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r <br /> Photograph 22: <br /> � I - <br /> OBSERVATION NO. 18: Unknown abandoned/discarded containers observed in a tractor <br /> trailer located along south end of the property At least one of the containers is storing an <br /> unknown solution. Regulatory Area of Concern:A waste generator must determine if the waste <br /> generated is hazardous waste. 22 CCR§66262.11 [40 CFR§26211]. <br /> RESPONSE: Sierra disputes U.S. EPA's conclusions. The solution in the container in the <br /> trailer was rinsate, which by generator knowledge Sierra had determined was not a hazardous <br /> waste. The observed drums have been cleaned and organized, and residual product has been <br /> recycled back into the system as ERM. <br /> RESPONSE TO SECTION III - <br /> AREAS OF CONCERN-GENERAL <br /> • Open, empty containers observed in outside equipment and container storage areas. Per <br /> 22 CCR§66261.70, empty containers must be marked empty along with the date the <br /> container was emptied. Additionally, containers should be stored in a manner to prevent <br /> precipitation from accumulating in the emptied containers. <br /> RESPONSE: The observed area has been organized such that the facility now has trailers <br /> designated for certain products, and areas for pallets.See Photograph 23, below. The empty <br /> containers that were observed in the designated bin during the inspection have been placed in a <br /> designated storage trailer for recycling. See Photograph 24, below, <br /> container, it is still important for the container to be covered tightly to prevent spills and air <br /> emissions. <br /> 19 <br /> 2673I756v.9 <br />