layde philips programs management, environmental … site visits and interview schedules ......
TRANSCRIPT
01M042012D
WHAT IS THE EMS VERIFICATION?
4 WHAT IS THE TXDOT EMS VERIFICATION AUDIT ?
A systematic and documented process for objectively obtaining and
evaluating evidence to determine the following:
Does implementation of the TxDOT EMS conform to the TxDOT EMS criteria?
Are EMS results communicated to management and acted upon appropriately?
Say what you do/Do what you say
EMS
TxDOT Management System Elements
1. EMS Policy
2. Roles and Responsibilities
3. Environmental Requirements
4. Assessment, Prevention and Control
5. Training Awareness and Competence
6. Records and Documentation
01M042012D 5
EMS VERIFICATION OBJECTIVES
WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
Independently evaluate the adequacy and effectiveness of
the TxDOT EMS implementation from top management
down and throughout each district based on a
representative sample.
Provide a independent assessment as to whether the
TxDOT EMS has been implemented in such a manner as
to facilitate understanding, by appropriate TxDOT
employees and contractors, of the following:
• the environmental aspects and impacts of road construction
• the environmental controls, monitoring and measurement
procedures or processes contained within the TxDOT EMS
to address the aspects and impacts of road construction
• individual environmental responsibilities related to the
aspects and impacts of road construction as stipulated within
the TxDOT EMS
TxDOT Management
System Elements:
1. EMS Policy
2. Roles and
Responsibilities
3. Environmental
Requirements
4. Assessment, Prevention
and Control
5. Training Awareness and
Competence
6. Records and
Documentation
01M042012D
EMS VERIFICATION APPROACH
6 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
HQ Audit
West
2 Districts
TBD
Active Road Construction Sites
North
2 Districts
TBD
Active Road Construction Sites
South
2 Districts
TBD
Active Road Construction Sites
East
2 Districts
TBD
Active Road Construction Sites
District Selection Criteria
Geographical Coverage
Construction Activity
Large/Small Geographical Area
Rural/Urban
01M042012D
EMS VERIFICATION APPROACH - HQ
7 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
Headquarters
Environmental Affairs
Division
Construction Division
Design Division
Maintenance Division
Administration Division
TxDOT EMS Elements
•Policy Statement
•Roles/Responsibilities
•Environmental Requirements
•Assessment, Prevention and Control
•Training, Awareness and Competence
•Records and Documentation
Two (2) person Team
Three (3) Day Verification
Five Divisions
01M042012D
EMS VERIFICATION APPROACH - Districts
8 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
DISTRICT
Project Development/Environmental
EMS Element
Design
EMS Element
Contractor/Subcontractor
Construction Phase
2-3 Construction Projects/District
Preliminary Design
EMS Element
District Engineer
Construction Inspector
TxDOT EMS Elements
•Policy Statement
•Roles/Responsibilities
•Environmental Requirements
•Assessment, Prevention and
Control
•Training, Awareness and
Competence
•Maintenance of Records and
Documentation
2.5 day verification
2 person teams
01M042012D
EMS VERIFICATION APPROACH
9 WHAT IS THE TXDOT EMS VERIFICATION AUDIT ?
Planning
Verification Plan Developed and Approved by USEPA
Master Audit Schedule
District Projects Selected Fit the EMS Road Construction Definition
Projects Selected From October 2012 Letting
Coordinate with Districts Regarding Visit Logistics
Identify Personnel to be Interviewed
01M042012D
EMS VERIFICATION APPROACH
10 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
Verification (2.5 days)
Opening Meeting
• Introductions/Process Overview
• Safety Requirements etc.
