CASE STUDY 6 Massachusetts Highway Department (Mass Highway) Environmental Management System © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-1 This page is intentionally left blank. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-2 CASE STUDY 6 Massachusetts Highway Department (MassHighway) Environmental Management System STATUS Implemented. FOCUS Operation and maintenance activities at depot facilities. DOT’s BASIS FOR In 1994, in response to an Administrative Consent Order (remediation costs SELECTION OF >$50 million) with the Department of Environmental Protection, MassHighway FOCUS began a comprehensive environmental compliance initiative at its maintenance facilities. Six major compliance programs were identified and EMS procedures, processes, and tools developed for: Hazardous Waste, Wetlands, Hazardous Materials, Underground Storage Tanks, Water Quality, and Solid Waste. RELEVANCE TO THE MassHighway uses the Plan – Do – Check – Act process (and, in turn, many of EMS PROCESS the steps presented in the Process Roadmap) in developing and implementing ROADMAP their EMS. ACCOMPLISHMENTS • MassHighway managers have noticed an increased environmental AND BENEFITS awareness in the substantial majority of maintenance employees. This awareness, coupled with environmental procedures, responsibilities, training, and assessments, helps Mass Highway prevent environmental problems and makes it easier to correct such problems when they do occur. This, in turn, reduces costs of compliance (including potential fines) and corrective actions. • The EMS has led to improved relations with regulatory authorities (thus easing oversight and permitting burdens and delays) and has helped MassHighway preserve its mission. KEYS to SUCCESS • Efforts to develop this system were supported by the Secretary of the Executive Office of Transportation and Construction (EOTC), the Commissioner of MassHighway, and senior management by declaring the EMS as a goal through the Massachusetts Managing for Results Initiative Program . • While considerable time has been invested in planning how the system should work, the Agency recognizes that the EMS must be dynamic and adaptive to regulatory and operational changes. • The Agency also recognized that continued environmental compliance is dependent upon the development of clear lines of authority, responsibility and accountability for environmental management and identification and allocation of adequate funding. • Involved personnel (including managers and staff) from across the organization and the state in efforts. • Communication of expectations, goals, requirements, and procedures to all involved employees ensures that personnel know what is expected and builds consistency. “You cannot communicate enough…” • Use existing methods and procedures, as much as possible with minor modifications as needed, to accomplish what you want to do – this builds acceptance and reduces the need to create new processes. Most people do not accept change readily. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-3 CASE STUDY 6 Massachusetts Highway Department (MassHighway) Environmental Management System KEYS to SUCCESS • MassHighway elected to develop programs to achieve compliance in (cont’d) advance of adopting the formal EMS. This was in part due to regulatory pressure but also allowed the EMS to encompass already existing programs that employees had been using. IMPLEMENTATION • Needed to identify expected costs and benefits to obtain resources and NEEDS commitment with the development of an Implementation Plan. • Consultant support was needed to assist in EMS development and implementation . • Training and other communications were needed to raise the environmental awareness of employees and are still needed to maintain awareness. • The EMS efforts required the support of approximately 10 Central Office and Field staff. • Consultant recourses are currently needed to inventory all permits to be logged into a web-based tracking database “EnviroTrac”, and to support other special projects such Spill Prevention Countermeasure and Control Plan development at selected Facilities. BACKGROUND, By assessing its facilities MassHighway established that there were many ADDITIONAL INFO issues relative to environmental compliance one of the most visible was the improper storage of hazardous waste. The Governor and the Executive Office of Environmental Affairs further required that all agencies perform environmental audits of their respective facilities. It became clear that it made sense to keep the facilities in proper order and develop sustainable methods of operation. The EMS was created sustain environmental compliance with respective its depot facilities. • In the mid-90s, MassHighway performed a gap analysis to evaluate MassHighway’s management structure and to determine the level of environmental compliance. 600 aspects were reduced to 6 compliance priority areas. • The gap analysis concluded that a significant financial and personnel investment was needed to correct violations of regulatory requirements and to provide a method to ensure on-going compliance. EMS became a tool to ensure compliance and realize savings in fines and supplemental environmental projects to preserve mission, while increasing consistency and understanding. • Separate Management System Improvement and Implementation Plans were prepared. Together these plans outlined the programs and funding needed to achieve environmental compliance. During the development of these plans it was determined that the majority of the funding for environmental compliance would be directed toward “cleaning up” the previously accumulated wastes located at the facilities. o Under the Hazardous Waste and Solid Waste Programs, these wastes were removed and either properly disposed of or recycled. New waste/material storage areas and equipment for spill management were also provided through the Hazardous Material Program. