FACILITY ENVIRONMENTAL
AUDIT PROGRAM
HAZARDOUS WASTE | UNIVERSAL WASTE | HAZARDOUS MATERIALS | ASBESTOS CONTAINING MATERIALS | SOLID WASTE
ROADSIDE ISSUES | TANKS | WATER QUALITY | WETLANDS | RECORD KEEPING | INSPECTIONS
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 1
Table of Contents
1.0
2.0
Introduction ..................................................................................... 2
1.1
Facility List ......................................................................... 2
1.2
Audit Schedule .................................................................... 2
1.3
Audit Team ......................................................................... 3
Self-Audit Procedure ...................................................................... 3
2.1
Pre-audit .............................................................................. 3
2.2
Audit Site Visit ................................................................... 4
2.3
Post-audit ............................................................................ 5
3.0
Environmental Requirement List .................................................... 6
4.0
Environmental Compliance Audit Checklist .................................. 7
List of Attachments
A.
Audit Facility List
B.
Audit Schedule
C.
Information Resources and Records Review List
D.
Audit Checklist
E.
Audit Finding Report Form
F.
Corrective Action Plan Report Form
G.
Environmental Requirement List
H.
Standard Operating Procedures
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 2
1.0
Introduction
Environmental compliance auditing is a component of The Massachusetts
Department of Transportation (MassDOT)’s Environmental Management
System (EMS). MassDOT’s EMS is summarized in the MassDOT EMS
Manual which can be accessed on the MassDOT intranet. Procedures for
periodic review and revision of the Environmental Compliance Audit
Program are provided in the EMS manual.
This Environmental Compliance Audit Program Fieldbook is intended to
assist MassDOT in self-identifying and correcting environmental
compliance issues at MassDOT maintenance facilities. The Environmental
Compliance Audit Program Fieldbook details the audit procedures and
provides audit forms, the Environmental Requirements List, the
Information Resources and Records Review List, and the Audit Checklist
as attachments.
1.1
Audit Facility List
Environmental compliance audits will be conducted at the MassDOT
facilities that appear on the Audit Facility List. Included on the list are
highway maintenance depots, snow & ice depots, special operation
facilities, and drawbridges. The Audit Facility List may be updated as
needed based upon changes in facilities’ operational status. The Audit
Facility List is presented in Attachment A.
1.2
Audit Schedule
All facilities on the Audit Facility List will be audited over a five-year
cycle, with approximately 20% of the total number of facilities audited
annually. The First Cycle audits will be conducted from 2008 to 2012, the
Second Cycle will take place between 2013 and 2017, and so on.
A general Master Schedule accounting for all the facilities on the Audit
Facility List will be produced at the beginning of each Cycle. The Master
Schedule is a template to be used for generating specific yearly audit
schedules that will be issued at the beginning of each calendar year
throughout a cycle. The yearly audit schedules will give the date, time,
facility name and address, and the Auditor assigned to perform each audit.
If a scheduled audit is canceled, than a rescheduled audit must be
conducted within 30 days of the original scheduled date. The Audit
Schedule is presented in Attachment B.
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 3
1.3
Audit Team
The Audit Team will be comprised of four individuals, including the Audit
Coordinator, the Auditor, a Facility Representative, and an EMS
Compliance Coordinator (ECC).
The Audit Coordinator is a person from the Environmental Services Division
assigned to oversee the Environmental Compliance Audit Program. The
Audit Coordinator is responsible for updating the Audit Facility List,
producing the Audit Schedule, tracking completion of audit documentation,
maintaining audit records, and making entries to the Clean State Database.
The Auditor is an ECC from a district other than that district where the
audited facility is located. The Auditor is responsible for making
observations and inquiries about activities conducted at the audited facility
in order to determine compliance with applicable Environmental
Requirements at the audited facility.
A Facility Representative is a person from the district where the audited
facility is located who is familiar with the operation of the audited facility.
The Facility Representative is responsible for providing access to all areas
of the audited facility and for answering questions regarding activities
conducted at the audited facility.
The ECC is a person from the Environmental Services Division who has
been assigned to coordinate a district’s efforts to comply with MassDOT’s
EMS. The ECC is responsible for providing information and
documentation regarding compliance with applicable environmental
requirements at the audited facility.
2.0
Audit Procedure
The Environmental Compliance Audit Procedure consists of three phases:
pre-audit, audit, and post-audit. The process for conducting each audit
phase is described below.
2.1
Pre-audit
Prior to the beginning of the calendar year, the Audit Coordinator develops a
proposed yearly audit schedule, using the Master Schedule as a template.
The proposed yearly audit schedule is forwarded to the ECCs, who consult
the District Maintenance Engineers (DMEs) for acceptance of the proposed
audit schedule. The Audit Coordinator makes changes requested by the
ECCs and DMEs and issues the yearly audit schedule.
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 4
At least two weeks prior to the audit site visit, the ECC contacts the DME to
verify that a Facility Representative will be present, and the ECC ensures
that all applicable facility records (e.g. waste manifests, permit conditions,
fuel inventory records and as built plans) will be made available for review.
Also in advance of the audit site visit, the Auditor obtains information
regarding the facility to be audited, including a copy of the Facility Plan, preexisting Clean State Matters, underground storage tank registration and MCP
site status.
2.2
Audit Site Visit
Initial Briefing. For the benefit of the Facility Representative the Auditor
conducts an introductory meeting to (1) inform personnel of the purpose
of the audit; (2) inform facility personnel of their responsibilities and
required participation in the audit and (3) to answer any questions that
facility personnel may have regarding the audit.
Walkthrough. Accompanied by the Facility Representative and the ECC,
the Auditor conducts a facility walkthrough to inspect all areas of the
facility and to make observations regarding the activities conducted at the
facility. The Auditor uses an Environmental Compliance Audit Checklist
to prompt examination of specific regulatory compliance programs and to
record field notes of observations. Interviews of facility personnel may be
conducted to ensure that the scope of facility operation has been
understood and verified by the Auditor.
Records Review. Following the walkthrough, the Auditor reviews
applicable facility records provided by the ECC. The Auditor may request
additional documentation that may be needed to evaluate compliance. The
Records Review List is presented as Attachment C.
Audit Checklist. Following the walkthrough and records review, the
Auditor completes the established Environmental Compliance Audit
Checklist, which serves to document environmental findings identified
during the audit, confirm regulated activities and act as a quality control
and assurance tool for ensuring that applicable regulatory compliance
program programs are reviewed during the audit. The Audit Checklist is
presented as Attachment D.
Exit Briefing. Based on the site walkthrough, records review, and
completed Audit Checklist, the Auditor discusses the audit findings and
responsibilities for correcting a violation with the Facility Representative
and the ECC.
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 5
2.3
Post-audit
Audit Findings Report. If the Auditor has findings to report, then within
3 days of conducting the audit site visit, the Auditor completes a typed
Audit Findings Report (AFR) in Word document format and e-mails a
signed electronic version to the ECC and the Audit Coordinator. The AFR
shall include a summary of each finding, a regulatory citation and/or SOP
reference, and a recommended corrective action. The AFR may also
include the Auditor’s recommendation for implementation of Good
Management Practices at the facility. The Audit Coordinator enters all
reported regulatory violations, as a new matter, into the Clean State
Database within twenty-one days of discovery. A copy of the Audit
Finding Report form is presented as Attachment E.
Facility Audit Reports. Within 14 days of the audit site visit, the Auditor
provides an Audit Report, via e-mail or inter-office mail, to the Audit
Coordinator. The Audit Report should include the following:
•
Cover memorandum summarizing the audit findings
•
Signed Audit Checklist (original or scanned)
•
Signed Audit Finding Report (if applicable; original or scanned)
•
Audit finding notes and photographs
Corrective Action Plan Report. Within 14 days of the audit site visit the
ECC prepares a separate Corrective Action Plan (CAP) Report for each
regulatory violation identified on the AFR. The District ECC works with
the DME to establish a CAP and records it on the CAP Report. The DME
signs the CAP Report to certify agreement with and commitment to
executing the CAP. At the end of the 14-day period, an electronic copy of
the CAP Report is e-mailed to the Audit Coordinator for entry into the
Clean State Database. A copy of the Corrective Action Plan Report is
presented in Attachment F.
