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- State of California-California Environmental Protection Agency _�t.-.✓ Department of Toxic Substances Control 5796 Corporate Ave. Cypress, CA 90630-4732 SUMMARY OF VIOLATIONS Facility Name: Thatcher Company of California, Inc. Date: 2/15/2019 SECTION I: NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION (Violations not considered Minor Violations) You must correct the following.violation(s) within the specified time frame for each violation. 1. Thatcher Company of California, Inc., Stockton (TCS) violated Califomia Code of Regulations (Cal. Code Regs.), title 22, §66262.10(h), 66262.34(a)(4), 66265.31, failure to minimize the possibility of a fire, explosion or any unplanned sudden, or non-sudden release of hazardous waste or hazardous waste constituents to the air, sail, or surface wafer which could threaten human health and the environment, to wit: on November 28, 2018, 1 observed the following: A. During the facility walk-through, in the Bleach Filter Area outside, sodium hypochlorite was leaking from a pipe into secondary containment (a raised, bermed area around the pipes and tanks). Facility staff did not know how long the pipe had been leaking, nor had they taken steps to fix the leak or contain the leaking solution. A pH strip measured the pH of the solution at 13-14. pH measurement of the collected sample was determined by ECL- Berkeley to be approximately 12.77. The sample was also determined to be hazardous in the Fish Bioassay (Method: CDFGP&M 1988) (Sample ID TCS- 05). Employees who work in the area are exposed to fumes from these solutions; the fumes are also released to the air. Reynon stated that leaks in this area were collected and put into a process for non-NSF certified product. During our investigation, there was an above ground tank on-site holding hundreds of gallons of non-NSF material that, if it cannot be sold, is a waste. Corrective Action: Within 30 days of the date of this SOV, to minimize the possibility of release and exposure to workers, please provide photographic and/or documentary evidence to show that the sodium hypochlorite solution is routinely managed such that there is no possibility of release of sodium hypochlorite solution and fumes to the environment by wind or rain or other elements, and there is no exposure to workers. Also within 30 days of the date of this SOV, please provide adequate documentation to show that there is a market for the materials that spill onto