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_ MORRIS ENGINEERING & ASSOCIATES, INC. CONSULTING ENGINEERS May 14,2011 Wayne Mannor Sumiden Wire Products Corporation 1412 El Pinal Drive Stockton,CA 95205 Tank System Integrity Report On May 5th 1 visited Sumiden Wire Products Corporation to conduct a system integrity assessment of the following tanks,and secondary containment of the Wastewater Discharge& Treatment Area: Tank# Description T1 Rust Inhibitor Bath T2 Heavy Metal Clarifier T3 Filter Press Our system integrity assessment consisted only of a visual inspection of the tanks,and secondary containment The tank system under certification is not currently treating or storing hazardous waste as defined by Federal and State Regulations. The Rust Inhibitor Bath is currently filled with a Lime-Borax solution which is not considered a hazardous waste by Federal or State Regulations. However,the tank is being certified for hazardous waste storage to allow the flexibility of modifying the system to a Zinc-Phosphate solution in the future. The Filter Press and the Heavy Metal Clarifier are not currently operational and have had all of their associated piping removed. The tanks are being certified to allow the flexibility of using them in the future to treat hazardous waste. If in the future it is decided to use these tanks as part of a system that handles hazardous wastes,any installed piping and associated pumps will need to be certified before the system is used in operation. During our inspections we were able to inspect the exterior of all the tanks,and the interior of the tanks where they were visible. The Rust Inhibitor Bath was full during our inspection,and therefore we were not able to perform a thorough inspection of the interior of the tank. However,the tank did not appear to be leaking. No leak tests,or other tank system integrity examination (i.e.ultrasonic,volumetric tank test,pipeline pressure, etc.)were performed. While not required at this time,it is recommended that a leak test be performed on the Heavy Metal Clarifier before it is used in operation to confirm the water tightness of the removable panels. The secondary containment for the tanks consisted of a concrete berm surrounding the tanks and an underground sump. The secondary containment generally appeared to be in good condition,but some repairs will need to be made prior to using it as containment for hazardous wastes. The repairs are not required to be made at this time,but should be completed prior to switching to a zinc-phosophate solution or other hazardous waste. The concrete berm appeared to be in good condition,but there were several structural cracks that should be repaired to ensure the tightness of the containment The underground sump also had several structural cracks in the concrete walls that should be repaired. Additionally,the epoxy coating appeared to be worn in the sump and the bermed area. It is our recommendation that the epoxy coating be reapplied to ensure the secondary containment is behaving as designed. An epoxy specialist should be consulted prior to applying the coating to confirm the type of epoxy that should be applied. It is also recommended that a leak test be performed on the underground sump after the repairs have been made to ensure its water tightness. 1300 INDUSTRIAL ROAD, SUITE 14,SAN CARLOS,CA 94070, (650)595-2973 FAX(650)595-2980 Email: lee@morriseng.com