chapter 11: appendixenvironment.transportation.org/documents/nchrp25_25_files/nchrp_chapter_11.pdfwe...

CHAPTER 11: APPENDIX

11.1. FLORIDA DOT ENVIRONMENTAL POLICY Example 1: Florida DOT Environmental Policy It is the policy of the Florida Department of Transportation to help preserve and enhance Florida’s natural, physical, cultural and social environment as we develop, implement, and maintain transportation facilities and services. In carrying out this policy, the Department will:

• Balance quality engineering and aesthetic design principles with consideration of environmental and economic aspects of the transportation program.

• Utilize methods to preserve, enhance, and protect trees and other vegetation as valuable natural resources consistent with ecosystem management principles, local community values and established safety practices.

• Take into account the effects of transportation improvements on prehistoric and historic cultural resources in all phases of Department activity and avoid, minimize, or mitigate for such impacts as applicable.

• Cooperate in the State’s Greenways Program of land acquisition and management through identification and prioritization of important habitat connections. Where alternative mitigation strategies permit, the Department will support land acquisition activities to help achieve this ecological infrastructure. Consideration of habitat connectivity and wildlife crossings will be included on existing facilities as well as in the development of planned projects.

• Consider, in all functional activities, environmental factors such as noise, air quality, stormwater runoff, water quality, wetlands, wildlife and habitat, and hazardous materials in order to preserve and enhance the state’s environmental quality.

• Maximize the use of recycled materials in highway construction.

• Cooperate in the State’s program to control the spread of invasive exotic plants.

• Consider social consequences resulting from transportation actions to ensure that impacts to the human environment are identified and fully considered equally with impacts related to the natural and physical environments.

• Be sensitive to community values and needs utilizing an open decision-making process, which strives to accommodate community concerns, where feasible, and facilitate problem solving in a collaborative manner.

• Utilize proactive public involvement that is responsive to agencies, citizens and groups in addressing environmental issues and developing transportation plans, programs and policies.

11.2. KENTUCKY TRANSPORTATION CABINET ENVIRONMENTAL POLICY Example 2: Kentucky Transportation Cabinet Environmental Policy The Kentucky Transportation Cabinet will use practical means and measures to provide an environmentally sound, fiscally responsible, safe and efficient transportation system which promotes conditions under which people and nature can exist in productive harmony while providing for economic growth and enhancing the quality of life for present and future generations of Kentuckians.

The principles and responsibilities of the above policy statement which we are incorporating into the culture and fabric of our organization and daily activities are as follows:

Stewardship We will strive to protect, conserve, restore, and enhance the natural and human environment, while we plan, design, construct, and maintain facilities that meet transportation needs.

Chapter 11: Appendix 1

Leadership We will promote development, sharing and the integration of sensitive and innovative environmental practices and technologies into planning, design, construction, and maintenance activities to encourage personnel to value and take pride in their environmental leadership roles.

Partnership We will seek stewardship opportunities to cooperatively partner with the public, federal and state resource agencies to identify shared visions, missions, and goals which will result in new consensus building processes, new methods and protocols, and new design and environmental technologies to be applied on mutually beneficial undertakings.

Practice We will employ Context Sensitive Solutions to ensure that our planning, design, construction, and maintenance activities reflect community and environmental values as determined through proactive involvement with the public, resource agencies, and other stakeholders.

Commitment Our Cabinet is committed to a culture that embraces environmental leadership with an unwavering focus on protecting the environment through stewardship and our devotion to satisfy the public, resource agencies, and other stakeholders as the primary measure of success in carrying out our mission.

By working with the public, resource agencies and other stakeholders to integrate environmental stewardship into our daily activities, the Cabinet is responding to the wishes and needs of its customers, the values it holds foremost as public servants while acting in the spirit of environmental law. It is the right thing to do for transportation and the human and natural environment.

11.3. MAINE DOT ENVIRONMENTAL POLICY Example 3: Maine DOT Environmental Policy It is the Vision of the Maine Department of Transportation that we “...will create and maintain a safe, efficient, and economical transportation system that is cost effective, energy efficient, environmentally sound and responsive to the diverse needs and values of the people of Maine and the Nation.” In accomplishing this, we recognize that the Department’s actions can, and often do, impact environmental resources. We understand that the public expects us to deliver our services and products in a way that protects and enhances environmental resources. We appreciate that these resources are the basis of our quality of life and have tremendous economic and social value.

It is therefore the policy of the Maine Department of Transportation that we continuously evaluate our actions for their impacts upon environmental resources and that we conduct our activities so as to avoid and minimize those impacts. It is our desire to deliver safe and efficient transportation systems and to protect and enhance environmental resources. It is not a question of either one or the other. It is a matter of delivering both.

To accomplish this, the Department will:

• Develop and utilize an Integrated Transportation Decision-making process (ITD) regarding transportation projects that incorporate environmental considerations from the earliest planning state through construction and maintenance;

• Evaluate areas that need improvement regarding protection of the environment and implement the changes necessary to make those improvements;

• Conduct a review of our organizational structure and culture regarding environmental responsibilities and make the changes necessary to strengthen that structure and to change the culture where appropriate;

• Partner with Federal and State environmental agencies to identify and collaborate on reaching goals of mutual interest; and

• Make environmental protection part of every employee’s job expectations.

As Commissioner, I am personally committed to making this policy work. It is what the public expects of us, it is an investment in our future, and it is simply the right thing to do. I will hold each employee accountable for his/her part of the Department’s commitment to the protection and enhancement of Maine’s environmental resources as we carry out our Transportation responsibilities.


11.4. NORTH CAROLINA DOT ENVIRONMENTAL STEWARDSHIP POLICY Example 4: North Carolina DOT Environmental Stewardship Policy The mission of the North Carolina Department of Transportation is to provide an integrated transportation system that enhances the state’s well being. Our goal is to provide a safe and well-maintained transportation system that meets the needs of our customers and supports the development of sustainable, vibrant communities. In so doing, we are committed to planning, designing, constructing, maintaining and managing an interconnected transportation system while striving to preserve and enhance our natural and cultural resources.

Environmental stewardship encompasses these responsibilities and is reflected in our day-to-day operations by:

• Safeguarding the public’s health by conducting our business in an environmentally responsible manner. • Demonstrating our care for and commitment to the environment. • Recognizing that our customers expect us to provide mobility and a quality of life that includes the

protection of the natural resources and the cultural and social values of their community. • Each employee is responsible for incorporating these principles of safety, environmental stewardship and

customer focus into their daily activities.

11.5. PENNDOT’S GREEN PLAN POLICY STATEMENT Example 5: PennDOT’s Green Plan Policy Statement As a direct result of our commitment to assuring adequate, safe and efficient intermodal transportation facilities and services at reasonable cost to the citizens of the Commonwealth of Pennsylvania, the Department of Transportation will play a leading role in the administration of environmental responsibility. The Department will demonstrate this leadership by committing to the following principles relative to the planning, design, construction, operation and maintenance of Pennsylvania’s balanced intermodal transportation system.

Principle 1 Plan, design, build, operate and maintain a statewide transportation system that protects the environment, prevents pollution and uses resources efficiently.

Principle 2 Contribute to economic vitality and quality of life by applying sound environmental management practices which address the requirements of the public, users, carriers, industry and labor.

Principle 3 Comply with applicable environmental legislation and regulations.

Principle 4 Establish a program of review and continual improvement of environmental performance which accounts for technical and economic developments, scientific understanding, and significant environmental impacts.

Principle 5 Establish relevant and measurable objectives which endeavor to improve environmental performance and provide the means to gauge progress.

Principle 6 Ensure employees understand those principles as well as their priority, and are furnished with the means to fulfill them.

These principles are essential elements for the management of the Department as we enter the 21st century. As part of a fully integrated environmental management system, these principles should be incorporated into the policies, programs and practices of all Department of Transportation organizations


11.6. WASHINGTON STATE DOT ENVIRONMENTAL POLICY Example 6: Washington State DOT Environmental Policy The Department of Transportation acknowledges the state’s vital interests in protecting and preserving natural resources and other environmental assets and its citizens’ health and safety. These interests must be integrated with other vital interests committed to the Department, including the cost-effective delivery and operation of transportation systems and services that meet public needs.

The Department shall conduct all its affairs in accordance with the dictates of sound environmental protection practices, including pollution prevention wherever reasonably possible. The Department shall also avoid, minimize and appropriately mitigate adverse environmental impacts. These undertakings extend to the construction, maintenance and operation of its systems and facilities. Legal obligations in these matters are established by applicable laws and regulations; this Policy Statement is not intended to create further or additional legally-enforceable requirements.

• To support the performance of the Department’s responsibilities and undertakings, as Secretary of Transportation, I hereby commit the Department:

• To implement and maintain an environmental management system that embraces all the Department’s program functions;

• To establish, maintain and make available to the public appropriate performance indicators of the Department’s exercise of its environmental stewardship and to consistently review these indicators as a basis to improve the Department’s performance;

• To comply with all environmental laws and regulations applicable to our business and activities; • To assure that employees of the Department receive training appropriate to their functions concerning the

Department’s environmental responsibilities; • To communicate to contractors, designers, consultants and other participants in the Department’s work the

management practices and compliance requirements established to further the aims of this Policy Statement;

• To encourage employees and all other citizens to communicate with the Department about ways to increase the effectiveness of Department’s practices supporting its mission of environmental stewardship;

• To make every reasonable effort to also protect the cultural and historic resources of the state. • Each employee of the Department is charged to exercise his or her responsibility on behalf of the

Department to assure that the intentions of the Policy Statement are diligently carried out.

11.7. NEW SOUTH WALES ROADS AND TRAFFIC AUTHORITY ENVIRONMENTAL POLICY

Example 7: New South Wales Roads and Traffic Authority Environmental Policy The RTA manages road related transport infrastructure and provides safe and efficient access to the road network for the people of NSW. The RTA will demonstrate due diligence in the provision of its services, manage its work activities in a manner that is consistent with the principles of ecologically sustainable development, and will deliver continuous improvement in environmental performance through:

• Developing and implementing an environmental management system. • Reviewing the environmental effects of our activities and setting appropriate environmental improvement

objectives. • Integrating environmental duty of care into business planning and day to day activities. • At a minimum, conducting all our operations, whether carried out by or on behalf of the RTA, in

accordance with relevant legislation and government policy and agreements. • Minimizing pollution and environmental impacts as a result of RTA activities. • Promoting the efficient use, reuse and recycling of resources, and the minimization of waste. • Involving the community in planning and implementation decisions. • Including environmental considerations in all aspects of strategic planning of our road and traffic

management.


• Providing our employees with the skills, awareness and leadership to achieve the RTA’s environmental responsibilities.

• Monitoring, reviewing and reporting publicly on the environmental performance of the organization.

11.8. TEXAS ENVIRONMENTAL COMMITMENT CHECKLIST Table 1: Texas Environmental Commitment Checklist

TxDOT ENVIRONMENTAL COMMITMENT CHECKLIST

For Construction, Maintenance and Facilities Projects

PROJECT: DATE:

CSJ: DEQC:

HIGHWAY: Name

Stormwater Pollution Prevention

Required Information and Documentation

Does the construction site have a Stormwater Permit? Yes No *

N/A

Is a notice posted in a publicly accessible location near where construction is actively underway (and moved as necessary)?

Yes No *

N/A

Does the notice contain the following information:

The permit number or a copy of the NOI? Yes No *

N/A

The name and telephone number of a local contact person? Yes No *

N/A

A brief description of the project? Yes No *

N/A

Location of SW3P (Job site or other location). Yes No *

Is there a copy of the Construction General Permit in the SW3P? (a copy of the Federal Register is sufficient)

Yes No *

N/A

Is there a copy of a Delegation of Authority Letter authorizing the inspector to sign inspection reports in the SW3P file?

Yes No *

N/A

Is the SW3P retained on-site at the facility that generates the stormwater? (If no, where is it located _____________________________________________)?

Yes No *

N/A

Is the SW3P updated and documented in the plans as necessary to remain consistent with any changes in design, construction, operation, or maintenance applicable to protecting surface water resources in sediment and erosion site plans or site permits, or stormwater management site plans or site permits approved by State, Tribal or Local Officials for which the permittee receives notice?

Yes No *

N/A

Is the description of construction and waste materials expected to be stored on-site updated? Yes No *

N/A

Are the following records maintained and available for inspection, or included in the SW3P?


Dates when major grading activities occur? Yes No *

N/A

Dates when construction activities temporarily or permanently cease on a portion of the site? Yes No *

N/A

Dates when stabilization measures are initiated? Yes No *

N/A

Did stabilization occur within 14 days at locations where soil disturbing activities have ceased or will cease for at least 21 days or were temporary measures installed?

Yes No *

N/A

General Conditions

Are Best Management Practices (BMPs) being utilized? Yes No *

N/A

Are silt fences, buffer strips, or equivalent sediment controls at a minimum used for all side-slope and down-slope boundaries of the construction area?

Yes No *

N/A

Controls & Measures

Have erosion and sediment controls been designed to retain sediment on-site to the extent practical during the construction phase?

Yes No *

N/A

Were control measures, in accordance with manufacturer specifications and good engineering practices:

Properly selected? Yes No *

N/A

Properly installed? Yes No *

N/A

Properly maintained? Yes No *

N/A

In effective operating conditions? Yes No *

N/A

Are controls in place to minimize:

Dust generation? Yes No *

N/A

Off-site vehicle tracking of sediments? Yes No *

N/A

Are off-site accumulations of sediment removed at a frequency sufficient to minimize off-site impacts? (sediment near off-site inlets, etc)

Yes No *

N/A

Is sediment removed from the sediment traps or sediment ponds when design capacity is reduced by 50 percent?

Yes No *

N/A

Are litter, construction debris, and construction chemicals exposed to stormwater prevented from becoming a pollutant source from stormwater discharges? (e.g., screening outfalls, picked up daily)

Yes No *

N/A

Are solid materials including building materials being discharged? (except those authorized by a permit issued under section 404 of the CWA)

Yes * No N/A

Were velocity dissipation devices (i.e. rock filter dams, holding ponds, etc) placed at discharge locations and along the length of any outfall channel to provide a non-erosive flow velocity from the structure to the water course?

Yes No *

N/A


Inspections

Were the inspections performed at least once every 14 calendar days and within 24 hours of the end of a 0.5 inch or more rain event (or once every 30 days in areas with less than an average 20 inches of rainfall per year)? (Note: some projects may require more frequent inspections, refer to the plans).

Yes No *

N/A

Did the inspector check the following:

Disturbed areas of the construction site that have not been stabilized? Yes No *

N/A

Areas used for storage of materials that are exposed to precipitation? Yes No *

N/A

Structural control measures? Yes No *

N/A

Locations where vehicles enter or exit the site? Yes No *

N/A

Based on the inspection, are the SW3P Sheet and SW3P Layouts modified within 7 calendar days following the inspection?

