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GYM:Y <br /> APR 15 1991 <br /> SWPC ENvtRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> April 11, 1991 <br /> DEPARTMENT OF HEALTH SERVICES Certified No. P 515 899 594 <br /> Toxic Substances Control Program <br /> Region 1 <br /> 10051 Croydon Way, Suite 3 <br /> Sacramento, California 95827-2106 <br /> Attention: Ms. Susan J. Laney, Chief <br /> Sacramento Complaint Unit <br /> Surveillance and Enforcement Branch <br /> Ref: REPORT OF VIOLATIONS Dated April 5, 1991 and February <br /> 21, 1991 inspection by Dept. of Health Services (DHS) <br /> conducted at Sumiden Wire Products Corporation (SWPC) . <br /> Dear Ms. Laney: <br /> The following is SWPC's action to subject violations letter: <br /> la. SWPC has contracted to have all waste oil to be removed <br /> and properly disposed of every 60 days. <br /> lb. Waste oil drums(5) have been removed by certified <br /> contractor and have been properly disposed. <br /> 2a. SWPC produces Zinc Phosphate filter cake. Although, Zinc <br /> Phosphate filter cake is not a "waste" , SWPC will treat it <br /> as such per instructions from your office. SWPC is doing <br /> this under protest. <br /> 2b. SWPC produces an iron enriched Sulfuric Acid solution. <br /> Iron enriched Sulfuric Acid is not a "waste" . Per the <br /> instructions from your office SWPC will treat it as a <br /> Hazardous Waste. However, SWPC is doing this under protest. <br /> 3 . SWPC has labeled the two 55-gallon drums of Zinc Phosphate <br /> cake. As we mentioned in 2a above, Zinc phosphate cake is <br /> not a waste. However, per your instruction SWPC will treat <br /> it as a "Hazardous waste" . <br /> 4a. Containers (4) of waste oil have been labeled with Hazardous <br /> Waste accumulation labels. <br /> 4b. This is the same material as stated in 2a. (Zinc Phosphate <br /> filter cake is not a "waste") . The Zinc Phosphate 10 cubic <br /> yard bin was properly labeled by the Department of <br /> Transportation (DOT) . However, as in 2a SWPC has labeled <br /> the bin including accumulation dates. <br /> SUMIDEN WIRE PRODUCTS CORPORATION <br /> 1412 EL PINAL DRIVE•STOCKTON,CA 95205 P.O.BOX 8719•STOCKTON,CA 95208 209-466.8924•TELEX 359424 <br />