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The cleaning baths in the OPMR room generate a waste stream which is <br /> transported and disposed of as a non-hazardous waste by Romic. This waste <br /> stream was recently reclassified as non-hazardous by B C Analytical, 1255 Powell <br /> Street, Emeryville, CA. The waste stream is a liquid waste consisting of spent <br /> water-based printing ink, grease, cleanser and water from the cleaning of press <br /> cylinders, etc. The printing line waste and the OPMR waste is stored in 55-gallon <br /> drums at the points of generation until the quantity limitations are reached. These <br /> wastes are then stored in the 90 day accumulation storage area until Romic mixes <br /> all the waste and transports it off site. <br /> The lab results indicate that the OPMR waste has a pH of 12.4/12.5. Dopaco <br /> environmental staff regularly check the pH to insure the appropriate non- <br /> hazardous levels are being maintained. This waste stream was also analyzed for <br /> copper using the WET Extraction and the B C Analytical report indicates a level <br /> of 9.5 mg/L. <br /> VII. VIOLATIONS: <br /> During the inspection on August 6, 1993, only one violation was noted. The <br /> hazardous waste storage area, located to the rear of the complex, did not have <br /> adequate decontamination equipment. This violates section 66265.32 (c), Article 3, <br /> Chapter 15, Title 22, California Code of Regulations. <br /> Upon review of the OPMR waste analysis, several additional violations were <br /> discovered. The violations are as follows: <br /> 1) The generator disposed of hazardous waste improperly. Section 25189.5, <br /> California and Safety Code. <br /> 2) The generator had not adequately characterized the OPMR waste stream. <br /> Section 66262.11, Article 1, Chapter 12, Title 22, California Code of Regulations. <br /> 3) The generator offered the hazardous waste for transportation for off-site <br /> transfer, treatment, storage, or disposal without preparing a Manifest, DHS Form <br /> 8022 A. Section 66262.20 (a), Article 2, Chapter 12, Title 22, California Code of <br /> Regulations. <br /> 4) The generator did not label each package in accordance with the applicable <br /> Department of Transportation regulations on hazardous materials under Title 49 <br /> CFR Part 172 before offering the hazardous waste for transportation off-site. <br /> Section 66262.31, Article 3, Chapter 12, Title 22, California Code of Regulations. <br /> 5) The containers were not labeled with the words "Hazardous Waste". Section <br /> 66262.34 (f) (3), Article 3, Chapter 12, Title 22, California Code of Regulations. <br /> 4 <br />