Layde Philips

Programs Management,

Environmental Affairs Division, TxDOT

EMS Status

What is the TXDOT Environmental Management System Verification Audit?

Short Course 2012

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WHAT IS THE EMS VERIFICATION?

4 WHAT IS THE TXDOT EMS VERIFICATION AUDIT ?

A systematic and documented process for objectively obtaining and

evaluating evidence to determine the following:

Does implementation of the TxDOT EMS conform to the TxDOT EMS criteria?

Are EMS results communicated to management and acted upon appropriately?

Say what you do/Do what you say

EMS

TxDOT Management System Elements

1. EMS Policy

2. Roles and Responsibilities

3. Environmental Requirements

4. Assessment, Prevention and Control

5. Training Awareness and Competence

6. Records and Documentation

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EMS VERIFICATION OBJECTIVES

WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

Independently evaluate the adequacy and effectiveness of

the TxDOT EMS implementation from top management

down and throughout each district based on a

representative sample.

Provide a independent assessment as to whether the

TxDOT EMS has been implemented in such a manner as

to facilitate understanding, by appropriate TxDOT

employees and contractors, of the following:

• the environmental aspects and impacts of road construction

• the environmental controls, monitoring and measurement

procedures or processes contained within the TxDOT EMS

to address the aspects and impacts of road construction

• individual environmental responsibilities related to the

aspects and impacts of road construction as stipulated within

the TxDOT EMS

TxDOT Management

System Elements:

1. EMS Policy

2. Roles and

Responsibilities

3. Environmental

Requirements

4. Assessment, Prevention

and Control

5. Training Awareness and

Competence

6. Records and

Documentation

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EMS VERIFICATION APPROACH

6 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

HQ Audit

West

2 Districts

TBD

Active Road Construction Sites

North

2 Districts

TBD

Active Road Construction Sites

South

2 Districts

TBD

Active Road Construction Sites

East

2 Districts

TBD

Active Road Construction Sites

District Selection Criteria

Geographical Coverage

Construction Activity

Large/Small Geographical Area

Rural/Urban

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EMS VERIFICATION APPROACH - HQ

7 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

Headquarters

Environmental Affairs

Division

Construction Division

Design Division

Maintenance Division

Administration Division

TxDOT EMS Elements

•Policy Statement

•Roles/Responsibilities

•Environmental Requirements

•Assessment, Prevention and Control

•Training, Awareness and Competence

•Records and Documentation

Two (2) person Team

Three (3) Day Verification

Five Divisions

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EMS VERIFICATION APPROACH - Districts

8 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

DISTRICT

Project Development/Environmental

EMS Element

Design

EMS Element

Contractor/Subcontractor

Construction Phase

2-3 Construction Projects/District

Preliminary Design

EMS Element

District Engineer

Construction Inspector

TxDOT EMS Elements

•Policy Statement

•Roles/Responsibilities

•Environmental Requirements

•Assessment, Prevention and

Control

•Training, Awareness and

Competence

•Maintenance of Records and

Documentation

2.5 day verification

2 person teams

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EMS VERIFICATION APPROACH

9 WHAT IS THE TXDOT EMS VERIFICATION AUDIT ?

Planning

Verification Plan Developed and Approved by USEPA

Master Audit Schedule

District Projects Selected Fit the EMS Road Construction Definition

Projects Selected From October 2012 Letting

Coordinate with Districts Regarding Visit Logistics

Identify Personnel to be Interviewed

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EMS VERIFICATION APPROACH

10 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

Verification (2.5 days)

Opening Meeting

• Introductions/Process Overview

• Safety Requirements etc.

