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2014
Rowan Companies, Inc.
6/20/2014
WASTE DISPOSAL
GUIDANCE MANUAL
GULF OF MEXICO
Waste Disposal Guidance Manual
Gulf of Mexico
Date
07/30/2014
Rev
0
page
1
of
45
Revised 7/30/14
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 DOTROWAN 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 DOTROWAN 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 DOTROWAN 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 DOTROWAN 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”
Waste Disposal Guidance Manual
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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: julie.lemelle@pscnow.com
VENDOR: Effective Environmental
ADDRESS: 9950 Chemical Road, Pasadena, TX 77507
CONTACT: Connie Laflower
PHONE: (214) 635-1353
EMAIL: CLaflower@eff-env.com
VENDOR: Martin Energy Services
ADDRESS: 307 Bunker Road; Lake Charles, LA 70615
CONTACT: Rene' Dillon
PHONE: (800) 445-6482
EMAIL: Rene.Dillon@martinmlp.com
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
Waste Disposal Guidance Manual
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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
nicrud@rowancompanies.com heamyk@rowancompanies.com
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
andcli@rowancompanies.com miclaw@rowancompanies.com
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
rictom@rowancompanies.com chrkni@rowancompanies.com
APPENDIX V: ROWAN HSE CONTACTS
Waste Disposal Guidance Manual
Gulf of Mexico
Date
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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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Waste Disposal Guidance Manual
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Rowan Waste Disposal manual rev 7-14-2014 (1)

  • 1. ks 2014 Rowan Companies, Inc. 6/20/2014 WASTE DISPOSAL GUIDANCE MANUAL GULF OF MEXICO
  • 2. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 1 of 45 Revised 7/30/14 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
  • 3. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 2 of 45 Revised 7/30/14 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
  • 4. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 3 of 45 Revised 7/30/14
  • 5. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 4 of 45 Revised 7/30/14
  • 6. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 5 of 45 Revised 7/30/14 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
  • 7. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 6 of 45 Revised 7/30/14 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
  • 8. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 7 of 45 Revised 7/30/14 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)
  • 9. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 8 of 45 Revised 7/30/14 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
  • 10. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 9 of 45 Revised 7/30/14 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
  • 11. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 10 of 45 Revised 7/30/14 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
  • 12. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 11 of 45 Revised 7/30/14 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
  • 13. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 12 of 45 Revised 7/30/14 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
  • 14. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 13 of 45 Revised 7/30/14 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
  • 15. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 14 of 45 Revised 7/30/14 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
  • 16. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 15 of 45 Revised 7/30/14 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 DOTROWAN XXX #123 WELL NAME AND NUMBER (713) 555 - 1212 January 1, 2014 RECYCLABLE
  • 17. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 16 of 45 Revised 7/30/14 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
  • 18. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 17 of 45 Revised 7/30/14 < 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
  • 19. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 18 of 45 Revised 7/30/14 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
  • 20. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 19 of 45 Revised 7/30/14 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
  • 21. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 20 of 45 Revised 7/30/14 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
  • 22. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 21 of 45 Revised 7/30/14 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
  • 23. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 22 of 45 Revised 7/30/14 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 DOTROWAN XXX #123 WELL NAME AND NUMBER (713) 555 - 1212 January 1, 2014
  • 24. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 23 of 45 Revised 7/30/14 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
  • 25. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 24 of 45 Revised 7/30/14 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
  • 26. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 25 of 45 Revised 7/30/14 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 DOTROWAN XXX #123 WELL NAME AND NUMBER (713) 555 - 1212 January 1, 2014
  • 27. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 26 of 45 Revised 7/30/14 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 DOTROWAN XXX #123 WELL NAME AND NUMBER (713) 555 - 1212 January 1, 2014 SANITARY WASTE
  • 28. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 27 of 45 Revised 7/30/14 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
  • 29. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 28 of 45 Revised 7/30/14 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)
  • 30. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 29 of 45 Revised 7/30/14 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
  • 31. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 30 of 45 Revised 7/30/14 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
  • 32. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 31 of 45 Revised 7/30/14 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
  • 33. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 32 of 45 Revised 7/30/14 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)’
  • 34. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 33 of 45 Revised 7/30/14 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
  • 35. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 34 of 45 Revised 7/30/14
  • 36. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 35 of 45 Revised 7/30/14 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.
  • 37. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 36 of 45 Revised 7/30/14
  • 38. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 37 of 45 Revised 7/30/14 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.
  • 39. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 38 of 45 Revised 7/30/14 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”
  • 40. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 39 of 45 Revised 7/30/14 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
  • 41. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 40 of 45 Revised 7/30/14 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: julie.lemelle@pscnow.com VENDOR: Effective Environmental ADDRESS: 9950 Chemical Road, Pasadena, TX 77507 CONTACT: Connie Laflower PHONE: (214) 635-1353 EMAIL: CLaflower@eff-env.com VENDOR: Martin Energy Services ADDRESS: 307 Bunker Road; Lake Charles, LA 70615 CONTACT: Rene' Dillon PHONE: (800) 445-6482 EMAIL: Rene.Dillon@martinmlp.com APPENDIX IV: ROWAN APPROVED VENDORS
  • 42. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 41 of 45 Revised 7/30/14 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
  • 43. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 42 of 45 Revised 7/30/14 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 nicrud@rowancompanies.com heamyk@rowancompanies.com 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 andcli@rowancompanies.com miclaw@rowancompanies.com 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 rictom@rowancompanies.com chrkni@rowancompanies.com APPENDIX V: ROWAN HSE CONTACTS
  • 44. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 43 of 45 Revised 7/30/14 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
  • 45. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 44 of 45 Revised 7/30/14
  • 46. Waste Disposal Guidance Manual Gulf of Mexico Date 07/30/2014 Rev 0 page 45 of 45 Revised 7/30/14