Authority: Corporate HSE Director
Issue Date: December 15, 2003
Scope: Elkhorn Holdings, Inc., All divisions, districts
and areas, including Elkhorn Construction, Hoad,
Dynamic Services, Eagle Pipeline and ProSafe.
Next Review Date: December 15, 2009
Purpose:
This document is to define the procedure for identifying activities performed by Elkhorn
Holdings, Inc. and all divisions and subsidiaries. It is also used to identify the environmental risk
associated with these activities.
Key Responsibilities:
HSE Director: Facilitate annual review with operations personnel to identify Elkhorn Holdings
Inc. activities and associated environmental risk. Will receive information concerning changes in
activities performed and modify the EMS to fit the new or changed activities. Maintain a current
list of activities and environmental risks.
District Managers, Area Managers and Division General Managers: Identify and provide staff
from each division, district and area to participate in the annual review of activities and associated
environmental risks. Alert the HSE Director when there are changes in activities and/or
environmental risks.
Procedure:
Identification of Activities and Risks: Activities are identified during an annual work session
facilitated by the HSE Director. These activities shall be identified and reviewed by both
management and supervisory personnel from each district, area and division of Elkhorn Holdings,
Inc. Environmental risks associated with each activity shall also be identified during the work
session. Special attention is provided to identify each waste stream from each activity and the
activities and environmental risks are recorded on the Environmental Risk List.
Minutes shall be kept for each of the annual meetings and copies of these minutes shall remain on
file for five (5) years.
Management Of Change:
MOC: When new activities are added to Elkhorn Holdings, Inc. operation, and when existing
activities change, the District Managers, Area Managers and Division General Managers will
notify the HSE Director. The HSE Director updates the Environmental Risk List as appropriate
based on the reported change, and evaluates and communicates any other changes needed in the
Environmental Management System.
Key Documents:
Waste Stream Generation List: Retain last updated version for five (5) years
Environmental Risk List: Retain last updated version for five (5) years
Revision Log:
Revision Date
11/15/03
05/15/07
12/15/08
Authority
Randy M. Erickson HSE Director
Walter A Jones HSE Director
Walter A Jones HSE Director
Revision Details
Initial Version
Review
Review
Authority: Corporate HSE Director
Issue Date: December 15,2003
Scope: Elkhorn Holdings, Inc., All divisions, districts
and areas, including Elkhorn Construction, Hoad,
Dynamic Services, Eagle Pipeline and ProSafe.
Next Review Date: December 15,2009
Waste Stream:
Waste Generated
Scrap Lumber
Waste Paper
Plastic Sheeting
Used Nails
Welding Rod
Glass
Food Waste
Fiberglass Insulation
Rock Wool insulation
Foam Insulation
Calcium Silicate Insulation
Copper Slag Sand Blast Media
Silica Sand Blast Media
Scrap Metal
Concrete
Fugitive Dust Emissions
Acetylene (cylinder)
Oxygen (cylinder)
Nitrogen (cylinder
Argon (cylinder)
Propane (cylinder)
Adhesives
Used Cutting Oil
Used Lubricating Oil
Used Hydraulic Oil
Used Filters
Diesel
Gasoline
Asbestos
Paint
Paint Solvent
Cleaning Solvent
Exhaust Emissions
Scrap Pipe (taken out of service)
Hydro Test Water
Tank Sludge
Fluorescent Light Tubes
Lead/Acid Batteries
Revision Log:
Revision Date
11/15/03
05/15/07
12/15/08
Classification of Waste
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non- hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Non-hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Hazardous
Unknown
Unknown
Unknown
Universal
Universal
Authority
Randy M. Erickson HSE Director
Walter A. Jones HSE Director
Walter A Jones HSE Director
Disposal Method
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Landfill
Recycle
Landfill
Correct at source
Return to Vender
Return to Vender
Return to Vender
Return to Vender
Return to Vender
Approved Method
Approved Method
Approved Method
Approved Method
Approved Method
Approved Method
Approved Method
Approved Landfill
Landfill after thoroughly dried
Approved Method
Approved Method
Correct at source
Recycle If NORM is not present
Approved Method
Approved Method
Approved Method
Recycle
Revision Details
Initial Version
Review
Review
Authority: Corporate HSE Director
Issue Date: December 15,2003
Activities:
Location
New construction
Scope: Elkhorn Holdings, Inc., All divisions, districts
and areas, including Elkhorn Construction, Hoad,
Dynamic Services, Eagle Pipeline and ProSafe.
Next Review Date: December 15,2009
Activity
Environmental Risk
Excavation
Storm water migrating off site
Liquid release from hitting unknown lines
Hydrocarbon gas release from hitting unknown
lines
Hydraulic line breakage/spill
Spills from refueling
Used oil disposal
Used oil filter disposal
Used fuel filter disposal
Non-hazardous waste disposed of improperly
Excessive exhaust emissions
Oil leaks
Ground water pumped from excavation
Form Oil spill
Non-hazardous waste disposed of improperly
Improper disposal/recycle of scrap metal and
pipe
Hydraulic line breakage/spill
Used oil disposal
Used oil filter disposal
Used fuel filter disposal
Excessive exhaust emissions
Oil leaks
Hydro test water disposal
Waste paint disposal
Waste paint solvent disposal
Sand blast media disposal
Client product release/spill
Improper disposal/recycle of scrap conduit and
wire
Hydraulic line breakage/spill
Universal waste disposal
Diesel fuel spill
Improper battery disposal/recycle
Used fuel filter disposal
Used oil filter disposal
Used oil disposal
Client product/sludge disposal
Waste paint disposal
Waste paint solvent disposal
Liquid release from vehicle malfunction or
accident
Scrap metal/pipe disposal
Civil
Mechanical
Tie In
Electrical
Fabrication/Shop
Revision Log:
Revision Date
11/15/02
05/15/07
12/15/08
Authority
Randy M. Erickson HSE Director
Walter A Jones HSE Director
Walter A Jones HSE Director
Revision Details
Initial Version
Review
Review