University of Vermont
Pollution Prevention Plan

March, 2000

Contents

Facility Information The EMS Approach Pollution Prevention Policy Baseline Assessment Pollution Prevention Opportunities:
Identification and Evaluation

Facility Information

Facility Name:

University of Vermont and State Agricultural College

Planning Status:

Class A Generator

SIC Code:

8221

Generator Locations:

Risk Management Department
109 South Prospect Street
Burlington, VT 05405

Environmental Safety Facility
667 Spear Street
Burlington, VT 05405

Facility Description:

The University of Vermont provides undergraduate and graduate education and research facilities. There are approximately 10,000 full-time graduate, undergraduate and medical students enrolled at the University. There are approximately 3200 faculty members and administrative staff employed at the University. Research funding averages approximately $55,000,000 per year.

The Environmental Safety Facility (ESF) is the University's state permitted hazardous waste storage facility. The primary functions which take place at the ESF include hazardous waste storage, commingling of compatible wastes, re-packing of laboratory wastes into labpacks, and virgin and preowned laboratory chemical distribution.

Contact Person:

Ralph Stuart
Environmental Safety Manager
rstuart@esf.uvm.edu
(802)656-5400

The EMS Approach to Pollution Prevention Plan Development (Project XL)

On September 28, 1999, the University of Vermont and two other schools, (Boston College and University of Massachusetts-Boston), signed an Final Project Agreement with the State of Vermont, the State of Massachusetts and EPA Region I to implement a Project XL in the three Universities' laboratories. As part of the Laboratory XL project, the UVM has developed an Environmental Management Plan (EMP) for laboratory waste. The EMP is a modified form of the Environmental Management System (EMS) described by ISO 14000 standards. Like an EMS, the University of Vermont's EMP organizes environmental management efforts around three principles:

In preparation for the work required for the Project XL program, the University of Vermont's Environmental Safety Facility staff participated in the EPA's EMS pilot project for small businesses with the Vermont Agency of Natural Resources Environmental Assistance Division in 1998 and 1999. Therefore, we believes that the enclosed Pollution Prevention Plan and Annual Performance Report, coupled with the EMP, meets the requirements for using the EMS alternative to standard pollution prevention plan development.

Pollution Prevention Policy

As part of its commitment to environmental responsibility, UVM is committed using processes and practices that reduce or eliminate the use of hazardous materials whenever possible. An important reason for this is to prevent the generation of pollutants and wastes at the source.

In instances where hazardous materials cannot be eliminated or reduced at the source, UVM will investigate methods for reuse and recycling. In order to be able to assess the success of these efforts, UVM will identify environmental objectives and targets on an annual basis as described in the Project XL Final Project Agreement and the Environmental Management Plan. By adopting the policies, plans and procedures outlined in UVM's EMP, the University of Vermont will continually improve its environmental performance with regard to hazardous waste from laboratories. The University is responsible for making available the resources necessary to implement the pollution prevention measures described in the EMP.

The University provides training for laboratory workers which includes information about the elements of UVM's EMP that are relevant to their responsibilities. This training covers pollution prevention programs and practices at the University, and promotes employee involvement in identifying and implementing pollution prevention opportunities.

The EMP is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. This review includes an evaluation of the policies and procedures which ensure ongoing identification, evaluation and implementation of pollution prevention opportunities. In addition, the University submits an Annual Pollution Prevention Performance Report describing progress in meeting current objectives and targets to the Vermont Agency of Natural Resources.

This plan is available to the public as part of the University's EMP, which is located on the web at http://esf.uvm.edu/uvmemp. Copies of the EMP are also available by contacting the ESF. Specific pollution prevention projects are identified below.

Baseline Assessment

As outlined in the Project XL Final Project Agreement, the following assessments will be preformed to establish a baseline for measuring performance goals and indicators.

These assessments and surveys are currently being conducted and a baseline report will be written by June 28, 2000. A copy of the Project XL Environmental Goals and Indicators is included as Attachment 1 to this plan. The University will submit the results of the baseline assessment to the Vermont Agency of Natural Resources during the Summer of 2000.

