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<br /> Aboveground Petroleum Storage Act Compliance Review Report
<br /> Facility Name: Facility Phone: Date:
<br /> Shell Oil Products US-Stockton Terminal 209 466-6941 June 30 2021
<br /> Facility Address: CERS ID:
<br /> 3515 Navy Dr Stockton CA 95203 10157477
<br /> Inspection Contact: Title: Phone:
<br /> Theresa Geijer Environmental Advisor (206)618-9061
<br /> VIOLATIONS
<br /> The following non-inspection related violations listed below from the California Health and Safety Code(HSC), California Code of
<br /> Requlations(CCR)and/or the Code of Federal Requlations(CFR)were found.
<br /> #711 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity
<br /> OBSERVATIONS:OBSERVATION:The reviewed Spill Prevention, Control, and Countermeasure(SPCC) Plan does appear
<br /> to adequately discuss procedures to test or inspect each aboveground container for integrity in accordance with industry
<br /> standards and does not address the frequency and type of testing and inspections based on container size, configuration,
<br /> and design.
<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 and
<br /> vessel testing and inspection processes/procedures follow applicable API or STI requirements and have been reviewed as
<br /> appropriate by the facility. Please refer to the Shell Pipeline Company LP, (SPLC),Tank and Pressure Vessel I &M Manual
<br /> for further documentation of Shell's policies, procedures and requirements." Table A-2 of the same SPCC plan lists the
<br /> following information for tank AG-8: "Gasoline Additive, [...], Integrity Testing Method-External& Internal (Note 1)-Refers to
<br /> tank integrity testing methods that include recommended industry standards(i.e.API 653, etc.)." No additional schedule or
<br /> standard specifics(including STI reference)was noted on this table in connection with integrity inspections/testing specifics.
<br /> Furthermore, although both API and STI standards are listed in the SPCC plan,the SPCC plan doesn't specify which
<br /> standard will be used for which tank and how often all onsite tanks will be tested.
<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 Database"
<br /> (table),which lists past and future tank inspections schedule, this table was not included in the reviewed SPCC plan.
<br /> Tank AG-8 was last inspected using API-653 standard on March 2, 2015. Per the 2015 API inspection report, the next formal
<br /> API-653 external inspection for this tank should be conducted within 5 years and no later than March 2020, and the
<br /> ultrasonic(UT)shell testing should be conducted again within 15 years and no later than March 2030. This tank was not
<br /> inspected as required by March 2020. Instead,the facility indicated that they switched to the STI standard for this tank in
<br /> 2015,forgoing the required API inspection in March 2020. Furthermore, in his email dated June 25, 2021 with regards to the
<br /> AG-8 tank testing/inspection standard, Richard Bronson indicated: "The SPCC incorrect, changed to STI in 2015."This
<br /> change from API to STI has not been reflected in the reviewed SPCC plan.
<br /> REGULATION GUIDANCE: 112.8(c)(6)Test or inspect each aboveground container for integrity on a regular schedule and
<br /> whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate
<br /> qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take
<br /> into account container size, configuration, and design (such as containers that are: shop-built,field-erected, skid-mounted,
<br /> elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not
<br /> limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other
<br /> systems of non-destructive testing. You must keep comparison records, and you must also inspect the container's supports
<br /> and foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration, discharges, or
<br /> accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices
<br /> satisfy the record keeping requirements of this paragraph.
<br /> FA0003747 PR0527478 SCO21 06/30/2021
<br /> Rev.9/16/2020 Page 1 of 4 Aboveground Petroleum Storage Act Compliance Review Report
<br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/EHD
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