View
35
Download
3
Category
Tags:
Preview:
DESCRIPTION
Region 2's College & University Compliance Initiative: Environmental Results From An Integrated Strategy. Leveraging Limited Resources To Obtain Better Compliance. Five Year Status Report. Goals For Compliance Initiative. - PowerPoint PPT Presentation
Citation preview
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
11
Region 2's College & Region 2's College & University Compliance University Compliance
Initiative: Environmental Initiative: Environmental Results From An Integrated Results From An Integrated
StrategyStrategy
Leveraging Limited Resources Leveraging Limited Resources To Obtain Better ComplianceTo Obtain Better Compliance
Five Year Status Report
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
22
Goals For Compliance Goals For Compliance InitiativeInitiative
• Improve environmental compliance and Improve environmental compliance and safety at main and off-site facilities.safety at main and off-site facilities.
• Change the culture to one in which Change the culture to one in which environmental compliance is a priority.environmental compliance is a priority.
• Ensure compliance of entire sector; not Ensure compliance of entire sector; not just those reached through inspections.just those reached through inspections.
• Ensure continued compliance by Ensure continued compliance by implementing permanent changes.implementing permanent changes.
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
33
ApproachApproach• Region 2 combined the following strategies Region 2 combined the following strategies
to address compliance issues in this sector:to address compliance issues in this sector:– Compliance assistanceCompliance assistance– Compliance incentives (voluntary Compliance incentives (voluntary
audit/disclosure)audit/disclosure)– Compliance monitoringCompliance monitoring– EnforcementEnforcement– Pollution preventionPollution prevention– Environmental management systems (EMS)Environmental management systems (EMS)
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
44
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
55
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
66
Results: Compliance Monitoring & Results: Compliance Monitoring & Incentives ProgramsIncentives Programs
Colleges & Universities
Universe375
Inspections67
Enforcement Actions 59
Formal Enforcement Actions 25 ($3,631,863)
Settlements 22 ($661,638)
Audit Agreements 16
Voluntary Disclosures 110 ($10,781,318 for 82 resolved)
Violations Corrected 1624
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
77
0
2
4
6
8
10
12
14
16
FY2001
FY2002
FY2003
FY2004
FY2005
Inspections
No ActionNOVs Only
ComplaintsUndetermined
AC
TIO
NS
/YE
AR
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
88
0
5
10
1520
25
30
35
40
4550
FY2001
FY2002
FY2003
FY2004
FY2005
% EPAInspectionsLeading toComplaints
PE
RC
EN
T /
YE
AR
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
99
University and College SEPsUniversity and College SEPs
• 10 settlements include SEPs10 settlements include SEPs
• Range from $26,000 to $270,000Range from $26,000 to $270,000
• Total value of SEPs = $1,711,297 Total value of SEPs = $1,711,297
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1010
Types of SEPsTypes of SEPs– Chemical Tracking & Control SystemsChemical Tracking & Control Systems– Mini/Micro-Scale ChemistryMini/Micro-Scale Chemistry– Solvent Recovery SystemsSolvent Recovery Systems– Other Equipment/Technology Other Equipment/Technology
ModificationsModifications– Environmental Compliance PromotionsEnvironmental Compliance Promotions– Environmental Management SystemsEnvironmental Management Systems
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1111
Results:Results:Environmental BenefitsEnvironmental Benefits
Program Environmental Benefits from Disclosures
RCRA More than 58,125 lbs/year of hazardous waste is now being managed properly because colleges have self-disclosed violations and corrected mismanagement.
SPCC At least 716,388 gallons of oil are now being managed properly.
TSCA At least 84 residential units now in compliance with lead-based paint rules.
CAA At least 4,000 pounds of chlorofluorocarbons now being appropriately managed.
