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Y. <br /> _ s <br /> STATE OF CALIFORNIA <br /> JAMES M. STROCK PETE WIL5ON, Governor <br /> Secretary for Environmental Protection October / , 1991 <br /> — <br /> :55 Capitol Mall. P.O.Box 2815 <br /> Sacramento.CA 95412 <br /> (916)445-3846 <br /> Mr. Ted Kamise <br /> President <br /> Sumiden Wire Products Corporation <br /> P.O. Box 8719 <br /> Stockton, California 95208 <br /> Dear Mr. Kamise: <br /> Thank you for your letter of August 29 , 1991. Governor Wilson <br /> has asked me to respond to your request for clarification on why <br /> the Department of Toxic Substances Control (DTSC) (formerly the <br /> Department of Health Services, Toxic Substances Control Program) <br /> considers two of your "products" hazardous waste. - I also - <br /> understand that you, Mr. Robert Olson, and your attorney, Mr. Mark <br /> Connolly, met with Senator Patrick Johnston and members of the <br /> DTSC on September 19, 1991 to discuss this subject. <br /> As stated in the DTSC's April 5 , 1991 Report of Violations, a <br /> February 21, 1991 inspection by the DTSC identified violations of <br /> the California Health and Safety Code at your facility. During <br /> the inspection, the DTSC inspector evaluated the materials from <br /> the two processes in your facility which generate the products you <br /> referenced in your letter. The first evaluation was conducted at <br /> the spent sulfuric acid bath where Sumiden Wire Products <br /> Corporation' s (SWPC) manufacturing process removes scale from the <br /> wire that is dipped into the bath. The used sulfuric acid, which <br /> you term "Ferrorich, " is considered a spent pickling liquor by <br /> DTSC. As requested at the meeting with Senator Johnston, DTSC <br /> staff recontacted the Federal Environmental Protection Agency <br /> Resource Conservation and Recovery' Act (RCRA) Hotline on <br /> September 19 , 1991 to consult with them again on the <br /> classification of the spent sulfuric acid bath. A second Hotline <br /> opinion also concurs with the opinion of the DTSC Alternative <br /> Technology Division, that the process generates a RCRA regulated <br /> K062 listed waste. <br /> A second evaluation point was the zinc plating bath which is <br /> used to coat the de-scaled wire with a layer of zinc. The <br /> materials which SWPC discharges from this plating bath (Ferrozinc <br /> Concentrate) are the result of a dewatering process which produces <br /> a zinc filtercake. The zinc filtercake, which was sampled by the <br /> DTSC inspector, is considered a hazardous waste due to the process <br /> by which it is generated and due to the high concentrations of <br /> zinc. A further concern expressed by the DTSC is that the zinc <br /> filtercake also contains smaller, but significant, quantities of <br />