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Pollution 101. (Water Disposal).

Some colleges and universities are paying stiff fines while others are voluntarily cleaning up their acts as regional offices of the U.S. Environmental Protection Agency (EPA) use education and enforcement to increase schools' compliance with federal environmental laws. Samantha Fairchild, director of the Office of Enforcement, Compliance, and Environmental Justice for EPA Region 3, says, "In general there seems to be a lack of understanding among colleges and universities that they are members of the regulated community, that oftentimes the things they are doing in these little villages are under the purview of environmental laws."

Colleges and universities, which do indeed function as self-contained mini-villages, conduct a wide range of operations that must comply with such laws as the Resource Conservation and Recovery Act, the Clean Water Act, and the Clean Air Act. Potential problems include hazardous waste produced by research labs, art studio supplies such as paints and thinners, leaks in underground storage tanks (which can spread oil and gasoline through soil and groundwater), and power plants and boilers (which can exceed allowable emissions of air pollutants such as particulate matter).

EPA Regions 1, 2, 3, and 9 are targeting college and university officials with an integrated strategy of speeches, press releases, and inspections. Enforcement varies among regions because states can choose to adopt regulations wholesale, or they can make them more stringent, says Peggy Bagnoli, an environmental engineer and co-lead for the College and University Sector of EPA Region 1.

Region 1, which covers the states of New England, began focusing on university compliance in early 1999 after inspectors found violations at Yale and the University of New Hampshire. Problems included failure to properly close or label hazardous waste containers, failure to separate incompatible hazardous waste, and lack of necessary permits. "[In Region 3] we have done eight or nine inspections and found violations at all but two colleges," Fairchild says.

In one of New England's largest cases, the University of Rhode Island at Kingston agreed to a settlement valued at more than $1 million for violations including those above. Joshua Secunda, senior enforcement counsel for EPA Region 1, reports in the August 2001 National Environmental Enforcement Journal that if incompatible wastes had been released together, a reaction could have generated toxic gases or an explosion.

Regional offices are encouraging schools to take advantage of the EPA's college and university self-audit initiative. Campuses can conduct a self-audit, and must notify the EPA of any violations within 21 days of discovery and correct the violations within 60 days or request an extension. There is no penalty for not self-auditing, but if a university meets nine self-audit criteria--which include, for example, that the reported violation has occurred only once in the past three years and poses no imminent threat to human or environmental health--any fines that would have been levied may be reduced by up to 100%. EPA regions across the country may offer additional incentives. In New England, for example, universities meeting the nine criteria will also be put on a low-priority inspection list for 18 months. So far, 140 schools have signed up to conduct self-audits.

As a direct result of its self-audit, Wesleyan University of Middletown, Connecticut, is pilot-testing nonchemical treatment of boiler water, says Harry Kinne, director of Wesleyan's facilities operations. Wesleyan's power plant foreman researched and suggested the idea. Kinne says, "The audit has reinforced that it is everyone's responsibility to help the university remain in compliance and come up with new ways to reduce our environmental impact."
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Author:Spivey, Angela
Publication:Environmental Health Perspectives
Date:Dec 1, 2001
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