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National Park Service US Department of the Interior National Park Service Concession Program Denver, Colorado

Final Environmental Audit Report

DNC Parks & Resorts @ Yosemite, Inc. (DNC) (YOSE004)

November 19, 2007

Prepared for: Yosemite National Park

P.O. Box 577 Yosemite National Park, CA 95389

Prepared by:

National Park Service WASO Concession Program

12795 West Alameda Parkway Lakewood, CO 80228

Table of Contents I. Executive Summary 2 II. Priority 1, 2, and 3 Regulatory Audit Findings 7 III. Best Management Practices (BMPs) 111 IV. Exceptional Practices 152 V. Photos 159 VI. Supporting Documentation: Concessioner, Park, and Concession Program Comments on the Preliminary Audit Report – Priority 1, 2, and 3 Regulatory Audit Findings 179 VII. Supporting Documentation: Concessioner, Park, and Concession Program Comments on Best Management Practices (BMPs) 228 VI. Supporting Documentation: Concessioner, Park, and Concession Program Comments on the Final Audit Report – Priority 1, 2, and 3 Regulatory Audit Findings ## VII. Supporting Documentation: Concessioner, Park, and Concession Program Comments on Best Management Practices (BMPs) ##

I. Executive Summary

CONFIDENTIAL Executive Summary - 3 -

FINAL ENVIRONMENTAL AUDIT REPORT EXECUTIVE SUMMARY

I. INTRODUCTION This Final Environmental Audit Report documents the audit findings of the baseline environmental audit for facilities and services provided by DNC Parks & Resorts @ Yosemite, Inc. (DNC) (the Concessioner) in Yosemite National Park (the Park) under the concession contract for YOSE004. The audit team conducted the site visit from July 30 through August 3, 2007. Key representatives participating in the environmental audit included those identified below:

NAME TITLE Audit Team Christine Chui Lee Audit Team Leader (PRIZIM Inc.) Dana Mooney Auditor (PRIZIM Inc.) John Saturley Observer (PRIZIM Inc.) Concessioner Steve Ullman Director of Facility Services Vicki McMichael Environmental Program Manager Mark Gallagher Resource Manager Dan Anthonijsz Garage Manager Jerry Ernest Director of Hotels Park Annette Catamec Concessions Management Specialist Kim Tucker Concessions Management Specialist Marty Nielson Chief, BRM Craig Anthony Safety Specialist

The audit period under review was January 1, 2006 to August 3, 2007. Only those Concessioner facilities and operations within the Park boundary and directly related to the YOSE004 contract were audited against audit criteria found in the NPS Environmental Audit Program Operating Guide (January 2006) and the draft Concession Environmental Audit System Operating Guide (May 2004). The environmental audit is a “snapshot in time” and does not guarantee that all regulatory compliance or environmental best management practice issues were identified. The audit team did not conduct a complete baseline environmental audit as not all relevant facilities and services could be reviewed in detail during the site visit. For example (this list is not complete), not all tanks storing fuel were inspected, High Country Camps could not be visited due to their inaccessibility, and services viewed as potentially having a lower environmental impact such as tennis courts and employee housing were not audited. However, the Concessioner is required to be in compliance with all Applicable Laws and regulations at all times, regardless of identified findings and deadlines to close them. II. AUDIT FINDINGS Audit findings are areas of non-compliance with Applicable Laws.

• Priority 1 findings represent non-conformances with laws and regulations that pose immediate actual or potential harm to human health or the environment, or the potential for significant liability exists. They are required to be closed within 90 days1 of distribution of the Final Environmental Audit Report.

1 If the Concessioner is closed for the season on this date, then these audit findings should be addressed within one month after the start of the next operating season.


• Priority 2 findings represent non-conformances with laws and regulations that do not pose an immediate threat to human health or the environment. They are required to be closed within 180 days1 of distribution of the Final Environmental Audit Report.

• Priority 3 findings represent non-conformances with Executive Orders; DOI, NPS, or park policy; or the concession contract that do not pose an immediate threat to human health or the environment. They are required to be closed within 180 days1 of distribution of the Final Environmental Audit Report.

Audit findings may be assigned a severity ranking of isolated if it is determined that the non-conformance was observed only once or twice during the site visit. The Concessioner can use this ranking when developing corrective action plans and assigning resources. Audit findings noted as “isolated” will be removed from the report if they are closed prior to the final report being distributed. This environmental audit identified 73 audit findings. The audit findings were in the following areas:

Audit Findings by Topic Area and Priority

Topic Area - NPS EnviroCheck Sheet 1 2 2I 3 3I 1 2 2I 3 3IAir Quality 2 2 0CFC and Halon Management 2 2 0Emergency Planning and Reporting 3 3 0Fuel Storage Management 3 3 6 0Hazard Communication 1 1 0Hazardous Materials Management 4 8 12 1 1Hazardous Waste 5 5 0Pesticide Management 3 3 0Respiratory Protection Program 7 7 0Solid Waste Management 1 1 2 0SPCC Planning 9 9 0Universal Waste Management 10 10 0Used Oil 1 1 0

Topic Area - NPS CEAS EnviroCheck SheetEnvironmental Management Systems (EMS) 1 1 0Gas and Service Stations 9 9 0

Total 0 48 0 24 1 73 0 0 0 1 0 1

1 - Priority 1 2 - Priority 2 3 - Priority 32I - Priority 2 Isolated 3I - Priority 3 Isolated

Total

Audit FindingsOpen & Closed

Audit FindingsClosed Only

TotalPriorityPriority

Photographs are provided to help Park and Concessioner staff identify some of these audit findings. See the Photos section of this Final Environmental Audit Report for more information. III. BEST MANAGEMENT PRACTICES


Best management practices (BMPs) are recommended practices from industry, regulations, or other sources that may result in:

• Improved compliance (e.g., it could be a BMP to develop standard operating procedures to help ensure compliance, even though they are not required);

• Pollution prevention and/or minimized compliance responsibilities (e.g., it could be a BMP to eliminate the use of solvents); or

• Helping the NPS meet its goals to promote environmental management and demonstrate commitment to environmental stewardship and sustainability (e.g., it could be a BMP to work in tandem with the NPS on its environmental management system).

BMPs are derived from a number of sources, including the expertise of the auditors. Auditors use their experience and discretion to identity those BMPs which are believed to be appropriate to the Concessioner’s facilities and operations. The resources and time needed to implement BMPs vary. Some BMPs may be implemented in the short-term with few resources. Other BMPs may be implemented if a longer timeline and more resources are available. BMPs identified in this Final Environmental Audit Report are not required to be implemented. These BMPs may not be technically and economically feasible at this point in time for the current concession operation. However, the Concessioner can evaluate the technical and economic feasibility of these BMPs, and is highly encouraged to implement them, where appropriate, as a means to further protect park resources. This environmental audit identified 36 BMP opportunities. The BMPs were in the following areas:

Best Management Practices by Topic Area

Topic Area - NPS EnviroCheck Sheet Potentially Low Potentially High TotalAir Quality 2 2CFC and Halon Management 1 1Emergency Planning and Reporting 1 1Environmental Purchasing 1 1Fuel Storage Management 4 4Hazard Communication 1 1Hazardous Materials Management 6 6Hazardous Waste 1 1Solid Waste Management 1 1Storm Water Management 2 2Used Oil 1 1Wastewater Management 1 1

Topic Area - NPS CEAS EnviroCheck SheetEnvironmental Management Systems 4 2 6Food Service 1 1Gas and Service Stations 3 3Horse, Mule, and Animal Husbandry Operations 2 2Retail Operations 1 1 2

Total 25 11 36

Time and Resources to Implement


IV. EXCEPTIONAL PRACTICES Exceptional practices are products used or activities undertaken not often seen at park concession operations that demonstrate the Concessioner’s commitment to environmental protection beyond compliance. The environmental audit identified five exceptional practices in the following areas:

• Environmental Management Systems and • Golf Courses.

V. NEXT STEPS – SUBMITTING CORRECTIVE ACTION TO THE NPSCP The Park and Concessioner should submit corrective action information to the NPS Concession Program (NPSCP) on at least an annual basis. Instructions on entering and submitting this information can be found on the Concession Program website at www.concessions.nps.gov/program3.cfm.gov/program3. VI. FOR MORE INFORMATION Further information on the environmental audit program and audit scope, and a general explanation of audit findings and recommended corrective actions are provided in the document titled Concession Environmental Audit System Protocol and Background, which is available on the Concession Program Website at concessions.nps.gov/program3.cfm. The GreenLine CD, which was given to the Park and the Concessioner during the audit site visit, has resources to assist in addressing audit findings and researching BMPs, in addition to general information on the NPSCP. The NPSCP has established a technical assistance telephone line (GreenLine Assistance Number: 303/987-6913) and email address ([email protected]) available to Park staff and the Concessioner to provide support throughout the audit and corrective action process as well as questions regarding the NPSCP in general. Additionally, the NPSCP publishes a bi-annual environmental GreenLine Newsletter that provides information on on-going environmental programs, issues and topics. Copies can be requested via the GreenLine Assistance Number or email address.

mailto:[email protected]

II. Priority 1, 2, and 3 Regulatory Audit Findings

These audit findings are based upon Applicable Laws and are required to be addressed by the Concessioner.

Final Environmental Audit Report -

Yosemite National Park

Monday, November 19, 2007DNC Parks & Resorts @ Yosemite, Inc. (DNC)

YOSE004

Priority: 2 Regulatory

Topic Area: Air Quality

Responsible Party: Environmental Program Manager

Date Audit Finding Closed: Not yet closed

Deadline to Close Audit Finding: 3/26/2008

Photo Number: YOSE004-08-2007-P001

Audit Finding Number: YOSE004-08-2007-001

Citation: Mariposa Air Pollution Control District, Air Permit Generators and Boilers AP-54 and AP-03 Section 4

Location/Asset Description: and Number

CW Concessionwide

Audit Finding:Air quality permit requirements to operate boilers and generators were not consistently met. For example: - Run times for boilers were not available for the boilers at Curry Village, Wawona, and Badger Pass; and - Records of run times for the past five years were not found for the generator at Crane Flat.

Recommended Corrective Action:Ensure all records are maintained in accordance with air permit requirements. Ensure all records are available for inspection per permit requirements.

Notes:

Concessioner employees indicated that it was not feasible to track boiler run times per permit requirements.

Coordinate with the Mariposa Air Pollution Control District to determine whether a permit modification can be obtained for tracking boiler run times. Maintain documentation of outcomes on file.

Assistance Resources:Mariposa Air Quality Control District (MAQCD) contact information: 209/966-2220

Audit Finding Notes

Recommended Corrective Action Notes

CONFIDENTIAL Audit Findings -- 8




YOSE004








Citation: Mariposa Air Quality Control District, Regulation 5, Rule 501.


84772 YOSE004 - BP MAINTENANCE GARAGEEvaporator

Audit Finding:It had not been determined whether a permit to operate was needed for the following equipment:- A propane vaporizer located at Boys Town; and- A maintenance shop evaporator located at Badger Pass.

Recommended Corrective Action:Determine if the propane vaporizer and evaporator require a permit under Mariposa Air Quality Control District regulations.

Obtain and maintain all documentation on file regarding whether a permit is required. If needed, obtain permit and follow permit directions.

Notes:

The evaporator boiled off water from an oily water mixture generated when water in the garage drained into a sump. Approximately 200 gallons of oily water mixture could be generated in two weeks.

None

Assistance Resources:Mariposa Air Quality Control District (MAQCD) contact information: 209/966-2220

Audit Finding Notes






YOSE004


Topic Area: CFC and Halon Management

Responsible Party: HVAC Manager



Photo Number: None


Citation: 40 CFR 82.156 (i)(2) and (5)


CW Concessionwide

Audit Finding:Leak rates had not been determined for all chiller and refrigeration equipment that contained greater than 50 pounds of refrigerant.

Equipment with over 50 pounds of refrigerant included:- Chiller system at the Ahwahnee Hotel;- Chiller system at the Yosemite Lodge; and- Cooling system for the ice rink.

Recommended Corrective Action:Track annual leak rates for pieces of equipment that use more than 50 pounds of refrigerant.

If leak rates for the chiller systems exceed 15 percent of the total charge during a 12-month period, repair the leak within 30 days such that the leak rate is brought to below 15 percent during a 12-month period.

If leak rates for the cooling system for the ice rink exceed 35 percent of the total charge during a 12-month period, repair the leak within 30 days (or 120 days if an industrial process refrigeration shut-down is required to fix the leak) such that the leak rate is brought to below 35 percent during a 12-month period.

Notes:

None

None

Assistance Resources:None identified - refer to the GreenLine CD.

Audit Finding Notes






YOSE004



Responsible Party: Garage Manager



Photo Number: None


Citation: 40 CFR 82.42 (a)(1)


84840 YOSE004 - YV GARAGE - YTSElectric/Refrigeration Shop

Audit Finding:It had not been certified with the Environmental Protection Agency (EPA) that three chlorofluorocarbon (CFC) recovery units complied with applicable regulatory requirements and that each individual authorized to use the recovery units was properly trained and certified.

Recommended Corrective Action:Certify to the EPA that approved equipment for repairing or servicing motor vehicle air conditioners (MVACs) is being used and that individuals using the equipment are properly trained and certified. Certification must take the form of a statement signed by the owner of the equipment or another responsible officer and include:- Name of the purchaser of the equipment;- Address of the establishment where the equipment will be located;- Manufacturer name, equipment mode number, date of manufacture, serial number of equipment;- Statement that the equipment will be properly used in servicing MVACs;- Statement that each individual authorized by the purchaser to perform service is properly trained and certified in accordance with 40 CFR 82.40; and- That the information given is true and correct.

The certification should be sent to MVAC's Recycling Program Manager, Stratospheric Protection Division, (6205J), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460.

Notes:

Three CFC recovery units were stored at the Yosemite Valley Garage. These included:- A unit to recover 407c CFCs. This unit was not yet used but would be used in the future for work on the shuttle buses;- A unit to recover R-22/134a CFCs. This unit was used when conducting work on Concessioner vehicles; and- A unit to recover R-22 CFCs. This unit was used with a shuttle bus fleet no longer in service. Concessioner employees were not anticipating using this piece of equipment in the future.

CURRENT CONCESSIONER PRACTICES:

Assistance Resources:A template certification form can be found at www.epa.gov/ozone/title6/609/mvac_recover.PDF.

Audit Finding Notes





YOSE004

The Concessioner had submitted a similar form for certification of use for CFC recovery equipment used to recover refrigerant from stationary heating, ventilation, and air-conditioning (HVAC) equipment.

NoneRecommended Corrective Action Notes





YOSE004


Topic Area: Emergency Planning and Reporting




Photo Number: None


Citation: 29 CFR 1910.38(a)-(d)


CW Concessionwide

Audit Finding:The emergency action plan (EAP) and other spill response documentation to address incidental and nonincidental hazardous substance spills and releases were not consistent. For example:- Different EAP documentation found in files and posted on walls indicated that the threshold at which employees should not respond to a hazardous substance spill was 25 gallons or 42 gallons; - The spill prevention control and countermeasure (SPCC) plan at Crane Flat indicated that employees should not respond to an oil release of over 25 gallons; and- The amounts to which employees could respond (i.e., either 25 gallons or 42 gallons) were quite large and might not be considered incidental amounts.

Recommended Corrective Action:Update the current EAP and other spill response documentation so that it is consistent. For example:- Determine the maximum hazardous substance amount to which employees can safely respond;- Develop new wording indicating that employees should not respond to hazardous substance releases that are below the spill response threshold unless they are safe to do so and understand the steps to be taken;- Clarify that employees should never attempt to stop the source of a hazardous substance release if it means that they must approach the hazardous substance release;- Remove all outdated spill response materials from employee files and postings;- Update all spill response plans with the maximum hazardous substance amount to which employees can safely respond and wording indicating that employees should not respond to hazardous substance releases that are below the spill response threshold unless they are safe to do so and understand the steps to be taken; and- Circulate the plans to employees and post the new plans in the workplace.

Notes:

Assistance Resources:To obtain information on the EAP including a sample EAP, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, Emergency Planning and Reporting, Guidance for Developing an Emergency Action Plan (EAP).

The Occupational Safety and Health Administration (OSHA) also has a simple tool for developing an EAP found at www.osha.gov/SLTC/etools/evacuation/index.html.





YOSE004

Concessioner staff could only respond to incidental releases. Only those Concessioner staff serving with the fire department were allowed to respond to nonincidental releases, and then only for perimeter control of bystanders (i.e., they were trained to the first responder awareness level).

A fact sheet indicated that Concessioner staff should stop the source of the hazardous substance release, but did not clarify that this should not take place if the employee needed to approach the source of the hazardous substance release. Carrying out this type of task places the employee in danger.

The Contingency and Emergency Plans indicated the following:- In Section 5, it stated that if employees were could contain the spill without endangering themselves, they should "do your best to do so." It also stated that drums on their sides should be set upright, and that liquid materials should be dammed or plugged; and- In Section 8, it stated that if there was a minor spill, employees should use personal protective equipment (PPE), contain the spill, and clean up the spill. However, if it was a large spill, employees should evacuate; if it was safe, employees should use PPE and remove the source of spill.

It was verbally stated that Concessioner employees should not respond unless they felt safe to do so, but the spill response plans reviewed did not always clearly state that this alternative to responding to incidental hazardous substance releases was available.

Between two and five gallons is commonly the threshold used for defining an incidental hazardous substance release amount. Volumes above that amount would then be considered nonincidental hazardous substance amounts.

Concessioner staff who are familiar with certain hazardous substances, such as service station staff who are familiar in working with fuel, may have incidental hazardous substance release amounts that are higher than other Concessioner staff (e.g., ten gallons). However, defining different incidental hazardous substance release amounts for different staff can lead to confusion unless training specifically points out the differences for different staff and the reasoning behind it.

Audit Finding Notes






YOSE004








Citation: 29 CFR 1910.38(e)-(f)


CW Concessionwide

Audit Finding:Employees were not trained on updated and consistent emergency action plan (EAP) documentation.

Recommended Corrective Action:Train employees on an updated and consistent EAP:- Upon initial assignment (i.e., when a new employee is hired);- Whenever the employee's responsibilities or designated actions under the plan change; and- Whenever the plan is changed (e.g., when the EAP is changed regarding incidental spill thresholds).

Notes:

Concessioner staff could only respond to incidental releases. Only those Concessioner staff serving with the fire department were allowed to respond to nonincidental releases, and then only for perimeter control of bystanders (i.e., they were trained to the first responder awareness level).

The emergency action plan (EAP) and other spill response documentation to address incidental and nonincidental hazardous substance spills and releases were not consistent and needed to be updated (see related audit finding). It was not certain what the maximum hazardous substance amount to which employees could safely respond was being communicated to employees.

CURRENT CONCESSIONER PRACTICES:Concessioner staff were trained on EAP procedures, but posted signs and plans available for review were not always consistent with what staff were being trained on.

At Badger Pass, employees stated that they were trained on the EAP annually, but had not yet been trained for 2007. They indicated that in the event of a spill from one of the aboveground storage tanks (ASTs), they would stop the spill with a boom and call for assistance.

Assistance Resources:To obtain information on the EAP including a sample EAP, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, Emergency Planning and Reporting, Guidance for Developing an Emergency Action Plan (EAP).

The Occupational Safety and Health Administration (OSHA) also has a simple tool for developing an EAP found at www.osha.gov/SLTC/etools/evacuation/index.html.

Audit Finding Notes





YOSE004

At the Curry Village boiler room, employees working with pool chemicals had some difficulty locating the spill response equipment.

Between two and five gallons is commonly the threshold used for defining an incidental hazardous substance release amount. Volumes above that amount would then be considered nonincidental hazardous substance amounts.

Concessioner staff who are familiar with certain hazardous substances, such as service station staff who are familiar in working with fuel, may have incidental hazardous substance release amounts that are higher than other Concessioner staff (e.g., ten gallons). However, defining different incidental hazardous substance release amounts for different staff can lead to confusion unless training specifically points out the differences for different staff and the reasoning behind it.






YOSE004






Photo Number: None


Citation: California Health and Safety Code, Section 25503.5


CW Concessionwide

Audit Finding:It had not been determined whether or not the quantity of sulfuric acid stored in vehicle and equipment batteries triggered reporting (i.e., Tier I or Tier II) requirements under 40 CFR 355.30 and California Health and Safety Code, Section 25503.5.

Recommended Corrective Action:Determine how many pounds of sulfuric acid are contained within Concessioner vehicles and equipment. If the quantity exceeds 500 pounds, the Concessioner needs to comply with 40 CFR 370.20 and submit a material safety data sheet (MSDS) for lead acid batteries as well as include sulfuric acid in the Concessioner's Tier I or II report. However, note that including appropriate information on the Concessioner's Hazardous Materials Business Plan and submitting it to the Certified Unified Program Agency (CUPA) meets the requirements listed previously in this paragraph.

If the quantity of sulfuric acid is equal to or exceeds 1,000 pounds, the Concessioner must notify the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) that the Concessioner triggers this regulation. Also, if the quantity is equal to or exceeds 1,000 pounds, a representative from the Concessioner must participate in the LEPC.

Notes:

None

The CUPAs for the Concessioner are the Mariposa County Health Department ([email protected]) and Tuolumne County Environmental Health (Walter Kruse, 209/533-5966).

Contact CUPAs to determine whether sulfuric acid in batteries triggers emergency planning reporting requirements. Some facilities nationwide have been required to file Tier I or II reports because of the amount of sulfuric acid contained in vehicle batteries and equipment.

Assistance Resources:Although this fact sheet was developed by the State of Connecticut, it demonstrates that sulfuric acid in batteries must be reported under EPCRA; see http://ct.gov/dep/lib/dep/p2/vehicle/epcrkappb.pdf.

Audit Finding Notes






YOSE004


Topic Area: Fuel Storage Management






Citation: 40 CFR 280.30(a)


CW Concessionwide

Audit Finding:It was not ensured that that the volume available in aboveground storage tanks (ASTs) was greater than the volume of product to be transferred to the ASTs before the transfer was made. For example:- At Badger Pass, manual gauging was used by the Concessioner to determine the liquid level in ASTs, but this information was not provided to the fuel delivery operator;- At the Yosemite Valley garage, there was no means provided for determining the liquid level in each AST; and- At the Mariposa Grove, there was no means provided for determining the liquid level in each AST.

Recommended Corrective Action:Ensure that the volume available in the ASTs is greater than the volume of product to be transferred to the ASTs before the transfer is made.

Notes:

The procedure by which the Concessioner's fuel delivery operator might have determined the volume available in ASTs was not determined during the audit site visit. Most ASTs were not monitored by automatic tank gauging equipment that could provide fuel delivery operators with the volume of fuel in an AST at the push of a button. Manual gauging was reportedly not occurring prior to the Concessioner's fuel delivery operator delivering fuel at some locations.

None

HELPFUL TIPS:Document liquid levels in each tank on a daily basis and provide this documentation to the delivery operator during each visit.


Audit Finding Notes






YOSE004






Photo Number: None


Citation: 40 CFR 280.50


84813 YOSE004 - WAW WASHBURNBoiler Room

Audit Finding:Reports were not made to the implementing agency within 24 hours (or another reasonable time period specified by the implementing agency) when unusual operating conditions for the underground storage tank (UST) were observed. For example, the Veeder-Root unit dispensed a ticket which indicated a piping sump alarm had occurred on 8/1/07 at 8:30 pm, but staff at the time of the site visit on the afternoon of 8/2/07 had not investigated why the ticket had been dispensed.

Recommended Corrective Action:Report to the implementing agency the unusual operating conditions observed unless the system equipment is found to be defective but not leaking. Immediately repair or replace defective equipment.

Notes:

The sump was not checked during the site visit since the cover was too heavy to be lifted.

Records maintained by the Concessioner indicated that the piping sump was being inspected by a staff member every day until 3/07. Concessioner staff indicated that the employee was injured and no one had been trained to take his place and maintain the inspection routine.

CURRENT CONCESSIONER PRACTICES:Bank’s and Company, the Concessioner's contractor, conducted simple documented monthly inspections of all aboveground storage tanks (ASTs) and USTs which included an inspection of sump areas.

None

HELPFUL TIPS: Train multiple personnel on operating procedures and records maintenance for each fuel storage tank to ensure the integrity and continuation of inspection routines and records maintenance when the responsible individual is absent.


Audit Finding Notes






YOSE004






Photo Number: None


Citation: California Code of Regulations, Title 22, Division 4.5, Chapter 32, Section 67383.4


84748 YOSE004 - CRANE FLAT STOREDiesel underground storage tank - no longer being used

Audit Finding:A posted Mariposa County Health Department permit indicated that a 10,000-gallon diesel underground storage tank (UST) was registered as being operated and active. However, the Concessioner indicated that actions had been taken to close the UST since an alarm had sounded and the UST was found to no longer be usable.

Recommended Corrective Action:Obtain an updated permit that indicates that the 10,000-gallon diesel UST is no longer being operated. Obtain documentation indicating that the UST has been properly closed.

Notes:

An amended registration was reportedly sent to the Mariposa County Health Department in order to obtain an updated permit.

An approval for a one year delay for removal of the closed UST had reportedly been obtained since the Concessioner was going to update the dispenser system with a Healy dispenser system. The Concessioner could then dig into the ground to replace the current dispenser system and remove the closed UST at the same time.

Ensure that the following have been followed:- Section 25298 of the Health and Safety Code, if applicable;- California Unified Program Agency, authorized agency or local implementing agency approval to close the tank system pursuant to California Code of Regulations, Title 23, Section 2672(c), if applicable;- California Code of Regulations, Title 22, Chapter 32, Section 67383.3; and- Filling the UST with a solid, inert material.

HELPFUL TIPS:Maintain a copy of all UST correspondence sent to regulatory authorities and confirm that all information is accurate on the permit. Contact the Mariposa County Health Department to obtain a copy of an updated permit which indicates the closed diesel UST is not currently active. Follow-up with the Mariposa County Health Department after 14 days if no status updates have been received to ensure correspondence documentation was received and inquire about the status of obtaining the updated permit.


Audit Finding Notes






YOSE004


Topic Area: Hazard Communication (HAZCOM)

Responsible Party: Safety Coordinator





Citation: 29 CFR 1910.1200(f)


CW Concessionwide

Audit Finding:Each container of hazardous chemicals in the workplace was not labeled, tagged, or marked with the following information:- Identity of the hazardous chemical(s) contained therein; and- Appropriate hazard warnings.

For example:- At the warehouse, there was an unlabeled spray bottle with a yellow liquid;- At the warehouse uniform room, there were two unlabeled containers;- At the Badger Pass shed, there was a corrosive container without hazard warnings that actually contained antifreeze;- At the Curry Village boiler room, there was an acid tank that was labeled as hydrochloric acid that did not have hazard warnings; - At Boys Town, there were four propane tanks that were unlabeled;- At Tuolumne Meadows, there was a fly spray bottle that did not include hazard warnings;- At Crane Flat service station, the 4000-gallon diesel aboveground storage tank (AST) did not have any labels or hazard warnings;- At Badger Pass, the diesel AST indicated that it had lead;- At Mariposa Grove, the diesel AST was labeled as used paint thinner, diesel, flammable, and combustible;- Concessionwide, there were multiple ASTs storing diesel that were labeled as flammable and combustible; and- Concessionwide, there were multiple propane tanks that were not labeled.

Recommended Corrective Action:Ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with the following information:- Identity of the hazardous chemical(s) contained therein; and- Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information that is immediately available to employees under the hazard communication (HAZCOM) program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.





YOSE004

Ensure that labels or other forms of warning are legible, in English, and prominently displayed on the container, or are readily available in the work area throughout each work shift.

If the Concessioner becomes newly aware of any significant information regarding the hazards of a chemical, revise the labels for the chemical within three months of becoming aware of the new information.

Notes:

The Concessioner had developed, implemented, and maintained a written HAZCOM program in the workplace.

In general, chemicals labeled by the manufacturer with the words "CAUTION," "WARNING," "DANGER," "POISON," or the skull and crossbones symbol are hazardous chemicals. These include, but are not limited to, cleaning chemicals, paints, oils, and solvents.

