Deval L Patrick. Governor
Timothy P. Murray. Lt. Governor
Richard A. Davey, Secretary & CEO
massDOT
Massachusetts Department of Transportation
September 2011
As the Massachusetts Department of Transportation carries out its mission to provide an
efficient, safe, clean and cost effective transportation system for the Commonwealth, the
Administrator and I are reinforcing our commitment to keeping MassDOT a responsible
environmental steward and in the forefront of environmentaf compliance.
In support of this commitment, MassDOT Highway has developed the latest version of its
Environmental Management System (EMS) manual outlining the organizational
structure, associated responsibilities, and procedures for integrating environmental
objectives in our day-to-day operations along our roadways and at our maintenance
facilities. Doing so will help maintain regulatory compliance and employ practices that
ensure a safe working environment, avoid environmental harm and minimize the
financial impacts of regulatory enforcement. All MassDOT employees are expected to
perform their jobs to meet the objectives of the EMS.
We realize that in order to continue the high standard of this system we must
continuously review our operational and maintenance needs, plan accordingly, audit for
inconsistencies and correct the problems and update as needed. We also realize that
regular mandatory EMS and Facility Environmental Awareness training will make us
have a stronger awareness of compliance requirements and stewardship.
Join us in strengthening the environmental sustainability of our roadway and facility
operations that will help MassDOT be the national leader in transportation excellence.
?~4~
Frank DePaola, P .E.
Administrator, Highway Division
Leading the Nation in Transportation Excellence
Ten Park Plaza. Suite 3170, Boston. MA 02116
Tel. 617-973-7000. TDD: 617-973-7306
www.mass.govj massdot
ENVIRONMENTAL MANAGEMENT
SYSTEM MANUAL
GENERAL ROLES AND RESPONSIBILITIES | EMS COMPONENTS | CONTACTS AND INFORMATION SOURCES
Environmental Management System Manual
February 2012
Table of Contents
Executive Summary ................................................................................................................................. i
Section I – General Roles and Responsibilities ........................................................................................ 1
1.0
Introduction ................................................................................................................................ 1
1.1
Division ......................................................................................................................... 1
1.1.1
Highway Administrator...................................................................................... 1
1.1.2
Chief Engineer................................................................................................... 1
1.1.3
District Highway Directors ................................................................................ 1
1.1.4
Deputy Chief Engineers ..................................................................................... 2
1.1.5
Highway Safety and Mobility............................................................................. 2
1.1.6
Project Management .......................................................................................... 2
1.1.7
Right of Way ..................................................................................................... 2
1.1.8
Roadway Operations and Maintenance............................................................... 2
1.1.9
Construction ...................................................................................................... 3
1.1.10 Research and Materials Testing Laboratory........................................................ 3
1.1.11 Districts ............................................................................................................. 3
1.1.12 Environmental Services ..................................................................................... 4
Section II – Environmental Management System Components................................................................. 6
2.0
Funding and Contract Procedures................................................................................................ 6
3.0
Environmental Requirements ...................................................................................................... 8
4.0
3.1
Environmental Requirements List................................................................................... 8
3.2
Procedure ....................................................................................................................... 8
3.3
Roles and Responsibilities .............................................................................................. 9
Emergency Preparedness/Incident Response ............................................................................. 10
4.1
4.2
5.0
Spills at Maintenance Facilities .................................................................................... 10
4.1.1
Procedure......................................................................................................... 10
4.1.2
Review and Update Procedures for Emergency Response Spill Plans ............... 11
4.1.3
Review and Update Procedures for SPCC Plans ............................................... 11
4.1.4
Roles and Responsibilities ............................................................................... 12
Roadway Traffic Incidents............................................................................................ 13
Standard Operating Procedures ................................................................................................. 15
5.1
Identification of New SOPs and SOPs Requiring Revision............................................ 15
5.2
Development, Revision, Final Review and Endorsement of SOPs................................. 15
5.3
Roles and Responsibilities ............................................................................................ 15
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6.0
7.0
8.0
Facility Environmental Handbook and Facility Plans................................................................. 17
6.1
Procedure ..................................................................................................................... 17
6.2
Roles and Responsibilities ............................................................................................ 17
Training.................................................................................................................................... 19
7.1
Procedure ..................................................................................................................... 19
7.2
Environmental Training Program Components ............................................................. 19
7.3
Roles and Responsibilities ............................................................................................ 23
Compliance Tracking and Auditing........................................................................................... 24
8.1
9.0
10.0
Compliance Tracking Components ............................................................................... 24
8.1.1
Audits.............................................................................................................. 24
8.1.2
Facility Inspections .......................................................................................... 24
8.1.3
Routine Facility Observations .......................................................................... 25
8.1.4
Correcting Out-of Compliance Issues............................................................... 25
8.1.5
Tracking Compliance Issues............................................................................. 25
8.1.6
Roles and Responsibilities ............................................................................... 25
8.2
Audit Program Implementation..................................................................................... 26
8.3
Audit Program Roles and Responsibilities .................................................................... 26
Maintenance Activities ............................................................................................................. 29
9.1
Environmental Scope Review Process .......................................................................... 29
9.2
Wetland and Riverfront Areas ...................................................................................... 30
9.3
Hazardous Materials/Waste Management and Contaminated Areas............................... 30
9.4
Development of Maintenance Activities SOPs.............................................................. 30
9.5
Maintenance Activities Roles and Responsibilities........................................................ 31
Stewardship, Sustainability and Pollution Prevention ................................................................ 32
10.1
MassDOT’s GreenDOT Policy Directive, “Leading By Example” and
Environmentally Preferable Products and Services ....................................................... 32
10.1.1 GreenDOT....................................................................................................... 32
10.1.2 Executive Orders ............................................................................................. 32
10.2
MassDOT’s Stormwater Management Program ............................................................ 32
10.2.1 MassDOT Stormwater Handbook .................................................................... 33
10.2.2 Impaired Waters Program ................................................................................ 33
10.2.3 Illicit Discharge Detection and Elimination (IDDE) Program ........................... 33
10.2.4 Environmental Status and Planning Report (ESPR) .......................................... 33
10.2.5 Other Stormwater Management Program Efforts .............................................. 34
10.3
Vegetation Management Program................................................................................. 34
Environmental Management System Manual
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10.3.1 Integrated Roadside Vegetation Management................................................... 35
10.3.2 Identifying and Protecting Sensitive Areas ....................................................... 35
10.3.3 Alternatives to Chemical Herbicide Study........................................................ 35
10.4
Bridge Section.............................................................................................................. 35
10.5
Pollution Prevention ..................................................................................................... 35
10.5.1 Water Pollution Prevention .............................................................................. 36
10.5.2 Toxics Use Reduction ...................................................................................... 36
10.5.3 On-going Initiatives ......................................................................................... 36
10.5.4 Future Goals .................................................................................................... 37
11.0
EMS Review............................................................................................................................. 39
11.1
Procedure ..................................................................................................................... 39
11.1.1 EMS Formal Reviews ...................................................................................... 39
11.1.2 MassDOT Management Team Review............................................................. 39
11.1.3 EMS Review Roles and Responsibilities .......................................................... 40
List of Tables
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table 8
Table 9
Table 10
Table 11
Table 12
Table 13
Table 14
Table 15
Table 16
Table 17
Environmental Management System Components.................................................................... ii
Roadway Operations and Maintenance Roles and Responsibilities ............................................3
District Roles and Responsibilities............................................................................................4
Environmental Services Roles and Responsibilities...................................................................5
Operational Environmental Compliance Spending Plan Requirements ......................................6
Requirements Roles and Responsibilities..................................................................................9
Emergency Preparedness Roles and Responsibilities for Spills – Maintenance Facilities .........12
Emergency Preparedness Roles and Responsibilities for Spills – Roadway Incidents...............14
Standard Operating Procedures Roles and Responsibilities .....................................................16
Facility Handbook and Facility Map Review and Revision Roles and Responsibilities ............18
MassDOT Regulatory Required and Best Management Practices Training Program ................20
Environmental Training Program Roles and Responsibilities ..................................................23
Compliance Tracking Roles and Responsibilities ....................................................................25
Audit Program Roles and Responsibilities ..............................................................................27
Maintenance Activities Roles and Responsibilities..................................................................31
On-going Pollution Prevention Initiatives ...............................................................................36
EMS Review and Evaluation ..................................................................................................40
List of Appendices
Appendix A
Environmental Services Contacts
Appendix B
Information Sources and MassDOT- Highway Division Programs
Appendix C
State Environmental Regulations
Appendix D
Federal Environmental Regulations
Appendix E
MassDEP Policies and Guidance Documents
Appendix F
Executive Orders
Appendix G
Environmental Responsibilities Schedule Summary
Environmental Management System Manual
February 2012
Executive Summary
An important goal of the Massachusetts Department of Transportation is to “Operate the
transportation system in a manner that embraces our stewardship of the Commonwealth’s
natural, cultural, and historic resources.” As such, MassDOT – Highway Division (MassDOT)
has made a commitment to designing, building and maintaining roads in a manner that promotes
economic well being and safety while supporting sustainable communities. MassDOT is
committed to reducing impacts to the environment from its daily operations and maintains a
leadership role in this initiative.
To achieve this goal, MassDOT has developed and implemented an Environmental Management
System (EMS) that outlines the organizational structure and associated responsibilities and
processes, procedures, and tools for integrating environmental considerations and objectives into
the ongoing management decision-making processes and operations of the organization. The
components and structure of the EMS are outlined within this Environmental Management
System Manual.
The communications and coordination features of the EMS rely upon two key elements: the
Plan-Do-Check-Act structure of an EMS as depicted below; and the processes, procedures, and
tools that derive from this structure.
© 2003 – AASHTO Center for Environmental Excellence
Environmental Management System Manual
February 2012
EMS Components
MassDOT’s EMS consists of specific components which serve separate and distinct purposes but
are integrated to become part of the overall system. An overview of these components is
provided in the following table.
Table 1
Environmental Management System Components
EMS Component
Description
Funding and Contract
Procedures
Identifies the process and responsibilities for allocating adequate funding for
environmental compliance; integrating environmental requirements into
maintenance contracts; and defining procedures and responsibilities for
administering environmental aspects of the contracts.
Environmental
Requirements
Discusses the applicable environmental laws, regulations, policies and
other mandates that apply to MassDOT activities.
Emergency
Preparedness/Incident
Response
Identifies procedures for planning and responding to spills at MassDOT
facilities and roadway incidents.
Standard Operating
Procedures
Describes the methods for developing environmental standard operating
procedures (SOPs) as well as the review, revision, and endorsement of
environmental SOPs to guide MassDOT staff on environmental
management requirements.
Facility Environmental
Handbook and Facility
Plans
Identifies the purpose of the Facility Environmental Handbook and Facility
Plans and designates the roles and responsibilities for updating these tools.
Training
Documents the procedures for planning, delivering, and tracking
environmental training.
Compliance Tracking and
Auditing
Defines the procedures MassDOT uses to identify, correct, and track
compliance issues including auditing which is a formal process for
evaluating environmental compliance and assessing conformance with the
EMS and related requirements.
Maintenance Activities
Presents the expansion of the EMS from primarily a facilities-based
program to also incorporate requirements, processes, and procedures for
limiting adverse environmental impacts and promoting environmental
stewardship while conducting roadway maintenance activities.
Stewardship,
Sustainability and
Pollution Prevention
Describes the environmental stewardship practices that MassDOT conducts
including those contained in its pollution prevention program and the
Sustainability Plan.
EMS Review
Describes the procedures and schedules for review and update of
MassDOT’s EMS and conformance with the EMS.
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EMS Manual Background and Purpose
MassDOT’s EMS Manual was first developed and published by the former Massachusetts
Highway Department in 2001 and has been revised periodically as the EMS has evolved. In this
revision, the EMS Manual has been amended to recognize the integration of the former
transportation departments and authorities of the Commonwealth that now comprise a unified
Highway Division within MassDOT. The EMS and EMS Manual has also been expanded from
its focus on facilities to include roadway maintenance activities conducted by MassDOT. The
potential environmental impact of roadway maintenance work activities has been incorporated
into this version of the EMS Manual (Section 9.0). Roadway maintenance work activities will be
further examined over the lifespan of this current version of the EMS Manual and will be further
expanded within the next version of the EMS Manual and the EMS. Following are roadway
maintenance activities presented in this EMS Manual:





