Denver International Airport Environmental Programs Management Performance Audit

Transcription

1 Denver International Airport Environmental Programs Management Performance Audit January 2012 Office of the Auditor Audit Services Division City and County of Denver Dennis J. Gallagher Auditor

2 The Auditor of the City and County of Denver is independently elected by the citizens of Denver. He is responsible for examining and evaluating the operations of City agencies for the purpose of ensuring the proper and efficient use of City resources and providing other audit services and information to City Council, the Mayor and the public to improve all aspects of Denver s government. He also chairs the City s Audit Committee. The Audit Committee is chaired by the Auditor and consists of seven members. The Audit Committee assists the Auditor in his oversight responsibilities of the integrity of the City s finances and operations, including the integrity of the City s financial statements. The Audit Committee is structured in a manner that ensures the independent oversight of City operations, thereby enhancing citizen confidence and avoiding any appearance of a conflict of interest. Audit Committee Dennis Gallagher, Chair Maurice Goodgaine Lesley Mitchell Rudolfo Payan Robert Bishop Jeffrey Hart Timothy O Brien Audit Staff John Carlson, Deputy Director, JD, MBA, CIA Chris Wedor, Internal Audit Supervisor, MBA, CICA Rudy Lopez, Lead Internal Auditor Travis Henline, Senior Internal Auditor, CICA Jessica Quintana, Senior Internal Auditor Manijeh Taherynia, Senior Internal Auditor, CPA, CFE You can obtain copies of this report by contacting us at: Office of the Auditor 201 West Colfax Avenue, Department 705 Denver CO, (720) Fax (720) Or download and view an electronic copy by visiting our website at:

3 City and County of Denver 201 West Colfax Avenue, Department 705 Denver, Colorado FAX Dennis J. Gallagher Auditor January 19, 2012 Norm Higley, Director of Environmental Services Department of Aviation City and County of Denver Dear Mr. Higley: Attached is our performance audit of environmental stewardship programs at Denver International Airport (DIA). The purpose of the audit was to evaluate the DIA environmental program, assess regulatory compliance, and ensure that proper internal controls are in place to address DIA s environmental initiatives, goals, and objectives. The Environmental Protection Agency defines Environmental Stewardship as the responsibility for environmental quality shared by all those whose actions affect the environment. I agree with this philosophy. Government at various levels has the ability to practice sound environmental stewardship. By incorporating thoughtful and practical environmental practices into operations, government can protect the environment, lead by example, and set the tone for its citizens. Programs that recognize this important policy objective can protect people and the environment, reduce cost, and propel innovation. Our audit observed that DIA appears to be in compliance with federal, state, and local environmental rules and regulations. I am also pleased that controls appear to be in place and working effectively to minimize environmental impact. Additionally, I was happy to hear that DIA is in the final stages of completing the Environmental Sustainability Program mentioned by Ms. Day in her weekly call on Monday November 28, 2011 and discussed in the enclosed report. DIA s commitment to and focus on environmental sustainability is admirable. If you have any questions, please contact Kip Memmott, Director of Audit Services, at Sincerely, Dennis J. Gallagher Auditor DJG/cw To promote open, accountable, efficient and effective government by performing impartial reviews and other audit services that provide objective and useful information to improve decision making by management and the people. We will monitor and report on recommendations and progress towards their implementation.

4 cc: Honorable Michael Hancock, Mayor Honorable Members of City Council Members of Audit Committee Ms. Janice Sinden, Chief of Staff Ms. Stephanie O Malley, Deputy Chief of Staff Ms. Cary Kennedy, Chief Financial Officer Mr. Doug Friednash, City Attorney Mr. L. Michael Henry, Staff Director, Board of Ethics Ms. Janna Bergquist, City Council Executive Staff Director Ms. Beth Machann, Controller Ms. Kim Day, Manager of Aviation Mr. David Rhodes, Deputy Manager of Aviation Mr. Patrick Heck, Deputy Manager of Finance and Administration To promote open, accountable, efficient and effective government by performing impartial reviews and other audit services that provide objective and useful information to improve decision making by management and the people. We will monitor and report on recommendations and progress towards their implementation.

