ENVIRONMENTAL MANAGEMENT SYSTEM

 

 

 

 

Prepared For:

KEAN UNIVERSITY

1000 MORRIS AVENUE

UNION, NEW JERSEY

OFFICE OF FACILITIES AND CAMPUS PLANNING

EDUARDO N. DEL VALLE, R.A., P.P., A.I.C.P.

ASSOCIATE VICE-PRESIDENT

 

 

 

Prepared By:

1373 Broad Street, Suite 301

Clifton, New Jersey 07013

 

 

 

 

 

 

ERL Project Number 08095-02

November 2001

TABLE OF CONTENTS

SECTION PAGE

SECTION 1. INTRODUCTION *

SECTION 2. ADMINISTRATION *

2.1. Policy *

2.2. Coverage *

2.3. Environmental Aspects *

2.4. Administration of Responsibility *

2.4.1. EMS Management Committee *

2.4.2. EMS Audit Team *

2.4.3. Facilities and Campus Planning *

2.4.4. Colleges, Laboratories and Administrative Departments *

2.4.5. Waste Disposal Contractors *

2.4.6. Visitors Students and Contractors *

2.5. Identification and Tracking of Legal Requirements *

2.6. Environmental Objectives and Targets *

2.7. Environmental Management Program *

2.8. Training *

2.8.1. Contents *

2.8.2. Visitors *

2.8.3. Record keeping *

2.9. Controlling the EMS Manual *

2.10. Monitor of Operations for Environmental Areas of Concern *

2.11. Non-Conformance *

2.12. Record-keeping Requirements *

2.13. EMS Audits *

2.13.1. EMS Audit Procedures *

2.14. Annual Review of the EMS Manual *

SECTION 3. AIR EMISSIONS *

SECTION 4. UNDERGROUND STORAGE TANKS *

SECTION 5. HAZARDOUS MATERIALS *

5.1. Facilities and Campus Planning *

5.2. Colleges and Laboratories *

5.3. Pool Area and Athletic Facilities *

5.4. Health Services *

5.5. Other Administrative Offices (Purchasing/Warehouse, Campus Police, Computer Services) *

SECTION 6. SOLID AND HAZARDOUS WASTE *

6.1. F&CP Waste *

6.2. Laboratory Waste *

6.3. Biomedical Waste *

6.4. Hazardous Waste *

6.5. Universal Waste *

6.6. Radioactive Material *

6.7. Recordkeeping *

SECTION 7. WATER AND WASTEWATER *

 

FIGURES

FIGURE 1 EMS Organization Chart

 

APPENDICES

Appendix A Standard Operating Procedures

Appendix B Objective and Target Reporting Forms

Appendix C Training Matrix and Training Tracking

Appendix D Environmental Management System Audit (links to a printable pdf form)

 

INTRODUCTION

Kean University (Kean) retained Environmental Risk Limited (ERL) to develop an Environmental Management System (EMS) that will provide a mechanism for effective management and control of the practices and procedures that ensure compliance with applicable State and Federal environmental laws and regulations, and reduce environmental impacts. As required by Kean, the EMS has been specially customized using the ISO 14001 standards, the U.S. Environmental Protection Agency (USEPA), and the New Jersey Department of Environmental Protection (NJDEP) Silver and Gold Track Environmental Performance Guidelines, and the best management practices for operations and activities specific to Kean.

The USEPA recently made environmental compliance at colleges and universities a major focus of its environmental enforcement programs. As part of the regulated community, it is important that colleges and universities are aware that EPA holds educational institutions to the same high environmental compliance standards expected of private industry. In fact, EPA expects colleges and universities to be role models for environmental behavior. Kean has taken a pro-active approach to perform a self-evaluation and develop an EMS. As a first step, a comprehensive "Environmental Compliance Audit (ECA)" of Kean's facilities was completed in December 2000 to evaluate the compliance status. Following the ECA, a Gap Analysis was also conducted to evaluate the existing environmental practices with respect to the ISO 14001 Standards.

An EMS is generally a tool for an organization to keep aware of the interactions that its products and activities have with the environment, and to achieve and continuously improve a desired level of environmental performance. It is designed to continuously identify and reduce the environmental harm (impacts) created by the activities, services, and products at a facility. Critical elements of Kean’s EMS include clear definition of the organization's environmental policy, which is founded on shared vision, commitment, and goals and targets; planning; implementation and operation; monitoring and corrective actions; and management review. Based on the findings of the ECA, planning considers the means to identify actual and potential environmental impacts from products, practices, and processes, and considers significant impacts in setting its objects and goals, as well as, regulatory and financial requirements. It also clearly defines institutional roles and responsibilities, describes how the goals are to be met, and specifies the audit and improvement procedures.

The implementation and operations play a critical role in achieving goals of an EMS and require development of detailed operating procedures that must be systematically followed (and improved with changing conditions) to ensure reduction of impacts to the environment and potential health exposures. Therefore, the EMS includes SOPs for specific operations and activities at Kean to aid in meeting the primary objectives of the EMS. The EMS Manual is a "living, breathing document," in the sense that it grows and changes as the need arises. The EMS requires careful monitoring and measurements, establishment of controls and making modifications, as necessary. In addition, the implementation of Kean's Spill Prevention Countermeasure and Containment (SPCC) Plan, and a Chemical Hygiene Plan will aid in achieving the goals of the EMS.

Section 2 Administration, includes Kean’s environmental policy, coverage, identification of environmental aspects, legal and other requirements, definitions of roles and responsibilities, record keeping, audit and annual review. Section 3 discusses Air Emissions, Section 4 discusses Underground Storage Tanks; Section 5 discusses Hazardous Materials; Section 6 discusses Solid and Hazardous Waste, and Section 7 discusses Water and Wastewater. The Standard Operating Procedures (SOPs) for significant environmental activities and operations are provided in Appendix A.

 

 

ADMINISTRATION

Policy

Kean is committed to the environmental policy and procedures outlined in this EMS as well as to comply with all applicable regulations, waste minimization, risk reduction, and continual improvement of the EMS. Implementation of this program will be through an EMS Management Organization that will be headed by Mr. Eduardo N. del Valle, R.A., P.P, A.I.C.P., Associate Vice President for Facilities and Campus Planning (F&CP) who will serve as the EMS Manager. Although the EMS organization will primarily consist of F&CP Staff, Deans of Schools, Department Chairpersons, Faculty and Staff Members, Students, Aides and Researchers, the responsibility of implementation will be shared by everyone at the campus. Understanding of this concept is critical to the success of the EMS.

