TXDOT’S ENVIRONMENTAL COMPLIANCE...
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TXDOT’S ENVIRONMENTAL COMPLIANCE PROGRAMS Managing Environmental Compliance During Construction and at TxDOT Facilities October 15, 2019
Transcript of TXDOT’S ENVIRONMENTAL COMPLIANCE...
TXDOT’S ENVIRONMENTAL COMPLIANCE PROGRAMSManaging Environmental Compliance During Construction and at TxDOT Facilities
October 15, 2019
Breakout Session Outline
A Look Into Environmental Compliance During Construction (~15 minutes):Speaker: Tracey Janus, P.G., Environmental Affairs Division
– Environmental Compliance Programs Overview– Designer Responsibilities– Who are the DEQCs?– SWAT Visits
TxDOT’s Facility Environmental Compliance (~15 minutes):Speaker: David Nuckels, Environmental Affairs Division
– What are TxDOT Facilities? – FEC Reviews and Compliance Areas– Waste Types Managed– Trends
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COMPLIANCE DURING CONSTRUCTIONPrograms and Tools Implemented By TxDOT
Overview of Environmental Compliance Concepts at TxDOT
Designer Responsibilities
DEQCs - Key Players During Construction
SWAT Program
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What are TxDOT Facilities?5
Facility Environmental Compliance
Waste Types Managed by TxDOT
Waste Trends
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TxDOT Operations/Compliance Programs
Environmental Management
System
EPIC Monitoring Program
MS4 Program
Facilities Environmental
ComplianceVegetation Management
Program (MNT
Division)
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Inspectors
DESIGNER RESPONSIBILITIESHow does the PS&E package help us achieve compliance during construction?
PS&E Package
Item 7 – Legal Relations and Responsibilities
Item 506 – Temporary Erosion, Sedimentation, and Environmental Controls
Additional standard and special specifications, and special provisions
Construction General Notes
Plan Sheets and Layouts
Environmental Issues, Permits, and Commitments (EPIC) sheet
SWP3 Template (in progress)
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PS&E Review Checklist
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Environmental Issues, Permits, and Commitments
DEQC’STxDOT’s Environmental Compliance Safeguard
What Is A DEQC?
The DEQC, or District Environmental Quality Coordinator, is a crucial role, acting as the District’s “eyes” in the field ensuring that environmental issues, permits,
and commitments (EPICS) are monitored and implemented during construction.
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DEQC Construction Stage Gate Checklist
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SWAT VISITSFunction of the EPIC Monitoring Program
SWAT program began in 1999
The purpose of the SWAT visit is to complete a comprehensive environmental compliance review of selected construction projects with a specific focus on the Construction General Permit (CGP) and EPICs identified in the NEPA document.
– Improve operations within the District to ensure environmental compliance
– Improve operations throughout TxDOT to ensure environmental compliance
– Cross-training opportunities for District and Division staff
– Peer exchange opportunities for District and Division staff
The SWAT Core Team is composed of District and Division staff
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Stormwater Advisory Team (SWAT)
Project Selection• Have at least one EPIC identified on the EPIC sheet (in the plan set ).• Have at least 1 acre or more of disturbance. Five or more acres of disturbance is preferable. • Bridge projects can be less than 1 acre of disturbance as long as they have at least one EPIC
associated with the project.• Be sufficiently complex to provide useful feedback to the District.
The District will select 2-4 candidates based on project complexity.
The Core Team will review as much documentation as possible prior to visiting the District, using ECOS, ProjectWise, shared files, etc.
The general structure for a SWAT visit is as follows:– Day 1: Pre-meeting at the District office– Day 2: Field visit and paperwork review– Day 3: Field visit and paperwork review– Day 4: Summary and presentation at the District office
Depending on the size of the project, the SWAT team may either visit the entire project area, or may visit representative examples and locations within the project limits (highlights, protected areas, potential trouble spots, etc.)
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SWAT Visit Methodology
FACILITY ENVIRONMENTAL COMPLIANCE PROGRAM
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FACILITY ENVIRONMENTAL COMPLIANCEManaging Regulatory Environmental Compliance at TxDOT Facilities
Outline
Facilities Defined
Facilities Environmental Compliance
Waste Types Managed
Waste Trends
Typical TxDOT Facility
Typical TxDOT Facility
What do we mean by a “TxDOT Facility”?
TxDOT owned/operated permanent locations, such as:
– Area Offices
– Maintenance Sections
– District Offices
– Sub-Sections
For our purposes:
– Generally : Everything inside the fence line/property line is considered the “facility”.
Not all TxDOT Facilities are situated equally…
Some are in:
– Small Towns
– Medium Towns
– Large Motorplex
– Out in a rural areas
Variety of surroundings:
– Neighborhoods
– Retail/Commercial
– Industrial/Warehouses
– Agricultural land
– Forests/Parks/”Nature”
Know your facility and how you fit in locally.
