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In the news lately ...

Region 2 EPA Fines to Universities and Colleges. In the news lately . Region 2 EPA University Fines. Raritan Valley Comm Coll. NJ City U. CW Post Coll. Seton Hall U. Vassar Coll. Kean U. U. MDNJ Princeton U. Clarkson U. Pace U. (All in the news in 2003). EPA Region 2 News 11/5/03.

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In the news lately ...

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  1. Region 2 EPA Fines to Universities and Colleges In the news lately ...

  2. Region 2 EPA University Fines Raritan Valley Comm Coll. NJ City U. CW Post Coll. Seton Hall U. Vassar Coll. • Kean U. • U. MDNJ • Princeton U. • Clarkson U. • Pace U. (All in the news in 2003)

  3. EPA Region 2 News 11/5/03 “….Vassar could have avoided most, if not all of, the penalties for violations of hazardous waste regulations by participating in EPA’s voluntary self-audit program,” said EPA Regional Administrator Jane M. Kenny. “Participation in the self-audit program helps educational institutions avoid most penalties and learn to better manage their hazardous waste, safeguarding both people and the environment.”

  4. Safety-L email 12/9/03 U. North Carolina EH&S Director notes: The EPA statement “implies that Vassar could have avoided the fine if they had only ‘voluntarily’ participated in Region 2's self-audit program. It doesn't sound so voluntary to me.”

  5. Depends on how you define…? No, it does not. Voluntary participation leads to (1) no or small fines for self-disclosed violations, and to (2) improved compliance, good future inspection. Declining to participate typically leads to no improved compliance, and bad future inspection.

  6. How the University of California Prepared for & Implemented Its U.S. EPA Compliance Incentive AuditLawrence S. Wong, CIHUniversity of California, San Francisco(415)514-2824 lwong@ehs.ucsf.edu Presented at AIHCe Dallas May 2003. Notes and animated elements added by L. Swihart, December 2003

  7. University of California System • Nine Campuses • 8 Undergraduate/Graduate Campuses • 5 Medical Schools • Manage 3 DOE National Laboratories • Lawrence Livermore National Laboratory • Lawrence Berkeley National Laboratory • Los Alamos National Laboratory (New Mexico) • Division of Agriculture & Natural Resources (DNR) – 130,00 Acres of Natural Habitats

  8. University of California System • 180,000 students • 150,000 faculty and staff • $14 billion annual expenditures

  9. Background • July, 2001 U.S. EPA region IX invitation • Compliance incentive program & self disclose by January 2002 • September 2001 meeting • U.S. EPA region IX • Calif. Dept. Of toxic substances control (DTSC) • Calif. Office of emergency services (OES) • Certified unified program agencies (CUPAs) • Disclosure deadline moved to March, 2002

  10. Programs • Hazardous Waste • UC Hazardous Waste Action Group (HWAG) • Business Plan, EPCRA, SPCC, and Cal-ARP Program • UC Environmental Managers

  11. Environmental Programs • Checklist of Questions Regarding: • Business Plan • EPCRA • SPCC • Cal-ARP • Self Disclosure Report – Written Narrative

  12. Hazardous Waste Audit • Single Page Audit Sheet • Satellite Accumulation Area • 1 Sheet/Room • Letter Code for Violations Found • Separate Audit Sheet for Universal Wastes or Special Waste

  13. UNIVERSITY OF CALIFORNIA SATELLITE ACCUMULATION AUDIT SUMMARYPAGE ______ OF ______ CAMPUS: ___________ SITE: ______________________________ BUILDING/ROOM NUMBER: ________________________________ AUDITOR: _____________________________ AUDIT DATE: _________________ FACILITY TYPE: ______________ PI/SUPERVISOR: _________________________________________ DEPARTMENT: _____________________________________________ NO. OF CONTAINERS AUDITED: _____ NO. OF CONTAINERS WITH VIOLATIONS: ____ CHP/HAZCOM TRAINING: Y OR N Q/C Date: _________________ Data Entry Date: __________________

  14. UC Universal Waste Satellite Accumulation Area/Facilities Audit Supplemental Sheet Campus: __________ Site: ____________________________ Building/Room Number: _______________________________ Auditor: _____________________________ Audit Date: _________________ Facility Type: _________________ PI/Supervisor/Responsible Party: _____________________________________ Department: ____________________________ Number of Containers Audited: ______ Number of Containers with Violations: _____ Training Violation: UW SW Q/C Date: _____________ Data Entry Date: _______________

  15. Training of Auditors I.e., people! • Lack of EH&S Resources • Facilities Management Personnel Used By Some Campuses • One Day Trainings – October 2001 • Dry Run @ UCSF – 10 Attendees • Northern California – 46 Attendees • Southern California – 66 Attendees

  16. Auditor Training • Audits Done Consistently • Very Basic Hazardous Waste Management • How to Complete the Audit Form • Ensure Violations Corrected ASAP • Interactive Training • How to Deal with Laboratory Personnel • How to Complete the Audit Form

  17. Hazardous Waste Self Audits • Mid-October to December, 2001 • First Week – Daily Meeting with Auditors • Ensure Violations Corrected ASAP • QA/QC Audit Sheets Prior to Data Entry

  18. Agricultural Operations Art Studios Athletic Departments Clinical Facilities Construction Sites Department Shops Facilities Management Laboratories Photo Processing Areas Printing & Reproduction Power Plant Waste Accumulation Areas Areas Audited

  19. Hazardous Waste Audit Database • UCSF IT Personnel Worked with HWAG • Designed a Webpage Data Entry Program • Check Box/Pull Down/Select Items • From Data Entry Could Generate • Waste Codes • State & Federal Regulations for Violations • Data Entry – QA/QC Added to Program

  20. Audit information is entered on this page and the next. OK will take you to the second audit information page, Cancel will return you to the previous page. On the second Audit Information page you will select the building where the audit occurred. The list of buildings is determined by the site you select on this page Add a new site to the list by selecting the Add Site link.

  21. Compliance Incentive Project Report (Office of the President) • Introduction Written By UCOP • Each Campus Wrote Their Own Report • Root Causes • Individual Campus Corrective Measures • March 2002: Met with EPA, DTSC & CUPA • Oral Presentation on What Was Done • Reports Provided to US EPA & DTSC • Copies of Reports Later Mailed to CUPAs Certified Unified Program Agency

  22. Status of Compliance Incentive Project • August, 2002 – US EPA Letter Requesting • Clarification of Certain Violations/Abatement • Status of Implementation of Corrective Measures • March, 2003 Call from US EPA • Clarification of Waste Codes • Clarification on Abatement of Violations

  23. Issues/Lessons Learned Definition of OK label….? • 80% Violations- Labeling • Facilities Management - Large Number of Violations for Certain Campuses • $1.2 Million (16,000 Hours @ $75/Hour) • Disclosure Policy • Every Container • Repeat Violation • Dual Jurisdiction

  24. UCSF Corrective Measures • Waste Tag Poster • Training • Biennial • On-Line • Facilities Management (FM) • Letters to Department Chair • Quarterly Audit of FM Areas • Deficiency Form All Sat Accum Areas Waste Tech employees fill out

  25. Questions???

  26. Postscript • “Performance Track” -- public/private partnership recognizing top environmental performance and leadership among participating U.S. facilities of all types, sizes, and complexity, public and private. Washington State U. is a participant.http://www.epa.gov/performancetrack/ • EPA activity in Region 5. http://www.environ.com/news/newsissue.asp?record=317

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