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9 <br /> After printing sheets of paperboard with the i,nk mixtures, <br /> the products are then sent to the Finishing Department where they <br /> are folded and glued into their final shapes. <br /> SITE INSPECTION <br /> U. S . EPA inspectors were escorted through the facility by <br /> facility representatives Beth Pratt and Ken Villani . Although no <br /> RCRA violations were observed at the time of the inspection, <br /> inspectors expressed some general concerns about the conditions <br /> at the facility. Inspectors suggested that all drums containing <br /> waste or raw material be labelled properly and stored closed when <br /> not in use. In addition, inspectors suggested that drums <br /> containing liquid waste be stored with the lid rings fastened. <br /> U. S . EPA received a letter from Beth Pratt (Attachment B) <br /> stating that the concerns discussed during the inspection are now <br /> being corrected. <br /> WASTE GENERATED <br /> Waste is generated from the process of cleaning the <br /> equipment used in ink printing, including the sumps, buckets, and <br /> cylinders from the printing press. The equipment is placed into <br /> a cleaning bath in the OPMR Room. The cleaning bath contains a <br /> mixture of approximately 5% cleaner and 95% water. The cleaner <br /> that is used in the bath, United Laboratories Total Surface <br /> Renovator (TSR 375 and 880) , is biodegradable and nonflammable. <br /> Waste ink is washed off into the bath and the resultant <br /> ink/water/alcohol rinsate (press water waste) is collected and <br /> disposed of as non-hazardous waste. Romic Chemical Corporation <br /> pumps tLF '„:.este out of 55-gallon drums and transports the waste <br /> off-site every month. The solid material that settles to the <br /> bottom of the drum is disposed of as sludge waste and incinerated <br /> by Romic. <br /> Waste oil , including silicone oil, gear oil, and mineral <br /> oil , is generated in the Finishing Room and picked up by Ramos <br /> Oil every two months for recycling. Approximately three 55- <br /> gallon drums of waste oil are generated every month. <br /> According to Beth Pratt, Dopaco notified U.S. EPA as a <br /> generator of RCRA regulated hazardous waste based on the <br /> hazardous waste that had been generated at the facility prior to <br /> November of 1987 , when Dopaco was using solvent-based inks. <br /> Dopaco has used only water-based inks since November, 1987, when <br /> the facility relocated to 4545 Qantas Lane. <br /> On the Notification Dopaco characterized its press water <br /> waste as ignitable on the assumption that the presence of alcohol <br /> in the waste indicated ignitability. However, the waste was <br />