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<br /> <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 /> <br />July 28, 2020 <br /> <br />Soua Her <br />Assistant Plant Manager <br />Sumiden Wire Products Corporation <br />1412 El Pinal Drive <br />Stockton, CA 95205 <br /> <br />Re: RCRA Large Quantity Hazardous Waste Generator Inspection Report 7/7/2020 <br /> <br /> <br />Dear Lydia Baker, <br /> <br />Below are details explaining corrections to the violations cited on 7/7/2020. <br /> <br />Item #122. HSC 25143.10 Failed to provide information for >100kg/month recyclable material <br />to claim the exclusion or exemption. Greater than 100kg/month of ferrous sulfate is being <br />recycled by the facility. Facility recycled 124 cubic yard bags of ferrous sulfate so far in the year <br />2020. A recyclable materials report was not uploaded to CERS and was not available for review <br />during the inspection. <br /> <br />Uploaded to CERS and attached is a copy of the Unified Program Consolidated Form Recyclable <br />Materials Report for Sumiden Wire Products Corporation for recyclable material Ferrous Sulfate <br />Heptahydrate, see Exhibit A. During your visit to the site, Sumiden was unable to produce the <br />tracker and report for the previous two years’ shipment of Ferrous Sulfate to pair with Straight <br />Bill of Lading records. Included in Exhibit A is the Unified Program Consolidated Form Recyclable <br />Materials Report for Ferrous Sulfate Heptahydrate, supporting documents of known market for <br />the material, original excel tracker for calendar year 2018 and 2019, updated tracker created <br />7/28/2020 to include load specific Shipper’s No. and copies of Strait Bill of Lading. <br /> <br />Item #303. CCR 66265.33 Failed to maintain all communication or alarm systems, spill control, <br />or decontamination equipment. The secondary containment pallet for the oily solids drums <br />located in the used oil storage area was observed with a dark liquid inside of it. <br /> <br />Observed was one 16”x9” surface area covered with used oil inside one 65-gallon secondary <br />containment. The liquid oil was cleaned up using multiple pieces of oily rags. The rags were <br />then placed inside the 5-gallon container which is emptied weekly by Cintas for industrial <br />laundry. See Exhibit B. <br /> <br /> <br /> <br />