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Chapter 6
Maintenance Facilities Management
6.1. Planning and Prioritizing Environmental Improvements at Maintenance Facilities

Facilities management encompasses a broad range of activities, including:

  • Storage, repair, and maintenance of vehicles, equipment, and related support materials
  • Fueling and washing of vehicles and equipment
  • Maintenance of buildings, stormwater drainage systems and landscaping
  • Storage of sand, salt, asphalt, rock, and pesticides
  • Storage of wastes generated on site
  • Bulk storage of sediment, litter and debris generated by road maintenance activities

Environmental stewardship in the course of these activities requires both structural and non-structural management practices. Examples of non-structural practices include procedures for performing operational activities, such as salt/sand mixing/loading that requires removal of all salt from the area surface after loading. The installation of a physical device that alters the release, transport, or discharge of pollutants from surface storm or melt water or facility-generated shop floor drain or washbay effluent is a structural practice.

Many environmental stewardship practices at maintenance facilities have to do with protection of water quality. EPA regulations have long required facilities to obtain National Pollution Discharge Elimination System (NPDES) permits for discharges, especially washbay and shop floor drain effluent discharges to the waters of the State. Such permit obligations arise under the Industrial Permitting portion of NPDES, and have received increased attention as state regulatory agencies have expanded beyond their initial focus on manufacturing facilities in implementation of this program. Brief summaries of federal water quality and wetlands requirements applicable to the transportation community are available at Center for Environmental Excellence by AASHTO.


6.1.1 Maintenance Facility Pollution Prevention Plans
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Facility Pollution Prevention Plans (FPPP) are typically developed for each maintenance facility owned or operated by a DOT. The FPPPs describe the activities conducted at the facility and the management practices to be implemented to reduce the discharge of pollutants in stormwater runoff from these facilities. The following practices are recommended:

  • District Maintenance Director or Environmental Personnel should be responsible for ensuring that Facility Pollution Prevention Plans (FPPPs) are developed for each maintenance facility.
  • The FPPPs should identify the work activities at each facility along with the corresponding BMPs that should be implemented.
  • Supervisors should inspect their maintenance facilities monthly to monitor the implementation and adequacy of the BMPs.
  • A report that includes the date of the inspection, the name of the inspector, observations, and recommended corrective actions should be prepared by the Supervisor.
  • All inspection records should be maintained for a period of 3 years. Any observed instances of non-compliance should be reported to the Stormwater Coordinator.
  • In addition to monthly facility inspections conducted by the facility supervisor, the more in depth review should occur in at least 20 percent of each District's facilities each year.
  • These reviews should monitor each facility's documentation (e.g., FPPP, monthly inspection reports, etc.) and include a thorough yard inspection.
  • Each District Maintenance Stormwater Coordinator should prepare a report including the date of the inspection, name(s) of the inspector, observations, and recommended corrective actions.
  • All FPPP records should be maintained for a period of 3 years by the Maintenance Supervisor.
  • Any observed instances of noncompliance should be reported in accordance with procedures.
  • In addition to inspections conducted by the facility supervisors DOTs may employ an audit program or other supplementary compliance monitoring to support continual improvement.


6.1.2 Environmental Information & Management Systems for Maintenance Facilities
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Environmental management systems are increasingly used by state DOTs to avoid generation of pollution and manage operations for continual environmental improvement. Examples follow, some of which are described in greater detail in sections 2.5, Measuring Environmental Performance and 2.6, Environmental Staffing, Roles, and Responsibilities. Short of an EMS , a number of DOTs conduct surveys of all maintenance facilities to establish compliance with federal, state and local environmental regulations. Missouri DOT's survey is included in the Appendix.

Maine DOT's EMS for Facilities
Maine DOT has developed and implemented Environmental Management Systems for all MDOT facilities. Combined Environmental and Office of Health and Safety Administration (OSHA) policy and procedure manuals are targeted to the managers who have responsibility for implementation. Quick reference environmental practice guides-written as a companion guide to the policies and procedures-were developed for supervisors and field crews.

MDOT's commitment to conduct annual audits of its facilities to systematically review the effectiveness of these policies and procedures has been an important aspect of implementing new environmental procedures. An Environmental Management Committee is responsible for tracking and timely closure of audit findings and development of a database of Corrective Action Reports. MDOT's audit program and performance measures are discussed in the respective sections of this report.

