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0 0 <br /> improve aesthetics, provide for easier housekeeping, and allow flexibility to use the containment <br /> for multiple purposes. While the appearance of the FRP was less than ideal,this was merely an <br /> aesthetic issue. Furthermore, the facility performs daily,weekly, and monthly audits that address <br /> the integrity of containment systems, and periodically commissions third-party audits to address <br /> containment and other environmental and safety issues throughout the facility.Notwithstanding <br /> the foregoing, given the concerns expressed by U.S. EPA the Company will remove the existing <br /> coating and further inspect the concrete. Any superficial cracks will be filled. If U.S. EPA would <br /> like updated photographs of the containment following filling of superficial cracks,please let us <br /> know and they will be provided. <br /> OBSERVATION NO. 3: Used/discarded aerosol containers observed on a shelf. The shelf is <br /> not designed for storing or accumulating flammable product or waste. Re u�ry Area of <br /> Concern:A waste generator must determine if the waste generated is hazardous waste. 22 CCR <br /> §66262.11 [40 CFR§262.11]. An aerosol can becomes a waste on the date the aerosol can is <br /> discarded or is no longer useable. An aerosol can is deemed to be no longer useable then any of <br /> the following occurs: (i) The can is as empty as possible, using standardpractices; (ii) The spray <br /> mechanism no longer operates as designed; (iii) The propellant is spent; (iv) The product is no <br /> longer used. HSC 25201.16(b)(2)(A). <br /> RESPONSE: The Company disputes that the observed aerosol cans were used or discarded, <br /> because they were useable and in use. They had not been discarded and were not a waste and as <br /> such there was no need to make a hazardous waste determination. Since the inspection by U.S. <br /> EPA Sierra has removed the cans from the shelf(see Photograph 2, below) and installed <br /> flammable cabinets for storage of the cans.See Photographs 3, 4, and 5, below. <br /> Photograph 2: <br /> L <br /> ,ta <br /> 3 <br /> 26731756v.9 <br />