Facility Environemntal Audit Program Cover Environmental Compliance Audit Program Fieldbook Page 2 January 2011 1.0 Introduction Environmental compliance auditing is a …

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FACILITY ENVIRONMENTAL AUDIT PROGRAM

MassDOT Environmental Compliance Audit

Program Fieldbook Page 1

January 2011

Table of Contents

1.0 Introduction ..................................................................................... 2

1.1 Facility List ......................................................................... 2

1.2 Audit Schedule .................................................................... 2

1.3 Audit Team ......................................................................... 3

2.0 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

MassDOT Environmental Compliance Audit Program Fieldbook Page 2

January 2011

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

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

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, pre-existing 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

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

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 Activity

Responsible Person

Timeline

Develop Schedules, Assign Auditors and Notify EMS Coordinators

Audit Coordinator Master Schedule at beginning of each new Cycle; Yearly Schedules at beginning of each year in a Cycle.

Notify DME to ensure availability of Facility Representative and documentation at audit

ECC At least two weeks before audit site visit date.

Complete and forward Audit Findings Report (AFR) to EMS Coordinator and Audit Coordinator

Auditor Within 3 days of audit site visit date.

Complete and forward Facility Audit Report to Audit Coordinator

Auditor Within 14 days of audit site visit date.

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.

ECC Within 14 days of audit site visit date.

Assist with and monitor performance of CAP, and finalize CAP Report with signature when the CAP is completed.

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

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

Hazardous Materials

Solid Waste

Roadside Issues

Storage Tanks

Water Quality

Natural Resource Areas

Pollution Prevention

Air Quality

Environmental Management

Page 1 of 3

Facility # City/Town Address Facility # City/Town Address M1 - Lee1 Lenox 270 Pittsfield Road (Route 7A) 8 North Adams 590 Ashland Street(Route 8A) M2 - Blandford2 Becket 98 Washington Road (Route 8) 9 Otis 298 North Main Road (Route 8)3 Buckland 1 Creamery Avenue (Route 2) 10 Pittsfield 77 Central Berkshire Boulevard (Route

41)4 Dalton 229 Orchard Road 11 Sheffield 1269 North Main Street (Route 7)5 Goshen USMC League Highway (Route 9) 12 Williamstown 900 New Ashfield Road (Route 7)6 Huntington Worthington Road (Route 112) 172 Lee 239 Marble Street7 Lee 435 Pleasant Street (Route 102) 173 Blandford 3 Old Chester Road

Facility # City/Town Address Facility # City/Town Address M3 - Chicopee13 Northampton North King Street 25 South Hadley Route 33 SPB - Westfield14 Athol Route 32 (Petersham Road) 26 Westfield Route 20 (East Main Street) M4 - Warren15 Belchertown Route 9 (Ware Road) 27 West Springfield 2 Ashley Avenue Toll Plaza 08 - Palmer16 Bernardston Route 10 (Northfield Road) 28 Winchenden Route 202 (Baldwinville Road)17 Deerfield Route116 120 Granby Route 116 18 Erving Route 2 (Mohawk Trail) 121 Ware Route 32 20 Northampton Route 5 (Mt. Tom Road) 174 Chicopee 240 Fuller Road22 Orange Route 122 175 Westfield Sgt. T.M. Dione Way23 Palmer Route 20 176 Warren Brimfield Rd. (Rt. 9)24 Springfield Magaziner Street 177 Palmer 146 Thorndike Road

