Emsmanual

Environmental
Management
System Manual
Table of Contents
Table of Contents
Environmental Commitment
Executive Summary
SECTION I – General Roles and Responsibilities

Executive Office of Transportation and Construction.................................. 1
Commissioner .................................................................................................... 1
Chief Engineer ................................................................................................... 1
Chief Counsel .................................................................................................... 2
Administrative Services Division..................................................................... 2
Projects Division ................................................................................................ 3
Environmental Section...................................................................................... 3
Right of Way Section ........................................................................................ 4
Highway Operations Division .......................................................................... 4
Privatization Engineer....................................................................................... 5
Construction Division ........................................................................................ 6
Research and Materials Laboratory............................................................... 7
EMS Task Force ................................................................................................ 7
Districts ............................................................................................................... 8
SECTION II - EMS Components

Funding....................................................................................................................... 9
Environmental Requirements .............................................................................13
Emergency Preparedness ...................................................................................17
Standard Operating Procedures ........................................................................21
Facility Environmental Handbook and Maps..................................................23
Training.....................................................................................................................26
Compliance Tracking ............................................................................................31
Self-Auditing............................................................................................................34
Pollution Prevention..............................................................................................38
Environmental Management System Manual

December 2003
EMS Review and Evaluation ...............................................................................40
Section III - Contacts and Information Sources

Contacts....................................................................................................................43
Information Sources..............................................................................................45

December 2003
Executive Summary
Executive Summary
Background
In 1994, in response to an Administrative Consent Order with the Department of Environmental
Protection, MassHighway began a comprehens ive environmental compliance initiative at its
maintenance facilities. At the outset, the Department performed a gap analysis to evaluate
MassHighway’s management structure and to determine the level of environmental compliance.
The gap analysis concluded that a significant financial and personnel investment was needed to
correct violations of regulatory requirements and to provide a method to ensure on-going
compliance. The need to develop and institutionalize a formal Environmental Management
System to support environmental compliance was thus identified. The efforts to develop this
system were supported by senior management at MassHighway and the Executive Office of
Transportation and Construction (EOTC). As a result, separate Management System
Improvement and Implementation Plans were prepared. Together these plans outlined the
programs and funding needed to achieve environmental compliance. During the development of
these plans it was determined that the majority of the funding for environmental compliance
would be directed toward “cleaning up” the previously accumulated wastes located at the
facilities. Six major compliance programs were immediately created: Hazardous Waste,
Wetlands, Hazardous Materials, Underground Storage Tanks, Water Quality and Solid Waste.
Under the Hazardous Waste and Solid Waste Programs, these wastes were removed and either
properly disposed of or recycled. New waste/material storage areas and equipment for spill
management were also provided through the Hazardous Material Program. The Water Quality
Program provided for facility improvements such as septic system upgrades/installation, sewer
connections, floor drain upgrades and the installation of wash water recycling systems. The
Wetland Program provided for the identification of impacts to wetlands and the development and
implementation of corrective actions. The Tank Program replaced or upgraded all USTs to meet
Federal standards. Subsequent to the development of the management plans, an additional
compliance program was instituted for managing MassHighway’s asbestos issues.
MassHighway further published a Facility Environmental Handbook particular to each facility.
This handbook is a reference document that provides guidance on conducting operations in
compliance with environmental requirements. It contains standard operating procedures and
maps to identify structures and environmentally sensitive areas such as wetlands. The handbook
is used to train MassHighway personnel on an annual basis and raise the level of environmental
awareness.
Environmental Compliance and the EMS Manual

While providing facility staff with the appropriate tools and upgrading the facility infrastructure
were important first steps, the Department also recognized that continued environmental
compliance is dependent upon the development of clear lines of authority, responsibility and
accountability for environmental management and identification and allocation of adequate
funding. This Environmental Management System (EMS) manual serves that purpose in that
it documents the lines of authority and the respective roles and responsibilities within the
December 2003
Department. This manual also provides the framework to instill an operating awareness at all
organizational levels of the importance of integrating sound environmental management
practices into the operations of the Department.
MassHighway has designed the EMS in accordance with a Plan, Do, Check, Act improvement
cycle. While considerable time has been invested in planning how the system should work, the
Department recognizes that the EMS must be dynamic and adaptive to regulatory and
operational changes. To meet this need a regular review process will be in effect to ensure that
the system can be modified and continually improved to meet the Department’s objectives.
Do
Plan
Act
Do Check Act
EMS
Check
Continuous Improvement Cycle
Environmental roles and responsibilities have been assigned to all levels of MassHighway. A
general description of roles and responsibilities of each Division, Section, and District is
provided in Section I of this manual. Procedures for implementing each component of the
system as well as a description of an employee’s specific role and responsibility is described in
further detail in Section II of the manual.

December 2003
MassHighway’s EMS consists of specific components which serve separate and distinct
purposes but are integrated to become part of the overall system. An overview of these
components is provided below.
Environmental Management System Manual Overview

EMS Component Description
Funding Identifies the process and responsibilities for allocating adequate
funding for environmental compliance at MassHighway Facilities.
Environmental Discusses the environmental laws and regulations that apply to operations at
Requirements maintenance facilities, and the procedures for identifying proposed and new
regulatory changes that affect operations at maintenance facilities.
Emergency Preparedness Identifies the MassHighway procedures for planning and responding to spills at
MassHighway facilities.
Standard Operating Describes the methods for identifying the need for environmental standard operating
Procedures procedures (SOPs) as well as the development, review, revision and, endorsement
of environmental SOPs to guide facility staff on environmental management
requirements.
Facility Environmental Identifies the purpose of the Facility Environmental Handbook and Maps and,
Handbook and Maps provides for the identification of the roles and responsibilities for updating the
handbook.
Training Documents the procedures for planning, delivering and tracking environmental
training of MassHighway personnel that support environmental compliance.
Compliance Tracking Defines the procedure MassHighway uses to identify, correct, and track compliance
issues.
Self-Auditing Describes the procedures for conduct of MassHighway’s program for evaluating the
status and return to environmental compliance at MassHighway Facilities.
Pollution Prevention Describes the activities MassHighway conducts to prevent pollution through
conservation and reduction programs.
EMS Review and Evaluation Describes the procedures and schedules for review and update of MassHighway’s
EMS and its associated Manual.

December 2003
Section 1
General Roles and Responsibilities
General Roles and Responsibilities
Below are the descriptions of the organizational roles and responsibilities relative to
environmental compliance management at MassHighway facilities. Personnel within the major
Organization Offices, Divisions, Districts and Sections that affect compliance with
MassHighway environmental requirements are identified. The implementation of this EMS
ensures that MassHighway facilities are operated and maintained in compliance with federal and
state regulations and policies and Consent Agreements. To support the EMS, all MassHighway
employees are expected to conduct their job in a manner that will support this EMS. This effort
will foster the integration of environmental stewardship into facility operations. Therefore, roles
and responsibilities for environmental management have been established and employees shall
be educated as how to best carry out their environmental related duties. The following sections
provide an overview of the EMS roles and responsibilities for personnel in the Organization
Offices, Divisions, Districts and Sections.
Executive Office of Transportation and Construction

The Executive Office of Transportation and Construction (EOTC) is responsible for monitoring
and approval of electronic Clean State quarterly progress reports related to compliance matters
as required by the Administrative Consent Order(s). The quarterly reports are transmitted to the
Executive Office of Environmental Affairs and the Massachusetts Department of Environmental
Protection (DEP). This reporting is conducted in accordance with MassHighway’s ACO with
the DEP. MassHighway also uses this quarterly report to reconcile Facility compliance
information as part of MassHighway’s Self Auditing Program.
Commissioner
The Commissioner is responsible for ensuring that MassHighway’s EMS is integrated as a
fundamental part of daily operations and is supported by all managerial and supervisory levels of
the Department. In doing so, the Commissioner’s Office ensures the following:
• The EMS is consistent with the Department’s overall Mission Statement, Goals and
Objectives;
• The facilitation of agreements with other Massachusetts State Departments including the
Department of Environmental Protection;
• Adequate EMS related funding and staff levels as recommended by the Chief Engineer.
Chief Engineer
The Chief Engineer ensures that the needs for staffing and resources for the sustainability of this
EMS are defined and communicated to the Commissioner and that environmental policies and
programs are effectively implemented and communicated by senior management. The Chief

December 2003
Page 1
Engineer also ensures that the EMS is reviewed on a regular basis and that practical measures are
implemented to improve its effectiveness.
Chief Counsel
The Chief Counsel provides legal support and advice to the Department relative to regulatory
and legal issues involved with supporting the EMS including the Department’s obligations for
adhering to all applicable environmental requirements, Administrative Consent Orders and,
Agreements. The Chief Counsel ensures that a member of its staff is knowledgeable of
environmental requirements and available to assist the Department in meeting its
EMS/regulatory goals and objectives.
Administrative Services Division

The Administrative Services Division provides MassHighway EMS support in areas of Budget,
Training, Safety, Information Technology Systems (ITS), and Personnel. A summary of the
roles and responsibilities for the Administrative Services Division is provided below.
Administrative Services Division Roles and Responsibilities

Role Responsibility
Director of Ultimately responsible for providing ITS, training budget, safety and general personnel
Administrative support to the EMS. Has been assigned the overall responsibility for administrative support
Services services for the Department.
Information Responsible for supporting EMS information management tools including EnviroTrac
Technology Systems system, and posting of the EMS documents on the MassHighway intranet. Provides
software and hardware support.
Training Responsible for the tracking of environmental training, preparation and monitoring of the
environmental training budget
Budget In cooperation with the Operation Division sand the Environmental Section, prepares the
annual spending budget for compliance activities at MassHighway Facilities. Coordinates
with the District Administrative Managers on the allocation and management of the funds for
compliance activities
Safety Presents annual Right-to-Know training for facility personnel. Responsible for regular facility
inspections for emergency response supplies and material safety data sheets. Responds to
exposure issues to suspected asbestos fiber releases. Responds to material/wastes
deposited on rights of way and highway spills.
Personnel Provide human resource support to the Department.

December 2003
Page 2
Projects Division
The Projects Division is responsible for ensuring that environmental laws and regulations are
considered and properly addressed during the design phase of projects at MassHighway facilities
and directly supports all components of the Environmental Management System. The Projects
Division consists of the following Sections; Bridge, Highway Design, Highway Administration,
Right of Way, Project Management and, Environmental. The Section primarily responsible for
stewardship of the EMS is the Environmental Section.
Environmental Section
The Environmental Section provides expertise in interpretation of environmental regulations,
compliance program development and implementation, compliance budget analysis, compliance
inspection and reporting and environmental SOP/policy review and development. The
Environmental Section supports the EMS with defined roles and responsibilities to maintain
environmental compliance at facilities. Below is a summary of general Environmental Section
roles and responsibilities. Specific roles and responsibilities are provided in the descriptions of
the individual EMS components of this manual.
Environmental Section Roles and Responsibilities

Role Responsibility
Deputy Chief Engineer Responsible for managing the Sections roles and responsibilities relative to this EMS;
Environmental ensures that the EMS review is conducted and continual improvements are made within
the Section.
Supervisor of HazMat Serves as the steward for the EMS. Responsible for the accuracy of the manual and its
/HazWaste Unit specific components including funding, Emergency Preparedness, Environmental
Requirements, SOPs, Facility Handbook, Training, Compliance Tracking and, Self-
Auditing, and EMS Review. Coordinates and facilitates programs including Hazardous
Waste, Wetlands, Hazardous Materials, Tanks, Water Quality, Solid Waste,
Massachusetts Contingency Plan. Assigns tasks to Unit personnel to ensure compliance
with State and Federal regulations. Maintains current Environmental Requirements List;
arranges quarterly meetings with regulatory agencies; assists the Deputy Chief Engineer
Environmental with EMS review process.
Audit Coordinator Ensures that the Self -Audit Program functions in accordance with the MassHighway Self
Audit Protocol. Performs regular review of the program and recommends modifications in
accordance with changes in MassHighway’s operations at Facilities.
Training Coordinator Administers Environmental Training Program by maintaining a current lis t of required
training and notifies respective staff of upcoming training. Coordinates submittal of
training registration documentation. Maintains training records for Environmental Section.
EMS Task Force Participates in the annual EMS Review and evaluation process.
Supervisor of Manages NOI and RDA process; obtains and tracks Order of Conditions; file
Wetlands and Water Completeness Reports; oversees Departments compliance with storm water regulations.
Quality Ensures corrective actions are implemented to comply with the Massachusetts Wetland
Regulations and Administrative Consent Orders.

