EMS for Highway Construction – A Texas Success Story
How do you design, purchase right-of-way, and maintain a “zero violations” environmental compliance record while building Texas’ largest transportation infrastructure project in five years? For the State Highway (SH) 130 project, an Environmental Management System (EMS) for highway construction has been the answer.
In early 2002, the Texas Department of Transportation (TxDOT) awarded a contract to design and construct SH 130 to Lone Star Infrastructure (LSI), a consortium of engineering and construction firms specifically organized to meet the state’s transportation challenges. (1) This 49-mile toll road will provide an alternative to the congested Interstate 35 corridor that currently runs through the Austin area. TxDOT decided to adopt the design-build project delivery system, a first for a Texas highway project, thereby allowing the LSI venture partners to carry out right-of-way acquisition, design, and construction activities simultaneously. The complete project is scheduled to open to the public in December of 2008 (the first half of the roadway is expected to be open by the end of 2007).
TxDOT recognized that the project’s complexity and accelerated pace would present significant environmental compliance challenges. The new location right–of-way spans more than 2,000 acres including sections of protected habitat as well as waters and wetlands. Notwithstanding the environmental compliance challenges inherent to any large construction project, the SH 130 project also has encountered environmental reviews during construction that are normally completed by the time construction starts; these reviews included an extensive NEPA (National Environmental Policy Act) reevaluation, preparation of Section 404 wetlands permit submittals, and development of mitigation plans under state and federal laws. In addition, TxDOT’s Exclusive Development Agreement (EDA) has imposed an extensive set of environmental management requirements on the developer including the ultimate goal of “zero violations” through the life of the project.
To meet these challenges, LSI’s environmental team (AGC-member Hicks & Company (2)) decided to implement an EMS that is tailored to the particular needs of the design-build process and designed to achieve certification under the Texas Commission on Environmental Quality’s Clean Texas Program. Key components of the EMS include an environmental policy, environmental quality control of design, environmental training for all project personnel, environmental compliance inspection and reporting, an awards program, and an active community outreach program.
Now in its fifth year of operation, the SH 130 EMS has accomplished a great deal, both in terms of environmental performance and the development of efficient and cost-effective systems for ensuring environmental compliance on a major transportation infrastructure project. Not only has the project maintained a perfect compliance record under the applicable state and federal regulatory programs, but it has met “beyond compliance” goals as well. Careful planning has preserved over 20 acres of high quality wildlife habitat within the state-owned right-of-way, and the use of recycled asphalt from the Austin airport demolition and other sources has greatly reduced the need for offsite material mining.
SH 130 at the Colorado River Crossing – Looking northwest. Note preserved vegetation within the roadway right of way on the south bank of the river.
The SH 130 EMS has also fostered innovative techniques in adaptive management and environmental performance measurement. Adaptive management provides a process for turning environmental surprises (and even mistakes) into learning opportunities. The Standard Operating Process (SOP) system has proven to be a key adaptive management tool. When the EMS compliance monitoring function identifies a new problem, or determines that an old problem is recurring with unexpected frequency, the SOP procedure analyzes the problem, obtains input (and buy-in) from construction and TxDOT staff, and then implements improved operating procedures. For example, an oil handling and spill prevention SOP has cut hydrocarbon spill incidents in half since its inception. Other SOPs have addressed compliance issues like right-of-way clearance, concrete washout, dewatering, and storm water issues, among others.
The SH 130 EMS has implemented an innovative metrics process that provides weekly performance scores for roadway, earthwork, underground, and structures components of the construction process. The Environmental Performance Measurement (EPM) system was integrated into the lead company’s internationally-recognized Safety Task Assignment process (AGC-member Fluor Corporation), which greatly facilitated the system roll-out. The EPM allows staff to chart variations in performance over time and spot anomalies before they become problems; it also has the added benefit of actively engaging production personnel at the foreman/supervisor level.
Hicks & Company Environmental Compliance Inspector monitoring construction activity on the SH 130 Project
Hicks & Company believes that the most important environmental benefit of a highway construction EMS is also the most basic: maintaining a consistently high level of compliance performance, especially with respect to storm water management. SH 130’s clean compliance record attests to this achievement. This means the contractor can focus on production rather than dealing with delays associated with regulatory violations.
In the longer view, the SH 130 project has shown that an EMS can provide the tools for proactive integration of the values of environmental compliance and awareness throughout the operation, from senior management down to new-hire construction hands. The SH 130 experience over the past four years has demonstrated that an EMS has the capability to gradually change the culture of an organization to a more environmentally-responsible future.
A number of state and federal agencies, as well as national organizations have recognized the SH 130 project as an innovative model for EMS applications. That project’s EMS is recognized in a White House Council on Environmental Quality report (due out next year) on the integration of adaptive management with NEPA. TxDOT also presented the SH 130 EMS as a case study in the roll-out of its statewide EMS-storm water program, which is mandated under a Consent Agreement with EPA. Under that program, TxDOT will apply EMS requirements on three pilot highway projects to be let in 2007 and early 2008. And at special invitation, Hicks & Company presented on the SH 130 project EMS to contractors at an EMS development workshop held by the Associated General Contractors (AGC) of America.
For more information on SH 130 and its EMS, please contact Hicks & Company at (512) 478-0858 or visit http://www.hicksenv.com.
(1) Organized as a joint venture between Fluor Corporation, Balfour Beatty Construction and T. J. Lambrecht Co., the LSI team includes more than a dozen firms who are leaders in their fields of design engineering, utility relocation, public outreach and environmental planning (http://www.sh130.com/about/). AGC members on the LSI team include Austin Bridge & Road, Balfour Beatty Construction, CTL/Thompson, DMJM+Harris, Fluor Corporation, Hicks & Company, T. J. Lambrecht Co., OTHON, PSI, Raba Kistner Infrastructure, Terra-Mar, and Turner Collie & Braden (in alphabetical order).
(2) Hicks & Company is an environmental, planning and archeological consulting firm with environmental compliance specialists who have pioneered the application of environmental management systems (EMS) to large scale construction projects. Hicks & Company environmental managers have developed programs that have received national attention for their innovations in the field of construction-related EMS, and can apply systematic management techniques to keep environmental risks for infrastructure and development projects under control. Hicks & Company is a member of the AGC of Texas Highway, Heavy, Utilities, and Industrial Branch.
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