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Thatcher Company of California, Inc.,
<br /> 2/15/2019
<br /> Four 5-gallon buckets were being stored near the tote. Reynon stated that they contained hydrotest wash water
<br /> generated from hydrotesting the compressed gas cylinders that formerly contained chlorine gas. The buckets were
<br /> not labeled and were not tightly closed. The waste was stored near a tote containing sodium hydroxide solution
<br /> associated with the bi-gas tank that was determined to have a pH of 12.95; the hydrotest wash water and bi-gas tank
<br /> solutions are highly incompatible and could cause a dangerous reaction upon contact. We collected a sample from
<br /> one of the buckets (Sample ID TCS-06, Attachment 4, Photos 29-35). Besides corrosivity, the hydrotest wash water
<br /> was also hazardous for soluble chromium, copper, lead and nickel.
<br /> According to Reynon, the cooling towers located on a concrete slab near this area supply water to cool the heat
<br /> exchangers during bleach manufacturing. When the heat exchangers are cleaned, a white residue is generated,
<br /> which is managed as sodium hydroxide or hydrochloric acid spills.
<br /> Totes stored in/near Acid Storage Area: a white 330-gallon tote in this area was full of a solution. The tote was
<br /> labeled as "SO3 Scrubber Solution"with a UN 2693 placard, for sodium bisulfites, n.o.s. Reynon stated that this was
<br /> spent scrubber solution that is shipped to the Thatcher facility in Sparks, Nevada, and is used there as an ingredient
<br /> to produce sodium bisulfite product. We collected a sample of this solution(Sample ID TCS-03, Attachment 4,
<br /> Photos 11-14; it was not hazardous in the Fish Bioassay Test).
<br /> Retention Pond: Reynon stated that nothing is discharged from the facility. There is piping underground in the yard,
<br /> the entire facility is graded to direct rainwater to trenches and the pond, and there is a liner/barrier underneath part of
<br /> the yard (the liner was installed in lieu of paving the entire yard). The facility has a Storm Water Pollution Prevention
<br /> Plan (SWPPP).
<br /> Trash and Recycling Area: We collected a sample of the solid that had leaked out of a trash container, along with
<br /> more of the solid that had leaked onto the soil immediately around the small pile of solidified substance (Sample ID
<br /> TCS-02, Attachment 4, Photos 7-10; not hazardous in the Fish Bioassay Test and not hazardous for semi-volatiles).
<br /> Ferric Chloride Tote Storage Area (in/near Acid Storage Area): Approximately 12, 330-gallon totes were stored that
<br /> had-rust-colored-stains on-the-outside. I-asked-Reynon-what the-totes-were-used-for-..Reynon-stated_that-they are
<br /> used to deliver ferric chloride solution to customers. I asked if the totes were used as is, or if they were cleaned
<br /> before delivery to customers. Reynon stated that they could clean the totes with hydrochloric acid, however, that
<br /> process generated a lot of liquid hazardous waste, so instead, they clean the outside of the totes as well as possible
<br /> using absorbent pads. Reynon further explained that their customers understand the nature of Ferric Chloride, and
<br /> that the staining is typical. The totes were not labeled with the concentration of Ferric Chloride, however, in a
<br /> telephone conversation with Reynon on January 9; 2019, he stated that the TCS Ferric Chloride product is maximum
<br /> 38% in concentration. At 40%, ferric chloride is very hazardous and can cause burns on contact with the skin and
<br /> eyes. Inhalation causes burning in the throat.
<br /> few yards east of the ferric chloride totes, in a bermed area,a rust-colored pool of water had accumulated. In the
<br /> same area were three square rubber bucket/containers approximately.five gallons in volume size, and full of dirt and
<br /> gravel. The containers were black and had handhold holes in the sides near the top. Reynon stated that the water
<br /> accumulated in the bermed area was rain-water, and the rubber containers contained dirt and gravel generated from
<br /> sump cleanout. In a phone conversation I had with Reynon on January 9, 2019, he stated that the waste profile TCS
<br /> used for the waste was one for sodium hypochlorite spills. According to the Generator Waste Profile for sodium
<br /> hypochlorite spill cleanup (revised 11/1/2016) provided by Reynon on November 28, 2018, the US DOT Shipping
<br /> Name for the waste is: UN1759, corrosive solids n.o.s. (sodium hypochlorite), Class 8, PGAI. None of the containers
<br /> of the sump cleanout waste had lids or labels identifying them as containing a hazardous waste.
<br /> We planned to collect a sample of the rust-colored water, however, when we returned prepared to sample, most of
<br /> the water had been removed, and the remaining water was mostly clear. We collected a sample from a container of
<br /> sump cleanout waste (Sample ID TCS-04, Attachment 4, Photos 18-24), however, the jar of sample was broken
<br /> during shipment, and the lab was unable to test the waste.
<br /> Just north of this area, in the Bleach Filter Waste/Containment#2 Tank Farm Area, a pipe containing sodium
<br /> hypochlorite product bleach was dripping onto the secondary containment/bermed area. This was a concreted
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