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1212
Root Causes Of Root Causes Of NoncomplianceNoncomplianceSystemic violations appear to stem from:Systemic violations appear to stem from:• Inadequate resources for people, Inadequate resources for people,
equipment and training to carry out equipment and training to carry out environmental activities;environmental activities;
• Limited or no environmental compliance Limited or no environmental compliance accountability for individual accountability for individual departments, laboratories, and staff;departments, laboratories, and staff;
• Limited authority vested in Limited authority vested in environmental compliance officials;environmental compliance officials;
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1313
Root Causes Of Root Causes Of NoncomplianceNoncompliance• No clear environmental compliance chain-No clear environmental compliance chain-
of-command;of-command;• Scattered, incomplete, and missing Scattered, incomplete, and missing
environmental compliance environmental compliance documentation;documentation;
• Incomplete institutional knowledge Incomplete institutional knowledge regarding environmental regulatory regarding environmental regulatory requirements; andrequirements; and
• Broad use of hazardous materials when Broad use of hazardous materials when effective substitutes existeffective substitutes exist
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1414
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1515
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1616
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1717
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1818
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
1919
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2020
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2121
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2222
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2323
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2424
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2525
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2626
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2727
Bulb CrushersBulb Crushers
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2828
Bulb CrushersBulb Crushers
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
2929
College & University ViolationsCollege & University Violations20052005
Breakout of Violations from C/U Disclosures
RCRA Violations53% TSCA Violations
7%
CAA Violations3%
CWA Violations36%
EPCRA Violations1%
SDWA Violations0%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3030
College & University RCRA College & University RCRA Violations - 2005Violations - 2005Breakout of RCRA Violations from C/U Disclosures
ID of HW 24%
Universal Waste21%
Container Management30%
Accumulation Time1%
Manifest 9%
Generator Requirements1%
General Facility Standards12%
UST 2%Generator Requirements
ID of HW
Universal Waste
Manifest
Accumulation Time
General Facility Standards
Container Management
UST
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3131
College & University CAA College & University CAA Violations 2005Violations 2005
Breakout of CAA Violations from C/U Disclosures
SIP (including MACT, NESHAPS,
& Title V) 57%
CFCs 40%
Asbestos 3%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3232
College & University CWA College & University CWA Violations 2005Violations 2005
Breakout of CWA Violations from C//U Disclosures
NPDES 0%
SPCC/OIL Spill100%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3333
College & University TSCA College & University TSCA Violations - 2005Violations - 2005
Breakout of TSCA Violations from C/U Disclosures
Lead Paint 100%
PCBs 0%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3434
College & University EPCRA College & University EPCRA Violations - 2005Violations - 2005
Breakout of EPCRA Violations from C/U Disclosures
Chemical Inventory50%
MSDS 50%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3535
Top 10 RCRA Violations From Top 10 RCRA Violations From Inspections – 936 ViolationsInspections – 936 ViolationsRankRank ViolationViolation FrequencyFrequency
11 ID of HW ID of HW 205205
22 Container Container ManagementManagement
141141
33 LabelingLabeling 113113
44 Accumulation TimeAccumulation Time 8484
55 Off-Site Receipt of Off-Site Receipt of HWHW
7878
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3636
Top 10 RCRA Violations From Top 10 RCRA Violations From Inspections – 936 ViolationsInspections – 936 ViolationsRankRank ViolationViolation FrequencyFrequency
66 InspectionsInspections 6262
77 Universal WasteUniversal Waste 5757
88 Requirements for Requirements for Ignitable, Reactive, Ignitable, Reactive, & Incompatible & Incompatible WastesWastes
4242
99 Incompatible Incompatible WastesWastes
2626
1010 Emergency Emergency ProceduresProcedures
2424
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3737
Top 10 RCRA Violations From Top 10 RCRA Violations From Disclosures – 245 ViolationsDisclosures – 245 ViolationsRankRank ViolationViolation FrequencyFrequency
11 ID of HW ID of HW 6363
22 Universal WasteUniversal Waste 4848
33 LabelingLabeling 4646
44 ManifestsManifests 3333
55 Container Container ManagementManagement
2222
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3838
Top 10 RCRA Violations From Top 10 RCRA Violations From Disclosures – 245 ViolationsDisclosures – 245 ViolationsRankRank ViolationViolation FrequencyFrequency
66 TrainingTraining 99
77 InspectionsInspections 44
88 Accumulation TimeAccumulation Time 44
99 CeSQG CeSQG RequirementsRequirements
33
1010 UST Leak UST Leak DetectionDetection
33
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
3939
Survey OverviewSurvey Overview
• 61 colleges61 colleges completed and returned the completed and returned the audit survey audit survey
• 33,899 faculty are reported to be working 33,899 faculty are reported to be working at these facilitiesat these facilities
• 69,205 staff are reported to be working at 69,205 staff are reported to be working at these facilitiesthese facilities
• 399,498 students are reported to attend 399,498 students are reported to attend these facilitiesthese facilities
• 2191 facilities are reported to compose 2191 facilities are reported to compose these 61 collegesthese 61 colleges
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4040
How many faculty does your College/University employ?