5 City and County of Denver Dennis J. Gallagher Auditor 201 West Colfax Avenue, Department 705 Denver, Colorado FAX AUDITOR S REPORT We have completed our performance audit of environmental programs management at Denver International Airport (DIA). The purpose of the audit was to examine and assess DIA s programs and processes governing environmental stewardship and to identify possible inefficiencies or opportunities for process improvement. This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, General Powers and Duties of Auditor, and was conducted in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. The audit revealed that DIA s Environmental Program appears to be in compliance with all federal, state, and local rules and regulations as evidenced by third-party review. Additionally, our work observed that environmental programs at DIA are viewed favorably by other U.S. airports and have received numerous awards and recognition in the environmental sustainability arena. Specifically, DIA has been recognized by the Colorado Department of Public Health and Environment as a Colorado Environmental Gold Leader from 2007 to DIA was also the first U.S. airport to achieve ISO certification and DIA has incurred no environmental fines for non-compliance with federal or state regulations. We extend our appreciation to the DIA Environmental Services team who cooperated with us during our audit. Audit Services Division Kip Memmott, MA, CGAP, CICA Director of Audit Services To promote open, accountable, efficient and effective government by performing impartial reviews and other audit services that provide objective and useful information to improve decision making by management and the people. We will monitor and report on recommendations and progress towards their implementation.

6 TABLE OF CONTENTS EXECUTIVE SUMMARY 1 The Environmental Program at Denver International Airport Appears to be Efficient, Effective, and Sustainable 1 INTRODUCTION & BACKGROUND 3 SCOPE 13 OBJECTIVE 13 METHODOLOGY 13 FINDING 15 The Environmental Program at Denver International Airport Appears to be Efficient, Effective, and Sustainable 15 RECOMMENDATIONS 19 ADDITIONAL INFORMATION 20 EXHIBIT A 21 DIA Water Structure Map 21 EXHIBIT B 22 DIA Sanitary Sewer Overflow 22 EXHIBIT B Cont. 23 EXHIBIT C 24 DIA Environmental Programs Organizational Chart 24 AGENCY RESPONSE 25

7 EXECUTIVE SUMMARY The Environmental Program at Denver International Airport Appears to be Efficient, Effective, and Sustainable The performance audit of the Environmental Program at Denver International Airport (DIA) revealed that the airport's management is focused on sustainability and environmental stewardship. The bedrocks of DIA s environmental program are compliance with environmental laws and regulations, timely reactions to environmental emergencies, and high training standards, all of which are evidenced by recognition from domestic airports. The Department of Aviation's Planning and Development Division should maintain environmental stewardship by considering new ways to be innovative, offering its training services to new DIA employees, and sharing best practices with additional airports throughout the country. Environmental Compliance DIA s Environmental Program appears to comply with rules and regulations promulgated by the federal Environmental Protection Agency (EPA), the Federal Aviation Administration (FAA), the Colorado Department of Public Health and Environment (CDPHE), and the City and County of Denver. Audit work substantiated DIA s environmental compliance by verifying its bi-annual external audits and verifying its ISO certification. Additionally, DIA has not been fined for any environmental violations during our audit, nor has it experienced material findings resulting from its external audits. Environmental Responsiveness A recent environmental incident at DIA demonstrates the responsiveness of DIA s Environmental Services section to environmental incidents. On September 3, 2011, DIA personnel discovered a sanitary sewer overflow. Less than three hours later, the overflow was contained. During that period of time, DIA personnel notified all necessary public and private entities and engaged in mitigation techniques using DIA engineers and existing materials. P a g e 1 Office of the Auditor

8 Environmental Training DIA s Environmental Services section has a training program that meets training requirements related to environmental regulations and permits. The curriculum addresses the responsibility of DIA personnel who perform tasks and activities with potential environmental impacts. DIA s Environmental Program is Recognized Nationally DIA s environmental program is recognized by peer airports as a leader in environmental sustainability and has received several environmental awards and certifications. 1 DIA was the first international airport in the United States to have its Environmental Management System (EMS) certified under the ISO standards. 2 It has also been recognized as a Colorado Environmental Gold Leader by CDPHE, a status that acknowledges DIA as an environmental leader and is limited to companies or organizations with excellent environmental records and commitments to continual improvement and sustainability. Additionally, DIA was the first airport to be accepted into EPA s National Environmental Performance Track Program. 3 This program recognized facilities that consistently exceeded regulatory requirements and excel in protecting human health and the environment. 1 DIA received the 2009 Sustainability Champion Award from the Colorado Department of Public Health and Environment and the Colorado Environmental Partnership. This award recognizes individuals and teams that place a high emphasis on and demonstrate environmental sustainability. 2 ISO is an internationally recognized standard for the environmental management of businesses. It prescribes controls for those activities that have an effect on the environment. ISO certification demonstrates an organization s commitment to improving the environment and addressing environmental issues that might arise. 3 National Environmental Performance, Environmental Protection Agency, accessed October 18, 2011, This program was discontinued by the Environmental Protection Agency on May 14, City and County of Denver P a g e 2