At the Curry Village boiler room, the acid tank labeled as hydrochloric acid was also labeled as muriatic acid.

At the Yosemite Lodge kitchen, there was an unlabeled container of used kitchen grease.

At Mariposa Grove, the fence surrounding the ASTs had a "no smoking" sign on the front but not on the side, which was what visitors saw while walking down the road past the ASTs.

The Concessioner may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the identity of the hazardous chemicals contained therein and appropriate hazard warnings. The written materials shall be readily accessible to the employees in their work areas throughout each work shift.

If the Concessioner has employees who speak other languages, the Concessioner may add the information in their languages to the material presented, as long as the information is presented in English as well.

HELPFUL TIPS:At the Curry Village boiler room, it is recommended that the newer term – hydrochloric acid – be used instead of muriatic acid to make the labeling consistent.

Although used kitchen grease is not a hazardous chemical, it is recommended that the 55-gallon drum of used kitchen grease be labeled at the Yosemite Lodge kitchen.

At Mariposa Grove, it is recommended that a "no smoking" sign also be posted on the side of the AST fence where visitors will clearly see the sign.

Assistance Resources:To obtain information on the HAZCOM Program including a sample written HAZCOM program, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, Hazard Communication, Guidance for Developing a Written Hazard Communication (HAZCOM) Program.

Audit Finding Notes






YOSE004


Topic Area: Hazardous Materials Management






Citation: 29 CFR 1910.101(b)


CW Concessionwide

Audit Finding:Compressed gas cylinders were not secured to prevent them from falling or being knocked over. For example, unsecured compressed gas cylinders included:- Carbon dioxide cylinders stored in the warehouse electric/refrigeration shop;- A carbon dioxide cylinder stored in the warehouse carpenter shop; and- An oxygen cylinder stored in the Yosemite Valley garage.

Recommended Corrective Action:Secure compressed gas cylinders to prevent them from falling or being knocked over.

Notes:

Some compressed gas cylinders observed did not have tags indicating whether they were full, in use, or empty.

CURRENT CONCESSIONER PRACTICES:The Concessioner stored several compressed gas cylinders throughout its operations. Many were stored within PVC piping tubes preventing the cylinders from tipping over.

Compressed gas cylinders were gang chained in some locations, such as at the warehouse machine shop.

One way in which to secure a compressed gas cylinder is by chaining it around the body. If this method is chosen, the compressed gas cylinder should be secured by chaining it approximately one-third down from the top of the cylinder. It is preferable to chain each cylinder individually, rather than chain several cylinders as a group (i.e., gang chain them).

The PVC piping tube method used by the Concessioner in several locations is also a method of securing compressed gas cylinders.

HELPFUL TIPS:Put tags on compressed gas cylinders indicating their status (e.g., full, in use, or empty).


Audit Finding Notes






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Citation: 29 CFR 1910.106(d)(6)(iv)


83687 YOSE004 - BP MAINTENANCE OIL SHEDAboveground Storage Tanks

Audit Finding:The area surrounding the aboveground storage tank (AST) for gasoline was not kept free of vegetation.

The area around the AST for diesel was not kept free of combustible material since several small containers of propane were gang chained against the side of the AST.

Recommended Corrective Action:Remove the vegetation growing around and brushing up against the gasoline AST.

Remove all containers of propane from the AST area.

Notes:

None

None

HELPFUL TIPS:Train employees to store equipment away from ASTs and to cut back vegetation from around ASTs. Include the inspection of such items as part of the employee daily visual inspection routine.


Audit Finding Notes






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Citation: 29 CFR 1910.106(d)(7)(iii)


107461 YOSE004 - CV ICE RINK - CHILLER BLDGOutdoor flammable storage cabinet

Audit Finding:There were no "No Smoking" signs posted to prevent open flames and smoking by the flammable storage cabinet.

Recommended Corrective Action:Post a conspicuous "No Smoking" sign to prevent open flames and smoking in flammable and combustible liquid storage areas.

Notes:

A cigarette butt was found laying in the flammable storage cabinet.

None


Audit Finding Notes






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Photo Number: None


Citation: California Code of Regulations, Title 19, Division 2, Chapter 4, Section 2729.5(b)


CW Concessionwide

Audit Finding:The Hazardous Material Business Plans (HMBPs) were not updated to reflect current operations. For example, the registration forms indicated that:- Fuel storage tank corrosion protection was "other"; however, a description of the type of corrosion protection used was not included;- Overfill protection for fuel storage tanks was "automatic shut-off" or "ballfloat"; however, this type of overfill protection was not always in place; and- The Valley Fuel Station HMBP indicated that three aboveground storage tanks (ASTs) were present when there were actually five.

Recommended Corrective Action:Review all HMBPs to determine which sections should be updated.

Inform the Certified Unified Program Agency of revisions to the previously submitted HMBPs.

Notes:

Since the Concessioner was operating in two counties, it had to submit HMBPs to two different counties.

None


Audit Finding Notes






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Topic Area: Hazardous Waste






Citation: California Code of Regulations, Title 22, Chapter 12, Article 1, Section 66262.11


CW Concessionwide

Audit Finding:It was not determined if solid waste was a hazardous waste. For example, it was not certain if the following were hazardous waste:- At the Curry Village ice rink, soil contaminated with calcium chloride solution when piping sprung a leak;- At Badger Pass, the oil-water solution produced from the maintenance shop and resulting residue after water had been boiled off;- At the Badger Pass boiler room, the substances in laboratory-type containers;- At Badger Pass, soil contaminated with oil in multiple locations; and- At Badger Pass, soil contaminated with fuel at the location of concern.

Recommended Corrective Action:Determine if the waste is excluded from regulation under California Code of Regulations (CCR), Title 22, Chapter 12, Article 1, Section 66261.4 or the California Health and Safety Code, Section 25143.2.

If the waste is not excluded from regulation per the previous paragraph, determine if the waste is listed as a hazardous waste in CCR, Title 22, Chapter 11, Articles 4 or 4.1 or CCR, Title 22, Chapter 11, Appendix X. If the waste is listed in Appendix X and is not listed in Articles 4 or 4.1 of CCR, Title 22, Chapter 11, determine if the waste is not a hazardous waste by either:- Testing the waste according to the methods set forth in CCR, Title 22, Chapter 11, Article 3, or according to an equivalent method approved by the Department of Toxic Substances Control pursuant to CCR, Title 22, Chapter 10, Article 3, Section 66260.21; or- Applying knowledge of the hazard characteristic of the waste in light of the materials used and the characteristics set forth in CCR, Title 22, Chapter 11, Article 3.

Notes:

At Badger Pass, there were:- Two spills associated with a CAT stored on the grounds;- Leakage associated with a 55-gallon capacity gear box and a 30- to 35-gallon capacity gear box for two separate chair lifts; and- Leakage from where a truck was normally parked during the season.


Audit Finding Notes





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CURRENT CONCESSIONER PRACTICES:The Concessioner had hazardous waste determinations on file for other wastes, including non-Resource Conservation and Recovery Act (RCRA) hazardous wastes such as:- Waste oil;- Waste antifreeze;- Oil/water separation sludge;- Polychlorinated Biphenyls (PCB) ballast;- Asbestos;- Oily water (unspecified oil-containing waste);- Off-specification, aged and surplus products; and- Paint waste.

The California Health and Safety Code, Section 25143.2 describes recyclable materials that are hazardous wastes and those that are not.

CCR, Title 22, Chapter 11, Article 3 lists characteristics of hazardous waste.

CCR, Title 22, Chapter 11, Articles 4 and 4.1 lists RCRA wastes and mercury-containing products respectively that are hazardous wastes when discarded.

CCR, Title 22, Chapter 11, Appendix X lists chemical names and common names for hazardous wastes and hazardous materials.

CCR, Title 22, Chapter 12, Article 1 describes whether the specific standards are applicable to generators of hazardous waste.






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84772 YOSE004 - BP MAINTENANCE GARAGEChair Lifts

84838 YOSE004 - YV DEGNANS BLDGEmergency Generator

Audit Finding:The Concessioner:- Did not reduce the volume of hazardous waste generated at Badger Pass from leaking gear boxes on chair lifts; and - Had not fixed all of the leakage from an emergency generator at Degnan's Deli.

Recommended Corrective Action:Minimize potential hazardous waste generation by preventing releases ofpetroleum products to the environment.

Notes:

A large quantity generator (LQG) of hazardous waste who initiates a shipment of hazardous waste must certify to the following statement in Item 15 of the uniform hazardous waste manifest: “I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.”

There were two leaky gear boxes at Badger Pass which reportedly could not be repaired and would not be replaced. Although spill cleanup equipment surrounded the gear boxes, oil reportedly dripped onto the ground below where the gear boxes were located.

The Degnan's Deli emergency generator was an older model that had leaked fuel onto the ground a few weeks prior to the audit site visit. Not all of the leaks had been repaired at the time of the site visit; coffee cans were being used to capture some of the leaks that came from the emergency generator.

CURRENT CONCESSIONER PRACTICES:An OzzyMat system was used in place of a conventional solvent-based parts washer system. Use of the OzzyMat reportedly resulted in no hazardous waste generated from the system.


Audit Finding Notes





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The Concessioner stated in the Audit Questionnaire and during the site visit that it managed hazardous wastes as an LQG. It was not necessarily an LQG during each month of a calendar year, but had decided to manage hazardous wastes as an LQG since it was not predictable as to when it would generate hazardous wastes that would make it an LQG rather than a small quantity generator of hazardous wastes (SQG).






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Citation: California Code of Regulations, Title 22, Chapter 12, Article 3, Section 66262.34 (e)


CW Concessionwide

Audit Finding:Hazardous waste was being managed in satellite accumulation areas but not at or near the area where the waste was being generated and under the control of the operator of the process generating the waste. For example, the following hazardous wastes were not being managed at or near the area where they were generated:- Asbestos generated periodically Concessionwide being stored in the warehouse near the light room;- Polychlorinated Biphenyls (PCB) ballasts generated periodically Concessionwide being stored in the warehouse near the light room; - Used oil generated Concessionwide being stored in the warehouse machine shop; and- Waste antifreeze generated Concessionwide being stored in the warehouse machine shop.

Recommended Corrective Action:Ensure that hazardous wastes being managed in satellite accumulation areas are actually generated at or near the area where the satellite accumulation areas are located. Otherwise, manage these hazardous wastes as those that are not being accumulated in satellite accumulation areas (e.g., the date on which they became a waste is the start date for storing the hazardous waste accumulation on-site).

Notes:

A 90-day hazardous waste storage shed was located at the warehouse. The shed had secondary containment and underwent weekly inspections.

More than 55 gallons of used absorbents could have been accumulated at the Crane Flat service station since there were two 55-gallon drums designated for used absorbents available. However, neither was full at the time of the site visit and the total amount of used absorbent did not exceed the 55-gallon threshold for accumulating hazardous waste in a satellite accumulation area.

CURRENT CONCESSIONER PRACTICES:Additional satellite accumulation areas were observed which appeared to store hazardous wastes generated at or near the process generating the waste such as:- Used solvent rags generated at the warehouse machine shop;

Assistance Resources:Information on satellite accumulation areas can be found at www.dtsc.ca.gov/HazardousWaste/upload/HWM_FS_Accumulating_HazWaste_Generators.pdf.

Audit Finding Notes





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- Used absorbents generated at the Crane Flat service station; and- Used absorbents generated at the Badger Pass aboveground storage tanks (ASTs).

None

HELPFUL TIPS:The 55-gallon drum used to accumulate used absorbents at the Badger Pass ASTs had an accumulation start date of 7/25/07; however, there were no used absorbents inside the drum. Consider not labeling the drum until the first used absorbent is deposited in the drum.

Remove one of the two 55-gallon drums designated for used absorbent from the Crane Flat service station so that more than 55 gallons of used absorbent will not accumulate at one time at the satellite accumulation area.






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Photo Number: None




CW Concessionwide

Audit Finding:A Biennial Report, Environmental Protection Agency (EPA) Form 8700-13A/B, 5-80, (Revised 11-89), had not been prepared and submitted to the Department of Toxic Substances Control (DTSC) by March 1 of each even-numbered year.

Recommended Corrective Action:Prepare and submit a Biennial Report, EPA Form 8700-13A/B, 5-80, (Revised 11-89), to the DTSC by March 1 of each even-numbered year. The Biennial Report should include:- The identification number, name, and address of the Concessioner;- The calendar year covered by the report;- The identification number, name, and address for each off-site transfer, treatment, storage or disposal facility in the United States to which waste was shipped during the year;- The name and identification number of each transporter used during the reporting year for shipments to a transfer, treatment, storage or disposal facility within the United States;- A description, EPA hazardous waste number (from CCR, Title 22, Chapter 11, Articles 3 or 4), California Hazardous Waste Category Number (from CCR, Title 22, Chapter 11, Appendix XII), DOT hazard class, and quantity of each hazardous waste shipped off-site to a transfer, treatment, storage or disposal facility within the United States. This information shall be listed by identification number of each such off-site facility to which waste was shipped. Wastes that are classified as non-Resource Conservation and Recovery Act (RCRA) hazardous wastes can be properly described by indicating a generic name of the waste and the phrase “Non-RCRA Hazardous Waste, Solid” or “Non-RCRA Hazardous Waste, Liquid” for solid or liquid wastes, respectively. When possible, the generic name shall be obtained from CCR, Title 22, Chapter 11, Appendix X, subdivision (e). If not listed, the commonly recognized industrial name of the waste shall be used;- A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated;- A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years to the extent such information is available for years prior to 1984; and- The certification signed by the generator or authorized representative.

Assistance Resources:Information on Biennial Reports can be found at www.dtsc.ca.gov/HazardousWaste/upload/HWM_FS_Generator_Requirements.pdf





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Notes:

Under California regulations, all hazardous waste generators are required to submit a Biennial Report to the DTSC.

The Concessioner had not received notification from the DTSC to submit a Biennial Report and therefore had not done so.

Based upon discussions with a California representative, although California regulations require all hazardous waste generators to submit a Biennial Report to the DTSC, only large quantity generators of hazardous waste (LQGs) are notified to submit the Biennial Report. Regulators reportedly do not issue notices of violation for hazardous waste generators other than LQGs who do not file Biennial Reports.

The Concessioner stated in the Audit Questionnaire and during the site visit that it managed hazardous wastes as an LQG. It was not necessarily an LQG during each month of a calendar year, but had decided to manage hazardous wastes as an LQG since it was not predictable as to when it would generate hazardous wastes that would make it an LQG rather than a small quantity generator of hazardous wastes (SQG).

Audit Finding Notes






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Photo Number: None




CW Concessionwide

Audit Finding:The name of each employee filling each job title for each position related to hazardous waste management was not documented.

Recommended Corrective Action:Document and maintain on file the name of each employee filling each job title for each position related to hazardous waste management.

Notes:

Job titles related to hazardous waste management were reportedly documented, but not names.

None


Audit Finding Notes






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Topic Area: Respiratory Protection Program




Photo Number: None


Citation: 29 CFR 1910.134(c)


CW Concessionwide

Audit Finding:A written respiratory protection program with required worksite-specific procedures and elements for required respirator use had not been updated.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require additional respiratory protection and engineering controls or other means do not eliminate the need to use respirators, update the written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program should include:- Providing respirators which are applicable and suitable for the purpose intended;- A written respiratory protection program with worksite-specific procedures;- Selection of respirators;- Medical evaluations;- Fit testing;- Respirator use;- Maintenance and care of respirators;- Breathing air quality and use;- Identification of filters, cartridges, and canisters;- Training and information;- Program evaluation; and- Recordkeeping.

Notes:

Concessioner representatives indicated that the written respiratory protection program had not been updated in many years and needed to be reviewed and updated. The written respiratory protection program reviewed:

Assistance Resources:To obtain information on the Respiratory Protection Program including a sample written respiratory protection program, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, Respiratory Protection, Guidance for Developing a Written Respiratory Protection Program (RPP).

Audit Finding Notes





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- Identified the program administrator as being the Maintenance Parts Manager (this was outdated);- Indicated that plumbers, painters, mechanics, body and fender repairmen, and firefighters were required to wear tight-fitting organic vapor/acid gas respirators- Described fit testing as taking place with irritant smoke;- Indicated that medical evaluations should take place annually;- Indicated that respirators must be protected from damage;- Stated that the Loss Control Officer and Management would conduct regular inspections of the respirators;- Indicated that records would be kept by the Maintenance Parts Department; and- Included a respirator fit checklist.

However:- The written respiratory protection program did not address voluntary use of respirators, including filtering facepieces;- Not all respirators observed on-site were protected from damage;- The Loss Control Officer and Management did not conduct regular inspections of respirators; and- Records were not maintained by the Maintenance Parts Department, but were maintained by the Environmental Program Manager.

This respiratory protection program element [29 CFR 1910.134(c )] must be included in a respiratory protection program where respirator use is REQUIRED.

Designation of a suitably trained respiratory protection program administrator must be included in a respiratory protection program where respirator use is VOLUNTARY. However, if the only respirator use is voluntary use of filtering facepieces (i.e., dust masks), this respiratory protection program element is not required.

HELPFUL TIPS:Ensure that the written respiratory protection program addresses a process to ensure that contractors working at Concessioner facilities where there is a respiratory hazard are suitably qualified and use respirators under their own compliant respiratory protection program.






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Photo Number: None


Citation: 29 CFR 1910.134(d)(1)(iii)


CW Concessionwide

Audit Finding:A complete, current hazard evaluation had not been conducted to identify and evaluate the respiratory hazards in the workplace. Potential respiratory hazards included: - Dust; - Paint; - Pool chemicals; and- Plumbing chemicals.

Recommended Corrective Action:Identify and evaluate the respiratory hazard(s) in the workplace. This evaluation should include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the Concessioner cannot identify or reasonably estimate the employee exposure, the Concessioner shall consider the atmosphere to be immediately dangerous to life or health.

Notes:

Concessioner representatives indicated that a hazard evaluation had not taken place for many years and that operations had changed since the written respiratory protection program had been developed.

According to the written respiratory protection program, plumbers, painters, mechanics, body and fender repairmen, and firefighters were required to wear tight-fitting organic vapor/acid gas respirators.

At least one hazardous chemical used by the Concessioner (i.e., cyanuric acid added to water in the Wawona Lodge boiler room) required the use of a respirator. However, employees reportedly did not use respirators while handling this hazardous chemical although they had received respirator training.

Other staff voluntarily wore filtering facepieces.


Audit Finding Notes





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If the Concessioner does not establish a policy prohibiting voluntary use of respirators, additional requirements under the Respiratory Protection Standard (29 CFR 1910.134) would apply.

HELPFUL TIPS:Document the hazard evaluation to demonstrate the applicability of a respiratory protection program.

If no respiratory hazards are identified in the workplace, or if respiratory hazards identified in the workplace do not require employee respirator use, develop, document, and implement a policy specifying that respirators are not required based upon this hazard evaluation. In addition, the Concessioner can develop, document, and implement a policy that voluntary respirator use is not permitted to completely eliminate the need for a respiratory protection program.






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Photo Number: None


Citation: 29 CFR 1910.134(g)


CW Concessionwide

Audit Finding:Procedures for the proper use of respirators had not been established and implemented.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, prohibit respirators with tight-fitting facepieces to be worn by employees who have:- Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or- Any condition that interferes with the face-to-facepiece seal or valve function.

If an employee wears corrective glasses or goggles or other personal protective equipment, ensure that such equipment is worn in a manner that does not interfere with the seal of the facepiece to the face of the user.

For all tight-fitting respirators, ensure that employees perform a user seal check each time they put on the respirator using the procedures in Appendix B-1 or procedures recommended by the respirator manufacturer that the Concessioner demonstrates are as effective as those in Appendix B-1 of 29 CFR 1910.134.

Notes:

The written respiratory protection program did not include procedures for the proper use of respirators.

At least one employee indicated that he wore a tight-fitting respirator even though he had a beard. He was aware that he should be clean shaven and was going to shave off his beard prior to his fit test.

The use of respirators element [29 CFR 1910.134(g)] must be included in a respiratory protection program where respirator use is REQUIRED.


Audit Finding Notes






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The use of respirators element [29 CFR 1910.134(g)] does not need to be included in a respiratory protection program where respirator use is VOLUNTARY.

HELPFUL TIPS: Inform employees with facial hair that they are required to be clean shaven not only for fit tests of tight-fitting respirators, but also during job functions which require wearing tight-fitting respirators.





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Photo Number: None


Citation: 29 CFR 1910.134(h)


CW Concessionwide

Audit Finding:Cleaning and disinfecting, inspection, and repair of respirators used by employees were not provided. For example:- At the warehouse carpenter shop, a respirator was stored out in the open (e.g., it was not stored in a bag to protect it from dust); - At the warehouse machine shop, a respirator was stored in an open bag in a cabinet;- At the warehouse visual design room, a filtering facepiece was stored out in the open;- At the Wawona Lodge boiler room, a half-mask respirator was observed stored out in the open;- At the Yosemite Lodge mechanic’s shop, a filtering facepiece was stored out in the open; and- At the Curry Village boiler room, the respirator used by the employee chlorinating the water for the swimming pool was not stored in his vehicle to protect it from the dust or other elements; the filters were also not stored in a bag to prevent them from becoming saturated with chemical vapors.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide for the cleaning and disinfecting, inspection, and repair of respirators used by employees.

If voluntary respirator use is allowed, also provide for the cleaning and disinfecting, and repair of respirators used by employees.

Provide each respirator user with a respirator that is clean, sanitary, and in good working order. Ensure that respirators are cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134, or procedures recommended by the respirator manufacturer, provided that such procedures are of equivalent effectiveness. Ensure respirators are cleaned and disinfected at the following intervals:- Clean and disinfect respirators issued for the exclusive use of an employee as often as necessary to maintain them in a sanitary condition;- Clean and disinfect respirators issued to more than one employee before they are worn by different individuals;- Clean and disinfect respirators maintained for emergency use after each use; and- Clean and disinfect respirators used in fit testing and training after each use.





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Store respirators to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. Pack and store respirators to prevent deformation of the facepiece and exhalation valve.

Ensure respirators are inspected as follows:- Before each use and during cleaning (for respirators used in routine situations);- At least monthly and in accordance with the manufacturer's recommendations (for respirators maintained for use in emergency situations), check respirators for proper function before and after each use; and- Before being carried into the workplace for use (for emergency escape-only respirators).

Ensure that respirator inspections include the following:- A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the facepiece, head straps, valves, connecting tube, and cartridges, canisters, or filters; and- A check of elastomeric parts for pliability and signs of deterioration.

Keep emergency respirators:- Accessible to the work area;- Stored in compartments or in covers that are clearly marked as containing emergency respirators; and- Stored in accordance with any applicable manufacturer instructions.

For respirators maintained for emergency use:- Certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who conducted the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and - Provide this information on a tag or label that is attached to the storage compartment for the respirator, is kept with the respirator, or is included in inspection reports stored as paper or electronic files. Maintain this information until replaced following a subsequent certification.

Ensure that respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded, repaired, or adjusted in accordance with the following procedures:- Repairs or adjustments to respirators are made only by persons appropriately trained to perform such operations and use only the respirator manufacturer's National Institute for Occupational Safety and Health (NIOSH)-approved parts designed for the respirator;- Repairs are made according to the manufacturer's recommendations and specifications for the type and extent of repairs to be performed; and- Repairs or adjustments to reducing and admission valves, regulators, and alarms are made by the manufacturer or a technician trained by the manufacturer.

Notes:






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The written respiratory protection program indicated that respirators must be protected from damage.

CURRENT CONCESSIONER PRACTICES:At the warehouse plumber’s shop, respirators were stored properly in closed bags in a respirator storage cabinet.

The maintenance and care of respirators element [29 CFR 1910.134(h)] must be included in a respiratory protection program where respirator use is REQUIRED.

The maintenance and care of respirators element [29 CFR 1910.134(h)] must be included in a respiratory protection program where respirator use is VOLUNTARY. However, if the only respirator use is voluntary use of filtering facepieces (i.e., dust masks), this respiratory protection program element is not required.

Audit Finding Notes






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Photo Number: None


Citation: 29 CFR 1910.134(i)


CW Concessionwide

Audit Finding:There was no process to ensure that employees using atmosphere-supplying respirators [supplied-air and SCBA (self-contained breathing apparatus)] were provided with breathing gases of high purity.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide employees using atmosphere-supplying respirators (supplied-air and SCBA) with breathing gases of high purity.

Ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration meet the following specifications:- Compressed and liquid oxygen meet the United States Pharmacopoeia requirements for medical or breathing oxygen; and- Compressed breathing air meet at least the requirements for Grade D breathing air described in American National Standards Institute (ANSI))/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, including: - Oxygen content (v/v) of 19.5-23.5%; - Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less; - Carbon monoxide (CO) content of 10 parts per million (ppm) or less; - Carbon dioxide content of 1,000 ppm or less; and - Lack of noticeable odor.

Ensure that compressed oxygen is not used in atmosphere-supplying respirators that have previously used compressed air.

Ensure that oxygen concentrations greater than 23.5% are used only in equipment designed for oxygen service or distribution.

Ensure that cylinders used to supply breathing air to respirators meet the following requirements:- Cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 173 and part 178);





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- Cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and- The moisture content in the cylinder does not exceed a dew point of -50 degrees Fahrenheit (-45.6 degrees Centigrade) at 1 atmosphere pressure.

Ensure that compressors used to supply breathing air to respirators are constructed and situated so as to:- Prevent entry of contaminated air into the air-supply system;- Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees Fahrenheit (5.56 degrees Centigrade) below the ambient temperature;- Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Maintain and replace sorbent beds and filters, or refurbish them periodically following the manufacturer's instructions; and- Have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. Maintain the tag at the compressor.

For compressors that are not oil-lubricated, ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm.

For oil-lubricated compressors, use a high-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, monitor the air supply at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm.

The employer shall use breathing gas containers marked in accordance with the National Institute for Occupational Safety and Health (NIOSH) respirator certification standard, 42 CFR part 84. Ensure that breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems. Do not introduce asphyxiating substances into breathing air lines.

Use breathing gas containers marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.

Notes:

None

CURRENT CONCESSIONER PRACTICES:Firefighting employees reportedly used SCBAs.

The breathing air quality and use element [29 CFR 1910.134(i)] must be included in a respiratory protection program where respirator use is REQUIRED.


Audit Finding Notes






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The breathing air quality and use element [29 CFR 1910.134(i)] does not need to be included in a respiratory protection program where respirator use is VOLUNTARY.





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Photo Number: None


Citation: 29 CFR 1910.134(k)


CW Concessionwide

Audit Finding:Effective training had not been provided to employees who were required to use respirators. In addition, the basic advisory information on respirators, as presented in Appendix D of the Respiratory Protection Standard (29 CFR 1910.134), was not provided to employees who wore respirators voluntarily.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide effective training to employees who are required to use respirators. Provide the training prior to requiring employees to use respirators in the workplace.

Ensure that each employee can demonstrate knowledge of at least the following:- Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;- What the limitations and capabilities of the respirator are;- How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;- How to inspect, put on and remove, use, and check the seals of the respirator;- What the procedures are for maintenance and storage of the respirator;- How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators; and- The general requirements of 29 CFR 1910.134.

If the Concessioner can demonstrate that new employees have received training within the last 12 months that addresses the elements listed in the previous paragraph, it is not required to repeat such training provided that the employee can demonstrate knowledge of those element(s).

Previous training not repeated initially by the employer must be provided no later than 12 months from the date of the previous training.

Retrain annually and when the following situations occur:- When changes in the workplace or the type of respirator render previous training obsolete;- Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not





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retained the requisite understanding or skill; or- Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Provide the basic advisory information on respirators in any written or oral format, as presented in Appendix D of the Respiratory Protection Standard (29 CFR 1910.134), to employees who wear respirators voluntarily.

Notes:

At least one employee indicated that he wore a tight-fitting respirator even though he had a beard. He was aware that he should be clean shaven and was going to shave off his beard prior to his fit test.

At least one hazardous chemical used by the Concessioner (i.e., cyanuric acid added to water in the Wawona Lodge boiler room) required the use of a respirator. However, employees reportedly did not use respirators while handling this hazardous chemical although they had received respirator training.

