December 2006 EMS Implementation Report.pdf

FINAL

ENVIRONMENTAL MANAGEMENT SYSTEM

IMPLEMENTATION REPORT

International Boundary and Water Commission, United States Section San Diego, Amistad, Falcon, and Mercedes

Field Offices

FINAL

ENVIRONMENTAL MANAGEMENT SYSTEM

IMPLEMENTATION REPORT

International Boundary and Water Commission, United States Section San Diego, Amistad, Falcon, and Mercedes

Field Offices

December 2006December 2006

FINAL

International Boundary and Water Commission, United States Section

Environmental Management System Implementation Report for San Diego, Amistad, Falcon, and Mercedes Field Offices

December 2006

International Boundary and Water Commission, United States Section i

Table of Contents Section 1 Introduction

1.1 Background

1.2 Purpose

Section 2 EMS Implementation Assessment

2.1 Site Visits

2.2 Training

2.3 Results of EMS Planning Workshops

2.3.1 Activities, Environmental Aspects and Environmental Impacts

2.3.2 Objectives and Targets

2.3.3 Environmental Management Programs

Section 3 Summary of EMS Implementation Status and Recommendations

3.1 USIBWC Headquarters, El Paso

3.2 San Diego Field Office

3.3 Amistad Field Office

3.4 Falcon Field Office

3.5 Mercedes Field Office

Section 4 References Cited

Appendices Appendix A EMS Implementation Report for San Diego Field Office, California

Appendix B EMS Implementation Report for Amistad Field Office, Texas

Appendix C EMS Implementation Report for Falcon Field Office, Texas

Appendix D EMS Implementation Report for Mercedes Field Office, Texas

Appendix E USIBWC EMS SOP 4.3.1 – SEA Identification of Significant Environmental Aspects

Appendix F USIBWC EMS SOP 4.3.3 – OT Development of Objectives, Targets and Environmental Management Programs

Environmental Management System Implementation Report

San Diego, Amistad, Falcon and Mercedes Field Offices ii

List of Figures Figure 1. O&M Functions Supporting the Mission of the USIBWC Figure 2. Status of EMS Implementation at the USIBWC

List of Tables Table 1. EMS Awareness Training Participants Table 2. Key Activities and Significant Environmental Aspects at USIBWC Field Offices Table 3. Objectives and Targets Identified for USIBWC Field Offices Table 4. EMPs and Performance Criteria Identified for USIBWC Field Offices Table 5. Action Items Identified for USIBWC Headquarters, El Paso Table 6. Action Items Identified for San Diego Field Office Table 7. Action Items Identified for Amistad Field Office Table 8. Action Items Identified for Falcon Field Office Table 9. Action Items Identified for Mercedes Field Office iii

Acronyms CA California E.O. Executive Order EMP Environmental Management Program EMR environmental management review EMS environmental management system IEA Initial Environmental Assessment ISO International Organization for Standardization n.d. no date NIWTP Nogales International Wastewater Treatment Plant O&M Operations and Maintenance QA/QC Quality Assurance/Quality Control SBIWTP South Bay International Wastewater Treatment Facility SOP standard operating procedure TSS total suspended solids TX Texas USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency USIBWC United States Section, International Boundary and Water Commission iv

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Section 1 Introduction

The United States Section of the International Boundary and Water Commission (USIBWC) is committed to minimizing its operational impact on the environment by complying with all applicable environmental laws and Presidential Executive Orders. The USIBWC is establishing an environmental management system (EMS) that satisfies the requirements of Executive Order (E.O.)

13148, Greening the Government Through Leadership in Environmental Management, and that conforms to the International Organization for Standardization (ISO) EMS standard ISO 14001:2004. The USIBWC has its headquarters in El Paso, Texas, and operates twelve field or project offices (three of which are satellite field offices) located along the United States and Mexico border. This report addresses EMS implementation at four USIBWC field office facilities (San Diego, Amistad, Falcon, and Mercedes).

The main purpose of the agency’s field offices is to perform all operations and maintenance (O&M) activities necessary to meet the agency’s mission goals. Mission functions are accomplished through the O&M of major activities shown on Figure 1.

The USIBWC has developed a Strategic Plan for 2006 through 2011 to define the agency’s commitment to improving performance and accountability in achieving its mission. The strategic plan focuses on four strategic goals: boundary preservation, water quantity operations, water quality management, and resource management (USIBWC, 2006).

The USIBWC is in the planning phase of developing an EMS for the four subject field office facilities. Under USIBWC Contract No. IBM04D002, Task Order IBM06T0018, Parsons has been tasked to assist in implementing an EMS for the four field office facilities at San Diego, Amistad, Falcon, and Mercedes. Parsons has prepared this EMS Implementation Report to accomplish the following goals:

♦ Document the initial assessment of the facilities.

♦ Establish a procedure to identify environmental aspects and impacts to the environment associated with its main activities.

♦ Assist the field offices develop appropriate objectives and targets.