roadway and shoulder maintenance and repair activities
drainage maintenance activities
roadside maintenance activities
structures maintenance activities
traffic control device maintenance and repair
Whether MassDOT is responding to an emergency roadway flooding incident, repairing a
damaged drainage culvert, or applying deicing materials on roadways, these activities must be
conducted in a manner that is consistent with the goals of this EMS, State and Federal
environmental regulations, and Executive Orders. This EMS Manual provides the framework,
policies, procedures, and tools to integrate sound environmental management practices into
MassDOT operations and maintenance activities.
Section I of this EMS Manual provides a general description of management roles, and Section II
provides details of the EMS components. Appendix A includes a list of Environmental Services
contacts for MassDOT – Highway Division. In addition, relevant information sources, EMS
reference documents, and regulatory requirements that apply to the EMS are presented in
Appendix B through G.
Suggestions and Comments
Suggestions and/or comments regarding the content and formatting of this EMS Manual should
be directed to Mr. Steven Miller who can be reached at 617-973-8248 or by e-mail at
steven.j.miller@state.ma.us.
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Section I – General Roles and Responsibilities
1.0
Introduction
MassDOT recognizes that environmental compliance is dependent upon the development of
clear lines of authority, responsibility, and accountability for environmental management as well
as identification and allocation of adequate funding and training. Roles and responsibilities for
environmental management have been assigned to all levels of MassDOT. A general description
of management roles and responsibilities is provided in Section I. Procedures for implementing
each component of the system as well as a description of specific roles and responsibilities are
described in further detail in Section II.
1.1
Division
All MassDOT employees are expected to conduct their job in a manner that will support this
EMS resulting in the integration of environmental stewardship into facility operations and
roadway maintenance. Therefore, roles and responsibilities for environmental management have
been established, and employees are educated as how to best conduct those duties that may result
in adverse environmental impacts.
1.1.1
Highway Administrator
The Highway Administrator ensures that the EMS remains a fundamental part of daily
operations and is supported by all managerial and supervisory levels of MassDOT. To
accomplish this, the Highway Administrator’s Office ensures that the EMS is consistent with
MassDOT’s overall mission, goals and objectives, and ensures adequate EMS-related funding,
staffing, and mandates EMS-related training at all employment levels as recommended by the
Chief Engineer. The Highway Administrator also facilitates agreements with other Federal and
Massachusetts agencies including the US Environmental Protection Agency and the
Massachusetts Department of Environmental Protection (MassDEP).
1.1.2
Chief Engineer
The Chief Engineer ensures that the needs for staffing and resources for the sustainability of this
EMS are defined and communicated to the Highway Administrator and that environmental
policies and programs are effectively implemented and communicated to the MassDOT
management team including Deputy Chief Engineers and Directors. The Chief Engineer ensures
that the EMS is reviewed on a regular basis and that practical measures are implemented to
improve its effectiveness. The Chief Engineer also participates in the management team review
of the EMS.
1.1.3
District Highway Directors
The District Highway Directors are responsible for overseeing the overall implementation of the
EMS within their District. The District Highway Directors assign District staff to participate in
the EMS and its supporting programs and participate in the management team review of the
EMS.
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1.1.4
Deputy Chief Engineers
Deputy Chief Engineers are responsible for activities being overseen by Directors within their
respective areas: Design, Bridges and Tunnels, Construction, Operations and Maintenance, and
Safety and Mobility. The Deputy Chief Engineers assign staff to participate in the EMS and its
supporting programs and requirements. Deputy Chief Engineers also participate in the
management team review of the EMS.
1.1.5
Highway Safety and Mobility
Highway Safety and Mobility is responsible for implementing the Strategic Highway Safety Plan
and employee safety initiatives and is aware of environmental issues that are related to highway
and employee safety including delivering initial Right-to-Know training for applicable
MassDOT personnel; conducting regular facility inspections for emergency response supplies;
investigating exposures incidents to suspected asbestos fiber releases; and responding to
materials/wastes deposited on rights of way and highway spills.
1.1.6
Project Management
Project Management is responsible for ensuring that environmental laws and regulations are
considered and properly addressed during the design phase of highway projects and directly
supports the components of the EMS by ensuring design specifications support compliance with
environmental regulations and MassDOT SOPs.
1.1.7
Right of Way
Right of Way (ROW) is responsible for ensuring that properties being considered for purchase
by MassDOT receive proper real estate assessment for the identification of environmental
compliance liabilities. ROW is also responsible for ensuring that properties receive canvassing
for environmental issues prior to disposition.
1.1.8
Roadway Operations and Maintenance
Roadway Operations (Operations) is responsible for the statewide maintenance fleet, statewide
communications including the Highway Operations Center, and snow and ice maintenance. The
Director ensures activities are conducted in a manner that adheres to environmental requirements
and protection of the environment.
Roadway Maintenance (Maintenance) prepares and publishes general maintenance specifications
for contract work involving the preservation of all classes of highways under MassDOT
jurisdiction. Maintenance establishes and maintains standard maintenance methods and practices
and gathers information and advises on new and improved maintenance equipment and practices.
It provides data on new types of equipment that will further mechanize and reduce the costs of
maintenance and generates maintenance performance records and reports that will identify
design features that should be corrected as disclosed through maintenance problems and
operation. It promotes efficient and effective maintenance through improved management
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practices that protect and enhance the quality of the environment, and develops instructional
recommendations for inclusion in a manual relating to roadside development and the
preservation of the roadside. Relative to the EMS, the Director ensures maintenance activities are
conducted in a manner that adheres to environmental requirements and protection of the
environment.
Table 2
Roadway Operations and Maintenance Roles and Responsibilities
Role
Responsibility
Operations and
Maintenance
Engineer(s)
Responsible for integrating environmental compliance and sustainability practices
within Maintenance and into contracts, and ensures that related personnel
responsibilities are communicated to the Districts. Ensures that maintenance
operations are conducted in accordance with SOPs and MassDOT’s
environmental programs including the Vegetation Management Program. Also,
ensures that applicable environmental notifications are made, and that applicable
environmental permits are obtained and communicated.
Director of Roadway
Maintenance
Responsible for ensuring that EMS and sustainability programs are implemented
within Maintenance. Ensures that Stockroom activities are conducted in
conformance with SOPs including supplying Material Safety Data Sheets upon
request and maintaining an appropriate inventory of spill response materials.
Ensures that roadway maintenance activities are conducted in conformance with
relevant SOPs.
Responsible for ensuring that EMS and sustainability programs are implemented
within Operations. Ensures that Snow and Ice operations are conducted in a
manner that is protective of the environment, and in accordance with current
SOPs, Policies, and the Snow and Ice Generic Environmental Impact Report. The
Director ensures that Contractors and MassDOT personnel are trained and are
aware of the environmental impacts due to deicing chemical applications.
Director of Roadway
Operations
1.1.9
Construction
Maintenance contracts for facilities or within the highway right-of-way are sometimes
administered at the District level through its District Construction Section. When this occurs,
Construction and the Resident Engineer are responsible for supporting the components of the
EMS by ensuring that applicable environmental regulations and MassDOT SOPs are properly
addressed during maintenance activities.
1.1.10
Research and Materials Testing Laboratory
The Research and Materials Testing Laboratory is responsible for ensuring that the laboratory is
operated in accordance with federal and state regulations and MassDOT SOPs.
1.1.11
Districts
The Districts are responsible for the implementation of the EMS at their respective facilities and
while conducting highway maintenance activities and ensure that operations are performed in
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compliance with environmental regulations and MassDOT SOPs. A summary of District EMS
roles and responsibilities for compliance is provided below.
Table 3
District Roles and Responsibilities
Role
Responsibility
District Highway
Director
Responsible for overseeing the overall implementation of the EMS within the
District. Assigns a District representative to the MassDOT Sustainability Team.
District Maintenance
and Operations
Engineers
Responsible for coordinating facility and highway maintenance activities in
accordance with EMS requirements. The District Maintenance and Operations
Engineers also ensure that environmental and sustainability practices are
communicated to District maintenance personnel. The District Maintenance
and Operations Engineers ensure that sufficient resources are allocated to
support EMS activities throughout the District, and ensure that District
employees attend environmental training programs, as appropriate.
Area Engineers,
Highway Maintenance
Engineer, Roadside
Engineers, Bridge
Engineers, Snow and
Ice Engineers
These individuals report to the District Maintenance and Operation Engineers.
In addition to using standard engineering and maintenance care at
maintenance facilities and the assigned roadways, they also ensure that
highway maintenance projects are planned and completed in conformance
with environmental regulations and MassDOT SOPs.
Area and Facility
Supervisors
The Area and Facility Supervisors ensure that maintenance personnel and
contract workers conduct routine maintenance activities in accordance with
MassDOT SOPs and contracts. The Area and Facility Supervisors work
closely with the EMS Compliance Coordinators to ensure compliance with the
EMS.
District Environmental
Engineers
The District Environmental Engineers support project design, facility and
highway maintenance operations with natural resource permitting and local
Conservation Commission and local Board of Health notifications and
approvals. The District Environmental Engineers also review work scopes for
possible environmental management requirements.
1.1.12
Environmental Services
Environmental Services provides expertise in interpretation of environmental regulations,
compliance program development and implementation, compliance budget analysis, compliance
inspection and environmental SOP/policy review and development. General roles and
responsibilities within Environmental Services are described below with more specific
responsibilities described within subsequent sections of this manual. A list of Environmental
Services contacts is also included within Appendix A.
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Table 4
Environmental Services Roles and Responsibilities
Role
Responsibility
Director of
Environmental
Services
Responsible for ensuring that EMS and sustainability programs are implemented
within Environmental Services.
EMS/Sustainability
Supervisor
Responsible for periodic reviews and updating of the EMS Manual and
compliance tools including Facility Plans, the Facility Environmental Handbook,
SOPs, and the Audit Program. Represents MassDOT on the Leading-ByExample Council, chairs MassDOT’s Sustainability Team and supervises the
District EMS Compliance Coordinators and Audit Coordinator.
EMS Compliance
Coordinators
Provide multi-media environmental compliance support, training, and auditing for
District facilities by reviewing environmental requirements and ensuring that new
requirements are identified in a timely manner for implementation into the EMS.
Audit Coordinator
Ensures that the Audit Program functions in accordance with the MassDOT
Audit Protocol. Performs periodic reviews of the program and recommends
modifications in accordance with changes in MassDOT’s operations. Creates,
maintains, and implements the auditing schedule and provides regular training
to the auditors.
Environmental
Specialists
Provide professional expertise in specific media programs including: the
Massachusetts Contingency Plan (MCP), National Pollutant Discharge
Elimination System (NPDES) Phase II Stormwater Management Program, Spill
Prevention Control and Countermeasures (SPCC), Snow and Ice General
Environmental Impact Report, Fuel Storage Tank and Vapor Recovery
Compliance Program, Industrial Wastewater Holding Tank Compliance, and
Asbestos Inspection, Maintenance, and Remediation Program.
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Section II – Environmental Management System Components
2.0
Funding and Contract Procedures
The annual review of funding needs and sources is critical for maintaining environmental
compliance. Environmental Services, Maintenance, Operations and the Districts each play a role
in identifying funding needs to support the goals of the EMS. The Directors of Environmental
Services, Maintenance, and Operations, with input from the District Highway Directors, District
Administration Managers, District Maintenance Engineers, and District EMS Compliance
Coordinators, provide input into the preparation of the environmental compliance budget for
submittal to the Federal Aid and Program Office (FAPO), the Executive Office of
Administration and Finance, the legislature, and final approval by the Governor. A summary of
typical funding needs relating to this EMS is provided below.
Table 5
Operational Environmental Compliance Spending Plan Requirements
Requirement
Description
Solid Waste Disposal
Disposal of accumulated solid wastes including, but not limited
to, street sweepings, catch basin cleaning, scrap tires, C&D
waste, ABC waste, wood waste, and trash.
Hazardous/Medical Waste/
Disposal
Disposal of hazardous waste, waste oil, universal waste, and
medical waste.
Wastewater Disposal
Analysis and disposal of industrial holding tank wastewater,
oil/water separator cleaning, septic tank pump outs, and other
generated wastewater.
Asbestos Inspection, Testing and
Abatement
Renovation and demolition of facility structures requires asbestos
inspection and testing and may require abatement by licensed
professionals.
Fuel Tanks and Vapor Recovery
Inspection & Testing
Inspection and testing of storage tanks and associated leak
detection equipment; inspection and testing of Stage II vapor
recovery equipment.
Environmental Training Programs
Implementation of regulatory-based training programs such as
hazardous/universal waste management and emergency spill
response training requirements.
Contaminated Sites (MCP/21E)
Assessment and remediation of contaminated properties require
Licensed Site Professionals and remediation contractors.
Spill Containment Equipment &
Supplies
Procuring of leak and spill response equipment, supplies,
absorbent materials, and contactor services to respond to spill
incidents.
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Requirement
Description
Highway Incident Response and
Recovery
Roadway spills resulting from MassDOT vehicles or equipment that
require the services of environmental cleanup contractors.
Environmental Consultant
Contracts
Consultant contracts to support EMS development, the NPDES
program, and other regulatory matters.
Specialized Studies
MassDOT is periodically called upon to evaluate impacts from
salt application and storage activities and vegetative
management product alternative research.
Upon approval of MassDOT’s overall spending plan and notice of funding, FAPO provides
notification concerning the availability of funds for program needs. Funds can then be
encumbered to support program needs. Some contracts are administered through pre-approved
Operational Services Division contracts (OSD). The EMS Compliance Coordinator, in
cooperation with the District Maintenance Engineer, manages the District spending schedule
such that funds are available throughout the fiscal year. Likewise, Maintenance, Operations and
Environmental Services are responsible for ensuring that their funds are appropriately allocated
and that the spending schedule is appropriately managed.
In addition, Boston Headquarters and each District Headquarters are responsible for identifying
and developing Consultant and Construction contracts to support the functions and needs of
MassDOT. Generally, contracts are used to assist in the design and construction of highway and
bridge projects, support operational and maintenance functions, environmental permitting and
compliance, and policy development. It is the responsibility of each Boston Headquarters section
and District to include contract requirements that preserve and enhance the scenic, aesthetic,
historic, community, and environmental resources and support compliance with environmental
requirements, laws, regulations, policies and procedures.
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3.0
Environmental Requirements
This EMS component identifies the procedure for reviewing the applicability of state and federal
laws, regulations, and policies that apply to MassDOT. As regulations are subject to change over
time, and as new regulations are promulgated by regulatory agencies, periodic reviews of
regulations to stay current on compliance requirements are conducted as necessary. Likewise,
MassDOT activities can change over time and must also be periodically reviewed to ensure that
activities are conducted in compliance with regulations and policy. MassDOT routinely reviews
federal and state regulatory information sources to stay current on compliance requirements. The
procedure and roles and responsibilities for managing the Environmental Requirements
component of the EMS are described in the following sections.
3.1
Environmental Requirements List
MassDOT maintains an Environmental Requirements List, which identifies regulations, policies
and procedures applicable to MassDOT maintenance and roadside activities. Environmental
Services regularly reviews and updates the Environmental Requirements List to reflect changes
to facility operations and roadside activities or the introduction of new regulations. A summary
of the Environmental Requirements List is provided in Appendices C through F of this document
and includes the following applicable references:
3.2

