TWMC Environmental Briefing and Contractor Method Statement Section 1: Environmental Management System (EMS) Overview The TECO-Westinghouse Motor Company (TWMC) EMS is designed to meet the requirements of ISO 14001 standard. The following is a description of the TWMC EMS. o TWMC will provide the necessary resources to establish, implement, maintain and continually improve an environmental management system committed to compliance with applicable environmental laws, regulations, policies, procedures and other adopted requirements. o All TWMC executives, directors, managers, supervisors and employees are accountable and have a personal and corporate responsibility to ensure that this commitment is incorporated into daily activities and functions. o TWMC employees will work to improve our environmental performance by: - Communicating our commitment to everyone working for or on behalf of TWMC. - Developing and periodically evaluating environmental objectives and targets that prevent pollution, minimize waste, improve service reliability, and promote energy efficiency and cost savings. Contractors and their sub-contractors are required to comply with TWMC environmental policies and procedures, as well as applicable local, state and federal environmental regulations. Contractor personnel have significant potential to affect the environmental performance and regulatory compliance of the facility. As a result, contractors must be aware of relevant environmental legislation, regulations, and possible non-compliances. Therefore, contractor personnel and the facility must work together to meet the goals of the EMS. Subcontractors and suppliers involved in work at the TWMC facility must complete a separate Contractor Method Statement for the facility's review before beginning work. In addition, the Contractor Method Statement must be completed, signed, and returned to HSE before contracted work commences. Section 2: Contactor Requirements The contractor is responsible for the following: o Developing a Contractor Method Statement o Returning the completed Contractor Method Statement to the Health, Safety, and Environmental Department (HSE) o Communicating the information in this document to relevant personnel o Complying with requirements of the TWMC EMS o Not discharging liquids, materials, and/wastes to drains and/or sewers without prior approval from HSE o Providing adequate spill or release prevention for all bulk materials o Notifying HSE and the associated TWMC project managers of any environmental incidents including, but not limited to, spills and releases o Immediately notifying HSE and the associated TWMC project manager of any abnormal conditions found during excavation activities. Abnormal conditions include, but are not limited to: visibly discolored soils, soils with a discernible odor, and/or heavily stained concrete. Issue Date: 02/15/2016 Page 1 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement o Communicating with the TWMC project manager and HSE regarding the management of potentially contaminated materials. These materials may not be removed from the site without prior approval of HSE. o Properly labeling, storing, and disposing of all waste materials generated from their activities at the TWMC facility o Seeking prior approval from HSE for potentially hazardous materials that are brought on-site o Providing manufacture’s safety data sheets as well as other relevant information (environmental or technical data sheets for example) for any chemicals or potentially hazardous materials prior to them being brought onto the property o Being aware of and sensitive to the effects of noise, odor, light, fugitive dust emissions, and vehicle movement while traveling around or to or from the facility o Preparing and maintaining records pertaining to the work performed in accordance with environmental regulatory requirements o Retaining the required records and providing these records to HSE in a timely manner o Ensuring the protection of the natural environment around the work area o Ensuring that all employees are properly trained on the following: proper handling of materials and equipment, proper response to incidents involving their materials, and general information related to the TWMC EMS Issue Date: 02/15/2016 Page 2 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement A. TWMC EMS Documents HSE or TWMC project managers provide the following information to contractors or subcontractors prior to beginning work. Applicable TWMC EMS Procedures, Work Practices, and Forms Document Number Title EP-002 Environmental Aspect, Objectives, Targets, and Management Programs EP-004 Non-Conformance, Corrective, and Preventative Actions EP-006 Emergency Preparedness and Response EP-009 Environmental Communications EP-010 Contractor Control EP-013 Competence, Training, and Awareness EWP-001 Hazardous and Universal Waste Management EWP-003 Spill Response EWP-004 Tracking of Surface Coatings EWP-005 Dry Abrasive Blasting EF-008 TWMC Environmental Briefing and Contractor Method Statement EF-009 Spill Reporting Form EF-010 Surface Coating Usage Log B. Contractor Method Statement The Contractor shall prepare and maintain information including a clear method statement regarding contractor/sub-contractor activities, which outline the work to be undertaken and the method(s) for minimizing environmental impacts and maintaining compliance with environmental regulations. 1. Initiating Activity or Project Manager (To be completed by TWMC personnel) Name Department Phone Number 2. Requisition Information (To be completed by TWMC personnel) Activity or Project Name Activity Reference Number Examples: PO, contract, or job number Issue Date: 02/15/2016 Page 3 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement 3. Service or Activity to be Performed (To be completed by Contractor) Material and Chemical Information Paint Solvent Sealer Treatment chemicals Lubricants, oils, and greases Gasoline (Production and non-production) Other (specify) Facility Maintenance and Construction Activities Industrial Services Provided (Includes Environmental Services) Electrical Paint Structural Roofing Mechanical HVAC General contractor Archeological, engineering, consulting General contractor Digging and excavation Other (specify) Asbestos Lead Maintenance Janitorial Emergency response Environmental consulting Paint booth cleaning Waste management Other (specify) 5 gal or less e) Drums Totes Bulk tanks Shipping containers Material and Waste Containerization Information Contract Information Janitorial and maintenance Other (specify) Type of contract: Issue Date: 02/15/2016 Commodity management On-site manager provided Total cost contract Page 4 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement 4. Contractor Information (To be