Yes No *

N/A

Is it documented and available for inspection? Yes No *

N/A

Based on the inspection, are controls and measures modified or added before the next anticipated storm event (or as soon as practicable)?

Yes No *

N/A

Did the inspection Summary Report include:

The name of the inspector? Yes No *

N/A

The date(s) of the inspection? Yes No *

N/A

Measures/area inspected? Yes No *

N/A

Actions needed/taken as a result of the inspection? Yes No *

N/A

Signature of inspector with certification statement? Yes No *

N/A

Inspector properly delegated in writing to EPA? Yes No *

N/A

Water Resources Compliance USAC Permits

U.S. Army Corps of Engineers (USACOE) Permits: Does the project have a USACOE (Section 10 or Section 404) permit?

Yes No N/A

If yes, is a copy of the permit kept onsite (in the form of Nationwide Permit text and/or a letter or other documents from the USACOE)?

Yes No *

N/A

Are any Project Specific Locations, on or off Right-of-Way, that are directly related to the USACOE permit addressed in the permit or Corps letters to the contractor (for off ROW PSLs)?

Yes No *

N/A


Has clearance been obtained for any changes in design or construction methods in the areas covered by the permit?

Yes No *

N/A

Does the project meet all conditions listed in the permit? Yes No N/A

Is a copy of the completed Section 401 Water Quality Certification Tier I checklist (or other specific Section 401 requirements) attached to the permit?

Yes No *

N/A

Does the project have the BMPs installed as designated in the Tier I checklist or as otherwise specified?

Yes No *

N/A

Are the BMPs working effectively? (If not, immediately bring the problem to the attention of the project engineer)

Yes No *

N/A

Are there wetlands on the project site? Yes No N/A

Are wetlands that are required to be preserved by the USACOE permit being effectively protected?

Yes No *

N/A

Other Water Requirements

Does the project require an Edwards Aquifer Protection Plan (for central Texas counties Kinney, Uvalde, Medina, Bexar, Comal, Hays, Travis, & Williamson only)

Yes No N/A

If yes, is a copy of the Water Abatement Plan kept on-site? Yes No *

N/A

Are all appropriate conditions affecting construction being met? Yes No *

N/A

Does the project have a U.S. Coast Guard Section 9 permit? Yes No N/A

If yes, is a copy of the permit kept onsite? Yes No *

N/A

Are all appropriate conditions affecting construction being met? Yes No *

N/A

Does the Project fall under the requirement of the Texas Coastal Management Plan? Yes No *

N/A

If yes, are all appropriate conditions affecting construction being met? Yes No *

N/A

Other Environmental Requirements

Vegetation Management

Are there any mitigation issues involving vegetation impacts? Yes No N/A

Is the ROW to be used for mitigation? Yes No N/A

Is there any vegetation that requires fencing, or other protection, to preserve it from damage or removal?

Yes No N/A

Are there any vegetative management issues within the project? Yes No N/A

Has project been coordinated with district environmental staff before removal of trees/shrubs within proposed ROW?

Yes No *

N/A


Has project been coordinated with district environmental staff to salvage native plants in project area?

Yes No *

N/A

Invasive species addressed as required? Yes No *

N/A

Is revegetation/landscaping with native grasses and shrubs in accordance with project plans? Yes No *

N/A

Are recycled plant trimmings to be used as mulch and to reduce runoff? Yes No *

N/A

Is any stockpiled organic layer of soil from existing wetlands to be used on mitigation site? Yes No *

N/A

Are the wetlands to be preserved already delineated? Yes No *

N/A

Noise

Are there any noise level concerns within the project? Yes No N/A

Minimized construction noise:

In residential areas Yes No *

N/A

In sensitive receptors in area. Yes No *

N/A

Historical and Archaeological

Are there any historical or archaeological issues in the PS&E? Yes No N/A

Archaeological survey to be conducted during/after ROW purchase. Parcel #_____ Yes No N/A

Are there any archaeological surveys needed to be done on outstanding parcels? Parcel #________.

Yes No N/A

Are there any archaeological sites that must be avoided until mitigation is complete and THC concurs no additional work is required prior to construction?

Yes No N/A

Are there any designated avoidance areas? Yes No N/A

If yes, are they delineated such that they are not disturbed? (If disturbed, notify project engineer immediately)

Yes No *

N/A

Are there any historical elements to be salvaged or protected? (i.e. bridge plaques or historic bridge rail)

Yes No N/A

If any archaeological evidence were discovered during the course of construction (bones, burnt rock, flint, pottery), were the TxDOT Emergency Discovery Guidelines followed?

Yes No N/A

Change Orders

Has the district environmental staff reviewed all draft change orders to determine whether an environmental analysis and/or resource agency coordination is necessary?

Yes No *

N/A

If any environmental analyses are required, has it received clearance? Yes No *

N/A


Federal Listed and Proposed Threatened and Endangered Species, Critical Habitat, State Listed Species, and Candidate Species

Are there any listed species, etc., within project limits? Yes * No N/A

Is there designated critical habitat in the project area? Yes * No N/A

Was there consultation with the U. S. Fish and Wildlife Service and/or National Marine Fisheries Service for the project?

Yes No N/A

If yes to any of the above 3, are there any commitments or requirements for on-site mitigation for endangered species?

Yes No N/A

Are they being done properly? Yes No N/A

Are there any species/wildlife commitments for scheduling the construction activities for the project?

Yes No N/A

If yes, are they complied with? Yes No N/A

Are there any requirements for species monitoring during construction? Yes No N/A


Are there any commitments for state listed species within the limits of the project? Yes No N/A

Does the inspector have a current list of species on the “watch list” for the project? Yes No *

N/A

Are pictures and descriptions that help identify these species available on the project? Yes No *

N/A

Have any of the species been spotted on the project site during construction? Yes * No N/A

Do TxDOT and Contractor staff know what they do if they see a listed species on-site?

Yes No N/A

Essential Fish Habitat

Is there any essential fish habitat within project limits? Yes * No N/A

Is there designated essential fish habitat in the project area? Yes * No N/A

Was there consultation with the U. S. Fish and Wildlife Service and/or National Marine Fisheries Service for the project?

Yes No N/A

If yes to any of the above, are there any commitments or requirements for on-site mitigation for essential fish habitat?

Yes No N/A

If so, are they being done properly? Yes No N/A

Are there any essential fish habitat commitments for scheduling the construction activities for the project?

Yes No N/A



Natural Habitat Commitments

Are there any commitments for natural habitat mitigation in the right-of-way other than vegetation management issues?

Yes No N/A

Are the mitigation commitments stated in the project plans? Yes No N/A

Migratory Birds

Are there any concerns that migratory birds are nesting within project limits? Yes * No N/A

Have migratory birds or nests been noticed on the project in such a situation that a ‘take’ of the birds might occur?

Yes * No N/A

If a migratory bird ‘take’ might occur, has coordination with the resource agencies cleared the action?

Yes No N/A

Hazardous Materials

Are there any hazardous materials on the site or are there plans to use any hazardous materials during construction?

Yes * No N/A

Is there evidence of hazardous materials not identified in the PS&E? (for example underground storage tanks, containers, spills)

Yes * No N/A

If yes, immediately contact the Area Engineer.

11.9. MAINE DOT ENVIRONMENTAL AND SAFETY AUDITING POLICY AND PROCEDURE

Example 8: Maine DOT Environmental and Safety Auditing Policy and Procedure OBJECTIVE This policy establishes a procedure to implement an effective environmental auditing program in the Bureau of Maintenance & Operations (M&O), including an auditing plan, auditing program, and auditor training. M&O’s goal is to maintain a safe workplace, protect the environment, and have no violations in conducting regulated activities. M&O’s objective is to close all non-conformances within time limits set by management at the time audit findings are reviewed. Other important benefits of auditing are cross-training, increased awareness of environmental requirements among its staff, and continuous improvement.

M&O recognizes that environmental and safety auditing is necessary to reduce the risk of noncompliance, and to provide assurance that regulations, Department requirements, policies and procedures are being followed. M&O’s environmental auditing program will focus on prioritizing compliance issues, managing environmental risks, improving operations, reducing costs, and verifying the effectiveness of management systems that will ensure compliance. M&O will identify and prioritize audit issues, develop annual audit plans, and develop standard audit protocols or methods.

APPLICABILITY This policy is applicable to all Maine DOT maintenance divisions, including Highway Maintenance, Motor Transport Services (MTS), Bridge Maintenance and Traffic Engineering.

TARGET AUDIENCE This policy will be distributed to M&O supervisory personnel in Highway, MTS, Bridge, and Traffic Engineering, and other affected units of Maine DOT, including but not limited to: Director, Bureau of Maintenance and Operations; Director, Motor Transport Services; Maine DOT Division Managers/Engineers; Assistant Division


Engineers; Safety Coordinators; Superintendents, Managers, and Supervisors. This policy will also be distributed to: Director, Environmental Office (ENV); Manager, Water Resources and Hazardous Waste, OES.

RESPONSIBILITY • It is the responsibility of the Division Manager/Engineer to implement actions that will ensure compliance

with laws and regulations and Maine DOT’s environmental policies and procedures. • The M&O Director will charter a standing Environmental Management Committee to oversee the

implementation of the audit program. The Environmental Management Committee’s responsibilities will include, but not be limited to the following:

o Approve an annual environmental auditing plan for M&O o Approve (and revise as needed) environmental audit procedures for M&O o Receive reports of audit findings and communicate specific findings to appropriate levels of

management o Monitor implementation of corrective actions from audits o Annually evaluate the audit program (and develop evaluation criteria and methodology) o Recommend resolution of any appeals of Corrective Action Reports to the Bureau Director

It is the M&O Director’s responsibility to prepare the annual audit plan and to manage the implementation of the audit plan in accordance with this procedure, including the appointment and training of qualified auditors to serve on audit teams. It is the responsibility of the M&O Director to follow up with Division Managers to ensure that all corrective actions are completed or resolved in a timely manner.

It is the responsibility of all employees to be familiar with the Department’s environmental policies and procedures that affect their work, as documented in Maine DOT’s Environmental Policy and Procedures Manual.

It is the responsibility of the audit team leaders to plan and schedule audits according to the predefined scopes and purpose in conjunction with Division Managers/Engineers.

REQUIREMENTS Audit Team. Auditors will be qualified by training and experience, and will follow generally accepted guidelines as described in ISO 14010, 14011 and 14012. Auditors must be approved by the M&O Director based on experience, training, and education. M&O will conduct its auditing program with advice as necessary from Legal Services, and will employ a team approach including members of ENV, M&O management, and M&O staff. M&O will use internal Department staff to perform audits when possible, provided that the auditors’ duties and responsibilities are independent of the area and activities being audited and that auditors have proper training and experience. Outside auditors will be used when necessary to ensure independence, and when specific expertise and experience are required.

Audit Preparation/Planning. The Director of M&O, with advice from ENV and Legal Service, will define a “regulatory framework” of laws and regulations that apply to M&O. This framework will be used to prioritize risks, and to develop the annual audit plan. The Director of M&O will prepare annually a two or three year audit plan which will include, at a minimum, the following elements: 1) Identification of high priority environmental compliance risks; 2) Areas and activities to be audited, including; compliance with regulations and internal policies and procedures, the required frequency of the audits, and the expected dates during the upcoming cycle; 3) Audit team to conduct each audit, including the team leader; and 4) Information about the planned scope and general methodology of each audit.

Audit Execution • The Division Manager/Engineer of the area to be audited should be notified of the audit at least 45 days

prior to the audit. The notification will include a definition of the audit scope, topics, and protocols, as well as a pre-audit questionnaire (if appropriate).

• At least two weeks prior to the audit, the audit team leader will provide to the Division Manager/Engineer a proposed schedule for the audit, which will include meeting times and a list of personnel who will be


interviewed or otherwise must be present for the audit. At this time, certain documents may be requested by the audit team leader to help prepare for the audit. One week prior to the audit, a final audit schedule will be agreed upon between the audit team leader and the Division Manager/Engineer.

• The audit team will prepare, in advance, the audit methodology to be used, including checklists, worksheets, interview questions, and protocols.

• The audit team will conduct an Opening Meeting with the Division Manager/Engineer and local management employees from the area being audited. The purpose of this meeting will be to review the audit scope, methods, logistics, reporting requirements, Corrective Action Request forms, and follow-up requirements, including an appeals process.

• The audit team will use accepted methods (e.g., ISO or ASQ) to collect objective, verifiable evidence pertaining to the environmental aspects that are the subject of the audit. This evidence will include, but not be limited to observation, measurement, photographs, document review, interviews, testing, or inspection.

• Audit findings, including any non-conformances, will be recorded in writing, and may be entered into an audit tracking software program. Corrective Action Request (CAR) forms (example attached) will be completed prior to the closing meeting by the audit team member. Each CAR will be signed by a local management representative, who will be given a copy.

• The audit team may hold interim meetings daily with local management to address questions or issues that arise during the audit, or to revise the schedule as needed.

• The audit team will conduct a Closing Meeting with local management at the completion of the audit to review a summary of the findings before departing the area being audited. This meeting will include a discussion of each CAR, and the requirements for Corrective Action plans, including any appeals of CARs.

Audit Reporting and Corrective Action Follow-up • A written audit report will be prepared by the audit team within two weeks of the audit. Copies of the audit

report will be forwarded to the M&O Director and the Division Manager/Engineer of the area that was audited. Report distribution will be limited to individuals specified by the M&O Director.

• Within two weeks of receiving the audit report, the Division Manager/Engineer will submit to the M&O Bureau Director, a Corrective Action Plan, which will identify specific corrective actions, resources required, persons responsible for completion, any CAR appeals, and target completion dates.

• Completion of the corrective actions in the Corrective Action Plan will be monitored by the Environmental Management Committee on a bimonthly basis. Completed actions will be deleted from the Corrective Action Plan when evidence of completion is provided.

• If necessary, the audit team may be asked by the Environmental Management Committee to conduct a follow-up review of corrective actions to ensure effective implementation.

• Any environmental policies or procedures that are revised as a result of the auditing process will be done so according to the Environmental Procedure Development procedure.

COMMUNICATION AND TRAINING All environmental auditors, including outside contractors, will be trained on the contents of this procedure and Environmental Management Systems auditing standards ( e.g., ISO 14010, 14011, and 14012) prior to conducting any audits.

The M&O Director will communicate to all M&O employees a general statement regarding the scope and purpose of environmental auditing at M&O, either in environmental awareness training or through other written or verbal communication, such as by memorandum or in Department or M&O newsletters.

EVALUATION The Environmental Management Committee will conduct an annual evaluation of M&O’s environmental audit program. A written report will be provided to the Chief Engineer summarizing the findings of the environmental audit program evaluation.


Table 2: Mass Highway Compliance Tracking Roles and Responsibilities

Role Responsibility

Deputy Chief Engineer Environmental

Assumes ultimate responsibility to ensure proper tracking of compliance matters at the facilities.

DMEs Responsible for ensuring that compliance matters are properly identified and corrected by District Personnel.

