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x Environmental Health Department
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<br /> Aboveground Petroleum Storage Act Compliance Review Report
<br /> Facility Name and Address: Shell Oil Products US-Stockton Terminal, 3515 Navy Dr, STOCKTON 95203
<br /> #713 CFR 112.7(e), 112.8(c)(6) Failed to test or inspect each container for integrity based on industry standards
<br /> OBSERVATIONS:OBSERVATION:Tank AG-8 doesn't appear to have been inspected as required in accordance with the
<br /> applicable industry standards.The AG-8 tank was inspected on March 2, 2015, using API-653 standard, and this inspection
<br /> report indicated that the next formal API-653 external inspection should be conducted within five years and no later than
<br /> March 2020.This tank was not inspected as required by March 2020. Mr. Richard Bronson provided information stating that
<br /> since this tank of a smaller capacity, it's now being inspected using the SP001 standard and stated that the next inspection
<br /> is not yet due for this tank.The facility indicated that this inspection didn't need to be conducted since tank AG-8 was last
<br /> inspected on March 2, 2015, and using the 20-year inspection frequency for a category 1 tank, per STI standards,the next
<br /> inspection will be not due until 2035.
<br /> The Shell Pipeline Company LP, (SPLC), Tank and Pressure Vessel I &M Manual, Page 9.3-2 (referenced in the SPCC
<br /> plan)lists out the procedure for inspection of small diameter tanks, specifically indicating that the following procedures must
<br /> be followed: "1. Conduct evaluation to categorize the tank in accordance with STI SP001. 2. Establish the inspection
<br /> frequency for each tank basis tank type, tank size, corrosion rates and inspection history."No evaluation by the certified STI
<br /> SP001 inspector was provided to the EHD for tank AG-8. Therefore, it appears that no evaluation to categorize the AG-8 tank
<br /> in accordance with STI SP001 standard has been done by the certified STI SP001 inspector, and no determination if the
<br /> API-653 tank inspection,dated March 2, 2015, meets all the STI requirements for the SP001 inspection has been
<br /> conducted. Based on the current schedule listed in the"Stockton Tank Database"(table), these requirements will not be met
<br /> until 2035 for the next onstream inspection and never for the next offstream inspection (since no offstream inspection
<br /> schedule is provided for this tank in the above table, offstream inspection would be required if this tank is categorized as
<br /> category 2 or 3 by the STI inspector).
<br /> REGULATION GUIDANCE: REGULATION GUIDANCE: 112.8(c)(6)-Test or inspect each aboveground container for integrity
<br /> on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards,
<br /> the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and
<br /> inspections,which take into account container size, configuration, and design (such as containers that are: shop-built,
<br /> field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity
<br /> tests include, but are not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic
<br /> emissions testing, or other systems of non-destructive testing.You must keep comparison records and you must also
<br /> inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for
<br /> signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under
<br /> usual and customary business practices satisfy the record-keeping requirements of this paragraph.
<br /> 112.7(e)- Inspections, tests, and records. Conduct inspections and tests required by this part in accordance with written
<br /> procedures that you or the certifying engineer develop for the facility.You must keep these written procedures and a record
<br /> of the inspections and tests, signed by the appropriate supervisor or inspector,with the SPCC Plan for a period of three
<br /> years. Records of inspections and tests kept under usual and customary business practices will suffice for the purposes of
<br /> this paragraph.
<br /> 25270.4.5. (a) Except as provided in subdivision (b), the owner or operator of a storage tank at a tank facility subject to this
<br /> chapter shall prepare a spill prevention control and countermeasure plan applying good engineering practices to prevent
<br /> petroleum releases using the same format required by Part 112 (commencing with Section 112.1)of Subchapter D of
<br /> Chapter I of Title 40 of the Code of Federal Regulations, including owners and operators of tank facilities not subject to the
<br /> general provisions in Section 112.1 of those regulations.An owner or operator specified in this subdivision shall conduct
<br /> periodic inspections of the storage tank to ensure compliance with Part 112 (commencing with Section 112.1)of Subchapter
<br /> D of Chapter I of Title 40 of the Code of Federal Regulations. In implementing the spill prevention control and countermeasure
<br /> plan, an owner or operator specified in this subdivision shall fully comply with the latest version of the regulations contained
<br /> in Part 112 (commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations.
<br /> CORRECTIVE ACTION: Immediately conduct all necessary integrity tests/inspections for the AG-8 tank based on industry
<br /> standards and per the adequately prepared SPCC plan. If the SPCC plan indicates that this tank shall be inspected using
<br /> FA0003747 PR0527478 SCO21 06/30/2021
<br /> Rev.9/16/2020 Page 3 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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