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SAN J OAQU I N Environmental Health Department CC LJ N T Y------- RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: SUMIDEN WIRE PRODUCTS CORPORATION 1 1412 EL PINAL DR, STOCKTON July 07, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 122 HSC 25143.10 Failed to provide information for>100 kg/mo recyclable material to claim the exclusion or exemption. OBSERVATION: Greater than 100 kg/month of ferrous sulfate is being recycled by the facility. Facility recycled 124 cubic yard bags of ferrous sulfate so far in the year 2020. A recyclable materials report was not uploaded to CERS and was unavailable for review during the inspection. REGULATION GUIDANCE: (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. (b) Except as provided in Section 25404.5, the governing body of a city or county may adopt an ordinance or resolution pursuant to Section 101325 to pay for the actual expenses of the activities carried out by local officers or agencies pursuant to subdivision (a). (c) If a person who recycles material under a claim that the material qualifies for exclusion or exemption pursuant to Section 25143.2 is not the same person who generated the recyclable material, the person who recycles the material shall, on or before July 1, 1992, and every two years thereafter, provide a copy of the information required to be submitted pursuant to subdivision (a)to the generator of the recyclable material. (d) The person providing the information required by subdivision (a)shall use a format developed by the California Conference of Directors of Environmental Health in consultation with the department. The department shall distribute the format to local officers and agencies authorized to enforce this section pursuant to subdivision (a)of Section 25180. (e) A recyclable material generated in a product or raw material storage tank, a product or raw material transport vehicle or vessel, a product or raw material pipeline, or in a manufacturing process unit or an associated nonwaste treatment manufacturing unit is not subject to the requirements of this section, until the recyclable material exits the unit in which it was generated, unless the unit is a surface impoundment, or unless the material remains in the unit for more than 90 days after the unit ceases to be operated for manufacturing, storage, or transportation of the product or raw material. (f) A local officer or agency authorized to enforce this section pursuant to subdivision (a)of Section 25180 may exempt from subdivision (a)any person who operates antifreeze recycling units or solvent distillation units,where the recycled material is returned to productive use at the site of generation, or may require less information than that required under subdivision (a)from the person. CORRECTIVE ACTION: Immediately submit a Recyclable Materials Report in CERS and provide a copy to the SJC EHD for the ferrous sulfate that you wish to claim the exclusion or exemption and provide that information FA0001479 PR0220094 SCO01 07/07/2020 EHD 22-03 Rev.9/20/2019 Page 7 of 9 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