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Item#202 The dye penetrant process is used to detect any cracks in the part. The dye penetrant (ZL-67) is applied to the part using a paint brush so it completely covers the part. It is allowed to dwell on the part for 30 minutes. This allows enough time for the ZL-67 to penetrate any cracks or voids. After 30 minutes the part is thoroughly rinsed off according to ASTM E1417. The standard requires low water pressure (we use 20 psi) and the water spray nozzle must be 12" away from the part while rinsing off the ZL-67. Very little of the dye penetrant is used and a large amount of water is required to thoroughly remove all the dye penetrant. If not thoroughly rinsed, the dye penetrant left on the part could interfere with inspector's ability to notice cracks. After completely rinsing the part, it is inspected under a black light and any cracks or voids will be easily seen. If the ZL-67 is less than 10%of the rinsewater generated, I believe that the toxicity characteristic would not apply. Item#204 Based on the definition of treatment in Title 22 California Code of Regulations, Section 66260.10, we do not feel that compacting our waste meets this definition. There are 2 parts to the definition. The first part states that"Treatment" means any method,technique, or process which changes or is designed to change the physical, chemical, or biological character or composition of any hazardous waste or any material contained therein. Compacting does not change the physical, chemical or biological character or composition of the waste. The second part states treatment removes or reduces its harmful properties or characteristics for any purpose including, but not limited to, energy recovery, material recovery, or reduction in volume. Compacting of our waste does not remove or reduce its harmful properties or characteristics. If you still consider compacting as treatment, wouldn't that also mean that you couldn't push the waste down into the drum to make more room? What's the difference? We would consider the following to be examples of treatment: (1) Evaporating solvent or water from a waste changes the physical and chemical composition of the waste, and removes or reduces its harmful properties by reducing the volume. (2) Squeezing oil from an oil soaked absorbent boom changes the physical character and composition, and removes harmful properties.