Supervisor of HazMat/HazWaste Unit

Responsible for ensuring those out-of-compliance matters are addressed as quickly as possible and that issues that cannot be corrected within 14 calendar days are properly reported to the Clean State Database. Requests compliance tracking data from the District HazMat Coordinators and the Audit Program Coordinator.

DHCs Perform regular inspections that ensure the compliance matters are properly addressed at the facilities. Ensure proper review of weekly inspection reports submitted by the CSIII/Area Supervisors and or the CSII/Facility Foreman.

Audit Program Coordinator Maintains a record of all Self-audits including the Corrective Action Reports and the Clean State Matters Reports. Upon request by the Supervisor of the HazMat/HazWaste Unit will produce a record of all compliance issues identified by the Self —Audit Program.

11.10. MAINE DOT CORRECTIVE ACTION REQUEST FORM Figure 1: Maine DOT Corrective Action Request Form

Location: __________________________ Number: _________________

Originator: _________________________ Date: ___________ Time: ____

Type:

� Internal Audit � Consultant � Outside Inspector/Auditor � External Complaint

� Internal Complaint � Other _______________________________

Entered by: _______________________________ Date: ______________ Phone:_____________

Process or activity where problem is noted: Relevant standard/procedure/instruction: ___________________________________________

Condition found:


Acknowledged by: ___________________________________________ Date:_________________

Corrective Action Plan: Target Date for Completion: ___________ Approved by: _________________________________________ Date:____________________

Maine Department of Transportation, Bureau of Maintenance and Operations 3/1999

11.11. MASS HIGHWAY COMPLIANCE TRACKING METHODS Example 9: Mass Highway Compliance Tracking Procedure for Facilities Facility Inspections Facility inspections are performed by Mass Highway personnel on a quarterly, bi-monthly or monthly schedule based upon the operations conducted at each facility. Facility personnel perform weekly inspections of facilities equipped with Hazardous Waste accumulation areas.

A facility designated for vehicle or heavy equipment repair will be inspected monthly whereas a seasonal snow and ice facility is inspected quarterly. These regular inspections permit Mass Highway to gather compliance information on a more frequent basis as compared to the self-audits. The results of these inspections are transmitted to the District Maintenance Engineer who facilitates the correction of any out-of-compliance issues. Corrections are coordinated between the DME the CS III, Facility Foreman and the DHC. The results of these inspections and the documented corrections are maintained at the District headquarters. The respective District HazMat Coordinator reports compliance matters that cannot be corrected within 14 days of identification to the Supervisor of the HazMat/HazWaste Unit. The Supervisor instructs the Mass Highway Clean State Database Coordinator to enter the matter into the database with a schedule for correction. Progress made on correcting the compliance matter is reported to the Clean State Database on a quarterly basis.

Routine Facility Observations Mass Highway personnel are expected to keep facilities neat and generally adhere to good housekeeping practices. Furthermore, facility personnel are expected to report issues that may pose a potential compliance issue to their supervisor. Examples of potential issues that should be reported include but are not limited to the identification of dumping of materials in non-designated areas, missing spill equipment, spills and/or dripping fluids from containers and/or equipment.

Correcting Out-of Compliance Issues Out-of Compliance situations that have been identified by way of Inspection, Self-Audit and/or Due Diligence must be corrected as soon as possible. Simple corrections such as replacing a label or closing a container should be made upon discovery. Corrections such as replacing broken or missing equipment, equipment repairs, and waste disposal should be made in a matter of days. Efforts should be made to resolve corrections requiring the use of outside contractors within 14 days of identification.

Tracking Compliance Matters The Supervisor of HazMat\HazWaste Unit receives regular updates from the District HazMat Coordinators that identify any needed compliance corrections at the Facilities. This information is gathered from the regular facility


inspections. The District HazMat Coordinators also maintain a log of compliance issues that require Environmental Section intervention. All issues that cannot be corrected within the 14 calendar period will be entered into the Clean State Database. Out-of-compliance issues from self-audits are tracked with the Audit Program Coordinator using the Corrective Action Report and the Clean State Matter Report. All issues that have not been corrected are entered into the clean state database.

Compliance Tracking Roles and Responsibilities A summary of the roles and responsibilities for the Compliance Tracking Component is provided below.

11.12. MASS HIGHWAY COMPLIANCE TRACKING ROLES AND RESPONSIBILITIES Table 3: Mass Highway Compliance Tracking Roles and Responsibilities

Role Responsibility


Assumes ultimate responsibility to ensure proper tracking of compliance matters at the facilities.

DMEs Responsible for ensuring that compliance matters are properly identified and corrected by District Personnel.

Supervisor of HazMat/HazWaste Unit

Responsible for ensuring those out-of-compliance matters are addressed as quickly as possible and that issues that cannot be corrected within 14 calendar days are properly reported to the Clean State Database. Requests compliance tracking data from the District HazMat Coordinators and the Audit Program Coordinator.

DHCs Perform regular inspections that ensure the compliance matters are properly addressed at the facilities. Ensure proper review of weekly inspection reports submitted by the CSIII/Area Supervisors and or the CSII/Facility Foreman.

Audit Program Coordinator Maintains a record of all Self-audits including the Corrective Action Reports and the Clean State Matters Reports. Upon request by the Supervisor of the HazMat/HazWaste Unit will produce a record of all compliance issues identified by the Self —Audit Program.

11.13. MASS HIGHWAY SELF-AUDIT PROCEDURE Example 10: Mass Highway Self-Audit Procedure

This section presents an overview of the procedures and roles and responsibilities for conduct of Mass Highway Self-Audits. The actual Mass Highway Self-Audit Protocol Handbook is available for a detailed discussion of the procedures and roles and responsibilities. The procedures discussed below generally involve five Mass Highway staff members; the Audit Coordinator, the Lead Auditor, District Maintenance Engineer, the Facility Forman and the District HazMat Coordinator. There are three Phases to a Mass Highway Self-Audit; the Pre-audit Preparation, the Audit Site Visit and the Post Audit Phase. The process is described below.

Pre-audit Preparation. The Audit Coordinator prepares a schedule for facility audits. Once the schedule has been prepared, the Audit Coordinator will designate a DHC as the District Lead Auditor. The Lead Auditor will be a DHC from a District other than the one being audited. The Lead Auditors are provided with facility and District contact information needed to complete the self-audit notifications, site visit, and follow up reporting. The Lead Auditor will notify the DHC and DME in the District of the scheduled audit at least two weeks in advance of the audit. The DHC and DME will ensure pre audit questionnaires are completed, Facility foremen are contacted, and that facility records are made available at the time of the audit.

Audit Site Visit. The Lead Auditor will conduct a pre-audit briefing with facility personnel to 1) inform facility personnel of the purpose of the audit; 2) inform facility personnel of their audit responsibilities and required


participation in the audit; and 3) answer any preliminary questions the facility personnel may have regarding the audit. After the briefing, the Lead Auditor conducts a facility walkthrough, recording any environmental compliance findings in field notes and facility plans. The Lead Auditor also performs a record review of applicable compliance documents, such as manifests and environmental permits. During the walkthrough and records review, the Lead Auditor completes the Audit Protocol Checklist. Findings that may be immediately corrected should be completed during the walkthrough and documented by the auditor. The Lead Auditor then conducts exit briefings and submits the draft findings list to the Facility Foreman at the completion of each audit. The list is provided so facility personnel may initiate corrective actions in advance of receiving a Corrective Action Report (CAR).

Post Audit Phase. Following the audit site visit, the Lead Auditor prepares a CAR, which summarizes the audit findings. An electronic version is forwarded to the Audit Coordinator and the DME. Upon receipt of the CAR, the DME coordinates with the facility foreman to ensure facility personnel conduct the necessary corrective actions. DHCs are responsible for correcting or managing corrective actions that fall outside operational responsibility of the Facility Foreman or DME.

The Facility Foreman ensures that the corrective actions have been completed and documents corrective actions in the space provided on the CAR. The completed CAR is forwarded to the Lead Auditor for review and confirms that the completed actions adequately address the findings on the CAR. The completed CAR is forwarded to the Audit Coordinator along with a memo that summarizes the completed self-audit.

For each unresolved regulatory finding, the Lead Auditor completes a Clean State Matter Report (CSMR). If a completed CAR has not been received within 14 days of the audit a CSMR is completed for all regulatory findings identified on the original CAR. Within two days of receiving the completed CAR, the Lead Auditor forwards all audit field notes, checklists, completed CAR, and CSMRs to the Audit Coordinator for archiving in the Environmental Section’s Self-Audit Program files. The Audit Coordinator will enter all unresolved regulatory findings documented on the CSMRs into the EOEA’s Clean State Database.

The Audit Coordinator provides the audit findings to the DHC. The DHC will complete and transmit to the Audit Coordinator and DME a Corrective Action Plan (CAP) for each unresolved regulatory finding on the completed CAR. The DHC will provide quarterly CAP progress reports to the Audit Coordinator until the CAP has been completely resolved. The Audit Coordinator will enter the updates into the Clean State database. Once a CAP has been completely resolved, the Audit Coordinator will complete and submit a request for de-listing of a regulatory finding from the EOEA’s Clean State Coordinator and the Clean State database.

A summary of the timelines described in the preceding sections for conducting Self-Audits and audit follow-up activities is provided below.

Activity Responsible Person Timeline

Assign Audit Team and Lead Auditor Audit Coordinator According to Annual Schedule

Notify DHC, DME, and Facility foreman of impending Self-Audit

Lead Auditor At least two weeks before audit site visit date

Complete and submit CAR to DHC, DME, and Foreman

Lead Auditor Within two days after audit site visit.

Complete and submit CAR and CCAR to Lead Auditor

Foreman/DHC Within 14 days of the date the audit was conducted

Complete audit summary memo and CSMRs and submit to Audit Coordinator

Lead Auditor Within 1 week after receipt of CCAR or within 2 days of CCAR due date

Enter audit results into Clean State database and submit final CAR to DHC

Audit Coordinator Within 2 weeks after receipt of CCAR from Lead Auditor

Complete Corrective Action Plan DHC Within 21 days after receipt of final CCAR from Audit Coordinator

Complete CAP Progress Reports DHC Quarterly — ongoing until Final CAP Completion Report issued


Update of Clean State database Audit Coordinator Quarterly — ongoing until Final CAP Completion Report issued

Mass Highway has a thorough system for performing environmental audits of maintenance facilities. This system and accompanying tools will be discussed in greater detail in the Facilities section. Checklist items cover hazardous waste, solid waste, water quality and natural resources, as follows, and include space to note comments and needed corrective actions:

11.14. MASS HIGHWAY FACILITY SELF-AUDIT CHECKLIST Example 11: Mass Highway Facility Self-Audit Checklist Hazardous Waste

1. Are all containers closed?

2. Are all containers labeled?

3. Is the waste compatible with the container and/or its liner?

4. Are containers holding ignitable or reactive wastes located at least 50 feet from the property line?

5. Is the accumulation area delineated?

6. Is the accumulation area posted with a sign?

7. Is secondary containment provided?

8. Is sand contained within a containment area?

9. Is salt contained indoors?

10. Are hazardous materials stored in appropriate locations?

11. Are hazardous materials stored in proper containers?

12. Are all hazardous material containers closed and labeled?

13. Are MDSS and right-to-know information prominently posted?

14. Are hazardous materials stored near floor drains?

15. Are all compressed gas cylinders properly sorted (labeled, capped, chained, or in rack)?

16. Are there any leaking vehicles/equipment present?

17. Are materials other than hazardous waste present in accumulation areas?

18. Is hazardous waste present outside the accumulation area?

19. If present, are satellite accumulation area requirements being met?

20. Are emergency contacts posted?

21. Does the facility have a supply of spill absorbents available?

22. Are weekly inspections being performed?

23. Are accumulation volume limits exceeded for the generator status?

24. For SQGS only: are hazardous wastes being stored for longer than 180 days?

25. Are all self-transporting two part receipts on file?

Solid Waste 1. Are bulk solid wastes stored in designated storage bins or segregated by type?

2. Are dumpsters and trash cans free of hazardous wastes, regulated recyclables, and universal wastes?

3. Is the facility free of litter?


4. Is solid waste accumulated in a natural resource area? (refer to facility plan)

5. Are there any decommissioned/ abandoned vehicles or equipment present?

6. Underground/aboveground storage tanks

7. Is there any evidence of spillage around tank fill ports or dispensing pumps?

8. Are required tank permits/registrations clearly posted at the facility?

9. For outdoor aboveground petroleum storage tanks: is secondary containment provided?

10. For aboveground storage tanks (including propane and calcium chloride tanks): are the tanks clearly placarded or labeled with their contents and NFPA ratings?

11. Are weekly stage ii vapor recovery inspections being performed?

Water Quality 1. Are garage floor drains clear of debris or obstructions and functioning properly?

2. Do floor drain sumps/troughs require sediment removal?

3. Is there evidence of oil or hazardous materials entering a floor drain or catch basin?

4. For wastewater recycling systems: are the systems functioning properly?

5. For wastewater tight tanks or recycling systems: does the tank or system need to be pumped?

6. Record current volume in tank or system.

7. Is there evidence of sand or sediment entering any catch basins or other drainage structures at the facility?

8. Is the oil/water separator functioning properly

Natural Resources 1. Are there any regulated wetland resource areas or waterways on or adjacent to the facility? (i.e. vegetated

wetlands, banks, floodplains, land under water, and the riverfront area) note: refer to the facility plan for confirmation.

2. Are there activities occurring which are resulting in direct impacts to a wetland resource area or waterway? Note: direct impacts include filling, excavating, dumping, or altering.

3. Are there activities occurring which are resulting in indirect impacts to a wetland resource area or waterway? Note: indirect impacts include erosion, sedimentation, or siltation.

4. Are there activities occurring within the buffer zone that are resulting in direct or indirect impacts to any vegetated wetland or bank to a waterway?

11.15. MASS HIGHWAY ENVIRONMENTAL ROLES & RESPONSIBILITIES Example 12: Mass Highway Environmental Roles & Responsibilities

Commissioner The Commissioner is responsible for ensuring that Mass Highway’s EMS is integrated as a fundamental part of daily operations and is supported by all managerial and supervisory levels of the Department. In doing so, the Commissioner’s Office ensures the EMS is consistent with the Department’s overall Mission Statement, Goals and Objectives; the facilitation of agreements with other Massachusetts State Departments including the Department of Environmental Protection; adequate EMS related funding and staff levels as recommended by the Chief Engineer.

Chief Engineer The Chief Engineer ensures that the needs for staffing and resources for the sustainability of this EMS are defined and communicated to the Commissioner and that environmental policies and programs are effectively implemented and communicated by senior management. The Chief Engineer also ensures that the EMS is reviewed on a regular basis and that practical measures are implemented to improve its effectiveness.


Administrative Services Division The Administrative Services Division provides Mass Highway EMS support in areas of Budget, Training, Safety, Information Technology Systems (ITS), and Personnel. A summary of the roles and responsibilities for the Administrative Services Division is provided below.

