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Thatcher Company of California, Inc., 2/15/2019 Observed a drum containing waste oil, an See Attachment 6, Photo#'s 17-19 unlabeled drum containing waste from a Hazardous Waste sulfuric acid spill, and two boxes of Universal Storage Area Waste fluorescent lamps Additional Important observations/information regarding inspected areas: Prior to the walk-through of the facility, Reynon asked DTSC and CUPA inspectors to sign a Visitor Safety form, which we all did (see Attachment 11). Reynon also asked if any of us were wearing contact lenses, I was the only person who was wearing contacts. Reynon recommended that all contact lens wearers remove them before the walk-through because chlorine gas can get trapped between contact lenses and the eyes and cause damage. I removed my contacts prior to beginning the walk-through. Chlorine Re-packaging Room: Chlorine gas in a pressurized liquid form is re-packaged in this room. Chlorine gas is off-gassed through pipes into a white 3,000 gallon scrubber tank in the same building. There was a strong smell of chlorine and a volatile organic compound (VOC) in this area. Reynon showed me an aerosol can containing an acrylic gloss (Krylon Cover Maxx) being used on tank valves that was the source of the VOC smell. The label on the aerosol can of Krylon Cover Maxx warned that it was extremely flammable. The one employee in the room during the inspection was not wearing a respirator or mask. Powell Machine/Bleach Manufacturing Room: Bleach is manufactured in the Powell Machine, then tested in this area. According to Reynon, analytics are done on the manufactured bleach in a sink located adjacent to the Powell Machine. Waste from the sink enters a square, walled-in open top sump, then is pumped back into the process. Th room with the sink sump also contains a large sump that encompasses the entire remainder of the small room. A grate covers the sump (See Attachment 6, Photo#'s 2-7). Reynon stated that the liquid in this sump is pumped into the big white scrubber tank, and from there to a waste water tank where it goes through a filter. It is then pumped back into the bleach manufacturing process. According to Reynon, the grates over the sump are removed once per year and cleaned out according to the facility's SOP for spill cleanup. When it rains and water accumulates on the floor in this area, employees remove the filter from a shop vac, vacuum up the water and return it to the bleach manufacturing process. A scrubber tank was in a corner across from the Powell Machine. Next to the scrubber tank was an open blue rectangular container. The open container was placed under a leaking pump to capture the leaking fluid. Reynon stated that this pump was used for recycling caustic, which also goes into the white tank with scrubber solution. There was liquid in the blue rectangular container, but no lid or label on the container. Reynon stated that this liquid is pumped back into the process. Reynon stated that they run the bleach manufacturing process until the scrubber tank is almost full; then remove 2,000 gallons. Once a month, they drain the tank, wash it, and inspect the spargers (assemblies used to inject gas into liquid). The wash water is put back through the bleach manufacturing process. Reynon stated that the tank does not accumulate sludge; the one time it did, the facility changed chlorine vendors, and the problem has not recurred. In this area,we collected samples as follows: waste liquid from sink analytics collected from the sump (Sample ID TCS-09, Attachment 4, Photos 48-52; not hazardous in the Fish Bioassay test); and waste from the blue, open rectangular container under the pump located adjacent to the scrubber tank (Sample ID TCS-08, Attachment 4, Photos 43-47; hazardous for corrosivity with a pH of 12.87). Empty tote storage near cooling towers: Inspected a 330-gallon tote that had a corrosive placard with UN number 1824(for sodium hydroxide) and a sign saying, "Please do not use; for B gas only'. The tote was near many empty totes and Reynon described the area as a waste storage area. However, when Clark asked him about the contents of this specific tote, he remarked that the tote was not actually a waste but happened to be placed by the wastes. The tote was almost half full of a solution that Reynon stated was a caustic. Reynon stated that the solution had either come from the bi-gas tank or was going to the bi-gas tank; he was unsure of the contents. The tote was not labeled with information regarding hazardous properties. We collected a sample from this tote (Sample ID TCS-07, Attachment 4, Photos 36-42); the solution in the tote was hazardous for corrosivity, with a pH of 12,95. This solution was stored near an incompatible waste h drotest wash water with a pH of 1.37. 3of10