Surviving the EPA Multimedia
Audit for Colleges and
Universities
Robin M. Izzo
Assistant Director for Lab Safety
Princeton University
Presenting Points
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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
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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
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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
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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
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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
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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
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Visual Arts department
Maintenance shops
University Health Services
All campus darkrooms
Print Shop
Cogen Plant
Fluorescent bulb recycling
RCRA Audit
• Records Reviewed
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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
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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
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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
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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?