Projects Division The Projects Division is responsible for ensuring that environmental laws and regulations are considered and properly addressed during the design phase of projects at Mass Highway facilities and directly supports all components of the Environmental Management System. The Projects Division consists of the following Sections; Bridge, Highway Design, Highway Administration, Right-of-way, Project Management and, Environmental. The Section primarily responsible for stewardship of the EMS is the Environmental Section.

Environmental Section The Environmental Section provides expertise in interpretation of environmental regulations, compliance program development and implementation, compliance budget analysis, compliance inspection and reporting and environmental SOP/policy review and development. The Environmental Section supports the EMS with defined roles and responsibilities to maintain environmental compliance at facilities. Below is a summary of general Environmental Section roles and responsibilities. Specific roles and responsibilities are provided in the descriptions of the individual EMS components of this manual.

11.16. MASS HIGHWAY ENVIRONMENTAL SECTION EMS ROLES AND RESPONSIBILITIES

Table 4: Mass Highway Environmental Section EMS Roles and Responsibilities

Role Responsibility Deputy Chief Engineer Environmental

Responsible for managing the Sections roles and responsibilities relative to this EMS; ensures that the EMS review is conducted and continual improvements are made within the Division.

Supervisor of HazMat /HazWaste Unit

Serves as the steward for the EMS. Responsible for the accuracy of the manual and its specific components including funding, Emergency Preparedness, Environmental Requirements, SOPs, Facility Handbook, Training, Compliance Tracking and, Self-Auditing, and EMS Review. Coordinates and facilitates programs including Hazardous Waste, Wetlands, Hazardous Materials, Tanks, Water Quality, Solid Waste, and Massachusetts Contingency Plan. Assigns tasks to Section personnel to ensure compliance with State and Federal regulations. Maintains current Environmental Requirements List; arranges quarterly meetings with regulatory agencies; assists the Deputy Chief Engineer Environmental with EMS review process.

Audit Coordinator Ensures that the Self -Audit Program functions in accordance with the Mass Highway Self Audit Protocol. Performs regular review of the program and recommends modifications in accordance with changes in Mass Highway’s operations at Facilities.

Training Coordinator Administers Environmental Training Program by maintaining a current list of required training and notifies respective staff of upcoming training. Coordinates submittal of training registration documentation. Maintains training records for Environmental Section.

EMS Task Force Participates in the annual EMS Review and evaluation process.

Supervisor of Wetlands and Water Quality

Manages NOI and RDA process; obtains and tracks Order of Conditions; file Completeness Reports; oversees Departments compliance with stormwater regulations. Ensures corrective actions are implemented to comply with the Massachusetts Wetland Regulations and Administrative Consent Orders.

District HazMat Coordinators

Play key roles in implementation of EMS component programs including Requirements, Self-Audits/Inspections, Emergency Preparedness, Environmental Training, and SOP

f i i f ( i h ldi kChapter 11: Appendix 20

programs. May arrange for inspection of systems (septic systems, holding tanks, oil/water separators, and vehicle wash recycling systems). May arrange for disposal of wastewater; forward water usage reports to Supervisor of HazMat/HazWaste Unit; ensures that monitoring wells are inspected, permits/as-built plans are kept at facilities, compliance with permit-specific requirements, inspects for presence of appropriate backflow prevention devices on drinking water sources/cross connections; conducts regular inspections of facilities, assists in obtaining Material Safety Data Sheets, assists in identification of unknown roadside materials; prepares Tier II Reports; manage MCP consultant contracts and provide MCP technical assistance; assists Supervisor of HazMat HazWaste Unit with on-site observation of contractor work; sign MCP submittal certifications; maintain hazardous waste generator registration and manifest files; arrange/notify when waste disposal is required; arrange for removal of unknown/roadside wastes; develop and conduct annual environmental awareness training; review options for street sweeping disposal; conduct facility audits.

Boston HazMat Staff Play key roles in implementation of EMS components including Environmental Requirements, Environmental Training, and SOPs. Manage contracts and timelines to support compliance with environmental requirement, EMS support programs and administrative consent orders; submit reports that track compliance progress to DEP and EPA. Track the status and provide guidance on permit renewal and assist as needed to ensure Mass Highway remains in compliance with applicable permits. Manage MCP consultant contracts; assist supervisor of HazMat/HazWaste Unit with MGL ch. 21E and the MCP tank permitting; manage Stage II Vapor Recovery forms/documentation; assist with NOI and RDA process.

Right-of-way Section The Right-of-way (the Section) is responsible for ensuring that properties being considered for purchase by Mass Highway for use as facilities receive proper real estate assessment for the identification of environmental compliance liabilities. The Section is also responsible for ensuring that facility properties receive canvassing by Mass Highway Environmental staff prior to disposition.

Operations Division The Operations Division is responsible for the implementation of the EMS to ensure that Districts/facilities receive proper personnel and contract support to ensure compliance with environmental regulations, Mass Highway SOPs and policies and, Administrative Consent Orders. The Operations Division is responsible for ensuring that all permits are secured for construction and improvement activities at the depot facilities and that copies of all permits are forwarded to the Projects Division/Environmental section. This applies to existing Units within Operations: Highway Maintenance, and Traffic Engineering and Operations. For the purpose of the EMS, Operations pays particular attention to current facility operations, proposed facility improvements and, lease agreements involving Mass Highway facilities. Operations staff ensures that the EMS is properly implemented at maintenance buildings and Draw Bridges. A summary of roles and responsibilities for the Operations Division staff is presented below.

11.17. MASS HIGHWAY OPERATIONS DIVISION EMS ROLES AND RESPONSIBILITIES

Table 5: Mass Highway Operations Division EMS Roles and Responsibilities

Role Responsibility Deputy Chief Engineer Operations

Ensures that the EMS review is conducted and continual improvements are made within the Division to ensure compliance with the EMS related to facility operations.

Operations Engineer Ensures proper support of the EMS from the Highway Maintenance Unit (Snow and Ice, Communications, Structure Maintenance, Facilities); Equipment and Materials (Central Stockroom in Franklin, Heavy Equipment maintenance, repair, storage and auctions,


Truck and Car fleet, Medford Sign Shop, Paint Crew (long Lines), Fuel Management; Traffic Engineering and Operations; ITS Programs (HOV Lane). Obtains and ensures compliance with applicable permits for Operation’s facilities. Responsible for implementation of the EMS and environmental compliance for Line Painting operations including cleaning of painting equipment without releasing cleaning residuals into the environment and ensures proper storage of any hazardous material and/ or wastes. Ensures that the foreman of each paint crew coordinates environmental related activities with the respective Facility Foreman to ensure environmental compliance.

Provides contract support and guidance to Unit and District maintenance personnel in such a manner that supports compliance with the EMS. The ensures that personnel are aware of Mass Highway Environmental Standard Operating Procedures, Policies, Administrative Consent Orders and environmental regulatory requirements. Ensures that facility project designs include proper environmental permitting in accordance with Federal and state regulations. Ensures that provisions are included for the operation of completed designs in accordance with issued environmental permits.

Construction Division The Construction Division is responsible for ensuring that environmental laws and regulations are considered and properly addressed during construction of projects on Mass Highway facilities.

Research and Materials Testing Laboratory The Research and Materials Testing Laboratory is responsible for ensuring that the laboratory is operated in accordance with federal and state regulations and Mass Highway’s SOPs in support of Mass Highway’s EMS.

EMS Task Force The EMS Task Force is composed of representatives of Offices, Divisions, Districts, and Sections. The Task Force provides input to the Annual EMS Review and Evaluation Process.

Districts The Districts are responsible for the implementation of the EMS at District facilities and to ensure that operations at facilities are in compliance with environmental regulations and Mass Highway SOPs. A summary of District EMS roles and responsibilities for facility compliance is provided below.

11.18. MASS HIGHWAY DISTRICT EMS ROLES AND RESPONSIBILITIES Table 6: Mass Highway District EMS Roles and Responsibilities

Role Responsibility District Highway Director

The District Highway Director is responsible for being familiar with and overseeing the implementation of the provisions of the EMS such that the District’s roles and responsibilities are carried out in such a manner so as to maintain environmental compliance.

District Maintenance Engineer

The District Maintenance Engineer (DME) must maintain an awareness of the EMS and is responsible for coordinating facility maintenance activities in accordance the procedures of the EMS Manual. This includes ensuring that facility personnel are allotted sufficient time to perform house keeping tasks that support environmental compliance and notifying appropriate Mass Highway personnel of an emergency situation at facilities in accordance with Mass Highway’ s Emergency Response Plan (ERP) and Spill Prevention Control and Countermeasure (SPCC) Plans at specific facilities. Obtains and ensures compliance with all applicable permits for District facilities.

Contract Specialist III’s/Area Supervisor

The Contract Specialist III/Area Supervisor (CS III/AS) ensures that: all personnel within the Area receive yearly Annual Environmental Awareness Training; facility inspections are conducted and that corrective actions are completed as required; EMS and Environmental


Program documentation (generated by Facility Foreman and personnel) such as regular inspection checklists, Stage II Vapor recovery system checklists, Hazardous Waste area inspections checklists and oil/water separator inspection reports are forwarded to the District Maintenance Engineer. Responsibilities also include: review and submittal of the facility inspection reports/self-audit findings to the DME and initiating corrections as required; scheduling work as needed at facilities to maintain compliance including: septic system pump-outs, septic system inspections, vehicle washing recycling system maintenance and holding tank and oil/water separator pump-outs. The CS III/AS is also the designated Primary Emergency Coordinator as defined by Mass Highway’s Emergency Response Spill Plan.

Contract Specialist II’s/Facility Foreman

The Contract Specialist II/ Facility Foreman (CSII/FF) is responsible for ensuring that all operational activities that impact environmental compliance at District Facilities are conducted in accordance with the EMS and specifically with the provisions of the Facility Environmental Handbook. This includes maintaining proper areas for material and hazardous waste storage; using the emergency response call down procedures; adhering to guidelines presented in the Annual Environmental Awareness Training; staying current with the Environmental Standard Operating Procedures and being familiar with the location of wetlands, buffer zones and other areas of environmental concern.

Facility Personnel The Facility Personnel are responsible for keeping work areas clean and materials and wastes stored properly, performing inspections on the Hazardous Material and Hazardous Waste storage areas, maintaining labels on material and waste containers, reporting spills of hazardous materials from machinery and heavy equipment and, attending annual refresher training related to environmental compliance.

Director of Equipment and Materials

Provides for EMS compliance at the Central Stockroom relative to proper hazardous material storage, appropriate HazMat labeling/signage, and proper management of Material Safety Data Sheets. Purchases materials that support EMS such as absorbents (pads, booms, Speedi-dri) spill kits for distribution to District stockrooms, and maintains an effort to purchase environmentally preferred products whenever practical. Ensures an adequate supply of fuel equipment such as nozzles and hoses that comply with the Department’s current fueling system. Provides for the support of the Department fuel management system; perform testing, inspection and reporting of storage tanks and monitors storage tank leak detection systems. Ensures that decommissioned vehicles are stored in a manner that supports compliance with the Departments SOPs, and this EMS.

11.19. MASS HIGHWAY TRAINING EXPECTATIONS BY ROLE Table 7: Mass Highway Training Expectations By Role

Training Regulation and Requirement Participants Delivery

Hazardous Waste

Awareness Training

310 CMR 30.351(9)(g) Employees having responsibility for handling/managing hazardous waste at SQG facilities must be properly trained so they know how to perform their duties and so that hazardous waste handling practices and emergency procedures are performed properly and in compliance with all applicable requirements. Employees are provided initial training to a competency level with refresher training as necessary.

District Structures Maintenance Engineer, CSIII/Area Foreman, HOV Facility Personnel, CSII/Facility Foremen, Facility Personnel District HazMat Coordinators

Training provided during annual Environmental Awareness Training by DHCs

Universal Waste

310 CMR 30.1035 Employees having the responsibility for handling or managing universal

District Structures Maintenance

Training provided


Training waste shall be informed of the proper handling and emergency procedures appropriate to the types of universal waste handled at the facility. Employees are provided initial training to a competency level with refresher training as necessary.

Engineer, CSIII/Area Foreman, HOV Facility Personnel, CSII/ Facility Foremen, Facility Personnel, District HazMat Coordinators.

during annual Environmental Awareness Training by DHCs

Department of Transportation

General Awareness, Manifest, and Safety Training Programs

49 CFR 172.704(a) 310 CMR 30.409 Each hazmat employee shall be provided 1) general awareness training designed to provide familiarity with the requirements of this subchapter, and to enable the employee to recognize and identify hazardous materials consistent with OSHA Hazard Communication Standard (29 CFR 1910.1200). OSHA or EPA training may be used to satisfy the requirements of 49 CFR 172.704(a) to avoid duplication of training efforts; 2) function specific training concerning the requirements of the DOT hazardous waste regulations specific to the function the employee performs; 3) safety training concerning emergency response information, measures for protection from the hazards associated with hazardous materials, and methods and procedures for avoiding accidents. Employees are provided initial training to a competency level with refresher training every 3 years thereafter.

District HazMat Coordinators, CSII/Facility Foreman

Training coordinated by Environmental Division and conducted through a consultant contract

Stage II Vapor Recovery System Inspection Training

310 CMR 7.24 Persons performing Stage II systems weekly inspections must be trained to inspect equipment including, but not limited to, nozzle boots and splash/vapor guards, hoses, hose retractors, coaxial adapters, dry breaks, fill caps, vapor recovery caps, spill containment boxes and drain valves. Employees are provided initial training to a competency level with refresher training as necessary.

CSIII, Foremen, Laborers

Training is provided by the DHCs.

Spill Prevention Control and Countermeasure (SPCC)

40 CFR 112.7(e)(10) (iii) Employees shall be trained in the use of the SPCC, applicable pollution control laws and the operation and maintenance of equipment to prevent the discharges of oil. Employees are provided initial training to a competency level with annual refresher training.

Employees having a role in the SPCC plan for a facility

Training provided during annual Environmental Awareness Training by DHCs

Roles and responsibilities accompanying the training program are as follows:


11.20. MASS HIGHWAY ENVIRONMENTAL TRAINING PROGRAM ROLES AND RESPONSIBILITIES

Table 8: Mass Highway Environmental Training Program Roles and Responsibilities

Role Responsibility


Assumes ultimate responsibility for managing the Environmental Training Program

Operations Engineer, Maintenance Engineer, District Maintenance Engineer

Responsible for ensuring appropriate personnel attend environmental training programs relative to their roles and responsibilities within the EMS and maintaining training attendance records for Boston Operations staff assigned to Central Stockroom in Franklin, Paint Crews stationed in Deerfield, Reading, and Bridgewater Facilities.

DMEs Responsible for ensuring appropriate personnel attend environmental training programs relative to their roles and responsibilities within the EMS and maintaining training attendance records for District Operations staff.

