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SANJ O 1` Q U I `IA,II, Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: LEGGETT& PLATT INC 2015 N MACARTHUR BLVD,TRACY March 15, 2019 Other Violations 4030 See below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS 4040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 4050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 301 CFR 112.5(a) Failed to amend Plan as necessary. The SPCC plan lists five 305 gallon tanks of dye as being operational equipment. Based on descriptions from facility personnels of how the tanks are used, the tanks are storing product and do not meet the definition of oil filled operational equipment. The SPCC plan does not address 55 gallon drums of used oil or"liquid oil sludge"which were observed in the maintenance area.A total of three'liquid oil sludge"drums where observed. The Spill Prevention, Control, and Countermeasure(SPCC) Plan must be amended when there is a change in the facility design, construction, operation,or maintenance that materially affects its potential for a discharge,within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. This is a minor violation. 602 CFR 112.7(a)(2)Plan failed to discuss equivalent environmental protection, if applicable. The Spill Prevention, Control, and Countermeasure(SPCC)failed to discuss alternative environmental protection requirements. The SPCC plan makes a claim of environmental equivalence to SPCC regulations which require visual inspections of ASTs(Aboveground Storage Tanks)combined with other testing techniques.The SPCC plan references the SPCC Guidance for Regional Inspectors Version 1.0 from November 18, 2005.The guidance document and regulation referenced in the SPCC plan have been updated and new language exists.The latest version of the SPCC Guidance for regional inspectors is dated December 16, 2013.The referenced regulation for integrity testing 112.8(c)(6)now reads, in part, "Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size, configuration, and design..."The SPCC plan does not identify the the industry standard for the tanks or if there is a deviation from the standard. Per the most recent version of the SPCC Guidance for Regional Inspectors"If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation,describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard."The current environmental equivalence does not satisfy the requirements of the regulations and/or guidance documents provided by the US EPA. If the SPCC Plan does not conform to the applicable requirements, the reasons for nonconformance must stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan. The SPCC Plan should include a discussion of equivalent environmental protection if deviating from SPCC regualtions. This is a Class II violation. FA0011063 PR0535642 SCO01 03/15/2019 EHD 28-01 Rev.09/27/2018 Page 4 of 6 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com