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ks 2014 Rowan Companies, Inc. 6/20/2014 WASTE DISPOSAL GUIDANCE MANUAL GULF OF MEXICO

Rowan Waste Disposal manual rev 7-14-2014 (1)

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Page 1: Rowan Waste Disposal manual rev 7-14-2014 (1)

ks

2014

Rowan Companies, Inc.

6/20/2014

WASTE DISPOSAL GUIDANCE MANUAL GULF OF MEXICO

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Aerosol Cans

Antifreeze (Engine coolant)

Asbestos

Ballasts, fluorescent lamp

Batteries (Alkaline)

Batteries (Lithium)

Batteries (Ni-Cad)

Batteries (Lead Acid)

Empty (Cylinders)

Empty (Drums)

Filters, used (Diesel)

Filters, used (Oil)

Flares & Pyrotechnics

Food Waste

Light Bulbs

NORM

Oil (Cooking)

Oil (Used)

Oily Rags

Operator’s Waste

Paint & related wastes

Sandblast Sand.

Sanitary Waste

Scrap Metal

Trash (non-recyclable)

Trash (recyclable)

Unknown Waste

Appendix I: EHS Insight Information

Appendix II: Rowan Regional Information

Appendix III: Rowan Approved Vendor List

Appendix IV: Rowan HSE Contacts

Appendix V: Labels and Markings

TABLE OF CONTENTS

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Waste Type

Liquids from aerosol cans that have been punctured utilizing the AEROSOLV 5000 System (SAP# 64138)

Source

This waste is generated from the puncturing of spent aerosol cans and collecting the liquid in a drum (paint, WD-40, liquid wrench, etc,). Solvents, paints and oils only! No Corrosive material.

Shipping Name

UN 1268, Petroleum Distillates, n.o.s., PG III

Additional Notes

Empty aerosol cans may be disposed as trash

Labels

55 Gal Drum 1-A1 DOT

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

REPORTABLE QUANITY

LAND: 100 POUNDS WATER: ANY AMOUNT

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

PETROLEUM DISTILLATES

January 1, 2014

ROWAN CONTAINER IDENTIFICATION STICKER

AEROSOL CANS (LIQUIDS) HAZARDOUS

55 Gal Drum 1-H1 DOT FLAMMABLE LIQUIDS CLASS 3

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Waste Type

Antifreeze used as an engine coolant is an industrial waste that is recyclable.

Source Used as engine coolant in equipment such as compressors, generators and cranes.

Shipping Name

Non-regulated material (aqueous anti-freeze solution)

Additional Notes

Antifreeze should be reused whenever possible.

Labels

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

ANTIFREEZE RECYCLABLE

REPORTABLE QUANITY

LAND: 5,000 POUNDS WATER: ANY AMOUNT

ROWAN CONTAINER IDENTIFICATION STICKER

Tote Tank

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

ANTIFREEZE

55 Gal Drum 1-A1 or 1-H1 DOT

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Waste Type

Asbestos is a toxic waste and is regulated for disposal purposes.

Source

This type of waste comes from equipment that has been insulated with asbestos or from

other asbestos-containing building material wastes.

Examples include asbestos-containing material (ACM) from:

Glasweld panels,

Roofing products,

Insulation,

Transite, and

Gaskets containing asbestos.

Asbestos Survey & Removal

Asbestos is nearly impossible to identify by visual inspection techniques. Only a licensed asbestos removal contractor shall be used to survey projects where asbestos is suspected. Also, because use of asbestos was phased out after 1981, records that document the age of the facility or equipment can be a useful determinant that ACM is not present. Without other objective data, suspect ACM must be identified by taking samples and analyzing them to verify the presence of asbestos.

Waste Vendors

Handling and disposal of any asbestos shall be done by an ROWAN-approved subcontractor.