The following policy represents the shared vision and commitment of Kean:

"Kean University (Kean) is committed to continual improvement of its Environmental Management System (EMS), which includes waste minimization, the prevention of pollution and compliance with all relevant and applicable federal and state environmental legislation and regulations. Kean will meet and adhere to all applicable environmental requirements promulgated by federal and state agencies and authorities. To sustain this commitment, the requirements of the Environmental Management System described in this Manual apply to all activities, equipment, materials and employees.

Mr. Eduardo N. del Valle, R.A., P.P, A.I.C.P., Associate Vice President for Facilities and Campus Planning is assigned as Kean’s Environmental Compliance Officer and the EMS Management Representative. This individual has the responsibility and authority to plan, enforce and maintain Kean’s Environmental Management System. This responsibility also includes stoppage of activities that deviate from the requirements of the EMS Manual. The Environmental Compliance Office, with the assistance of the Environmental Task Group, will propose annual targets and objectives to be approved by the President’s Council.

The EMS Management Representative may delegate some of his authority through the organization in order to effectively implement the system".

Eduardo N. del Valle, R.A., P.P, A.I.C.P.
Associate Vice President for Facilities and Campus Planning
EMS Manager

 

 

Coverage

To sustain the commitment of Kean's environmental policy, the requirements of the EMS described in this document apply to all activities, equipment, materials and employees, specifically to all F&CP personnel, Deans of Schools, Department Chairpersons, Faculty and Staff Members, Students and Aides, Researchers, Laboratory Technicians and outside contractors.

Primarily, the EMS covers the management of the following environmental aspects:

The departments covered under this plan include the following:

 

 

Environmental Aspects

Operations and activities conducted at Kean are primarily of an academic nature. However, activities in various laboratories (chemical, biological, radiological, and photographic), health services, athletic activities, and operations and maintenance of campus facilities entail handling of chemicals and generation of wastes. Some of these activities require the delivery, storage, and use of hazardous materials, the generation of hazardous wastes, and the release of pollutants to the media (e.g. air emissions). The "environmental aspects" are those operations and activities at Kean that have the potential to impact the environment if not managed properly and in compliance with the applicable rules and regulations. Table 1 summarizes Kean's current environmental aspects, sources, associated controls and monitoring/measurements.

The key environmental aspects of Kean are as follows:

 

 

Administration of Responsibility

To fully implement the EMS, the assistance and cooperation of all Kean faculties, staff, and students are necessary. The Kean EMS Organization Chart is presented in Figure 1. Table 2 presents a summary of roles and responsibilities of key members of the EMS team. Mr. Eduardo N. del Valle, R.A., P.P., A.I.C.P., Associate Vice President for F&CP will serve as EMS Manager and will report to the President and Board of Trustees in the area of environmental management. He will be assisted by members of both F&CP and colleges. Based on the operations and practices at Kean, primarily the staff members of the F&CP are responsible for most of the environmental activities except those that are related to various colleges, laboratories and studios. The management of chemicals, hazardous materials used and wastes generated from various laboratories and studios, are primarily the responsibility of the Dean of each College. The Dean of each College will be assisted by the Department Chairperson, Chemical Hygiene Officer, laboratory technicians and student aides. At Kean, the following three colleges have environmental activities:

An EMS Management Committee will also assist the EMS Manager and EMS Audit Team as described in the following Sections 2.4.1 and 2.42.

EMS Management Committee

The EMS Management Committee (the "Committee") will consist of selected key senior members shown in Figure 1, EMS Organization Chart. The Committee will be chaired by individual(s) appointed by the EMS Manager. At a minimum from each college, it will include the Dean, Department Chairperson, Chemical Hygiene Officer and from the F&CP, the Chief Maintenance Engineer. The primary function of the Committee will be to ensure the implementation and continual improvement of the EMS consistent with the environmental policy as well as to establish objectives and targets. The Committee will ensure Kean’s compliance with federal, state, and local regulations and best management practices (BMPs). The Committee is to provide technical guidance, resources, and support in the implementation of the EMS and in the development and introduction of any corrective measures to ensure continual improvement. The Committee will have the authority to make recommendations to revise the EMS plan on the basis of changing conditions and to enforce the SOPs. The Committee members must be fully acclimated to the environmental aspects and the legal requirements concerning the regulated materials at Kean. The Committee may seek assistance from the outside environmental consultant(s) and will prepare and submit Annual Progress Reports to the EMS Manager, who in turn will present such reports along with corrective action recommendations and requirements of financial and personnel resources, if so needed, to the Management Review Panel (MRP).

The MRP will consist of the Board of Trustees, Building, Finance and Audit Committee, senior level administrators including the President of Kean, the University’s Deputy Attorney General, and the Vice President for Administration and Finance. The MRP’s mission is to review and provide support to the EMS Manager in meeting his commitments to implement the EMS and ensuring its continual improvement in the area of environmental compliance.

EMS Audit Team

The EMS Audit Team will consist of a Lead Auditor, two members from the EMS Organization, and one from an outside environmental consulting firm. The audit team will not include the EMS Manager but will include a senior member from the F&CP and a senior member from one of the colleges. The function of the audit team will be to conduct audit in described Section 2.15, prepare a report and submit to the EMS Manager.

Facilities and Campus Planning

Facilities and Campus Planning is the lead department at Kean for the implementation of the EMS Plan. In addition to managing all activities under F&CP, it will coordinate and oversee the implementation of EMS at applicable colleges and University departments throughout the two Campuses and be responsible for centralizing the records of the EMS implementation, hazardous materials usage and disposal of wastes. The roles and responsibilities of key personnel are summarized in Table 2 and also discussed below.

The primary responsibilities of F&CP are as follows:

In addition the F&CP personnel will perform the following functions:

Colleges, Laboratories and Administrative Departments

Each of the colleges and its departments, as well as all administrative departments, where hazardous materials are used, handled, or stored, and where chemical/hazardous waste is generated is responsible for the implementation of the EMS. The overall responsibility for the EMS implementation, at the colleges level, will be with the Dean of each college, who, under the supervision of the EMS Manager, will be assisted by Department Chairpersons, Chemical Hygiene Officers, faculty, laboratory technicians, and students. In the case of administrative departments, the Director shall be responsible for implementation of the EMS under the supervision of the EMS Manager. The roles and responsibilities of the key members are summarized in Table 2 and also described in the following.

