Waste Management Procedures Scrap Metals Before you begin Description Scrap Metal Scrap Metal is Non-hazardous Non-exempt recyclable materials Category NORM is E&P exempt waste Radioactive waste Analysis For metal surfaces exposed to the flow of produced water: Use a gamma-ray scintillator capable of detecting 50R/hr (50Roentgens/hr) [Ludlum Model 3, or Model 19, Survey Meter] Establish background level using the gamma-ray scintillator If test is higher than twice background level, lab testing is necessary to determine picocuries per gram For metal surfaces not exposed to the flow of produced water: No analysis is required Accumulation Waste Reduction Recycle scrap metal Disposal Scrap metals free of NORM should be sent to a facility that will beneficially reuse or recycle the metal. Recordkeeping Version 0, October 2013 Place in storage baskets and bins, and/or skids If material is questionable, check it with a gamma-ray scintillator Do not mix NORM materials with any other materials NORM and NORM-free scrap metals must be separated before shipment. List on general cargo section [Section II] of Fieldwood Energy Shipping Manifest Maintain a copy of records at offshore and shorebase facilities while active Send original manifest with shipment Retain records for one year Page 1 of 2 Waste Management Procedures Shipping Instructions: SCRAP METALS 1. Call or FAX Dock/Base to coordinate materials arrival at Dock/Base 2. Package Scrap Metals as follows: Place in scrap metal basket NOTE: NORM AND NORM-FREE SCRAP METALS MUST BE SEPARATED PRIOR TO SHIPMENT 3. Mark Package: a. No DOT marking is required b. Stencil Container-“Fieldwood Energy” and the generator’s location (i.e. Eugene Island 158) 4. Label Package: No DOT label is required 5. Prepare shipping papers: a. Complete entry in General Cargo Section [Section II] of the Fieldwood Energy Shipping Manifest (See example) b. Send to customary dock facility as scrap 6. Placard Vehicle/Vessel: No DOT placard is required 7. Load cargo in accordance with the following shipping limitations: No DOT hazardous material restrictions apply 8. No MSDS required Version 0, October 2013 Page 2 of 2