Shipping Name

Case by Case

Additional Notes

All rigs built after the Rowan Gorilla IV (1986) should have been built asbestos free. Rigs built before then have the potential of asbestos. Any handling of ACM should be done in planned and controlled environment. It is recommended that ROWAN retain all records associated with asbestos for a minimum of Forty (40) years

Labels Case by Case

ASBESTOS SPECIAL HANDLING BY THIRD PARTY REQUIRED

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Waste Type

Spent ballasts are a recyclable Universal Waste

Source Generated during the replacement of spent ballasts in fluorescent lamp fixtures

Shipping Name

Spent Lamp Ballasts DOT Non-Regulated Article

Additional Notes

N/A

Labels

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

UNIVERSAL WASTE

ROWAN CONTAINER IDENTIFICATION STICKER

5 Gallon Bucket

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

BALLASTS

BALLASTS (FLUORESCENT LAMPS)

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Waste Type

Spent dry alkaline batteries are a recyclable

Source Generated during the replacement of spent batteries in flashlights, radios, watches, clocks, etc.

Shipping Name

Battery, Dry (Alkaline Batteries)

Additional Notes

N/A

Labels

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

BATTERIES (ALKALINE)

ROWAN CONTAINER IDENTIFICATION STICKER

RECYCLABLE

5 Gallon Bucket

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

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Waste Type

Spent dry Lithium batteries are a recyclable Universal Waste

Source Generated during the replacement of spent batteries in flashlights, radios, watches, clocks, etc.

Shipping Name

UN 3090, Lithium metal batteries, 9, PG III

Additional Notes

Tape the end of the terminals to avoid arcing with the other batteries. Shipment of batteries by air is prohibited.

Labels

MISCELLANEOUS CLASS 9

5 Gallon Bucket

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

BATTERIES (LITHIUM) UNIVERSAL WASTE

ROWAN CONTAINER IDENTIFICATION STICKER

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

LITHIUM BATTERIES

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Waste Type

Spent dry Nickel Cadmium (Ni-Cad) batteries are a recyclable Universal Waste

Source Generated during the replacement of spent batteries in flashlights, radios, watches, clocks, etc.

Shipping Name

UN 3028, Batteries Dry Containing Potassium Hydroxide Solid, 8, PGIII

Additional Notes

Tape the end of the terminals to avoid arcing with the other batteries. Shipment of batteries by air is prohibited.

Labels

CORROSIVE CLASS 8

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

BATTERIES (NI-CAD) UNIVERSAL WASTE

ROWAN CONTAINER IDENTIFICATION STICKER

5 Gallon Bucket

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

NI-CAD BATTERIES

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Waste Type

Spent Lead Acid batteries are a recyclable Universal Waste

Source Generated during the replacement of spent batteries in flashlights, radios, watches, clocks, machinery, etc.

Shipping Name

UN 2800, Batteries, Wet Non-spillable, 8, PG III OR UN 2794, Batteries, Wet Filled with Acid, 8, PG III

Additional Notes

Tape the end of the terminals to avoid arcing with the other batteries. Shipment of batteries by air is prohibited.

Labels

1 or 5 Gallon Bucket

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

BATTERIES (LEAD ACID) UNIVERSAL WASTE

ROWAN CONTAINER IDENTIFICATION STICKER

Wood Pallet

REPORTABLE QUANITY

LAND: 3,333 POUNDS WATER: ANY AMOUNT

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

LEAD ACID BATTERIES

CORROSIVE CLASS 8

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Waste Type

EMPTY Gas Cylinders such as fire extinguisher bottles, SCBA bottles, cylinders of N2, CO2, etc.

Source EMPTY Gas Calibration Bottles, Fire Extinguisher Charges, Freon Tanks, and Compressed Gas Bottles are the main source of this waste.

Disposal Methods

EMPTY Gas Cylinders should be exchanged out with new cylinders with the supplier whenever possible. EMPTY Gas Cylinders which cannot be exchanged out should be disposed of as scrap metal.

Shipping Name

Case by case

Additional Notes

EMPTY Gas Cylinders being shipped back to be swapped out, need to check with the supplier on how they would like them shipped back. EMPTY Gas Cylinders being shipped in for recycling need to verify how the facility receiving the cylinders would like the cylinders shipped in. The cylinders MUST be EMPTY and the valves removed.

