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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 - PowerPoint PPT Presentation
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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