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i • Sierra Chemical Co. Hazardous Waste Management Plan 10. Excludable, Recyclable Materials (ERMs) Sierra Chemical Co. offers for delivery many finished products to customers. Finished chlorinated and other hazardous products delivered may occasionally be rejected by customers due to minor defects, incorrect quantities,customer order error,or other minor defects. When this occurs,the customer typically requests to return the product that was originally provided to them.Since these chlorinated and other hazardous products may only be transported by a transporter with appropriate licensing, Sierra Chemical Co.will retrieve the product using a third party carrier licensed to transport such products such as Sierra Chemical's sister company, Circle Transport, located at the Stockton CA Facility. The approved carrier will transport product back to the Sierra Chemical Co.facility after obtaining a Return Material Authorization (RMA)from Sierra Chemical's customer service group.When a rejected product is retrieved from a client,Sierra Chemical Co. recycles the product as an ingredient into one of its manufacturing processes or as an effective substitute for a commercial product,without treatment or reclamation.These materials that are returned from vendors and reused in the chemical manufacturing process to create raw products are considered an "Excludable, Recyclable Materials' (ERMs) and are excluded from the definition as a hazardous waste as specified in Health and Safety Code (HSC)sections 25143.2(b) and 25143.9.All hazardous materials are handled by Sierra Chemical Co. in accordance with all applicable laws and regulations.Sierra Chemical Co. is currently authorized and licensed to offer for transport specific hazardous materials including sodium hypochlorite, in accordance with 49 CFR sections 100-199.Therefore,when Sierra Chemical Co. retrieves a damaged or unused product(s)from a customer,the material is considered a hazardous material,as opposed to a hazardous waste,according to the U.S. EPA, Cal/EPA and U.S. DOT definitions of a waste.The regulations regarding ERMs are outlined in the next paragraph. Per Health and Safety Code(HSC)Sections 25143.2(b)and 25143.9, recyclable materials recycled in the following methods shall be excluded from the classification as a waste if the material is: 1) Used or reused as an ingredient in an industrial process to make a product if the material is not being reclaimed. 2) Used or reused as an effective substitute for commercial products if the material is not being reclaimed. 3) Returned to the original process from which the material was generated,without first being reclaimed, if the material is returned as a substitute for a raw material for raw material feedstock, and the process uses raw materials as principal feedstocks. These materials must be managed in accordance with HSC 25149.9: a) The material is held within a container or tank and the container or tank is appropriately labeled, marked, and placarded in accordance with the department's hazardous waste labeling, marking and placarding requirements which are applicable to generators,except that the container or tank shall be labeled or marked clearly with the words"Excludable Recyclable Material" instead of the words "Hazardous Waste," and manifest document numbers are not applicable. b) The owner or operator of the business location where the material is located has a business plan that meets the requirements of HSC 25504, including but not limited to, emergency response plans,and procedures, as described in subdivision (b)of Section 25504,which specifically Prepared By: Issue date: Replaces: Page: ACT Environmental Services, Inc. May 12,2016 March 4,2016 19 of 27