9 INTRODUCTION & BACKGROUND History of Denver s Airports The City and County of Denver has had two major airports. The Denver Municipal Airport opened in 1929 as Colorado s premier airport. It was later renamed Stapleton International Airport (Stapleton) in honor of the City s Mayor, Benjamin Stapleton. In 1995 Stapleton was decommissioned when Denver International Airport (DIA) opened. The Stapleton site was later redeveloped into one of the largest urban infill development projects in the United States and includes housing, open space, schools, retail, and commercial sites. 4 However, project development could not commence until various environmental issues associated with the operation of the airport were remediated. Stapleton International Airport Environmental Remediation Before the Stapleton site was redeveloped, extensive environmental remediation efforts were required on the approximately 4,700 acres of land previously operated by Stapleton. 5 Over time aviation activities contributed to a number of environmental issues, including soil and groundwater contamination from jet fuel, gasoline, and de-icing agents. Furthermore, a number of buildings that had been used for airport operations contained hazardous substances such as asbestos, polychlorinated biphenyls, and leadbased paint. The DIA Commercial group and Airport Legal Services have managed the Stapleton remediation project. The clean-up process involved remediating the soil overlaying a majority of the Stapleton site. Jet fuel had leaked from an underground network of pipes and hydrants, starting small but growing larger with time as the fuel seeped below ground and eventually into underground water. The water provided the fuel with a horizontal pathway, creating an underground plume of contamination. 6 The remediation process was originally estimated to cost $5 million; to date costs have reached $50 million and are expected to continue to rise. 4 Stapleton Brownfield Remediation, Parsons Engineering, accessed November 10, 2011, 5 Ibid. 6 Paula Moore, Engineers clean up Stapleton: Parsons Engineering handles old airport, Denver Business Journal, February 21, 2000, P a g e 3 Office of the Auditor

10 Denver International Airport Environmental Services In the 1980s the City and County of Denver commenced plans for building a new airport on a new site larger than the land on which Stapleton was situated. The expansion was intended to enhance the airport s capabilities and, in turn, the City s economic development. Due to increased environmental awareness at the time, and in an effort to ensure environmental stewardship, DIA was planned, designed, and constructed to mitigate potential environmental incidents. DIA opened in 1995 on a site spanning approximately fifty-three square miles of open prairie. DIA s Environmental Services section is responsible for the environmental compliance and management program at DIA and is part of the Department of Aviation s (Department) Planning and Development Division. The program encompasses water quality, air quality, permitting, materials management, recycling, storage tank management, environmental training, stormwater inspections, and tenant activities. The program s primary goals are to ensure that DIA facilities and activities comply with environmental requirements established by federal, state, and local regulatory agencies and to support and implement the Department s vision and environmental policies. Responsibilities of DIA s Environmental Services section include but are not limited to: Implementing and maintaining DIA s environmental management system (EMS), which is described later in this report Interacting and coordinating with regulatory agencies Participating in project meetings to ensure consideration of environmental impacts and compliance with permitting and other regulatory requirements Inspecting facilities and activities to ensure compliance with regulatory requirements Providing environmental training and educational materials to DIA employees, contractors, tenants, and other business partners Department of Aviation s Environmental Vision and Policy DIA s Environmental Services section serves to implement the goals of the City s Department of Aviation, which operates DIA. The Department issued a strategic plan in 2009, setting out five goals to help achieve the vision of the airport; one of the goals is taking environmental stewardship to new heights. 7 To implement this goal, the Department has committed to seven action items. 8 7 Together We Soar: A Strategic Plan for Denver International Airport, Denver International Airport, May Denver International Airport Environmental Policy, Denver International Airport, accessed June 22, 2011, City and County of Denver P a g e 4

11 Systematically manage its environmental aspects to identify opportunities for continual improvement. Maintain systematic program to support continued compliance with all applicable regulations. Enhance its material and energy efficiency and pursue pollution-prevention opportunities. Foster environmental stewardship at all levels within the organization. Grow its business and facility in an environmentally and economically sustainable manner. Engage its business partners to support DIA s environmental commitment. Recognize and take advantage of opportunities to derive business value from improved environmental performance. Denver International Airport s Long-Term Strategic Initiatives and Planning DIA leadership has developed five strategic priorities to help achieve the vision of the airport. Five priority areas comprise the strategic vision regarding the future of the facility. 9 Excelling in airport management Providing unparalleled, inspiring service Taking environmental stewardship to new heights Delivering via high-performance teams Enhancing DIA s competitive advantage To establish DIA as a global leader in environmental sustainability, DIA has developed various objectives, including seven areas of focus. 10 Create and publicize both internally and externally a framework for achieving environmental goals. Develop and implement a clean air policy addressing both mobile and stationary emissions sources. Implement and accelerate initiatives to reduce emissions and energy consumption, increase air quality, and subsequently achieve long-term cost savings. 9 Together We Soar: A Strategic Plan for Denver International Airport, Denver International Airport, May Ibid. P a g e 5 Office of the Auditor