Key responsibilities of each college and administrative department include:

Waste Disposal Contractors

The waste contractors providing services to Kean will perform the following duties in regards to this EMS:

Visitors Students and Contractors

Visitors of laboratories, students at Kean, who use hazardous materials and/or generate hazardous waste, and all contractors who work in laboratories need to be aware of this EMS and comply with Kean's policies and procedures.

Identification and Tracking of Legal Requirements

  1. The primary source for rules and regulations regarding compliance are state and federal government agencies. Rules and regulations, as well as updates such as the Federal Register are available in both hardcopy and electronic format. The EMS Managers office will be responsible for the tracking of legal requirements applicable to the management of hazardous materials and wastes through a variety of means including journals, newsletters, the Internet (in particular USEPA and NJDEP websites), and professional associations. Table 3 summarizes both federal and state regulations and their sources:

    At least once per month, a designated staff from the EMS Manager's Office will perform a search of one or more of these resources in order to determine if there have been any changes in regulatory requirements. Any changes found that are applicable to the plan will be taken into account in the review process as outlined in Section 1.10 and an update will be communicated to the applicable operations/activities. Periodic memorandums will be sent to the relevant colleges, laboratories, and administrative departments to provide update on regulations.

    link to Figure 1 Organizational Chart

    TABLE 2 Roles and Responsibilities

    Staff Member Title Roles and Responsibilities Environmental Aspect
    F & CP    
    Alonso Losada

    Ken Kimble

    		 Associate Director F&CP

    Chief Engineer
    • Maintaining all permits for paint shop and other trade shops
    • Designation of satellite storage areas
    • Disposal of wastes
    • Regular replacement of spent solvents for parts washer
    • Proper storage and disposal of fluorescent light bulbs
    • Segregation of batteries, switches, bulbs, and pesticides
    • Management of universal waste (SOP #KU011 and KU014)
    • Maintain rolling monthly fuel use logs
    • Operation and maintenance, including periodic testing, of CEMS
    • Liaison with NJDEP officials and environmental consultants
    • Conduct periodic inventory of insignificant sources
    • Oversee continuous monitoring of opacity of emissions
    • Title V compliance plan obligations
    • Ensure all applicable SOPs are followed
    • Maintenance of leak detection system
    • Monitor surface water discharges
    • Train employees in proper techniques
    • Adherence and periodic review of SPCC Plan
    • Supervise cleanup activities in the event of a spill
    • Regular inspection of storage containers and storage areas for leaks or spills
    • Monitoring of blowdown water for toxic conditions (metals, pH, etc)
    • Record-keeping of inventory and usage (rolling fuel use log), and fuel delivery manifests
    • Monitor wastewater accumulation and discharge
    • Monitor wastewater characteristics
    • Record-keeping of wastewater discharges
    		Air Emissions

    Underground Storage Tanks

    Waste Oil

    Boilers

    Petroleum Chemical storage area
    Sheryl M. Fornoff Associate Director for Environmental Health and Safety
    • Maintenance of MSDS' and environmental compliance records
    • Liaison with NJDEP officials and environmental consultants
    • Inspection and labeling of containers, including container integrity
    • Maintenance of storage area (spill prevention, floor drain containment, spill reporting)
    • Ensure all applicable EMS SOPs are adhered to
    • Quality assurance review of all EMS requirements
    • Manage environmental safety and health training program
    • Regular inspection and audits to ensure compliance with EMS requirements
    • Inspection of labels and container integrity
    • Record-keeping of disposal manifests, waste generation logs, accumulation times, and hazardous waste inspectors
    • Awareness training for waste management
    • Record-keeping of waste manifests, waste inventories, and disposal dates/times
    		Chemical Storage

    Industrial Hygiene

    Spill Prevention

    Hazardous Waste
    LABORATORIES    
    Dr. Betty Barber

    Dr. Ron Criasia

    		 Dean, College of Natural, Applied and Health Sciences

    Chairperson, Chemistry & Physics
    • Designation of and security of hazardous waste satellite storage areas
    • Disposal of all related waste
    • Establish environmental goals and targets
    • Inspection of all containers and labels
    • Performance appraisals for subordinates with hands-on hazardous waste handling responsibilities
    • Updating of CRTK information (MSDS, etc)
    • Liaison with Emergency Responders in the event of a HW spill
    • Record-keeping of disposal manifests, waste generation logs, accumulation times, and authorized personnel (hazardous waste inspectors, etc)
    • Arrange awareness training for waste management
    • Generate and follow lab pack program
    • Oversee waste segregation by compatibility
    • Ensure all SOPs (SOP #KU014, KU018, KU020) for laboratory waste are followed
    		Hazardous Waste

    Spill Prevention

    Biomedical Waste
    Dr. Denise Mancarella

    Cathleen M. Londino

    		 Chairperson Biology Department

    Interim Dean, College of Arts, Humanities & Social Sciences
    • Enforcement of applicable laboratory SOPs (SOP # KU020 and KU021)
    • Training to segregate biological waste from laboratory non-hazardous waste
    • Maintenance of laboratory waste/materials storage areas
    • Storage of substances by compatibility
    • Inspection of containers and labels
    • Coordination of OSHA 29 CFR 1910.120 (Hazardous Waste Operations) and hazardous materials awareness/management training for staff members
    • Compliance with OSHA 29 CFR 1910.1030
    • Record-keeping of waste discharges
    • Maintenance of storage area (spill prevention, floor drain containment, spill reporting)
    • Record-keeping of rolling supply inventory, manifests of delivery of supplies
    • Designate satellite storage areas
    • Establish environmental goals and targets
    • Inspection of labels and container integrity
    • Semi-annual disposal of hazardous waste
    • Monitoring of photographic liquid waste
    • Record-keeping of disposal manifests, accumulation times, and assignment of hazardous waste inspectors
    • Monitor wastewater characteristics (e.g. silver nitrate disposal)
    • Record-keeping of wastewater accumulation and discharge amounts
    • Storage of chemicals by compatibility
    • Maintenance of storage area (spill prevention, floor drain containment, spill reporting)
    • Designation of segregated storage areas
    • Record-keeping of supply inventory, manifests of supply deliveries
    • Designation and maintenance of segregated supply area
    		Laboratory Chemical Storage