State Environmental Regulations (Appendix C)

Federal Environmental Regulations (Appendix D)

MassDEP Policies and Guidance Documents (Appendix E)

Executive Orders (Appendix F).
Procedure
Environmental Services is responsible for monitoring proposed regulations and policies
applicable to current MassDOT operations. Regulatory monitoring may include but is not limited
to periodic review of MassDEP, EPA, and Federal Register websites for information on new or
upcoming regulations. Also reviewed are the existing Codes of Massachusetts and Federal
Regulations (CMRs and CFRs) and Executive Orders. Changes in facility operations are
identified through periodic inspections and through regular communication between District and
Environmental Services staff. The EMS/Sustainability Supervisor or their designee coordinates a
review of the Environmental Requirements List as part of the regular review of the EMS.
Revisions to the Environmental Requirements List are also based on continuing input from
Maintenance, Operations, District representatives and Environmental Services personnel. A
change in Operational or Maintenance procedure may precipitate the inclusion or deletion of a
requirement on the Environmental Requirements List, and the EMS/Sustainability Supervisor
provides final approval of changes to the Environmental Requirement List.
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3.3
Roles and Responsibilities
The following table presents a summary of the roles and responsibilities for review and
development of the Environmental Requirements List.
Table 6
Requirements Roles and Responsibilities
Role
Responsibility
Operations Engineers,
Maintenance Engineers, and
District Maintenance Engineers
Responsible for notifying EMS Compliance Coordinators,
Environmental Specialists, and District Environmental Engineers
concerning anticipated changes in operations that should be
reviewed for compliance with regulations/policies.
Environmental Specialists and
District Environmental
Engineers
Responsible for reviewing changes in maintenance operations and
receiving input from District Maintenance and Operations Engineers
concerning facility operational changes that may be subject to
environmental regulation/policy. Provides regular updates to the
EMS/Sustainability Supervisor on the status of pending new
regulations, changes to existing regulations, or changes to facility
operations subject to regulation.
EMS/Sustainability Supervisor
Responsible for tracking and reviewing existing and proposed
regulations and policies. Provides regular updates to the Director of
Environmental Services on status of pending new regulations,
changes to existing regulations, or changes to facility operations
subject to regulation. Maintains current Environmental Requirements
List and ensures that the Environmental Requirements List is
incorporated into the facility audit protocol. Convenes/coordinates
the review of the Environmental Requirements List. Meets with
MassDEP regional office and policy staff to discuss pending
regulations that may affect MassDOT maintenance operations.
EMS Compliance Coordinators
Responsible for review of regulations and policies as directed by the
EMS/Sustainability Supervisor. Responsible for reviewing changes
in maintenance operations and receiving input from District
Maintenance and Operations Engineers concerning facility
operational changes that may be subject to environmental
regulation/policy. Provides regular updates to the EMS/Sustainability
Supervisor on the status of pending new regulations, changes to
existing regulations, or changes to facility operations subject to
regulation. Also, provide multi-media environmental compliance
support, training, and auditing for District facilities.
Supervisor of Wetlands and
Water Quality
Responsible for tracking and review of existing and proposed
regulations and policies related to wetlands, waterways, and natural
resource protection programs. Provides regular updates to the
EMS/Sustainability Coordinator on the status of pending new
regulations or changes to existing regulations.
Director of Environmental
Services
Ensures that the Environmental Requirements List is reviewed
periodically.
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4.0
Emergency Preparedness/Incident Response
This EMS component establishes the procedures for planning and responding to hazardous
materials or hazardous waste spills at MassDOT maintenance facilities and incidents along the
roadway.
4.1
Spills at Maintenance Facilities
The procedures for addressing spills at maintenance facilities are documented in two types of
written plans: (1) the Emergency Response Spill Plan (ERSP) for MassDOT Facilities which
establishes procedures for responding to minor and major spills at facilities, and (2) Spill
Prevention Control and Countermeasure Plans (SPCC Plans) developed for facilities that store
oil in quantities triggering the requirements for a written plan in accordance with 40 CFR 112.
Environmental Services conducts periodic reviews to identify changes in facility operations and
storage relative existing plans and updates plans when applicable. The procedures, roles and
responsibilities for managing the Emergency Preparedness component of the EMS are described
below.
4.1.1
Procedure
MassDOT has distributed the Emergency Response Spill Plan (ERSP) to all MassDOT facilities,
and a generic plan is available within the Facility Environmental Handbook. SPCC plans have
also been prepared for those facilities that require a SPCC plan. These plans assist MassDOT
personnel in preventing and responding to oil or hazardous material spills at facilities. Personnel
having responsibilities under these plans are provided with the necessary training to ensure they
are competent to fulfill the roles established in the plans.
Input from Operations and Maintenance staff assists MassDOT in revising the plans to be more
effective. Facilities have been supplied with emergency spill equipment for use in emergency
response. The District EMS Compliance Coordinators and Safety Inspectors regularly inspect
maintenance facilities to ensure that adequate spill supplies are available and information
contained in the plans is current. Inspections generally confirm the following for those facilities
that maintain hazardous waste or hazardous material storage areas:








Accessible telephone or two-way communication
Telephone number of the emergency coordinator
Telephone number of local fire and police
Telephone number of MassDEP
Accessible and portable fire extinguisher
Accessible spill clean-up equipment
Readily available water supply
Documentation that employees have been instructed in emergency response procedures
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4.1.2
Review and Update Procedures for Emergency Response Spill Plans
The ERSP for MassDOT facilities outlines roles, responsibilities, and procedures for responding
to oil and hazardous material spills. A generic ERSP applies for all maintenance facilities and is
included within the Facility Environmental Handbook. An ERSP for all Small and Large
Quantity Generators of hazardous waste has been developed in accordance with 29 CFR
1910.120 (q)(1) and SOP 3 Hazardous Waste Management for applicable facilities.
The ERSP has been distributed to all MassDOT maintenance facilities and is available for review
by facility personnel. In the event of an oil or hazardous material spill, MassDOT personnel
follow the procedures outlined in the ERSP including incident command structure, MassDOT
notification procedures, reporting of spills to regulatory agencies, and control and containment of
oil and hazardous material spills. The ERSP addresses two types of spill events, Minor and
Major. MassDOT personnel who receive the annual awareness training are deemed qualified to
clean-up a minor spill as defined in the spill plan. Generally, Minor spills are defined as those
that may result from the operation of an auto repair garage (e.g. accidental spills of motor oil
during oil changes, of less than 10 gallons). A Major spill event as defined by the ERSP may
require the attention of personnel trained under OSHA’s HAZWOPER Standard (29 CFR
1910.120) (greater than 10 gallons or a direct release to floor drain, catchbasin, or natural
resource). In the case of a Major spill, a qualified spill clean-up contractor may be dispatched to
the spill location to conduct the clean up.
Regular review of the ERSP for MassDOT facilities is necessary to ensure that the plan reflects
current operations at maintenance facilities. The ERSP is reviewed on a regular basis by the
EMS Compliance Coordinators to identify areas where updates and/or revisions are needed. The
EMS Compliance Coordinators ensure that the ERSP is distributed to the maintenance facilities
and incorporate any changes into the annual Environmental Awareness Training program.
4.1.3
Review and Update Procedures for SPCC Plans
The current regulatory threshold necessitating the preparation and maintenance of an SPCC Plan
is aggregate aboveground oil storage of greater than 1,320 gallons (within minimum 55-gallon
containers). An SPCC Plan is also required when underground storage of greater than 42,000
gallons exists at a facility. As a good management practice, MassDOT minimizes the storage
quantities of oil at facilities to mitigate the need for SPCC Plans, where feasible.
As of the date that this EMS Manual was developed, the Franklin (Central Stockroom), Weston
(South Avenue), and Boston CMF (370 D Street) facilities currently have oil storage triggering
the requirements for a written SPCC under 40 CFR 112. The SPCC Plan outlines oil storage at
the facility; spill pathways in the event of an oil spill; spill prevention; control and
countermeasure techniques; inspections of oil storage areas; emergency contacts; and spill
reporting procedures. Applicable personnel working at facilities with SPCC Plans are trained in
the procedures outlined in the plan to ensure competence when handling, transferring, and
responding to oil spills.
SPCC Plans must be updated every five years or whenever there is a change in facility design,
construction, operation or maintenance. As a good management practice, on an annual basis, the
EMS/Sustainability Supervisor and the EMS Compliance Coordinators review the SPCC Plans
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and oil storage practices to assess whether changes at the facility may warrant plan preparation
or revision. The Districts are also consulted relative to the need for the SPCC Plan changes. In
the event that revisions are needed, the EMS/Sustainability Supervisor will coordinate applicable
revisions to include the services of a Professional Engineer, if applicable. Upon certification, the
EMS Compliance Coordinators provide copies of the plan to the respective facilities and
incorporate any changes to the plans into the annual SPCC training. The EMS Compliance
Coordinators are responsible for keeping records to document the conduct of the annual SPCC
Plan review.
4.1.4
Roles and Responsibilities
The following table presents a summary of the roles and responsibilities for Emergency
Preparedness involving maintenance facilities. For specific roles, responsibilities, definitions,
review and update procedures, refer to the ERSP and the SPCC Plans.
Table 7
Emergency Preparedness Roles and Responsibilities for Spills –
Maintenance Facilities
Role
Responsibility
Highway Administrator
Endorses the Environmental Services’ preparation of Emergency
Response Spill Plan for MassDOT Facilities and SPCC Plans.
Chief Engineer
Supports the Emergency Response Spill Plan by allocating
resources to the Districts.
Deputy Chief Engineer of Safety and
Mobility
Supports the Emergency Response Spill Plan by participating in
the review of the plans, allocating personnel to conduct safety
inspections of facilities, and presenting Health and Safety training
sessions to District staff. Directs their staff to support spill
response as needed.
District Highway Director
Responsible for ensuring that District adheres to emergency
response procedures.
District Maintenance and Operations
Engineers or their designee
Responsible for notifying appropriate MassDOT personnel during
an emergency response.
Area Supervisor or Other Designee of
the District Highway Director
Serves as the Primary Emergency Coordinator for the ERSP and
SPCC Plan. Initiate spill response efforts and contacts the District
Maintenance Engineer upon notification of a spill.
Facility Supervisor or Other Designee of
the District Highway Director
Acts as the Secondary Emergency Coordinator for the ERSP and
SPCC Plan. The Secondary Emergency Coordinator assumes the
role of Primary Emergency Coordinator in the absence of the
Primary Emergency Coordinator. Also responsible for adhering to
the SPCC Plan.
District Safety Inspectors
Support the Primary Emergency Coordinator as needed. Initiate
and assist District in spill response efforts and reporting incident to
local emergency authorities.
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Role
Responsibility
Facility Personnel
Responsible for reporting a spill to the Primary Emergency
Coordinator and responding to spills under the direction of the
Primary Emergency Coordinator. Also responsible for adhering to
the ERSP and SPCC Plan requirements, if applicable.
EMS Compliance Coordinators
Prepare manifests and/or review manifests prepared by
contractors for spill response and communicate with appropriate
authorities following a spill event. Distribute the ERSP and SPCC
Plans to MassDOT facilities. Incorporate any emergency
preparedness changes into annual awareness training.
EMS/Sustainability Supervisor
Responsible for ensuring the EMS Compliance Coordinators
review the Emergency Response Spill Plan for MassDOT Facilities
on a regular basis. Ensures EMS Compliance Coordinators
review, revise, and reissue the ERSP and SPCC Plans, as
applicable.
Director of Environmental Services
Responsible for ensuring that the Emergency Preparedness
Component of the EMS remains current and effective.
4.2
Roadway Traffic Incidents
Response to incidents associated with roadway traffic on state roadways is documented in the
Unified Response Manual (URM) for Roadway Incidents which was developed and endorsed
(December 2006) by the Massachusetts Incident Management Task Force comprised of the
Massachusetts Highway Department, Massachusetts Turnpike Authority, Massachusetts
Emergency Management Agency, Massachusetts Department of Public Health, Massachusetts
Port Authority, Massachusetts Department of State Police, Fire Chiefs’ Association of
Massachusetts, Massachusetts Department of Environmental Protection, the Statewide Towing
Association and the Federal Highway Administration.
For the purposes of this EMS and as presented in the Unified Response Manual for Roadside
Incidents, the response by MassDOT personnel shall include performing first-on-scene duties
and assuming Incident Commander, if applicable, which would include an initial assessment of
potential environmental impacts. As documented within the URM, environmental response
actions that may be performed by MassDOT personnel are limited to the following:

Perform Initial Containment of a Petroleum Release using available means to stem or
reduce the flow of releases (petroleum products) and prevent access to sensitive
environmental receptors, catch basins, wetlands, and waterways.

