Exhibit_GG_-_EMS_Manual_2020.pdf

Environmental Management System (EMS) Manual

TRANSDEV SERVICES, INC

ENVIRONMENTAL MANAGEMENT

SYSTEM (EMS) MANUAL

PREPARED FOR:

TRANSDEV SERVICES INC.

720 Butterfield Road, Suite 300

Lombard, Illinois 60148

This manual was prepared for the sole use of the party noted. No part of this manual may be used, relied upon, or reproduced without the express written consent of TRANSDEV SERVICES, INC.

PREPARED BY:

Steve Kotel (10/20 revisions by Michael Olsen) Environmental Director Transdev Services, Inc.

Latest Revision:

October 2020

TABLE OF CONTENTS

EMS GUIDELINES

1.0 INTRODUCTION

1.1 Introduction 1-1

1.2 Commitment Statement 1-3

1.3 Our Charter for Sustainable Development 1-4

2.0 EMS STRUCTURE AND ELEMENTS

2.1 Environmental Policy 2-1

2.2 List of Significant Environmental Aspects and Impacts 2-2

2.3 Legal and Other Requirements 2-6

2.4 Objectives and Targets 2-7

2.5 Environmental Management Program 2-10

2.6 Structure and Responsibility 2-11

2.7 Training, Awareness, and Competence 2-13

2.8 Communication 2-15

2.9 EMS Documentation 2-16

2.10 Document Control 2-18

2.11 Operational Control 2-19

2.12 Emergency Preparedness and Response 2-21

2.13 Monitoring and Measurement 2-22

2.14 Nonconformance and Corrective and Preventive Action 2-27

2.15 Records 2-31

2.16 Environmental Management System Audit 2-32

2.17 Management Review 2-33

COMPLIANCE AND POLICIES

3.0 EMERGENCY PLANNING & COMMUNITY RIGHT-TO-KNOW ACT (EPCRA)

3.1 Federal Program 3-1

3.2 State Program 3-2

3.3 Tier II Reporting 3-3

3.4 Emergency Spill or Release Action Plan 3-11

Emergency Spill or Release Communications Protocol 3-13 Emergency Key Personnel Phone List 3-15 Emergency Spill or Release Report Form 3-16

4.0 EMPLOYEE RIGHT-TO-KNOW PROGRAM

4.1 Introduction 4-1

4.2 Written Hazard Communication Program 4-4

4.3 Health Effects 4-11

(Continued)

4.4 MSDSs/SDSs On-Line Platform 4-24

4.5 Hazardous Material Inventory Rosters 4-29

4.6 Overview of MSDSs/SDSs 4-32

4.7 Common MSDS/SDS Terms 4-38

4.8 Hazard Communication Training 4-46

5.0 HAZARDOUS WASTE MANAGEMENT (HAZMAT) PROGRAM

5.1 Introduction 5-1

5.2 Do I Generate Hazardous Wastes? 5-3

5.3 What is a Hazardous Waste? 5-4

5.4 What to do if you Generate Hazardous Waste 5-6

5.5 Generator Status 5-8

5.6 Managing Hazardous Wastes 5-9

5.7 Hazardous Waste Storage 5-23

5.8 EPA Notification 5-25

5.9 Manifests 5-26

5.10 Transporting Hazardous Wastes 5-28

5.11 Waste Reduction and Recycling 5-30

5.12 Reporting and Recordkeeping 5-31

5.13 Emergency Coordinators 5-32

5.14 Universal Hazardous Wastes 5-33

5.15 Hazmat Employee Training 5-35

6.0 CLEAN WATER MANAGEMENT PROGRAM

6.1 Storm water Regulations 6-1

6.2 Pollution Prevention Plan (SWP-3) 6-4

6.3 Spill Prevention Control and Countermeasure (SPCC) plan 6-19

6.4 POTWs & The National Pretreatment Program 6-23

6.5 Inspection & Maintenance of Oil/Water Separators 6-25

6.6 Managing In-Ground Automotive Lifts 6-27

7.0 CLEAN AIR MANAGEMENT PROGRAM

7.1 Introduction 7-1

7.2 Mobile Air Conditioning and Refrigeration 7-2

7.3 Parts Cleaning 7-8

7.4 Automotive Refinishing 7-9

7.5 Fuels, Refueling and Emissions 7-14

7.6 Alternate Fuels 7-18

8.0 STORAGE TANK PROGRAM

8.1 Introduction 8-1

8.2 Key Definitions 8-2

8.3 State Variations 8-3

8.4 Notification 8-3

8.5 Minimum Requirements 8-9

8.6 Leak Detection 8-12

8.7 Fuel Dispensing System Inspections 8-13

8.8 Release Detection 8-15

8.9 Investigation of Suspected Releases 8-16

8.10 Confirmed Releases 8-17

8.11 Initial Site Characterization 8-18

8.12 Soil and Groundwater Investigations 8-18

8.13 Corrective Action 8-19

8.14 Permanent and Temporary Closure 8-20

8.15 Tank Removal 8-21

8.16 Tank Disposal 8-22

8.17 Notification and Recordkeeping 8-22

8.18 Secondary Containment 8-23

8.19 Aboveground Storage Tanks 8-23

8.20 Financial Responsibility and Reimbursement 8-25

8.21 Fueling Procedures 8-27

8.22 Risk Management Plans (RMPs) 8-28

8.23 UST Operator Training Program 8-29

APPENDICES

Appendix A Organizational Charts Appendix B Internal Environmental Management System (EMS) ISO 14001 Audit Appendix C Environmental Facility Annual Compliance Audit

Environmental Compliance Audit Aspect Scoring Procedure Appendix D EPA ID Notification Instructions - Form 8700-23

