Environmental liabilities may not be as apparent at colleges and universities as they are at industrial facilities, yet both have many of the same exposures. These include the use of hazardous chemicals; the generation of hazardous waste; the use of above and underground storage tanks; and the acquisition of real estate for future expansion/development. Colleges and Universities will benefit by implementing many of the same programs in place at industrial facilities. These programs include Environmental Due Diligence, Chemical Management, Waste Management, and Tank Management Programs.

Environmental Due Diligence

Environmental Due Diligence Procedures are a necessity at colleges and universities as property ownership grows through acquisition and alumni land trusts. To minimize potential environmental concerns at properties, it is essential to develop a Due Diligence Procedure for evaluating and accepting real estate that includes:

Environmental Questionnaire – Require property donors to complete a standard environmental questionnaire. The questionnaire should address the historical and current uses of the property, summarize past owners/operators of the property, and list any known environmental concerns. The ASTM Preliminary Site Assessment may serve as a guideline for developing such a questionnaire.

Phase I Environmental Site Assessment - Obtain a Phase I Environmental Site Assessment for those properties that involve historic or current site uses known to be related to environmental issues (i.e., industrial operations) and/or contain other environmental concerns. The Phase I ESA should follow ASTM or Canadian CSA guidelines and include a thorough investigation of the property’s historical uses and associated potential environmental concerns.

Acquisition Go/No-Go Criteria – Develop specific criteria for accepting or declining a real estate donation. These criteria should use the information identified in the Phase I ESA to determine whether the value of the property outweighs any potential remedial costs associated with suspect environmental concerns at the property.

Chemical Management

Implementing a formal chemical management program not only will help to minimize environmental, health, and safety exposures but also will reduce costs associated with chemical purchasing and disposal. Key components of a comprehensive chemical management plan include:

Central Chemical Tracking System. – Establish a tracking system/procedure for chemicals from purchase to disposal (i.e., Cradle to Grave as specified in RCRA). The tracking system should include a centralized purchasing program that monitors chemical requisitions, promotes sharing chemicals, and arranges shipments on an as-needed basis rather than in bulk. Purchasing only what is needed reduces disposal costs since your institution won’t be required to dispose of excess outdated chemicals.

Chemical Inventory Control System – The chemical tracking system should include an inventory control mechanism capable of providing data on what chemicals are utilized (i.e., Material Safety Data Sheets), who is using extremely hazardous chemicals, who the “high-volume” users are, and delineating where waste reduction operations need to be implemented. An effective inventory control program will assist departments with monitoring each chemical’s remaining shelf life and ensure that chemicals are used prior to their expiration.

Dedicated Chemical Storage – Each institution should designate central chemical storage area(s) to ensure that chemicals are stored safely. Within each dedicated chemical storage area, chemicals should be segregated according to chemical class and/or compatibility (i.e., flammables, corrosives, oxidizers, water reactive, etc.). The chemical storage areas should be designed to minimize the potential for environmental exposures. Engineering controls for an effective chemical storage area include construction with an impervious material such as concrete/masonry coated with an epoxy or chemical resistant finish, secondary spill containment, and explosion-proof electrical fixtures. They should also be located away from high risk traffic areas such as loading docks, student entrances, building exits, doors, and floor drains. Outdoor storage of chemicals should be eliminated entirely to reduce the potential for spills and contamination of stormwater, surface water, and soils. Consult local authorities to determine the appropriate fire codes/building codes related to hazardous material storage areas.

Waste Management

Almost every university department generates a waste stream other than general municipal solid waste. These other waste streams include:

• waste maintenance fluids;
• PCB-containing oils;
• PCB-containing light ballasts;
• asbestos;
• lead-based paints from maintenance shop/plant operations;
• waste fertilizer/pesticides from the grounds department;
• organic and inorganic solvents, corrosives, heavy metals, biohazardous waste and radioactive waste from science departments;
• medical waste and sharps from medical facilities or teaching hospital; and
• acids, waste paint, solvents, and waste photographic developing chemicals from the art/printing/theater department.

It is essential to develop and implement a campus-wide waste management program that addresses the following:

Training – Provide awareness training so that the staff is aware of the Waste Management Program Procedures. For those directly responsible for handling wastes, provide detailed hazardous waste training.

Waste Segregation - Segregate waste streams according to hazard class (i.e., hazardous, radioactive, biological, chlorinated/non-chlorinated solvents, etc.) to assist with consolidation and minimizing waste disposal costs.

Waste Storage – Establish a dedicated waste storage area equipped with secondary containment, explosion-proof electrical fixtures, lead shielding, fire suppression, etc. Provide appropriate waste collection containers (i.e., safety cans for flammables) at each location where wastes are generated. Routinely inspect designated hazardous waste storage areas.

Waste Disposal Facility Selection/Audits - Never assume that an outside contractor accepts liability for the waste removed from your facility. A generator may be held liable for costs to remediate the disposal facility if any waste can be tracked to that generator. Cleanup of disposal sites may cost millions of dollars. To avoid this liability, audit a disposal facility prior to using it.

Tank Management

Most educational institutions have both above and underground storage tanks on site; however, not all tanks may be regulated or require registration/permitting. Developing and implementing a formal tank management program helps ensure that no above and underground tanks are overlooked. A formal tank management program should include:

Tank Inventory – Document the location and features of all above and underground storage tanks. A tank inventory should include a summary of the key features of each tank such as age, construction, size, contents, overfill prevention, leak detection and permit numbers. Conduct periodic visual inspections of aboveground storage tanks and aboveground and underground storage tank fill areas.

Tank Integrity Tests – Conduct integrity tests and review operating systems. Tanks must be visually inspected and mechanically tested on a regular basis, and secondary containment structures must be provided to minimize the environmental impact from an accidental tank failure. Require routine inspection and integrity testing for all underground and aboveground storage tanks.