Labels Case by Case

CYLINDERS (EMPTY) RECYCLABLE

RETURN TO THE SUPPLIER FOR REUSE OTHERWISE SEND IN AS SCRAP METAL

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Waste Type

Empty drums or containers that previously held a product for use.

Source Various uses and areas.

Disposal Methods

Empty containers may be shipped for recycling or sent for land disposal depending on the last contents and if they have been rinsed or not. Please note if containers are to be rinsed, the rinseate must be accumulated as a waste material.

Shipping Name

Case by case. If the product it previously contained is non-regulated by DOT, the empty containers are non DOT regulated. If container previously held a DOT regulated material (and the empty container has not been triple rinsed), the container maintains the same DOT shipping name as when full except the phrase “empty container last containing….” Is added before the proper shipping name.

Additional Notes

Please note the difference between what DOT calls “empty” versus what EPA calls “empty” (per RCRA guidelines). DOT empty means the container is drained dry and rinsed clean. EPA empty means the container is drained dry (per commonly used methods to empty a container). EPA does not require rinsing of the empty container unless it last contained a discarded commercial chemical listed in 40 CFR 261.33 (“P” listed chemicals).

Labels Recommend adding a label stating “EMPTY”. Do not obliterate the original contents label if original material was hazardous per DOT (49 CFR 172.101) unless the container has been triple rinsed.

DRUMS (EMPTY) RECYCABLE

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Waste Type

Fuel filters

Source Combustion equipment

Shipping Name

RQ, UN1325, Waste Flammable Solids, Organic, n.o.s., (empty diesel fuel filters), PG III

Additional Notes

Drain all filters before placing in waste drum. . Also put some oil dry or similar absorbent in bottom of waste container to ensure no free liquids are present.

Labels

ROWAN CONTAINER IDENTIFICATION STICKER

FILTERS (DIESEL) HAZARDOUS

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

FLAMMABLE SOLIDS CLASS 4.1

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

55 Gal Drum 1-A2 DOT

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Waste Type

Used oil filters

Source Combustion and hydraulic equipment

Shipping Name

Non-DOT regulated material (used oil filters)

Additional Notes

Per 40 CFR 279, used oil filters must be drain while still warm to make sure all liquid oil drains. Also put some oil dry or similar absorbent in bottom of waste container to ensure no free liquids are present.

Labels

FILTERS (OIL)

ROWAN CONTAINER IDENTIFICATION STICKER

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

55 Gal Drum 1-A2 DOT ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

RECYCLABLE

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Waste Type

Used/ Expended Signal Flares and other emergency signaling pyrotechnics are trash. Un-used/ un-expended flares and other emergency signaling pyrotechnics are flammable hazardous waste.

Source Expired signal flares and pyrotechnical devices.

Disposal Contact Rowan HSE for Guidance

Shipping Name

Case by Case

Additional Notes

With prior approval through the USCG, these can be to flared off during drills and exercises.

Labels Case by Case

FLARES & PYROTECHNICS SPECIAL HANDLING BY THIRD PARTY REQUIRED

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< 12 nautical miles

Discharge is prohibited within 12 nautical miles of land.

Containerization: use T-bags or odor-controlling containers with limited wildlife access.

Labeling: stencil bags with “RDC” and rig number.

The amount of food waste and the name of the transporter and waste facility shall be recorded by the BE/CE or designated person on the Discharge Monitoring Report (DMR), in the Garbage Record Book, and on the Waste Shipping Logs in EHS Insight.

> 12 nautical miles

Discharge is allowed only if food waste is ground to less than 25mm (1 inch). Otherwise, food waste shall be shipped to shore for disposal. The amounts discharged shall be recorded by the BE/CE or designated person in the Garbage Record Book.

Every effort shall be made to keep cooking oil out of this waste stream.

FOOD WASTE

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Waste Type

Spent Fluorescent tubes and compact fluorescent lamps.

Source Lighting fixtures

Shipping Name

UN3506, Waste mercury contained in manufactured articles, 8 (6.1), PG III

Additional Notes

DO NOT BREAK OR CRUSH these bulbs unless the facility is equipped with a properly rated bulb crushed with vapor control.

