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