Facility # City/Town Address Facility # City/Town Address SPB - Charlton29 Worcester 403 Belmont Street 46 Townsend New Fitchburg Road M5 - Auburn30 Boxboro Swanson Road at Route 495 47 Upton Route 140 SA 6AW - Hopkinton31 Charlton Route 20 48 Uxbridge Route 146 SPB - Southborough32 Franklin Route 140 at Route 495 49 Westford Route 225 Sturbridge salt shed33 Hopkinton West Elm Street 50 Westminister Routes 140 & 234 Lancaster Mechanic Street 122 Boylston Route 14035 Littleton Route 2 at Underpass 123 Framingham Route 936 Littleton Route 2 at Railroad Bridge 124 Hudson Routes 62 & 49537 Millbury Route 146 125 West Brookfield Route 938 Millbury West Main Street 165 Worcester Cambridge Street39 Northboro Route 9 166 Marlborough Route 290 at Route 49540 Oxford Depot Road 167 Spencer Route 941 Rutland Route 122A 178 Charlton Route 90/Sturbridge Road42 Sterling Route 12 179 Auburn 85-89 Bancroft St43 Sterling Chocksett Road 180 Westboro/Hopkinton Route 90/Wood Street44 Sturbridge Routes 20 & 131 181 Southborough 115 Woodland Road45 Sudbury Boston Post Road 192 Sturbridge Routes 90 & 84

Facility # City/Town Address Facility # City/Town Address51 Arlington 519 Appleton Street 70 Manchester Pine Street off Route 12852 Andover Route 125 & Prospect Street 73 Newbury Scotland Road53 Bedford Crosby Road 74 Peabody Route 158 Boxford Topsfield Road 75 Reading Route 28 at Route 12860 Burlington Grant Avenue 76 Reading Route 129 at Route 9361 Chelmsford Route 4 north of Route 3 77 Revere 745 Washington Avenue

Audit Facilities List (Updated: December 2012)

District 1

District 2

District 3

District 4

Page 2 of 3

62 Concord Route 2 at Crosby Corner 78 Rowley 279 Newbyr Turnpike63 Concord 215 Elm Street 79 Salisbury Rabbit Road65 Haverhill Route 97 81 Tewskbury Clark Street66 Ipswich Route 1A 130 Lexington Route 2 at Watertown Street67 Lawrence Marston Street 131 Lowell Route 495 at Lowell Connector

153 Somerville Mystic Avenue beneath Route 9368 Lawrence Route 114 at Route 495 160 Andover Route 93 at Route 49569 Lexington Marrett Road 163 Medford Area 4C HQ, Mystic Avenue

196 Andover River Road

Facility # City/Town Address Facility # City/Town Address85 Taunton 1000 County Street 105 Orleans Route 6A at Bay Ridge86 Avon Pond Street 106 Plymouth Obery Street87 Bridgewater Routes 24 & 104 107 Sandwich Route 13088 Bourne Sagamore Circle 108 Seekonk Route 114A89 Cohassett Route 3A 109 Sharon-Walpole Route 2790 Dartmouth Route 6 110 Stoughton Park Street91 Dartmouth Faunce Corner Road 111 Swansea 1001 G.A.R. Highway92 Duxbury East & Summer Streets 113 Truro Route 693 East Freetown Braley Road 114 Wareham Plymouth Road Ext.94 Fall River North Main Street 116 Whitman Route 18 & Bedford Street95 Falmouth Route 151 117 Wrentham Route 196 Freetown Route 79 off Route 140 118 Yarmouth Willow Street97 Foxboro Route 140 133 Barnstable Phinney's Lane98 Hanover Route 53 at Mill Street 134 Bourne MacArthur Boulevard99 Lakeville Routes 105 at 118 136 Dennis Theo F. Smith Road

100 Mattapoisett North Street at Route 195 137 Edgartown Meshakett Road101 Middleboro Vine Street 138 Fall River Under Braga Bridge102 Middleboro Route 28 139 New Bedford King's Highway103 Norton Route 123 170 Edgartown 14 A Street104 North Attleboro Draper Avenue 171 Tisbury 115 High Point Lane112 Taunton 1050 County Street

Facility # City/Town Address Facility # City/Town Address M6 - Weston VB #15 - Boston59 Braintree 90 Wood Road 184 SMF Rear of 410 Rutherford St, Boston M8 CMF - South Boston ERS 1 - Boston72 Milton Granite Avenue at Route 93 185 Vent Bldg #5 300 Massport Haul Road, Boston SMF - Charlestown ESS 3 - Boston84 Westwood Route 1A 186 Vent Bldg #7 7 Harborside Dr, Boston OCC - South Boston TBF #1 - Boston

