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SAN ` , J O A Q U I ` , Environmental Health Department COUNTY— AMENDED FTD 4-29-19 RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: SUMIDEN WIRE PRODUCTS CORPORATION 1 1412 EL PINAL DR, STOCKTON April 23, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 123 HSC 25143.10 Failed to provide information for>100 kg/mo recyclable material to claim the exclusion or exemption. Sumiden uses sulfuric acid to clean wire. When the sulfuric acid is spent it is processed to reclaim the sulfuric acid for reuse onsite. The process produces ferrous sulfate which is bagged and then shipped to Philbro—Tech, Inc, 8851 Dice Road, Santa Fe Springs, CA 90670. The bags of ferrous sulfate are labeled "Ferrous Sulfate"only. Sumiden could not provide documentation to satisfy section HSC 25143.10(a)(3)listed below. California Health and Safety Code(HSC)25143.9. A recyclable material shall not be excluded from classification as a waste pursuant to subdivision (b)or(d)of Section 25143.2, unless all of the following requirements are met: (a) If the material is held in a container or tank,the container or tank is labeled, marked, and placarded in accordance with the department's hazardous waste labeling, marking, and placarding requirements which are applicable to generators, except that the container or tank shall be labeled or marked clearly with the words"Excluded Recyclable Material"instead of the words"Hazardous Waste,"and manifest document numbers are not applicable. California Health and Safety Code 25143.10 (a) Except as provided in subdivisions (e)and (f), any person who recycles more than 100 kilograms per month of recyclable material under a claim that the material qualifies for exclusion or exemption pursuant to Section 25143.2 shall, on or before July 1, 1992, and every two years thereafter, provide to the local officer or agency authorized to enforce this section pursuant to subdivision (a)of Section 25180, all of the following information, using the format established pursuant to subdivision (d), in writing: (1) The name, site address, mailing address, and telephone number of the owner or operator of any facility that recycles the material. (2) The name and address of the generator of the recyclable material. (3) Documentation that the requirements of any exemptions or exclusions pursuant to Section 25143.2 are met, including, but not limited to, all of the following: (A) Where a person who recycles the material is not the same person who generated the recyclable material, documentation that there is a known market for disposition of the recyclable material and any products manufactured from the recyclable material. (B) Where the basis for the exclusion is that the recyclable material is used or reused to make a product or as a safe and effective substitute for a commercial product, a general description of the material and products, identification of the constituents or group of constituents, and their approximate concentrations, that would render the material or product hazardous under the regulations adopted pursuant to Sections 25140 and 25141, if it were a waste, and the means by which the material is beneficially used. Label all Ferrous Sulfate Excluded Recyclable Material (ERM)with the following"Excluded Recyclable Material", Sumiden's name and address,the physical state and hazardous properties of the ferrous sulfate, accumulation start date, and "Ferrous Sulfate". Provide documentation that there is a known market for disposition of the recyclable material and any products manufactured from the recyclable material. This is a repeat violation, Class ll. FA0001479 PR0220094 SCO01 04/23/2019 EHD 22-03 Rev.09/27/2018 Page 7 of 12 RCRA Large Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com