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Thatcher Company.-Stockton <br /> Inspection Date: 07/25/2019 <br /> concentration. Thatcher receives tankers of hydrochloric acid that it repackages into totes, drums, <br /> and 1-gallon bottles (in boxes of four). Thatcher also receives 1-ton cylinders of sulfur dioxide <br /> (SO2) from their Sparks, Nevada plant. The SO2 1-ton cylinders are stored and then pass through <br /> Thatcher's Stockton plant as part of their distribution chain but are not repackaged at this <br /> location. <br /> Thatcher's production rates vary seasonally. Thatcher is busier during the summer and operates <br /> two shifts per day: 07:30 pm- 04:00 am and 04:00 am— 12:30 pm. Thatcher maintains nine <br /> operators that work in the chlorine covered process area. The nine operators are full-time (not <br /> temporary) employees. <br /> The RMP submission includes a worst case scenario (WCS) and alternate release scenario (ARS) <br /> offsite consequence analysis (OCA) for both sulfur dioxide and chlorine. Thatcher used the <br /> Hazard Prediction and Analysis Capability (HPAC) Model Scenarios from the Chlorine Institute <br /> Pamphlet 74, Edition 6, to perform the WCS and ARS OCA modeling for chlorine. On <br /> September 12, 2017, the Chlorine Institute suspended publication of Pamphlet 74 pending a <br /> completed review of the results from the Jack Rabbit II field testing and modeling work <br /> performed by the Department of Homeland Security Chemical Security Analysis Center (CSAC) <br /> under contract to the Chlorine Institute. <br /> The facility RMP was submitted on December 10, 2015 as a resubmission due to regulated <br /> substance present above threshold quantity in a new or not previously covered process. The next <br /> RMP submittal is due December 10, 2020. The facility has two Program Level 3 RMP-covered <br /> processes: one for chlorine and one for sulfur dioxide (anhydrous). <br /> RMP Chemicals: <br /> Process Process Program Chemical Mame ► CAS Quantity C91 Flammable; <br /> ID + Chemical Number Ubs? C Claimed : Toxic r <br /> ID p <br /> 1000067085 1000082872 3 Chlorine 7782-50-5 1,870,000 Toxic <br /> 10000671 45 1000082933 3 Sulfur dioxide 74467-'19-5 90,000 Toxic <br /> (anhydrous) <br /> SECTION II—OBSERVATIONS <br /> The inspection covered RMP elements in 40 C.F.R. Part 68 and included both document review <br /> and a facility walkthrough. The following observations were made by the EPA inspector based <br /> on the review of documentation and the facility walkthrough. <br /> 3 <br />