December 2003
Page 3
Role Responsibility
District HazMat Play key roles in implementation of EMS component programs including Requirements,
Coordinators Self-Audits/Inspections, Emergency Preparedness, Environmental Training, and SOP
programs. May arrange for inspection of systems (septic systems, holding tanks,
oil/water separators, and vehicle wash recycling systems). May arrange for disposal of
wastewater; forward water usage reports to Supervisor of HazMat\HazWaste Unit;
ensures that monitoring wells are inspected, permits/as -built plans are kept at facilities,
compliance with permit-specific requirements, inspects for presence of appropriate
backflow prevention devices on drinking water sources/cross connections; conducts
regular inspections of facilities, assists in obtaining Material Safety Data Sheets, assists in
identification of unknown roadside materials; prepares Tier II Reports; manage MCP
consultant contracts and provide MCP technical assistance; assists Supervisor of HazMat
HazWaste Unit with on-site observation of contractor work; sign MCP submittal
certifications; maintain hazardous waste generator registration and manifest files;
arrange/notify when waste disposal is required; arrange for removal of unknown/roadside
wastes; develop and conduct annual environmental awareness training; review options
for street sweeping disposal; conduct facility audits
Boston HazMat Staff Play key roles in implementation of EMS components including Environmental
Requirements, Environmental Training, and SOPs. Manage contracts and timelines to
support compliance with environmental requirement, EMS support programs and
administrative consent orders; submit reports that track compliance progress to DEP and
EPA. Track the status and provide guidance on permit renewal and assist as needed to
ensure MassHighway remains in compliance with applicable permits. Manage MCP
consultant contracts; assist supervisor of HazMat/HazWaste Unit with MGL ch. 21E and
the MCP tank permitting; manage Stage II Vapor Recovery forms/documentation; assist
with NOI and RDA process
Right of Way Section

The Right of Way (the Section) is responsible for ensuring that properties being considered for
purchase by MassHighway for use as facilities receive proper real estate assessment for the
identification of environmental compliance liabilities. The Section is also responsible for
ensuring that facility properties receive canvassing by MassHighway Environmental staff prior
to disposition.
Highway Operations Division

The Highway Operations Division is responsible for the implementation of the EMS to ensure
that Districts/facilities receive proper personnel and contract support to ensure compliance with
environmental regulations, MassHighway SOPs and policies and, Administrative Consent
Orders. The Highway Operations Division is responsible for ensuring that all permits are
secured for construction and improvement activities at facilities and that copies of all permits are
forwarded to the Projects Division/Environmental section. For the purpose of the EMS,
Highway Operations pays particular attention to current facility operations such as snow and ice
operations, proposed facility improvements and, lease agreements involving MassHighway
facilities. Highway Operations staff ensures that the EMS is properly implemented at
maintenance buildings and draw bridges and at the Line Painting Facilities located at Deerfield,
Reading and Bridgewater facility locations. A summary of roles and responsibilities for the
Highway Operations Division staff is presented below.

December 2003
Page 4
Highway Operations Division Roles and Responsibilities
Role Responsibility
Deputy Chief Engineer Ensures that the EMS review is conducted and continual improvements are made within
Highway Operations the Division to ensure compliance with the EMS related to facility operations.
Highway Operations Ensures proper support of the EMS from Highway Operations including Communications,
Engineer Drainage Structure Maintenance, Bridge Maintenance; ITS Programs (HOV Lane).
Ensures that MassHighway personnel are aware of Environmental requirements,
Environmental Standard Operation Procedures and policies and that contracts contain
proper language to support the EMS and adherence to environmental permitting Standard
Operation Procedures, Policies and Administrative Consent Orders. Ensures that copies of
permits are forwarded to the respective District and the Environmental Section.
Facilities Engineer Provides contract support and guidance to Highway Operations personnel and District
maintenance personnel in such a manner that supports compliance with the EMS. The
Facilities Engineer ensures that personnel are aware of MassHighway Environmental
Standard Operating Procedures, Policies, Administrative Consent Orders and
environmental regulatory requirements. The ensures that facility project designs include
proper environmental permitting in accordance with Federal and state regulations. The
Facilities Engineer ensures that provisions are included for the proper operation of
completed designs (septic system, floor drain discharge etc.) in accordance with issued
environmental permits.
Maintenance Engineer Provides contract support and guidance to Unit and District maintenance personnel in such
a manner that supports compliance with the EMS. The Maintenance Engineer ensures
that personnel are aware of MassHighway Environmental Standard Operating Procedures,
Policies, Administrative Consent Orders and environmental regulatory requirements. The
Maintenance Engineer ensures compliance with environmental requirements, SOPs and
Policies for activities related to the Central Stockroom in Franklin, Heavy Equipment
maintenance, repair, storage of vehicles at state auctions, Truck and Car fleet, Medford
Sign Shop, Paint Crew (long Lines) and , Fuel Management. The Maintenance Engineer
ensures that appropriate provisions are included within contracts to support the EMS. The
Maintenance Engineer ensures snow and ice/Roadside operations are conducted in a
manner that supports MassHighway environmental SOPs and, environmental regulations
and that the District Maintenance Engineers maintain awareness and support compliance
with the EMS. Responsible for implementation of the EMS and environmental compliance
for Line Painting operations including cleaning of painting equipment without releasing
cleaning residuals into the environment and ensures proper storage of any hazardous
material and/ or wastes. Ensures that the foreman of each paint crew coordinates
environmental related activities with the respective Facility Foreman to ensure
environmental compliance.
Director of Equipment Provides for EMS compliance at the Central Stockroom relative to proper hazardous
and Materials material storage, appropriate HazMat labeling/signage, and proper management of
Material Safety Data Sheets. Purchases materials that support EMS such as absorbents
(pads, booms, Speedi-dri) spill kits for distribution to District stockrooms, and maintains an
effort to purchase environmentally preferred products whenever practical. Ensures an
adequate supply of fuel equipment such as nozzles and hoses that comply with the
Department’s current fueling system. Provides for the support of the Department fuel
management system; perform testing, inspection and reporting of storage tanks and
monitors storage tank leak detection systems. Ensures that decommissioned vehicles are
stored in a manner that supports compliance with the Departments SOPs, and this EMS.
Administrator of Responsible for the implementation of the EMS and environmental compliance at the HOV
ITS/HOV Lane Facility including: monitoring compliance with applicable permits; maintaining
permits/as -built plans at the facility; scheduling installation of appropriate backflow
prevention devices; establishing proper hazardous material storage areas; providing
appropriate HazMat labeling/signage; establishing appropriate temporary accumulation

December 2003
Page 5
areas for hazardous waste, universal waste, special waste and solid waste; managing
accumulation areas, dumpsters and storage sheds; arranging testing, inspection and
reporting of storage tanks
Privatization Engineer
The Privatization Engineer oversees the management of privatized maintenance areas and
ensures that appropriate provisions for environmental management are in place. The
Privatization Engineer prepares contracts on a biennial basis and coordinates with the
Environmental Section to ensure that appropriate environmental provisions are incorporated into
privatized contracts to support the EMS.
Construction Division
The Construction Division is responsible for ensuring that environmental laws and regulations
are considered and properly addressed during construction of projects on MassHighway
facilities.
Research and Materials Testing Laboratory

The Research and Materials Testing Laboratory is respons ible for ensuring that the laboratory is
operated in accordance with federal and state regulations and MassHighway’s SOPs in support
of MassHighway’s EMS.
EMS Task Force

The EMS Task Force is composed of representatives of Offices, Divisions, Districts, and
Sections. The Task Force provides input to the Annual EMS Review and Evaluation Process.

December 2003
Page 6
Districts
The Districts are responsible for the implementation of the EMS at District facilities and to
ensure that operations at facilities are in compliance with environmental regulations and
MassHighway SOPs. A summary of District EMS roles and responsibilities for facility
compliance is provided below.
District Roles and Responsibilities

Role Responsibility
District Highway The District Highway Director is responsible for being familiar with and overseeing the
Director implementation of the provisions of the EMS such that the District’s roles and
responsibilities are carried out in such a manner so as to maintain environmental
compliance.
District Maintenance The District Maintenance Engineer (DME) must maintain an awareness of the EMS and is
Engineer responsible for coordinating facility maintenance activities in accordance the procedures
of the EMS Manual. This includes ensuring that facility personnel are allotted sufficient
time to perform house keeping tasks that support environmental compliance and notifying
appropriate MassHighway personnel of an emergency situation at facilities in accordance
with MassHighway’ s Emergency Response Plan (ERP) and Spill Prevention Control and
Countermeasure (SPCC) Plans at specific facilities. Obtains and ensures compliance with
all applicable permits for District facilities.
Contract Specialist The Contract Specialist III/Area Supervisor (CS III/AS) ensures that: all personnel within
III’s/Area Supervisor the Area receive yearly Annual Environmental Awareness Training; facility inspections are
conducted and that corrective actions are completed as required; EMS and Environmental
Program documentation (generated by Facility Foreman and personnel) such as regular
inspection checklists, Stage II Vapor recovery system checklists, Hazardous Waste area
inspections checklists and oil/water separator inspection reports are forwarded to the
District Maintenance Engineer. Responsibilities also include: review and submittal of the
facility inspection reports/self-audit findings to the DME and initiating corrections as
required; scheduling work as needed at facilities to maintain compliance including: septic
system pump-outs, septic system inspections, vehicle washing recycling system
maintenance and holding tank and oil/water separator pump-outs. The CS III/AS is also
the designated Primary Emergency Coordinator as defined by MassHighway’s
Emergency Response Spill Plan.
Contract Specialist The Contract Specialist II/ Facility Foreman (CSII/FF) is responsible for ensuring that all
II’s/Facility Foreman operational activities that impact environmental compliance at District Facilities are
conducted in accordance with the EMS and specifically with the provisions of the Facility
Environmental Handbook. This includes maintaining proper areas for material and
hazardous waste storage; using the emergency response call down procedures; adhering
to guidelines presented in the Annual Environmental Awareness Training; staying current
with the Environmental Standard Operating Procedures and being familiar with the
location of wetlands, buffer zones and other areas of environmental concern.
Facility Personnel The Facility Personnel are res ponsible for keeping work areas clean and materials and
wastes stored properly, performing inspections on the Hazardous Material and Hazardous
Waste storage areas, maintaining labels on material and waste containers, reporting spills
of hazardous materials from machinery and heavy equipment and, attending annual
refresher training related to environmental compliance.

