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Sierra Chemical Co. . • SOP 917 RO Waste Management Program Section 3: Spill/Release Mitigation Chemical Receiving/Loading Pad The area is designed to contain spillage and direct it to a recovery sump where the product can be recovered and pumped to product storage or effluent storage for recycling. In the event the spill resulted in a spray that would not remain in the containment, soils could become contaminated. Spilled product on soils will require an analysis to determine the extent of contamination. The contaminated soil will be neutralized if appropriate, excavated and placed in appropriately labeled containers. The containers will be stored in the designated Hazardous Waste Accumulation Area pending waste determination. All spills will be handled according to SOP 110 "Spill Response Plan". Railcar Spur Chlorine or Sodium Hydroxide could be released or spilled at the railcar spur area. In the event of a release of chlorine the Emergency Response Plan would be immediately activated. Spilled sodium hydroxide would be contained and cleaned up utilizing the methods discussed for spilled product on soils under the Chemical Receiving/Loading Pad. Storage Tank Containment Areas Any storm water or spilled product, although captured, until repairs are made, by virtue of the secondary containment, shall be pumped out and cleaned up daily. In the event of spilled product the material should be pumped to the proper storage tank. The cause of the spill should be determined, work orders prepared, and any required repairs completed, prior to the resumption of the production line. If the cause of the spill is operator inattention, the operator should be counseled and retrained to prevent a reoccurrence. Overhead Piping Depending on the severity of the leak, the product could be captured by placing a container under the leak until the process can be shut down and/or repairs can be made. Work orders will be prepared and the required repairs will be completed no later than the start of the next production shift. The recovered product will be transferred to the appropriate product or effluent storage tank and re-introduced into the manufacturing process. All of the overhead piping is located over secondary containment or concrete floors. All spilled product would be cleaned up using approved methods in accordance with SOP 110"Spill Response Plan". Rotary Bottling Lines Each bottling line has secondary containment under the filling, capping, and rinsing portion of the system. It is designed to capture any rinse water or product resulting from overfilling, broken or defective filling hoses, or product released due to defective bottles. The liquid within this containment area is pumped to the appropriate effluent tank. 14