Housekeeping staff voluntarily used filtering facepieces.

The training and information element [29 CFR 1910.134(k)] must be included in a respiratory protection program where respirator use is REQUIRED.

The Concessioner must provide the information contained in Appendix D of 29 CFR 1910.134 to employees in a respiratory protection program where respirator use is VOLUNTARY.

HELPFUL TIPS:Provide effective training to employees who use respirators voluntarily.

It is recommended that employees voluntarily using filtering facepieces (dust masks) use those that have been National Institute for Occupational Safety and Health (NIOSH)-certified.

Demonstrate that employees voluntarily using respirators have received Appendix D of the Respiratory Protection Standard by documenting their names and maintaining this information on file.


Audit Finding Notes






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Photo Number: None


Citation: 29 CFR 1910.134(l)


CW Concessionwide

Audit Finding:Evaluations of the workplace had not been conducted to ensure that the written respiratory protection program was being properly implemented, and the Concessioner did not consult employees to ensure that they were using the respirators properly.

Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented and to consult employees to ensure that they are using the respirators properly.

Conduct evaluations of the workplace as necessary to ensure that the provisions of an updated written program are being effectively implemented and that it continues to be effective.

Regularly consult employees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Correct any problems that are identified during this assessment. Factors to be assessed include, but are not limited to:- Respirator fit (including the ability to use the respirator without interfering with effective workplace performance);- Appropriate respirator selection for the hazards to which the employee is exposed;- Proper respirator use under the workplace conditions the employee encounters; and- Proper respirator maintenance.

Notes:

At least one employee indicated that he wore a tight-fitting respirator even though he had a beard. He was aware that he should be


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clean shaven and was going to shave off his beard prior to his fit test.

The program evaluation element [29 CFR 1910.134(l)]must be included in a respiratory protection program where respirator use is REQUIRED.

The program evaluation element [29 CFR 1910.134(l)] does not need to be included in a respiratory protection program where respirator use is VOLUNTARY.






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Topic Area: Solid Waste Management

Responsible Party: Resource Manager





Citation: 40 CFR 243.200-1(a)


CW Concessionwide

Audit Finding:All solid wastes and materials separated for the purpose of recycling were not stored in such a manner so that they did not provide food or harborage for vectors. For example, at the Curry Village, Wawona, and Tuolumne Meadows stables, the large solid waste containers for manure were not always covered to prevent the harborage of vectors.

Recommended Corrective Action:Cover large solid waste containers for manure to prevent the harborage of vectors.

Notes:

Manure can attract flies. At the Curry Village stables, Concessioner staff indicated that manure containers were covered if a storm was approaching.

None

HELPFUL TIPS:Consider also covering the large recycling containers in the warehouse loading dock area.


Audit Finding Notes






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Topic Area: SPCC Planning




Photo Number: None


Citation: 40 CFR 112.20(e)


CW Concessionwide

Audit Finding:A determination of substantial harm had not been completed and maintained in the Concessioner's Spill Prevention Control and Countermeasure (SPCC) plans.

Recommended Corrective Action:Determine whether Concessioner facilities pose substantial harm to the environment by using the flowchart in Attachment C-I to Appendix C to 40 CFR 112.- If it is determined that Concessioner facilities pose substantial harm to the environment, develop and implement a facility response plan as a part of the SPCC plan.- If it is determined that Concessioner facilities do not pose substantial harm to the environment, ensure that the "Certification for Facilities That Do Not Pose Substantial Harm" is included in the Concessioner SPCC Plan.

Notes:

The Concessioner maintained multiple SPCC plans for different locations within the Park.

None

Assistance Resources:EPA SPCC website: www.epa.gov/oilspill

To obtain information on the SPCC Plan, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, SPCC Planning, Understanding Spill Prevention Control and Countermeasure (SPCC) Plans.

Audit Finding Notes






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Citation: 40 CFR 112.3


84842 YOSE004 - YV WAREHOUSE BLDG

Audit Finding:A Spill Prevention Control and Countermeasure (SPCC) plan had not been developed for the warehouse.

Recommended Corrective Action:Develop and document an SPCC plan. Ensure that it contains the following information:- Discussion of the Concessioner's conformance with requirements listed in the SPCC regulations;- Description of the physical layout of the Concessioner operations including a diagram which marks the location and contents of each oil storage container (the diagram must include completely buried tanks that are otherwise exempt from the SPCC Plan and must also include all transfer stations and connecting pipes);- Description of the types of oil in each container and each container's storage capacity;- Prevention measures to avoid discharges including procedures for routine handling of products (loading, unloading, transfers);- Description of discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of discharge;- Explanation of countermeasures for discharge discovery, response, and cleanup (both Concessioner's capability and those that might be required of a contractor);- Description of methods of disposal of recovered materials;- List of contacts and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom the Concessioner has an agreement for response, and all appropriate Federal, state, and local agencies who must be contacted in case of a discharge;- Information and procedures to enable a person reporting a discharge to relate information on the exact address or location and phone number of the Concessioner, the date and time of the discharge, the type of material discharged, estimates of the total quantity discharged, the source and cause of the discharge, a description of all affected media, any damages or injuries caused by the discharge, actions being used to stop, remove, and mitigate the effects of the discharge, whether an evacuation may be needed, and the name of individuals and/or organizations who have also been contacted (these procedures must be organized in the SPCC plan in a manner that is easy to use during an emergency);- Prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the Concessioner as a result of each type of major equipment failure (loading and unloading equipment, tank overflow, rupture, leakage);- Inspection and testing procedures for containers;- Provision of an oil spill contingency plan; and





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- A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

Also ensure the SPCC plan:- Has the full approval of management at a level of authority to commit the necessary resources to fully implement the SPCC plan; and- Is maintained on-site and available for review by the Regional Environmental Protection Agency (EPA) Administrator.

Notes:

An SPCC plan is needed for the warehouse since it has the capacity to store greater than 1,320 gallons of oil, including:- The 500-gallon aboveground storage tank for the generator;- Twenty-one 55-gallon containers of kitchen grease (which equals a total capacity of 1,155 gallons); and- Five 55-gallon empty containers in the "empty storage area."

CURRENT CONCESSIONER PRACTICES: SPCC plans had been developed for all other applicable facilities managed by the Concessioner.

The SPCC plan should include a diagram which includes the underground storage tank (UST) for the boiler.



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Citation: 40 CFR 112.5 (a)


CW Concessionwide

Audit Finding:The Spill Prevention Control and Countermeasure (SPCC) plans had not been updated to include tanks with a capacity equal to or greater than 55-gallons that materially affected the potential for a discharge. For example, the following were not included in SPCC plans:- A gear box at Badger Pass for one of the chairlifts;- A day tank at the Badger Pass boiler room; - 55-gallon containers of used and new oil at the garage, Crane Flat service station, and Badger Pass; and- Kitchen grease storage areas.

The SPCC plan for the garage did not accurately reflect the current conditions observed during the visit. For example, it stated that the four indoor used oil tanks had secondary containment, but they were single-walled and did not have any other secondary containment.

The SPCC plan for the Crane Flat service station did not accurately reflect the current conditions observed during the visit. For example:- One version of the SPCC plan had crossed out in pencil the 1,000-gallon diesel aboveground storage tank (AST) which was no longer used. However, since the 1,000-gallon AST has not yet been removed, it should remain a part of the SPCC plan since it has the potential to store oil; and- The 4,000-gallon diesel AST was handwritten into the SPCC plan, but did not indicate that it was compartmentalized where 1,000 gallons fed the generator and 3,000 gallons supplied fuel to the service station dispensers.

Recommended Corrective Action:Update and implement the SPCC plans, including amendments that account for changes in the facility design, construction, operation, or maintenance that materially affect the potential for a discharge. Ensure that the updates include an accurate facility map detailing the location of applicable containers.


To obtain information on the SPCC Plan, refer to the GreenLine CD. Click on Assistance Resources, Enter Assistance Resources, Environmental Management Topic, SPCC Planning, Understanding Spill Prevention





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Notes:

The Concessioner maintained multiple SPCC plans for different locations within the Park.

CURRENT CONCESSIONER PRACTICES:The use and availability of spill clean-up kits was mentioned in the SPCC plans, but the location and type of spill clean-up kits was not described.

None

HELPFUL TIPS:Describe in greater detail in the SPCC plans the type of spill clean-up kits available and where they are located.

Control and Countermeasure (SPCC) Plans.

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Photo Number: None


Citation: 40 CFR 112.7(a)(3)


CW Concessionwide

Audit Finding:The contact list and phone numbers had not been updated in the Spill Prevention Control and Countermeasure (SPCC) plans.

Recommended Corrective Action:Update the contact list and phone numbers in the SPCC plans. Contact information should include phone numbers for the:- Facility response coordinator;- National Response Center;- Clean-up contractors for which there is an agreement for response; and - All appropriate Federal, state, and local agencies who must be contacted in case of a discharge.

Notes:

None

None



Audit Finding Notes






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Citation: 40 CFR 112.7(c)(1)


CW Concessionwide

Audit Finding:An appropriate containment and/or diversionary structure or equipment to prevent an oil discharge was not available for:- The Yosemite Village garage 55-gallon motor oil and used oil containers and for the four aboveground storage tanks (ASTs) holding oil;- The Crane Flat 55-gallon container storing oil; and- The Badger Pass 55-gallon containers storing oil.

Recommended Corrective Action:Provide adequate secondary containment for all 55-gallon containers storing petroleum products and the four ASTs holding oil.

Notes:

None

CURRENT CONCESSIONER PRACTICES: The garage had two secondary containment pallets for 55-gallon motor oil containers.

None



Audit Finding Notes






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Photo Number: None


Citation: 40 CFR 112.7(f)


CW Concessionwide

Audit Finding:The Spill Prevention Control and Countermeasures (SPCC) plan did not clearly indicate that Concessioner staff were trained to ensure that they would not respond to a spill unless it was safe to do so (i.e., they must be leaving the area of a spill in order to respond).

Recommended Corrective Action:Train oil-handling personnel in discharge procedure protocols and the contents of the SPCC plan.

Schedule and conduct discharge prevention briefings for oil-handling personnel at least once per year to assure adequate understanding of the SPCC plan.

Notes:

Concessioner staff were trained on the SPCC plan. However, it was not clear that Concessioner staff must never approach a nonincidental spill or release for response purposes.

According to Concessioner verbal policies, Concessioner employees should not respond to nonincidental hazardous substance spills and releases.



Audit Finding Notes






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Citation: 40 CFR 112.7(g)(1)


84842 YOSE004 - YV WAREHOUSE BLDGEmergency Generator

Audit Finding:The aboveground storage tank (AST) located near the employee parking lot which was used for the emergency generator was not fenced.

Recommended Corrective Action:Fence the area around the AST for the emergency generator and ensure it is locked when unattended.

Notes:

None

None



Audit Finding Notes






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Citation: 40 CFR 112.7(g)(5)


10662 YOSE004 - VaP Yosemite Valley Fuel Station84538 YOSE004 - BT MARIPOSA GROVE GIFT SHOP

Aboveground storage tanks

Audit Finding:Facility lighting was not provided to assist with the discovery of discharges occurring during hours of darkness and prevent discharges occurring through acts of vandalism. For example:- The Valley Fuel Station dispensing area had lighting at nighttime, but the aboveground storage tanks (ASTs) did not have lighting; and- The Mariposa Grove ASTs did not have lighting at nighttime.

Recommended Corrective Action:Provide facility lighting commensurate with the type and location of the facility to assist with the discovery of discharges occurring during hours of darkness and prevent discharges occurring through acts of vandalism.

Notes:

Other Concessioner facilities that had SPCC plans provided facility lighting during hours of darkness.

None



Audit Finding Notes






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Photo Number: None


Citation: 40 CFR 112.8(c)(6)


CW Concessionwide

Audit Finding:A regular schedule for inspecting the integrity of aboveground containers, such as aboveground storage tanks, was not included in the Spill Prevention Control and Countermeasure (SPCC) plan.

Recommended Corrective Action:Test each aboveground container for integrity on a regular schedule.

The frequency and type of testing must take into account container size and design (such as floating roof, skid-mounted, elevated, or partially buried). Combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing.

Keep comparison records and inspect the container's supports and foundations. In addition, frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas.

Notes:

None

Records of inspections and tests kept under usual and customary business practices are sufficient to meet the requirements of this section of the regulation .



Audit Finding Notes






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Topic Area: Universal Waste Management




Photo Number: None




CW Concessionwide

Audit Finding:Not all universal waste was recycled. For example:- Burned out fluorescent lamps were disposed of in the regular solid waste stream at Badger Pass;- Some batteries, including alkaline batteries, were disposed of in the regular solid waste stream Concessionwide; and- Some aerosol cans were disposed of in the regular solid waste stream Concessionwide.

Recommended Corrective Action:Recycle all universal waste including:- Fluorescent lamps;- Batteries (including alkaline batteries); and- Aerosol cans.

Notes:

Universal waste lamps such as fluorescent lamps were recycled as universal waste at other locations visited.

Batteries that were universal waste under the Federal definition were being managed as universal waste. However, California defines additional types of batteries as being universal waste, and not all of these types of batteries were being recycled.

The Concessioner was not aware that California considered aerosol cans to be a universal waste. However, aerosol cans were being recycled where employees were aware of the Concessioner's aerosol can recycling program.

Assistance Resources:A May 2007 California Fact Sheet entitled "It is Illegal to Dispose of Fluorescent Light Tubes/Lamps in the Trash!" is available at http://www.dtsc.ca.gov/HazardousWaste/Mercury/upload/HWMP_FS_Fluorescent-Tubes-Trash.pdf.

For a description of the types of batteries considered to be universal waste in California, go to www.ciwmb.ca.gov/WPIE/Batteries/.

A fact sheet on aerosol cans being designated as universal wastes can be found at www.dtsc.ca.gov/HazardousWaste/UniversalWaste/upload/HWM_FS_SB1158.pdf.

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A battery recycler from Merced reportedly visited the Concessioner once per week.






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CW Concessionwide

Audit Finding:Universal waste batteries were not always managed in a way that prevented releases of any universal waste or component of a universal waste to the environment. For example, some universal waste batteries, such as alkaline batteries, were disposed of in the regular solid waste.

Universal waste lamps were not stored in containers and packages that remained closed. For example:- At the warehouse, universal waste lamps were stored in boxes that had open tops;- At the Yosemite Lodge housekeeping office, universal waste lamps were stored in a container that could not be closed due to the length of the universal waste lamps;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not stored in a container; and- At the Ahwahnee boiler room, universal waste lamps were stored in containers that could not be closed due to the length of the universal waste lamps.

Recommended Corrective Action:Recycle all universal waste batteries.

Store universal waste lamps in containers and packages that remain closed unless additional universal waste lamps are being added to the containers and packages.

Notes:


Universal waste lamps such as fluorescent lamps were recycled as universal waste except at Badger Pass.

None

Assistance Resources:A summary of universal waste handler requirements can be found at www.dtsc.ca.gov/HazardousWaste/Mercury/upload/HWM_REP_UW_Requirements_04-07-06.pdf.

Audit Finding Notes






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CW Concessionwide

Audit Finding:Not all universal waste batteries and lamps were labeled or marked to identify the type of universal waste. For example:- At the warehouse light room, some universal waste lamps were labeled as “sick”;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not labeled;- At the Ahwahnee boiler room, universal waste lamps were stored in containers that were not labeled; and- At the Badger Pass maintenance area, batteries from cats and ski lifts were not labeled prior to being picked up by maintenance for recycling.

Recommended Corrective Action:Clearly label or mark universal waste batteries (i.e., each battery) or a container in which the batteries are stored with any one of the following phrases: “Universal Waste--Battery(ies)," or “Waste Battery(ies),” or “Used Battery(ies).”

Clearly label or mark universal waste lamps or containers or packages in which such lamps are stored, with one of the following phrases: “Universal Waste--Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).”

Notes:



None


Audit Finding Notes






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CW Concessionwide

Audit Finding:It could not always be demonstrated the length of time that universal waste had been accumulated from the date it became a waste. For example:- Some types of universal waste batteries and lamps were disposed of in the regular solid waste;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not labeled with a date; and- At the Ahwahnee boiler room, universal waste lamps were stored in containers that were not labeled with a date.

Recommended Corrective Action:Demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste by:- Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received;- Marking or labeling each individual item of universal waste (e.g., each battery or lamp) with the date it became a waste or was received;- Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received;- Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received;- Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or- Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.

Notes:

Batteries that were universal waste under the Federal definition were being managed as universal waste. However, California


Audit Finding Notes





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defines additional types of batteries as being universal waste, and not all of these types of batteries were being recycled.







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CW Concessionwide

Audit Finding:Not all employees were aware of proper handling and emergency procedures appropriate to the type(s) of universal waste handled at Concessioner facilities. For example:- Not all employees were aware that certain types of batteries (e.g., alkaline) should be managed as universal waste; and - Employees at Badger Pass were not aware that used fluorescent lamps should be managed as universal wastes.

Recommended Corrective Action:Inform all employees who handle or have responsibility for managing universal waste as to proper handling and emergency procedures appropriate to the type(s) of universal waste handled at Concessioner facilities.

Notes:



None


Audit Finding Notes






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Photo Number: None




CW Concessionwide

Audit Finding:A record of each shipment of universal waste sent from the handler to other facilities was not maintained for at least three years since some types of universal waste batteries and lamps were disposed of in the regular solid waste.

Recommended Corrective Action:Maintain a record of each shipment of universal waste sent to other facilities. Ensure the record includes the following information:- The name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent;- The quantity of each type of universal waste sent (e.g., batteries, thermostats, lamps, mercury switches, etc.); and- The date the shipment of universal waste left the facility.

Maintain the records for at least three years from the date a shipment of universal waste left the facility.

Notes:



The record may take the form of a log, invoice, manifest, bill of lading or other shipping document.


Audit Finding Notes






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Photo Number: None


Citation: California Health and Safety Code, Section 25201.16 (e)


CW Concessionwide

Audit Finding:Universal waste aerosol cans were sometimes disposed of in the regular solid waste stream. For example:- At the Housekeeping Camp, aerosol cans were disposed of in the regular solid waste stream; and- At the Badger Pass maintenance area, aerosol cans were disposed of in the regular solid waste stream.

Recommended Corrective Action:Recycle universal waste aerosol cans.

Notes:

“Aerosol can” means a container in which gas under pressure is used to aerate and dispense any material through a valve in the form of a spray or foam.

“Universal waste aerosol can” means a hazardous waste aerosol can while it is being managed in accordance with California regulations governing the management of universal waste.

Many used aerosol cans may be considered "universal waste aerosol cans" if they have either propellant or product in them.


CURRENT CONCESSIONER PRACTICES:Other universal wastes, such as some types of batteries and fluorescent lamps, were being recycled from some Concessioner locations.

At the Yosemite Lodge bike shop, it was stated that empty aerosol cans had not yet been generated and that it was not known how to dispose of them properly.

None

Assistance Resources:A fact sheet on aerosol cans being designated as universal wastes can be found at www.dtsc.ca.gov/HazardousWaste/UniversalWaste/upload/HWM_FS_SB1158.pdf.

Audit Finding Notes






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Citation: California Health and Safety Code, Section 25201.16 (g)


CW Concessionwide

Audit Finding:Universal waste aerosol cans were not always stored in accumulation containers that were:- Structurally sound and compatible with the contents of the universal waste aerosol can;- Covered at the end of each workday;- Placed in a location that had sufficient ventilation to avoid formation of an explosive atmosphere, and designed, built, and maintained to withstand pressures reasonably expected during storage and transportation; and - Labeled or marked clearly with one of the following phrases: “Universal Waste-Aerosol Cans,” “Waste Aerosol Cans,” or “Used Aerosol Cans.”

Recommended Corrective Action:Store universal waste aerosol cans in containers that are:- Structurally sound and compatible with the contents of the universal waste aerosol can;- Covered at the end of each workday;- Placed in a location that has sufficient ventilation to avoid formation of an explosive atmosphere, and designed, built, and maintained to withstand pressures reasonably expected during storage and transportation; and- Labeled or marked clearly with one of the following phrases: “Universal Waste-Aerosol Cans,” “Waste Aerosol Cans,” or “Used Aerosol Cans.”

Notes:



The Concessioner was not aware that California considered aerosol cans to be a universal waste. However, aerosol cans were


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being recycled where employees were aware of the Concessioner's aerosol can recycling program.


None

HELPFUL TIP:Although not outlined in the California Health and Safety Code, the fact sheet on managing aerosol cans as universal waste indicates that universal waste aerosol cans should be recycled and/or disposed of within one year after they become wastes.






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Citation: California Health and Safety Code, Section 25201.16 (h)


84840 YOSE004 - YV GARAGE - YTS

Audit Finding:The unit used to process the universal waste aerosol cans was not placed on or above a nonearthen floor that was free of cracks or gaps and sufficiently impervious and bermed to contain leaks and spills.

A written operating procedure detailing the safe processing of universal waste aerosol cans was not developed and implemented.

Recommended Corrective Action:Place the unit used to process universal waste aerosol cans on or above a nonearthen floor that is free of cracks or gaps and sufficiently impervious and bermed to contain leaks and spills.

Develop and implement a written operating procedure detailing the safe processing of universal waste aerosol cans. The written operating procedure should, at a minimum, include all of the following:- The type of equipment to be used to process the universal waste aerosol cans safely;- Operation and maintenance of the unit;- Segregation of incompatible wastes;- Proper waste management practices, including ensuring that flammable wastes are stored away from heat and open flames; and- Waste characterization.

Notes:



The unit used to process the universal waste aerosol cans was located near a drain. It was called "Aerosolv." The Concessioner


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reportedly followed the manufacturer's instruction manual for operating the unit.








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Photo Number: None


Citation: California Health and Safety Code, Section 25201.16 (j)



Audit Finding:Notification was not submitted to the Certified Unified Program Agency (CUPA) that described the Concessioner's universal waste aerosol can processing activities.

Recommended Corrective Action:Submit a notification to the CUPA that describes the Concessioner's universal waste aerosol can processing activities. The notification should include, but not be limited to:- The name, identification number, site address, mailing address, and telephone number of the Concessioner;- A description of the universal waste aerosol can processing activities, including the type and estimated volumes or quantities of universal waste aerosol cans to be processed monthly, the treatment process or processes, equipment descriptions, and design capacities; and- A description of the characteristics and management of any hazardous treatment residuals.

Within 30 days of any change in operation which necessitates modifying any of the information submitted in the notification, submit an amended notification to the CUPA.

Notes:



The unit used to process the universal waste aerosol cans was located near a drain in Mariposa County. It was called "Aerosolv." The Concessioner reportedly followed the manufacturer's instruction manual for operating the unit.



Audit Finding Notes





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YOSE004


Topic Area: Used Oil






Citation: California Code of Regulations, Title 22, Division 4.5, Chapter 29, Article 3, Section 66279.21


84772 YOSE004 - BP MAINTENANCE GARAGE84840 YOSE004 - YV GARAGE - YTS

Audit Finding:Containers of used oil were not labeled. Unlabeled containers were found in the following locations:- Yosemite Valley garage; and- Badger Pass maintenance building.

Recommended Corrective Action:Label all containers and piping containing used oil with the words "Used Oil."

Notes:

California regulations require that uncontaminated used oil containers be labeled with the words "used oil." California also states that as a best management practice, containers of used oil can also be labeled with the words "hazardous waste" and the accumulation start date.

None

Assistance Resources:For more information on used oil, refer to www.dtsc.ca.gov/HazardousWaste/upload/OAD_Used-Oil_FS1.pdf.

Audit Finding Notes






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Topic Area: Environmental Management Systems




Photo Number: None


Citation: CC-YOSE004-93; Exhibit I: Maintenance Plan; Section V: Concessioner's Responsibilities; H, Utilities


CW Concessionwide

Audit Finding:A plan to reduce consumption of electrical energy had not been developed and submitted to the Park for review and approval.

Recommended Corrective Action:Prepare a plan to reduce consumption of electrical energy and submit it to the Park for review and approval.

Notes:

A formal plan to reduce the consumption of electricity had not been prepared.

CURRENT CONCESSIONER PRACTICES:A number of practices had been undertaken to reduce the use of electricity, including participation in a Pacific Gas and Electric (PG&E) energy conservation program.

None


Audit Finding Notes






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Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30 4.3.2.3.3


CW Concessionwide

Audit Finding:Where a secondary containment tank was used to provide spill control for an aboveground storage tank (AST), the AST did not always have means provided to prevent overfilling by sounding an alarm when the liquid level in the tank reached 90 percent of capacity and by automatically stopping delivery of liquid to the tank when the liquid level in the tank reached 95 percent of capacity. For example, this was the case for:- Badger Pass ASTs;- Degnan's Deli emergency generator AST; and- Mariposa Grove ASTs.

In addition, the Degnan's Deli emergency generator AST was not capable of resisting the damage from the impact of a motor vehicle.

Recommended Corrective Action:Ensure that means is provided to prevent overfilling ASTs (where a secondary containment tank is used to provide spill control) by sounding an alarm when the liquid level in the tank reaches 90 percent of capacity and by automatically stopping delivery of liquid to the tank when the liquid level in the tank reaches 95 percent of capacity.

Provide suitable collision barriers to protect the Degnan's Deli AST from the impact of a motor vehicle. For example, install concrete reinforced bollards surrounding the emergency generator. Alternatively, relocate the generator (since it is mobile) to a location where there is no traffic.

Notes:

Concessioner staff verbally indicated that the Degnan's Deli emergency generator AST had secondary containment.

Some ASTs, such as the Yosemite Valley fuel station, had audible alarms which sounded when the liquid level in the ASTs reached 90 percent of capacity. However, none of these ASTs had automatic flow restrictors installed in addition to the alarm.

Several sites had either automatic (e.g., Veeder-Root) or visual gauges which would allow the fuel delivery driver to check the


Audit Finding Notes





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current liquid level in tanks; however some, as listed in the audit finding, did not.

Note that NFPA 30A 4.3.6.3, which is specific to motor fuel dispensing rather than all types of AST uses, alternatively indicates for motor fuel dispensing facilities only that "Means shall be provided to sound an audible alarm when the liquid level in the [aboveground storage] tank reaches 90 percent of capacity. Means shall also be provided either to automatically stop the flow of liquid into the [aboveground storage] tank when the liquid level in the [aboveground storage] tank reaches 98 percent capacity or to restrict the flow of liquid into the [aboveground storage] tank to a maximum flow rate of 9.5 L/min (2.5 gpm) when the liquid in the [aboveground storage] tank reaches 95 percent capacity. These provisions shall not restrict or interfere with the operation of either the normal vent or the emergency vent."






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Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30 4.3.2.7


84783 YOSE004 - WAW STORE - GIFTDiesel aboveground storage tank

Audit Finding:Protection was not provided to prevent damage to the aboveground tank located behind the gift shop where it might be exposed to vehicular impact.

Recommended Corrective Action:Provide protection, such as bollards or fencing, to prevent damage to the aboveground tank where it might be exposed to vehicular impact.

Notes:

The 500-gallon aboveground tank was not bolted down and could have been accidentally hit by company or contractor vehicles that use the back of the building.

None


Audit Finding Notes






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Photo Number: None


Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30 4.6.1.5.2


CW Concessionwide

Audit Finding:An approved means was not provided to stop delivery of liquid to the tank prior to the complete filling of the tank. For example, this occurred at:- The Valley Fuel Station; - The Wawona Hotel; and- The Crane Flat service station.

Recommended Corrective Action:Develop, document, and implement an approved means to stop delivery of liquid to the tank prior to the complete filling of the tank.

Notes:

None

CURRENT CONCESSIONER PRACTICES: The Valley Fuel Station and Crane Flat service station had audible alarms which sounded when the tanks reached 90 percent capacity; however, none of these tanks had automatic flow restrictors installed in addition to the alarm (except for the 4,000-gallon compartmentalized aboveground storage tank located at Crane Flat).