December 2003
Page 7
Section 1I
EMS Components
Plan Act
EMS
Check
Do
Funding
Funding
Annual review of funding needs and sources is critical for maintaining environmental
compliance at MassHighway’s facilities. Projects, Environmental, Highway Operations, and the
Districts are all responsible for identifying the operational areas that require environmental
compliance funding to the Administrative Services Division. Environmental monitors the need
for consultant and contractor services and generally provides Project Manager support for
capital- funded projects. Highway Operations maintains an awareness of District and facility
activities that will impact environmental compliance and activities that require funding to
maintain compliance. Highway Operations will review annual compliance budgets prepared by
the Districts and provide recommendations regarding the approval to Administrative Services.
The Districts are responsible for identifying specific activities that impact environmental
compliance and are responsible for providing accurate estimates for the annual budget. The
District HazMat Coordinators may assist with the District budget preparation and validation
process.
Administrative Services identifies the potential accounts available to support the funding
requests. This annual review coincides with the Commonwealth of Massachusetts fiscal year,
which begins on July 1 and ends on June 30. Financial resources for environmental compliance
at facilities are provided from two sources: legislative appropriations for operational budget
needs and transportation bonds that are eligible for capital funded projects. Ultimately,
Administrative Services is assigned funding from the State Department of Administration and
Finance.
An overview of the procedure that the Department will follow in identifying and soliciting
funding for implementing the EMS and a description of the roles and responsibilities with
MassHighway is provided below.
Capital (Bonded) Spending Plan

The Deputy Chief Engineer Environmental ensures that funding needs for environmental
compliance are identified and communicated to the Chief Engineer for incorporation into the
Capital Spending Plan. Project’s Training Coordinator identifies funding needs for
environmental training programs. The Supervisor of HazMat\HazWaste Unit, with input from
Environmental staff, identifies funding needs for consultant contracts that will support various
environmental projects such as 21E/MCP site cleanup and consultant auditing programs.
Highway Operations and District staff provide input to the Environmental Section regarding
funding needs for Highway Operations programs having an environmental-related capital
requirement. Below is a summary of typical environmental compliance budgetary needs that are
included in the yearly Capital Spending Plan.

December 2003
Page 8
Capital Spending Plan Requirements
Requirement Description
21E/MCP Projects Cleanup of contaminated sites.
DEP and EPA Consent Order Matters Implementation of DEP and EPA Consent Order-mandated environmental
projects to address Consent Order mandates.
3rd Party Environmental Compliance Environmental Compliance Audits of all maintenance facilities to be
Audits conducted by an outside audit firm.
Self-Audits Implementation of EMS Self-Audit Program via District HazMat

Coordinators and consultant-assisted audits.
Environmental Training Programs Implementation of regulatory-based training programs such as

hazardous/universal waste management and emergency spill response
training requirements.
Consultant Contracts for Compliance Procurement of consultants to implement capital environmental projects
Program design support i.e. Water Quality, Wetlands, Solid and Hazardous Waste, Hazardous
Materials, and Tanks.
The roles and responsibilities for funding through the Capital Spending Plan are described
below.
Capital Spending Plan Roles and Responsibilities

Role Responsibility
Administrative Services Preparation of the Department’s Capital Spending Plan and submits the
final spending plan to Administration and Finance
Chief Engineer Submits the Division budgets to Administrative Services and, approves the
Department Spending Plan prior to submittal to Administration and Finance.
Deputy Chief Engineer Prepares capital funding needs for submittal to the Chief Engineer
Environmental
Training Administrator Identifies funding needs for environmental training programs
Supervisor of HazMat\HazWaste Identifies projected funding needs for consultant contracts

Unit
Environmental Staff Provide input to the Supervisor of HazMat\HazWaste Unit and to the
Training Administrator concerning environmental program funding needs
Highway Operations Staff Provide input to Environmental concerning environmental program funding
needs

December 2003
Page 9
Operational Spending Plan
The Chief Engineer maintains ultimate responsibility for ensuring that funding for operational
needs is identified and solicited for the Operational Spending Plan. The Deputy Chief Engineer
Highway Operations and the Deputy Chief Engineer, with input from the District Highway
Directors, District Administration Managers, District Maintenance Engineers, District HazMat
Coordinators, the Maintenance Engineer, and the Deputy Chief Engineer, Environmental
prepares the Operational Spending Plan for submittal to the Chief Engineer. A summary of
typical environmental needs that are included in the Operational Spending Plan is provided
below.
Operational Spending Plan Requirements

Requirement Description
Solid Waste Disposal Disposal of accumulated solid wastes including, but not limited to, street
sweepings, catch basin cleaning, tires, C&D waste, ABC waste, wood
waste, and trash.
Hazardous/Medical Waste/ Disposal Disposal of hazardous waste, waste oil, universal waste, and medical
waste.
Wastewater Disposal Analysis and disposal of industrial holding tank wastewater, oil/water
separator cleaning, septic tank pump outs, etc.
Inspection & Testing Inspection and testing of storage tanks and associated leak detection
equipm ent; inspection and testing of Stage II vapor recovery equipment.
Spill Containment Equipment & Leak and spill response supplies, absorbent materials, etc.
Supplies
The Deputy Chief Engineer Highway Operations submits the spending plan to the Chief
Engineer for review. Upon approving the final spending plan, the Chief Engineer submits the
plan to Administrative Services. Administrative Services compiles the Department Spending
Plan for submittal to Administration and Finance. A summary of the roles and responsibilities
for the Operations Spending Plan is provided below.
Operational Spending Plan Roles and Responsibilities

Role Responsibilities
Administrative Services Compiles and submits the Department Spending Plan to
Administration and Finance.
Chief Engineer Approves the Spending Plan and submits it to Administrative

Services.
Deputy Chief Engineer Highway Operations Assumes responsibility for ensuring that Boston Operation’s
environmental compliance funding needs are identified and
solicited.

December 2003
Page 10
Role Responsibilities
Highway Operations Engineer Identifies projected environmental compliance funding needs

for activities at facilities
Maintenance Engineer Identifies projected environmental compliance funding needs
for activities at facilities
District Highway Directors Assume ultimate responsibility for ensuring that District
Operations environmental compliance funding needs are
identified and solicited.
District Operations Engineer Identifies projected environmental compliance funding needs

for Boston Operation activities at facilities.
District Maintenance Engineers Identify projected environmental compliance funding needs for
District operations.
Environmental Section Staff Provide input concerning environmental program funding

needs.
District Administration Managers Prepare the district budgets for submittal to the Chief
Engineer.
Operational Fund Distribution

Upon approval of the Department’s overall spending plan and notice of funding by the State
Legislature, Administrative Service’s notifies the appropriate Divisions and Districts concerning
the availability of funds for environmental program needs. Highway Operations, Environmental
and the Districts encumber the funds by identifying program needs and procuring contractors.
Some contracts are administered through pre-approved Operational Services Division (OSD)
contracts (J39-Fund Contracts). The DME must manage the District spending schedule such that
routine maintenance funds are available during the time between the end of the fiscal year and
the availability of the next years funding without the need to tap emergency funds. Likewise,
Highway Operations is responsible for ensuring that Boston operational funds are appropriately
spent and that the spending schedule is appropriately managed.

December 2003
Page 11
Environmental Requirements
United States
Environmental Protection Agency
Environmental Requirements
This EMS component identifies the procedure for reviewing the applicability of state and federal
laws and regulations affecting MassHighway Maintenance Facilities. As regulations are subject
to change over time, and as new regulations are promulgated by regulatory agencies, periodic
reviews of regulations to stay current on compliance requirements are conducted as necessary.
Likewise, facility operations can change over time, and must also be periodically reviewed to
ensure that operations subject to regulation are conducted in compliance with such regulations.
MassHighway routinely reviews federal and state regulatory information sources to stay current
on compliance requirements.
MassHighway maintains an Environmental Requirements List, which identifies federal and state
environmental regulations applicable to MassHighway Maintenance Facilities. This 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
Pollution Control/Underground Injection Control/Drinking Water Supply (Water Quality),
Wetlands, and Asbestos. Environmental regularly reviews and updates the Environmental
Requirements List to reflect changes to facility operations, changes to existing regulations, or the
introduction of new regulations. The Environmental Requirements List is available for review in
MassHighway’s self- audit protocol document.
The procedure and roles and responsibilities for managing the Environmental Requirements
Component of the EMS are described below.
Procedure
During the course of the year, Environmental staff, as summarized in the following table, is
responsible for monitoring proposed regulations and policies applicable to current MassHighway
operations. Regulatory monitoring may include but not be limited to periodic review of DEP,
EPA and Federal Register websites for information on new or upcoming regulations. Also
reviewed are the existing Codes of Massachusetts and Federal Regulations (CMRs and CFRs).
Changes in facility operations will be identified through periodic inspections performed by
DHC’s and through regular communication between Highway Operations, District and,
Environmental Section staff.
Environmental staff regularly report information to the Supervisor of the HazMat/HazWaste

Unit, and/or the Supervisor of the Wetlands Unit regarding the status of changed or new
regulations, or regarding identified changes in facility operations subject to regulation. The
Supervisor of the HazMat/HazWaste Unit and the Supervisor of the Wetlands Unit in turn report
regularly to the Deputy Chief Engineer Environmental regarding the regulation status and the
potential effect on maintenance facility operations. The Supervisor HazMat/HazWaste Unit
convenes periodic meetings with the DEP Regional and Policy staff to review pending regulatory
changes that may affect Facility operations.
The Supervisor HazMat/HazWaste Unit determines whether revisions are needed to the
Environmental Requirements List, and if so, requests approval from the Deputy Chief Engineer
Environmental to revise the list and propose necessary changes to maintain compliance. The
December 2003
Page 12
need for any additional equipment and resources is coordinated within the Department, as
applicable. Upon receipt of the Deputy Chief Engineer Environmental directive, the Supervisor
HazMat/HazWaste Unit prepares the necessary revisions, posts the revised Environmental
Requirements List on the MassHighway intranet, and informs the Environmental Section staff of
the changes to the list and their respective implications on other EMS components.
Each year, the Supervisor HazMat/HazWaste Unit or other Designee coordinates a meeting to
review the current Environmental Requirements List and Requirements Program procedures.
The meeting will be convened with the Environmental Section Supervisors and Highway
Operation’s staff between November and January to coincide with the Facility Environmental
Handbook, Maps and Standard Operating Procedure review process. The criteria for the review
include opportunities to improve effectiveness and efficiency. The Supervisor HazMat/HazWaste
Unit collects the comments and reports recommended revisions to the Deputy Chief Engineer
Environmental.
Roles and Responsibilities

The following table presents a summary of the roles and responsibilities for review and
development of the Environmental Requirements List.
Requirements Roles and Responsibilities

Role Responsibility
Deputy Chief Engineer Environmental Assumes ultimate responsibility for managing the
requirements component of the EMS
Supervisor of HazMat/HazWaste Unit Responsible for tracking and review of existing and proposed
regulations and policies. Provides regular updates to the
Deputy Chief Engineer Environmental on status of pending
new regulations or changes to existing regulations or changes
to facility operations subject to regulation. Ensures that the
updated requirements list is incorporated into the facility self-
audit protocol. Maintains current Environmental Requirements
List and Requirements Procedure document.
Convenes/coordinates annual meeting to review
Requirements List and Requirements Procedure. Meets with
DEP regional office and policy staff to discuss pending
regulations that may affect MassHighway maintenance facility
operations.
Supervisor of Wetlands and Water Quality Responsible for tracking and review of existing and proposed
regulations and policies related to wetlands, waterways, and
natural resource protection programs. Provides regular
updates to the Supervisor HazMat/HazWaste Unit on status of
pending new regulations or changes to existing regulations.
District HazMat Coordinators and Boston Responsible for review of regulations and policies as directed
Environmental Section Staff by the Supervisor of the HazMat/HazWaste Unit. Responsible
for reviewing changes in facility operations and receiving input
from District Maintenance Engineers concerning facility
operational changes that could be subject to environmental
regulation/policy. Provides regular updates to the Supervisor
of HazMat/HazWaste Unit on status of pending new

December 2003
Page 13
Role Responsibility
regulations or changes to existing regulations, or changes to
facility operations subject to regulation.
Highway Operations Engineer, Maintenance Responsible for notifying Environmental Section staff
Engineer and District Maintenance Engineers concerning actual or anticipated changes in facility operations
that should be reviewed for compliance with
regulations/policies.