28
18
6 5
1 1 0 0 1
0
5
10
15
20
25
30
0-250 251-500 501-1000
1001-2000
2001-3000
3001-4000
4001-5000
5001-6000
6001-7000
Number of Faculty
Nu
mb
er
of
Co
lleges
&
Un
ivers
itie
s
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4141
How many Staff does your College/University employ?
1819
1211
02468
101214161820
Number of Staff
Nu
mb
er
of
Colleges
&
Un
ivers
itie
s
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4242
How Many Students Attend your College/University?
12
7
11
76
5
32 2
1
6
4
0
2
4
6
8
10
12
251-500
1001-2000
3001-4000
5001-6000
7001-8000
9001-10000
>20000
Number of Students
Nu
mb
er
of
Co
lleges
&
Un
ivers
itie
s
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4343
How many facilities are part of your institution?
28
8 97
41
4
0
5
10
15
20
25
30
0 to 5 6 to10
11 to25
26 to50
51 to75
76 to100
>100
Number of Facilities
Nu
mb
er
of
Co
lleges/
Un
ivers
itie
s
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4444
What best describes your status with the Audit Initiative?
3%19%
59%
19%
No, did notparticipate in AuditPolicy
Yes, audited withoutcommunicating withEPA
Yes, signed an AuditAgreement with EPARegion 2
Yes, voluntarily self-disclosed complianceissues
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4545
% of Respondants who found each Compliance Assistance Activity
'Very Useful'
24%
25%33%
18%
Workshops/trainings/presentations
Outreach materials
Region 2 websites
EPA responses tophone calls/emails
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4646
Understanding Of Waste Understanding Of Waste Management Regulations Management Regulations Before And After Before And After Compliance Initiative (40% - 98%)Compliance Initiative (40% - 98%)
Before
High40%
None2%
Some58%
After
Some
2%
High
98%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4747
Changes in Understanding – Changes in Understanding – Very High ResponsesVery High Responses
ProgramProgram BeforeBefore AfterAfter
RCRARCRA 4040 9898
ASTAST 4848 9292
USTUST 5555 9393
CAACAA 3131 8282
CWACWA 4343 7373
SPCCSPCC 3333 8787
TSCATSCA 4343 7676
PesticidesPesticides 5252 8282
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4848
Changes Made as a Result of Changes Made as a Result of the Initiativethe Initiative
Type of ChangeType of Change PercentagePercentage
Handling, processing, Handling, processing, monitoring, and O&Mmonitoring, and O&M
41%41%
Paperwork, labeling, and Paperwork, labeling, and reportingreporting
33%33%
TrainingTraining 13%13%
Implement P2 and waste Implement P2 and waste minmin
8%8%
EMS: 5%EMS: 5% 5%5%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
4949
Changes Planned as a Result of Changes Planned as a Result of the Initiativethe Initiative
Type of ChangeType of Change PercentagePercentage
Handling, processing, Handling, processing, monitoring, and O&Mmonitoring, and O&M
33%33%
Paperwork, labeling, and Paperwork, labeling, and reportingreporting
25%25%
EMSEMS 28%28%
TrainingTraining 8%8%
Implement P2 and waste Implement P2 and waste minmin
6%6%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5454
What percentage of your institution was audited?
