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Thatcher Company.-Stockton Inspection Date:07/25/2019 ILA—FIELD OBSERVATIONS The EPA inspector conducted a walkthrough of the chlorine process,the sulfur dioxide storage area, and the warehouse. • Field walkdown of P&ID for chlorine railcar spot#9 • 7 chlorine railcars onsite at the time of the inspection with the capacity for 10 railcars • Observed hoses at the chlorine filling stations • Observed gas sensors and placement/location of sensors • Observed corrosion and paint coating failure on chlorine lines in the Powell Room • Observed chlorine scrubber and activation switch • 4 SCBAS and masks in warehouse area ILB —DOCUMENTATION REVIEW Hazard Assessment 40 CFR §§ 68.20-42 The RMP submission includes a worst case scenario(WCS) and alternate release scenario (ARS) offsite consequence analysis (OCA) for both sulfur dioxide and chlorine.Thatcher used the Hazard Prediction and Analysis Capability (HPAC) Model Scenarios from the Chlorine Institute Pamphlet 74, Edition 6, to perform the WCS and ARS OCA modeling for chlorine. On September 12, 2017, the Chlorine Institute (CI) suspended publication of Pamphlet 74 pending a completed review of the results from the Jack Rabbit II field testing and modeling work, performed by the Department of Homeland Security Chemical Security Analysis Center (CSAC) under contract to the Chlorine Institute. Thatcher provided a revised draft WCS for chlorine but had not officially submitted the WCS at the time of the EPA inspection. In this revised RMP submission, Thatcher used RMPComp* instead of the suspended Cl Pamphlet 74. Process Safety Information 40 CFR § 68.65 The EPA inspector conducted a walkdown of the P&ID including chlorine railcar spot#9. The EPA inspector observed the manufacture date printed on the hoses associated with the chlorine_ fill stations to be 3/28/19. Process Hazard Analysis 40 CFR § 68.67 The EPA inspector requested the most recent PHA, including recommendations and tracking, as a follow-up to the inspection. Operating Procedures 40 CFR § 68.69 The EPA inspector reviewed the emergency shutdown procedures for the chlorine system. Written procedures provided at the time of the EPA inspection did not mention manual activation of the chlorine scrubber system or the switch panel to activate the actuators, which can cut 4