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a'" Environmental Health Department <br /> c SAN JOAQUIN <br /> COUNTY Jasjit Kang , REHS , Director <br /> Cireotness grows here . MuniappaNaidu , REHS, Assistant Director <br /> PROGRAM COORDINATORS <br /> Robert McClellon , REHS <br /> Jeff Carruesco , REHS , RDI <br /> Willy Ng , REHS <br /> Melissa Nissim , REHS <br /> Steven Shih , REHS <br /> November 15 , 2021 <br /> Reid Collier <br /> Regional Tank Lead <br /> Shell Training & Supply <br /> 209 S Wilmington Ave , <br /> Carson , CA 90810 <br /> RE : Violation Dispute for Shell Oil Products US - Stockton Terminal Facility Located at <br /> 3515 Navy Drive , Stockton , CA <br /> The Environmental Health Department ( EHD ) reviewed your response and supporting <br /> documentation to the in -office inspection report dated June 30 , 2021 , and the request to rescind <br /> all report violations dated October 7 , 2021 . <br /> 1 ) Violation 711 ( CFR 112 . 8 ( c) ( 6 ) ) : The facility provided supporting information that <br /> indicated that the Spill Prevention Control and Countermeasure Plan ( SPCC ) along with <br /> the referenced onsite Tank and Pressure Vessel I & M Manual ( I & MM ) , which included <br /> the " Stockton Tank Database " (table ) as its official attachment , adequately discussed the <br /> procedures to test or inspect each above ground storage container for integrity , in <br /> accordance with applicable industry standards . This violation was rescinded . <br /> 2 ) Violation 713 ( CFR 112 . 7 (f) , 112 . 8 ( c ) ( 6 ) : The facility provided a written statement , <br /> signed by Raymond Beutler (American Petroleum Institute (API ) 653 , API 570 , and API <br /> 510 certified inspector) , which classified tank AG - 8 as a Category 1 tank ; this statement <br /> was not dated . Mr . Beutler' s statement indicated that : " at the time of this inspection , API <br /> 653 inspection standard was utilized for inspection purposes . It should be noted that the <br /> data and inspection techniques , Visual (VT) inspection and Ultrasonic ( UT) inspection of <br /> these tanks to meet API 653 current standard could be utilized to meet STI SP001 <br /> requirements . " The API and the Steele Tank Institute ( STI ) certifications for David <br /> Udonsen ( not Raymond Beutler) were included with the most recent return to <br /> compliance . <br /> Provide a return to compliance documentation or further documentation in support of this <br /> violation dispute , indicating that the API -653 inspection report dated March 2 , 2015 , <br /> satisfies the minimum requirement of the STI SP001 industry standard (for example , a <br /> professional engineer ( PE ) or an STI SP001 certification for Raymond Beutler or a <br /> statement by David Udonsen ( or a statement by a PE that certified the SPCC plan ) . The <br /> 1868 E . Hazelton Avenue Stockton , California 95205 1 T 209 468 -3420 F 209 464-0138 1 www. sjgov. org/ehd <br />