Surviving the EPA Multimedia Audit for Colleges and

Universities

Robin M. Izzo

Assistant Director for Lab Safety

Princeton University

Presenting Points

• The Announcement

• Preparation

• The Audit, Part I

• The Audit, Part II

• The Audit, Part III

• The Aftermath

• Best Practices

The Announcement

• Happy New Year!– Letter to college and university presidents

• Environmental Advisory Committee– EHS– Facilities– Legal– University Research Board– Treasurer– Senior VP– Risk Management

Preparing for the Audit

• University EHS Audit Experiences

• Web Information

• EPA Meetings– Region 3– Region 2

Preparing for the Audit

• Internal Audit– Led by Environmental Advisory Team

• Princeton Plasma Physics Lab– Federal facility multimedia audit 1999

• External Audit

Preparing for the Audit

• Legal Interpretations– Training – Accumulation Date– Waste Determination

• Fines

• Environmental Accomplishments

• Inspection Strategy

Preparing for the Audit

• Outreach– Faculty meetings– Lab group meetings– The Waste Paper– Continued Vigilance Inspections– Training Audit– Letter from President– Communications Plan

Preparing for the Audit

• Faculty/Group Meetings– Review compliance issues

» Storage, packaging, labeling» Include potential fines

– Preparation» Self-audit» Prompt disposal» Training» Emergencies» Pollution Prevention

Preparing for the Audit

• Faculty/Group Meetings– Conduct during inspections

» Inspector must be accompanied by EHS

» Don’t argue with the inspectors

» Don’t complain about the regulations

» Don’t be evasive

» Don’t lie to the inspectors

» Don’t engage in speculation

» If a problem is found, correct it immediately

The Audit: Part I

• June 25, 2001

• Unannounced arrival at Facilities

• Opening conference– Schedule – unable to change

• Total of 7 inspectors

• 3 full days

• Everything except RCRA (waste)!

Part I, Day 1

• Underground Storage Tanks– Brought NJDEP inventory– Reviewed permits– Reviewed inspection records– Looked at systems– Interviewed users – Minor problems noted

» No environmental impairment

Part I, Day 1

• Air Emissions– Title V Permit– Interviewed Environmental Compliance

Manager– Cogen Plant

» Continuous emission monitoring» Log books of daily maximum heat output of boilers» Rolling day average calculations of fuel burning» CFC repairs and equipment

– No problems noted

Part I, Day 2

• PCBs (TSCA)– Uses of PCBs in research– PCB annual summaries, last 3 years

» Did not like format of our report

» Completed 2000 report in recommended format

– Visited vault– Waste manifests and certificates of destruction

Part I, Day 2

• PCB Documentation Requested– List of PCB transformers disposed or retrofilled

» Name, serial number, disposal date, electrical rating, amount of fluid

– Copies of manifests for the disposed transformers

– Current list of all oil-filled transformers» Name, serial number, electrical rating, amount of

fluid

Part I, Day 2

• Underground Injection Control– Federal regulation to protect underground

sources of drinking water pertains to » “bored, drilled or driven shaft or dug hole, where the

depth is greater than the largest surface dimension, that is used to discharge fluids underground”

– Region 2 interpretations include floor drains, sink drains, sumps, etc.

» Conveying fluid to a septic tank, drywell, etc.

Part I, Day 2

• UIC Documentation requested– Maps or other evidence showing where all drains

discharge

– Sewer permits

– Right to Know Survey and R&D Exemption

– Invoices from chemical waste contractor

– Drain disposal policy

– Full chemical inventory (satisfied with summary)

– Open groundwater cases

Part I, Day 2

• UIC Site Visit– Originally every building– Bookbinding operation– Mechanical room– Lab, preferably with chem, rad and bio waste– Environmental chemicals storage (pesticides)– Art studio– Vehicle maintenance shop– Car wash area– Maintenance shop– Paint shop– Cogen/Chilled Water Plants

