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HAZWOPER Plan for Boilers

1.0 Introduction

Departments storing and using hazardous chemicals are responsible for the safe containment of those materials. Every effort should be made to prevent an accidental spill or release of a hazardous chemical. Personnel should be properly trained, procedures developed, and appropriate emergency equipment provided. Failure to incorporate preventive measures may result in the university becoming liable for emergency management and decontamination expenses associated with a hazardous material release incident. Environmental contamination can bring EPA citations and penalties for the university and individuals. All personnel working with hazardous chemicals at the boiler plant and emergency personnel should be familiar with this plan.

2.0 Scope

These procedures are designed to minimize hazards to human health, property, and the environment from unplanned releases of hazardous chemicals at the Boiler Plant. This plan is in compliance with OSHA's HAZWOPER regulations (1910.120).

3.0 Availability

The plan is kept in the Boiler Plant and in the Safety Office. Copies will be made available to employees within 15 days of a request.

4.0 Major Spills

Initial Response and Notification

1. Any incident which could endanger personnel, property, or the environment should be treated as a major spill. If you are unsure about the severity of the spill or the hazards are unknown, treat it as a major spill. In addition, any fires involving hazardous chemicals or spills that cause any injury such as unconsciousness should be considered a major spill.

2. The following are examples of spills that should be considered major:

Type of Spill	Amoung	Examples
Extremely flammable liquids (flash point <0 F)	> 1 pint	ethyl ether
Flammable liquids (flash point <100 F)	> 1 quart	toluene
Combustible liquids ( flash point >100 F)	> 1 quart	mineral spirits
Highly toxic liquids	> 1 pint	acrylonitrile
Toxic liquids	> 1 quart	ammonia
Concentrated acids	> 1 gallon	sulfuric acid
Concentrated alkalis	> 1 gallon	lye solution
Concentrated Hydrofluoric Acid	any amount	Hydrofluoric Acid
Poisonous, reactive materials	any amount	cyanides, sulfides
Oxidizing agents	> 1 pound	concentrated nitric acid
Leaks from gas cylinders	uncontrolled	chlorine, acetylene

3. Do not attempt to clean up a major spill. Only individuals who have received the 40-hour HAZWOPER training course and are part of an emergency response team should clean up major spills.

4. If flammable or combustible liquids are spilled, immediately turn off all sources of ignition.

5. Evacuate persons in the immediate vicinity of the spill. If occupants in the building are in danger, activate the air horn to evacuate the building. Evacuate to an upwind location for toxic gases. Assemble in a designated area well away from the building. Distances from the building will be determined from the DOT Emergency Response Guidebook based upon the type of spilled material. Individuals trained to at least the first responder operations level (Level II) will determine the evacuation distance.

6. Report the spill to the University Police Department. The Police Department will call the Safety Manager. If appropriate, the Police Department will also call the Vice President for Finance and Administration and the Assistant Vice President for Facilities. If deemed appropriate, the Vice President for Finance and Administration will notify the President.

7. Provide the following information and wait in a safe place for emergency personnel to arrive and direct them to the spill:

• Name and telephone number of the caller.
• Location of the spill.
• Name and quantity of materials involved.
• Extent of injuries, if any.
• Environmental concerns, such as the location of storm drains & streams.
• Any unusual features such as foaming, odor, fire, etc.

8. If you have been properly trained (at least Level III training ) and can do so without putting yourself in danger, don appropriate PPE and attempt to stop the leak or reduce contamination by quickly doing the following:

• Close a valve.
• Upright a drum.
• Roll a drum to point the leak up.
• Put a container under the leak.
• Surround the leak with spill booms.
• Surround storm drains and sanitary drains with spill booms.
• Place an oil-only boom in the stream behind the boiler plant.

9. The Safety Office will obtain the MSDS during normal hours if the identity of the spill is known. The Police Department will obtain the MSDS after hours.

10. A Police Officer will proceed to the site and cautiously evaluate the situation while waiting for the Safety Manager. The officer will evacuate the building if there is clear danger to the occupants of the building. If the spill is clearly beyond the capabilities of the university to handle, the Police Officer will immediately call the Radford City Fire Department.

11. The Safety Office and Police Department will evaluate the hazards. The Safety Office will attempt to clean up the spill if it is within the capabilities of university personnel. Safety Office personnel will wear proper personal protective equipment based on the nature of the spill.

12. If the Safety Office cannot handle the spill, they will call the Radford City Fire Department and a spill response contractor.

13. The Safety Office will notify the City of Radford and Pepper's Ferry Treatment Authority as soon as possible, but within four hours, of an accidental discharge into the sanitary sewer system. This notification will include the location, type of waste, concentration and volume, and corrective actions being taken. A written report will be submitted within five days describing the incident and the measures taken to prevent a future occurrence.

