Negotiating the Regulatory
Map: An Outline Approach for College and University Training
I. New
Awareness for Colleges and Universities
Colleges and universities are on the leading edge of
research and teaching discoveries and methodologies, bringing only the best to
students. However, in today’s world of increasing environmental awareness and
protection efforts, more and more regulations affect the operational costs of
higher learning institutes. Universities and colleges have become more aware of
the impacts associated with environmental regulations that apply to their
schools’ activities, and the cost of compliance with these regulations must be included
in their budgets and operating expenses.
Chemistry and biology lab materials and wastes, motor
pool support services, and building maintenance operations are regulated by
environmental laws that, until recently, received little attention from
regulatory agencies or schools. But that scenario has changed, and college and
university operations are now closely scrutinized by environmental
agencies. The cost of environmental
non-compliance can amount to hundreds of thousands of dollars; schools must
deal with environmental regulations proactively in order to avoid costly fines
and negative publicity.
In response to EPA’s recent inspection focus on them,
many colleges and universities have undertaken aggressive programs to come into
compliance and stay ahead of environmental regulations. The following outline
was designed as a map for schools to determine which regulations apply to their
operations. It is organized by specific activity in order to facilitate
understanding of compliance obligations. This outline does not provide details
of compliance responsibilities but should be used to identify activities that
may be associated with a specific regulation. The organization can then
systematically examine each operation in further detail to determine its state
of compliance.
II. The
Regulatory Picture
Many activities are associated with environmental regulations:
research and student laboratory work, daily operations, maintenance activities,
and utility operations to support all of these activities. Environmental
regulations are mandated to protect human health and the environment and
include laws to protect the air, water, and soils, and the well-being of the
community.
CAA
The Clean Air Act (CAA) and its 1990 amendments
regulate emissions to the atmosphere and spills and leaks of regulated toxic
substances such as hazardous gases and volatile liquids. Air permits are
required for specific activities that emit pollutants into the air above
certain thresholds. Pollutants from boiler operations, emergency power
generators, solvent cleaning, and painting operations are only a few of the
emissions that may be regulated by the CAA at colleges and universities. The
1990 amendments also regulate potentially harmful air releases by requiring
risk management plans (RMPs) to reduce or eliminate potential threats to public
health and the environment from toxic, reactive, flammable, and/or volatile
chemicals. RMPs also dictate certain safety measures for any quantity of
chemical if it is on the regulated toxic substances (RTS) list under a “general
duty” clause, which affects any area where these chemicals are stored or used
on campus.
CWA
The Clean Water Act (CWA) mandates protection of surface
water from contaminants generated by point and non-point source discharges. Point
sources come from an identifiable conveyance, such as a pipe or drain line. Non-point
sources come from stormwater conveyances or other unpiped drainages. Some CWA
requirements are specific for certain industries, as in “categorical” regulations,
or may be specific to certain contaminants such as oil storage and spills (spill
prevention control and countermeasures (SPCC)), or may control contaminates
according to the final destination of the wastewater or storm water runoff, as
in National Pollutant Discharge Elimination System, or NPDES permits. Water
regulations can also be very specific to location, such as publicly owned
treatment works (POTWs), and are based on concentrations of contaminants
irregardless of origin such as discharge limits for grease and total dissolved
solids, ammonia, or metals.
RCRA
The Resource Conservation and Recovery Act and the
Hazardous and Solid Waste Amendments regulate disposal of solid wastes and
underground storage tanks, and require companies to reduce wastes and conserve
natural resources. This regulation probably affects more campus operations than
any other, because of the wastes produced by colleges and universities. Storage
requirements, transportation, and final disposal processes and facilities of
all hazardous wastes are highly regulated to prevent environmental
contamination. Pollution prevention measures can be used to reduce or eliminate
waste at the source of generation and can be used by schools to meet the RCRA
requirement for companies to reduce wastes, and in many instances can reduce
regulatory responsibilities with other environmental regulations.