♦ Assist the field offices develop associated environmental management programs to achieve the identified objectives and targets.

This report follows guidance provided in the Environmental Management Systems Implementers Guide, December 2003 prepared by the U.S. Army Corps of Engineers (USACE).

Levee and Floodway Systems

International Storage Dams and Reservoirs

Hydroelectric Power

Generating Plants

International Wastewater

Treatment Plants

River Gaging Stations

Boundary Monumentation and Demarcation All

Related Structures and

Facilities

Levee and Floodway Systems

International Storage Dams and Reservoirs

Hydroelectric Power

Generating Plants

International Wastewater

Treatment Plants

River Gaging Stations

Boundary Monumentation and Demarcation All

Related Structures and

Facilities

Figure 1. O&M Functions Supporting the Mission of the USIBWC

1.1 Background

As a means to understand the USIBWC EMS status, an environmental management review (EMR) was conducted by the United States Environmental Protection Agency (USEPA) Regions 6 and 9 in July 2005 (USEPA, 2005). The USEPA evaluated the USIBWC existing management system for its environmental program and provided key observations and recommendation for improvement.

Additional initial environmental assessments (IEA) were conducted for the El Paso, Texas, headquarters office, the American Dam field office in El Paso and the Nogales International Wastewater Treatment Plant (NIWTP) in Nogales, Arizona, in October 2005 to assess the status of EMS implementation at these facilities (CDM, 2005).

Based on the USEPA EMR findings and results from an IEA conducted in October 2005 (CDM, 2005), the USIBWC has taken action in moving forward with the EMS development. The USIBWC is in the process of rolling out the same or a similar EMS at the San Diego, Amistad, Falcon and Mercedes Field Offices in order to comply with E.O. 13148 and conform to the ISO 14001 standard. This study was undertaken as part of the continuing EMS implementation at the USIBWC, as depicted on Figure 2.

1.2 Purpose

This EMS Implementation Report documents specific activities that have been undertaken by the USIBWC to develop and sustain its EMS at its appropriate facilities. The report presents the progress of the USIBWC phases of its EMS development and identifies ISO 14001 elements to be developed for the San Diego, Amistad, Falcon, and Mercedes Field Offices. The results of the initial EMS implementation activities for each of the four field offices are included in Appendixes A through D of this report.

Section 2 EMS Implementation Assessment

2.1 Site Visits

Site visits to the USIBWC field offices in San Diego, Amistad, Falcon, and Mercedes were conducted to provide EMS awareness training and workshops for key facility supervisors and personnel. Site visits were conducted as follows:

Figure 2. Status of EMS Implementation at the USIBWC

♦ October 3 and 4, 2006: San Diego, CA, Field Office (South Bay International Wastewater Treatment Plant)

♦ October 24 and 25, 2006: Mercedes, TX, Field Office (Anzalduas and Retamal Dams) ♦ October 26 and 27, 2006: Falcon, TX, Field Office (Falcon Dam and Hydroelectric Power

Plant) ♦ November 1 and 2, 2006: Amistad, TX, Field Office (Amistad Dam and Hydroelectric Power

Plant)

2.2 Training

Parsons provided an EMS Awareness Training presentation to field office personnel in order to review the policies and principles of EMS, train staff in EMS terminology and objectives, and present an overview of the planning workshop. The training presentation was followed by a question-and-answer session. Key participants at each EMS Awareness Training session are listed in Table 1.

Table 1. EMS Awareness Training Participants

USIBWC Field Office EMS Awareness Training Participant Title and Function

San Diego Dion McMicheaux Project Manager Dawi Dakhil Civil Engineer Richard Perna Project Manager (Veolia)/ SBIWTP Superintendent Mercedes Enrique Reyes Project Manager Chris Anzaldua Assistant Project Manager Francisco Martinez Civil Engineer Falcon Silverio Garza, Jr. Supervisory Facility Manager Joel Garza Power Plant Superintendent Scott Mullins Assistant Facility Manager Amistad Kenneth Breiten Project Manager William Conner General Maintenance and Operations Supervisor Michael Evans Operations Support Specialist Roberto Ramos Supervisory Hydraulic Engineer Benito Garcia Powerhouse Superintendent Note: Glenn Hansel, EMS Coordinator from USIBWC Headquarters in El Paso, TX, was present at each of the site visits and participated in the EMS awareness training and planning workshops.

Following the presentation, a tour of the facilities was provided by the field office personnel to present an overview of project field office main operations and functions at each location.

2.3 Results of EMS Planning Workshops

After the EMS Awareness Training and site tours, key field office personnel were interviewed to identify primary roles, responsibilities, and work processes. The personnel interviews and review of relevant operations and maintenance documentation, as well as environmental documents, were conducted to perform the initial assessment of the facility EMS.