    Chemical Storage

    Housekeeping

    Hazardous Waste Fine Arts

    Fine Arts Wastewater

    Industrial Arts Chemical Storage
    UNIVERSITY SERVICES
    		    
    George Thorn Director of Purchasing and Warehouse
    • Continue regular grease trap service
    • Management of recycling program for used cooking oil
    • Record-keeping for every maintenance of grease trap and manifest for waste disposal
    • Monitoring of grease trap integrity
    • Designation of segregated storage areas
    		Cafeteria Universal Waste
    Glen Hedden Director of Athletics and Recreation
    • Monitoring of swimming pool wastewater discharge (surface and sanitary)
    • Record keeping of all swimming pool maintenance activities
    		Wastewater – Athletics & Recreation Areas
    Ann Marie Hummel Director Health Services
    • Record keeping of waste disposal manifests
    • Integrate environmental compliance into performance appraisals
    • Monitoring of storage area, container integrity, and container labels
    • Ensure proper segregation, ventilation, and pest control of storage area
    • Ensure proper handling and disposal of waste (SOP # KU020 & KU021)
    • Coordination of OSHA “Bloodborne Pathogens” training for staff members
    • Establish environmental goals and objectives
    		Biomedical Waste – Health Services

    Chemical Storage

    Joe Marinello Director of Computer and Information Services
    • Record keeping of computer monitors and CPU waste, including disposal manifests, storage area conditions, and authorized personnel
    • Ensure proper management and disposal of universal waste
    		Universal waste – IT Department
    Cy Hardy Director of Campus Police
    • Coordination of OSHA “Bloodborne Pathogens” training for staff
    		 

    Table 3

    Identification and Tracking of Legal Requirements

    USEPA Regulations
    Regulation Contact/Internet Address Description
    42 CFR 103 George Zachos – Superfund Ombudsman (EPA Region 2)

    888-283-7626

    		 A question and answer page about the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986. Currently, Kean does not fall under the jurisdiction of CERCLA.
    40 CFR 302.4 Pollution Prevention Information Clearinghouse (PPIC)

    202-260-1023

    		 “Designation of Hazardous Substances” – describes the regulations regarding the declaration of a substance as hazardous and the Release Reporting Regulations concerning releases of said substances into the environment.
    40 CFR 112 USEPA Oil Spill Program Hotline

    1-800-424-9346

    		Spill Prevention Countermeasure and Control (SPCC) Plan regarding the controlling and prevention of petroleum releases from USTs or other petroleum storage areas.
    49 CFR 20 Pollution Prevention Information Clearinghouse (PPIC)

    202-260-1023

    		 National Oil and Hazardous Substances Pollution Contingency Plan – The requirements for reporting and controlling hazardous substance and petroleum product releases as promulgated under CERCLA.
    40 CFR 260-262 NJDEP Bureau of Emergency Response

    Phone: (609) 633-2168Fax: (609) 633-1454

    		 RCRA regulations regarding health and safety when handling hazardous waste and materials.
    42 CFR 72.6 Center for Disease Control FAQ Hotline

    1-800-311-3435

    		 Summary and explanation of the federal “Interstate Shipment of Etiologic Agents” standard, explaining the regulations regarding packaging, handling, and shipment of biomedical waste.
    40 CFR 240-299 RCRA Hotline

    (800) 424-9346

    		Information page regarding the Resource Conservation and Recovery Act (RCRA) of 1976. Kean is listed as a Conditionally Exempt Small Quantity Generator of regulated hazardous waste (EPA ID No. NJD981560352).
    40 CFR 261 RCRA Hotline

    (800) 424-9346

    		 Classification of hazardous waste as designated by RCRA
    40 CFR 273 RCRA Hotline

    (800) 424-9346

    		 Universal Waste Rule – Under RCRA, this section governs universal wastes (discarded computer monitors, CPUs, fluorescent light bulbs, capacitors, ballasts, etc). Both summaries of the rule and documents (including the rule itself) are included in this website.
    33 USC 1251 et.seq Surya Shah

    Bureau of Point Source Permitting

    (609) 292-4860

    		 Information regarding Kean's NPDES permit (NJ0128589) and regulations regarding discharges to surface water in New Jersey under the Federal Clean Water Act.
    42 U.S.C. 2011–2259 NRC Switchboard

    1-800-368-5642

    		 Atomic Energy Act of 1954 – handling and licensing of radioactive material.

    Table 3

    Identification and Tracking of Legal Requirements, cont.

New Jersey Regulations
Regulation Contact/Internet Address Description
NJAC 7:14B NJDEP Bureau of USTs Hotline

800-424-9346

 “Underground Storage of Hazardous Substances” – regulations from the NJDEP regarding USTs and substances stored within USTs.
NJAC 7:27-22 Thomas Hanna – NJDEP

(609) 777-0129

 Title V Air Permits – a step-by-step guide for submitting Title V Air Permits, as well as special topics regarding the Clean Air Act (created by NJPIRG)
NJAC 7:27-8 Thomas Hanna – NJDEP

(609) 777-0129

 The requirements for air quality permitting for “minor facilities.” Kean is considered to be a minor facility for all pollutants except NOx, for which it is considered a “major facility.”
NJAC 7:27-21 Thomas Hanna – NJDEP

(609) 777-0129

 Regulations on how to create emissions statements. The emission statement threshold levels for Kean have been established at 100 tons per year for CO, SO2, TSP and PM-10, 25 tons per year for NOx, 10 tons per year for VOC and 5 tons per year for lead.
NJAC 7:27-5 Thomas Hanna – NJDEP

(609) 777-0129

 Visible Emissions Limited – regulations regarding emissions of substances, including opacity and concentration
NJAC 7:26A-7 Tom Sherman

Office of Permitting & Technical Programs(609) 984-5950

 Information from the Division of Solid and Hazardous Waste of the NJDEP regarding recycling of solid and hazardous waste. The actual recycling regulations for the State of New Jersey can be found at
NJAC 7:14A-1.1 Surya Shah

Bureau of Point Source Permitting

(609) 292-4860

 Regulations and information from the NJDEP Division of Water Quality regarding swimming pool discharges.
NJAC 7:26E Al Kaczoroski, Assistant Director

Discharge Response Element

(609) 633-0708

Regulations for Technical Requirements for Site Remediation
NJAC 7:26G Frank Coolick

NJDEP Division of Solid and Hazardous Waste

(609) 633-1418

 Regulations for Solid and Hazardous Waste, including handling, storage, and transport.
NJAC 7:26-3 Frank Coolick

NJDEP Division of Solid and Hazardous Waste

(609) 633-1418

 “Comprehensive Regulated Medical Waste Management Act” of March 1989, which details management and handling of medical waste. This is also covered under the NJDEP Division of Solid and Hazardous Waste

 

Environmental Objectives and Targets

ISO 14001 defines an environmental objective as an "overall environmental goal arising from the environmental policy that an organization sets itself to achieve, and which is quantified where practicable." ISO 14001 goes on to define an environmental target as a "detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives." The implementation of environmental objectives and targets by Kean will promulgate a multi-faceted approach to environmental impact reduction and pollution prevention.