Specific Emergency Procedures

1. The Police Director is the Campus Emergency Coordinator and has overall responsibility at the spill site until the arrival of the Fire Chief. The Police Director will ensure that appropriate emergency responders have been called.

2. The Chief of the Radford City Fire Department or his designate will be the initial senior emergency response official at the scene and direct the clean-up operation.

3. Until the arrival of the Fire Chief, the Safety Manager will serve as the Incident Commander for a hazardous chemical spill. The Safety Manager will also serve as the safety official at the site and will be familiar with the emergency plan, facilities, emergency equipment, hazardous materials, storage sites, and records. The Safety Manager has the authority to stop operations that pose an immediate threat to lives, property, or the environment.

4. The following monitoring equipment is available to the Safety Manager to take air samples to assess the spill and determine proper respiratory protection if needed:

• Confined space meter that measures oxygen, LEL, CO, and H2S.
• Photoionization detector for measuring VOCs.
• Personal air sampling pump.
• Natural-gas meter.

5. The Radford City Fire Department in cooperation with university personnel will assess the severity of the spill, level of personal protective equipment needed, and implement appropriate emergency operations. If necessary, assistance will be requested from:

• Department of Environmental Quality.
• °ÄÃÅÀÏÆæÈËÂÛ̳ Police Department.
• Radford City Police Department.
• State Hazardous Waste Emergency Response Team.
• Hazardous materials response teams from Giles County, Roanoke County, or Salem.
• °ÄÃÅÀÏÆæÈËÂÛ̳ Facilities Management.
• Local environmental contractors.
• Virginia Tech Safety Office.

6. An evacuation of a building or the university may be ordered by the Fire Chief or the University Police Director.  The evacuation plan for the university is in the Emergency Response Plan. Safe distances from the building will be determined from the ERG based on the material spilled. Safe distances will be determined by an individual trained to at least the first responder operations level (Level II).

7. Site security and crowd control to prevent entry into the hot zone will be provided by the °ÄÃÅÀÏÆæÈËÂÛ̳ Police Department.

8. Assistance with university facilities and equipment will be provided by Facilities Management.

9. As other emergency response teams arrive, the most senior emergency response official at the site will be in charge. All emergency responders and operations will be coordinated through this individual.

10. Spills requiring Level A or B protection will be handled by an outside hazardous materials team. SCBAs and chemical resistant suits will be worn. Spills requiring Level C or D protection may be handled by properly trained individuals from the Fire Department or °ÄÃÅÀÏÆæÈËÂÛ̳. Proper PPE will be worn. The Personal Protective Equipment Program for the university is in the Appendices. Operations in hazardous areas will be performed using a buddy system.

11. Victims of a chemical spill will be taken to Radford Community Hospital.

12. Emergency medical treatment will be provided by the Radford Community Hospital EMS squad. First aid for emergency responders will be provided by °ÄÃÅÀÏÆæÈËÂÛ̳ Emergency Services (RUEMS).

13. Decontamination of victims, equipment, and emergency responders will be performed under the supervision of the Safety Manager in cooperation with the Fire Department and outside contractors. Individuals performing decontamination will wear proper PPE and be trained in decontamination procedures. PPE will be at the same level or one level below the emergency responders. Decontamination equipment is stored in the paint room next to the Allen Building.

14. The Safety Office will notify the National Response Center if a reportable quantity is released and file a report with the Department of Environmental Quality if required.

15. Immediately after the emergency, the Safety Office will ensure that recovered waste and contaminated materials are properly disposed.

16. Within a week of the incident the Safety Office will contact all parties involved in the incident and critique the emergency response. Necessary changes will be made to the plan.

5.0 Minor Spills

Initial Response and Notification

1. Spills that can be cleaned up by personnel on the spot are minor spills. Minor spills are releases of low toxicity liquids or solids not generating dangerous gases or fumes, e.g., small acid and solvent spills, hydraulic fluids, fuel oils, etc. Minor spills are limited in quantity and pose no emergency or significant threat to the safety and health of employees.
2. Notify persons in the immediate area and prevent access to the spill if possible. Evacuate persons in the immediate vicinity of the spill if they are in danger.
3. If flammable or combustible liquids are spilled, immediately turn off all sources of ignition.
4. Avoid breathing vapors from the spill.
5. Contact the Safety Office if assistance is needed in cleaning up the spill.