Following staff interviews, an EMS Planning Workshop was convened to first focus on identifying the main activities conducted at the facilities to sustain its mission. The list of environmental aspects associated with the identified activities were then ranked based on several significance ranking criteria. From the list of significant environmental aspects, appropriate objectives and targets were developed, along with environmental management programs to achieve the objectives/targets.

2.3.1 Activities, Environmental Aspects and Environmental Impacts

The ISO 14001 Standard requires each federal agency to establish a procedure to identify environmental aspects of its activities (e.g., activities under its control or for which it has an influence) in order to determine those aspects that can have significant impacts on the environment.

The organization must ensure that the aspects related to those significant impacts are considered in setting its environmental objectives. Appropriate identification of environmental aspects is essential in the development of an EMS. The organization’s environmental aspects provide:

♦ The foundation for management programs ♦ Development of objectives and targets ♦ Identification of training requirements ♦ Establishment of standard procedures for operations ♦ Determination of operational controls ♦ Completing general risk assessments ♦ Periodic management reviews ♦ Continual improvement

During the EMS Planning Workshop, main project functions were identified, associated activities that have environmental aspects were listed, and their environmental impacts were identified and ranked. This analysis was conducted with key management and operational staff at each of the four USIBWC field offices in this study. The procedure followed to identify the significant environmental aspects are provided in Appendix E. Table 2 lists the facility, function, activities, and identified significant environmental aspects/impacts developed during the EMS Planning Workshops.

2.3.2 Objectives and Targets

A group of top-ranked environmental impacts identified during the ranking process was selected based on the resulting significance score. The ranking aspects were evaluated to identify specific, measurable objectives that could be implemented in the future. Based on the particular objective, targets were established for preventing or eliminating impacts using the procedure in Appendix F.

Targets are more specific than objectives, drive a specific action, are measurable over time, and have a completion date. Table 3 lists the objectives and targets identified for each of the field offices.

2.3.3 Environmental Management Programs

Environmental Management Programs (EMP) were developed to achieve the associated objectives and targets. The EMP is a convenient way to organize activities and information within the EMS framework. The EMP identifies responsibilities, resources, timelines, and performance records for achieving the target. The EMPs will be coordinated and updated regularly to measure progress and implementation of the EMS. The list of EMPs and performance criteria developed for each of the field offices is provided in Table 4.

Table 2. Key Activities and Significant Environmental Aspects at USIBWC Field Offices

USIBWC Field Office Function Activity Environmental Aspect

San Diego Wastewater Treatment Effluent Water Pollution Wastewater Influent Sewage Overflow Flood Control (Structures) Infrastructure Maintenance Damage to Natural Resources Wastewater Treatment Influent Odor Emissions Amistad O&M of Power Plant and Dam Vehicle and Heavy Equipment

Maintenance Waste Petroleum, Oils, and Lubricants

Dam Operation Gates Operation – Failure Flooding Power Plant Operation Oil Storage Oil Spills Dam Operation Gates Maintenance Waste Oils/Lubricants Falcon Power Plant Operation Oil Storage Oil Spills (in Containment) Water Treatment Hazardous Materials Storage Hazardous Materials Release Power Plant Operation Annual Inspections Waste Rags Power Plant Operation Annual Inspections Waste Oil Generation/Sludge Mercedes Flood Control Levee Design Water Use-Flooding, Levee

Rehabilitation Dam Operation Mis-Operation of Gates Flooding Upstream or

Downstream Irrigation and Drainage

Structures Mis-Operation of Structures Damage to Natural Resources

Maintenance Operations Hazardous Materials, Fuel, Oils, and Lubricant Storage

Hazardous Materials Storage/ Release

Table 3. Objectives and Targets Identified for USIBWC Field Offices

USIBWC Field Office Objective Target

San Diego Meet NPDES Discharge Limits Improve Wastewater Treatment Process Reduce Influent Overflow Reduce Overflow from Facility Collection System Reduce Potential for Habitat Damage Reduce Habitat Damage Compliance with San Diego Air Pollution

Control District Nuisance Rules Reduce Odor-Related Complaints

Amistad Ensure Adequate Flood Protection and Water Conservation/Storage

Adequate Maintenance Plan

Oil Spill Prevention Adequate Secondary Containment Adequate Emergency Response Update and Implement Emergency Response

Procedures Falcon Hazardous Materials Release Prevention Proper Hazardous Materials Storage and Handling Functional Emergency Response Develop and Implement Emergency Response

Procedures Mercedes Ensure Adequate Flood Protection Complete Levee Rehabilitation Ensure Proper Gates Operation Adequate Preventive Maintenance Ensure Operational Flood Control

(Irrigation and Drainage) Structures Proper Implementation of Work Plans

Adequate Emergency Response Develop and Implement Emergency Response Procedures

Table 4. EMPs and Performance Criteria Identified for USIBWC Field Offices

USIBWC

Field Office Target EMP Performance Indicator

SBIWTP Facility Upgrade Increased Percent Total Suspended Solids (TSS) Removal

Improve Wastewater Treatment Process

Build Secondary Treatment Plant in Mexico

Improved Influent Water Quality

Reduce Overflow from Facility Collection System

Improve Canyon Collector System

Reduced Occurrence of Influent Overflow

Reduce Habitat Damage Develop SOPs for Conducting Infrastructure Clearing/ Maintenance Activities