A CAP must be implemented and completed within 60 days of discovery
of the regulatory violation (i.e. the audit site visit). When the corrective
action has been completed, the ECC signs the CAP Report to certify that
the violation has been corrected. The completed CAP Report with both
the DME’s and the ECC’s signatures is submitted to the Audit
Coordinator, along with supporting documentation, by the end of the
sixty-day correction period.
If the CAP is implemented and completed within 60 days of discovery, the
Audit Coordinator updates the Clean State Database and submits to DEP a
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 6
request for de-listing of a regulatory finding from the Clean State
Database. If the CAP cannot be completed within the 60-day period, the
EMS Coordinator provides written justification on the CAP Report and the
Audit Coordinator updates the Clean State Database to include the written
justification.
Upon its completion, the original CAP Report(s) with signatures will be
added to the Facility Audit Report by the Audit Coordinator to finalize the
documentation.
A summary of the timelines described in the preceding sections for
conducting audits and follow-up activities is provided below.
Table 1
Environmental Compliance Audit Process Timelines
Responsible
Person
Activity
Timeline
Develop Schedules, Assign Auditors and
Notify EMS Coordinators
Audit Coordinator
Notify DME to ensure availability of Facility
Representative and documentation at audit
Complete and forward Audit Findings Report
(AFR) to EMS Coordinator and Audit
Coordinator
Complete and forward Facility Audit Report
to Audit Coordinator
Work with DME to develop a CAP. Record
CAP on the CAP Report and forward an
electronic version (with DME’s signature) to
Audit Coordinator for entry into Clean State
Database.
Assist with and monitor performance of
CAP, and finalize CAP Report with signature
when the CAP is completed.
ECC
Master Schedule at beginning of each new Cycle;
Yearly Schedules at beginning of each year in a Cycle.
At least two weeks before audit site visit date.
Auditor
Within 3 days of audit site visit date.
Auditor
Within 14 days of audit site visit date.
ECC
Within 14 days of audit site visit date.
ECC
Within 60 days of audit site visit
3.0
Environmental Requirements List
The Environmental Requirements List identifies federal and state
environmental regulations and policies, as well as Standard Operating
Procedures (SOPs), which are applicable to MassDOT facilities. The list
covers a wide variety of environmental compliance areas including Air
Quality, Hazardous Materials and Hazardous Waste, Tanks, Waste Site
Clean-up (21E) and Solid Waste Landfill Closure, Water Quality,
Wetlands, and Asbestos. The Environmental Requirements List is a
component of MassDOT’s EMS. Procedures for review and revision of
the Environmental Requirements List are described in MassDOT’s EMS
January 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Page 7
Manual. The Environmental Requirements List is presented as Attachment
G, and SOPs are presented as Attachment H.
4.0
Environmental Compliance Audit Checklist
The Requirements List was used as a basis for the development of the
Environmental Compliance Audit Checklist. The Checklist consists of a
structured series of questions organized by environmental media to aid the
auditors in evaluating compliance status at MassDOT maintenance
facilities. Regulatory and SOP references are provided to assist auditors in
post-audit regulatory research. Sections of the Checklist include:

Hazardous Waste

Water Quality

Hazardous Materials

Natural Resource Areas

Solid Waste

Pollution Prevention

Roadside Issues

Air Quality

Storage Tanks

Environmental
Management
January 2011
Audit Facilities List (Updated: December 2012)
District 1
Facility #
1
2
3
4
5
6
7
City/Town
Lenox
Becket
Buckland
Address
270 Pittsfield Road (Route 7A)
98 Washington Road (Route 8)
1 Creamery Avenue (Route 2)
Dalton
Goshen
Huntington
Lee
229 Orchard Road
USMC League Highway (Route 9)
Worthington Road (Route 112)
435 Pleasant Street (Route 102)
Facility #
8
9
10
City/Town
North Adams
Otis
Pittsfield
M1 - Lee
M2 - Blandford
Sheffield
Williamstown
Lee
Blandford
Address
590 Ashland Street(Route 8A)
298 North Main Road (Route 8)
77 Central Berkshire Boulevard (Route
41)
1269 North Main Street (Route 7)
900 New Ashfield Road (Route 7)
239 Marble Street
3 Old Chester Road
11
12
172
173
District 2
Facility #
13
14
15
16
17
18
20
22
23
24
City/Town
Northampton
Athol
Belchertown
Bernardston
Deerfield
Erving
Northampton
Orange
Palmer
Springfield
Address
North King Street
Route 32 (Petersham Road)
Route 9 (Ware Road)
Route 10 (Northfield Road)
Route116
Route 2 (Mohawk Trail)
Route 5 (Mt. Tom Road)
Route 122
Route 20
Magaziner Street
Facility #
25
26
27
28
120
121
174
175
176
177
City/Town
South Hadley
Westfield
West Springfield
Winchenden
Granby
Ware
Chicopee
Westfield
Warren
Palmer
Address
Route 33
Route 20 (East Main Street)
2 Ashley Avenue
Route 202 (Baldwinville Road)
Route 116
Route 32
240 Fuller Road
Sgt. T.M. Dione Way
Brimfield Rd. (Rt. 9)
146 Thorndike Road
M3 - Chicopee
SPB - Westfield
M4 - Warren
Toll Plaza 08 - Palmer
Address
403 Belmont Street
Swanson Road at Route 495
Route 20
Route 140 at Route 495
West Elm Street
Mechanic Street
Route 2 at Underpass
Route 2 at Railroad Bridge
Route 146
West Main Street
Route 9
Depot Road
Route 122A
Route 12
Chocksett Road
Routes 20 & 131
Boston Post Road
Facility #
46
47
48
49
50
122
123
124
125
165
166
167
178
179
180
181
192
City/Town
Townsend
Upton
Uxbridge
Westford
Westminister
Boylston
Framingham
Hudson
West Brookfield
Worcester
Marlborough
Spencer
Charlton
Auburn
Westboro/Hopkinton
Southborough
Sturbridge
Address
New Fitchburg Road
Route 140
Route 146
Route 225
Routes 140 & 2
Route 140
Route 9
Routes 62 & 495
Route 9
Cambridge Street
Route 290 at Route 495
Route 9
Route 90/Sturbridge Road
85-89 Bancroft St
Route 90/Wood Street
115 Woodland Road
Routes 90 & 84
SPB - Charlton
M5 - Auburn
SA 6AW - Hopkinton
SPB - Southborough
Sturbridge salt shed
Address
519 Appleton Street
Route 125 & Prospect Street
Crosby Road
Topsfield Road
Grant Avenue
Route 4 north of Route 3
Facility #
70
73
74
75
76
77
City/Town
Manchester
Newbury
Peabody
Reading
Reading
Revere
Address
Pine Street off Route 128
Scotland Road
Route 1
Route 28 at Route 128
Route 129 at Route 93
745 Washington Avenue
District 3
Facility #
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
City/Town
Worcester
Boxboro
Charlton
Franklin
Hopkinton
Lancaster
Littleton
Littleton
Millbury
Millbury
Northboro
Oxford
Rutland
Sterling
Sterling
Sturbridge
Sudbury
District 4
Facility #
51
52
53
58
60
61
City/Town
Arlington
Andover
Bedford
Boxford
Burlington
Chelmsford
Page 1 of 3
62
63
65
66
67
Concord
Concord
Haverhill
Ipswich
Lawrence
68 Lawrence
69 Lexington
196 Andover
Route 2 at Crosby Corner
215 Elm Street
Route 97
Route 1A
Marston Street
Route 114 at Route 495
Marrett Road
River Road
78
79
81
130
131
153
160
163
Rowley
Salisbury
Tewskbury
Lexington
Lowell
Somerville
Andover
Medford
279 Newbyr Turnpike
Rabbit Road
Clark Street
Route 2 at Watertown Street
Route 495 at Lowell Connector
Mystic Avenue beneath Route 93
Route 93 at Route 495
Area 4C HQ, Mystic Avenue
City/Town
Orleans
Plymouth
Sandwich
Seekonk
Sharon-Walpole
Stoughton
Swansea
Truro
Wareham
Whitman
Wrentham
Yarmouth
Barnstable
Bourne
Dennis
Edgartown
Fall River
New Bedford
Edgartown
Tisbury
Address
Route 6A at Bay Ridge
Obery Street
Route 130
Route 114A
Route 27
Park Street
1001 G.A.R. Highway
Route 6
Plymouth Road Ext.