Kean will review and update environmental objectives and targets important to the goals of Kean, to student education, and in support of research according to its environmental policy (see section 1.1). Appendix B contains some of the Objectives and Target reporting Forms for use. Mr. Eduardo N. del Valle will function as the facilitator for all objectives and targets agreed upon by the EMS Committee.

In setting objectives, the following ideas will be considered:

Departmental Input: Each department head and relevant F&CP employees will first be responsible for providing input regarding current operations and activities, strengths and weaknesses with current operations, and suggestions for improvements in operations or the improvement of current pollution prevention controls. The input will be based on the following considerations:

Each member will fill out an "Objective Review Form" detailing their suggestion(s) and from which of the above sources the suggestion was formulated. Once completed, this form will be sent to the EMS Manager for review.

Orientation Meeting: Upon review of the Objective Review Forms, the EMS Manager or a designee, will schedule a meeting with the EMS Committee to review existing or generate new objectives and goals for the new school year. The objectives and goals may be action- and prevention-oriented, designed to implement environmental controls to minimize impact and enhance existing environmental controls to further reduce exposure.

Some objectives may include:

Feedback: After a roundtable discussion, the suggested objectives and targets will be presented to the EMS Manager for further discussion and evaluation, including adherence to current legal requirements, consistency with Kean’s environmental policy, and projected effectiveness in maximizing pollution prevention and minimizing environmental impact. Based on review comments from the EMS Manager, the EMS Committee, and other interested parties, the objectives will be finalized and communicated in writing to all Kean personnel in every department covered under this EMS manual. The EMS Manager shall distribute and promulgate Kean’s environmental objectives and targets.

Tracking Progress: Once the objectives and targets have been formalized, each Dean of College and his/her staff will be responsible for meeting the objectives and targets within the proposed time frame. Status of objectives and targets will be tracked via a Checklist (see Appendix B) that will be available for public scrutiny by all members of the departments covered in this EMS manual. Regular quarterly progress reports will be presented to the EMS Manager by the first week of each quarter. A final year-end progress report will also be generated by each college and F&CP leader and an "end-of-the-year" conference will be held to review the performance with regards to achieving the objectives and targets. This information will be used as input for the designation of new or expansion of existing objectives and targets for the upcoming year.

Environmental Management Program

The EMS Manager will be responsible for implementing, reviewing and making necessary changes in the Environmental Management Program based upon changing environmental conditions and objectives. The EMS Manager will present any revisions to the program to all participants. He will also establish new responsibilities to the EMS member staff on the basis of revisions and new targets.

For the first year of this plan, the goal is to properly implement the EMS plan at Kean. Since the EMS Manual is a "living and breathing" document, the EMS Committee shall make changes to adjust to compliance measures based on new regulations, materials and units, including modifications of existing SOPs. Any student, faculty, staff member, or other interested party may provide suggestions to the improvement of the EMS plan to the EMS Committee. However, the EMS Manager will have the final authority concerning any modifications to the Manual.

Training

The office of the EMS Manager will be responsible for providing the initial orientation of the environmental policy, targets and objectives, SOPs, and the EMS Manual to all participants of the EMS plan including F&CP staff, Dean of Colleges, Chairpersons, students, faculty and staff. Following the orientation, a training program will be implemented on a periodic basis. Sample Training Matrix and Tracking guidelines and forms are provided in Appendix C. Generally the refresher training will occur on a bi-annual basis. Any modifications and/or revisions to the existing SOPs, targets and goals, and the EMS plan due to changes in the environmental practices, use of materials, or driven by environmental regulations will be communicated either via memorandums or training classes.

For students, faculty and staff working in laboratories, EMS training is typically conducted along with Chemical Hygiene Plan training. Currently, F&CP provide this training several times throughout the year, during both semesters and summer sessions. Other information will be provided on an on-going basis through informational pamphlets for new employees, informal discussions, newsletters, memorandums and publication of material.

  1. Contents

Information provided to students, faculty and staff will cover:

In addition, the training for students, faculty and staff of various colleges will include the following information:

  1. Visitors

Visitors, such as on-site contractors, visiting scientists, or environmental vendors that require information and training under this EMS Plan should be informed of the availability of this program. Individuals responsible for a laboratory will provide information to visitors. The Office of the EMS Manager will be available to conduct more intensive training for these groups, as deemed necessary. Visitors will require information if they generate or handle waste in a Kean laboratory or classroom. This includes all current waste contractors.

  1. Record keeping

Training materials are to be kept on file at the Office of the EMS Manager as well as the relevant department. The records will include but not limited to the training records such as, the agenda, materials used in training, the name of the instructor, the attendees, the date, and the location. Each College will maintain a list of the faculty and their laboratories or classes (identified by Building and Room number). A copy of this list shall be forwarded to the Office of the EMS Manager on a bi-annual basis or whenever a change occurs.

Controlling the EMS Manual

The EMS Manual will be located in the Office of the EMS Manager, who is in-charge of controlling the document. The EMS Manager's office will distribute the appropriate SOPs that apply to the specific colleges/departments. Each college will distribute the applicable SOPs to the Department Chairperson, faculty, students, and staff, as deemed necessary. Copies of the complete EMS Manual will remain with the Office of the Dean and the Department Chairperson, and in the classroom or area of environmental concern, and cannot be copied or removed without authorization from the Dean of the College or Department Chairperson. It is imperative that strict adherence to this procedure be enforced, and unauthorized copies are not circulated.

The Office of the EMS Manager may publish the EMS Manual on-line but only in an "html" or "pdf" format. It shall include the date of publication of the EMS Manual and the format of the document shall be stored in a "read only" access file to prevent any changes to the wording of the Manual.

The EMS Manager's Office shall monitor all copies of the SOPs and their locations. A "Document Request Form" should be developed in order to track the distribution of the copies of the EMS Manual or any part thereof. This form should be kept under the control of the document control manager located in the EMS Manager's Office. In the event that changes are made to an SOP or to any part of the manual while an individual has a predated copy, that individual should be notified of the changes immediately. Departments shall also monitor the their own copies of the SOPs. If there is a change made to a SOP, EMS Manager's Office shall communicate those changes to the relevant college.