completed by Contractor) Contractor Status (choose one): Current contractor to this facility On-Site Frequency: 75-100% 50-74% 25-49% New contractor to this facility 11-24% 1-10% Company Name Address City State and ZIP Code Phone Number Fax Number President or General Manager Account Representative or Site Coordinator Email Address Phone Number Mobile Number Fax Number 24-Hour Emergency Number Issue Date: 02/15/2016 Page 5 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement 5. Subcontractor and Supplier Information (To be completed by Contractor) Describe all suppliers or subcontractors that will be used. Type Firm Name Architectural Asbestos remediation Chemical supplier Consulting Demolition disposal Electrical Engineering Industrial services Mechanical HVAC Painting Roofing Sampling or testing Scrap or salvage dealer Waste disposal Other (specify) Issue Date: 02/15/2016 Page 6 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement 6. Contractor, Subcontractor, and Supplier Responsibilities (To be completed by Contractor) The Contractor is financially responsible for on-site environmental remediation actions resulting from incidents involving their employees and subcontractors. To minimize the risk of environmental incidents please review and initial the items in the table below. Environmental Management Basics Supplier/Contractor Initials The Contractor understands the importance of compliance with relevant environmental legislation and regulations and the consequences of non-compliance. All Contractors working at the facility are required to comply with and ensure their employees and any Suppliers/Sub-Contractors or agents comply with the TWMC EMS and environmental policy. All Contractors acknowledge receiving or were made aware of the TWMC facility's environmental policy, as well as applicable system procedures and work practices. Contractors shall not discharge anything to drains and/or sewers without prior approval from HSE. Spills and other releases to the environment must be immediately reported to the HSE. Contractors shall provide adequate spill release prevention as approved by HSE. Contractors shall immediately notify HSE and the Project Manager of any abnormal conditions found during excavation activities at the facility. Contractors shall properly label, store, and dispose of all their waste materials used on-site in accordance with facility procedures and all legal requirements. If facility personnel are required to work with potentially hazardous materials brought on-site by a contractor, prior approval of the material is required by HSE. Issue Date: 02/15/2016 Page 7 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement Environmental Management Basics Supplier/Contractor Initials Contractors must provide manufacture’s safety and environmental data for any chemicals or potentially hazardous materials brought onto company property. Contractors shall minimize the effects of noise, odor, light, fugitive dust emissions, and traffic movement on both TWMC property and adjacent property. Prior to commencing work Contractors shall obtain all necessary environmental approvals or permits and present copies of such permits to HSE and the TWMC Project Manager. Contractors were informed of actions to be taken during an actual environmental emergency situation. The Contractor understands that the facility may interrupt Supplier/Contractor activities that violate facility policies and/or other legal requirements. Issue Date: 02/15/2016 Page 8 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement 7. Contractor Method Statement (To be completed by Contractor) Please tell TWMC about the work you will be doing for us. Work Description Briefly describe the work to be performed while on-site, including the activities of each of the suppliers/contractors. Air Emissions Will the work you perform produce or cause the release of any air emissions? Yes No Yes No If Yes, list air emissions and method for preventing impact to the environment. Water Discharges Will the work you perform produce or cause the release of any wastewater? If Yes, how will the wastewater be handled? Materials and Equipment What materials (chemicals, oils, etc.) and/or equipment will you be handling or bringing on-site to perform the contracted work? Training Your employees should be trained on the proper handling of materials and equipment and the proper response to incidents involving these materials. Describe the environmental training your employees receive regarding the materials and equipment associated with the contracted work. Issue Date: 02/15/2016 Page 9 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement Waste Generation Will the work you perform result in any wastes? Yes No If Yes, list the waste disposal location, the amounts and types of wastes expected to be produced, and the proposed disposal method. Recycling Yes No Yes No Will any of the waste generated by this work be recyclable? If Yes, describe the recyclable material and where and how it will be recycled. Energy Consumption Will the work you perform consume energy? Examples of energy that may be used include electricity, compressed air, natural gas, steam, etc. If Yes, explain what type of energy will be consumed and how you will minimize consumption. Environmental Affects Will your work affect the local environment? Yes No Please include actions with both positive (soil stabilization, erosion control measures, etc.) and adverse effects (erosion from construction activities, etc.). If Yes, please describe below. Issue Date: 02/15/2016 Page 10 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement Waste Minimization Describe how you will minimize waste, emissions, and energy usage while onsite. Environmental Monitoring Describe any environmental monitoring that will be performed including sampling methods, frequency, analytical requirements, and laboratories. Other Legal Requirements Identify environmental legal requirements applicable to the contracted work that have not already addressed in this document. 8. Contractor Certification (To be completed by Contractor) I have reviewed and understand the information contained in this document. I also understand that TWMC has the right to inspect our activities and those of our Suppliers/Contractors with regards to our on-site activities. I further understand that activities pertaining to service and/or maintenance contracts may only require submission of this form on an annual basis. TWMC HSE should be contacted to make this determination. Name Title Signature Date Issue Date: 02/15/2016 Page 11 of 12 EF-008.04 TWMC Environmental Briefing and Contractor Method Statement Section 3: TWMC Review and Approval Name and Title of TWMC Reviewer Approval Date Signature Issue Date: 02/15/2016 Page 12 of 12 EF-008.04