December 2003
Page 14
Emergency Preparedness
Emergency Preparedness
This EMS component establishes the procedures for planning for and responding to spills
at MassHighway maintenance facilities. The procedures are documented in two types of
written plans: (1) the Emergency Response Spill Plan for MassHighway Facilities (E-99-
005) which establishes procedures for responding to minor and major spills at facilities,
and (2) Spill Prevention Control and Countermeasure Plans (SPCC Plans) developed for
certain facilities that store oil in quantities triggering the requirements for a written plan in
accordance with 40 CFR 112. MassHighway ensures a regular review to identify changes
to existing spill plans and changes in facility operations but depends on Environmental,
Highway Operations to verify the applicability of the existing plans against current
operations and conditions at the Facilities. The procedure and roles and responsibilities for
managing the Emergency Preparedness Component of the EMS are described below.
Procedure
MassHighway has distributed the Emergency Response Spill Plan (ERSP) to all
MassHighway facilities. Spill Prevention Countermeasure Control (SPCC) plans have also
been prepared for those facilities that require a SPCC plan. These two plans assist
MassHighway personnel in responding to hazardous material spills at facilities. Personnel
having responsibilities under these plans are provided with the necessary training to ensure
they are competent to fulfill the roles established in the plans. Reports generated from
training drills assist MassHighway in making the plans more efficient and comprehensive.
Facilities have been supplied with emergency spill equipment for use in emergency
response. The District HazMat Coordinators and Safety Inspectors regularly inspect
maintenance facilities to ensure that adequate spill supplies are available and information
contained in the plans is current. Inspections generally confirm the following for those
facilities that maintain hazardous waste storage areas:
• Accessible telephone or two-way communication;

• Telephone number of the emergency coordinator;
• Telephone Number of local fire and police;
• Telephone number of the DEP;
• Easily accessible and portable fire extinguisher;
• Easily and accessible spill cleanup equipment;
• Readily available water supply;
• Documentation that employees have been instructed in emergency
response procedures

December 2003
Page 15
Review and Update Procedure s for Emergency Response Spill
Plan
(E-99-005)
The ERSP for MassHighway facilities outlines roles, responsibilities, and procedures for
responding to oil and hazardous material spills and has been developed in accordance with
29 CFR 1910.120 (q)(1) which states “An emergency response plan shall be developed and
implemented to handle anticipated emergencies prior to the commencement of emergency
response operations.” The plan is in place at all MassHighway Maintenance Facilities and
is available for review by facility personnel. In the event of an oil or hazardous material
spill, MassHighway personnel follow the procedures outlined in the ERSP, including
incident command structure, MassHighway notification procedures, reporting of spills to
regulatory agencies, and control and containment of oil and hazardous material spills. The
spill plan addresses two types of spill events, Minor and Major. MassHighway personnel
who receive the annual refresher training and participate in mock spill events are deemed
qualified to clean-up a minor spill as defined in the spill plan. Generally, minor spills can
be qualified as those that may result from the operation of an auto repair garage e.g.
accidental spills of motor oil during oil changes. A major spill event as defined by the plan
requires the attention of personnel trained under OSHA’s HAZWOPER Standard (29 CFR
1910.120). In the case of a Major spill, a qualified spill cleanup contractor will be
dispatched to the spill location to conduct the clean up.
Regular review of the ERSP for MassHighway facilities is necessary to ensure that the plan
reflects current operations at Maintenance Facilities. The ERSP is reviewed at least
annually to identify areas where updates and/or revisions are needed. The Supervisor
solicits input from Office, District, Division, and Section personnel to provide review and
comment, as deemed appropriate, on any emergency responses performed during the
previous year and make recommendations on procedural and organizational improvement
of the Plan. The Supervisor of Facility HazMat/HazWaste Unit updates the plan and
forwards it to the Deputy Chief Engineer Environme ntal for review. Upon receipt of
Deputy Chief Engineer Environmental approval, the revised plan is submitted to the Chief
Engineer and Division Engineers and District Highway Directors for approval. Upon
receipt of the Chief Engineer’s approval, the plan is submitted to the Commissioner for
signature. The Commissioner reviews and endorses the plan for distribution to the
Department. The DHCs ensure that the plans are distributed to the Maintenance facilities
and incorporate any changes into the annual Environmental Awareness Training program.
Review and Update Procedures for SPCC Plans

The Williamstown, Northampton, Lenox, Taunton and Franklin (Central Stockroom)
facilities currently have oil storage triggering the requirements for a written SPCC under 40
CFR 112 (i.e. 1,320 gallons aggregate above ground oil storage). The SPCC Plan outlines
oil storage at the facility, spill pathways in the event of an oil spill, spill prevention, control
and countermeasure techniques, inspections of oil storage areas, emergency contacts and
spill reporting procedures. Personnel working in facilities with a SPCC Plan are trained in
the procedures outlined in the plan to ensure competence when handling, transferring, and
responding to oil spills.

December 2003
Page 16
SPCC plans must be updated every five years or whenever there is a change in facility
design, construction, operation or maintenance. As a good management practice, on an
annual basis, the DHCs and the Supervisor of HazMat/HazWaste Unit review the SPCC
plans and assess whether changes at the facility may warrant plan revision. Highway
Operations and the Districts are consulted relative to the need of the SPCC. As a good
management practice, MassHighway will strive to minimize the storage quantities of oil
and/or hazardous materials at all facilities thus potentially eliminating the need for SPCC
plans. In the event that revisions are needed, the Supervisor of HazMat/HazWaste Unit
procures the services of a professional engineer to revise and stamp applicable SPCC plans.
Upon certification by the Professional Engineer, the DHC will provide copies of the plan to
the respective facilities. The DHCs incorporate any changes to the plans into the annual
SPCC training. The DHCs are responsible for keeping records to document the conduct of
the annual SPCC plan review.

The following table presents a summary of the roles and responsibilities for Emergency
Preparedness. For specific roles, responsibilities, definitions, review and update
procedures, please refer to the ERSP and the SPCC plans.
General Emergency Preparedness Roles and Responsibilities

Role Responsibility
Commissioner Endorses the Emergency Response Spill Plan for MassHighway
Facilities.
Chief Engineer Reviews and provides comment on Emergency Response Spill Plan
revisions.
Deputy Chief Engineer Environmental Ultimately responsible for ensuring that the Emergency Preparedness
Component of the EMS remain current and effective.
District Highway Director Ultimately responsible for ensuring that District adheres to emergency
response procedures.
District Maintenance Engineer/Operations Responsible for notifying appropriate MassHighway personnel during
Engineer emergency response.
CS III or Other Designee of the District Is the as Primary Emergency Coordinator for the ERSP. Initiate spill
Highway Director response efforts and contact the DME upon notification of a spill.
CS II/Facility Foreman or Other Designee of Act as the Secondary Emergency Coordinator for the ERSP. The
the District Highway Director Secondary Emergency Coordinator assumes the role of Primary
Emergency Coordinator in the absence of the Primary Emergency
Coordinator.
Supervisor of HazMat/HazWaste Unit Responsible for convening the EMS Task Force to review the Emergency
Response Spill Plan for MassHighway Facilities, and District HazMat
Coordinators to review the SPCC plans. Serves as the Emergency
response Coordinator for the ERSP. Revises and reissues spill plans.
HazMat/HazWaste Unit Member Act as the Emergency Response Coordinator. Available for assistance
during a spill emergency and coordinate spill response efforts.

December 2003
Page 17
Role Responsibility
HazMat Coordinator Support the Primary Emergency Coordinator as needed. Prepare
manifests for spill response and submit spill reports to appropriate
authorities. Distribute the Emergency Response Spill Plans and SPCC
plans to MassHighway facilities. Incorporate any emergency
preparedness changes into annual awareness training.
Facility Personnel/District Safety Inspectors Responsible for reporting a spill to the Primary Emergency Coordinator.
Respond to spills at the direction of the Primary Emergency Coordinator.

December 2003
Page 18
Standard Operating Procedures
Standard Operating Procedure ENV-01-22-2-000
…To ensure the proper method of washing vehicles and

equipment …consistent with environmental regulations
Standard Operating Procedures
This EMS component documents the method for the development and revision of
MassHighway’s Environmental Standard Operating Procedures (SOPs). SOPs define roles
and responsibilities, policies and minimum performance criteria for managing
environmental compliance issues at MassHighway facilities. MassHighway is therefore
committed to routinely reviewing existing SOPs to ensure their appropriateness, revising
them on a regular basis and developing new SOPs as needed to account for regulatory and
MassHighway operational changes. Environmental is assigned to coordinate SOP review
and development and obtains all signatures needed for approval of all SOPs. As part of this
process, Boston and District Operations’ staff are responsible for reviewing existing and
proposed SOP content to make certain that the procedures can be implemented without
undue impact on operations and available resources.
Procedure
Below are the two primary methods by which MassHighway manages the applicability and
endorsement of environmental SOPs; 1) identification of the need for new SOPS and the
revision of existing SOPs; 2) the development, revision, final review and endorsement of
all SOPs.
Identification of New SOPs and SOPs Needing Revision

The DHCs and Boston Environmental staff monitor regulations that could be applicable to
MassHighway operations at facilities. DHCs through regular facility inspections identify
changes in facility operations that may warrant new or revised SOPs. Additionally, facility
personnel notify their superior and the respective DHC of any anticipated changes to
operations that may pose a potential environmental compliance issue. The DHCs and
Boston Environmental staff make recommendations to the Supervisor of
HazMat/HazWaste Unit relative to the need for new or revised SOPs. The Supervisor of
HazMat/HazWaste Unit will submit the recommendations of the DHCs and Boston
Environmental staff to the DCEE who will then review the recommendations and direct the
Supervisor of HazMat/HazWaste to prepare or revise an SOP if necessary.
Development, Revision, Final Review and Endorsement of SOPs

Upon receipt of the Deputy Chief Engineer Environmental’s directive, the Supervisor of
the HazMat/HazWaste Unit designates a member of the Environmental Section to develop
a new or revise an existing SOP with input from representatives of Offices, Divisions,
Districts, and Sections as deemed necessary. The draft SOP will be submitted to the
Supervisor of HazMat/HazWaste Unit who will then solicit input from the Environmental
Section staff during a designated comment period. The Supervisor of HazMat\HazWaste

December 2003
Page 19
Unit will attach a summary memo explaining the need for the draft SOP prior to submittal
to the Deputy Chief Engineer Environmental for review and comment.
The Supervisor of HazMat/HazWaste Unit will draft a cover summary memo explaining
the content and need for the new or revised SOPs to assist the Chief Engineer’s, Division
Director’s, and Highway Director’s review. The SOP shall be amended by the Supervisor
of the HazMat/HazWaste Unit to reflect the comments before forwarding to the
Commissioner for signature. The Commissioner will review and endorse the SOP for
distribution to the Department. The comment resolution and SOP preparation is intended
to be an objective process that will addresses all operational and environmental concerns.

