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Chapter 2
Organizational Environmental Stewardship Practices
2.5. Operational Controls, Procedures, and Practices

To implement an effective environmental management system, an organization must identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. An organization then must plan those activities, including construction and maintenance, in order to ensure that they are carried out under specified conditions in order to ensure that the desired environmental objectives or outcomes are achieved. To accomplish this, organizations typically establish and maintain documented procedures to cover situations where the absence of such procedures could lead to deviations from the environmental policy and the objectives and targets.

 

2.5.1 Procedures and Manuals
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Procedures are commonly established for both wide and highly specific areas of construction and maintenance. Procedures and manuals support environmental stewardship as they function to:

  • Provide guidance for employee performance and decision-making.
  • Reinforce DOTs' stewardship commitments.
  • Help reduce the potential for internal and external conflicts about authorization for stewardship-related activities.
  • Help ensure consistency in the completeness, accuracy, and currency of environmental instructions and documents and the delivery of this information to the appropriate audiences.
  • Help DOT employees and contractors comply with current environmental commitments and requirements.
  • Reduce the number and cost of environmental incidents as well as agency risk.

Typically DOTs already maintain Standard Specifications and Maintenance Activity Manuals. In some cases, stewardship performance could be enhanced by adding expected environmental practices that should occur in conjunction with the activities outlined in the specs or maintenance activity manual. It is hoped that this research project will provide a further source of such practices. Common activities for which subject specific guides have been developed include erosion control, herbicide application, or facilities maintenance. Few states have developed guides to the environmental aspects of maintenance and operations on a broader level, though a few excellent examples exist, including the NYSDOT Environmental Handbook for Transportation Operations, NCDOT Best Management Practices Manual for Construction & Maintenance, and the New Brunswick DOT Field Guide for Construction & Maintenance Operations. NYSDOT and NCDOT have generously made their manuals available for other states to copy and use. Virginia DOT is starting to develop standard operating procedures for environmental practice in maintenance operations. Maryland SHA is working on an Environmental Maintenance manual as well. Neither of the latter were developed to the point that they were available for use in drafting this document.

Oregon DOT's Routine Road Maintenance Water Quality & Habitat BMP Guide, Minnesota's Best Practices Handbook on Roadside Vegetation, Washington State DOT's Best Practices Handbook on Roadside Vegetation, Caltrans Storm Quality Practice Guidelines, MDT's Erosion and Sediment Control Best Practices, New Hampshire DOT's Handbook of Best Management Practices for Routine Roadway Maintenance, and the Transportation Association of Canada's Syntheses of Best Practices in Road Salt Management all cover narrower sets of BMPs. These compilations were primary sources for best practices in the wider compendium of DOT environmental stewardship practice.

Overviews of a selection of these manuals follows:

New York State DOT Environmental Handbook for Transportation Operations

NYSDOT's Environmental Handbook for Transportation Operations was developed to provide NYSDOT personnel with general awareness of and guidance on the primary requirements that apply to the types of activities conducted by NYSDOT Operations, to further adherence to NYSDOT stewardship commitments. It was published in 2001 and reviews typical issues operations and maintenance staff may encounter, as well as other issues that may require more assistance from Landscape Architects or Environmental Specialists and Coordinators. The manual covers work in the right-of-way and especially sensitive environments therein, as well as facility-based activities conducted at a residency or shop. With the exception of sensitive environments, the manual presents environmental requirements and considerations in the context of the operation or type of facility or equipment most affected by the issue. NYSDOT's Environmental Handbook for Transportation Operations is available on-line.

Mass Highway 's Facility Environmental Handbook

Mass Highway published a Facility Environmental Handbook to provide guidance on conducting operations in compliance with environmental requirements, containing standard operating procedures and maps to identify structures and environmentally sensitive areas such as wetlands. The handbook is used to train Mass Highway personnel on an annual basis. The department also has an EMS manual, associated operating procedures, and an EMS 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). Mass Highway's Standard Operating Procedures reference these roles and responsibilities.