Route 18 & Bedford Street
Route 1
Willow Street
Phinney's Lane
MacArthur Boulevard
Theo F. Smith Road
Meshakett Road
Under Braga Bridge
King's Highway
14 A Street
115 High Point Lane
District 5
Facility #
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
112
City/Town
Taunton
Avon
Bridgewater
Bourne
Cohassett
Dartmouth
Dartmouth
Duxbury
East Freetown
Fall River
Falmouth
Freetown
Foxboro
Hanover
Lakeville
Mattapoisett
Middleboro
Middleboro
Norton
North Attleboro
Taunton
Address
1000 County Street
Pond Street
Routes 24 & 104
Sagamore Circle
Route 3A
Route 6
Faunce Corner Road
East & Summer Streets
Braley Road
North Main Street
Route 151
Route 79 off Route 140
Route 140
Route 53 at Mill Street
Routes 105 at 118
North Street at Route 195
Vine Street
Route 28
Route 123
Draper Avenue
1050 County Street
Facility #
105
106
107
108
109
110
111
113
114
116
117
118
133
134
136
137
138
139
170
171
Address
90 Wood Road
Granite Avenue at Route 93
Route 1A
Beech & Sixth Street
West Street
Facility #
184
185
186
187
188
District 6
Facility #
59
72
84
128
129
City/Town
Braintree
Milton
Westwood
Chelsea
Dedham
183 CMF
370 D Street, Boston
152
162
158
159
182
197
199
201
203
205
207
Neptune Road beneath Route 1A
Columbia Rd (under I-93)
Route 128N at Route 95
Recreation Road
668 South Ave
55 Dorchester Ave
500 Atlantic Ave
2 FID Kennedy Ave
100 Massport Haul Road
50 Bunker Hill Industrial Park, SMF
257 Congress Street
East Boston
Boston
Canton
Weston
Weston
Vent Bldg #1
Vent Bldg #3
Vent Bldg #6
Em. Resp. 2
Em. Resp. 10
Air Intake Struc
City/Town
SMF
Vent Bldg #5
Vent Bldg #7
Vent Bldg #15
Em. Resp. 1, ESS
#3, ET Toll Support
Bldg
191 Tobin Bridge
193
194
195
198
200
202
204
206
208
Allston/Brighton S&I
Weston
Boston
Vent Bldg #2
Vent Bldg #4
Vent Bldg #8
Em. Resp. 4
OCC
Elec Substation #3
Address
Rear of 410 Rutherford St, Boston
300 Massport Haul Road, Boston
7 Harborside Dr, Boston
Chelsea and Warren, Boston
2B & 4 Harborside Dr, Boston
M6 - Weston
M8 CMF - South Boston
SMF - Charlestown
OCC - South Boston
VB #5 - Boston
VB #7 - Boston
Charlestown (191a); 62 Broadway St.,
Chelsea (191)
Exit 18 toll booth
Park Road
185 Kneeland Street
257 Congress Street
136 Blackstone Street
42 Acclon Way
480 Albany Street
50 Massport Haul Road
497 W Austin Street
Weston Park Road
5
Page 2 of 3
VB #15 - Boston
ERS 1 - Boston
ESS 3 - Boston
TBF #1 - Boston
Tobin Bridge - Chelsea, Charlestown
Allston/Brighton
2
Boston - Special Operations
Facility # City/Town
57 Boston R&M
112 Taunton
156 Braintree
Address
400 D Street
1050 County Street
HOV Lane Route 93 (audit w/157, same
facility)
Facility # City/Town
157 Boston
163 Medford
Address
HOV Lane Route 93 (audit w/156, same
facility)
Medford Sign Shop
Statewide - Drawbridges
Facility # Drawbridge
Location
140 Blynman Bridge Blynman Canal and Anisquam River,
#G-05-002
Gloucester
141
142
143
144
145
Facility # Drawbridge
Location
147 Derek Hines
Merrimack River, Amesbury
Memorial Bridge #A07-010
Kenwood
Danvers River, Beverly to Salem
148 Oak Bluffs Lagoon
Vineyard Haven Barbor, Oak Bluffs to
Bridge #B-11Bridge #O-01-001=T- Tisbury
005=S-01-013
04-001
Gillis Bridge #N- Merrimack River, Salisbury to Newburyport
149 Fairhaven/New
Taunton River, Fall River
11-011=S-02Bedford Bridge #F-01003
002
Plum Island
Plum Island River, Newburyport
150 Route 88 Bridge #W- westport River, Westport
Bridge #N-1003-016
011
Belden Bly
Saugus River, Lynn to Saugus
151 Brightman Street
Taunton River, Fall River
(Foxhill) Bridge
Bridge #F-02-001=S#L-18-016
16-004
Granite Avenue Neponset River, Boston to Milton
Bridge #B-16002=M-25-001
Page 3 of 3
Master Schedule - 2008 to 2012
First Cycle
District 1
District 2
District 3
District 4
District 5
District 6
S.O & Drawbridges
2013
January
February
Worcester HQ 29
Duxbury 92
March
Bedford 53
Granby 120
April
Littleton 36
Weston 182
Foxboro 97
Burlington 60
Em Resp. etc. 188
Truro 113
May
Ware 121
Boylston 122
Air Intake Struct 207
Boxford 58
June
Avon 86
Goshen 5
Stoughton 110
July
Sturbridge 44
Orange 22
August
CMF 183
Manchester 70
Dartmouth 91
Vent Bldg. #4 200
September
Becket 2
Framingham 123
Lawrence 67
New bedford 139
Revere 77
Taunton 112
Lancaster 34
Andover 52
Seekonk 108
Townsend 46
Haverhill 65
Vent Bldg #3 199
October
Allston/Brighton S&I 193
Palmer 23
November
December
2014
January
February
N. Adams 8
March
Sandwich 107
Tobin Bridge 191
West Brookfield 125
April
Concord 62
Williamstown 12
May
Falmouth 95
Dennis 136
Milton 72
Millbury Route-146 37
South Hadley 25
June
Middleboro 101.
Taunton 112
Braintree 59
Upton 47
July
Lakeville 99
Vent Bldg #15 187
Northampton -20
August
Ipswich 66
Sterling 42
September
Buckland 3
Wrentham 117
Concord 63
Athol 14
Sturbridge 192
Vent Bldg #6 201
Middleboro 102
Vent Bldg #7 186
October
Sudbury 45
Palmer 177
November
Belden Bly Bridge 144
Tewksbury 81
Vent Bldg #8 202
East Freetown 93
December
2015
January
Arlington HQ 51
February
Somerville 153
March
Plymouth 106
Boxborough 30
Em. Resp. 2 203
Deerfield 17
April
Edgartown 170
Lawrence 68
Huntington 6
May
Fall River 138
Franklin 32
West Springfield 27
June
Oak Bluffs Lagoon 148
Weston 194
Brightman St. Bridge 151
Vent Bldg #1 197
Andover 160
Hanover 98
Westminister 50
Barnstable 133
July
Southborough 181
Sheffield 11
August
Newbury 73
Belchertown 15
Plum Island Bridge 143
Orleans 105
Uxbridge 48
Whitman 116
Em. Resp. 4 204
Otis 9
October
SMF 184
Reading 75
September
Worcester Camb. St. 165
Canton 158
Winchendon 28
November
North Attleboro 104
Route 88 Bridge 150
Spencer 167
Lexington 69
December
2016
January
February
Hudson 124
March
Fall River 94
Reading 76
Pittsfield 10
April
Fairhaven Bridge 149
Boston 195
Bourne 134
Chicopee 174
Littleton 35
May
Lee 7
June
Erving 18
Rutland 41
July
Cohasset 89
Bernardston 16
Andover River Rd 196
Westboro/Hopkinton 180
Chelsea 128
Tisbury 171 - done w/170 2010
Dedham 129
Norton 103
Boston 162
Kenwood Bridge 141
HOV Lane Garage 156/7
Lee 172
August
Sterling 43.