12 Become a zero-waste facility by Become a carbon-neutral airport by Incorporate sustainability principles into all aspects of business. Aggressively publicize DIA s environmental practices and significant milestones. DIA is taking steps to achieve these goals and objectives through the implementation of its Strategic Plan and Environmental Policy. DIA portends to engage its community partners to become the industry leader in environmental stewardship and to create a better facility in the process. Environmental Rules and Regulations Governing the Denver Municipal Airport System DIA is subject to numerous federal, state, and local rules and regulations. The Airport Environmental Program helps airports implement environmental policies and comply with other Federal environmental rules and regulations. Areas include regulation focused on air quality, water quality, noise, sustainability, land use, and wildlife hazard mitigation. National Environmental Policy Act The National Environmental Policy Act, or NEPA, establishes national environmental policies and goals for the protection, maintenance, and enhancement of the environment in the United States. 11 The act requires that federal agencies integrate environmental factors into their decision-making processes by considering the environmental impacts of their proposed actions. They must also consider reasonable alternatives to any actions that may have an adverse affect on the environment. The Office of Airports (ARP) within the Federal Aviation Administration (FAA) is responsible for ensuring that all public-use airports comply with NEPA requirements. FAA Order B provides guidelines for ARP personnel and other parties to consider NEPA requirements in all airport actions. Accordingly, airport authorities must take into account known environmental factors early in their project planning for all airport development and redevelopment projects. Any airport seeking FAA approvals for changes to airport layout plans, or applying for federal funds under the airport improvement program to build airport facilities, must consider potential environmental impacts. 12 DIA is regulated by NEPA and is also subject to local regulations U.S.C Federal Aviation Administration, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Projects, Order B, Chapter 2, pages (April 28, 2006). City and County of Denver P a g e 6

13 Federal Air Quality Standards The aviation industry is subject to myriad air quality rules and regulations. The Air Pollution Control Act of 1955 was the first time federal legislation was passed acknowledging air pollution as a concern. The purpose of the act was to provide monies for air pollution research, which led to the passage of the Clean Air Act of This federal legislation moved the 1955 act further by proposing air pollution control measures. Specifically, it established a federal program within the U.S. Public Health Service and authorized research into techniques for monitoring and controlling air pollution. Federal monitoring activities were further increased in 1967 with the passage of the Air Quality Act, which addressed the concept of air pollution transport. As a result, the federal government conducted for the first time widespread monitoring studies and stationary source inspections. 13 In accordance with federal, state, and local requirements, DIA s Environmental Services section conducts a variety of air quality reporting and compliance activities. These activities include oil and gas operations reporting, air permitting, boiler air pollutant emission notices, paint booth air pollutant emission notices, monthly emissions tracking, visible observation reporting, and volatile organic compound (VOC) reporting. Clean Air Act The passage of the Clean Air Act (CAA) resulted in a major shift in the federal government's role in air pollution control. This legislation authorized the development of comprehensive federal and state regulations to limit emissions from both stationary industrial sources and mobile sources. The adoption of this legislation passed at approximately the same time as NEPA, which established the U.S. Environmental Protection Agency (EPA). EPA was established on May 2, 1971, to implement the requirements of the Clean Air Act of State Air Quality Standards The Colorado Department of Public Health and Environment (CDPHE) issues air permits to facilities governed by federal air quality rules and regulations, including DIA. CDPHE issued DIA a facility-wide permit, which covers all emissions occurring at the airport, including the Jeppesen Terminal, the Central Plant, the Airport Office Building, and the Maintenance Support Center. Depicted in table one are DIA s annual emissions limitations. Notably, DIA did not exceed permitted levels during our review. 13 History of the Clean Air Act, Environmental Protection Agency, accessed August 24, 2011, 14 Ibid. P a g e 7 Office of the Auditor