Reduced Occurrence of Habitat Damage

Determine Feasibility of Covering Primary Sedimentation Basins

Reduced Number of Odor-Related Complaints

San Diego

Reduce Odor-Related Complaints

Perform Study to Determine Optimal Life for Odor-Reduction System

Reduced Number of Odor-Related Complaints

Amistad Adequate Maintenance Plan

Amistad Dam Maintenance Plan

– Software Implementation

Maintenance Plan Software Implementation

Maintenance Plan – Employee Training

Completed Employee Training

Adequate Secondary Containment

Investigate Adequacy of Existing Bulk Oil Storage Secondary Containment Systems

Completed Study and Implemented Improvement

Update and Implement Emergency Response Procedures

Update Functional Emergency Response Procedures to Include Chlorine Release/Spills

Completed Emergency Response Procedures and Personnel Training

Falcon Proper Hazardous Materials Storage

Update Water Treatment Plant SOP to Address Process Changes (New Chlorine Process)

Updated Water Treatment Plant SOP

Develop and Implement Emergency Response Procedures

Develop Functional Emergency Response Procedures

Completed Emergency Response Procedures and Employee Training

Mercedes Complete Levee Rehabilitation

Levee Upgrade Adequate Levee Design

Adequate Preventive Maintenance

Develop Procedures to Document Maintenance Actions Performed for Anzalduas and Retamal Dams

Proper Gates Operation

Proper Implementation of Work Plans

Develop Procedures to Conduct Quality Assurance/Quality Control (QA/QC) Check on Work Actions

Completed Work Plans

Develop and Implement Emergency Response Procedures

Develop Functional Emergency Response Procedures

Completed Emergency Response Procedures and Employee Training

Section 3 Summary of EMS Implementation Status and Recommendations

The results of the initial EMS implementation assessment for each of the four field offices are included in Appendixes A through D of this report. The following sections provide recommendations for each of the key EMS elements for the San Diego, Amistad, Falcon and Mercedes Field Offices. These recommendations will assist the USIBWC in meeting the requirements of E.O. 13148 in conformance with the ISO 14001 standard. Action items for USIBWC Headquarters and those included in the previous EMR (USEPA, 2005) and EMS Implementation Reports (CDM, 2005a) are included in Tables 5 through 9 for continuity purposes.

3.1 USIBWC Headquarters, El Paso

Table 5. Action Items Identified for USIBWC Headquarters, El Paso

EMS Element Action Item Framed copies of the Environmental Policy should be made available to all facilities.

Review and authorize the policy when a permanent Commissioner is named and on an annual basis.

Include the environmental policy in EMS document control system.

Distribute the environmental policy to staff and make it available to contractors, vendors, and suppliers.

Promote the environmental policy and EMS through publication of stories related to environmental management and updates on the EMS in The Boundary Marker.

Environmental Policy

Continue publication of the environmental policy on the USIBWC website and ensure that periodic review and updates are conducted.

Develop EMS Procedure to identify legal and other requirements, and documenting these.

The Field Office EMS Implementation Team in coordination with the EMS Core Team should develop and maintain a list of applicable rules, regulations or additional requirements associated with daily activities.

Planning – Legal and Other Requirements

Field Office EMS Implementation Team and/or the EMS Core Team representative should communicate to employees where the location of the regulatory list is retained, and ensure that employees are aware that they are responsible for undertaking actions in compliance with applicable laws and regulations.

Consider P2 opportunities during periodic review of significant environmental aspects, objectives, targets, and EMPs.

Planning – Objectives, Targets and Programs

Consider green building design in future procurement and planned facility upgrades.

Finalize Core EMS Team and Steering Committee.

All staff should be informed of the key contacts for the EMS.

USIBWC should insert EMS language in job descriptions so that employees are aware of their environmental responsibilities.

Implementing – Roles and Responsibilities

The EMS organizational structure, policy, objectives, targets, and procedures should also be communicated to contractors, suppliers, and vendors.

Table 5. Action Items Identified for USIBWC Headquarters, El Paso (Cont’d)

EMS Element Action Item USIBWC should provide competency-based training to those employees whose tasks have the potential to cause a significant environmental impact.

USIBWC should include a copy of the environmental policy, and a description of employees’ roles in environmental management and the EMS, during new hire orientation USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees. The EMS Coordinator and project managers should review these requirements annually.

Implementing – Training

USIBWC should communicate with nearby federal facilities in order to identify and share training opportunities, as appropriate.

USIBWC should assign responsibilities for communicating environmental roles and responsibilities through operational control plans or SOPs, which staff must follow for conducting their work activities.

