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SANdOAQUIN <br />i:• COUNTY <br />Greatness grows here. <br />November 15, 2021 <br />Reid Collier <br />Regional Tank Lead <br />Shell Training & Supply <br />20945 S. Wilmington Ave, <br />Carson, CA 90810 <br />Environmental Health Department <br />Jasjit Kang, REHS, Director <br />Muniappa Naidu, 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 />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 This violation was rescinded.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 per the Steel Tank Institute (STI) <br />standard as a Category 1 tank; this statement was not dated. Mr. Beutler's statement <br />indicated that: "at the time of this inspection, API 653 inspection standard was utilized <br />for inspection purposes. It should be noted that the data and inspection techniques, <br />Visual (VT) inspection and Ultrasonic (UT) inspection of these tanks to meet API 653 <br />current standard could be utilized to meet STI SP001 requirements." The API and the <br />STI certifications for David Udonsen (not Raymond Beutler) were included with the most <br />recent submittal. <br />The PE (or the STI SP001 inspector) shall categorize the GA -8 tank according to the <br />elected STI standard and establish its inspection schedule, which must be made part of <br />the SPCC plan. Provide a return to compliance documentation or further documentation <br />in support of this violation dispute, indicating that the API -653 inspection report dated <br />March 2, 2015, satisfies the minimum requirement of the STI SP001 industry standard, <br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/ehd <br />