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July 19,2019 Owens-Brockway Glass Container Inc. Response to San Joaquin County Environmental Health Department's June 5,2019 RCRA Large Quantity Hazardous Generator Inspection Report Item#301 —CCR 66265.31 Facility not maintained to minimize the release of a hazardous waste. The following observations were made at the time of inspection: 1. Oily staining and used absorbent were found on the concrete pad and on the floor beneath the compressor in the compressor room (location SK-08 on the site map) (IMG 6921-8). Response to Item #301 (1): This area has been cleaned and painted. (Please see photographs attached as Exhibit 8.) Oily debris generated during cleanup was disposed of under Hazardous Waste Manifest 013185897FLE, a copy of which is attached as Exhibit 9. This issue has been corrected. 2. Oily staining was observed on the ground next to the used oil tank located in HWA-10 on the site map (IMG 6938-40). 3. Oily staining was observed on the ground, walls, and pillars throughout the lower ground/basement area of the facility(IMG 6947-9). Response to Items#301 (2) and (3): This area near the used oil tanks has been cleaned. Oily debris collected from these areas was disposed of using Manifest 013185897FLE, a copy of which is attached as Exhibit 9. These issues have been corrected. As discussed previously, water is used to cool hot glass and glass containers that due to quality or maintenance reasons are diverted to the basement via the cullet chutes for eventual recycling into the batch to produce new glass containers. The water flows into the plant's lower level, commonly referred to as a basement (even though at the Tracy Plant, the "basement" is above grade). Excess shear spray, comprised of clean water with a small amount of food grade oil, also flows into the basement after use. The basement floor acts as containment for this water, which is directed by the design of the basement floor to a basement sump, and an oil/water separator. Oil is skimmed from the surface of the water and pumped into a used oil tank, and the water is pumped back to the cullet chutes where it is re-used in a continuous loop as cooling water. A flow chart for the Tracy Plant basement is attached as Exhibit 10. 4. Oily staining and used absorbent pads were observed on the ground throughout the area next to the satellite accumulation area and vac pumps #2 and #3, located in the lower ground/basement area of the facility(IMG 6950-60). 5