USIBWC should communicate emergency preparedness and response procedures with its counterparts in Mexico, local authorities, neighboring facilities and contractors, suppliers and vendors. The means for external communication may include, but are not limited to, quarterly Citizens Forum meetings, meetings, annual reports, newsletters or other mailings, and postings on the website.

Implementing - Communication

USIBWC should develop a procedure for handling external communications to ensure that inquiries and concerns are properly referred to the appropriate USIBWC personnel including the Public Affairs representative at USIBWC Headquarters Develop EMS Document and Records control system. Implementing -

Documentation Complete EMS Manual.

USIBWC should ensure that employees and contractor personnel are familiar with project activities with significant aspects and comply with the operational controls to manage the significant environmental impacts.

Implementing – Operational Controls

USIBWC should ensure that employees and contractor personnel document procedures and maintain best practices where their absence could cause nonconformities with the Environmental Policy and/or objectives and targets (such as procedures for equipment maintenance and waste disposal).

Emergency response documents and procedures should be made readily available on the organizational website or intranet page. These procedures can include: risk management plans, spill contingency plans including SPCC Plans, RCRA Contingency Plan, Facility Response Plan, and CAIRA plan.

Implementing – Emergency Response

USIBWC should ensure that emergency evacuation routes are posted in each occupied building.

Develop a procedure for consistent monitoring and measurement program of its environmental performance that also identifies root causes of problems or nonconformities.

Evaluate and document environmental compliance.

Develop corrective action procedures for performing root cause analysis and correcting and preventing any deficiencies or nonconformities.

Develop EMS internal audit program that includes documentation of results and communication to top management.

Follow up in implementation of EMPs.

Checking and Corrective Action

Report quarterly EMS Results and Activities.

Table 5. Action Items Identified for USIBWC Headquarters, El Paso (Cont’d)

EMS Element Action Item Establish a reporting program from EMS Coordinator to EMS Steering Committee.

Report EMS results and activities to EMS Steering Committee.

Develop management review procedures (by the EMS Steering Committee).

Update USIBWC management personnel and staff on current activities at Annual meeting.

Conduct management review at Headquarters, American Dam and NIWTP.

Roll out EMS to any of the remaining USIBWC facilities.

Management Review

Conduct management reviews at least annually.

3.2 San Diego Field Office

Table 6. Action Items Identified for San Diego Field Office

EMS Element Action Item Post copies of the environmental policy in prominent places in the San Diego Field Office and occupied buildings at the SBIWTP.

Include the environmental policy in EMS document control system.

Environmental Policy

Distribute the environmental policy to staff and make it available to contractors, vendors, and suppliers.

The San Diego Field Office in coordination with the EMS Core Team should develop and maintain a list of applicable rules, regulations or additional requirements associated with daily activities. This list should correlate to the Veolia Work Plan to ensure that requirements are adequately addressed and implemented.

The San Diego Field Office and/or the EMS Core Team representative should communicate to employees where the location of the regulatory list is retained, and ensure that employees are aware that they are responsible for undertaking actions in compliance with applicable laws and regulations. This requirement should be also be implemented by the contractor (Veolia) as part of its responsibilities at the SBIWTP.

Planning – Legal and Other Requirements

Consider green building design in procurement and planned facility upgrades.

The San Diego Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Objectives, Targets and Programs

Consider P2 opportunities during periodic review of significant environmental aspects, objectives, targets, and EMPs.

All staff should understand their roles and responsibilities for working under the requirements of the EMS. All staff should be informed of the key contacts for the EMS.

USIBWC should insert EMS language in job descriptions so that employees are aware of their environmental responsibilities.

Staff should be informed on who to contact for direction when significant aspects associated with a project are identified.

Implementing – Roles and Responsibilities

The EMS organizational structure, policy, objectives, targets, and procedures should also be communicated to contractors, suppliers, and vendors, as appropriate.

Table 6. Action Items Identified for San Diego Field Office (Cont’d)

The EMS Coordinator and Core EMS Team should coordinate through Human Resources to collect and retain training records. Collection and retention of training records should also be coordinated with staff working in positions where certification or licensing requirements include continuing education (i.e., SBIWTP plant operators).

The USIBWC should include a copy of the environmental policy, and a description of employees’ roles in environmental management and the EMS, during new hire orientation.

The USIBWC should provide general EMS training to new and existing employees.

Implementing – Training

The USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees. The EMS Coordinator and project managers should review these requirements annually.

The USIBWC should assign responsibilities for communicating environmental roles and responsibilities through operational control plans or SOPs, which staff must follow for conducting their work activities.

Implementing - Communication

The USIBWC should communicate emergency preparedness and response procedures with its counterparts in Mexico, local authorities, neighboring facilities and contractors, suppliers and vendors. The means for external communication may include, but are not limited to, quarterly Citizens Forum meetings, meetings, annual reports, newsletters or other mailings, and postings on the website.