Provide Sorbent Materials to dike releases of oil and hazardous materials (only when
hazards are known, and proper personal protective equipment is available) and to curtail
migration to sensitive environmental receptors.
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
Respond to Unknown Hazardous Materials such as spills of unknown material,
discovery of drums or other containers of unknown oil or hazardous materials. MassDOT
will follow applicable MassDOT SOPs for managing unknown materials.
Table 8
Emergency Preparedness Roles and Responsibilities for Spills – Roadway
Incidents
Role
Responsibility
Highway Administrator
Endorses the URM.
Chief Engineer
Provides the recommendation to endorse the URM.
Deputy Chief Engineer of Safety and
Mobility
Responsible for allocating personnel and resources to respond to
roadway incidents as described in the URM. Responsible for
participation in the review and update of the URM and attends
meetings with participating agencies. Identifies the need for
environmental assessment by the responsible party.
Director of Roadway Operations
Provides a copy of the draft URM to Environmental Services for
review and the recommendation to endorse the URM once all
comments have been addressed. Responsible for participation in
the review and update of the URM and attends meetings with
participating agencies. Responsible for incident response and
coordinating the notification of incidents.
District Maintenance
Engineer/Operations Engineer
Responsible for notifying appropriate MassDOT personnel during
emergency response, implementation of the URM and identifying
and reporting spills of oil and/or hazardous materials. Responsible
for participation in the review and update of the URM and attends
meetings with participating agencies.
District Maintenance Engineer, First-OnScene MassDOT Personnel or District
Safety inspectors
Responsible for contacting the Highway Operations Center and
the immediate supervisor and for implementing First-On-Scene
duties as identified within the URM. Responsible for providing
input during the review and update of the URM.
EMS Compliance Coordinators
Support the District in implementing the URM as needed.
Prepares/reviews manifests for spill response and submits spill
reports to appropriate authorities if necessary. Incorporate any
applicable emergency preparedness changes into annual
awareness training. Responsible for providing input during the
review and update of the URM.
EMS/Sustainability Supervisor
Reviews the URM and provides recommendations to improve
environmental performance.
Director of Environmental Services
Provides the recommendation to endorse the URM as it relates to
compliance with environmental requirements and provides support
to mitigate a release of oil and/or hazardous material.
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5.0
Standard Operating Procedures
This component documents the process of regular review, development, and revision of standard
operating procedures (SOPs) to support the EMS. SOPs define roles and responsibilities,
policies, and minimum performance criteria for managing environmental compliance-related
issues.
MassDOT is committed to routinely reviewing SOPs to ensure their appropriateness; revising
them on a regular basis; and developing new SOPs as needed to reflect regulatory and MassDOT
operational changes. Environmental Services performs SOP review and development, and
obtains all signatures needed for approval of SOPs applicable to this EMS. As part of this
process, Boston Headquarters and District Maintenance and Operations staff are responsible for
participating in reviewing existing and proposed SOP content to ensure that the procedures can
be implemented without undue impact on operations and available resources.
5.1
Identification of New SOPs and SOPs Requiring Revision
The EMS Compliance Coordinators, District Environmental Engineers, and Environmental
Specialists monitor regulations, policies, guidance documents, and Executive Orders that may be
applicable to MassDOT operations and monitor changes in activities that may warrant new or
revised SOPs. Additionally, District personnel notify their supervisor and their respective EMS
Compliance Coordinator and/or District Environmental Engineer of any anticipated changes to
activities that may pose a potential environmental compliance issue. Recommendations for new
or updated SOPs are submitted to the EMS/Sustainability Supervisor who ensures that the EMS
Compliance Coordinators prepare/revise SOPs, as applicable.
5.2
Development, Revision, Final Review and Endorsement of SOPs
The development or modification of SOPs is initiated by the EMS/Sustainability Supervisor who
instructs an Environmental Specialist or EMS Compliance Coordinator to develop a new or
revise an existing SOP with input from applicable MassDOT personnel. The draft SOP will be
submitted to the Director of Environmental Services who will then solicit input from and
applicable sections within MassDOT (the Chief Engineer/Operations and Maintenance section,
the Chief Engineer/Safety and Mobility, District Highway Directors, District Maintenance and
Operation staff and Environmental Services staff) during a designated comment period. The SOP
is revised to reflect the comments before forwarding to the Highway Administrator. The
Highway Administrator will endorse the SOP for dissemination throughout MassDOT.
5.3
Roles and Responsibilities
A summary of the roles and responsibilities for environmental SOP review and development is
provided in the following table.
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Table 9
Standard Operating Procedures Roles and Responsibilities
Role
Responsibility
Highway Administrator
SOPs are issued under the Highway Administrator’s
signature.
Chief Engineer
Review SOPs and provides recommendations for SOP
revisions.
Deputy Chief Engineer of Safety and
Mobility
Review SOPs and provides recommendation for
applicable SOP revisions and notifies Environmental
Services of any changes in operations that should be
reviewed for environmental compliance. Coordinate
input from District Safety Inspectors.
Operations Engineer and District
Maintenance Engineer
Review SOPs and provides recommendation for
applicable SOP revisions and notifies Environmental
Services of any changes in operations that should be
reviewed for environmental compliance.
Representatives of Maintenance,
Operations, and the Districts.
Review and provide input to Environmental Services
relative to SOP content, format and distribution.
EMS Compliance Coordinators,
Serve as the primary developers of SOP content.
EMS Sustainability Supervisor
Coordinates and directs the SOP development and
revision process.
Director of Environmental Services
Ensures EMS Compliance Coordinators review SOPs
on a regular basis
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6.0
Facility Environmental Handbook and Facility Plans
This EMS component provides a description of the roles and responsibilities for revising the
Facility Environmental Handbook and Facility Plans. The Facility Environmental Handbook and
Facility Plans are available electronically on the MassDOT Transnet website. CD-ROM copies
and hardcopies are available at MassDOT Headquarters in Boston, each of the District
Headquarters, and applicable facilities.
Facility Plans detail environmental information including, but not limited to, facility building
features, solid waste collection areas, wetlands, hazardous materials storage areas, utilities
related to water quality, aboveground and underground storage tank locations and associated
piping and pumps, and sheds for sand and salt storage.
Regular review and updates to the Facility Environmental Handbook and Facility Plans are
conducted to ensure that the text and graphical information reflect possible regulatory,
operational, or administrative changes. Environmental Services assume the lead in the update
and distribution of the Facility Environmental Handbook and Facility Plans. MassDOT also
relies upon these reference materials for use in its annual Environmental Awareness Training.
6.1
Procedure
The EMS/Sustainability Supervisor directs members of the Environmental Services staff to
review the Facility Environmental Handbook and recommend appropriate changes based on
current or proposed facility activities. During regular inspections of MassDOT facilities, EMS
Compliance Coordinators ensure that Facility Plans reflect current operating conditions at the
facilities. EMS Compliance Coordinators indicate any changes to operating conditions
(establishment of new solid waste collection areas, new hazardous waste collection areas, etc.)
on the Facility Plans during their audits/inspections. At the designated review appropriate
changes are made to the Facility Plans.
The EMS/Sustainability Supervisor collects and reviews the revisions made to the Facility
Environmental Handbook and Facility Plans before submitting draft copies to the Directors of
Operations and Maintenance, the District Highway Directors, and Environmental Services for
review and approval. Approved final versions of the Facility Environmental Handbook or
Facility Maps are distributed to MassDOT facilities. Additionally, the EMS/Sustainability
Supervisor provides an electronic version of the updated Handbook or Facility Plans to
Information Technology Enterprise Services for posting on the MassDOT Transnet web site.
6.2
Roles and Responsibilities
A summary of roles and responsibilities for the Facility Environmental Handbook and Facility
Plans review and revision process is provided on the following table.
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Table 10
Facility Handbook and Facility Map Review and Revision Roles and
Responsibilities
Role
Directors of, Maintenance, Operations, the
District Highway Directors, and
Environmental Services
Responsibility
Responsible for the review of the revised Facility
Environmental Handbook and Facility Plans prior to
distribution.
Operations Engineer, Maintenance
Engineer, and District Maintenance
Engineers and EMS Compliance
Coordinators
Review and provide comments on revisions to the
Facility Environmental Handbook. Responsible for
updating the Facility Plans to reflect any infrastructure
changes that have occurred in the facility.
EMS/Sustainability Supervisor
Coordinates and directs Facility Environmental
Handbook and Facility Map reviews and updates.
Responsible for posting the Facility Environmental
Handbook and Facility Plans onto the MassDOT
Transnet website.
Director of Environmental Services
Ensures that the current revision is distributed to
Facilities and Districts.
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7.0
Training
This EMS component establishes the procedures for identifying, planning, delivering, and
tracking training programs to support this EMS. The training is provided to MassDOT staff to
ensure that they understand their roles and responsibilities and can adequately perform their
duties to support the EMS. Training is provided to MassDOT employees through four primary
means:




