Waste Management Procedures Paint and Related Materials Contents The section on Paint and Associated Materials contains the following: Topic Version 0, October 2013 See Page Before You Begin 2 Paint 4 Paint Thinner 10 Paint Brushes and Cans 15 Page 1 of 14 Waste Management Procedures Paint and Related Materials Before you begin Description Paints, paint thinner, paint brushes and cans Category Non-exempt May be hazardous or non-hazardous waste when discarded Analysis MSDS may be used to assist in hazard determination Unused products may be disposed based on the MSDS Only if necessary, for mixtures, check ignitability and the presents of TCLP metals Accumulation Store in closed drums or containers Separate paints and associated wastes from other waste streams Contact the EH&S Department to determine whether the waste will be a hazardous waste, and if sampling will be required. Waste Reduction Consume all of product. If this is done, no other requirements in this section are needed. Disposal Minimize wasteful practices (i.e., overuse or excessive usage, return excess purchases to vendor) Return unused, unopened product to the manufacturer, when possible If Hazardous Waste: Dispose of materials at state permitted hazardous waste disposal facility. Do not place in trash or allow to be placed in a landfill. If Non-Hazardous Waste: Dispose of materials at a state permitted industrial solid waste disposal facility. Must no longer be a liquid. Continued on next page Version 0, October 2013 Page 2 of 14 Waste Management Procedures Paint and Related Materials Before you begin, Recordkeeping (continued) If hazardous waste: List on the Hazardous Materials [Section I] of the Fieldwood Energy Shipping Manifest Complete all Uniform Hazardous Waste Manifest, EPA Form 8700-22b, for hazardous waste Maintain copy of records at offshore and shorebase facilities while active Send original manifest with shipment Retain records for three years If non-hazardous waste: List on General Cargo Manifest Maintain copy of records at offshore and shorebase facilities while active Send original manifest with shipment Retain records for one year Version 0, October 2013 Page 3 of 14 Waste Management Procedures Shipping Instructions: PAINT 1. Call or FAX Dock/Base to schedule shipment 2. Package Paint as follows: a. Non-Bulk Packaging: 1. Place in drum 1A1 or 1A2, b. Bulk Packaging: 1. DOT 51, 52, 53, 56, 57, or 60 Portable Tanks 2. Marine Portable Tanks 3. Mark Package: a. "Paint, 3, UN1263 PG II". b. Stencil Container-"Fieldwood Energy" and the generator's location (i.e. Eugene Island 158). Note: Paint [intended for use] has no reportable quantity [RQ] if spilled. Waste Paint [EPA waste number D001] has a reportable quantity [RQ] of 100 pounds. c. If declared a waste, add the word “Waste” before the name “Paint” and the letters “RQ” after the name “Paint”. If the container holds less than 100 pounds, the letters “RQ” are not added. (Not all paint weighs the same, however, 100 pounds of MEK paint thinner is approximately 15 gallons) 4. Label Package: a. DOT "Flammable Liquid" label b. For packages having a volume over 64 cubic feet (478 gallons) and for portable tanks of less than 1000 gallons: place DOT labels on at least two ends (other than the bottom) or two sides c. EPA “Hazardous Waste” label 5. Prepare shipping papers: a. Complete entry in Hazardous Materials Section [Section I] of the Fieldwood Energy Shipping Manifest (See example) b. Complete entry in Uniform Hazardous Waste Manifest, EPA Form 8700-22, (See example) Continued on next page Version 0, October 2013 Page 4 of 14 Waste Management Procedures Shipping Instructions: PAINT, (continued) 6. Placard Vehicle/Vessel a. For cargoes of more than 1000 pounds and any Bulk Packaging: "Flammable" Placard with 1263 in center and 3 in lower corner (1000 pounds of MEK is approximately 149 gallons). b. For cargoes less than 1000 pounds and any Non-Bulk Packaging: No Placard required on transport vehicle. c. Cargo or portable tanks shall be placarded as above on opposing sides if capacity is between 119 and 999 gallons and on all four sides if 1000 gallons or more. d. See attached placard 7. Load cargo in accordance with the following shipping limitations: AIR RESTRICTIONS (49 CFR 172.101) Passenger Aircraft 5 quarts (5 Liters) if in Packing Group II 15 gallons (60 Liters) if in Packing Group III. Cargo Aircraft 15 gallons (60 Liters) if in Packing Group II 220 gallons (220 Liters) if in Packing Group III WATER 8. RESTRICTIONS (49 CFR 172.101) Cargo and up to 25 passengers Must be stowed either on deck or under deck, however under deck should be used if available Passengers Prohibited when vessels under 246 feet length overall exceed 25 passengers on board Other Requirements None Include MSDS with shipment Version 0, October 2013 Page 5 of 14 Waste Management Procedures Reuse / Recycle To be issued by state of shore base Fieldwood Energy LLC [Address of field location] Phone of field location McCall Boat Rental, Inc. LAD981594054 Coastal Environmental Coastal Environmental Specialists 1313 West Pinhook Road Lafayette, La. 70583 318/775-5485 LAD981057342 LAD000000000 Waste Paint RQ, Flammable, 3, UN 1263 337/264-1112 10 DM 523 G F005 R Reuse / Recycle If not accepted at disposer's address, return to Fieldwood Energy. In case of emergency contact: (1) (337) 232-8282 and (2) Louisiana Transportation & Environmental Safety Section (TESS) at (504) 925-6595 Emergency Response Guide Number 