The regulations mentioned above are by no means the
only ones that can apply to schools. In addition, the following regulations
affect specific materials or wastes used or generated by campuses:
·
The
Toxic Substance Control Act (TSCA) tracks chemicals made or imported in the
United States and can allow the federal Environmental Protection Agency (EPA)
to control the production and distribution of new or existing chemicals, establish
specific disposal rules; and ban or control use of high-risk chemicals such as
PCBs, asbestos, lead, and biotechnology.
·
The
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) provides regulatory
oversight to protect consumers, applicators, and the environment from
pesticide-related hazards or harm. This includes personnel training for
applying pesticides, managing waste pesticides, and handling pesticide
containers and residues.
·
The
Safe Drinking Water Act (SDWA) regulates the quality of drinking water to a
public water system, community water system, or public water system that serves
the same people between six and 12 months out of the year (non-transient,
non-community water systems). Schools that supply drinking water must meet
certain maximum contaminant levels for impurities in their water supply.
·
The
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
is also known as “Superfund” and regulates potential and actual spills of
hazardous substances, and allows the EPA to identify and hold accountable those
responsible for spills or releases of these substances. Liability for releases
is permanent and applies to all past practices such as disposal of hazardous
wastes at a treatment, storage, and disposal facility (TSDF).
·
The
Emergency Planning and Community Right-to-Know Act (EPCRA) requires public
reporting of storage, use, and releases (including disposal and recycling) of
hazardous and extremely hazardous materials at a facility if they are present
above certain quantities, known as threshold planning quantities (TPQs), or if
they are spilled or released above a reportable quantity (RQ). It also requires
emergency response notification and planning with local emergency planning
committees (LEPC) and state emergency response commissions to control spills or
releases and their impact on local communities.
Resources providing more in-depth details for each of
the above regulations are provided at the end of this document for users to
research their compliance requirements. Technical assistance with regulations
and pollution prevention opportunities is also available from the Kansas Small
Business Environmental Assistance Program through the confidential
environmental hotline at 800-578-8898 or the onsite assessment program for
“hands-on” assistance.
III. Pollution
Prevention (P2)
P2 can be used by colleges and universities to reduce
the amount of wastes generated by their operations and to reduce their
regulatory responsibilities. P2 may involve changes in work practices,
substitution of less hazardous materials, or use of new technologies that reduce
or eliminate wastes. The regulatory outline provides resources for common P2
practices for each of the activities.
The outline is organized in a table format by
activity, regulation, and P2 resources; each activity listed may involve
several environmental regulations. In some instances, an example of a relevant
regulatory issue is provided to clarify regulatory involvement. Worker health
and safety standards are not covered by this outline.
There are many P2 resources available for college and
university operations on the internet. For more information visit the following
sites:
Environmental Virtual Campus: http://www.c2e2.org/evc/home.html
College Guide to Campus Wide Composting: http://www.projectcompost.ucdavis.edu/Compost_Guide.pdf
Facilities Design and Management: http://www.p2rx.org/P2InfoNexpert/Facilities.cfm
EPA Regulations
that Affect College and University Activities
Activities |
Possible regulatory involvement |
P2 practices |
|
Science
and research labs |
CERCLA(spills
