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A A <br /> Photograph 12: <br /> r m'4-U- <br /> TE <br /> i <br /> OBSERVATION NO. 10: Observed left side secondary containment unit used to dispose/treat <br /> D002 of acid wastes is significantly cracked and deteriorated. Regulatory Area of Concern: <br /> Facilities shall be maintained and operated to minimize the possibility of afire, explosion, or <br /> any unplanned sudden or non-sudden release of hazardous waste or hazardous waste <br /> constituents to air, soil, or surface water which could threaten human health or the environment. <br /> 22 CCR§§66262.34(a)(4); 66265.31 [40 CFR§§262.34(a)(4); 265.31]. <br /> RESPONSE: As stated above, any liquid in the engineered catch basin is not a waste. <br /> Accordingly, the system is not regulated under RCRA. Furthermore, its condition is sufficient to <br /> minimize the possibility of release. To that end, the concrete is 8 - 12 inches thick. The "crack" <br /> alleged by U.S. EPA is merely a demarcation of the acid level since the acid has eroded much of <br /> the top coating of concrete. However, as evidenced by Photograph 13 below,the tap coating has <br /> not been completely eroded; some of it still remains. Siena notes this because it has taken since <br /> at least 2011, when the facility was acquired by Siena, for the thin top coating of concrete to <br /> partially erode 2. Therefore, it would take an extraordinarily long time for the acid to erode the 8 - <br /> 2 During U.S. EPA's inspection,the agency indicated concern that the containment area was <br /> unprotected ground. Siena notes, however, that the accumulation of the mostly eroded top layer <br /> I1 <br /> 26731756v.9 <br />