14 Table One DIA Air Pollutant Emissions Limitations Source Annual Amount Particulate Matter 16.8 Tons PM Tons Sulfur Dioxide 13.8 Tons Nitrogen Oxides 38.7 Tons Volatile Organic Compounds 4.6 Tons Carbon Monoxide 22.5 Tons Any Single Hazardous Air Pollutant 8.0 Tons Source: DIA Permit 99DE0142 Federal Water Quality Standards The Federal Water Pollution Control Act of 1948 was the first major U.S. law to address water pollution. According to EPA, growing public awareness and concern for controlling water pollution led to sweeping amendments in As amended in 1977, the law became commonly known as the Clean Water Act (CWA). 15 In 1977 five significant amendments were made to CWA. 16 Established the basic structure for regulating pollutants discharged into the waters of the United States. Granted EPA the authority to implement water pollution control programs. Maintained existing requirements to set water quality standards for all contaminants in surface waters. Made it unlawful for any person to discharge any pollutant from a point source into navigable waters, unless a permit was obtained under its provisions. Funded the construction of sewage treatment plants. DIA s approach to CWA compliance includes stormwater pollution prevention and deicing (Glycol) reclamation. 17 DIA s main focus remains on the Glycol reclamation percentage for de-icing planes in cold weather. Any non-compliance with Glycol reclamation, in conjunction with a breach of the stormwater pollution system, could lead to a CWA violation U.S.C (1972) U.S.C. 1251, et. seq. 17 Refer to Exhibit A for a map of the DIA Water Structure System. City and County of Denver P a g e 8

15 CWA permitting can be complex and has been the subject of litigation. The EPA and U.S. Army Corps of Engineers have recently issued guidance to increase clarity with regard to CWA permitting. 18 Denver Municipal Airport System Rules and Regulations In addition to complying with NEPA, DIA is subject to the Denver Municipal Airport System Rules and Regulations; Part 180 specifically addresses environmental management. 19 Additionally, each DIA Business Partner must comply with all provisions of Part 180 when conducting activities and operations at DIA. 20 DIA Business Partners must develop procedures to manage their operations to meet environmental requirements. 21 The Department has identified the following environmental aspects as significant for DIA. 22 Fourteen distinct areas comprise potential significant environmental aspects for DIA. Aircraft De-icing Fluid (ADF) Criteria Air Pollutants Hazardous Waste Liquid Fuels Lubricants Municipal Solid Waste Ozone-depleting Compounds (ODCs) DIA Significant Environmental Aspects Pavement De-icers Remediation-/Investigation-Derived Waste Sediment and Street-Sweeping Waste Sewage Solvents Universal Waste Wash Fluids The list of significant aspects and their related impacts must be maintained and kept current in order to meet the ISO standard On May 2, 2011, EPA released draft guidance for identifying waters protected by the CWA. For more information on this guidance see generally Deborah Freeman and Steve Dougherty, New Federal Guidance on Identifying Waters Protected by the Clean Water Act, The Colorado Lawyer, Vol. 40, No. 12, December Denver Municipal Airport System Rules and Regulations: Part , Introduction, Denver International Airport, accessed October 4, 2011, 20 DIA Business Partner refers to any person or legal entity that operates a business or non-profit organization at the airport under a lease, concession agreement, operating agreement, permit, contract, use and lease agreement, purchase order, license, or other legal authority. 21 Denver Municipal Airport System Rules and Regulations: Part , Definitions, Denver International Airport, accessed October 4, 2011, 22 Denver Municipal Airport System Rules and Regulations: Part , Significant Environmental Aspects at DIA, Denver International Airport, accessed October 4, 2011, 23 A significant environmental aspect is an element of an organization's activities, products, or services that can interact with the environment. P a g e 9 Office of the Auditor

16 Environmental Management System and ISO Standard To manage the environmental aspects of the DIA facilities and activities in a more effective manner, and consistent with the steps defined in the DIA Environmental Policy, DIA s Environmental Services section has implemented an Environmental Management System (EMS); the EMS is based on an internationally accepted standard developed by the International Organization for Standardization known as ISO DIA s EMS consists of a series of guidelines, policies, procedures, and processes to ensure that daily environmental impacts are addressed in a systematic manner. As a part of the EMS, DIA s Environmental Services section sets annual environmental goals and objectives and develops programs and projects to pursue those goals and objectives through a multiple-step cycle; steps in the cycle include Plan, Do, Check, and Feedback. 25 Using the EMS also helps DIA increase its operating efficiency. 26 DIA s EMS has been certified in accordance with ISO since 2004 and is subject to external audits every three years to ensure conformity with these standards. Additionally, DIA is audited bi-annually by NFS, an external auditing firm. NFS provides third-party environmental auditing and compliance reporting and is nationally certified by EPA. Federal Requirements for Use of the ISO Standard Two federal Executive Orders require federal agencies to implement EMS systems at all appropriate levels and facilities. The orders include Executive Order 13423, "Strengthening Federal Environmental, Energy, and Transportation Management," and Executive Order 13148, Greening the Government through Leadership in Environmental Management. The EMS approach is intended to ensure that federal agencies take all actions necessary to integrate environmental accountability into day-to-day decision making and longterm planning processes, across all agency missions, activities, and functions. 27 The ISO Standard is one of the most widely recognized EMS models and is the choice of the FAA as well as most other federal agencies, where the agencies have decided it is appropriate to implement an EMS. Following the ISO model, an implementing organization or facility would incorporate five major elements into its EMS. 24 ISO stands for the International Organization for Standardization, located in Geneva, Switzerland. ISO promotes the development and implementation of voluntary international standards for environmental management issues. ISO standards are developed through a voluntary, consensus-based approach. For more information on the ISO standard see the Environmental Management System/ISO Frequently Asked Questions section found at: 25 Environmental Management System, Environmental Protection Agency, accessed October 25, 2011, 26 Ibid. 27 Aligning National Environmental Policy Act Processes with Environmental Management Systems, Council on Environmental Quality, page City and County of Denver P a g e 10