128 Chelsea Beech & Sixth Street 187 Vent Bldg #15 Chelsea and Warren, Boston VB #5 - Boston Tobin Bridge - Chelsea, Charlestown129 Dedham West Street 188 Em. Resp. 1, ESS

#3, ET Toll Support Bldg

2B & 4 Harborside Dr, Boston VB #7 - Boston Allston/Brighton

183 CMF 370 D Street, Boston 191 Tobin Bridge Charlestown (191a); 62 Broadway St., Chelsea (191)

Weston Park Road

152 East Boston Neptune Road beneath Route 1A 193 Allston/Brighton S&I Exit 18 toll booth162 Boston Columbia Rd (under I-93) 194 Weston Park Road158 Canton Route 128N at Route 95 195 Boston 185 Kneeland Street159 Weston Recreation Road 198 Vent Bldg #2 257 Congress Street182 Weston 668 South Ave 200 Vent Bldg #4 136 Blackstone Street197 Vent Bldg #1 55 Dorchester Ave 202 Vent Bldg #8 42 Acclon Way199 Vent Bldg #3 500 Atlantic Ave 204 Em. Resp. 4 480 Albany Street201 Vent Bldg #6 2 FID Kennedy Ave 206 OCC 50 Massport Haul Road203 Em. Resp. 2 100 Massport Haul Road 208 Elec Substation #3 497 W Austin Street205 Em. Resp. 10 50 Bunker Hill Industrial Park, SMF207 Air Intake Struc 257 Congress Street

5

District 5

District 6

Page 3 of 3

2

Facility # City/Town Address Facility # City/Town Address57 Boston R&M 400 D Street 157 Boston HOV Lane Route 93 (audit w/156, same

facility)112 Taunton 1050 County Street156 Braintree HOV Lane Route 93 (audit w/157, same

facility)163 Medford Medford Sign Shop

Facility # Drawbridge Location Facility # Drawbridge Location140 Blynman Bridge

#G-05-002Blynman Canal and Anisquam River, Gloucester

147 Derek Hines Memorial Bridge #A-07-010

Merrimack River, Amesbury

141 Kenwood Bridge #B-11-005=S-01-013

Danvers River, Beverly to Salem 148 Oak Bluffs Lagoon Bridge #O-01-001=T-04-001

Vineyard Haven Barbor, Oak Bluffs to Tisbury

142 Gillis Bridge #N-11-011=S-02-003

Merrimack River, Salisbury to Newburyport 149 Fairhaven/New Bedford Bridge #F-01-002

Taunton River, Fall River

143 Plum Island Bridge #N-10-011

Plum Island River, Newburyport 150 Route 88 Bridge #W-03-016

westport River, Westport

144 Belden Bly (Foxhill) Bridge #L-18-016

Saugus River, Lynn to Saugus 151 Brightman Street Bridge #F-02-001=S-16-004

Taunton River, Fall River

145 Granite Avenue Bridge #B-16-002=M-25-001

Neponset River, Boston to Milton

Statewide - Drawbridges

Boston - Special Operations

Master Schedule - 2008 to 2012First Cycle

District 1 District 2 District 3 District 4 District 5 District 6 S.O & Drawbridges