Chelmsford 61
Warren 176
September
October
Taunton HQ 85
Oxford 40
Wareham 114
Marlboro 290 @ 495 166Lexington 130
Mattapoisett 100
East Boston 152
D Street Lab 57
OCC 206
November
December
2017
January
Medford 4C HQ 163
Medford Sign Shop 163
February
Charlton 31
March
June
Springfield 24
November
December
Westwood 84
Hopkington 33
Sharon/Walpole 109
Weston 159
Dalton 4
Westfield 26
Granite Ave Bridge 145
Edgartown 137
Northboro 39
Bourne 88
Blandford 173
Charlton 178
Peabody 74
Bl;yman Bridge 140
Northampton HQ 13
Em. Resp 10 205
Millbury 38
September
October
Derek Hines Bridge 147
Auburn 179
Swansea 111
Lenox 1
July
August
Freetown 96
Elec Substation #3 208
April
May
Lowell 131
Yarmouth 118
Salisbury 79
Vent Bldg. #2 198
Dartmouth 90
Westfield 175
Westford 49
Vent Bldg #5 185
Bridgwaters E/W 87
Rowley 78
Gillis Bridge 142
Audit Schedule - 2013
Second Cycle
Date
2/20/2013
3/21/2013
3/26/2013
4/10/2013
4/16/2013
4/18/2013
4/23/2013
5/1/2013
5/15/2013
5/15/2013
5/20/2013
5/29/2013
6/4/2013
6/4/2013
6/11/2013
6/18/2013
7/9/2013
7/11/2013
7/16/2013
7/23/2013
8/1/2013
8/6/2013
9/4/2013
9/5/2013
9/12/2013
9/17/2013
9/19/2013
9/20/2013
10/1/2013
10/9/2013
10/15/2013
10/17/2013
11/5/2013
11/7/2013
11/12/2013
Time
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
10:00 AM
Facility (District)
Worcester HQ #29 (D3)
Bedford #53 (D4)
Weston #182 (D6)
Littleton #36 (D3)
Burlington #60 (D4)
Foxboro #97 (D5)
I-90 Toll Bldg #209 (D6)
Truro #113 (D5)
Ware #121 (D2)
Granby #120 (D2)
Duxbury
Boylston #122 (D3)
Air Intake Struct #207 (D6)
Boxford #58 (D4)
Avon #86 (D5)
Goshen #5 (D1)
Stoughton #110 (D5)
CMF #183 (D6)
Sturbridge #44 (D3)
Manchester #70 (D4)
Orange #22 (D2)
Dartmouth #91 (D5)
Becket #2 (D1)
Framingham #123 (D3)
Vent Bldg 4 #200 (D6)
Lawrence #67 (D4)
New Bedford #139 (D5)
Vent Bldg #3 #199 (D6)
Revere #44 (D4)
Taunton #112 (D5)
Palmer #23 (D2)
Allston/Brighton S&I #193 (D6)
Lancaster #34 (D3)
Seekonk #108 (D5)
Andover #52 (D4)
Auditor
LaParl
LaParl
Leach
Spink
Giando
LaParl
Leach
LaParl
Abbott
Abbott
Spink
Abbott
Fulgione
Giando
Leach
Spink
Spink
Giando
Abbott
LaParl
Leach
Giando
Spink
Abbott
Fulgione
LaParl
Leach
Giando
Fulgione
Spink
Abbott
Giando
Abbott
Leach
Fulgione
Coordinator
Giando
Leach
LaParl
Giando
Leach
Fulgione
LaParl
Fulgione
Spink
Spink
Fulgione
Giando
LaParl
Leach
Fulgione
Abbott
Fulgione
LaParl
Giando
Leach
Spink
Fulgione
Abbott
Giando
LaParl
Leach
Fulgione
LaParl
Leach
Fulgione
Spink
LaParl
Giando
Fulgione
Leach
Status
complete, no violations
complete, no violations
complete, 19 regulatory violations, three SOP violations
complete, no violations
complete, one SOP violation
complete, no violations
complete, one regulatory violation, one SOP violation
complete, no violations
complete, no violations
complete, no violations
complete, no violations
complete, no violations
complete, no violations
complete, one SOP violation
complete, no violations
complete, three regulatory violations, one SOP violation
complete, no violations
complete, two regulatory violations, two SOP violations
complete, no violations
complete, no violations
complete, no violations
complete, two SOP violations
complete, no violations
complete, no violations
complete, no violations
complete, no violations
complete, no violations
complete, one regulatory violation, one SOP violation, one BMP
complete, no violations
complete, no violations
complete, 2 BMPs
MassDOT
Environmental Compliance Audit Program
Information Resource and Records Review List
This is a list of information resources and facility records that should be available for review
during the audit where applicable:
Pre-Audit Information Resources






Facility Maps on the EOT Intraway
Previous Environmental Compliance Audit Reports on Environmental Share Drive at
S:\HQ\Environment\EMS-Sustainability\Environmental Compliance Audit Program
Existing Clean State Matter on the Clean State Database
UST Registry on the Massachusetts Department of Environmental Protection Website at
http://db.state.ma.us/dep/ust/ustQueryPage.asp
21E/MCP Sites at http://db.state.ma.us/dep/cleanup/sites/search.asp
USEPA Enforcement & Compliance History Online at
www.epa-echo.gov/echo/compliance_report.html
Record Review



















Building Floor Plans indicating functions of each area
Building Plumbing Plans
Chemical Usage Records for Past 2 years
Waste Characterization/Profile Records
Weekly Hazardous Waste Inspection Forms
Hazardous Waste Generator Registration Certificate
Hazardous Waste Manifests for past 36 months
Notices of Noncompliance, Consent Orders, or other Notices Issued by DEP or EPA
Personnel Training Records relative to environmental regulations
Aboveground and Underground Storage Tank Permits
Spill Prevention Control and Countermeasure Plan & Spill Reports
Facility Asbestos Survey Reports
UST and UIC Closure Reports
Septic System Permits and related documents
Fuel reconciliation records
DEP Class A Recycling Permit or DEP On-Site Class A Recycling Notification Form
Local Fire Department permit for waste oil space heater
Waste oil accumulation records
Documentation that the waste oil space heater is approved for use
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Facility Information
Facility Name:
Facility Representative:
Address:
Title:
City, State, Zip:
Telephone:
Fax:
Auditing Information
Regulated Activities
Date of Audit:
Vehicle Fueling
Auditor:
Vehicle Washing
Signature:_______________________________________________________
Wastewater Recycling System
EMS Compliance Coordinator:
Industrial Wastewater Discharge
Persons Interviewed:
Oil Water Separator
Industrial Wastewater Holding Tank
Waste Oil Generation
RCRA Hazardous Waste Generation
Inaccessible Areas:
Universal Waste Generation
Hazardous Materials Use/Storage
General Comments:
Solid Waste Accumulation
On-Site Sewage Disposal
On-Site Drinking Water Well
Natural Resources:
wetlands
Riverfront Area
USTs
ASTs
MCP Site
Existing Clean State Matters
AULs
Other:
Facility Operations
Vehicle/Equipment Maintenance
Snow/Ice Operations
Stockroom
District Offices
Other:
=
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 2 of 9
SECTION 1: HAZARDOUS WASTE (310 CMR 30.000 and SOP ENV-03)
YES
NO
N/A
Citation
Verification of Generator Status (310 CMR30.060 and 30.303)
Has the facility registered as a Generator of Hazardous Waste and/or Waste Oil? Generator ID No: _________________
30.303(1)
Facility Hazardous Waste Generator Status:
Facility Waste Oil Generator Status:
SQG 30.351(1)
VSQG 30.353(1)
VSQG
VSQG
SQG
SQG
Is the registered generator status appropriate? VSQG <25 gallons/month (100 kg/month) or SQG <250 gallons/month
(1,000 kg/month). Review manifests for confirmation.
SQG 30.351(1)
VSQG 30.353(1)
Have appropriate hazardous waste determinations been made for wastes generated at the facility?
30.302
Verification of the Accumulation Limits
If the facility is a VSQG, are there less than four 55-gallon drums (<1,000 kg or approximately 250 gallons) of
hazardous waste/waste oil at the facility?
30.353(1)(b)
If the facility is an SQG, are there less than twenty-seven 55-gallon drums (6,000 kg or approximately 1,500 gallons) of
hazardous waste/waste oil at the facility (30.351(1)(b))?