and liability), EPCRA(storage quantities and spills of reportable quantities),
RCRA(hazardous wastes and storage compatibility issues), CWA(sewer
discharges, spills, and leaks), TSCA(biotechnology), possible CAA(air toxics,
ozone depleting compounds, general duty for safety measures) |
Microscale
chemistry: http://campus.umr.edu/ehs/Hazardous_Waste_Mgmt/Waste_Minimization_Program/wmmicro.html Laboratory
waste minimization and P2: http://www.seattle.battelle.org/services/e&s/P2LabMan/ Inventory
control: http://www.sbeap.org/ppi/publications/inventory_control_checklist_replace.PDF |
|
Grounds
maintenance |
CERCLA(spills
and leaks), EPCRA(material storage and reportable quantities), RCRA(haz
waste, fuel storage, used oil), CWA(SPCC, storm water runoff),
FIFRA(applicator’s license), CAA(small engine emission standards),
TSCA(possible asbestos, lead-based paint, PCBs) |
Integrated
pest management: http://www.ipminstitute.org/ North
Central Pest Management Center: http://www.ncpmc.org/ College
Guide to Campus Wide Composting: http://www.projectcompost.ucdavis.edu/Compost_Guide.pdf Best
Management Practices for Grounds Maintenance: http://www.dfwstormwater.com/P2/PDF/P2ground_bmps.pdf |
|
Motor
pool/vehicle maintenance |
RCRA(solvent
wastes, fuel storage, used oil), CWA(SPCC, sewer discharges), EPCRA(flammable
storage), CAA(ozone-depleting compounds, air toxics, clean fleet requirements),
CERCLA(spills) |
P2
for Auto Repair: http://www.sbeap.org/ppi/publications/ppi_automanual.pdf Fleet
Maintenance: http://www.dfwstormwater.com/P2/PDF/P2fleet_bmps.pdf P2
for Auto Repair and Fleet Maintenance:
http://www.epa.gov/region09/p2/autofleet/ |
|
Health
center |
CWA(sewer
discharges), RCRA(medical waste), CAA(possible incineration permits),
CERCLA(spills and leaks) |
Hospitals
for a Healthy Environment: http://www.h2e-online.org/index.cfm Pollution
Solutions for Health Care Facilities:
http://outreach.missouri.edu/polsol/health.htm |
|
Agriculture |
CWA(confined-animal
feeding operations, wastewater and runoff discharges), FIFRA(pesticide
application/ residue handling), CERCLA, CAA(risk management plans for
chemical storage), EPCRA(chemical storage and use), RCRA(underground fuel
storage, waste disposal), SDWA(drinking water supply), TSCA(biotechnology) |
USDA
Conservation Choices guide: http://www.ctic.purdue.edu/Core4/CT/Choices/Choices.html Composting
dead livestock: a new solution to an old problem: http://www.exnet.iastate.edu/Publications/SA8.pdf National
Agriculture Compliance Assistance Center: Risk Management Program http://www.epa.gov/agriculture/trmp.html Farm-A-Syst
Home-A-Syst Drinking Water Protection:
http://www.uwex.edu/farmasyst/projects/drinkfront.html |
|
Veterinary
or medical schools |
CWA(sewer
discharges), FIFRA(pesticide applicator license), CERCLA(spills and leaks),
RCRA(X-ray fixer disposal, haz waste disposal), CAA(carcass, medical waste incinerators),TSCA(biotechnology)
|
Fact sheet on
Silver Recovery from Photographic and Imaging Wastes: http://www.p2pays.org/ref/05/04619.htm
Composting
dead livestock: a new solution to an old problem: http://www.exnet.iastate.edu/Publications/SA8.pdf |
|
Carpentry |
RCRA(solvent
waste, stain rags), CAA(possible air toxics), CWA(sewer use), CERCLA,
TSCA(asbestos, lead) |
Construction,
Demolition, and Rennovation–P2 Opportunities: http://www.epa.gov/fedsite/cd/p2debris.html Environmental
Yellow Pages: http://www.enviroyellowpages.com/listings/USA/KS/ |
|
Painting
|
RCRA(haz
waste disposal), CERCLA, CWA(sewer discharges), CAA(air emissions),
TSCA(lead-based paint) |
Pollution
Solutions Painting Operations: http://outreach.missouri.edu/polsol/paint.htm P2
Resources for the Painting and Coating Industry: http://www.epa.state.oh.us/opp/paints.html |
|
Swimming
pool |
CWA(pool
drainage), CAA(chlorine storage: risk management plans), CERCLA, EPCRA(chemical
storage and use), TSCA(asbestos on water lines) |
Guidelines for Swimming Pool and Spa Owners
and Operators: http://www.montgomerycountymd.gov/mc/services/dep/Enforcement/pools.htm
Fact
