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Agency and University Partner in Campus EMS Development

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  1. Agency and University Partner in Campus EMS Development

  2. Origination-Hazardous Waste Enforcement Case • Hazardous waste compliance assistance inspections targeted at universities in 1997 • Non-compliance items found and corrective actions recommended, with re-inspection noted • Second hazardous waste inspection conducted in 2000 revealed similar potential Small Quantity Generator violations

  3. Potential Violations Repeated • Waste determinations needed on potentially hazardous wastes both from facility and contractor operations • Waste accumulation containers were not dated, labeled or closed • Satellite containers were not marked or labeled with content identification or kept closed

  4. Other Repeating Violations • Certain department personnel lacked current training • Potential incidental releases of wastes were observed due either to maintenance or operational problems, or to failing or open containers • Unplanned waste generation could bump university to a LQG without intervention

  5. Waste Accumulation-Examples • Uncontrolled/unidentified paint materials left unannounced by outside contractor • Lead/acid batteries for reclamation on pallets but exposed to elements • Facility paint waste accumulating without a hazardous waste determination

  6. Multiple and Varied Waste Sources-Colleges

  7. Multiple and Varied Waste Sources-Specialized

  8. Multiple and Varied Waste Sources-Services

  9. Independent and/or Temporary Generators • Professors • Students • Supervisors • Managers • Operators • Contractors

  10. Diverse and/or Intermittent Operations • Teaching • Research • Productions • Performances • Services • Construction • Maintenance

  11. Teaching laboratories Research laboratories Contractor sites Vehicle maintenance shop Maintenance activities Painting operations Grounds-keeping Student Health Center Printing operations Janitorial operations Examples of Waste Sources

  12. Laboratory chemicals Construction/demoli-tion materials Maintenance wastes Printing chemicals Paint wastes Solvent wastes Biomedical waste Radioactive waste Examples of Waste Types

  13. Existing Waste Management System • UCF EH&S staff becoming increasingly proficient at tracking, monitoring and managing wastes • Personnel and operations generating wastes change with student population, research projects, new activities, service contracts, construction and expansion

  14. Waste Management System-Continued • EH&S staff not always able to detect and manage problematic situations • Campus is a community with many diverse entities, functions and needs • Management structure is matrix type with with different lines of authority to the top level

  15. Waste Management System-Continued • EH&S staff not fully empowered to direct and manage emerging waste issues • Potential waste generators not always predictable, informed and accountable

  16. Role of the EMS in Enforcement Negotiation • FDEP offers EMSs in settlement agreements as a means of offsetting civil penalties, fostering sustained compliance and promoting pollution prevention • FDEP began encouraging use of EMSs over recent years without really understanding their nature and benefits

  17. EMS Regulatory Tool Role-Continued • FDEP role in evaluating an EMS not defined • EMS has unclear role in regulatory arena • Personnel not all familiar with EMSs • No current unilateral basis for recognizing and using EMS in our dealings with regulated entities

  18. FDEP and UCF EMS • Negotiated as a Supplemental Environmental Project (SEP) to offset a portion of monies collected in a consent order • UCF agreed to implement a campus-wide EMS with a relatively small amount of money allotted • FDEP hoping to gain enhanced compliance

  19. UCF EMS Goal • UCF expected to implement a comprehensive EMS to consist of a systematic, periodic, and objective program to detect and correct violations by:

  20. Informing employees and agents through standards, policies and procedures; Assigning specific responsibilities for ensuring compliance throughout organization; Instituting a means for employees and agents to report violations without fear of retaliation. UCF EMS Obligations

  21. UCF EMS Function • UCF’s EMS anticipated to include provisions for:

  22. Procedure for periodic review, evaluation and monitoring of the system; Incentives to encourage all affected employees to perform in accordance with environmental requirements; Appropriate disciplinary mechanisms for failure to perform. UCF EMS Components

  23. UCF EMS Responsibility and Accountability • UCF to designate individuals responsible for implementing the EMS who are empowered to adequately address all functional areas impacting environmental issues • Approved EMS Plan to be distributed to all Department Chairs and Directors

  24. UCF EMS Reporting • UCF to submit Final Report detailing EMS implementation and including the following:

  25. UCF EMS Reporting Requirements • Description of the methods used to quantify wastes; • Expense report, receipts and other cost itemization information documenting development and implementation expenditures.

  26. FDEP’s Role • FDEP to review initial plan submitted and monthly progress reports • FDEP Pollution Prevention liaison serves as a non-regulatory/compliance assistance EMS Committee team member • Liaison negotiates EMS terms and issues between hazardous waste regulatory and university peers

  27. FDEP P2 Staff as Liaison • FDEP P2 staff member participates in EMS exercise to learn how the system works • Enables FDEP to interact as an equal on the team and provide insight and input in a non-regulatory manner • Provides FDEP staff experience with which to educate the agency and the public

  28. Sustainable Campus for Future Students • Our mutual mission • To showcase our local state campus as a leader in environmental sustainability • For our future students like this budding young scholar