Agency and University Partner in Campus EMS Development

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

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

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

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

Multiple and Varied Waste Sources-Colleges

Multiple and Varied Waste Sources-Specialized

Multiple and Varied Waste Sources-Services

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

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

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

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

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

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

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

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

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

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:

UCF EMS Obligations 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 Function UCF’s EMS anticipated to include provisions for:

UCF EMS Components 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 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

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

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.

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

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

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