North Carolina DOT BMPs for Construction and Maintenance Activities

Published in 2003, NCDOT's BMP manual for construction and maintenance activities focuses on activities that impact water quality and waters of the state, and practices to avoid or minimize those impacts during normal construction, maintenance, and emergency repair situations. The Project Planning and Preconstruction section describes the actions that should be performed prior to any construction or maintenance activities. The General Project Construction Practices/Operations section provides an overview and general guidance for field personnel/contractor to be applied to all projects and activities within or adjacent to jurisdictional areas. Specific construction practices are identified and guidance provided so the project can be completed in an environmentally responsible manner. This section also identifies appropriate BMPs, provides a general overview of the construction sequence as it relates to protecting jurisdictional areas, and highlights specific conditions that must be followed in order to be in compliance with NCDOT Environmental Stewardship Policy, as well as State and Federal regulations. The last section of the manual includes activity-specific information for each individual BMP such as where the practice is and is not applicable, construction standards, maintenance requirements, and typical problems. Some of the BMPs identify the appropriate NCDOT standard and specification for proper construction. While providing guidance to construction crews when working within and adjacent to jurisdictional areas, the manual aims to provide flexibility to the crews to choose which method is suitable for each given situation. The NCDOT Best Management Practices Manual for Construction & Maintenance is available on-line.

Oregon DOT Right-of-Way BMP Manual

The Oregon Department of Transportation (ODOT) first developed a program to minimize impacts to water quality from routine road maintenance activities in January 1995. A team of maintenance managers, field staff, and environmental staff reviewed maintenance activity for potential impacts to water quality and developed best management practices (BMPs) to minimize those impacts. The review was documented in the Oregon Department of Transportation Maintenance Management System Water Quality Guide and submitted to the Oregon Department of Environmental Quality (DEQ) as part of the ODOT National Pollutant Discharge Elimination System (NPDES) Municipal Separated Storm Sewer System (MS4) permit requirements under the Clean Water Act.

In 1997, a similar team reviewed maintenance activities for impacts to habitat, with an emphasis on habitat and fishery resources that are listed as threatened or endangered under the Federal Endangered Species Act. This review was documented in the Oregon Department of Transportation Maintenance Management System Water Quality and Habitat Guide: Best Management Practices, June 1997. The 1997 document served as the foundation for a Programmatic Biological Assessment on certain ODOT road routine maintenance activities that evolved into an updated manual in 1999 with more thorough descriptions of an extensive list of routine maintenance activities and accompanying minimization/avoidance actions, ODOT's training program for routine maintenance and environmental considerations, letters of commitment from the agency directors, relevant references or examples, and description of the process for review, documentation and monitoring implementation and effectiveness of maintenance actions. In addition, the manual includes appendices on:

  • Guidelines for maintaining water quality in snow & ice operations
  • Guidelines & criteria for stream-road crossings
  • Guidelines for timing of in-water work to protect fish & wildlife resources
  • Guidance for maintenance activities in wetland ditches
  • Guidelines for bridge washing
  • Guidance for emergency highway repair

ODOT is now in the process of updating the Manual and the accompanying 4(d) rule with NOAA Fisheries and the Corps. ODOT's BMP manual is available online.

Standards & Measures for Implementing Environmental Programs & Process Improvements: ISO 14001 Practices

As with other aspects of an overall environmental management system, international standards provide a guideline. ISO 14001 Section 4.3.3 says that such environmental management programs, established by an organization to achieve their objectives and targets, should include:

  • Designation of responsibility for achieving objectives and targets at each relevant function and level of the organization.
  • The means and time-frame by which they are to be achieved.
  • A defined period of time between audits of how the system or program is functioning.
  • A process for ensuring that new developments and new or modified activities, products or services, program(s) are covered and the plan/program amended.

Thus an EMS auditor would look for the following in evaluating implementation of environmental programs:

  • Awareness of roles and responsibilities for achieving objectives and targets.
  • Progress on each environmental management program.
  • Adequate resources to achieve objectives and targets.
  • Appropriate changes to environmental management programs as changes occur within the organization.
Communications

Suggested standards with regard to communications regarding setting environmental priorities and setting and implementing an environmental management system include the following (ISO 14001, section 4.4.3), which DOTs may want to consider as suggestions for non-EMS certified environmental management systems:

  • The organization shall establish and maintain procedures for (and be able to evidence):

Internal communication between the various levels and functions of the organization.

