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Thatcher Company.-Stockton <br /> Inspection Date: 07/25/2019 <br /> testing of actuators (chlorine control valves (CCV)). EPA specifically requested <br /> inspection and testing history for CCV-4B during the inspection. Thatcher's <br /> PMMI calls for an inspection or reponacement per Chlorine Institute's <br /> Pamphlet 60. <br /> EPA also requested documentation on inspection and testing history for chlorine <br /> piping. Thatcher personnel indicated that non-destructive testing had not been <br /> performed on chlorine piping. Documentation of visual inspections of chlorine <br /> piping was not provided. PM281ST-301 is Thatcher's written procedure for visual <br /> inspection of chlorine piping systems and PM281ST-302 is the procedure for non- <br /> destructive testing of piping systems. During the EPA inspection, external <br /> corrosion and paint coating failure was observed on chlorine piping in the Powell <br /> Room. <br /> Mechanical.Integrity, 40 CFR§68.73 <br /> (d)(3) The frequency of inspections and tests of process equipment shall be consistent with <br /> applicable manufacturers' recommendations and good engineering practices, and more <br /> frequently <br /> AOC 4: Thatcher failed to calibrate their chlorine sensors at a frequency consistent with <br /> manufacturers' recommendations and the company's internal written procedures. <br /> Thatcher's PMMI procedures designates a semi-annual (6 months) frequency for <br /> gas sensor maintenance. The manufacturer of the sensor, Drager, also set a default <br /> calibration interval of 6 months. Records for chlorine sensors indicate the most <br /> recent calibration was conducted on August 30, 2018. Prior records of chlorine <br /> sensor calibration were from September 16, 2015. The time between calibrations <br /> was over 35 months, far exceeding the 6 month manufacturers' recommendation. <br /> Compliance Audits, 40 CFR §68.79 <br /> (a) The owner or operator shall certify that they have evaluated compliance with the provisions <br /> of this subpart at least every three years to verify that procedures and practices developed under <br /> this subpart are adequate and are being followed <br /> AOC 5: Thatcher failed to conduct a compliance audit under this subpart at least every <br /> three years. At the time of the EPA inspection, the most recent compliance audit <br /> was performed in April 2015. <br /> Compliance Audits, 40 CFR §68.79 <br /> (d) The owner or operator shall promptly determine and document an appropriate response to <br /> each of the findings of the compliance audit, and document that deficiencies have been <br /> corrected. <br /> AOC 6: Thatcher failed to document that.deficiencies from the April 2015 compliance <br /> audit have been corrected. <br /> 7 <br />