Rutgers, the state university of New Jersey, is about to learn something. The university is taking advantage of the Environmental Protection Agency's (EPA) innovative self-audit policy and will conduct a comprehensive environmental audit of its five major campuses and off-campus facilities.
The agreement is the first of its kind between EPA and a college or university, and is part of a national initiative to help institutions of higher education comply with environmental regulations. EPA Acting Regional Administrator William J. Muszynski and Rutgers Senior Vice President and Treasurer JoAnne Jackson signed the agreement late yesterday at the university.
"Universities and colleges -- many of which are the size of small towns -- often have the same regulatory responsibilities and environmental concerns that large corporations do," said Muszynski. "We started a compliance initiative aimed at colleges and universities to give them a chance to look at their facilities, see where potential concerns might lie, tell us about them and correct them before we conduct official inspections. We are very gratified that Rutgers the largest university system in New Jersey is the first in the country to take us up on our offer, and we look forward to seeing the results of its audit."
EPA's Region 2 office started the colleges and universities initiative because it found that many such institutions were not aware of their responsibilities under various environmental laws. As part of the initiative, EPA informed colleges and universities of the benefits of the audit policy, under which facilities can investigate and disclose violations to EPA and, if a number of qualifications are met, receive a partial or, in some cases, 100 percent reduction in financial penalties.
EPA also held workshops to help schools comply, provided them with information about their duties under the law (with no risk to the institution of financial penalties) and warned them that official EPA inspections of their facilities with the risk of financial penalties were imminent if they did not perform an audit.
In advance of performing an audit, Rutgers approached EPA and requested an agreement laying out the details of the audit and the university's responsibilities. The university's audit of five campuses -- Busch/Livingston Campus; College Avenue; Newark; Camden and Cook & Douglass began on Oct. 1 and will take approximately one-and-a-half years.
Among other things, the university will determine whether hazardous wastes generated on the campuses are stored, treated and disposed of correctly; above ground and underground storage tanks in operation are managed properly and others closed according to regulation; proper emissions controls are installed on boilers and operated correctly; all recent asbestos abatement was done correctly; PCB-containing equipment has been managed properly; and that pesticides used on the campuses are used, stored and disposed of safely.
Rutgers will disclose any violations it discovers to EPA according to a set schedule, and indicate how it plans to correct each violation, the status of the correction (which must be completed within 60 days after a violation is discovered) and what measures were taken to ensure that the violation is not repeated. EPA may oversee or monitor the corrections and may inspect the facility afterwards to make sure any violations have been corrected.
If Rutgers discloses violations in accordance with the agreement and EPA's audit policy, it will not face gravity-based (punitive) penalties. Rutgers may face economic benefit-based penalties, however, which are based on how much money the institution may have saved by not complying with a particular environmental regulation.
Rutgers plans to share its inspection protocols and what it has learned by conducting this internal audit with other colleges and universities throughout the nation.
edited by Sandy Smith ([email protected])