As you consider your options for environmental compliance - including "self-reporting" under the United States Environmental Protection Agency (EPA's) Audit Policy - you should be looking carefully at the advisors you assemble to assist you. Whether you are still just thinking things over, or are gathering qualifications of environmental auditors to support your self-disclosure effort, I encourage you to consider Environmental Risk Limited.
Environmental Risk Limited has conducted many audits of secondary school and college campuses (large and small) dating back to the late 1980's. Our resume includes work for more than 40 public and private universities, medical schools, and preparatory schools in the Northeast (including several of the "Ivys" and large state universities). We have been following the progression of the EPA College and University Initiative since its inception. We have also developed Environmental Management System (EMS) plans and were invited to sit on the EMS committee for a large research university.
We are confident that our experience will put ERL at the top of your list.
Arts Smarts!
Many of ERL's school and university clients have voiced their frustration about what a difficult challenge it is to achieve regulatory compliance in their Arts Departments. One of the first stumbling blocks to compliance is that many students and teachers purchase their own art supplies (such as paints and thinners) and Environmental Health and Safety and Facilities Staff are simply uninformed as to what is being used on campus until they have to dispose of it.
Also, it appears that most art students do not understand the potential hazards involved as well as the regulations the school must comply with regarding waste disposal. So, they do what they would do at home and either dispose of waste thinners and paints in the sinks or let it evaporate and then throw the dried paint in the trash. This poses a problem because many of the thinners used are flammable (or may contain chlorinated solvents) and therefore must be managed as hazardous waste. Also, the paints they use may be oil-based or may contain cadmium and other heavy toxic metals (lead, chromium, etc.), which require disposal as hazardous waste.
Another problematic area commonly found in arts departments is printmaking. Printmaking uses corrosive chemicals, usually strong acids to etch metal plates. These strong acids must be carefully used and properly disposed of. Also, waste rags soaked with linseed oil and solvents are often generated but are not managed correctly. All waste rags, whether used with a solvent containing a listed waste or not, must be properly managed and disposed of (i.e., stored in a red rag can, properly labeled, the container kept closed and tested to determine if the rags are hazardous). After testing is performed, the rags must be disposed of either as hazardous waste, as regulated waste or as regular trash depending on the test results. It is important to maintain copies of these waste determinations to verify that your waste is being handled and disposed of properly. Another option may be to send your waste rags to an industrial laundry facility and avoid the issue of disposal altogether.
Other issues include unrestricted access to art studios 24-hours a day, which can be a serious safety issue. For example, one student accidentally electrocuted himself and was not found until hours later, while yet another was found "asleep" the next morning in a studio suffering from solvent narcosis. These are extreme cases, but they illustrate what can happen.
For help in evaluating the compliance issues and potential safety hazards in your institution's arts departments, please call us at 1-800-883-1568.
Keeping Your Students Safe From Mercury
I'm sure many of you have seen recent headlines involving mercury spills in schools. While some of you may even remember pushing little beads of mercury around with your finger or coating coins with it, times have definitely changed since then.
People are more aware that mercury is an extremely potent toxin, which can cause severe health effects even in small quantities. These health effects include acute poisoning, severe kidney and liver damage and nervous system dysfunction. These health impacts are caused not only by ingestion of contaminated foods (such as fish), but also by inhalation, which is a more efficient mode of entry into the body and results in far more immediate danger. Because of this air borne health risk, even a very small amount (an ounce or less) can be enough to necessitate the evacuation of an entire building, and require mercury exposure testing and other precautionary measures for a potentially large number of students and staff.
In Connecticut alone, there have been at least a half dozen mercury spills at schools in the past two years. It has become such a problem that there are several bills in the legislature proposing to ban all mercury use in schools. If you haven't already started, what steps can you take to protect your school?
The best way is to get rid of the potential threat! Remove the sources of mercury from your campus - replace mercury thermometers with alcohol or digital thermometers, get rid of old containers of mercury stored for experimental purposes, look for old switches and gauges that may be an unsuspected source of mercury.
Getting rid of all sources of mercury is not always easy -- certain medical and scientific protocols may, in fact, dictate the use of mercury -- in those circumstances, it is best to be prepared. Educate personnel of the dangers of mercury and proper spill response (for example, trying to vacuum up a mercury spill may not only spread the problem, but increases the health hazards by heating up and vaporizing the harmful mercury).
For help with mercury reduction, spill response planning, or staff training for your school or university, please contact ERL at 800-883-1568.
Dazzle'em With Preparedness….
