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State of California—California Environmental Protection Agency SUMMARY OF VIOLATIONS Department of Toxic Substances Control Facility Name: Thatcher Company of California Date: 2/15/2019 Continuation Sheet for SECTION I NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION the ground or into the sumps and other rinsates that are used for the non- NSF product. Please provide the following: L Written Standard Operating Procedures (SOPs) or training materials provided to employees with specific instructions for how to collect each of the separate spills, rinsates or sump materials. ii. Written SOPs or training materials provided to employees with specific instructions for how to introduce each of the separate spills, rinsates or sump materials into its intended process. iii. Written SOPs for each of the processes into which each of the separate spills, rinsates or sump materials is introduced, from its - - - - - introduction to the process,through to the final product.- iv. Photographs of product containers for each of the products. V. Shipping documents for each of the products showing where they are shipped, if they are shipped somewhere other than directly to a customer. vi. Shipping documents for each of the products for shipment to the customers, with attached copies of invoices or bills of sale. B. During the facility walk-through in the Powell Room/Bleach Manufacturing Room, there was,a blue plastic rectangular container under a pump adjacent to the Sodium Hypochlorite Scrubber tank. The container held a liquid. A pH strip indicated an approximate pH of 14. pH measurement of the collected sample was determined by ECL-Berkeley to be approximately 12.87. The container was open, with no lid or label (Sample ID TCS-08). Reynon stated that this solution is from the sodium hypochlorite tank and is returned to the bleach manufacturing process. Corrective Action: Within 30 days of the date of this SOV, to minimize the possibility of release and exposure to workers, please provide photographic evidence that the sodium hypochlorite solution in the blue plastic rectangular container described above is routinely managed to minimize release and protect workers from the hazardous characteristics of the sodium hypochlorite DTSC 1565(11/12/2014) Page 2 of 6