Sheet: Preventing Accidental Releases: Chlorine Gas: http://www.p2pays.org/ref/10/09959.htm
|
|
Residence
halls; child care facilities |
RCRA(universal
waste: fluorescent bulb disposal), CWA(sewer discharges, SPCC), CERCLA(spills
and leaks).TSCA(asbestos, lead-based paint, PCBs) |
Food
Waste Compost Program: http://www.recycle.umich.edu/grounds/recycle/food_composting.html A Summary of Solid Waste Services UNC at Chapel Hill: http://www.fac.unc.edu/WasteReduction/OWRR%20short%20presentation.pdf |
|
Machine
shops |
CWA(machine
coolant), RCRA(machine coolant disposal), CERCLA(spills and leaks), EPRCA(material
storage) |
Extending the Life of Metal Working Fluids: http://www.epa.state.oh.us/opp/metalw/fact11.html Metal Fabrication and Machining Topic Hub:
http://www.pprc.org/hubs/toc.cfm?hub=23&subsec=7&nav=7 |
|
Printing
shop |
RCRA(press-cleaning
solvent and rag disposal, photo fixer), CAA(air toxics), CWA(sewer
discharges), CERCLA(spills and leaks) |
Pollution
Prevention Institute Publications for Printers: http://www.sbeap.org/ppi/industry/printers.htm Printers'
National Environmental Assistance Center:
http://www.pneac.org/ |
|
Studio
arts |
RCRA(photo-fixer
disposal, haz waste), CERCLA, CWA(sewer discharges), CAA(air toxics) |
The
Crafts Report: The Dangers of Working with Glass are Clear: http://www.craftsreport.com/february01/studioissues.html
|
|
Power
plant |
CAA(boiler
emissions), CWA(SPCC: fuel storage, boiler blow-down discharge: POTW or
NPDES), RCRA(haz and solid waste, USTs), CERCLA(spills and leaks),
EPRCA(fuel, chemical storage), TSCA(asbestos insulation) |
P2
for Power Plant Systems: http://www.sbeap.org/ppi/publications/college_powerplant.pdf |
|
Cooling
tower operations |
CAA(MACT
for chromium corrosion protection), CWA(sewer/point source discharges),
RCRA(haz waste disposal), CERCLA(spills and leaks) |
P2
for Power Plant Systems: http://www.sbeap.org/ppi/publications/college_powerplant.pdf |
|
Construction
activities |
CWA(storm
water permit), CERCLA, EPCRA(fuel storages), RCRA(haz and solid waste
disposal), TSCA(asbestos |
Construction
site storm water runoff control:
http://cfpub.epa.gov/npdes/stormwater/menuofbmps/con_site.cfm |
IV. Environmental Management Systems for Colleges and Universities: A
Key to Success
In
light of EPA's coordinated enforcement and compliance-assistance efforts, it is
important to have a cost-effective strategy to respond to current and future
environmental issues. EPA's recent efforts, directed at improving the
compliance performance of colleges and universities, include both proactive
assistance and an aggressive enforcement, including unannounced inspections at
university campuses, many of which have resulted in significant fines and
unwelcome publicity.
The
most effective approach to improve overall environmental performance and avoid
enforcement penalties is as follows:
·
Conduct
third-party, multimedia compliance audits to identify areas of vulnerability
and to prepare for a pending EPA inspection.
·
Implement
programs to improve laboratory hazardous waste management programs and ensure
compliance.
·
Develop
and implement a framework for an environmental management system to sustain and
improve overall environmental compliance, a key element of EPA's college
initiative.
Third-party
audits are the most effective means to prepare for an EPA inspection by
identifying compliance issues and areas of vulnerability. In fact, these audits
can serve as a mock EPA inspection, as well as educate and create campus-wide
compliance awareness. As potential compliance issues are identified, auditors
can provide on-the-spot corrective actions and guidance on how to improve the
organization’s compliance program.
Although
environmental audits may focus on EPA’s priorities, they also provide a broader
assessment of compliance with applicable local, state, and federal
environmental agencies and OSHA that are likely to be important to an EPA
inspector.
EPA
inspectors target easy-to-identify violations and review documented evidence of
compliance.
