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RECT JUL 94 2015 Pnc-riv <br /> ! Packaging <br /> ink wash water was disposed of at the Safety-Kleen facility in Newark Ca (US EPA ID Number <br /> CAD980887418). Earlier in 2014, Safety-Kleen picked up the same waste and disposed of it at <br /> the same facility but characterized it as a hazardous waste. Despite the inconsistent <br /> characterization, all ink wash water was disposed of at a properly permitted facility. <br /> To help clarify the waste characterization of the ink wash water, we collected a number of <br /> samples in the latter part of 2014. This testing confirmed that the ink wash water was, <br /> indeed, non-hazardous. We also have standardized waste nomenclature to indicate ink wash <br /> water as the waste name. See Attachment 2 for the results of the waste characterization. <br /> Incomplete waste analysis records were available for the "ink and water" waste, no waste <br /> analysis records were available for the oily water mixture - "mop water"and for the "vac-oil, <br /> water, sludge" which are being generated at this facility; <br /> Pactiv Response: The 'Vacuum/oil, water, sludge" was incorrectly used on the manifest—this <br /> was actually the "ink wash water" waste. The waste characterization record for the ink wash <br /> water has been updated to assure all testing records have been included. As noted above, <br /> the testing records for the latter part of 2014 are attached as Attachment 2. <br /> The oily water mixture is presumed to be California Hazardous Waste per generator <br /> knowledge—therefore, no waste characterization testing is necessary. <br /> No fish bioassay was available for any of the above waste streams. <br /> Pactiv Response: Fish bioassay was performed as part of the ink wash water characterization. <br /> See Attachment 3. <br /> Furthermore, the quality control for the reviewed "ink wash water"laboratory analytical result <br /> indicated abnormal QC indicators; no explanation was found indicating if these results were <br /> acceptable. <br /> Pactiv Response: The laboratory performing the waste determination analysis for the ink <br /> wash water has indicated that none of the quality control notes/comments invalidate the <br /> analytical testing. Correspondence from the laboratory is provided as Attachment 4. This <br /> correspondence is included as part of the ink wash water waste characterization files. <br /> The aforementioned wastes are being disposed of intermittently as hazardous and as non- <br /> hazardous wastes. According to Mr. Mark Ross, this facility changed their ink formulation and <br /> conducted a waste profiling to enable them to dispose of some generated wastes as non- <br /> hazardous. <br /> Pactiv Response: We have confirmed that the waste is non-hazardous. See response above. <br /> Several plastic lined drip pans with some residual paint were set out to dry in the "cup" <br /> manufacturing area. Mr. David Bauer stated that they are placed into their solid waste once <br /> they are dry. Mr. Mark Ross indicated that all their paint solids are being handled as hazardous <br />