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Inspection Report : 0 9 Facility Name
<br /> Pilkington North America, inc.
<br /> Ill. BACKGROUND
<br /> On December 14, 2010, DTSC staff conducted a Compliance Evaluation Inspection (CEi) of
<br /> Pilkington North America, Inc. (PNA) located at 500 East Louise Avenue Lathrop, CA 95330,
<br /> San Joaquin County. PNA formerly known as Libbey Owens Ford (LOF) Company. PNA
<br /> acquired LOF in 1986. PNA manufactures float glass for the construction and automotive
<br /> industries. The manufacturing site at 500 E Louise Avenue Lathrop, San Joaquin County, is
<br /> housed in a 165 acres lot with about 160 employees. The facility generally operates 24 hours
<br /> per day in three shifts. Raw materials required to manufacture float glass include sand, sodium
<br /> carbonate, calcium carbonate, and dolomite. The manufacturing process consists of batch
<br /> mixing, melting, annealing, cutting, and packaging. The facility generates various hazardous
<br /> wastes including corrosive waste, solid waste, used oils, and flammable liquids. The facility
<br /> was inspected previously by DTSC in November, 2003 and was cited for failure to perform
<br /> tank assessment for the oil-water tank system, onsite storage of hazardous waste for more
<br /> than 90 days, failure to maintain the facility in the acid battery recharging station, failure to
<br /> label, and close open containers. A review of the CUPA's inspection reports for their 2007,
<br /> 2009, and 2010 inspections indicate that PNA has repeated same violations such as onsite
<br /> storage for more than 90 days, failure to complete training records for the employees handling
<br /> hazardous waste, failure to update contingency plan, and failure to completely label containers
<br /> of hazardous waste. The facility has a history of on going repeated violations from CUPA and
<br /> is therefore, a recalcitrant violator (See inspection reports, Attachment B).
<br /> The DTSC inspection on December 14, 2010 found that the facility is in violation with
<br /> hazardous waste regulations including storage of hazardous waste on-site for greater than 90-
<br /> days without authorization, on-site storage of a-waste and empty container for greater than
<br /> one year without authorization, failure to properly maintain their facility to prevent releases,
<br /> failure to properly label containers of hazardous waste with the hazardous waste markings,
<br /> failure to keep containers of hazardous waste closed except when adding or removing
<br /> hazardous waste, and disposal of hazardous waste to the trash. After the inspection, a
<br /> Summary of Violations (Attachment A) was left with the facility detailing the above violations
<br /> and the corrective action necessary to come into compliance.
<br /> IV. DOCUMENTS REVIEWED
<br /> 1. Employee Training Plan and Records:
<br /> Cal. Code Regs., tit. 22, § 66265.16 requires that employees successfully complete classroom
<br /> instruction or on-the-job training in hazardous waste management procedures relevant to the
<br /> positions they fill, which should also include contingency plan implementation. Facility
<br /> personnel shall also take part in an annual review of the initial training (Cal. Code Regs., tit.
<br /> 22, § 66265.16, subdivision (c)). In addition, the owner or operator of the facility shall maintain
<br /> a training file for the duration of an employ's employment and for three years following their
<br /> departure from the facility. The file should contain a record of the employee's name and job
<br /> title related to hazardous waste management, a written job description for each position and a
<br /> written description of introductory and continuing education given to each ;person filling such
<br /> position(s) Cal. Code Regs., tit. 22, § 66265.16, subdivision (d)).
<br /> PNA has a written training program that specifies the training requirements for each job
<br /> position by job title. DTSC staff reviewed PNA's training documents and found major
<br /> deficiencies in the facility's training program. The training deficiencies included a failure to
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