Layde Philips
Programs Management,
Environmental Affairs Division, TxDOT

What is the TXDOT Environmental Management System Verification Audit?
Short Course 2012
3

 A systematic and documented process for objectively obtaining and evaluating evidence to determine the following:

Does implementation of the TxDOT EMS conform to the TxDOT EMS criteria?
 Are EMS results communicated to management and acted upon appropriately?
TxDOT Management System Elements
1. EMS Policy
2. Roles and Responsibilities
3. Environmental Requirements
4. Assessment, Prevention and Control
5. Training Awareness and Competence
6. Records and Documentation
EMS
WHAT IS THE TXDOT EMS VERIFICATION AUDIT ? 4
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TxDOT Management
System Elements:
1.
EMS Policy
2.
Roles and
Responsibilities
3.
Environmental
Requirements
4.
Assessment, Prevention and Control
5.
Training Awareness and
Competence
6.
Records and
Documentation
 Independently evaluate the adequacy and effectiveness of the TxDOT EMS implementation from top management down and throughout each district based on a representative sample.
 Provide a independent assessment as to whether the
TxDOT EMS has been implemented in such a manner as to facilitate understanding, by appropriate TxDOT employees and contractors, of the following:
• the environmental aspects and impacts of road construction
• the environmental controls, monitoring and measurement procedures or processes contained within the TxDOT EMS to address the aspects and impacts of road construction
• individual environmental responsibilities related to the aspects and impacts of road construction as stipulated within the TxDOT EMS
WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 5
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HQ Audit
West North South East
2 Districts
TBD
2 Districts
TBD
2 Districts
TBD
2 Districts
TBD
District Selection Criteria
Geographical Coverage
Construction Activity
Large/Small Geographical Area
Rural/Urban
Active Road
Construction Sites
Active Road
Construction Sites
Active Road
Construction Sites
Active Road
Construction Sites
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WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 6

Design Division Administration Division
Headquarters
Environmental Affairs
Division
Maintenance Division
Two (2) person Team
Three (3) Day Verification
Five Divisions
Construction Division
TxDOT EMS Elements
•Policy Statement
•Roles/Responsibilities
•Environmental Requirements
•Assessment, Prevention and Control
•Training, Awareness and Competence
•Records and Documentation
WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 7
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Project
Development/Environmental
EMS Element
Preliminary Design
EMS Element
Design
EMS Element
TxDOT EMS Elements
•Policy Statement
•Roles/Responsibilities
•Environmental Requirements
•Assessment, Prevention and
Control
•Training, Awareness and
Competence
•Maintenance of Records and
Documentation
District Engineer
DISTRICT
Construction Phase
2-3 Construction
Projects/District
Construction
Inspector
2.5 day verification
2 person teams
Contractor/Subcontractor
WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 8
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Planning
 Verification Plan Developed and Approved by USEPA
 Master Audit Schedule
 District Projects Selected Fit the EMS Road Construction Definition
 Projects Selected From October 2012 Letting
 Coordinate with Districts Regarding Visit Logistics
 Identify Personnel to be Interviewed
WHAT IS THE TXDOT EMS VERIFICATION AUDIT ?
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Verification (2.5 days)
 Opening Meeting
• Introductions/Process Overview
• Safety Requirements etc.
 Records Review
 Personnel Interviews
• District Employees/Contractors
 Physical inspections
•
2-3 Active Road Construction Projects

Closing Meeting
•
AM Meeting
•
Review of Findings
•
Discussion of Corrective Actions
•
Q&A
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Day 1
Day 2
Day 3
WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 10

Reporting and Follow Up
 Findings Report
• Submit to HQ within seven (7) business days
• Summarize Verification Activities
• Provide Detailed Verification Findings + Corrective Actions
 Periodic Requests for Corrective Action Updates
• E-Mails from Shaw to EMS Coordinator and District Contact
• Requesting Updates Regarding Corrective Action
• Track Closure of Verification Findings
• Closure Progress Reported to HQ On Recurring Basis
WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
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 Are EMS procedures/processes adequately inclusive of road construction environmental impacts?
 Do the TxDOT EMS procedures/processes describe what’s actually happening?
• Review of job site for environmental requirements, implementation of procedures.
 Is there objective evidence that EMS procedures/processes are being followed?
• Review of District and Project EMS Records
 Is EMS documentation controlled?
• Current versions or forms, procedures etc. used?
 Are related documents and records referenced?
• SOPs
• Environmental Scoping
•
EPIC Sheet
•
Pre-Construction Conference
•
Construction State Gate Checklist
• Storm Water Inspection Checklist
EMS
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WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 12

TxDOT EMS Elements:
1.
EMS Policy
2.
Roles and
Responsibilities
3.
Environmental
Requirements
4.
Assessment,
Prevention and
Control
5.
Training Awareness and Competence
6.
Records and
Documentation






EXAMPLE PERSONNEL INTERVIEW QUESTIONS
 How did you become aware of the TxDOT Environmental
Policy?
 What is your understanding of the EMS Policy and how does it apply to your day-to-day work?
What are your responsibilities within the TxDOT EMS?
What environmental impacts are associated with your work?
What EMS procedures or processes do you follow when conducting your work?
How does your work vary from the procedures?
What kind of EMS or environmental training have you received?
How do you escalate environmental concerns to management?
WHAT IS THE TXDOT EMS VERIFICATION AUDIT? 13
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Project Tasks
Develop Verification Plan content outline
Define corrective action and follow-up methodology
Draft Verification Plan to meet CAFO requirements
Coordinate with TxDOT for Verification Plan Development
Provide draft Verification Plan to TxDOT
Incorporate TxDOT comments into Plan
Submit final Verification Plan to EPA as directed by
TxDOT
Incorporate EPA comments into Plan (30 days of receipt)
Obtain EPA approval of final Verification Plan
Finalize site visits and interview schedules
Conduct Austin, TX Headquarters Audit
Conduct Audits – TxDOT Southern Region
Conduct Audits – TxDOT Eastern Region
Conduct Audits – TxDOT Northern Region
Conduct Audits – TxDOT Western Region
Develop Verification Report Content Outline
Coordinate with TxDOT for Report development
Provide draft Verification Report to TxDOT for review
Incorporate TxDOT comments into final Report
Submit final Verification Report to EPA
S O N D J
September 2012 – January 2014
F M A M J J A S O N D J
WHAT IS THE TXDOT EMS VERIFICATION AUDIT?
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Road Construction Project - Road construction operation that includes any of the following associated activities: earth work, concrete work, asphalt work, steel work, masonry work, demolition work, excavation work, fill work, land clearing, painting, soil stabilization, equipment operation, de-watering activities, material storage, waste management, waste disposal, and waste recycling activities. Under this definition, construction also includes project specific locations (PSLs), such as concrete and asphalt batch plants, within the Right-of-Way. The term construction does not include routine or preventative roadway maintenance activities.
– Types of projects include new location, existing pavement rehabilitations/widening, culvert work, bridge rehabilitation/replacement.
– Typical projects not requiring the Stage Gate Checklist (SGC) to be completed would be signal installation, crack sealing, retrace striping, seal coating, bridge joint repair.
– Districts should determine whether the SGC should be completed on minimal soil disturbance Construction or Maintenance contracts such as any MBGF upgrade, landscaping, ACP overlays.
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EMS TOOLS
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