The San Diego Field Office should develop a procedure to establish and maintain EMS information. This includes the EMS Policy, EMS and other appropriate SOPs, environmental compliance plans, emergency response plans and procedures, and other required regulatory permits or reports.

Implementing - Documentation

The San Diego Field Office should develop a procedure to routinely review the operating contractor’s Work Plan, database for maintenance activities, and monitoring reports.

The San Diego Field Office EMS Implementation Team should ensure that SOPs and work instructions associated with daily operations that have potential for environmental impacts have been developed and address the management of environmental aspects and impacts.

These procedures should be developed for the identified significant aspects. The San Diego EMS Implementation Team should update, maintain, and disseminate the procedures and work instructions to staff.

The San Diego EMS Implementation Team should develop a procedure to properly oversee and manage operational controls (i.e., odor-reduction systems) at the treatment plant. The procedure should identify operational controls and specify the scope and schedule for periodic reviews and updates, as required.

The USIBWC should ensure that employees and contractor personnel are familiar with project activities with significant aspects and comply with the operational controls to manage the significant environmental impacts.

Implementing – Operational Controls

The USIBWC should ensure that employees and contractor personnel document procedures and maintain best practices where their absence could cause nonconformities with the Environmental Policy and/or objectives and targets (such as procedures for equipment maintenance and waste disposal).

Table 6. Action Items Identified for San Diego Field Office (Cont’d)

EMS Element Action Item The San Diego Field Office EMS Implementation team should identify all the emergency documents and procedures that are required by rules, regulations, permit stipulations and other sources. The team should compile a list to include the required emergency response documents and procedures including readily available procedures developed by the USIBWC. This list should be reviewed and updated annually by the team.

The San Diego Field Office EMS Implementation Team should incorporate the applicable emergency response documents and procedures into project activities, and ensure that all applicable documents and procedures are integrated into the Veolia Work Plan for the operation of the SBIWTP.

Employees must know where to find a current list of the emergency response documents and procedures associated with daily operations, and are responsible for undertaking actions in compliance with the applicable emergency response procedure.

The San Diego Field Office EMS Implementation Team should ensure that emergency evacuation drills are conducted at the SBIWTP, and included in the Emergency Preparedness Program and Response Plan of the current Veolia Work Plan.

Implementing – Emergency Response

The USIBWC should ensure that emergency evacuation routes are posted in each occupied building at the SBIWTP.

3.3 Amistad Field Office

Table 7. Action Items Identified for Amistad Field Office

EMS Element Action Item Post copies of the environmental policy in prominent places in the Amistad Field Office and occupied buildings.

Include the environmental policy in EMS document control system.

Environmental Policy

Distribute the environmental policy to staff and make it available to contractors, vendors, and suppliers.

The Amistad Field Office EMS Implementation Team in coordination with the EMS Core Team should develop and maintain a list of applicable rules, regulations or additional requirements associated with daily activities.

The Amistad Field Office EMS Implementation Team and/or the EMS Core Team representative should communicate to employees where the location of the regulatory list is retained, and ensure that employees are aware that they are responsible for undertaking actions in compliance with applicable laws and regulations.

The Amistad Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Legal and Other Requirements

Consider green building design in future and planned procurement and facility upgrades.

The Amistad Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Objectives, Targets and Programs

Consider P2 opportunities during periodic review of significant environmental aspects, objectives, targets, and EMPs.

Table 7. Action Items Identified for Amistad Field Office (Cont’d)

All staff should understand their roles and responsibilities for working under the requirements of the EMS. All staff should be informed of the key contacts for the EMS.

USIBWC should insert EMS language in job descriptions so that employees are aware of their environmental responsibilities.

Staff should be informed on who to contact for direction when significant aspects associated with a project are identified.

Implementing – Roles and Responsibilities

The EMS organizational structure, policy, objectives, targets, and procedures should also be communicated to contractors, suppliers, and vendors, as appropriate.

The EMS Coordinator and Core EMS Team should coordinate through Human Resources to collect and retain training records. Collection and retention of training records should also be coordinated with staff working in positions where certification or licensing requirements include continuing education.

The USIBWC should include a copy of the environmental policy, and a description of employees’ roles in environmental management and the EMS, during new hire orientation.

The USIBWC should provide general EMS training to new and existing employees.

Implementing – Training

The USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees. The EMS Coordinator and project managers should review these requirements annually.

The USIBWC should assign responsibilities for communicating environmental roles and responsibilities through operational control plans or SOPs, which staff must follow for conducting their work activities.

Implementing - Communication

The USIBWC should communicate emergency preparedness and response procedures with its counterparts in Mexico, local authorities, neighboring facilities and contractors, suppliers and vendors. The means for external communication may include, but are not limited to, quarterly Citizens Forum meetings, meetings, annual reports, newsletters or other mailings, and postings on the website.

The Amistad Field Office should develop a procedure to establish and maintain EMS information. This includes the EMS Policy, EMS and other appropriate SOPs, environmental compliance plans, emergency response plans and procedures, and other required regulatory permits or reports.