REVISION HISTORY

Rev. Chapter Changes Made Date

0 N/A Initial Issue 09/92

0 N/A Records of revisions for the period 09/09 to 05/01 are no longer available -----

1 00, 02, 04, 07, 08 Revised cover page, CFR change, added EPCRA, added training chapter, word corrections, minor revisions 05/01

2 Entire manual Changed ATC/Vancom to ATC Transportation 11/01

3 00, 02, 04, 08, 09 Revised cover page, change of wording, added new form 8700-12, added

Facility Monthly Checklist, added annual compliance audit, changed appendices

11/02

4 05 SPCC Regulations amended on pages 5-19 to 5-21 in Chapter 5. 12/02

00, 01, 02, 03, 04, 05, 06, 07, Added Code of Federal Regulations numbers to chapters 01/03

6 08 Updated annual compliance audit, added monthly compliance audit checklist 02/03

7 05 More user friendly PPP form, added new A/C certification form on page 6-4 in

Chapter 6 12/03

8 00, 05 Revised cover page, updated SWP-3 model plan 02/04

9 App C Updated Preparedness and Prevention Plan 05/04

10 00, App D Revised cover page, added updated form 8700-12 06/04

11 00, 01, 02, 04, App D Changed Table of Content, removed spill & release notification form, added new section which included emergency spill & release phone list and report form, added form 8700-22 and instructions for 8700-12 06/05

12 Entire manual Changed ATC Transportation to Connex/ATC, added sustainable development in Chapter 1 09/05

13 01, App C, App D Added more on sustainable development, revised annual compliance audit 02/06

14 00, 04 Revised cover page, added EPA notification section, added updated form

8700-12 04/07

15 00, 02, 05 Revised cover page, minor revisions in chapter 2, added emergency spill or release communication protocol, moved employee training attendance sheets to end of chapter, updated SPCC deadline

06/07

16 00, 01 Revised cover page, added commitment statement 07/07

17 00, 05, 08, App D Revised cover page, changed Table of Content, added emergency generators, removed Chapter 8, removed Appendix D 09/07

18 00, 01, 04 Revised cover page, amended charter for S/D in Chapter 01, revised wording in Chapter 04 11/07

19 Manual front cover, spine New version showing Ginkgo leaf 12/07

20 00, 06 Revised cover page, updated EPA A/C equipment reporting form in Chapter 6 03/08

21 00, 01, 08, App B Revised cover page and Table of Content, Added measuring performance to chapter 1, added S/D performance measurements in Chapter 8, updated annual compliance audit

05/08

22 00, App B Revised cover page, updated annual compliance audit 03/09

Manual front cover and spine, 00, 01 Address change to cover and spine, revised cover page, added list of significant aspects and impacts to Chapter 1 06/09

24 00, 07 Revised cover page, change in table of content, updated Chapter 7 Table of

Content, added UST Operator Training section 07/09

25 Revised Entire Manual

Added new Veolia Transport Commitments in Chapter 1 and EMS Reinforcement letters from Henri Proglio and Cyrille du Peloux.

Added EMS Guidelines as Chapter 2 including all (17) ISO 14001 standards. Chapter 8 has been removed and incorporated into Chapter 2. Original Chapters 2 - 7 have been moved back one tab.

Added POTWs and The National Pretreatment Program to Chapter

6. Updated Form 2050-0068 in Chapter 8. Appendix A is now Organizational Charts. Appendix B is a new EMS Internal Audit Process. Appendix C is now Environmental Facility Annual Compliance Audit.

01/10

26 03 Added nation-wide 24 hour emergency spill response contractor and number on page 3-15 in Chapter 3.

04/10

27 00, 02, 04, 08

Updated cover page and Table of Content. In Chapter 2, updated the Table of Content, updated environmental policy on page 2-1, made change to persons responsible on page 2-11, added 2.9 – EMS Documentation pages 2-16 and 2-17, changed name of SME to EIS questionnaire on page 2-25. In Chapter 8, changed the requirement for obtaining an RMP.

07/10

28 00, 02 Updated cover page and Table of Content. In Chapter 2, added signature blocks for CEO and COO. 08/10

29 00, App A Updated revision history in Chapter 00, and updated Organizational Charts in Appendix A.

09/10

30 00, 02, 05

Updated cover page. Removed the word “Measurement” from 2.5 of the EMS Table of Content. Removed the word “Measurement” from

2.5 of the Table of Content in Chapter 2. Added signatures for CEO and COO on Environmental Policy on page 2-1. Revised 2.3 Legal And Other Requirements on page 2-6. Removed the word “Measurement” from Environmental Management Program Measurement on page 2-10. Added new updated Process Interaction Map on page 2-12. Added signature page for Management Review on page 2-39. Added sub-bullets for Universal Wastes in Chapter 5 - Table of Content.

11/10

00, 02, 07, 08, App C

Updated cover page. Made changes to Table of Content. Changed document box on page 2-5 in Chapter 2. Changed web site for Aarcher Institute on page 2-6 in Chapter 2. Removed Eco- Effectiveness Survey form pages 2-25 and 2-26 in Chapter 2.

Updated list of alternate refrigerant for bus and train air conditioning systems on page 7-5 in Chapter 7. Added new section (8.7) on fuel dispensing system inspections on pages 8-13 and 8-14 in Chapter

8. Updated Environmental Facility Compliance audit in Appendix C.

04/11

32 00, 02, App A, App D

Updated cover page. Made changes to Table of Content. Updated Page 2-40 in Chapter 2. Added statement about new EPA Form 8700-12 on page 5-25 in Chapter 5. Replaced old EPA Form 8700- 12 with new one on pages 05-25a to 05-25e in Chapter 5. Updated Veolia’s Organizational Charts in Appendix A. Added Appendix D – Instructions for EPA Form 8700-12.

