Policy on RCRA, Hazardous Waste Management

The policy within the Company is to minimize the generation of waste materials resulting from all operations. In order of preference, waste elimination or reduction is sought through process change, materials substitution, reuse, recovery, sale, or energy recovery. For residual wastes that are not amenable to this hierarchy, the goal in disposal is use of the most cost-effective method that is consistent with State and Federal regulations and is adequately protective of human health and the environment. Both long term effects and current requirements must be considered when making selections among applicable disposal methods, and evaluations of cost, effectiveness and protection.

The Company accepts the waste management hierarchy adopted by regulatory agencies at the federal and state level:

For some waste, the use of land disposal is the only practicable alternative, and for many others, it is the most cost-effective choice that is also adequately protective of the environment. For these reasons, land disposal shall continue to be an available option in the management of all non-hazardous wastes. Proper evaluation of this method prior to usage must indicate that the proposal is satisfactory in consideration of bio-accumulation, toxicity, compatibility and leachability characteristics of the waste; geological and hydrological qualities of the site and surrounds; the proximity of populations; and the beneficial uses of adjacent or potentially affected properties.

The preceding policy and practices within the Company provide an assurance to those employees who are required to sign hazardous waste manifests, that there is a policy and program in place that addresses the certification statements on the hazardous waste manifest.