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TOP-WASTE Disposing of Hazardous and Non-Hazardous Waste

REV: 9/30/08

Scope:  This procedure covers the disposal of hazardous and non-hazardous waste created by Trinity Forge, Inc., as well as Trinity's reporting requirements as outlined by the Texas Natural Resource Conservation Commission (TNRCC).

NOTE: IN THE CASE OF A SPILL, SEE TOP-EMERP..

STEP WHO WHEN INFO TO USE WHAT TO DO RESULTS
1 Any employee Waste product to be disposed of Own observation Notify supervisor that waste product needs to be disposed of. Supervisor notified
2 Any supervisor Upon notification from employee waste product is to be disposed of Notification Verify that product does need disposal; notify Environmental Coordinator* that a waste needs to be disposed of, specifying its location and exact contents. Need for disposal verified; notified Environmental Coordinator
3 Environmental Coordinator Upon notification Material Safety Data Sheet (MSDS); test results, and any other info deemed necessary Determine how material needs to be removed considering test results (if any), reporting requirements, professional opinions, and best available waste hauling options; make sure waste has been identified according to Notice of Registration on file with Texas Natural Resource Conservation Commission (TNRCC) prior to shipment. Waste removal method and responsibilities determined

4

Any employee acceptable to Environmental Coordinator Upon instructions from Environmental Coordinator Laboratory results; MSDS; instructions from Environmental Coordinator; National Fire Prevention Association (NFPA) approved label Follow MSDS to bring hazard (if any) to 2000 gallons in storage; store in Department of Transportation approved and properly labeled container; notify Environmental Coordinator waste is ready for transporting from premises. Waste brought to lowest possible level of danger/exposure; now ready for transporting from premises
5 Environmental Coordinator Waste is ready for transporting to approved waste facility List of approved waste hauling facilities; list of approved licensed disposal sites; MSDS Determine which waste hauling facility and licensed disposal site to use; coordinate transportation of waste to disposal site. Waste removal coordinated
6 Waste hauling facility Upon arrival for pick up and removal of waste Waste manifest; laboratory results; hauling permit Waste hauling facility to provide Trinity Forge with:

- Waste manifest

- Hauling permit for classification of waste as determined by laboratory results.

Proper documentation obtained for removal of waste
7 Environmental Coordinator Receipt of proper documentation for removal of waste from waste hauling facility Waste manifest; laboratory results; hauling permit; any other notes pertaining to shipment File waste manifest and all supporting documentation -- must be kept on file for at least three years as required by law. Waste manifest and documentation filed
8 Waste hauling facility Within 35 days of shipment Waste manifest Provide Environmental Coordinator a signed, completed waste manifest as required by law. Signed completed waste manifest provided to Trinity Forge
9 Environmental Coordinator As signed completed waste manifest is received Waste manifest Attach to waste manifest information already on file. Waste manifest now considered complete and on file
10 Environmental Coordinator Monthly Unsigned waste manifests on file awaiting signature from waste hauling facility If after 35 days from shipment, signed waste manifest form is not received, notify waste hauling facility of delinquent manifest. Waste manifest not forgotten

 

11 Environmental Coordinator Ten days after notification to waste hauling facility Exception Report from TNRCC File Exception Report with TNRCC; maintain copy for five years. Documentation maintained to prove attempts to complete waste manifest
12 Environmental Coordinator Monthly, By 25th of each month

 

Monthly Waste Summary; all Class 1 Industrial Solid and/or Hazardous Waste Manifests Complete Monthly Waste Summary and submit to TNRCC on or before 25th of each month. Reporting requirements to State of Texas fulfilled
13 Environmental Coordinator Annually, by January 25 Annual Waste Summary Report; all Class 1 Industrial Solid Waste and/or Hazardous Waste Manifests Complete Annual Waste Summary and submit to TNRCC on or before January 25.

 

Reporting requirements to State of Texas fulfilled

 

*The Human Resources Manager performs the duties of the Environmental Coordinator.

 

 

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