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-4 CASE STUDY 6 Massachusetts Department of Transportation (Mass Highway) Environmental Management System BACKGROUND, o The Water Quality Program provided for facility improvements such as ADDITIONAL INFO septic system upgrades/installation, sewer connections, floor drain (cont’d) upgrades and the installation of wash water recycling systems. o The Wetland Program provided for the identification of impacts to wetlands, and the implementation of corrective actions. o The Tank Program replaced or upgraded all USTs to meet Federal standards. Subsequent to the development of the management plans, an additional compliance program was instituted for managing asbestos issues and is currently responsible for inspection and abatement of known locations of asbestos and requires the oversight of the Statewide and District Asbestos Coordinators during facility demolition and renovation projects. • MassHighway published a Facility Environmental Handbook particular to each facility. This handbook is a reference document that provides guidance on conducting operations in compliance with environmental requirements. It contains standard operating procedures and maps to identify structures and environmentally sensitive areas such as wetlands. The handbook is used to train MassHighway personnel on an annual basis and raise the level of environmental awareness. The department also has an EMS manual and 20 operating procedures and is developing a website. • A committee with District Maintenance Engineers was established to define roles, which are reviewed annually during training events for all facility personnel (training in off season time). MassHighway’s Standard Operating Procedures references these roles and responsibilities. • In developing the EMS, MassHighway used existing methods and procedures to accomplish wants with minimum (/) modifications. CONTACT(S) Mr. Steven Miller, Supervisor, Hazardous Materials Section, 617/973-8248, [email protected] EXAMPLE TOOLS, A key to the success of any EMS is the commitment of senior management. PROCEDURES Exhibit 1, A Commitment to the Environment, demonstrates this commitment in MassHighway and explains the significance of the EMS. Mass Highway has prepared an EMS Manual which captures its EMS procedures, processes, and tools. Following are descriptions of excerpts from this Manual. • Exhibit 2 provides the Table of Contents. • Exhibit 3 presents the EMS Manual’s Executive Summary. This section provides background on the EMS and explains EMS goals, procedures, processes, and tools. PLEASE NOTE: the Executive Summary embodies the Plan – Do – Check – Act process described in the AASHTO EMS Process Roadmap. • Exhibit 4 provides an excerpt that identifies District Roles and Responsibilities. This excerpt illustrates the need to clearly identify and communicate environmental roles and responsibilities. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-5 CASE STUDY 6 Massachusetts Department of Transportation (Mass Highway) Environmental Management System EXAMPLE TOOLS, • Exhibit 5 presents an excerpt describing training requirements. Training is a PROCEDURES key to understanding and implementing environmental requirements and (cont’d) EMS procedures. • Exhibit 6 provides an excerpt that describes another key element of a successful EMS – self auditing. Following are excerpts of procedures and tools that MassHighway uses to implement its EMS. • Exhibit 7 shows the Self Audit Checklist used during the annual facility self audit. This checklist is provided in the Self Audit Procedure Fieldbook. • Exhibit 8 presents an excerpt of the Regular Inspection Checklist which is used to periodically inspect for compliance violations and initiate corrective actions if needed. • Exhibits 9 through 12 provide examples of Standard Operating Procedures which are used by field personal as a tool to support compliance and Agency goals. There are 24 such procedures. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-6 CASE STUDY 6 Exhibit 1 © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-7 CASE STUDY 6 Exhibit 2 Table of Contents Environmental Commitment Executive Summary SECTION I – General Roles and Responsibilities Executive Office of Transportation and Construction...............................1 Commissioner..........................................................................................1 Chief Engineer.........................................................................................1 Chief Counsel..........................................................................................2 Administrative Services Division..............................................................2 Environmental Division............................................................................3 Operations Division..................................................................................4 Construction Division...............................................................................5 Engineering Division................................................................................6 Right of Way Section ..............................................................................6 Privatization Engineer..............................................................................6 Research and Materials Laboratory.........................................................6 EMS Task