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1 <br />Raymond von Flue [EH] <br />From:Raymond von Flue [EH] <br />Sent:Thursday, December 17, 2015 4:21 PM <br />To:Edward.McNair@dla.mil <br />Cc:'chris.thornton@dla.mil'; Kasey Foley [EH]; Linda Turkatte [EH]; <br />lawrence.kathryn@epa.gov; Angie Proboszcz (PROBOSZCZ.ANGIE@EPA.GOV) <br />Subject:Notice to develop and submit a Risk Management Plan for the CalARP Program for <br />Defense Distribution Depot of San Joaquin, 25600 S. Chrisman Rd., Tracy CA <br />Attachments:Notice to develop an RMP.pdf <br />TrackingTracking:Recipient Delivery <br />Edward.McNair@dla.mil <br />'chris.thornton@dla.mil' <br />Kasey Foley [EH]Delivered: 12/17/2015 4:21 PM <br />Linda Turkatte [EH] Delivered: 12/17/2015 4:21 PM <br />lawrence.kathryn@epa.gov <br />Angie Proboszcz (PROBOSZCZ.ANGIE@EPA.GOV) <br />Garrett Backus [EH] Delivered: 12/17/2015 4:21 PM <br />Muniappa Naidu [EH] Delivered: 12/17/2015 4:21 PM <br />Michelle D. Henry [EH] Delivered: 12/17/2015 4:21 PM <br />Ed, <br /> <br />I wanted to reiterate our phone conversation today. The Chlorine is received at the facility 1 to 2 times per year. The <br />Chlorine is supposed to be shipped directly to the port for transportation by ship. You are in the process of making <br />administrative changes so that the Chlorine is never shipped directly to the depot in the future. I went over our <br />interpretation of what qualifies for the exemption from being a stationary source because of storage incident to <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 <br />transportation. Therefore this facility has been determined to meet the definition of a stationary source and the storage <br />of Chlorine is a covered process since it exceeds the threshold quantity of 100 lbs. <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 />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 />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.