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San Joaquin County Environmental Health Department R E G I °' E C Hazardous Waste Generator Inspection-Compliance Certification Follow Up DEC 0 6 2017 Auditor:Stacy Rivera ENVIRONMENTAL HEALTH DEPARTMENT #111-CCR66262.40(a)Failed to comply with uniform hazardous waste manifest exception requirements As noted above, Manifests 012796190JJK and 014395178JJK have been obtained and our on site. In the future, should PNA not receive a timely copy of any manifest, it will follow up and, if necessary,complete the manifest exception requirements. #113-HSC2516O.2(b)(3) Failed to keep copies of consolidated manifesting receipts for three years Disputed Pilkington disputes this audit finding because the company is not the generator of the "used oil" in question pursuant to California Health &Safety Code §25250.12. As the auditing finding noted, an outside vendor(Pape) handles the maintenance of certain Pilkington equipment. The vendor consolidates the used oil from its various customers for recycling and, because it meets the criteria at §25250.12(a)-(d), the "used oil is deemed generated at the point of consolidate upon consolidation." As such, Pape, not Pilkington, is the generator of the used oil and subject to the manifesting requirements. That said, in response to the auditor's concerns, Pilkington will increase its associated monitoring and recordkeeping to track the dates and amounts of material taken by Pape under this scenario. #117-HSC25185(c)(3) Failed to submit a written response within 30 days of receiving an inspection Disputed Pilkington disputes this audit finding, which the auditor based the alleged "repeat"violation described in audit finding#102 (i.e., "Failed to determine if a waste is a hazardous waste"),for the reasons provided above. That said, to the extent that additional documentation is requested, Exhibit H provides the cover letter that Pilkington sent to the SJCEHD on April 6, 2015, which is clearly within 30 days of the 2019 inspection. Additional requests made by SJCEHD were also addressed in a timely manner. #206-HSC25160.2(c)(2)-Waste stream or generator not eligible to use consolidated manifest procedure Pilkington contractor American Valley Waste Oil disposed of certain diesel contaminated water from triple rinsing during removal of diesel tanks using consolidated manifest procedures. Although Pilkington no longer has any tanks, and therefore will not have this type of waste in the future,the company understands SJCEHD's concern and pledges that it will not dispose of this type of using a consolidated manifest procedure, but rather a uniform manifest. Pilkington North America—Lathrop Page 4 of 5 12/4/17 (CERS ID:10154015)