Initial Right-to-Know Training provided by Highway Safety and Mobility;
Annual Environmental Awareness Training provided by Environmental Services staff;
Regulatory Specific Training provided with assistance from technically experienced
consultants; and,
Relevant training provided by other state agencies (i.e. DEP, Executive Offices of Energy
and Environmental Affairs) such as Massachusetts Contingency Plan, stage II vapor
recovery equipment, and sustainability.
All Boston Headquarters sections and Districts are responsible for identifying the personnel that
require training based upon job duties and how those duties relate to environmental compliance.
Environmental Services coordinates MassDOT’s current training needs to support the EMS but
relies upon input from all areas within MassDOT to ensure the training programs are funded and
remain current and applicable to MassDOT operations.
7.1
Procedure
Environmental Services, with assistance from Operations and Maintenance, trains the personnel
that have been selected for training according to their roles and responsibilities within the EMS.
Records of attendance are maintained by the employee's respective Boston Headquarters section
and/or District. The EMS/Sustainability Supervisor, or designee, conducts a regular review of the
Environmental Training Program to ensure the program is both current and relevant to MassDOT
facility operations.
7.2
Environmental Training Program Components
The following table provides a summary of the regulatory and best management practice
Environmental Training provided to MassDOT staff.
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Table 11
MassDOT Regulatory Required and Best Management Practices Training Program
Training
Regulation
Regulatory Requirement
Participants
Delivery
Hazardous
Waste
Awareness
Training
310 CMR
30.351(9)(g)
Employees having responsibility for handling/managing
hazardous waste at Small Quantity Generator and Very
Small Quantity Generator facilities must be properly trained
so they know how to perform their duties and so that
hazardous waste handling practices and emergency
procedures are performed properly and in compliance with
all applicable requirements. Employees are provided initial
training to a competency level with refresher training
annually.
District Maintenance Engineer,
Area Supervisor, HOV Facility
Personnel, Facility Supervisor,
Facility Personnel, and EMS
Compliance Coordinators
Training
provided during
annual
Environmental
Awareness
Training by EMS
Compliance
Coordinators
Universal Waste
Training
310 CMR
30.1035
Employees having the responsibility for handling or
managing universal waste shall be informed of the proper
handling and emergency procedures appropriate to the
types of universal waste handled at the facility. Employees
are provided initial training to a competency level with
refresher training annually.
District Maintenance Engineer,
Area Supervisor, HOV Facility
Personnel, Facility Supervisor,
Facility Personnel, and EMS
Compliance Coordinators
Training
provided during
annual
Environmental
Awareness
Training by EMS
Compliance
Coordinators
Department of
Transportation/
General
Awareness,
Manifest, and
Safety Training
Programs
49 CFR
172.704(a)
310 CMR
30.409
Each hazmat employee* shall be provided 1) general
awareness training designed to provide familiarity with the
requirements of this subchapter and to enable the
employee to recognize and identify hazardous materials
consistent with OSHA Hazard Communication Standard
(29 CFR 1910.1200). OSHA or EPA training may be used
to satisfy the requirements of 49 CFR 172.704(a) to avoid
duplication of training efforts. 2) function-specific training
concerning the requirements of the DOT hazardous waste
regulations specific to the function the employee performs.
3) Safety training concerning emergency response
information, measures for protection from the hazards
associated with hazardous materials and methods and
procedures for avoiding accidents. Employees are provided
initial training to a competency level with refresher training
every 3 years thereafter.
EMS Compliance Coordinators
and designated District personnel
Training
coordinated by
Environmental
Services and
conducted
through a
consultant
contract
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Training
Regulation
Regulatory Requirement
Participants
Delivery
Stage II Vapor
Recovery System
Inspection
Training
310 CMR 7.24
Persons performing Stage II systems weekly inspections
must be trained to inspect equipment including, but not
limited to, nozzle boots and splash/vapor guards, hoses,
hose retractors, coaxial adapters, dry breaks, fill caps,
vapor recovery caps, spill containment boxes and drain
valves. Employees are provided initial training to a
competency level with refresher training annually.
Area Supervisor, Facility
Supervisor, Laborers
Wetland
Resource
Management/
Stormwater
Management
310 CMR
10.00
Employees shall be trained in identifying wetland and
riverfront resource areas, buffer zones, stormwater
management. This training is provided biennially.
District Maintenance Engineer,
Area Supervisor, HOV Facility
Personnel, Facility Supervisor,
Facility Personnel, Maintenance
Personnel and EMS Compliance
Coordinators
Initial training is
provided by the
Director of
Roadway
Maintenance.
Refresher
training is
provided upon
request by EMS
Compliance
Coordinators.
Training by
Environmental
Services Wetlands
Spill Prevention
Control and
Countermeasure
(SPCC)
40 CFR
112.7(e)(10)
(iii)
Employees shall be trained in spill prevention and control
including applicable pollution control laws and the operation
and maintenance of equipment to prevent the discharges of
oil. Employees are provided initial training to a competency
level with annual refresher training.
Employees having a role in the
SPCC Plan for a facility
Emergency
Response Spill
Plan for Facilities
Training
Best
Management
Practice
Employees shall be trained to understand the roles and
responsibilities of Emergency Coordinators and
Responders; the notification procedures in the event of a
hazardous materials spill; the procedures for identification
and response to minor and major releases of hazardous
material; and the reporting requirements to regulatory
agencies for hazardous material releases. Employees are
provided annual training to a competency level.
Employees having a role in the
Emergency Response Spill Plan
for MassDOT facilities are
indicated on the individual call
sheets posted at the facilities.
Generally, the Facility
Supervisor, Area Supervisors,
Safety Inspectors, and the
District Maintenance have key
roles in responding to spills at
facilities
21
Training by EMS
Compliance
Coordinators or
Environmental
Services
contractor
Training
provided during
annual
Environmental
Awareness
Training by EMS
Compliance
Coordinators
Environmental Management System Manual
February 2012
Training
Regulation
Regulatory Requirement
Participants
Delivery
Asbestos
Awareness
Training
29 CFR
1910.1001
Employees who may be exposed to asbestos-containing
materials or presumed asbestos-containing materials shall
be provided an awareness training course. The course
includes the health effects of asbestos; locations, signs of
damage and deterioration of asbestos-containing materials;
and the proper response to a fiber release episode.
District Maintenance Engineer,
Area Supervisor, Facility
Supervisor, Facility Personnel,
EMS Compliance Coordinators,
and personnel reporting to
Operations in Boston: Franklin
Stockroom, Sign Shop, HOV
Facilities, and construction
personnel
Right-to-Know
454 CMR
21.07
Employees who may be exposed to toxic or hazardous
substances at the workplace shall be provided training on
employee rights, MSDS, specific substances stored and/or
handled at the workplace, explanation of toxicity, labeling,
and instruction on the proper personal protective
equipment (PPE) to be used when handling hazardous
substances. Employees receive initial competency training
with refresher training as necessary.
District Maintenance Engineer,
Area Supervisor, Facility
Supervisor, Facility Personnel,
EMS Compliance Coordinators,
and personnel reporting to
Operations in Boston: Franklin
Stockroom, Weston Warehouse,
Sign Shop, and HOV Facilities
Initial training
provided by
Asbestos
Coordinator.
Refresher
during Annual
Environmental
Awareness
Training by
EMS
Compliance
Coordinators.
Initial training
conducted by
Highway Safety
and Mobility.
Refresher
during Annual
Environmental
Awareness
Training by
EMS
Compliance
Coordinators.
Training
provided by
EMS
Compliance
Coordinators
District Structure Maintenance
Maintenance facility employees shall be trained on the
materials and procedures contained within the Facility
Engineer, Area Supervisor,
Environmental Handbook. Topics covered during this
Facility Supervisor, Facility
Personnel, EMS Compliance
Environmental Awareness Training include Hazardous
Coordinators, and the following
Waste, Universal Waste, Hazardous Materials, Solid
Waste, Salt Storage, Asbestos-containing Materials,
personnel reporting to Operations
Roadside Issues, Tanks, Water Quality, Wetlands, Record
in Boston: Franklin Stockroom,
Keeping, and Inspections. Employees receive annual
Sign Shop, and HOV Facilities
Facility Environmental Awareness Training to the
competency level.
*Note: The term “hazmat employee” as it relates to MassDOT operations, includes only personnel responsible for shipping (packaging, labeling,
manifesting) a RCRA hazardous waste and/or those employees who offer a DOT hazardous material to a private transporter (contractor).
Environmental
Annual
Awareness
Training
Best
Management
Practice
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7.3
Roles and Responsibilities
A summary of the roles and responsibilities for the Environmental Training Component is
provided below.
Table 12
Environmental Training Program Roles and Responsibilities
Role
Responsibility
District Highway Director,
District Maintenance and
Operations Engineer
Responsible for ensuring appropriate personnel attend environmental
training programs relative to their roles and responsibilities within the
EMS and maintaining training attendance records for District staff.
Directors of Maintenance
Operations, and
Environmental Services,
Responsible for ensuring appropriate personnel attend environmental
training programs relative to their roles and responsibilities within the
EMS and maintaining training attendance records.
EMS Compliance Coordinators
Develop and deliver the Annual Facility Environmental Awareness
Training program and SPCC training within their District and
participate in the annual review of the environmental training
program. Annually reviews the environmental training programs to
determine if regulatory or operational changes necessitate revisions
to the program and specify training materials to be included on the
MassDOT Transnet website.
Environmental Services –
Wetlands Unit
Develop and deliver the biennial Wetlands Resource
Protection/Stormwater Management Training.
EMS/Sustainability Supervisor
Responsible for the approval of training program content revisions
and ensures that the training program is delivered.
Director of Environmental
Services
Responsible for the Environmental Training Program and ensuring
that appropriate training materials are provided to applicable
MassDOT employees. Ensures appropriate Environmental Services
staff is available to present training programs.
Highway Safety and Mobility
Develops and presents the initial Right-to-Know Training.
All MassDOT Highway
Division Staff
Provide comment and guidance to Environmental Services, Highway
Safety and Mobility relative to the feasibility and content of
environmental training programs.
Information Technology
Posts EMS and related training onto the MassDOT Transnet website.
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8.0
Compliance Tracking and Auditing
This EMS component describes the procedures used by MassDOT to identify, correct, and track
environmental compliance information.
8.1
Compliance Tracking Components
Compliance information is generated by three typical methods: scheduled audits, regular facility
inspections, and observations during routine facility operations. By identifying and tracking
compliance information, MassDOT enhances its ability to remain in compliance with its legal
and regulatory obligations. Procedures and additional guidance information on inspections can
be found in the Facility Environmental Handbook and MassDOT SOP #31. Procedures and
guidance for conducting environmental compliance audits are further discussed in the following
sections and in the Audit Protocol Field book.
8.1.1
Audits
The Audit Program is designed to adhere to the guidelines presented in MassDEP’s Policy on
Incentives for Self-Policing: Environmental Audit Policy (ENF-97-004) and the Policy on
Incentives for Self-Policing: Environmental Self Audit Policy Addendum for State Agencies
(ENF-05-001). Audits are conducted at a rate of approximately 20 percent of the total number of
facilities per year. Therefore, all target facilities are typically audited over a 5-year period.
Information regarding regulatory non-compliance identified during audits is documented in
Audit Findings Reports, which the auditor submits to the Audit Coordinator promptly following
audit visits. The Audit Coordinator enters all regulatory non-compliance findings into the
Executive Office of Energy and Environmental Affairs (EOEEA) Clean State Database within
21 days of discovery. All regulatory non-compliance findings must be resolved within 60 days of
discovery. Audit records are maintained by the Audit Coordinator at the Environmental Services
office in Boston.
8.1.2
Facility Inspections
Facility inspections are performed by MassDOT personnel in accordance with the applicable
SOP using the Facility Environmental Compliance Inspection Report. The recommended
minimum inspection frequency for facilities is quarterly for maintenance facilities, fueling
facilities, stockrooms or warehouses, District Headquarters and drawbridges, and semi-annually
for strictly snow & ice facilities. Facility personnel also perform weekly inspections Hazardous
Waste accumulation areas.
These regular inspections provide a means to gather compliance information on a more frequent
basis as compared to formal audits. The results of these inspections are communicated to the
District Maintenance Engineer who facilitates the correction of any out-of-compliance issues.
Corrections are coordinated between the District Maintenance Engineer, Area Supervisor,
Facility Supervisor, and the EMS Compliance Coordinator. The results of these inspections and
the documented corrections are maintained at the District headquarters. If the EMS Compliance
Coordinator determines the compliance issue warrants entry into the EOEEA Clean State
Database, the EMS Compliance Coordinator reports the compliance issue to the
EMS/Sustainability Supervisor.
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8.1.3
Routine Facility Observations
MassDOT personnel are expected to keep facilities neat and adhere to good housekeeping
practices. Furthermore, facility personnel are expected to report issues that may pose a potential
compliance issue to their supervisor and/or to the EMS Compliance Coordinator. Examples of
potential issues that should be reported include identification of storage of materials in nondesignated areas, missing spill equipment, spills, or dripping fluids from containers and/or
equipment.
8.1.4
Correcting Out-of Compliance Issues
Routine non-compliance issues that are identified through Audits, Facility Inspections or Routine
Facility Observations are generally corrected within 60 days of their discovery. Simple
corrections, such as replacing a label or closing a container, are typically resolved immediately.
Compliance tracking and written justification via the EOEEA Clean State Database are required
for corrective actions that need greater than 60 days to complete.
8.1.5
Tracking Compliance Issues
The EMS/Sustainability Supervisor receives regular updates from the EMS Compliance
Coordinators regarding regulatory non-compliance issues that require correction at facilities.
This information is gathered during regular facility inspections. The EMS Compliance
Coordinators also oversee regulatory non-compliance issues that require intervention by
Environmental Services. For each issue reported to the EOEEA Clean State Database, the EMS
Compliance Coordinator and the District Maintenance Engineer develop a corrective action plan.
The corrective action plan is documented on a Corrective Action Plan Report, which the District
Maintenance Engineer signs to certify commitment to the plan. Upon completion of the planned
corrective action, the EMS Compliance Coordinator signs the Corrective Action Plan Report to
certify that the violation has been corrected and submits it to the Audit Coordinator for updating
the EOEEA Clean State Database.
8.1.6
Roles and Responsibilities
A summary of the roles and responsibilities for the Compliance Tracking Component is provided
in the following table.
Table 13
Compliance Tracking Roles and Responsibilities
Role
Responsibility
District Highway Directors,
District Maintenance and
Operations Engineers
Responsible for ensuring non-compliance issues are properly
addressed and corrected by facility personnel.
EMS Compliance Coordinators
Perform regular inspections and scheduled audits to identify issues of
non-compliance at facilities. Ensure proper review of weekly
inspection reports (hazardous waste storage areas, Stage I/II vapor
recovery systems, etc) or other regularly required compliance
documentation completed by the Area Supervisors, the Facility
Supervisors and or Facility staff. Tracks corrective action efforts.
Reports repetitive non-compliance to District Maintenance and
Operations Engineers and/or EMS/Sustainability Supervisor.
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Role
Responsibility
Reports any operational changes or observed activity in the District
affecting compliance status to District Maintenance and Operations
Engineers and/or EMS/Sustainability Supervisor.
EMS/Sustainability Supervisor
Responsible for managing audit participants in the execution of their
duties associated with identifying, tracking, and correcting issues of
non-compliance. Communicates repetitive non-compliance issues
and potential compliance issues with the Director of Environmental
Services.
Director of Environmental
Services
Ensure the audit program remains current. Communicates repetitive
issues of non-compliance, observed activity in the District affecting
compliance status, and potential compliance issues to the Deputy
Chief of Operations and Maintenance.
Audit Program Coordinator
Maintains audit schedule and other records and enters/updates
compliance issues in the EOEEA Clean State Database.
8.2
Audit Program Implementation
The Audit Program is intended to evaluate environmental compliance at MassDOT Maintenance
Facilities and track a facility’s return to compliance through corrective action implementation.
The Protocol is designed to reflect the compliance themes contained in the Facility
Environmental Handbook across eight major compliance areas covering multi-media federal and
state environmental regulatory programs, MassDOT SOPs, and best management practices
(BMPs). Because it is designed to identify and correct environmental compliance matters, the
Audit Program is a critical component of MassDOT’s EMS.
MassDOT is committed to keeping the Audit Protocol current. The Audit Program and Protocol
are reviewed on a regular basis to identify areas where updates and/or revisions are needed due
to either regulatory or operational changes. Review of the Audit Program is necessary to ensure
continual improvement and ensure that the Audit Protocol reflects current regulations, SOPs, and
facility operations.
8.3
Audit Program Roles and Responsibilities
A summary of the roles and responsibilities for the Audit Program is provided below.
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Table 14
Audit Program Roles and Responsibilities
Role
Responsibility
District Highway
Directors, District
Maintenance
Engineers and
Operations Engineer
The District Highway Directors, Maintenance Engineers and Operations
Engineers are responsible for facility operational activities, including
compliance with environmental regulations and MassDOT SOPs. With regard
to the Audit Program, the District Maintenance Engineers and Operations
Engineer are responsible for assisting with the scheduling and directing
facility staff to participate in Audits and to perform Corrective Actions.
Facility Supervisors
and facility staff
The Facility Supervisors and facility staff are responsible for day-to-day facility
operations-related environmental activities, as described in the Facility
Environmental Handbook. With regard to the Audit Program, the Facility
Supervisor and facility staff are responsible for representing the facility during
Audits and assisting with Corrective Actions.
Audit Coordinator
The Audit Coordinator oversees the Audit Program. The Audit Coordinator is
responsible for: developing an annual auditing schedule; designating Lead
Auditors; modifying the Audit Checklist and Protocol on a regular basis to
incorporate changes in environmental regulations and MassDOT SOPs;
reviewing Corrective Action Plans developed by the EMS Compliance
Coordinators and Facility Supervisor for Program consistency and timeliness;
monitoring progress of Corrective Actions; entering regulatory noncompliance issues into the EOEEA Clean State database; updating Clean
State matters to justify corrective actions needing greater than 60 days to
complete and to request delisting of corrected matters; and coordinating and
directing Audit Program review and revision.
Lead Auditor
The Lead Auditor will typically be an EMS Compliance Coordinator from a
District other than the audited facility’s District. The Lead Auditor is
responsible for: notifying the EMS Compliance Coordinator of the impending
Audit; completing the Audit Checklist and field documents; leading the Site
Visit phase of the audit; completing an Audit Findings Report (AFR) and
summary memorandum.
EMS Compliance
Coordinators
The EMS Compliance Coordinator serves as the District’s liaison to federal,
state, and local environmental agencies with respect to environmental
compliance issues and is responsible for facility environmental compliance
that is outside the day-to-day operational control of facility staff. The EMS
Compliance Coordinator is responsible for notifying the District Maintenance
Engineer and Facility Supervisor of an impending audit; providing compliance
records for review during audits; assisting with the conduct of the audits;
assuming Lead Auditor role when assigned by the Audit Coordinator;
assisting the Facility Supervisor in the implementation of Corrective Actions;
completing or managing Corrective Actions outside the operational control of
the Facility Supervisor and/or District Maintenance Engineer; developing
Corrective Action Plans for unresolved regulatory non-compliance; follow-up
coordination, tracking, and reporting on the status of Corrective Action Plan
implementation; and completing the audit Corrective Action Plan Report. Also
responsible for providing assistance to the Audit Coordinator with updating
the Audit Checklist and Protocol on a regular basis to incorporate changes in
environmental regulations and MassDOT SOPs; and ensuring audits are
performed in accordance with the Audit Program. The EMS Compliance
Coordinator provides comment on revisions to the Audit Program procedures.
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Role
Responsibility
EMS/Sustainability
Supervisor
Approves entries into the EOEEA Clean State Database.
Director of
Environmental
Services
Ensures that the Audit Program remains current and effective.
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9.0
Maintenance Activities
MassDOT has recently expanded the focus of the EMS from primarily a facilities-based program
to also incorporate requirements, processes, and procedures for limiting adverse environmental
impacts and promoting environmental stewardship while conducting maintenance activities.
Although current SOPs, handbooks, and training programs exist within MassDOT for this
purpose, the inclusion of applicable maintenance activities will provide the framework to define
individual responsibilities and enable accountability with respect to environmental management.
The EMS expansion into maintenance activities includes, but is not limited to, the following
MassDOT activities:

