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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for OWENS-BROCKWAY GLASS CONTAINER INC as of October 04, 2016. Open violations from April 14, 2016 inspection Violation #706 - Failed to provide and maintain adequate secondary containment. According to the site inspection and according to the reviewed tank assessment report, prepared by Canestoga-Rovers&Associates (dated August 15, 2012), the 450 -gallon and 1750 -gallon waste oil tanks appear to have insufficient secondary containment. The reviewed waste oil tank assessment, indicated the oil water separator pit used as secondary containment for the 1,750 -gallon tank "doesn't appear to meet the requirements of 22 CCR 66265.193 and it didn't appear to be lined and cracks were observed in concrete above the liquid level in the pit". Furthermore, according to the same tank assessment, the 450 -gallon waste oil tank has no secondary containment. Also, the oily waste mixture, referred to as "biosol" and used in the glass making process, discharges directly from the glass making area into an unlined area where it pools and subsequently flows into the in -ground oil water separators. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. #706 RESPONSE TO THE RECEIVED RETURN TO COMPLIANCE CORRECTIVE ACTION STATEMENT (RTC): The submitted SPCC plan is conditional pending the installation of adequate secondary containment for above ground storage containers. As such, this facility is still out of compliance until the adequate secondary containment is provided. Submit proof of correction to the EHD. Violation #710 -Failed to maintain records of drainage from diked areas. Records of drainage of uncontaminated rainwater from diked areas were not found on site. Adequate records (or NPDES permit records) of drainage from diked areas shall be retained. Immediately begin maintaining adequate records (or NPDES permit records) of drainage from diked areas. Submit proof of correction to the EHD. #710 RESPONSE TO THE RECEIVED RETURN TO COMPLIANCE CORRECTIVE ACTION STATEMENT (RTC): The submitted return to compliance documentation indicates that "Owens will, (...J, create an inspection record [drainage record] to use in the event when we have a discharge. " The reviewed SPCC plan indicated that facility is not required to maintain and complete a drainage release log. Please clarify this inconsistency, and submit a revised corrective action statement, as necessary. Violation #712 -Failed to pertorm tank inspections that take into account size, configuration, and design. API -653 Tank reports (dated 6-13-2012), prepared for the 450 -gallon and the 1,750 gallon waste oil tanks, were reviewed at the time of inspection. No integrity testing reports were available for the rest of the onsite tanks. The reviewed API -653 Tank reports could only be utilized for these tanks, if these tanks were built according to the APA -650 standards. However, according to the reviewed API -653 Tank reports reports, these tanks (for which these integrity testing reports were prepared, the 450 -gallon and the 1,750 -gallon tanks), "were not built to any observed codes". Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Submit proof of correction to the EHD. #712 RESPONSE TO THE RECEIVED RETURN TO COMPLIANCE CORRECTIVE ACTION STATEMENT (RTC): The submitted return to compliance documentation for this violation ndicates that "Owens is currently performing any inspections of its hazardous waste used oil tank system." According to the reviewed SPCC plan (page 31), for all existing site tanks (category A, 8, C and D tanks) visual inspections, as well as formal external inspections by a certified inspector and a leak testing every 10 years, and a leak testing every 5 years per California Hazardous Waste are required. As such, implement all appropriate inspections/testing for all regulated containers, and submit proof of correction to the EHD. Page 3 of 4