Force......................................................................................6 Districts....................................................................................................7 SECTION II - EMS Components Funding...........................................................................................................8 Environmental Requirements.....................................................................12 Emergency Preparedness...........................................................................15 Standard Operating Procedures.................................................................18 Facility Environmental Handbook and Maps.............................................20 Training.........................................................................................................23 Compliance Tracking...................................................................................28 Self-Auditing.................................................................................................31 Pollution Prevention....................................................................................35 EMS Review and Evaluation.......................................................................37 © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-8 Section III - Contacts and Information Sources Contacts .......................................................................................................40 Information Sources....................................................................................42 © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-9 CASE STUDY 6 Exhibit 3 Executive Summary Background In 1994, in response to an Administrative Consent Order with the Department of Environmental Protection, MassHighway began a comprehensive environmental compliance initiative at its maintenance facilities. At the outset, the department performed a gap analysis to evaluate MassHighway’s management structure and to determine the level of environmental compliance. The gap analysis concluded that a significant financial and personnel investment was needed to correct violations of regulatory requirements and to provide a method to ensure on-going compliance. The need to develop and institutionalize a formal Environmental Management System to support environmental compliance was thus identified. The efforts to develop this system were supported by senior management at MassHighway and the Executive Office of Transportation and Construction (EOTC). As a result, separate Management System Improvement and Implementation Plans were prepared. Together these plans outlined the programs and funding needed to achieve environmental compliance. During the development of these plans it was determined that the majority of the funding for environmental compliance would be directed toward “cleaning up” the previously accumulated wastes located at the facilities. Six major compliance programs were immediately created: Hazardous Waste, Wetlands, Hazardous Materials, Underground Storage Tanks, Water Quality and Solid Waste. Under the Hazardous Waste and Solid Waste Programs, these wastes were removed and either properly disposed of or recycled. New waste/material storage areas and equipment for spill management were also provided through the Hazardous Material Program. The Water Quality Program provided for facility improvements such as septic system upgrades/installation, sewer connections, floor drain upgrades and the installation of wash water recycling systems. The Wetland Program provided for the identification of impacts to wetlands and the development and implementation of corrective actions. The Tank Program replaced or upgraded all USTs to meet Federal standards. Subsequent to the development of the management plans, an additional compliance program was instituted for managing MassHighway’s asbestos issues. MassHighway further published a Facility Environmental Handbook particular to each facility. This handbook is a reference document that provides guidance on conducting operations in compliance with environmental requirements. It contains standard operating procedures and maps to identify structures and environmentally sensitive areas such as wetlands. The handbook is used to train MassHighway personnel on an annual basis and raise the level of environmental awareness. Environmental Compliance and the EMS Manual While providing facility staff with the appropriate tools and upgrading the facility infrastructure were important first steps, the Department also recognized that continued environmental compliance is dependent upon the development of clear lines of authority, responsibility and accountability for environmental management and identification and allocation of adequate funding. This Environmental Management System (EMS) manual serves that purpose in that it documents the lines of authority and the respective roles and responsibilities within the department. This manual also provides the framework to instill an operating awareness at all organizational levels of the importance of integrating sound environmental management practices into the operations of the Department. MassHighway has designed the EMS in accordance with a Plan, Do, Check, Act improvement cycle. While considerable time has been invested in planning how the system should work, the Department recognizes that the EMS must be dynamic and adaptive to regulatory and operational changes. To meet this need a regular review process will be in effect to ensure that the system can be modified and continually improved to meet the Department’s objectives. © 2003 – AASHTO Center for Environmental Excellence Case Study 6 Page 6-10