1. SUNY Environmental Audit Update SEHSA Corning November 2005

2. Barbara A. Boyle, CIH, CSP EPA Project Coordinator State University of New York Office of the University CounselboyleEHS @ aol.com

3. SUNY Programs • EPA Program • Signed in April 2002 • 7 reports to date • DEC Program • Signed in February 2005 • 2 reports to date

4. Inspections EPA Assigned SUNY “lowest priority” for five-years Exceptions include: citizen’s complaint, actual harm or imminent and substantial threat, criminal violation, or notification of spill; and oversight and confirmation DEC DEC will not inspect while auditors are on-site, except for conditions similar to above

5. EPA Program Status(April 2002) Through Nov 2005, SUNY has reported: 35 campuses 7 disclosure reports 533 non compliances 514 corrected non compliances EPA has calculated waived penalties.

6. DEC Program Status(February 2005) Through Nov 2005, SUNY has reported: 16 campuses 2 disclosure reports 132 non-compliances 123 corrected non-compliances Regional level awareness has been increasing.

7. EPA Fines & Penalties(through May 2005 disclosure) Waived all economic benefit penalties. <$10K per violation, per campus Waived all gravity based penalties: $6.6M 27 campuses

8. Reality Check One, open, unlabeled container of hazardous waste in hood. Possible violations @ $27.5K ea >>$82.5K: • Open container • Labeling missing • Treatment of HW

9. EPA Waived Fines By Program • Air Programs – $2.2M • 86 violations @ 20/27 campuses (non-Title V) • Water Programs - $2.1M • 45 violations @ 9/27 campuses • RCRA/Universal - $1.5M • 158 violations @ 26/27 campuses • Oil and SPCC - $0.6M • 48 violations @ 20/27 campuses

10. EPA Additional Info • Cost of correction • Scope of problem • Campus specific

11. November 2005 Disclosure • Eight Campuses • Passed half-way point • Total EPA Violations: 84 • Corrected as of reporting date: 75 • Total State-Only Violations: 50 • Corrected as of reporting date: 44

12. Violations by Program AreaNov 2005 Report

13. Air Programs Reported by 24 of 35 campuses. Note: the SUNY EPA Agreement does not extend to most Title V permit conditions. Permit violations/Lack of or incomplete permits Parts washers, spray booths, emergency generators CFC management

14. Water Reported by 11 of 35 campuses Stormwater issues ($$$) MS4, construction Only two items in last disclosure

15. SPCC & Oil Reported by 27 of 35 campuses Secondary containment 55 gallons or more, including kitchen grease Issues with SPCC plans updated and complete, signed by PE

16. Asbestos & Lead Reported by 13 of 35 campuses Lead notifications to tenants Asbestos NOIs and waste shipment records

17. Hazardous Waste Reported by 34 of 35 campuses: • HW determinations • Containers and Labels • Contingency Planning • SAA Issues • Training of Personnel • On-site Batch Treatment • Manifests

18. Universal Waste • Training • Closed containers • Labeling/Tracking

19. DEC- Only Violations Air Programs • State level regs Oil Storage • PBS registration, inspections Pesticide • Certification/reporting issues RMW • Manifests, labeling, sharps

20. Program Year 4May 05 – April 06 Disclosed November 2005: • Downstate • Optometry • Empire State • Adirondack • Columbia Greene • Corning • Hudson Valley • Tompkins Cortland

21. Remainder of Year 4 • Stony Brook • Canton • Jefferson • Brockport • Genesee • Buffalo State • Niagara • Westchester (December audit) • Alfred (December audit) • Jamestown (December audit)

22. Program Year 5 2006 Audit Dates • February Utica Rome, Herkimer, Mohawk Valley • April Fulton Montgomery, Schenectady, Broome • September Oswego, Onondaga, Cayuga • October Geneseo, Finger Lakes • December Morrisville, Oneonta

23. Prevent Recurrence Reported to EPA • Violations and status • Method to remedy • Method to prevent recurrence • Documentation • Inspection Program • Environmental Management System

24. Part II Pilot • System Administration Office of the University Auditor • Pilot Program limited to previously reported items