INTRODUCTION

Waste Harmonics is committed to conducting business in a manner that preserves the quality of the environment by continuously seeking ways to minimize the environmental impact of past, present and future operations. We are also committed to conducting our activities to meet all applicable laws and regulations, as well as company policies and the requirements of our Environmental Management System (EMS) and require the same of our vendors. Therefore, environmental performance is a consideration in the selection of Vendors. Waste Harmonics Environmental Policy should be viewed at https://www.whwebsite.wpengine.com/.

Waste Harmonics retains the right to require the Vendor to immediately cease work activities if, in the opinion of Waste Harmonics, the Vendor is not performing work in an environmentally-responsible manner or is in violation of Waste Harmonics procedures.

APPLICABILITY

This document applies to all Vendors, vendors, consultants and others (hereinafter collectively referred to as “vendors”) who have a contractual relationship with Waste Harmonics.

COMPLIANCE WITH REGULATORY REQUIREMENTS

Vendors are required to comply with Federal, state and local environmental regulations and all other applicable laws, ordinances, and regulations, and project and site-specific permits. Compliance of personnel with all environmental and other applicable regulatory law and regulations is essential in protecting the environment.

SPILL PREVENTION

All Vendors shall conduct all activities in a manner that will prevent a release to the environment. Spill prevention measures, including maintaining spill control materials, may be required based on the activity being performed and the potential for spills.

Immediate notification by all Vendors to the appropriate Company representative is required for all environmental incidents resulting in a release of oil/hazardous materials or damage to public or private property. A written report describing the incident and proposing preventative measures must be provided to the Company within 24 hours of the incident.

All Vendors are responsible to make all required notifications to regulatory agencies in the required time frame and to ensure that the release is properly responded to, including cleanup and disposal of waste materials. The Vendor is responsible for hiring Vendors for the cleanup of releases, as necessary. The Vendor may request assistance from Waste Harmonics in determining whether notifications are required and for guidance in response actions. If the Vendor does not respond appropriately, Waste Harmonics reserves the right to assume response actions and recover costs incurred from the Vendor.

DISPOSAL

All Vendors will work with Waste Harmonics to characterize all work-related wastes to ensure proper management and shall arrange for disposal in accordance with Federal, state and local regulations. All Vendors will work with Waste Harmonics to prevent pollution at the source, minimize waste generation and recycle/reuse materials when economically feasible (e.g., recycle oily soil via asphalt batching). There shall be no onsite disposal of wastes unless specified by Waste Harmonics elsewhere in the Agreement.

CHEMICALS

All Vendors shall provide a Material Safety Data Sheet (MSDS) for each material to be used during the work. All chemicals must be approved for use by the Safety Department and the Environmental Department.

All unused chemical (non-waste) products originally brought to the property by the Vendor shall remain the responsibility of the Vendor and shall be removed by the Vendor at the conclusion of the Vendor’s onsite activities.

ENVIRONMENTAL POLICY – WASTE HARMONICS LLC

(effective 9-1-2012)

Waste Harmonics LLC is committed to conducting business in a manner that preserves the quality of the environment by continuously seeking ways to minimize the environmental impact of past, present and future operations. We are also committed to conducting our activities to meet all applicable laws and regulations, as well as customer policies. We will work to prevent pollution at the source, minimize waste generation, recycle/reuse materials where allowed by law and economically feasible, and dispose of remaining wastes only through safe and environmentally sound methods. We require the same commitments of our vendors. Therefore, environmental performance is a consideration in the selection of vendors.

Waste Harmonics retains the right to require the vendor to immediately cease work activities if, in the opinion of Waste Harmonics, the vendor is not performing work in an environmentally-responsible manner.

The Vendor shall be responsible for developing, implementing and monitoring an Environmental Protection Plan, if notified by Waste Harmonics that one is required for the project. The plan shall be submitted to Waste Harmonics prior to mobilization on the work site, and is subject to approval. The Environmental Protection Plan shall address the following items:

• Land, air and water resource protection measures;
• Identification, handling, management, transportation, and disposal of all materials;
• Spill prevention and emergency response measures; and,
• Environmental performance monitoring.

APPLICABILITY

This document applies to all vendors who offer services including, but are not limited to, all types of equipment installation and repair; construction and maintenance services; recycling and waste disposal; and transportation.

COMPLIANCE WITH REGULATORY REQUIREMENTS

Vendors are required to comply with all Federal, state and local environmental regulations and all other applicable laws, ordinances, and regulations, and project and site-specific permits. In addition, the Vendor must comply with Waste Harmonics rules, practices, or work methods that may be more stringent than regulatory requirements, as well as any additional site-specific conditions. The following sections outline Waste Harmonics requirements. Any questions concerning the requirements should be referred to your Waste Harmonics contact.