Monitor of Operations for Environmental Areas of Concern

Selected staff from the EMS Manager's Office will perform periodic inspections of areas of concern (AOCs). For colleges, these will consist of formal reviews of each class or laboratory’s conformance with policies and procedures stated in the relevant SOPs. Inspections may be unannounced but may include Department Chairperson and/or faculty members during inspections of their work areas. Each department can also do an internal inspection for compliance with the SOPs. A checklist for EMS Inspection (Form B002) is provided in Appendix B. Following each inspection, a written inspection report will be prepared and presented to EMS Manager with a copy to the college/department inspected.

A copy of the completed "EMS Inspection Checklist" will also be sent to the Dean of the College and Department Chairperson for their record and for addressing any issues. The Department Chairperson shall identify who will take and document required corrective actions on the checklist and send a copy of that document to the EMS Manager's Office.

Non-Conformance

If it is determined that there are issues of non-conformance with EMS in the class, laboratory, or other area, corrective action in accordance with the EMS Manual shall be taken immediately by students, faculty and/or staff. Necessary corrections are to be made as soon as possible after notification. A signed copy of the EMS Audit Findings Form (see Form D003 in Appendix D) and the actions taken must be given to the Office of the EMS Manger within 30 days of receipt.

If the same non-compliance issue is noted after a second inspection, and is considered to be significant in the professional judgement of EMS Manager's Office, the Dean of the College will also be notified in writing within 30 days of the second inspection. If the same non-compliance issues remain during the third inspection, the non-conformance issue will be discussed in the EMS Management Committee meeting.

In cases of imminent and substantial danger to life, health or the environment, the EMS Manager or a designee is authorized to order the cessation of hazardous activity in the class until the danger from such a condition is abated or adequate protective measures have been taken.

Record-keeping Requirements

Documents to be maintained at Office of the EMS Manger include the following:

Records to be maintained in Department offices, individual classes and the EMS Manager’s office include:

Records shall be kept for five years in accordance with other legal/regulatory/Kean requirements as they apply.

EMS Audits

The purpose of an EMS Audit is to ensure the proper implementation and maintenance of the EMS and to ensure that documented procedures are being followed and relevant corrective actions are taken whenever necessary. This audit should have a wide scope, and be conducted with the assistance from an external environmental professional.

EMS Audits are conducted annually, and typically conducted by a trained auditor or an audit team. For Kean the recommended audit will consist of two senior members from the colleges, one senior member from the F&CP and one from an outside environmental consulting firm. The EMS Manager will not be a part of the audit team. The Lead Auditor will either be the outside consultant to conduct an uninfluenced audit. The primary responsibilities of the Lead Auditor will include:

The audit team member from the F&CP will closely work with the Lead Auditor in coordinating, scheduling and maintaining corrective action database. The primary responsibilities of this individual will include the following:

  1. EMS Audit Procedures

Audit Team Orientation: Once team members have been selected, an Audit Team Orientation should be conducted. Team members should review the relevant historical and current departmental information, previous audit reports, current SOPs, updated regulatory requirements. The team members will also be advised of any modifications in the EMS due to changes in the environmental regulations and/or environmental practices at Kean.

Prior Audit Notification: Prior to conducting the audit, the audit team may decide to notify the appropriate Kean Departments in advance. The audit team member from the F&CP will coordinate the notification and scheduling. The audit team may decide to conduct unannounced inspections, in which case the Deans of the Colleges, Department Chairperson, and Chief Engineer of the F&CP will be notified at least one week in advance.

Conducting the Audit: The audit team will use the audit forms and guidelines provided in Appendix D. The following key points must be followed when conducting an EMS audit:

Post-Audit Conference: Once the EMS audit has been completed, the Lead Auditor, and all members of the audit team will meet in a Post-Audit Conference to discuss the individual findings, conclusions, and recommendations for each department that has been audited. Clarifications of any potential misunderstandings will be introduced so that all parties are familiar with the audit findings. Once a general consensus on all audit findings and corrective actions has been reached, all audit findings will be handed over to the Lead Auditor, who will then prepare the EMS Audit Report with the assistance of the team members. The audit team may share the audit findings with the respective Department Chairperson during the audit, specifically if there are issues that need corrective measures.

Reporting Audit Results: The audit report will consist of two distinct sections. The first section will summarize the audit scope, identify members of the audit team, describe the sources of evidence used in conducting the audit (e.g. employee interviews, document reviews, auditor observations, etc), provide the status of any previous recommendations/corrective measures, and summarize the audit results. The second section of the report will include the Corrective Action Findings/Recommendations.

The Office of the EMS Manager will be responsible for the distribution and control of the Audit Report and for communicating the results of the audit to applicable personnel (Kean President, Deans of Colleges, Department Chairpersons, Directors, Supervisors, EMS Management Committee, and Management Review Panel). The EMS Manager's office will also be responsible for the coordination, implementation, and tracking of the recommended corrective measures. The main audit report will be kept on file with the EMS Manager.

Statute of Limitations: The EMS Audit Report and Corrective Action Database will be retained for at least two (2) years from the date of the audit’s completion by the Office of the EMS Manager.

Annual Review of the EMS Manual

The EMS Manual shall be reviewed annually by F&CP to ensure its continued accuracy, suitability, adequacy and effectiveness. This review may include, but not be limited to, examination of monitoring and measuring information, performance data assessment and audit results, and other relevant information and data. In addition, each department will be given the opportunity to review and comment. F&CP will bring proposed major revisions to the Committee for review. F&CP can make minor changes to the EMS Manual as necessary. The updated version of the EMS Manual will be maintained on the web. Departments that have SOPs shall be notified of any changes to the EMS Manual. The purpose of the management review is to assess the in place controls, systems, efficiency and accessibility of the EMS program. Annually, senior management is to have a roundtable meeting to discuss whether or not the EMS program is meeting its stated goals, what deficiencies have been reported as part of the audit program, and what actions need to be taken (and have been taken) in order to correct any of those deficiencies.

