CASE STUDY 2

Texas Department of Transportation (TxDOT)

Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations

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CASE STUDY 2

Texas Department of Transportation (TxDOT) Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations
STATUS	Implemented (at least in part) – with an On-Going Process of Continuous Improvement.
FOCUS	TxDOT’s overall focus is on regulatory compliance in the following major program areas: Project Planning and Development – On-going development of a comprehensive project tracking system designed to track NEPA commitments, environmental permits and agency coordination during project planning. Primary Components: Environmental Tracking System (ETS) and Comprehensive Training. Construction Operations – On-going development of multiple management practices designed to ensure NEPA commitments and permit conditions are met during project construction. Primary Components: District Environmental Quality Coordinator (DECQ) and Storm Water Advisory Team (SWAT). Facility Operations – On-going development of multiple management practices designed to ensure compliance with environmental regulations affecting facility operations. Primary Component: Pollution Prevention and Abatement (PPA) Surveys.
DOT’s BASIS FOR SELECTION OF FOCUS	TxDOT’s vision statement includes the need to provide an environmentally sensitive transportation system that works together with the need to provide a comfortable, safe, durable, cost-effective, and aesthetically appealing state transportation system. In support of the environmental aspect of this vision statement, TxDOT has focused on the three broad operational areas listed above. Focusing on the project planning and development process ensures that TxDOT will continuously improve its environmental planning procedures resulting in more timely, more accurate and overall more environmentally sensitive planning. Focusing on construction and facility operations prevents non-compliance with environmental requirements and commitments that would result in regulatory fines and penalties and costly construction delays.
RELEVANCE TO THE EMS PROCESS ROADMAP	The process TxDOT uses to identify its needs and prioritize its efforts generally corresponds with the “Plan-Do-Check-Act” framework discussed in AASHTO’s EMS guidance. However, the development of TxDOT’s multiple environmental management systems has not been a simultaneous linear planning process. Rather it has been an on-going process of continuous improvement and modification that began with processes and programs already in place at TxDOT.

CASE STUDY 2

Texas Department of Transportation (TxDOT) Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations

ACCOMPLISHMENTS AND BENEFITS

Project Planning and Development Highlights : · TxDOT has developed a comprehensive Environmental Tracking System (ETS) that tracks projects throughout the planning stages to ensure the NEPA issues are addressed and environmental permits are coordinated before the project is released for construction. · TxDOT design personnel can determine if all Environmental Permits, Issues and Commitments (EPIC) are addressed in the project plans by accessing ETS. · By accessing ETS, TxDOT construction and maintenance personnel have realized the implications and importance of adhering to project environmental requirements and other environmental rules and laws and are able to take actions that prevent, or, at the least, minimize the environmental impacts and costs associated with nonconformance / noncompliance during the project construction stages. · TxDOT's ETS also has created a near-paperless environment that allows many project papers to be saved, edited and circulated electronically, thereby reducing storage expenses and minimizing the time needed to retrieve files. · ETS also calculates estimated process time for environmental clearance, ROW, and PS&E. · The ETS has enabled TxDOT to involve the entire organization and account for all critical paths, some of which are not always obvious with the result that actions and plans are both efficient and effective. Construction and Maintenance Project Highlights: · TxDOT’s 25 districts have been directed to name a District Environmental Quality Coordinator (DEQC) to perform environmental performance reviews for construction and maintenance projects using an established checklist to ensure all that all EPICs identified for a project and tracked in ETS are addressed properly during construction and maintenance projects. · DEQCs are required to perform at least one review a year for projects with permits, formal consultation, or other mitigation requirements. DEQCs report findings to the district Area or Project Engineer and send a copy to the District Engineer. · DEQCs are required to perform at least one inspection every six months on a randomly selected project for each area office for other construction projects. This review is primarily to address compliance with storm water permit requirements, ensure compliance with other environmental regulations and to increase uniformity in the required documentation used to demonstrate compliance with environmental regulations and requirements. Findings are reported to the Area or Project Engineer and copies to the District Director of Construction.

