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July 14, 1995 <br /> Mr. Robert Olson <br /> Sumiden Wire Products Corporation <br /> 1412 El Pinal Drive <br /> Stockton CA 95207 <br /> RE : REPORT OF VIOLATION AND SCHEDULE OF CORRECTION <br /> On July 13 , 1995, San Joaquin County Public Health Services (PHD- <br /> EHD) conducted a joint Hazardous Waste Generator/Tiered Permitting <br /> Inspection of Sumiden Wire Products Corporation located at 1412 El <br /> Pinal Drive in Stockton. <br /> As a result of that inspection violations of the hazardous waste <br /> statues and or regulations were identified. Several violations <br /> were listed in the notice to comply given at time of inspection. <br /> Further violations were found during inspection and documentation <br /> review of Sumiden Wire Products . <br /> I. REPORT OF VIOLATIONS: <br /> Waste Minimization: <br /> 1 . Section 25244 .4 Division 20, Chapter 6 . 5, CA Health & Safety <br /> Code (CA H & S) : Sumiden Wire Products Corporation (SWPC) <br /> Hazardous Waste Minimization Plan does not meet minimum state <br /> reporting requirements . <br /> 2 . Section 25244 . 19 (b) (3) (A-C) CA H & S : SPWC' s Hazardous Waste <br /> Minimization Plan does not identify each hazardous waste <br /> stream produced from generation point to final disposal <br /> location. <br /> 3 . Section 25244 . 19 CA H & S (b) (3) (A) : SWPC' s Hazardous Waste <br /> Minimization Plan does not quantify each hazardous waste <br /> stream produced. <br /> 4 . Section 25244 . 19 CA H & S (4) (f) SWPC' s Hazardous Waste <br /> Minimization Plan is not certified by a registered engineer. <br /> Illegal Operations : <br /> 5 . Section 25189 . 5 CA H & S Code : On February 23 , 1995, SWPC <br /> Shipped 11 . 08 ton Ferrous Sulfate to Tech-Iron, P.O. Box <br /> 50426 , Indianapolis IN 46250-0426 was taken to Van Walters <br /> & Rogers 2 . 5 miles East of Old Highway 140, Carlin, Nevada. <br /> Shipping was done through a company called Crown Technology, <br /> Inc . Telephone # (317) 845-0045 . During manifest review I did <br /> not see a manifest or manifest # for this shipment . <br /> 6 . Section 66262 . 11 California Code of Regulations (CCR) : At the <br /> time of inspection, SWPC did not have proof that the Ferrous <br /> Sulfate was non-hazardous . <br /> 7 . Section 66262 . 11 (CCR) : SWPC is holding sludge in a bin under <br /> the filter press . This sludge resembles the old zinc <br /> phosphate sludge (grey color) seen on the August 23 , 1989 <br /> inspection. SWP has failed to clearly identify this waste by <br /> determination for all four hazardous characteristics . <br />