2013

Worcester HQ 29Duxbury 92

Bedford 53 Weston 182Granby 120 Littleton 36 Foxboro 97

Burlington 60 Em Resp. etc. 188Truro 113

Ware 121 Boylston 122 Air Intake Struct 207Boxford 58 Avon 86

Goshen 5Stoughton 110 CMF 183

Sturbridge 44 Manchester 70Orange 22 Dartmouth 91

Vent Bldg. #4 200Becket 2 Framingham 123 Lawrence 67 New bedford 139

Vent Bldg #3 199Revere 77 Taunton 112

Palmer 23 Allston/Brighton S&I 193Lancaster 34 Andover 52 Seekonk 108

2014

Townsend 46 Haverhill 65N. Adams 8 Sandwich 107

Tobin Bridge 191West Brookfield 125 Concord 62 Falmouth 95

Williamstown 12 Dennis 136 Milton 72Millbury Route-146 37

South Hadley 25 Middleboro 101. Taunton 112Braintree 59

Upton 47 Lakeville 99Vent Bldg #15 187

Northampton -20 Ipswich 66Sterling 42 Wrentham 117

Buckland 3 Concord 63 Vent Bldg #6 201Athol 14 Sturbridge 192 Middleboro 102

Vent Bldg #7 186Sudbury 45 Belden Bly Bridge 144

Palmer 177 Tewksbury 81 Vent Bldg #8 202East Freetown 93

2015

Arlington HQ 51

Somerville 153 Plymouth 106Boxborough 30 Em. Resp. 2 203

Deerfield 17 Edgartown 170 Oak Bluffs Lagoon 148Lawrence 68 Weston 194

Huntington 6 Fall River 138 Brightman St. Bridge 151Franklin 32 Vent Bldg #1 197

West Springfield 27 Andover 160 Hanover 98Westminister 50

Barnstable 133Southborough 181 Newbury 73 Plum Island Bridge 143

Sheffield 11 Belchertown 15 Orleans 105Uxbridge 48 SMF 184

Reading 75 Whitman 116Em. Resp. 4 204

Otis 9 Worcester Camb. St. 165Canton 158

Winchendon 28 North Attleboro 104 Route 88 Bridge 150Spencer 167

Lexington 69

2016

Hudson 124 Fall River 94 Fairhaven Bridge 149Reading 76 Boston 195

Pittsfield 10 Bourne 134Chicopee 174

Littleton 35 Cohasset 89 Chelsea 128 Kenwood Bridge 141

Lee 7 Erving 18 Tisbury 171 - done w/170 2010Rutland 41 Andover River Rd 196 Dedham 129

Norton 103Bernardston 16 Westboro/Hopkinton 180 Boston 162 HOV Lane Garage 156/7

Lee 172Sterling 43. Chelmsford 61

Warren 176 Taunton HQ 85

Oxford 40 Wareham 114 East Boston 152 D Street Lab 57

OCC 206Marlboro 290 @ 495 166Lexington 130 Mattapoisett 100

2017

Medford 4C HQ 163 Medford Sign Shop 163

Charlton 31 Lowell 131 Freetown 96 Derek Hines Bridge 147Elec Substation #3 208

Springfield 24 Auburn 179Swansea 111 Westwood 84

Lenox 1 Hopkington 33Sharon/Walpole 109

Weston 159 Granite Ave Bridge 145Dalton 4 Westfield 26 Edgartown 137

Northboro 39Bourne 88

Blandford 173 Charlton 178 Peabody 74 Bl;yman Bridge 140Northampton HQ 13 Em. Resp 10 205