The
outcome of an audit identifies and details areas of non-compliance requiring
attention. Finally, and perhaps most importantly, audits identify root causes
of compliance issues and provide recommendations and assistance for
implementing an effective environmental management system (EMS). An effective
EMS enables the college to sustain compliance in the future, as well as improve
the efficiency of its environmental programs. The EPA strongly supports EMS as
a compliance-assurance mechanism, and efforts to develop an EMS may be regarded
favorably during a regulatory agency inspection.
A well-designed EMS will help ensure long-term compliance
with complex EPA and state regulations. The EPA strongly supports these systems
as a compliance-assurance mechanism, and regards them favorably during a
regulatory agency inspection. With major organizational changes (such as new
buildings or equipment) and the ever-increasing myriad of environmental
regulations, the need for an effective EMS is critical.
An environmental management system (EMS) is a framework for
understanding an
organization’s “environmental footprint,” complying with
environmental regulations, and implementing proactive P2 strategies. An EMS is
not a checklist completed once a year to review compliance, a one-time project,
or a policy statement. An EMS involves a continuous cycle of planning, doing,
reviewing, and improving the processes and actions associated with an
organization’s responsible environmental management. A college or university
that invests in an EMS can realize many benefits to justify the cost of
developing it.
How does your school interact with the environment? The
fundamental purpose of the EMS is to control and reduce the environmental
impacts of your activities and procedures. For this reason, a very critical
element of the EMS involves identifying and prioritizing the environmental
aspects and impacts associated with your school. Using the concept of
identifying your “environmental footprint,” identifying an “aspect” is like
taking a picture of your foot, while determining the “impact” is comparable to evaluating the effect or “footprint” of
your step. An environmental aspect is
an element of an organization’s activities, products, or services that can
interact with the environment (ISO 14001 definition). Aspects may have
an impact defined as, “Any change to the environment…wholly or partially
resulting from an organization’s activities, products, or services,” (ISO
14001definition).
Aspect = Cause Impact = Effect
Examples of college and university activities, aspects, and
impacts are provided below.
|
Activity |
Aspect |
Impact |
|
Food Service |
Electricity Use |
Air Pollution |
|
|
Water Use |
Resource
Consumption (water, energy, food) |
|
|
Solid Waste |
Landfilling |
|
|
Food Waste |
Landfilling |
|
|
|
|
|
Grounds
Maintenance |
Fuel Use |
Air Pollution |
|
|
Pesticide/Fertilizer
Use |
Pollutant
Runoff |
|
|
Green Waste |
Compost |
Assessing environmental aspects and impacts on a college or
university campus can be particularly difficult. The organizational structure
of the many school departments and support operations involved in the EMS can
make identification and prioritization of environmental aspects and impacts a challenging
task. Also, because colleges and universities operate much like a small
community, a wide variety of activities exist, each with its own set of aspects
and impacts. While it is important to accurately identify environmental aspects
and impacts, it can be easy to get caught up in the evaluation process and
delay progress. It may be easier to
start the EMS with one department. The following questions should be considered
when identifying aspects and impacts:
|
Identifying Aspects |
Evaluating Impacts |
|
Which
activities and services interface with the
environment in a way that could result (or has
resulted) in environmental impacts? |
Are the impacts
actual or potential? |
|
What materials,
energy sources, and other resources are used in regular operations? |
Are the impacts
beneficial or damaging to the environment? |
|
What are the
primary sources of emissions to the air, water, or land? |
What is the
magnitude or degree of these impacts? |
|
What are the
primary types of waste produced? What
are the primary sources associated with
each waste? Does the treatment or
disposal of these wastes have potential environmental impacts? |
What are the
frequency or likelihood of these impacts? |
|
How does our
land or infrastructure (such as buildings
and campus grounds) interact with the environment? |
What is the
duration and geographic area of these impacts? |
|
Which
activities (for example, chemical or fuel storage)
might lead to accidental releases? |
Which parts of
the environment might be affected
(for example, air, water , land, flora, or fauna)? |
|
|
Is the impact
regulated in some manner? |
|
|
Have parties
internal or external to the school
expressed concerns about these impacts? |
V. Getting Started with an EMS
1. Obtain top-level commitment. An EMS without commitment from the highest level of the
administration is like a car without a driver – it may run but not very far.
