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• • Large Quantity Hazardous Waste Generator Inspection Report Follow Up 4/6/2015 Pilkington N.A. Lathrop In regards to the Inspection Report issued by the San Joaquin County Environmental Health Department for the March 13, 2015 inspection to the former Pilkington North America Inc.facility at 500 E. Louise Avenue in Lathrop, we have attached the "Return to Compliance Certification." Additional details for each asserted violation are provided below. Attached: RECEI\MIEL a) Return to Compliance Certification APR 0 8 2015 Summary of Violations Response: ENVIRONMENTAL rjrvtPT+AcPJT #105—Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 years: To respond to Item#105, Ms. Manzo requests that a laboratory analysis be submitted. Note that according to 22 CCR 66262.11(b)(2) ...the generator may determine that the waste from his particular facility or operation is not a hazardous waste by either: (1)testing the waste according to the methods set forth in article 3 of chapter 11 of this division...;or (2)applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used and the characteristics set forth in article 3 of chapter 11 of this division. Paragraph (b)(2) is commonly known as"generator knowledge". This soda ash waste was previously characterized in December 2014 through a combination of laboratory testing and generator knowledge. Soda ash along with sand are the primary constituents of glass. In previous waste characterizations of Pilkington batch waste (comprised primarily of soda ash and sand), no California hazardous waste characteristics were identified. Further in December 2014 a sample was collected of the soda ash alone to validate the assessment via generator knowledge that soda ash is non-hazardous. Because this material is high purity sodium carbonate, a dry solid, it was clear that the material would not be flammable or reactive from review of the material safety data sheets. The two characteristics that needed to be addressed were California corrosivity and toxicity. The report from the certified laboratory is attached which shows the pH to be 9.94 and only two metals from the CAM-17 test that were present at a level well below the TTLC value and 10 times the STLC value (the dilution ratio for the test). Based on a review of material safety data sheets and its common uses as domestic water softener and food additive, it was otherwise deemed to not meet any other characteristic of toxicity including acute fish toxicity. This confirmed that like the batch waste,soda ash does not meet any Federal or California hazardous waste characteristics. Attached: b) analytical results on the soda ash—McCampbell Analytical, Inc. report#1412518(note for clarity, four papers of the analytical data not pertaining to the soda ash have been omitted)