06/12

Manual Front Cover, Spine & Back Cover, 00, 02, 04, 05, App A & C

Updated cover, spine and added back cover. Updated cover page.

Updated Table of Content. Updated Management Review page 2-

40. Added Globally Harmonized System (GHS) in Chapter 4.

Updated cover page for Chapter 5. Updated Appendix A - “Organizational Charts”, and C - “Environmental Facility Annual Compliance Audit” with updated 2013 version.

06/13

34 00, 04, 06, 07,08, App C

Updated cover page. Updated Table of Content. Clerical changes on page 4-32. Updated Chapter 6 – Table of Content. Added “amending SPCC plan” and page changes on pages 6-22 – 6-30.

Updated refrigerant recovery certification form 7610-31 on pages 7- 4 – 7-4b. Updated notification for USTs form 7530-1 on pages 8-4 – 8-8. Updated Appendix C – “Environmental Facility Annual Compliance Audit” with updated 2014 version.

06/14

35 Entire manual Changed Veolia Transportation to Transdev Services, Inc. 09/14

00,02,03,04,05,07,08, App A, C, & D

Updated Chapter 00, updated Chapter 02 Table of Content, replaced Tier II form with new one in Chapter 03, pages 3-10 to3- 10a, changed wording and phone number in Chapter 03, pages 3- 12 to 3-15, updated Chapter, 04 Table of Content, updated training materials in Chapter 04, pages 4-9 to 4-10, replaced MSDS request forms with MSDS on-line platform in Chapter 04, pages 4-25 to 4- 27, updated MSDS form in Chapter 04, page 4-32, updated SDS form in Chapter 04, pages 4-34 to 4-37, changed page numbers in Chapter 04, pages 4-38 to 4-49, updated EPA web-site in Chapter 05, page 5-25, updated EPA ID number notification form in Chapter 05, pages 5-25a to 5-25e, updated EPA refrigerant recovery form in Chapter 07, pages 7-4 to 7-4b, updated EPA UST notification form in Chapter 08, pages 8-4 to 8-8a, updated organizational charts in Appendix A, updated environmental compliance audit in Appendix C and updated EPA ID notification instructions in Appendix D.

03/16

37 00,02,03,05, App C & D

Updated Chapter 00, removed references to ECO questionnaire and added RODEO questionnaire in Chapter 02, misc. minor changes and updated EPA maximum fine in Chapter 03, updated EPA maximum fines and updated EPA form in Chapter 05, updated environmental compliance audit in Appendix C, replaced Appendix D with update instructions.

03/18

38 00,02,05

Updated Chapter 00, updated CEO signature in Chapter 01, page 1-3, updated CEO signature in Chapter 02, page 2-1, added new revision box in Chapter 02, page 2-3, changed wording in Chapter 02, page 2- 14, replaced conditionally exempt generator with very small quantity generator wording in Chapter 05, page 5-8, replaced old EPA form 8700 with new one in Chapter 05, pages 5-27 and 5-27a.

06/19

00, 01, 02, 03 Updated chapter 00 for revision date and who prepared, Updated CEO Signature in Chapter 1 and 2, Updated emergency contact info in Pages 3-15 and 3-16.

10/20

Transdev Services, Inc. Revised 10/20

TRANSDEV SERVICES, INC.

ENVIRONMENTAL MANAGEMENT

SYSTEM (EMS) MANUAL

CHAPTER 1

INTRODUCTION

(ISO 14001)

1.1 INTRODUCTION

The purpose of this Environmental Management System (EMS) manual is to provide the foundational elements and basic structure as found in an ISO 14001 Standard application for the establishment, implementation, and maintenance of an EMS. It provides Managers of Transdev Services, Inc. facilities, a practical action plan and a starting reference of the environmental rules, regulations, compliance, and Sustainable Development guidelines governing their operation. An EMS will only be effective as it is further developed and implemented at the local level and with specific operations and circumstances in mind.

The following provides a brief introduction to a few of the foundational elements, specific applications, and basic questions that discuss an EMS and the fundamental motivations for having one in place:

What is an Environmental Management System (EMS)?

o An EMS is a structured process that helps us to continuously improve our environmental program.

Why are we implementing an EMS?

o Using an EMS approach helps to ensure that we are following our environmental requirements, assists us in the protection of the surrounding environment and, takes these environmental policies and procedures, organizing them into an ISO format. Furthermore, an EMS or ISO 14001certification may be required by some of our customers or clients in the future.

What are some of the benefits of an EMS?

o Reduces risk, improves our public image, reduces cost, and improves competitiveness through:

PIC: Prevention, Improvement, Compliance

Prevent pollution and promote resource efficiency.

Improve continually in our environmental performance through communication, employee engagement, and planning

Comply with all applicable laws and other requirements to which the organization subscribes

How do we communicate information about the EMS?

o All employees need to know we have an EMS and why we are implementing it.

o If employees have questions or concerns they need to let their supervisor, manager, or corporate environmental staff know.

1-1 o Facility employees should not communicate with the media or external parties about the EMS; forward all inquiries to your supervisor, or corporate environmental and marketing/communications personnel.

o If you find non-conformity with the EMS let your supervisor, manager, or corporate environmental personnel know.

What are significant aspects and operational controls?

o Significant aspects are those activities that we take part in that could have a very serious impact on the environment. A scoring system was used to determine what activities are significant.

o An operational control is anything we have in place to prevent the significant aspect from occurring… such as standard operating procedures. Those who work with significant aspects need to understand what could happen if they deviate from those operational controls.

What is the purpose and importance of the internal EMS audit and the third party audit?

o The intent of the internal EMS audit is to ensure that we are doing what we say we are doing and adhering to the EMS. The internal EMS identifies non-conformances so that we can continuously improve our EMS. The third party audit is crucial because it determines if we are in accordance with ISO and can be ISO 14001 certified. The internal EMS audit prepares us for the third party audit.

