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SECTION 3.0: RECOMMENDATIONS IVES visited the Leggett & Platt facility on May 15, 2019 to collect information pertinent to preparing the SPCC Plan Amendment for the facility. In the course of the site visit, the following items were identified that must be addressed in order to fully comply with the applicable requirements set forth in 40 CFR Part 112, as revised on July 17, 2002 and including subsequent revisions to that amendment, and the California Aboveground Petroleum Storage Act (APSA) as codified in Section 25270 of the California Health and Safety Code. The "Items Requiring Attention" listed in the Recommendations table below should be addressed and implemented as soon as practicable but no later than 6 months from the date of this Plan Amendment. RECOMMENDATIONS Item Requiring Attention Recommendation The normal vent pipes on the Polyether Polyol and Industrial Oil ASTs are undersized. The vent pipes are 2" in diameter and the fill pipes are 3" in diameter. Normal vent pipe sizing on The ASTs are atmospheric tanks not designed to be pressurized. The vent pipes also the Polyether Polyol and are fitted with filters,which can clog over time, further reducing vent capacity. To Industrial Oil ASTs avoid over-pressurization of the ASTs during tank fills,the vent piping should be the same diameter as the fill pipe. It is recommended that the normal vent piping and vents be increased to 3" in diameter. Ref:40 CFR 112.8(c)(8) Emergency vents not Replace the short bolts on the menway covers for the 6,834-gallon ASTs with long operational ve Polyether bolts to allow the mamvay cover to lift and vent properly in the event of a fire. The Polyol and Industrial Oil replacement bolts should have a blank (unthreaded) shank of sufficient length to ASTs allow the lid to raise 1" even after bolt nuts have been completely tightened. Ref:40 CFR 112.8(c)(8) The steel IBC tanks (totes) in the Chemical Room are used in a stationary application to store carpet dye, a Class IIIb combustible liquid. Consequently, they are subject to the requirements of the California Fire Code (CFC) and National Fire Protection Association (NFPA) to provide emergency venting. The current IBCs do not meet these requirements. The facility indicated that they routinely change out the IBC tanks approximately every tree years.When changing out these tanks, replace them with ASTs that carry a UL 142 listing a certification to ensure they are equipped with the proper venting. IBC tanks that carry a UL 142 certification are commercially available but may require special order.Alternately,the IBCs could be replaced with shop-built containers meeting UL 142 standards a the existing IBCs IBC emergency venting could be repaired consistent with industry standards for the repair, alteration, and reconstruction of ASTs and then inspected and certified by a UL inspector as meeting UL 142 standards. Ref: 40 CFR 112.8(c)(8); CFC Section 5704.2.7.4; NFPA 30, Section 22.7.1.1.3 Now The portable IBC containers, when not being used in transportation service, are not required to meet the Department of Transportation (DOT) requirements for testing and inspection(e.g., 49 CFR 180.605 and 49 CFR 180.352); however,when in use at the facility, they must meet the AST inspection and testing requirements identified in this Plan Amendment. If/when these containers are returned to transportation service, they must meet all applicable DOT requirements prior to transportation reuse. SPCC P1anAm orhnc t Revision#I—Jure 2019 23 NR$Rm. Leggett&Mott,J.. NRS Project NmLber 1106EC4440.00 20157hbrth AfacAnh rWive, Tracy, Colifonda 95376