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SUMIDEN WIRE HAZARDOUS WASTE HANDLER TRAINING Sumiden Wire is a Large Quantity Generator (LQG). A Large Quantity Generator is a generator that generates >I 000 kilograms (2200) pounds of RCRA hazardous waste or > 1 kilogram (2.2 pounds) of acutely hazardous waste per month. In California, the definition of a Large Quantity Generator combines the volume of both Non-RCRA and RCRA hazardous waste. As an example over the last several years, Sumiden has averaged the following amounts of wastes per year. Waste Federal Codes State Codes Quantity Phosphoric Acid/Water D002 791 2.87 Ton Sulfuric Acid/Water KO62 / D002 791 11.42 Ton Sulfuric Acid/Solids KO62 / D002 791 17.05 Ton Used Oils & Oily Water 221 9.56 Ton Waste Aerosol Cans <1 liter D001 181 0.18 Ton Manifest: The Manifest is the Federal Shipping Document, EPA form 8700-22. It is a required form, and is the documentation for the transportation of hazardous waste, and is a paper trail from start to finish of the shipment and is also the documentation for what some refer to documenting the Cradle -to -Grave issues for the generator. Normally, the Generator makes out the manifest, however, in some cases, the Transporter or the Designated Facility will make it out prior to their arrival to pick up the waste. In many cases the Transporter and the Designated Facility are owned by the same company. As of September 5th, 2006, all generators are required to use Form 8700-22, and the old "Uniform Hazardous Waste Manifest" will no longer be acceptable. Unlike the old form that contained colored pages, the new form is six (6) pages and is only White in color. The Original page, stays with the waste from the time it leaves the site until it reaches the designated facility it is being shipped to. It contains all the required shipping information and signatures of all parties handling the waste during the shipping process. The manifest describes the waste in accordance with the EPA and DOT requirements including the quantities of the waste shipped on the manifest, the date it was shipped and the date it was received and accepted at the TSDF (Designated Facility). It also contains the emergency 24-hour telephone number and any discrepancies. When the waste is accepted by the TSDF. They will mail the original page-one of the manifest to the State where the waste was shipped to. In Sumidens case with the Pickling Bath Liquid (K062), it is normally shipped to Fernley Nevada. In this case, the original page of the manifest will be mailed to DTSC in Nevada. The second copy stays with the waste from the time it leaves Sumiden, until it reaches the designated facility. Then it too gets mailed out, but because the waste was generated in California, the second copy goes to DTSC in Sacramento. The third copy is commonly referred to as the "Generators Copy". It is an exact duplicate of the original with all dates and signatures and gets mailed back to the generator as a form of receipt that the waste has arrived and has been accepted. The fourth copy is also a duplicate of the original and stays with the Designated Facility. The fifth copy is a duplicate of the original and goes to the transporter of the waste. The sixth copy stays with the generator when the waste is shipped, and does not have the signature of the designated facility, and serves only that the waste has been shipped. When Sumiden receives the third copy back from the designated facility, it is filed with the sixth copy that Sumiden retained at shipment. Sumiden is also required to mail a copy of the manifest within 30 days to DTSC in Sacramento. As there is not an extra copy to send to DTSC, it would be prudent to make a copy of the original, prior to the load leaving the plant. This way, it would be the most legible copy. 2