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PACTIV <br /> Foodservice/Food Packaging <br /> Pactiv <br /> 4545 Qantas lane <br /> Stockton,California 95206-3982 <br /> Tel 209.983.1930 <br /> www.pactiv.com <br /> July 23, 2015 <br /> Ms. Elena Manzo <br /> Registered Environmental Health Specialist <br /> San Joaquin County RECT JUL 24 2015 <br /> Environmental Health Department <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205-6232 <br /> Re: Inspection Findings Response and Certification of Return to Compliance <br /> Small Quantity Hazardous Waste Generator Inspection —June 5, 2015 <br /> Pactiv Packaging Stockton — Performance Drive Facility <br /> Dear Ms. Manzo, <br /> On June 5, 2015, you conducted a Large Quantity Hazardous Waste Generator Inspection at the <br /> Pactiv Packaging (Pactiv) facility located at 1110 Performance Drive in Stockton. After <br /> completing the inspection, you provided us with your Inspection Report finalized on June 22, <br /> 2015, and received by us on June 26, which listed each potential violation and requested <br /> documentation of corrective actions, along with a Return to Compliance Certification. <br /> This letter provides our response to each of the potential violations, including corrective actions <br /> where necessary. The completed/certified Return to Compliance Certification Form is also <br /> provided as Attachment 1 to this letter. For ease of review, a brief summary of each potential <br /> violation is provided, followed by Pactiv's response and corrective action, if needed. <br /> 105 <br /> Metal fines, generated from metal grinding and metal cutting equipment are being recycled as <br /> scrap metal without first determining particle size or hazardous properties. <br /> Pactiv Response: Metal fines are now collected and disposed of as California Hazardous <br /> Waste. We are also testing the metal fines to support our waste characterization. <br /> 'Vacuum/oil, water, sludge"has been disposed of on two occasions (May 22, 2014 and July 15, <br /> 2014)as a non-hazardous waste,several hazardous waste manifests were also present for the <br /> disposal of oily water and sludge in 2014 and 2015. Several containers and totes were observed <br /> onsite with varying contents ("mop water"in particular) with "non-hazardous waste"labels. <br /> Pactiv Response: The 'Vacuum/oil,water, sludge" was incorrectly used on the manifest—this <br /> was actually the "ink wash water"waste. For the May 22 and July 15, 2014 shipments, this <br />