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OBSERVATION NO. 4: Discarded aerosol containers observed in an unlabeled plastic bag. <br /> Regulatory Area of Concern:A container used to hold universal waste aerosol cans shall be <br /> labeled or marked clearly with one of the following phrases.• "Universal Waste-Aerosol Cans <br /> "Waste Aerosol Cans", or "Used Aerosol Cans". HSC 25201.1669(6). Except when waste is <br /> added or removed or as provided in subparagraph (B), the container shall be closed, structurally <br /> sound, and compatible with the contents of the universal waste aerosol can, and shall show no <br /> evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable <br /> conditions. HSC 25201. 16(fl(1)(A). <br /> RESPONSE: As a result of U.S. EPA's observation, Sierra has implemented a policy as part of <br /> its Hazardous Waste Management Plan("HWMP") to address aerosol cans that are no longer in <br /> use. Per the policy, empty aerosol cans are managed as Universal Waste. See Photograph 6, <br /> below. See also HWMP at pp. 13-14, attached as Exhibit C. Partially full and full aerosol cans <br /> that are no longer in use are managed as Hazardous Waste and, as such, are stored in the <br /> Hazardous Waste area(see Photograph 7, below) and properly disposed of under U.S. EPA <br /> waste codes D001 and D035 and Cal-EPA waste code 343. See id. <br /> Photograph 6: <br /> HANDLE WITH CARE! <br /> �WIT ARE! Y.N <br /> UNI VERSA L <br /> Per 40 CFR273,14 and 27 TE <br /> ,b <br /> A"41%g <br /> ftU"a <br /> �.�„ HANDLE wIT <br /> 5 <br /> 26731756v.9 <br />