ISO 14001:2004, International and American Environmental ... · ISO 14001:2004, International and...

***IN PRINTED FORM, THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT CREATED ON 6/19/2007. THE MOST CURRENT VERSION OF THIS DOCUMENT CAN BE FOUND AT www.wmataems.com. ***

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ENVIRONMENTAL

MANAGEMENT SYSTEM PROCEDURES MANUAL ISO 14001:2004, International and

American Environmental Management System Specification

WASHINGTON METROPOLITAN

AREA TRANSIT AUTHORITY SHADY GROVE RAIL MAINTENANCE FACILITY

15903 SOMERVILLE DRIVE ROCKVILLE, MD 20855-2213

June 19, 2007

Final Shady Grove EMS Manual 6-18-07.doc


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TABLE OF CONTENTS Section Page

1. PURPOSE............................................................................................................................1

2. SCOPE .................................................................................................................................1

3. DEFINITIONS.....................................................................................................................1

4. ENVIRONMENTAL POLICY............................................................................................1

5. ENVIRONMENTAL ASPECTS.........................................................................................1

6. LEGAL AND OTHER REQUIREMENTS.........................................................................1

7. OBJECTIVES, TARGETS, AND PROGRAMS ................................................................1

8. RESOURCES, ROLES, RESPONSIBILITY, AND AUTHORITY ...................................1

9. COMPETENCE, TRAINING, AND AWARENESS..........................................................1

10. COMMUNICATION...........................................................................................................1

11. DOCUMENTATION...........................................................................................................1

12. CONTROL OF DOCUMENTS...........................................................................................1

13. OPERATIONAL CONTROL..............................................................................................1

14. EMERGENCY PREPAREDNESS AND RESPONSE.......................................................1

15. MONITORING AND MEASUREMENT...........................................................................1

16. EVALUATION OF COMPLIANCE...................................................................................1

17. NONCONFORMITY, CORRECTIVE AND PREVENTIVE ACTION ............................1

18. CONTROL OF RECORDS .................................................................................................1

19. INTERNAL AUDIT ............................................................................................................1

20. MANAGEMENT REVIEW ................................................................................................1



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ENVIRONMENTAL MANAGEMENT SYSTEM PROCEDURES MANUAL 1. PURPOSE The Washington Metropolitan Area Transit Authority (WMATA) has implemented, is maintaining and continually improving an environmental management system (EMS) at the Shady Grove Rail Maintenance Facility (hereafter, Shady Grove). The EMS is based on the environmental management requirements of ISO 14001:2004, International and American Environmental Management System Specification. This Environmental Management System Procedures Manual (EMS Procedures Manual) describes the facility-wide implementation of the main elements of the EMS and provides direction to related WMATA-wide documentation, such as the Environmental Handbook for ECOs, DCOs and other Supervisors, to which Shady Grove subscribes. 2. SCOPE The Washington Metropolitan Area Transit Authority operates the second largest rail transit system and the fifth largest bus network in the United States. Safe, clean and reliable, “America’s Transit System” transports more than a third of the federal government to work and millions of tourists to the landmarks in the Nation’s Capital. The Authority was created in 1967 and construction of the Metrorail system began in 1969. The first phase of Metrorail began operation in 1976. The final leg of the original 103-mile rail network was completed in early 2001. Today there are 86 Metro stations in service within a 106.3 mile network. The Shady Grove extension of the red line was opened in December 1984. The Shady Grove Rail Yard serves as the terminal maintenance facility for the red line. The Shady Grove Rail Yard is located at 15903 Somerville Road in Rockville, Montgomery County, Maryland, between Redland and Shady Grove Roads. The Shady Grove Rail Yard presently serves as a maintenance, housing, and dispatch center for Metrorail trains, having been used in this capacity since its inception. The rail yard houses approximately 160 cars, of which 132 cars must be made available for daily use. The Shady Grove Rail Yard consists of the following six buildings: the Service and Inspection Shop; the Plant Maintenance Field Base; the Traction Power Substation Building; two Tie Breaker Buildings; and the Yard Operations Building. The facility also contains parking and inspection areas for the rail cars and outdoor parking lots for employees and WMATA non-revenue vehicles. The general topography of the Shady Grove Rail Yard is characterized by gently rolling land. The elevation of the facility ranges from 450 to 475 feet above mean sea level (msl). The nearest surface water body is Crabbs Branch Creek, which ultimately drains to Rock Creek. Stormwater runoff from the Shady Grove Rail Yard parking and outdoor areas flows to the storm sewer, and discharges through a culvert located at the east end of the facility into Crabbs Branch Creek. The water then flows eastward through two Montgomery County Stormwater Ponds, which ultimately discharge to Rock Creek.



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The nature of the activities at the facility require the use of hazardous materials requiring proper management that includes storage, transport and the permitting of air, stormwater and wastewater discharges. The storage and use of these hazardous materials requires the facility to maintain emergency response capabilities in the event of an environmental incident. The scope of the EMS implementation currently (2007) covers the activities, products, and services occurring at Shady Grove Rail Yard and conforming to the requirements of ISO 14001: 2004. 3. DEFINITIONS The following terms are used throughout this manual and are defined as follows: AGM, SSEM and Executive Leadership Team � �those persons who, of their own authority, can carry out the responsibilities of �top management� as specified in ISO 14001.� Auditor � �person with the competence to conduct an audit.� Contingency Plan - A facility-specific, combined Hazardous Waste Contingency Plan (HWCP), Spill Prevention Control and Countermeasures Plan (SPCCP) and Stormwater Pollution Prevention Plan (SPPP) that is prepared and implemented with full approval of WMATA consistent with Federal, state and local environmental regulations. Continual Improvement � �recurring process of enhancing the EMS in order to achieve improvements in overall environmental performance consistent with the organization�s environmental policy.� Adapted from ISO 14001:2004 Contracting Officer - WMATA-assigned contracts expert overseeing the proper execution of the administrative portions of a contract between WMATA and a third party. Corrective Action – “action to eliminate the cause of a detected nonconformity.” Deputy Compliance Officer (DCO) � Shady Grove Supervisor assigned by the ECO in support of EMS implementation. Responsible for overall environmental compliance to applicable regulations as well as ISO 14001:2004 requirements, in accordance with the EMS Procedures Manual and ECO Handbook. Document - Information and its supporting medium. Documents are typically living (i.e., subject to change through review). EMIH – WMATA Office of Environmental Management and Industrial Hygiene, Department of Safety, Security and Emergency Management (SSEM)



