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Home » Reports

Environmental Safety Program Review for Colleges and Universities

Date: __________________________

Institution Name: ______________________________________

Persons in Attendance: ______________

Number of Buildings: ________________

Number of Students: ________________

Environmental Safety Program Structure / Reporting Relationships: Solid Waste | Storage Tanks | Asbestos | Lead | Pesticide | CFC | Emissions | Water | Other Issues | General Safety

1. Solid and Hazardous Waste Management:

   Hazardous Waste:

   General Issues:

   1. Any regulatory inspections in last 3 years?
   2. EPA notification completed? Facility EPA ID number?
   3. Institution generator status?
   4. Types of wastes generated? Any acute (P-listed) hazardous waste (HW)?
   5. Waste determinations performed?
   6. Written procedures in place for HW management?
   7. Does institution discharge waste water to lagoon or impoundment?
   8. Does institution store HW on-site for more that 90 days (LQG) or 180 days (SQG)?
   9. Does institution transport HW between facilities on-site?
   10. Does institution use only transporters and TSDFs with EPA ID numbers for HW disposal?
   11. Has institution notified local fire / emergency response officials regarding HW activities at site?
   
   

   Recordkeeping:

   12. Are all manifests and land disposal restriction (LDRs) properly completed?
   13. Are manifest copies retained for at least 3 years?
   14. Have exception reports been filed for any missing manifests? Have such reports been retained for 3 years?
   15. Has institution submitted any biennial reports / waste minimization plans?
   16. Have any HW fees been paid in past? Fee records kept for 3 years?
   
   

   Satellite HW Accumulation Areas:

   17. Are satellite HW accumulation areas present at the Facility? Where?
   18. Are satellite HW accumulation areas located at or near point of HW generation?
   19. Are satellite HW accumulation containers in good condition, labeled and compatible with stored HW?
   20. Once satellite accumulation area limit of 55 gallons of HW is reached, are the containers dated and moved to a HW holding area until ultimate transfer to a TSDF?
   21. Are weekly inspections of HW containers in satellite accumulation areas conducted?
   22. Are procedures in place to correct HW storage deficiencies in satellite accumulation areas?
   23. Are employees trained to properly manage satellite HW accumulation areas?
   
   

   Employee Training:

   24. Are employees thoroughly familiar with appropriate HW emergency procedures?
   25. Is at least 1 person on call and trained to deal with HW emergencies?
   26. More detailed / specific training in place for LQGs?
   
   

   Other Requirements:

   27. Is sufficient aisle space maintained for unobstructed access by emergency personnel and equipment to HW areas.
   28. Does institution have a RCRA Part A or Part B permit?
   29. Is institution subject to SARA Title III Reporting? LEPC / Local Fire Dept. contacts:
   
   

   Used Oil Management:

   30. Does institution store used oil?
   31. Used oil storage containers labeled as Used Oil and in good condition?
   32. Any used oil releases in past?
   33. Does institution mix potential HW with used oil?
   34. Any reason to believe any used oil may contain > 1,000 ppm halogens (e.g. chiller oil)?
   35. Does institution burn used oil in space heaters?
   36. Does institution transport used oil to a collection center (> 55 gals.)?
   37. Is the used oil collection center registered, licensed or permitted to manage used oil?
   38. Does the used oil transporter have an EPA ID number?
   39. Are oil filters gravity hot-drained?
   
   

   Other Potential Hazardous Wastes:

   40. How are used (burned out) fluorescent lamps currently handled?
   41. How are used ballasts currently handled?
   42. How are used batteries (lead/acid and others) currently handled?
   43. How are scrap tires currently managed?
   44. Any PCB-containing equipment known to be present at the institution?
   
   

   Other Solid Wastes:

   Biohazardous Wastes

   45. Where are biohazardous wastes generated at the Institution? Approximate Quantity?
   46. Is any biohazardous waste autoclaved on-site? Are written procedures in-place for autoclaving?
   47. Is contract in place for the removal and disposal of biohazardous wastes? With whom?
   48. How are sharps such as needles or razor blades handled?
   49. List any points of interest with regards to biohazardous waste handling at the institution:
   
   

   Solid Waste Handling

   50. Are procedures in place to prevent the mixing of hazardous waste streams with non- hazardous wastes?
   51. What types of non-hazardous waste are generated at the institution (trash, landscape debris, etc.)?
   52. How is household-type institutional trash handled at the site?
   53. Is a contract service used for trash disposal?
   54. Do institution employees transport or otherwise handle trash on-site?
   55. Is trash burned, buried or otherwise disposed of on-site?
   56. Are there any areas on-site which are known or suspected to have been used for trash (or other solid waste) burning, burial or disposal in the past?
   57. Does the institution currently hold any permit(s) for solid waste handling?
   58. How is construction rubble/debris currently handled at the institution?
   59. How is landscape debris currently handled at the institution?
   60. Does institution conduct any composting activities?
        