Millbury 38 Yarmouth 118Salisbury 79 Vent Bldg. #2 198 Gillis Bridge 142

Dartmouth 90Westfield 175 Westford 49 Vent Bldg #5 185

Bridgwaters E/W 87Rowley 78

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Date Time Facility (District) Auditor Coordinator Status2/20/2013 10:00 AM Worcester HQ #29 (D3) LaParl Giando complete, no violations3/21/2013 10:00 AM Bedford #53 (D4) LaParl Leach complete, no violations3/26/2013 10:00 AM Weston #182 (D6) Leach LaParl complete, 19 regulatory violations, three SOP violations4/10/2013 10:00 AM Littleton #36 (D3) Spink Giando complete, no violations4/16/2013 10:00 AM Burlington #60 (D4) Giando Leach complete, one SOP violation4/18/2013 10:00 AM Foxboro #97 (D5) LaParl Fulgione complete, no violations4/23/2013 10:00 AM I-90 Toll Bldg #209 (D6) Leach LaParl complete, one regulatory violation, one SOP violation5/1/2013 10:00 AM Truro #113 (D5) LaParl Fulgione complete, no violations5/15/2013 10:00 AM Ware #121 (D2) Abbott Spink complete, no violations5/15/2013 10:00 AM Granby #120 (D2) Abbott Spink complete, no violations5/20/2013 10:00 AM Duxbury Spink Fulgione complete, no violations5/29/2013 10:00 AM Boylston #122 (D3) Abbott Giando complete, no violations6/4/2013 10:00 AM Air Intake Struct #207 (D6) Fulgione LaParl complete, no violations6/4/2013 10:00 AM Boxford #58 (D4) Giando Leach complete, one SOP violation6/11/2013 10:00 AM Avon #86 (D5) Leach Fulgione complete, no violations6/18/2013 10:00 AM Goshen #5 (D1) Spink Abbott complete, three regulatory violations, one SOP violation7/9/2013 10:00 AM Stoughton #110 (D5) Spink Fulgione complete, no violations7/11/2013 10:00 AM CMF #183 (D6) Giando LaParl complete, two regulatory violations, two SOP violations7/16/2013 10:00 AM Sturbridge #44 (D3) Abbott Giando complete, no violations7/23/2013 10:00 AM Manchester #70 (D4) LaParl Leach complete, no violations8/1/2013 10:00 AM Orange #22 (D2) Leach Spink complete, no violations8/6/2013 10:00 AM Dartmouth #91 (D5) Giando Fulgione complete, two SOP violations9/4/2013 10:00 AM Becket #2 (D1) Spink Abbott complete, no violations9/5/2013 10:00 AM Framingham #123 (D3) Abbott Giando complete, no violations9/12/2013 10:00 AM Vent Bldg 4 #200 (D6) Fulgione LaParl complete, no violations9/17/2013 10:00 AM Lawrence #67 (D4) LaParl Leach complete, no violations9/19/2013 10:00 AM New Bedford #139 (D5) Leach Fulgione complete, no violations9/20/2013 10:00 AM Vent Bldg #3 #199 (D6) Giando LaParl complete, one regulatory violation, one SOP violation, one BMP10/1/2013 10:00 AM Revere #44 (D4) Fulgione Leach complete, no violations10/9/2013 10:00 AM Taunton #112 (D5) Spink Fulgione complete, no violations10/15/2013 10:00 AM Palmer #23 (D2) Abbott Spink complete, 2 BMPs10/17/2013 10:00 AM Allston/Brighton S&I #193 (D6) Giando LaParl11/5/2013 10:00 AM Lancaster #34 (D3) Abbott Giando11/7/2013 10:00 AM Seekonk #108 (D5) Leach Fulgione11/12/2013 10:00 AM Andover #52 (D4) Fulgione Leach

Audit Schedule - 2013Second Cycle

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

http://db.state.ma.us/dep/ust/ustQueryPage.asp

http://db.state.ma.us/dep/cleanup/sites/search.asp

http://www.epa-echo.gov/echo/compliance_report.html

ENVIRONMENTAL COMPLIANCE AUDIT CHECKLIST

=

Facility Information

Facility Name:

Address:

City, State, Zip:

Facility Representative:

Title:

Telephone:

Fax:

Auditing Information Regulated Activities

Date of Audit:

Auditor:

Signature:_______________________________________________________

EMS Compliance Coordinator:

Persons Interviewed:

Inaccessible Areas:

General Comments:

Vehicle Fueling

Vehicle Washing

Wastewater Recycling System

Industrial Wastewater Discharge

Oil Water Separator

Industrial Wastewater Holding Tank

Waste Oil Generation

RCRA Hazardous Waste Generation

Universal Waste Generation

Hazardous Materials Use/Storage

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) Citation

YES NO N/A 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: VSQG SQG Facility Waste Oil Generator Status: VSQG SQG

SQG 30.351(1) VSQG 30.353(1)

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)


SECTION 1: HAZARDOUS WASTE (CONT’D) Citation

YES NO N/A 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)


SECTION 1: HAZARDOUS WASTE (CONT’D) Citation

YES NO N/A 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)

30.205(19)

Is the space heater operated only between September 15th and June 15th? (7.04(9)(d)4.) 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)


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-94-092

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:



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 Other: If the facility is supplied with municipal water answer backflow devices questions below.