30.351(1)(b)
IF the facility has DUAL STATUS (e.g. VSQG of hazardous waste and SQG of waste oil), are the quantities of
hazardous waste and waste oil stored at the facility below the maximum allowed for each status?
(e.g. < 4 drums of hazardous waste and < 27 drums of waste oil)
30.253(5)
Waste Container Management (310 CMR 30.253; 30.351; 30.353)
Are all hazardous waste containers in good condition? (Note any dents, rust, or damage)
SQG: 30.351(8)(b)
VSQG: 30.353(6)(g)
Are all hazardous waste containers tightly closed (bungs sealed and bolt ring secured, except when adding/removing
waste)?
SQG: 30.351(8)(b)
VSQG: 30.353(6)(g)
Are all hazardous waste containers labeled?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(g)
Do the labels include the name of the waste (waste oil, waste paint, etc.)?
SQG: 351(8)(a)
VSQG: 30.353(6)(g)
Is the waste Hazard Type (toxic, ignitable, corrosive, and/or reactive) included on each label?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(g)
If the facility is a Small Quantity Generator (SQG), is the date when accumulation began clearly marked on the container
label?
30.351(5)
Is the accumulation time within regulatory limits? (180-days for SQGs)
30.351(5) and (6)
Are containers compatible with the waste being accumulated?
SQG: 30.351(8)(b)
VSQG: 30.353(6)(g)
Are containers of hazardous waste stored in the designated accumulation area?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(h)
Hazardous Waste Accumulation Areas (310 CMR 30.253; 30.351; 30.353)
If the facility maintains a Hazardous Waste Accumulation Area:
Is the accumulation area secured to prevent unauthorized entry?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(h)
Is the accumulation area adequately demarcated? ( e.g., visible line on floor and only hazardous waste stored therein)?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(h)
Is the accumulation area located on a surface free of cracks/gaps and is impervious to the hazardous wastes being stored,
or is secondary containment in use?
SQG: 30.351(8)(b)
VSQG: 30.353(6)(h)
Is the accumulation area labeled as “HAZARDOUS WASTE” with lettering at least 1-inch high?
SQG: 30.351(8)(a)
VSQG: 30.353(6)(h)
Is Emergency Information/Contact List posted at the facility phone?
SQG: 30.351(9)(c)(6)
Is emergency equipment (spill, fire, etc.) located nearby?
SQG: 30.351(9)(c)(3)
Is secondary containment in use where required (e.g., if located outside)?
SQG: 30.351(8)(b)
VSQG; 30.353(6)(h)
Is the accumulation area in good order?
SQG: 30.351(8)(b)
VSQG; 30.353(6)(h)
Does the accumulation area have adequate aisle space between drums to allow for inspections of the containers?
SQG: 30.351(8)(b)
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 3 of 9
SECTION 1: HAZARDOUS WASTE (CONT’D)
YES
NO
N/A
Citation
If the facility does NOT maintain a Hazardous Waste Accumulation Area:
Is the waste transported to a designated facility on the day of generation or within 3 days of filling a container?
VSQG: 30.353(6)(i)
Hazardous Waste Satellite Accumulation Areas (310 CMR 30.253; 30.351; 30.353):
If the facility maintains a Satellite Hazardous Waste Accumulation Area:
SQG: 30.351(4)
VSQG: 30.353(6)(i)
Is there only one drum/container for each waste type? (limit one container up to 55-gallons)
See above
Is the satellite accumulation area at or near the waste’s point of generation?
See above
Is the satellite accumulation area managed by the person responsible for the area/operations generating the waste?
See above
Are container labels complete? (e.g. “Hazardous Waste,” type of waste, & hazard associated with waste)
See above
Are wastes moved to the accumulation area or shipped within 3 days of the satellite container becoming filled?
See above
Are containers compatible with the waste?
See above
Are containers closed when not adding/removing waste?
See above
Is secondary containment in use where required/warranted? (e.g., if located outside)
See above
Hazardous Waste Recordkeeping (310 CMR 30.253; 30.351; 30.353; 30.310; 30.330; 30.750)
All Hazardous Waste Generators:
If SQG, are weekly inspection records of the hazardous waste and satellite accumulation areas maintained? (One Year)
39.351(8)(b)
If the facility is a VSQG and self-transports hazardous waste:
Is a receipt received from the destination facility and on file?
30.353(7)
If the facility does NOT self-transport hazardous waste (VSQG, SQG):
Are hazardous waste manifests used when shipping hazardous wastes?
30.311(1)
Are manifest records maintained for three years?
30.331(1)
Has the facility received all return copies of manifests from receiving facilities and maintained for 3 years?
30.331(1)
Is the hazardous waste generator ID number properly written on each manifest?
30.311(1)
If the facility has not received a return copy of a manifest from the disposal facility in 45 days, has the facility filed an
Exception Report and are these Exception Reports maintained for 3 years?
30.333(1) and (2)
30.331(3)(b)
Are copies of Land Ban Certifications completed and maintained for 3 years?
40 CFR 268.7
Did the manifests reviewed demonstrate that the facility is appropriately disposing of all waste to only licensed facilities
via licensed transporters?
30.311(2) and (3)
If SQG of Hazardous Waste or Waste Oil:
Has the facility made an attempt to notify the police department, fire department, local board of health, and emergency
response teams as to the facility layout, the hazards associated with the wastes, location of the hazards, and possible
emergency evacuation routes? (e.g., with a signed and dated letter)
30.351(9)(j) and (k)
Are applicable employees trained as to their duties related to hazardous waste handling?
SQG: 30.351(9)(g)
Universal & Special Waste (310 CMR 30.1000 and ENV-07)
Universal Waste Batteries (skip subsection if not generated)
Are universal waste batteries stored in a container or other manner suitable for preventing/containing possible leakage?
(This is only required if there is evidence of leakage, spillage, or damage that could cause leakage)
30.1034(1)
Is battery container labeled with “Universal Waste – Batteries”?
30.1034(1)(d)
Is battery container labeled with accumulation start date?
30.1034(6)(c)
Is the accumulation date no more than one year old?
30.1034(6)(a)
Universal Waste Mercury Containing Lamps and/or Devices (skip subsection if not generated)
Are devices stored in a container or other manner suitable for preventing/containing possible breakage? (This is only
required if the device or lamp is leaking or broken)
30.1034(4) and (5)
Is storage container labeled with “Universal Waste-Mercury Containing Devices” or “Universal Waste-Mercury
Containing Lamps” for fluorescent bulbs?
30.1034(4)(d)
30.1034(5)(e)
Are containers labeled with the start date of accumulation?
30.1034(6)(c)
Is the accumulation date no more than one year old?
30.1034(6)(a)
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 4 of 9
SECTION 1: HAZARDOUS WASTE (CONT’D)
YES
NO
N/A
Citation
Lead Acid Batteries (40 CFR 266 Subpart G, SOP ENV-05)
Are used lead acid batteries appropriately stored, or, if leaking, containerized for eventual return to the Stockroom,
supplier, or recycler?
40 CFR 266.80
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
Hazardous Waste Management at MassDOT Highway Facilities?
ENV-01-03
Used Vehicle Battery Disposal at MassDOT Highway Division Facilities?
ENV-01-05
Universal Waste Management at MassDOT Highway Division Facilities?
ENV-01-07
Roadside Unknown Waste Handling?
ENV-01-25
Used Oil Fired Space Heaters (310 CMR 30.200, 527 CMR 4.03, 310 CMR 7.04)
Does the facility have a DEP Class A Recycling Permit that was issued by February 27, 2004?
30.225
If not, was a one-time Class A Recycling Notification Form submitted to the DEP?
30.225
Does the facility have approval to operate a waste oil burner from the local fire department?
527 CMR 4.03(1)
Are records of burner operation hours properly maintained?
30.205(14)
Are all Used Oil FUEL containers properly labeled?
(Burner Tank: Regulated Recyclable Material, “USED OIL,” Toxic; Drums: Regulated Recyclable Material, “USED
OIL,” Toxic, and labeled with the accumulation date)
Is the space heater operated only between September 15th and June 15th? (7.04(9)(d)4.)
30.205(19)
7.04(9)(d)4.
