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PAGTIV <br /> Foodservice/Food Packaging <br /> RECEIVED Pactiv <br /> 4545 Qantas Lane <br /> Stockton,California 95206-3982 <br /> Tel.1 3 20% www.pactiv.com NOVV �J 0 www.pactiv.com <br /> November 9, 2018 ENVIItONNIENIAL HEALI H <br /> pEpARTME„T r <br /> Mr. John Alaniz, REHS <br /> San Joaquin County <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 —October 17, 2018 <br /> Pactiv Packaging Stockton - Qantas Lane Facility <br /> Dear Mr. Alaniz: <br /> On October 17, 2018, you conducted a Small Quantity Hazardous Waste Generator Inspection <br /> at the Pactiv Packaging (Pactiv) facility located at 4545 Qantas Lane in Stockton. After <br /> completing the inspection, you provided us with an amended Inspection Report on October 22, <br /> 2018, which listed each potential violation and requested documentation of corrective actions, <br /> 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 /> 102 <br /> The hazardous waste determination for the ink wash water is incomplete. The sampling for <br /> hazardous waste determination was done at the point where the ink rinse waters were <br /> combined. The determination has to be made at the point of generation. <br /> Pactiv Response: As stated in our response to the 2015 inspection findings, Pactiv believes <br /> that the waste ink rinse water (in buckets), along with the wash tanks, are all the same waste <br /> (now referred to consistently as "ink wash water"). All of this waste is generated from the <br /> same process—washing ink off of various press parts and components using soapy <br /> water. The ink is all the same water-based inks, the same soap is used for washing, and the <br /> water/soap mixture is similar for all processes (10-20% soap). Therefore, we think our waste <br /> characterization testing to date has been representative of the point of generation, as the ink <br /> wash water initially generated in the "OPMR" room would be similar to the stored ink wash <br /> water awaiting disposal. "Note—There is no process to wash cylinders and generate ink <br /> wash water at the press. Also, note that printing no longer occurs at this facility as we are in <br />