78%
20%2% 100%
Greater than%50
Less than %50
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5555
Did you encounter roadblocks with the cost of your audit?
Definite roadblocks
8%
No roadblocks
57%
Some issues, but no
major issues
35%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5656
Did you encounter roadblocks with the cost of compliance?
Definite roadblocks
15%
No roadblocks
32%
Some issues, but no major
issues53%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5757
Did you encounter roadblocks with upper management when
implementing your audit?
No roadblocks
75%
Definite Roadblocks
8%
Some issues, but no major
issues17%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5858
Did you encounter roadblocks with identifying appropriate
contractors?
Definite roadblocks
6%
No roadblocks65%
Some issues, but no major issues
29%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
5959
Did you encounter roadblocks with lack of knowledge of regulations?
Definite roadblocks
12%
No roadblocks33%
Some issues, but no major issues
55%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6060
Did you encounter roadblocks with overall time and
commitment?Definite
roadblocks25%
No roadblcoks
29%
Some issues, but not major
46%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6161
Did you encounter roadblocks interacting with regulatory
agencies?
No roadblocks
74%
Some issues, but not
major
22%
Definite roadblocks
4%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6262
Did you encounter roadblocks with cooperation of
faculty/staff/students?
Definite roadblocks
14%
No roadblocks
25%
Some issues, but not major
61%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6363
How much time was required to complete the correction of all
areas of non-compliance?
More than 120 days,
38%
More than 60 days but
less than 120 days,
31%
Within 60 days, 31%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6464
What influenced you to participate in an Audit Agreement or self-
disclosure?
Penalty reductions
21%
Avoid enforcement
action44%
Moral responsibility
20%SUNY
agreement15%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6565
How often does your institution typically audit under your formal
mulit-media environmental compliance audit?
Once every three to five
years29%
Once every two years
18%
Once every year53%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6666
Reported College & University Reported College & University Audit CostsAudit Costs
• Average cost of audit is $38,208Average cost of audit is $38,208
• Average cost of audit without 5 most Average cost of audit without 5 most expensive (>$100,000) is $11,607expensive (>$100,000) is $11,607
• Average cost of compliance is $108,815Average cost of compliance is $108,815
• Average cost of compliance without 8 Average cost of compliance without 8 most expensive (>$100,000) is $17,307most expensive (>$100,000) is $17,307
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6767
Does your institution have a formal Environmental
Management System (EMS)?
No73%
Yes27%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6868
If an EMS is not in place, are you considering adopting an EMS?
Not planned9%
Planned23%
Under consideration
68%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
6969
If an EMS is not in place, what are the roadblocks?
Time5%
Other5%
Insuf f icient technical
resources5%
Lack of management
support42%Cost
consideration43%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
7070
Does your EMS include a periodic, systematic review of your facility's
compliance?
No10%
Yes90%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
7171
Has your EMS been the basis for any operating changes beyond
compliance?
Yes65%
No35%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
7272
Did the Compliance Initiative/self-audit play a role
in the decision to implement an EMS or modify an existing EMS?
No22%
Yes78%
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
7373
Goals For Compliance Goals For Compliance InitiativeInitiativeImprove environmental compliance and Improve environmental compliance and
safety at main and off-site facilities.safety at main and off-site facilities.Change the culture to one in which Change the culture to one in which
environmental compliance is a priority.environmental compliance is a priority.Ensure compliance of entire sector; not Ensure compliance of entire sector; not
just those reached through inspections.just those reached through inspections.Ensure continued compliance by Ensure continued compliance by
implementing permanent changes.implementing permanent changes.
Region 2 College & University ComRegion 2 College & University Compliance Initiativepliance Initiative
7474
John Gorman
212-637-4008
gorman.john@epa.govwww.epa.gov/region02/p2/
college/
Recommended