A summary of the roles and responsibilities for environmental SOP review and
development is provided below.
Standard Operating Procedures Roles and Responsibilities

Role Responsibility
Commissioner SOPs are issued under the Commissioner’s signature.
Chief Engineer Provides final approval of all SOPs prior to obtaining the
Commissioner’s endorsement.
Deputy Chief Engineer Environmental Maintains ultimate responsibility for the development and
revision of SOPs.
Highway Operations Engineer and District Notify Environmental of any changes in operations that affect
Maintenance Engineer environmental compliance at Maintenance facilities.
Supervisor of HazMat/HazWaste or other Coordinates and directs SOP development and revision
Designee process.
District HazMat Coordinators, Boston Hazmat Serve as the primary developers of SOPs.
Staff
Representatives of Administrative, Highway Provide guidance to Environmental relative to operational
Operations, Construction, Projects Division and demands and feasibility of implementation of SOPs.
Districts

December 2003
Page 20
Facility Environmental Handbook and Maps
Facility Environmental Handbook and Facility Maps
This EMS Component provides a description of the roles and responsibilities for carrying
out the process of making revisions to the Facility Environmental Handbook and Facility
Maps. Facility Environmental Handbooks are readily available reference tools located at
all District Headquarters, maintenance facilities, Highway Operations and Environmental
to support MassHighway’s EMS. Two versions of the handbook are available. Both
versions contain descriptive text on regulatory programs, copies of the Environmental
SOPs and the Emergency Response Spill Plan. The generic version, primarily for use in
Boston and the District Headquarters, contains a list of facilities with general information.
The specific version resides at each of the facilities and contains a facility profile specific
to that facility only. Additionally, Facility Maps detailing existing environmental and
operating conditions at these facilities are available separately and are included in the
handbook. These maps detail environmental information including, but not limited to,
solid waste collection areas, wetlands and buffer zones, hazardous materials storage areas,
utilities related to water quality, above ground and under ground storage tank locations and
associated piping and pumps, and storage sheds for sand and salt storage.
Annual review and updates to the Facility Environmental Handbook and Facility Maps
ensure the text and information reflect any regulatory, operational, or administrative
changes. Environmental assumes the lead in the update and distribution of the Facility
Environmental Handbooks and Facility Maps. MassHighway relies on these reference
materials for its annual Environmental Awareness Training.
Procedure
The Supervisor of the HazMat/HazWaste Unit directs members of the Environmental
Section staff to review the Facility Environmental Handbook and recommend needed
changes to the descriptive text, addition or removal of SOPs, and updates to the Emergency
Response Spill Plan. Upon receipt of these recommendations, the Supervisor of
HazMat/HazWaste Unit directs staff to revise the handbook text. The Supervisor of
HazMat/HazWaste Unit provides the revised handbook text SOPs and maps to the DHCs
and other Environmental staff for review and comment within a designated comment
period.
During the annual self-audits and/or regular inspection of MassHighway facilities, DHCs
ensure the Facility Maps reflect current operating conditions at the facilities. DHCs will
indicate any changes to operating conditions (establishment of new solid waste collection
areas, new hazardous waste collection areas, presence of additional spill kits, etc.) on the
Facility Maps during their audits/inspections and submit the changes to the Supervisor of
the HazMat/HazWaste Unit. MassHighway CADD staff or a consultant may be used to
make the necessary changes to the Facility Maps.
The Supervisor of the HazMat/HazWaste Unit collects and reviews the revisions made to
the Facility Environmental Handbook and Facility Maps before submitting them to the
Deputy Chief Engineer Environmental for review and comment. The Deputy Chief

December 2003
Page 21
Engineer Environmental reviews and approves the revisions to the handbook and maps
prior to issuing the updated handbook and maps to MassHighway facilities. Additionally,
the Supervisor of the HazMat/HazWaste Unit provides an electronic version of the updated
Facility Environmental Handbook and Facility Maps to Information Technology Services
for posting onto the MassHighway Intranet. A graphic illustration of the schedule for the
review cycle is provided below. This review cycle is used as the primary method for
ensuring that the handbook, SOPs and maps are updated as needed prior to conducting the
Annual Environmental Awareness Training in the fall.
Annual Handbook Review and Implementation Cycle
January
Plan
Train
October April
Issue Review
June

December 2003
Page 22
A summary of roles and responsibilities for the Facility Environmental Handbook and
Facility Maps review and revision process is provided below.
Facility Handbook and Facility Map Review and Revision Roles and Responsibilities
Role Responsibility
ITS Responsible for posting the Facility Environmental Handbook and Facility
Maps onto the MassHighway intranet.
Deputy Chief Engineer Environmental Maintains ultimate responsibility for the review and revision of the Facility
Handbook And Facility Maps.
Supervisor of Coordinates and directs Facility Environmental Handbook and Facility

Maps review and update. Ensures latest revision is distributed to Facilities,
HazMat/HazWaste Unit Districts, and Divisions.
District HazMat Coordinators Provide comment on revisions to the Handbook. Responsible for updating
information for Facility Profiles and dis tributing revised handbook pages to
the facilities. Responsible for updating the Facility Maps to reflect any
infrastructure changes that have occurred in the facility. Ensure, through
regular inspections, that the most recent versions of the Facility Maps are
available at the facility.
Environmental Section Staff Responsible for providing comments on revisions to Facility Environmental
Handbook.

December 2003
Page 23
Training
Training
This EMS component establishes the procedures for identifying, planning, delivering and
tracking Environmental Training. The training is provided to MassHighway staff as
necessary to maintain knowledge and skills that help ensure that they understand their roles
and responsibilities and can adequately perform their duties as they relate to supporting the
EMS. Training is provided to MassHighway employees through four basic means: 1)
Annual Environmental Awareness Training provided by Environmental staff; 2) Right-to-
Know Training provided by the Safety Unit; 3) Regulatory Specific Training provided with
assistance from technically experienced consultants and 4) related training provided by
other state agencies (i.e. DEP, Executive Office of Environmental Affairs) such as MCP,
stage II vapor recovery equipment and, State Sustainability Training. All Divisions and
Departments are responsible for identifying the personnel that require training based upon
job duties and how those duties relate to environmental compliance. Environmental
coordinates the Departments current training needs to support the EMS but, depends on
input from all MassHighway Divisions/Departments/Section to ensure the training
programs are funded, remain current and, applicable to MassHighway operations.
Procedure
Environmental, with assistance from Highway Operations, trains the personnel that have
been selected for training according to their roles and responsibilities within the EMS.
Records of attendance are maintained by the employees respective Division and/or District
and are provided to regulatory agencies upon request. The Training Coordinator conducts
an annual review of the Environmental Training Program to ensure the program is both
current and relevant to MassHighway facility operations.
Environmental Training Program Components

The following table provides a summary of the regulatory and best management practice
Environmental Training provided to MassHighway staff.

December 2003
Page 24
MassHighway Regulatory Required and Best Management Practices Training Program
Training Regulation Regulatory Requirement Participants Delivery
Hazardous Waste 310 CMR Employees having responsibility for handling/managing District Structures Maintenance Training provided
Awareness hazardous waste at SQG facilities must be properly trained so Engineer, CSIII/Area Foreman, HOV during annual
30.351(9)(g)
Training they know how to perform their duties and so that hazardous Facility Personnel, CSII/Facility Environmental
waste handling practices and emergency procedures are Foremen, Facility Personnel District Awareness
performed properly and in compliance with all applicable HazMat Coordinators Training by DHCs
requirements. Employees are provided initial training to a
competency level with refresher training as necessary.
Universal Waste 310 CMR Employees having the responsibility for handling or managing District Structures Maintenance Training provided
Training 30.1035 universal waste shall be informed of the proper handling and Engineer, CSIII/Area Foreman, HOV during annual
emergency procedures appropriate to the types of universal waste Facility Personnel, CSII/ Facility Environmental
handled at the facility. Employees are provided initial training to a Foremen, Facility Personnel, District Awareness
competency level with refresher training as necessary. HazMat Coordinators. Training by DHCs
Department of 49 CFR Each hazmat employee* shall be provided 1) general awareness District HazMat Coordinators, Training
Transportation/ 172.704(a) training designed to provide familiarity with the requirements of CSII/Facility Foreman coordinated by
this subchapter, and to enable the employee to recognize and Environmental
General 310 CMR identify hazardous materials consistent with OSHA Hazard Section and
Awareness, 30.409 Communication Standard (29 CFR 1910.1200). OSHA or EPA conducted through
Manifest, and
training may be used to satisfy the requirements of 49 CFR a consultant
Safety Training
172.704(a) to avoid duplication of training efforts. 2) function contract
Programs
specific training concerning the requirements of the DOT
hazardous waste regulations specific to the function the employee
performs. 3) safety training concerning emergency response
information, measures for protection from the hazards associated
with hazardous materials, and methods and procedures for
avoiding accidents. Employees are provided initial training to a
competency level with refresher training every 3 years thereafter.
Stage II Vapor 310 CMR 7.24 Persons performing Stage II systems weekly inspections must be CSIII, Foremen, Laborers Training is
Recovery System trained to inspect equipment including, but not limited to, nozzle provided by the
Inspection Training boots and splash/vapor guards, hoses, hose retractors, coaxial DHCs.
adapters, dry breaks, fill caps, vapor recovery caps, spill
containment boxes and drain valves. Employees are provided
initial training to a competency level with refresher training as
necessary.
Spill Prevention 40 CFR Employees shall be trained in the use of the SPCC, applicable Employees having a role in the Training provided
Control and 112.7(e)(10) pollution control laws and the operation and maintenance of SPCC plan for a facility during annual
Countermeasure (iii) equipment to prevent the discharges of oil. Employees are Environmental
(SPCC) provided initial training to a competency level with annual Awareness
refresher training. Training by DHCs
Emergency Best Employees shall be trained so as to know the roles and Employees having a role in the Training provided
Response Spill Management responsibilities of Emergency Coordinators and Responders, the Emergency Response Spill Plan for during annual
Plan for Facilities Practice notification procedures in the event of a hazardous materials spill, MassHighway Facilities are indicated Environmental
Training the procedures for identification and response to minor and major on the individual call sheets posted Awareness