Receiving, documenting and responding to relevant communication from external interested parties.

  • The organization shall consider processes for external communication on its significant environmental aspects and record its decisions.
Documentation

Organizations which develop environmental management systems and programs should establish and maintain information, in paper or electronic form to describe the core elements of the management system and their interaction and to provide direction to related documentation. State DOTs developing formal environmental management systems often develop an EMS manual and a list of EMS documents and referenced procedures. Though this is not a requirement of the international standard (ISO 14001, section 4.4.4), it helps prove to regulators and auditors that the system is indeed in place.

Documentation is considered to occur at several levels:

  • Level 1: Policy
  • Level 2: Procedures - who, what, when, where (4.4.6(a), 4.5.1) and other documents
  • Level 3: Optional Job Instructions - Describes how tasks and specific activities are done
  • Level 4: Other documents prompting recording of evidence of conformity/compliance to requirements (See Records: 4.5.3)

Records, a Level 4 form of documentation, include training records, calibration checks and the results of audits and reviews. ISO 14001 requires certified organizations to establish and maintain procedures for the identification, maintenance and disposition of environmental records, so that

  • Environmental records shall be legible, identifiable and traceable to the activity, product or service involved.
  • Environmental records shall be stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration or loss, (e.g. back-up systems).
  • Retention times shall be established and recorded (e.g. a record retention schedule).

Overall, the extent of documentation an organization chooses to undertake should depend on:

  • Size and type of organization
  • Complexity of products and processes
  • Customer and regulatory requirements
  • Industry standards and codes
  • Education, experience, and training
  • Workforce stability - a very stable workforce may require less documentation of procedures, etc.
  • Past environmental problems
Document Control

As managers of very large quantities of documents, whether required by federal law or necessary for design, construction, and maintenance, DOTs face the challenge of document control. International standards for document control, as enunciated in ISO 14001 section 4.4.5 require that the organization shall establish and maintain procedures for controlling all documents required by this International Standard to ensure that:

  • They can be located.
  • They are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel.
  • The current versions of relevant documents are available at all locations where operations essential to their effective functioning of the environmental management system are performed.

Obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use.

Any obsolete documents retained for legal and/or knowledge of preservation purposes are suitably identified.

  • Documentation shall be legible, dated (with title, document #, dates of revision) and readily identifiable, maintained in an orderly manner and retained for a specified period.
  • Procedures and responsibilities shall be established and maintained concerning the creation and modification of the various types of document.

Thus an EMS auditor will look for periodic review of documents, availability and accessibility of documents, document control methods for electronic and hard-copy documents, and responsibilities and authorities for creating and modifying documents.

To date, most DOT document control initiatives have focused on NEPA documents and the project development process. Pertaining to construction and maintenance, several states have begun efforts to document and ensure communication of and follow up on environmental commitments that have been made, through NEPA and other environmental approval and permitting processes. These stewardship practices are described further under section 2.2, Setting Objectives and Targets & Tracking Environmental Commitments.

 

2.5.2 Standards for Evaluating Procedures
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For an environmental management system organization-wide or in a specific area of the organization, an auditor for ISO 14001 (section 4.4.6) would look for:

  • Evidence that operations/activities linked to significant aspects have been identified
  • Appropriate documented procedures and work instructions related to significant activities, products, services
  • Applicable communication with suppliers and contractors pertaining to significant aspects

Standards and Measures for Emergency Preparedness and Response Procedures

DOTs and other organizations are required to establish and maintain procedures to identify potential for and respond to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them. Spill prevention and control is the most common emergency preparedness and response requirement.

ISO 14001 sets standards for emergency preparedness and response (section 4.4.7) as follows:

  • The organization shall review and revise, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations
  • The organization shall also periodically test such procedures where practicable.

