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Hazardous waste treatment, storage, and disposal facilities (TSDFs) have more requirements for preparedness, prevention, and contingency plans than do generators of hazardous waste. Generators are divided into three categories: conditionally exempt small quantity generators (CESQGs), small-quantity generators (SQGs), and large- quantity generators (LQGs) based on the amount of hazardous waste that is generated on site. LQGs have the most stringent requirements and CESQGs have the least stringent requirements related to preparedness, prevention, and contingency plans. At this time, a conservative assumption of hazardous waste generation quantity for the Yankee Gulch Project is about one-half of a 55-gallon drum per month (approximately 220 pounds or 100 kilograms, assuming a waste density of 8 pounds per gallon). This quantity would place American Soda just above the minimum requirements for the SQG category. The mass requirement for a SQG is 100 to 1,000 kilograms (approximately 220 to 2,200 pounds) of hazardous waste generation per month. Once American Soda has determined that hazardous waste will be generated, they will complete the Notification of Regulated Waste Activity forms in order to obtain an EPA Generator Identification Number. The Parachute Site would use the Unocal Oil Shale Upgrade Facility EPA Generator Identification (ID) Number if it is deactivated by Unocal. The number is COD 980718902. Unocal is classified as a LQG and a TSDF. If the ID number is not deactivated, American Soda will apply for a new ID number. Since there has been no prior hazardous waste generation at the Piceance Site, American Soda would apply for a new number, if needed. Colorado hazardous waste regulations generally follow the federal regulations except Colorado requires that the contingency plan should include a groundwater protection component. The federal regulations include air, soil, and surface water components. A general outline of the RCRA Preparedness, Prevention, and Contingency Plan that will be developed if American Soda generates hazardous waste is provided in Appendix B. Many of the items in the outline are covered in this preliminary Response Plan. 3.3 Svill Prevention Control and Countermeasures (SPCC) Plans SPCC Plans are required for facilities that have the potential to discharge oil to navigable waters of the U.S. The main objective of the SPCC Plan is to prevent discharges rather than develop clean-up measures. The regulation applies to any facility engaging in drilling, producing, gathering, storing, processing, refining, transferring, or consuming oil and oil products, providing that all three of the following conditions are met: 6 Preliminary Response Plan Yankee Gulch Sodium Minerals Project American Soda, L.L.P.