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 |
|
| < back to top >
|
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 |
|
| < back to top >
|
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 |
|
| < back to top >
|
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 s pecies 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]
- Maintenance facility locations within designated
MS4 areas.
- Maintenance facility locations within 3,000 feet
of a community public well.
- Maintenance facility locations within (1,000 feet)
(3,000 feet) (5,280 feet) of a public surface water
intake.
- Maintenance facility locations within one mile
of high quality and exceptional use waters.
- Maintenance facility locations within one mile
of federal, state, county, municipal or township recreation
facility having a lake, pond, river, or stream.
- 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).
- Maintenance facilities within 3,000 feet of a natural
area containing Rare, Threatened, or Endangered species.
- Maintenance facilities within one mile of the "best
remaining examples of natural wetland communities," as
determined by IDNR.
|
| < back to top >
|
| |
| Continue
to Section 6.2 » |
| |
|
