NC Sturgeon Safety Management System

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Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 1 of 6 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 NC Sturgeon employees. When work is performed on a non-owned or operated site, the operator s program shall take precedence, however, this document covers NC Sturgeon 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 NC Sturgeon Safety Manager or other designated person in his or her absence is assigned the responsibility for proper waste or scrap materials. Estimation Each work site will estimate the waste that will be generated 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 NC Sturgeon must coordinate with the project site or owner to ensure proper of wastes or scrap materials. NC Sturgeon must ensure the owner client is aware of whether wastes and scrap materials will be taken off site by NC Sturgeon or will be disposed of on the owner client s site.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 2 of 6 Segregation Do not mix waste streams Only place waste in the designated container, satellite accumulation area (SAA), recyclable accumulation area (RSS), universal waste accumulation area (UWAA) or designated. Recycling 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 NC Sturgeon 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 b4e covered to prevent dispersion of waste materials and to control the potential for runoff. Stream Aerosol Can Contents Aerosol Can Puncturing Unit Filter Aerosol Cans Ash Smart Ash Unit Puncturing of aerosol cans Filter Changes Painting, lubricants, cleaning Incineration of acceptable waste /Non if aerosol can is punctured and drained Non SAA is selfcontained in the repair shop designated labeled container Place punctured aerosol can in RAA storage drum Dispose of Immediately Crush RAA storage drum and place in the scrap metal from client. the Read warnings before use of Aerosolv unit. Change filter every 3 months See "Scrap Metal" for waste stream management Gloves Goggles

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 3 of 6 Stream /Non Automotive and Heavy Parts-Used Replacement RAA's by repair shop Returned to vendors for recycling Starters, Alternators, Pumps, Transmissions Batteries (Alkaline) Batteries (Lead Acid) Battery Failures Battery Failures Universal Universal the UWAA in the repair shop No storage allowed. Containment boxes are labeled and available in the shops. "D" cell and below are acceptable in the Non- Lead acid batteries are returned to the Vendor upon removal designated site designated site Batteries (Nicad) Battery Failures Universal UWAA in the 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 in the Hog Barn Place on pallet in RAA and band for shipment to. Computers Discarded Parts Department & Offices Replacement RAA @ EMS Conex 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 Mechanic in clear bags

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 4 of 6 Stream Drained Diesel Repair and Fab Shop Draining diesel fuel and filters /Non when burned as off-spec fuel "used oil" tank in the repair shop and fab shop. Burned for energy recovery in our 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 EMS Conex Label bulbs "Used Bulb" when put into RAA. Glass Replacement None Ensure glass containers are empty. Glycol Rags Glycol-Used Fluid Changes Fluid Changes WAA's lined w/clear bags RAA - self contained tank on recycling unit Recycled in glycol recycling unit Minimize use of absorbent rags Recycling unit stored in Repair Shop Grinding Wheels Grinding None Hoses & Belts Replacement of NSB or into the Oily WAA's 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.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 5 of 6 Stream /Non 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.) Parts Cleaner Rags Scrap Metal, Fab Shop, Service Trucks Draining oil and filters Mechanic, drips and leaks Painting Cleaning parts Fabrication & house cleaning if burned for energy recovery Determine on per occurrence basis. Use MSDS or testing if recycled 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. WAA's lined w/clear bags or metal only RAA's 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. 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.

Preparation: Safety Mgr Authority: President Issuing Dept: Safety Page: Page 6 of 6 Stream Toner Cartridges Offices Copiers, printers, fax machines /Non 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 NC Sturgeon 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. Education and Training Employees shall be instructed on the proper method of wastes. Examples include: General instruction on of non-hazardous wastes, trash or scrap materials Minimization methods to reduce waste Recycling methods If wastes generated are hazardous then employees shall be trained to ensure proper and compliance with regulations.