WASTE HARMONICS ENVIRONMENTAL REQUIREMENTS

1. AIR QUALITY

1.1. Fugitive Dust & Odor Management

Vendor is responsible to take preventive measures with the operation of equipment to prevent fugitive dust emissions and/or a condition of air pollution including, but not limited to, malodorous conditions. Waste Harmonics reserves the right to suspend and/or terminate Vendor activities in the event fugitive dust or odors are causing a condition of air pollution, threat to human health or a public nuisance.

1.2. Noise Control

Vendor is responsible to take preventive measures with the operation of their equipment to prevent nuisance noise. Waste Harmonics reserves the right to suspend and/or terminate Vendor activities in the event noise levels are excessive. Town ordinances may dictate specific noise level limits.

1.3. Volatile Organic Compounds (VOCs)

All coatings, paints, and thinners used by the Vendor shall comply with the VOC requirements of the applicable air quality regulations. VOC monitoring is not required, unless otherwise specified.

2. LAND

2.1. Resource Protection

During any work, the Vendor shall prevent damage to land resources at the work site. The Vendor shall not destroy, remove, or cut trees or shrubs without prior permission of the site Owner.

2.2. Excavations

Vendors are responsible to inform Waste Harmonics and the site Owner prior to the excavation of any soil on the project property. Soil excavation includes activities such as boring, trenching, digging, grading or installation of groundwater monitoring wells.

Discovery of Contamination

Vendors who perform excavation activities on site Owner’s property not designated as a contaminated area must immediately cease excavation activities and notify Owner and Waste Harmonics whenever the following occurs:

Visual observation or odor of Oil or Hazardous Materials (OHM) in the soil, or analytical test results that indicate the presence of OHM in the soil.

Visual Observation of improper solid waste disposal.

Visual observation or odor of OHM in the groundwater, or analytical test results that indicate the presence of OHM in the groundwater.

2.3. Off-site Disposal of Excess Excavated Soil

For Projects where it is anticipated that excess excavated soils will not be able to be reused on-site, soil disposal is allowed only at approved facilities. Sampling of the excess excavated soil is required. Preferences should first be given to soil recycling (e.g., recycle oily soil via asphalt batching where allowed by law) as opposed to land filling. All soils that are transported upon public roadways must be covered to minimize fugitive dust, and, where necessary, truck tire and undercarriage washing shall be employed to minimize tracking soils onto public roadways.

3. WATER/WETLANDS

3.1. Resource Protection

During any project, all water/wetland resources shall be protected during work activities, including protection from construction debris (including asphalt, concrete, soil), the leaching of chemical pollutants, and work site erosion. Chemicals, fuels, oils, greases, bituminous materials, solids and concrete shall be stored and handled to prevent leaching or surface run-off into public waters. Work site run-off shall be controlled with hay bales, silt fences, berms, and settling basins, as directed by Waste Harmonics.

All dewatering operations shall conform to state and local permitting requirements.

3.2. Wetlands/Waterways Projects

Prior to scoping work associated with new construction or maintenance work for Waste Harmonics, the Vendor will be given copies of all pertinent Permits, Licenses, Certificates, Orders and other regulatory approvals associated with the project. Waste Harmonics Environmental Engineer or designee will assist the Vendor, as requested, in interpreting the Project’s environmental requirements after which it becomes the Vendor’s responsibility for full compliance. Restoration activities, as required by the permits or by Waste Harmonics, will be subject to Waste Harmonics inspection before the Vendor is released from the project.

The Vendor shall comply with the site Owner’s Best Management Practices (BMPs) at a minimum.

4. MATERIAL IDENTIFICATION, STORAGE AND MANAGEMENT

Prior to mobilization, the Vendor shall provide a Material Safety Data Sheet (MSDS) for each material to be used during any work. All chemicals must be approved for use by the Safety Department and the Environmental Department. The Vendor shall also provide Waste Harmonics with a list of anticipated waste types and quantities requiring disposal.

Products shall be stored in the original labeled containers at the work site and stored in a manner consistent with label directions and all applicable regulatory requirements to provide protection from accidental releases to the environment, fire or explosion. Use of cargo containers and/or bulk storage trailers must meet the approval of the Environmental Engineer. Storage locations may be limited due to site­specific requirements or procedures. At a minimum, all storage trailers or cargo containers shall be labeled on all accessible sides with an appropriate NFPA 704M hazard identification diamond, appropriate DOT markings or other hazard communication markings as required, emergency contact phone numbers and an identification number if more than one trailer or cargo container is used.

