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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone:(209)468-3420 Fax:(209)468-3433 Web:www.sigov.org/ehd Small Quantity Hazardous Waste Generator Inspection Report Facility Address: Date: Facility Name: 4545 QANTAS LN STOCKTON June 08 2015 Pactiv Packaging Inc Universal Waste 705 CCR 66273.33(c) Failed to properly manage mercury containing universal waste ❑V o R n COS 706 CCR 66273.33.5 Failed to properly manage universal waste electronic devices,CRTs or CRT glass ❑V ❑R ❑COS 707 HSC 25201.16(e) Failed to manage aerosol cans in a manner that prevents the unauthorized release of waste ❑V ❑R ❑COS 708 HSC 25201.16(+) Failed to properly manage containers of waste aerosol cans ❑V ❑R ❑COS 709 HSC 25201.16(g) Failed to store used aerosol cans in an accumulation container ❑V ❑R ❑COS 710 HSC 25201.16(h)(4) No written operating procedure for aerosol can processing ❑V ❑R ❑COS 711 HSC 25201.160) Failed to submit or amend notification for aerosol can processing ❑V ❑R ❑COS 712 CCR 66273.34 Failed to label universal waste to identify type of universal waste ❑V ❑R ❑COS 713 CCR 66273.35 Stored UW onsite greater than one year or was unable to demonstrate the time UW has been stored ❑V ❑R o COS 714 CCR 66273.36 Failed to train employees and maintain records on UW handling and emergency procedures ❑V ❑R ❑COS 715 CCR 66273.39 Failed to keep complete records of each shipment of universal waste for three years ❑V o R o COS Other Violations [OSee below Unlisted Administration/Documentation violation ❑V o R ❑COS below Unlisted Training violation ❑V oR ❑COS below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS below Unlisted Release/LeakslSpillS violation ❑V ❑R ❑COS below Unlisted Abandonmentlillegal Disposal/Unauthorized Treatment violation o V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS 1,CLASS ll,or MINOR-Notice to Comply) Item# Remarks 102 CCR 66262.11, 66262.40(c) Failed to determine if a waste is a hazardous waste or retain waste analysis on site for 3 years. The hazardous waste determination for waste ink rinse, ink mop water, and ink wash water is incomplete. The analytical did not include a bioassay. The quality control for the ink water analytical results indicated several areas that were outside of acceptable limits; no explanation was found indicating if the results were still acceptable or why the results may have been accepted. The mop water and waste ink rinse(found in 5 gallon buckets of various colored ink in the OPMR)are being mixed into the ink wash water for disposal. According to Mr. Ross, the sample is taken of the mixture being stored in the wash water container instead of at the point of generation. This may result in possible dilution of the waste prior to sampling. Ink sludge and ink solids are being disposed of as hazardous waste. No waste analytical was available on site for the glue sludge and water mixture. These wastes are all being disposed of as non-hazardous. Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately stop disposing of these wastes as non-hazardous, make a complete hazardous waste determination for the liquid ink wastes and the glue sludge wastes, and manage them according the Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this waste was managed. This is a repeat violation, Class It. Received by Inspector: Phone: Date: (initial): /r//�_ STACY RIVERA, Senior REHS O r (209)468-3440 06/08/2015 Page 3 of 6