It is vitally important to remember that, in regard to compliance, this manual covers only the highlights of the rules. It is not within the scope of this manual to provide every potential legal, technical and regulatory issue arising out of complex and rapidly changing local, state and federal environmental rules and polices. As such, the [compliance-specific] contents of this manual are based on federal regulations. State and local rules may differ and may be more stringent than federal rules. In all cases, state and local regulations must take precedence.

[When in doubt, managers should seek the advice of Transdev services, Inc. Director of Environmental Services, the state and local environmental agency, a qualified attorney, or consultant for a given situation.]

1-2

1.2 COMMITMENT STATEMENT

On behalf of Transdev Services, Inc., I want to express our commitment to the principles of Sustainable Development. In short, that means, “meeting the needs of the present without compromising the ability of future generations to meet their own needs.”

As an organization, our goal is to increase revenue through the practical application of these principles. We must do this with practices that demonstrate good environmental stewardship. Our corporate management believes in this strongly and holds us accountable to provide transportation in a manner that improves the world in which we live.

The Environmental Management System (EMS) is one tool that reflects and supports the policies and procedures that make up a Sustainability Development approach. It is, in effect, an Action Plan by which we perform our day-to-day activities.

However, our investment in Sustainable Development is more than a manual or series of documents - it is the creation of an attitude, a culture, and a process of continual improvement. Every Transdev employee has a role to play from myself up to the men and women who drive, maintain, and manage our services. Every member of the Transdev team can and must have a positive impact on delivering the Sustainable Development vision. Our children and our grandchildren depend on us to do the right thing to protect the earth. Even the biggest detractors now admit the reality of global warming and the urgency to act now.

By its very nature, public transportation is consistent with Sustainable Development.

For us, we live it in our day-to-day supply of buses, vans, taxis, and trains, in the practices we follow to maintain our vehicles and our facilities, in our support for the communities in which we live and work and in our ongoing effort to innovate through research and development.

I look forward to joining with you in these pursuits. Together with you, it is our goal to be the leaders in assuring a healthy, nurturing world in which to bring our children.

Sincerely, 1-3

1.3 OUR CHARTER FOR SUSTAINABLE DEVELOPMENT

At Transdev Services, Inc., we provide our clients with tailor-made solutions to the problems they face in the area of transportation. In doing so, Transdev Services, Inc. is responding to the profound changes affecting the modern world: urban expansion, more stringent environmental standards and the increasing recourse to public-private partnerships.

These changes offer the company new opportunities but also new challenges. In particular, we at Transdev Services, Inc. must assert our leadership in Sustainable Development in the years to come, which in turn will require us to come up with innovative solutions to manage the impact of our activities. We believe that what is now an option will become an urgent necessity in the future. And we need to prepare for that time, and better, anticipate it.

Our principles and organization testify to our commitment to and awareness of our responsibilities. Governed by our Transdev Charter and our values, the scope of our action, the rules which structure our organization in terms of corporate governance, business ethics, and dialogue with stakeholders and risk management, are all in line with our determination to develop sustainability.

Transdev Services, Inc. Commitments

Fight Climate Change by proving the environmental performance of public transportation using the Transdev “Eco-Efficient Travel™” calculator.

Measure and Control the environmental impacts of our activities using our Environmental Management System and reduce the usage of fossil fuels.

Offer High Quality Service based on a customer-centric, forward-thinking and cost-effective approach.

Educate and Inform about the environmental benefits of sustainable mobility, the preservation of resources and “eco-friendly actions.”

Ensure Everyone’s Safety, contribute to improved public health, and ensure the health and safety of our employees in the workplace.

Maintain a recruitment and human resources policy based on diversity, equality and personal development.

Be a Local Actor and serve communities by understanding and implementing local specificities and dynamics.

Establish an open and transparent dialogue with our partners in order to continually improve our objectives and action plans.

1-4

Driven by a Core Promise and our Values

We will grow into being seen as an admired leader in our industry because we will live, by example, the values that make us unique. Our values are summarized in our core promise, “We Care.” The ring that is part of our logo represents our care, commitment and trustworthiness.

“WE CARE”

CUSTOMERS (Courtesy, patience, safety, best service, top performance).

ACCOUNTABILITY (Do the right thing. Keep promises, build trust, insist on high standards)

RESPECT (Listen, value diversity of people & ideas. Disagree, but respectively.

Build teamwork.)

EMPLOYEES (Empower people to make decisions & promises. Discuss issues openly. Implement Solutions. Be creative.)

1-5

ENVIRONMENTAL MANAGEMENT

SYSTEM (EMS) MANUAL

CHAPTER 2

EMS STRUCTURE & ELEMENTS

(ISO 14001)

2.1 ENVIRONMENTAL POLICY……………………………………………….….. 2-1

2.2 LIST OF SIGNIFICANT ENVIRONMENTAL ASPECTS AND IMPACTS.....2-2

2.3 LEGAL AND OTHER REQUIREMENTS………………………………..……. 2-6

2.4 OBJECTIVES AND TARGETS……………………………………………..…. 2-7

2.5 ENVIRONMENTAL MANAGEMENT PROGRAM …………………….......... 2-10

2.6 STRUCTURE AND RESPONSIBILITY……………………………………….. 2-11

2.7 TRAINING, AWARENESS, AND COMPETENCE………………………….. 2-13

2.8 COMMUNICATION……………………………….. ………………….……….. 2-15

2.9 EMS DOCUMENTATION.……………..…………………………………..……2-16

2.10 DOCUMENT CONTROL……………. ………………………………………… 2-18

2.11 OPERATIONAL CONTROL……………………… …………………….......... 2-19

2.12 EMERGENCY PREPAREDNESS AND RESPONSE..…………………….. 2-21

2.13 MONITORING AND MEASUREMENT………. ………………………….……2-22

2.14 NONCONFORMANCE AND CORRECTIVE & PREVENTIVE ACTION.…..2-27

2.15 RECORDS……… ………………………………………………………………. 2-31

2.16 ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT……………………... 2-32

2.17 MANAGEMENT REVIEW…….. ………………………………………………. 2-33

2.1 ENVIRONMENTAL POLICY

(ISO 14001 4.2)

This policy statement describes the Transdev Services, Inc. Environmental Policy. All our employees are responsible for incorporating the actions necessary to fulfill this commitment.

