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Stacy Rivera [EH] <br /> From: Rehor, Mike W. [mrehor@pactiv.com] <br /> Sent: Friday, September 18, 2015 2:35 PM <br /> To: Stacy Rivera [EH] <br /> Cc: Frese, Jeff J.; Christopherson, Aaron M.; Rogers, Glenn <br /> Subject: RE: Waste Inspection of Pactiv Packaging Stockton Qantas-June 8, 2015- REQUESTED <br /> FOLLOW-UP <br /> Attachments: Pactiv Stockton Qantas-Metal Fines Container.jpg <br /> I k-11 <br /> Pactiv Stockton <br /> Qantas-Metal... <br /> Stacy - I did visit the Stockton Qantas facility this week. Below is our <br /> response to your two questions: <br /> 1. Metal Grinds - why are they being managed as non-RCRA waste? <br /> Pactiv Response - The metal fines/grinds generated at the Pactiv Stockton Qantas facility <br /> are currently being managed as a RCRA Hazardous Waste (see attached photo) . We are <br /> working on testing the fines to confirm this waste classification, and/or determine if <br /> reclassification is possible. However, until such time as a reclassification is made, the <br /> 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 <br /> that the mop water and the waste ink rinse water (in buckets) , along with the wash tanks, <br /> are all the same waste (now referred to consistently as "ink wash water") . All of this <br /> waste is generated from the same process - washing ink off of various press parts and <br /> components using soapy water. The ink is all the same water-based inks, the same soap is <br /> used for washing, and the water/soap mixture is similar for all processes (10-20% soap) . <br /> Therefore, we think our waste characterization testing to date has been representative of <br /> the point of generation, as the ink wash water initially generated at the press or "OPMR" <br /> room would be similar to the stored ink wash water awaiting disposal. <br /> However, in consideration of your question and to confirm our testing results, we will <br /> undertake additional point of generation waste characterization testing of the ink wash <br /> water. We will provide results to you no later than Oct. 31, 2015. <br /> If you have any questions or concerns on our responses, please e-mail me, or contact me at <br /> the number below. As I 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 /> 1 <br />