December 2003
Page 25
releases of hazardous material, and the reporting requirements to at the facilities. Generally, the Training by DHCs
regulatory agencies for hazardous material releases. Employees Foreman, Area Supervisors, Safety
are provided annual training to the competency level. Inspectors and the District
Maintenance have key roles in
responding to spills at facilities.
8 Hour First 29 CFR Employees who are “Responding Personnel” under Employees who witness a spill and Training is
Responder 1910.120(q) MassHighway’s Emergency Response Spill Plan who witness or notify authorities. coordinated by the
Awareness Level (6)(i) discover a hazardous substance release and are responsible only Incident Response
for initiating the emergency response sequence by notifying the Unit and
proper authorities shall be trained to demonstrate competency in conducted through
accordance with 29 CFR 1910.120(q)(6)(i): First Responder a consultant
Awareness Level. First Responders at the Awareness level are contract
certified through 8 hours of initial training and receive an 8 hour
annual refresher.
8 Hour First 29 CFR Employees who are “Responding Personnel” under Employees who respond to a spill in Training is
Responder 1910.120(q) MassHighway’s Emergency Response Spill Plan who respond to a defensive manner. coordinated by the
Operations Level (6) (ii) releases of hazardous substances in a defensive manner (i.e. Incident Response
diking or berming a spill) as part of the initial response for the Unit and
purpose of protecting nearby persons, property or the conducted through
environment from the effects of the release shall be trained to a consultant
demonstrate competency in accordance with 29 CFR contract
1910.120(q)(6)(ii):
First Responder Operations Level. First Responders at the
Operations level are certified through 8 hours of initial training and
receive an 8-hour annual refresher.
24 Hour HAZMAT 29 CFR Employees who are “Responding Personnel” under Employees who respond to a spill to Training is
Technician Training 1910.120 MassHighway’s Emergency Response Spill Plan who respond to stop the release coordinated by the
(q)(6)(iii) releases of hazardous substances to stop the release of Incident Response
hazardous substances shall be trained to demonstrate Unit and
competency in accordance with 29 CFR 1910.120(q)(6)(iii): conducted through
HAZMAT Technician Level. HAZMAT Technicians are certified a consultant
through 24 hours of initial training and receive an 8 hour annual contract
refresher.
24 Hour HAZMAT 29 CFR Employees who are “Emergency Coordinators” under the Employees who assume the role of Training is
Incident 1910.120 MassHighway Emergency Response Spill Plan who assume Emergency Coordinator coordinated by the
Commander (q)(6)(V) control of a hazardous materials incident beyond the first- Incident Response
Training responder awareness level shall be trained to demonstrate Unit and
competency in accordance with 29 CFR 1910.120(q)(6)(v). conducted through
HAZMAT Incident Commanders are certified through 24 hours of a consultant
initial training and receive an 8 hour annual refresher. contract
24 Hour Hazardous 29 CFR Employees occasionally working at Hazardous Waste Sites (i.e. HazMat\HazWaste Unit Training is
Waste Site Training 1910.120(e) MCP sites, tank removals) for specific limited tasks (including, but coordinated by the
(3) (i) not limited to, ground water monitoring, land surveying, or Environmental

December 2003
Page 26
geophysical surveying) shall be trained in accordance with 29 Section Unit and
CFR 1910.120(e)(3)(I). Hazardous Waste Site Workers are conducted through
certified through 24 hours of initial training and receive an 8 hour a consultant
annual refresher. contract
Right-to-Know 454 CMR 21.07 Employees who are or may be exposed to toxic or hazardous This training as it related to this EMS Training
substances at the workplace shall be provided training on is applicable to the District Structure conducted by the
employee rights, MSDS, specific substances stored and/or Maintenance Engineer, CSIII/Area Risk
handled at the workplace, explanation of toxicity, labeling, and Supervisor, CSII/Facility Foreman, Managem ent/
instruction on the proper personal protective equipment (PPE) to Facility Personnel, District HazMat Safety Unit
be used when handling hazardous substances. Employees Coordinators, and personnel
receive initial competency training with refresher training as reporting to Highway Operations in
necessary. Boston: Franklin Stockroom, Sign
Shop, HOV Facilities
Environmental Best Maintenance facility employees shall be trained on the materials District Structure Maintenance Training provided
Annual Awareness Management and procedures contained within the Facility Environmental Engineer, CSIII/Area Supervisor, by DHCs
Training Practice Handbook. Topics covered during this Environmental Awareness CSII/Facility Foreman, Facility
Training include Hazardous Waste, Universal Waste, Hazardous Personnel, District HazMat
Materials, Solid Waste, Roadside Issues, Tanks, Water Quality, Coordinators, and the following
Wetlands, Record Keeping, and Inspections. Employees receive personnel reporting to Highway
annual Facility Environmental Awareness Training to the Operations in Boston: Franklin
competency level. Stockroom, Sign Shop, HOV
Facilities
*Note: The term “hazmat employee” as it relates to MassHighway operations, includes only personnel responsible for shipping (packaging,
labeling, manifesting) a RCRA hazardous waste and/or those employees who offer a DOT hazardous material to a private transporter (contractor

December 2003
Page 27
Training Roles and Responsibilities
A summary of the roles and responsibilities for the Environmental Training Component is
provided below.
Environmental Training Program Roles and Responsibilities

Role Responsibility
Deputy Chief Engineer Assumes ultimate responsibility for managing the Environmental Training
Environmental Program
Highway Operations Engineer, Responsible for ensuring appropriate personnel attend environmental training
Maintenance Engineer, District programs relative to their roles and responsibilities within the EMS and
Maintenance Engineer maintaining training attendance records for Highway Operations staff
assigned to Central Stockroom in Franklin, Paint Crews stationed in
Deerfield, Reading, and Bridgewater Facilities.
DMEs Responsible for ensuring appropriate personnel attend environmental training
programs relative to their roles and responsibilities within the EMS and
maintaining training attendance records for District Operations staff.
Projects Division Training Responsible for developing an annual budget for submission to
Coordinator Administrative Services, coordinating the training schedule, ensuring
contracts are in place for training consultant services and conducting the
annual review of the training program in accordance with the EMS.
Supervisor of HazMat\HazWaste Responsible for the approval of training program content revisions.
Unit
DHCs The DHCs develop and deliver the Annual Facility Environmental Awareness
Training program and initial SPCC training within their District and participate
in the annual review of the environmental training program.
Environmental Staff Environmental staff annually reviews the environmental training programs to
determine if regulatory or operational changes necessitate revisions to the
program. Share training materials over the MHD intranet.
EMS Task Force Provides comment and guidance to the Environmental Section, Safety Unit
(Administrative, Highway and Incident Response Unit relative to the feasibility and content of
Operations, Construction and environmental training programs.
Projects Divisions)
Safety Unit Develops and presents the Right-to-Know Training.
Administrative Services Identifies environmental training budgetary needs as part of the operations
budget, communicates the availability of funding to the Environmental
Section, and maintains training documentation for the Department
ITS Posts PowerPoint presentations onto the MassHighway intranet.

December 2003
Page 28
Compliance Tracking
Compliance Tracking
This EMS component describes the procedures used by MassHighway to identify, correct and
track environmental compliance information. The Department anticipates that tracking will be
enhanced in the future with the introduction of an electronic tracking system that is currently
under development. Compliance information is generated by three methods: scheduled self-
audits, facility inspections and, routine facility observations. By identifying and tracking
compliance information, MassHighway enha nces its ability to remain in compliance with its
legal and regulatory obligations. Procedures and additional guidance information on inspections
can be found in the Facility Environmental Handbook and SOP No. ENV-01-03-1-000;
Hazardous Waste Management at MassHighway Facilities. Procedures and guidance for
conducting Self- Audits can be found in the Self-Audit Protocol Fieldbook.
Identification
Self-Audits
Unresolved compliance information identified through MassHighway’s Self- Audit Program is
documented in Corrective Action Reports and Clean State Matter Reports, as required by the
Self- Audit Program. This information is maintained at Boston Environmental and District
Headquarter Offices by the Audit Coordinator and District HazMat Coordinators respectively.
The Audit Coordinator submits a copy of the CSMR to the Supervisor of the HazMat/HazWaste
Unit for review. Upon approval of the Supervisor and the Deputy Chief Engineer
Environmental, the Clean State Matter Report is entered into the Clean State Database.
Facility Inspections
Facility inspections are performed by MassHighway personnel on a quarterly, bi- monthly or

monthly schedule based upon the operations conducted at each facility. Facility personnel
perform weekly inspections of facilities equipped with Hazardous Waste accumulation areas.
A facility designated for vehicle or heavy equipment repair will be inspected monthly whereas a
seasonal snow and ice facility is inspected quarterly. These regular inspections permit
MassHighway to gather compliance information on a more frequent basis as compared to the
self-audits. The results of these inspections are transmitted to the District Maintenance Engineer
who facilitates the correction of any out-of-compliance issues. Corrections are coordinated
between the DME the CS III, Facility Foreman and the DHC. The results of these inspections
and the documented corrections are maintained at the District headquarters. The respective
District HazMat Coordinator reports compliance matters that cannot be corrected within 14 days
of identification to the Supervisor of the HazMat/HazWaste Unit. The Supervisor instructs the
MassHighway Clean State Database Coordinator to enter the matter into the database with a
schedule for correction. Progress made on correcting the compliance matter is reported to the
Clean State Database on a quarterly basis.
December 2003
Page 29
Routine Facility Observations
MassHighway personnel are expected to keep facilities neat and generally adhere to good
housekeeping practices. Furthermore, facility personnel are expected to report issues that may
pose a potential compliance issue to their supervisor. Examples of potential issues that should be
reported include but are not limited to the identification of dumping of materials in non-
designated areas, missing spill equipment, spills and/or dripping fluids from containers and/or
equipment.
Correcting Out-of Compliance Issues

Out-of Compliance situations that have been identified by way of Inspection, Self- Audit and/or
Due Diligence must be corrected as soon as possible. Simple corrections such as replacing a
label or closing a container should be made upon discovery. Corrections such as replacing
broken or missing equipment, equipment repairs, waste disposal should be made in a matter of
days. Efforts sho uld be made to resolve corrections requiring the use of outside contractors
within 14 days of identification.
Tracking Compliance Matters

The Supervisor of HazMat\HazWaste Unit receives regular updates from the District HazMat
Coordinators that identify any needed compliance corrections at the Facilities. This information
is gathered from the regular facility inspections. The District HazMat Coordinators also
maintain a log of compliance issues that require Environmental Section intervention. All issues
that cannot be corrected within the 14 calendar period will entered into the Clean State Database.
Out-of-compliance issues from self-audits are tracked with the Audit Program Coordinator using
the Corrective Action Report and the Clean State Matter Report. All issues that have not been
corrected are entered into the clean state database.

December 2003
Page 30
Compliance Tracking Roles and Responsibilities
A summary of the roles and responsibilities for the Compliance Tracking Component is provided
below.
Compliance Tracking Roles and Responsibilities

Role Responsibility
Deputy Chief Engineer Assumes ultimate responsibility to ensure proper tracking of compliance
Environmental matters at the facilities.
DMEs Responsible for ensuring that compliance matters are properly identified and
corrected by District Personnel.
Supervisor of HazMat/HazWaste Responsible for ensuring those out-of-compliance matters are addressed as
Unit quickly as possible and that issues that cannot be corrected within 14
calendar days are properly reported to the Clean State Database. Requests
compliance tracking data from the District HazMat Coordinators and the Audit
Program Coordinator.
DHCs Perform regular inspections that ensure the compliance matters are properly
addressed at the facilities. Ensure proper review of weekly inspection reports
submitted by the CSIII/Area Supervisors and or the CSII/Facility Foreman.
Audit Program Coordinator Maintains a record of all Self-audits including the Corrective Action Reports
and the Clean State Matters Reports. Upon request by the Supervisor of the
HazMat/HazWaste Unit will produce a record of all compliance issues
identified by the Self –Audit Program.