Massachusetts Highway 's EMS for Facilities Management
Mass Highway 's EMS for Facilities Management focuses on hazardous waste and hazardous materials, underground storage tank management, wetland and water quality protection, and solid waste management. System Improvement and Implementation plans are developed for each facility.

Mass Highway has developed an implementation manual describing organizational roles and responsibilities relative to environmental compliance management at Mass Highway facilities. Personnel within the major Organization Offices, Divisions, Districts, and Sections that affect compliance with Mass Highway environmental requirements are identified, along with associated training programs to educate staff "how to best carry out their environmental related duties."(33)

Facility Management in PennDOT District 10 Strategic Environmental Management Program (SEMP)
Maintenance District 10 developed Process Maps operations associated with each significant aspect of operations with a special focus on the District 10 Maintenance Facility, providing information to plan, conduct, assess, and complete activities according to "Plan-Do-Check-Act" framework and principles. Process Maps identify responsibilities associated with each action. For example, PennDOT staff developed Quality Assurance Evaluations for Maintenance Stockpiles and Foreman's 15-Minute Stockpile Walkarounds. PennDOT implemented procedures to enhance environmental performance, including annual calibration of spreaders before the onset of the winter services season, use of two-way radios between operators during storms to communicate information about application rates and roadway temperatures, daily electronic leak detection tests in the morning hours before the day shift at garages with corrective action if necessary to prevent leaks, and completion of a Foreman's Erosion and Sedimentation Checklist as part of planning for earth disturbance activities that require control measures. [N]

PennDOT's ISO-based SEMP plan resulted in: [N]

  • Development of information on contractor/supplier procedures and requirements related to significant aspects, which are consistent with department-wide contract terms and conditions, requirements, and procedures.
  • Establishment of procedures for emergency response and spill prevention.
  • Development of procedures, checklists, and responsibilities in monitoring and measurement activities related to significant aspects.
  • Internal development of auditing procedures for SEMP activities performed by trained staff from another district.

New Hampshire DOT's Inventory of Managed Properties
New Hampshire DOT (NHDOT) developed an IMP (Inventory of Managed Properties) to inventory hazardous materials at all of the Department's maintenance and operations facilities. NHDOT operations policy requires that all NH DOT properties be screened and all environmental concerns recorded. To address this need, NHDOT implemented a system of integrated handheld computers and web-based data management to support a contaminated property valuation policy for prospective and currently owned properties.

NHDOT's increased emphasis on inventory and risk management of all properties potentially impacted by a project or currently owned by the state greatly increased the volume of hazmat data being collected and managed. It also placed more emphasis on early detection. A robust site screening protocol was developed to collect preliminary field observations of hazmat sources and receptors. To support the protocol, the field data collection application was developed for use on personal digital assistants (PDAs). The PDA software standardizes site-screening data, improves data completeness and quality, and reduces time delays from fieldwork to data reporting. Since digital photographs and GPS data are captured using integrated hardware, and are stored directly to the database upon collection, there is no sorting, labeling, and management of this information following field work. The database is dynamically linked to the Bureau of Right-of-Way, ensuring that property information is kept accurate and redundancy of data is eliminated. Functionality built into the graphic user interface on the web calculates "risk scores" for each property and prioritizes all of the sites within a corridor, flagging key hazmat issues. The developed technology provides the NHDOT with better and faster data from the initial phases of a project; the ability to "triage" sites based on their calculated risk rankings and flags; and the capability to manage contaminated sites from identification through remediation within the web application. IMP also allowed NHDOT to easily communicate with the state's Department of Environmental Services (NHDES). Minor incidents do not need to be reported directly to the department, as long as the occurrence is posted on the database, eliminating several sets of paperwork, which would normally need to be prepared for both NHDOT and NHDES.

This new technology has reduced the time spent on site, and standardized data collection and reporting performed by consultants. Currently, IMP is used solely in the documentation of hazardous waste inventories, remediation and issues for each of the DOT maintenance facilities throughout the state; however, it will soon be used to document stormwater management and cultural resource issues at all DOT owned sites. In conjunction with IMP, NHDOT also developed a Risk Assessment for Site Contamination and Appraisal of Lands (RASCAL). Though developed primarily for project development and right-of-way purposes, it is also used by construction personnel to determine the status of hazardous materials cleanup at construction sites.

 

6.1.3 Facility Siting and Prioritization of Environmental Improvements
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Facility Siting Considerations
Currently, future sites for DOT facilities are usually selected based on cost of land acquisition and operational convenience. Some facility sites have been acquired through "swapping" an existing DOT site for a more desirable parcel. Environmental factors are often not considered and evaluated, unless a procedure specifying such consideration is in place and/or information has been made readily available or a study has been performed.

