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RCRA Inspection Report U.S. Environmental Protection Agency w Region IX Hazardous Waste Management Division Waste Compliance Branch BACKGROUND Dopaco, Inc. , located in Stockton, California, EPA ID Number CAD982415804, notified the U.S. Environmental Protection Agency (U.S. EPA) on November 24, 1987, as a generator of hazardous waste (Attachment A) . The facility has been located at 4545 Qantas Lane, Stockton, since November, 1987. From 1979 until 1987, the facility was located at 800 W. Church Street, Stockton. On May 20, 1992, representatives from the U.S. EPA conducted a Resource Conservation and Recovery Act Compliance Evaluation Inspection (RCRA CEI) to determine Dopaco's compliance with hazardous waste regulations. Based on the records of the U.S. EPA and the California EPA Department of Toxic Substances Control, no inspection has previously been conducted at this facility to evaluate Dopaco-s compliance with RCRA. However, a routine inspection was conducted at this facility on October 10, 1990, by the San Joaquin County Public Health Services as part of the Public Health Services-Environmental Health Division Hazardous Waste Generator Program. As a result of this inspection, violations of the California Code of Regulations were identified, including the presence of unlabelled drums containing hazardous waste, an unattended open drum containing hazardous waste, and the absence of health & safety training records. PROCESS Dopaco, Inc. manufactures paperboard cartons, paperboard cups, and plastic cup lids for the fast-food industry. Roto- gravure printing presses are used to print designs onto paperboard with inks. Dopaco purchases water-based ink and mixes it with an extender and an alcohol/water mixture before using it for printing. The extender is composed of the same constituents as the ink, but does not contain any pigments. The alcohol/water mixture, which may include isopropyl alcohol, isobutyl alcohol, and n-propyl alcohol , is composed of approximately 80% water and 20% alcohol and is added to the ink in order to maintain the desired viscosity and color of the product. The final ink mixture used for printing is composed of approximately 50% pure ink (as received by the manufacturer) , 25% alcohol/water mixture, and 25% extender. In addition, ammonium hydroxide may be used, if necessary, to raise the pH of the ink mixture to 9. A pH below 9 may cause the ink pigment to separate, resulting in color streaking. A high pH may result in the erosion of the cylinder of the printing press.