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CHAPTERTWO Agency preferred Alternatlye <br />Resource Conservation and Recovery Act (RCRA) Prepa-edness, Prevention and <br />Contingency Plan (40 CFR Part 265) <br />RCRA plans are required for facilities that generate, treat, store, and/or dispose of hazardous <br />wastes as defined in 40 CFR Part 261. American Soda does not anticipate generating RCRA <br />hazardous wastes in the normal mining or processing operations of the Yankee Gulch Project. <br />However, American Soda would develop a RCRA plan should conditions warrant it. <br />Spill Prevention, Control and Countermeasures (SPCC) Plan (40 CFR Pan` 112) <br />SPCC Plans are required for facilities that have the potential to dischazge oil to navigable waters <br />of the U.S. As stated in the Draft EIS (page 2-23), the total amount of fuel that would be stored <br />on site would be less than the regulatory threshold limits for a SPCC Plan. P,merican Soda <br />personnel would conduct periodic reviews of oil product storage to determine; if the SPCC <br />requvements would apply at a later date. <br />Occupational Safety and Health Administration (OSHA) Emergency and fire Prevention Plan <br />(29 CFR Part 1910.38) <br />OSHA Site Emergency and Fire Prevention Plans are required for all U.S. employers to ensure <br />employee safety from fire and other emergencies. This plan would be completed by American <br />Soda prior to startup. <br />OSHA Hazard Communication Plan (HazCom) (20 CFR Part 1910.1200) <br />The purpose of the OSHA HazCom plan is to ensure that the hazards of all chemicals produced <br />or imported aze evaluated, and that information concerning their hazards is hansmitted to <br />employers and employees [29 CFR 1910.1200(x)1 ]. A HazCom Plan would be developed by <br />American Soda once the manufacturer/supplies of materials has been selected. The plan would <br />contain copies of all Material Safety Data Sheets (MSDS); procedures for proper labeling of <br />containers; handling and storage procedures; spill containment and cleanup, and employee <br />training. <br />Emergency Planning and Community Right-to-Know Act (EPCRA) repo-L~ng (40 CFR Parts <br />370, 372) <br />EPCRA, also known as Title III of the Superfund Amendments and Reauthorization Act <br />(SARA), requires owners and operators of facilities to report on the hazazdous chemical present <br />at their facilities and the releases of hazardous chemicals from their facilities to the environment. <br />For the Yankee Gulch Project, this EPCRA requvement would apply to sulfuric acid. American <br />Soda intends to store approximately two 55-gallon drums (110 gallons) of sidfuric acid at the <br />Parachute Site. American Soda would comply with the reporting requirements per EPCRA. <br />r~ <br />L <br />2-16 <br />