SECTION 2: HAZARDOUS MATERIALS
YES
NO
N/A
Hazardous Materials Management (454 CMR 21.00, 40 CFR 355, and SOPs ENV-02, -06, -08, 09, -11)
Are hazardous material containers labeled with the name of their contents?
MGL 111F Chapter 7(a)
Are storage tanks/dispensers and containers having capacities greater than 5 gallons labeled with an NFPA label?
MGL 111F Chapter 7(a)
Does the Facility have any Extremely Hazardous Substances equal to or greater than the Threshold Planning Quantity?
40 CFR 355
If Yes, has there been a release above and RQ?
40 CFR 355
If Yes was the SERC or LEPC notified?
40 CFR 355
Are MSDS maintained at the Facility or available upon request?
MGL 111F Chapter 11
Has a list of hazardous materials been filed with DEP? (e.g., with a signed and dated letter)
MGL Ch 111F(16)
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
Material Safety Data Sheet Management at MassDOT Highway Division Facilities?
ENV-01-02
Handling, Storage, and Disposal of Compressed Gas Cylinders at MassDOT Highway Division Facilities?
ENV-01-06
Management of Sand and Deicing Chemicals at MassDOT Highway Division Facilities?
ENV-01-08
Hazardous Materials Management at MassDOT Highway Division Facilities?
ENV-01-11
SECTION 3: SOLID WASTE
YES
NO
N/A
Solid Waste Management (310 CMR 16.00 & 19.000 and SOPs ENV-10, -12, -13, and -24)
Are the solid wastes present at the facility separated by type and/or stored in designated accumulation areas and trash
stored in a covered dumpster?
310 CMR 16.05(5)(a)
ENV-01-12
Are street sweepings stored in accordance with requirements of DEP Policy?
DEP Policy #BWP-94092
Is there evidence of improper disposal in the trash dumpster (batteries, lamps, waste oil, etc.)?
310 CMR 19.017
Are cathode ray tubes (CRTs) collected, stored, handle and transported in a manner that prevents and minimizes
breakage and stored/segregated from other solid waste?
310 CMR 16.05(3)(f)
Is there an active or inactive landfill or dumping ground at the Facility?
If yes, has the landfill/dumping ground been approved or closed or is it being closed in accordance with a DEP
approved plan?
If Yes, describe status:
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 5 of 9
Disposal of Animal Carcasses?
ENV-01-10
Temporary Storage of Solid Waste at MassDOT Highway Division Facilities?
ENV-01-12
SECTION 4: STORAGE TANKS
YES
NO
N/A
Storage Tank Management (527 CMR 9.00 and SOPs ENV-14 and -28)
Underground Storage Tanks (527 CMR 9.00)
Are the USTs equipped with secondary containment, spill and overflow protection, and leak detection?
9.05
Are steel USTs/underground piping equipped with cathodic protection?
9.05(A)(3)
Are cathodic protection systems tested and calibrated every 60 days, annually, or triennially as applicable?
9.05(H)(4)-(6)
Are electronic daily inventory checks conducted on Facility USTs?
9.05(D)(2)
Are daily inventory/monthly reconciliation records completed and kept at the Facility and/or at the District HQ?
9.05(E)(1)
Are the electronic inventory checks/reconciliations reviewed by District personnel for abnormal loss of product and/or
gain of water?
9.05(E)(1)
Are leak detection systems tested and calibrated in accordance with manufacturer recommendations?
9.05(D)(3)
Is leak detection equipment maintained in operating condition?
9.05(D)(3)
Has the tank been inspected by a third party within the past three years?
9.07(P)
If the UST electronic system is inoperable:
Has the facility taken steps to initiate repair of the leak detection equipment?
9.05(D)
If the Facility Dispenses Gasoline (310 CMR 7.24):
Is the gasoline dispensing operation equipped with a Stage II vapor recovery system?
7.24(6)(a) 1-3
Is the Stage II system registered with DEP and tested annually (Annual In-Use Compliance Certification submittal)?
7.24(6)(c)3
Are records of Stage II system weekly inspections and periodic maintenance documentation kept at the Facility or
immediately available for inspection (able to be faxed by District Headquarters)?
7.24(6)(b)3
All Tanks (527 CMR 9.07)
Have tanks been appropriately registered/permitted with the local fire department and the State Fire Marshal?
9.07(M); M.G.L. c. 148,
Section 37
Are tank registration/permit certificates conspicuously posted or kept at the Facility?
9.07(M)(1)
Are there any abandoned tanks at the facility?
9.07(J) 2-3
If yes, describe out of service date(s) and status of any DEP notification and/or closure/removal:
Spill Prevention (40 CFR 112)
Does the facility store oil in aboveground tanks or drums in quantities equal to or greater than 1,320 gallons?
40 CFR 112.1(d)(2)(ii)
If Yes, does the facility have and up-to-date and P.E.-certified SPCC Plan?
40 CFR 112.3(d)
If Yes, is the facility implementing the SPCC Plan?
40 CFR 112.3
In addition to the specific compliance areas above, is the facility in compliance with the following SOP:
Inspection And Repair Of Stage I And Stage II Recovery Systems Associated With Underground Storage Tanks?
ENV-01-28
SECTION 5: WATER QUALITY
YES
NO
N/A
Drinking Water Supply (310 CMR 22.22)
What is the Facility’s water supply source?
 Private Well
 Municipal Public Water Supply
If the facility is supplied with municipal water answer backflow devices questions below.
 Other:
Does the facility have backflow prevention devices for boiler supply water?
22.22(9)(a)
Does the facility have backflow prevention devices on its fire protection/sprinkler system?
22.22(9)(a)
Does the facility have backflow prevention devices on threaded hose connections?
22.22(2)(b)
Have applicable devices been registered with the Public Water Supplier?
22.22(7)(b)
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 6 of 9
SECTION 5: WATER QUALITY (CONT’D)
YES
NO
N/A
Septic Systems (310 CMR 15.000, SOP ENV-17)
Does the facility discharge to a subsurface sewage disposal system (septic system)?
If present and installed on or after 3/31/95, has the facility received a certificate of compliance (COC) for the septic
system?
310 CMR 15.021
If present, is only sanitary wastewater discharged to the septic system (i.e., no process water/chemicals)?
310 CMR 15.004
Drainage Systems (314 CMR 1-15)
Does the facility have a floor drain(s)?
If yes, where do they discharge to:
Describe:
 Yes
 POTW
 No
 Surface Water  Ground
 Holding Tank
 Other
If floor drains are located in an area of hazardous material storage or maintenance areas, do the drains discharge to a
sanitary sewer or to an industrial wastewater holding tank?
If the facility discharges process wastewater to a municipal sewer system, has the facility notified the POTW of the
discharge to determine whether a permit is required?
314 CMR 7.00
If floor drains, have been sealed, did the facility file a WS-1 form with the DEP? (NA for drains connected to sanitary
sewer)
310 CMR 27.10
If floor drains discharged to the ground, did facility close underground structure(s) and file UIC Notification Form with
DEP?
310 CMR 27.10
Are there any oil/water separators on-site?
If present, are oil/water separators inspected and serviced periodically (as required in some areas, such as MWRA)?
If a permit has been issued, are the facility oil/water separators in compliance with permit requirements?
MWRA: 360 CMR
10.016(4) or permit
Stormwater Discharges (310 CMR 27.00; 314 CMR 3.00; 314 CMR 5.00, SOP ENV-19)
Are there stormwater catchbasins on the property?
If Yes, where do the catch basins discharge?
describe:
 POTW
 Surface Water
 Ground
 Other,
If present, have leaching catch basins located within process areas been registered with the DEP (Class V Injection
Well Registration)?
310 CMR 27.08
If a leaching catch basin was registered with DEP, does the Facility maintain a map/plan showing the catch basin
location?
310 CMR 27.08
Vehicle Washing (310 CMR 1-15; 40 CFR 122, SOP ENV-22)
If facility is a Designated Vehicle Washing Facility:
Are vehicles washed only indoors?
Is the facility equipped with floor drains connected to either the municipal sewer or wash water recycling system, or
Is the facility equipped with an approved holding tank?
If facility is NOT a Designated Vehicle Washing Facility:
Are vehicles only rinsed onsite (no detergents or heated water/steam)?