Projects Division Training Coordinator

Responsible for developing an annual budget for submission to Administrative Services, coordinating the training schedule, ensuring contracts are in place for training consultant services and conducting the annual review of the training program in accordance with the EMS.

Supervisor of HazMat\HazWaste Unit

Responsible for the approval of training program content revisions.

DHCs The DHCs develop and deliver the Annual Facility Environmental Awareness Training program and initial SPCC training within their District and participate in the annual review of the environmental training program.

Environmental Staff

Environmental staff annually reviews the environmental training programs to determine if regulatory or operational changes necessitate revisions to the program. Share training materials over the MHD intranet.

EMS Task Force

(Admin, Ops, Project, & Construction Divs.)

Provides comment and guidance to the Environmental Section, Safety Unit and Incident Response Unit relative to the feasibility and content of environmental training programs.

Safety Unit Develops and presents the Right-to-Know Training.

Administrative Services

Identifies environmental training budgetary needs as part of the operations budget, communicates the availability of funding to the Environmental Section, and maintains training documentation for the Department.

ITS Posts PowerPoint presentations onto the Mass Highway intranet.

11.21. PENNDOT DISTRICT 10 SEMP RESPONSIBILITY TABLE Table 9: PennDOT District 10 Strategic Environmental Management Program Responsibility Table

Working Title Responsibility Statement (refer to Section 6. of the Job Description) District Directs activities to fulfill the maintenance environmental requirements described or


Engineer referenced in the District’s Strategic Environmental Management Program (SEMP) Manual for Sound Environmental Practices. This direction of activities includes efforts to ensure that, within the fiscal constraints imposed through the Department’s budgetary processes, resources are made available to fulfill the District’s SEMP commitments and objectives. As a member of the District’s Strategic Management Committee (SMC) performs the activities to fulfill the requirements identified for members of the SMC in the District’s SEMP Development and Implementation Manual.

Directs activities to fulfill the District’s SEMP-related business plan objectives.

Attends environmental training identified for this Working Title and for members of the SMC in the District’s SEMP Manual for Sound Environmental Practices.

ADE Maintenance

Plans, organizes, and directs activities to fulfill the maintenance environmental requirements described in the Maintenance, MORIS, and Bridge Maintenance Manuals, and identified for this Working Title in the District’s Strategic Environmental Management Program (SEMP) Manual for Sound Environmental Practices. This planning, organization, and direction of activities includes efforts to ensure that, within the fiscal constraints imposed through the Department’s budgetary processes, resources are made available to fulfill the District’s SEMP commitments and objectives. As a member of the District’s Strategic Management Committee (SMC) performs the activities to fulfill the requirements identified for members of the SMC in the District’s SEMP Development and Implementation Manual. Also fulfills the environmental management requirements designated for this title in environmental training programs.

Implements the SEMP-related maintenance unit business plan objectives designated for this title. Supports the efforts of other managers and employees to implement the SEMP-related maintenance unit business plan objectives.

Attends environmental training identified for this Working Title and for members of the SMC in the District’s SEMP Manual for Sound Environmental Practices.

County Maintenance Manager

Manages, plans, and organizes county roads maintenance activities to fulfill the environmental management requirements identified in the Maintenance, MORIS, and Bridge Maintenance Manuals and designated for this title in the District’s Strategic Environmental Management Program (SEMP) Manual for Sound Environmental Practices. This management, planning, and organization of activities includes efforts to ensure that, within the fiscal constraints imposed through the Department’s budgetary processes, resources are made available to fulfill the District’s SEMP commitments and objectives. Receives new information for or revisions to the District’s SEMP Manual for Sound Environmental Practices from the District SEMP Process Owner, incorporates this information in each county and stockpile copy of the District’s SEMP Manual for Sound Environmental Practices, and implements the new or revised SEMP procedures, processes, or tools. Also fulfills the environmental management requirements designated for this title in environmental training programs.

Implements the SEMP-related maintenance unit business plan objectives designated for this title. Supports the efforts of other managers and employees to implement the SEMP-related maintenance unit business plan objectives.

Attends environmental training designated for this title in the District’s SEMP Manual for Sound Environmental Practices.

Transportation Equip. Operator B

Implements the environmental protection requirements of maintenance work activities performed by the employee. Also fulfills the environmental management requirements designated for this title in environmental training programs.


Transportation Equip. Operator A Temp. Equip. Op.A Hwy Maint. Worker Hwy. Sign Worker Carpenter Mason

Recognizing that everyone is involved in the District’s and County’s actions to demonstrate sound environmental practices, each employee fulfills the maintenance unit business plan objectives related to the Strategic Environmental Management Program (SEMP). Also, supports the efforts of other employees to meet these objectives. Attends environmental training designated for this position in the District’s SEMP Manual for Sound Environmental Practices.

Table from PennDOT District 10’s Strategic Environmental Management Program Manual


11.22. PENNDOT DISTRICT 10 SEMP TRAINING TABLE Figure 2: PennDOT District 10 Strategic Environmental Management Program Training Table

Working Title

Envi

ronm

enta

l Aw

aren

ess

Sto

ckpi

le/F

acili

ties

Acad

emy

Sto

ckpi

le/F

acilit

ies

Ref

resh

er

E&S

Con

trol

E&S

Con

trol R

efre

sher

Win

ter S

ervi

ces

Sprin

g M

aint

enan

ce M

eetin

g

Fall

Mai

nten

ance

Mee

ting

New

Em

ploy

ee O

rient

atio

n P

rog.

Firs

t Res

pond

er/In

cide

nt R

espo

nse

County Maintenance ManagerAssistant Maintenance Manager

Highway Foreman I, II, and IIITransportation Equipment Operator BTransportation Equipment Operator ATemporary Equipment Operator AHighway Maintenance WorkerHighway Sign WorkerCarpenterMason

County Equipment ManagerMechanic Supervisor

Automotive MechanicEquipment Body Repairer PainterMaintenance RepairmanTradesman HelperSemi-skilled LaborerWelderDiesel MechanicCustodian

County Roadway Programs CoordinatorChief ClerkRoadway Programs Technician (RPT)Radio OperatorStock Clerk

Accounting Assistant

Purchasing Agent

Clerical Staff

Training ProgramsC

ount

y M

aint

enan

ce U

nit

Table from PennDOT District 10’s Strategic Environmental Management Program Manual


11.23. NYSDOT CONSTRUCTION/ENVIRONMENTAL TRAINING SCHEDULE Table 10: NYSDOT Construction Environmental Sample Training Schedule

Region Topic(s) Presenter(s) Audience (#) Date(s) 1a. Environmental and Landscape Permits, Issues

and Practices - SEQR, Wetlands, SPDES, ECOPAC, Tree Preservation, Landscaping Enhancements

D. Hitt, D. Goetke, M. Manosh, R. Ambuske, D. Graves, C. Schleede

EICs 1/28/03

2a. General Environmental Awareness, West Nile, SPDES, Waste Areas

E. Warner, E. Frantz, DEC

Winter Construction Meeting (80)

3/12/03

3a.

Erosion and Sediment Control, Tank Removal, Haz Waste, Asbestos, ECOPAC, SPDES, Waste Areas, Lead Paint (7.5 hrs)

R. Steele, C. Anderson, H. Koslowsky

Construction Staff and Contractors(25)

2/10/03 3/10/03 4/10/03 4/25/03

3b.

Erosion and Sediment Control, SPDES, Waste Areas (1 hr)

R. Steele Contractors (50) 3/14/03

3c.

Haz Waste (1 hr) R. Steele, M.

Brophy Bainbridge Residency (20)

3/18/03

3d.

Hazcom for NYSDOT (1 hr) R. Steele

March

4a.

Disposal of Surplus Material-BMPs (1 hr) T. Martin AGC/DOT Conference (50)

12/11/02

4b.

Disposal of Surplus Material-BMPs (1 hr) T. Martin MEC/CEC Statewide Meeting (60)

1/17/03

4c.

Disposal of Surplus Material-BMPs (1 hr) T. Martin New EIC Training

(40) 2/7/03

4d.

SPDES, Section 209 (1 hr) T. Martin EIC/Field Staff

Winter Training (100)

2/26/03

4e.

Solid and Haz Waste Regs (30 min) T. Martin

LAB/EAB Conference(25

3/6/03

4f.

Haz Waste Manifests (45 min) T. Martin EIC/Field Staff

Winter Training (55) 3/13/03

5a. Environmental Ethic, Wetlands, Streams, Water Quality, MBTA, Erosion and Sediment Control, Cultural resources, Asbestos, Noise, Air Quality, Trees & Planting, Curb, Ramps,

Shepherd, NYSDEC, Wheeler, Jones, Kluck,

Construction Inspectors School (75)

2/10/03 2/18/03 2/28/03


Pedestrians Christner, Tackley

5b. Same as above with emphasis on E&SC and Contractor Responsibilities

J. Shepherd Contractor (20) 2/27/03

5c. Same J. Shepherd EIC Annual Training (55)

3/13/03

6 SPDES Phase 2 Construction Permit (At So. Tier Reg Planning Board Conference)

T. Markel, NYSDEC

Town Highway Superintendent

4/10/03

8a-c

Erosion and Sediment Control, SPDES, 209 Revisions (2 hr)

J. Ayers, J. Fogietta

EICs and Inspectors(100

1/28, 29 & 30/03

8d-g

Erosion and Sediment Control (1 hr) J. Ayers, S. Davis

Residency Maintenance Staff (110)

2/24-27

10 Environmental Awareness, SPDES, Erosion and Sediment Control, etc

L. Star EIC Annual Mtg (45) 2/4/03

11.24. ENVIRONMENTAL CHECKLIST FOR MODOT FACILITIES Surveys are conducted of all maintenance facilities to establish compliance with federal, state and local environmental regulations. The form used to conduct these surveys covers areas of concern.

District____

1-Facility

Name: ___________________________ Date: ________/_________/_______

Address: _________________________ City: _________________ Zip: _______

2-Drinking Water

Private System _____ Distance to Public system ______ miles

Public System _____ Name: ______________________________

Backflow Preventer where needed: Yes______ No ______

Comment: _________________________________________________________

3-Sewage system

Private System: _____ Lagoon: _____ Tile field: _____ Working? ________

Distance to public system______ miles Name: ____________________

Public System: ______ Name: ___________________________________

Floor Drains Yes ___ No ____ (If yes) Connected to sewer ____ Tile field____

Daylight to ditch _____ Drains: plugged _____ covered _____


Comments: ______________________________________________________

4-Salt Storage

Type of Salt Building: Fabric ____ Dome _____ Bay _____ (# bays) _____

Gabriel _____ Outside pile _____ (covered? No ____Yes____

Type of cover ________________________)

Storage Building Condition: _____________________

Salt Basin ______ Salt Pond ______ (needed yes ____ no ____)

Salt Damage Yes____ No____ if yes----Onsite: ____ Offsite: ____

Damage result of Storage _____ salt pond_____ accident ____

Result of Past ______ Current ______ problems

Claim paid or land bought Yes _____ No _____

Comment: _______________________________________________________

5-Hazardous Material Storage

Evidence of Leaks or Spills Yes ____ No _____ (ongoing Yes ____ No ____)

Incompatible Chemicals stored separately Yes ____ No _____

Containers Properly Labeled Yes ____ No _____

Comments: ________________________________________________

Closed ____ Open _____

Parts Cleaner Closed _____ Open _____ Brand ______________________

Recycled ____ Filtered ____

Old Lead Acid Batteries Yes ____ No _____ (properly stored Yes ____ No ___

Comment: _________________________________________________________

____________________________________________________________

____________________________________________________________

6-Gasoline, Diesel Fuel, Oil, Asphalt, and Used Oil

Tank Number & Size (gallons): Gasoline (___)_______, Diesel (___)________

Kerosene (___)________Asphalt (___)________ (in service Yes ___

No___) Used Oil (___)________ Other _________________________


Containment: Largest tank plus %10 Yes ____ No _____ Some _______

Total Tanks/containers over 1,320 gallons Yes ____ No _____

(containers under 55 gallons not counted in total)

List Tanks that need containment: ____________________________

________________________________________________________

________________________________________________________

SPCC plan Yes _____ No _____ In the works _______

Containers Labeled Yes ____ No ____ Need _______________________

New Oil In containment Yes ____ No____

Floor Drains if present plugged Yes ____ No ____

connect to oil/water separator Yes ____ No ____

Used Oil in containment Yes____ No____ Tank or drum size _______ gal.

Used Oil Heater used at site Yes ____ No ____

If not for heat, disposal method ________________________________

Cost per gallon ______ Company ________________________

Comments: ______________________________________________________

7-Solid Waste Management

Waste Tires Hauled by Corrections Yes ____ No ____ (company)____________

No. Stored on site _______ More than 25 under cover Yes ____ No ____

Types of Waste Segregated Yes ____ No ____

Street Sweepings stored at site Yes ____ No ____ Disposal Method ___________

Landfill Name & Location ____________________________________________

Oil Filter Disposal: Landfill ______ Recycle _____ Company _______________

Comments: ________________________________________________________

8-Neighboring Environmental Concerns

One Mile – NPL Site ______________________, RCRA site ________________

Landfill site________________________________

Adjoining Property – UST _________________, RCRA site ________________,


Discharge to site _________________, Storage Tanks _______________,

Drums ___________, Stressed Vegetation _________Pits/Ponds _______,

Lagoons __________, Septic Waste ________, Wells _______________,

Property use for (i.e. residential, industrial or rural)__________________

9-Comments

Inspector Sign: __________________________________ Date: ___________________

11.25. PENNDOT STOCKPILE QUALITY ASSURANCE RESPONSIBILITIES Example 13: PennDOT Stockpile Quality Assurance Responsibilities

Foremen • Decide when walkaround best fits his/her schedule for the week (1 required per/week)

• Discuss his vision with all crew members

• If feasible, select one or two crew members to join him

• Check all items on payroll checklist and documents

• Check any other noticeable deficiencies and records in payroll remarks section

• Address any safety problems immediately if possible

• Report any safety problems unable to be addressed immediately to ACM

• Take care of any deficiencies he is able to during walkaround

• Finish walkaround and reports to his planned activity for that day

• Charge stockpile code for time spent doing inspection

Crew members • Participate in walkaround with foreman and helps him/her address any deficiencies

• Get first hand knowledge what stockpile deficiencies are being looked for

• Get clear idea of what his role is when it comes to stockpile maintenance

• Carry what he/she has learned to other crew members throughout our organization

Assistant County Maintenance Manager • Ensures that foreman is completing his weekly stockpile walkaround

• Addresses any stockpile safety needs foreman is unable to complete immediately

• Supports foreman when planning to address stockpile deficiencies

• Ensures county manager receives periodic progress reports

County Maintenance Manager • Addresses any decision assistant county manager is unable to make

• Supports all levels and encourages everyone’s participation to reach a common goal and vision


