Operating Policies & Procedures Manual. American Tower Corporation ATC REVISION HISTORY. REV Description of Change Author Effective Date

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1 merican Tower Corporation TC 1 of 6 REVISION HISTORY REV Description of Change uthor Effective Date 0 Initial Release S. Sandefur 12/18/12 PROCEDURE SIGN-OFF Role Process Owner (primary) Other (secondary) Director, Environmental Health and Safety Hazmat Specialist DOCUMENT DISTRIBUTION Function Role Process Owner Process Step Owner Others Hazmat Specialist Hazmat Coordinator Support Staff

2 merican Tower Corporation TC 2 of 6 REFERENCE DOCUMENTS Document Number Document Title 1 HMBP Tracker Documents referenced in this procedure are applicable to the extent specified herein. 1.0 TBLE OF CONTENTS Section Page 2.0 PURPOSE SCOPE DEFINITIONS PROCESS FLOW ROLES ND RESPONSIBILITIES PROCEDURE 4

3 merican Tower Corporation TC 3 of PURPOSE The purpose of this policy and procedure is to provide guidelines on how to be compliant based on State regulations in California that comply with Federal law. The Environmental Health and Safety Department must detect, research and record and track information pertaining to sites that qualify under EPCR reporting in California. The site information and details will be retained in the HMBP Tracker. 3.0 SCOPE The scope of the process details steps required for EPCR Compliance in California. It entails how to review site specific compliance related data and report on the amounts of hazardous materials. This requires the Environmental Health and Safety Department to provide the general location of the hazardous materials, the chemical name, estimate the maximum quantity on site, provide storage container information, and location of the facility on required HMBP documentation. 4.0 DEFINITIONS 4.1 TC merican Tower Corporation. 4.2 Hazmat Hazardous Material. 4.3 HMBP - Hazardous Materials Business Plan. 4.4 Compressed Gas Cylinder pressure vessel designed to hold compressed gas. 4.5 CUP Certified Unified Protection gency. 4.6 EPCR Emergency Planning and Community Right-to-Know ct. 4.7 Hazardous Material - ny substance that could potentially pose a real hazard to human health or the environment. Materials (including mixtures and solutions) subject to these guidelines can be classified as: explosives, toxic flammable gases, flammable liquids, flammable solids, oxidizing substances, toxic and infectious substances, radioactive material, corrosive substances, and other miscellaneous dangerous materials. 4.8 Site ny tower or building owned or managed by TC. 4.9 Toxic Capable of causing injury or death by poisoning TPQ Threshold Planning Quantities Uform Universal Form used to record tower site details.

4 merican Tower Corporation TC 4 of PROCESS FLOW N/ 6.0 ROLES ND RESPONSIBILITIES 6.1 Hazmat Specialist/Coordinator Responsible for the review of Uforms, determination of the TRQ, research of the CUP s and preparation of HMBP plans or certifications. lso responsible for obtaining supervisor s signature, doing a job dispatch and sending out s to field technician, mailing the HMBP plan to the CUP and field technician, and uploading copies to our shared drive. 6.2 Supervisor - Required to review and sign the HMBP Plan or Certification and provide it back to the Hazmat Specialist/Coordinator for scanning, uploading, copying and mailing. 7.0 PROCEDURE 7.1 New Reporting Review Uform and determine if the hazmat is over the California Threshold Planning Quantity (TPQ) for reporting: Flammable liquids 55 gallons Hazmat solid 500 pounds (total weight of battery) or 55 gallons electrolyte Compressed gases 200 cubic feet (6 gallons) 7.2 Review Hazardous Materials Business Plan (HMBP) tracker to determine if a site is already being reported on by a Certified Unified Participating gency (CUP) or Participating gency (P), and if there are any changes to hazmat, or if an annual certification is required Once a Uform has been processed, action must be taken within 30 days from the date of review On a newly reportable Uform, type HMBP Reportable and summarize the totals next to it along with the individual hazmat totals below Determine which CUP has jurisdiction and research the correct forms that need to be downloaded for completion.

5 merican Tower Corporation TC 5 of If no documents are found, then find a similar site in the same jurisdiction on the shared drive in the working files to work off their documents, or go to for standard HMBP documents Follow guidelines of the CUP for form completion Complete forms, save as PDF and upload to the site specific folder s working file. 7.3 Existing Reporting Review HMBP tracker for the current and following month to see what is coming up for renewal Look at the existing Uform on file If there is no Uform within 4-5 months that has been reviewed, then prepare a job dispatch ticket for the field technician to do a site visit If Uform has not changed, then type HMBP Compliant and summarize the totals next to it along with the individual hazmat totals below If a Uform s hazmat has changed less than 100%, type HMBP Compliant but upon next certification make the following changes: Then, List changed and individualize each hazmat If a Uform shows a change of 100% or greater in hazmat, type HMBP in place. Need to submit revised HMBP to reflect new inventory within 30 days. List individual totals next to each hazmat. 7.4 Documentation and Tracking Procedure Upload all working documents to the HMBP working files section on the shared drive in the site specific folders If fees are due to the CUP, prepare a check request Once all the forms involved in the HMBP are completed, have the supervisor review and sign off Scan and upload the HMBP to the HMBP Permit folder on the shared drive Make a copy of the HMBP and submit a copy to the field technician via ground FedEx.

6 merican Tower Corporation TC 6 of Send the field technician an with the attached HMBP and state that you have sent a copy via Fedex of the HMBP and to post a copy at the site. Mention that you will be doing a job dispatch ticket as well Open a job dispatch ticket and instruct the field technician to post the HMBP at the site Submit original HMBP to the CUP via FedEx ground If this is annual renewal certification, have it signed by the supervisor, scanned and uploaded to the shared drive, submit the original to the CUP via ground FedEx the field technician and CC Thomas Foulk and state to the field technician that he is to post the HMBP Certification at the site and that you will be preparing a job dispatch. There is no need to submit a copy via FedEx unless its requested by the field technician Review the HMBP Tracker to make sure the correct information is on the HMBP s tab Update the HMBP monthly recerts tab with the new date of the HMBP Certification or enter information if it s a new site Depending on the CUP requirements of annual certifications, place the site into the month that is 30 days prior to the date of the original HMBP certification.