Roadway and shoulder repair maintenance activities

Drainage maintenance activities

Roadside maintenance activities

Structure maintenance activities

Traffic control device maintenance and repair
An Environmental Scope Review (ESR) process has been developed to identify and address
potential environmental management issues associated with conducting certain routine or
planned maintenance activities. The environmental issues most often identified by the ESR
process will be work within/near wetland or riverfront resource areas, management of hazardous
materials, generation of potentially hazardous wastes, and handling contaminated soil. Therefore,
this expansion of the EMS into maintenance activities has focused upon these areas.
9.1
Environmental Scope Review Process
The ESR process is initiated by Maintenance personnel prior to conducting certain routine or
planned maintenance activities. The ESR process involves submission of a locus plan and scope
of work to the District Environmental Engineer (DEE) or the District designee for screening of
potential environmental issues associated with a planned work activity and location. Based on
the initial screening, the DEE or District designee determines if a more thorough evaluation is
required (possibly involving Environmental Services) and/or if a regulatory filing or notification
may be required prior to conducting the scope of work. The DEE or District must properly
document whether the proposed scope of work requires permitting, notifications and/or further
environmental review. This determination is readily available to all field personnel and to the
applicable Local, State, or Federal authorities upon request.
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An ESR is required for all applicable maintenance work beyond the paved road surface and for
the following activities associated with roadway maintenance:




9.2
Work within wetland/riverfront resources areas, buffer zones OR the work has the
potential to impact these areas
Planned use of hazardous materials
Possible generation of hazardous waste or uncharacterized wastes
Excavation work in potentially contaminated areas
Wetland and Riverfront Areas
The Wetlands Protection Act and its regulations (310 CMR 10.00) are commonly relevant during
maintenance activities since wetlands and surface water bodies are often located proximate to
roadways and roadway structures. MassDOT has developed the Storm Water Handbook for
Highways and Bridges (see also Section 10.2) to assist in managing this process. Certain
activities are exempt from review under the Wetlands Protection Act (and other environmental
permitting requirements) if certain criteria are met. Under the EMS, proposed maintenance
activities that may be subject to the Wetlands Protection Act or other environmental permitting
requirements are reviewed by the DEE or District designee through the ESR process followed by
appropriate action in accordance with applicable regulations, policies and SOPs.
9.3
Hazardous Materials/Waste Management and Contaminated Areas
When anticipated usage of hazardous materials, the generation of potential hazardous wastes,
and/or excavation may be conducted within a contaminated area are possible on a maintenance
project, this information is communicated to the DEE or the District designee through the ESR
prior to the initiation of work. The DEE or District designee, with the assistance from the EMS
Compliance Coordinator, is responsible for developing the required management procedures for
hazardous materials and/or hazardous wastes as applicable for the scope of work.
9.4
Development of Maintenance Activities SOPs
The expansion of the EMS into maintenance activities includes the development of new SOPs
that define roles and responsibilities, policies, and minimum performance criteria for managing
environmental compliance-related issues. The following SOPs, which relate to maintenance
activities, have recently been developed:



Environmental Scope Review for Maintenance Projects (SOP 34)
Routine Maintenance of Drainage Structures on Roadways and Facilities (SOP 35)
Emergency Response to Roadway Flooding (SOP 36)
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9.5
Maintenance Activities Roles and Responsibilities
A summary of the roles and responsibilities for the Maintenance Activities is provided below.
Table 15
Maintenance Activities Roles and Responsibilities
Role
Responsibility
District Highway
Director
Responsible for overseeing the overall implementation of the EMS within the
District.
Maintenance,
Operations, Facility,
and Bridge
Engineer(s)
Responsible for integrating environmental compliance and sustainability practices
within Maintenance, Operations, Facilities, and Bridges and into all contracts
under their control, and ensure that related personnel responsibilities are
communicated to the Districts. Also, ensure that the ESR process is conducted for
all applicable maintenance projects; applicable environmental notifications are
made; applicable environmental permits are communicated to and followed by
their staff; and maintenance work is not performed prior to consideration of the
ESR process.
Director of
Environmental
Services
Responsible for providing support to the District upon request and also providing
regular comprehensive training to the Districts. The areas of training relevant to
the ESR process must include but are not limited to the following:
Wetland/Riverfront Resource Protection and Permitting, Stormwater Management
Regulations and Permitting, Hazardous Materials/Waste Awareness, and
Excavation in Contaminated Areas.
District
Environmental
Engineer (or District
designee)
Responsible for performing ESRs for proposed maintenance activities. The DEE is
also responsible for preparing required Wetlands Protection Act filings and
notifications. For unique environmental issues, permits, filings or other compliance
issues that require further review, evaluation, or assistance, the DEE consults with
the EMS Compliance Coordinators or others within Environmental Services for
assistance. The DEE is responsible for fully communicating the details of the
applicable permit(s) and work limits to the appropriate District personnel. The DEE
is responsible for conducting random inspections of maintenance projects to
ensure compliance with applicable permits and SOPs; the results of these
inspections are forwarded to the appropriate District and Environmental Service
personnel.
EMS Compliance
Coordinators,
Environmental
Services
EMS Compliance Coordinators and others within Environmental Services (i.e.
Wetlands Unit) assist the DEE with unique environmental issues, permits, filings or
other compliance issues when assistance is needed. The EMS Compliance
Coordinators are responsible for conducting random inspections of maintenance
projects to ensure compliance with applicable permits and SOPs; the results of
these inspections are forwarded to the appropriate District and Environmental
Service personnel.
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10.0 Stewardship, Sustainability and Pollution Prevention
10.1
MassDOT’s GreenDOT Policy Directive, “Leading By Example” and
Environmentally Preferable Products and Services
10.1.1
GreenDOT
GreenDOT is the Massachusetts Department of Transportation’s sustainability initiative.
“The Massachusetts Department of Transportation will be a national leader in promoting
sustainability in the transportation sector. Through the full range of our activities, from strategic
planning to construction and system operations, MassDOT will promote sustainable economic
development, protect the natural environment, and enhance the quality of life for all of the
Commonwealth’s residents and visitors. This will enable MassDOT to use resources in a manner
that serves its existing customers while preserving our resources for future generations.”
The following three mutually-reinforcing goals form the foundation of GreenDOT:



Reduce greenhouse gas (GHG) emissions
Promote the healthy transportation modes of walking, bicycling, and public transit
Support smart growth development
10.1.2
Executive Orders
Executive Order 484 (Leading By Example: Clean Energy and Efficient Buildings) was
introduced on April 18, 2007 and establishes goals for reductions in greenhouse gas emissions,
energy use and water use as well as increased procurement of energy from renewable resources
for all Commonwealth agencies. Also, Executive Order 484 further mandates the implementation
of green building practices for all new construction and major renovations. MassDOT is
committed to implementing programs and practices that will further advance sustainability and
energy efficiency.
Executive Order 515 (Establishing an Environmental Purchasing Policy) was introduced on
October 27, 2009 and requires agencies to procure Environmentally Preferable Products and
services (EPPs) whenever such products and services are readily available, perform to
satisfactory standards, and represent best value.
10.2
MassDOT’s Stormwater Management Program
Stormwater runoff from MassDOT roads within urban areas and runoff from construction
activities are regulated by National Pollution Discharge Elimination System (NPDES)
stormwater discharge permits issued by the United States Environmental Protection Agency (US
EPA). These permits require that MassDOT minimize to the extent practicable the impact of
stormwater discharges on receiving waters by requiring best management practices (BMPs).
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MassDOT’s multi-faceted Stormwater Management Program consists of six minimum control
measures that minimize the potential impact of stormwater discharges:






Public Education and Outreach
Public Participation and Involvement
Illicit Discharge Detection and Elimination
Construction Site Runoff Control
Post-Construction Site Runoff Control
Pollution Prevention and Good Housekeeping
Activities undertaken pursuant to the six minimum control measures are documented in the
NPDES Annual Report submitted to the USEPA and MassDEP every April.
10.2.1
MassDOT Stormwater Handbook
All MassDOT construction and improvement projects are designed and implemented in
accordance with the MassDOT Storm Water Handbook for Highways and Bridges. This
MassDEP-approved guidance was written for project developers and maintenance personnel to
ensure compliance with MassDEP’s Stormwater Handbook and provides guidance for the
selection of stormwater runoff controls for maintenance and construction site activities.
10.2.2
Impaired Waters Program
MassDOT has proactively committed to identifying water bodies that receive highway runoff
and are classified as “impaired” in MassDEP’s Listing of the Condition of Massachusetts’
Waters (referred to as the 303(d) list). Under this program, MassDOT assesses whether
stormwater from MassDOT highways and facilities is reaching an impaired water body; whether
such stormwater is potentially contributing to the impairment; and eliminate the effectiveness of
existing BMPs at treating runoff from the roadways. In the event that existing BMPs are
inadequate, MassDOT will design and construct additional BMPs.
10.2.3
Illicit Discharge Detection and Elimination (IDDE) Program
MassDOT’s IDDE Program is designed to identify and eliminate non-stormwater and/or illicit
discharge to the MassDOT stormwater system. When an illicit discharge is identified, MassDOT
attempts to identify the responsible party and eliminate the discharge. MassDOT is focusing the
IDDE Program on areas where illicit discharges may be more likely and in areas with water body
impairments more commonly associated with contributions from illicit discharges (e.g., areas
with pathogen impaired water bodies).
10.2.4
Environmental Status and Planning Report (ESPR)
The Massachusetts Office of Environmental and Energy Affairs (EOEEA) requires MassDOT to
prepare an Environmental Status and Planning Report (ESPR) to examine the effects
MassDOT’s Snow and Ice Control Program has on the environment, improve long range
planning, and identify efficient and effective snow and ice operations. The ESPR replaces the
Generic Environmental Impact Report (GEIR).
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MassDOT’s Snow and Ice Control Program seeks to maintain an acceptable balance between the
benefits of controlling snow and ice on mobility, public safety, and the economy of the
Commonwealth with the environmental consequences and taxpayer costs of spreading salt and
other deicing materials. The ESPR requires that MassDOT evaluate and update their Best
Management Practices (BMPs) for improving road salt storage, use and efficiency. Current
BMPs include:








Permanent salt storage structures
Designated reduced salt zones
Training on policies and procedures
Equipment improvements to improve efficiency, accuracy and uniformity in anti-icing
and deicing application
Enhanced weather forecasting information improving the efficiency of mobilizing
equipment and timing of road salt applications
Formal management oversight and reporting procedures
Pre-wetting and anti-icing procedures
Alternative deicing materials and technologies.
10.2.5
Other Stormwater Management Program Efforts
MassDOT is also implementing other stormwater management programs to support pollution
prevention and environmental stewardship:

Research Efforts - MassDOT funds research to improve the understanding of highway
stormwater management. For example, MassDOT funded a U.S. Geological Survey
pollutant loading study. This effort generated data on the ranges of pollutant
concentrations in roadway runoff under various conditions and provided MassDOT
critical insight into where to best focus its efforts to reduce stormwater pollution.