Successful EMSs are characterized by top-level commitment supported with
directives, actions, and necessary financial resources.
2. Identify an EMS manager
responsible for coordinating the EMS effort. The EMS manager should form an EMS team with other personnel
familiar with the institution’s operations, material use, and waste management
procedures. At least one person on the EMS team should have good spreadsheet
skills (for example, Microsoft Excel) to track EMS performance metrics.
3. Identify and discuss
important EMS features. EMSs are as
unique as the colleges and universities that create and implement them. The EMS
team should meet to identify important EMS features that will guide the
creation and implementation efforts. Several examples are provided below.
a. Continual
Improvement. An EMS should feature continual improvement through "plan-do-check-act"
strategies that lead to more efficient EMS implementation and better
environmental performance.
b. Compliance. An EMS should, at
a minimum, incorporate a systematic approach to maintaining compliance. For colleges
and universities with prior regulatory issues, compliance may be the primary
concern for developing an EMS. In any case, colleges and universities should
strive to move towards meeting and exceeding compliance obligations.
c. Emphasis on
Pollution Prevention. When developing options for achieving objectives
and targets to address those aspects associated with environmental impacts,
action plans should include P2 measures as much as possible.
d. Results-Oriented. Although colleges
and universities will create detailed documentation during the EMS
implementation phase, the focus of the EMS should be on achieving results that
are measurable or demonstrate specific environmental performance improvements.
4. Communicate
the EMS initiative to faculty and staff and invite input. Faculty, students, and staff should be aware of the EMS
implementation effort, its purpose and elements, and what their roles will be
in achieving targeted environmental performance objectives.
5. Conduct a preliminary
review or gap analysis. A gap analysis should be performed to identify current
environmental management practices that can "evolve" into EMS
elements and missing EMS elements. Consider using the Campus Consortium for
Environmental Excellence (C2E2) EMS Self-Assessment Checklist to perform the
gap analysis for your institution. In addition to the gap analysis, consider
benchmarking your EMS plans by working with other colleges and universities.
6. Determine the scope
for the EMS. Every college and university will have
unique circumstances that dictate the extent and focus of its EMS. After
completing the gap analysis, the EMS team should step back and evaluate the
institution’s environmental status and make decisions regarding the scope of
the EMS and how best to implement the initiative. The EMS team should consider
issues such as the following:
a. Should the EMS
cover both environment and health and safety issues?
b. Does the ISO
14001 EMS model “fit” our college or university?
c. Do we need to
tackle the whole school at once, or build on small successes with selected departments and targeted activities?
7. Begin implementing
guide elements. Steps 1 through 5 lay the foundation for
actions to construct the EMS. The college and university EMS implementation guide
contains the minimum elements needed for a functioning EMS. Creating and
implementing an EMS is a challenging endeavor. Although some colleges and
universities may choose to implement all elements of the guide as part of a
single effort, experience implementing EMSs at other types of organizations
suggests that momentum can be gained by implementing the following EMS elements
first:
a. Develop an environmental
policy for the school.
b. Identify and
document environmental aspects and impacts.
c. Identify state of
compliance.
d. Set objectives
and identify targets.
e. Assign roles and responsibilities.
f. Establish an
effective communication system.
g. Establish a training
program.
h. Document measurement
and monitoring.
Full implementation of the above elements typically requires six
to nine months. The remaining elements can then be implemented gradually over
the following 12 months. The implementation tips presented below should get EMS
implementation efforts off to an efficient start.
EMS Implementation Tips:
·
Avoid "reinventing" procedures for the EMS. Leverage
components of other management systems and programs for example, adapt existing
training programs to include environmental training or model EMS documentation
and document control procedures on document control used for other operations.
·
Address priority areas first. Although seemingly obvious, EMSs
often stall after the organization expends a significant amount of effort
cataloguing all its environmental aspects. Instead, select a few top priority
aspects then create and execute an action plan to mitigate those aspects. This will
achieve results quicker and allow the EMS team to build on successes to establish
the momentum vital to the EMS effort.