17 An environmental policy with a commitment to continual improvement, pollution prevention, and compliance with relevant environmental legislation and regulations. Procedures to identify the organization s environmental impacts, identify legal and other responsibilities, and set objectives and targets with environmental management programs. System implementation and operation, including identification of responsibilities, training and awareness, documentation, and operational controls. Checking and corrective actions, including monitoring and measuring performance to meet targets for continual improvement. Management reviews to ensure that the EMS is structured for changing conditions and information. Airport Sustainability The FAA recently introduced the Sustainable Master Plan Pilot Program. This program is evaluating ways to make sustainability a core objective at every airport in the country by funding long-range planning documents at ten participating airports. These documents, called Sustainable Master Plans and Sustainable Management Plans, will include initiatives for reducing environmental impacts and achieving economic benefits while increasing integration with local communities. The program will end in late 2012, and the FAA intends to use lessons learned to develop national program guidance on airport sustainability. Table two highlights airports that are participating in the pilot program. Table Two Airports Participating in the FAA s Sustainable Master Plan Pilot Program Airport Denver International Airport Fresno Yosemite International Airport Hartsfield-Jackson Atlanta International Airport Nashville International Airport Newark Liberty International Airport Newport News / Williamsburg International Airport Newton City-County Airport Outagamie County Regional Airport Renton Municipal Airport Teterboro Airport State Colorado California Georgia Tennessee New Jersey Virginia Kansas Wisconsin Washington New Jersey Source: FAA Airport Sustainable Master Plan Pilot Program. Beyond the FAA pilot program, many airports routinely incorporate sustainability principles into their planning, design, building, and operations. The concept of airport sustainability comprises three core principles: protecting the environment, maintaining high and stable levels of economic growth, and social progress that recognizes all stakeholders needs. P a g e 11 Office of the Auditor

18 There are many benefits associated with incorporating sustainability practices into airport planning. Some of these benefits include a reduction in energy consumption, noise impacts, hazardous and solid waste, and greenhouse gas emissions. Facilities may also enjoy improved water quality and community relations as well as cost savings. Airport master plans have traditionally focused first on accommodating an airport's forecasted demand and secondarily on the associated environmental impacts. However, considering sustainability issues during the planning process promotes design, project implementation, and financial decisions that will ultimately reduce facility energy consumption, environmental impacts, and an airport s carbon footprint. City and County of Denver P a g e 12

19 SCOPE To assess Denver International Airport s (DIA) programs and processes governing environmental safety. The audit included a risk assessment of various environmental risks at DIA. Areas reviewed included stormwater, de-icing fluid, air quality, the Environmental Management System, and strategic initiatives. OBJECTIVE The objective of the audit was to assess Denver International Airport s (DIA) environmental programs and determine if DIA is in compliance with various federal, state, and local government rules and regulations. This included a review of DIA s strategic initiatives, air and water quality, de-icing fluid reclamation, and the Environmental Management System. METHODOLOGY We utilized several methodologies to achieve the audit objective. These evidence-gathering techniques included, but were not limited to: Reviewing federal, state, and local environmental laws, rules, and regulations Reviewing Federal Aviation Administration regulations and ensuring that Denver International Airport (DIA) has programs required by those regulations Researching environmental topics from the Environmental Protection Agency and the Committee on Environmental Quality Interviewing staff from DIA s Environmental Services section Reviewing DIA s Environmental Management System (EMS) Reviewing compliance and monitoring reports generated by DIA s Environmental Services section Reviewing the results of DIA s external environmental audits Touring environmental incident locations, which occurred in association with the operations of DIA Documenting DIA s current environmental programs Benchmarking against environmental programs at the following airports: Chicago O Hare International Airport Dallas/Fort Worth International Airport LaGuardia Airport Salt Lake City International Airport P a g e 13 Office of the Auditor

20 Los Angeles International Airport LA/Ontario International Airport Van Nuys Airport City and County of Denver P a g e 14

