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State of California—Califomla Environmental Protection Agency =� <br /> SUMMARY OF VIOLATIONS <br /> Department of Toxic Substances Control <br /> Facility Name: Thatcher Company of California Date: 2/15/2019 <br /> Continuation Sheet for SECTION I <br /> NON - MINOR VIOLATIONS AND REQUIRED CORRECTIVE ACTION <br /> hazardous waste. Please include photographs showing the waste in proper <br /> containers with tightly-closed lids, with completed hazardous waste labels that <br /> contain an accumulation date, stored in the satellite storage area or <br /> hazardous waste storage area immediately after generation. <br /> B. During the facility walk-through in the Empty Tote Storage Area (outside, near <br /> the cooling towers), we observed a 330-gallon tote that had a corrosive <br /> placard on it with LIN number 1824 (for sodium hydroxide) and a hand-written <br /> sign saying, 'Please do not use; for B gas only'. The tote was almost half full <br /> of a solution that Reynon was a caustic.- Reynon stated that the - - - - <br /> solution had either come from the bi-gas tank or was going to the bi-gas tank; <br /> he was unsure of the contents. The solution was stored illegally because the <br /> container was not labeled with a proper hazardous waste label including <br /> information regarding hazardous properties and/or an accumulation date, to <br /> show how long the solution had been stored. A pH strip indicated a pH of <br /> approximately 14. pH measurement of the collected sample was determined <br /> by ECL-Berkeley to be approximately 12.95. (Sample ID TCS-07). <br /> Corrective Action: Within 30 days of the date of this SOV, please provide <br /> photographic evidence and documentation to show that the caustic solution <br /> related to the bi-gas tank is routinely properly stored as a hazardous waste, <br /> separate from incompatible materials. Please include photographs showing <br /> the waste in proper containers with tightly-closed lids, with completed <br /> hazardous waste labels that contain an accumulation date, stored in the <br /> satellite storage area or hazardous waste storage area immediately after <br /> generation. <br /> C. During the facility walk-through in the Acid Storage Area were three square <br /> rubber bucket/containers approximately three gallons in volume size full of dirt <br /> and gravel. The containers were black and had handhold holes in the sides <br /> near the top. Reynon stated that the rubber containers contained dirt and <br /> DTSC 1565(11/12/2014) Page 4 of 6 <br />