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Thatcher Company.-Stockton Inspection Date:07/25/2019 Supervisor Review: Signature Date ZZ USEPA Manager, Hazardous 415-972-3306 Kaoru Morimoto Waste and Chemical Section SECTION I—INTRODUCTION Purpose of the Inspection Objective The purpose and scope of US EPA's inspection was to evaluate Thatcher Company's implementation of their requirements under the CAA Section §112(r) Risk Management Plan (RMP) Rule and compliance with the requirements under EPCRA Sections §§ 302-312 and CERCLA Section § 103. The inspection was announced to facility representatives on July 15, 2019 and employee representatives were encouraged to participate in all meetings, interviews, and discussions. This report documents the US EPA inspection. The following narrative includes a general description of the facility and documents the compliance review of the facility's programs to address CAA § 112(r), EPCRA non-313, and CERCLA § 103 regulatory provisions. This report also identifies Areas of Concern (AOC), which are not necessarily formal compliance determinations or violations. Likewise, the lack of an AOC does not necessarily indicate full compliance with the regulatory provisions of CAA § 112(r), EPCRA non-313, and CERCLA § 103. Opening Conference The opening conference included the EPA inspector, two representatives from the CUPA(San Joaquin Environmental Health Dept.), and facility representatives. The EPA inspector presented credentials to facility representatives. The Notice of Inspection form and Confidential Business Information (CBI) form was provided to facility representatives for acknowledgement and signature. The EPA inspector explained that the inspection included both a records review and a facility walk through. Facility/Site Description Thatcher Company's facility is located at 1010 Industrial Drive, Stockton, CA. Thatcher produces and distributes chemicals used in water purification in the municipal, agricultural, mining, and industrial markets. Example customers include water treatment plants, wineries, water parks, and commercial swimming pools. Thatcher receives chlorine by railcar and repackages it into 34,000-1b trucks, 1-ton cylinders, and 150-1b cylinders. Thatcher also produces industrial strength bleach: 12.5% to 13% NaOCI, which is packaged into tankers, 275- or 350- gallon totes, drums, and 1-gallon bottles (in boxes of four). Thatcher receives 50% concentration sodium hydroxide used in the bleach manufacturing process, and to repackage at a 20% 2