None


Audit Finding Notes






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Topic Area: Gas and Service Stations






Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30A 4.3.7.1


CW Concessionwide

Audit Finding:Aboveground storage tanks (ASTs) at service stations were not enclosed with a chain link fence at least 1.8 meters (6 feet) high that were separated from the ASTs by at least 3 meters (10 feet) with a gate secured against unauthorized entry. For example:- At the Yosemite Valley fuel station, a wooden fence was closer than 10 feet to the ASTs;- At the Crane Flat service station, a wooden fence was closer than 10 feet to the ASTs;- At Badger Pass, there was no chain link fence surrounding the ASTs; and- At Mariposa Grove, a wooden fence was closer than 10 feet to the ASTs.

Recommended Corrective Action:Enclose ASTs in areas dispensing fuel to vehicles with a chain link fence at least 1.8 meters (6 feet) high.

Ensure that the fence is separated from the ASTs by at least 3 meters (10 feet) and has a gate that is secured against unauthorized entry.

Notes:

A chain link fence helps protect the ASTs from tampering.

None

HELPFUL TIPS:Consider fencing ASTs that do not dispense fuel to vehicles in a similar manner to help protect the ASTs from tampering, such as at White Wolf, the Yosemite Valley garage, and the warehouse.


Audit Finding Notes






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Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30A 6.5.1


84538 YOSE004 - BT MARIPOSA GROVE GIFT SHOPAboveground storage tanks

Audit Finding:A listed hose assembly was not used to dispense fuel.

Recommended Corrective Action:Use only listed hose assemblies to dispense fuel.

Notes:

There was no marking on the hose indicating that it was listed.

None


Audit Finding Notes






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84538 YOSE004 - BT MARIPOSA GROVE GIFT SHOPAboveground storage tanks

Audit Finding:A listed emergency breakaway device designed to retain liquid on both sides of the breakaway point was not installed on each hose dispensing Class I and II liquids.

Recommended Corrective Action:Install a listed emergency breakaway device designed to retain liquid on both sides of the breakaway point on the hose used to dispense gasoline from the aboveground storage tank (AST).

Install and maintain the listed emergency breakaway device designed to retain liquid on both sides of the breakaway point in accordance with the manufacturers’ instructions.

Notes:

"Listed" is defined by the National Fire Protection Association (NFPA) as equipment, materials, or services included in a list published by an organization that is acceptable to the authority having jurisdiction over the Concessioner. In general, UL-approved emergency breakaway devices are "listed."

CURRENT CONCESSIONER PRACTICES: A breakaway device was installed on the hose used to dispense diesel.

None


Audit Finding Notes






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Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30A 6.7


83687 YOSE004 - BP MAINTENANCE OIL SHEDAboveground Storage Tanks

84726 YOSE004 - WAW SERVICE STATION84538 YOSE004 - BT MARIPOSA GROVE GIFT SHOP

Aboveground Storage Tanks

Audit Finding:Fuel dispensing systems’ emergency shutoff devices or electrical disconnects were not provided or were not installed less than 6 meters (20 feet) from the fuel dispensing devices that they served. For example:- The emergency shutoff switch for the aboveground storage tanks (ASTs) at Badger Pass were installed within 20 feet of the dispensing equipment; and- There was no emergency shutoff switch for the ASTs at Mariposa Grove.

It was not certain whether the emergency shutoff switch for the fueling facilities at the Wawona service station was within 20 feet of the dispensing equipment.

Recommended Corrective Action:Provide fuel dispensing systems with one or more clearly identified emergency shutoff devices or electrical disconnects. Such devices or disconnects should be installed in approved locations but not less than 6 meters (20 feet) or more than 30 meters (100 feet) from the fuel dispensing devices that they serve.

Notes:

The emergency shutoff switch at the Wawona Lodge was located at the rear of the AST by a wall, making it difficult to escape the dispensing and AST area after going to and pressing the emergency shutoff switch.

CURRENT CONCESSIONER PRACTICES:Other service stations had emergency shutoff switches properly located.

None

HELPFUL TIPS:Relocate the emergency shutoff switch for the AST at Wawona Lodge so that staff can easily retreat to a safe area after going to


Audit Finding Notes






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and pressing the emergency shutoff switch.





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Photo Number: None




CW Concessionwide

Audit Finding:Accurate daily inventory records were not maintained and reconciled for all liquid fuel storage tanks at service stations for indication of possible leakage from tanks or piping. For example, daily inventory records were not maintained and reconciled at:- Valley Fuel Station aboveground storage tanks (ASTs);- Crane Flat service station underground storage tanks (USTs) and ASTs;- Tuolumne Meadows service station USTs;- Wawona Lodge AST;- Mariposa Grove ASTs;- Badger Pass ASTs; and- Wawona service station USTs.

Recommended Corrective Action:Maintain accurate daily inventory records and reconcile the amount of product sold or used to the amount of inventory on hand for all liquid fuel storage tanks for indication of possible leakage from the AST. Keep records on the premises or make them available to the authority having jurisdiction for inspection within 24 hours of a written or verbal request.

Where there is more than one storage system serving an individual pump or dispensing device for any product, maintain reconciliation separately for each system.

Notes:

None

Provide necessary tools (e.g., tank measuring stick) and recordkeeping documentation (e.g., inventory and reconciliation log) to employees and train each staff member involved in tank operations to use the items on a daily basis. Monitor the employee's performance using the equipment.


Audit Finding Notes






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CW Concessionwide

Audit Finding:The fuel delivery vehicle was not separated from the aboveground storage tank (AST) by at least 7.6 meters (25 feet) when delivering a Class I liquid, or 4.6 meters (15 feet) for non-Class I liquids. For example:- At the Yosemite Valley fuel station, Badger Pass, and Mariposa Grove, gasoline was delivered within 25 feet of the gasoline ASTs; and- At the Yosemite Valley fuel station, Badger Pass, and Mariposa Grove, diesel was delivered within 15 feet of the diesel ASTs.

Recommended Corrective Action:Ensure that fuel delivery vehicles are separated from gasoline ASTs by at least 25 feet and from diesel ASTs by at least 15 feet when delivering fuel.

Notes:

The audit team witnessed a diesel fuel delivery at the Valley fuel station.

None

HELPFUL TIPS: Train employees to attend and monitor the fuel delivery process to ensure the fuel deliverer is parked in an appropriate location.


Audit Finding Notes






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CW Concessionwide

Audit Finding:Warning signs were not conspicuously posted in the dispensing area and did not incorporate the following or equivalent wording:"W A R N I N G - It is unlawful and dangerous to dispense gasoline into unapproved containers. - No smoking. - Stop motor. - No filling of portable containers in or on a motor vehicle. - Place container on ground before filling."

For example, warning signs with all of the information above were not posted at:- Tuolumne Meadows service station;- Crane Flat service station;- Wawona service station;- Wawona Lodge;- Mariposa Grove; and- Badger Pass.

Recommended Corrective Action:Conspicuously post warning signs in the dispensing area that incorporate the following or equivalent wording:"W A R N I N G - It is unlawful and dangerous to dispense gasoline into unapproved containers. - No smoking. - Stop motor. - No filling of portable containers in or on a motor vehicle. - Place container on ground before filling."

Notes:


Audit Finding Notes





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None






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CW Concessionwide

Audit Finding:Operating instructions posted by the fuel dispensers did not include the location of emergency controls. For example, the location of the emergency shutoff switch was not posted at:- Tuolumne Meadows service station;- Crane Flat service station;- Wawona service station;- Wawona Lodge;- Mariposa Grove; and- Badger Pass.

Recommended Corrective Action:Post operating instructions by the fuel dispensers to indicate where the emergency shutoff switch is located.

Notes:

None

None


Audit Finding Notes






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CW Concessionwide

Audit Finding:Emergency instructions posted in the dispenser area did not indicate the following or equivalent wording:"In case of fire or spill (1) Use emergency stop button. (2) Report accident by calling (specify local fire number) on the phone. Report location."

Emergency instructions were not posted in the following areas:- Wawona Lodge;- Mariposa Grove; and- Badger Pass.

Recommended Corrective Action:Emergency instructions shall be conspicuously posted in the dispenser area. The instructions shall incorporate the following or equivalent wording:"In case of fire or spill (1) Use emergency stop button. (2) Report accident by calling (specify local fire number) on the phone. Report location."

Notes:

None

None


Audit Finding Notes






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Photo Number: None


Citation: CC-YOSE004-93; Exhibit I: Maintenance Plan; Section V: Concessioner's Responsibilities; C, Snow Removal


84772 YOSE004 - BP MAINTENANCE GARAGE

Audit Finding:Fertilizer was being used as a deicer.

Recommended Corrective Action:Prohibit the use of fertilizer as a deicer and use only Park-approved deicer when needed.

Notes:

Previously, fertilizer was used Concessionwide as a deicer. The Badger Pass employees were unaware that fertilizer was not approved as a deicer.

None


Audit Finding Notes






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Photo Number: None


Citation: CC-YOSE004-93; Exhibit I: Maintenance Plan; Section V: Concessioner's Responsibilities; E, Grounds and Landscaping


CW Concessionwide

Audit Finding:A written landscaping plan had not been prepared and submitted to the Park for approval.

Recommended Corrective Action:Prepare a written landscaping plan and submit it to the Park for approval. The written landscaping plan should include, but is not limited to the following:- General statements regarding the desired regime (manicured, natural, etc.) and the condition of the area and sub areas, as appropriate;- Specific information including plant and seed lists, locations, and scope of work proposed, safety and resource considerations, debris disposal, and proposed use of irrigation systems; and- Appropriate use of native vegetation, need for revegetation/restoration efforts, and the potential existence of cultural landscapes.

Notes:

None

None


Audit Finding Notes






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Date Audit Finding Closed: 10/24/2007


Photo Number: None


Citation: CC-YOSE004-93; Exhibit J: Operating Plan; Section XIII: Protection and Security; D, Fire Protection


CW Concessionwide

Audit Finding:A list had not been provided to the Park of service companies who deliver hazardous materials within Park boundaries and have personnel with necessary expertise to provide hazardous materials training to Concessioner and Park emergency response teams for the specific materials transported to the Park.

Recommended Corrective Action:Provide a list to the Park of service companies who deliver hazardous materials within Park boundaries and have personnel with necessary expertise to provide hazardous materials training to Concessioner and Park emergency response teams for the specific materials transported to the Park.

Notes:

None

None


Audit Finding Notes






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Photo Number: None


Citation: CC-YOSE004-93; Exhibit J: Operating Plan; Section XV: Underground Storage Tank/Hazardous Waste Program


CW Concessionwide

Audit Finding:The Concessioner's Hazardous Materials Business Plans (HMBPs) had not been sent to the Park for approval.

Recommended Corrective Action:Submit HMBPs to the Park for approval.

Notes:

HBMPs had already been developed and submitted to the Concessioner's Certified Unified Program Agencies (CUPAs).

The HBMPs were to be submitted to the Park within six months of execution of the contract.

None

Assistance Resources:For more information on how to develop a HMBP in the format required by California, please refer to page 8 of www.mariposacounty.org/healthdepartment/CUPA/Mariposa%20CUPA%20Application.pdf.

Audit Finding Notes






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Citation: NPS Director's Order 58 Chapter 5 Sec. F, NFPA 30 6.3.2



Audit Finding:There was a minimum of four flammable storage cabinets observed in one fire area.

Recommended Corrective Action:Ensure that there are not more than three flammable storage cabinets located in a fire area.

Consider conducting an inventory of all items contained in each of the four flammable storage cabinets. Consolidate flammable materials into a maximum of three flammable storage cabinets; store non-flammable materials elsewhere (i.e., not in the flammable storage cabinets).

Another option is to relocate one flammable storage cabinet to a different fire area.

Notes:

None

None


Audit Finding Notes






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Photo Number: None




84835 YOSE004 - CV PAVILIONBasement

Audit Finding:Class I liquids such as white gas were stored in basements.

Recommended Corrective Action:Ensure that Class I liquids are not stored in basements.

Notes:

White gas and propane stored for retail sales were reportedly stored in a locked room in the basement. The audit team was not able to observe the storage space at the time of the site visit.

The Concessioner indicated that storage space was difficult to find in the area.

None


Audit Finding Notes






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84842 YOSE004 - YV WAREHOUSE BLDGFlammable materials storage building

Audit Finding:Class III liquids (kitchen grease) and combustible commodities (camping fuel and propane) were stored in a warehouse that was not equipped with automatic sprinklers in accordance with National Fire Protection Association 13 for 20 feet high storage of Class IV commodities.

Recommended Corrective Action:Install automatic sprinklers for 20 feet high storage of Class IV commodities as defined in NFPA 13.

Notes:

The building used to store kitchen grease and containers of propane and camping fuel was defined to be a "general-purpose warehouse" since it was a separate, detached building used only for warehousing-type operations.

It was estimated that there were approximately nineteen 55-gallon drums of kitchen grease stored in the warehouse.

The NFPA defines a combustible commodity as a combination of product, packing material, and container that is combustible. Containers of camping fuel and propane along with their packaging material would be classified as a combustible commodity.

None

HELPFUL TIPS:It is recommended that the Concessioner contact a local fire protection expert to determine the specific sprinkler system requirements that must be followed.


Audit Finding Notes






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84842 YOSE004 - YV WAREHOUSE BLDGFlammable materials storage building

Audit Finding:Ordinary combustible commodities were not separated from liquids in containers by a minimum of 2.4 meters (i.e., eight feet). For example, the distance between the storage of kitchen grease and containers of propane and camping fuel (combustible commodities) was less than eight feet.

Recommended Corrective Action:Ensure that kitchen grease containers are separated from any other combustible commodity by at least eight feet.

Notes:

The building used to store kitchen grease and containers of propane and camping fuel was defined to be a "general-purpose warehouse" since it was a separate, detached building used only for warehousing-type operations.

It was estimated that there were approximately nineteen 55-gallon drums of kitchen grease stored in the warehouse.

The National Fire Protection Association (NFPA) defines a combustible commodity as a combination of product, packing material, and container that is combustible. Containers of camping fuel and propane along with their packaging material would be classified as a combustible commodity.

None


Audit Finding Notes






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Topic Area: Pesticide Management






Citation: NPS-77, Natural Resources Management, Integrated Pest Management, Program Guidance I A


CW Concessionwide

Audit Finding:A Pesticide Use Proposal was not annually submitted to the Park for the use of pesticides. Pesticides for which a Pesticide Use Proposal had not been annually submitted included:- Flying Insect Killer found at the Curry Village stables;- Sling Shot Death Blow Crawling Insect Killer found at the Badger Pass maintenance building;- CB-40 Insecticide found at the Badger Pass maintenance building;- Raid found at the Badger Pass maintenance building, warehouse paint storage room, and Ahwahnee Hotel housekeeping area;- Wasp and Hornet Spray found at the Ahwahnee Hotel housekeeping area;- GLB Algyimycin 2000 found at the Curry Village Boiler Room; - Wasp Freeze;- 565 Plus XLO;- Sani-Chlor pool chlorinating tablets found at the Ahwahnee boiler room;- Repel-X fly spray;- Tri-tech fly repellent;- End Bac II Virucidal Spray Disinfectant found at the Yosemite Valley garage; and- Pesticides applied by the Concessioner's pesticide contractor, Paramount Pest Control.

Recommended Corrective Action:Obtain a list of pesticides that Paramount Pest Control is using or will potentially use in Concessioner facilities.

Compile a list of pesticides that are proposed to be used by the Concessioner, Paramount Pest Control, and any other pesticides that are being or will be potentially used by the Concessioner. Submit this list to the Park and request permission to use these pesticides prior to actually using them. Coordinate with the Park to ensure that the Park can meet the December 31st deadline for pesticide approval. If the request is granted, direct Paramount Pest Control to use the pesticides according to manufacturer's and Park directions, and also direct Concessioner staff to use pesticides according to manufacturer's and Park directions. If the request is not granted, prohibit use and dispose of pesticides according to Applicable Laws.

Once permission is granted for pesticides currently being used, ensure that permission is obtained from the





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Park Integrated Pest Management (IPM) Coordinator before any other pesticides are purchased in the future.

Notes:

NPS-77 reads "This section of the Guideline applies to any pesticide use within the National Park System, except for cleaning solutions used in restrooms, restaurants, etc., and includes but is not limited to . . . Concessioners . . ."

CURRENT CONCESSIONER PRACTICES:Concessioner management had obtained authorization from the NPS in a prior year for the use of Wasp Freeze and 565 Plus XLO but had not officially obtained authorization for the current year. Stocks of these pesticides were managed at a central distribution area located in the warehouse. Though the Concessioner had a central distribution area for approved pesticides, several other types of pesticides were found throughout Concessioner facilities and had not gone through the formal NPS Pesticide Use Proposal request process.

The Concessioner indicated that the pest control operator, Paramount Pest Control, had obtained permission for the use of pesticides applied on NPS property through the NPS (but not through the Park's IPM Coordinator). The Concessioner did not have documentation indicating that Paramount Pest Control had obtained pesticide use authorization for the current year.

As a general rule of thumb, pesticides generally have an Environmental Protection Agency registration number listed on the container.

Before Concessioner employees or Paramount Pest Control uses additional or different pesticides, another Pesticide Use Proposal should be submitted to the Park and permission granted before the pesticides are applied.

Proactively discuss non-chemical pest management options with the Park that could be used at Concessioner facilities.

The Park IPM Coordinator is Greg Stock ([email protected], 209/379-1420).

The Pesticide Use Proposal should be submitted first and permission granted by the Park to use the pesticides before the Concessioner purchases the pesticides.

Annual Park approvals for pesticide use expire on December 31st. Parks are required to enter their IPM information on the NPS Intranet site.

Emergency pesticide reviews can be obtained via telephone or e-mail from Regional IPM Coordinators or from the Washington Office IPM staff.

HELPFUL TIPS:Develop, document, and implement a procedure to annually request permission from the Park to use certain types of pesticides, even if they are the same pesticides used from year to year. Retain any documentation from the Park regarding these requests and responses on file.


Audit Finding Notes






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Citation: NPS-77, Natural Resources Management, Integrated Pest Management, Program Guidance IV D


CW Concessionwide

Audit Finding:An annual report documenting the types and amounts of pesticides used (i.e., a Pesticide Use Log) was not submitted to the Park so that the Park could report its pesticide use data by the April 15th deadline. Pesticides for which a Pesticide Use Log was not submitted to the Park included:- Flying Insect Killer found at the Yosemite Valley stables;- Sling Shot Death Blow Crawling Insect Killer found at the Badger Pass maintenance building;- CB-40 Insecticide found at the Badger Pass maintenance building;- Raid found at the Badger Pass maintenance building, warehouse paint storage room, and Ahwahnee Hotel housekeeping area;- Wasp and Hornet Spray found at the Ahwahnee Hotel housekeeping area;- GLB Algyimycin 2000 found at the Curry Village Boiler Room; - Wasp Freeze;- 565 Plus XLO;- Sani-Chlor pool chlorinating tablets found at the Ahwahnee boiler room;- Repel-X fly spray;- Tri-tech fly repellent;- End Bac II Virucidal Spray Disinfectant found at the Yosemite Valley garage; and- Pesticides applied by the Concessioner's pesticide contractor, Paramount Pest Control.

Recommended Corrective Action:Submit an annual Pesticide Use Log to the Park. The Pesticide Use Log should include the following information:- Pesticide name, including the Environmental Protection Agency Pesticide Product Registration Number if applicable;- Amount of pesticide used;- Location pesticide was used; and- Pests targeted.

Coordinate with the Park to ensure that the Park can meet its April 15th deadline for reporting the previous year's actual pesticide use.





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Notes:


CURRENT CONCESSIONER PRACTICES:Concessioner management was unclear regarding which Park staff was serving as the Park Integrated Pest Management (IPM) Coordinator.

The Concessioner indicated that its pest control operator, Paramount Pest Control, did not annually report the use of pesticides to the Park IPM Coordinator.

Other information that is useful to track in the Pesticide Use Log includes the following:- Date pesticide was used;- Person applying the pesticide; and- Additional notes on pesticide application.

Instead of developing its own Pesticide Use Log form or using Pesticide Use Log forms in other assistance materials, the Concessioner may be able to obtain similar forms from the State’s Pesticide Board.

Non-chemical pesticides management efforts proposed to be undertaken by the Concessioner should be discussed with the Park.

The Park IPM Coordinator is Greg Stock ([email protected], 209/379-1420).

Actual pesticide reporting must be done through the NPS Intranet.

HELPFUL TIPS:Document, maintain on file, and implement a procedure to submit an annual Pesticide Use Log to the Park at the end of each calendar year.


Audit Finding Notes






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Citation: NPS-77, Natural Resources Management, Integrated Pest Management, Program Guidance IV F


CW Concessionwide

Audit Finding:Pesticide storage facilities were not locked, fireproof, and ventilated, and proper warning signs were not posted. For example:- Pesticides stored in the Yosemite Valley housekeeping office did not have proper warning signs and the cabinet where pesticides were stored was not locked;- Pesticides stored in the Ahwahnee Hotel housekeeping area did not have proper warning signs and the flammable storage cabinet where pesticides were stored was not locked; and- Pesticides stored in the Badger Pass maintenance area did not have proper warning signs and the flammable storage cabinet where pesticides were stored was not locked.

Pesticides were stored with oils, paints, and spray cans in the following areas: - Warehouse paint storage room;- Yosemite Valley stables;- Badger Pass maintenance area;- Ahwahnee Hotel housekeeping area; and- Yosemite Valley housekeeping office.

A pesticide was not stored according to directions provided on its label. For example, the label on containers of Calcium Hypochlorite briquettes used to manage the Curry Village pool's water quality indicated that the briquettes should be stored in a cool, dry place. They were currently stored in the Curry Village Boiler Room which was a wet, warm location.

Recommended Corrective Action:Store pesticides separately from other substances; obtain pesticides storage facilities that can be locked and are fireproof and ventilated; and post proper warning signs.

Store each type of pesticide on separate shelves and preferably in different cabinets. Store pesticides according to their labels.

Post warning signs on any structure(s) used for the storage of pesticides; keep copies of labels, Material Safety Data Sheets (MSDSs) at the site of application; and keep pesticide inventories in a locked container





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outside the storage facilities.

Notes:


Storing pesticides with cleaning fluids, paints, solvents, or other chemical substances unnecessarily increases the opportunities for accidents, fires, etc.

If purchasing a pesticide storage facility or container that is lockable, fireproof, and ventilated is not technically and economically feasible, ensure at a minimum that pesticides are stored separately from other chemicals.

The Calcium Hypochlorite briquettes had an Environmental Protection Agency pesticide registration number.

The Park Integrated Pest Management Coordinator is Greg Stock, [email protected], 209/379-1420.

HELPFUL TIPS:Consider whether storing the Calcium Hypochlorite briquettes elsewhere is feasible. A suggestion would be to store the briquettes closer to the doorway to the outside where weather conditions might be less humid and more temperate. Be sure to consider whether storing the briquettes in an alternate (possibly farther away) location would increase the chance of spillage of briquettes during transport back to the pool water system.


Audit Finding Notes






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Priority: 3 Regulatory - Isolated







Citation: CC-YOSE004-93; Exhibit I: Maintenance Plan; Section V: Concessioner's Responsibilities; D. Litter and Garbage


CW Concessionwide

Audit Finding:Refuse, including recyclables, was not always stored in receptacles that were covered, waterproof, and bear- and vermin-proof. For example:- At the Wawona service station, the large solid waste container was not secured to prevent bears from accessing the solid waste; - At the Wawona Lodge, recyclables were stored outside;- At White Wolf and Tuolumne Meadows service stations, the recycling container openings for glass did not have covers to prevent vermin from accessing the recyclables; and- At Tuolumne Meadows stables, the glass, plastic, and aluminum recycling containers did not have covers to prevent vermin from accessing the recyclables.

Recommended Corrective Action:Ensure that all large solid waste containers that potentially contain food are bear-proof and that all recycling containers are vermin-proof.

Notes:

The majority of large solid waste containers observed during the site visit were bear-proof.

None


Audit Finding Notes



III. Best Management Practices (BMPs)

These BMPs are good business practices. Concessioners are not required but are encouraged to address these BMPs, as appropriate.




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Time and Resources to Implement: Best Management Practice - Potentially Low



BMP Number: YOSE004-08-2007-074-BMP

BMP Source: NPS Environmental Audit Program Operating Guide

Best Management Practice (BMP):As a BMP, consider keeping parts washers closed when not in use.

The parts washer in the warehouse machine shop had a malfunctioning lid that prevented it from closing all the way. This increased the potential for solvent to evaporate into the air. It is recommended that the Concessioner coordinate with Safety Kleen to repair the lid on the parts washer.


Notes:

CONFIDENTIAL Best Management Practices -- 112




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Photo Number: None



Best Management Practice (BMP):As a BMP, consider implementing a policy of "no idling" for vehicles used to transport supplies to and from Concessioner facilities, including vehicles from outside vendors.

The Concessioner had a no idling policy in place for its shuttle bus fleet.

The Park was considered a Class I Area that is protected under the Regional Haze Program.


Notes:





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Photo Number: None



Best Management Practice (BMP):As a BMP, consider having used refrigerant oils reclaimed and recycled at an Environmental Protection Agency (EPA)-approved refrigerant reclamation facility rather than with a used oil vendor.

Used oil generated from the maintenance of chorofluorocarbon (CFC)-containing equipment may be contaminated with CFCs. A used oil vendor may not be able to remove the CFCs from the used oil prior to its re-refining or other method of used oil disposal, thus releasing the CFCs into the atmosphere.

Discuss with the Concessioner's used oil vendor whether they have the capability to capture and remove any CFCs contaminating used oil. Ensure that if the vendor is able to capture the CFCs, the CFCs are disposed of properly and not vented to the atmosphere.


Notes:





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Photo Number: None


BMP Source: NPS Concession Program

Best Management Practice (BMP):As a BMP, consider ensuring that spill response equipment which is compatible with the hazardous substance of concern is available in the same area.

At the Curry Village boiler room, available spill response equipment appeared to be only for petroleum products. However, corrosive hazardous substances were also stored in the area, and there was no spill response equipment specific to corrosives that was available.


Notes:





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Photo Number: None



Best Management Practice (BMP):As a BMP, consider providing a cross-reference between Section 6 of Standard Concession Contract language (Federal Register Vol. 65, No. 87 26052-26086, Concession Contract) and the current ISO 14001-certified environmental management system (EMS).

The Concessioner EMS had five aspects – wildlife, combustible engines, communication, energy and water, and material use/waste. There was an action plan in place for each specific environmental management plan.

The Concessioner's green team consisted of eight managers from different divisions.


Notes:





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Photo Number: None



Best Management Practice (BMP):As a BMP, consider providing Concessioner employees with read-only access to the current ISO 14001-certified environmental management system (EMS) so that they are familiar with the details of the EMS.

Concern was raised over employees potentially changing files. This can be addressed by providing read-only access to the files or posting copies of files on the Concessioner Intranet or network.

The Concessioner EMS had five aspects – wildlife, combustible engines, communication, energy and water, and material use/waste. There were action plans for each environmental management plan.



Notes:





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Photo Number: None



Best Management Practice (BMP):As a BMP, consider continuing to research ways to partner with Pacific Gas and Electric (PG&E) to further reduce energy costs and save energy. For example:- Consider researching and implementing the rebates and incentives for retail facilities for conserving energy on the PG&E website; and- Consider researching and implementing the rebates and incentives for hotels, resorts, and food service facilities for conserving energy on the PG&E website.

The Concessioner was already in the midst of participating in the LodgingSavers program with PG&E.

Assistance Resources:To learn more about the PG&E retail facility rebates and incentives, go to www.pge.com/biz/rebates/retail/index.html.

To learn more about the PG&E hotels, resorts, and food service facilities rebates and incentives, go to www.pge.com/biz/rebates/hospitality/index.html.

