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2 _ <br /> F Jr <br /> CERTIFIED MAIL <br /> Mr. Ted Kamise, President <br /> Sumiden Wire Products Corporation <br /> 1412 E1 Pinal Drive <br /> P.O. Box 8719 <br /> Stockton, CA 95208 <br /> Dear Mr. Kamise: <br /> As requested by Mr. Tyler Hammond in Assembly Member Dean <br /> Andal ' s office, I am writing to you to formally restate the <br /> Department of Toxic Substances Control 's (DTSC) rationale for <br /> considering the substances generated by Sumiden Wire Products <br /> Corporation (SWPC) as hazardous wastes. This is the same <br /> information which was verbally conveyed in our September 19 , 1991 <br /> meeting with you, Mr. Robert Olson, and Mr. Mark Connolly in <br /> Senator Patrick Johnston' s office. Additionally, a portion of this <br /> rationale was contained in a letter to you dated October 7 , 1991 <br /> from James E. Strock, Secretary for Environmental Protection (new <br /> Cal-EPA) . I also understand that your attorney, Mr. Mark Connolly, <br /> has requested this information through Mr. Hammond. <br /> As you are aware, the DTSC' s February 21, 1991 inspection of <br /> SWPC raised questions about the classification of the materials <br /> generated as the result of two industrial manufacturing processes <br /> conducted at your facility. The first process involves dipping <br /> steel wire into a sulfuric acid bath which removes rust and scale <br /> from the wire. It was the DTSC' s initial interpretation that the <br /> used acid bath was a spent pickling liquor, and defined by the <br /> Federal Resource Conservation and Recovery Act (RCRA) as a K062 <br /> listed hazardous waste. Since the primary responsibility for <br /> interpreting the RCRA statutes and regulations rests with the <br /> Federal Environmental Protection Agency (EPA) , DTSC staff twice <br /> consulted the RCRA Hotline to solicit EPA' s interpretation of the <br /> federal regulations with regard to the waste classification <br /> determination. Both consultations on different days concluded that <br /> the spent acid bath is a hazardous waste. The RCRA Hotline is a <br /> federal information assistance program established to provide <br /> information on and clarification of the federal hazardous waste <br /> regulations and statutes. As an informational note, the RCRA <br /> Hotline number is (800) 424-9346. <br /> The second process evaluated by the DTSC involves the zinc <br /> plating bath which is used to coat the de-scaled wire with a layer <br /> of zinc. The waste which SWPC discharges from the plating bath, <br /> results from a de-watering process which produces a zinc <br /> filtercake. The filtercake was sampled by the DTSC inspector. Due <br /> to the high concentrations of zinc and the process by which the <br /> zinc is generated, the DTSC considers the zinc filtercake a <br /> hazardous waste. . <br /> Additionally, I have enclosed a copy of the September 16 , 1991 <br /> memo from Mr. Robert McCormick, Alternative Technology Division <br />