COMPLIANCE INFO_2021 - Laserfiche WebLink

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For the write up below: Black text is copied from Elena Manzo 9/9/21 email of the amended report. Blue text is Shell's response to respective item. 1. Violation 712 (EHD's checklist was recently updated, now it's violation This violation was written because the facility failed to test or inspect each container for integrity based on industry standards. Specifically, failing to implement a formal inspection for tank AG -8 by March 2020 per API -653 report recommendation). The facility indicated that this inspection didn't need to be Yes, the above statement in gray is still accurate for Tank AG -8, AG -1Q and AG -47 based on the attached determination by the certified inspector, David Udonsen: Please note this is the same inspector that performed the API 653 External Inspection for Tank AG -8 on March 2, 2015, The Shell Pipeline Company LP, (SPCC), Tank and Pressure Vessel I & M Manual, Page 9.3-2 (referenced in the SPCC plan) lists out the procedure for inspection of small diameter tanks, specifically indicating that the following procedures must be followed: "1. Conduct evaluation to categorize the tank in accordance with STI SP001. 2. Establish the inspection frequency for each tank basis tank type, tank size, corrosion rates and inspection history." Since no inspection by a certified STI inspector was conducted The above statement is not accurate and this information was never requested for review during the audit or as a follow-up item. Reference the attached pdf which captures this assessment classifying Tank AG -8 as STI Category 1 tanks and per STI Table 5.5 these tanks require Periodic (P) inspections and a 20 year formal External Inspection (E). Therefore, as shown in the previously provided spreadsheet the next formal External Inspection on AG -8 is March 2, 2035. 1 have circled the relevant items below and attached the pdf for ease of review. Based on the current schedule listed in the "Stockton Tank Database" (table), these requirements will not be met until 2035 for the next onstream inspection and never for the next offstream inspection (since no offstream inspection schedule is provided for this tank in the above table). For Category #1 tanks per STI Table 5.5 there is no requirement to remove the tank from service to perform an "offstream" inspection. Therefore, the "Stockton Tank Database" does reflect a date for the next offstream inspection and is compliant with the STI regulations. syxaw ID RRV�Am Is so At AMU Based on the current schedule listed in the "Stockton Tank Database" (table), these requirements will not be met until 2035 for the next onstream inspection and never for the next offstream inspection (since no offstream inspection schedule is provided for this tank in the above table). For Category #1 tanks per STI Table 5.5 there is no requirement to remove the tank from service to perform an "offstream" inspection. Therefore, the "Stockton Tank Database" does reflect a date for the next offstream inspection and is compliant with the STI regulations.