Checks & Balances
One way we seek continual improvement in environmental performance is the use of a formal, integrated environmental, safety and health (ES&H) management system. Based on the success we achieved in our fossil and hydro generating plants and construction projects, we are expanding the initiative to reach mining operations, coal transfer facilities and river operations.
We annually conduct internal audits of our environmental management systems and compliance processes. Environmental programs were audited at 18 locations during 2012. Generally, the audits confirmed that environmental management programs are in place and effectively achieving compliance objectives. Audits are beginning to move beyond simple compliance objectives to target risks and controls, assuring that procedures are functioning effectively. For example, the Spill Prevention, Control & Countermeasure (SPCC) audit in Transmission was aimed at determining whether existing procedures were effectively assuring that SPCC plans were being updated in a timely manner for new or changed facilities. Enhancements to training and notification processes occurred as a result. The effectiveness of these changes in assuring that the plans are updated and implemented is being assessed.