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VIII. OBSERVATIONS: On August 6, 1993, Carol Oz and I arrived at Dopaco at approximately 9;30 a.m. We met with Beth Pratt and immediately began the facility inspection. We began in the printing room where we observed hazardous waste containers located at their points of generation. Appropriate spill, fire, and decontamination equipment was readily available in the event of a spill or leak. After the "Printing and Thermoformer room", we inspected the OPMR room where printing equipment is cleaned, stored, and prepared for production. This is where the Safety Kleen solvents are used. We then walked to the rear of the complex and outside where hazardous waste and hazardous materials are stored. A fenced, labeled, and bermed enclosure has been built to more securely store these chemicals. The hazardous wastes and materials were separated by a 10" cement berm. We noted that there was no personal decontamination equipment available at this location. Beth Pratt made note of this also and agreed to provide the required equipment. From here, we went back inside to the "Finishing Room". This is a highly automated equipment room where the printed paper products are formed, glued, and prepared for shipping. Upon completion of the facility inspection, we regrouped in the conference room to review required documents which include hazardous waste manifests, bills of lading, land disposal restriction forms, employee training records, the contingency plan, biennial report for 1990-1991, hazardous waste minimization plan, and the hazardous waste minimization report. On August 17, 1993 Eleanor Ratliff and Carol Oz returned to the site to obtain a sample of the OPMR waste stream which was recently reclassified as non- hazardous by Dopaco. The sample was obtained from the drum adjacent to the ink cylinder bath. The sample was properly labeled and sealed with custody tape. The sample I.D. number was 81793A. The sample was then placed in a plastic bag and immediately transferred under chain of custody to FGL Laboratory for analysis. The analysis requested was pH, flammability, and copper. A Waste Extraction Test was requested if the level of copper exceeded the Soluble Threshold Limit Concentration (STLC). Paul Rubia, Printing Services Supervisor, observed the sampling and questioned the sample location. He stated that Dopaco obtained their sample from a large mixture of OPMR and printing line waste after it was pumped into a transportable tank by Romic. I stated that I believed this location would yield the most representative sample. We gave Paul Rubia a duplicate sample which was labeled and sealed with custody tape. 5