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Thatcher Company. -Stockton Inspection Date: 07/25/2019 SECTION III—AREAS OF CONCERN (AOC) The presentation of areas of concern does not constitute a formal compliance determination or violation. CAA § 112(r) RMP DOCUMENTATION Worst-Case Release Scenario Analysis, 40 CFR § 68.25 (g)Parameters to be applied. The owner or operator shall use the parameters defined in 68.22 to determine the distance to endpoints. The owner or operator may use the methodology provided in the RMP Offsite Consequence Analysis Guidance or any commercially or publicly available air dispersion modeling techniques,provided the techniques account for the modeling conditions and are recognized by industry as applicable as part of current practices. AOC 1: Thatcher failed to correct their WCS which 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. Operating Procedures, 40 CFR § 68.69 (a)(1)(iv) The owner or operator shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements...emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a same and timely manner. AOC 2: Thatcher failed to provide clear instructions for the emergency shutdown of 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 chlorine flow. In addition, the written procedures do not specify the assignment of shutdown responsibility to qualified operators. Mechanical Integrity,40 CFR § 68.73 (d)(4)Inspection and testing. The owner or operator shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. AOC 3: Thatcher failed to document inspections and tests in accordance with written company policies and procedures. Thatcher's Preventative Maintenance Mechanical Integrity (PMMI) Procedure for chlorine transfer operations designates the frequency at which tests and inspections should be performed on specific types of equipment. Documentation was not available for inspection and 6