An EMS auditor would utilize measures such as those that follow to assess the adequacy of emergency preparedness and response:

  • Plans and procedures for potential or actual accidents and emergencies
  • Review and revision (if necessary) of emergency procedures following an incident
  • Evidence that emergency procedures are periodically tested (if practicable)
  • Appropriate training of personnel involved in emergency preparedness and response

FHWA and AASHTO On-Line Clearinghouse for DOT Specifications

FHWA and AASTHO have established an online clearinghouse and electronic library where users can search, review, cross-reference and download current specifications, supplements and related documents from all 50 states, the District of Columbia and Puerto Rico.

DOTs can search any - or all - of the states (and AASHTO) for specifications in main categories or search across all documents for key words included in a specification. Main categories include: Grading, Pavements, Structures, Materials, Traffic control, and Surveying. Links are also provided to transportation related ASTM specifications. An Innovative and Emerging Specifications category can be searched for states specs and background information on design-build, performance related, quality assurance and warranty.

 

2.5.3 Construction and Maintenance Decision Support Systems
 

The utility of Environmental Information Management and Decision Support Systems (EIM&DSS) rests on the existence of well-designed business processes that agencies develop to meet the environmental goals they set. EIM&DSS software provides the technical tools that transportation planners and managers need to make better environmental decisions in the process of doing a DOT's work. Environmental information and decision support systems require data about the environment in which a DOT is operating (environmental requirements and areas requiring special management), and criteria or decision points associated with the various construction or maintenance activities a DOT undertakes.

Decision support systems in maintenance address both the roadway and the roadside. Roadway concerns can be categorized by season. During good weather and/or the construction season, pavement maintenance is the dominant on-road concern; to this end, some states have evolved sophisticated pavement management systems to focus limited maintenance dollars to achieve the maximum system preservation and pavement smoothness. Winter decision support systems have centered around Roadway Weather Information Systems (RWIS) to help guide decisionmaking regarding snow and ice removal and prevention, and accompanying chemical applications. ROW management is in the initial stages of exploration with regard to management via an EIM&DSS.

Environmental Information Management and Decision Support Systems are already in place at many DOTs to support pavement and/or bridge management. Now Environmental Information Management and Decision Support (EIM&DSS) are being developed for other key aspects of construction and maintenance. Practice areas and some of the leaders in the field are noted below:

Roadkill Data and Habitat Linkage Area Assessment, with Feedback to Design

  • In a collaborative effort with the Vermont Department of Fish and Wildlife, VTrans is sponsoring the development of a GIS level habitat database, called the Habitat Linkage Area Assessment, which will be used for making decisions for addressing habitat connectivity on VTrans projects. It will serve as a tool for the two agencies to identify priority areas for consideration for habitat connectivity. The assessment uses landscape features as its base and is augmented by years of existing data collected with regard to wildlife crossing areas, recorded road kill locations, anecdotal reports of crossing areas, land ownership, conservation lands, and other layers of data. The database identifies areas that range from high priority to low priority in terms of habitat and overlays the Vermont transportation infrastructure over this information. The interface of the transportation system and the habitat data, in turn, identifies critical linkage areas for further action. The Habitat Linkage Assessment utilizes the Roadkill Data Collection effort described below.
  • VTrans Operations and Maintenance division in collaboration with the Environmental Section and the Vermont Department of Fish and Wildlife (VT DF&W) have developed a method for collecting road kill information from District Maintenance Crews. The method utilizes an existing database that the Maintenance and Operation Division uses to manage their resources. The Operations Division identified an unused field and modified it, with the guidance of VT DF&W, as a field for recording roadkill data. The Maintenance field crews keep a log in their trucks. When they identify a road kill that is included as a target species in the database they record the species, location/mile marker, date, and route. These data sheets are collected on a monthly basis and then entered into the database. This information is shared with the VT DF&W and is included as a field in the Habitat Linkage Assessment described above.

Maintenance Facilities Management and Auditing

  • Texas DOT is undertaking Pollution Prevention Audits of facilities.
  • Maine DOT has developed an EMS for all maintenance facilities, associated procedure manuals, and audits of all facilities. One-third of all facilities get audited annually and all facilities are audited within a three-year period.
  • Mass Highway's EMS focuses on hazardous materials and hazardous waste management underground storage tanks, wetlands, water quality, and solid waste. Management System Improvement and Implementation plans are in place for all areas.

