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Let me know if you have any questions in the meantime. <br /> Thanks, <br /> Mike Rehor <br /> Director, Environmental Health &Safety <br /> Pactiv LLC <br /> 1900 W. Field Court, Lake Forest, IL 60045 <br /> 847-482-2675 (o) 847-915-0665 (c) <br /> 847-615-6516(fax) <br /> mrehor@pactiv.com <br /> From: Rehor, Mike W. <br /> Sent: Friday, September 18, 2015 4:35 PM <br /> To: 'srivera@sjcehd.com' <br /> Cc: Frese, Jeff J.; Christopherson, Aaron M.; Rogers, Glenn <br /> Subject: RE: Waste Inspection of Pactiv Packaging Stockton Qantas -June 8, 2015 - REQUESTED FOLLOW-UP <br /> Stacy—I did visit the Stockton Qantas facility this week. Below is our response to your two questions: <br /> 1. Metol Grinds—why are they being managed as non-RCRA waste? <br /> Pactiv Response—The metal fines/grinds generated at the Pactiv Stockton Qantas facility are currently being <br /> managed as a RCRA Hazardous Waste (see attached photo). We are working on testing the fines to confirm this <br /> waste classification,and/or determine if reclassification is possible. However, until such time as a <br /> reclassification is made,the metal fines will continue to be managed as a RCRA Hazardous Waste. <br /> 2. Liquid Ink Waste—why was it not sampled at the point of generation? <br /> Pactiv Response—As stated in our response to your inspection findings, Pactiv believes that the mop water and <br /> the waste ink rinse water(in buckets), along with the wash tanks, are all the same waste (now referred to <br /> consistently as"ink wash water'). All of this waste is generated from the same process—washing ink off of <br /> various press parts and components using soapy water. The ink is all the same water-based inks,the same soap <br /> is used for washing, and the water/soap mixture is similar for all processes (10-20%soap). Therefore,we think <br /> our waste characterization testing to date has been representative of the point of generation, as the ink wash <br /> water initially generated at the press or"OPMR" room would be similar to the stored ink wash water awaiting <br /> disposal. <br /> However, in consideration of your question and to confirm our testing results, we will undertake additional <br /> point of generation waste characterization testing of the ink wash water. We will provide results to you no later <br /> than Oct. 31, 2015. <br /> If you have any questions or concerns on our responses, please e-mail me, or contact me at the number below. As I <br /> frequently travel,e-mail is the best method to contact me. <br /> Thanks, Mike <br /> Mike Rehor <br /> Director, Environmental Health &Safety <br /> Pactiv LLC <br /> 1900 W. Field Court, Lake Forest, IL 60045 <br /> 847-482-2675 (a)847-915-0665 (c) <br /> 847-615-6516 (fax) <br /> mrehorCcDpactiv.com <br /> 2 <br />