The EMS program should add value to Kean's operations. If there are indications that some of the areas of the EMS program are not adding value, either in environmental compliance, environmental protection, cost savings, or employee safety, these areas should be scrutinized and if found to be unnecessary, eliminated from the program. All management review meetings should have minutes and an agreed upon mailing list for internal communication purposes. Meeting minutes should be included in the document control room. The management review team should take this opportunity to:

 

The management review team may find that circumstances have occurred over which they have no control that had an effect on the EMS. Typically these factors may include (but are not limited to):

 

AIR EMISSIONS

Kean currently operates a 1.2 MW Solar steam cogeneration unit containing a natural gas-fueled turbine, dual oil/natural gas-fueled turbine, and duct burner, with a Heat Recovery Steam Generator at its Main Campus. Kean also maintains three 25.106 million BTU per hour (MMBTU/hr) boilers powered primarily by natural gas with an alternate supply of No. 2 fuel oil backup on the Main Campus, and three boilers on the East Campus which are fueled exclusively by No. 2 fuel oil. In addition, there are two boilers in the D’Angola Gymnasium powered by natural gas. The boilers in the gymnasium are not included in Kean's Title V permit, however, due to being significant sources, have individual air permits. The No. 2 oil is used as a fuel source during times when the natural gas service is interrupted.

Kean’s emissions are covered under Title V of the Federal Clean Air Act (40 CFR 70) and state regulations covered under N.J.A.C. 7:27-22. Kean currently has a Title V Operating Permit, No. BOP000002 (Program Interest No. 41735) effective August 16, 1999 with an expiration date of August 16, 2004. Kean has recently submitted a modification to this permit to account for the removal of four oil-fired boilers fueled by No. 6 fuel oil and their replacement with the three 25.106 MMBTU/hr boilers. The permit requires the measurement and monitoring of emissions of total VOCs, NOx, CO, SO2, TSP, and miscellaneous emissions, as well as the secondary emissions of PM10, Lead, and Hazardous Air Pollutants ("HAP"s).

The following procedures regarding the operation of the cogeneration plant are required by F&CP personnel:

A summary of the operations of the cogeneration system is provided in SOP KU004.

Kean also maintains a supply of emergency generators that are categorized as "insignificant sources" under Subchapter 8 (N.J.A.C 7:27-8). It is also required under N.J.A.C. 7:27-3.5 to perform periodic visual inspections of the emergency generators to monitor visible emissions, opacity, and substances exclusive of condensed water vapor for no more than 10 consecutive seconds. The following procedures regarding the emergency generators are required by F&CP personnel:

A summary of procedures regarding emergency generators is provided in SOP KU010.

Kean is further required to submit an annual Emission Statement (ES) containing total emissions calculated from throughputs for all sources. The ES is due on April 15 of the year following the year being reported. RADIUS electronic submittals are due May 15. A Compliance Certification Report (CCR) is due on the "anniversary date" of the Title V Permit approval by the NJDEP. A quarterly Excess Emissions Report (EER) must also be submitted to the NJDEP one month after the end of each quarter (April 30, July 30, October 30 and January 30). Refer to SOP KU004 for the submittal information. As required by the compliance plan of the Title V permit, the EER must be submitted on a quarterly basis, whether excess emissions occurred or not. In case of exceedence of emissions from the combustion turbine of the cogeneration with the permit limit, an Affirmative Defense Letter (ADL) is required to be submitted to the NJDEP. (See Form KU004-02, SOP KU004 for a sample ADL).

For additional information, refer to the Title V Operating Permit and associated compliance plan.

 

UNDERGROUND STORAGE TANKS

There are currently six active USTs at Kean. All of these USTs were installed in 1999 in accordance with USEPA and NJDEP upgrade requirements and are equipped with double-wall-fiberglass-coated steel and leak detection alarm systems. Two 20,000-gallon No. 2 fuel oil UST, one 10,000-gallon No. 2 fuel oil UST, one 4,000-gallon gasoline UST, and one 1,000-gallon diesel fuel UST are located at the Main Campus. One 10,000-gallon No. 2 fuel oil UST is located at the East Campus. The diesel and gasoline USTs are located along the Facilities and Campus Planning Maintenance Building and are provided with dispenser pumps to fuel Kean vehicles. The three USTs at the Main Campus are also located outside the Maintenance Building and store No. 2 fuel oil as alternate fuel for the gas-fired boilers, and the cogeneration plant. The 10,000-gallon #2 UST at the East Campus is located outside the main building.

Kean’s USTs are registered with the NJDEP Bureau of Underground Storage Tanks (Facility ID No. 0131582 for Main Campus and 0165107 for East Campus) as per the New Jersey regulations for Underground Storage of Hazardous Substances and Petroleum (N.J.A.C. 7:14B). Kean currently has a SPCC Plan for the prevention of spills and releases from its USTs and other petroleum containers as per the Federal SPCC regulations (40 CFR 112). F&CP is responsible for the maintenance of the USTs and for the implementation of the SPCC.

UST systems should be inspected, at a minimum, on a monthly basis, including the leak detection system alarms, vent pipes, fill ports, and overfill catch basins. The fuel dispenser pumps should also be inspected, including aboveground valves and pipelines both inside and outside the F&CP building for the general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. Use the "UST Inspection Checklist" provided as part of SOP KU005, "Underground Storage Tank Records". All records of any inspections made on the UST systems and fuel dispenser pumps shall be maintained on file for no less than three (3) years.

Procedures for filling USTs and for fuel dispensing from the gasoline and diesel fuel pumps are summarized in SOP KU009. All bills of lading for petroleum delivered to Kean, as well as fuel use throughput, for each UST shall be kept on-file to comply both with SPCC record-keeping requirements and the requirements of the Air Emissions Compliance Plan (see Section 5.0). Records for fuel loading from the gasoline and diesel USTs, including date, time, and amount of fuel dispensed, shall also be recorded and kept on file.

Procedures for reporting spills and leak occurrences shall be followed according to the SPCC Plan. Records of all spills, leaks, and inventories of spill cleanup equipment (which should be taken on, at a minimum, a monthly basis) shall be kept in accordance with SOP KU005 and the record-keeping requirements of the SPCC.

The SPCC Coordinator and the EMS Manager shall be responsible for the training of F&CP personnel, as well as all personnel responsible for the USTs, in the following areas:

Additional information regarding training and maintenance of the USTs, as well as preventative measures for controlling spills, releases, leaks, or other potential environmental impacts can be found in the Kean SPCC Plan.

HAZARDOUS MATERIALS

Hazardous materials are present campus-wide, both in storage and in day-to-day use. Material Safety Data Sheets ("MSDS") are to be provided by the manufacturer of the hazardous material and must be made available for employee review at all times. The MSDS for individual chemicals should be consulted for information regarding specific hazards associated with each chemical. All individuals should be made aware of the storage location for the MSDS’, and they should be made available 24 hours per day, 7 days a week.