11.26. PENNDOT 15-MINUTE STOCKPILE WALKAROUND Example 14: PennDOT 15-Minute Stockpile Walkaround Checklist

1. Are all salt & mixed materials stored under a permanently roofed building ?

2. Is the salt loaded properly (at the front & sides of the storage structures)?

3. Have all visible signs of salt trailing away from the storage area been cleaned up?

4. Is water directed away from the entrances of the salt storage buildings?

5. Are all stored materials grouped together in separate areas with proper signs posted?

6. Are all drums & containers properly labeled & stored?

7. Are all compressed gas cylinders stored properly?

8. Do above ground storage tanks have proper containment?

9. Are confiscated or abandoned vehicles stored properly on the site (on paved pad)?

10. Is the equipment wash facility operating properly?

11. Are oil/water separators properly maintained?

12. Is there a stormwater management system in place & is it functioning properly?

13. Is the PPC Plan on site & updated within the past year?

14. Is the landscaping neatly maintained?

15. Are all required signs properly posted?

16. Have all necessary permits been updated & displayed?

17. Are all gates, locks & fences in place & in good repair?

18. Are all shingles in place on roofed structures?

19. Are all buildings & structures completely intact & damage free?

20. Are all of the buildings completely free of pigeons & other animals?

21. Do all buildings have proper identification signs & presentable paint jobs?

22. Are gutters & downspouts clear, free flowing, damage free & direct water away from buildings?

23. Have all fire extinguishers been identified by signs, inspected, and charged?

24. Is the safety station properly equipped?

25. Are the exhaust systems operating properly?

26. Are the proper clean sanitary facilities provided?

27. Is the site clear of trash & litter?

28. Are all of the lighting systems working properly?

29. Are all of the lightning rods & electrical systems damage free & working properly?

30. Are the truck heater outlets installed properly & operating with cords used or stored properly?

31. Has the emergency generator been tested in the last seven days?

11.27. PENNDOT STOCKPILE SNAPSHOT Example 15: PennDOT Stockpile Snapshot

1. All salt and salt premix materials stored inside a roofed structure?

2. Is the area around the entrance and inside the salt building water free?


3. Are there visible signs of salt trailing away from the salt building?

4. Are all buildings and structures completely intact and damage-free?

5. Are shingles missing from the roof of the salt building?

6. Are gutters and downspouts functioning properly and damage free?

7. Is there proper secondary containment of above ground storage tanks?

8. Do all buildings have proper ID signs and presentable paint jobs?

9. Is premix covered or under roof?

10. Is the site clean and litter free?

11. Are all gates, locks and fences completely intact? If no one is present are they locked?

12. Are all materials and entrance properly signed?

13. Is the landscaping properly maintained?

11.28. PENNDOT MAINTENANCE STOCKPILE ACTIVITY PROTOCOL Example 16: PennDOT Maintenance Stockpile Activity Protocol

MAINTENANCE STOCKPILE ACTIVITY PROTOCOL Protocol for Specified Tasks

Maintenance Activity Facility Component

Task Timeframe Responsible Person Reference

GENERAL AND PREVENTIVE ROOF INSPECT ANNUALLY FOREMAN Visual/QA/Foreman

Checklist

ROOF REPAIR AS NEEDED ACM County Br. Crew/Contractor

GUTTERS & DOWNSPOUTS INSPECT

SEMI-ANNUALY (APRIL &

OCTOBER)

FOREMAN Visual/ Foreman Checklist

GUTTERS &

DOWNSPOUTS REPAIR AS NEEDED ACM Contractor/ Br. Crew

WINDOWS INSPECT ANNUALLY FOREMAN Visual/ Foreman

Checklist

WINDOWS REPAIR AS NEEDED ACM Contractor

LOCKS INSPECT ANNUALLY FOREMAN Visual/QA/Foreman

Checklist

LOCKS REPAIR AS NEEDED ACM Contract/Br.

Crew/Crew

DOORS INSPECT ANNUALLY FOREMAN Visual/QA/Foreman

Checklist

DOORS REPAIR AS NEEDED ACM Contract/Br.

Crew/Crew


OVERHEAD DOORS SAFETY INSPECTION ANNUALLY

OVERHEAD DOORS LUBRICATE ANNUALLY

OVERHEAD DOORS PAINT AS NEEDED

EQ MANAGER OR CONTRACTOR

Visual/ Manufactures Specifications

OVERHEAD DOORS REPAIR AS NEEDED EQ MANAGER Contract/Bridge

Crew/ Painter

SIGNS INSPECT ANNUALLY FOREMAN/CREW Visual/QA/Foreman

Checklist

SIGNS REPAIR/ REPLACE AS NEEDED FOREMAN Sign Crew

LUMINAIRES INSPECT


OCTOBER)

FOREMAN/CREW Visual/QA/Foreman Checklist

LUMINAIRES REPAIR AS NEEDED ACM/FOREMAN Contract/Crew

FIRE EXTINGUISHER INSPECT


OCTOBER)

FOREMAN Visual/QA/Foreman Checklist

FIRE EXTINGUISHER RECHARGE AS NEEDED ACM Contractor

PAVED AREAS(PARKING,

PADS) INSPECT SEALING ANNUALLY FOREMAN Visual/QA/Foreman

Checklist


PADS) REPAIR AS NEEDED ACM Seal Crew




GENERAL AND PREVENTIVE


PADS) INSPECT ANNUALLY FOREMAN Visual/QA/Foreman

Checklist


PADS) REPAIR AS NEEDED ACM Paving

Crew/Contract


PADS)

CONDUCT SWEEPING AND FLUSHING AS NEEDED FOREMAN Visual/QA/Foreman

Checklist/Crew


PADS)

CONDUCT SWEEPING AND FLUSHING AS NEEDED FOREMAN Crew


NON PAVED AREAS INSPECT GRADING & SHAPING


OCTOBER)

FOREMAN Visual/ QA/ Foreman Checklist

NON PAVED AREAS REPAIR GRADING


OCTOBER)

FOREMAN Crew

NON PAVED AREAS DUST CONTROL AS NEEDED FOREMAN Visual/QA/Foreman Checklist

NON PAVED AREAS APPLY DUST CONTROL AS NEEDED ACM Specialized Crew

BUILDING EXTERIOR INSPECT PAINTING ANNUALLY FOREMAN/ACM Visual/QA/Foreman

Checklist

BUILDING EXTERIOR REPAIR AS NEEDED ACM Contract/Crew

BUILDING EXTERIOR INSPECT PAINTING ANNUALLY FOREMAN/ACM Visual/QA/Foreman

Checklist

BUILDING EXTERIOR REPAIR AS NEEDED ACM Contract/Crew

HOUSEKEEPING INTERIOR OF FACILITY GENERAL CLEANING & SWEEPING DAILY FOREMAN/

CREW Visual/QA/Foreman

Checklist

INTERIOR OF FACILITY GENERAL CLEANING & SWEEPING DAILY FOREMAN/

CREW Crew

INTERIOR OF FACILITY PROPER STORAGE FLAMABLES DAILY FOREMAN/


Checklist

INTERIOR OF FACILITY PROPER STORAGE FLAMABLES DAILY FOREMAN/

CREW Crew

EXTERIOR OF FACILITY PICK UP LITTER DAILY FOREMAN/ CREW Visual

EXTERIOR OF FACILITY PICK UP LITTER DAILY FOREMAN/ CREW Crew

EXTERIOR OF FACILITY PROPER ENTRANCE SIGNING AS NEEDED FOREMAN/


Checklist

EXTERIOR OF FACILITY PROPER ENTRANCE SIGNING AS NEEDED FOREMAN/

CREW Crew

EXTERIOR OF FACILITY GATE LOCKED DAILY FOREMAN/ CREW Visual

EXTERIOR OF FACILITY LOCK THE GATE DAILY FOREMAN/ CREW Crew




HOUSEKEEPING EXTERIOR OF FACILITY FENCING ANNUALLY FOREMAN/ CREW

Visual/QA/Foreman Checklist


EXTERIOR OF FACILITY REPAIR AS NEEDED ACM Contract/Crew

EXTERIOR OF FACILITY PILES MARKED DAILY FOREMAN/ CREW


EXTERIOR OF FACILITY MARK PILES DAILY FOREMAN/ CREW Crew

EXTERIOR OF FACILITY SPILLS CLEANED UP DAILY FOREMAN/ CREW Visual

EXTERIOR OF FACILITY CLEAN UP SPILLS DAILY FOREMAN/ CREW Crew

STORAGE AREA PIPE SIGNED & NEAT DAILY FOREMAN/ CREW


STORAGE AREA PIPE SIGNED & NEAT DAILY FOREMAN/ CREW Crew

STORAGE SHED NEAT & SPILL KIT DAILY FOREMAN/ CREW


STORAGE SHED NEAT & SPILL KIT DAILY FOREMAN/ CREW

Foreman/ Store room

STORAGE SHED CONDITION/ APPEARANCE INSPECT FOREMAN/

ACM Visual/QA/Foreman

Checklist

STORAGE SHED REPAIR/ REPLACE AS NEEDED ACM Contractor/ Br. Crew

LANDSCAPING FLAG POLE INSPECT DAILY EQ. MANAGER Visual/QA/Foreman Checklist

FLAG POLE REPAIR AS NEEDED EQ. MANAGER Welder

FLAGS INSPECT DAILY EQ. MANAGER Visual/QA/Foreman Checklist

FLAGS REPLACE AS NEEDED EQ. MANAGER Purchasing Agent

GROUNDS & VEGATATION MOWING AS NEEDED FOREMAN/ACM Visual/QA/Foreman

Checklist

GROUNDS & VEGATATION MOWING AS NEEDED FOREMAN/ACM Roadside Crew/

Crew

GROUNDS & VEGATATION

VEGATATION CONTROL/ WEED

EATING AS NEEDED FOREMAN/ACM Visual/QA/Foreman

Checklist


VEGATATION CONTROL/ WEED

EATING AS NEEDED FOREMAN/ACM Roadside Crew/

Crew


HERBICIDE/ VEGATATION

CONTROL AS NEEDED FOREMAN/ACM Visual/QA/Foreman

Checklist


HERBICIDE/ VEGATATION

CONTROL AS NEEDED FOREMAN/ACM Roadside Crew/

Crew


INSPECT PLANTING BEDS ANNUALLY FOREMAN/ACM Visual/QA/Foreman

Checklist


INSPECT PLANTING BEDS ANNUALLY FOREMAN/ACM Roadside Crew/

Crew

GROUNDS & VEGATATION MULCH ANNUALLY FOREMAN Visual/QA/Foreman

Checklist


GROUNDS & VEGATATION MULCH ANNUALLY FOREMAN Roadside Crew/

Crew


Maintenance Activity

Facility Component Task Timeframe Responsible

Person Reference

LANDSCAPING TREES/ SHRUBS INSPECT APRIL & OCTOBER FOREMAN/ACM Visual/QA/Foreman

Checklist

TREES/ SHRUBS TRIM & SHAPE AS NEEDED FOREMAN Roadside Crew/ Crew

DRAINAGE INLETS & PIPES INSPECT QUARTERLY FOREMAN/ACM Visual/QA/Foreman Checklist

INLETS & PIPES CLEAN AS NEEDED ACM Roadside Crew/ Crew

SEDIMENTATION DEVICES INSPECT QUARTERLY FOREMAN/ACM Visual/QA/Foreman

Checklist

SEDIMENTATION DEVICES CLEAN AS NEEDED FOREMAN Crew

DITCHES & SWALES INSPECT APRIL & OCTOBER FOREMAN/ACM Visual/QA/Foreman Checklist

DITCHES & SWALES CLEAN AS NEEDED FOREMAN Crew

OIL/WATER SEPARATOR INSPECT SEMI ANNUALLY EQ. MANAGER Visual/QA/Foreman

Checklist

OIL/WATER SEPARATOR CLEAN AS NEEDED EQ. MANAGER Contractor/ Crew

UTILITIES ELECTRICAL INSPECT TRUCK RAIL APRIL & OCTOBER FOREMAN Visual/QA/Foreman Checklist

ELECTRICAL REPAIR AS NEEDED ACM Contractor

ELECTRICAL INSPECT FACILITY ANNUALLY EQ. MANAGER Visual/QA/Foreman Checklist

ELECTRICAL REPAIR AS NEEDED EQ. MANAGER Contractor

EMERGENCY GENERATOR INSPECT MONTHLY EQ. MANAGER Policy

EMERGENCY GENERATOR REPAIR AS NEEDED EQ. MANAGER Vendor/ Shop

WATER WELLS SAMPLING APRIL & OCTOBER EQ. MANAGER State Reg’s

WATER WELLS SERVICE & TREATMENT AS NEEDED EQ. MANAGER Contractor

STAGING BLDG. HEATER INSPECT ANNUALLY FOREMAN Visual/QA/Foreman

Checklist

STAGING BLDG. HEATER REPAIR AS NEEDED ACM Contractor

UNDER GROUND

TANKS REGISTERED INSPECT APRIL & OCTOBER EQ. MANAGER Pub 23

REGISTERED SERVICE AS NEEDED EQ. MANAGER Tank Contractor/ Contractor

ABOVE GROUND

TANKS HEATED TANKS INSPECT APRIL & OCTOBER SEAL COAT

FOREMAN Pub 23

HEATED TANKS SERVICE AS NEEDED ACM/ EQ MANAGER

Garage-Contractor-Crew


CALCIUM TANKS INSPECT APRIL & OCTOBER FOREMAN/ACM Visual/QA/Foreman Checklist

CALCIUM TANKS SERVICE AS NEEDED ACM Garage-Contractor-Crew

CONTAINMENT AREA INSPECT MONTHLY FOREMAN/ACM Visual/QA/Foreman

Checklist

CONTAINMENT AREA LITTER/WEEDS/WATER MONTHLY FOREMAN/CREW Foreman/ Crew


Maintenance Activity

Facility Component Task Timeframe Responsible

Person Reference

RECORD KEEPING PPC PLAN UPDATE ANNUALLY CMM / RPC Policy

(see appendix A)

PPC EMERGENCY PLAN CONDUCT ANNUALLY CEM / FOREMAN Policy

SEMP MANUAL UPDATE AS NEEDED

PROCESS OWNER CMM / CHIEF CLERK

RPC / FOREMAN

Process Map

STOCKPILE INSPECTION

WEEKLY WALK AROUND WEEKLY FOREMAN /

CREW Process Map

STOCKPILE CHECKLIST CHECKLIST QUARTERLY FOREMAN Pub 23 / Process

Map

STOCKPILE SNAPSHOT QA AS COMPLETED DIST./COUNTY

PERSONNEL Process Map

STOCKPILE QA QA MAY THROUGH

SEPTEMBER ENVIRONMENTAL

PLANNER/ RPS Process Map

(see appendix A)

HAZARD / ENVIRONMENTAL ID

FORM FORM AS NEEDED ANYONE Process Map

(see appendix A)

STOCKPILE WEEKLY WALK

AROUND QA WEEKLY FOREMAN /

CREW Process Map

11.29. PENNDOT POST-STORM SALT MANAGEMENT TRACKING RESPONSIBILITIES

Example 17: PennDOT Post-Storm Salt Management Tracking Responsibilities

District Management / County Management Teams • Analyze last years winter data and revise application charts

• Update winter training plan

• Revise tracking sheets to improve application rates

• Update target application rates by snow lane miles by truck.

