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5.6.1 <br />P:=Penodk'AST inspection <br />Refer to Section 6 <br />6.6.2 <br />E-- Formal external inspection: by certified Inspector: <br />Refer to Section 7 <br />5.6.3 <br />1— Formal internal inspection by certified Inspector <br />Refer to Section 8 <br />6.5.4 <br />L — leak test by owner or owner's designee <br />Refer to Section 9 <br />6.6.6 <br />( ) Indicates maximum inspection interval In years. For <br />example, E (6) Indicates formal external <br />inspection every 6 years. <br />TABLE 5.5 TABLE OF INSPECTION SCHEDULES <br />AST Type and Size (U.S. gallons) <br />Category 1 <br />Category 2 <br />Category 3 <br />0-1100 <br />(0-4164 liters) <br />P <br />P <br />P,E&L(10) <br />1101 - 6,000 <br />(P, E&L(5), 1(10)) <br />(4168.1 8,927 liters) <br />P <br />P, E&L(10) <br />or <br />P, L 2 E(6)] <br />Shop <br />-Fabricated ASTs <br />, <br />(P, E(100), 1(20)) <br />(P, E&L(05), I(10)) <br />6;001:.:30;000 <br />PiE 20) <br />(18 t931.113,662 liters) <br />P,E 6,L10) <br />P,L1,E6) <br />30,001 -50,000 <br />(113,566.1891271 liters) <br />P, E(20) <br />P, E&L(6), 1(16) <br />Portable Containers <br />P <br />P <br />P" <br />Based on the EHD's discussion with the Steel Tank Institute (STI) engineer, the SP001 certified inspector <br />needs to evaluate the last API -653 inspection report for the AG -8 tank and provide a determination if it <br />meets all of the requirements of the STI SP001 standard. If the API -653 inspection did not meet the STI <br />SP001 standard (for example, if the liquid in secondary and primary containment was not evaluated, or <br />emergency and regular vents adequacy and functionality were not addressed in the API report, etc.,) <br />according to the STI, the API -653 inspection dated March 2, 2015 would not meet the minimum <br />requirements of the SP001 inspection standard, and tank AG -8 would not have been inspected as <br />required per the STI industry standards in 2015, impacting the timeframe forthe next SP001 inspection. <br />Furthermore, the STI engineer indicated that the SP001 inspector must determine what tank category <br />AG -8 is and set its future inspection schedule as part of their evaluation. This is further supported by the <br />Shell Pipeline Company LP (SPLC), Tank and Pressure Vessel I&M Manual (page 9.3-2, which outlines the <br />procedure for small diameter tank inspections). Page 9.3-2 of this manual requires establishing the <br />inspection frequency for each tank basis tank type, tank size, corrosion rates, and inspection history. <br />Provide a written determination by a Certified Inspector (STI, SP001) if the API -653 inspection report <br />dated March 2, 2015, satisfies the minimum requirement of the STI SP001 industry standard and provide <br />a schedule for the next formal internal and external inspection by a certified inspector. The SPCC Plan <br />shall also adequately discuss procedures to test and inspect aboveground/bulk storage containers <br />according to all applicable. <br />Please reference the attached STI category <br />assessment for AG -8. Note the below items to address the <br />above comments. <br />® Attached letter categorizes Tank AG -8 as a Category 1 tanks. <br />® David Udosen was a certified inspector for STI and API 653 during the inspection in 2015 and <br />his Certs are included within the assessment letter. <br />