21 FINDING The Environmental Program at Denver International Airport Appears to be Efficient, Effective, and Sustainable Denver International Airport s (DIA) environmental program is the result of effective management strategy and practices focused on sustainability and practical environmental stewardship. The foundation of DIA s environmental program are controls designed to achieve compliance with environmental laws and regulations, timely reactions to environmental emergencies, and high training standards, the effectiveness of which are evidenced by national recognition. Environmental Compliance Program Category DIA s Environmental Program appears to be fully compliant with rules and regulations promulgated by the federal Environmental Protection Agency (EPA), the Federal Aviation Administration (FAA), the Colorado Department of Public Health and Environment (CDPHE), and the City and County of Denver. Audit work substantiated DIA s environmental compliance by verifying its bi-annual external audits and verifying its ISO certification. Additionally, DIA has not been fined for any environmental violations during our audit, nor has it had material findings resulting from its external audits. Areas of DIA s compliance are identified in the table three. Table Three Areas Examined Compliance Verified By Third Party Air Air Permit Annual emissions allowance Yes Air Air Quality Non-attainment strategy Yes Air Reporting and Monitoring Incinerator and central plant EMS Meeting ISO Standard EMS Certification Yes EMS Third-party bi-annual EMS audits Yes Water De-icing Glycol captured Yes Water Stormwater Inspection compliance Yes Yes Factors Contributing to Environmental Success We identified several reasons for DIA s environmental management success. DIA s vision, mission, and strong commitment to becoming the world s leading airport now and in the future contribute to the overall success of DIA s Environmental Program. DIA was the first airport in the nation that has designed and implemented an ISO certified Environmental Management System (EMS). Further, the management of DIA s P a g e 15 Office of the Auditor

22 Environmental Services section has created an environment of open communication and responsiveness. Environmental Responsiveness During our audit, we encountered a situation that demonstrates the responsiveness of the DIA Environmental Services section to environmental situations. The following incident highlights the ability of DIA and the Environmental Services section to work cohesively as a unit. Collectively, they made time-dependent decisions; drew upon synergies between federal, state, local environmental agencies; and notified the local community. September 2011 Sewer Overflow and Containment On September 3, 2011, at approximately 12:40 p.m., DIA personnel discovered an untreated sanitary sewer overflow. At 2:53 p.m., DIA personnel notified CDPHE, the National Response Center (NRC), the Tri- County Health Department, Adams County, Farmer s Irrigation and Reservoir Company, and downstream residents of the sewer overflow. By 3:30 p.m. less than three hours later the overflow was contained. DIA personnel determined that the overflow originated from a manhole within a swale located between 75 th Avenue and Peña Boulevard, east of Jackson Gap. 28 The overflow was believed to be the result of a gravity main sanitary line that was obstructed by a collapsed manhole and blockage in the line. Immediately after the overflow was discovered, DIA engineers placed an earth berm downstream of the manhole to divert the sewage flow into an alternate line that led to DIA s Lift Station One, and then discharged to Metro Wastewater s treatment facility. Two days later, DIA engineers constructed a dam at DIA s property line to contain and treat the sewage overflow with chlorinated tabs before it could enter into nearby Third Creek and Barr Lake. Third Creek is part of DIA s storm water drainage system and also flows through private property and into an irrigation canal. Less than three hours from the overflow discovery Environmental Services achieved containment In addition to installing the berm and the dam, DIA engineers also designed a filtration water release control system at the dam to treat the water with de-chlorination tabs as it was being released into Third Creek. 29 The filtration system was built utilizing on-hand supplies, resulting in minimal cost to the City. In addition, DIA personnel placed warning signs along Third Creek notifying the public of the potential health risks present. DIA 28 Refer to Exhibit B for images of the DIA Sanitary Sewer Overflow. 29 Chlorinated tabs help kill harmful microorganisms and bacteria in water, while de-chlorinated tabs help remove the residual chlorine. City and County of Denver P a g e 16