Transdev Services, Inc.:

Is strongly committed to providing safe, efficient and innovative transportation solutions while maintaining a clean environment, preventing pollution, minimizing waste generation, and preserving our natural resources.

Strives to continuously improve environmental practices with the goal of meeting or exceeding all environmental regulatory requirements and demonstrating a deep commitment to the principles of sustainable development.

Seeks to empower each employee through ongoing training and communications, and will solicit employee and public input in the promotion of the highest level of environmental stewardship and sustainable development.

Is committed to minimizing significant environmental impacts identified in the Environmental Management System (EMS) by setting environmental objectives and continually evaluating our progress in meeting those objectives.

The execution and accomplishment of these commitments calls for an individual, as well as collective effort on the part of all department employees. Therefore, the management, in keeping with this policy and under the leadership of the local General Manager promotes the spirit of cooperation and will provide the necessary support in the establishment of locally targeted and specific goals and programs which protect the community and the environment for future generations.

This environmental policy will be reviewed and communicated annually to all employees and available to the public on request.

2-1

2.2 LIST OF SIGNIFICANT ASPECTS AND IMPACTS

(ISO 14001 4.3.1)

Identifying and prioritizing environmental aspects and impacts are the most critical steps in developing and maintaining an EMS. Specifically, the assessment of Transdev’s environmental aspects and impacts provides the foundation upon which the environmental policy and key parts of the EMS are built. The significant aspects that have been identified and addressed become the driving force for several EMS requirements such as objectives and targets, operational controls, and competency determinations for both employees and other personnel who work either for or on behalf of the organization. The outcome has formed the basis for planning, programs, processes, monitoring and measurement for Transdev Services, Inc.’s operations.

Transdev Services, Inc. has established and will maintain procedures to identify the environmental aspects of its activities and services that it can control, and over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment. Transdev Services, Inc. shall ensure that the aspects related to these significant impacts are considered in setting its environmental objectives.

Process

The Environmental Team working together with the Regional Directors of Maintenance will develop the list of aspects and impacts.

All activities, functions, products and services performed by the entity shall be identified. For each activity, function, product or service identified, a list of aspects associated with them will be developed.

The list of aspects will then be evaluated to identify impacts that the aspects could have on the environment.

The inventory of aspects/impacts is evaluated using the following significant risk criteria and giving a rating of 1 to 5, with 1 having the least impact and 5 having the highest impact:

o Business Impact o Degree of Impact o Legal and Regulatory Requirements

Each of the aspects will then be individually rated using the above criteria.

These ratings are added and the total is recorded for each aspect/impact. This number is the total score of the aspect/impact.

The Environmental Team will determine what minimal rating will be used to identify an aspect/impact as significant.

The Ratings* box on the table is labeled “S” for significant or “NS” for non-significant for each aspect/impact with a total score that exceeds the significant threshold of 11.

2-2

The Environmental Team will reassess the list of aspects annually to make any necessary modifications and to reflect any changes to operations.

REVISION HISTORY

Rev. Chapter/Pages Changed Changes Made Date

0 N/A Initial Issue of Document 2004

01 N/A Changed document from Connex to Veolia Transportation, Inc. 09/05

02 N/A Changed aspects to reflect sections in the Environmental Compliance Audit 08/09

03 Chapter 02 Chapters 2–7 became Chapters 3-8. Added ISO Standards including List of

Significant Aspects and Impacts to new Chapter 2. Added Environmental Compliance Audit section numbers to aspects.

01/10

04 Chapter 02 Changed Veolia Transportation to Transdev Services, Inc. 09/14

05 Chapter 02 Removed references to ECO questionnaire and added RODEO questionnaire. 03/18

06 Chapter 02 Updated CEO signature 06/19

2-3

Transdev Services, Inc. Revised 09/14

LIST OF SIGNIFICANT ASPECTS AND IMPACTS

(and method for identifying site-specific impacts)

The significant aspects and impacts at Transdev Services, Inc. are presented in the table below. In the Activities box, the numbers in parenthesis match Section numbers in the Facility Compliance Audit.

Site-specific aspects and impacts can be identified in the table below.

Activities Environmental Aspects Impacts Rating*

Fuel Storage (03 & 04)

Spills/Releases (05 & 06)

In ground Hydraulic Lifts (07)

Waste Water Discharges (08)

Vehicle/Engine Washing (09)

Storm Water (10)

Parts Cleaning (11)

Used Oils and Filters (12 & 13)

Used Antifreeze (14)

Fueling Vehicles & Storage (15)

Vehicle Painting (16)

Used Batteries (17)

Used Drum Storage (18)

Scrap Tires (19)

Air Emissions (20)

Vehicle Air Conditioning (20)

Vehicle Operation in Shop/Road (20)