127 Version 0, October 2013 Page 6 of 14 Waste Management Procedures Version 0, October 2013 Page 7 of 14 Waste Management Procedures Waste Paint UN 1263 Fieldwood Energy LLC (EI 158) [Address of field location] 39121 F005 July 1.2011 Version 0, October 2013 001 Page 8 of 14 Waste Management Procedures Shipping Instructions: PAINT THINNER 1. Call or FAX Dock/Base to schedule shipment 2. Package Thinner as follows: a. Non-Bulk Packaging: 1. Place in drum 1A1 or 1A2, b. Bulk Packaging: 1. DOT 51, 52, 53, 56, 57, or 60 Portable Tanks 2. Marine Portable Tanks Note: Methyl Ethyl Ketone [intended for use] has a reportable [spilled] quantity of 5000 pounds (745 gallons). Waste methyl ethyl ketone [EPA waste number D001] has a reportable quantity [RQ] of 100 pounds. (100 pounds of MEK is approximately 15 gallons) 3. Mark Package: a. If material has a flash point below 73oF, mark container as follows: 1. "Waste Paint Related Material, (Paint Thinner), 3, UN1263 PG II". 2. Mark container "Waste Paint Related Material (Paint Thinner) RQ, 3, UN1263 PG II". If container holds less than 100 lbs. (15 gallons), the letters RQ are not required. b. If material has a flash point above 73oF, mark container: 1. "Waste Paint Related Material, (Paint Thinner), 3, UN1263 PG III". 2. Mark container "Waste Paint Related Material (Paint Thinner) RQ, 3, UN1263 PG III". If container holds less than 100 lbs. (15 gallons), the letters RQ are not required. c. Stencil Container-"Fieldwood Energy" and the generator's location (i.e. Eugene Island 158) 4. Label Package: a. DOT "Flammable Liquid" label b. For packages having a volume over 64 cubic feet (478 gallons) and for portable tanks of less than 1000 gallons: place labels on at least two ends (other than the bottom) or two sides c. EPA “Hazardous Waste” label Continued on next page Version 0, October 2013 Page 9 of 14 Waste Management Procedures Shipping Instructions: PAINT THINNER, (continued) 5. Prepare shipping papers: a. Complete entry in Hazardous Materials Section [Section I] of the Fieldwood Energy Shipping Manifest (See example). b. Complete entry in Uniform Hazardous Waste Manifest (See example). 6. Placard Vehicle/Vessel: a. For cargoes of more than 1000 pounds and any Bulk Packaging: "Flammable" Placard with 1263 in center and 3 in lower corner (1000 pounds of MEK is approximately 149 gallons). b. For cargoes less than 1000 pounds and any Non-Bulk Packaging: No Placard required on transport vehicle. c. Cargo or portable tanks shall be placarded as above on opposing sides if capacity is between 119 and 999 gallons and on all four sides if 1000 gallons or more. d. See attached placard 7. Load cargo in accordance with the following shipping limitations: AIR RESTRICTIONS (49 CFR 172.101) Passenger Aircraft 5 quarts (5 Liters) if in Packing Group II 15 gallons (60 Liters) if in Packing Group III Cargo Aircraft 15 gallons (60 Liters) if in Packing Group II 220 gallons (220 Liters) if in Packing Group III WATER 8. RESTRICTIONS (49 CFR 172.101) Cargo and up to 25 passengers Must be stowed either on deck or under deck, however under deck should be used if available Passengers Prohibited when vessels under 246 feet length overall exceed 25 passengers on board Other Requirements None Include MSDS with shipment Version 0, October 2013 Page 10 of 14 Waste Management Procedures Reuse / Recycle To be issued by state of shore base Fieldwood Energy LLC [Address of field location] Phone of field location McCall Boat Rental, Inc. LAD981594054 318/775-5485 LAD981057342 Coastal Environmental Spcialists or Fieldwood Energy Transportation 318/233-9073 Coastal Environmental Specialists 1313 West Pinhook Road Lafayette, La. 70583 LAD000000000 WastePaintRelated Material, RQ, Flammable, 3, UN 1263 337/264-1112 10 DM 523 G F005 R Reuse / Recycle If not accepted at disposer's address, return to Fieldwood Energy. In case of emergency contact: (1) Fieldwood Energy (337) 232-8282 and (2) Louisiana Transportation & Environmental Safety Section (TESS) at (504) 925-6595 Emergency Response Guide Number 127 Version 0, October 2013 Page 11 of 14 Waste Management Procedures Version 0, October 2013 Page 12 of 14 Waste Management Procedures Waste Paint Related Materials UN 1263 Fieldwood Energy LLC (EI 158) [Address of field location] F005 July 1, 2011 Version 0, October 2013 001 Page 13 of 14 Waste Management Procedures Shipping Instructions: PAINT BRUSHES AND CANS NOTE: To qualify as non-hazardous waste and non-hazardous DOT material, the paint brushes and cans must not contain wet paint. 1. Call or FAX Dock/Base to schedule shipment 2. Package Brushes and Cans as follows: a. Remove as much residual product as possible b. Allow remainder to dry and harden c. Discard Materials: 1. Place Brushes in Trash Basket 2. Place Cans in Scrap Metal Basket 3. Mark Container: a. Stencil Container-“Fieldwood Energy” and the generator’s location (i.e. Eugene Island 158) 4. Label Package: a. No labels required 5. Prepare shipping papers: a. Complete entry in General Cargo Section [Section II] of the Fieldwood Energy Shipping Manifest (See example). 6. Placard Vehicle/Vessel: a. No Placard required 7. Load cargo in accordance with the following shipping limitations: AIR RESTRICTIONS (49 CFR 172.101) Passenger Aircraft No Requirement Cargo Aircraft No Requirement WATER RESTRICTIONS Cargo vessels No Requirement Passenger vessels No Requirement Other Requirements None 8. No MSDS is required Version 0, October 2013 Page 14 of 14