Information on existing DOT maintenance facilities is needed to allow identification and ranking of sites that are the most environmentally sensitive, to decide which sites to address first. Such information enables DOTs to:

  • Prioritize sites that should be closed or relocated based on environmental concerns, as funds become available or on a more pressing basis.
  • Identify facilities that require pollution control devices, such as oil/water separators or implementation of other environmental stewardship practices, and those that need to implement stormwater runoff controls.
  • Identify environmentally appropriate locations for new facilities , including newly-designed salt storage buildings.
  • Develop and implement appropriate decommissioning policies or procedures . Many DOT maintenance facilities are currently closed and/or relocated without a decommissioning policy or procedures. This can result in abandoned areas of actual or potential contamination and/or the transfer of hazardous and non-hazardous chemicals and wastes to other DOT facilities without advanced planning and, sometimes, without advance notification.

Environmental Data Needed for Evaluation in Facility Siting
Consideration of the following widely available environmental data is recommended in considering facility siting and future changes that may be needed to improve environmental stewardship. Most of this data is available from state environmental quality or natural resource agencies, or a federal agency if noted: [N]

  • Well log data
  • Soil borings
  • Surface water intakes and wellhead protection areas for public drinking water systems
  • High-volume groundwater users
  • Spill, Superfund, Leaking Underground Storage Tank and other contaminated sites locations of groundwater aquifers and surface water bodies (EPA)
  • Environmentally sensitive areas (e.g., parks, wetlands, reserves) ( DNR , U.S. Department of Interior , U.S. Department of Agriculture). Criteria used by INDOT for identifying "sensitive waters" include those waters: [N]
    • Providing habitat for species of concern; i.e. having state or federal designations of endangered, threatened, rare, extirpated or on a "watch list" identified by generic descriptor (mammal, etc.) or heritage species code.
    • Used as a public surface water supply intake; i.e. maintenance facilities are within 1,000 feet, 3,000 feet or one mile of a public water intake.
    • Used for public recreation; i.e. within a mile of such a recreation area and not connected to a POTW.
    • Classified as outstanding state resource waters or high quality waters
  • Groundwater aquifers and surface water bodies (U.S. Geological Service)
  • Locations of urban wet-weather and rural (agricultural) drainage patterns (U.S. Department of Agriculture - Natural Resources Conservation Service)

For maintenance facilities that are captured under the Municipal Separate Storm Sewer System (MS4) portion of the NPDES program, the DOT is required to assess the water quality of known receiving waters and stormwater outfall discharges and known sensitive areas, and to identify those places having a reasonable potential for causing stormwater problems. In case of the latter, DOTs are expected to implement control measures and conduct operations in ways that will reduce contamination of stormwater discharges. As a result, it is important to:

  • Identify facilities that are not currently connected to a Publicly Owned Treatment Works (POTW)
  • Attempt to connect to a POTW when new sites are developed.

Criteria for Prioritizing Attention to Maintenance Facilities
Utilizing data such as that discussed above, criteria can be developed to identify maintenance facilities that should receive priority attention. INDOT utilized the following criteria that are applicable to other states, to identify those that provide the greatest potential risk to the environment from stormwater discharge, locations both within and outside MS4 areas: [N]

  1. Maintenance facility locations within designated MS4 areas.
  2. Maintenance facility locations within 3,000 feet of a community public well.
  3. Maintenance facility locations within (1,000 feet) (3,000 feet) (5,280 feet) of a public surface water intake.
  4. Maintenance facility locations within one mile of high quality and exceptional use waters.
  5. Maintenance facility locations within one mile of federal, state, county, municipal or township recreation facility having a lake, pond, river, or stream.
  6. Maintenance facility locations within 3,000 feet of groundwater that is highly vulnerable and very highly vulnerable to contamination by nitrates (as surrogate for chloride).
  7. Maintenance facilities within 3,000 feet of a natural area containing Rare, Threatened, or Endangered species.
  8. Maintenance facilities within one mile of the "best remaining examples of natural wetland communities," as determined by IDNR.

 

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Table of Contents
 
Chapter 6
Maintenance Facilities Management
6.1 Planning and Prioritizing Environmental Improvements at Maintenance Facilities
6.2 Facility Housekeeping Practices
6.3 Yard and Floor Drain Management
6.4 Energy Conservation
6.5 Under and Above-Ground Storage Tanks
   
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