Tank leak/infiltration Odor Emissions Leaks/evaporation during filling

Spills/releases to environment

Leaks from pistons/lines

Spill/releases discharged to public sanitary system

Wash water & detergents

Contaminants leaching into storm water discharges

Solvent spill/release to drains

Waste fluids Used filters

Waste fluids

Evaporation and leaks/releases during handling and fueling

Paint wastes Battery acid Contaminated rain water Scrap tires

Tailpipe emissions

Energy consumption Polluting emissions

Polluting emissions during operation of vehicle

Ground pollution Air pollution Water pollution

Ground/water pollution

Ground/water pollution

Water pollution

Ground/water pollution

Water pollution

Water pollution

Ground/water pollution Ground/water pollution

Ground/water pollution

Air/ground/water pollution

Air/ground pollution

Ground/water pollution

Ground/water pollution

Mosquito breeding ground Fire hazard

Air pollution

Natural resource depletion & Air pollution

Air pollution

S

S

NS

NS

NS

S

NS

NS

NS

S

NS

NS

NS

NS

NS

NS

NS

2-4

Transdev Services, Inc. Revised 09/14

Activities Environmental Aspects Impacts Risk

Hazardous Waste (21 &23)

Solid Waste (22)

Compressor (24)

Office Materials & Equipment (24)

Site Heating/Cooling/Ventilation (24)

Employee Training (25)

Site - Shops and Offices (26)

Hazardous waste disposal

Garbage disposal

Noise

Waste produced

Energy consumption Polluting emissions

Failure to do training may result in:

* Excessive energy consumption during operation

* Pollution emissions

* Handling hazardous materials spill/releases

Energy consumption Spills/releases Waste produced Wash water & detergents

Air/water/ground pollution

Water pollution

Noise nuisance

Air/ground pollution

Natural resource depletion & Air pollution

Natural resource depletion

Air pollution Ground/water pollution Ground/water pollution

Natural resource depletion Air/ground/water pollution Air/ground/water pollution Water pollution

S

NS

NS

NS

NS

NS

NS

* S = Significant

* NS = Non-Significant

2-5

Transdev Services, Inc. Revised 03/18

2.3 LEGAL AND OTHER REQUIREMENTS

(ISO 14001 4.3.2)

Transdev Services, Inc. has established and will maintain a procedure to identify and have access to legal and other requirements to which the organization subscribes, that are applicable to the environmental aspects of its activities and services. The Environmental Team will ensure that the most federal up-to-date information is available to all relevant employees. The Environmental Team will ensure that the applicable legal and other requirements are considered in establishing and maintaining the EMS.

The Environmental Team of Transdev Services, Inc. identifies federal legal and regulatory requirements from a variety of sources that include:

Monthly newsletters from several well recognized publishing groups who provide authoritative analysis of laws and regulations pertaining to transportation operations.

Annual regulatory training from an accredited environmental training and consulting company.

Environmental regulatory information provided by industry professionals in the course of due diligence, activities, and specific regulatory applications.

Review of regulatory agencies’ web-site updates.

Resources

Federal Environmental Laws – the following includes primary environmental laws:

o Clean Air Act (CAA) - [40 CFR Parts 100-145, 220-232, 410-471] o Clean Water Act (CWA) - [40CFR Parts 100-145, 220-232, 410-471] o Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) – [40 CFR Parts

150-189] o Resource Conservation and Recovery Act (RCRA) – [40 CFR Parts 240-299] o Toxic Substances Control Act (TSCA) – [40 CFR Parts 700-799] o Comprehensive Environmental Response, Compensation and Liability Act

(CERCLA) – [40 CFR Parts 300-311] o Emergency Planning and Community Right-to-Know Act (EPCRA) – [40 CFR

Parts 350-374] o Hazardous Materials Transportation Act (HMTA) – [40 CFR Parts 100-180] o Underground Storage Tank Program (UST) – [40 CFR Part 280] o Oil Pollution and Prevention Act (OPA 90)

Internet Resources – The following list are primary internet resources for obtaining environmental regulatory laws and regulations:

o Thompson Publishing Group www.thompson.com o Aarcher Institute www.aarcherinstitute.com o U.S. Environmental Protection Agency www.epa.com o Department of Transportation www.dot.gov

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2.4 OBJECTIVES AND TARGETS

(ISO 14001 4.3.3)

Transdev Services, Inc. has established and will maintain documented environmental objectives and targets, at each relevant function and level within the organization.

Transdev Services, Inc. has considered the legal and other requirements, its significant environmental aspects, its technological options, its financial and business requirements, and the views of interested parties. Our objectives and targets are consistent with the environmental policy, including the commitment to the prevention of pollution.

Maintaining public health by reducing noise and air pollution, avoiding the depletion of non-renewable energy resources and reducing road congestion are all major challenges facing public authorities worldwide with respect to daily public transport and the movement of goods that accompany social, economic and cultural life.

Public transport is, in and of itself, a solution to wasted energy and the deterioration of the quality of air caused by the increase in motor traffic in and around towns. Transdev Services, Inc. is also increasingly involved in improving people’s surroundings and protecting the environment with ambitious objectives regarding the reduction of its fleet’s pollution emissions.

The use of alternatives fuel, the improvement of engine and exhaust system maintenance, the use of particulate traps, and new engine design are just some of the technologies implemented by Transdev Services, Inc. as part of its environmental objectives and targets.

Reduce Atmospheric Pollution:

Reducing consumption (improving combustion, electronic fuel injection, and fuel saving devices).

Reducing exhaust emissions: nitrogen oxides, un-burnt hydrocarbons, carbon monoxide, and soot.

Reducing vehicle idling time by following EPA guidelines pertaining to state anti-idling regulations in cold climates as well as the use of overhead canopies and sun shades to reduce the amount of time necessary to cool vehicles in warm climates.

Using water-soluble, and/or low VOC paints that have VOC levels as low as 2.8 pounds per gallon for topcoats and even lower levels for primers. (VOC levels found in a typical paint system is 5.5 or higher).

Using non-solvent parts washing systems, or covering solvent baths when not in use, and locating solvent baths in cooler areas to avoid evaporation.