·
Set reasonable goals. Develop goals that are “do-able” within
12 months, and make sure that several are achievable within six months; build
momentum for your EMS and avoid setting over-ambitious goals that may frustrate
or stall EMS participants.
·
Communicate. Communication cannot be overemphasized: publicize
efforts, announce successes, build support, and keep administrators involved.
·
Get help. College- and university-specific and general EMS
assistance can be obtained from a variety of organizations and documents
including the following:
o
U.S. EPA New England (Region I) Colleges and Universities Home
Page http://www.epa.gov/ne/assistance/univ/index.html
o
Environmental Management Systems: An Implementation Guide for
Small and Medium-Sized Organizations, Second Edition, NSF International, 2001. http://www.nsf-isr.com/info/articles.html
o
Integrated Environmental Management Systems: Implementation Guide,
EPA 744-R-00-011, 2000 http://www.epa.gov/opptintr/dfe/tools/iemsguide.htm
o
Campus Consortium for Environmental Excellence (C2E2) EMS
Self-Assessment Checklist, 2000. http://esf.uvm.edu/c2e2
o
University of Massachusetts Lowell EMS Service Program; contact Matthew_Donahue@uml.edu
VI. Persistent, Bioaccumulative, and Toxics
(PBT) in College and University Operations
Persistent,
bioaccumulative toxic pollutants (PBTs) are highly toxic, long-lasting
substances which can build up in the food chain to levels that are harmful to
human health and cause environmental harm. These contaminants can be
transported long distances and move readily from land to air and water.
The
Environmental Protection Agency’s (EPA) Waste Minimization Program has drafted
a strategy to reduce 53 PBTs in RCRA-regulated waste through voluntary measures
employing P2. The focus of this initiative will be on reducing toxicity of
hazardous wastes, rather than merely the volume. The goal is a 10 percent cut
in PBTs found in RCRA-regulated waste by 2001 and a 50 percent cut by 2005, as
measured by TRI reports.
Targeted PBTs in the Draft RCRA List
|
||||||||||||||||||||||||||||||||||||||||||
Colleges and
universities can help to reduce the amounts of PBTs used on campus by inventory
tracking and MSDS approval programs to reduce or eliminate chemicals containing
any of the materials listed above. Schools may wish to prioritize their PBT
reduction efforts by targeting the following operations or departments:
·
health care
centers: mercury-containing instruments
·
veterinary and
medical schools: mercury-containing instruments
·
art projects:
heavy metals in colorants for glass making, dyes, paint pigments
·
chemistry and
other laboratory work: any of the above chemicals may be involved in
specialized research and possibly student lab experiments
·
power house
operations: chromium and copper metal species may be used in corrosion protection
and as biocides in water treatment processes
·
motor pool and
grounds maintenance: small engine repair, wood finishing, painting operation:
chlorination solvents
·
ground
maintenance and agricultural studies: pesticides
PBT Resources:
·
Persistent Bioaccumulative and Toxic (PBT) Chemical Program: http://www.epa.gov/opptintr/pbt/
·
Washington’s
Mercury Chemical Action Plan: http://www.ecy.wa.gov/programs/eap/pbt/mercuryplan.html
·
EPA’s Priority
PBT Profiles: http://www.epa.gov/pbt/cheminfo.htm
VII.
