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UNIVAR USA INC. v univAR CONTINGENCY PLAN )6/14/11 Replaces 03/10/10 SECTION SUBJECT PAGE 13 FIVE PRE-EMERGENCY PLANNING OF 15 HAZARDOUS WASTES Although it is recognized that the threat posed by an emergency involving hazardous waste on the branch premises is chemically equivalent to that involving virgin materials of the same chemical or mixture of chemicals, some different emergency procedures do apply. The most likely emergencies involving hazardous waste will be those of a release or fire. The Emergency Coordinator must try to determine by observation, branch records, or analysis (time permitting), the identity of the material involved, the amount, and the potential impact of the release or fire on human health and the environment. The Emergency Coordinator must also determine whether facility personnel are properly equipped and trained to handle the situation or if it is necessary to call in outside contractors or emergency assistance agencies. If this is a Branch permitted to store hazardous wastes, the secondary containment area will hold materials released from drums, IBCs and portable tanks during storage. Leaks into the containment dike must be reported to the Emergency Coordinator immediately so that clean-up activities can begin. Liquid materials can be removed and contained in a DOT UN specification container suitable for the lading by use of a portable pump. Absorbent material used to collect the spill may be shoveled into the DOT UN specification container suitable for the lading. Spills confined to the secondary containment area are a minor problem. Spills or leaks that occur in satellite accumulation areas, transportation vehicles, or spills that escape from the secondary containment area are potentially very serious emergency situations. Because the facility normally deals only with containerized wastes, the amount of waste which has potential to be released is relatively small. In the event the Contingency Plan is implemented, a written report must be filed with authorities in accordance with 40 CFR Part 264.56(J) as detailed at the end of Section XII (Reporting) of this Plan. Hazardous wastes are similar to the hazardous material handled at the branch. The hazardous characteristics of the wastes are those of ignitability, reactivity, corrosivity and/or toxicity. Hazardous wastes will usually be in containers (55 gallon drums, IBC's), or occasionally in bulk. They will be in transit through the facility (on-site for only several days) or in storage in a specially designed storage facility with a secondary containment system. The types of hazardous wastes that may be present at the branch are: