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 5 REVISION HISTORY REV Description of Change uthor Effective Date 0 Initial Release S. Sandefur 06/05/12 PROCEDURE SIGN-OFF Role Process Owner (primary) Director, Environmental Health and Safety Other (secondary) DOCUMENT DISTRIBUTION Function Process Owner Process Step Owner Role Director, Environmental Health and Safety HazMat Specialist Others

2 merican Tower Corporation TC 2 of 5 REFERENCE DOCUMENTS Document Number Document Title 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 EPCR Reporting-Delaware Procedure is for internal merican Tower Corporation use only. It details the procedures for filing annual Tier II hazardous material inventory reports in the State of Delaware. 3.0 SCOPE The procedure applies to all TC sites subject to hazardous material reporting under the Emergency Planning and Community Right to Know ct. 4.0 DEFINITIONS 4.1 TC merican Tower Corporation. 4.2 EPCR Emergency Planning and Community Right to Know ct of lso known as Title III of the Superfund mendments Reauthorization ct. Federal regulation requiring owners/operators of hazardous materials in quantities equal to or exceeding the threshold planning quantity to report inventories annually to respective jurisdictions. 4.3 Hazmat Hazardous Materials. 4.4 LEPC Local Emergency Planning Committee. committee appointed by the State Emergency Response Commission (SERC). It develops emergency plans for Local Emergency Planning Districts, collects material safety data sheet (MSDS) forms and chemical release reports. It also provides this information to the public 4.5 MSDS Material Safety Data Sheet. document that contains information on the potential health effects of exposure to chemicals, or other potentially dangerous substances, and on safe working procedures users should adhere to when handling chemical products. 4.6 PO Purchase Order. 4.7 SERC - State Emergency Response Commission. n agency appointed by the Governor to oversee the administration of EPCR at the state level. The SERC designates and appoints members to LEPC and reviews emergency response plans for cities and counties 4.8 Tier II report or form containing the chemical name and common name of the hazardous materials; an estimate of the maximum amount of such chemical present at the facility during the preceding calendar year; a description on method of storage of the chemical; location of storage of the material in the facility and an indication whether owner wants the location information to be withheld from disclosure to public. The information obtained from Tier II forms are available to public from SERC and LEPCs.

4 merican Tower Corporation TC 4 of TPQ Threshold Planning Quantity. The specified quantity of hazardous materials in gallons and/or pounds required to be reported in the Tier II form. The TPQ varies by chemical. 5.0 PROCESS FLOW N/ 6.0 ROLES ND RESPONSIBILITIES 6.1 EH&S staff are responsible for: 7.0 PROCEDURE Calculating the quantity of hazardous materials stored at TC sites Determining the TPQ for those materials to ensure reporting is accurate Identifying the SERC, LEPCs and Fire Departments required for filing Tier II reports and forms Securing copies of relevant MSDSs Determining the cost of filings and securing checks for the amounts specified Filing Tier II reports in the timeframe specified by the SERC Retaining records of Tier II filings. 7.1 Determine if hazmat is over the Delaware Threshold Planning Quantities (TPQ) for reporting Delaware TPQs. 55 gallons flammable liquid located inside a building (e.g. diesel, gasoline). 55 gallons flammable liquid outside a building 55 gallons propane 55 gallons or 500 lbs, whichever is lower, corrosive liquids (sulfuric acid) 7.2 Check the National Tier II Tracker to determine if the site is already being reported. 7.3 If Tier II reporting is required, register the site for reporting using the Delaware Online Tier II Manager program. Provide the site name, number and address.

5 merican Tower Corporation TC 5 of Once confirmation of the site registration is received, proceed to Delaware Tier II Manager web site and log on to their electronic reporting page Use the log-in and password provided on the National Tier II Tracker to enter site specific information. 7.5 Prepare and submit the Tier II as required Delaware requires the MSDS sheet of the hazmat being reported as well as a site drawing depicting the location of the hazmat at the site. 7.6 When approval from Delaware Tier II Manager arrives, re-enter the program and print to PDF the electronic copies of the Tier II. 7.7 Print filing fee invoice Request a PO for the filing fee When PO is received on, request a quick check to pay fees Mail check and filing fee invoice to SERC when received. 7.8 Upload PDF copy of completed Tier II to EH&S Tier II Documentation folder on the Internal Shared drive. 7.9 Delaware SERC acts as the jurisdictional LEPC and Fire Department. Signed copies of the Tier II do not need to be mailed to LEPC or Fire Department Update the National Tier II Tracker with the date Tier II was filed with the SERC and any changes that are needed.