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4q> SUMIDEN WIRE <br /> PRODUCTS CORPORATION <br /> June 12, 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. STLC for chromium results attached at 0.478 mg/L. <br /> n. Oily metal fines by the lathe equipment at the maintenance shop. A representative <br /> sample was submitted to Precision Enviro-Tech with 100% of sample retained through <br /> use of Sieve 120. Sumiden practice has been to collect and recycle metal shavings <br /> greater than 100 microns from industrial process and repair scrap with our metal <br /> recycle. The scrap is collected and placed in a 20 yd' container, sent to Universal Service <br /> Recycle in Stockton, CA on a Bill of Lading, bundled and prepared at Universal Service <br /> Recycle and sent to Cascade Steel Rolling Mills in McMinnville, OR to be reprocess. <br /> Attached are lab results for size and sample of bill of lading. <br /> Sincerely, <br /> Soua Her <br /> Assistant Plant Manager <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 />