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Thatcher Company.-Stockton <br /> Inspection Date:07/25/2019 <br /> chlorine flow. In addition, the written procedures do not specify the assignment of shutdown <br /> responsibility to qualified operators. <br /> Mechanical Integrity 40 CFR § 68.73 <br /> Sprocket is a work order system that houses the facility's mechanical integrity records. Thatcher <br /> converted to this system around May of 2018. Prior to May of 2018 they were using an Excel- <br /> based mechanical integrity system. <br /> EPA reviewed the calibration records for the SO2 and C12 sensors at the facility. Thatcher's <br /> PMMI procedures designates a semi-annual (6 months) frequency for gas sensor maintenance. <br /> The manufacturer of the sensor, Drager, also set a default calibration interval of 6 months. <br /> Records for chlorine sensors indicate the most recent calibration was conducted on August 30, <br /> 2018. Prior records of chlorine sensor calibration were from September 16, 2015. The time <br /> between calibrations was over 35 months, far exceeding the 6 month manufacturers' <br /> recommendation. <br /> The EPA inspector requested inspection records for valves in chlorine system. Thatcher's <br /> Preventative Maintenance Mechanical Integrity (PMMI) Procedure for chlorine transfer <br /> operations designates the frequency at which tests and inspections should be performed on <br /> specific types of equipment. Documentation was not available for inspection and testing of <br /> actuators (chlorine control valves (CCV)). EPA specifically requested inspection and testing <br /> history for CCV-4B during the inspection. Thatcher's PMMI calls for an inspection or <br /> reponacement per Chlorine Institute's Pamphlet 60. <br /> EPA also requested documentation on inspection and testing history for chlorine piping. <br /> Thatcher personnel indicated that non-destructive testing had not been performed on chlorine <br /> piping. Documentation of visual inspections of chlorine piping was not provided. PM281ST-301 <br /> is Thatcher's written procedure for visual inspection of chlorine piping systems and PM281ST- <br /> 302 is the procedure for non-destructive testing of piping systems. During the EPA inspection, <br /> external corrosion and paint coating failure was observed on chlorine piping in the Powell Room. <br /> Compliance Audits 40 CFR § 68.79 <br /> EPA requested the two most recent compliance audits. EPA received and reviewed a compliance <br /> audit from April 2015. At the time of the EPA inspection, the most recent compliance audit was <br /> performed in April 2015 (four years ago). In addition, Thatcher failed to document that <br /> deficiencies from the April 2015 compliance audit have been corrected. <br /> Incident Investigation 40 CFR § 68.81 <br /> EPA requested all incident investigations conducted within the past 5 years. <br /> Emergency Response Program 40 CFR § 68.95 <br /> EPA received and reviewed the facilities Emergency Action Plan and Emergency Response Plan. <br /> 5 <br />