Notes:





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Best Management Practice (BMP):As a BMP, consider the following to help conserve energy and water resources:- Repair the water leak observed near the chiller building at the Curry Village ice rink;- Repair the dripping water faucets in the warehouse carpenter shop and machine shop;- Purchase energy- and water-conserving appliances (e.g., Energy Star-rated washers and dryers) when current appliances need to be replaced at the Housekeeping Camp;- Use a passive infrared sensor on vending machines, such as at the Wawona service station;- Close windows and doors if air is being cooled with an air conditioner or swamp cooler (such as at the Wawona golf shop); and- Continue to replace incandescent lamps with energy-conserving fluorescent lamps;

The Concessioner was already implementing the following to help conserve energy and water resources:- Considered purchasing energy- and water-conserving appliances when the current appliances need to be replaced;- Implemented a linen and towel reuse program at Yosemite Lodge;- Used low-flow faucets and toilets at White Wolf;- Watered the Wawona golf course only at nighttime using greywater from the Park's treatment works; - Provided bikes that had been retired from the bicycle rental fleet to management for use throughout the Park. Additional bikes will be provided to employees in the future as more bikes are retired from the bicycle rental fleet;- Used hybrid shuttle buses whose average fuel consumption was 6 miles per gallon (MPG) rather than 3 MPG for conventional shuttle buses; and- Tracking energy and water usage.

The hybrid shuttle buses used ultralow sulfur diesel fuel and electricity; air emissions were reportedly reduced by 90 percent. There were some signs in the vehicle detailing the benefits of the buses in terms of air emissions. The dual power inverters had already failed but because of the warranty, they were replaced without cost to the Concessioner. The batteries on top of the buses had a nine-year 100 percent replacement warranty. The warranty continued for a total of 15 years, but the amount covered diminished between years 10 and 15.

The Concessioner was considering providing fuel to employees at cost if they carpooled and providing vouchers for employees who use the Yosemite Area Regional Transit System (YARTS).


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Topic Area: Food Service

Photo Number: None



Best Management Practice (BMP):As a BMP, consider developing a standard operating procedure (SOP) at White Wolf Lodge to transport kitchen grease from the kitchen to 30-gallon drums to help minimize the potential for spills outdoors.

Concessioner employees indicated that a 30-gallon drum of kitchen grease stored in a locked, fenced area located behind the kitchen would be wheeled to the kitchen area. Concessioner employees would then bring out small containers of kitchen grease and pour the grease into the 30-gallon drum. The 30-gallon drum would then be wheeled back to its storage location.

The ground surface between the storage area and the kitchen was uneven increasing the likelihood that the 30-gallon drum could tip and spill its contents.

The 30-gallon container of grease did not have secondary containment.


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Best Management Practice (BMP):As a BMP, consider checking the annular space of aboveground storage tanks (ASTs) that do not have automatic leak detection for releases on a regular basis.

ASTs that did not have automatic leak detection included those at:- The warehouse;- The garage;- Badger Pass;- The Wawona general store; and - Mariposa Grove.


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Best Management Practice (BMP):As a BMP, consider securing against tampering all of the fill ports for underground and aboveground storage tanks by locking them.

Locking fill ports will help prevent tampering, including potential terrorist acts.


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Best Management Practice (BMP):As a BMP, consider using spill pads to prevent drips and spills on the ground when:- Filling up equipment or vehicles with fuel (e.g., fueling bobcats at any of the stables, fueling vehicles at Badger Pass);- Changing fuel filters on aboveground storage tanks (e.g., at the warehouse boiler); and- Adding used oil to used oil containers (e.g., at the warehouse machine shop).

In addition, consider developing, documenting, implementing, and monitoring a standard operating procedure for adding used oil to used oil containers in the warehouse machine shop.

At the warehouse machine shop, used oil spills were prevalent around the used oil containers. Reportedly, there was no control over use of the used oil containers, accounting for the used oil spills.

Fuel spills were observed at Badger Pass around the dispensing area.


Notes:





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Best Management Practice (BMP):As a BMP, consider bolting the legs of the 500-gallon diesel aboveground storage tank (AST) to the underlying concrete pad.

None


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Best Management Practice (BMP):As a BMP, consider ensuring that spill protection for underground storage tanks (USTs) is maintained clean and dry.

A small amount of fuel, water, and/or debris was observed in the spill buckets for:- The diesel UST at the warehouse generator;- A UST at the Tuolumne Meadows service station;- The diesel UST at the Ahwahnee Hotel boiler;- The diesel UST at the Yosemite Lodge boiler; and- The diesel UST at the Curry Village boiler.

All other spill buckets observed were clean and dry. Any fuel that collects in the spill bucket after fuel is transferred to the UST should be drained into the UST using the plunger. Maintaining fuel in the spill bucket limits the capacity of the spill bucket to contain other spills. If larger amounts of fuel and/or debris had been observed in the spill buckets that substantially affected the spill buckets' ability to contain spills, an audit finding would have been developed.


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Photo Number: None



Best Management Practice (BMP):As a BMP, consider documenting the daily visual inspection of the aboveground storage tanks storing petroleum.

Daily visual inspections were reportedly taking place at the Valley Fuel Station. Although forms to indicate that the visual inspections were available, they were not always being completed to help demonstrate that visual inspections were taking place daily.

Conducting visual inspections is required by the California Health and Safety Code; however, documenting them is a BMP.


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Photo Number: None



Best Management Practice (BMP):As a BMP, consider having all underground storage tank (UST) and aboveground storage tank (AST) monitoring systems installed to notify a manned remote location when the alarm is set off, especially during non-operating hours. This could include having monitoring systems contact individuals via phone or fax.

Connecting UST and AST monitoring systems to phones or fax machines can help ensure immediate action is taken in the event of a breach in UST or AST integrity.

Some but not all USTs were already configured to notify a manned remote location when the alarm was set off.

A number of USTs and ASTs did not have automatic monitoring systems installed such as:- At the garage, the ASTs outdoors;- At the warehouse, the diesel UST for the boiler and the diesel AST for the generator;- At Badger Pass, the diesel UST for the boiler; and- At the Ahwahnee Hotel, the diesel UST for the boiler.


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Photo Number: None



Best Management Practice (BMP):As a BMP, consider storing incompatible materials (such as corrosives and ammonia-based hazardous materials which are incompatible with flammable hazardous materials) that are stored in containers having a capacity of less than five pounds or 0.5 gallons in separate locations. For example:- In the warehouse paint storage room, separate the container of corrosive material from the paints and aerosol cans in the flammable storage cabinet; and- At Mariposa Grove, separate the two bottles of ammonia-based Windex from the fuels and other flammable materials in the flammable storage cabinet.

Alternatively, store incompatibles in separate containers such as plastic tubs. This will help incompatible materials from mixing should containers leak.

Incompatible materials are those materials that, when mixed, cause an adverse environmental or health effect. For example, if flammable materials stored in a flammable storage cabinet were to ignite, an ammonia-based product in the fire could produce noxious fumes hazardous to human health.

It is a requirement to separate incompatible materials if they are stored in containers having a capacity of five pounds or more, or 0.5 gallons or more (National Fire Protection Association 1 60.1.2.17).


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Best Management Practice (BMP):As a BMP, consider storing hazardous materials in closed containers.

There was an open container of a cleaner found in the Curry Village housekeeping office and open containers found in a number of flammable storage cabinets.


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Best Management Practice (BMP):As a BMP, consider storing hazardous substances in a manner that would tend to control leakage. For example:- Store all containers of liquid hazardous substances upright rather than on their sides;- Do not store hazardous substances on the floor of flammable storage cabinets;- Ensure all flammable material cabinets are stored on a flat surface; and - Provide secondary containment for hazardous substances stored near floor drains or with the potential to affect the outdoor environment.

Hazardous materials were stored on their sides in a flammable storage cabinet at the Curry Village ice rink and warehouse plumber’s shop.

The storage of flammable materials (e.g., fuel, cleaning chemicals, paints) on the bottom of flammable storage cabinets impacted and therefore did not allow for adequate spill containment capacity. Most flammable storage cabinets have a built-in secondary containment area. If flammable storage cabinets do not have a built-in secondary containment area, it may be possible to place a pan or tub in existing cabinets to provide secondary containment. The pan or tub must be made of a material that is compatible with the type of material stored. As an alternative approach, look into the possibility of replacing the cabinets with other flammable storage cabinets that have secondary containment.

A flammable storage cabinet outside of the Curry Village ice rink's chiller building was located on wood decking and the ground. The uneven surface caused the flammable storage cabinet to tilt backwards, increasingly the likelihood that it would fall over.

Containers of the following hazardous substances were stored near floor drains or near or in the outside environment without secondary containment:- Sani-Chlor in the Ahwahnee Boiler Room; - Corrosive in the kitchen at White Wolf;- Fluid evacuator for used oil at the Wawona golf maintenance shed;- Aqua Trol in the Curry Village Boiler Room; and- Oasis cleaning chemicals outside at the Tuolumne Meadows Kitchen.

Corrosive battery acid stored at the Badger Pass maintenance area did not have any secondary containment.


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Best Management Practice (BMP):As a BMP, consider locking the door to the flammable storage cabinet that is stored outside of the Curry Village ice rink chiller building when it is not in use.

The flammable storage cabinet had containers of gasoline, mineral spirits, and various aerosol spray containers. However, it was fenced off from the general public.


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Best Management Practice (BMP):As a BMP, consider conducting an inventory of all hazardous substances maintained on-site, especially those hazardous substances in storage areas. For those hazardous substances that will not be used, consider either donating or disposing of them, ensuring that hazardous wastes intended for disposal are managed in accordance with all applicable regulations.

Old and/or unused hazardous chemicals were found in various locations during the site visit. For example, old and/or unused chemicals were found:- In a storage cabinet at the Wawona Stables; and- In a flammable storage cabinet at the Curry Valley ice rink chiller building.

For any hazardous chemicals that are not being used in the current location, determine whether other Concessioner locations have a use for those that are in good condition. If no other Concessioner location is in need of the unused chemicals, determine whether they can be donated to local organizations such as Habitat for Humanity (which may take unused paint). Provide documentation to the organization at the time of the donation indicating that disposal of the donated hazardous chemicals is no longer the responsibility of the Concessioner. Alternatively, conduct hazardous waste characterizations of each of the old and unused chemicals and dispose of them in accordance with applicable regulations.


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Best Management Practice (BMP):As a BMP, consider removing rope used to support a wood fence that surrounded three propane tanks at the Boy's Camp employee housing area.

There were three propane tanks located at the Boy's Camp employee housing area. A wooden fence was used to provide vehicle protection. A piece of rope was tied to the wooden fence and tied to the top of one of the propane tanks to support and keep the fence in an upright position.

The California Department of Occupational Safety and Health (DOSH) was contacted to determine if removing the rope was required; as of the time of this audit report, DOSH had not yet responded to the audit team's inquiry.


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Topic Area: Retail Operations

Photo Number: None



Best Management Practice (BMP):As a BMP, consider expanding communication on the Leave No Trace program to retail and horse stable operations. For example, consider leaving copies of the Leave No Trace program near each register in the Curry Village mountaineering store and instructing horse guides to talk about Leave No Trace to Park visitors or sending Leave No Trace brochures to guests who have reserved horse and mule trips into the backcountry.

Some mountaineering guides at the mountaineering school were Master Leave No Trace trainers. Leave No Trace was going to be the topic of discussion for mountaineering guides during their August 3, 2007 meeting. However, the mountaineering retail store (which was separate from the mountaineering school although part of the same building) did not have information about Leave No Trace.

Horse guides did not receive Leave No Trace training. Leave No Trace covers horseback riding.


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BMP Source: EO 13101 Sec. 601(a)(2)36 CFR 6.8(d)NPS Solid Waste Management HandbookGreening Your Property, Green Seal

Best Management Practice (BMP):As a BMP, to help maximize recycling opportunities, consider implementing the following if economically feasible and appropriate:- At the warehouse loading dock area, label large recycling containers used to hold newspapers and phonebooks for pick-up;- At the Wawona service station, provide recycling containers for the general public;- When guests check into lodging facilities, verbally promote the Concessioner recycling program and how guests should recycle their recyclable materials; and- Indicate on lodging area maps (e.g., for the Housekeeping Camp and Curry Village) where all recycling stations are located.

It is understood that all elements in the BMP may not be implemented if they are not economically or technically feasible. However, the Concessioner should demonstrate that goals are developed and in place to ensure that:- Products that will improve the Concessioner’s recycling efforts will be considered for purchase; and- Strategies that will improve the Concessioner’s recycling efforts will be considered for implementation.

CURRENT CONCESSIONER PRACTICES:The Concessioner provided recycling stations at several of its facilities, including in rooms at Yosemite Lodge where aluminum, glass, plastic, and newspaper were recycled from guests. It was estimated that guests in the Yosemite Lodge rooms had a recycling rate of approximately 30 percent. Housekeeping staff would take recyclables out of the solid waste containers if it was safe to do so, but were not required to implement this practice.

The Concessioner's solid waste diversion rate ranged between 39 and 45 percent over the past few years.


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Topic Area: Used Oil




Best Management Practice (BMP):As a BMP, consider closing containers of used oil when not being used to pour used oil in or take used oil out.

While some containers of used oil were found in closed containers, other containers were found with an open funnel or other type of lid that allowed for easy draining of used oil into the container.

A lid or cover can help prevent spills should one of the used oil containers tip and fall over.


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Time and Resources to Implement: Best Management Practice - Potentially High




BMP Source: GeneralNPS Environmental Audit Program Operating Guide

Horse, Mule and Animal Husbandry OperationsLeave No Trace

Retail OperationsNPS Environmental Audit Program Operating Guide

Best Management Practice (BMP):As a BMP, consider communicating environmental messages in additional ways to staff and the public. For example:- Educate visitors on the environmentally preferable foods (e.g., local and organic) being used throughout food service operations;- Print environmental messages on the Tuolumne Lodge placemats, which are currently plain; and- Inform visitors that the recycling center by the Yosemite Village Store is environmentally preferable since it is made from wood from hazard trees, has a roof made from tires, and uses natural lighting.

The napkins at Tuolumne Lodge already had a map printed on them; printing messages on the placemats might not be aesthetically pleasing.

CURRENT CONCESSIONER PRACTICES:Multiple signs were posted indicating that visitors should not feed wildlife.

At Yosemite Lodge, the directory found in each guest room had an environmental section describing the Concessioner's ISO 14001-certified environmental management system, why wildlife should not be fed, and Leave No Trace.

Security staff walked around to look for food storage issues and informed visitors if they came across any issues.


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Photo Number: None



Best Management Practice (BMP):As a BMP, consider linking Concessioner-specific standard operating procedures (SOPs) to the current ISO 14001-certified environmental management system (EMS).

The Concessioner EMS had five aspects – wildlife, combustible engines, communication, energy and water, and material use/waste. There were action plans for each environmental management plan.



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Topic Area: Environmental Purchasing

Photo Number: None


BMP Source: GeneralChoose Green Report: General Purpose Cleaners, Green City of San Francisco, Department of the Environment and Michigan Department of Environmental Quality

Food Service:Food Service Facilities Model Shop Report, Air Force Center for Environmental ExcellenceRecycling Guidebook for the Hospitality and Restaurant Industry, Metropolitan Washington Council of Governments Green Restaurant Association Storm Water Best Management Practices for the Food Service Industry, City of Los Angeles Department of Public Works

Gas and Service StationsComprehensive Procurement Guideline for Products Containing Recovered Materials, 40 CFR 247 DOE Alternative Fuels Data Center

Guide and Outfitter ServicesLeave No Trace

Lodging OperationsGreening Your Property, Green Seal

Retail OperationsMichigan Department of Environmental Quality

Transportation OperationsComprehensive Procurement Guideline for Products Containing Recovered Materials, 40 CFR 247DOE Alternative Fuels Data Center

Winter Sports OperatorsSustainable Slopes, National Ski Areas AssociationDOE Alternative Fuels Data Center Comprehensive Procurement Guideline for Products Containing Recovered Materials, 40 CFR 247

Best Management Practice (BMP):As a BMP, consider identifying and implementing additional opportunities to expand the types of environmentally preferable items purchased where economically feasible and appropriate. These environmentally preferable products could include, but are not limited to:RETAIL- Organic wines;- Post-consumer recycled content T-shirts (e.g., Wawona Golf Gift Shop);





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- Disposable bowls, plates, and cups for stores that are made of unbleached paper or are easily biodegradable for sale in Concessioner grocery stores; and- Post-consumer recycled content retail bags, calendars, and postcards.

MAINTENANCE- Propylene glycol antifreeze for vehicles;- Re-refined motor oil; - Retread tires; - Biodiesel and other alternative fuel sources for vehicles; and- Bicycle biolubricants.

FOOD AND BEVERAGE- Organic and/or locally produced food in all food operations (e.g., Curry Taqueria);- Bulk condiment dispensing areas (e.g., Curry Taqueria ketchup and other condiments and Tuolumne Lodge pancake syrup); and- Post-consumer recycled content paper napkins and paper placemats (e.g., Tuolumne Lodge).

LODGING- Organic, post-consumer recycled cotton, or biobased renewable sources for sheets and towels; and- Energy Star-qualified washers and dryers in the Housekeeping Camp Laundromat.

Document environmentally preferable purchases so that performance can be tracked against internally set goals. As appropriate, document research and/or decisions that demonstrate why certain environmentally preferable products were not purchased.

Educate visitors on environmentally preferable products used throughout Concessioner facilities via signs, posters, Concessioner employees, and other means.

In identifying and implementing opportunities to expand the types of environmentally preferable products purchased, several criteria should be considered:- Whether the environmentally preferable products are economically feasible, appropriate, and consistent with the mission and/or merchandise themes of the Park; and- Whether the environmentally preferable products could be replaced incrementally as maintenance and service warrant or as part of a comprehensive retrofit.

It is understood that all elements in the BMP may not be implemented if they are not economically or technically feasible. However, the Concessioner should demonstrate that goals are in place to ensure that:- Products that will improve the Concessioner’s environmental purchasing efforts will be considered for purchase; and- Strategies that will improve the Concessioner’s environmental purchasing efforts will be considered for implementation.

Using POST-consumer recycled materials is better for the environment than using PRE-consumer recycled materials since it helps close the consumer recycling "loop."


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The Concessioner had purchased, used, and/or was selling a number of environmentally preferable products and services in parts of its operation, but not necessarily Concessionwide.

CURRENT CONCESSIONER PRACTICES:The Concessioner already was using a wide variety of environmentally preferable items including but not limited to:RETAIL- Organic pumpkin seeds;- Organic peanut butter;- Organic soymilk;- Vegetables from local organic farms (e.g., TD Willy); - Post-consumer recycled content garbage bags;- Biodegradable laundry detergent; - Ecover products (e.g., toilet bowl cream scrub, chlorine-free diapers);- Seventh Generation products;- Biokleen laundry liquid;- Almond wood and cedar firewood supplied in cardboard boxes; and- Organic cotton clothing that had non-lethal dyes (e.g., from Indigenous Design).

MAINTENANCE- Soy based hydraulic fluid; and- Ultra-low sulfur diesel.

FOOD AND BEVERAGE- Foods from a local, family farmer;- Organic and local starch foods where available;- Rainforest Alliance certified coffee;- Monterey Bay Aquarium Seafood Watch list fish;- American farmed shrimp (since effluent from American farmed shrimp is not as bad as it is from other countries);- Seasonal menus such that food is not transported over long distances;- Organic salad bar in the springtime; and- Wooden stirrers (rather than plastic stirrers).

LODGING- Minimizing housekeeping chemicals used through a system where mixtures and concentrations were created from a “dial a chemical” system; and- Yosemite Lodge rooms had post-consumer recycled content carpet squares, compact fluorescent lamps (except where dimmers were needed), and bulk soap, shampoo, shower gel, and lotion dispensers.

OTHER- Weed-free feed for horse and mule operations; and- Ecotees (i.e., corn starch-based biodegradable tees for the golf course).

The Concessioner used Sysco as its main food distributor. Reportedly, the Concessioner could request that Sysco add a specific item or supplier.

At the Yosemite Village Store, an organic “grab and go” snack section and the $30 organic cotton Half Dome shirt were promoted. There was also a sign for customers to support environmentally preferable products.

The Concessioner was not using the following so that it would operate in a more environmentally preferable manner:- Polystyrene;- Straws (to reduce litter); and- Bleach (unless it was required for certain health reasons).

The Concessioner had already researched some environmental purchasing opportunities proposed in this audit finding, including





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the use of biodiesel in its shuttle bus fleet. The Concessioner had partnered with the California Air Resources Board (CARB) to conduct a pilot study for the use of biodiesel. While the study showed a reduction in particulate matter, other air emission criteria (e.g., nitrogen oxide) were found to increase or results were not statistically significant. As biodiesel quality and technology improves and new shuttle buses are needed, the Concessioner is encouraged to continue researching whether biodiesel buses are environmentally preferred and available in the future.





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Topic Area: Hazard Communication (HAZCOM)

Photo Number: None



Best Management Practice (BMP):As a BMP, consider:- Obtaining and maintaining in a readily accessible location a paper copy material safety data sheet (MSDS) for each hazardous chemical used in the workplace;- Removing from MSDS binders or filing in a separate location MSDSs that are no longer being used; and- Alphabetizing MSDSs so that it is easy to find a particular paper copy MSDS.

Also:- Update the paper copy MSDS file(s) in conjunction with the list of hazardous chemicals whenever a new chemical is introduced to the workplace; and- Review the MSDS file(s) periodically (at least annually) to ensure that it is kept up-to-date. This review can be carried out at the same time as the list of hazardous materials is being updated.

The Concessioner obtained and maintained some (but not all) MSDSs for hazardous chemicals in paper copy on-site. However, the Concessioner relied upon a fax-on-demand system to supply updated MSDSs. Concessioner employees were well aware of the fax-on-demand system for MSDSs.

In particular, it was noted that MSDSs were not available at stable operations for veterinary medicines. According to Occupational Safety and Health Administration regulation 29 CFR 1910.1200(b)(6)(vii), "[d]rugs, as defined in the Federal Food, Drug and Cosmetic Act, in solid, final form for direct administration to the patient (i.e., tablets, pills, capsules) are exempt . . . " from the MSDS requirement. However, those drugs that are not in solid, final form - such as those that must be injected under the skin or are required to be crushed or dissolved - are not exempt from the MSDS requirement.

MSDSs for each hazardous chemical should be made "readily accessible" to employees on all work shifts per 29 CFR 1910.1200 (g)(8). This requires that employees have access to the information when they need it. Compliance with this requirement may be accomplished in many different ways; the employer must decide what is appropriate for the particular workplace. For example, a Concessioner may provide actual paper copies of MSDSs or may choose to have them available by a "fax on demand" system. While a fax-on-demand system is allowed, the Concession Program recommends maintaining paper copies to ensure access to MSDSs in the event that there is an interruption of service of phone lines or electricity.

CURRENT CONCESSIONER PRACTICES:The Concessioner had developed, implemented, and maintained a written hazard communication (HAZCOM) program in the workplace.

Those MSDSs available in paper copy were often not organized in a particular manner, making it difficult to locate a particular MSDS.

Assistance Resources:Interpretation on the HAZCOM standard and pharmaceuticals:www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=21354&p_table=INTERPRETATIONS.

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At the Yosemite Lodge housekeeping office, the MSDSs were accompanied by photos of the hazardous chemicals.





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Best Management Practice (BMP):As a BMP, consider providing secondary containment for all containers holding hazardous waste.

None


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Topic Area: Horse, Mule, and Animal Husbandry Operations

Photo Number: None



Best Management Practice (BMP):As a BMP, consider packing out manure from all High Sierra Camp corrals for disposal along with manure generated from stable operations at Curry Village, Tuolumne Meadows, and Wawona.

Manure was reportedly spread around the corrals and not packed out.


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Topic Area: Horse, Mule, and Animal Husbandry Operations

Photo Number: None



Best Management Practice (BMP):As a BMP, consider cleaning up manure from trails in the area of the start of trail rides on a more frequent basis such as twice per week.

Animals had a tendency to defecate in the same location, resulting in a concentration of manure in particular locations near the beginning of some trails.


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Topic Area: Retail Operations

Photo Number: None



Best Management Practice (BMP):As a BMP, consider if technically and economically feasible, printing environmental education messages on bags given to Park visitors to hold purchases. Some environmental messages that could be printed on the bags include, but are not limited to:- "Please use this bag to carry your trash."- Park and environmental facts and stories.

Brown paper bags given out at retail locations observed during the site visit did not contain information about Park resources, Park facts, or environmental messages.


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Topic Area: Storm Water Management




Best Management Practice (BMP):As a BMP, consider planting vegetation at Wawona stables, especially around the horse corral.

There was very little vegetation in the Wawona stables land assignment. The area was reportedly very dry, and it was very dusty at the time of the site visit. According to Concessioner employees, during times of heavy rainfall, a stream of storm water run-off reportedly traversed the land assignment and was absorbed in a grassy field located nearby.


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Topic Area: Storm Water Management




Best Management Practice (BMP):As a BMP, consider installing canopies over any fuel dispensers that do not already have one in place.

Specifically, install canopies over the fuel dispenser areas at the Tuolumne Meadow service station, Crane Flat service station, and Wawona service station.

A canopy can help reduce the amount of contaminated storm water runoff from gas stations.


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Topic Area: Wastewater Management




Best Management Practice (BMP):As a BMP, consider installing an oil-water separator at the garage where wash water from washing buses drains.

Only the outside, not the undercarriage, of buses were washed at the garage. Dirt settled out in a drain and was removed approximately four times per year. The Concessioner had already determined that the dirt was not considered a hazardous waste.


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IV. Exceptional Practices




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Exceptional Practices Number: YOSE004-08-2007-110-EXP


CW Concessionwide

Exceptional Practices:Earth Day was celebrated annually. In 2007, the Concessioner celebrated through a three-day festival which included:- An Earth Day craft festival; - An EarthDance film festival; - An earth-friendly products fair highlighting environmentally preferable products sold in stores;- A free organic salad bar; - An Earth Day hike;- A children’s tent; - Theatre presentations celebrating environmental pioneers; - Showcasing the hybrid shuttle buses;- A stewardship project for visitors; and- Multiple educational bike tours.

NoneNotes:

CONFIDENTIAL Exceptional Practices -- 153




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84588 YOSE004 - WW REGISTRATION - DINING ROOM - KITCHEN

Exceptional Practices:The Concessioner was in the midst of completing a restoration project at White Wolf to increase natural vegetation in the lodging area. To do this, the Concessioner:- Placed rocks around areas to delineate where it did not want visitors to walk;- Decompacted the soil in the areas cordoned off by rocks; and- Added duff to add nutrients to the soil.

Already, vegetation had started growing back this year. The Concessioner was planning on reseeding the areas cordoned off by rocks in the autumn and reducing storm water runoff using check dams to reduce erosion in the area.

Merced Lake HSC restoration had also been completed in previous years.

Work was being completed by volunteers.

The Concessioner had gone through the National Environmental Policy Act (NEPA) process to gain approval for implementing this project.

The completed project will restore the natural condition of the camp area, reduce dust, and help enhance visitor experiences by improving camp aesthetics.

The Concessioner had already successfully completed similar restoration projects at a number of High Sierra Camps in previous years, including Glen Aulin, May Lake, Vogelsang, and Sunrise.

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Photo Number: None



CW Concessionwide

Exceptional Practices:The Concessioner hosted a “green” meeting for the Sierra Business Council’s (SBC) 12th Annual Conference from November 1-3, 2006. In doing so, the Concessioner was awarded the 2007 Silver Green Meetings Award from IMEX and the Green Meeting Industry Council (GMIC).

Achievements at the conference not normally used in Concessioner operations included but were not limited to:- When disposable utensils, plates, and cups were offered, using a biodegradable product called bagasse (which is a byproduct from the sugarcane process and compostable);- Offering meals where 50 percent were made using local, sustainable produce and resulting in a 70 percent reduction of waste due to recycling, composting, re-use, and minimization of packaging;- Using trash can liners that were biodegradable;- Offering a recycling table for promotional items for the participants to read and return; - Not offering coffee cup lids or stir sticks; and- Educating visitors on how the conference was “green.”

It cost approximately 75 percent more for biodegradable overall versus contracted non-biodegradable or standard disposable items, although using compostable items did save in some tipping fees (approximately $150.00) since the organic food waste from the conference could be composted rather than disposed in a landfill. The cost comparison between biodegradable items used at the conference versus conventional items was as follows:- Plates: Paid 30 percent lower (for biodegradable plates);- Bowls with lids, 8 ounces: Paid 49 percent higher;- Cutlery (averaged): Paid 68 percent higher;- Hot cups: Paid 143 percent higher;- Trash can liners, 40-45 gallons: Paid 288 percent higher; and- Trash can liners, 64 gallons: Paid 166 percent higher (although the largest conventional item size contracted is 60 gallons).

