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4<> SUMIDEN WIRE <br /> PRODUCTS CORPORATION <br /> May 28, 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 RCRA Large Quantity Hazardous Waste Generator Inspection Report <br /> Date 4/23/2019 <br /> Dear Tricia Dai, <br /> Below are details explaining corrections to the violations cited on 4/23/2019. <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 /> a. (2) totes (265gallon an d330gallon) container of cooling tower water. The collection of <br /> the water was from inside the cooling tower containment. Cooling tower water <br /> operates under profile #631171CA as non-hazardous liquid. The water was reclaimed <br /> and used in cooling tower water system. <br /> b. (1) waterless battery stored inside of the storage building (bone yard) fence. Battery was <br /> treated as universal waste, battery banks separated and taken to Nor Cal Batteries Co. <br /> 3432 Cherokee Road, Stockton CA 95205 for recycle on 5/10/2019. <br /> c. (1) container of unknown oily sludge substance on top of a 55gallon oily water at the <br /> used oil area. Sludge was determined to be used lube, NON-RCRA CA Hazardous Waste. <br /> Substance was wiped off with red rag and placed inside oily absorbent container for <br /> disposal. <br /> d. Oily absorbent pad left on top of a used oil drum at the drums in oil storage area. All <br /> towels and pads which contained oil were removed and placed into 55gallon oil <br /> absorbent drum and treated as NON-RCRA CA Hazardous Waste. <br /> e. Open 55-gallon drum labeled as Empty inside of oil storage building still contained some <br /> oil. The cut open top drum is used as transport when changing out machine oil as part of <br /> preventative maintenance. Used oil contents were pumped into 250gallon tote, turned <br /> upside-down on top of secondary containment, labeled as appropriate with all <br /> maintenance personnel communicated to continue practice of turning upside-down <br /> after use. <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 />