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EMP Matrix - The Environmental Management Program (EMP) matrix is a tool used to track the schedules, resources, and responsibilities for achieving objectives and targets. Environment � �surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation. NOTE � Surroundings in this context extend from within an organization to the global system.� Environmental Aspect � �element of an organization�s activities or products or services that can interact with the environment. Note � A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact.� Environmental Compliance Officer (ECO) � Shady Grove Superintendent assigned by the Department Head in support of EMS implementation. Responsible for overall environmental compliance to applicable regulations as well as ISO 14001:2004 requirements, in accordance with the EMS Procedures Manual and ECO Handbook. The ECO is typically, but not exclusively, the Superintendent. Environmental Impact � �any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization�s environmental aspects.� Environmental Management System (EMS) � �part of the WMATA�s overall management system used to develop and implement its environmental policy and manage its environmental aspects. NOTE 1 � A management system is a set of interrelated elements used to establish policy and objectives and to achieve those objectives. NOTE 2 � A management system includes organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources.� Adapted from ISO 14001:2004, �3.8. Environmental Objective – “overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve”. EMS Procedures Manual – This document. EMS Procedures (EPs) – Individual sections of this document (e.g., Competence, Training and Awareness). Environmental Performance – “measurable results of an organization’s management of its environmental aspects”. Environmental Policy � �policy defined by [WMATA�s Executive Leadership] (i.e., top management) establishing a framework for the EMS and expressing management�s intentions toward WMATA�s environmental performance.�



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Environmental Protection Oversight Administrator (EPOA) � Assigned to the Office of Environmental Management and Industrial Hygiene, Department of Safety, Security and Emergency Management (EMIH/SSEM), responsible for legal requirements and auditing. Environmental Standards of Practice (ESOPs) – ESOPs are work practices (operational controls) incorporated as part of the EMS in the ECO/DCO manual. ESOPs ensure that operations and activities are carried out consistent with the Environmental Policy, objectives, and targets. ESOPs provide guidance on how to conduct specific tasks or perform certain duties that are related to significant aspects. Environmental Target - “detailed performance requirement, applicable to the organization or parts thereof, that arises form the environmental objectives and that needs to be set and met in order to achieve those objectives”. Executive Leadership Team � The General Manager and his/her direct reports (e.g., “Top Management”). EMS Team � Internal WMATA committee responsible for assisting the EMS Management Representative (Manager, EMIH) in establishing and implementing the EMS and ensuring its conformance with ISO 14001. The EMS Management Representative is the Chair of the EMS Team that consists of the Shady Grove ECO and DCO, as well as other WMATA staff whose roles include EMS implementation responsibility. Facility – For purposes of this document, facility can mean either a physical location (e.g., the Shady Grove Rail Maintenance Facility) or a permanent presence at a physical location that is under direct control of a ECO or DCO. Interested Party ��person or group concerned with or affected by the environmental performance of an organization.� Adapted from ISO 14001:2004, �3.11. Internal Audit � “systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by he organization are fulfilled”. Management Review � �periodic review of EMS activities conducted by the Executive Leaders (i.e., top management). The Management Review considers the adequacy, effectiveness, and suitability of the EMS and directs changes to the EMS as necessary to achieve the goals for the EMS including the policy commitment to continual improvement.� Manager, EMIH � Manager, Office of Environmental Management and Industrial Hygiene, Department of Safety, Security and Emergency Management. Assigned with overall responsibility for the EMS.



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Nonconformity � �any non-fulfillment of a requirement of ISO 14001 or WMATA�s EMS including:

Adverse findings of a regulatory compliance evaluation or EMS audit; Discovery of noncompliance with an environmental law, regulation, ordinance, or other requirement; Failure to achieve environmental objectives and targets within established timeframes; Substantial nonconformity with the Environmental Policy; or Any other failure to meet the requirements of the EMS as described in the EMS Procedures Manual.�

ODEV � Office of Organizational Development. Plans, implements, coordinates and tracks all non-operations training and development programs offered internally at WMATA. Operating Unit – Operating Unit refers to a functioning unit of WMATA that is under direct senior management supervision (e.g., ELES, TSSM) but may not necessarily be physically located at one site. Employees of operating units may provide services directly to facilities as well as to other operating units. Organization – “company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration”. �Other� Requirements � �those affiliations, endorsements, commitments, contracts, pledges, customer or government requirements, made by or on behalf of WMATA, that relate to the facility�s commitments to its stewardship of the environment.� Preventive Action � “action to eliminate the cause of a potential nonconformity”. Prevention of Pollution – “use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts”. Procedure � �specified way to carry out an activity or process. NOTE 1 � Procedures can be documented or not.� ISO 14001:2004, �3.19 NOTE 2 � In the context of this EMS Procedures Manual, a procedure is a succinct statement of a specified way to carry out an activity or process. If a procedure in and of itself does not adequately state the way to carry out an activity or process, it may be supplemented with environmental operating procedures. Project Manager – WMATA-assigned technical expert overseeing the proper execution of the technical portions of a contract between WMATA and a third party.