Other achievements highlighted in the Concessioner’s award application (which are ongoing practices in Concessioner operations) included, but were not limited to the following:- Using post-consumer content paper products;- Using motion sensors and replacing incandescent lighting with compact fluorescent lighting;- Implementing a towel and linen reuse program;- Educating guests on the ISO 14001-certified GreenPath environmental management system; and- Reducing, recycling, and composting solid waste.





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The remaining bagasse was used in Curry Village. Additional bagasse disposables were not purchased due to the high cost.Notes:





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Photo Number: None



CW Concessionwide

Exceptional Practices:The Concessioner was participating in the Pacific Gas and Electric (PG&E) LodgingSavers Program. All lodging facilities including employee housing, except for those at White Wolf and Tuolumne, underwent an energy audit.

The report issued as a result of the energy audit indicated that:- At Wawona, lighting retrofits would total $11,222.96, which would result in a payback period in energy savings of only 0.6 years. However, the Concessioner would only need to pay $1683.44 of the total (with the remaining being paid by PG&E), which would result in a payback period in energy savings of only 0.1 years.- For the rest of the lodging facilities, lighting retrofits would total $55,294.17, which would result in a payback period in energy savings of only 0.8 years. However, the Concessioner would only need to pay $15,429.35 of the total (with the remaining being paid by PG&E), which would result in a payback period in energy savings of only 0.2 years.

The lighting retrofits are ongoing, where T-12 lamps are being replaced with energy efficient T-8 lamps and incandescent lamps are being replaced with compact fluorescent lamps. Motion sensors are also being added, as are vendingmisers to vending machines. Based on the lighting retrofit alone, the Concessioner expected to save approximately $80,000 per year in electricity costs.

The Concessioner had also expressed interest in switching to an in-room heating system so unoccupied rooms would not receive heated air during the winter months.

Notes:





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Topic Area: Golf Courses




----- Wawona Golf Course

Exceptional Practices:The Wawona nine hole golf course was a Certified Audubon Cooperative Sanctuary. Some practices implemented by the Concessioner to achieve status as a Certified Audubon Cooperative Sanctuary included:- Leaving nonhazard tree stumps standing as habitat for animals;- Letting grass grow longer at the river's edge and mowing fewer areas;- Having smaller greens and letting the grass grow slightly longer at the greens;- Not using pesticides and instead pulling out invasive plants by hand;- Using electric golf carts;- Watering with greywater from the Park's wastewater treatment plant; and- Watering by hand when needed.

To reach certification, the Concessioner demonstrated environmental responsibility in six areas: Water Conservation, Environmental Planning, Wildlife and Habitat Management, Outreach and Education, Chemical Use Reduction and Safety, and Water Quality Management.

The Concessioner first achieved certification in 2003 and was still certified in 2007, four years after it had been first been certified. (Recertification is required every two years.)

The Audubon Cooperative Sanctuary Program is an education and certification program that certifies golf courses that go above and beyond to protect the surrounding environment while preserving the game of golf.

Notes:


V. Photos

Final Environmental Audit Report – November 19, 2007 DNC Parks & Resorts @ Yosemite, Inc. (DNC) – YOSE004


CONFIDENTIAL Photos - 160 -

Photo: YOSE004-08-2007-P001

Audit Finding Number or

BMP Number:

YOSE004-08-2007-001

Photo: YOSE004-08-2007-P002

Audit Finding Number

or BMP Number:

YOSE004-08-2007-002

Photo: YOSE004-08-2007-P003

Audit Finding Number or BMP Number:

YOSE004-08-2007-006




Photo: YOSE004-08-2007-P004


BMP Number:

YOSE004-08-2007-008 YOSE004-08-2007-083-BMP

Photo: YOSE004-08-2007-P005


BMP Number:

YOSE004-08-2007-011

Photo: YOSE004-08-2007-P006


BMP Number:

YOSE004-08-2007-012




Photo: YOSE004-08-2007-P007


BMP Number:

YOSE004-08-2007-013

Photo: YOSE004-08-2007-P008


YOSE004-08-2007-014 YOSE004-08-2007-093-BMP




Photo: YOSE004-08-2007-P009


or BMP Number:

YOSE004-08-2007-016

Photo: YOSE004-08-2007-P010


BMP Number:

YOSE004-08-2007-017 YOSE004-08-2007-031

Photo: YOSE004-08-2007-P011


BMP Number:

YOSE004-08-2007-018




Photo: YOSE004-08-2007-P012


YOSE004-08-2007-028

Photo: YOSE004-08-2007-P013


BMP Number:

YOSE004-08-2007-030

Photo: YOSE004-08-2007-P014


BMP Number:

YOSE004-08-2007-033




Photo: YOSE004-08-2007-P015


or BMP Number:

YOSE004-08-2007-035

Photo: YOSE004-08-2007-P016


BMP Number:

YOSE004-08-2007-036 YOSE004-08-2007-050 YOSE004-08-2007-053 YOSE004-08-2007-054 YOSE004-08-2007-055

Photo: YOSE004-08-2007-P017


YOSE004-08-2007-039




Photo: YOSE004-08-2007-P018


BMP Number:

YOSE004-08-2007-040 YOSE004-08-2007-042

Photo: YOSE004-08-2007-P019


BMP Number:

YOSE004-08-2007-041




Photo: YOSE004-08-2007-P020


BMP Number:

YOSE004-08-2007-045 YOSE004-08-2007-046

Photo: YOSE004-08-2007-P021


or BMP Number:

YOSE004-08-2007-048




Photo: YOSE004-08-2007-P022


BMP Number:

YOSE004-08-2007-051 YOSE004-08-2007-086-BMP

Photo: YOSE004-08-2007-P023


BMP Number:

YOSE004-08-2007-056



CONFIDENTIAL Photos

Photo: YOSE004-08-2007-P024


BMP Number:

YOSE004-08-2007-058

Photo: YOSE004-08-2007-P025


YOSE004-08-2007-059

- 169 -

Photo: YOSE004-08-2007-P026


YOSE004-08-2007-060




Photo: YOSE004-08-2007-P027


BMP Number:

YOSE004-08-2007-061

Photo: YOSE004-08-2007-P028


YOSE004-08-2007-066

Photo: YOSE004-08-2007-P029


BMP Number:

YOSE004-08-2007-068




Photo: YOSE004-08-2007-P030


BMP Number:

YOSE004-08-2007-069

Photo: YOSE004-08-2007-P031


BMP Number:

YOSE004-08-2007-070 YOSE004-08-2007-071 YOSE004-08-2007-072

Photo: YOSE004-08-2007-P032


BMP Number:

YOSE004-08-2007-073




Photo: YOSE004-08-2007-P033


BMP Number:

YOSE004-08-2007-074-BMP

Photo: YOSE004-08-2007-P034


BMP Number:

YOSE004-08-2007-081-BMP

Photo: YOSE004-08-2007-P035


BMP Number:

YOSE004-08-2007-084-BMP




Photo: YOSE004-08-2007-P036


BMP Number:

YOSE004-08-2007-085-BMP YOSE004-08-2007-103-BMP

Photo: YOSE004-08-2007-P037


BMP Number:

YOSE004-08-2007-087-BMP

Photo: YOSE004-08-2007-P038


YOSE004-08-2007-091-BMP




Photo: YOSE004-08-2007-P039


BMP Number:

YOSE004-08-2007-092-BMP

Photo: YOSE004-08-2007-P040


BMP Number:

YOSE004-08-2007-094-BMP




Photo: YOSE004-08-2007-P041


YOSE004-08-2007-095-BMP

Photo: YOSE004-08-2007-P042


BMP Number:

YOSE004-08-2007-097-BMP




Photo: YOSE004-08-2007-P043


YOSE004-08-2007-098-BMP

Photo: YOSE004-08-2007-P044


or BMP Number:

YOSE004-08-2007-099-BMP




Photo: YOSE004-08-2007-P045


BMP Number:

YOSE004-08-2007-107-BMP

Photo: YOSE004-08-2007-P046


BMP Number:

YOSE004-08-2007-108-BMP

Photo: YOSE004-08-2007-P047


YOSE004-08-2007-109-BMP




Photo: YOSE004-08-2007-P048


BMP Number:

YOSE004-08-2007-110-EXP

Photo: YOSE004-08-2007-P049


or BMP Number:

YOSE004-08-2007-111-EXP

Photo: YOSE004-08-2007-P050


YOSE004-08-2007-114-EXP

VI. Concessioner, Park, and Concession Program Comments on the Preliminary Environmental Audit Report Priority 1, 2, and 3 Regulatory Audit Findings




YOSE004

Audit Finding Number: YOSE004-08-2007-001Audit Finding:Air quality permit requirements to operate boilers and generators were not consistently met. For example: - Run times for boilers were not available for the boilers at Curry Village, Wawona, and Badger Pass; and - Records of run times for the past five years were not found for the generator at Crane Flat.Recommended Corrective Action:Ensure all records are maintained in accordance with air permit requirements. Ensure all records are available for inspection per permit requirements.

4. Does the Park have comments on this audit finding? (If you do not agree with the audit finding or the Concessioner’s

NONE ENTEREDConcession Environmental Audit System Comments

N/A

Concessioner Comments

Park Comments

2. Does the Park agree with the Concessioner's comments above for this audit finding? . . . . . . . . . . . . . . . . . . . . . NA1. Does the Park agree with this audit finding? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes

3. Does the Park believe that the audit finding should be closed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . No

2. Does the Concessioner have comments on this audit finding? (If you answered “no” above, comments are required;

NONE ENTERED

otherwise, comments are optional.)

comments, comments are required; otherwise comments are optional.)

1. Does the concessioner agree with this audit finding (in Section II, Priority 1, 2, and 3 Regulatory Audit Findings)? Yes

Audit Finding Number: YOSE004-08-2007-002Audit Finding:It had not been determined whether a permit to operate was needed for the following equipment:- A propane vaporizer located at Boys Town; and- A maintenance shop evaporator located at Badger Pass.Recommended Corrective Action:Determine if the propane vaporizer and evaporator require a permit under Mariposa Air Quality Control District regulations.

Obtain and maintain all documentation on file regarding whether a permit is required. If needed, obtain permit and follow permit directions.



Park Comments

2. Does the Park agree with the Concessioner's comments above for this audit finding? . . . . . . . . . . . . . . . . . . . . . Yes1. Does the Park agree with this audit finding? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes



DNC will verify permit requirement with APCD of Mariposa County. Per APCD Officer (Dave Conway), equipment is believed to be exempt from permit requirements.




CONFIDENTIAL Comments - Audit Findings -- 180




YOSE004


N/A

Audit Finding Number: YOSE004-08-2007-003Audit Finding:Leak rates had not been determined for all chiller and refrigeration equipment that contained greater than 50 pounds of refrigerant.

Equipment with over 50 pounds of refrigerant included:- Chiller system at the Ahwahnee Hotel;- Chiller system at the Yosemite Lodge; and- Cooling system for the ice rink.Recommended Corrective Action:Track annual leak rates for pieces of equipment that use more than 50 pounds of refrigerant.

If leak rates for the chiller systems exceed 15 percent of the total charge during a 12-month period, repair the leak within 30 days such that the leak rate is brought to below 15 percent during a 12-month period.

If leak rates for the cooling system for the ice rink exceed 35 percent of the total charge during a 12-month period, repair the leak within 30 days (or 120 days if an industrial process refrigeration shut-down is required to fix the leak) such that the leak rate is brought to below 35 percent during a 12-month period.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-004Audit Finding:It had not been certified with the Environmental Protection Agency (EPA) that three chlorofluorocarbon (CFC) recovery units complied with applicable regulatory requirements and that each individual authorized to use the recovery units was properly trained and certified.Recommended Corrective Action:Certify to the EPA that approved equipment for repairing or servicing motor vehicle air conditioners (MVACs) is being used and that individuals using the equipment are properly trained and certified. Certification must take the form of a statement signed by the owner of the equipment or another responsible officer and include:- Name of the purchaser of the equipment;- Address of the establishment where the equipment will be located;





YOSE004

- Manufacturer name, equipment mode number, date of manufacture, serial number of equipment;- Statement that the equipment will be properly used in servicing MVACs;- Statement that each individual authorized by the purchaser to perform service is properly trained and certified in accordance with 40 CFR 82.40; and- That the information given is true and correct.

The certification should be sent to MVAC's Recycling Program Manager, Stratospheric Protection Division, (6205J), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, DC 20460.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-005Audit Finding:The emergency action plan (EAP) and other spill response documentation to address incidental and nonincidental hazardous substance spills and releases were not consistent. For example:- Different EAP documentation found in files and posted on walls indicated that the threshold at which employees should not respond to a hazardous substance spill was 25 gallons or 42 gallons; - The spill prevention control and countermeasure (SPCC) plan at Crane Flat indicated that employees should not respond to an oil release of over 25 gallons; and- The amounts to which employees could respond (i.e., either 25 gallons or 42 gallons) were quite large and might not be considered incidental amounts.Recommended Corrective Action:Update the current EAP and other spill response documentation so that it is consistent. For example:- Determine the maximum hazardous substance amount to which employees can safely respond;- Develop new wording indicating that employees should not respond to hazardous substance releases that are below the spill response threshold unless they are safe to do so and understand the steps to be taken;- Clarify that employees should never attempt to stop the source of a hazardous substance release if it means that they must approach the hazardous substance release;- Remove all outdated spill response materials from employee files and postings;- Update all spill response plans with the maximum hazardous substance amount to which employees can safely respond and wording indicating that employees should not respond to hazardous substance releases that are below the spill response threshold unless they are safe to do so and understand the steps to be taken; and- Circulate the plans to employees and post the new plans in the workplace.

Concessioner Comments1. Does the concessioner agree with this audit finding (in Section II, Priority 1, 2, and 3 Regulatory Audit Findings)? Yes





YOSE004



N/A

Park Comments




NONE ENTERED



Audit Finding Number: YOSE004-08-2007-006Audit Finding:Employees were not trained on updated and consistent emergency action plan (EAP) documentation.Recommended Corrective Action:Train employees on an updated and consistent EAP:- Upon initial assignment (i.e., when a new employee is hired);- Whenever the employee's responsibilities or designated actions under the plan change; and- Whenever the plan is changed (e.g., when the EAP is changed regarding incidental spill thresholds).



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-007Audit Finding:It had not been determined whether or not the quantity of sulfuric acid stored in vehicle and equipment batteries triggered reporting (i.e., Tier I or Tier II) requirements under 40 CFR 355.30 and California Health and Safety Code, Section 25503.5.Recommended Corrective Action:Determine how many pounds of sulfuric acid are contained within Concessioner vehicles and equipment. If the quantity exceeds 500 pounds, the Concessioner needs to comply with 40 CFR 370.20 and submit a material safety data sheet (MSDS) for lead acid batteries as well as include sulfuric acid in the Concessioner's Tier I or II report. However, note that including appropriate information on the Concessioner's Hazardous Materials Business Plan and submitting it to the Certified Unified Program Agency





YOSE004

(CUPA) meets the requirements listed previously in this paragraph.

If the quantity of sulfuric acid is equal to or exceeds 1,000 pounds, the Concessioner must notify the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) that the Concessioner triggers this regulation. Also, if the quantity is equal to or exceeds 1,000 pounds, a representative from the Concessioner must participate in the LEPC.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-008Audit Finding:It was not ensured that that the volume available in aboveground storage tanks (ASTs) was greater than the volume of product to be transferred to the ASTs before the transfer was made. For example:- At Badger Pass, manual gauging was used by the Concessioner to determine the liquid level in ASTs, but this information was not provided to the fuel delivery operator;- At the Yosemite Valley garage, there was no means provided for determining the liquid level in each AST; and- At the Mariposa Grove, there was no means provided for determining the liquid level in each AST.Recommended Corrective Action:Ensure that the volume available in the ASTs is greater than the volume of product to be transferred to the ASTs before the transfer is made.



N/A


Park Comments




NONE ENTERED








YOSE004

Audit Finding Number: YOSE004-08-2007-009Audit Finding:Reports were not made to the implementing agency within 24 hours (or another reasonable time period specified by the implementing agency) when unusual operating conditions for the underground storage tank (UST) were observed. For example, the Veeder-Root unit dispensed a ticket which indicated a piping sump alarm had occurred on 8/1/07 at 8:30 pm, but staff at the time of the site visit on the afternoon of 8/2/07 had not investigated why the ticket had been dispensed.Recommended Corrective Action:Report to the implementing agency the unusual operating conditions observed unless the system equipment is found to be defective but not leaking. Immediately repair or replace defective equipment.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-010Audit Finding:A posted Mariposa County Health Department permit indicated that a 10,000-gallon diesel underground storage tank (UST) was registered as being operated and active. However, the Concessioner indicated that actions had been taken to close the UST since an alarm had sounded and the UST was found to no longer be usable.Recommended Corrective Action:Obtain an updated permit that indicates that the 10,000-gallon diesel UST is no longer being operated. Obtain documentation indicating that the UST has been properly closed.


Documentation has not yet been received.


Park Comments




DNC will receive final permit closure documentation upon completion of the project to remove the tank which is expected to be by mid-October.








YOSE004

Concession Environmental Audit System CommentsOnce the Park confirms that the Concessioner’s corrective action adequately addresses all components of the recommended corrective action, it will be closed by the Park.

Audit Finding Number: YOSE004-08-2007-011Audit Finding:Each container of hazardous chemicals in the workplace was not labeled, tagged, or marked with the following information:- Identity of the hazardous chemical(s) contained therein; and- Appropriate hazard warnings.

For example:- At the warehouse, there was an unlabeled spray bottle with a yellow liquid;- At the warehouse uniform room, there were two unlabeled containers;- At the Badger Pass shed, there was a corrosive container without hazard warnings that actually contained antifreeze;- At the Curry Village boiler room, there was an acid tank that was labeled as hydrochloric acid that did not have hazard warnings; - At Boys Town, there were four propane tanks that were unlabeled;- At Tuolumne Meadows, there was a fly spray bottle that did not include hazard warnings;- At Crane Flat service station, the 4000-gallon diesel aboveground storage tank (AST) did not have any labels or hazard warnings;- At Badger Pass, the diesel AST indicated that it had lead;- At Mariposa Grove, the diesel AST was labeled as used paint thinner, diesel, flammable, and combustible;- Concessionwide, there were multiple ASTs storing diesel that were labeled as flammable and combustible; and- Concessionwide, there were multiple propane tanks that were not labeled.Recommended Corrective Action:Ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with the following information:- Identity of the hazardous chemical(s) contained therein; and- Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information that is immediately available to employees under the hazard communication (HAZCOM) program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Ensure that labels or other forms of warning are legible, in English, and prominently displayed on the container, or are readily available in the work area throughout each work shift.

If the Concessioner becomes newly aware of any significant information regarding the hazards of a chemical, revise the labels for the chemical within three months of becoming aware of the new information.



N/A


Park Comments




NONE ENTERED








YOSE004

Audit Finding Number: YOSE004-08-2007-012Audit Finding:Compressed gas cylinders were not secured to prevent them from falling or being knocked over. For example, unsecured compressed gas cylinders included:- Carbon dioxide cylinders stored in the warehouse electric/refrigeration shop;- A carbon dioxide cylinder stored in the warehouse carpenter shop; and- An oxygen cylinder stored in the Yosemite Valley garage.Recommended Corrective Action:Secure compressed gas cylinders to prevent them from falling or being knocked over.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-013Audit Finding:The area surrounding the aboveground storage tank (AST) for gasoline was not kept free of vegetation.

The area around the AST for diesel was not kept free of combustible material since several small containers of propane were gang chained against the side of the AST.Recommended Corrective Action:Remove the vegetation growing around and brushing up against the gasoline AST.

Remove all containers of propane from the AST area.



Park Comments




NONE ENTERED








YOSE004


N/A

Audit Finding Number: YOSE004-08-2007-014Audit Finding:There were no "No Smoking" signs posted to prevent open flames and smoking by the flammable storage cabinet.Recommended Corrective Action:Post a conspicuous "No Smoking" sign to prevent open flames and smoking in flammable and combustible liquid storage areas.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-015Audit Finding:The Hazardous Material Business Plans (HMBPs) were not updated to reflect current operations. For example, the registration forms indicated that:- Fuel storage tank corrosion protection was "other"; however, a description of the type of corrosion protection used was not included;- Overfill protection for fuel storage tanks was "automatic shut-off" or "ballfloat"; however, this type of overfill protection was not always in place; and- The Valley Fuel Station HMBP indicated that three aboveground storage tanks (ASTs) were present when there were actually five.Recommended Corrective Action:Review all HMBPs to determine which sections should be updated.

Inform the Certified Unified Program Agency of revisions to the previously submitted HMBPs.


Park Comments



NONE ENTERED







YOSE004



N/A



Audit Finding Number: YOSE004-08-2007-016Audit Finding:It was not determined if solid waste was a hazardous waste. For example, it was not certain if the following were hazardous waste:- At the Curry Village ice rink, soil contaminated with calcium chloride solution when piping sprung a leak;- At Badger Pass, the oil-water solution produced from the maintenance shop and resulting residue after water had been boiled off;- At the Badger Pass boiler room, the substances in laboratory-type containers;- At Badger Pass, soil contaminated with oil in multiple locations; and- At Badger Pass, soil contaminated with fuel at the location of concern.Recommended Corrective Action:Determine if the waste is excluded from regulation under California Code of Regulations (CCR), Title 22, Chapter 12, Article 1, Section 66261.4 or the California Health and Safety Code, Section 25143.2.

If the waste is not excluded from regulation per the previous paragraph, determine if the waste is listed as a hazardous waste in CCR, Title 22, Chapter 11, Articles 4 or 4.1 or CCR, Title 22, Chapter 11, Appendix X. If the waste is listed in Appendix X and is not listed in Articles 4 or 4.1 of CCR, Title 22, Chapter 11, determine if the waste is not a hazardous waste by either:- Testing the waste according to the methods set forth in CCR, Title 22, Chapter 11, Article 3, or according to an equivalent method approved by the Department of Toxic Substances Control pursuant to CCR, Title 22, Chapter 10, Article 3, Section 66260.21; or- Applying knowledge of the hazard characteristic of the waste in light of the materials used and the characteristics set forth in CCR, Title 22, Chapter 11, Article 3.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-017Audit Finding:The Concessioner:- Did not reduce the volume of hazardous waste generated at Badger Pass from leaking gear boxes on chair lifts; and - Had not fixed all of the leakage from an emergency generator at Degnan's Deli.





YOSE004

Recommended Corrective Action:Minimize potential hazardous waste generation by preventing releases ofpetroleum products to the environment.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-018Audit Finding:Hazardous waste was being managed in satellite accumulation areas but not at or near the area where the waste was being generated and under the control of the operator of the process generating the waste. For example, the following hazardous wastes were not being managed at or near the area where they were generated:- Asbestos generated periodically Concessionwide being stored in the warehouse near the light room;- Polychlorinated Biphenyls (PCB) ballasts generated periodically Concessionwide being stored in the warehouse near the light room; - Used oil generated Concessionwide being stored in the warehouse machine shop; and- Waste antifreeze generated Concessionwide being stored in the warehouse machine shop.Recommended Corrective Action:Ensure that hazardous wastes being managed in satellite accumulation areas are actually generated at or near the area where the satellite accumulation areas are located. Otherwise, manage these hazardous wastes as those that are not being accumulated in satellite accumulation areas (e.g., the date on which they became a waste is the start date for storing the hazardous waste accumulation on-site).




Park Comments




DNC will seek Mariposa CUPA approval to manage satellite storage.








YOSE004

N/A

Audit Finding Number: YOSE004-08-2007-019Audit Finding:A Biennial Report, Environmental Protection Agency (EPA) Form 8700-13A/B, 5-80, (Revised 11-89), had not been prepared and submitted to the Department of Toxic Substances Control (DTSC) by March 1 of each even-numbered year.Recommended Corrective Action:Prepare and submit a Biennial Report, EPA Form 8700-13A/B, 5-80, (Revised 11-89), to the DTSC by March 1 of each even-numbered year. The Biennial Report should include:- The identification number, name, and address of the Concessioner;- The calendar year covered by the report;- The identification number, name, and address for each off-site transfer, treatment, storage or disposal facility in the United States to which waste was shipped during the year;- The name and identification number of each transporter used during the reporting year for shipments to a transfer, treatment, storage or disposal facility within the United States;- A description, EPA hazardous waste number (from CCR, Title 22, Chapter 11, Articles 3 or 4), California Hazardous Waste Category Number (from CCR, Title 22, Chapter 11, Appendix XII), DOT hazard class, and quantity of each hazardous waste shipped off-site to a transfer, treatment, storage or disposal facility within the United States. This information shall be listed by identification number of each such off-site facility to which waste was shipped. Wastes that are classified as non-Resource Conservation and Recovery Act (RCRA) hazardous wastes can be properly described by indicating a generic name of the waste and the phrase “Non-RCRA Hazardous Waste, Solid” or “Non-RCRA Hazardous Waste, Liquid” for solid or liquid wastes, respectively. When possible, the generic name shall be obtained from CCR, Title 22, Chapter 11, Appendix X, subdivision (e). If not listed, the commonly recognized industrial name of the waste shall be used;- A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated;- A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years to the extent such information is available for years prior to 1984; and- The certification signed by the generator or authorized representative.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-020Audit Finding:The name of each employee filling each job title for each position related to hazardous waste management was not documented.Recommended Corrective Action:Document and maintain on file the name of each employee filling each job title for each position related to hazardous waste management.





YOSE004



N/A


Park Comments




Due to employee turnover, DNC had not listed individual names of staff as it relates to hazardous materials responsibilities. DNC will contact the Mariposa CUPA for assistance with regulatory requirements.




Audit Finding Number: YOSE004-08-2007-021Audit Finding:A written respiratory protection program with required worksite-specific procedures and elements for required respirator use had not been updated.Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require additional respiratory protection and engineering controls or other means do not eliminate the need to use respirators, update the written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program should include:- Providing respirators which are applicable and suitable for the purpose intended;- A written respiratory protection program with worksite-specific procedures;- Selection of respirators;- Medical evaluations;- Fit testing;- Respirator use;- Maintenance and care of respirators;- Breathing air quality and use;- Identification of filters, cartridges, and canisters;- Training and information;- Program evaluation; and- Recordkeeping.


Park Comments




NONE ENTERED







YOSE004



N/A


Audit Finding Number: YOSE004-08-2007-022Audit Finding:A complete, current hazard evaluation had not been conducted to identify and evaluate the respiratory hazards in the workplace. Potential respiratory hazards included: - Dust; - Paint; - Pool chemicals; and- Plumbing chemicals.Recommended Corrective Action:Identify and evaluate the respiratory hazard(s) in the workplace. This evaluation should include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the Concessioner cannot identify or reasonably estimate the employee exposure, the Concessioner shall consider the atmosphere to be immediately dangerous to life or health.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-023Audit Finding:Procedures for the proper use of respirators had not been established and implemented.Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, prohibit respirators with tight-fitting facepieces to be worn by employees who have:- Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or- Any condition that interferes with the face-to-facepiece seal or valve function.

If an employee wears corrective glasses or goggles or other personal protective equipment, ensure that such equipment is worn in a manner that does not interfere with the seal of the facepiece to the face of the user.





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For all tight-fitting respirators, ensure that employees perform a user seal check each time they put on the respirator using the procedures in Appendix B-1 or procedures recommended by the respirator manufacturer that the Concessioner demonstrates are as effective as those in Appendix B-1 of 29 CFR 1910.134.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-024Audit Finding:Cleaning and disinfecting, inspection, and repair of respirators used by employees were not provided. For example:- At the warehouse carpenter shop, a respirator was stored out in the open (e.g., it was not stored in a bag to protect it from dust); - At the warehouse machine shop, a respirator was stored in an open bag in a cabinet;- At the warehouse visual design room, a filtering facepiece was stored out in the open;- At the Wawona Lodge boiler room, a half-mask respirator was observed stored out in the open;- At the Yosemite Lodge mechanic’s shop, a filtering facepiece was stored out in the open; and- At the Curry Village boiler room, the respirator used by the employee chlorinating the water for the swimming pool was not stored in his vehicle to protect it from the dust or other elements; the filters were also not stored in a bag to prevent them from becoming saturated with chemical vapors.Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide for the cleaning and disinfecting, inspection, and repair of respirators used by employees.