If the facility has an Industrial Wastewater Holding Tank: (Existing Permits; 314 CMR 18.00)
Does the facility have a DEP Industrial Wastewater Holding Tank Permit?
If Yes, is the Facility in compliance with permit conditions?
314 CMR 18.00
Review permit
For applicable holding tanks, has the Facility submitted a one-time compliance certification to DEP (due by February 15,
2003, or within 60 days for new tanks)? (Not required if the Facility has a DEP-issued plan approval for the holding
tank.)
18.10(1)
Does the Facility maintain copies of installation plans (until tank is decommissioned) and records on pumping and
wastewater shipments/disposal (three years)?
18.09(1)
If an existing holding tank was not installed in accordance with PE Certified Plans, has the holding tank undergone an
integrity assessment (due by November 15, 2003)?
18.08(2)
Is the Holding Tank labeled as “Non-Hazardous Industrial Wastewater?” (required for underground and aboveground
tanks)
18.07(6)
Is the Holding Tank equipped with a high level alarm?
If yes, is the alarm functioning properly?
18.07 or 18.08
Is the holding tank gauged/inspected for leakage regularly? (required for new underground tanks, otherwise SOP)
ENV-01-18
Is the alarm system tested by an electrician on a semi-annual basis? (SOP, unless permit condition says otherwise)
ENV-01-18
Is the holding tank pumped cleaned and inspected for structural integrity every five years? (SOP, unless permit condition
says otherwise)
ENV-01-18
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 7 of 9
SECTION 5: WATER QUALITY (CONT’D)
YES
NO
N/A
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
Groundwater Monitoring Well Maintenance at MassDOT Highway Division Facilities?
ENV-01-16
Maintenance of Subsurface Sewage Disposal Systems at MassDOT Highway Division Facilities?
ENV-01-17
Maintenance of Wastewater Holding Tanks and Proper Disposal of Accumulated Wastewater at MassDOT
Highway Division Facilities?
ENV-01-18
Inspection and Maintenance of Stormwater Catch Basins at MassDOT Highway Facilities?
ENV-01-19
Vehicle Washing at MassDOT Highway Facilities?
ENV-01-22
Inspection And Maintenance of Oil/Water Separators (OWS) at MassDOT Highway Division Facilities?
ENV-01-27
SECTION 6: NATURAL RESOURCE AREAS
YES
NO
N/A
Wetlands, Buffer Zones, and Riverfront Zones (310 CMR 9.00 & 10.00, SOP ENV-15)
Are there any Natural Resource Areas (wetland, buffer zone, or riverfront zone) at the property?
(If NO, go to next section)
9.02 and 10.03
Is the facility conducting work in a Natural Resource Area (e.g. removing, filling, dredging, or altering)?
9.03 - .04
10.02-10.05(6)
If the facility is conducting work in a Resource Area, was a Request for Determination of applicability, or NOI submitted
to and approved by the local Conservation Commission, and was Certificate of Compliance received upon work
completion?
10.05(4)
If issued, is the facility is compliance with wetlands Order of Conditions or enforcement order?
310 CMR 10.02-05
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
Protection of Wetland Resource Areas at MassDOT Highway Facilities?
ENV-01-15
SECTION 7: POLLUTION PREVENTION
YES
NO
N/A
Spills/Releases (310 CMR 40.0000; 40 CFR 300; 40 CFR 355, SOPs ENV-03, -07, -11, -20, and -21)
Is there an indication of a release or threat of release of oil and/or hazardous material at the facility?
310 CMR 40.0000
If yes, describe event(s) and actions taken, including notifications made.
Is there an MCP site at the facility in which a permanent solution has not been achieved?
310 CMR 40.0000
If yes, have MCP/Clean State timelines been met?
Describe status and conditions:
Is there an AUL at the facility?
310 CMR 40.0000
Is the facility in compliance with the terms of the AUL?
Asbestos (310 CMR 7.09 & 7.15; 453 CMR 6.00)
Has the facility conducted building renovations/demolitions or asbestos abatement projects?
453 CMR 6.01 - .02
If yes, was an asbestos survey conducted prior to renovation/demolition?
Prior to renovation/demolition, was DEP properly notified using ANF 001 Form?
310 CMR 7.09 and 7.15
453 CMR 6.12
If an asbestos abatement project was conducted, were licensed contractors used?
453 CMR 6.030
If an asbestos abatement project was conducted, was asbestos containerized for offsite disposal at a licensed
facility?
453 CMR 6.13(2)(b)
453 CMR 6.14(4)(h)
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 8 of 9
SECTION 7: POLLUTION PREVENTION (CONT’D)
YES
NO
N/A
In addition to the specific compliance areas above, is the facility in compliance with the following SOPs:
Outdoor Operation/Maintenance Equipment Storage at MassDOT Highway Facilities?
ENV-01-20
Management of Asbestos Containing Materials at MassDOT Highway Division Facilities?
ENV-01-29
SECTION 8: AIR QUALITY
YES
NO
N/A
Air Emissions, Permits & Recordkeeping (310 CMR 7.00)
Parts Cleaners
Is a solvent parts cleaner used?
310 CMR 7.18
If yes, is the unit equipped with a drain to a remote reservoir?
310 CMR 7.18
If present, is the unit equipped with a functioning cover?
310 CMR 7.18
If present, is the unit cover kept closed when not in use and are instructions on the proper operation posted on the unit?
BMP
Refrigerant Management
Does the facility conduct vehicle refrigeration maintenance?
40 CFR 82
If yes, are personnel who perform refrigerant work certified by EPA?
40 CFR 82.34(a)(2)
Is refrigerant recovery equipment EPA-certified?
40 CFR 82.34(a)(1)
Has the facility submitted a Notification Form with EPA for use of the refrigeration equipment?
40 CFR 82.42(a)
Are waste appliances containing refrigerants (e.g., refrigerators, air conditioners) properly stored to prevent damage and
accidental release of refrigerant?
40 CFR 82
SECTION 9: TRAINING
YES
NO
N/A
Training Records
Does the facility have the following training records on file, where applicable:
Hazardous Waste Management training?
SQG: 30.351(9)(g)
Universal Waste Management Training?
30.1035
Stage II Vapor Recovery System training?
7.24(6)(b)2.
Spill Prevention, Control, and Countermeasure Plan training?
40 CFR 112.7(f)
Other (list)?
SECTION 10: CLEAN STATE PROGRAM
YES
NO
N/A
Clean State Program Management
Are there any existing Clean State Matters for the facility?
If Yes, list and describe status:
Policy ENF-05-001
ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST
Page 9 of 9
Additional notes/Comments:
MassDOT
Environmental Compliance Audit
AUDIT FINDINGS REPORT
Facility:
PAGE ___ of ___
Audit Date:
Note: Provide a description of each finding (i.e. regulatory violation or SOP noncompliance) identified during the audit and the
appropriate recommendation (corrective action or best management practice) for implementation.
FINDING SUMMARY
Finding Description
Regulatory Citation or SOP
Reference
Recommended Corrective Action (Violation)
or Best Management Practice (SOP)
The signature below certifies that the Auditor has identified the finding listed above and that the above are accurate
and true to the best of the Auditor’s knowledge.
Auditor
Date
MassDOT
Environmental Compliance Audit
CORRECTIVE ACTION PLAN REPORT
Facility:
PAGE __ of __
Audit Date:
Description of Violation and Regulatory Citation:
Possible Cause of Violation:
Corrective Action Plan:
The following signature certifies agreement with the Corrective Action Plan, as described above, and commitment to
providing the necessary personnel, equipment and/or contractual resources for its successful completion within sixty
days of the audit date:
District Maintenance Engineer
Date
Note: The CAP Report with the DME Signature must be submitted to the Audit Coordinator via e-mail within 14
days of audit site visit date for updating the Clean State Database.
The following signature certifies that the completed corrective action, as described above, has successfully corrected
the violation within sixty days of its discovery:
EMS Compliance Coordinator
Date
MassDOT
Environmental Compliance Audit
Program Fieldbook
ENVIRONMENTAL REQUIREMENTS LIST
This Environmental Requirements List provides a summary of State and Federal regulations,
State Department of Environmental Protection policies, and Executive Orders that may be
applicable to MassDOT Facilities. In addition, a list of current MassDOT Environmental
Standard Operating Procedures is provided herein.
