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State of California—California-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 /> gravel generated from sump cleanout. He said that the facility has a waste <br /> profile for the sump cleanout waste. None of the containers of the sump <br /> cleanout waste had lids or labels identifying it as a hazardous waste. We <br /> collected a sample from a can of sump cleanout waste (Sample ID TCS-04), <br /> however, the jar of sample was broken during shipment, and the lab was <br /> unable to test the waste. In a phone conversation I had with Reynon on <br /> January 9, 2019, he stated that the waste profile TCS used for the waste was <br /> one for sodium hypochlorite spills. According to the Generator Waste Profile <br /> for sodium hypochlorite spill cleanup (revised 11/1/2016) provided by Reynon <br /> on November 28, 2018, the US DOT Shipping Name for the waste is: <br /> UNI 759, corrosive solids n.o.s. (sodium hypochlorite), Class 8, PG-11. <br /> Corrective Action: Within 30 days of the date of this SOV, please provide <br /> photographic evidence and documentation to show that the sump cleanout <br /> waste (characterized as sodium hypochlorite spill clean-up) is routinely and <br /> properly stored as a hazardous waste. 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 /> 3. TCS violated Cal. Code Regs., §66260.200 and §66262.11; failure to determine <br /> that a waste is a hazardous waste, to wit: on November 28, 2018, 1 observed the <br /> following: <br /> A. During the facility walk-through, in the Empty Tote Storage Area outside, we <br /> observed four yellow, 5-gallon buckets of hydrotest wash water from <br /> hydrotesting compressed gas cylinders that previously held chlorine gas. <br /> The wash water in the buckets was rust-brown and contained solids. A pH <br /> strip indicated a pH of approximately 2. pH measurement of the collected <br /> DTSC 1565(11/12/2014) Page 5 of 6 <br />