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2 <br />transportation. The standard operating procedure CG-01 Chlorine Gas that was emailed earlier states that chlorine is <br />only stored under emergency circumstances temporarily in building 238 and "Every attempt must be made to process <br />and ship the transshipped chlorine gas the same day its received". Also you stated in an email that this facility removes <br />the chlorine cylinders from the truck trailer and stores them in building 238 which is setup with monitoring and <br />ventilation for a maximum of 15 days. USEPA has a guidance document regarding general applicability that states if the <br />motive power is still attached to a trailer, the truck and its contents are considered to be in transportation. Since the <br />cylinders are removed from the motive power they are no longer considered to be in storage incident to transportation. <br />Therefore this facility has been determined to meet the definition of a stationary source and the storage of Chlorine is a <br />covered process since it exceeds the threshold quantity of 100 lbs. <br /> <br /> <br /> <br />Please review the attached Notice to Develop and Submit a Risk Management Plan (RMP), which will also be sent by <br />certified mail. A RMP would need to be developed, implemented and reviewed no later than the date on which the <br />regulated substance is fire present above the threshold quantity. <br /> <br /> <br /> <br />If the standard operating procedure is revised and administrative changes are made to ensure that the Chlorine remains <br />in transportation by staying with the motive source or by not receiving it at the facility in quantities above the threshold <br />quantity, then a RMP would not be required to be developed. <br /> <br /> <br /> <br />Please provide documentation for how the Defense Distribution Depot of San Joaquin will proceed with returning to <br />compliance for these requirements by January 17, 2016. <br /> <br /> <br /> <br />If you have any questions, please contact me at your earliest opportunity. Thank you. <br /> <br /> <br /> <br /> <br /> <br />Raymond von Flüe <br /> <br />San Joaquin County <br /> <br />Environmental Health Department <br /> <br />Lead Sr. REHS, CUPA Programs <br /> <br />1868 E. Hazelton Ave. <br /> <br />Stockton, CA 95205 <br /> <br />(209) 468-9848 <br /> <br /> <br />