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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 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 603 CFR 112.7(a)(3)Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram does not identify the storage area where mobile or portable containers are located. 55 gallon drums of dyes outside of the chemical room are not identified on the facility diagram. 55 gallon drums of new oil and "liquid oily sludge", described to be waste oil by facility personnel, located in the maintenance area were not identified in the facility diagram. The Spill Prevention, Control, and Countermeasure(SPCC)Plan shall include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as"exempt" underground tanks. It must also include all transfer stations and connecting pipes, including intra-facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit a legible copy of the updated facility diagram to the EHD for review. This is a Class II violation. 710 CFR 112.8(c)(6)Plan failed to adequately discuss procedures to test or inspect each container for integrity. Table 1 "Tank Test Category", note 4, states that some of the tanks will be inspected under the Steel Tank Institutes (STI)SP001 standard. The note on the table indicates that the tanks that fall under the inspection criteria of the ST-001 standard need monthly inspections but does not reference annual inspections required by the standard. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site.The SPCC plan should address all requirements from applicable standard and not deviate from the standard, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. 718 CFR 112.8(c)(11) Failed to locate properly or provide sufficient secondary containment for mobile/portable containers. A 55 gallon oil container was observed with insufficient secondary containment. The 55 gallon drum in the maintenance area was observed by roll up door. The door did not have a berm or other method of containing the oil from escaping the building in the case of a release.The SPCC plan describes the building as secondary containment for this area. Other drums were observed on secondary containment pallets. Portable oil storage containers must be positioned or located to prevent a discharge and shall be furnished with a secondary means of containment sufficient to contain the capacity of the largest single container with sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other portable containers at this facility, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, by April 14, 2019. FA0011063 PR0535642 SCO01 03/15/2019 EHD 28-01 Rev.09/27/2018 Page 5 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