December 2003
Page 31
Self-Auditing
Self-Auditing
This EMS component describes the procedures used by MassHighway during the
implementation of its Self- Audit Program including conducting of the self audits, post audit
reporting and follow up, and revising and updating the Self- Audit Protocol. The Self-Audit
Program is intended to evaluate environmental compliance at MassHighway Maintenance
Facilities and track a facility’s return to compliance through corrective action implementation.
The Protocol is designed to reflect the compliance themes contained in the Facility
Environmental Handbook across eight major compliance areas covering multi- media federal and
state environmental regulatory programs, MassHighway SOPs, and best management practices
(BMPs). Because it is designed to discover and correct environmental compliance matters, the
Self- Audit Program is an integral component of MassHighway’s EMS.
MassHighway is committed to keeping the Self- Audit Protocol current. The Self- Audit Program
and Protocol is reviewed at least annually to identify areas where updates and/or revisions are
needed due to either regulatory or operationa l changes. Review of the Program is necessary to
ensure continual improvement and ensure that the Protocol reflects current regulations, SOPs,
and facility operations.
Procedure
This section presents an overview of the procedures and roles and responsibilities for conduct of
MassHighway Self-Audits. The actual MassHighway Self- Audit Protocol Handbook is available
for a detailed discussion of the procedures and roles and responsibilities. The procedures
discussed below generally involve five MassHighway staff members; the Audit Coordinator, the
Lead Auditor, District Maintenance Engineer, the Facility Forman and the District HazMat
Coordinator. There are three Phases to a MassHighway Self- Audit; the Pre-audit Preparation,
the Audit Site Visit and the Post Audit Phase. The process is described below.
Pre-audit Preparation. The Audit Coordinator prepares a schedule for facility audits. Once
the schedule has been prepared, the Audit Coordinator will designate a DHC as the District Lead
Auditor. The Lead Auditor will be a DHC from a District other than the one being audited. The
Lead Auditors are provided with facility and District contact information needed to complete the
self-audit notifications, site visit, and follow up reporting. The Lead Auditor will notify the
DHC and DME in the District of the scheduled audit at least two weeks in advance of the audit.
The DHC and DME will ensure pre audit questionnaires are completed, Facility foremen are
contacted, and that facility records are made available at the time of the audit.
Audit Site Visit. The Lead Auditor will conduct a pre-audit briefing with facility personnel to
1) inform facility personnel of the purpose of the audit; 2) inform facility personnel of their audit
responsibilities and required participation in the audit; and 3) answer any preliminary questions
the facility personnel may have regarding the audit. After the briefing, the Lead Auditor
conducts a facility walkthrough, recording any environmental compliance findings in field notes
and facility plans. The Lead Auditor also performs a record review of applicable compliance
December 2003
Page 32
documents, such as manifests and environmental permits. During the walkthrough and records
review, the Lead Auditor completes the Audit Protocol Checklist. Findings that may be
immediately corrected should be completed during the walkthrough and documented by the
auditor. The Lead Auditor then conducts exit briefings and submits the draft findings list to the
Facility Foreman at the completion of each audit. The list is provided so facility personnel may
initiate corrective actions in advance of receiving a Corrective Action Report (CAR).
Post Audit Phase. Following the audit site visit, the Lead Auditor prepares a CAR, which
summarizes the audit findings. An electronic version is forwarded to the Audit Coordinator and
the DME. Upon receipt of the CAR, the DME coordinates with the facility foreman to ensure
facility personnel conduct the necessary corrective actions. DHCs are responsible for correcting
or managing corrective actions that fall outside operational responsibility of the Facility Foreman
or DME.
The Facility Foreman ensures that the corrective actions have been completed and documents
corrective actions in the space provided on the CAR. The completed CAR is forwarded to the
Lead Auditor for review and confirms that the completed actions adequately address the findings
on the CAR. The completed CAR is forwarded to the Audit Coordinator along with a memo that
summarizes the completed self-audit.
For each unresolved regulatory finding, the Lead Auditor completes a Clean State Matter Report
(CSMR). If a completed CAR has not been received within 14 days of the audit a CSMR is
completed for all regulatory findings identified on the original CAR. Within two days of
receiving the completed CAR, the Lead Auditor forwards all audit field notes, checklists,
completed CAR, and CSMRs to the Audit Coordinator for archiving in the Environmental
Section’s Self-Audit Program files. The Audit Coordinator will enter all unresolved regulatory
findings documented on the CSMRs into the EOEA’s Clean State Database.
The Audit Coordinator provides the audit findings to the DHC. The DHC will complete and
transmit to the Audit Coordinator and DME a Corrective Action Plan (CAP) for each unresolved
regulatory finding on the completed CAR. The DHC will provide quarterly CAP progress reports
to the Audit Coordinator until the CAP has been completely resolved. The Audit Coordinator
will enter the updates into the Clean State database. Once a CAP has been completely resolved,
the Audit Coordinator will complete and submit a request for de- listing of a regulatory finding
from the EOEA’s Clean State Coordinator and the Clean State database.
A summary of the timelines described in the preceding sections for conducting Self-Audits and
audit follow-up activities is provided below.

December 2003
Page 33
Self-Audit Process Timelines
Activity Responsible Person Timeline
Assign Audit Team and Lead Auditor Audit Coordinator According to Annual Schedule
Notify DHC, DME, and Facility foreman Lead Auditor At least two weeks before audit site visit date
of impending Self-Audit
Complete and submit CAR to DHC, Lead Auditor Within two days after audit site visit.
DME, and Foreman
Complete and submit CAR and CCAR Foreman/DHC Within 14 days of the date the audit was
to Lead Auditor conducted
Complete audit summary memo and Lead Auditor Within 1 week after receipt of CCAR or within 2
CSMRs and submit to Audit Coordinator days of CCAR due date
Enter audit results into Clean State Audit Coordinator Within 2 weeks after receipt of CCAR from Lead
database and submit final CAR to DHC Auditor
Complete Corrective Action Plan DHC Within 21 days after receipt of final CCAR from
Audit Coordinator
Complete CAP Progress Reports DHC Quarterly – ongoing until Final CAP Completion
Report issued
Update of Clean State database Audit Coordinator Quarterly – ongoing until Final CAP Completion
Report issued

December 2003
Page 34
Self-Audit Roles and Responsibilities
A summary of the roles and responsibilities for conducting Self- Audits and audit follow-up
activities is provided below.
Self-Audit Program Roles and Responsibilities

Role Responsibility
Deputy Chief Assumes ultimate responsibility for managing the Self-Audit Program.
Environmental
Supervisor of Approves entries into the Clean State Database
HazMat/HazWaste
Unit
Audit Coordinator The Audit Coordinator oversees the Self-Audit Program. The Audit Coordinator is
responsible for: developing an Annual Self-Auditing Schedule; assigning Audit Teams and
assigning Lead Auditors; modifying the Self-Audit Protocol and Program Documents on a
regular basis to incorporate changes in environmental laws, regulations and MassHighway
Policy; reviewing Corrective Action plans developed by the DHCs and the facility foreman
for Program consistency and timeliness; monitoring progress of Corrective Actions; entering
unresolved regulatory findings into EOEA’s Clean State database; Coordinates and directs
Self-Audit Program review and revision.
Lead Auditor The Lead Auditor will typically be a DHC from a District other than the audited facility’s
District who will manage the Audit Team through all phases of the Self-Audit. The Lead
Auditor is responsible for: notifying the DHC of the impending Self-Audit; completing the
Self-Audit Protocol and field documents; leading the Site Visit Phase of the Self-Audit;
completing the audit Corrective Action Report; completing an audit summary report
memorandum; completing Clean State Matter Reports for unresolved regulatory findings.
District HazMat The DHC serves as the District’s liaison to federal, state, and local environmental agencies
Coordinators with respect to environmental compliance issues and is responsible for facility
environmental compliance that is outside the day to day operational control of facility staff.
The DHC is responsible for notifying the DME and facility personnel of an impending self-
audit; providing compliance documents for review during audit; assisting with the conduct of
the self-audits; assuming Lead Auditor role when assigned by the Audit Coordinator;
assisting the Facility foreman in the implementation of Corrective Actions; completion or
managing of Corrective Actions outside the operational control of the Facility foreman and/or
DME; development of Corrective Action Plans for unresolved findings; follow-up
coordination, tracking and reporting on the status of Corrective Action implementation;
providing assistance to the Audit Coordinator with modifying the Self-Audit Protocol and
Program Documents on a regular basis to incorporate changes in environmental regulations
and MassHighway SOPs; ensuring audits are performed in accordance with the Self-Audit
Program. Provide comment on revisions to the Self-Audit Program procedures and Protocol.
Facility foreman The Facility foreman is responsible for day-to-day facility-operations -related environmental
activities, as described in the Facility Environmental Handbook. With regard to the Audit
Program, the Facility foreman is responsible for assisting with the conduct of the Self-Audits
and Corrective Actions.
DME and Highway The DME and Highway Operations Engineer are is responsible for facility operational
Operations activities, including compliance with environmental regulations and MassHighway SOPs.
Engineer, With regard to the Self-Audit Program, the DME or Highway Operations Engineer is
Maintenance responsible for assisting with the scheduling and allocating resources for conducting Self-
Engineer Audits and completion of Corrective Actions

December 2003
Page 35
Pollution Prevention
Pollution Prevention
For the past several years, MassHighway has undertaken efforts to prevent pollution through
conservation and reduction programs relating to construction projects as well as operation of
maintenance facilities. MassHighway initiated a Pollution Prevention Task Force (PPTF) as part
of the Environmental Management System Implementation Plan to reduce risk and improve the
overall environmental quality at Department facilities through toxic use reduction The PPTF is
made up of District HazMat Coordinators and other Environmental personnel who is
cooperation with certain District Operations personnel are leading the pollution prevention
efforts for maintenance facilities
Initiatives
Ongoing pollution prevention initiatives relative to the operation of MassHighway maintenance
facilities include:
Media Initiatives
Air Pollution Prevention Fleet inspections to ensure vehicle emissions
compliance; Garage location consolidations to reduce
overall fume emissions; and installation of vapor
recovery systems for underground storage tanks.
Energy Conservation Installation of high efficiency lighting systems.
Sold Waste Source Reduction Waste reductions have been realized through the
expanded use of recycled and re-manufactured products
including the construction of salt sheds composed of
50% recycled plastic aggregate.
Water Conservation and Pollution Prevention Installation of vehicle washwater recycling units at
several maintenance facilities.
Toxics Use Reduction The Pollution Prevention Task Force has prepared
technical evaluations of products and made
recommendations for reduction of the following
substances: petroleum -based hydraulic and lubricating
oils; automotive parts cleaning solvents and associated
cleaning systems; perchlorethylene cleaning solvent and
miscellaneous automotive lube/cleaning products.
In response to these recommendations, the Department:
switched to non-chlorinated solvent brake cleaner;
eliminated solvent parts cleaner tanks in some districts,
and; reduced automotive fluid use through the leasing
and out-servicing of fleet vehicles.
Future Goals
While much has been accomplished, the Department will continue to identify, evaluate and
implement pollution prevention initiatives. Pollution prevention opportunities and activities
under current consideration include:

December 2003
Page 36
§ eliminating solvent parts cleaners statewide;
§ upgrading maintenance garages to include state-of-the-art automated oil dispensing and

quick drain capabilities;
§ use of vegetable-based diesel fuels to reduce heavy equipment air emissions;
§ purchasing low volume high pressure washers for vehicle/equipment cleaning to reduce
water use.
§ purchasing aqueous brake cleaning systems to eliminate all brake solvent use and
eliminate asbestos dust hazards
§ use of vegetable based hydraulic oil
§ use of neutral pH, non-oil emulsifying vehicle degreasing/washing detergents to

eliminate caustic detergents and improve effectiveness of oil/water separators;
§ identifying specific areas within a given project for experimental or full usage of new
products comprised of solid waste materials;
§ developing specifications and special provisions for incorporating recycled materials into
construction projects;
§ developing and tracking test applications of recycled products and materials to document
product effectiveness relative to standards for highway performance and environmental
acceptability;
§ investigating and implement economically viable opportunities to reuse and recycle solid
and hazardous waste generated by routine operations suc h as waste oil, street sweepings,
catch basin cleanings, tires, construction and demolition debris, special waste, scrap
metal and wood waste;
§ active participation of the Research Needs Committee to identify potential programming

and funding opportunities; provide input of needed material reuse and recycling research
efforts and to keep up to date on new recycling and reuse technologies, regulations and
activities successfully utilized by industry and other state transportation departments;
§ working with state agencies and other organizations to develop training and educational
workshops of the use of recycled materials;
§ actively participating with state and federal regulatory agencies on Beneficial Reuse
policies.