Stormwater Facility Evaluation and Prioritization of Improvements

  • MDSHA has developed a thorough and duplicable grade-based rating system for stormwater management facilities and has developed an inventory, database, and photo record of all facilities statewide and their maintenance status. Under the rating system, those graded A or B are considered functionally adequate. As of late 2003, between 73 and 75 percent of MDSHA stormwater were functionally adequate (A=everything fine, working fine, no maintenance required, B= minor maintenance, need mowing or trash removal), leaving approximately 25 percent needing maintenance or retrofitting to achieve functional requirements. MDSHA aims to have 80 percent or more of MDSHA stormwater management facilities rated functionally adequate by 2006, and 95 percent of facilities by 2010.

Culvert and Fish Passage Evaluation and Prioritization of Improvements

  • Oregon and Washington DOTs have worked with their state resource agencies to survey culverts statewide and develop systems to identify and prioritize those that need improvement.

Selection of Appropriate Environmental Measures

  • NCHRP 25-25(01) is developing a decision support system for selection of water quality control best management practices (BMPs).
  • NCHRP 25-27 and current projects underway by the Western Transportation Institute will develop decision support systems for selecting wildlife passage measures.
  • NCHRP 24-19 is developing a decision support system for selecting environmentally sensitive bank and erosion control (bioengineering) measures.

Field Compliance Management

  • Maryland State Highway Administration tracks NEPA document mitigation and project commitments at the 30 percent, 65 percent, and 90 percent design completion stage or when major design modifications are proposed.
  • For large and environmentally controversial projects such as the Woodrow Wilson Bridge, MDSHA has developed a comprehensive tracking system database using Microsoft Access to track 1200+ ROD commitments and permit special conditions. A 1:400 scale map/plan was developed for each contract depicting permitted impacts. Tracking reports from the database are created for each of 24 construction contracts and compliance is documented in concert with daily compliance inspections. A final compliance tracking report is produced at the close of each contract, complete with a narrative. As part of the final report, MDSHA will show the as-built version of the impacts and compare those to the permitted impacts. The system has also enabled MDSHA to show reductions from anticipated permanent impacts to the environment, due to careful management and minimization efforts throughout each contract. MDSHA is working to create a less labor intensive, statewide system for all NEPA EA and EIS projects.
  • To achieve their stewardship planning goal of 100 percent compliance with erosion and sedimentation control requirements on all MDSHA construction projects, MDSHA is seeking to raise the bar on its past performance measure of ratings of B or better on 90 percent of construction projects annually to achievement of 100 percent compliance in construction. In addition to tracking performance on all construction projects, Maryland is considering certification and recertification of inspectors, contractors, and designers. Certification would require refresher courses and certification that could be lost for poor performance.

Roadside Vegetation Management

  • Washington State DOT has a Maintenance Accountability Process and measures performance of both road and roadside maintenance activities.
  • WSDOT also has a system for evaluating, monitoring, and addressing Slope Failures and Chronic Environmental Deficiencies in the ROW.
  • Oregon DOT has surveyed all state roadsides for environmentally sensitive areas and incorporated that information in a GIS and activity maps for maintenance which indicate what activities are allowed and limitations in place where maintenance activities occur.
  • MDSHA and other DOTs are tracking reductions in infestations of noxious weeds, to meet reduction goals.

Winter Operations

Road Weather Information Systems are being tied to increasingly finely tuned anti-icing and salt application strategies. In turn, such systems are being connected to vehicle Geographic Positioning Systems, materials usage, and labor management.

 

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Table of Contents
 
Chapter 2
Organizational Environmental Stewardship Practices
2.1 DOT Environmental Policies and Mission Statements
2.2 Environmental Strategic Planning at Transportation Agencies
2.3 Setting Objectives and Targets & Tracking Environmental Commitments
2.4 Environmental Management Systems - Benefits & Approaches
2.5 Operational Controls, Procedures, and Practices
2.6 Measuring Environmental Performance
2.7 Environmental Staffing, Roles, and Responsibilities
2.8 Environmental Training and Certification
2.9 Regional DOT Stewardship Practice Exchange & Discussion
   
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