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Record � “document stating results achieved or providing evidence of activities performed”. Records are typically historical in nature. SSEM – WMATA Department of Safety, Security and Emergency Management. Superintendent – Top Shady Grove fence-line management person in charge of a physical location or a permanent presence at a physical location (see Operating Unit in definitions) that has direct control of their assigned operations. �working� on behalf of� � WMATA has determined that the undefined phrase used variously in ISO 14001 relating to persons working on behalf of WMATA shall apply to contractors and sub-contractors working at WMATA facilities or properties. WMATA does not include suppliers in this definition. 4. ENVIRONMENTAL POLICY

a. Statement of Policy

i. WMATA will provide the necessary resources to establish, implement, maintain and continually improve the environmental management system committed to compliance with applicable environmental laws, regulations, policies, procedures and other adopted requirements. All WMATA executives, directors, managers, supervisors and employees are accountable and have a personal and corporate responsibility to ensure that this commitment is incorporated into daily activities and functions. We will work to improve environmental performance by:

• Communicating our commitment to everyone working for or on

behalf of WMATA; • Developing and periodically evaluating environmental objectives

and targets that prevent pollution, minimize waste, improve service reliability and promote energy efficiency and cost savings;

• Reducing regional air pollution by providing public

transportation services; and, • Being responsible stewards of the environment entrusted to

WMATA by the Communities we serve.

ii. Top management has approved the posting of this Statement of Policy at Shady Grove as one method of communicating the policy to all persons



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working for or on behalf of Shady Grove, as well as communicating the policy to visiting public.

b. The Environmental Policy shall be:

i. Communicated to all persons working for or on behalf of Shady Grove

through any or all of the following methods:

(1) Provided to all new employees during new employee orientation. (2) Posted at various points around Shady Grove. (3) Made available to the public through the WMATA website

(www.wmata.com).

ii. Reviewed, revised, and documented as required by the EMS team with approval from the Executive Leadership Team and documented by the EPOA.

iii. Made available on the WMATA Intranet at www.wmataems.com .

5. ENVIRONMENTAL ASPECTS

a. Purpose

The purpose of this procedure is to describe a consistent method by which Shady Grove identifies the environmental aspects of its activities, products, and services within the EMS. The primary purpose of this procedure is to determine those activities, products, and services that can have significant impacts on the environment, and to ensure that these are considered when developing, implementing, and maintaining the EMS.

b. Procedure

i. Within each calendar year, the EMS Team shall:

(1) Identify, revise, or update the environmental aspects of Shady Grove�s activities, products, and services through informal process mapping and discussion;

(2) Through the aspect identification process, identify aspects that it can

control and determine those that Shady Grove determines can have a significant impact on the environment.



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(3) Determine the significant aspects, through discussion and consensus.

ii. During this process, the EMS Team may solicit input from the ECOs/DCOs at the annual ECO/DCO meeting.

iii. The significant aspects identified will be considered in the maintenance of the

EMS at Shady Grove, to include the selection of environmental objectives and targets.

iv. This evaluation process will be documented by the EMS team through

meeting notes and aspect ranking worksheets.

v. Environmental Aspects will be managed as aspects, significant aspects, and controlled aspects. Once a significant aspect has been managed, this aspect becomes a controlled aspect. Once a year, the controlled aspects will be evaluated by the EMS team to determine whether the aspect is still controlled. If it is determined that the aspect is not controlled, this aspect will once again become significant and be reassigned objectives and targets.

(1) The controlled aspects will be monitored through the EMP matrix.

vi. Implementation and execution of objectives and targets related to the

significant aspects will be tracked through the EMP matrix.

(1) The EMP matrix will include target date (milestones), persons responsible, and completion date.

6. LEGAL AND OTHER REQUIREMENTS

a. Purpose

The purpose of this procedure is to establish the method by which Shady Grove identifies, reviews, and ensures access to the applicable legal requirements and other requirements to which Shady Grove subscribes that are related to its significant environmental aspects and the EMS, and to determine how these requirements apply. WMATA shall maintain the mechanisms for identification and review of new or changing legal requirements applicable to its significant environmental aspects and the EMS.

b. Procedure

i. The EPOA is the primary responsible party for Legal and Other Requirements

as specified in this section.



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ii. The EPOA shall:

(1) Establish, maintain access to, and continually review and update the inventory of laws, regulations, and other requirements applicable to Shady Grove�s environmental aspects by:

(a) Maintaining a subscription to a legal regulatory update and

information service (e.g., Business and Legal Reports). (b) Maintaining access to pertinent Federal and State

environmental regulatory websites. (c) Incorporating other sources of regulatory updates (e.g.

consultant, newsletters, etc.) (2) Determine how these laws, regulations, and other requirements apply

to the significant aspects for Shady Grove through:

(a) Use of the Legal Requirements matrix to determine how the requirements apply to the significant aspects.

(3) Communicate legal and other requirements related to the significant

aspects to the EMS Team through emails and team meetings.

iii. The EMS Team shall consider the applicable legal and other requirements in establishing, implementing, and maintaining the EMS.

7. OBJECTIVES, TARGETS, AND PROGRAMS

a. Purpose

The purpose of this procedure is to describe the methods and processes by which Shady Grove establishes, reviews, and documents environmental objectives and targets affecting each relevant function and level within Shady Grove, as they relate to the significant aspects of its EMS. b. Procedure

i. Following the determination of the significant aspects, the EMS Team shall:

(1) Establish, review, update, and document environmental objectives

and targets:



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(a) For each relevant function and level within Shady Grove.

(b) Consistent with the Environmental Policy, including the commitments to pollution prevention, compliance with legal and other requirements, and continual improvement;

(c) That take into account the significant environmental aspects, the

legal, and other requirements to which Shady Grove subscribes; (c) That consider technological options, financial, operational, and

business requirements, and the views of interested parties.

(e) During this process, the EMS Team will solicit input from the ECOs/DCOs at the annual ECO/DCO meeting.

