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bond I . Background This Engineering Assessment and Certification of Integrity of the 1,550-Gallon Polyethylene Waste Tank System (Poly Tank/System/Tank System) at the Owens-Brockway Glass Container Inc. (0-1) Plant#22 in Tracy, California (Site), has been prepared according to 22 CCR 66265.192 for tank systems that manage hazardous waste. As required, this written assessment has been completed by an independent, qualified, California-registered professional engineer who has certified the tank system for the following: • Sufficient structural integrity • Acceptability for storing of hazardous waste • Compatibility with the waste • Suitability of tank and containment system design to achieve the requirements of the applicable regulations so it will not collapse, rupture, or fail This report must be kept on Site for an inspector's review. 2. Introduction On August 29, 2019, GHD conducted an inspection of the Poly Tank aboveground storage tank (AST) and Poly Tank System. The Poly Tank was in service at the time of inspection, and the inspection was performed using methods and procedures consistent with acceptable industry standards. The findings and conclusions presented in this report were based upon information obtained at the Site and provided by O-I. 0-1 Site contacts had no records of significant modifications or changes in service for the Poly Tank System since it was first placed in service. 3. AST Inspection Procedure The AST inspection of the Poly Tank was performed according to the Steel Tank Institute (STI) Standard for Inspection of ASTs (SP001), which satisfies the tank integrity testing requirements specified in 40 CFR 112.8(c)(6). This regulation states "test(inspect) each aboveground container for integrity on a regular schedule, and whenever you make material repairs." The United States Environmental Protection Agency(EPA)delegates the specifics and frequency of testing to established standards such as the STI SP001. The STI standard provides an inspection and evaluation criteria to determine the "suitability for continued service" of ASTs under 40 CFR 112.8(c)(6). The purpose of conducting inspections is to identify the condition and changes to the AST. The STI standard applies to steel ASTs storing stable, flammable and combustible liquids at atmospheric pressure with a specific gravity less than one. At a minimum, the following tank components shall be inspected: • Primary tank shell thickness GHD I Engineering Assessment and Certification of Integrity of the 1,550-Gallon Polyethylene Waste Tank System 111189093(2)1 Pagel