If voluntary respirator use is allowed, also provide for the cleaning and disinfecting, and repair of respirators used by employees.

Provide each respirator user with a respirator that is clean, sanitary, and in good working order. Ensure that respirators are cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134, or procedures recommended by the respirator manufacturer, provided that such procedures are of equivalent effectiveness. Ensure respirators are cleaned and disinfected at the following intervals:- Clean and disinfect respirators issued for the exclusive use of an employee as often as necessary to maintain them in a sanitary condition;- Clean and disinfect respirators issued to more than one employee before they are worn by different individuals;- Clean and disinfect respirators maintained for emergency use after each use; and- Clean and disinfect respirators used in fit testing and training after each use.

Store respirators to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. Pack and store respirators to prevent deformation of the facepiece and exhalation valve.

Ensure respirators are inspected as follows:





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- Before each use and during cleaning (for respirators used in routine situations);- At least monthly and in accordance with the manufacturer's recommendations (for respirators maintained for use in emergency situations), check respirators for proper function before and after each use; and- Before being carried into the workplace for use (for emergency escape-only respirators).

Ensure that respirator inspections include the following:- A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the facepiece, head straps, valves, connecting tube, and cartridges, canisters, or filters; and- A check of elastomeric parts for pliability and signs of deterioration.

Keep emergency respirators:- Accessible to the work area;- Stored in compartments or in covers that are clearly marked as containing emergency respirators; and- Stored in accordance with any applicable manufacturer instructions.

For respirators maintained for emergency use:- Certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who conducted the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and - Provide this information on a tag or label that is attached to the storage compartment for the respirator, is kept with the respirator, or is included in inspection reports stored as paper or electronic files. Maintain this information until replaced following a subsequent certification.

Ensure that respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded, repaired, or adjusted in accordance with the following procedures:- Repairs or adjustments to respirators are made only by persons appropriately trained to perform such operations and use only the respirator manufacturer's National Institute for Occupational Safety and Health (NIOSH)-approved parts designed for the respirator;- Repairs are made according to the manufacturer's recommendations and specifications for the type and extent of repairs to be performed; and- Repairs or adjustments to reducing and admission valves, regulators, and alarms are made by the manufacturer or a technician trained by the manufacturer.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-025Audit Finding:There was no process to ensure that employees using atmosphere-supplying respirators [supplied-air and SCBA (self-contained breathing apparatus)] were provided with breathing gases of high purity.





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Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide employees using atmosphere-supplying respirators (supplied-air and SCBA) with breathing gases of high purity.

Ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration meet the following specifications:- Compressed and liquid oxygen meet the United States Pharmacopoeia requirements for medical or breathing oxygen; and- Compressed breathing air meet at least the requirements for Grade D breathing air described in American National Standards Institute (ANSI))/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, including: - Oxygen content (v/v) of 19.5-23.5%; - Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less; - Carbon monoxide (CO) content of 10 parts per million (ppm) or less; - Carbon dioxide content of 1,000 ppm or less; and - Lack of noticeable odor.

Ensure that compressed oxygen is not used in atmosphere-supplying respirators that have previously used compressed air.

Ensure that oxygen concentrations greater than 23.5% are used only in equipment designed for oxygen service or distribution.

Ensure that cylinders used to supply breathing air to respirators meet the following requirements:- Cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR part 173 and part 178);- Cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and- The moisture content in the cylinder does not exceed a dew point of -50 degrees Fahrenheit (-45.6 degrees Centigrade) at 1 atmosphere pressure.

Ensure that compressors used to supply breathing air to respirators are constructed and situated so as to:- Prevent entry of contaminated air into the air-supply system;- Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees Fahrenheit (5.56 degrees Centigrade) below the ambient temperature;- Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Maintain and replace sorbent beds and filters, or refurbish them periodically following the manufacturer's instructions; and- Have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. Maintain the tag at the compressor.

For compressors that are not oil-lubricated, ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm.

For oil-lubricated compressors, use a high-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, monitor the air supply at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm.

The employer shall use breathing gas containers marked in accordance with the National Institute for Occupational Safety and Health (NIOSH) respirator certification standard, 42 CFR part 84. Ensure that breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems. Do not introduce asphyxiating substances into breathing air lines.

Use breathing gas containers marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.


Park Comments


NONE ENTERED







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Audit Finding Number: YOSE004-08-2007-026Audit Finding:Effective training had not been provided to employees who were required to use respirators. In addition, the basic advisory information on respirators, as presented in Appendix D of the Respiratory Protection Standard (29 CFR 1910.134), was not provided to employees who wore respirators voluntarily.Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, provide effective training to employees who are required to use respirators. Provide the training prior to requiring employees to use respirators in the workplace.

Ensure that each employee can demonstrate knowledge of at least the following:- Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;- What the limitations and capabilities of the respirator are;- How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;- How to inspect, put on and remove, use, and check the seals of the respirator;- What the procedures are for maintenance and storage of the respirator;- How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators; and- The general requirements of 29 CFR 1910.134.

If the Concessioner can demonstrate that new employees have received training within the last 12 months that addresses the elements listed in the previous paragraph, it is not required to repeat such training provided that the employee can demonstrate knowledge of those element(s).

Previous training not repeated initially by the employer must be provided no later than 12 months from the date of the previous training.

Retrain annually and when the following situations occur:- When changes in the workplace or the type of respirator render previous training obsolete;- Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or- Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Provide the basic advisory information on respirators in any written or oral format, as presented in Appendix D of the Respiratory Protection Standard (29 CFR 1910.134), to employees who wear respirators voluntarily.


Park Comments


NONE ENTERED







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Audit Finding Number: YOSE004-08-2007-027Audit Finding:Evaluations of the workplace had not been conducted to ensure that the written respiratory protection program was being properly implemented, and the Concessioner did not consult employees to ensure that they were using the respirators properly.Recommended Corrective Action:If the hazard evaluation (see related audit finding) identifies that workplace hazards exist that would require a respiratory protection program and engineering controls or other means do not eliminate the need to use respirators, conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented and to consult employees to ensure that they are using the respirators properly.

Conduct evaluations of the workplace as necessary to ensure that the provisions of an updated written program are being effectively implemented and that it continues to be effective.

Regularly consult employees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Correct any problems that are identified during this assessment. Factors to be assessed include, but are not limited to:- Respirator fit (including the ability to use the respirator without interfering with effective workplace performance);- Appropriate respirator selection for the hazards to which the employee is exposed;- Proper respirator use under the workplace conditions the employee encounters; and- Proper respirator maintenance.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-028Audit Finding:All solid wastes and materials separated for the purpose of recycling were not stored in such a manner so that they did not provide





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food or harborage for vectors. For example, at the Curry Village, Wawona, and Tuolumne Meadows stables, the large solid waste containers for manure were not always covered to prevent the harborage of vectors.Recommended Corrective Action:Cover large solid waste containers for manure to prevent the harborage of vectors.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-029Audit Finding:A determination of substantial harm had not been completed and maintained in the Concessioner's Spill Prevention Control and Countermeasure (SPCC) plans.Recommended Corrective Action:Determine whether Concessioner facilities pose substantial harm to the environment by using the flowchart in Attachment C-I to Appendix C to 40 CFR 112.- If it is determined that Concessioner facilities pose substantial harm to the environment, develop and implement a facility response plan as a part of the SPCC plan.- If it is determined that Concessioner facilities do not pose substantial harm to the environment, ensure that the "Certification for Facilities That Do Not Pose Substantial Harm" is included in the Concessioner SPCC Plan.



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Park Comments




NONE ENTERED








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Audit Finding Number: YOSE004-08-2007-030Audit Finding:A Spill Prevention Control and Countermeasure (SPCC) plan had not been developed for the warehouse.Recommended Corrective Action:Develop and document an SPCC plan. Ensure that it contains the following information:- Discussion of the Concessioner's conformance with requirements listed in the SPCC regulations;- Description of the physical layout of the Concessioner operations including a diagram which marks the location and contents of each oil storage container (the diagram must include completely buried tanks that are otherwise exempt from the SPCC Plan and must also include all transfer stations and connecting pipes);- Description of the types of oil in each container and each container's storage capacity;- Prevention measures to avoid discharges including procedures for routine handling of products (loading, unloading, transfers);- Description of discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of discharge;- Explanation of countermeasures for discharge discovery, response, and cleanup (both Concessioner's capability and those that might be required of a contractor);- Description of methods of disposal of recovered materials;- List of contacts and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom the Concessioner has an agreement for response, and all appropriate Federal, state, and local agencies who must be contacted in case of a discharge;- Information and procedures to enable a person reporting a discharge to relate information on the exact address or location and phone number of the Concessioner, the date and time of the discharge, the type of material discharged, estimates of the total quantity discharged, the source and cause of the discharge, a description of all affected media, any damages or injuries caused by the discharge, actions being used to stop, remove, and mitigate the effects of the discharge, whether an evacuation may be needed, and the name of individuals and/or organizations who have also been contacted (these procedures must be organized in the SPCC plan in a manner that is easy to use during an emergency);- Prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the Concessioner as a result of each type of major equipment failure (loading and unloading equipment, tank overflow, rupture, leakage);- Inspection and testing procedures for containers;- Provision of an oil spill contingency plan; and - A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

Also ensure the SPCC plan:- Has the full approval of management at a level of authority to commit the necessary resources to fully implement the SPCC plan; and- Is maintained on-site and available for review by the Regional Environmental Protection Agency (EPA) Administrator.



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Park Comments




NONE ENTERED








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Audit Finding Number: YOSE004-08-2007-031Audit Finding:The Spill Prevention Control and Countermeasure (SPCC) plans had not been updated to include tanks with a capacity equal to or greater than 55-gallons that materially affected the potential for a discharge. For example, the following were not included in SPCC plans:- A gear box at Badger Pass for one of the chairlifts;- A day tank at the Badger Pass boiler room; - 55-gallon containers of used and new oil at the garage, Crane Flat service station, and Badger Pass; and- Kitchen grease storage areas.

The SPCC plan for the garage did not accurately reflect the current conditions observed during the visit. For example, it stated that the four indoor used oil tanks had secondary containment, but they were single-walled and did not have any other secondary containment.

The SPCC plan for the Crane Flat service station did not accurately reflect the current conditions observed during the visit. For example:- One version of the SPCC plan had crossed out in pencil the 1,000-gallon diesel aboveground storage tank (AST) which was no longer used. However, since the 1,000-gallon AST has not yet been removed, it should remain a part of the SPCC plan since it has the potential to store oil; and- The 4,000-gallon diesel AST was handwritten into the SPCC plan, but did not indicate that it was compartmentalized where 1,000 gallons fed the generator and 3,000 gallons supplied fuel to the service station dispensers.Recommended Corrective Action:Update and implement the SPCC plans, including amendments that account for changes in the facility design, construction, operation, or maintenance that materially affect the potential for a discharge. Ensure that the updates include an accurate facility map detailing the location of applicable containers.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-032Audit Finding:The contact list and phone numbers had not been updated in the Spill Prevention Control and Countermeasure (SPCC) plans.Recommended Corrective Action:Update the contact list and phone numbers in the SPCC plans. Contact information should include phone numbers for the:- Facility response coordinator;- National Response Center;- Clean-up contractors for which there is an agreement for response; and





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- All appropriate Federal, state, and local agencies who must be contacted in case of a discharge.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-033Audit Finding:An appropriate containment and/or diversionary structure or equipment to prevent an oil discharge was not available for:- The Yosemite Village garage 55-gallon motor oil and used oil containers and for the four aboveground storage tanks (ASTs) holding oil;- The Crane Flat 55-gallon container storing oil; and- The Badger Pass 55-gallon containers storing oil.Recommended Corrective Action:Provide adequate secondary containment for all 55-gallon containers storing petroleum products and the four ASTs holding oil.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-034Audit Finding:The Spill Prevention Control and Countermeasures (SPCC) plan did not clearly indicate that Concessioner staff were trained to ensure that they would not respond to a spill unless it was safe to do so (i.e., they must be leaving the area of a spill in order to





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respond).Recommended Corrective Action:Train oil-handling personnel in discharge procedure protocols and the contents of the SPCC plan.

Schedule and conduct discharge prevention briefings for oil-handling personnel at least once per year to assure adequate understanding of the SPCC plan.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-035Audit Finding:The aboveground storage tank (AST) located near the employee parking lot which was used for the emergency generator was not fenced.Recommended Corrective Action:Fence the area around the AST for the emergency generator and ensure it is locked when unattended.



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Park Comments




NONE ENTERED









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Audit Finding:Facility lighting was not provided to assist with the discovery of discharges occurring during hours of darkness and prevent discharges occurring through acts of vandalism. For example:- The Valley Fuel Station dispensing area had lighting at nighttime, but the aboveground storage tanks (ASTs) did not have lighting; and- The Mariposa Grove ASTs did not have lighting at nighttime.Recommended Corrective Action:Provide facility lighting commensurate with the type and location of the facility to assist with the discovery of discharges occurring during hours of darkness and prevent discharges occurring through acts of vandalism.


Night time lighting installation may exceed 180 day requirement to close finding.Concession Environmental Audit System Comments

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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-037Audit Finding:A regular schedule for inspecting the integrity of aboveground containers, such as aboveground storage tanks, was not included in the Spill Prevention Control and Countermeasure (SPCC) plan.Recommended Corrective Action:Test each aboveground container for integrity on a regular schedule.

The frequency and type of testing must take into account container size and design (such as floating roof, skid-mounted, elevated, or partially buried). Combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing.

Keep comparison records and inspect the container's supports and foundations. In addition, frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas.


Park Comments




NONE ENTERED







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Audit Finding Number: YOSE004-08-2007-038Audit Finding:Not all universal waste was recycled. For example:- Burned out fluorescent lamps were disposed of in the regular solid waste stream at Badger Pass;- Some batteries, including alkaline batteries, were disposed of in the regular solid waste stream Concessionwide; and- Some aerosol cans were disposed of in the regular solid waste stream Concessionwide.Recommended Corrective Action:Recycle all universal waste including:- Fluorescent lamps;- Batteries (including alkaline batteries); and- Aerosol cans.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-039Audit Finding:Universal waste batteries were not always managed in a way that prevented releases of any universal waste or component of a universal waste to the environment. For example, some universal waste batteries, such as alkaline batteries, were disposed of in the regular solid waste.

Universal waste lamps were not stored in containers and packages that remained closed. For example:- At the warehouse, universal waste lamps were stored in boxes that had open tops;- At the Yosemite Lodge housekeeping office, universal waste lamps were stored in a container that could not be closed due to the length of the universal waste lamps;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not stored in a container; and- At the Ahwahnee boiler room, universal waste lamps were stored in containers that could not be closed due to the length of the universal waste lamps.Recommended Corrective Action:Recycle all universal waste batteries.





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Store universal waste lamps in containers and packages that remain closed unless additional universal waste lamps are being added to the containers and packages.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-040Audit Finding:Not all universal waste batteries and lamps were labeled or marked to identify the type of universal waste. For example:- At the warehouse light room, some universal waste lamps were labeled as “sick”;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not labeled;- At the Ahwahnee boiler room, universal waste lamps were stored in containers that were not labeled; and- At the Badger Pass maintenance area, batteries from cats and ski lifts were not labeled prior to being picked up by maintenance for recycling.Recommended Corrective Action:Clearly label or mark universal waste batteries (i.e., each battery) or a container in which the batteries are stored with any one of the following phrases: “Universal Waste--Battery(ies)," or “Waste Battery(ies),” or “Used Battery(ies).”

Clearly label or mark universal waste lamps or containers or packages in which such lamps are stored, with one of the following phrases: “Universal Waste--Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s).”



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Park Comments




NONE ENTERED








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Audit Finding Number: YOSE004-08-2007-041Audit Finding:It could not always be demonstrated the length of time that universal waste had been accumulated from the date it became a waste. For example:- Some types of universal waste batteries and lamps were disposed of in the regular solid waste;- At the Badger Pass maintenance area, approximately eight fluorescent lamps were not labeled with a date; and- At the Ahwahnee boiler room, universal waste lamps were stored in containers that were not labeled with a date.Recommended Corrective Action:Demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste by:- Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received;- Marking or labeling each individual item of universal waste (e.g., each battery or lamp) with the date it became a waste or was received;- Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received;- Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received;- Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or- Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-042Audit Finding:Not all employees were aware of proper handling and emergency procedures appropriate to the type(s) of universal waste handled at Concessioner facilities. For example:- Not all employees were aware that certain types of batteries (e.g., alkaline) should be managed as universal waste; and - Employees at Badger Pass were not aware that used fluorescent lamps should be managed as universal wastes.Recommended Corrective Action:Inform all employees who handle or have responsibility for managing universal waste as to proper handling and emergency procedures appropriate to the type(s) of universal waste handled at Concessioner facilities.






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Park Comments




NONE ENTERED



Audit Finding Number: YOSE004-08-2007-043Audit Finding:A record of each shipment of universal waste sent from the handler to other facilities was not maintained for at least three years since some types of universal waste batteries and lamps were disposed of in the regular solid waste.Recommended Corrective Action:Maintain a record of each shipment of universal waste sent to other facilities. Ensure the record includes the following information:- The name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent;- The quantity of each type of universal waste sent (e.g., batteries, thermostats, lamps, mercury switches, etc.); and- The date the shipment of universal waste left the facility.

Maintain the records for at least three years from the date a shipment of universal waste left the facility.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-044Audit Finding:Universal waste aerosol cans were sometimes disposed of in the regular solid waste stream. For example:- At the Housekeeping Camp, aerosol cans were disposed of in the regular solid waste stream; and- At the Badger Pass maintenance area, aerosol cans were disposed of in the regular solid waste stream.





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Recommended Corrective Action:Recycle universal waste aerosol cans.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-045Audit Finding:Universal waste aerosol cans were not always stored in accumulation containers that were:- Structurally sound and compatible with the contents of the universal waste aerosol can;- Covered at the end of each workday;- Placed in a location that had sufficient ventilation to avoid formation of an explosive atmosphere, and designed, built, and maintained to withstand pressures reasonably expected during storage and transportation; and - Labeled or marked clearly with one of the following phrases: “Universal Waste-Aerosol Cans,” “Waste Aerosol Cans,” or “Used Aerosol Cans.”Recommended Corrective Action:Store universal waste aerosol cans in containers that are:- Structurally sound and compatible with the contents of the universal waste aerosol can;- Covered at the end of each workday;- Placed in a location that has sufficient ventilation to avoid formation of an explosive atmosphere, and designed, built, and maintained to withstand pressures reasonably expected during storage and transportation; and- Labeled or marked clearly with one of the following phrases: “Universal Waste-Aerosol Cans,” “Waste Aerosol Cans,” or “Used Aerosol Cans.”


Unless item has been resolved Concession-wide as identified in the report, the Park does not recommend closure of this finding.


Park Comments

2. Does the Park agree with the Concessioner's comments above for this audit finding? . . . . . . . . . . . . . . . . . . . . . No1. Does the Park agree with this audit finding? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes



Recommend Closure: Issues related to aerosol can waste management have been resolved at the Garage.








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Concession Environmental Audit System CommentsOnce the Park confirms that the Concessioner’s corrective action adequately addresses all components of the recommended corrective action, it will be closed by the Park.

Audit Finding Number: YOSE004-08-2007-046Audit Finding:The unit used to process the universal waste aerosol cans was not placed on or above a nonearthen floor that was free of cracks or gaps and sufficiently impervious and bermed to contain leaks and spills.

A written operating procedure detailing the safe processing of universal waste aerosol cans was not developed and implemented.Recommended Corrective Action:Place the unit used to process universal waste aerosol cans on or above a nonearthen floor that is free of cracks or gaps and sufficiently impervious and bermed to contain leaks and spills.

Develop and implement a written operating procedure detailing the safe processing of universal waste aerosol cans. The written operating procedure should, at a minimum, include all of the following:- The type of equipment to be used to process the universal waste aerosol cans safely;- Operation and maintenance of the unit;- Segregation of incompatible wastes;- Proper waste management practices, including ensuring that flammable wastes are stored away from heat and open flames; and- Waste characterization.


Park is working on verification.Concession Environmental Audit System Comments

Once the Park confirms that the Concessioner’s corrective action adequately addresses all components of the recommended corrective action, it will be closed by the Park.


Park Comments




Recommend Closure: Aerosol can waste container has been double-contained.




Audit Finding Number: YOSE004-08-2007-047Audit Finding:Notification was not submitted to the Certified Unified Program Agency (CUPA) that described the Concessioner's universal waste aerosol can processing activities.Recommended Corrective Action:Submit a notification to the CUPA that describes the Concessioner's universal waste aerosol can processing activities. The notification should include, but not be limited to:- The name, identification number, site address, mailing address, and telephone number of the Concessioner;- A description of the universal waste aerosol can processing activities, including the type and estimated volumes or quantities of universal waste aerosol cans to be processed monthly, the treatment process or processes, equipment descriptions, and design capacities; and





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- A description of the characteristics and management of any hazardous treatment residuals.

Within 30 days of any change in operation which necessitates modifying any of the information submitted in the notification, submit an amended notification to the CUPA.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-048Audit Finding:Containers of used oil were not labeled. Unlabeled containers were found in the following locations:- Yosemite Valley garage; and- Badger Pass maintenance building.Recommended Corrective Action:Label all containers and piping containing used oil with the words "Used Oil."



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-049Audit Finding:A plan to reduce consumption of electrical energy had not been developed and submitted to the Park for review and approval.





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Recommended Corrective Action:Prepare a plan to reduce consumption of electrical energy and submit it to the Park for review and approval.



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Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-050Audit Finding:Where a secondary containment tank was used to provide spill control for an aboveground storage tank (AST), the AST did not always have means provided to prevent overfilling by sounding an alarm when the liquid level in the tank reached 90 percent of capacity and by automatically stopping delivery of liquid to the tank when the liquid level in the tank reached 95 percent of capacity. For example, this was the case for:- Badger Pass ASTs;- Degnan's Deli emergency generator AST; and- Mariposa Grove ASTs.

In addition, the Degnan's Deli emergency generator AST was not capable of resisting the damage from the impact of a motor vehicle.Recommended Corrective Action:Ensure that means is provided to prevent overfilling ASTs (where a secondary containment tank is used to provide spill control) by sounding an alarm when the liquid level in the tank reaches 90 percent of capacity and by automatically stopping delivery of liquid to the tank when the liquid level in the tank reaches 95 percent of capacity.

Provide suitable collision barriers to protect the Degnan's Deli AST from the impact of a motor vehicle. For example, install concrete reinforced bollards surrounding the emergency generator. Alternatively, relocate the generator (since it is mobile) to a location where there is no traffic.


Park Comments




This item and #052 are redundant. Combine findings into one citation. TM Service Station does not have an AST on site – remove this site upon submittal of final audit report.







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The Park is uncertain that #050 and #052 are redundant.Concession Environmental Audit System Comments

See #052 for comments and explanation.


Audit Finding Number: YOSE004-08-2007-051Audit Finding:Protection was not provided to prevent damage to the aboveground tank located behind the gift shop where it might be exposed to vehicular impact.Recommended Corrective Action:Provide protection, such as bollards or fencing, to prevent damage to the aboveground tank where it might be exposed to vehicular impact.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-052Audit Finding:An approved means was not provided to stop delivery of liquid to the tank prior to the complete filling of the tank. For example, this occurred at:- The Valley Fuel Station; - The Wawona Hotel; and- The Crane Flat service station.Recommended Corrective Action:Develop, document, and implement an approved means to stop delivery of liquid to the tank prior to the complete filling of the tank.


Park Comments



See #050 for comments.







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The Park is uncertain that #050 and #052 are redundant.Concession Environmental Audit System Comments

The regulatory citation below (NFPA 30 4.6.1.5.2) is very similar to the citation from #050 (NFPA 30 4.3.2.3.3) with regards to overfill prevention - both indicate that means shall be provided to prevent overflow. However, NFPA 30 4.6.1.5.2 is general and NFPA 30 4.3.2.3.3 provides details regarding the specified means for preventing overfills. For example, NFPA 30 4.3.2.3.3 states that an alarm must sound once the tank reaches 90% capacity and also indicates that equipment must be installed which is capable of automatically stopping the delivery of liquid to the tank when the liquid level in the tank reached 95% capacity.

In addition, NFPA 30 4.3.2.3.3 details that "Means shall be provided for determining the level of liquid in the tank. This means shall be accessible to the delivery operator." Auditors noted that aboveground storage tanks at sites such as Badger Pass and Mariposa Grove did not have fuel gauges and/or inventory logs were not maintained and made accessible to the fuel delivery driver.

Also, NFPA 30 4.3.2.3.3 provides details for the vehicle impact protection requirements which are not detailed in NFPA 30 4.6.1.5.2.

The Tuolumne Meadows service station has been removed from the list of properties identified with ASTs and replaced with the correct AST which was identified at the Wawona Hotel.



Audit Finding Number: YOSE004-08-2007-053Audit Finding:Aboveground storage tanks (ASTs) at service stations were not enclosed with a chain link fence at least 1.8 meters (6 feet) high that were separated from the ASTs by at least 3 meters (10 feet) with a gate secured against unauthorized entry. For example:- At the Yosemite Valley fuel station, a wooden fence was closer than 10 feet to the ASTs;- At the Crane Flat service station, a wooden fence was closer than 10 feet to the ASTs;- At Badger Pass, there was no chain link fence surrounding the ASTs; and- At Mariposa Grove, a wooden fence was closer than 10 feet to the ASTs.Recommended Corrective Action:Enclose ASTs in areas dispensing fuel to vehicles with a chain link fence at least 1.8 meters (6 feet) high.

Ensure that the fence is separated from the ASTs by at least 3 meters (10 feet) and has a gate that is secured against unauthorized entry.


NONE ENTERED


Park Comments




This item will have to go through the NPS NEPA process and may exceed 180 day Priority 2 deadline due to planning and compliance required to implement. Fences affect landscape and land assignment issues in YNP. Some locations have seasonal access.








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Concession Environmental Audit System CommentsN/A

Audit Finding Number: YOSE004-08-2007-054Audit Finding:A listed hose assembly was not used to dispense fuel.Recommended Corrective Action:Use only listed hose assemblies to dispense fuel.





Park Comments




UL hose assembly installed at BTT fuel tank – close item #54




Audit Finding Number: YOSE004-08-2007-055Audit Finding:A listed emergency breakaway device designed to retain liquid on both sides of the breakaway point was not installed on each hose dispensing Class I and II liquids.Recommended Corrective Action:Install a listed emergency breakaway device designed to retain liquid on both sides of the breakaway point on the hose used to dispense gasoline from the aboveground storage tank (AST).

Install and maintain the listed emergency breakaway device designed to retain liquid on both sides of the breakaway point in accordance with the manufacturers’ instructions.



Park Comments




Breakaway hose installed at BTT fuel tank – close item #55.








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Audit Finding Number: YOSE004-08-2007-056Audit Finding:Fuel dispensing systems’ emergency shutoff devices or electrical disconnects were not provided or were not installed less than 6 meters (20 feet) from the fuel dispensing devices that they served. For example:- The emergency shutoff switch for the aboveground storage tanks (ASTs) at Badger Pass were installed within 20 feet of the dispensing equipment; and- There was no emergency shutoff switch for the ASTs at Mariposa Grove.