5. TRANSPORTATION OF WASTE

Only qualified hazardous waste transporters may transport hazardous waste. All waste labeling, packaging and transport shall be completed by the Vendor in accordance with all applicable Federal, state and local regulations and Waste Harmonics policies as set forth below. All waste labeling, packaging and transport documentation is subject to inspection and review by Waste Harmonics prior to removal from the work site.

Additionally, the Vendor is forbidden to transport or bring any hazardous waste that has been generated, released or encountered at off-site locations to the work site for any reason.

The transport of hazardous waste and PCBs may be prohibited on certain roads. It is the Vendor’s sole responsibility to identify and prohibit travel of these wastes on said roads. The scope of work may require the development of a site-specific transportation plan due to potential public impacts of local area roadways. If required, a satisfactory plan shall be developed and submitted for approval.

6. DISPOSAL

Unless otherwise stated, the Vendor will work with Waste Harmonics and the site Owner to characterize all work-related wastes, except unintended Vendor-generated wastes, to ensure proper on-site management and shall arrange for disposal in accordance with Federal, state and local regulations. Waste Harmonics shall be identified as the generator of the waste, unless the Environmental Engineer determines otherwise. All hazardous waste manifests shall be reviewed and signed by Waste Harmonics or Owner’s Agent.

All hazardous wastes and scrap metals shall be disposed of at an Waste Harmonics approved waste disposal facility.

Vendor shall provide copies of all hazardous waste manifests, bills of lading, and/or certificates of disposal, as appropriate to Waste Harmonics immediately upon receipt by the Vendor.

All unused chemical (non-waste) products originally brought to the property by the Vendor shall remain the responsibility of the Vendor and shall be removed by the Vendor at the conclusion of the Vendor’s onsite activities.

7. TRAINING

All Vendor employees who handle, transport or in any way manage hazardous wastes, substances or PCBs, or participate in the cleanup of hazardous substance releases are required to be trained in accordance with Federal, state and local hazardous waste and OSHA requirements.

8. SPILL PREVENTION

The Vendor shall conduct all activities in a manner that will prevent a release to the environment. Spill prevention measures, including maintaining spill control materials at the job site, shall be required based on the types, quantities, and locations of material stored. Documented inspections of storage areas by the Vendor may also be required.

9. RELEASE RESPONSE AND NOTIFICATION REQUIREMENTS

The Vendor shall immediately notify Waste Harmonics of any release of any quantity of oil or hazardous material.

For releases of oil or hazardous material owned by the Vendor (e.g., hydraulic fluid on a Vendor-owned vehicle), the Vendor is responsible to make all required notifications to regulatory agencies and to ensure that the release is properly handled. The Vendor is responsible for hiring Vendors for the cleanup of releases of Vendor-owned material. The Vendor may request assistance from Waste Harmonics in determining whether notifications are required and for guidance in response actions. If the Vendor does not respond appropriately, Waste Harmonics reserves the right to assume response actions and recover any costs incurred from the Vendor. For releases of oil or hazardous material identified by the Vendor (e.g., hydraulic oil from a damaged cylinder), Waste Harmonics expects to be immediately notified. It will be Waste Harmonics’ responsibility to arrange for the cleanup of these releases; however, the Waste Harmonics expects that the Vendor will assist, as necessary, in the initial assessment and containment of the spill or in other ways requested.

No response actions other than those necessary to remove personnel from the vicinity of the release and/or stop/minimize the release of the hazardous substance/waste shall be initiated until all necessary safety precautions have been taken, including but not limited to, securing the work site and donning of personal protective gear. The Vendor shall attempt to contain any spill using absorbent material or other available materials when possible to do so in a safe manner. Measures shall be taken to prevent the material from discharging to soil, drains, or waterways.

When a release occurs, the Vendor shall document all release response actions in writing. The Vendor may be requested to submit this information to Waste Harmonics within one working day after a release has occurred. However, verbal notification must be given to Waste Harmonics immediately after a release has occurred.

The Vendor may also be requested to supply Waste Harmonics with a copy of all other documentation required by regulatory agencies related to the release, including documentation of soil, water and solid surface clearance samples within five (5) days of receipt by the Vendor.

Spill cleanup debris, discarded protective equipment and other waste resulting from a release and cleanup by the Vendor shall be packaged and disposed of in accordance with all Department of Transportation requirements, and all Federal, state and local hazardous waste regulations by the Vendor.