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Sierra Chemical Co. <br />Hazardous Waste Management Plan <br />40 CFR 262.27 Waste Minimization Certification reads: <br />A <br />generator who <br />initiates <br />a shipment of hazardous waste <br />must certify to one <br />of the following statements <br />in <br />Item 15 of the <br />uniform <br />hazardous waste manifest: <br />(a) "I am a large quantity generator. 1 have a program in place to reduce the volume and toxicity <br />of waste generated to the degree I have determined to be economically practicable and I have <br />selected the practicable method of treatment, storage, or disposal currently available to me <br />which minimizes the present and future threat to human health and the environment;" or <br />(b) "1 am a small quantity generator. 1 have made a good faith effort to minimize my waste <br />generation and select the best waste management method that is available to me and that / can <br />afford." <br />Sierra Chemical Co will make every effort to reduce the amount of non -hazardous, universal, medical, <br />and/or hazardous waste onsite. This will include, but not be limited to, maintaining an inventory control <br />system to avoid unnecessary accumulation of chemicals. The EPA has established guidance <br />recommending six key elements that should be incorporated into a waste minimization program. These <br />I<ey elements are: <br />• Top management support; <br />• Characterization of waste generation and waste management costs; <br />• Periodic waste minimization assessments; <br />• Cost allocation system; <br />• Encourage Technology transfer; and <br />• Program implementation and evaluation. <br />Sierra Chemical Co. will periodically assess waste streams to determine where reduction measures can <br />be implemented, to the extent feasible. Sierra Chemical Co. trains appropriate employees on waste <br />handling procedures and hazardous waste awareness. Waste is appropriately characterized according to <br />Section 5 of this plan. All waste generation is accounted for by the EHSS Manager and documented. <br />Sierra Chemical Co. attempts to recycle waste, when possible, and in accordance with all laws and <br />regulations as described in the section below. Process improvements are continually evaluated to <br />determine source reduction measures and associated economic costs. <br />1®. Excludab9e, Re�y�lable foflia6s jERIN <br />11s) <br />Sierra Chemical Co. offers for delivery many finished products to customers. Finished chlorinated and <br />other hazardous products delivered may occasionally be rejected by customers due to minor defects, <br />incorrect quantities, customer order error, or other minor defects. When this occurs, the customer <br />typically requests to return the product that was originally provided to them. Since these chlorinated <br />and other hazardous products may only be transported by a transporter with appropriate licensing, <br />Sierra Chemical Co. will retrieve the product using a third party carrier licensed to transport such <br />products such as Sierra Chemical's sister company, Circle Transport, located at the Stockton CA Facility. <br />The approved carrier will transport product back to the Sierra Chemical Co. facility after obtaining a <br />Return Material Authorization (RMA) from Sierra Chemical's customer service group. When a rejected <br />Prepared By: <br />Issue date: <br />Replaces: <br />Page: <br />ACT Environmental Services, Inc. <br />March 4, 2016 <br />NA <br />17 of 23 <br />