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Ce44? ( 11VXQ�( <br />NLI 3 L/ q t) 000 ( 4 :T q 1*4� [2 <br />July22, 2016 - NED <br />AUG zo �2 2016 <br />San Joaquin Valley Environmental Health Department ("Health Department") <br />Attn: Elena ManzoSenior RVIROPJMENTAL <br />ENS <br />1868 East Hazelton Avenue <br />Stockton, CA 95205-6232 <br />EN <br />, <br />HEALTH DEPARTMENT <br />Re: Owens -Brockway Glass Container Inc. Tracy Plant ("Owens") <br />RCRA Large Quantity Hazardous Waste Generator Inspection Report <br />Aboveground Petroleum Storage Act Inspection Report <br />Dear Ms. Manzo: <br />This letter is written in response to the Health Department's RCRA Large Quantity Hazardous <br />Waste Generator Inspection Report and Aboveground Petroleum Storage Act Inspection <br />Report, both dated April 14, 2016, amended June 13, 2016, and received by Owens on June <br />231 2016. For its response, Owens has grouped the alleged violations into categories, with <br />reference to the applicable item numbers shown in the Health Departments reports. <br />RCRA LARGE QUANTITY HAZARDOUS WASTE GENERATOR INSPECTION REPORT <br />Metal Eines <br />Item 106: CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br />No waste analysis was available for the metal fines being generated on site. These waste <br />streams are mixed with the scrap metal recycling. A hazardous waste determination had <br />been made according to the 2011 return to compliance certification but it was not indicated <br />which waste streams were determined to be hazardous. The hazardous waste analysis was <br />not available on site for review. A generator shall make a hazardous waste determination <br />and keep a record of any test results, waste analyses, or other determinations made in <br />accordance with hazardous waste regulations for at least three years from the date that the <br />waste was last disposed of. Immediately stop recycling metal fines, locate a copy of the waste <br />analysis conducted for all metal fines generated on site and submit copies to the EHD. If a <br />copy is unavailable, immediately make a hazardouswaste determination and begin managing <br />the metal fines underTitle 22 hazardous waste regulations. Particles 100 microns or smaller <br />must be handled as hazardous waste if the metal is determined to be a hazardous waste. <br />This is a Class II violation. <br />Item 202(a) <br />: HSC25189.5(a) Disposed or caused disposal of HW at an unauthorized paint. <br />-Metal fines seen throughout the facility, from different machinery are being handled as scrap <br />metal. According to the return to compliance submitted July 8, 2011 all metal lathes, (it do <br />1 <br />