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OBSERVATION NO. 7: Spent filter socks were observed at the facility. At least one filter sock <br /> had been placed in the trash. The facility had not determined whether or not the spent filter socks <br /> are hazardous. Regulatory Area of Concern:A waste generator must determine if the waste <br /> generated is hazardous waste. 22 CCR§66262.11 [40 CFR§262.11]. <br /> RESPONSE: The Company disputes the conclusions reached by U.S. EPA. The filter socks <br /> were determined by the Company to be non-hazardous based on generator knowledge. Sierra has <br /> since performed a fish bioassay which confirms that the material is not regulated under RCRA <br /> but is subject to certain state regulations applicable to non-RCRA hazardous waste. Accordingly, <br /> Sierra manages the filter socks in accordance with California requirements, including the <br /> establishment of a satellite accumulation drum (See Photograph 9, below), the contents of which <br /> are moved to the facility's hazardous waste storage area and properly disposed of. See <br /> Photograph 10, below. <br /> Photograph 9: <br /> 0 <br /> I <br /> 8 <br /> 2673I756v.9 <br />