The handling and management of hazardous materials is covered under the Occupational Safety and Health Administration (OSHA) standards for "Hazardous Waste Operations and Emergency Response" (29 CFR 1910.120), as well as the "Designation of Hazardous Substances" (40 CFR 302) and the "Worker Community Right to Know" (N.J.A.C. 7:1G)

Health and safety of individuals using or storing hazardous materials may reference the Hazard Communication and Chemical Hygiene Plans for information regarding the types of hazardous chemicals that they might come into contact with. Hazards include flammability, toxicity, reactivity, corrosivity, and a number of other characteristics. Many materials pose a combination of threats due to their hazardous characteristics. The appropriate personal protective equipment ("PPE") should be used at all times to prevent unnecessary exposure to any hazardous materials.

Materials that present new hazards to the working environment must have approval, before being introduced, by the Chemical Hygiene Officer ("CHO"). This provides a system of checks and balances to ensure that individuals are provided with the appropriate safety information.

Each department should maintain an inventory of hazardous substances and keep records of approved materials, which include date of approval, approval code of the CHO, and MSDS locations.

Outside contractors working at the Campus and having any potential for exposure to the hazardous materials must be considered affected individuals and, therefore, must be trained by the contracting company in the hazardous materials. Contractors who bring their own hazardous materials on-site must register them with the CHO for approval. This includes electricians, pipe fitters, general contractors, custodial, and any other applicable subcontractor that provides services to Kean. The CHO will then notify any other on-site affected individuals of the presence of the hazard.

In the event that overexposure is a concern, a certified industrial hygienist (CIH) shall perform monitoring to ensure that exposure levels are not exceeded. In the event of a spill of a hazardous material and impending cleanup, the MSDS must be referenced before attempting to address the problem. Emergency response personnel shall have knowledge of the location of all MSDS's and immediate access to them in the event of a spill or release.

Consult the National Institute of Occupational Safety and Health ("NIOSH") Pocket Guide to Chemical Hazards for specific exposure levels to chemicals in the workplace.

The following is a list of University departments and the types of hazardous materials stored and/or used in their facilities:

Facilities and Campus Planning

Affected areas in these departments include a paint shop, repair and maintenance garage, electric and plumbing shops, and grounds shop. These locations may handle the following hazardous materials:

Colleges and Laboratories

Currently, Kean has approximately 50 laboratories as well as studios in the fine arts department and shops and studios in the technology building for industrial arts. Various chemicals on site may include, but are not limited to the following:

Pool Area and Athletic Facilities

Kean maintains athletic and recreational swimming pools in the D'Angola Gymnasium and the East Campus. Chemicals associated with pool maintenance may include chlorine, industrial strength disinfectants, and pesticides and/or other pest control chemicals.

Health Services

Kean's Health Services department provides medical assistance to all Kean personnel and students. Disinfectants and pesticides for biomedical waste storage areas are the most prevalent hazardous substances that may be encountered in the Health Services Department.

Other Administrative Offices (Purchasing/Warehouse, Campus Police, Computer Services)

In each affected department, every hazardous material container is to be properly labeled including phase, name of material, ingredients (with Chemical Abstract numbers included), National Fire Protection Association ("NFPA") hazards and "fire diamond," quantity stored, target organs, handling procedures, and date of purchase. If the vendor does not provide a label identifying these properties, then the MSDS sheet must be consulted for labeling purposes. Contact the CHO for further information if the MSDS is older than two (2) years or is illegible.

Recordkeeping requirements for hazardous materials for such forms as purchase orders, materials use forms, and updated inventories, should include the following:

For more information regarding the handling, storage, and labeling of hazardous materials, consult the Standard Operating Procedures (KU015 through KU018). The Kean Chemical Hygiene Plan and Compatibility Matrix should also be referenced for information regarding hazardous substances and their storage requirements.

SOLID AND HAZARDOUS WASTE

The handling and management of hazardous waste is covered under the USEPA standards for "Resource Conservation Recovery Act" (RCRA, 40 CFR 260 - 262), as well as the "Universal Waste" (40 CFR 273) and the "Hazardous Waste Regulations" (N.J.A.C. 7:26G). Since Kean is not a large quantity generator of hazardous waste, the 90-day storage of hazardous waste does not apply.

Hazardous waste must be handled according to the guidelines set forth in the above cited regulations, including but not limited to the following:

The following is a summary of the various departments and the types of wastes they generate:

F&CP Waste

Wastes generated from F&CP activities include, but are not limited to, spill cleanups, gasoline waste, diesel waste, transmission oil waste, swimming pool maintenance waste, boiler room and universal wastes.

Laboratory Waste

Laboratory wastes are defined as: a hazardous chemical that results from laboratory scale activities and includes the following: excess or unused hazardous chemicals that may or may not be reused, hazardous chemicals determined to be RCRA hazardous waste (see SOP KU016 "Laboratory Chemical Waste Handling" for definitions) and hazardous chemicals that are not RCRA wastes. Therefore, laboratory wastes may be classified as biomedical, RCRA hazardous, regulated, universal, radioactive, or non-hazardous. This includes scientific laboratories as well as photography and fine arts studios. A brief description of each type of waste is provided in the following:

Biomedical Waste

Kean generates biomedical waste from the operations of Health Services and Athletic Department. Kean is registered, under the NJDEP, as a generator of regulated medical waste (ID No. 0158673). The waste is shipped to a number of off-site disposal facilities and is transported, at present, by Environmental Control Co., of Bronx, New York.

All entities (laboratories, gymnasiums, first aid stations, and health offices) that generate biomedical waste are responsible for properly packaging and labeling regulated medical waste for off-site transport, and for completing an approved Medical Waste Tracking Form ("MWTF"). To simplify this requirement, a generator of medical waste is encouraged to identify and segregate biomedical waste from other solid waste at the point of origin within the facility, thus keeping the total amount of biomedical waste to a minimum. In addition, to ensure safe handling and transport within the generating facility, all employees involved with the on-site handling and management of biomedical waste need to be trained in accordance with the requirements of the OSHA Exposure to Bloodborne Pathogens regulations in 29 CFR Part 1910.1030.

The storage of biomedical waste is to comply with applicable regulation by maintaining an area that is designated and clearly labeled with the word "biohazard" or the universal biohazard symbol, that is properly ventilated, located to