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t CONTAINER MANAGEMENT POLICY INTRODUCTION B&B Excavating, Inc. operates a gravel operation under Mined Land Reclamation Board Permits. B&B is permitted to mine gravel, stockpile materials, crush aggregate, and process concrete and asphalt. The facilities include a concrete batch plants, asphalt batch plants, truck scales, offices, vehicles and truck parking, diesel and gasoline fuel storage, rock crushers and screens. Fuel is located on site to serve a fleet of trucks, construction and mining equipment, generators and miscellaneous eyuipmen[. All fuel storage is in aboveground storage tanks. A spill prevention control and countermeasure plan is in place to provide for fuel containment. B&B purchases and uses a limited number of products in 55-gallon containers. They consist of drums of oil, anti-freeze, grease, Stodazd solvent and various biodegradable concrete cleaners and additives. Although this Company Policy primarily addresses the management and use of chemicals purchased in 55-gallon containers it also covers any chemical purchase, use or storage of a chemical in a single container of 10 gallons or more and the disposal of any chemical in a container that is not defined as empty by this standard. The procurement, transfer, labeling, use, and storage of all chemicals aze subject to the requirements of the Hazazd Communication Policy (HCP) found in the Company Policy Manual. This policy is not intended to govern the transportation of materials in or on vehicles. GENERAL SPILL CLEAUP Due to the sensitivity of [he envirorunent to contaminated soils or groundwater, there is a strong incentive to quickly respond to even minor spills. Typical absorbent-type materials currently on the market that soak up products are available at the BBcB facility to be used for minor spill cleanup. Some of the more common adsorbents used are Lite-Dri Absorbent, Volclay, or kitty litter. For large spills or leaks, such as the complete failure of a drum, B&B will maintain portable pumps capable of pumping excess material into the tank storage to await proper disposal. B&B also maintains the capability (i.e., loaders, and backhoes) to excavate contaminated soils and build emergency berms to redirect/control arelease. For leaks where adsorbents aze used or when surface soils are impacted, the resulting waste material will be disposed of at approved landfills or, if oil or fuel aze the only contaminate, they may be recycled in asphalt mixes. The State of Colorado Department of Health, approved Visible Emission Control Plan for this site, defines the mix, feed rate, and total daily and aimual volume of soil contaminated with oil that may be processed in the asphalt mix. SECURITY The B&B Excavating facilities aze fenced and have lockable gates at its entrances. These gates remain locked when the facilities aze unattended. Unauthorized personnel are not allowed on B&B facilities. Precautions aze taken in the production and storage areas to locate drums where they should not be subject to damage by vehicle collision.