Reducing the Greenhouse Effect

Reduce carbon gas emissions by:

o Good maintenance practices (i.e. engine tune-ups, re-flashing, particulate traps, etc.).

2-7 o Use of alternative fuels such as reformulated gasoline, ultra low-sulfur diesel, Liquid Natural Gas (LNG), Compressed Natural Gas (CNG), propane, biodiesel, electricity, and others including hybrid applications.

o Approved modification and/or replacement of old fleets, engines, and exhaust systems.

Prohibiting venting of CFC refrigerants to the atmosphere.

Noise Reduction:

Coordinate with the Safety department to measure noise sources around the facility.

Reducing noise pollution by improving engine performance, replacing of faulty exhaust systems, ensuring proper tire maintenance and upgrading to aerodynamic vehicles.

Reducing the Quantity of Waste:

Recycling of paper, cardboard, plastic bottles, cans, printer cartridges, electronics, etc.

generated from all office and shop operations.

Recycling of all CFC refrigerants.

Cleaning of mechanical parts with solvents free from chlorine derivatives, and using solvent baths that do not require solvent replacement.

Increasing oil change intervals by use of new synthetic oils.

Reducing electronic waste by maintaining and keeping equipment for longer periods of time.

Utilizing EPA’s programs such as “Plug-In-To E-cycling” program which, recycles used or unwanted cell phones and computers, and ENERGY STAR® which, encourages switching to electrical products that have earned the ENERGY STAR® label to save energy and protect the environment.

Administrative and Regulatory Compliance Checks of All Sites:

Completing an annual environmental [scored] audit of 100% of all sites.

Random site assessments to evaluate compliance of the facility.

Use of an internal newsletter that informs Transdev Services, Inc. personnel and clients of current environmental regulations, compliance, and Sustainable Development issues

Respect for the Environment Also Means Involving All the Company's Personnel

Reinforce environmental training by:

o Implementing and deploying a comprehensive environmentally-friendly driving course for all driving personnel.

2-8 o Annual comprehensive in-depth environmental “Train-the-Trainer” training for all Shop Managers of Transdev Services, Inc..

o Use of the Intranet which contains resources, training materials, newsletters, contacts, etc.

Encouraging employee car-pooling.

Continuous improvement through:

o Employee suggestions o Best Management Practice submission and dissemination

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2.5 ENVIRONMENTAL MANAGEMENT PROGRAM

(ISO 14001 4.3.4)

Transdev Services, Inc. has established and will maintain programs and procedures for periodic environmental management systems audits to be carried out, in order to:

Determine whether or not the environmental management system:

o Conforms to planned arrangements for environmental management including the requirements of the ISO 14001; and o Has been properly implemented and maintained

Provide information on the results of audits to management.

Transdev Services, Inc.’s Environmental Management Program (EMP) integrates existing organizational structures such as financial management, purchasing, legal, operational, and management information systems by:

Utilizing employee input wherever possible.

Communicating the expectations of the EMS and EMP along with the responsibilities to those individuals who can affect environmental aspects.

Constructing the EMP based on current programs and management structures wherever possible, assuming that existing programs are sound and financially efficient.

Including health and safety programs; and

Continually reevaluating Transdev Services, Inc.’s action plans when changes occur in procedures or facilities.

In instances where existing management structures are not adequate to achieve the Targets and Objectives set for the EMS, new structures will be developed. These new structures will be developed with input from those responsible for the function area in question.

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2.6 STRUCTURE AND RESPONSIBILTY

(ISO 14001 4.4.1)

Transdev Services, Inc. has defined, documented and communicated roles and responsibilities in order to facilitate environmental management. For an EMS to be effective, individual roles and responsibilities must clearly be defined and communicated as they relate to the achievement of environmental Objectives and Targets, and overall operation of the EMS. Top management will supply the necessary resources, both financial and staff, to ensure that the EMS is effectively implemented.

Key personnel are identified as follows (see also Appendix A for entire organizational structure):

Environmental Responsibilities Person(s) Responsible

Establish Overall Direction Executive Leadership, CEO, COO

Monitor Overall EMS Performance Chief Safety & Quality Officer (Management Representative)

Develop Environmental Policy Environmental Director

Develop Environmental Objectives, Targets and Programs

Environmental Director

Assure Regulatory Compliance (External) Senior Operating Manager

Ensure EMS Compliance (Internal) Regional Directors of Maintenance All General Managers

Ensure Continual Improvement All General Managers

Identify Customers Expectations Sales and Marketing Staff

Develop and Maintain Accounting Procedures Finance/Accounting Managers

Comply with Defined Procedures All Staff

In addition to the above, it is required by Transdev Services, Inc. that two employees are designated at each facility as a Primary and Secondary Environmental Coordinator. (The Primary Environmental Coordinator as directed by company policy will be the responsibility of the local Maintenance Manager). These employees have the responsibility for recordkeeping, reporting, notification and emergency response as well as assisting in training functions.

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2.7 TRAINING, AWARENESS AND COMPETENCE

(ISO 14001 4.4.2)

Transdev Services, Inc. has identified training needs. It requires that all personnel, whose work may create a significant impact on the environment, have received appropriate training.

Transdev Services, Inc. maintains procedures to make its employees at each function and level aware of:

The importance of conformance with the environmental policy and procedures and with the requirements of the environmental management system;

The significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance;

Their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the environmental management system, including emergency preparedness and response requirements;

The potential consequences of departure from specific operating procedures.

Personnel performing the tasks which can cause significant environmental impacts will be competent on the basis of appropriate education, training and/or experience.

Management has an essential role in developing organizational awareness and motivation by expressing and explaining environmental Policy and demonstrating our commitment to it. This commitment of individuals and resources to the goals outlined in the environmental Policy, Objectives and Targets, is the event that brings our EMS to life.