• Update charts to collect actual results

• Train Equipment Operators on application rates and prepare presentation to all employees


Every Equipment Operator, after every Snow Event • Completes tracking forms

• Turns into Foreman after every shift

Assistant Manager • Checks application rate and discuss variance if any with Foreman after every storm

• Prepares summary for stockpile

County Foreman • Check application rate and discuss variance if any with Operators after every storm using prepared

summary for stockpile

County Coordinator • Collected summary of stockpile

• Makes County summary

• Sends copy to District

• Completes County CSI results after every storm external and internal

PennDOT District • Develop scorecards of all counties by stockpile average rate

• Completes and sends report back to County

• Distributes reports to stockpiles

11.30. RISK, COMPLIANCE ISSUES, AND MANAGEMENT EXAMPLES FOR HIGHWAY-GENERATED WASTE - OREGON DOT

Table 11: Risk, Compliance Issues, and Management Examples for Highway-Generated Waste - Oregon DOT

Waste Toxicity/Risk Compliance issues Management Examples Vactor Waste • Catchment Cleanout • Sediment Ponds • Bridge Culverts

High (in urban areas). Typically the most contaminated roadwaste. Hydrocarbons and metals are common. Historical pollutants can be present. Low to High Depending on factors such as ADT, land-use, maintenance schedules, etc. Low (if content of silt or fine soils is low).

Vactor waste must be separated into liquids and solids prior to disposal. Each waste must be disposed of separately. Many waste disposal rules apply. ODOT Environmental and DEQ can offer guidance. Even free of toxins, litter, and trash, vactor waste requires proper placing and erosion control.

• Develop alternative disposal options such as bioremediation or composting. • Pursue alternative decanting techniques (retrofit sewerage manholes for liquid field disposal, treat vactor slurries with flocculent, etc.). • Partner with other agencies and share waste disposal facilities. • Construct ODOT decant facilities that separate vactor waste into liquids and solids. Landfill solids and dispose liquids to sewer.


Sweepings • Winter Sand

Low to High

Litter and sharps will be obvious. Hydrocarbons and metals are a concern. Urban sweepings usually test high in toxin levels. Low (with quick pick up). Less time on roadway reduces litter and toxins.

Similar to vactor solids in risk and environmental concerns. Testing may be needed to determine toxin levels. Litter and trash must be disposed of at permitted waste facilities.

• Test, characterize, and sort for reuse. • Develop re-use options: compost, shoulder repair, fill, concrete, etc. (remove trash by screening). • Develop and permit disposal sites (partnering). • Thermal treatment (incinerator). • Landfill.

Ditching Spoils Low to Medium Generally risk is low but urban ditchings have tested positive for toxins (hydrocarbons, metals, historical pollutants, chemical dumping, etc).

Storage sites must be suitable (protect wetlands and streams). Clean soil is a pollutant if it is not contained (erosion control).

• Use as fill material in appropriate locations. • Partner in give-away programs if material is suitable (agriculture, construction, etc.). • Develop and permit disposal sites.

Landscape Cuttings

Low Nitrogen, bacteria, and other pollutants associated with the break down of organic material can be considered toxic pollutants.

Landscape debris must be disposed at permitted facilities. Composting is allowed but may require a permit. Odor, vector control, and public perception are concerns.

• Keep landscape debris separate from other waste and dispose appropriately. • Composting. • Burning (only allowed at limited locations). • Chipping/Mulching.

Construction Soils and Slide Debris

Low Toxins can sometimes be a concern (fuel spills, septic waste, excessive vegetation, etc.)

Similar to Ditching Spoils in risks and concerns. Storage sites must be suitable. Material must be contained.

• Use as fill or construction material if appropriate (rock fall or sound berms, general fill, etc.). • Develop give-away programs with partners. • Develop and permit disposal sites.

11.31. NYSDOT-DEC DEER CARCASS COMPOSTING – PRACTICE GUIDELINES Example 18: NYSDOT-DEC Deer Carcass Composting – Practice Guidelines 1. Choose a well-drained site with minimal slope, at least 200 feet from water courses or other hydrologically sensitive landscape features including streams and wetlands. Separation distances should be 500 feet from a residence and 200 feet from a property line. Siting should also consider prevailing winds and aesthetic impacts on neighbors. 2. Composting bin or windrow should be placed on a hard surface made of paved asphalt, concrete, or compacted millings. The pad needs to provide a good working surface in all weather conditions and protection of ground water. Sufficient amounts of amendments should be added to piles to minimize the movement of liquids (blood, etc.) from the carcasses. Any liquid that leaves the pad must be absorbed in woodchips or other acceptable materials and must be kept away from sensitive areas (streams etc.). 3. Prepare a foundation layer of wood chips or recycled deer compost in the bottom of the windrow or bin before adding carcasses. This initial layer should be 18-24 inches deep. Sufficient quantities of woodchips and/or finished compost must be at the site before any carcasses arrive to ensure the piles can be formed in a timely manner. 4. Place deer carcasses back to back in a single layer on the foundation leaving at least 6 inches between the carcasses and the bin walls. Completely surround and cover the carcasses with at least 6 inches of damp wood chips or recycled deer compost. If there are not sufficient carcasses for a full layer, cover the edges of the available carcasses with at least 6 inches of wood chips or recycled deer compost and begin adding carcasses at that point as they become available. Never leave any part of a carcass exposed even if extra wood chips or recycled deer compost must be added.


5. Continue this layering procedure until a windrow or bin is full. The last layer used to cap the bin should be 24 inches of wood chips or recycled deer compost. This layer should curtail odors and dissuade scavengers. Do not stack windrows/bins over 6 feet high. A temperature rise in the compost pile to 125 degrees F or higher indicates that the process is working. 6. Allow the pile to remain idle for several months. The pile can be broken down sooner, if the carcasses are clearly fully degraded. The internal temperature of the pile should be 120F to 150F during the active composting phase. For pathogen reduction, it must be shown that the carcass achieved a temperature of 131/F or greater for three consecutive days. The temperature probe used must be able to record temperatures in the areas of the pile where the carcasses are located. 7. Once the material is fully composted, it can be reused in starting new compost piles or used within a highway right-of-way with appropriate setbacks. DEC approval will be required for uses outside of the compost area.

FACILITY REQUIREMENTS

• Suitable site allowing for setbacks

• Hard surface made of asphalt, concrete or compacted millings for compost windrow OR

• Compost bins on asphalt, concrete or compacted millings work pads

• Sufficient supply of wood chips

• Provisions for monitoring temperatures within the compost pile. (Thermocouple probe, thermister probe or similar device may be used.)

• Rubber gloves and face masks

• Loader

• Water

• Before composting, contact the DOT Maintenance Environmental Coordinator (MEC).

FACILITY CONTROLS

The compost piles will be segregated from other facility operations, utilities, farming activities and main traffic areas. A sign designating the compost pile as such will be clearly visible at each compost area. The sign may state “Deer Carcass Compost.” All workers at the assigned locations should be made aware of the compost windrow or bin. Safety instructions will be given via classroom or field setting.

PERSONNEL TRAINING

The Highway Maintenance Supervisor assigned to the yard where the composting facility is located will inform all yard employees of the composting facility. All yard employees will be made aware of safety precautions required. Employees working with the compost will be informed of the Operations and Maintenance procedures described herein.

LOADING PROCEDURES

Deer typically get collected by manually lifting the carcass into the back of a pick-up truck. While the first carcasses may be added to the fresh compost pile manually, any subsequent additions should be added via heavy equipment, such as a loader. It is allowable to park the pick-up truck as close as possible to the compost pile and manually place the carcass from the truck to the pile, as long as workers will not have to step onto the compost pile. Woodchips should be added via heavy equipment or off a pick-up truck. As it may be challenging to place the deer back to back with heavy equipment, the boards on one side of the bins should be removable to make loading and unloading the bins easier.

HANDLING INSTRUCTIONS

Handling of the compost pile will be accomplished via heavy equipment.


Handling of the compost should be performed in a manner that would prevent dispersion of the compost material on the ground and prevent dispersion of compost particles in the air.

COMPOST MANAGEMENT

A carcass may be added to the compost pile as ordered by the Resident Engineer. In general, any deer collected from the roadside may be added to the composting facility as long as it does not show any overt signs of disease. A deer that appears emaciated or showed untypical behavior prior to becoming killed should not be added to the compost pile as it may be diseased. Emaciated deer should be reported to NYSDEC Wildlife Pathology Unit in Albany (Phone number 518/478-3032) for testing. Through the trial composting effort, DOT will be able to determine how many deer carcasses each compost bin/windrow can handle within a given time frame. Potentially, each composting bin could handle up to 30 carcasses per composting effort, depending on the size of the work pad. Compost windrows, extended lengthwise, would be able to accommodate more carcasses. Each composting bin/windrow can accept up to three layers of carcasses to a maximum height of 6 feet. The first layer should consist of 18-24” of woodchips, followed by a layer of carcasses. Carcasses should be placed back to back. This arrangement aids in achieving higher composting temperatures. The carcasses should be covered by 6” of woodchips. Repeat this process until three layers are complete. Finish top layer with 24” of woodchips. For windrows, repeat this process in 10-15 foot long sections, adding on to the existing windrow. The moisture content of the pile contributes to proper composting temperatures. The moisture content of the wood chips or recycled deer compost added to the mix should be about 60 percent, which is the point where a handful of the material will just begin to stay together when squeezed (wear rubber gloves if it is compost!).

• The wood chips or recycled deer compost should have the proper moisture content before adding it to the bin/windrow. It is difficult to uniformly add water to the mix in the composter.

• If the material falls apart after being squeezed, it is too dry. Water should be sprinkled and mixed into the wood chips.

• If free water drips from the squeezed material, or if a film of free water is left on the hand, the material is too wet. The material should be spread to air dry or mixed with drier material to lower the moisture content before adding to the compost mix.

• If a compost pile does not properly heat, it is probably too wet or too dry or was filled improperly.

RECORDKEEPING

Compost monitoring and record keeping is necessary in order to document proper functioning of the compost pile. If dysfunction is evident, steps can be taken to correct poor conditions. Compost monitoring will let DOT learn more about the composting process and create optimal composting conditions in the future.

• Any deer composting activities must be approved by NYSDEC.

• Record the number of carcasses added to the pile along with date.

• Temperatures within the compost pile will be monitored and recorded once a day. A sample data log sheet is attached for use. See Temperature Monitoring section.

• Odors should be recorded daily. Indicate whether there are odors disseminating in the downwind direction and if an odor is present, estimate how many feet downwind it is noticeable.

• State when last carcass was added.

TEMPERATURE MONITORING

Proper composting requires sustained elevated temperatures (120F -170F). High temperatures also achieve desired pathogen reduction and a physically stabilized compost material at the end of the process. Ideally, a continuous temperature monitoring device should be utilized. A thermocouple probe, thermistor probe or similar device can be embedded in the compost pile. This device should be connected to a lead wire and data logger, where temperature variations can be recorded over a period of time.

• A temperature probe (bimetal thermometer) with a four foot extension may also be used.


• The probe should be placed so that readings are taken at 12”-36” from the top of the pile in areas where the carcasses are located. As the pile grows, the probe will need to be repositioned.

SAMPLING PLAN

Testing of finished compost will document the presence of certain pathogens and ascertain what re-use the compost product is suitable for. Sampling parameters include pathogenic organisms and pathogen indicator organisms. The Maintenance Environmental Coordinator will be in charge of sampling. Within 3 months after start-up of the project, a compost sampling and analysis plan will be submitted to DEC for approval. Parameters to be analyzed may include total coliform, fecal coliform, E.coli, Salmonella, Cryptosporidium, total carbon and total Kjehldal nitrogen. Bacteria causing Lyme disease will not survive temperatures above 130F and as long as composting achieved proper temperatures, testing for this pathogen will not be necessary.

RECYCLING OF FINAL COMPOST PRODUCT

Material that is fully composted may be re-used as a base for a new compost pile. Compost that has been determined safe by inspection of records and the sampling analysis, can be land applied within the highway right-of-way subject to DEC approval.

CONTINGENCY PLAN

If any activity does not go according to plan, contact the Resident Engineer. In the event that problems develop which result or may result in environmental or public health impacts or nuisance conditions, the compost operation should be suspended and corrective measures should be taken to mitigate impacts. Problems which will trigger implementation of the contingency plan will include, but not be limited to, odors detected beyond the facility boundary, animals scavenging in the compost piles or receipt of deer carcasses at a rate which exceeds the handling capacity of the compost facility. Corrective measures will include, but not be limited to, covering with additional woodchips and/or addition of lime to control odors, fencing the area to prevent access by animals, temporarily covering the piles with a tarp, cessation of operation until the adverse impacts have been mitigated and, if other measures fail, removal and disposal of the pile contents by pit burial in accordance with applicable DEC regulations and DOT guidelines or disposal of pit contents at an approved solid waste management facility.

CLOSURE PLAN

The Maintenance Environmental Coordinator (MEC) is contacted before composting is started and needs to be contacted in order to officially close out a composting activity. The MEC will schedule a site visit at that time, possibly with NYSDEC. Composting records should be made available at that time and elements of the process should be discussed. At that time it should be determined, whether composting appears complete and final sampling should be ordered. If yes, the MEC will initiate the sampling process. Sampling results and monitoring records will be provided to NYSDEC. Depending on results, the compost will be recommended for re-use as composting amendment or determined to be suitable as a soil amendment. If the finished compost will be used as soil amendment, the site approval by the MEC and by DEC is required. To permanently close a composting site, bins should be disassembled and taken to a landfill. The workpad may be kept for other uses, but must be decontaminated using a 5 percent or 10 percent solution of sodium hypochlorite (household bleach) in water. The MEC and NYSDEC will be notified that the deer composting facility has been discontinued.

PERSONAL PROTECTION

Employees should follow the personal protective equipment requirements outlined in the Rabies Safety Bulletin 92-1 (attached) when working with any road kill. The safety bulletin recommends that rubber gloves be worn. Questions in regard to the Safety Bulletin should be directed to the Regional Safety Officer (see Contact Information). If a worker will be in immediate contact with the compost for the purpose of taking a temperature reading or other, personal protective equipment, such as rubber gloves. Disposable face mask should be available and worn at the discretion of the employee.


Emaciated deer or deer showing untypical behaviors (either alive or before becoming roadkill) should be reported to NYSDEC Wildlife Pathology Unit in Albany (Phone number 518/478-3032). Do not add animals other than deer to the compost!

ENVIRONMENTAL CONTROLS

Environmental quality will be addressed by carefully choosing a site (see Guidelines II.1.). In order to ensure proper site selection, the Maintenance Environmental Coordinator should conduct a site screening via a physical walk-over. To ensure that the active compost pile does not pose risks not addressed through proper setbacks, the following should be considered:

• If nuisance vectors, such as flies etc are attracted to the pile, more woodchips should be added to cover the pile.

