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4q> SUMIDEN WIRE <br /> PRODUCTS CORPORATION <br /> June 3, 2019 <br /> Soua Her <br /> Assistant Plant Manager <br /> Sumiden Wire Products Corporation <br /> 1412 EI Pinal Drive <br /> Stockton, CA 95205 <br /> Re: Response to Sumiden Wire Corp - 1412 EI Pinal Dr- Return to Compliance Status email <br /> sent 5/30/2019 <br /> Dear Tricia Dai, <br /> Below are details explaining corrections and or clarification to your email request. <br /> Item#102. CCR 66262.11 Failed to determine if a waste is a hazardous waste. Any person who <br /> generates a waste shall determine if the waste is a hazardous waste. Immediately, make a <br /> hazardous waste determination for the following wastes, and manage it according to Title 22 <br /> hazardous waste regulations. See supporting PDF files Item 102A/B. <br /> i. Used drawing lube need STLC for chromium. TTLC chromium level is more than 10 times <br /> the STLC limit. Testing in progress. Will submit test result as soon as they become <br /> available? <br /> j. Parts washer waste in the maintenance shop. The parts washer uses the material Bio- <br /> Circle L which is non-hazardous per SDS. However, when the liquid cleaning agent is no <br /> longer effective and because it has come in contact with oil and/or has become oily <br /> water solution, the liquid is pumped into the oily water container to be process by an <br /> authorized facility. Treating facility U.S. EPA ID CAL000190816 Riverbank Oil Transfer <br /> processed the collected oily water under Management Code H141. H141 is defined as, <br /> the site receiving this waste stored/bulked and transferred the waste with no treatment <br /> or recovery (H010-H129), fuel blending (H061), or disposal (H131-H135) at that receiving <br /> site. See manifest#015864909JJK and 018248866JJK. <br /> n. Oily metal fines by the lathe equipment at the maintenance shop. Metal fines were <br /> gathered and disposed along with our hard steel recycle materials. Established cleaning <br /> scheduled with communication to maintenance and plant team as standard operating <br /> procedure to clean up fines after they are made. <br /> Additional request to provide hazardous waste determination for metal fines <br /> demonstrating they are safe for recycle. Metal fines that are less than 100 microns <br /> SUMIDEN WIRE PRODUCTS CORPORATION <br /> 710 MARSHALL STUART DR•DICKSON,TN 37055•(615)446-3199 <br /> 1412 EL PINAL DR•STOCKTON,CA 95205•(209)466-8924 <br /> 1800 HIGHWAY 146•DAYTON,TX 77535•(936)257-6010 <br />