(2) Establish a program that will maintain a means for measuring

achievement of objectives and targets such as through use of an objectives and targets tracking matrix (EMP Matrix). The matrix shall include the following:

(a) Designation of responsibility for achievement at each relevant

function; and (b) The means and time frames by which they will be achieved.

ii. The EMS Team shall consider the significant aspects in establishing,

implementing, and maintaining the EMS. 8. RESOURCES, ROLES, RESPONSIBILITY, AND AUTHORITY

a. Purpose

The Roles, Responsibilities, and Authorities element of the EMS is established to ensure that the responsibilities, authorities, and accountabilities for the EMS are understood. The following subsections describe the principal roles and their associated responsibilities and authorities.

b. Procedure

Through approval of the Environmental Policy, top management has committed to providing the resources essential to establish, implement, maintain, and improve the EMS. This includes the designation of roles, responsibilities and authority to ensure



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implementation of the EMS. The following roles and responsibilities will be communicated to the affected parties:

i. Manager, Office of Environmental Management and Industrial Hygiene

(1) Authority: The Assistant General Manager, Safety, Security and

Emergency Management (AGM, SSEM) has designated the Manager, Environmental Management and Industrial Hygiene (EMIH) as responsible and accountable for establishing, implementing, maintaining, and continually improving the EMS.

(2) MANAGER, EMIH�s Responsibilities:

(a) Ensuring that the EMS conforms to the requirements of ISO

14001; (b) With the EMS Team, identifying the environmental aspects of

Shady Grove �s activities, products, and services;

(c) With the EMS Team, determining which environmental aspects are significant;

(d) With the EMS Team, establishing provisional environmental

objectives and targets and plans and programs to achieve them for submission to the Superintendent;

(e) With the EMS Team, identifying the resources necessary to

establish, implement, and maintain the EMS in conformance with ISO 14001 and to achieve the environmental objectives and targets;

(f) Reporting to the AGM, SSEM on the performance of the

EMS for review and as a basis for improvement;

(g) Acquiring and compiling the information necessary to track progress in the achievement of EMS objectives and targets;

(h) Prompting the EMS Team to timely execute the EMS

procedures that are its responsibility;

(i) Maintaining this EMS Procedures Manual; and



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(j) Such other responsibilities as are described within this EMS Procedures Manual

ii. EMS Team

The EMS Team has the responsibility to assist the Manager, EMIH in carrying out the Manager, EMIH�s responsibilities for establishing, implementing, maintaining, and continually improving the EMS.

(1) EMS Team Responsibilities:

(a) Identifying the environmental aspects of Shady Grove�s

activities, products, and services;

(b) Determining which environmental aspects are significant;

(c) Establishing environmental objectives and targets, plans and programs;

(d) Identifying resources necessary to meet ISO 14001

requirements and the environmental objectives and targets;

(e) Assisting the Manager, EMIH in the maintenance and continual improvement of the EMS;

(f) Providing oversight management for the achievement of the

environmental objectives and targets;

(g) Participating in the Management Review; and

(h) Such other responsibilities as are described within this EMS Procedures Manual.

iii. Environmental Protection Oversight Administrator � Regulatory Compliance

The Environmental Protection Oversight Administrator (EPOA) is responsible and accountable for establishing and maintaining procedures to identify and have access to environmental laws, regulations, and other requirements. The EPOA shall determine their applicability and support Shady Grove�s compliance activities.

(1) EPOA Regulatory Compliance Responsibilities:



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(a) The EPOA is responsible and accountable for implementing and maintaining the Legal Requirements procedure described in this EMS Procedures Manual.

iv. Shady Grove Facility and Operating Unit Superintendents and Supervisors

Shady Grove Superintendents and the Supervisors who report to them have the authority, responsibility, and accountability for assisting the Manager, EMIH in managing the environmental aspects of Shady Grove’s activities, products, and services at the facility or in the operational unit under their control. This approach ensures EMS implementation at the operations level.

(1) ECOs and DCOs, Shady Grove EMS Responsibilities:

(a) Applying the Environmental Policy (which has been defined

by top management) as it affects their facility’s or operating unit’s activities;

(b) Delegating responsibility and authority for the establishment,

implementation, maintenance, and continual improvement of the EMS at their facility or operating unit level;

(c) Providing resources to meet ISO 14001 requirements and

EMS objectives and targets;

(d) Periodically reviewing the EMS with the Manager, EMIH for suitability, adequacy, and effectiveness and addressing the need for change to policies, objectives, and other elements of the EMS in light of changing circumstances and the commitment to continual improvement.

(2) Shady Grove Supervisors are directed by the Superintendent to

uphold the Environmental Policy and to support the establishment, implementation, maintenance, and continual improvement of the EMS within their designated areas of responsibility.

v. All Persons Working for or on Behalf of WMATA at Shady Grove

(1) Employees and persons working on behalf of WMATA at Shady Grove are expected by the Superintendent to uphold the Environmental Policy and to conform to the requirements of the EMS.



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9. COMPETENCE, TRAINING, AND AWARENESS

a. Purpose

The purpose of the Competence, Training, and Awareness element of the EMS is to ensure that:

1) Any persons performing tasks that could cause a significant environmental impact are competent to perform these tasks,

2) Shady Grove identifies and requires training at the appropriate level to ensure

competency, and

3) All persons working for or on behalf of Shady Grove are aware of the Environmental Policy, procedures and requirements of the EMS.

b. Procedure

1. Training Needs Assessment

a) Each year, concurrent with establishing the objectives and targets

(and plans and programs to achieve them), the EMS Team shall:

(1) Identify any persons performing tasks for Shady Grove or on its behalf that have the potential to cause a significant environmental, health, or safety impact as identified by the EMS Team;

(2) Ensure that these persons are competent to perform their

significant impact tasks based on appropriate education, training, or experience; and

(3) Establish, maintain, and retain appropriate records of this

process.

b) Each year concurrent with establishing the objectives and targets (and plans and programs to achieve them), the Manager, EMIH shall:

(1) Identify the level of competency for any person performing

tasks at Shady Grove that have the potential to cause a significant environmental impact;

(2) Identify the training needs to establish or maintain

competency;



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(3) Develop a training matrix delineating training needs by job

function;

(4) Provide training or take other action to ensure that these training needs are met; and

(5) Establish, maintain, and retain appropriate records of this

process.

