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SWPC <br /> January 14, 2000 <br /> San Joaquin County <br /> Unified Program Agency <br /> Department of Toxic Substance Control <br /> Environmental Health Division <br /> 304 E. Weber Avenue <br /> Stockton, CA 95202 <br /> Attn: Letitia Briggs— Sr. R.E.H.S. <br /> J <br /> Subject: PBR Checklist and Initial Verification Inspection Report. <br /> Dear Letitia, <br /> On November 16 and 17, 1999, you and two trainees, (Mr. Steve Sasson and Ms. Alison <br /> Youngblood) called upon Sumiden Wire Products Corporation, and performed an <br /> inspection that included"Hazardous Waste Inspection Report" and"Permit by Rule <br /> Inspection Report". I offer the following response to the Permit by Rule Inspection <br /> Report. <br /> Generator Standards: <br /> Item# 3 —Meet container management standards. Filter cake must be stored in a <br /> closed, labeled container. Ferrous Sulfate bags must be labeled with an accumulation <br /> start date. <br /> Sumiden Wire was wrong in keeping what appeared to be Filter cake in the Filter Press <br /> Hopper. Even though the contents was not "Filter Cake",it may have been a hazardous <br /> material,and should have been disposed of in a timely fashion and not allowed to stay in <br /> the hopper without a label. After you took samples of the material,the hopper was <br /> emptied into the Haz-Mat bin and the contents in the Haz-Mat bin was hauled to an <br /> approved landfill for proper disposal. See Uniform Hazardous Waste Manifest <br /> #96113856 included with this report as Enclosure# 1. <br /> The enforcement of printing the accumulation start date directly on the Super Sacks was <br /> relaxed since Sumiden Wire started to re-use the Super Sacks over and over again. This <br /> had presented a problem as to the actual accumulation date, if the operator failed to <br /> blackout the previous accumulation date that was stenciled on the fabric bag. Sumiden <br /> Wire had instructed its operators to make out manila tags with their Name, Shift and Date <br /> whenever installing an empty bag on the Acid Recovery System, which we felt,met the <br /> intent of the regulation to label with the accumulation start date. Since your inspection, <br /> all Managers, Supervisors and Operators have been informed of the requirement to <br /> comply with this regulation, and we will do it. <br /> 1 <br /> SUMIDEN WIRE PRODUCTS CORPORATION <br /> 1412 EL PINAL DRIVE •STOCKTON,CA 95205 P.O.BOX 8719 •STOCKTON,CA 95208 209-466-8924 •FAX 209-941-2990 <br />