Federal Laboratories Integrated Strategy
In October of 2006, EPA's Federal Facilities Enforcement Program embarked upon a national compliance initiative to improve the environmental footprint of Federal laboratories. Past inspections had found Federal laboratories pouring used chemicals into sinks and drains connected to public sewage systems; improperly identifying, storing, handling, and disposing of hazardous wastes; operating their on-site power generators and boilers in ways that violate air pollution requirements; being without adequate spill prevention and emergency response plans, and not having adequate wastewater treatment processes. Below you will find information on EPA Region 2's efforts to improve environmental compliance within the Federal laboratory sector in New York, New Jersey and the Caribbean as well as to encourage the adoption of best management practices and pollution prevention opportunities.
In the Spotlight...
Environmental Compliance Training for Federal Laboratories - FedCenter, the Federal government's home for comprehensive environmental stewardship and compliance assistance information, is now offering web-based, on-demand training courses for Federal employees, including this one to help Federal laboratories comply with environmental requirements and institute good stewardship practices, such as the development of environmetal management systems.
EPA Region 2 held two environmental 101 workshops for Federal laboratories. The first was hosted by the Department of Energy's Princeton Plasma Physics Laboratory in November 2007 and the second was hosted by the Department of Veterans Affairs' Samuel S. Stratton Medical Center in Albany, NY in April 2008. Based on the result of pre-post tests, 79% of participants improved their undersctanding of environmental regulations as a result of our workshops. A cd-rom was distributed to participants that contained resource materials for further study. A copy of this cd-rom can be obtained by contacting Diane Buxbaum at 212-637-3919 or email@example.com.
We greatly encourage all Federal laboratories in New York, New Jersey, Puerto Rico, and the U.S. Virgin Islands to join the Labs Community of Practice that has been set up at FedCenter. This Labs Community of Practice is a networking tool which links up Federal labs practitioners throughout the country and provides a forum for them to communicate and ask questions of each other. To apply for membership, send e-mail to firstname.lastname@example.org, and leave the subject line and body blank.
Furthermore, FedCenter has a Laboratory Regulatory Tour that includes detailed information on the large variety of environmental regulations which typically apply at Federal Laboratories.
Moreover, EPA Region 2's Pollution Prevention Website has links to resources to help laboratories develop and implement environmental management systems and pollution prevention opportunities such as Labs21, a voluntary partnership program dedicated to improving the environmental performance of U.S. laboratories.
From October 2006 until June 2009, EPA Region 2 conducted twenty multi-media and seven single-media inspections at Federal laboratories and found the following concerns:
- Lack of required permits for storm water discharges from vehicle maintenance and construction activities;
- Improper labeling, storage and disposal of hazardous waste;
- No weekly inspections of hazardous waste storage areas;
- No posting of emergency information by the nearest phone to hazardous waste storage areas;
- No or inadequate training of personnel handling hazardous waste;
- No or insufficient overfill prevention, cathodic protection, and leak detection equipment on underground oil storage tanks;
- Lack of records showing required cathodic protection tests and inspections and monthly leak detection for underground storage tanks are being conducted;
- No complete inventory of underground injection control wells;
- No or inadequate oil spill prevention, control, and countermeasure (SPCC) plans;
- No or inadequate training on SPCC plans and/or annual spill prevention briefings;
- No general containment for fuel transfers; and
- Insufficient secondary containment of above ground oil storage tanks.
Given the extent of compliance problems being found at Federal laboratories, EPA Region 2 encourages Federal Agencies to conduct self-audits of laboratories and to voluntarily disclose any violations to EPA under EPA's Voluntary Audit Policy. By doing so, one may be able to eliminate or substantially reduce the civil penalties for those violations that would normally have been assessed (see enforcement below) provided, of course, that certain conditions are met..
Since October 2006, EPA Region 2 issued five formal enforcement actions against Federal laboratories for violations of the Resource Conservation and Recovery Act (RCRA) with proposed penalties totaling $447,428. Three of these cases have since been settled reducing 1,000 pounds of volatile organic compound (VOC) waste through waste minimization, and preventing 500 gallons of solid waste, 500 gallons of VOC waste, and 14,000 gallons of gasoline from contaminating the land. Also, one of the Federal laboratories agreed to carry out a supplemental environmental project worth $281,500 to develop an automated hazardous material and waste management program as part of their settlement in return for reduced monetary penalties.