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<br />5.0 PREVENTION AND PLANNING <br />Prevention and planning are important parts of a Response Plan. Reducing or <br />eliminating the potential for emergencies is the ultimate goal of American Soda. <br />Prevention can include measures such as enclosing or containing process areas, training <br />employees, and performing preventative maintenance. Planning measures include <br />items such as developing personnel evacuation routes, installing and maintaining fire <br />extinguishers, training on use of spill containment materials, and reviewing Material <br />Safety Data Sheets (MSDSs). <br />Preliminary locations of material storage areas and evacuation meeting areas are shown <br />in Figure 1 for the Piceance Site and Figure 2 for the Parachute Site. Locations of <br />evacuation routes, fire extinguishers, spill carts, telephones, personal protective <br />equipment (PPE) storage areas, and MSDS stations will be provided as more <br />engineering design details are finalized. Final locations for the above items will be <br />obtained prior to the startup of the Yankee Gulch Project and will be included in the <br />final Response Plan. <br />5.1 Trainin¢ <br />All employees will receive training that will include (at a minimum) information <br />regarding evacuation routes, telephone locations, PPE usage, MSDS information, <br />material storage and handling requirements, hazardous waste handling procedures, <br />and best management practices (BMPs). The training will, at a minimum, follow <br />OSHA's HazCom (29CFR1910.1200) requirements. Frequency of training will be as <br />follows: <br />• prior to plant startup <br />• for all new employees within 30 days of hire <br />• when substantial changes have been made to equipment, materials, or <br />processes such that response procedures are affected <br />• at least annually <br />[n addition to the general employee training programs, members of the Response Team <br />as well as several representative employees from each shift will receive additional <br />training. The additional training will include (at a minimum) fire extinguisher, spill <br />cleanup, hazardous waste handling, first aid, and CPR training. Training programs will <br />follow applicable standards and will be directed by qualified individuals. The spill <br />response training will follow at least the requirements of OHSA First-Responder <br />Operations-Level training. Fire extinguisher and fire fighting training will follow <br />recommendations from the local fire departments. <br />14 <br />Preliminarv Response Plan <br />Yankee Gulch Sodium Minerals Protect <br />American Suda, L.L.P. <br />