Labels

CORROSIVE CLASS 8

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

LIGHT BULBS UNIVERSAL WASTE

ROWAN CONTAINER IDENTIFICATION STICKER

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

4G Boxes or Drums

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Waste Type

Naturally Occurring Radioactive Materials (NORM) are classified as NORM. This waste classification is distinct from every other classification of waste (e.g. Hazardous, non-hazardous, NOW, etc)

Industry Best Practice recommends that equipment/waste that has a Ludlum surfaces will be considered

potentially NORM contaminated.

Potentially NORM contaminated equipment and waste will be transferred to the shore base as NORM.

Source Naturally-Occurring Radioactive Materials (NORM) occurs as scale or solids in tubulars & equipment that has been in contact with the production stream.

Additional Notes

See appropriate procedure for scanning suspected NORM material for activity above background.

Labels The responsibility of the operator

NORM WASTE TO BE HANDLED BY THE OPERATOR

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Waste Type

Cooking Oil is a recyclable solid waste

Source Generated in the Galley

Shipping Name

Used Cooking Oil

Additional Notes

Do not mix cooking oil with any other types of waste.

Labels

55 Gal Drum 1-A1 DOT

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

OIL (COOKING) RECYCLABLE

ROWAN CONTAINER IDENTIFICATION STICKER

REPORTABLE QUANITY

LAND: 25 GALLONS WATER: ANY AMOUNT

55 Gal Drum 1-H1 DOT

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

COOKING OIL

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Waste Type

Used oil

Source Various combustion and hydraulic components.

Shipping Name

Non-DOT regulated material (used oil)

Additional Notes

Make sure the used oil does not get mixed with other liquids such as diesel fuel, solvents, acids, bases, etc. This may change the shipping name and hazard class of this material.

Labels

55 Gal Drum 1-A1 DOT

Tote Tank

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

OIL (USED ENGINE) RECYCLABLE

ROWAN CONTAINER IDENTIFICATION STICKER

REPORTABLE QUANITY

LAND: 25 GALLONS WATER: ANY AMOUNT

TOTES REQUIRE “USED OIL”ON

ALL 4 SIDES

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

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Waste Type

Oil/grease contaminated rags

Source Cleaning and maintenance of equipment

Shipping Name

BY WATER: UN 1856, Rags Oily, 4.2, II

Additional Notes

Oily rags are not a hazardous waste, but are a hazardous material when shipped over water.

Labels

SPONTANEOUSLY COMBUSTIBLE CLASS 4.2

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

OILY RAGS NON HAZARDOUS

ROWAN CONTAINER IDENTIFICATION STICKER

55 Gal Drum 1-A2 DOT ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

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Completion Fluids

N.O.W.

Used Completion Fluids are classified as an EPA non-hazardous oilfield waste (NOW).

HAZARD CLASS: Additionally the DOT rules classify as follows: 1. Completion fluids with a flash point < 100 o F are flammable liquids 2. Completion fluids with flash point > 100o < 200 F are combustible liquids

PROPER SHIPPING NAME (FLAMMABLE): Used Completion Fluids, NOW Flammable liquid, N.O.S., (contains insert chemical name), UN1993,3, PGII PROPER SHIPPING NAME (COMBUSTIBLE): Used completion fluids NOW - Combustible Liquid, N.O.S.(contains insert chemical name), NA1993, PGIII

NOTE: Offshore injection is an option

Mud, Oil Based &

Synthetic Based: N.O.W.

Used Oil Base mud (OBM) & Synthetic Base Mud (SBM) are a non-hazardous oilfield waste (NOW) that is recyclable. The waste must be USED mud. This means the mud must have gone DOWN-HOLE or in the process stream to be a N.O.W. waste. HAZARD CLASS: N/A PROPER SHIPPING NAME: Oil Base Mud, NOW (non-DOT regulated) or Synthetic Base Mud (non-DOT regulated).

Mud Water Based

N.O.W.

Used Water Base Mud is a non-hazardous oilfield waste. The waste must be USED mud. This means the mud must have gone DOWN-HOLE or in the process stream to be a N.O.W. waste.

