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Thatcher Company of California, Inc., 2/15/2019 B. During the facility walk-through in the Empty Tote Storage Area (outside, near the cooling towers), we observed a 330-gallon tote that had a corrosive placard on it with UN number 1824 (for sodium hydroxide) and a hand-written sign saying, `Please do not use; for B gas only". The tote was almost half full of a solution that Reynon stated was a caustic. Initially, Reynon stated that the totes in this area contained waste but changed his explanation when Clark questioned him. 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 solution was stored illegally because the container was not labeled with a proper hazardous waste label including information regarding hazardous propertiesand/or an accumulation date to show how long the solution had been stored. A pH strip indicated a pH of approximately 14. pH measurement of the collected sample wasdetermined by ECL-Berkeley to be approximately 12.95 (Sample ID TCS-07, Attachment 4, Photos 36-42). C. During the facility walk-through in the Acid Storage Area were three square rubber bucket/containers approximately three gallons in volume size full of dirt and gravel. The containers were black and had handhold holes in the sides near the top. Reynon stated that the rubber containers contained dirt and gravel generated from sump cleanout. He said that the facility has a waste profile for the sump cleanout waste. None of the containers of the sump cleanout waste had lids or labels identifying it as a hazardous waste. We collected a sample from a container of sump cleanout waste (Sample ID TCS-04), however, the jar of sample was broken during shipment, and the lab was unable to test the waste. In a phone conversation I had with Reynon on January 9, 2019, he stated that the waste profile TCS used for the waste was one for sodium hypochlorite spills. According to the Generator Waste Profile for sodium hypochlorite spill cleanup (revised 11/1/2016) provided by Reynon on November 28, 2018, the US DOT Shipping Name for the waste is: UN1759, corrosive solids n.o.s. (sodium hypochlorite), Class 8, PG-II. Evidence: ® Photo ❑ Document ❑ Statement ® Samples ® Observation ❑ Other Observations by Dylan Clark and Anne Ekker, DTSC Scientists. Corrective Actions taken by facility: Return to compliance (RTC) Select RTC Scheduled for: March 18, 2019 date: Violation#: 3 Date: 11/28/2018 Violation Class I Repeat Violation: ❑ Yes ® No Classification: Repeat Violation Date: Citation: 12 - CCR §66260.200 & 66262.11 8of10