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5. LABELING Heritage Environmental Services, LLC, will supply assistance, including provision of required labels. The Heritage"Waste Handling Manual"has procedures that explain how labels must be completed and attached by individuals at the plant responsible for managing the waste stream. This is found on the Heritage Interctive website. 6. MAINTAINING GENERATOR STATUS You are classified as a: CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR (CESQG) As a CESQG,you cannot generate a total of 220 pounds (100 kilograms) or more hazardous waste in one month. If you do, you become a Small Quantity Generator(SQG) and have additional regulatory requirements to meet. • EXAMPLE 1 —If you had 26.5 gallons of spent parts washer fluid(at 8.3 lbs./gal. density), it would weigh approximately 220 lbs. and put you in danger of going over your limit and becoming a Small Quantity Generator. ACTION—Manage your spent parts washer such that you don't go over the CESQG limit of 220 pounds of hazardous waste generated in one month. Your Corrugated Packaging Corporate Environmental Engineer and the hazardous waste management contractor are available for help and assistance. • EXAMPLE 2 —If you 17.7 gallons of 50%liquid caustic waste (at 12.42 lbs./gal. density), it would weigh approximately 220 lbs. and put you in danger of becoming a SQG. ACTION— Minimize/manage any spills of 50%liquid caustic to 17 gallons or less per month(the goal is don't have any spills). Try and reuse/recycle any spilled caustic to keep the spill under 17 gallons or less per month. You must continue to meet the above definition(220 pounds total limit)to maintain this classification. If you see a situation where you may have a problem meeting the definition, contact the Corrugated Packaging Corporate Environmental Engineer assigned to your facility IMMEDIATELY! 7. WASTE MANAGEMENT OPTIONS Simply remember that the less hazardous waste you generate in any given month, the less hazardous waste rules, regulations and laws you have to contend with. Therefore your first option for managing a hazardous waste stream should be avoid generating it. If you generate no hazardous waste, make sure you review your waste streams at least annually to document that the waste streams do not exhibit any hazardous characteristics. If you cannot eliminate a hazardous waste stream, you should try to reuse it, provide it to another company as a raw material (accepted in all but a few states), or recycle it. If none of these options are possible, it will be necessary to have an approved hazardous waste management contractor dispose of the hazardous waste. Contact Heritage and/or your assigned Corporate Environmental Engineer for assistance. E10a - 2