HAZARD CLASS: N/A

PROPER SHIPPING NAME: Used Water Base Mud – N.O.W. (non-DOT regulated)

Paraffin N.O.W.

Paraffin is a NON-Hazardous Oilfield Waste (NOW) that is recyclable. Paraffin is generated when cleaning lines and equipment.

HAZARD CLASS: N/A

PROPER SHIPPING NAME: Used Water Base Mud – N.O.W. (non-DOT regulated)

Produced Sand

Produced sand is a byproduct of production processes. A Ludlum survey is required to determine if it is temporarily classified for shipment as non-hazardous oilfield waste (NOW) or classified as potential Naturally-Occurring Radioactive Material (NORM).

OPERATIONAL WASTE: WASTES GENERATED AND HANDLED BY THE OPERATOR

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Waste Type

Waste paint and paint related material

Source Maintenance activities.

Shipping Name

RQ, UN1263, Waste Paint related material, PG III

Additional Notes

Liquids should be stored in closed top drums, and debris and clean up materials can be stored in open top drums.

Labels

FLAMMABLE LIQUIDS CLASS 3

55 Gal Drum 1-A1 DOT

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

REPORTABLE QUANITY

LAND: 100 POUNDS WATER: ANY AMOUNT

ROWAN CONTAINER IDENTIFICATION STICKER

PAINT RELATED MATERIAL HAZARDOUS

55 Gal Drum 1-H1 DOT

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

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Waste Type

Spent Sandblast grit

Source This waste is generated during preparation for painting and maintenance.

Shipping Name

Spent sandblast media with paint chips

Additional Notes

Rigs built prior to 1987 will need to contact the Rowan HSE Department to determine it Lead testing should be performed.

Labels

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

SANDBLAST SAND NON HAZARDOUS

ROWAN CONTAINER IDENTIFICATION STICKER

55 Gal Drum 1-A2 DOT ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

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Waste Type

Sanitary waste is a solid waste.

Source Sanitary waste is generated from cleaning out Sewage Treatment Units or Marine Sanitation Device.

Shipping Name

Sanitary Waste

Additional Notes

Contact the HSE Department for disposal guidance

Labels

1-H2X Plastic Drum

CONTAINERS FOR STORAGE AND SHIPPING AND LABEL PLACEMENT

SANITARY WASTE NON HAZARDOUS

ROWAN CONTAINER IDENTIFICATION STICKER

55 Gal Drum 1-A2 DOT

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

SANITARY WASTE

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Waste Type

Scrap metal is a non-hazardous industrial waste that is recyclable.

Source Any used or scrap metal.

Shipping Name

N/A

Additional Notes

All metal needs to be clear of any petroleum residue

Scrap metal shall be placed in the Scrap metal basket or scrap metal dumpster

Labels Make sure the container is labeled with the rig name and RDC

SCRAP METAL RECYCLABLE

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Waste Type

Trash is a disposable solid waste.

Source

Trash is generated by the disposal of non-hazardous "household" items (e.g., garbage, water filters, AC filters, etc) and non-hazardous or otherwise un-regulated items. Examples include:

• Flares (EXPENDED) and Pyrotechnics

• Glass

• Paint Brushes (used and dried)

• Paint cans (EMPTY: water-based paint ONLY)

• Thread Protectors

• Wood (e.g. broken pallets, non-creosote)

• Place trash into appropriate trash bags.

Shipping Name

N/A

Additional Notes

Do not crush glass.

Labels Make sure the container is labeled with the rig name and RDC

TRASH (NON RECYCLABLE)

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Waste Type

Disposable solid waste that is recyclable

Source

Trash (recyclable) is generated by the disposal of non-hazardous

"household" items and non-hazardous or otherwise un-regulated

items that can be beneficially recycled. Examples include:

• Empty aluminum cans (e.g. soft drink cans)

• Newspapers

• Magazines

• Paper bags

• Cardboard

• Aluminum foil

• Plastic bottles

Shipping Name

N/A

Additional Notes

Recycling options will vary from operator to operator.

Labels Labeling: stencil containers with “RDC” and rig number.