2. General Awareness Training

a) Concurrent with establishing the objectives and targets (and the plans and programs to achieve them), the Manager, EMIH shall develop, implement, and maintain a program to make all persons working for or on behalf of Shady Grove aware of:

(1) The importance of conformity with the Environmental Policy

and procedures and with the requirements of the EMS;

(2) The significant environmental aspects associated with the facility, and the environmental benefits of improved personal performance;

(3) The organizational roles and responsibilities within the EMS;

(4) The potential consequences of departure from specified

procedures; (5) The components of the ECO/DCO manual and the importance

of supporting the ECO/DCO;

b) Provide for the delivery of this information to all persons working for or on behalf of Shady Grove; and

c) Establish, maintain, and retain appropriate records of this process.

d) The awareness program will be provided through classroom or Computer Based Training (CBT). The awareness program shall include measurement of employee competency through a written competency test at the completion of the training session.



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e) Thereafter, this awareness program shall be provided to new hires either as a part of their new employee orientation or within 6 months of hire through CBT.

3. Job-Specific Training and Competency

a) Job-specific competency training is for Shady Grove employees

whose work may create a significant impact on the environment. These employees must have the necessary skills, experience and awareness to perform their duties in a manner that conforms to the Environmental Policy, procedures, work instructions, and environmental regulations. These employees will receive a level of training commensurate with the level of potential environmental impact of their assigned work functions. For most, a combination of the use of written work procedures, OEM manuals and the general awareness training will satisfy this requirement. For specific job functions, regulatory requirements mandate a higher level of training further delineated in c) and d) below.

b) Training and/or certification of competency may include but not be

limited to any combination of education, formal training, or related work experience. This may occur in the class, at the job site, or a combination of the two.

c) Training sessions on EMS program components relevant to work

functions may include but not be limited to the following:

(1) Weekly Safety Meetings (2) Monthly Safety Meetings

(3) Computer-Based Training

(4) EMIH-Initiated Training

(5) First Responder Training

(6) Hazardous Waste Training

(7) ECO/DCO Training

(8) Safety Management Course for Supervisors

(9) Internal Auditor Training



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d) In addition, WMATA policy also identifies the following training in

order to meet be compliant with specific regulatory requirements. This training may be conducted concurrent to or separate from the above-referenced EMS training.

(1) Environmental professionals (EMIH employees and

Environmental Protection Specialist; Manager, Occupational Health and Environmental Oversight; and Environmental Protection Oversight Administrator) shall complete a minimum of 12 class hours of environmental training annually. External training is encouraged.

(2) ECOs and DCOs shall complete initial ECO/DCO training.

Additional training will be in the format of internal seminars or meetings addressing specific topics on environmental regulations and EMS issues. Attendance is documented.

(3) ECOs, DCOs, managers, supervisors of facilities that generate hazardous waste and employees who handle hazardous waste are required to have completed a hazardous waste management course. Hazardous waste training must be in accordance with 40 CFR 265.16.

(4) In facilities that generate hazardous waste, use hazardous

materials, or store or handle regulated materials such as oil and fuels, adequate numbers of personnel must be trained as First Responder Operations (29 CFR 1910.120) to ensure coverage during all hours of operation. This training qualifies individuals to respond to releases and take defensive action only.

(5) ECOs, DCOs and others assigned to serve as On-Scene

Incident Commanders during hazardous materials incidents, require 24 hours of training in First Responder Operations and On-Scene Incident Command (29 CFR 1910.120(q)(6)(v)). Note: The 8 Hour First Responder Operations Course is a prerequisite and counts toward the 24 hour requirement. Refresher training will consist of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly (29 CFR 1910.120(q)(8)(i)).



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(6) EMIH staff who are assigned to respond to a hazardous materials release, for the purpose of stopping and cleaning-up the release, require a 40 Hour Hazardous Waste Operations Course, with annual refresher training.

(7) Employees who service or repair motor vehicle air

conditioning systems require training and certification in accordance with 40 CFR � 82.40.

(8) Employees who service, repair or dispose of refrigeration

systems such as those in buildings, rail cars, buses, construction vehicles, and dispose of motor vehicle air conditioners, require training and certification in accordance with 40 CFR � 82.161.

4. Contractor Training and Competency

Contractor competency relating to Shady Grove�s significant aspects will be verified through contractual language requiring either:

a) Contractor submittal of employee training records and certifications,

or b) Contractor letter certifying competency of employees working on

behalf of WMATA.

5. Training Records

EMIH and/or ODEV will maintain and retain appropriate training records for EMS-related training. Computer Based Training records will be maintained and tracked by ODEV. Employee training through CBT training will be tracked through WMATA’s online CBT system by ODEV. Editorial note: WMATA’s current system (TS Online) will be replaced with a yet to be determined CBT system. The CBT General Awareness training will be incorporated following the implementation of the new ODEV CBT system. EMS components discussed at weekly or monthly safety meetings will be recorded in the Supervisor�s safety training meeting notes and will include an employee attendance list. The facility ECO/DCO will maintain those records.

Contractor certification of competencies will be maintained as part of the project files that are maintained by the Contracting Officer or Project Manager.



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10. COMMUNICATION

a. Purpose

The purpose of the Communication element of the EMS is to ensure that WMATA communicates internally (with regard to the environmental aspects and the EMS), and that it responds to relevant communication from external interested parties.

b. Procedure

i. Internal Communication Among Levels Within WMATA

(1) Each year, concurrent with establishing the objectives and targets

(and plans and programs to achieve them), the Manager, EMIH shall make and execute plans to:

(a) Communicate internally about the EMS to Shady Grove and

the various functions, facilities, operating units and all persons working for or on behalf of Shady Grove; and

(b) Establish, maintain, and retain appropriate records of this

process.

(2) The Manager, EMIH, through the e-mail system and EMS/safety meetings, will communicate changes or additions to the environmental program to the affected ECOs and DCOs. ECOs and DCOs will then communicate the changes to their employees on-the-job, as necessary.

