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Inspection Report : Facility Name Pilkington North America, Inc. hazardous waste and, (3) the plan was not updated with current list of response team persons. The facility has a history on noncompliance and, therefore, the violation is ongoing. On or about December 14, 2010, PNA violated Cal. Code Regs., tit. 22, § 66265.54(d), in that PNA failed to immediately revise contingency plan with the names of employees who were designated to act as the emergency coordinator. PNA shall also submit a copy of the revised plan to the CUPA and DTSC. This violation was not included in the Summary of Violations that was left with the facility on December 15, 2010, but is now being added as a Class i violation to the inspection report. 3. Uniform Hazardous Waste Manifest Records: In accordance with Cal. Code Regs., tit. 22, § 66262.20(a) generators of hazardous waste must complete a Uniform Hazardous Waste Manifest (manifest) for hazardous waste shipped or sent offsite and maintain the manifest record onsite for three years. During the inspection, DTSC requested to review the facility's manifests for the past three years. Mr. Franko provided DTSC staff with several binders that contained the site manifests. The CUPA's 2009 inspection indicates that facility was not properly maintaining signed manifests, failed to determine status of hazardous waste when manifest copy not receive and failed to complete exception reports Prior to the inspection, DTSC staff had reviewed the Hazardous Waste Tracking System and noted that the facility has not been submitting to DTSC paired copies of the manifest for the time periods 2008, 2009, and 2010, although paired copies were observed in the facilities documents during the documents review on December 15, 2010. Mr. Baillie asked if the facility had mailed any manifests to DTSC. Mr. Franko replied that he was not aware that he had to send DTSC a copy. Mr. Baillie explained that after U.S. Environmental Protection Agency (U.S.EPA) changed the manifest format, the blue colored copy for DTSC was removed and the facility is now required to make a copy of the manifest and then mail it to DTSC. Mr. Franko acknowledged that he had not mailed DTSC copies of the manifest but now would start. Mr. Baillie asked if the facility had any exception reports for the manifests. Mr. Franko was not familiar with the term "exception reports and asked to have it explained to him. Mr. Baillie noted that the manifests were not organized in the binder in that generator copy was not kept with the facility copy but rather these copies were intermixing within the binder. Mr. Baillie asked how the facility tracked manifested shipments. Mr. Franko replied that when he receives a manifest he puts it in the binder. Mr. Baillie asked how the facility tracked the time period for the shipment to be received by the disposal site. Mr. Franko was not aware of the time period for reporting if a facility does not receives a waste shipment or that the facility must report, exception report, if a waste shipment does not reach the disposal facility. Mr. Baillie explained why it was important to track the waste shipment to ensure it actually reached the disposal facility and time requirement for reporting missing shipments and what an exception report is? Mr. Franko explained that he taken over the job of managing the manifests after the company's Environmental Manager, Mr. Bryan Villar left PNA in June 2010 and had not received any instructions on manifests. PNA must provide training to employees that are responsible for completing and managing manifest. Therefore, Mr. Franko had been managing manifests for approximately six-months without receiving training in manifests. On or about December 14, 2010, PNA violated Cal. Code Regs., tit. 22, § 662.62.20(a) (4), in that the facility failed to send copies of the manifests to DTSC within 30 days of each hazardous waste shipment. In particular, beginning June 2010 and continuing until the present, PNA failed to submit copies of manifests to DTSC. This violation was not included in the Summary of Violations that was 5 of 73