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1%.. <br /> I believe Items 15, 16 and 17 are all related to Item 12 above. Sumiden Wire has not <br /> changed its PBR process. We did discuss with you and your team,the possible future use <br /> of the filter press to remove residual solids from one of our cooling towers, however we <br /> have never tried this yet. <br /> Item# 19—There are written operating instructions and a record of the dates, <br /> volumes, residual management, and types of wastes treated in the unit. —Inspectors did <br /> not see the written operating instructions and record for the treatment unit. <br /> There are written operating instructions and record keeping program for this treatment <br /> unit. Please see Enclosure# 3 for the"written operating instructions" and Enclosure#4 <br /> for the record form. <br /> Item# 22—If the unit has been closed,the generator has notified DTSC and the local <br /> agency of the closure.—If the treatment unit is no longer being used for the Zinc <br /> Phosphate treatment process the unit must be properly closed, with notification to DTSC <br /> and EHD. <br /> We had not closed this unit in the past, pending our decision to continue or dis-continue <br /> the use of lime borax as a substitute for Zinc Phosphate in the foreseeable future. <br /> Sumidens reluctance to go through a closure was based solely on the time, cost and effort <br /> to restart the whole program over again in the future. I have now asked the offices of <br /> Brown and Caldwell to advise Sumiden Wire on this subject. Based on advice from our <br /> Environmental Consultants, we will either fill our Form 1772 or perform closure of the <br /> PBR unit. <br /> For each PBR unit: <br /> Item # 24—There is a waste analysis plan.—A waste analysis plan was not available <br /> during the inspection. <br /> Sumiden Wire Products does have a waste analysis plan. Please see Enclosure# 5. <br /> Item#25 —There are waste analysis records.—Waste analysis records are incomplete. <br /> Keep records of analysis for each waste stream on site. <br /> Please see the enclosed TTLC, TCLP, and STLC as Enclosure# 6 <br /> Item# 27—The appropriate local agency has been notified. HSC 25143.10— See# 12. <br /> The treatment has not changed, the treatment has been stopped and on hold pending <br /> decision. Please see answer to Item# 22 above. <br /> Item # 28—Activities claimed under the onsite recycling exemption are appropriate. <br /> HSC 25143.2 et sec. —Activities claimed under the onsite recycling exemption are <br /> unknown at time of inspection. Submit Recyclable Materials Reporting Form to EHD by <br /> 12/19/99. <br /> The Recyclable Materials Reporting Form has been filled out and is enclosed under <br /> Enclosure# 2 <br /> 3 <br />