(3) Whenever possible, the EMS Team will use existing media to

communicate internally with employees. The Internet/Intranet, Metro Weekly, point-of-use signage and bulletin boards will be chosen based on effectiveness to communicate and post general information about the environment and the EMS.

(4) The environmental procedures for the significant aspects and any

other environmental requirements shall be communicated by e-mail and/or memorandum, and posted to all employees whose work is subject to environmental regulations. Supplemental point-of-use signage may also be posted. Line managers and supervisors will integrate the environmental implications of employees’ jobs into daily



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work function, including methods to address employee recognition of potential environmental non-compliance conditions.

(5) The ECO/DCO meeting will be used to communicate Environmental

Aspects and EMS components in general. (6) EMIH participates in special internal functions, such as the Bus and

Rail Rodeos. Participation may include information booths, one-on-one open discussion and literature handouts. Components of the EMS program may be communicated to internal sources during these functions.

ii. External Communication

(1) The Environmental Policy will be made accessible to the public via

the WMATA Internet site at www.wmata.com . The Environmental Policy and additional components of the EMS will also be available at http://wmataems.com .

(2) The Manager, EMIH will receive, document, and respond to relevant

communication on environmental issues from external interested parties. Requests from specific external parties will be addressed as follows:

(a) All media inquiries regarding WMATA environmental

policies, procedures, and programs are directed to WMATA�s Office of Public Relations (PREL). PREL will coordinate the response with the Manager, EMIH and the other responsible organizations within WMATA. All referrals regarding the EMS will be documented by the Manager, EMIH.

(b) All customer inquiries regarding WMATA environmental

policies, procedures, and programs are directed to WMATA�s Office of Public Services (CSVC). CSVC will coordinate the response with the Manager, EMIH and the other responsible organizations within WMATA. All referrals regarding the EMS will be documented by the Manager, EMIH.

(c) Questions from the local fire, rescue and law enforcement

authorities regarding emergency and life safety planning in the operating system shall be coordinated with SSEM. SSEM will notify EMIH of any related environmental concerns.



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iii. External Communication of Significant Environmental Aspects

WMATA will not initiate broadcast advertisement of its EMS program externally, but may make components of the EMS available through http://wmataems.com for those who seek information on the EMS. WMATA retains the right to communicate select EMS components to the public as deemed appropriate by top management. For example, WMATA may participate in Earth Day celebrations and other similar functions. Participation may include information booths, hands-on activities, one-on-one open discussion and literature handouts that include information on the EMS.

iv. Notification of Environmental Incidents

(1) Internal

Spills and/or releases of hazardous substances, including fuels and lubricants are reported to:

i. The immediate supervisor or other appropriate authorities at the location

ii. The Maintenance Operation Center (MOC) at 202-962-1530

iii. The Manager, EMIH at (301) 618-7522 and/or the designated

EMIH on-call representative (through MOC)

The Manager, EMIH is responsible for notification and reporting of environmental incidents to appropriate authorities and top management within WMATA.

(1) External

In the event of a life-threatening situation, any person has the right to notify emergency response authorities outside of WMATA through the 911 system. MOC is the primary point of contact for environmental emergencies and is authorized to contact external emergency response authorities. The Manager, EMIH is responsible for notification to regulatory authorities on environmental incidents as required by law.



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11. DOCUMENTATION

a. Purpose

The purpose of this procedure is to describe the methods by which Shady Grove documents and records components of the EMS.

b. Procedure

i. The following components of the EMS shall be documented:

(1) The EPOA shall establish, implement, and maintain documentation in this EMS Procedures Manual that includes:

(a) The Environmental Policy and objectives and targets;

(b) Description of the scope of the EMS;

(c) Description of the main elements of the EMS and their interaction with reference to related documents;

(d) Documents, including records, required by ISO 14001; and

(e) Documents, including records, determined by the EMS Team

to be necessary to ensure the effective planning, operation, and control of processes that relate to the significant environmental aspects.

12. CONTROL OF DOCUMENTS

a. Purpose The purpose of this procedure is to describe the methods by which Shady Grove establishes, implements, and maintains procedures to control EMS documents. Document control is intended to minimize or eliminate the dissemination of misinformation through incorrect or obsolete documents.

b. Procedure

i. The EPOA shall ensure that:



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(1) Documents are approved prior to issue; (2) Documents are reviewed, updated and re-approved as necessary;;

(3) Revised documents are tracked through the Document Revisions

Matrix

ii, WMATA shall maintain the most recent copy of primary EMS related documents on www.wmataems.com. The following label will be inserted on all controlled documents printed from the website:

***IN PRINTED FORM, THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED ON [date]. THE MOST CURRENT VERSION OF THIS DOCUMENT CAN BE FOUND AT www.WMATAEMS.COM. ***

iii. The Manager, EMIH shall approve all documents prior to posting on

www.wmataems.com.

iv. Those documents (e.g. permits, official correspondence) related to regulatory requirements will be maintained by EMIH either at the facility or at a central location or on the EMIH intranet web site, depending on legal requirements.

v. Documents of external origin determined by the EMS Team to be necessary

for the planning and operation of the EMS are identified and their location controlled. Examples include:

(1) Manufacturer’s manual (onsite, EMIH office, or manufacturer’s

website) (2) ISO 14001 standard (EMIH files and EMS website) (3) Regulations (BLR, federal and state websites)

vi. Previous versions of documents shall be considered records and shall be

maintained in the EMIH files.



