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Sierra Chemical Co. RCRA Contingency Plan Bulk chemical and fuel storage tanks are all located within secondary containments that are sized to contain 115 percent of the largest tank. The walls of the containments are higher than the projected flood waters based on the floodplain boundary. This will eliminate contact and any potential contamination. Acid and Caustic Repack Containments The only area not located within a structure, where full containers are routinely stored, would be the acid and caustic repack containments. Sodium hydroxide, sulfuric acid, and hydrochloric acid are repacked nto containers varying from 5 to 500 gallons. The product is repacked into containers and normally loaded onto trucks for delivery the same day. However, there are occasions where full containers are left overnight in the containment area. There is very low probability that full containers would be transported by floodwaters from this area due to the following reasons: The specific gravity of the product is heavier than water and probably would not float. The repack containments are on the very edge of the floodplain boundary with the projected depth of floodwater being less than one foot. Sierra Chemical will however take steps to eliminate any potential of full containers moving downstream by relocating any filled containers into the secured warehouse upon threat of flooding. Empty Containers Containers are returned for refill and are stored at the facility. The U.S. DOT requires that all containers returned for deposit and refill are empty and that all caps or bungs in place. They also require that the exterior be free from residue. This eliminates the potential for contamination of floodwater coming in contact with the containers. The containers will float in the event of a flood and will be contained by the six-foot chain link fence that surrounds the facility. e For the transition from the emergency phase to the cleanup phase, the following items will be completed: NA 25 of 44 • Emergency scene will be stabilized • Release of hazardous substances will be stopped • Reaction of hazardous substances will be controlled • The released hazardous substance will be contained within a localized manageable area • The area of contamination will be adequately secure from unauthorized entry At every incident involving hazardous materials, there is a possibility that response personnel and their equipment will become contaminated. Emergency response personnel have procedures to minimize contamination or contact, and to properly dispose of contaminated materials. For non -emergencies and level I incidents, the following methods of decontamination are available for personnel, environment, and/or equipment according to emergency response procedures: • Absorption • Adsorption • Chemical degradation Prepared By: Issue date: Replaces: Page: ACT Environmental Services, Inc. February 25, 2016 NA 25 of 44