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Thatcher Company of California, Inc., 2/15/2019 Additional Important Information regarding documents reviewed: During the investigation on November 28, 2018, 1 requested documents from Reynon including: waste profiles for wastes generated (discussed and/or observed previous to, and during the walk-through); lists of customers and copies of sales receipts for any non-NSF products; lists of customers and copies of sales receipts for spent scrubber solution shipped to the Thatcher . Company Sparks Nevada facility as an ingredient in a product made and sold there; SOPS for all liquids from any/all process(es) that are put back into the process; SOP for cleaning heat exchangers; SOPs for management of all waste filters generated at the facility; SOPs for all spill cleanups; drawings and/or specifications of the lining/barrier installed underneath the yard; Storm Water Pollution Prevention Plan (SWPPP); and SOP and waste determination/profile for cleaning Ferric Chloride totes. After the facility walk-through and sample collection, Reynon had many folders available with documents for my review, however, he stated that many of the documents could not be removed from the facility. Due to time constraints, I.requested that Reynon give me copies of all documents that could be taken from the facility. Reynon provided me with the documents listed in Section VI above, I told Reynon that I would return to review other documents or request them in a formal Request for Information (RFI) letter, if necessary. VII. Violations VNS Total # of Violations (VNS): 3 Total Class 1 VNS: 3 Total.Class 2 VNS: 0 Total Minor VNS: 0 Violation#: 1 Date: 11/28/2018 Violation Class I Repeat Violation: ❑ Yes ® No Classification: Repeat Violation Date: Citation: 9 - CCR §66262.10(h), 66262.34(a)(4), 66265.31 Citation Reads: 9 - Failed to minimize the release of hazardous waste or hazardous waste constituents to the air, soil, or surface water which could threaten human health and the environment Violation: A. During the facility walk-through, in the Bleach Filter Area outside, sodium hypochlorite was leaking from a pipe into secondary containment (a raised, bermed area around the pipes and tanks). Facility staff did not know how long the pipe had been leaking, nor had they taken steps to fix the leak or contain the leaking solution. Reynon stated that leaks in this area were collected and put into a process for non-NSF certified product. A pH strip measured the pH of the solution at 13-14. pH measurement of the collected sample was determined by ECL-Berkeley to be approximately 12.77. The sample was also determined to be hazardous in the Fish Bioassay (Method: CDFGP&M 1988) (Sample ID TCS-05, Attachment 4, Photos 15-17 and 25-28). Employees who work in the area are exposed to fumes from these solutions; the fumes are also released to the air. Hazards of the ingredients and product are as follows: i. Caustic soda (sodium hydroxide): Causes severe skin burns and eye damage. Incompatible materials: oxidizing agents, acids, acidic materials, ammonium compounds, nitro compounds, organic halides, active metals, wood, paper, glass. Contact with aluminum, zinc, or tin will generate hydrogen gas. ii. Chlorine: chlorine can be absorbed into the body by inhalation and is corrosive to the eyes, skin and respiratory tract. Serious cases may be fatal. Chlorine has unusual fire/explosion hazards; many metals ignite in the presence of chlorine (i.e. steel at 485 degrees F), titanium on contact with dry chlorine. Chlorine may react to cause fire and/or explosion on contact with organics like turpentine, penetrating oil, ether, ammonia, hydrocarbons and fine particles of 6of10