Implementing - Documentation

The Amistad Field Office should develop a procedure to routinely review maintenance Work Plans, database for maintenance activities, and monitoring reports.

The Amistad Field Office EMS Implementation Team should ensure that SOPs and work instructions associated with daily operations that have potential for environmental impacts have been developed and address the management of environmental aspects and impacts.

These procedures should be developed for the identified significant aspects. The Amistad EMS Implementation Team should update, maintain, and disseminate the procedures and work instructions to staff.

The Amistad Field Office EMS Implementation Team should develop a procedure to properly oversee and manage operational controls (i.e., secondary containment and drain systems). The procedure should identify operational controls and specify the scope and schedule for periodic reviews and updates, as required.

The USIBWC should ensure that employees and contractor personnel are familiar with project activities with significant aspects and comply with the operational controls to manage the significant environmental impacts.

Implementing – Operational Controls

The USIBWC should ensure that employees and contractor personnel document procedures and maintain best practices where their absence could cause nonconformities with the

Table 7. Action Items Identified for Amistad Field Office (Cont’d)

EMS Element Action Item The Amistad Field Office EMS Implementation team should identify all the emergency documents and procedures that are required by rules, regulations, permit stipulations and other sources. The team should compile a list to include the required emergency response documents and procedures including readily available procedures developed by the USIBWC. This list should be reviewed and updated annually by the team.

The Amistad Field Office EMS Implementation Team should incorporate the applicable emergency response documents and procedures into project activities.

Employees must know where to find a current list of the emergency response documents and procedures associated with daily operations, and are responsible for undertaking actions in compliance with the applicable emergency response procedure.

The Amistad Field Office EMS Implementation Team should ensure that emergency evacuation drills are conducted.

Implementing – Emergency Response

The Amistad Field Office EMS Implementation Team should ensure that emergency evacuation routes are posted in each occupied building.

3.4 Falcon Field Office

Table 8. Action Items Identified for Falcon Field Office

EMS Element Action Item Post copies of the environmental policy in prominent places in the Falcon Field Office and occupied buildings.

Include the environmental policy in EMS document control system.

Environmental Policy

Distribute the environmental policy to staff and make it available to contractors, vendors, and suppliers.

The Falcon Field Office EMS Implementation Team in coordination with the EMS Core Team should develop and maintain a list of applicable rules, regulations or additional requirements associated with daily activities.

The Falcon Field Office EMS Implementation Team and/or the EMS Core Team representative should communicate to employees where the location of the regulatory list is retained, and ensure that employees are aware that they are responsible for undertaking actions in compliance with applicable laws and regulations.

The Falcon Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Legal and Other Requirements

Consider green building design in future and planned procurement and facility upgrades The Falcon Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Objectives, Targets and Programs

Table 8. Action Items Identified for Falcon Field Office (Cont’d)

All staff should understand their roles and responsibilities for working under the requirements of the EMS. All staff should be informed of the key contacts for the EMS.

USIBWC should insert EMS language in job descriptions so that employees are aware of their environmental responsibilities.

Staff should be informed on who to contact for direction when significant aspects associated with a project are identified.

Implementing – Roles and Responsibilities

The EMS organizational structure, policy, objectives, targets, and procedures should also be communicated to contractors, suppliers, and vendors, as appropriate.

The EMS Coordinator and Core EMS Team should coordinate through Human Resources to collect and retain training records. Collection and retention of training records should also be coordinated with staff working in positions where certification or licensing requirements include continuing education.

The USIBWC should include a copy of the environmental policy, and a description of employees’ roles in environmental management and the EMS, during new hire orientation.

The USIBWC should provide general EMS training to new and existing employees.

Implementing – Training

The USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees. The EMS Coordinator and project managers should review these requirements annually.

The USIBWC should assign responsibilities for communicating environmental roles and responsibilities through operational control plans or SOPs, which staff must follow for conducting their work activities.

Implementing - Communication

The USIBWC should communicate emergency preparedness and response procedures with its counterparts in Mexico, local authorities, neighboring facilities and contractors, suppliers and vendors. The means for external communication may include, but are not limited to, quarterly Citizens Forum meetings, meetings, annual reports, newsletters or other mailings, and postings on the website.

The Falcon Field Office should develop a procedure to establish and maintain EMS information. This includes the EMS Policy, EMS and other appropriate SOPs, environmental compliance plans, emergency response plans and procedures, and other required regulatory permits or reports.

Implementing - Documentation

The Falcon Field Office should develop a procedure to routinely review maintenance Work Plans, database for maintenance activities, and monitoring reports.

The Falcon Field Office EMS Implementation Team should ensure that SOPs and work instructions associated with daily operations that have potential for environmental impacts have been developed and address the management of environmental aspects and impacts.

These procedures should be developed for the identified significant aspects. The Falcon EMS Implementation Team should update, maintain, and disseminate the procedures and work instructions to staff.

