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Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 1 of 7 Purpose The purpose of this waste management strategy was developed to provide guidance and requirements necessary for efficient, effective and compliant waste management during construction and operations. Scope This procedure applies to all COMPANY employees. When work is performed on a non-owned or operated site, the operator s program shall take precedence, however, this document covers COMPANY employees and contractors and shall be used on owned premises, or when an operator s program doesn t exist or is less stringent. Procedure The COMPANY Safety Manager or other designated person in his or her absence is accountable for managing waste and disposition of wastes generated at the work site. Estimation Each work site will estimate the waste, trash and/or scrap that will be generated and taken into consideration prior to work being performed so the need for containers and waste removal, if necessary, can be determined. Each site will utilize the following for planning of scheduling and total non-hazardous dry waste material. These figures do not include neither recycling nor waste minimization efforts and reflect no use of an incinerator. figures are based on a 40 yard container and can be modified if another size is used by changing the table below. SAMPLE ONLY - SOLID WASTE Number of Employees 10 25 35 50 100 Total Estimated Square Feet of (@ 0.675 cu ft per person daily) Daily 7 17 24 34 68 Weekly 47 118 165 236 473 Monthly (4.33 wks) 205 511 716 1,023 2,046 Annual 2,455 6,138 8,593 12,276 24,551 Total Estimated Weight of (@ 4lb per person daily) 40 100 140 200 400 Weekly 280 700 980 1,400 2,800 Monthly (4.33 wks) 1,212 3,031 4,243 6,062 12,124 Annual 14,549 36,372 50,921 72,744 145,488 Number of Total Fills 40 yard 7x8x22 = 1,232 square feet Daily 0.0 0.0 0.0 0.0 0.1 Weekly 0.0 0.1 0.1 0.2 0.4 Monthly (4.33 wks) 0.2 0.4 0.6 0.8 1.7 Annual 2.0 5.0 7.0 10.0 19.9 COMPANY must coordinate with the project site or owner to ensure proper of wastes or scrap materials.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 2 of 7 COMPANY must ensure the owner client is aware of whether wastes and scrap materials will be taken off site by COMPANY or will be disposed of on the owner client s site. Segregation Do not mix waste streams Only place waste in the designated container, satellite accumulation area (SAA), recyclable accumulation area (RAA), universal waste accumulation area (UWAA) or designated. Recycling s should be recycled whenever practicable. COMPANY will encourage proper segregation of waste materials to ensure opportunities for reuse or recycling occurs at each work site. The collection of recycled material will reduce the total load on the environment. Bins of sufficient size must be lined with a plastic bag and clearly labeled for use. Posters from COMPANY will be posted throughout the work site to encourage recycling. Collection bins will also be placed in administrative areas will follow the following color guiding: Blue - Paper Green - Aluminum cans Yellow - Plastic Cardboard will be flattened, staples and excess shipping tape removed. No cardboard shall be placed in the used for the landfill. Handling Matrix Each work site will develop a Handling Matrix (sample shown) that will: Address safe practices related to the immediate storage and handling of waste, scrap or leftover material. The handling, organization and storage of waste and scrap materials to minimize potential impact to the environment. materials shall be properly stored and handled to minimize the potential for a spill or impact to the environment. During outdoor receptacles must be covered to prevent dispersion of waste materials and to control the potential for runoff. Stream Aerosol Can Contents Aerosol Can Puncturing Unit Filter Puncturing of aerosol cans Filter Changes /Non SAA is selfcontained in the equipment repair shop designated labeled container Read warnings before use of unit. Change filter every 3 months

Doc No: GNWSTE COMPANY Revision Date: Initial Version Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 3 of 7 Stream /Non Aerosol Cans Painting, lubricants, cleaning if aerosol can is punctured and drained Place punctured aerosol can in RAA storage drum Crush RAA storage drum and place in the scrap metal from client. See "Scrap Metal" for waste stream management Ash Smart Ash Unit Incineration of acceptable waste Non Dispose of Immediately the Gloves Goggles Automotive and Heavy Parts-Used Replacement RAA Returned to vendors for recycling Starters, Alternators, Pumps, Transmissions Batteries (Alkaline) Battery Failures Universal the UWAA "D" cell and below are acceptable in the Non- designated site Batteries (Lead Acid) Battery Failures Universal No storage allowed. Containment boxes are labeled and available in the shops. Lead acid batteries are returned to the Vendor upon removal designated site Batteries (NiCad) Battery Failures Universal UWAA in the equipment repair shop. Cell phones, radios Butane Torch Bottle Mechanic if recycled Place drained Butane Torch Bottles in RAA storage drum Crush RAA storage drum and place in the scrap metal Prosolv Butane Bottle processor l Cardboard/Office Paper Parts Department & Offices Shipping Boxes & Office Activities RAA Place on pallet in RAA and band for shipment to.