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Thatcher Company of California, Inc., 2/15/2019 metals. Chlorine will collect at the floor or ground level; exhaust systems must be designed accordingly. Absorption or scrubber systems are recommended. iii. Sodium hypochlorite (product of the above ingredients), 12.5% (the facility guarantees 12.5% concentration of bleach in the product): causes severe skin burns and eye damage. Incompatible with acids, metals and strong oxidizing agents. It is a marine pollutant. B. During the facility walk-through in the Powell Room/Bleach Manufacturing Room, there was a blue plastic rectangular container under a pump adjacent to the Sodium Hypochlorite Scrubber tank. The container held a liquid. A pH strip indicated an approximate pH of 14. pH measurement of the collected sample was determined by ECL-Berkeley to be approximately 12.87 (Sample ID TCS-08, Attachment 4, Photos 43-47). The container was open, with no lid or label. Reynon stated that this solution is from the sodium hypochlorite tank and is returned to the bleach manufacturing process. Evidence: M Photo ❑ Document ❑ Statement ® Samples M Observation ❑ Other Observations by Dylan Clark and Anne Ekker, DTSC Scientists. I Corrective Actions taken by facility: i Return to compliance (RTC) Select RTC Scheduled for: March 18, 2019 date: j I Violation#: 2 Date: 11/28/2018 Violation Class I Repeat Violation: ❑ Yes ® No Classification: Repeat Violation Date: Citation: 14 - HSC 25189.5(d) Citation Reads: 14 - (unpermitted facility) Stored hazardous waste at a facility, area, or point without a hazardous waste facilities permit or other grant of authorization from the Department Violation: A. During the facility walk-through, in the Empty Tote Storage Area outside, we observed four yellow, 5- gallon buckets of hydrotest wash water from hydrotesting compressed gas cylinders that once held chlorine gas. The wash water in the buckets was rust-brown and contained solids (soil or metals). A pH strip indicated a pH of approximately 2. pH measurement of the collected sample was determined by ECL-Berkeley to be approximately 1.37. The sample was also hazardous in the soluble metals test for chromium, copper, lead and nickel. The corrosive solution was illegally stored because the bucket lids were not firmly closed, and they were not labeled with proper hazardous waste labels containing an accumulation date showing how long the solution had been stored (Sample ID TCS-06, Attachment 4, Photos 29-35). 7of10