The Falcon Field Office EMS Implementation Team should develop a procedure to properly oversee and manage operational controls (i.e., secondary containment and drain systems).

The procedure should identify operational controls and specify the scope and schedule for periodic reviews and updates, as required.

The USIBWC should ensure that employees and contractor personnel are familiar with project activities with significant aspects and comply with the operational controls to manage the significant environmental impacts.

Implementing – Operational Controls

The USIBWC should ensure that employees and contractor personnel document procedures and maintain best practices where their absence could cause nonconformities with the

Table 8. Action Items Identified for Falcon Field Office (Cont’d)

EMS Element Action Item The Falcon Field Office EMS Implementation team should identify all the emergency documents and procedures that are required by rules, regulations, permit stipulations and other sources. The team should compile a list to include the required emergency response documents and procedures including readily available procedures developed by the USIBWC. This list should be reviewed and updated annually by the team.

The Falcon Field Office EMS Implementation Team should incorporate the applicable emergency response documents and procedures into project activities.

Employees must know where to find a current list of the emergency response documents and procedures associated with daily operations, and are responsible for undertaking actions in compliance with the applicable emergency response procedure.

The Falcon Field Office EMS Implementation Team should ensure that emergency evacuation drills are conducted.

Implementing – Emergency Response

The Falcon Field Office EMS Implementation Team should ensure that emergency

3.5 Mercedes Field Office

Table 9. Action Items Identified for Mercedes Field Office

EMS Element Action Item Post copies of the environmental policy in prominent places in the Mercedes Field Office and occupied buildings.

Include the environmental policy in EMS document control system.

Environmental Policy

Distribute the environmental policy to staff and make it available to contractors, vendors, and suppliers.

The Mercedes Field Office EMS Implementation Team in coordination with the EMS Core Team should develop and maintain a list of applicable rules, regulations or additional requirements associated with daily activities. This list should correlate to the Veolia Work Plan to ensure that requirements are adequately addressed and implemented.

The Mercedes Field Office EMS Implementation Team and/or the EMS Core Team representative should communicate to employees where the location of the regulatory list is retained, and ensure that employees are aware that they are responsible for undertaking actions in compliance with applicable laws and regulations.

The Mercedes Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Legal and Other Requirements

Consider green building design in future and planned procurement and facility upgrades.

The Mercedes Field Office EMS Implementation Team should revise and distribute the EMPs for each objective. The team should review and update objectives, targets, and EMPs annually or more frequently, if daily activities change (i.e., new services provided that impact the environment).

Planning – Objectives, Targets and Programs

Table 9. Action Items Identified for Mercedes Field Office (Cont’d)

All staff should understand their roles and responsibilities for working under the requirements of the EMS. All staff should be informed of the key contacts for the EMS.

USIBWC should insert EMS language in job descriptions so that employees are aware of their environmental responsibilities.

Staff should be informed on who to contact for direction when significant aspects associated with a project are identified.

Implementing – Roles and Responsibilities

The EMS organizational structure, policy, objectives, targets, and procedures should also be communicated to contractors, suppliers, and vendors, as appropriate.

The EMS Coordinator and Core EMS Team should coordinate through Human Resources to collect and retain training records. Collection and retention of training records should also be coordinated with staff working in positions where certification or licensing requirements include continuing education.

The USIBWC should include a copy of the environmental policy, and a description of employees’ roles in environmental management and the EMS, during new hire orientation.

The USIBWC should provide general EMS training to new and existing employees.

Implementing – Training

The USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees. The EMS Coordinator and project managers should review these requirements annually.

The USIBWC should assign responsibilities for communicating environmental roles and responsibilities through operational control plans or SOPs, which staff must follow for conducting their work activities.

Implementing - Communication

The USIBWC should communicate emergency preparedness and response procedures with its counterparts in Mexico, local authorities, neighboring facilities and contractors, suppliers and vendors. The means for external communication may include, but are not limited to, quarterly Citizens Forum meetings, meetings, annual reports, newsletters or other mailings, and postings on the website.

The Mercedes Field Office should develop a procedure to establish and maintain EMS information. This includes the EMS Policy, EMS and other appropriate SOPs, environmental compliance plans, emergency response plans and procedures, and other required regulatory permits or reports.

Implementing - Documentation

The Mercedes Field Office should develop a procedure to routinely review maintenance Work Plans, database for maintenance activities, and monitoring reports.

The Mercedes Field Office EMS Implementation Team should ensure that SOPs and work instructions associated with daily operations that have potential for environmental impacts have been developed and address the management of environmental aspects and impacts.

These procedures should be developed for the identified significant aspects. The Mercedes EMS Implementation Team should update, maintain, and disseminate the procedures and work instructions to staff.

The Mercedes Field Office EMS Implementation Team should develop a procedure to properly oversee and manage operational controls (i.e., secondary containment and drain systems).