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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 16s. <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 /> 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 /> 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 /> If you have any questions, please contact me at your earliest opportunity. Thank you. <br /> JAN 19 2016 <br /> ENVIRONMENTAL <br /> Raymond von Flue <br /> San Joaquin County <br /> Environmental Health Department <br /> Lead Sr. REHS, CUPA Programs <br /> 1868 E. Hazelton Ave. <br /> Stockton, CA 95205 <br /> i <br /> (209)468-9848 <br /> 2 <br />