Part I, Day 3

• UIC Prep– Pulled together documentation related to drain paths– Placed removable plugs in all floor drains in labs and

areas where chemicals are stored– “No Chemical Storage” signs

• UIC– Most time-consuming part of audit and overlapped PCB– Outcome

» No evidence of UIC» Post dry wells with “Rainwater Only” signs

Part I, Day 3

• EPCRA/Risk Management Plan– Requested copy of EPCRA inventories– Asked about use of chlorine or ammonia

outside research lab– Confirmed no Risk Management Plan needed– No site visit– No problems noted

Part I, Day 3

• SPCC Plans– Requested copy of plan for review– Visited

» Fuel filling areas» Detention basins» Cogen plant – substations, etc.» Storm drain discharge into lake

– Warned to expect numerous comments, but unlikely to receive fines if fixed

» None, completely inadequate or fair

Closeout

• Closing conference with lead inspector– Considered end of

“multi-media audit”

• Expect letter in 3-4 weeks

• Received letter one month later

The Audit, Part II

• December 4, 2001

• Unannounced EPA audit – RCRA only

• Classes not in session in June

• 4 inspectors, 3 days, 2-3 teams

• Planned on EVERY lab and chemical use area

RCRA Audit

• Inspectors were prepared– Copy of our Lab Safety Manual

– Hazardous Waste information from EHS web site

– EPA ID numbers for all entities with “Princeton” in name

– Campus maps

• Started immediately– Two teams accompanied by 1-2 EHS staff

RCRA Inspection

• Princeton University Research– >500 labs– >100 PIs– 10 science and engineering departments

• Visited at least one lab for each PI, usually all labs

• Visited all three 90-day storage areas

RCRA Audit

• Lab Audits– Interviewed lab occupants – students, faculty,

etc.» Emergency response

» Most hazardous materials

» How to dispose of waste

» What goes down the drain

– Physical inspection

RCRA Audit

• Other areas visited– Visual Arts department– Maintenance shops– University Health Services– All campus darkrooms– Print Shop– Cogen Plant– Fluorescent bulb recycling

RCRA Audit

• Records Reviewed– All manifests from 1998 – 2001– 1999 Biennial Report – Contingency Plans for 90-day storage areas– Job descriptions of people involved in program– Training outlines/attendance records for EHS, 90-day storage

area staff and chemical users– Letters to emergency responders and local hospital– Summary of chemical waste program– Pollution Prevention/Waste Minimization Goals– Training manuals for lab workers, chemical workers and Visual

Arts faculty, staff and students

Audit Part II - Closeout

• Closing Conference• Findings

– No environmental impairment

– Minor issues – very much “the exception, not the rule”

– Closeout letter received one month later

» No fines

Audit Part III

• July 11, 2002

• Follow-up PCB Inspection– Two inspectors from June 2001 audit– Review of records – an administrator

recommended violations/fines– Reviewed most of the same records, plus latest

annual report– Minor violations and fine

The Aftermath

• All involved have better understanding of comprehensive environmental program

• Raised awareness of EHS issues in general

• Troublesome groups have developed better habits

• Continued vigilance – DEP inspections

The Aftermath

• The Decision Not to Self-Disclose– EPA noted issues that other auditors had not – Increased credibility of our program– Timing– Negative Press

» “Previous complaints with penalties totaling more than $1.5 million have been filed over the past fifteen months against Pratt Institute, Manhattan College, Princeton University, Columbia University, Long Island University's Brooklyn campus, New Jersey City University and Raritan Valley Community College.”

Best Practices

• Visual Arts training program and guide• Lab Safety Training Guide• Hazardous Waste Information on the web• The Waste Paper• Waste posters• Funnel caps• Written Hazardous Waste Disposal Program • Secondary Containment

Visual Arts Training

• Annual training required for all faculty, staff and students – General and specific

information

– Quiz

• Mostly adjunct faculty, changes yearly

Did Van Gogh Die for His Art?

The Waste Paper

• Monthly newsletter

• Announces next pickup

• Articles

• Waste minimization

• Pet Peeves

• Contacts

Waste Posters

• Simple instructions– Packaging– Storing– Labeling– Disposing

• Holder for waste labels

Waste Posters

• Waste Stream Coding

Funnel Caps

• Nalgene

Secondary Containment

• Sink covers

• Plastic bins

• Party tubs

Questions?