You are at an interview. You feel okay because you know you've got a great resume and you really know your stuff. Then bad things happen - you are caught off guard by a question you didn't expect, you fail to convey your strengths and get trapped looking at weaknesses. You can't lay your hands on samples of your work that you know are in your briefcase. Later, your ace references are totally unprepared to help you. Yikes.
We all know better than to let this happen - but is this close to the reality of how an interview with an EPA inspection team would go? How can you improve your chances at a more successful showing if they appear at your college?
Plan out the interview. Especially the opening conference. Know who will attend, what topics you want to cover, how much time you want to fill up, what handouts to have ready to pass out. Take charge and sell your strengths!
Prepare your "supporting cast." Okay - they are not references, but they will be acting as interviewees and escorts. Many will be spending time alone with an inspector. Make sure they really know their respective roles and responsibilities during an inspection.
Rehearse an audit event. It will reinforce to all the people involved that you are taking the prospect of an inspection seriously, but just as importantly, it will improve both your confidence and the chances of making a good showing.
EPCRA- It's more than just Tier II forms!
I'm sure most of you are aware that you need to submit annual Tier II forms listing all hazardous chemicals you have on campus in quantities greater than 10,000 pounds. Many schools file Tier II forms for storage of fuel oil, diesel fuel and/or gasoline. What you may not know is exactly what the EPA (at least the Region I enforcement officer) considers hazardous chemicals. ERL recently attended an EPA-sponsored EPCRA conference and learned that the EPA appears to have different interpretations from everybody else. For instance, did you know that the pile of salt and sand you have stored out by your grounds department (if more than 10,000 pounds at any time during the year) must be reported because it contains silica, which is considered a hazardous substance?
Did you also know that Section 302 regarding Extremely Hazardous Substances (EHS) applies to all extremely hazardous substances on campus and does not have the same exemptions as Section 312 (Tier II reporting) for substances used in a research laboratory, hospital or medical facilities?
What does this all mean? It means that when you are determining if you have greater than the Threshold Planning Quantity (TPQ) of any EHS on your campus, you must include all the sulfuric acid in your labs (research or otherwise) and even the sulfuric acid in the car batteries of your school-owned vehicles. And you must count not only the ammonia in your hockey rink cooling system, but also in your refrigeration systems on campus, and in the bottles of windshield washer fluid you store and use in your school vehicles.
And what if you do have more than the TPQ for any substance? That can be easy to do because some of the most common ones (sulfuric acid, ammonia and formaldehyde) have a TPQ of only 500 pounds. Then you must submit a one-page Section 302 Notification to your Local Emergency Planning Committee (LEPC) and State Emergency Response Commission (SERC). This may sound easy, but the 302 Notification also requires that you assign a facility representative to participate in the LEPC. To further complicate matters, in some very rural areas there may not even be a LEPC. This means you either have to initiate one (as one university did) or you must submit annual letters to the local Fire Marshal and the SERC indicating that you would like to be notified if any meetings are held.
Distributed Generation Takes Hold
The age of electric utility deregulation has created a new awareness of the options available for meeting energy needs. In response to demands for improved efficiency and greater reliability, a new concept referred to as "distributed generation" is taking hold and gaining momentum. Essentially, it entails building small-scale power generating units at the site of the primary user.
According to The Department of Energy, "distributed generation strategically applies relatively small generating units (typically less than 30 megawatts (MW)) at or near consumer sites to meet specific customer needs, to support economic operation of the existing power distribution grid, or both. Reliability of service and power quality are enhanced by proximity to the customer, and efficiency is improved in on-site applications by using the heat from power generation." The latest technologies in distributed generation systems typically utilize reciprocating engines, gas turbines and fuel cells.
There are numerous benefits to distributed generation, but perhaps the biggest driver pushing this market sector at the current time is the Internet and data storage centers. At a recent conference sponsored by the Northeast Energy and Commerce Association on "Ultra Reliable On-Site Power," one presenter stated that energy requirements for large data centers are now approaching 100 watts per square foot. Therefore, a 100,000 square foot facility housing a large sophisticated computer network would have an energy demand that would approach 10 MW. With buzz words such as "five 9s" (99.999% reliability) now commonplace in the industry, there are many institutions eager to explore new options to supply electricity and climate control for their digital equipment and data storage centers. We are currently involved in one such project on a college campus and are aware of at least two other large campuses that are actively exploring the idea.
Though the new power generation technologies for distributed generation have become quite efficient, compact and clean, it still doesn't take much to trigger the environmental permitting process. Because the permitting process is a lengthy one, a project planner must build in a significant amount of lead-time to acquire environmental approvals so that the project can be operational as originally planned.
