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SUPPORTING DOCUMENTATION Violation #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 Standard Practice for Liquid Penetrant Testing, Section 7 . 3 Penetrant Removal , and 7 . 3 . 1 . 1 Manual Spray ( attached ) . The standard requires low water pressure ( we use 20 psi ) and the water spray nozzle must be a minimum distance of 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 . Since the LD50s mentioned in the inspection report were for the pure ZL-67 itself, and based on the assumption that the ZL- 67 is less than 10% of the rinsewater generated , which I believe to be pretty conservative , I believe that the calculated toxicity would be above the threshold and the rinsewater would not be considered a toxicity characteristic hazardous waste . I ' ve also attached results of analytical testing ( ignitability and hazardous waste bioassay ) of the dye penetrant rinse water that was performed in 2017 . Violation #204 Based on the definition of treatment in Title 22 California Code of Regulations, Section 66260 . 10, we do not agree that compacting our waste is in any way "treatment" . Per the regulations , 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 the waste 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 . It is our position that compacting the waste is physically the same as manually pushing the waste into a drum to make more room . We are simply reducing the volume , and not treating it, which is beneficial to everyone, including the waste disposal sites . Without compacting, we estimate that we would be sending 2 -3 times as many 55 gallon drums to the waste disposal facility than we currently do . i 1 By contrast, we would consider the following to be examples of treatment per the regulation definition : ( 1 ) Intentionally evaporating solvent or water from a waste which changes the physical and chemical composition of the waste, and removes or reduces its harmful properties by reducing the volume . ( 2 ) Intentionally squeezing or extracting oil from an oil soaked absorbent boom changes the physical character and composition , and removes harmful properties .