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San Joaquin County Environmental Health Department Hazardous Waste Generator Inspection-Compliance Certification Follow Up Auditor:Stacy Rivera #109-CCR66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days Disputed Pilkington disputes this audit finding because the company timely submitted the manifest in question, which was accompanied by a cover letter documenting this fact. Manifest 006825223FLE (3/7/15)was submitted on March 17, 2015,to DTSC at P.O. Box 400 in Sacramento,which is documented in the attached Exhibit D(the original letter and manifests that were sent). Cyndi Ward called DTSC on November 13, 2017 and asked if the agency could confirm receipt of the manifest and, while DTSC could not do so, the DTSC representative noted this has happened before because the manifest was not entered properly or the mail was misrouted. DTSC suggested that Pilkington re-send manifest to the PO Box. Ms. Cyndi Ward also contacted Ms. Stacy Rivera on November, 13, 2017, and confirmed that resending the manifest to the PO Box would be acceptable since there was no a physical address for certified mail. When Ms. Rivera asked how Pilkington already knew that the manifest was previously sent to DTSC, Cyndi Ward informed her that the manifest cover letter dated March 17, 2015 was stapled to the manifest, which is Pilkington's procedure to address this very situation. Pilkington disputes this violation as it fulfilled their obligation in sending the original manifest within 30 days of shipment to the DTSC at the given address, and has re-sent the manifest to ensure proper documentation. Attachments: RECENED d) Original letter sent to DTSC(March 17, 2015) e) Follow up letter sent to DTSC(November 13, 2017) DEC 0 6 2017 ENVIRONMENTAL HEALTH DEPARTMENT #110-CCR66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years Manifests 012796190JJK and 014395178JJK have been obtained and are filed on site. Complete Environmental Solutions, a contractor for Jones Development and Pilkington,facilitated this hazardous waste shipment from the facility,which apparently led to Pilkington not receiving its copy of the manifest. The Designated facilities, Clean Harbors Buttonwillow and Ramos Environmental, however, both have copies of the manifests as well. Going forward Pilkington will insure that all manifests from outside contractors be kept at Pilkington on-site. Attachments: f) Copy of manifest 012796190JJK(6/29/15) g) Copy of manifest 014395178JJK(6/11/15) Pilkington North America—Lathrop Page 3 of 5 12/4/17 (CERS ID:10154015)