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SUMIDEN WIRE <br /> PRODUCTS CORPORATION <br /> July 28, 2020 <br /> Soua Her <br /> Assistant Plant Manager <br /> Sumiden Wire Products Corporation <br /> 1412 EI Pinal Drive <br /> Stockton, CA 95205 <br /> Re: RCRA Large Quantity Hazardous Waste Generator Inspection Report 7/7/2020 <br /> Dear Lydia Baker, <br /> Below are details explaining corrections to the violations cited on 7/7/2020. <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 /> 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 /> 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 /> 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 /> 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 />