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P,L4 3`-I ooa( 4 769Li <br /> I �2 <br /> July 22, 2016 R",EE E ' <br /> _E� <br /> 1'1G _' 2010 <br /> San Joaquin Valley Environmental Health Department ("Health Department") <br /> Attn: Elena Manzo, Senior REHS ENVIROs•NIENTAL <br /> 1868 East Hazelton Avenue HEALTH DEIPARTMENT <br /> Stockton, CA 95205-6232 <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 /> 23, 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 Fines <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 itwas 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 hazardous waste 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): HSC25189.5(a) Disposed or caused disposal of HW at an unauthorized point. <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 />