TXDOT Environmental Management System Verification Audit - Results. TxDOT Short Course October 16, 2013

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1 TXDOT Environmental Management System Verification Audit - Results TxDOT Short Course October 16, 2013

2 EMS VERIFICATION - BACKGROUND WHY PERFORM AN EMS VERIFICATION? TxDOT and EPA entered into a Consent Agreement and Final Order (CAFO) due to a settlement for alleged violations of the clean water act The CAFO required TxDOT to implement a Construction Oversight Program (COP) known as the Environmental Management System (EMS) and conduct an independent verification of the EMS implementation Shaw was contracted to perform the independent verification TXDOT EMS VERIFICATION AUDIT - RESULTS 2

3 EMS VERIFICATION - BACKGROUND WHAT WAS THE EMS VERIFICATION? A systematic and documented process for objectively obtaining and evaluating evidence to determine the following: Has the EMS been implemented on a statewide basis? Does implementation of the EMS conform to the TxDOT EMS criteria? Are EMS results communicated to management and acted upon appropriately? TXDOT EMS VERIFICATION AUDIT - RESULTS 3

4 EMS VERIFICATION - BACKGROUND WHAT WERE THE EMS VERIFICATION OBJECTIVES? 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 implemented EMS Manual and processes 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 impacts of road construction as stipulated within the TxDOT EMS 4

5 EMS VERIFICATION - BACKGROUND EMS VERIFICATION APPROACH HQ Audit West North South East Amarillo (Rural) Childress (Rural) Paris (Rural) Dallas (Metro) Austin (Metro) San Antonio (Metro) Beaumont (Urban) Bryan (Urban) 2 Road Construction Projects 2 Road Construction Projects 2 Road Construction Projects 2 Road Construction Projects Verifications Included: TP&D Construction Environmental (DEQC, Environmental Coordinator) TXDOT EMS VERIFICATION AUDIT - RESULTS 5

6 EMS VERIFICATION - RESULTS Nine (9) Verification Audits Conducted 79 Total Findings Findings Distribution No. Findings 6

7 EMS VERIFICATION - RESULTS Findings Placed Into 13 Categories 75% of Findings Related to Five (5) Categories Findings By Category % No. Findings 7

8 EMS VERIFICATION - RESULTS 1. CONFORMANCE WITH SPECIAL SPECIFICATION & SPECIAL PROVISION 1122 Findings related to three (3) main areas: Contractor Training Contractor Certification Contractor Daily Monitoring of Project Sites 8

9 EMS VERIFICATION - RESULTS 2. COMPLIANCE WITH TPDES CGP AND SWP3 Findings related to two (2) main areas: SWP3 Administrative Compliance - Documentation (vast majority of findings) BMPs 9

10 EMS VERIFICATION - RESULTS 3. CONFORMANCE WITH EMS MANUAL REQUIREMENTS Centered around on-site practices at the District level that differed from those described in the EMS Manual. Identified during the early district verifications EMS Manual revised in June 2013 to provide clarification regarding communication of inspection/monitoring/measurement results 10

11 EMS VERIFICATION - RESULTS 4. Conformance with EMS TRAINING REQUIREMENTS Completion and/or documentation of TxDOT personnel training per EMS Training Matrix Training course availability. 11

12 EMS VERIFICATION - RESULTS 5. CONFORMANCE WITH TxDOT STORMWATER INSPECTION FORM (2118) Findings related to three (3) main areas: Establishing and Maintaining Inspection Frequency Prioritizing Findings Identification of Potential CGP/SWP3 Noncompliances 12

13 EMS VERIFICATION - CONCLUSIONS CONCLUSIONS Majority of findings related to administratively complying with or conforming to regulatory or EMS requirements Few field issues noted during road construction site visits. Majority of the road construction projects evaluated were the first projects subject to the new EMS requirements. 13

14 EMS VERIFICATION - CONCLUSIONS CONCLUSIONS Administrative issues highlighted in the findings do not appear to be the result of a lack of implementation but are likely reflective of the newness of the EMS requirements. Verification review results indicate that the TxDOT EMS has been implemented on a statewide basis. Conformance to the Key EMS Management Elements and other requirements of the TxDOT EMS was observed at all sites evaluated during the EMS review process. 14

15 QUESTIONS? 15