Amtrak 2009 Annual Report Download - page 13

2009 Environmental Health & Safety Report
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Environmental
scoring system for pilot use in FY ‘06. The new EMS scoring system was implemented for
FY ‘07 use with “potential violations per audit” phased out as the preferred metric.
In FY ‘09, three types of findings were included in the audit results: Positive Findings (PF);
Potential Violations (PV); and Management Practices (MP).
Positive Findings are operational practices and designs exceeding compliance requirements
or enhanced environmental protection that promotes pollution prevention, creates
efficiency, and/or reduces Amtrak’ s risks.
The criteria for a Potential Violation finding are based on environmental law or regulation.
A PV finding indicates less than full compliance with applicable requirements.
Management Practices findings indicate that the facility is not fully following Amtrak
standards or best business practices or policies, but does not rise to the level of a Potential
Violation.
For the 17 site audits performed during fiscal year 2009, the audit score was 79 versus an
environmental audit score goal of 82.
The EPA Consent Decree audit requirements and company environmental policy require
Amtrak to identify and resolve environmental compliance issues that appear to be systemic.
As per Amtrak process, one environmental alert on EPA reporting of transformer oil was
issued during FY ‘09.
Environmental FACE Program
The Amtrak Facility Assessment Compliance Evaluation (FACE) Program was initially
rolled out at the end of 2003. As part of the EMS, the FACE Program helps Amtrak assess,
report and correct environmental non-conformance at Amtrak facilities and equipment
locations that are not included in the Environmental Audit Program. During FY ‘09, 47
FACE reviews were performed as part of the Amtrak EMS.
The FACE Program is an evolution of the Environmental Audit Program designed to assess
facilities and operations that present a lower environmental risk than sites included in the
Audit Program. By evaluating and managing potential environmental impacts of Amtrak
operations, the company reduces its environmental risk. The FACE Program covers
approximately 120 facilities—including 70 substation sites in the Northeast Corridor—as
compared to 30 facilities in the Audit Program. FACE protocols are less complex than
Audit Program protocols, and the purpose is to assess general compliance at FACE
facilities. A typical FACE review will normally take a couple of hours of on-site effort,
although some sites may take a day or more to complete.
As with the Audit Program, FACE findings must be addressed with Corrective Action
Plans (CAP). Environmental coordinators usually conduct the FACE evaluations with
support from the Division Senior Environmental Coordinator. FACE findings are reported