• Any leachate that may have puddled around the pile needs to be absorbed by woodchips and adequately covered.

• Odors would also indicate that additional woodchip coverage is necessary.

Experiences of various entities utilizing composting has shown that carnivorous animals will not be attracted to compost piles as long as the pile is adequately covered. Prior to releasing the finished compost product to the environment, monitoring records such as the temperature logs and pile records will be reviewed. The temperature log will indicate whether the material has properly composted and whether the temperature necessary for pathogen kill was reached. The operators of the pile should ensure that adequate temperatures are reached as outlined in the Guidelines. Composting shall not be considered complete unless adequate temperature data is collected after addition of the last carcass to demonstrate that a minimum temperature of 131 F has been reached and maintained for a minimum of three consecutive days. The final sampling test results will also determine the safety of the compost.

STAFFING PLAN AND CONTACT INFORMATION

The Highway Maintenance Supervisor II assigned to the yard is responsible for day to day operations, monitoring and proper functioning of the compost pile. Correspondence, composting performance evaluation, procedural guidance and sampling will be coordinated by the Maintenance Environmental Coordinator. Elisabeth Kolb, Maintenance Environmental Coordinator Tel. 845/575-6158

11.32. NYSDOT’S DRAFT METRIC FOR ASSESSING PERFORMANCE OF INTEGRATED VEGETATION MANAGEMENT ON ROW

Example 19: NYSDOT’s Draft Metric for Assessing Performance of Integrated Vegetation Management on the ROW PRINCIPLE #1: COMPLIANCE WITH LAWS 1.1 Vegetation management shall respect all national and local laws, for example, use of pesticides by certified applicators, Best Management Practices and other protective measures for water quality, that exist within the state or other appropriate jurisdiction(s) in which the operations occur.

1.2 Vegetation management areas should be protected from unauthorized activities.

PRINCIPLE #2: TENURE AND USE RIGHTS AND RESPONSIBILTIES 2.1. Clear evidence of long-term land use rights (e.g., land title or lease agreements) should be demonstrated, including clearly identified, on-the-ground land boundaries.

PRINCIPLE #3: COMMUNITY RELATIONS AND WORKERS’ RIGHTS 3.1. The communities adjacent to the vegetation management area should be given opportunities for other professional services from the vegetation manager such as representation in local civic activities, e.g., Earth Day clean-up, Arbor Day plantings, etc. or contribution to public education about vegetation management practices in conjunction with schools, community colleges, and/or other providers of training and education.


3.2. Vegetation management meets or exceeds all applicable laws and regulations covering health and safety of employees, including the development and implementation of safety programs and procedures that include:

a) Well-maintained and safe machinery and equipment

b) Use of safety equipment appropriate to each task

c) Documentation and posting of safety procedure in the workplace

d) Education and training

e) Contracts with safety requirements

f) Safety records, training reports, and certificates

PRINCIPLE #4: UNDERSTANDING PEST AND ECOSYSTEM DYNAMICS 4.1. Vegetation managers are knowledgeable about the managed ecosystem, especially with regard to the basic biology and ecology of all organisms in the system, and the environment in which they live.

4.2. Research and development activities are engaged to produce missing basic information on ecology of the managed ecosystem.

4.3. Vegetation managers are provided opportunities to improve their skills and knowledge through training.

PRINCIPLE #5: SETTING MANAGEMENT OBJECTIVES AND TOLERANCE LEVELS 5.1. Management planning, including the development of management objectives, shall incorporate the results of evaluations of social impact. Consultations should be maintained with people and groups directly affected by management operations (see also PRINCIPLE #8).

5.2. Tolerance levels are used to develop thresholds for when vegetation management activities are applied to control vegetation.

5.3. People and groups affected by management operations are apprised of proposed vegetation management activities and associated environmental and aesthetic effects in order to solicit their comments or concerns.

5.4. Significant concerns identified in Criteria 5.1 and 5.3 are addressed in management policies and plans (for example, management activities are modified in response to concerns, or a rationale is provided for not responding to a concern).

PRINCIPLE #6. COMPILATION OF A BROAD ARRAY OF TREATMENT OPTIONS 6.1. A wide variety of different mechanical, physical, chemical, cultural, and biological/ecological treatments are available for use/consideration on all sites.

6.2. New treatments are progressively added to the vegetation management program, with emphasis on non-herbicide alternatives.

6.3. Where possible, treatments are featured that lead to, directly or indirectly, pest prevention and biological and ecological control of pests.

PRINCIPLE #7: ACCOUNTING FOR ECONOMIC AND ECOLOGICAL EFFECTS OF TREATMENTS 7.1. Vegetation management should strive toward economic viability, while taking into account the full environmental, social, and operational costs of vegetation management. Treatment choices are made with full consideration of cost effectiveness, including a wide array of positive and negative environmental externalities, as follows.

a) Water resources: perennial and ephemeral streams, wetlands, vernal pools, seeps (see also Criterion 7.5)

b) Wildlife: common plants, animals and their habitats, and imperiled, threatened, and endangered species and their habitats (according to state and federal statutory listings)

c) Biodiversity: efforts are made to control invasive, exotic plants; also, if state or federal listings and species databases indicate the likely presence of a rare, threatened or endangered species or plant community type, either a survey is conducted prior to management activities being carried out (to verify the species presence or


absence) or the vegetation manager manages as if the species were present. If an applicable species and plant community type is determined to be present, its location is reported to the manager of the applicable database, and necessary modification are made in both the management plan and its implementation.

d) Aesthetics: visual impacts of treatments are assessed.

Written guidelines should be prepared and implemented to address management of these resources.

7.2. Management systems shall promote the development and adoption of environmentally-sensitive, non-chemical methods of pest management and strive to minimize the use of chemical pesticides. If chemicals are used, proper equipment and training should be provided to minimize health and environmental risks. (See also Criterion 1.1)

7.3. Chemicals are used to control plants only when non-chemical management practices have proven ineffective or cost prohibitive.

7.4. When chemicals are used, a section is included in the prescription that fully describes the risks and benefits of their use and the precautions that workers must employ. Records are kept to document the occurrence of pests, measures to control them, and incidences of worker exposure to chemicals.

7.5. Broken and leaking equipment and parts are repaired and removed from a right-of-way as they may contaminate a site with fuel, oil, or other chemicals; discarded parts are taken to a designated disposal facility. Equipment is not parked in riparian zones, or near groundwater supplies, where fluid can leak into them.

7.6. Chemicals, containers, liquid and solid non-organic wastes including fuel and oil should be disposed of in an environmentally appropriate manner at off-site locations. (See also Criterion 1.1)

7.7. Use of exotic species in planting is carefully controlled and actively monitored to avoid adverse ecological impacts. Furthermore, use of exotic plant species is contingent on peer-reviewed scientific evidence that any species in question is non-invasive and does not diminish biodiversity. If non-invasive exotic plant species are used, the location of their use is documented, and their ecological effects actively monitored.

7.8. Special cultural, ecological, economic or religious resources should be clearly identified, recognized and protected by vegetation managers.

PRINCIPLE #8: MANAGEMENT PLANNING 8.1. A strategic management plan and supporting documents must be in place that provide:

a) Management objectives

b) Description of the resources to be managed (e.g., water, wildlife, aesthetics) and socioeconomic conditions, and a profile of adjacent lands

c) Description of the vegetation management system, based on the ecology of the ecosystem in question and information gathered through resource inventories

d) Provisions for monitoring

e) Environmental limitations and safeguards based on environmental assessments

f) Plans for biodiversity

g) Maps describing the resource base.

8.2. Tactical management plans are developed that report local considerations and activity plans on a year-by-year basis.

8.3. Strategic and tactical management plans should be periodically revised to incorporate the results of monitoring or new scientific and technical information, as well as to respond to changing environmental, social, and economic circumstances.

8.4. A summary of vegetation management activities is produced annually, and both strategic and tactical management plans are revised at least every 10 years.

8.5. Workers shall receive adequate training and supervision to ensure proper implementation of the management plans.


8.6. While respecting the confidentiality of information, vegetation managers shall make publicly available a summary of primary elements of the management plan, including those listed in Criterion 8.1.

PRINCIPLE #9: SITE SPECIFIC IMPLEMENTATION OF TREATMENTS 9.1. Land management units are designated within rights-of-way, for example, buffers to protect water resources, conservation areas, and vegetative communities that may cause a change in successional directions and rate or warrant different vegetation treatment.

9.2. Written prescriptions (or operational plans) are used to describe/prescribe treatments on a land management unit basis, and justify treatment choices using ecological, socioeconomic and administrative opportunities and constraints.

Prescriptions should include:

a) Land management unit designation

b) Description of current vegetation and environmental conditions

c) Desired future conditions

e) Definition of treatment

f) Justifications for treatment based on tolerance thresholds (also see PRINCIPLE # 5) and ecological, environmental, socioeconomic, and administrative considerations

g) Site-specific maps that detail land management units, and show important cultural and environmental features

9.3. Prescriptions and the decision to treat are based on contemporary inventories of vegetation and environmental conditions.

PRINCIPLE #10: ADAPTIVE MANAGEMENT AND MONITORING 10.1 Monitoring procedures should be consistent and replicable over time to allow comparison of results and assessment of change. Implementation of the strategic and tactical management plans are periodically monitored to assess:

a) The degree to which the management vision, goals, and objectives have been achieved

b) Deviations from the plan

c) Unexpected effects of management activities and other disturbances

d) Social and environmental effects of management

10.2. Vegetation management should include the research and data collection needed to monitor, at a minimum, the following indicators:

a) Condition of the right-of-way

b) Composition and changes in the flora and fauna

c) Environmental and social impacts of operations

d) Chemical use

e) Cost, productivity, and efficiency of vegetation management

10.3. Results of monitoring should be incorporated into the implementation and revision of the management plan.

10.4. While respecting the confidentiality of information, vegetation managers shall make publicly available a summary of the results of monitoring indicators, including those listed in 10.1.


11.33. NCDOT ROADSIDE VEGETATION MANAGEMENT GUIDELINES IN MARKED AREAS

Example 20: NCDOT Roadside Vegetation Management Guidelines in Marked Areas

• No mowing April 1-November 15.

• No herbicides, no fertilizers. (Exceptions can be made for herbicides under special circumstances, discussed below.)

• Mowing from November 16-March 31 is allowed and, in most cases (*see exception below), should be done at least every other year. Winter mowing every year is acceptable. If regular contract mowers are unable to mow the sites under this time frame, NCDOT mowers may be used during the winter.

• Mowing should not be conducted when the soil is wet, as compaction and rutting will occur.

• In some instances, rare plants may be growing right along the edge of the road. Ideally, the plants should be protected if at all possible in this situation, but if NCDOT division staff determine that the road shoulder should be mowed during the growing season for safety or visibility, then the shoulder may be mowed accordingly. If possible, an NCDOT biologist can visit the site and mark where individual plants are, so they can be avoided.

• NCDOT mowing contracts are under modification to ensure that contractors are responsible for finding out if any endangered plants are within the areas they will be working, and for avoiding injury to the plants. The County Mowing Inspector or the Division Roadside Environmental Engineer should review the No Mow policy with each county maintenance office and mowing contractor prior to any mowing activities on roads with rare plant populations.

• The standard mowing height is usually four inches; ideally, the mower should be set at a level to avoid scalping the ground and damaging rare plants.

• Clippings from winter mowing should be left on site so any rare plant seeds produced will have the opportunity to germinate within the population. An exception can be made if only weeds are reproducing.

• Prior to entering the site, mowers and equipment should be cleaned off, removing any accumulated vegetative debris that contains weed seeds.

• Rare plants along roadsides often extend into utility line ROWs. Utilities managing plant growth in DOT ROWs must be told that herbicide use on DOT ROW is unlawful without a permit. Utilities conducting plant management adjacent to DOT ROWs should be notified when rare plants are present.

* Mowing Exception

There is an exception to winter mowing for Virginia spiraea. This shrub is found along streams, rivers and roadsides in the mountains. Because it is a woody shrub it should never be mowed, regardless of the time of year. Trimming or selective thinning of other woody vegetation that compete with this species may be recommended for management.

Signs/Stakes When rare plants are discovered on NCDOT’s ROW, the population should be marked with ‘Do Not Mow’ signs. These signs should be large enough to be easily noticed by roadside mowers. A variety of signs have already been placed along roadside populations; most simply state, ‘Do Not Mow’ while others include dates for the no mow period (April 1 - November 15), or add ‘Do Not Spray.’ To ensure that signs are readily understood by a variety of workers, signs with universal symbols for ‘Do Not Mow’ and ‘Do Not Spray’ are under review for future use.

Do Not Mow signs should be positioned at both ends of a population, facing so mowers will see the signs as they approach the No Mow area. Where rare plants occur along a significant stretch of roadway it is suggested that double sided Do Not Mow signs be placed periodically along the population - two Do Not Mow signs placed back to back on a single post. The reasoning for this is that if a sign at one end of the population disappears, the mower will encounter another Do Not Mow sign before the entire population is mowed. MMaaiinnttaaiinniinngg tthhee ssiiggnnss aanndd sseeeeiinngg tthhaatt


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White-topped wooden stakes can also be useful in alerting mower operators that the site is designated as a No Mow area. These should be used in addition to (not instead of) Do Not Mow signs. The wooden stakes are approximately 40 inches long with the top six inches painted white, the same stakes used to delineate mowing patterns and areas that are off limits to mowers. Stakes should be placed at regular intervals along the entire edge of the roadway side of the population.

Encroachments/Maintenance Division environmental officers, district offices and maintenance units should make sure rare plant sites are taken into consideration for proposed ROW encroachments and maintenance work. ROW encroachments such as driveways, utility work, minor widenings, installation of utility lines and pipes for driveways have the potential to damage rare plant populations. All ROW access requests and driveway access applications in areas where rare species are known to occur should be reviewed to ensure there will be no impacts. If impacts to rare plants are likely to occur, efforts should be made to avoid or minimize damage. District offices should maintain secondary road files with a notation to remind them that the road has a protected species.

Roadside maintenance activities, such as grading and ditch maintenance can also harm rare plants. As above, if impacts to rare plants are likely to occur, efforts should be made to avoid or minimize damage. Heavy equipment should be kept out of rare plant areas during the No Mow period. Employees working in the area should be shown the rare plant so they can avoid damaging them.

Herbicide Use To reduce competition from invasive weeds, herbicides should only be used when mechanical removal is not an option. Herbicides can be used near rare plant populations when specifically prescribed by someone familiar with the biology of the rare plant. Two main herbicides have been recommended for use on roadside rare plant populations. These herbicides have been tried in a variety of situations by NCDOT and are believed to be most suitable for managing these sites, glyphosate triclopyr for woody vegetation. All herbicide applications for roadside rare plant sites should be conducted by a Licensed Pesticide Applicator.


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