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Cit y of Dallas Environmental Management Syst e m

MANAGEMENT OF CHANGE PROCEDURE

Document OEQ-EMS-020 Number: Effective 1/14/2008 Date: Revision Number: 1

Reviewed By:

Approved By:

Signature: ('

EMSCore Team

Laura Fiffick .s, ~Q(i~

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1.0 Policy

This procedure describes the process for incorporation of environmental considerations and environmental legal requirements when planning and designing new and/or renovations to buildings, operations, processes, equipment, maintenance activities and products (hereinafter called changes).

2.0 Purpose

Management of change is the process of incorporating environmental concerns and initiatives in proposed changes. This process will consider environmental aspects and legal requirements for proposed changes to prevent pollution, reduce adverse environmental impact, avoid future costly retrofitting, comply with or exceed environmental regulations, and provide for future sustainability.

3.0 Scope

This procedure applies to City operations within the Environmental Management System (EMS) fenceline. This procedure only applies to projects starting predesign January 1, 2008 at City of Dallas facilities listed in the EPA Consent Decree dated August 28, 2006.

4.0 Responsibility & Authority

4.1 The Office of Environmental Quality (OEQ) is responsible for assisting City facilities with identifying and minimizing environmental impacts, and with identifying and complying with associated environmental legal requirements.

4.2 Facility Managers, Building Engineers, and/or Architects shall coordinate proposed changes with the appropriate Department Environmental Staff so that legal and environmental impact/considerations are included in the decision-making process.

4.3 The Department Environmental Staff shall be responsible for reviewing proposed changes and providing associated environmental information to

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City of Dallas Environmental Management Syste m

facility managers and other personnel during the planning and design stages of proposed changes. The Department Environmental Staff shall be delegated by the Department Director and consist of staff (including the Department Environmental Management Representative (EMR)) with the appropriate environmental training, training in the City of Dallas Environmental Management System, and with any other appropriate training.

4.4 In the case where contractors conduct the planning or design of the proposed change, the contractor is responsible for identifying environmental issues and legal requirements. However, the Department Environmental Staff have ultimate responsibility to ensure environmental issues and legal requirements are identified.

5.0 Procedures

5.1 During the planning and design of the proposed change, the Department Environmental Staff shall conduct an environmental review for the proposed change. This review shall include a review of the Department's current environmental aspect list and legal requirements list to determine if the proposed change is incorporated in these lists, and if the change increases the scoring of any of the associated aspects in each of the significance criteria.

5.2 The attached Checklist (OEQ-EMS-020.01) and Tables 1 and 2 (OEQEMS-020.02 and .03) are provided to assist with the environmental review for the proposed change. The Checklist contains environmental aspects and legal considerations for various changes (activities). Table 1 contains guidance on the aspects and regulatory considerations. Table 2 contains additional regulatory considerations and subsequent impacts for a variety of aspects.

5.3 Once the Department Environmental Staff have completed this review, and determined if the proposed activity qualifies as a change (i.e. adds additional legal requirements and environmental aspects, and increases the scoring of any associated aspects in each of the significance criteria), then they shall complete the attached "Qualification for Management of Change Procedure Form" (QMP form) (OEQ-EMS-020.04), including signing and dating the QMP form, and maintain the QMP form in the department files.

5.4 For a proposed change that qualifies for this procedure, the Department Environmental Staff shall continue the environmental review by thoroughly identifying the additional legal requirements and environmental aspects, and any increase in the scoring of any associated aspects in each of the significance criteria for the proposed change during the planning and design stages.


City of Da llas Environme tal Management System

5.5 The Department Environmental Staff shall make recommendations to the project manager and/or management regarding environmental considerations for the proposed change. Recommendations due to legal requirements must be incorporated into the proposed change. Examples of environmental recommendations are as follows:

5.5.1 Structural Controls such as a berm, trench, or oil/water separator

5.5.2 Construction practices such as silt fences, dust control, and/or avoidance of wetlands

5.5.3 Permits

5.5.4 Additional Training

5.5.5 Inspections

5.6 After the project manager and/or management review the recommendations, the Department Environmental Staff shall meet with the above staff and document the agreed recommendations for meeting legal requirements and/or reducing environmental impact that shall be incorporated into the proposed change. This document shall be signed by the project manager and the department management and maintained by the department. The Department Environmental Staff shall be kept informed and involved during the planning and design process, and during implementation of the change.

5.7 During implementation of the change, the Department Environmental Staff shall periodically review the progress of the change to determine if the agreed recommendations for meeting legal requirements and/or reducing environmental impact are being appropriately implemented. With regard to any Change Orders issued during the project, Change Orders that only change the cost of the project do not need an environmental review. However, Change Orders that substantially change the scope or the environmental aspects of the project will need an environmental review described in this section.

5.8 Following the change, the facility shall make adjustments to the EMS as required. This includes, but is not limited to the following: aspects/impacts; significant aspects; objectives and targets; operational controls; training, awareness and competency; legal and other; and roles and responsibilities.

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Cit y of Dallas Environmental Management Syste m

5.9 Any unresolved disagreements during any of the reviews of the proposed change, and any discrepancies during the implementation of the change shall be elevated to the Department Director.

6.0 Procedure for Contractors

If a contractor has been hired to do the environmental review (as listed in section 5) for a proposed change, then the contractor is responsible for the final work product. Department Environmental Staff are responsible for reviewing the contractor's final work product.

7.0 Related Documentation

Administrative Directive 3-73, Environmental Management Program OEQ-EMS-001 Environmental Aspects, Impacts, and Significance Criteria Procedure OEQ-EMS-002 Legal and Other Requirements Procedure OEQ-EMS-005 Structure and Responsibility Example OEQ-EMS-006 Training, Awareness and Competency Procedure OEQ-EMS-008 Documents and Records Management Procedure OEQ-EMS-009 Operational Controls OEQ-EMS-010 Emergency Preparedness and Response Procedure OEQ-EMS-018 EMS Guide OEQ-EMS-020.01 Checklist, Guidance for Identification of Legal Requirements and Environmental Aspects for Changes OEQ-EMS-020.02 Table 1, Detailed Guidance for Checklist OEQ-EMS020.01 OEQ-EMS-020.03 Table 2, Additional Regulatory Guidance for Checklist OEQ-EMS-020.01 OEQ-EMS-020.04 Qualification for Management of Change Procedure Form

8.0 Change History - Revision 1

8.1 Added wording to Section 3.0 that this procedure only applies to City of Dallas facilities listed in the EPA Consent Decree dated August 28,2006.

8.2 Deleted 'from the Guidance Checklist (OEQ-EMS-020.01) and Guidance Table 1 (OEQ-EMS-020.02) the following facilities from the list of City of Dallas facilities with TPDES permits: Dallas Police Auto Pound, Southwest Transfer Station, Stevens Park Golf Course, and COD Street Services Department District 4 Street Services D-1 (Southeast)