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13. OPERATIONAL CONTROL

a. Purpose The purpose of the Operational Controls element of the EMS is to ensure that Shady Grove has documented procedures for operations affecting the identified significant environmental aspects, and establishes requirements and procedures for addressing the significant environmental aspects of services provided by others. WMATA (via EMIH) shall maintain awareness for opportunities to implement operational controls that could significantly impact goods provided to Shady Grove by others. WMATA shall address these opportunities on a case-by-case basis. In order to manage significant aspects and minimize their impacts, written Environmental Standards of Practice (ESOPs) are incorporated as part of the EMS through the ECO/DCO manual. ESOPs ensure that operations and activities are carried out consistent with the Environmental Policy, objectives, and targets. ESOPs provide guidance on how to conduct specific tasks or perform certain duties that are related to significant aspects. The ECO/DCO Handbook provides the specific ESOPs (operational controls) for the current EMS period.

b. Procedure

i. ESOPs

(1) Each calendar year, concurrent with establishing the objectives and

targets and plans and programs to achieve them, the EMS Team shall:

(a) Identify the Shady Grove operations affecting the significant environmental aspects;

(b) If necessary, develop ESOPs to ensure that those operations

are consistent with the Environmental Policy and the objectives and targets;

(c) Ensure that they are carried out under specified conditions by

stipulating operating criteria in the ESOPs. (d) Significant Aspects of Services



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(i) Each calendar year, concurrent with establishing the objectives and targets and plans and programs to achieve them, the EMS Team shall:

1) Identify the impact of those working on behalf

of Shady Grove on Shady Grove’s significant environmental aspects;

2) Determine or review existing procedures,

requirements, or contractual language that will be necessary to ensure conformance to the Environmental Policy, aspects, objectives and targets; and

3) Communicate applicable procedures,

requirements, or contractual language to those working on behalf of Shady Grove.

14. EMERGENCY PREPAREDNESS AND RESPONSE

a. Purpose

The purpose of the Emergency Preparedness and Response element of the EMS is to prevent or mitigate situations that may impact the environment. Shady Grove shall:

(1) Identify potential emergency and accident situations that can have an

impact on the environment; and

(2) Determine how Shady Grove will respond to emergency situations to mitigate environmental impacts.

b. Procedure

i. Annually and following the occurrence of an emergency or accident situation,

the EMS Team shall identify, review or revise the inventory of potential emergency or accident situations relating to Shady Grove�s operations and activities and the environmental consequences arising from them. Newly identified potential emergency or accident situations will be incorporated in the Shady Grove Contingency Plan.

ii. The EMS Team shall create procedures to respond to newly-identified

potential emergency or accident situations.



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iii. Currently, it is not practicable for Shady Grove to test such procedures (e.g., spill scenarios, tabletop exercises).

15. MONITORING AND MEASUREMENT

a. Purpose

The purpose of this procedure is to describe the methods employed by Shady Grove for monitoring and measuring, on a regular basis, the key characteristics of its operations that can have a significant impact on the environment. This procedure addresses the monitoring and measurement of environmental performance (including tracking of progress toward achieving established objectives and targets), applicable operational controls, the verification and maintenance of equipment used for environmental monitoring and measuring, and the evaluation of compliance with regulations relating to the significant environmental aspects of the EMS.

b. Procedure

i. Shady Grove will track progress toward achieving established objectives and

targets through the EMP matrix. The matrix shall identify milestones (e.g. 27% completion on training) where measurable.

ii. Applicable ESOPs will be monitored and measured through an annual review

process to ensure their continuing effectiveness and suitability in managing significant aspects. This may include the following methods:

(1) Internal audits (2) Impromptu interviews with employees

(3) Notice of Violations and other regulatory citations

iii. Shady Grove will maintain a matrix for ensuring that equipment used for

environmental monitoring and measuring is maintained so that accuracy and precision of environmental data collected, and any subsequent calculations that are made using this data, are consistent and defensible. Verification and maintenance procedures shall be based on the manufacturer's recommendations or owners manual for the particular piece of equipment, instrument, or measurement device being serviced.

iv. The EPOA will conduct periodic compliance assessments to evaluate

compliance with regulations relating to the significant environmental aspects of the EMS.



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16. EVALUATION OF COMPLIANCE

a. Purpose

The purpose of this element of the EMS is to ensure that Shady Grove maintains compliance with regulations, the Environmental Policy and other requirements (to which Shady Grove subscribes) through periodic objective regulatory and EMS program evaluation.

b. Procedure

i. Frequency

(1) The Manager, EMIH shall arrange for the evaluation of Shady

Grove�s compliance with environmental laws, regulations, and other requirements every three years, or more frequently as required by law. Summaries of compliance evaluations shall be communicated to appropriate top management. Records of such communication will be maintained and retained by the Manager, EMIH.

ii. Noncompliance

(1) Noncompliance findings found during EMS program evaluations and

audits shall be handled according to the requirements of the Nonconformity, Corrective and Preventive Action element of this EMS Procedures Manual.

(2) Noncompliance findings of regulatory laws and requirements shall be

addressed in accordance with regulatory directives or guidelines. 17. NONCONFORMITY, CORRECTIVE AND PREVENTIVE ACTION

a. Purpose

The purpose of the Nonconformity, Corrective, and Preventive Action element of the EMS is to ensure the elements of the EMS are consistent with ISO 14001 and to evaluate and correct nonconformities (i.e. where the system does not meet the EMS criteria or implementation is not consistent with the EMS description).



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b. Procedure

i. The following procedure will be standard for all reports of nonconformities as well as any preventive action recommendations:

(1) Actively identify and investigate nonconformities; (2) Determine their root causes;

(3) Evaluate the need for actions to prevent nonconformities, thus

mitigating environmental impacts; (4) Implement appropriate actions designed to avoid their occurrence or

recurrence.

