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iii iuiiiiiuiiiiii • 999 • B & B EXCAVATING, INC. Drawer 249 Vail, Colorado 81658 (970) 926-3311 • Fax (970) 926-2344 Allen Sorenson State of Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, CO 80203 June 9, 1999 Dear Allen, RECEIVED JUN 11 1999 Division of Minerals & Geolo9Y Enclosed you will find our Company Container Management Policy along with our current Hazard Communication Program. The two programs are designed to dovetail together so that container management becomes an integral part of our everyday HazCom program. We have gone to a great deal of effort to curtail the use of and restrict the purchasing of bulk product in our day to day operations. We have established company policy that requires review of bulk purchases and continued monitoring along with controlled disposal procedures for any chemical. Responsibility for oversight has been placed in the safety department, which reports directly to upper management. In November 1998, to prevent the reoccurrence of a similar accident we began an immediate company wide survey to identify potential problems. The following actions were the result of our survey. All empty barrels with previously known contents (those properly labeled and marked) were crushed and disposed of in an approved landfill. All barrels who's contents could no[ be identified whether empty or partially full were disposed of by an approved licensed contractor. 3. Storage areas were consolidated for the remaining barrels in a properly bermed and lined area. 4. In November all employees who previously used or ordered bulk chemicals were verbally notified to cease ordering chemicals in bulk. 5. Also in November all employees who previously used or ordered bulk chemicals were verbally notified of the new company policy with regards to the requirement for Safety Department approval of such purchases. 6. On June 3, 1999 a draft policy was prepared and has been distributed to the company Safety Committee.