TRASH RECYCLABLE

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Waste Type

All unknown wastes

Source • Mixtures of chemicals that have been put into a common container.

• Containers without labels, or with illegible labels.

• Containers for which records or MSDS have been lost.

Disposal Methods

DO NOT SHIP: Contact Rowan’s HSE Department for assistance

Waste Vendors

Contact Rowan’s HSE Department for assistance

Shipping Name

Contact Rowan’s HSE Department for assistance

Additional Notes

If the waste cannot be determined through generator knowledge, arrangements may have to be made for a sample to be taken for proper analysis of the waste. Store in an area away from potentially incompatible material. NOTE: It is important to collect any and all information about the unknown item, such as:

Container Information: Size, type, condition

Physical state: Liquid, solid, gas

Where was the item found

Any ideas of what the waste may or may not be and why

Labels Contact Rowan’s HSE Department for assistance

UNKNOWN WASTE

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The following is an example of completing a ‘Waste Shipping Log’ in EHS Insight. In this example, we are using the following information:

SHIPPING INFORMATION:

RIG: EXL III OPERATOR: McMoran VENDOR: PSC DOCK: Broussard Brothers Dock 337-898-4066

5817 La. Hwy 333 - Abbeville, La. 70510

WASTE BEING SHIPPED:

OILY RAGS USED OIL 3 X 55 GAL DRUM METAL 1 X 500 GAL TOTE WEIGHT: 200 LBS/DRUM WEIGHT: 1000 LBS

PAINT WASTE NI-CAD BATTERIES 1 X 55 GAL DRUM METAL 1 X 5 GAL DRUM FIBER WEIGHS 500 LBS WEIGHT: 25 LBS

APPENDIX I: EHS INSIGHT – COMPLETING A WASTE LOG

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TO START A NEW FORM:

From the main page of EHS Insight, Go the

‘Environmental Dashboard’

Under ‘Start New Form – Periodic Environmental’ Click on ‘Waste Shipping Log (As Occurs)’

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Select the rig

Enter in the current date

Enter Rig Location Latitude & Longitude

Enter the address of the dock that the waste will go to and be picked up by the waste vendor.

Enter the name of the vessel taking the waste to the dock

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Select the type of waste being shipped

Enter # of items being shipped

Select the type of container the waste is in.

Enter the size of the container and the unit of measure.

Enter TOTAL weight of containers for that item and the unit of measure. (3 x 200 lbs = 600 lbs)

Enter the name of the disposal facility that will be handling the waste.

To add another waste item to the form, ‘Click’ on ‘Add Another Package.’

Disposal facilities may have ID numbers on their containers. Enter those numbers here.

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Enter the name of the employee filling out the form and not the position of the person

Attach documentation that may be significant to the shipment such as lab analysis, pictures, signed shipping papers, etc...

Once the form is completed, click the “PRINT” icon to produce the ‘Dangerous Goods Form’

‘Save’ allows you to save your work if you are not finished completing the form, but need to exit the program.

‘Submit’ click the submit button when the waste has been shipped to shore.

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This section is for the transport vessel taking the waste to shore. The signed form should be loaded up in EHS Insight under “Add Attachments” Under “Shipment Details”

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WASTE SHIPMENTS IN THE GULF OF MEXICO

All Waste shipments must be completed in EHS Insight and logged in The Garbage

Record Book. EHS Insight will provide the Dangerous Goods Form required by IMDG and

DOT to transport the material from the rig to the dock.

RMS-QHSE-0203 WASTE MANAGEMENT POLICY / PROCEDURE

RMS-QHSE-0205 GARBAGE MANAGEMENT POLICY / PROCEDURE

Materials that are considered waste will be shipped from the rig to the dock as a

hazardous material, if it meets the criteria as a hazardous material per IMDG Code

and/or DOT regulations

Once the material has been received at the dock, the materials will then be deemed a

waste and Rowan’s waste vendors will then provide the proper labeling, paperwork,

transportation and disposal in accordance with 29 CFR (USDOT) and 40 CFR (RCRA-EPA).