23 continues to work with CDPHE to monitor the water entering Third Creek to ensure that fecal coliform bacteria levels and water quality are within the allowable standards. Environmental Training DIA s Environmental Services section strives to meet training requirements related to environmental regulations and permits and to provide general awareness to DIA personnel regarding environmental issues. Materials from DIA s environmental training program address the responsibility of DIA personnel who perform tasks and activities with potential environmental impacts. Environmental training covers eight major topic areas. Stormwater pollution prevention Permit inspection and enforcement Environmental awareness Composting Resource Conservation and Recovery Act awareness Airport-specific environmental regulation Spill prevention controls and countermeasures Incinerators The most recent external audit of DIA s EMS, completed in November 2010, found that the environmental training program is an effective component of the EMS. 30 DIA s Environmental Program is Recognized Nationally DIA s environmental program is recognized by peer airports as a leader in environmental sustainability and has received several environmental awards and certifications. DIA was the first international airport in the United States to have its EMS certified under ISO standards. It has also been recognized as a Colorado Environmental Gold Leader by CDPHE, a status that acknowledges DIA as an environmental leader and is limited to companies or organizations with excellent environmental records and commitments to continual improvement and sustainability. 31 Additionally, DIA was the first airport to be accepted into EPA s National Environmental Performance Track Program. 32 This program recognized facilities that consistently exceeded regulatory requirements and excel in protecting human health 30 NSF International Strategic Registrations Audit Report, Surveillance Audit, November 3, 2010 to November 4, 2010, p Environmental Leadership Program, Office of Environmental Integration and Sustainability, accessed October 20, 2011, 32 National Environmental Performance, Environmental Protection Agency, accessed October 18, 2011, This program was discontinued by the Environmental Protection Agency on May 14, P a g e 17 Office of the Auditor

24 and the environment. The commitment of DIA s Environmental Services section to environmental stewardship is also illustrated by the following achievements: DIA has not been fined for any issues related to environmental compliance during the audit period DIA is recognized for its environmental program by some peer airports. DIA reduced its energy usage from 4.58 kilowatts per passenger in 2009 to 4.44 in 2010 DIA reduced its waste from 6.1 lbs. of hazardous waste per passenger in 2009 to 3.6 in 2010 Fifty-two percent of DIA s fleet is alternatively fueled DIA installed a third photovoltaic system DIA consistently captures between 69 and 71 percent of the airport s de-icing fluid (Glycol); EPA requires that airports reclaim at least 60 percent of all de-icing fluid DIA significantly reduced paper usage in 2009 and 2010 Various recycling and composting programs resulted in a reduction in pounds of total disposed solids per passenger, yielding over $51,000 in savings In 2009, DIA s recycling operations generated a cost savings of $1.4 million To ensure that DIA s environmental policy is implemented, DIA asks employees to follow essential procedures, comply with legal requirements, and DIA s Environmental Policy when performing all work at the airport. Moreover, the expectation is that employees know which significant environmental aspects apply to their job at DIA and attend environmental training when offered. City and County of Denver P a g e 18

25 RECOMMENDATIONS We offer the following three recommendations to the Department of Aviation s Planning and Development Division regarding its environmental stewardship: 1.1 Environmental Management Leadership Implement initiatives outlined in the DIA Strategic Plan to further enhance environmental stewardship goals. 1.2 New Hire Training Consider instituting mandatory Environmental General Awareness Training for all new DIA employees to promote awareness and provide education regarding DIA s environmental stewardship and supporting programs. 1.3 Environmental Program Exchange Consider sharing environmental best practices with other U.S. airports and leverage learning opportunities from other environmental stewardship programs. P a g e 19 Office of the Auditor

26 ADDITIONAL INFORMATION 33 U.S.C Clean Water Act. 42 U.S.C National Environmental Policy Act. Aligning National Environmental Policy Act Processes with Environmental Management Systems, Council on Environmental Quality. Denver International Airport Environmental Policy, Denver International Airport, Denver Municipal Airport System Rules and Regulations: Part , Introduction, Denver International Airport, Denver Municipal Airport System Rules and Regulations: Part , Definitions, Denver International Airport, Denver Municipal Airport System Rules and Regulations: Part , Significant Environmental Aspects at DIA, Denver International Airport, Environmental Leadership Program, Office of Environmental Integration and Sustainability, Environmental Management System, Environmental Protection Agency, National Environmental Policy Act (NEPA) Implementing Instructions for Airport Projects, Federal Aviation Administration, Order B, Chapter 2, April 28, History of the Clean Air Act, Environmental Protection Agency, Moore, Paula. Engineers clean up Stapleton: Parsons Engineering handles old airport, Denver Business Journal, February 21, 2000, National Environmental Performance, Environmental Protection Agency, NSF International Strategic Registrations Audit Report, Surveillance Audit, November 3-4, Stapleton Brownfield Remediation, Parsons Engineering, Together We Soar: A Strategic Plan for Denver International Airport, Denver International Airport, May City and County of Denver P a g e 20

27 EXHIBIT A DIA Water Structure Map P a g e 21 Office of the Auditor

28 EXHIBIT B DIA Sanitary Sewer Overflow Source: DIA Environmental Services. City and County of Denver P a g e 22

29 EXHIBIT B Cont. Source: Audit Services Division Audit Team. P a g e 23 Office of the Auditor

30 EXHIBIT C DIA Environmental Programs Organizational Chart City and County of Denver P a g e 24

31 AGENCY RESPONSE P a g e 25 Office of the Auditor

32 City and County of Denver P a g e 26