CASE STUDY 2

Texas Department of Transportation (TxDOT) Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations

ACCOMPLISHMENTS AND BENEFITS (cont’d)

Construction and Maintenance Project Highlights (cont’d): · DEQCs are required to perform at least one inspection every six months for maintenance section projects in each district area office. This review is primarily to address compliance with storm water permit requirements, ensure compliance with other environmental regulations and to increase uniformity in the required documentation used to demonstrate compliance with environmental regulations and requirements. The DEQC reports all findings to the Maintenance Supervisor, Area Engineer and the District Director of Maintenance. · TxDOT’s executive management also directed each district to conduct reviews for every ongoing construction project that involves formal resource agency consultations or US Army Corps of Engineers permits to ensure that avoidance, mitigation, or permit conditions are being met. Storm Water Management Highlights: · TxDOT has organized a Storm Water Advisory Team (SWAT) for the purpose of: 1) Ensuring that TxDOT is in full compliance with state and federal storm water regulations; 2) Providing guidance to the district offices regarding storm water management issues; 3) Assisting in the development of a model Storm Water Pollution Prevention Plan (SWP3) packet for TxDOT that could be utilized by all Districts, and 4) Assisting in the development of a coordinated and efficient Statewide Storm Water Management Program (SWMP). · The SWAT uses a multi-pronged approach to achieve its goal, such as: conveying information through internal bulletins, providing training information for district staff, providing SW3P inspection assistance, gathering information about the effectiveness of BMPs, and generate ideas for overall improvements to storm water management. The SWAT is a multi-disciplinary team comprised of representatives from TxDOT's Design, Construction, Maintenance and Environmental Affairs Divisions who share their expertise and develop practical cost-effective solutions to meet the storm water management regulatory requirements. Facility Operations Highlights: · Pollution Prevention and Abatement (PPA) facility compliance surveys are conducted internally by TxDOT staff. The PPA survey process, which has evolved over the last few years, helps identify TxDOT district facilities that need improvement in PPA practices and thus prevents regulatory noncompliance and its associated costs and environmental impacts. District facility surveys are currently repeated on a two-year rotating schedule. · The PPA surveys also identify good PPA practices that can be incorporated at other TxDOT facilities thus encouraging new ways to continuously improve PPA practices. · The PPA survey process incorporates district “response forms” that provide a feedback mechanism regarding PPA improvements and corrective action being implemented following the survey. Implementing improved management practices result in higher compliance rates.

CASE STUDY 2

Texas Department of Transportation (TxDOT) Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations
ACCOMPLISHMENTS AND BENEFITS (cont’d)	Facility Operations Highlights (cont’d): · Survey results are recorded on a Microsoft® Excel-based checklist form. Macros automatically transfer the survey results to a summary scoring table and generate a deficiencies table with corrective action steps and a response form for the district. · Survey results also have highlighted areas where additional PPA resources and training programs are needed. Environmental Training Highlights: · To support its environmental efforts, TxDOT has developed a comprehensive series of introductory level and advanced environmental training courses for TxDOT staff. TxDOT’s 17 environmental training courses provide staff with the necessary knowledge and skills to ensure compliance with TxDOT's Environmental Policy, the NEPA, and other state and federal regulations. · The courses provide information to attendees so that they can effectively incorporate sound decision-making during project development and construction and facility operations.
IMPLEMENTATION NEEDS	TxDOT envisions adding functionality that would fully integrate and automate the current collection of environmental management systems. This includes a central repository for PPA surveys with the ability to make compliance updates online; a central repository for internal environmental policies, guidance and training as well as internet links to resource agencies’ policies; and a central repository for job descriptions outlining environmental-related job duties and responsibilities. Additional staff time with the help of internal and/or external information technology resources are needed to begin this next step.
KEYS TO SUCCESS	· Visible commitment from senior management and committed technical level staff. · Build environmental management systems a little at a time to balance the management system needs with other demands. · Build on existing successful efforts already in place. · Involve the whole organization, from top to bottom, on any issue involving environmental documentation, processes or compliance. Tracking NEPA processing is not enough; assuring compliance draws in personnel who learn how critical they are in meeting various rules and laws. · In a large organization, environmental management systems have to account for all relevant critical paths associated with environmental documentation, processes or compliance that may exist within a large organization. Sometimes the paths are obvious, sometimes they aren’t.
BACKGROUND, ADDITIONAL INFO	TxDOT’s ETS was implemented several years ago and is being developed and enhanced a little at a time as a work in progress to balance the need for it against other demands. Implementation of the ETS has resulted in the development of tracking software and an interactive web-based manual that is available at http://manuals.dot.state.tx.us/dynaweb/coltrsys/env or portable document format at http://manuals.dot.state.tx.us/docs/coltrsys/forms/env.pdf .