Pollution Prevention Opportunities:
Identification and Evaluation

Over the last few years, the University of Vermont has identified the following ongoing pollution prevention opportunities in its efforts to reduce hazardous substances and pollutants at the source. These efforts will continue as part of the Project XL and their success will be measured by the Environmental Performance Indicators required by the project.

1.) ChemSource

ChemSource is the University's chemical distribution and recycling program. The services provided by ChemSource promote waste source reduction through improved inventory control. By allowing campus chemical users to realize the unit price savings of case quantities when buying single containers, ChemSource reduces the generation of surplus, outdated materials which in turn become hazardous wastes. ChemSource also offers surplus chemical storage at the ESF for those University chemical users who need to order hazardous chemicals in case lots. This service reduces long-term storage and the potential for hazardous material spills in laboratories.

ChemSource activity is evaluated annually and compared to previous years. Success is based on increased sales and the addition of new services. Examples of such services include replacement of mercury thermometers and identification of non-hazardous glassware cleaning solutions.

  1. Objective: Measure hazardous materials distributied and recycled through the ChemSource program
    Goal: 20% increase over life of XL Project

2.) Annual Hazardous Chemicals of Concern (HCOC) surveys

Each year, the University sends laboratory personnel a storage inventory form for hazardous chemicals stored in the laboratory. One reason for this effort is to encourage laboratories to cull their inventory of unused hazardous chemicals before shelf life of chemicals is exceeded and the chemicals become hazardous wastes. The University evaluates preowned chemicals no longer needed by a laboratory for redistribution to other laboratory personnel who have uses for the chemicals.

The success of this program is based on the number of inventory forms returned, the amount of preowned chemicals that are redistributed and evidence that the quantities of hazardous materials stored in laboratories is decreasing over time. A copy of the HCOC survey procedure is included as Attachment 2. in this plan. The results of the HCOC survey are part of the Annual Pollution Prevention Progress Report.

Objective: Verify annual HCOC surveys for completeness
Goal: 100% completion of surveys each year

3.) Environmental awareness training

The University provides training for employees that includes information about the pollution prevention plan and encourages employees to be involved in identifying and implementing pollution prevention opportunities.

Environmental awareness training can be evaluated based on the training record and the results of the Environmental Awareness Survey. A copy of the Environmental Awareness Survey is included as Attachment 3. in this plan.

Objective: environmental awareness
Goal: Increased environmental awareness, performance based on improved scores and increased number of students and lab workers receiving training over the life of the XL Project

4.) Improved housekeeping

The University has instituted a laboratory inspection program which includes improved housekeeping as an important aspect of the inspection checklist. As part of the inspection, laboratory personnel are encouraged to eliminate excess chemicals and to date chemicals with dates received in order to assure that older chemicals are used first. Chemicals that must be stored on the floor are required to be in secondary containment bins.

Improved housekeeping in the laboratories can be evaluated based on the inspection record. A copy of the laboratory inspection procedure is included as Attachment 4 to this plan. The University intends to continually improve hazardous material storage in laboratories by using the inspection results to prioritize pollution prevention opportunities and by instituting a laboratory self-inspection program.

Objective: compliance with EMP
Goal: improved performance based on above objectives and goals, and inspection results over the life of the XL Project

5.) Individual Pollution Prevention Projects

Laboratory workers and Environmental Safety Facility staff regularly identify opportunities for hazardous waste minimization as they perform their day to day operations. These opportunities are evaluated based on feasibility, regulatory and cost criteria. This evaluation is conducted on the Pollution Prevention Project Planning Form (Attachment 5).

Objective: Identify, evaluate and implement pollution prevention opportunities
Goal: Conduct at least one laboratory pollution prevention project each year

6.) Monitoring of laboratory waste generation rates

Each year, Environmental Safety Facility staff prepare an annual report of the amount of hazardous waste generated on campus, and the amount shipped from the Environmental Safety Facility. This is an important management tool to assess the value of potential pollution opportunities. This is also required as part of the Lab XL project's Environmental Performance Indicators.

Objective: Measure laboratory waste generation rates
Goal: 10% reduction of hazardous waste over life of XL Project


Document Control Information: http://esf.uvm.edu/uvmemp HTML Author: Ralph Stuart, rstuart@esf.uvm.edu
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