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0 9 <br /> OBSERVATION NO. 16: Inadequate aisle space being provided to waste containers located <br /> within the hazardous waste/universal waste storage area. Regulatory Area of Concern: The <br /> owner or operator shall maintain aisle space to allow the unobstructed movement of personnel, <br /> fire protection equipment, spill control equipment, and decontamination equipment to any area <br /> offacility operation in an emergency, unless it can be demonstrated to the Department that aisle <br /> space is not needed for any of these purposes. 22 CCR§§66262.34(a)(4); 662 65.3 5[40 CFR§§ <br /> 262.34(a)(4); 265.35]. <br /> RESPONSE: Sierra believes that the storage area at the time of observation provided adequate <br /> space to allow the necessary movement of personnel, fire protection equipment, spill control <br /> equipment, and decontamination equipment to any area of facility operation in an emergency. <br /> However as a result of U.S. EPA's inspection, the Company has moved the hazardous waste <br /> storage area and enlarged it to eliminate any potential obstruction in aisles. See Photograph 21, <br /> below. <br /> Photograph 21: <br /> ee " Tr AN <br /> 1 <br /> r „ <br /> OBSERVATION NO. 17: Open, labeled satellite accumulation container. Container label is <br /> not visible for inspection. Regulatory Area of Concern:If the container is accumulating <br /> hazardous waste the container must be kept closed, except when adding or removing waste. 22 <br /> CCR§§66262.34(e)(1); 66265.173(a) [40 CFR§§262.34(a)(1); 265.173(a)]. <br /> RESPONSE: Sierra disputes U.S. EPA's conclusions. The container label was temporarily <br /> blocked from view but was easily accessible. There is no requirement that containers be bolted <br /> shut, and the lid was closed, thus satisfying the requirements of the regulations. Sierra is aware <br /> of EPA's Closed Container Guidance and believes that its practice at the time of the inspection <br /> met that guidance.3 Notwithstanding, to address the concern of U.S. EPA, the Company where <br /> practical will keep lids bolted.See Photograph 22, below. <br /> 3 The Guidance states: Because hazardous waste may be added frequently to a container in a <br /> SAA, it may not be practical for the generator to secure the cover or lid using snap rings, <br /> securely cap the bungholes, or securely fasten the container with other types of covers or lids <br /> during working hours. However, while it may not be practical to secure snap rings, etc. to the <br /> 18 <br /> 26731756v.9 <br />