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Thatcher Company of California, Inc., 2/15/2019 Citation Reads: 12 - Failed to determine if waste(s) were hazardous waste(s) Violation: 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 previously held chlorine gas. The wash water in the buckets was rust-brown and contained solids. 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 waste was also hazardous for soluble chromium, copper; lead and nickel. The facility failed to determine if this waste was a hazardous waste, and to manage it properly (Sample ID TCS-06, Attachment 4, Photos 29-35). Evidence: N Photo ❑ Document ❑ Statement N Samples N Observation ❑ Other Observations by Dylan Clark and Anne Ekker, DTSC Scientists. i I i Corrective Actions taken by facility: Return to compliance (RTC) Select RTC Scheduled for: March 18, 2019 I date: VIII. Summary of Exit Interview and Discussion of Unresolved Issues with Facility Staff At the conclusion of the walk-through and sampling, I explained to Reynon that DTSC Office of Criminal Investigations (OCI) was investigating TCS as part of the California Environmental Protection Agency (CaIEPA) Environmental Justice Initiative in Stockton. I, also explained that many other facilities in the Stockton area would be inspected as part of the initiative, and that TCS was being investigated specifically because they produce bleach using chlorine gas, and there are residential homes nearby. I told Reynon that I would send a report within 30 days that would include the activities conducted on November 28, 2018 (facility walk-through, sample collection and brief document review); the report was issued on January 30, 2019. Analytical results for the samples collected have been received; an addendum report that includes those results is attached (Attachment 6). IX. List of Attachments Attachment Number Description of Document Attachment 1 Sample Location Map Attachment 2 DTSC Official Sample Receipt Attachment 3 Chain of Custody Forms/Sample Analysis Request Attachment 4 Sampling Photographic Log Attachment 5 Facility Site Map 9of10