CASE STUDY 2

Texas Department of Transportation (TxDOT) Internal Environmental Management Systems Supporting Project Development, Construction Operations, and Facility Operations
BACKGROUND, ADDITIONAL INFO (cont’d)	As a work in progress, the ETS is continuously upgraded. Current efforts to improve the effectiveness of the ETS include the integration of compliance tracking and EPICs into project plan sheets. TxDOT’s DEQC program is relatively new and was developed to emphasize the environmental compliance side of the environmental process particularly during construction and maintenance projects. DEQC actions, duties and responsibilities for this position are under development by each of TxDOT’s twenty-five district offices. TxDOT’s SWAT program initially began several years ago when the NPDES storm water construction general permit was first issued. The SWAT was reformed a few years ago when it became apparent that storm water management issues were becoming increasing complex and a permanent technical advisory team was needed. The SWAT currently is exploring the possibility of providing a “Storm Water” e-mail address that could link TxDOT districts to members of the SWAT. District staff could utilize this e-mail as a platform to post questions related to the NPDES permit, disseminate lessons learned, share good ideas, insights and experiences, and discuss common challenges. The PPA surveys began several years ago in conjunction with TxDOT’s health and safety inspection program. Current plans are to enhance TxDOT’s on-line environmental facility guidance information into a more user friendly format that has a direct link with the PPA survey checklist. TxDOT also is exploring the development of comprehensive training program for TxDOT staff involved in environmental compliance for facility operations.
CONTACT(S)	Duncan Stewart, P.E., Section Director, Environmental Affairs Division, 512/416-3014, dstewart@dot.state.tx.us
EXAMPLE TOOLS, PROCEDURES	Exhibit 1 provides an excerpt screen from TxDOT’s Environmental Tracking System. In particular this screen shows how environmental reviews and clearances are tracked so that times can be shortened and events can be planned concurrently. Exhibit 2 presents TxDOT‘s District Environmental Quality Coordinators Checklist. Exhibit 3 presents the TxDOT’s Pollution Prevention and Abatement Facility Compliance Checklist.

CASE STUDY 2 – Exhibit 1 – PAGE FROM TxDOT’s ENVIRONMENTAL TRACKING SYSTEM

Case Study 2 - Exhibit 2 – District Environmental Quality Coordinators (DECQ) Checklist