Many/Most of TXDOT offices were built before they were surrounded by development, industry, residential homes, retail, etc.
Be aware that some of our routine daily activities may create:
– Sounds (machinery)
– Smells (asphalt operations)
– Sights (good housekeeping)
– Etc.
Every office has a different layout.
What is facility environmental compliance (FEC) ?
Lots of moving parts.
Broad issues:
– Managing wastes.
• From our daily activities
• From the items we pick up from roadways.
– Maintaining our materials (within the fence lines).
– Recycling or proper disposal.
Facilities Environmental Compliance (FEC) Program
TxDOT operates roughly one maintenance section per county.
Many day-to-day operations require compliance.
Helpful to have a second set of eyes review your operations.
Assist in preparation for regulatory compliance visits. (EPA/TCEQ)
Risk Associated with Facility Environmental Compliance (FEC)
General Overview of What We’re Looking For…
Can fall “generally” into three categories:
1. Records and Record Keeping
2. Facility Good Housekeeping
3. Implementing/engaging in regulatory requirements. (i.e. annual certification, required training, etc.)
4. Environmental Trends
What you need to know!
A large portion of a FEC review is based on a sites SPCC plan and its implementation.
Items we visually check are primarily the areas indicated on the SPCC plans.
– Secondary containment areas around:
• Fueling areas
• Used oil collection
• Garage/shop areas
• Brine tanks (non-SPCC item)
FEC Program - REVIEWS
Surveys are conducted for the purpose of assessing compliance with various environmental regulations associated with facility operations.
Conducted every 36 months.
Environmental compliance is not always associated with just transportation projects.
How do we review compliance efforts?
Value Added Service
Verify the effectiveness of a District’s facilities environmental compliance (FEC) program.
Provide feedback to district personnel that will improve compliance at TxDOT.
Survey typically is an overview of many programs.
Helps single out one or more program areas for a district to consider conducting a more in-depth review and with implementing necessary changes.
FEC Areas Covered
Petroleum Storage Tank (PST) Management
Wastewater / Stormwater Runoff Management
Spill Prevention Control and Countermeasure Planning
Waste Management
Used Oil and Oil Filter Management
Used Antifreeze Management
Used Lead Acid Battery Management
Scrap Tire Management
Municipal Separate Storm Sewer System Permit (MS4 Permit)
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Typical SPCC Layout of a TxDOT Facility
Scrap Tires/Metal
Asphalt Tank
Fuel
Aboveground Storage Tank
Aboveground Storage Tank
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Aboveground Storage Tank
Aboveground Storage Tank
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AST
Underground Storage Tank
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Underground Storage Tank
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UST
Spill Prevention Control and Countermeasures Plans
Keep your SPCC up to date.
– Use the amendment log, sign, date.
Perform annual training.
Perform monthly inspections
– Remember to include brine tanks, brine maker, salt barns, and salt piles.
Address any items noted that are not in compliance.
Checking Secondary Containment
Organize your manifests and other documents.
Maintain all your waste manifests in a central location.
– One file drawer, on a shelf, etc. for easy locating/access.
Ensure that multiple office employees know where the records are, and what they are for, etc.
Ensure employee cross-training in the event of a retirement/departure.
– Institutional Knowledge won’t be lost
Well organized waste manifests and records…
…makes all the difference!
Scrap tires can build up quickly.
Grit traps need to be cleaned regularly.
Always get your manifest back from the contractor!
Documentation is Key!
Keep good records!
Manifests
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Trends: Types of Wastes and Manifests
1. Scrap Tires
2. Grit Trap Waste
3. Used Oil/Oil Filters
4. Antifreeze & Parts Washer Waste
5. Batteries (vehicles)
6. Salt Management
Trends and Changes Over Time
Many waste management items have trended down over the years.
New items to consider have replaced them in recent years.
– Salt/Brine Management
– MNT Activity Wastes
• Hydro/Micro Blading
• Diamond Grinding
As new or improved methods emerge, accounting for managing these wastes appropriately is critical.
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Trends - Salt Management
Increased installations of brine makers, and salt barns around the state.
Salt Management is something we’re looking at more closely now with our Facilities Environmental Compliance Reviews.
Requesting that districts perform monthly visual inspections on salt management equipment, in line with regular SPCC inspection process.
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FEC Reviews and Action Items
At the end of the FEC Review, we note:– Good use of best practices– Items needing attention (minor/major/new)– Offer recommendations on how to come into compliance
• Or provide potential new BMPs we’ve seen work well in other places.
The District then:– Follows up with a written response.– Implements any needed recommendations to maintain
compliance.
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QUESTIONS?
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Tracey Janus, P.G.Environmental Specialist
TxDOT Environmental Affairs [email protected]
David NuckelsEnvironmental Specialist
TxDOT Environmental Affairs [email protected]
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Contact Information