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2. Storage Tanks:

   Above Ground Storage Tanks (ASTs)

   List type and location of any ASTs at the institution:

   1. Has the State or Local Fire Marshal approved the design and installation of the ASTs?
   2. Any ASTs (or other containers) which combined, amount to >1320 gallons of oil/fuel at same site?
   3. Any single AST (or other container) with > 660 gallons of oil/fuel
   4. Is a Spill Prevention, Control, and Countermeasures (SPCC) plan required for site?
   5. Is a National Oil and Hazardous Substances Pollution Contingency plan required for the site?
   6. Has any oil or fuel been spilled or previously released at the site?
   7. Are spill containment measures and clean-up equipment adequate for the site?
   
   

   Underground Storage Tanks (USTs)

   7. List type, location and size of all regulated USTs at the institution:
   8. Are USTs properly registered according to GUST Rules? Certificates available?
   9. Any USTs previously closed in place at the site?
   10. Has GEFA contacted the institution to develop an action plan for UST remediation?
   11. Are there any USTs present at the site which meet the December 1998 regulations for corrosion protection, overfill protection and leak detection?
   12. Are inventory control procedures (e.g. daily sticking, meter readings, mass balance) currently used?
   13. Has annual UST tightness testing (including piping systems) been performed? Records available?
   14. Have there been any releases from or near any USTs at the site? Reported? Corrective Action?
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3. Asbestos-Containing Materials:

   1. Does the institution have ACM control procedures in place?
   2. Has an institution-wide ACM inspection been completed? Records available on-site?
   3. Have ACM abatement projects been completed in the past? Records available?
   4. Where is ACM still present on-site?
   5. Which areas are the highest priority for abatement?
   6. Are procedures in-place to ensure that institution demolition/renovation projects will not release asbestos into the environment?
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4. Environmental Lead:

   1. Does institution have lead exposure control procedures in place?
   2. Any areas suspected to contain lead-based paint (LBP) on-site?
   3. Any child care facilities at the institution?
   4. Any pre-1978 residential dwelling units (1 BR or more) at the institution?
   5. Any large steel structures at the institution such as a water tower or bridge?
   6. How are old (pre-1978) painted surfaces handled at the institution?
   7. Has drinking water ever been tested for lead at the institution? Results available?
   8. Any firing ranges present at the institution?
   9. Are procedures in-place to ensure that lead will not be released into the environment during structure demolition/renovation projects?
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5. Pesticide Use and Management:

   27. Does the institution have a written Pesticide Use and Management Procedure in place?
   28. Do institution employees apply pesticides on inside of buildings? Are they licensed applicators?
   29. Do institution employees apply pesticides on the grounds of the institution (outside of buildings)? Are they licensed applicators?
   30. Are appreciable quantities of pesticides stored / mixed on-site? Where stored? By Whom?
   31. Has the institution posted pesticide application notices in accordance with HB1317?
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6. CFC Management Program:

   1. Has the institution adopted a refrigerant (CFC) management program?
   2. Does the institution have CFC capture / recycling equipment in use on-site? Registered? Employees trained?
   3. How are chiller repairs and refrigerant leaks handled at the institution?
   4. What is the institutions primary choice for CFC replacement in cooling equipment?
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7. Air Emissions:

   1. Has the institution conducted a Title V Potential to Emit assessment? Documentation on file?
   2. What type of emission source is the institution? Major/ Minor/ Synthetic Minor/ Permit-by-Rule (PBR)
   3. Is institution in ozone non-attainment area?
   4. Does institution participate in vehicle emissions testing program?
   5. Does institution monitor air emissions from any source(s)?
   6. Does institution emit appreciable concentrations of HAPs?
   7. Emergency generators present?
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8. Water:
   1. Does the institution have water quality control procedures in place?
   2. Does the institution discharge waste water to POTW? Name of POTW:
   3. Does the facility have a copy of the POTWs sewer ordinance, discharge permit and pretreatment program?
   4. Are procedures in place to prevent discharge of prohibited pollutants into the POTW?
   5. Does the institution have an NPDES permit for any activities at the site?
   6. Does the institution discharge storm water associated with industrial activity? Any storm water discharge permit(s)?
   7. Any known wetlands on or adjacent to the institution site?
   8. Where do storm sewers discharge from the facility?
   9. Any drinking water wells present on-site? Test results available? Personnel complaints?
   10. Any irrigation wells present on-site? Test results available?
   11. Any ground water monitoring wells present on-site? History? Test results?
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9. Other General EHS Issues:
   1. Any property planned for development or buildings planned for renovation?
   2. Fire Protection and Life Safety Compliance Status:
   3. Indoor Air Quality Concerns / HVAC PM Program in place?
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10. General Safety Issues:

    Are written programs/procedures in place for:

    1. Bloodborne Pathogen Exposure Control Procedures?
    2. Confined Space Entry Procedures?
    3. PPE Use and Maintenance Procedures / Medical Surveillance Programs?
    4. Trenching / Excavation Procedures?
    5. Machine Guarding?
    6. Radiation Safety?
    7. Hearing Conservation Program?
    8. Other Safety Issues?