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12 inches of additional concrete and present any release risk. Moreover, even in the remote <br /> chance that a release occurred, Sierra would immediately be aware of the occurrence and abate <br /> it. This is because the natural flow of liquid from this area deposits in the stormwater catch basin, <br /> the contents of which are routinely measured for pH. Notwithstanding,to address the concern of <br /> U.S. EPA, Sierra is evaluating whether the apply a coating to the concrete for aesthetic and <br /> housekeeping purposes. <br /> Photograph 13: <br /> OBSERVATION NO. 11: Tanks residual observed in an out-service tank. Re latou Area of <br /> Concern:A waste generator must determine if the waste generated is hazardous-waste. The <br /> facility had not determined If the waste generated is hazardous waste. 22 CCR§66262.11 [40 <br /> CFR§262.11]. <br /> RESPONSE: The Company disputes the conclusions reached by U.S. EPA. At the time of the <br /> inspection by U.S. EPA,the tank in question was already cleaned of residuals, and those <br /> residuals were properly managed. What U.S. EPA observed in the tanks was simply rainwater, <br /> dust, and/or debris that had accumulated after cleaning. Based on generator knowledge, Sierra <br /> had concluded that such accumulation in the already-cleaned tank would be non-hazardous. <br /> Since U.S. EPA's inspection, Sierra has re-rinsed the tanks, reprocessed the water, disposed of <br /> the residue, cut up the tanks, and cleaned and organized the area. See Photograph 14, below. <br /> concrete simply looks like a gravel ground. Sierra has removed the "gravel" so that the <br /> underlying concrete is evident. <br /> 12 <br /> 26731756x.9 <br />