Agency and University Partner in Campus EMS Development

Agency and University Partner in Campus EMS Development

Origination-Hazardous Waste Enforcement Case

• Hazardous waste compliance assistance inspections targeted at universities in 1997

• Non-compliance items found and corrective actions recommended, with re-inspection noted

• Second hazardous waste inspection conducted in 2000 revealed similar potential Small Quantity Generator violations

Potential Violations Repeated

• Waste determinations needed on potentially hazardous wastes both from facility and contractor operations

• Waste accumulation containers were not dated, labeled or closed

• Satellite containers were not marked or labeled with content identification or kept closed

Other Repeating Violations

• Certain department personnel lacked current training

• Potential incidental releases of wastes were observed due either to maintenance or operational problems, or to failing or open containers

• Unplanned waste generation could bump university to a LQG without intervention

Waste Accumulation-Examples

• Uncontrolled/unidentified paint materials left unannounced by outside contractor

• Lead/acid batteries for reclamation on pallets but exposed to elements

• Facility paint waste accumulating without a hazardous waste determination

Multiple and Varied Waste Sources-Colleges

Multiple and Varied Waste Sources-Specialized

Multiple and Varied Waste Sources-Services

Independent and/or Temporary Generators

• Professors

• Students

• Supervisors

• Managers

• Operators

• Contractors

Diverse and/or Intermittent Operations

• Teaching

• Research

• Productions

• Performances

• Services

• Construction

• Maintenance

Examples of Waste Sources

• Teaching laboratories• Research laboratories• Contractor sites• Vehicle maintenance

shop• Maintenance activities

• Painting operations• Grounds-keeping• Student Health Center• Printing operations• Janitorial operations

Examples of Waste Types

• Laboratory chemicals• Construction/demoli-

tion materials• Maintenance wastes• Printing chemicals

• Paint wastes• Solvent wastes• Biomedical waste• Radioactive waste

Existing Waste Management System

• UCF EH&S staff becoming increasingly proficient at tracking, monitoring and managing wastes

• Personnel and operations generating wastes change with student population, research projects, new activities, service contracts, construction and expansion

Waste Management System-Continued

• EH&S staff not always able to detect and manage problematic situations

• Campus is a community with many diverse entities, functions and needs

• Management structure is matrix type with with different lines of authority to the top level

Waste Management System-Continued

• EH&S staff not fully empowered to direct and manage emerging waste issues

• Potential waste generators not always predictable, informed and accountable

Role of the EMS in Enforcement Negotiation

• FDEP offers EMSs in settlement agreements as a means of offsetting civil penalties, fostering sustained compliance and promoting pollution prevention

• FDEP began encouraging use of EMSs over recent years without really understanding their nature and benefits

EMS Regulatory Tool Role-Continued

• FDEP role in evaluating an EMS not defined

• EMS has unclear role in regulatory arena

• Personnel not all familiar with EMSs

• No current unilateral basis for recognizing and using EMS in our dealings with regulated entities

FDEP and UCF EMS

• Negotiated as a Supplemental Environmental Project (SEP) to offset a portion of monies collected in a consent order

• UCF agreed to implement a campus-wide EMS with a relatively small amount of money allotted

• FDEP hoping to gain enhanced compliance

UCF EMS Goal

• UCF expected to implement a comprehensive EMS to consist of a systematic, periodic, and objective program to detect and correct violations by:

UCF EMS Obligations

• Informing employees and agents through standards, policies and procedures;

• Assigning specific responsibilities for ensuring compliance throughout organization;

• Instituting a means for employees and agents to report violations without fear of retaliation.

UCF EMS Function

• UCF’s EMS anticipated to include provisions for:

UCF EMS Components

• Procedure for periodic review, evaluation and monitoring of the system;

• Incentives to encourage all affected employees to perform in accordance with environmental requirements;

• Appropriate disciplinary mechanisms for failure to perform.

UCF EMS Responsibility and Accountability

• UCF to designate individuals responsible for implementing the EMS who are empowered to adequately address all functional areas impacting environmental issues

• Approved EMS Plan to be distributed to all Department Chairs and Directors

UCF EMS Reporting

• UCF to submit Final Report detailing EMS implementation and including the following:

UCF EMS Reporting Requirements

• Description of the methods used to quantify wastes;

• Expense report, receipts and other cost itemization information documenting development and implementation expenditures.

FDEP’s Role

• FDEP to review initial plan submitted and monthly progress reports

• FDEP Pollution Prevention liaison serves as a non-regulatory/compliance assistance EMS Committee team member

• Liaison negotiates EMS terms and issues between hazardous waste regulatory and university peers

FDEP P2 Staff as Liaison

• FDEP P2 staff member participates in EMS exercise to learn how the system works

• Enables FDEP to interact as an equal on the team and provide insight and input in a non-regulatory manner

• Provides FDEP staff experience with which to educate the agency and the public

Sustainable Campus for Future Students

• Our mutual mission

• To showcase our local state campus as a leader in environmental sustainability

• For our future students like this budding young scholar