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)


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)? Yes No If yes, where do they discharge to: POTW Surface Water Ground Holding Tank Other

Describe:

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? POTW Surface Water Ground Other, describe:

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? 314 CMR 18.00

If Yes, is the Facility in compliance with permit conditions? 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


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


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)


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? Policy ENF-05-001

If Yes, list and describe status:


Additional notes/Comments:


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


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


Program Fieldbook

Page 1 of 7 July 2011

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.

MassDOT Environmental Compliance Audit Program Fieldbook


State Environmental Regulations

State Law/Regulation Subject MGL c. 111 § 2B-2C; § 31C; § 142A-142M; 150A-B Air Quality 310 CMR 7.00 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 Hazardous Waste Management 310 CMR 30.0000 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

Hazardous waste management for VSQG and SQG

310 CMR 30.310 Manifests


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 O&M of buildings/structures/garages/service stations for gasoline or other motor fuel storage/use

527 CMR 6.00 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

527 CMR 9.07 General provisions: Abandoned USTs, Tank removal, Registration and permitting of tanks

MGL c. 21E MGL c. 21H Waste Site Cleanup 310 CMR 40.0000 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 Maintenance of Response Action Outcomes & Activity and Use Limitations

310 CMR 40.0300 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



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

310 CMR 19.021 Closure of Un-permitted Waste dumps

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

Water Pollution Control; Underground Injection Control

310 CMR 15.00 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

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


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 Asbestos & Radiation 105 CMR 410.000 Maintenance of asbestos-containing materials

453 CMR 6.00 Licensing and protection of asbestos workers

310 CMR 7.09; 310 CMR 7.15

Demolition/renovation of asbestos containing materials

310 CMR 19.061 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 Right to Know 105 CMR 670.000 Massachusetts right-to-know law

310 CMR 33.00 Community right-to-know: Filing of Material Safety Data Sheets with DEP

454 CMR 21.00 Employee right-to-know



Federal Environmental Regulations

Federal Regulation Subject

Air Quality 40 CFR 61 National Emission Standards for Hazardous Air Pollutants

(NESHAPs) (Asbestos) 40 CFR 82 Ozone depleting substances (ODS)

Federal hazardous Waste Regulations

40 CFR 266 Subpart G Spent Lead-Acid Batteries Being Reclaimed

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) – Emergency Planning and Right-to-Know Regulations

40 CFR 311- (29 CFR 1910.120)

Worker Protection – hazardous waste operations and emergency response

40 CFR 355 Emergency planning and notification – CERLCA extremely hazardous substances reportable quantities (RQs)

40 CFR 370* 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

40 CFR 403 General pretreatment standards for existing and new sources of pollution

33 CFR 320-330 US Army Corps of Engineer Regulations (Massachusetts Programmatic General Permit)

Wildlife

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 US Coast Guard Protection of Navigable Waters

* Voluntary participation


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

BWP/DHW-92-02 Waste Management Guidance for Industrial Wipers and Sorptive Minerals Contaminated with Waste Oil

BWP-94.092 Reuse and Disposal of Street Sweepings

ABC Guide (rev 2/2000) Guide to Regulations for Using or Processing Asphalt, Brick and Concrete Rubble

BWP-95-005 Management Requirements for Hazardous Waste Batteries intended for Recycling

DWSG97-1 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)

http://www.mass.gov/dep/recycle/approvals/oscarpkg.pdf

http://www.mass.gov/dep/recycle/laws/spacehtr.pdf

http://www.mass.gov/dep/water/laws/mc_stormw.htm

http://www.mass.gov/dep/water/laws/2010eg.htm



Executive Orders

Executive Order No. Subject 484 Leading By Example – Clean Energy and Efficient Buildings

515 Establishing an Environmental Purchasing Policy


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