TOP-WASTE

Trinity Operating Procedures - TOPs

TOP-WASTE Disposing of Hazardous and Non-Hazardous Waste

Rev: 12/06/2017

Scope: This procedure covers the disposal of hazardous and non-hazardous waste created by Trinity Forge & Machine, as well as Trinity's reporting requirements as outlined by the Texas Natural Resource Conservation Commission (TNRCC).

Procedure:

STEP WHO WHEN INFO TO USE WHAT TO DO

1 Any employee Waste product to be disposed of Own observation Notify the Warehouse Administrator that waste product needs to be disposed of.

2 Any supervisor Upon notification from employee waste product is to be disposed of Notification Verify that product does need disposal.

3 Warehouse Administrator Upon notification Material Safety Data Sheet (MSDS); test results, and any other info deemed necessary Determine how material needs to be removed considering test results (if any), reporting requirements, professional opinions, and best available waste hauling options; make sure waste has been identified according to Notice of Registration on file with Texas Commission of Environmental Quality (TCEQ) prior to shipment.

4
Any employee acceptable to Warehouse Administrator Upon instructions from Warehouse Administrator Laboratory results; MSDS; instructions from Warehouse Administrator; National Fire Prevention Association (NFPA) approved label Follow MSDS to bring hazard (if any) to 2000 gallons in storage; store in Department of Transportation approved and properly labeled container; notify Warehouse Administrator waste is ready for transporting from premises.

5 Warehouse Administrator Coordinator Waste is ready for transporting to approved waste facility List of approved waste hauling facilities; list of approved licensed disposal sites; MSDS Determine which waste hauling facility and licensed disposal site to use; coordinate transportation of waste to disposal site.

6 Waste hauling facility Upon arrival for pick up and removal of waste Waste manifest; laboratory results; hauling permit Waste hauling facility to provide Trinity Forge with:
- Waste manifest
- Hauling permit for classification of waste as determined by laboratory results.

7 Environmental Coordinator Receipt of proper documentation for removal of waste from waste hauling facility Waste manifest; laboratory results; hauling permit; any other notes pertaining to shipment File waste manifest and all supporting documentation -- must be kept on file for at least three years as required by law.

8 Waste hauling facility Within 35 days of shipment Waste manifest Provide Environmental Coordinator a signed, completed waste manifest as required by law.

9 Environmental Coordinator As signed completed waste manifest is received Waste manifest Attach to waste manifest information already on file.

11 Environmental Coordinator Annually, by January 25 Annual Waste Summary Report; all Class 1 Industrial Solid Waste and/or Hazardous Waste Manifests Complete Annual Waste Summary and submit to TCEQ on or before January 25.

Revision history:

Release Date	Description of Change	Owner	Approver
12/06/2017	Updated to comply with revised Quality Manual and new TOPs format.	Tim Ellis	Todd Sheppard

Documents are controlled only when viewed on-line at trinityforge.com in the original English -- printed copies or translations are not controlled documents.
? Trinity Forge & Machine

STEP	WHO	WHEN	INFO TO USE	WHAT TO DO
1	Any employee	Waste product to be disposed of	Own observation	Notify the Warehouse Administrator that waste product needs to be disposed of.
2	Any supervisor	Upon notification from employee waste product is to be disposed of	Notification	Verify that product does need disposal.
3	Warehouse Administrator	Upon notification	Material Safety Data Sheet (MSDS); test results, and any other info deemed necessary	Determine how material needs to be removed considering test results (if any), reporting requirements, professional opinions, and best available waste hauling options; make sure waste has been identified according to Notice of Registration on file with Texas Commission of Environmental Quality (TCEQ) prior to shipment.
4	Any employee acceptable to Warehouse Administrator	Upon instructions from Warehouse Administrator	Laboratory results; MSDS; instructions from Warehouse Administrator; National Fire Prevention Association (NFPA) approved label	Follow MSDS to bring hazard (if any) to 2000 gallons in storage; store in Department of Transportation approved and properly labeled container; notify Warehouse Administrator waste is ready for transporting from premises.
5	Warehouse Administrator Coordinator	Waste is ready for transporting to approved waste facility	List of approved waste hauling facilities; list of approved licensed disposal sites; MSDS	Determine which waste hauling facility and licensed disposal site to use; coordinate transportation of waste to disposal site.
6	Waste hauling facility	Upon arrival for pick up and removal of waste	Waste manifest; laboratory results; hauling permit	Waste hauling facility to provide Trinity Forge with: - Waste manifest - Hauling permit for classification of waste as determined by laboratory results.
7	Environmental Coordinator	Receipt of proper documentation for removal of waste from waste hauling facility	Waste manifest; laboratory results; hauling permit; any other notes pertaining to shipment	File waste manifest and all supporting documentation -- must be kept on file for at least three years as required by law.
8	Waste hauling facility	Within 35 days of shipment	Waste manifest	Provide Environmental Coordinator a signed, completed waste manifest as required by law.
9	Environmental Coordinator	As signed completed waste manifest is received	Waste manifest	Attach to waste manifest information already on file.
11	Environmental Coordinator	Annually, by January 25	Annual Waste Summary Report; all Class 1 Industrial Solid Waste and/or Hazardous Waste Manifests	Complete Annual Waste Summary and submit to TCEQ on or before January 25.