Records Review

Personnel Interviews

• District Employees/Contractors

Physical inspections

• 2-3 Active Road Construction Projects

Closing Meeting

• AM Meeting

• Review of Findings

• Discussion of Corrective Actions

• Q&A

Day 1

Day 2

Day 3

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EMS VERIFICATION APPROACH

11 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

Reporting and Follow Up

Findings Report

• Submit to HQ within seven (7) business days

• Summarize Verification Activities

• Provide Detailed Verification Findings + Corrective Actions

Periodic Requests for Corrective Action Updates

• E-Mails from Shaw to EMS Coordinator and District Contact

• Requesting Updates Regarding Corrective Action

• Track Closure of Verification Findings

• Closure Progress Reported to HQ On Recurring Basis

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EMS VERIFICATION PROCESS - General

12 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

Say what you do/Do what you say

Are EMS procedures/processes adequately inclusive of road construction

environmental impacts?

Do the TxDOT EMS procedures/processes describe what’s actually happening? • Review of job site for environmental requirements, implementation of procedures.

Is there objective evidence that EMS procedures/processes are being followed?

• Review of District and Project EMS Records

Is EMS documentation controlled?

• Current versions or forms, procedures etc. used?

Are related documents and records referenced?

• SOPs • Environmental Scoping • EPIC Sheet • Pre-Construction Conference • Construction State Gate Checklist • Storm Water Inspection Checklist

EMS

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EMS VERIFICATION PROCESS

EXAMPLE PERSONNEL INTERVIEW QUESTIONS

How did you become aware of the TxDOT Environmental

Policy?

What is your understanding of the EMS Policy and how does it

apply to your day-to-day work?

What are your responsibilities within the TxDOT EMS?

What environmental impacts are associated with your work?

What EMS procedures or processes do you follow when

conducting your work?

How does your work vary from the procedures?

What kind of EMS or environmental training have you received?

How do you escalate environmental concerns to management?

TxDOT EMS Elements:

1. EMS Policy

2. Roles and

Responsibilities

3. Environmental

Requirements

4. Assessment,

Prevention and

Control

5. Training Awareness

and Competence

6. Records and

Documentation

WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

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14 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?

EMS VERIFICATION SCHEDULE

Project Tasks September 2012 – January 2014

S O N D J F M A M J J A S O N D J

Develop Verification Plan content outline

Define corrective action and follow-up methodology

Draft Verification Plan to meet CAFO requirements

Coordinate with TxDOT for Verification Plan Development

Provide draft Verification Plan to TxDOT

Incorporate TxDOT comments into Plan

Submit final Verification Plan to EPA as directed by TxDOT

Incorporate EPA comments into Plan (30 days of receipt)

Obtain EPA approval of final Verification Plan

Finalize site visits and interview schedules

Conduct Austin, TX Headquarters Audit

Conduct Audits – TxDOT Southern Region

Conduct Audits – TxDOT Eastern Region

Conduct Audits – TxDOT Northern Region

Conduct Audits – TxDOT Western Region

Develop Verification Report Content Outline

Coordinate with TxDOT for Report development

Provide draft Verification Report to TxDOT for review

Incorporate TxDOT comments into final Report

Submit final Verification Report to EPA

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QUESTIONS?

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"This project was undertaken in connection with the settlement of an enforcement action taken by the U.S. Environmental Protection Agency for alleged violations of Clean Water Act provisions.“ (CAFO 27)

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Back-Up Slides

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EMS

TOOLS

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Road Construction Project - Road construction operation that includes any of the following associated activities: earth work, concrete work, asphalt work, steel work, masonry work, demolition work, excavation work, fill work, land clearing, painting, soil stabilization, equipment operation, de-watering activities, material storage, waste management, waste disposal, and waste recycling activities. Under this definition, construction also includes project specific locations (PSLs), such as concrete and asphalt batch plants, within the Right-of-Way. The term construction does not include routine or preventative roadway maintenance activities.

– Types of projects include new location, existing pavement

rehabilitations/widening, culvert work, bridge rehabilitation/replacement.

– Typical projects not requiring the Stage Gate Checklist (SGC) to be completed would be signal installation, crack sealing, retrace striping, seal coating, bridge joint repair.

– Districts should determine whether the SGC should be completed on minimal soil disturbance Construction or Maintenance contracts such as any MBGF upgrade, landscaping, ACP overlays.

EMS Road Construction Definition with

Guidance

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EMS TOOLS

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