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SUMIDEN WIRE HAZARDOUS WASTE HANDLER TRAINING <br />An Overview of Reportable Quantity (RQ) means "the quantity of a hazardous substance that triggers <br />reporting under CERCLA (Comprehensive Environmental Response, Compensation and Liability Act)." <br />If the substance is released in amounts exceeding its RQ, the release must be reported to the National <br />Response Center, California State Warning Center (CSWC)/ CAL OES, Poison Control Center, Local <br />Unified Program Agency, the USEPA and State EPA, and possibly the Coast Guard or Army Corp of <br />Engineers. In general, the State EPA or USEPA should be contacted if the incident involves a release to <br />inland areas or inland waters, and the Coast Guard should be contacted if the incident involves a release to <br />inland areas or inland waters, and the Coast Guard should be contacted for releases to the coastal waters, <br />the Great Lakes, ports and harbors. The RQ for a hazardous substance can vary from one pound to 5000 <br />pound of a pure component released in a 24-hour period depending on the hazardous substance. In the case <br />of oil reaching navigable waters or an adjoining shoreline, a RQ is exceeded if a sheen is produced on the <br />navigable water. <br />Contingency Plan: <br />The Contingency Plan is a written document that spells out the actions that the Company must take in the <br />event of an emergency or accident involving Hazardous Waste Spills, Fires, Explosions, Bomb Threats, <br />Civil Disorders etc. It contains the name of the designated Emergency Coordinator, it lists the available <br />Emergency Equipment and its location, the phone numbers to use in case of an emergency, including the <br />Fire Dept., Police Dept., Office of Emergency Services, National Response Center (for spills exceeding the <br />RQ), Chemical Waste Mgt. Etc. <br />RCRA = Resource Conservation and Recovery Act. This is a Federal Act and covers Characteristic <br />wastes such as the following: Hazardous Waste Number D001, exhibits the characteristic of Ignitability (it <br />will burn), D002 exhibits the characteristic of Corrosivity. A substance is a Corrosive if a representative <br />sample has the following properties: It is aqueous and has a pH less than or equal to 2 or greater than or <br />equal to 12.5, (RCRA & Non-RCRA). D003 exhibits the characteristic of Reactivity. A substance is <br />Reactive if it reacts violently with water, readily undergoes violent change without detonating, generates <br />toxic gases, vapors or fumes etc. (RCRA & Non-RCRA) <br />Listed Wastes: <br />In addition to the "D" Codes, RCRA also covers "F" Codes, "K" Codes, "P" Codes and "U" Codes. In <br />general, employees of Sumiden Wire do not come in contact with these codes except for the following "K" <br />Code: Sumiden Wire produces a Hazardous Waste with the code of "K062." K062 is specifically assigned <br />to the Iron and Steel Industries with a SIC Code of 331 and 332. Sumiden Wire Products Corp. has a SIC <br />(Standard Industrial Code) of 3315. "K062" is defined as "Spent Pickle Liquor generated by Steel <br />Finishing Operations of facilities within the Iron and Steel Industry. <br />Non-RCRA = In many cases, the state of California lists a substance as Hazardous Waste, even though it is <br />not listed on the Federal Level as a Hazardous Waste. As an example, the Gear Oil that is removed from <br />gear boxes at Sumiden in California, must be shipped to the recycler on a Hazardous Waste Manifest, with <br />the designation of Non-RCRA Hazardous Waste Liquid, while on a Federal Level, it could be shipped to <br />the recycler on a "straight bill of lading". Gear Oils at Sumiden Wire in Dickson Tennessee is handled <br />according to Fed. Regulations and not as Non-RCRA. <br />Universal Waste = Usually, a Universal Waste is a Hazardous Waste that is more common and pose a <br />lower risk to people and the environment than other hazardous wastes. Universal Waste includes, but is not <br />limited to, Mercury Thermostats and Switches, Aerosol Cans, Electronic Devices, CRT (TV Tubes, <br />Computer Monitors), Batteries, fluorescent light bulbs etc. <br />The Generator always has the responsibility of determining if a waste is a Hazardous Waste or not. <br />5 <br />