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San Joaquin County Environmental Health Department Hazardous Waste Generator Inspection-Compliance Certification Follow Up Auditor:Stacy Rivera Attachments: RECEIVED a) Copy of email sent from Dana Parry to Kasey Foley DEC 0 6 2017 b) McCampbell Analytical testing on soda ash ENVIRONMENTAL HEALTH DEPARTMENT Item#104—CCR 66262.34(d) No modified contingency plan Disputed Pilkington disputes this audit finding because the company has an emergency coordinator and complies with its large quantity generator contingency plan. When Pilkington received a October 2, 2017t invoice from SJCEHD that identified Pilkington as large quantity generator status, Cyndi Ward contacted the SJCEHD to inquire and was told that Pilkington's invoice would be place on hold until an audit of the facility was completed to determine generator status. An audit was scheduled for November 9, 2015, but the SJCEHD was not willing to yet recognize Pilkington as a small quantity generator,which is one of the reasons that the company had not transitioned to the more lenient requirements for a small quantity generator, including emergency contact list posted by the telephone.Thus, at the time of the inspection, Pilkington was still considered a large quantity generator according to SJCEHD. More importantly, Pilkington's compliance with the robust requirements for a large quantity generator is a permissible substitute for complying with the more lenient requirements for a small quantity generator. This is why generator facilities whose status oscillates between large and small status will simply comply with the large quantity requirements, and without being cited for failure to comply with small quantity requirements.To this end, Pilkington keeps an Emergency Response/Contingency Plan in compliance with CCR66265. Further,the emergency coordinator for Pilkington's facility is Mr.John Olivas,which is noted in within the facility binder. That said, at the request of the SJCEHD auditor, Pilkington completed an Emergency Phone List form and posted it by the phone. Despite this step to address the SJCEHD's concern, Pilkington disputes this violation because (1) at the time of the audit, Pilkington was considered a large quantity generator by the SJVEHD; and (2)the company had an emergency coordinator and Emergency Response/Contingency Plan in place,thereby satisfying the more robust requirements for a large quantity generator. Attachments: c) Picture of Emergency Phone List posted by phone Pilkington North America—Lathrop Page 2 of 5 12/4/17 (CERS ID:10154015)