, 2015, meets all the STI requirements for the SP001 inspection. Based on the current schedule listed in the "Stockton Tank Database" (table), these requirements will not be met until 2035 for the next onstream inspection and never for the next offstream inspection (since no offstream inspection schedule is provided for this tank in the above table). Based on the EHD's discussion with the Steel Tank Institute (STI) engineer, the SP001 certified inspector needs to evaluate the last API-653 inspection report for the AG-8 tank and provide a determination if it meets all of the requirements of the STI SP001 standard. If the API-653 inspection did not meet the STI SP001 standard (for example, if the liquid in secondary and primary containment was not evaluated, or emergency and regular vents adequacy and functionality were not addressed in the API report, etc.,) according to the STI,the API-653 inspection dated March 2, 2015 would not meet the minimum requirements of the SP001 inspection standard, and tank AG-8 would not have been inspected as required per the STI industry standards in 2015, impacting the timeframe for the next SP001 inspection. 2