(5) Recording results and reviewing the effectiveness of corrective and preventive actions taken.

ii. Concerns associated with environmental issues (e.g. nonconformities) raised

by Shady Grove employees and those working on behalf of Shady Grove will be directed to the Manager, EMIH by any of the following routes of verbal or written communication:

(1) Supervisor or Line Manager (2) Project Manager

(3) EMS Team member

(4) Regional Safety Officer

(5) Internal e-mail system

(6) Periodic safety meetings

(7) ECO/DCO Meetings

(8) Environmental Compliance Audit Results

(9) Corrective/Preventive Action Request Form (www.wmataems.com)

iii. The Manager, EMIH shall maintain records of corrective or preventive action

requests to include but not limited to:



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(1) Hard or electronic copies of email requests;

(2) Submitted Corrective/Preventive Action Request Forms

(3) Phone Logs

(4) Memorandums

(5) Safety Meeting Notes

(6) Internal audits/compliance evaluations

iv. The Manager, EMIH shall insert pertinent information relating to corrective

or preventive actions into the EMP matrix. This shall include milestones, persons responsible, and description of corrective and preventive action.

v. The Manager, EMIH shall evaluate and respond to each nonconformity on a

case-by-case basis with input from the EMS Team, EMIH staff, and any other available resources necessary to correct the situation.

vi. Additionally, during the annual ECO/DCO Meeting, or when the need arises

(i.e., during the EMS team meetings), the EMS Team shall conduct and document the EMS assessment of Shady Grove �s activities and operations in order to identify actual and potential nonconformities with ISO 14001 or the EMS.

vii. Actions taken shall be appropriate to the magnitude of the problems and the

environmental impacts encountered. 18. CONTROL OF RECORDS

a. Purpose

The purpose of the Control of Records element of the EMS is to ensure that WMATA establishes and maintains records to demonstrate conformity with ISO 14001 and this EMS. The intent of this element is to ensure that Shady Grove can demonstrate that it is actually implementing the EMS as designed.



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b. Procedure

i. The EMS Team shall establish, implement, and maintain electronic and/or hard copy records as necessary to demonstrate conformity. These records will be maintained in one of three primary locations:

(1) EMIH central files (2) Shady Grove EMS files

(3) ODEV training files

ii. The EMS Team shall establish, implement, and maintain procedures for the

identification, storage, protection, retrieval, retention, and disposal of these records.

(1) Identification - The EMS team in conjunction with EMIH will

identify which records must be maintained. (2) Storage and Protection - The EMS records will be stored in secured

locations within either the EMIH central files or at the facility. Files maintained on the EMIH drive are backed up in accordance with WMATA IT policy to ensure that recent versions of documents can be recovered.

(3) Retrieval - EMS related records will remain accessible through an

organized filing system controlled by the EPOA.

(4) Retention - The EPOA will maintain a records retention matrix that will delineate records maintained, retention times, and storage location. The EPOA will determine the length of retention based on legal requirements or when deemed no longer needed by the EMS team.

(5) Disposal - Every three years, the EPOA shall submit a list of records

for disposal to the Manager, EMIH for final determination. Record retention times for each type of record are defined in the Records Retention Times Matrix.



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19. INTERNAL AUDIT

a. Purpose

The purpose of the Internal Audit Program element of the EMS is to ensure that Shady Grove establishes and maintains a program to audit, at planned intervals, its conformance to the requirements of ISO 14001 and the EMS.

b. Procedure

i. Frequency and Methodology

(1) The Manager, EMIH shall ensure that EMS audits are conducted

every six months until the 3 year mark and every three years thereafter. Additional audits may be conducted at the discretion of the Manager, EMIH, when specifically requested by upper management, or following significant change to the ISO 14001 standard. The Manager, EMIH shall arrange for the conduct of scheduled internal EMS audits. The Manager, EMIH shall also arrange for partial audits of particular operations based on environmental importance and/or results of previous audits. Written audit reports shall be furnished to the Manager, EMIH for summary and dissemination to top management. The Manager, EMIH shall maintain and retain copies of the audit reports. Copies of the audit reports shall be maintained in the EMIH files

(2) The EPOA shall coordinate audit activities to include:

a) Scheduling of audit events; b) Notification of audit intent to superintendent;

c) Audit plan development; d) Audit team selection; and

e) Audit checklist preparation

(3) The Audit shall include:

a) Opening meeting with facility/operation superintendent



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b) Conducting the audit;

c) Audit debrief with facility/operation superintendent

d) Audit Report to Superintendent and Manager, EMIH

ii. Selection of Auditors

(1) The EPOA shall select audit team members based on a consideration of the audit scope, the qualifications and capabilities of the prospective auditors, and the sufficient independence of the individuals from the day-to-day management/operations of the audit areas in order to minimize potential conflicts of interest. Additionally, the EPOA may designate WMATA staff for auditor training and certification on the ISO 14001 standard.

iii. Nonconformity findings of environmental audits shall be handled according

to the requirements of the Nonconformity, Corrective and Preventive Action element of this EMS Procedures Manual.

iv. Documents will be revised, if necessary, based on Internal audit findings.

20. MANAGEMENT REVIEW

c. Purpose

The purpose of the Management Review element of the EMS is to ensure that the AGM, SSEM and Executive Leadership Team reviews, at planned intervals, the Shady Grove EMS for suitability, adequacy, and effectiveness and that it makes decisions for change consistent with the Environmental Policy commitment to continual improvement.

d. Procedure

i. In January of each year, the Manager, EMIH shall present the status of the

Shady Grove EMS program to top management and/or the Executive Leadership Team. Top management and/or the Executive Leadership Team shall review the status of the EMS program to ensure its continuing suitability, adequacy, and effectiveness.

(1) In the Management Review, the Manager, EMIH shall summarize the

following:



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(a) Results of internal EMS audits and evaluations of compliance with legal requirements and the other requirements to which Shady Grove subscribes;

(b) Communication(s) from external interested parties, including

complaints;

(c) The environmental performance of Shady Grove;

(d) The extent to which objectives and targets have been met;

(e) Status of corrective and preventive actions;

(f) EMP matrix;

(g) Follow-up actions from previous management reviews;

(h) Changing circumstances, including developments in legal and other requirements related to Shady Grove�s environmental aspects; and

(i) Recommendations for improvement.

(2) The Manager, EMIH shall present recommendations or directives

resulting from the Management Review to the EMS Team and EMIH.

(a) Output from the Management Review shall include any decisions and actions related to possible changes to the Environmental Policy, the objectives and targets, and other elements of the EMS that are consistent with the commitment to continual improvement.

(b) The Manager, EMIH shall maintain a permanent record of all

documents, exhibits, and reports of the Management Review.

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