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Sierra Chemical Co. RCRA Contingency Plan Spill or release involving materials excluded according to the SARA Title III, Statute 42 USC 11021(e) such as: • Any substance present in the same form and concentration as a product packaged for distribution and use by the general public. • Any substance to the extent it is used in the laboratory under the direct supervision of a technically qualified individual. • Petroleum, including crude oil or any fraction thereof, which is not otherwise specifically listed or designated as a hazardous substance by CERCLA. Incident Level I: According to the NFPA 471, Responding to Hazardous Materials Incidents (see figure 3.1), if the product(s) involved in the spill or leakage meet the following criteria, it will be classified as a Level I incident and does not implement the Contingency Plan. a. The product does not require a U.S. DOT placard, is an NFPA 0 or 1 for all categories, and it Other Regulated Materials A, B, C, or D. b. The spill or explosion is under control, and the reactivity rating of the material is less than a rating of 2, indicating a low potential for a subsequent explosion as the hazardous material can be considered generally stable. c. There was no release, or the release can be confined with readily available resources. d. There is no life-threatening situation. e. There is no potential for environmental impact. 4. Incident Level II: According to NFPA 471, Responding to Hazardous Materials Incidents (see figure 3.1), if the product(s) involved in the fire, explosion, spill or leakage meet the following criteria, it will be classified as a Level II incident and the Contingency Plan will be implemented by the Emergency Coordinator. a. The product(s) requires a DOT placard, is an NFPA 2 for any categories, or is an EPA regulated waste. b. The incident involved multiple packages. c. There is potential for the fire to spread from the hazardous material's flammability level (rating 2) is below 200 degrees Fahrenheit or the reactivity (rating 21 indicates that violent chemical changes are possible and thus may be explosive. d. The release may not be controllable without special resources. e. The incident requires evacuation of a limited area of life safety. f. The potential for environmental impact is limited to soil and air within incident boundaries. g. The container is damaged but able to contain the contents to allow handling or transfer of product. 5. Incident Level III: According to NFPA 471, Responding to Hazardous Materials Incidents (see figure 3.1), if the product(s) involved in the fire, explosion, spill or leakage meet the following criteria, it will be classified as a Level III incident and the Contingency Plan will be implemented by the Emergency Coordinator. a. The product is a poison A (gas), an explosive A/B, organic peroxide, flammable solid, material that is dangerous when wet, chlorine, fluorine, anhydrous ammonia, NFPA 3 and 4 for any categories including special hazards, EPA extremely hazardous substances (FHS), and cryogenics. b. The site-specific container size for this incident level will be a tank truck. c. There is potential for the fire to spread because the hazardous material's flammability level (rating 3 or 4) is below 100 degrees Fahrenheit, or the reactivity (rating 3 or 4) indicates that the material may explode. d. The release may not be controlled even with special resources. Prepared By: Issue date: Replaces: Page: ACT Environmental Services, Inc. February 25, 2016 NA 12 of 44