Stormwater Training: MassDOT funds training programs through the MassDOT
Baystate Roads Program (Baystate) and the Massachusetts Training Assistance Program
(MTAP). These programs provide training to municipal DPW and MassDOT staff,
respectively, and include workshops and seminars addressing stormwater management,
as well as wetland protection, hazardous waste management and other operational issues.
10.3
Vegetation Management Program
The MassDOT Vegetation Management Program is intended to establish the criteria whereby
MassDOT controls vegetation along state roads and highways in compliance with the Rights of
Way Management Regulations (333 CMR 11.00) as promulgated by the Massachusetts
Department of Food and Agriculture. Under this regulatory program, MassDOT has prepared
5-Year Vegetation Management Plans (VMP) and Yearly Operational Plans (YOP) for
Vegetation Management. The provisions of MassDOT’s current VMPs are summarized below.
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10.3.1
Integrated Roadside Vegetation Management
MassDOT's VMP incorporates Integrated Roadside Vegetation Management (IRVM) methods
which include roadside development (active planting to encourage appropriate competing
vegetation and non-organic barriers), mechanical (mowing, hand cutting, and selective
trimming), and chemical (low volume foliar herbicide treatments). One goal of the VMP is to
minimize the use of chemical controls, through minimizing areas of application, quantity of
chemicals, and frequency of application.
10.3.2
Identifying and Protecting Sensitive Areas
Sensitive areas are defined as areas within rights-of-way in which public health, environmental,
or agricultural concerns warrant special protection to further minimize risks of adverse effects
from chemical herbicide applications and include public groundwater supplies, public surface
water supplies, private drinking water supplies, surface waters, wetlands, rivers, inhabited areas,
and agricultural areas.
10.3.3
Alternatives to Chemical Herbicide Study
MassDOT, in collaboration with the Federal Highway Administration, funded a research project
at the University of Massachusetts seeking alternatives to Chemical Herbicides for Roadside
Weed control. With the assistance of the Department of Soil Sciences at the University of
Massachusetts, MassDOT tested alternative chemicals and non-conventional control methods.
This study has been published and is available on-line form MassDOT. MassDOT continues to
consider alternative methods and materials to reduce reliance on pesticides, and will integrate
appropriate new methods into the VMP and YOP. Other methods for management of roadside
vegetation under guardrails include hand mowing, steaming, flaming, mulching with organic
materials, and mulching with sheeting made from recycled products such as tires or plastic
bottles.
10.4
Bridge Section
The MassDOT Bridge section is responsible for overseeing the design and for monitoring the
condition of MassDOT and municipally owned highway bridges in the Commonwealth.
MassDOT maintains both fixed and movable bridge structures. The Bridge section consists of
Operations, Project Development, Consultant Design and In-House Design. Bridge rehabilitation
preservation and inspection promotes a longer life cycle of the structure. While doing so, it is
important to monitor potential impacts to the environment from releases of potentially hazardous
material to air, water, and soil that could occur if best practices to control the work are not
followed. It is the responsibility of the Bridge section to ensure that contractors under its control
follow permit conditions and best practice procedures while conducting maintenance. This is
important while conducting repairs and painting on older structures that may be coated in leadbased paint. Also, movable structures (draw bridges) may have tender houses that store oils and
greases and may have drainage systems for sanitary discharges.
10.5
Pollution Prevention
MassDOT follows the Mass DEP Toxics Use Reduction Act (TURA) Planning Requirements to
evaluate methods to reduce risk and improve the overall environmental quality at MassDOT
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facilities through toxic use reduction. Environmental Services personnel in cooperation with
designated District personnel spearhead the pollution prevention efforts.
MassDOT supports in-house efforts to research environmentally preferable products intended to
minimize waste, conserve energy and water, and reduce the amount of toxics disposed or utilized
by construction, maintenance, and facilities operations. MassDOT continues to undertake inhouse efforts to prevent pollution through conservation and reduction programs relating to
construction and maintenance projects as well as activities at maintenance facilities. Ongoing
pollution prevention initiatives include, but are not limited to, the following:
10.5.1
Water Pollution Prevention
MassDOT has installed indoor vehicle wash bays at several maintenance facilities. Vehicle
washing is also conducted under an SOP that regulates surface discharges that could result in
adverse environmental impacts.
10.5.2
Toxics Use Reduction
Environmental Services personnel in cooperation with designated District personnel have
conducted real world evaluations of new products and recommended reduction of the following
substances: petroleum-based hydraulic and lubricating oils; automotive parts cleaning solvents
and associated cleaning systems; and miscellaneous automotive lube/cleaning products. In
response to these recommendations, MassDOT switched to non-chlorinated solvent brake
cleaner and automated oil and grease dispensing equipment; eliminated solvent parts cleaner
tanks in some districts; and reduced automotive fluid use through the leasing and out-servicing of
fleet vehicles. MassDOT has undertaken pollution prevention efforts through conservation and
reduction programs relating to construction projects as well.
10.5.3
On-going Initiatives
On-going pollution prevention initiatives relative to the operation of MassDOT maintenance
facilities include:
Table 16
On-going Pollution Prevention Initiatives
Media
Initiatives
Air Pollution Prevention
Fleet inspections to ensure vehicle emissions
compliance; and installation of vapor recovery systems
for underground storage tanks. Continuous review of
facility operations, such as vehicle painting, to ensure
regulatory compliance.
Energy Conservation
Installation of high efficiency lighting systems.
Solid Waste Source Reduction
Waste reductions have been realized through the
expanded use of recycled and re-manufactured
products including the construction of salt sheds
composed of 50% recycled plastic aggregate.
A study entitled “Street Sweeping Reuse at MassDOT –
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Media
Initiatives
Barriers, Economics and Opportunities” identified
possible re-use options for street sweepings and catch
basin cleanings.
Toxics Use Reduction
MassDOT has conducted real world evaluations of
products and made recommendations for reduction of
the following substances: petroleum-based hydraulic
and lubricating oils; automotive parts cleaning solvents
and associated cleaning systems; perchlorethylene
cleaning solvent and miscellaneous automotive
lube/cleaning products.
In response to these recommendations, MassDOT
switched to non-chlorinated solvent brake cleaner;
eliminated solvent parts cleaner tanks in some Districts;
and, reduced automotive fluid use through the leasing
and out-servicing of fleet vehicles.
10.5.4
Future Goals
While much has been accomplished, MassDOT will continue to identify, evaluate, and
implement pollution prevention initiatives. Pollution prevention opportunities and activities
under limited implementation (pilot study) or consideration include:
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Minimizing or eliminating solvent parts cleaners statewide;
upgrading all maintenance garages to include state-of-the-art automated oil dispensing;
use of vegetable-based diesel fuels to reduce heavy equipment air emissions;
purchasing low volume high pressure washers for vehicle/equipment cleaning to reduce
water use;
purchasing aqueous brake cleaning systems to eliminate all brake chlorinated solvent use
and eliminate asbestos dust hazards;
use of enclosed bead/sand blasting cabinets to reduce use of solvents and toxic cleaners;
rust-proofing heavy equipment hydraulic fittings to reduce failure and resulting hydraulic
fluid releases;
use of vegetable-based hydraulic oil;
use of neutral pH, non-oil emulsifying vehicle degreasing/washing detergents to
eliminate caustic detergents and improve effectiveness of oil/water separators;
identifying specific areas within a given project for experimental or full usage of new
products comprised of solid waste materials;
developing specifications and special provisions for incorporating recycled materials into
construction projects;
developing and tracking test applications of recycled products and materials to document
product effectiveness relative to standards for highway performance and environmental
acceptability;
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investigating and implementing economically viable opportunities to reuse and recycle
solid and hazardous waste generated by routine operations such as waste oil, street
sweepings, catch basin cleanings, tires, construction and demolition debris, special waste,
scrap metal, and wood waste;
active participation of the Research Needs Committee to identify potential programming
and funding opportunities;
provide input of needed material reuse and recycling research efforts and to keep up to
date on new recycling and reuse technologies, regulations and activities successfully
utilized by industry and other state transportation departments;
working with state agencies and other organizations to develop training and educational
workshops on the use of recycled materials;
actively participating with state and federal regulatory agencies on Beneficial Reuse
policies;
investigating energy conservation technologies in new buildings and building upgrades;
and,
evaluating options for centralized purchasing/distribution of materials to eliminate
purchase of certain hazardous substances.
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11.0 EMS Review
This EMS component establishes the procedures for reviewing the overall effectiveness of the
EMS. MassDOT’s EMS review is a dynamic process designed to ensure that the EMS adapts to
regulatory and operational changes that affect environmental compliance and full integration of
the EMS into MassDOT activities.
11.1
Procedure
Regular review of the EMS is essential to its success. The procedure for review of the EMS
includes a periodic formal review by designated MassDOT personnel. The purpose for the
formal review is to assess if organizational, operational and/or regulatory changes necessitate a
revision or update to the EMS. Additional review of the EMS may also be conducted by an
external EMS consultant. Recommended changes to the EMS are presented to the Director of
Environmental Services for review followed by review by the MassDOT management team, as
applicable. This process ensures all levels of the organization provide comment on the success of
the EMS and its individual components.
11.1.1
EMS Formal Reviews
The EMS/Sustainability Supervisor coordinates a formal review of the EMS and EMS Manual
on an as needed basis. Input on the EMS and EMS Manual is solicited from designated
MassDOT representatives from the Chief’s Office, Environmental Services, Maintenance,
Operations, and the Districts. The purpose of the formal review is to provide input relative to the
overall EMS effectiveness and program implementation; success in relation to EMS objectives;
and integration into MassDOT operations. In addition, conclusions and/or recommendations
gleaned from the review of in-house compliance audits are considered during the formal review.
The EMS/Sustainability Supervisor maintains records of the observations, conclusions, and
recommendations from all of MassDOT personnel and presents recommendations, corrective
actions and implementation strategies such as new or revised SOPs or training made during the
formal review and prepares a summary report (EMS Review Report) for use by the Director of
Environmental Services. The Director of Environmental Services either implements applicable
recommendations based on the immediate need or brings the recommendations forward to the
management team for their consideration, if warranted.
11.1.2
MassDOT Management Team Review
The MassDOT management team (Chief Engineer’s office, designated Deputy Chief Engineers,
statewide Directors and District Highway Directors) participation in the EMS review process
ensures that individuals responsible for the establishing and implementing policy are directly
involved in monitoring the progress of the EMS. The management team review of the EMS is
crucial to successful implementation of the EMS and it subsidiary compliance programs. The
management team must use this opportunity to review relevant EMS-related issues and
recommendations for policy or procedural changes that ensure continued improvement to the
EMS.
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11.1.3
EMS Review Roles and Responsibilities
A summary of the EMS review roles and responsibilities is provided below.
Table 17
EMS Review and Evaluation
Role
Responsibility
Chief Engineer, Deputy Chief Engineers,
District Highway Directors
Participate in the review of the EMS.
Directors of Maintenance, Operations,
District Highway Directors
Responsible for reviewing and assessing compliance with
the EMS and participating in the review of the EMS.
Director of Environmental Services
Responsible for ensuring that the EMS review is conducted
and recommendations are reviewed and implemented.
EMS/Sustainability Supervisor
Coordinates EMS review meeting. Prepares the draft EMS
to include recommendations for review by the Director of
Environmental Services and management team.
Designated MassDOT Highway Division
Personnel
Participate in EMS review process. Provide comments on
EMS effectiveness and make recommendations for
improvements.
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Appendix A. MassDOT Environmental Services Contacts
Environmental Services
Director
Kevin M. Walsh
617-973-7484
Deputy Director
David White
617-973-7577
EMS/Sustainability Supervisor
Steven Miller
617-973-8248
Audit Coordinator
Katherin McArthur
617-973-8409
District 1 EMS Compliance Coordinator
David Abbott
413-637-1750
District 2 EMS Compliance Coordinator
Douglas Spink
413-584-1611
District 3 EMS Compliance Coordinator
Michael Giando
508-929-3865
District 4 EMS Compliance Coordinator
Kenneth Leach
781-641-8473
District 5 EMS Compliance Coordinator
Gregory Fulgione
508-884-4362
District 6 EMS Compliance Coordinator
Vacant
