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Mayor Tom Leppert, City of Dallas
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City Manager Mary K. Suhm, City of Dallas
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Auditing and Compliance

To measure and improve environmental compliance, the Office of Environmental Quality initiated an environmental compliance program in 2004. The program consists of conducting formal compliance assessments of City departments. A compliance assessment determines which environmental laws and regulations apply to a department’s facilities, and whether the facility is currently managing its compliance requirements. The compliance assessment:

  1. Determines applicable regulatory requirements.
  2. Reviews and compares current operations and procedures for compliance with federal, state, and local regulations and internal City policies.
  3. Identifies opportunities for improvement and best management practices.

The assessments consist of an opening meeting, review of facility operations, document review, site walk, personnel interviews, and a closing meeting. Areas of concern are presented and discussed with the City Manager’s Office, the department director, facility personnel and OEQ. The purpose of the meeting is to assign responsibilities and due dates for resolution. An assessment report is issued to the affected facility and OEQ works with the department to resolve areas of concern. Within one year of the completion of the assessment report, OEQ revisits the facility to verify and document the successful resolution of the problem.

Regulated areas reviewed during the compliance assessment are broad and comprehensive. They include:

OEQ began this environmental assessment program in October 2004 and completed 47 assessments in fiscal year 2004-2005.

With over 4,000 pieces of mobile equipment in operation and wide use of oil-based products at multiple City facilities, spills of these materials do occur. OEQ has been charged with managing these spills for the City. This includes on-scene response, regulatory reporting, spill review, tracking and trend analysis. Beginning in late 2004, OEQ fielded a four person Response Team for the express purpose of assisting the departments with non-hazardous spill cleanups and to provide specific spill training.

The City has also established a five-member Environmental Compliance Committee (ECC) chaired by the Director of OEQ to review incidents and spills that occurred during the previous month. The committee determines if the spills were handled correctly, if a spill was preventable and also identifies root causes and trends. If a spill was deemed to be preventable or was not handled correctly (such as not reported in a timely manner to OEQ) the committee may recommend disciplinary action for the affected department director.

The total number of spills reported to and reviewed by OEQ in 2005 was 343. The majority of these spills occurred as the result of equipment malfunction and was not of a size that required reporting to a state or federal agency.

The total number of gallons spilled in 2005 was approximately 2,800. Most of the spills were non-hazardous in nature and some 85 percent included oils and fuels. These materials are used in various processes and activities conducted at City facilities.

 


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