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 4 of 7 Stream Computers Discarded Parts Department & Offices /Non Replacement RAA Diesel Filters-Used Filter Changes RAA for drained and crushed used filters Drain for 12 hrs., crush and incinerate in Place metal in Diesel Rags Drained Diesel Repair and Fab Shop Mechanic Draining diesel fuel and filters when burned as off-spec fuel in clear bags "used oil" tank in the equipment repair shop and fab shop. Burned for energy recovery in clean burn multi-oil heating system. Empty Paint Cans Painting No storage allowed Paint cans must be RCRA empty. Fluorescent Light Ballast Failure unless they contain PCB's or DEHP None Ballast will say on the label if it contains PCB's Fluorescent Light Bulbs Shops, Office Areas Bulb replacement Universal Place bulbs in their original container in the RAA in the shop area Label bulbs "Used Bulb" when put into RAA. Glass Replacement None Ensure glass containers are empty. Glycol Rags Fluid Changes WAA's lined w/clear bags Minimize use of absorbent rags

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 5 of 7 Stream Glycol-Used Fluid Changes /Non RAA - selfcontained tank on recycling unit Recycled in glycol recycling unit Recycling unit stored in shop Grinding Wheels Grinding None Hoses & Belts Replacement Drain all fluids from hoses Metal Shavings/Cuttings Fabricating if recycled or metal only RAA's Ensure there are no free flowing cutting fluids present before. Oil Filters-Used Oil filter changes RAA for drained and crushed used filters Drain for 12 hrs., crush and incinerate in Place metal in Oil-Used Oily (rags, absorbents) Paint (rags, rollers, brushes, etc.), Fab Shop, Service Trucks Draining oil and filters Mechanic, equipment drips and leaks Painting if burned for energy recovery Determine on per occurrence basis. Use MSDS or testing Receiving sumps are located in the and Fab Shop WAA's lined w/clear bags If hazardous, store in the assigned area. If nonhazardous, no storage is required. Burned for energy recovery in clean burn multi-oil heating system. If hazardous, ship to f. If nonhazardous, place in burnable waste. Keep lids on receiving sumps at all times. DO NOT PUT SOLVENTS INTO USED OIL Collected daily. Need to review MSDS, do analytical test, or use generator knowledge to make waste determinations.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 6 of 7 Stream Parts Cleaner Rags Scrap Metal Cleaning parts Fabrication & house cleaning /Non if recycled WAA's lined w/clear bags or metal only RAA's Eye Protection Gloves Sodium Vapor/ Metal Halide Light Bulbs Bulb replacement Universal Place bulbs in their original container in the RAA. Label bulbs "Used Bulb" when put into RAA. Tires Replacement None Place tires up to 20" rim diameter into. Toner Cartridges Offices Copiers, printers, fax machines original container in RAA Verify toner is expended before. Water Scrubber Filter & Absorbents Filtering sump water in shops None Welding Rods Welding or metal only RAA's See "Scrap Metal" for waste stream management Wood and shipping pallets Store on the far back corner of the pad or in the dump truck box if available. recycle wood Pallets are refurbished and recycled when possible Storage Requirements COMPANY must ensure project related wastes are stored and maintained in an organized fashion to encourage proper and minimize risks to employees. Proper waste receptacles must be provided for trash and materials that may be reused or recycled during a project.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 7 of 7 PPE For each site waste management plan COMPANY shall determine a PPE matrix that includes gloves, hand protection, eye and face protection and/or other necessary PPE. Education and Training Employees shall be instructed on managing waste generated at the work site and on the proper method of wastes. Examples include: Instruction on the proper handling, storage and of wastes and depending on the waste generated at the site to also include general instruction on of non-hazardous wastes, trash or scrap materials. If wastes generated are classified as hazardous then employees shall be trained to ensure proper and compliance with regulations. Minimization methods to reduce waste. Recycling methods and proper PPE to be utilized.