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#711 in the SJC EHD 9/9/21 Amended Report The text pasted in blue below is copied from the above referenced SJC EHD report Observations. Shell's response addressing these observations is in black text below. On page 3-3 of the reviewed SPCC plan indicates, "All internal or external tank inspections are certified in appropriate licensing, or meet required industry qualifications such as API -653, STI, or OQ requirements. The frequency of all tank and vessel testing and inspection processes/procedures follow applicable API or STI requirements and have been reviewed as appropriate by the facility. Please refer to the Shell Pipeline Company LP, (SPLC), Tank and Pressure Vessel I & M Manual for further documentation of Shell's policies, procedures and requirements." Table A-2 of the same SPCC plan lists the following information for tank AG -8: "Gasoline Additive, [...j, Integrity Testing Method - External & Internal (Note 1) - Refers to tank integrity testing methods that include recommended industry standards (i.e. API 653, etc.)" No additional schedule or standard specifics (including STI reference) was noted on this table in connection with integrity inspections/testing specifics. Furthermore, although both API and STI standards are listed in the SPCC plan, the SPCC plan doesn't specify which standard will be used for which tank and how often all onsite tanks will be tested. Shell's response: As noted above, the facility SPCC plan which is PE certified as adequate in meeting regulatory requirements, describes inspection qualifications, based on indicated standards, as well as testing and inspection frequency following API 653 or STI, with reference to procedures in the `I&M Manual'. The I&M manual references were previously provided to SJC EHD for review (8/6/21 emailed response). SJC EHD was also provided a copy of Table A-2 where the foot note referenced in the observation above, had been expanded, although as noted by the observation above this information was already in section 3.2 of the SPCC plan. The Shell Pipeline Company LP, (SPCC), Tank and Pressure Vessel I & M Manual (I&MM), as referenced in the SPCC plan, details facility policies, procedures, and requirements. Although the facility has a separate table, "Stockton Tank Database" (table), which lists past and future tank inspections schedule, this table was not included in the reviewed SPCC plan. Shell's response: The Table `Stockton Tank Database' was provided to SJC EHD previously, most recently 8/6/21 email to SJC EHD. Tank AG -8 was last inspected using API -053 standard on March 2, 2015. Per the 2015 API inspection report, the next formal API -653 external inspection for this tank 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 June 25, 2021 with regards to the AG -8 tank testinglinspection standard, Richard Bronson indicated: "The SPCC incorrect, changed to STI in 2015." This change from API to STI has not been reflected in the reviewed SPCC plan. Shell's response: The documentation for the testing and inspecting of AG -8 has been previously provided to S1C EHD, including the change from API 653 to STI. The response to item #713 in this report provides further elaboration and fully documents compliance with this item.