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On September 1, 1993, F{GL sent the laboratory results to PHS-EHD. The results indicated the level of copper in the liquid sample reached 120 mg/L using the EPA test method 7210. The sample was then analyzed by FGL to determine the soluble level of copper which was 114.1 mg/L. This level exceeds the STLC of 25 mg/L and should be considered hazardous. IX. DISCUSSION WITH MANAGEMENT: Upon completion of the inspection, we discussed several issues. The waste reclassification analytical data was provided by Beth Pratt for later review by PHS- EHD. We reviewed the waste minimization report. Hazardous waste quantities have been reduced from 172.4 tons in 1990 to 90.24 tons in 1991. In 1992, hazardous waste generation was reduced even further to 74.28 tons. The reduction was due to many factors including the reclassification of OPMR liquid cleaning waste to a non-hazardous classification, switching to non-toxic glues, changing to non- hazardous cleaners, changing to no-VOC inks and lacquers, reducing solvent use at "Press Side", improving product and waste management, and more efficient "housekeeping". We ended our discussion by reviewing the one violation regarding the lack of decontamination equipment at the hazardous waste storage area. We informed Beth Pratt that a report of violation would be sent to her and a sample certification statement would be included. At this point, we left the facility. Upon receipt of the analytical results, I called Beth Pratt to inform her this waste stream is hazardous and should be managed as such. Ms. Pratt said she could not understand where the copper is coming from but she would look into it. She also informed me that Dopaco had their split sample analyzed by BSK Laboratory and the result was 92 mg/L using EPA test method 6010. The solubility portion of the test was not run. I informed Ms. Pratt that PHS-EHD would evaluate this new information. c: Alan Ito, CAL EPA, Department of Toxic Substances Control 6