December 2003
Page 37
EMS Review and Evaluation
Act
Plan
EMS Review
and Evaluation
Check
DO
EMS Review and Evaluation
This EMS component establishes the procedures for reviewing the overall effectiveness of the
EMS. MassHighway’s EMS review is a dynamic process designed to ensure that the EMS
adapts to regulatory and operational changes that affect environmental compliance and full
integration of the EMS into MassHighway activities. To this end, regular review of the EMS is
essential to its success and therefore all elements of the EMS are reviewed annually.
MassHighway uses a three-tier review: 1) Annual Senior Management Review, 2) Annual EMS
Task Force Formal Review, and 3) Bi-annual Independent EMS Review performed by an
external EMS consultant/reviewer. This process ensures all levels of the organization provide
comment on the success of the EMS and its individual components. The EMS is updated to
reflect applicable recommendations made during the review process to ensure continual
improvement.
Procedure
Senior Management Review

Senior management participation in the EMS review process ensures that individuals responsible
for the establishment and implementation of policy are directly involved in monitoring the EMS
success. The Senior Management Review of the EMS is a process that is intended to coincide
with a scheduled monthly meeting of MassHighway’s Chief Engineer, Deputy Chief Engineers,
District Highway Directors and other Department/Section heads as warranted. Senior managers
use this opportunity to review the success of the EMS in relation to established environmental
procedures, discuss EMS implementation into MassHighway Operations, and make
recommendations for policy or procedural changes ensuring continual improvement to the EMS.
As part of the review, senior managers recommend corrective actions and implementation
strategies in relation to findings made as a result of the audit. The Senior Managers utilize a
variety of reports to complete the review including the Independent EMS Review report and the
Annual Report by the EMS Task Force.
EMS Task Force Formal Reviews

The Deputy Chief Engineer Environmental convenes an annual meeting of the EMS Task Force
to conduct a formal review of the MassHighway EMS. The Task Force generally consists of
representatives who have a major role and responsibility in the EMS from each District, Division
and, certain Sections in Boston Headquarters. The EMS Task Force provides input on the
overall EMS effectiveness relative to program implementation, success in relation to EMS
objectives, and integration into MassHighway operations. In addition, the EMS Task Force
reviews conclusions and/or recommendations brought forward by any independent EMS audits
that have been conducted during the year and recommends corrective actions and
implementation strategies such as new or revised SOPs or training. The Supervisor of the
HazMat/HazWaste Unit maintain records of the observations, conclusions and recommendations
made during the EMS Task Force review and prepares a summary report of the meeting for use
December 2003
Page 38
by the Deputy Chief Engineer Environmental. The Deputy Chief Engineer Environmental either
implements applicable recommendations based on the immediate need or brings the
recommendations forward to Senior Management for their consideration.
Independent EMS Review

In addition to an internal EMS review, MassHighway provides for independent EMS review on a
bi annual basis to obtain an unbiased evaluation of the EMS effectiveness and to ensure the
identification of areas where improvements may be made to the EMS. The review is an
impartial opinion on the extent to which the system is defined, implemented, and effective. A
qualified EMS auditor who is objective when evaluating the MassHighway EMS performs this
review. The EMS auditor uses several techniques including, but not limited to, reviewing
MassHighway documentation to ensure that procedures, programs and EMS components are
effective, conducting facility inspections to ensure that environmental systems are effective, and
conducting employee interviews to ensure each person responsible for the implementation of the
EMS is aware of their role with respect to the EMS.
The independent reviewer prepares a summary of findings and submits this report to the Deputy
Chief Engineer Environmental who reviews the auditor’s report and ensures copies are provided
to the senior managers and the EMS Task Force during their annual review meetings. The senior
managers and EMS Task Force will provide their recommendations for correction and
implementation of the findings from the audit, and the Deputy Chief Engineer Environmental
will implement the applicable recommendations within the EMS.
EMS Review Roles and Responsibilities

A summary of the EMS review roles and responsibilities is provided below.
EMS Review Roles and Responsibilities

Role Responsibility
Chief Engineer Assumes ultimate responsibility for ensuring the annual EMS
review is conducted
Deputy Chief Engineer Environmental Assumes ultimate responsibility for the EMS Program review.
Coordinates Senior Management Review and EMS Task Force
reviews. Coordinates independent EMS audits. Implements
recommendations from the review into the EMS
Supervisor HazMat/HazWaste Unit Conducts the annual EMS Task Force review meeting. Prepares a
summary of EMS Task Force recommendations for the Deputy
Chief Engineer Environmental

December 2003
Page 39
EMS Review and Evaluation (Continued)
Role Responsibility
Senior Managers Participate in annual Senior Management Review process.
(Chief Engineer, District Highway Directors, Represent their District/Operation by providing input on current
Deputy Chiefs, Department/Section Heads) operations and EMS implementation into those operations. Review
bi-annual independent EMS audit and make recommendations on
correction and implementation of audit findings.
EMS Task Force Participate in annual EMS Task Force review process. Provide
comments on EMS effectiveness and make recommendations for
improvements.
EMS Independent Reviewer Conduct bi-annual EMS program reviews. Prepare a summary of
findings for submission to the Deputy Chief Engineer
Environmental

December 2003
Page 40
Contacts
Executive Office of Transportation and Construction

General Counsel
Robert DiAdamo 617-973-7410
Commissioner
John Cogliano 617-973-7800
Chief Engineer
Thomas F. Broderick III, P.E. 617-973-7830
Chief Counsel’s Office

David L. Veatorz 617-973-7813
Administrative Services
Director Susan Bristol 617-973-7404
Budget George McNamara 617-973-7269
Training Administrator Adam Swan 617-973-7263
Safety/Risk Management Joseph DeSisto 617-973-7702
Information Technology Charles McCarthy 617-973-8492
Personnel Thomas Keely 617-973-7308
Projects Division
Deputy Chief Engineer John Blundo 617-973-7521
Training Coordinator Peter Vanbuskirk 617-973-7445
Environmental Section
Deputy Chief Engineer Gregory H. Prendergast 617-973-7484
Supervisor of HazMat/HazWaste Steven Miller 617-973-8248
Audit Coordinator Robert Johnson 617-973-8409
Supervisor of Wetlands Henry Barbaro 617-973-7419
District 1 HazMat Coordinator David Abbott 413-637-1750
District 2 HazMat Coordinator Douglas Spink 413-584-1611
District 3 HazMat Coordinator Michael Giando 508-929-3865
District 4 HazMat Coordinator Kenneth Leach 781-641-8473
District 5 HazMat Coordinator Gregory Fulgione 508-884-4362
Right of Way Section

Director Gerald Solomon 617-973-7910

December 2003
Page 41
Highway Operations Division
Deputy Chief Kelly Holbrook 617-973-7750
Highway Operations/
Privatization Engineer David Rock 617-973-8822
Administrator ITS Programs/HOV Michelle Maffeo 617-973-7315
Facilities Engineer Bassam (Sam) Salfity 617-973-7305
Maintenance Engineer
Director of Equipment and
Materials Peter J. Fallon 508-279-1731
Construction Division
Deputy Chief Engineer Michael McGrath 617-973-7610
Research and Materials Laboratory

Director Clement Fung 617-292-2750
District 1 413-637-1750
Highway Director Ross Dindio

Maintenance Engineer Rudyard Longton
District 2 413-584-1611
Highway Director Al Stegemann (Acting)
Maintenance Engineer Kenneth Wanar
District 3 508-929-3800
Highway Director Thomas Waruzila
Maintenance Engineer Charles Mistretta
District 4 781-641-8300
Highway Director Stephen O’Donnell
Maintenance Engineer John Hayden
District 5 508-824-6633
Highway Director Bernard McCourt
Maintenance Engineer Roy Fierra

December 2003
Page 42
Information Sources
Reference documents that support MassHighway’s EMS are listed below. Copies of the
documents are available on the MassHighway Intranet or may be obtained from the
Environmental Section.
• Administrative Consent Orders

• Asbestos Operation and Maintenance Manual
• Compliance Plans for Hazardous Waste, Wetlands, Hazardous Materials, Tanks, Water
Quality, and Solid Waste.
• Facility Environmental Handbook
• Facility Maps
• Management Systems Improvement Plan
• Management Systems Report
• MassHighway Environmental Standard Operating Procedures
• MassHighway Implementation Plan
• Regular Inspection Checklist
• Self- Audit Protocol Fieldbook
• Weekly Hazardous Waste Storage Area Checklist
Suggestions and Comments

Suggestions and/or comments regarding the content and formatting of this manual can be
directed toward Mr. Steven Miller. He can be reached at 617-973-8248 or e-mail
steven.miller@mhd.state.ma.us

December 2003
Page 43

Emsmanual

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Emsmanual

Uploaded by

Copyright:

Available Formats

Environmental

SECTION I – General Roles and Responsibilities

SECTION II - EMS Components

Environmental Management System Manual

Section III - Contacts and Information Sources

Environmental Management System Manual

Environmental Compliance and the EMS Manual

Continuous Improvement Cycle

Environmental Management System Manual

Environmental Management System Manual Overview

Environmental Management System Manual

Executive Office of Transportation and Construction

Environmental Management System Manual

Administrative Services Division

Administrative Services Division Roles and Responsibilities

Personnel Provide human resource support to the Department.

Environmental Management System Manual

Environmental Section Roles and Responsibilities

Environmental Management System Manual

Right of Way Section

Highway Operations Division

Environmental Management System Manual

Environmental Management System Manual

Research and Materials Testing Laboratory

EMS Task Force

Environmental Management System Manual

District Roles and Responsibilities

Environmental Management System Manual

Capital (Bonded) Spending Plan

Environmental Management System Manual

Self-Audits Implementation of EMS Self-Audit Program via District HazMat

Environmental Training Programs Implementation of regulatory-based training programs such as

Capital Spending Plan Roles and Responsibilities

Supervisor of HazMat\HazWaste Identifies projected funding needs for consultant contracts

Environmental Management System Manual

Operational Spending Plan Requirements

Operational Spending Plan Roles and Responsibilities

Chief Engineer Approves the Spending Plan and submits it to Administrative

Environmental Management System Manual

Highway Operations Engineer Identifies projected environmental compliance funding needs

District Operations Engineer Identifies projected environmental compliance funding needs

Environmental Section Staff Provide input concerning environmental program funding

Operational Fund Distribution

Environmental Management System Manual

Environmental staff regularly report information to the Supervisor of the HazMat/HazWaste

Roles and Responsibilities

Requirements Roles and Responsibilities

Environmental Management System Manual

Environmental Management System Manual

• Accessible telephone or two-way communication;

Environmental Management System Manual

Review and Update Procedures for SPCC Plans

Environmental Management System Manual

Roles and Responsibilities

General Emergency Preparedness Roles and Responsibilities

Environmental Management System Manual

Environmental Management System Manual

Standard Operating Procedure ENV-01-22-2-000

…To ensure the proper method of washing vehicles and

Identification of New SOPs and SOPs Needing Revision

Development, Revision, Final Review and Endorsement of SOPs

Environmental Management System Manual