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Thatcher Company of California, Inc., 2/15/2019 open area that people could walk through. Reynon did not know how long the pipe had been dripping, and no visible means was being made to collect/contain the leaking solution. Reynon stated that leaks in this area were collected and put into a process for non-NSF certified product. We collected-a sample of this solution (Sample ID TCS-05, Attachment 4, Photos 15-17 and 25-28); it was hazardous for corrosivity with a pH of 12.77 and hazardous in the Fish Bioassay test. A sign posted in the area said: "Process Make Up Water (containing 1-12% bleach) Pumped Back for Re rocessin ". IV. Discussion with Operator Duringdiscussions with Reynon during the investigation on November 28, 2018, he told us that the plant manufactures two types of bleach products: a National Sanitation Foundation (NSF) certified bleach product, and a non-NSF bleach product. The materials that spill onto the ground or into the sumps and other rinsates are used for the non-NSF product. Reynon stated that they have a market for the non-NSF product. Documentation to support this claim will be requested as part of the corrective actions for relevant violations cited. During our investigation, there was an above ground tank on-site holding hundreds of gallons of non-NSF material that, if it cannot be sold, is a waste. In a telephone conversation with Reynon on January 9, 2019, 1 told Reynon which violations would be cited from the investigation on November 28, 2018, and I gave him verbal sample results associated with each of the violations. In the same conversation, Reynon told me that the concentration of Ferric Chloride the facility sells is approximately 38%, and that the Generator Waste Profile for the sump cleanout waste was the profile for sodium hypochlorite spills. On February 12, 2019, 1 mailed to Reynon a letter of delayed Investigation Report (see Attachment 10), i i V. Sampling Samples ZYes ❑ No Sample Collection Date: 11/28/2018 i taken: See Sampling Activities Report issued on January 30, 2019, for details of sampling activities. Sample i results are included as an addendum to this investigation report (see Attachment 6). VI. Document Review Document Name Violations?Violation Reference# Attachment# Brief Comments Waste Profiles (Thatcher and No violations noted at 9 Sierra) this time Resource Conservation and No violations noted at 9 Prepared by ACT Environmental Recovery Act (RCRA) Contingency this time Services, Escondido, CA Plan Bills of Lading and associated- No violations noted at 9 7Tw:oBOLs along with list ofshipping documents for Pro Bleach this time ers for Pro Bleach product 9/1/2018 to 11/21/2018 5of10