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Appendix B – Information Sources and MassDOT – Highway Division Programs
Reference documents that support MassDOT’s EMS are listed below. Copies of the documents
are available on the MassDOT Transnet or may be obtained from Environmental Services.
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Asbestos Operation and Maintenance Manual
Facility Environmental Handbook
Facility Plans
MassDOT Environmental Standard Operating Procedures (SOP Index on next page)
Environmental Compliance Audit Checklist
Audit Protocol Fieldbook
Audit Environmental Compliance Audit Checklist
Weekly Hazardous Waste Storage Area Checklist
MassDOT Snow and Ice Control Environmental Status and Planning Report
Vegetation Management Plan
NPDES Phase II Stormwater Management Plan
MassDOT Sustainability Plan
Unified Response Manual for Roadway Traffic Incidents
Emergency Response Spill Plan
Massachusetts Highway Department Project Development and Design Guidebook
Herbicide Alternatives Research
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February 2012
STANDARD OPERATING PROCEDURES (SOP) INDEX:
SOP 01 Environmental Compliance SOPS
SOP 02 Materials Safety Data Sheet Management
SOP 03 Hazardous Waste Management
SOP 05 Used Vehicle Battery Disposal
SOP 06 Handling, Storage and Disposal of Compressed Gas Cylinders
SOP 07 Universal Waste Management
SOP 08 Management of Sand and Deicing Chemicals
SOP 10 Disposal of Animal Carcasses
SOP 11 Hazardous Materials Management
SOP 12 Temporary Storage of Solid Waste
SOP 15 Wetland Resource Protection
SOP 16 Groundwater Monitoring Well Maintenance
SOP 17 Maintenance of Subsurface Sewage Disposal Systems
SOP 18 Maintenance of Wastewater Holding Tanks
SOP 19 Inspection and Maintenance of Stormwater Catch Basins
SOP 20 Outdoor Operation/Maintenance Equipment Storage
SOP 22 Vehicle Washing
SOP 25 Roadside Unknown Waste Handling
SOP 27 Inspection and Maintenance of Oil/Water Separators
SOP 28 Inspection and Repair of Stage I and Stage II Recovery Systems
SOP 29 Management of Asbestos Containing Materials
SOP 31 Performing Facility Environmental Compliance Inspections
SOP 32 Contractors’ Use of Facilities
SOP 33 Beaver Dam Control
SOP 34 Environmental Scope Review of Maintenance Projects
SOP 35 Routine Maintenance of Drainage Structures
SOP 36 Emergency Response to Roadway Flooding
SOP 37 Operation of Waste or Used Oil Space Heaters
SOP 38 Inventory Control for Underground Storage Tanks
ENV-01-01-1-000
ENV-01-02-1-000
ENV-01-03-1-000
ENV-01-05-1-000
ENV-01-06-1-000
ENV-01-07-1-000
ENV-01-08-1-000
ENV-01-10-1-000
ENV-01-11-1-000
ENV-01-12-1-000
ENV-01-15-1-000
ENV-01-16-1-000
ENV-01-17-1-000
ENV-01-18-1-000
ENV-01-19-1-000
ENV-01-20-1-000
ENV-01-22-1-000
ENV-01-25-1-000
ENV-01-27-1-000
ENV-01-28-1-000
ENV-01-29-1-000
ENV-01-31-1-000
ENV-01-32-1-000
ENV-01-33-1-000
ENV-01-34-1-000
ENV-01-35-1-000
ENV-01-36-1-000
ENV-01-37-1-000
ENV-01-38-1-000
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February 2012
Appendix C – State Environmental Regulations
State Law/Regulation
Subject
MGL c. 111 § 2B-2C; § 31C; § 142A142M; 150A-B
310 CMR 7.00
Air Quality
Air pollution control regulations
310 CMR 7.01
Causing or contributing to a condition of air pollution
310 CMR 7.02
Air Plan Approval permits, Restricted Emission Status
310 CMR 7.03
Plan Approval exemption construction requirements
310 CMR 7.04
Maintenance and testing of fuel burners
310 CMR 7.05
Fuel restrictions – sulfur, ash, and additives – fuel supply records
310 CMR 7.06
Opacity/smoke density limits for fuel burner emissions
310 CMR 7.07
Open burning of combustible material
310 CMR 7.09
Construction and demolition causing or contributing to air pollution
310 CMR 7.10
Causing or contributing to a condition of noise pollution
310 CMR 7.11
Motor vehicle emission standards (idling vehicles)
310 CMR 7.12
Source Registration
310 CMR 7.15
Asbestos
310 CMR 7.18
Volatile organic compound emission limits and controls
310 CMR 7.24
Vapor control for organic material storage – Stage I and Stage II
MGL c. 21C
310 CMR 30.0000
Hazardous Waste Management
Massachusetts hazardous waste management regulations
310 CMR 30.060 - 064
Notification procedures
310 CMR 30.253
Waste oil storage and disposal
310 CMR 30.302
Determination of whether a waste is hazardous
310 CMR 30.303
Generator registration
310 CMR 30.351
310 CMR 30.353
310 CMR 30.310
Hazardous waste management for VSQG and SQG
Manifests
310 CMR 30.330
Record Keeping
310 CMR 30.750
Land Disposal Restrictions
310 CMR 30.320
Pre-transport requirements
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February 2012
State Law/Regulation
Subject
310 CMR 30.1000
Disposal of universal waste
MGL c. 22, §§ 2 & 14
MGL c. 30, § 30
MGL c. 146, § 22
MGL c. 148, § 9 – 38E
MGL c. 21E
Storage Tanks and Equipment
527 CMR 4.00
Oil burning equipment
527 CMR 5.00
527 CMR 6.00
O&M of buildings/structures/garages/service stations for gasoline
or other motor fuel storage/use
LPG containers and systems
527 CMR 8.00
Transportation of combustible liquids
527 CMR 9.00
Tanks and containers
527 CMR 9.05
310 CMR 80.01 & 80.02
Leak detection, Inventory monitoring, Tightness testing, Upgrading,
and Corrosion protection for USTs
General provisions: Abandoned USTs, Tank removal, Registration
and permitting of tanks
UST Operator Training & Certification
MGL c. 21E
MGL c. 21H
310 CMR 40.0000
Waste Site Cleanup
Massachusetts Contingency Plan
310 CMR 40.0000 Subpart C
Reporting of hazardous material releases
310 CMR 40.0000 Subpart E
Assessment and cleanup of hazardous material releases
310 CMR 40.0000 Subpart J
310 CMR 40.0300
Maintenance of Response Action Outcomes & Activity and Use
Limitations
Management of remediation wastes
310 CMR 40.0400
IRA, RAM, URAM procedures
MGL c. 21A, §§ 2 and 8
MGL c. 111 § 150A-150A1/2
Solid Waste Management
310 CMR 16.00
Site assignment regulations for solid waste facilities
310 CMR 16.05
Applicability and conditionally exempt operations
310 CMR 16.06
Prohibitions
310 CMR 19.000
Solid waste management regulations
310 CMR 19.003 & 19.013
Applicability and exemptions
310 CMR 19.014 - 19.016
Prohibitions on open dumps, dumping grounds and un-permitted
facilities - post closure use restrictions
Closure of Un-permitted Waste dumps
527 CMR 9.07
310 CMR 19.021
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February 2012
State Law/Regulation
Subject
MGL c. 21 § 26-53
MGL c. 111, § 17 – 160
MGL c. 83 § 11
MGL c. 131, § 40
St. 1984, c. 372§ 40 6(e) & 8(m)
St. 1987, c. 307
St. 1991, c.41
MGL c.142, § 13
310 CMR 15.00
Water Pollution Control;
Underground Injection Control
Septic systems: Title 5
310 CMR 27.00
Underground water source protection: Class V injection Wells
314 CMR 2.00
General Permitting
314 CMR 3.00
Surface water discharge permit program
314 CMR 5.00
Ground water discharge permit program
314 CMR 7.00
Sewer system extension and connection permit program
314 CMR 18.00
Industrial wastewater holding tanks
314 CMR 19.00
Oil Spill Prevention & Response Regulations
360 CMR 10.00
Massachusetts Water Resources Authority (MWRA)
248 CMR 2.00
Uniform state plumbing code
MGL c. 131 § 40
MGL c. 30 §§ 61-62H
MGL c. 91
MGL c.6A § 2-7
MGL c. 21A, § 4A
Wetlands Protection Act
Massachusetts Environmental Protection Act (MEPA)
Wetlands and Waterways;
Water withdrawals
310 CMR 9.00
Waterways
310 CMR 10.00
Wetlands
301 CMR 12.00
Areas of Critical Environmental Concern
301 CMR 20.00-21.00
Coastal Zone Management Program
321 CMR 10.00
Endangered Species Act Regulations
321 CMR 8.00
Endangered Wildlife and Wild Plants
950 CMR 71.00
Historic Commission
301 CMR 11.00
Massachusetts Environmental Policy Act (MEPA)
321 CMR 2.14
Problem Animal Control (Beavers)
MGL c. 40, 111, 114, 140, 165
Drinking Water Supply
310 CMR 22.00
Drinking water protection: Public water supply wells – cross
connection program
Environmental Management System Manual
February 2012
State Law/Regulation
Subject
MGL c. 149 §§ 2, 5, & 6
MGL c. 111 §§ 2 – 5P
105 CMR 410.000
Asbestos & Radiation
Maintenance of asbestos-containing materials
453 CMR 6.00
Licensing and protection of asbestos workers
310 CMR 7.09;
310 CMR 7.15
310 CMR 19.061
Demolition/renovation of asbestos containing materials
Disposal of asbestos waste
105 CMR 122.000
Fixed facilities which generate electromagnetic fields
453 CMR 4.00
Ionizing radiation
453 CMR 5.00
Non-Ionizing radiation
Vegetation Management
333 CMR
Pesticide Board
330 CMR 9.00
Plant Pest Control
MGL c. 111F
MGL c. 21I, §§ 3, 10, 11, and 12
105 CMR 670.000
Right to Know
Massachusetts right-to-know law
310 CMR 33.00
454 CMR 21.00
Community right-to-know: Filing of Material Safety Data Sheets
with DEP
Employee right-to-know
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February 2012
Appendix D – Federal Environmental Regulations
Federal Regulation
Subject
40 CFR 61
National Emission Standards for Hazardous Air Pollutants (NESHAPs)
(Asbestos)
Ozone depleting substances (ODS)
Air Quality
40 CFR 82
Federal hazardous Waste Regulations
40 CFR 266 Subpart G
40 CFR 311- (29 CFR
1910.120)
40 CFR 355
40 CFR 370*
Spent Lead-Acid Batteries Being Reclaimed
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) – Emergency Planning and Right-to-Know Regulations
Worker Protection – hazardous waste operations and emergency response
Emergency planning and notification – CERLCA extremely hazardous
substances reportable quantities (RQs)
Hazardous chemical reporting: Community right-to-know – MSDS and Tier
reports
Water Quality
40 CFR 110
Discharge of Oil
40 CFR 112
Spill prevention control and countermeasure plans (SPCC)
40 CFR 122
National Pollutant Discharge Elimination System (NPDES)
40 CFR 300
National oil and hazardous substances pollution contingency plan – Notification
of Releases to NRC
General pretreatment standards for existing and new sources of pollution
40 CFR 403
33 CFR 320-330
US Army Corps of Engineer Regulations (Massachusetts Programmatic General
Permit)
Wildlife
50 CFR 17.00
Federal Endangered Species Act
40 CFR 761
49 CFR 106, 107, 110, 130,
171-180
Toxic Substances Control Act (TSCA)
Manufacturing, processing, distribution in commerce, and use of PCBs and PCB
items
Department of transportation (DOT)
Regulations for Shipping and Receiving Hazardous Materials
Coast Guard
33 CFR 114-115
*
Voluntary participation
US Coast Guard Protection of Navigable Waters
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February 2012
Appendix E – MassDEP Policies & Guidance Documents
DEP Policy Number
Subject
BWP-94-015
Policy for Industrial Wipers Contaminated with Solvents
BWP-89-02
Policy for Contractors with Hazardous Waste
HW-93-02
Policy for the Management of Used Oil Filters
BWP/DHW-92-01
Policy for the Disposal of Lighting Ballasts from Fluorescent Lights Containing
PCB Impregnated Capacitors
Waste Management Guidance for Industrial Wipers and Sorptive Minerals
Contaminated with Waste Oil
Reuse and Disposal of Street Sweepings
BWP/DHW-92-02
BWP-94.092
ABC Guide (rev 2/2000)
DWSG97-1
Guide to Regulations for Using or Processing Asphalt, Brick and Concrete
Rubble
Management Requirements for Hazardous Waste Batteries intended for
Recycling
Guideline on Deicing Chemical (Road Salt) Storage
BRPG01-01
Snow Disposal Guidelines
ENF-05-001
Policy on Incentives for Self-Policing: Environmental Self Audit Policy Addendum
for State Agencies
ENF-97-004
Policy on Incentives for Self-Policing: Environmental Audit Policy
MassDEP Fact Sheet (4/2004)
Management of Catch Basin Cleanings
BMP (4/2004)
On-Site Class A Recycling Guidance
(http://www.mass.gov/dep/recycle/approvals/oscarpkg.pdf)
MassDEP Fact Sheet (3/2005)
Safe Handling of Waste Oil for Burning in Space Heaters
(http://www.mass.gov/dep/recycle/laws/spacehtr.pdf)
MassDEP Municipal
Compliance Fact Sheet
(6/2007)
Municipal Compliance Fact Sheet: Stormwater
(http://www.mass.gov/dep/water/laws/mc_stormw.htm)
MassDEP Guidance (09/2010)
Guidance for Emergency repairs in Wetland Resource Areas or Buffer Zones, &
Waterways (http://www.mass.gov/dep/water/laws/2010eg.htm)
BWP-95-005
Environmental Management System Manual
February 2012
Appendix F – Executive Orders
Executive Order No.
Subject
484
Leading By Example – Clean Energy and Efficient Buildings
515
Establishing an Environmental Purchasing Policy
Environmental Management System Manual
February 2012
Appendix G – EMS Responsibilities Schedule Summary
Role
MassDOT Management
Team
Responsibility
Schedule
Participate in review of the EMS.
As needed
Director of Environmental
Services
Reviews recommendations and updates of the EMS Manual and
EMS as provided by the EMS/Sustainability Supervisor with respect
to new regulations, changes to existing regulations, or changes to
facility operations subject to regulation.
As needed
EMS/Sustainability
Supervisor
Conducts periodic reviews and updates of the EMS Manual and
compliance tools including Facility Plans, Facility Environmental
Handbooks, Standard Operating Procedures, Audit Program,
Emergency Response Spill Plans, and Spill Prevention Control and
Countermeasure Plans. Review the environmental training
programs to determine if regulatory or operational changes
necessitate revisions to the program
As needed
Convenes/coordinates a formal review of the EMS and reports the
result of the review for the Director of Environmental Services.
As needed
Provides regular updates to the Director of Environmental Services
on status of pending new regulations, changes to existing
regulations, or changes to facility operations subject to regulation.
As needed
Performs regular review of the audit program and recommends
modifications in accordance with changes in MassDOT’s
operations.
As needed
Prepares facility audit schedule.
Annually
Supervisor of Wetlands and
Water Quality
Provide regular updates to the EMS/Sustainability Supervisor on
the status of pending new regulations or changes to existing
regulations.
As needed
Environmental Specialists
and District Environmental
Engineers
Provide regular updates to the EMS/Sustainability Supervisor on
the status of pending new regulations, changes to existing
regulations, or changes to facility operations subject to regulation.
As needed
EMS Compliance
Coordinators
Provide regular updates to the EMS/Sustainability Supervisor on
the status of pending new regulations, changes to existing
regulations, or changes to facility operations subject to regulation.
As needed
Participate in the review and update of the EMS.
As needed
Audit Coordinator
Environmental Management System Manual
February 2012
Role
Responsibility
Schedule
Develop and deliver the Annual Facility Environmental Awareness
Training program.
Annually
Conduct or participate in facility inspections and audits.
As needed
Participate in the review of the environmental training program.
As needed
District Personnel
Assigned District personnel participate as EMS Task Members for
the review and update of the EMS.
As needed
Highway Safety and Mobility
Present annual Right-to-Know training for maintenance personnel.
Annually