Regulatory Resources
Common violations at colleges and universities: http://www.epa.gov/ne/assistance/univ/index.html
Clean Air Act (CAA)
·
What
Is the Clean Air Act About? http://www.epa.gov/oar/oaqps/peg_caa/pegcaain.html
·
Air
pollution control: http://www.epa.gov/oar/oaqps/greenbk/index.html
·
Clean
Air Act rules by state: http://www.epa.gov/ttn/atw/stprogs.html
·
Emissions
calculations: http://www.epa.gov/ttn/chief/ap42/ch01
·
Risk
Management Program Implementation: http://www.eqe.com/procsafety/120.htm
·
Risk
Management Plans: more information http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/index.html
Clean Water Act (CWA)
·
EPA
Office of Waste Water Management:: http://www.epa.gov/owm/
·
National
Pretreatment Program: http://cfpub.epa.gov/npdes/home.cfm?program_id=3
·
The
National Pollutant Discharge Elimination System (NPDES): http://cfpub.epa.gov/npdes/
·
EPA
Storm Water Program: http://cfpub.epa.gov/npdes/home.cfm?program_id=6
·
New
Spill Prevention Control and Countermeasure Rules: http://www.uaienvironmental.com/pdf/NEW_SPCC_RULE.pdf
·
NFESC
Spill Prevention Guidance Manual: http://enviro.nfesc.navy.mil/ps/spillprev/
·
Effluent
guidelines: http://www.epa.gov/OST/guide
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA)
·
What
Are CERCLA and the Superfund? http://www.epa.gov/superfund/action/law/cercla.htm
Emergency Planning and Community Right-to-Know
(EPCRA)
·
EPA’s
EPCRA page: http://yosemite.epa.gov/oswer/CeppoWeb.nsf/content/epcraOverview.htm
·
List
of CERCLA hazardous substances: http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_40/40cfr302_00.html
·
EPRCRA
List of Lists: http://130.11.53.73/lol/
·
National
Response Center: http://www.nrc.uscg.mil/nrchp.html
Resource Conservation and Recovery Act (RCRA)
·
RCRA
Orientation Manual: http://www.epa.gov/epaoswer/general/orientat/
·
Kansas
RCRA Notification Form: http://www.kdhe.state.ks.us/waste/apps-hw/notify.pdf
·
EPA’s
Environmental Management Guide for Small Laboratories: http://www.epa.gov/sbo/labguide.htm http://www.epa.gov/sbo/smalllabguide_500.pdf
·
What
Is Waste Minimization? http://www.epa.gov/wastemin http://gcisolutions.com/HWFN0993.htm
·
Hazardous
Waste Requirements for Large Quantity Generators: http://www.epa.gov/epaoswer/hazwaste/gener/lqgpdf.pdf
·
What
Is Pollution Prevention? http://www.epa.gov/opptintr/p2home/
·
National
Pollution Prevention Roundtable: http://www.p2.org/
·
Pollution
Prevention Resource Exchange: http://www.p2rx.org/
·
“Musts
for USTs”: Requirements for Underground Storage Tanks http://www.epa.gov/swerust1/pubs/musts.pdf
·
KDHE’s technical guidance documents for hazardous and solid wastes: http://www.kdhe.state.ks.us/waste/bwm_tech_guide.html
Safe Drinking Water Act (SDWA)
·
EPA’s
public drinking water systems programs:
http://www.epa.gov/safewater/pws/pwss.html
·
EPA’s
Office of Water: http://www.epa.gov/safewater
·
The
Underground Injection Control (UIC) Program:
http://www.epa.gov/safewater/uic.html
·
Class
V Injection Well Rules: http://www.epa.gov/safewater/uic/c5imp.html
Toxic Substances Control Act (TSCA)
·
Detailed
Summary of TSCA: http://www.cnie.org/nle/leg-8/k.html
·
Cornell
TSCA Chemical Search Database: http://msds.pdc.cornell.edu/tscasrch.asp
·
Guidance
for filing requirements: http://www.epa.gov/oppt/newchems/index.htm
·
The
TSCA Biotechnology Final Rule Fact Sheet::
http://www.epa.gov/opptintr/biotech/pdf/fs-002.pdf
·
EPA’s
Asbestos Web page: http://www.epa.gov/asbestos/
·
Regional
contacts for TSCA’s Biotechnology Program:
http://www.epa.gov/opptintr/biotech/biocontx.htm
·
EPA’s
Lead Program Page: http://www.epa.gov/lead
·
The
National Lead Information Center: http://www.epa.gov/lead/nlic.htm
·
EPA’s
PCB home page: http://www.epa.gov/fedsite/elecshop/pcb.html
General Assistance
·
Environmental
Law Guide from the National Association of College and University
Attorneys: http://www.nacua.org/publications/pubs/compendia/environlaw.html
·
Code
of Federal Regulations: http://www.gpo.gov/nara/cfr/index.html