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SUMIDEN WIRE HAZARDOUS WASTE HANDLER TRAINING Prior to the shipment of Hazardous Waste,the manifest must be signed by both the transporter and the shipper.The only employees of Sumiden Wire who are authorized to sign a Hazardous Waste Manifest,are those who have been trained as a Hazardous Waste Handler and has personal knowledge of the Hazardous Waste that is being shipped.The manifest must be kept for 3 years. Satellite Accumulation Containers: Sumiden is allowed to maintain"Satellite" containers for the accumulation of items such as Aerosol Cans that are used throughout the plant site. The rules for a satellite container is as follows: Sumiden can accumulate up to 55 gallons,the container must have a Hazardous Waste Label,filled out using an indelible pen,the initial date of accumulation is clearly marked on the label,the container has a cover and is closed. The accumulation time is no more than one(1)year or 90 days from the time the quantity limit of 55 gallons is reached,whichever occurs first. The 90-day accumulation time limit begins on the day the container became full and is transferred to the Hazardous Waste Accumulation Area,but cannot exceed 1 year from the accumulation start date. There is no limit as to how many satellite containers Sumiden maintains,however,each must comply with the regulations. Hazardous Waste Training: Sumiden employees who perform work that generates hazardous waste or who may come in contact by handling or loading hazardous waste or who can affect compliance,must successfully complete a program of classroom instruction or on-the-job training.The training should take place within the first six months of employment or reassignment to a new position with different hazardous waste responsibilities at a facility, and have refresher training on an annual basis.The employees written Job Description for each position, must include the required skill,education,or other qualifications. The employees training records shall show the training dates and the employees Job Title,and shall be kept on file until the closure of the facility or for a period of three years after the employee leaves the company. Regulating Agencies: Sumiden Wire must operate under many different regulating agencies such as the City of Stockton Environmental Control Section for our Wastewater,the San Joaquin County Air Pollution Control District for the emissions from the Boiler,Acid Fume Scrubber,Dust Collectors,the Stockton Fire Department for fire hazards and safety issues, San Joaquin County Office of Emergency Services requires annual review of the HMMP(Hazardous Materials Management Plan), San Joaquin County Department of Environmental Health.EPA(Environmental Protection Agency),DOT(Department of Transportation),Cal-OSHA (California Occupation, Safety and Health Administration),DTSC(Department of Toxic Substance Control)and others.All want to review Hazardous Waste records and training records etc. Hazardous Waste Container and Storage Area: A weekly Inspection of all containers of Hazardous Materials and Hazardous Waste is conducted and documented.The inspector looks for potential hazards such as evidence of corrosion on containers,leaking containers,upsets,spills,closed containers,oil drum bungs installed,Empty Labels installed on empty containers,Hazardous Waste Labels installed on containers with substance in them with the generators name,substance within, Start Date,Physical State checked off,the Hazardous Properties checked off,the 90-day storage limit has not been exceeded etc. Hazardous Waste Label: Any employee who deposits a Hazardous Waste in a container is responsible for removing the Empty Label,if one is installed,and is responsible for properly filling out and installing a new,Hazardous Waste Label,as that person knows what was deposited. 6