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AMENDED San Joaquin County Environmental Health Department 1868 East Hazelton Avenue , Stockton , California 95205-6232 Telephone: (209) 468-3420 Fax: (209 ) 468-3433 Web : www. slgoy. org/ehd Small Quantity Hazardous Waste Generator Inspection Report Facility Name : Facility Address : Date: PACTIV PACKAGING INC 4545 QANTAS LN , STOCKTON October 17 , 2018 Item # Remarks 102 CCR 66262 . 11 Failed to determine if a waste is a hazardous waste. The hazardous waste determination for the ink wash water is incomplete . According to the manager, all of the ink rinse water is combined and then disposed of as nonhazardous waste. The sampling for hazardous waste determination was done at the point where the ink rinse waters were combined . The determination has to be made at the point of generation . Any person who generates a waste shall determine if the waste is a hazardous waste. Immediately make a hazardous waste determination for the waste , and manage it 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 II . 103 CCR 66262 . 40(c) Failed to retain hazardous waste determination including waste analysis on site for 3 years . According to the manager, the waste streams for the ink wash water were sampled and shown to be nonhazardous . No waste analysis was available for review. This waste is being disposed of as non-hazardous waste . A generator shall make a hazardous waste determination and keep a record of any test results , waste analyses , or other determinations made in accordance with hazardous waste regulations for at least three years from the date that the waste was last disposed of. Immediately locate a copy of the waste analysis conducted for the ink wash water and submit a copy to the EHD . If a copy is unavailable , immediately make a hazardous waste determination and begin managing the ink wash water and metal fine wastes under Title 22 hazardous waste regulations . This is a minor violation . 113 HSC 25160. 2(b) (3) Failed to keep copies of consolidated manifesting receipts for three years . Copies of hazardous waste disposal records for used oil were not found on site. According to the manager, Watts comes to service the forklifts . Hazardous waste generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a consolidated manifesting procedure on site for three years and have them readily available for review. Immediately locate a copy of all manifests and receipts for the last three years , maintain them on site , and submit copies of the forklift receipts to to the EHD . This is a minor violation . 301 CCR 66262 . 34(d ) (2) Facility not maintained to minimize the release of a hazardous waste . -In the ink tank area , one metal quart sized container was flipped upside down with dried ink waste coming out of it. -In the compressor room , oily staining and oily absorbent were observed on the ground . - In the machine room , used absorbent and dried ink were observed on the ground and on the machines . - In the outside area near the empty totes , used absorbent was observed on the ground in multiple locations . Facilities shall be maintained and operated to minimize the possibility of a fire, explosion , or release of hazardous waste to air, soil , or surface water which could threaten human health or the environment. Immediately clean the wastes and manage them according to Title 22 hazardous waste regulations. Submit a statement and supporting documentation explaining how this waste was managed . This is a repeat violation , Class II , FA0002502 PR0220070 SCO01 10/17/2018 EHD 22-01 Rev. 09/22/16 Page 4 of 8 Small Quantity Hazardous Waste Generator OIR