	ENVIRONMENTAL COMMITMENT CHECKLIST For Construction, Maintenance and Facilities Projects
PROJECT:		DATE:
CSJ:		DEQC:
HIGHWAY:		Name
I. Storm Water Pollution Prevention
A. Required Information and Documentation
1. Does the construction site have a Storm Water Permit?			Yes	No *		N/A
2. Is a notice posted in a publicly accessible location near where construction is actively underway (and moved as necessary)?			Yes	No *		N/A
3. Does the notice contain the following information:
a. The permit number or a copy of the NOI?			Yes		No *		N/A
b. The name and telephone number of a local contact person?			Yes		No *		N/A
c. A brief description of the project?			Yes		No *		N/A
d Location of SW3P (Job site or other location).			Yes		No *
4. Is there a copy of the Construction General Permit in the SW3P? (a copy of the Federal Register is sufficient)			Yes		No *		N/A
5. 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
6. Is the SW3P retained on-site at the facility that generates the storm water? (If no, where is it located _____________________________________________)?			Yes		No *		N/A
7. 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 storm water management site plans or site permits approved by State, Tribal or Local Officials for which the permittee receives notice?			Yes		No *		N/A
8. Is the description of construction and waste materials expected to be stored on-site updated?			Yes		No *		N/A
9. Are the following records maintained and available for inspection, or included in the SW3P?
a. Dates when major grading activities occur?			Yes		No *		N/A
b. Dates when construction activities temporarily or permanently cease on a portion of the site?			Yes		No *		N/A
c. Dates when stabilization measures are initiated?			Yes		No *		N/A
10. 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
B. General Conditions
1. Are Best Management Practices (BMPs) being utilized?			Yes		No *		N/A
2. 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
C. Controls & Measures
1. Have erosion and sediment controls been designed to retain sediment on-site to the extent practical during the construction phase?			Yes		No *		N/A
2. Were control measures, in accordance with manufacturer specifications and good engineering practices:
a. Properly selected?			Yes		No *		N/A
b. Properly installed?			Yes		No *		N/A
c. Properly maintained?			Yes		No *		N/A
d. In effective operating conditions?			Yes		No *		N/A
3. Are controls in place to minimize:
a. Dust generation?			Yes		No *		N/A
b. Off-site vehicle tracking of sediments?			Yes		No *		N/A
4. 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
5. Is sediment removed from the sediment traps or sediment ponds when design capacity is reduced by 50%?			Yes		No *		N/A
6. Are litter, construction debris, and construction chemicals exposed to storm water prevented from becoming a pollutant source from storm water discharges? (e.g., screening outfalls, picked up daily)			Yes		No *		N/A
7. 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
8. 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
D. Inspections
1. 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
2. Did the inspector check the following:
a. Disturbed areas of the construction site that have not been stabilized?			Yes		No *		N/A
b. Areas used for storage of materials that are exposed to precipitation?			Yes		No *		N/A
c. Structural control measures?			Yes		No *		N/A
d. Locations where vehicles enter or exit the site?			Yes		No *		N/A
3. 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
4. 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
5. Did the inspection Summary Report include:
a. The name of the inspector?			Yes		No *		N/A
b. The date(s) of the inspection?			Yes		No *		N/A
c. Measures/area inspected?			Yes		No *		N/A
d. Actions needed/taken as a result of the inspection?			Yes		No *		N/A
e. Signature of inspector with certification statement?			Yes		No *		N/A
f. Inspector properly delegated in writing to EPA?			Yes		No *		N/A
II. Water Resources Compliance
A. USAC Permits
1. US Army Corps of Engineers (USACE) Permits: Does the project have a USACE (Section 10 or Section 404) permit?			Yes		No		N/A
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 USACE)?			Yes		No *		N/A
b. Are any Project Specific Locations, on or off Right-of-Way, that are directly related to the USACE permit addressed in the permit or Corps letters to the contractor (for off ROW PSLs)?			Yes		No *		N/A
c. Has clearance been obtained for any changes in design or construction methods in the areas covered by the permit?			Yes		No *		N/A
d. Does the project meet all conditions listed in the permit?			Yes		No		N/A
2. 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
a. Does the project have the BMPs installed as designated in the Tier I checklist or as otherwise specified?			Yes		No *		N/A
b. Are the BMPs working effectively? (If not, immediately bring the problem to the attention of the project engineer)			Yes		No *		N/A
c. Are there wetlands on the project site?			Yes		No		N/A
d. Are wetlands that are required to be preserved by the USACE permit being effectively protected?			Yes		No *		N/A
B. Other Water Requirements
1. Does the project require an Edwards Aquifer Protection Plan (for central Texas counties Kinney, Uvalde, Medina, Bexar, Comal, Hays, Travis, & Williamson only)			Yes