It was not certain whether the emergency shutoff switch for the fueling facilities at the Wawona service station was within 20 feet of the dispensing equipment.Recommended Corrective Action:Provide fuel dispensing systems with one or more clearly identified emergency shutoff devices or electrical disconnects. Such devices or disconnects should be installed in approved locations but not less than 6 meters (20 feet) or more than 30 meters (100 feet) from the fuel dispensing devices that they serve.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-057Audit Finding:Accurate daily inventory records were not maintained and reconciled for all liquid fuel storage tanks at service stations for indication of possible leakage from tanks or piping. For example, daily inventory records were not maintained and reconciled at:- Valley Fuel Station aboveground storage tanks (ASTs);- Crane Flat service station underground storage tanks (USTs) and ASTs;- Tuolumne Meadows service station USTs;- Wawona Lodge AST;- Mariposa Grove ASTs;- Badger Pass ASTs; and- Wawona service station USTs.Recommended Corrective Action:Maintain accurate daily inventory records and reconcile the amount of product sold or used to the amount of inventory on hand for





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all liquid fuel storage tanks for indication of possible leakage from the AST. Keep records on the premises or make them available to the authority having jurisdiction for inspection within 24 hours of a written or verbal request.

Where there is more than one storage system serving an individual pump or dispensing device for any product, maintain reconciliation separately for each system.





Park Comments




DNC operated AST’s need to meet the requirement, however UST’s listed at Service Station locations do have daily inventory reconciliation which occurs during daily financial and end of shift reporting.




Audit Finding Number: YOSE004-08-2007-058Audit Finding:The fuel delivery vehicle was not separated from the aboveground storage tank (AST) by at least 7.6 meters (25 feet) when delivering a Class I liquid, or 4.6 meters (15 feet) for non-Class I liquids. For example:- At the Yosemite Valley fuel station, Badger Pass, and Mariposa Grove, gasoline was delivered within 25 feet of the gasoline ASTs; and- At the Yosemite Valley fuel station, Badger Pass, and Mariposa Grove, diesel was delivered within 15 feet of the diesel ASTs.Recommended Corrective Action:Ensure that fuel delivery vehicles are separated from gasoline ASTs by at least 25 feet and from diesel ASTs by at least 15 feet when delivering fuel.



N/A


Park Comments




NONE ENTERED








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Audit Finding Number: YOSE004-08-2007-059Audit Finding:Warning signs were not conspicuously posted in the dispensing area and did not incorporate the following or equivalent wording:"W A R N I N G - It is unlawful and dangerous to dispense gasoline into unapproved containers. - No smoking. - Stop motor. - No filling of portable containers in or on a motor vehicle. - Place container on ground before filling."

For example, warning signs with all of the information above were not posted at:- Tuolumne Meadows service station;- Crane Flat service station;- Wawona service station;- Wawona Lodge;- Mariposa Grove; and- Badger Pass.Recommended Corrective Action:Conspicuously post warning signs in the dispensing area that incorporate the following or equivalent wording:"W A R N I N G - It is unlawful and dangerous to dispense gasoline into unapproved containers. - No smoking. - Stop motor. - No filling of portable containers in or on a motor vehicle. - Place container on ground before filling."



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-060Audit Finding:Operating instructions posted by the fuel dispensers did not include the location of emergency controls. For example, the location of the emergency shutoff switch was not posted at:- Tuolumne Meadows service station;- Crane Flat service station;- Wawona service station;- Wawona Lodge;





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- Mariposa Grove; and- Badger Pass.Recommended Corrective Action:Post operating instructions by the fuel dispensers to indicate where the emergency shutoff switch is located.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-061Audit Finding:Emergency instructions posted in the dispenser area did not indicate the following or equivalent wording:"In case of fire or spill (1) Use emergency stop button. (2) Report accident by calling (specify local fire number) on the phone. Report location."

Emergency instructions were not posted in the following areas:- Wawona Lodge;- Mariposa Grove; and- Badger Pass.Recommended Corrective Action:Emergency instructions shall be conspicuously posted in the dispenser area. The instructions shall incorporate the following or equivalent wording:"In case of fire or spill (1) Use emergency stop button. (2) Report accident by calling (specify local fire number) on the phone. Report location."


Park Comments




NONE ENTERED







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N/A


Audit Finding Number: YOSE004-08-2007-062Audit Finding:Fertilizer was being used as a deicer.Recommended Corrective Action:Prohibit the use of fertilizer as a deicer and use only Park-approved deicer when needed.


NPS documented on 2004 Badger Pass Periodic Concession Evaluation Report concern for concessioner using fertilizer as a deicer. NPS and DNC have discussed issue periodically over several years. In February 2007, NPS formally requested DNC to discontinue use of fertilizer immediately and recommended Green Fire Ice Melter.

Concession Environmental Audit System CommentsConcurred with Park comments. The audit finding was not changed.


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-063Audit Finding:A written landscaping plan had not been prepared and submitted to the Park for approval.Recommended Corrective Action:Prepare a written landscaping plan and submit it to the Park for approval. The written landscaping plan should include, but is not limited to the following:- General statements regarding the desired regime (manicured, natural, etc.) and the condition of the area and sub areas, as appropriate;- Specific information including plant and seed lists, locations, and scope of work proposed, safety and resource considerations, debris disposal, and proposed use of irrigation systems; and- Appropriate use of native vegetation, need for revegetation/restoration efforts, and the potential existence of cultural landscapes.


Park Comments


NONE ENTERED







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The Concessioner has submitted written landscape maintenance plans for The Ahwahnee and Wawona Hotel, but not for other land assigned areas. NPS approved The Ahwahnee plan in 1996.

Concession Environmental Audit System CommentsConcurred with Park comments. The audit finding was not changed.




Audit Finding Number: YOSE004-08-2007-064Audit Finding:A list had not been provided to the Park of service companies who deliver hazardous materials within Park boundaries and have personnel with necessary expertise to provide hazardous materials training to Concessioner and Park emergency response teams for the specific materials transported to the Park.Recommended Corrective Action:Provide a list to the Park of service companies who deliver hazardous materials within Park boundaries and have personnel with necessary expertise to provide hazardous materials training to Concessioner and Park emergency response teams for the specific materials transported to the Park.


See attached Excel spreadsheet.Concession Environmental Audit System Comments

Attached spreadsheet was reviewed and meets criteria detailed in finding. Recommend the finding be closed.


Park Comments


3. Does the Park believe that the audit finding should be closed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes


Recommend Closure: A list of vendors with an attached letter has been sent to NPS Superintendent dated 10-15-07. Annual spill response training does cover types of haz mat products stored on site and transported to and from YNP.




Audit Finding Number: YOSE004-08-2007-065Audit Finding:The Concessioner's Hazardous Materials Business Plans (HMBPs) had not been sent to the Park for approval.Recommended Corrective Action:Submit HMBPs to the Park for approval.



NONE ENTERED







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N/A

Park Comments




Audit Finding Number: YOSE004-08-2007-066Audit Finding:There was a minimum of four flammable storage cabinets observed in one fire area.Recommended Corrective Action:Ensure that there are not more than three flammable storage cabinets located in a fire area.

Consider conducting an inventory of all items contained in each of the four flammable storage cabinets. Consolidate flammable materials into a maximum of three flammable storage cabinets; store non-flammable materials elsewhere (i.e., not in the flammable storage cabinets).

Another option is to relocate one flammable storage cabinet to a different fire area.





Park Comments




Recommend Closure: Flammable Cabinet has been removed at the Garage and relocated for use at another DNC site storing flammable products.




Audit Finding Number: YOSE004-08-2007-067Audit Finding:Class I liquids such as white gas were stored in basements.Recommended Corrective Action:Ensure that Class I liquids are not stored in basements.






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N/A

Park Comments




NONE ENTERED



Audit Finding Number: YOSE004-08-2007-068Audit Finding:Class III liquids (kitchen grease) and combustible commodities (camping fuel and propane) were stored in a warehouse that was not equipped with automatic sprinklers in accordance with National Fire Protection Association 13 for 20 feet high storage of Class IV commodities.Recommended Corrective Action:Install automatic sprinklers for 20 feet high storage of Class IV commodities as defined in NFPA 13.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-069Audit Finding:Ordinary combustible commodities were not separated from liquids in containers by a minimum of 2.4 meters (i.e., eight feet). For example, the distance between the storage of kitchen grease and containers of propane and camping fuel (combustible commodities) was less than eight feet.Recommended Corrective Action:Ensure that kitchen grease containers are separated from any other combustible commodity by at least eight feet.






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N/A

Park Comments




NONE ENTERED



Audit Finding Number: YOSE004-08-2007-070Audit Finding:A Pesticide Use Proposal was not annually submitted to the Park for the use of pesticides. Pesticides for which a Pesticide Use Proposal had not been annually submitted included:- Flying Insect Killer found at the Curry Village stables;- Sling Shot Death Blow Crawling Insect Killer found at the Badger Pass maintenance building;- CB-40 Insecticide found at the Badger Pass maintenance building;- Raid found at the Badger Pass maintenance building, warehouse paint storage room, and Ahwahnee Hotel housekeeping area;- Wasp and Hornet Spray found at the Ahwahnee Hotel housekeeping area;- GLB Algyimycin 2000 found at the Curry Village Boiler Room; - Wasp Freeze;- 565 Plus XLO;- Sani-Chlor pool chlorinating tablets found at the Ahwahnee boiler room;- Repel-X fly spray;- Tri-tech fly repellent;- End Bac II Virucidal Spray Disinfectant found at the Yosemite Valley garage; and- Pesticides applied by the Concessioner's pesticide contractor, Paramount Pest Control.Recommended Corrective Action:Obtain a list of pesticides that Paramount Pest Control is using or will potentially use in Concessioner facilities.

Compile a list of pesticides that are proposed to be used by the Concessioner, Paramount Pest Control, and any other pesticides that are being or will be potentially used by the Concessioner. Submit this list to the Park and request permission to use these pesticides prior to actually using them. Coordinate with the Park to ensure that the Park can meet the December 31st deadline for pesticide approval. If the request is granted, direct Paramount Pest Control to use the pesticides according to manufacturer's and Park directions, and also direct Concessioner staff to use pesticides according to manufacturer's and Park directions. If the request is not granted, prohibit use and dispose of pesticides according to Applicable Laws.

Once permission is granted for pesticides currently being used, ensure that permission is obtained from the Park Integrated Pest Management (IPM) Coordinator before any other pesticides are purchased in the future.


Park Comments1. Does the Park agree with this audit finding? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes


NONE ENTERED







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N/A

2. Does the Park agree with the Concessioner's comments above for this audit finding? . . . . . . . . . . . . . . . . . . . . . NA3. Does the Park believe that the audit finding should be closed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . No


Audit Finding Number: YOSE004-08-2007-071Audit Finding:An annual report documenting the types and amounts of pesticides used (i.e., a Pesticide Use Log) was not submitted to the Park so that the Park could report its pesticide use data by the April 15th deadline. Pesticides for which a Pesticide Use Log was not submitted to the Park included:- Flying Insect Killer found at the Yosemite Valley stables;- Sling Shot Death Blow Crawling Insect Killer found at the Badger Pass maintenance building;- CB-40 Insecticide found at the Badger Pass maintenance building;- Raid found at the Badger Pass maintenance building, warehouse paint storage room, and Ahwahnee Hotel housekeeping area;- Wasp and Hornet Spray found at the Ahwahnee Hotel housekeeping area;- GLB Algyimycin 2000 found at the Curry Village Boiler Room; - Wasp Freeze;- 565 Plus XLO;- Sani-Chlor pool chlorinating tablets found at the Ahwahnee boiler room;- Repel-X fly spray;- Tri-tech fly repellent;- End Bac II Virucidal Spray Disinfectant found at the Yosemite Valley garage; and- Pesticides applied by the Concessioner's pesticide contractor, Paramount Pest Control.Recommended Corrective Action:Submit an annual Pesticide Use Log to the Park. The Pesticide Use Log should include the following information:- Pesticide name, including the Environmental Protection Agency Pesticide Product Registration Number if applicable;- Amount of pesticide used;- Location pesticide was used; and- Pests targeted.

Coordinate with the Park to ensure that the Park can meet its April 15th deadline for reporting the previous year's actual pesticide use.




Park Comments




NONE ENTERED








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N/A

Audit Finding Number: YOSE004-08-2007-072Audit Finding:Pesticide storage facilities were not locked, fireproof, and ventilated, and proper warning signs were not posted. For example:- Pesticides stored in the Yosemite Valley housekeeping office did not have proper warning signs and the cabinet where pesticides were stored was not locked;- Pesticides stored in the Ahwahnee Hotel housekeeping area did not have proper warning signs and the flammable storage cabinet where pesticides were stored was not locked; and- Pesticides stored in the Badger Pass maintenance area did not have proper warning signs and the flammable storage cabinet where pesticides were stored was not locked.

Pesticides were stored with oils, paints, and spray cans in the following areas: - Warehouse paint storage room;- Yosemite Valley stables;- Badger Pass maintenance area;- Ahwahnee Hotel housekeeping area; and- Yosemite Valley housekeeping office.

A pesticide was not stored according to directions provided on its label. For example, the label on containers of Calcium Hypochlorite briquettes used to manage the Curry Village pool's water quality indicated that the briquettes should be stored in a cool, dry place. They were currently stored in the Curry Village Boiler Room which was a wet, warm location.Recommended Corrective Action:Store pesticides separately from other substances; obtain pesticides storage facilities that can be locked and are fireproof and ventilated; and post proper warning signs.

Store each type of pesticide on separate shelves and preferably in different cabinets. Store pesticides according to their labels.

Post warning signs on any structure(s) used for the storage of pesticides; keep copies of labels, Material Safety Data Sheets (MSDSs) at the site of application; and keep pesticide inventories in a locked container outside the storage facilities.



N/A


Park Comments




NONE ENTERED




Audit Finding Number: YOSE004-08-2007-073Audit Finding:Refuse, including recyclables, was not always stored in receptacles that were covered, waterproof, and bear- and vermin-proof. For





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example:- At the Wawona service station, the large solid waste container was not secured to prevent bears from accessing the solid waste; - At the Wawona Lodge, recyclables were stored outside;- At White Wolf and Tuolumne Meadows service stations, the recycling container openings for glass did not have covers to prevent vermin from accessing the recyclables; and- At Tuolumne Meadows stables, the glass, plastic, and aluminum recycling containers did not have covers to prevent vermin from accessing the recyclables.Recommended Corrective Action:Ensure that all large solid waste containers that potentially contain food are bear-proof and that all recycling containers are vermin-proof.



N/A


Park Comments




NONE ENTERED





VII. Concessioner, Park, and Concession Program Comments on Best Management Practices (BMPs)




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BMP Number: YOSE004-08-2007-074-BMPBest Management Practice (BMP):As a BMP, consider keeping parts washers closed when not in use.

Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)NONE ENTEREDConcession Environmental Audit System CommentsN/A


Park Comments

Does the Concessioner have comments on this BMP? (Comments are optional.)Each BMP will be evaluated by the DNC Green Team through the EMS process for future implementation.

BMP Number: YOSE004-08-2007-075-BMPBest Management Practice (BMP):As a BMP, consider implementing a policy of "no idling" for vehicles used to transport supplies to and from Concessioner facilities, including vehicles from outside vendors.



Park Comments


BMP Number: YOSE004-08-2007-076-BMPBest Management Practice (BMP):As a BMP, consider having used refrigerant oils reclaimed and recycled at an Environmental Protection Agency (EPA)-approved refrigerant reclamation facility rather than with a used oil vendor.



Park Comments


BMP Number: YOSE004-08-2007-077-BMPBest Management Practice (BMP):As a BMP, consider ensuring that spill response equipment which is compatible with the hazardous substance of concern is available in the same area.

CONFIDENTIAL Comments - Best Management Practices -- 229




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Park Comments


BMP Number: YOSE004-08-2007-078-BMPBest Management Practice (BMP):As a BMP, consider providing a cross-reference between Section 6 of Standard Concession Contract language (Federal Register Vol. 65, No. 87 26052-26086, Concession Contract) and the current ISO 14001-certified environmental management system (EMS).



Park Comments


BMP Number: YOSE004-08-2007-079-BMPBest Management Practice (BMP):As a BMP, consider providing Concessioner employees with read-only access to the current ISO 14001-certified environmental management system (EMS) so that they are familiar with the details of the EMS.



Park Comments


BMP Number: YOSE004-08-2007-080-BMPBest Management Practice (BMP):As a BMP, consider continuing to research ways to partner with Pacific Gas and Electric (PG&E) to further reduce energy costs and save energy. For example:- Consider researching and implementing the rebates and incentives for retail facilities for conserving energy on the PG&E website; and- Consider researching and implementing the rebates and incentives for hotels, resorts, and food service facilities for conserving energy on the PG&E website.





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Park Comments


BMP Number: YOSE004-08-2007-081-BMPBest Management Practice (BMP):As a BMP, consider the following to help conserve energy and water resources:- Repair the water leak observed near the chiller building at the Curry Village ice rink;- Repair the dripping water faucets in the warehouse carpenter shop and machine shop;- Purchase energy- and water-conserving appliances (e.g., Energy Star-rated washers and dryers) when current appliances need to be replaced at the Housekeeping Camp;- Use a passive infrared sensor on vending machines, such as at the Wawona service station;- Close windows and doors if air is being cooled with an air conditioner or swamp cooler (such as at the Wawona golf shop); and- Continue to replace incandescent lamps with energy-conserving fluorescent lamps;



Park Comments


BMP Number: YOSE004-08-2007-082-BMPBest Management Practice (BMP):As a BMP, consider developing a standard operating procedure (SOP) at White Wolf Lodge to transport kitchen grease from the kitchen to 30-gallon drums to help minimize the potential for spills outdoors.



Park Comments


BMP Number: YOSE004-08-2007-083-BMPBest Management Practice (BMP):As a BMP, consider checking the annular space of aboveground storage tanks (ASTs) that do not have automatic leak detection for releases on a regular basis.





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Park Comments


BMP Number: YOSE004-08-2007-084-BMPBest Management Practice (BMP):As a BMP, consider securing against tampering all of the fill ports for underground and aboveground storage tanks by locking them.



Park Comments


BMP Number: YOSE004-08-2007-085-BMPBest Management Practice (BMP):As a BMP, consider using spill pads to prevent drips and spills on the ground when:- Filling up equipment or vehicles with fuel (e.g., fueling bobcats at any of the stables, fueling vehicles at Badger Pass);- Changing fuel filters on aboveground storage tanks (e.g., at the warehouse boiler); and- Adding used oil to used oil containers (e.g., at the warehouse machine shop).

In addition, consider developing, documenting, implementing, and monitoring a standard operating procedure for adding used oil to used oil containers in the warehouse machine shop.



Park Comments


BMP Number: YOSE004-08-2007-086-BMPBest Management Practice (BMP):As a BMP, consider bolting the legs of the 500-gallon diesel aboveground storage tank (AST) to the underlying concrete pad.

Concessioner CommentsDoes the Concessioner have comments on this BMP? (Comments are optional.)Each BMP will be evaluated by the DNC Green Team through the EMS process for future implementation.





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Park Comments

BMP Number: YOSE004-08-2007-087-BMPBest Management Practice (BMP):As a BMP, consider ensuring that spill protection for underground storage tanks (USTs) is maintained clean and dry.



Park Comments


BMP Number: YOSE004-08-2007-088-BMPBest Management Practice (BMP):As a BMP, consider documenting the daily visual inspection of the aboveground storage tanks storing petroleum.



Park Comments


BMP Number: YOSE004-08-2007-089-BMPBest Management Practice (BMP):As a BMP, consider having all underground storage tank (UST) and aboveground storage tank (AST) monitoring systems installed to notify a manned remote location when the alarm is set off, especially during non-operating hours. This could include having monitoring systems contact individuals via phone or fax.



Park Comments






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BMP Number: YOSE004-08-2007-090-BMPBest Management Practice (BMP):As a BMP, consider storing incompatible materials (such as corrosives and ammonia-based hazardous materials which are incompatible with flammable hazardous materials) that are stored in containers having a capacity of less than five pounds or 0.5 gallons in separate locations. For example:- In the warehouse paint storage room, separate the container of corrosive material from the paints and aerosol cans in the flammable storage cabinet; and- At Mariposa Grove, separate the two bottles of ammonia-based Windex from the fuels and other flammable materials in the flammable storage cabinet.

Alternatively, store incompatibles in separate containers such as plastic tubs. This will help incompatible materials from mixing should containers leak.



Park Comments


BMP Number: YOSE004-08-2007-091-BMPBest Management Practice (BMP):As a BMP, consider storing hazardous materials in closed containers.



Park Comments


BMP Number: YOSE004-08-2007-092-BMPBest Management Practice (BMP):As a BMP, consider storing hazardous substances in a manner that would tend to control leakage. For example:- Store all containers of liquid hazardous substances upright rather than on their sides;- Do not store hazardous substances on the floor of flammable storage cabinets;- Ensure all flammable material cabinets are stored on a flat surface; and - Provide secondary containment for hazardous substances stored near floor drains or with the potential to affect the outdoor environment.


Park Comments






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BMP Number: YOSE004-08-2007-093-BMPBest Management Practice (BMP):As a BMP, consider locking the door to the flammable storage cabinet that is stored outside of the Curry Village ice rink chiller building when it is not in use.



Park Comments


BMP Number: YOSE004-08-2007-094-BMPBest Management Practice (BMP):As a BMP, consider conducting an inventory of all hazardous substances maintained on-site, especially those hazardous substances in storage areas. For those hazardous substances that will not be used, consider either donating or disposing of them, ensuring that hazardous wastes intended for disposal are managed in accordance with all applicable regulations.



Park Comments


BMP Number: YOSE004-08-2007-095-BMPBest Management Practice (BMP):As a BMP, consider removing rope used to support a wood fence that surrounded three propane tanks at the Boy's Camp employee housing area.

Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)The fence should be repaired and in good condition. It should not be supported and held in an upright position by rope attached to the top of the propane tank.Concession Environmental Audit System Comments


Park Comments






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In response to Concessioner comments, note that while strongly recommended, BMP opportunities are not required to be implemented by the Concessioner.

BMP Number: YOSE004-08-2007-096-BMPBest Management Practice (BMP):As a BMP, consider expanding communication on the Leave No Trace program to retail and horse stable operations. For example, consider leaving copies of the Leave No Trace program near each register in the Curry Village mountaineering store and instructing horse guides to talk about Leave No Trace to Park visitors or sending Leave No Trace brochures to guests who have reserved horse and mule trips into the backcountry.

Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)The Concessioner can implement the LNT program copies at each CV Mountain Shop register immediately and horse guides can incorporate LNT principles into their interpretive program next season when they reopen.Concession Environmental Audit System CommentsIn response to Concessioner comments, note that while strongly recommended, BMP opportunities are not required to be implemented by the Concessioner.


Park Comments


BMP Number: YOSE004-08-2007-097-BMPBest Management Practice (BMP):As a BMP, to help maximize recycling opportunities, consider implementing the following if economically feasible and appropriate:- At the warehouse loading dock area, label large recycling containers used to hold newspapers and phonebooks for pick-up;- At the Wawona service station, provide recycling containers for the general public;- When guests check into lodging facilities, verbally promote the Concessioner recycling program and how guests should recycle their recyclable materials; and- Indicate on lodging area maps (e.g., for the Housekeeping Camp and Curry Village) where all recycling stations are located.



Park Comments


BMP Number: YOSE004-08-2007-098-BMPBest Management Practice (BMP):As a BMP, consider closing containers of used oil when not being used to pour used oil in or take used oil out.


Park Comments






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Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)This BMP could be incorporated into the operations now.Concession Environmental Audit System CommentsN/A

BMP Number: YOSE004-08-2007-099-BMPBest Management Practice (BMP):As a BMP, consider communicating environmental messages in additional ways to staff and the public. For example:- Educate visitors on the environmentally preferable foods (e.g., local and organic) being used throughout food service operations;- Print environmental messages on the Tuolumne Lodge placemats, which are currently plain; and- Inform visitors that the recycling center by the Yosemite Village Store is environmentally preferable since it is made from wood from hazard trees, has a roof made from tires, and uses natural lighting.



Park Comments


BMP Number: YOSE004-08-2007-100-BMPBest Management Practice (BMP):As a BMP, consider linking Concessioner-specific standard operating procedures (SOPs) to the current ISO 14001-certified environmental management system (EMS).



Park Comments


BMP Number: YOSE004-08-2007-101-BMPBest Management Practice (BMP):As a BMP, consider identifying and implementing additional opportunities to expand the types of environmentally preferable items purchased where economically feasible and appropriate. These environmentally preferable products could include, but are not limited to:RETAIL- Organic wines;- Post-consumer recycled content T-shirts (e.g., Wawona Golf Gift Shop);- Disposable bowls, plates, and cups for stores that are made of unbleached paper or are easily biodegradable for sale in Concessioner grocery stores; and- Post-consumer recycled content retail bags, calendars, and postcards.





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MAINTENANCE- Propylene glycol antifreeze for vehicles;- Re-refined motor oil; - Retread tires; - Biodiesel and other alternative fuel sources for vehicles; and- Bicycle biolubricants.

FOOD AND BEVERAGE- Organic and/or locally produced food in all food operations (e.g., Curry Taqueria);- Bulk condiment dispensing areas (e.g., Curry Taqueria ketchup and other condiments and Tuolumne Lodge pancake syrup); and- Post-consumer recycled content paper napkins and paper placemats (e.g., Tuolumne Lodge).

LODGING- Organic, post-consumer recycled cotton, or biobased renewable sources for sheets and towels; and- Energy Star-qualified washers and dryers in the Housekeeping Camp Laundromat.

Document environmentally preferable purchases so that performance can be tracked against internally set goals. As appropriate, document research and/or decisions that demonstrate why certain environmentally preferable products were not purchased.

Educate visitors on environmentally preferable products used throughout Concessioner facilities via signs, posters, Concessioner employees, and other means.



Park Comments


BMP Number: YOSE004-08-2007-102-BMPBest Management Practice (BMP):As a BMP, consider:- Obtaining and maintaining in a readily accessible location a paper copy material safety data sheet (MSDS) for each hazardous chemical used in the workplace;- Removing from MSDS binders or filing in a separate location MSDSs that are no longer being used; and- Alphabetizing MSDSs so that it is easy to find a particular paper copy MSDS.

Also:- Update the paper copy MSDS file(s) in conjunction with the list of hazardous chemicals whenever a new chemical is introduced to the workplace; and- Review the MSDS file(s) periodically (at least annually) to ensure that it is kept up-to-date. This review can be carried out at the same time as the list of hazardous materials is being updated.

Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)NONE ENTEREDConcession Environmental Audit System Comments


Park Comments






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N/A

BMP Number: YOSE004-08-2007-103-BMPBest Management Practice (BMP):As a BMP, consider providing secondary containment for all containers holding hazardous waste.



Park Comments


BMP Number: YOSE004-08-2007-104-BMPBest Management Practice (BMP):As a BMP, consider packing out manure from all High Sierra Camp corrals for disposal along with manure generated from stable operations at Curry Village, Tuolumne Meadows, and Wawona.

Does the Park have comments on this BMP or the Concessioner's comments? (Comments are optional.)The Park expects the Concessioner to pack out horse manure from High Sierra Camp corrals and not spread it on the grounds. Per the Operating Plan, the Concessioner will clean corrals and ditches to ensure proper drainage and manure will be removed from the Park on a regular basis.Concession Environmental Audit System CommentsConcurred with Concessioner and Park comments.


Park Comments


BMP Number: YOSE004-08-2007-105-BMPBest Management Practice (BMP):As a BMP, consider cleaning up manure from trails in the area of the start of trail rides on a more frequent basis such as twice per week.



Park Comments







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Best Management Practice (BMP):As a BMP, consider if technically and economically feasible, printing environmental education messages on bags given to Park visitors to hold purchases. Some environmental messages that could be printed on the bags include, but are not limited to:- "Please use this bag to carry your trash."- Park and environmental facts and stories.



Park Comments


BMP Number: YOSE004-08-2007-107-BMPBest Management Practice (BMP):As a BMP, consider planting vegetation at Wawona stables, especially around the horse corral.



Park Comments


BMP Number: YOSE004-08-2007-108-BMPBest Management Practice (BMP):As a BMP, consider installing canopies over any fuel dispensers that do not already have one in place.



Park Comments


BMP Number: YOSE004-08-2007-109-BMPBest Management Practice (BMP):As a BMP, consider installing an oil-water separator at the garage where wash water from washing buses drains.

Concessioner CommentsDoes the Concessioner have comments on this BMP? (Comments are optional.)Each BMP will be evaluated by the DNC Green Team through the EMS process for future implementation.





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Park Comments


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