Final paperwork from the disposal facilities will be sent to the Rowan Corporate HSE

department for record retention.

APPENDIX III: ROWAN REGIONAL INFORMATION

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These approved Rowan vendors should be able to handle all the wastes generated by the rig. If there is an issue with any of these vendors not being able to accommodate the rigs disposal needs, please contact Rowan’s Corporate HSE Department for assistance.

VENDOR: PSC

ADDRESS: 4050 Homestead Rd, Houston, TX 77028

CONTACT: Julie LeMelle

PHONE: 713-679-2315

EMAIL: [email protected]

VENDOR: Effective Environmental ADDRESS: 9950 Chemical Road, Pasadena, TX 77507

CONTACT: Connie Laflower

PHONE: (214) 635-1353

EMAIL: [email protected]

VENDOR: Martin Energy Services

ADDRESS: 307 Bunker Road; Lake Charles, LA 70615

CONTACT: Rene' Dillon

PHONE: (800) 445-6482

EMAIL: [email protected]

APPENDIX IV: ROWAN APPROVED VENDORS

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1 - Primary/Preferred Vendor 2 – Secondary Vendor Blank – Call Rowan HSE for guidance

WASTE PSC E2 MARTIN VARIES

BY OPERATOR

RETURN TO

SUPPLIER

HANDLED BY

OPERATOR

CONTACT ROWAN

HSE

Aerosol Cans 1 1

Antifreeze 1 1 2

Asbestos 1

Ballasts 1 1

Batteries (Alkaline) 1 1

Batteries (Lithium) 1 1

Batteries (Ni-Cad) 1 1

Batteries (Lead Acid) 1 1

Cylinders (Empty) 2 2 1

Drums (Empty) 2 2

Filters, used (Diesel) 1 1 2

Filters, used (Oil) 1 1 1

Flares & Pyrotechnics 1

Food Waste 1

Light Bulbs 1 1

NORM 1

Oil, Cooking 1 1

Oil, Used 1 1 1

Oily Rags 1 1 1

Operational Wastes 1

Paint & related wastes 1 1

Sandblast Sand. 1 1

Sanitary Waste 1

Scrap Metal 1

Trash (non-recyclable) 1

Trash (recyclable) 1

Unknown Waste 1

APPENDIX IV: ROWAN PREFERRED VENDOR MATRIX

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CORPORATE

NICOLE RUDOLPH HEATHER MYKLEBUST ENVIRONMENTAL SPECIALIST ENVIRONMENTAL SPECIALIST (713) 960-5357 Office (713) 968-1444 Office (281) 224-7768 Cell (281) 979-3170 Cell 2800 Post Oak Blvd – Suite 5450 2800 Post Oak Blvd – Suite 5450 Houston, TX 77056 Houston, TX 77056 [email protected] [email protected]

ANDY CLINE MICHAEL LAWSON CORPORATE HSE MANAGER VP OF HSE (713) 960-7544 Office (713) 968-1440 Office (504) 259-7543 Cell (832) 506-4862 Cell 2800 Post Oak Blvd – Suite 5450 2800 Post Oak Blvd – Suite 5450 Houston, TX 77056 Houston, TX 77056 [email protected] [email protected]

AMERICAS

RICHARD TOMLIN CHRISTOPHER KNIGHT REGIONAL HSE MANAGER HSE MANAGER DEEPWATER (713) 960-7514 Office (713) 968-1452 Office (832) 455-4559 Cell (713) 542-6403 Cell 5051 Westheimer Suite 1700 5051 Westheimer Suite 1700 Houston, TX 77056 Houston, TX 77056 [email protected] [email protected]

APPENDIX V: ROWAN HSE CONTACTS

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NOTE: Accumulation Start Date: Waste generators must place an accumulation start date on all tanks and containers of hazardous waste in their accumulation area. That date must be visible for inspection. This would indicate the day the first waste entered the container in the accumulation area or the date a satellite accumulation container was moved to the accumulation area.

ROWAN XXX #123

WELL NAME AND NUMBER

(713) 555 - 1212

January 1, 2014

COOKING OIL

APPENDIX VI: LABELS AND MARKINGS

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