Metropolitan Transportation Authority, USEPA Region 2 Facility Audit Agreement – Disclosure Support and Training Module Development
Posted on July 29, 2015
Client: Metropolitan Transportation Authority
Location: New York City and Long Island, New York
Project Type: USEPA Region 2 Facility Audit Agreement - Disclosure Support and Training Module Development
- Negotiation and Preparation of Facility Audit Agreement
- Development of “train the Trainer” Program
- Oversight of Auditors
In recognition of the critical role that environmental auditing plays in protecting human health and the environment by identifying, correcting and ultimately preventing violations of environmental regulations, the Metropolitan Transportation Authority (MTA) and the United States Environmental Protection Agency (USEPA) Region 2 entered into a facility audit agreement (FAA) to assess compliance with the regulations promulgated or authorized by the USEPA.
In support of the FAA, the Metropolitan Transportation Authority retained the services of Dvirka and Bartilucci Consulting Engineers (D&B) to develop and oversee the Audit Program. The MTA operating agencies that participated in the audit program included New York City Transit, Bridges and Tunnels, Long Island Bus and MTA Bus. In total, the program encompasses 43 garages, buildings and storehouses of the MTA.
As part of the Audit Program, the firm provided the following support:
• Participation in strategic planning sessions in preparation for meetings with USEPA Region 2;
• Negotiation and preparation of the USEPA Region 2 FAA;
• Preparation of audit procedures and protocols as attachments to the FAA;
• Preparation of a detailed schedule as an attachment to the FAA;
• Development and presentation of a training program to MTA operating agency environmental managers on conducting multimedia environmental compliance audits:
• Undertake and complete “pilot program” multimedia compliance audits at five facilities, addressing each of the participating operating agencies, and prepare disclosure reports;
• Provide limited oversight of MTA personnel conducting internal audits; and
• Provide regulatory review/interpretation and guidance to MTA Operating Agencies (auditors) regarding site-specific issues.
In addition, as part of the early stages of the program, the firm developed and implemented a multi-level training program for compliance with federal regulations aimed at a number of targeted audiences within the MTA organization. One crucial phase of the training program was “train the trainers.” This program also was designed to familiarize facility managers and support personnel with newly developed standard operating procedures (SOPs), as well as existing procedures for waste management and environmental compliance.
The firm also created a guidance tool for the MTA to use as part of their Audit Program, which included a checklist identifying applicable compliance areas. As part of the training program, the firm “walked through” a series of initial selfaudits of varying facilities with MTA personnel to ensure that all in-house staff involved were familiar with and comfortable with the Audit Program procedures.
Once the training program was completed, the MTA, under the direction and support of the firm, conducted multimedia environmental compliance audits of the remaining facilities to evaluate compliance with the following federal regulatory programs:
• Air Programs
• Water Programs
• Pesticide Programs
• Solid and Hazardous Waste Programs
• Hazardous Substances and Chemicals
• Environmental Response
• Emergency Planning and Community Right-to-Know Programs
• Toxic Substance Control Programs
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