Training is important for two reasons:

Employee action will have an impact on the environment.

Employees are a useful resource for generating ideas about establishing operational control for a process, defining environmental aspects, or defining structural responsibilities.

Staff members are trained in their specific environmental responsibilities that are directly related to Significant Aspects, Objectives and Targets in the EMS. New hires and re-assigned staff members are given appropriate training on the specific aspects of their new position, the equipment they will be expected to operate, its impacts on the environment and expected methods of operation. Employees will need to be kept abreast of regulatory changes that impact their job performance. Environmental Train-the-Trainer program for management and their operations staff has been developed to ensure this continuing education. See required training requirements in Figure 1.

The Director of Environmental Services with direction of the Management Representative will be responsible for the establishment of training requirements for Transdev Services, Inc. facilities, in keeping with corporate policy and regulatory requirements.

2-13

Figure 1

Training Programs Training

Requirements Regulations Staff Attendees

Emergency Planning & Community Right-to-Know Act (EPCRA)

Annually 40 CFR, Part 370-372 Shop

Employee Right-to-Know Program Annually 29 CFR, Part 1910.1200 Shop

Office personnel

Hazardous Waste Management (Hazmat) Annually 40 CFR, Parts 260-262 Shop

Clean Water Management Program Semi Annually

Annually 40 CFR, Parts 112, 122-124

Shop Fuelers

Clean Air Management Program Annually 40 CFR, Parts 52, 53-86 Shop

Storage Tank Program Annually 40 CFR. Part 280 Shop

Fuelers

Training shall be accomplished by means of:

• Annual distribution of a Train-the-Trainer program

• MS TEAMS based Train-the-Trainer program Power Point presentation/s

• As requested for various conferences and meetings

• On case-by-case basis during site visits

• Newsletters and other environmental literature.

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2.8 COMMUNICATION

(ISO 14001 4.4.3)

Transdev Services, Inc.’s EMS includes the communication of internal and external environmental information to management, and from management to others of our activities regarding environmental impacts. Communication includes procedures for internal reporting as well as external reporting on environmental activities of the organization.

It is important to note that this section refers to internal and external communication that is related to the environmental aspects and the Environmental Management System (EMS).

External communication is communication between our organization and an interested party outside the facility (e.g. EPA, environmental organizations, adjacent facilities or residents).

It is the responsibility of the environmental and marketing departments to gather, generate, and communicate environmental information to all effected and interested internal and external parties. Establishing and maintaining communications will:

1. Raise awareness of Transdev Services, Inc.’s environmental Policy, Objectives and Targets, and EMS.

2. Receive, document, and respond to environmental questions, concerns, and suggestions that come from employees.

The methods by which internal and external communications are communicated include, but are not limited to:

Internal communications o Spill Prevention Control and Countermeasure (SPCC) plans o Going for Green program o Need to Know and Balance Newsletters o Advantage Series o Sustainable Development Kits o Auditing / Questionnaires

External communications o Tier II Reporting o Stormwater Pollution Prevention Plans (SWP-3) o Greenhouse gas reporting (CCCR) o Spill Prevention Control and Countermeasure (SPCC) plans o EPA hazardous waste manifests o Spill or release reports

2-15

2.9 EMS DOCUMENTATION

(ISO 14001 4.4.4)

The purpose of this procedure is to describe the process and requirements of creating and maintaining the documents directly related to the Environmental Management System (EMS).

Transdev Services, Inc. has established and will maintain documentation of all programs for achieving its objectives and targets. It shall include:

Designation of responsibility for achieving objectives and targets at each relevant function and level of the organization;

The means and time frame by which they are to be achieved.

It is the responsibility of the Environmental Team to prepare all EMS documents, review them annually with the Management Representative and then submit them to the Executive Management for final approval.

If a project relates to new developments and new or modified activities, products or services, program(s) shall be amended where relevant to ensure that environmental management applies to such projects.

Once Transdev Services, Inc. establishes its environmental Objectives and Targets, then planning begins to develop an Environmental Management Program (EMP) for achieving them at all levels. This program can then be integrated into the existing EMP at a facility level, and should be tied into the overall strategic plan of the organization. Issues such as scheduling, resource allocation, and individual responsibilities should be included in the program to allow for the successful achievement of the Objectives and Targets.

The program develops specific actions, in order of priority, dealing with processes, products, and services that relate to the already established environmental Significant Aspects, Objectives and Targets. The actions must be included in the documentation of the program so that crucial operational practices and responsibilities are reviewed, revised, and redeployed regularly.

The EMP shall incorporate existing organizational structures such as financial management, purchasing, legal, operations, maintenance, risk/safety, and management information systems structures.

EMP monitoring is primarily the responsibility of the Environmental Team. The Environmental Team will routinely report to the Management Representative the status of any and all environmental programs and projects under their respective control.

The Environmental Management Plan shall consist of (as applicable but not limited to) the following documents:

EMS Manual o EMS Guidelines o Compliance and Policies o Appendix A – Organizational Charts

2-16 o Appendix B – EMS Procedure Audit o Appendix C – Compliance Audit

The Advantage Series o Bio Diesel Advantage o Energy Management Advantage o Facility BMPs Advantage o Green Building Advantage o Green Garage Advantage o Green Office Advantage o Greenhouse Gas Reduction Advantage o Idle Reduction Advantage

The Environmental Train-the-Trainer Program

Prevention & Preparedness Plan

Spill Prevention Control & Countermeasure (SPCC) plan (facility level)

Stormwater Pollution Prevention Plan (SWP-3) (facility level)

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2.10 DOCUMENT CONTROL

(ISO 14001 4.4.5)

Transdev Services, Inc. has established and will maintain information in paper and electronic form to:

Describe our core elements of the management system and their interaction;

Provide overall…