Records Review
Personnel Interviews
• District Employees/Contractors
Physical inspections
• 2-3 Active Road Construction Projects
Closing Meeting
• AM Meeting
• Review of Findings
• Discussion of Corrective Actions
• Q&A
Day 1
Day 2
Day 3
01M042012D
EMS VERIFICATION APPROACH
11 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
Reporting and Follow Up
Findings Report
• Submit to HQ within seven (7) business days
• Summarize Verification Activities
• Provide Detailed Verification Findings + Corrective Actions
Periodic Requests for Corrective Action Updates
• E-Mails from Shaw to EMS Coordinator and District Contact
• Requesting Updates Regarding Corrective Action
• Track Closure of Verification Findings
• Closure Progress Reported to HQ On Recurring Basis
01M042012D
EMS VERIFICATION PROCESS - General
12 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
Say what you do/Do what you say
Are EMS procedures/processes adequately inclusive of road construction
environmental impacts?
Do the TxDOT EMS procedures/processes describe what’s actually happening? • Review of job site for environmental requirements, implementation of procedures.
Is there objective evidence that EMS procedures/processes are being followed?
• Review of District and Project EMS Records
Is EMS documentation controlled?
• Current versions or forms, procedures etc. used?
Are related documents and records referenced?
• SOPs • Environmental Scoping • EPIC Sheet • Pre-Construction Conference • Construction State Gate Checklist • Storm Water Inspection Checklist
EMS
01M042012D 13
EMS VERIFICATION PROCESS
EXAMPLE PERSONNEL INTERVIEW QUESTIONS
How did you become aware of the TxDOT Environmental
Policy?
What is your understanding of the EMS Policy and how does it
apply to your day-to-day work?
What are your responsibilities within the TxDOT EMS?
What environmental impacts are associated with your work?
What EMS procedures or processes do you follow when
conducting your work?
How does your work vary from the procedures?
What kind of EMS or environmental training have you received?
How do you escalate environmental concerns to management?
TxDOT EMS Elements:
1. EMS Policy
2. Roles and
Responsibilities
3. Environmental
Requirements
4. Assessment,
Prevention and
Control
5. Training Awareness
and Competence
6. Records and
Documentation
WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
01M042012D
14 WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
EMS VERIFICATION SCHEDULE
Project Tasks September 2012 – January 2014
S O N D J F M A M J J A S O N D J
Develop Verification Plan content outline
Define corrective action and follow-up methodology
Draft Verification Plan to meet CAFO requirements
Coordinate with TxDOT for Verification Plan Development
Provide draft Verification Plan to TxDOT
Incorporate TxDOT comments into Plan
Submit final Verification Plan to EPA as directed by TxDOT
Incorporate EPA comments into Plan (30 days of receipt)
Obtain EPA approval of final Verification Plan
Finalize site visits and interview schedules
Conduct Austin, TX Headquarters Audit
Conduct Audits – TxDOT Southern Region
Conduct Audits – TxDOT Eastern Region
Conduct Audits – TxDOT Northern Region
Conduct Audits – TxDOT Western Region
Develop Verification Report Content Outline
Coordinate with TxDOT for Report development
Provide draft Verification Report to TxDOT for review
Incorporate TxDOT comments into final Report
Submit final Verification Report to EPA
01M042012D
"This project was undertaken in connection with the settlement of an enforcement action taken by the U.S. Environmental Protection Agency for alleged violations of Clean Water Act provisions.“ (CAFO 27)
16
01M042012D
Road Construction Project - Road construction operation that includes any of the following associated activities: earth work, concrete work, asphalt work, steel work, masonry work, demolition work, excavation work, fill work, land clearing, painting, soil stabilization, equipment operation, de-watering activities, material storage, waste management, waste disposal, and waste recycling activities. Under this definition, construction also includes project specific locations (PSLs), such as concrete and asphalt batch plants, within the Right-of-Way. The term construction does not include routine or preventative roadway maintenance activities.
– Types of projects include new location, existing pavement
rehabilitations/widening, culvert work, bridge rehabilitation/replacement.
– Typical projects not requiring the Stage Gate Checklist (SGC) to be completed would be signal installation, crack sealing, retrace striping, seal coating, bridge joint repair.
– Districts should determine whether the SGC should be completed on minimal soil disturbance Construction or Maintenance contracts such as any MBGF upgrade, landscaping, ACP overlays.
EMS Road Construction Definition with
Guidance