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6 <br />Thanks so much for providing further interpretation of "storage incident to transportation." Notice to develop an RMP <br />will be distributed. Alternative procedures may be discussed and implimented. <br /> <br />Thank you, <br /> <br />Ed <br /> <br />Edward McNair <br />Environmental Protection Specialist <br />DLA Installation Support at San Joaquin <br />Phone: (209) 839-5539 <br />Mobile: (209) 507-1432 <br />DSN: 462-5539 <br />Fax: (209) 839-4949 <br /> <br /> <br />-----Original Message----- <br />From: Raymond von Flue [EH] [mailto:rvonflue@sjcehd.com] <br />Sent: Thursday, December 17, 2015 4:21 PM <br />To: McNair, Edward DLA CIV DISTRIBUTION SAN JOAQUIN, CA <br />Cc: Thornton, Chris J DLA CIV INSTALLATION SUPPORT; Kasey Foley [EH]; Linda Turkatte [EH]; <br />lawrence.kathryn@epa.gov; Angie Proboszcz (PROBOSZCZ.ANGIE@EPA.GOV) <br />Subject: [Non-DoD Source] Notice to develop and submit a Risk Management Plan for the CalARP Program for Defense <br />Distribution Depot of San Joaquin, 25600 S. Chrisman Rd., Tracy CA <br /> <br />Ed, <br /> <br /> <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 t o 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 />