Under MassDOT’s GreenDOT Policy, Policy P-10-002, MassDOT will pursue the
GreenDOT Vision and achieve the three GreenDOT goals by making sustainability an
integral part of every MassDOT employee’s job, and by integrating these objectives into
our organizational vision and mission.
•
We will address short- and long-term greenhouse gas emissions at every stage of
design, construction, and operation of our transportation system in order to
minimize climate disruption and its effects on the environment and on our
customers.
•
We will consider the needs of all our customers, regardless of mode choice or ability,
in the design and operation of MassDOT transportation facilities. We will be guided
by the MassDOT Complete Streets design philosophy articulated in the Highway
Division Project Development and Design Guide and the principles of safe and full
access to and within transit, rail, and other transportation facilities.
•
We will distribute staff resources and define department objectives in a
manner that ensures adequate attention to all customers and modes.
•
We will design, build and operate our transportation system so that it supports smart
growth development; this in turn will facilitate travel by the healthy transportation
modes of walking, bicycling, and public transit; improve air quality; preserve the
environment; and enhance quality of life for all of our customers.
•
We will measure our performance toward the GreenDOT goals with a robust set of
performance measures that evaluate sustainability and service to our customers – the
users of our transportation facilities.
Page 1 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
State Environmental Regulations
State Law/Regulation
Subject
MGL c. 111 § 2B-2C; § 31C; § 142A142M; 150A-B
310 CMR 7.00
Air Quality
310 CMR 7.01
310 CMR 7.02
310 CMR 7.03
310 CMR 7.04
310 CMR 7.05
310 CMR 7.06
310 CMR 7.07
310 CMR 7.09
Air pollution control regulations
Causing or contributing to a condition of air
pollution
Air Plan Approval permits, Restricted Emission
Status
Plan Approval exemption construction
requirements
Maintenance and testing of fuel burners
Fuel restrictions – sulfur, ash, and additives – fuel
supply records
Opacity/smoke density limits for fuel burner
emissions
Open burning of combustible material
310 CMR 7.11
Construction and demolition causing or
contributing to air pollution
Causing or contributing to a condition of noise
pollution
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
Vapor control for organic material storage – Stage
I and Stage II
310 CMR 7.10
310 CMR 7.24
MGL c. 21C
Hazardous Waste Management
310 CMR 30.0000
310 CMR 30.060 - 064
Massachusetts hazardous waste management
regulations
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
Page 2 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
State Law/Regulation
Subject
310 CMR 30.330
Record Keeping
310 CMR 30.750
Land Disposal Restrictions
310 CMR 30.320
Pre-transport requirements
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
Leak detection, Inventory monitoring, Tightness
testing, Upgrading, and Corrosion protection for
USTs
General provisions: Abandoned USTs, Tank
removal, Registration and permitting of tanks
527 CMR 9.07
MGL c. 21E
MGL c. 21H
310 CMR 40.0000
Waste Site Cleanup
310 CMR 40.0000 Subpart C
Reporting of hazardous material releases
310 CMR 40.0000 Subpart E
310 CMR 40.0300
Assessment and cleanup of hazardous material
releases
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 40.0000 Subpart J
310 CMR 16.00
Massachusetts Contingency Plan
310 CMR 16.05
Site assignment regulations for solid waste
facilities
Applicability and conditionally exempt operations
310 CMR 16.06
Prohibitions
310 CMR 19.000
Solid waste management regulations
Page 3 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
State Law/Regulation
Subject
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
310 CMR 19.021
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
310 CMR 27.00
Water Pollution Control;
Underground Injection Control
Septic systems: Title 5
314 CMR 2.00
Underground water source protection: Class V
injection Wells
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
Industrial wastewater holding tanks
314 CMR 18.00
360 CMR 10.00
248 CMR 2.00
Massachusetts Water Resources Authority
(MWRA)
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
Page 4 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
State Law/Regulation
Subject
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
MGL c. 149 §§ 2, 5, & 6
MGL c. 111 §§ 2 – 5P
105 CMR 410.000
Asbestos & Radiation
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
453 CMR 4.00
Fixed facilities which generate electromagnetic
fields
Ionizing radiation
453 CMR 5.00
Non-Ionizing radiation
Maintenance of asbestos-containing materials
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
310 CMR 33.00
454 CMR 21.00
Massachusetts right-to-know law
Community right-to-know: Filing of Material Safety
Data Sheets with DEP
Employee right-to-know
Page 5 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Federal Environmental Regulations
Federal Regulation
Subject
Air Quality
40 CFR 61
40 CFR 82
National Emission Standards for Hazardous Air Pollutants
(NESHAPs) (Asbestos)
Ozone depleting substances (ODS)
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-toKnow 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
US Army Corps of Engineer Regulations (Massachusetts
Programmatic General Permit)
Wildlife
40 CFR 403
33 CFR 320-330
50 CFR 17.00
Federal Endangered Species Act
Toxic Substances Control Act (TSCA)
40 CFR 761
Manufacturing, processing, distribution in commerce, and use
of PCBs and PCB items
Department of transportation (DOT)
49 CFR 106, 107, 110, 130,
171-180
Regulations for Shipping and Receiving Hazardous Materials
Coast Guard
33 CFR 114-115
*
Voluntary participation
Page 6 of 7
July 2011
US Coast Guard Protection of Navigable Waters
MassDOT
Environmental Compliance Audit
Program Fieldbook
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
Page 7 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
Executive Orders
Executive Order No.
Subject
484
Leading By Example – Clean Energy and Efficient Buildings
515
Establishing an Environmental Purchasing Policy
Page 8 of 7
July 2011
MassDOT
Environmental Compliance Audit
Program Fieldbook
MassDOT Standard Operating Procedures
SOP 01 Environmental Compliance SOPS
ENV-01-01-1-000
SOP 02 Materials Safety Data Sheet Management
ENV-01-02-1-000
SOP 03 Hazardous Waste Management
ENV-01-03-1-000
SOP 05 Used Vehicle Battery Disposal
ENV-01-05-1-000
SOP 06 Handling, Storage and Disposal of Compressed Gas Cylinders ENV-01-06-1-000
SOP 07 Universal Waste Management
ENV-01-07-1-000
SOP 08 Management of Sand and Deicing Chemicals
ENV-01-08-1-000
SOP 10 Disposal of Animal Carcasses
ENV-01-10-1-000
SOP 11 Hazardous Materials Management
ENV-01-11-1-000
SOP 12 Temporary Storage of Solid Waste
ENV-01-12-1-000
SOP 15 Wetland Resource Protection
ENV-01-15-1-000
SOP 16 Groundwater Monitoring Well Maintenance
ENV-01-16-1-000
SOP 17 Maintenance of Subsurface Sewage Disposal Systems
ENV-01-17-1-000
SOP 18 Maintenance of Wastewater Holding Tanks
ENV-01-18-1-000
SOP 19 Inspection and Maintenance of Stormwater Catch Basins
ENV-01-19-1-000
SOP 20 Outdoor Operation/Maintenance Equipment Storage
ENV-01-20-1-000
SOP 22 Vehicle Washing
ENV-01-22-1-000
SOP 25 Roadside Unknown Waste Handling
ENV-01-25-1-000
SOP 27 Inspection and Maintenance of Oil/Water Separators
ENV-01-27-1-000
SOP 28 Inspection and Repair of Stage I and Stage II Recovery Systems ENV-01-28-1-000
SOP 29 Management of Asbestos Containing Materials
ENV-01-29-1-000
SOP 31 Performing Facility Environmental Compliance Inspections
ENV-01-31-1-000
SOP 32 Contractors’ Use of Facilities
ENV-01-32-1-000
SOP 33 Beaver Dam Control
ENV-01-33-1-000
SOP 34 Environmental Scope Review of Maintenance Projects
ENV-01-34-1-000
SOP 35 Routine Maintenance of Drainage Structures
ENV-01-35-1-000
SOP 36 Emergency Response to Roadway Flooding
ENV-01-36-1-000
SOP 37 Operation of Waste or Used Oil Space Heaters
ENV-01-37-1-000
SOP 38 Inventory Control for Underground Storage Tanks
ENV-01-38-1-000
Page 9 of 7
July 2011