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r <br /> The Inspection Findings state that Sierra must obtain a RCRA identification number. Please note <br /> that the Company has submitted an application,through ACT Environmental Services, for a <br /> RCRA identification number. The application was submitted on April 28,2016, and notification <br /> of the application has already been provided to the U.S. EPA Region 9 office. See Exhibit J. <br /> The Inspection Findings state that the inspectors reviewed certain hazardous waste manifests and <br /> land disposal restrictions found in the facility's manifest files, and observed that copies of <br /> certain manifests were not being maintained at the facility. The Company notes that all copies of <br /> manifests were at the facility,however some had been misfiled and thus were not immediately <br /> available. As a result of U.S. EPA's observation,the Company audited its manifests and <br /> organization system, and its current manifest file contains all required copies. See 2013-2016 <br /> manifests which EPA believed to be missing during the inspection, attached as Exhibit K. <br /> The Inspection Findings state that U.S. EPA is deferring review of training records until the <br /> generator status of Sierra is confirmed, however the Company notes that it has provided updated <br /> RCRA training to employees in accordance with LQG status. Attached as Exhibit E are the <br /> training records for the PureSafety training of all employees. In addition to this training, certain <br /> members of management received additional RCRA training, including DOT hazardous waste <br /> training covering proper use and completion of manifests (Exhibit L) and basic hazardous waste <br /> management training through San Joaquin County(Exhibit M). <br /> CONCLUSION <br /> Sierra Chemical is committed to environmental and safety compliance, and is most interested in <br /> continuing to work with U.S. EPA regarding the matters contained in Inspection Findings. Siena <br /> looks forward to the opportunity to speak with you and your staff about the Inspection Findings <br /> and to clarify any remaining questions or issues that U.S. EPA should this response not be <br /> adequate. <br /> Sincerely, <br /> t <br /> Director, EHSS <br /> cc: Stacy Rivera <br /> Greg Thiess <br /> Andrew Perellis <br /> liana Morady <br /> 27057357v.1 <br />