Specific Emergency Procedures

1. Determine the chemical name of the spilled material by checking labels and shipping papers. Obtain the MSDS and identify the hazards associated with the spill. Is it flammable, combustible, reactive, toxic, corrosive, or an oxidizing agent?
2. Do not touch spilled materials. Consult the MSDS. Wear appropriate gloves, eye protection, and protective clothing if necessary. For concentrated acids and alkalis, a face shield is needed in addition to goggles. Wear an air-purifying respirator if hazardous gases, fumes, or dusts are present that are within the range of protection of the respirator. Ensure that proper cartridges are used. Anyone who wears an air-purifying respirator must be properly trained and medically evaluated.
3. Stop the leak at the source and try to prevent the spill from spreading. Prevent the spill from entering drains or leaking onto the ground. Upright overturned containers. Turn the container so that a hole points up. Transfer liquids from leaking containers to new ones. Plug or patch a leaking drum. Surround the spill with an inert absorbent such as vermiculite or spill booms.
4. Absorb small spills of acids, caustics, solvents, oil, and aqueous solutions with paper towels, spill pads, or spill control pillows. Paper towels should not be used for more than tiny amounts of volatile liquids because the paper will aid evaporation. Using tongs, carefully place the towels, pads, or pillows onto the spill. Pick up flammable liquid spill control materials using spark-proof tools (e.g. plastic, aluminum). Carefully pick up the saturated material with a scoop or tongs, place in a plastic bag, label, and dispose as hazardous waste. Keep oxidizers away from combustible materials (wood, paper towels, oil, etc.).
5. For a large liquid spill, use a squeegee to bring the liquid into contact with absorbents. Always work toward the center of the spill. If an absorbent is not readily available, cover the spill with a plastic sheet to reduce vaporization.
6. Carefully push solids into a pile with a plastic scraper. Brushes and brooms may create an unacceptable dust hazard and should be used with caution.
7. Acid and base residues that were not absorbed by the vermiculite or spill pillows should be removed with neutralizers. Small acid spills can be neutralized with sodium bicarbonate or sodium carbonate and alkali spills with sodium bisulfate, citric acid or vinegar. Commercial adsorbent spill control materials can also be used. Wash the contaminated area with soap and water to remove any remaining residues.

6.0 Training

1. All individuals involved in the management of hazardous chemicals at the boiler plant will be trained in the proper handling of chemical spills and emergency procedures. The Safety Manager and the Environmental Inspector will receive OSHAs 40-hour HAZWOPER training class. Boiler Plant operators who may take limited action to prevent a spill from getting worse, e.g., shutting off a valve, will receive at least 24 hours of training at the hazardous materials technician level (Level III). °ÄÃÅÀÏÆæÈËÂÛ̳ Police Officers will be trained to at least the first responder awareness level (Level I).
2. In-house training at the awareness level is conducted by the Safety Manager. Training beyond the awareness level will be conducted by the Safety Manager or by qualified individuals located outside the university.
3. Individuals handling minor spills of hazardous chemicals will be properly trained in spill procedures by the Safety Manager per the requirements of the Hazard Communication Standard.
4. All employees trained in emergency response will receive annually retraining. Retraining will be performed by the Safety Manager or other qualified individual.
5. All training records are kept in the Safety Office.

7.0 Medical Surveillance

1. Members of the chemical emergency response team on campus will be enrolled in a Medical Surveillance Program. Medical examinations will be given prior to assignment and every year thereafter at no cost to the employee. An examination will be given upon termination if the employee has not had an examination within the last six months. Members of the team will be trained to the first responder specialist level or receive the 40-hour HAZWOPER course.
2. Medical examinations will include a medical and work history with special emphasis on symptoms related to the handling of hazardous materials and to fitness for duty including the ability to wear PPE. The content of the medical examinations shall be determined by the physician.
3. The following information will be provided to the physician:
   1. A copy of OSHAs HAZWOPER Standard and its appendices.
   2. A description of the employee=s duties.
   3. The employees= exposure levels.
   4. A description of PPE used.
   5. Information from previous medical examinations.
4. A copy of the physicians written opinion will be furnished to the employee. The written opinion will contain the following:
   1. The physician's opinion as to whether the employee has any medical conditions which would place the employee at increased risk from work in emergency response or hazardous waste operations.
   2. Recommended limitations upon the employees assigned work.
   3. The results of the medical examination and tests if requested by the employee.
   4. A statement that the employee has been informed of the results of the medical examination and any medical conditions which require further examination or treatment.
5. The written opinion shall not contain specific findings or diagnoses unrelated to occupational exposure.
6. Individuals trained to the first responder awareness level, operations level, or the technician level will not be enrolled in the Medical Surveillance Program.
7. Any emergency response employee who exhibit symptoms which may have resulted from exposure to hazardous substances during the course of or after the emergency will be provided with medical consultation at no cost to the employee.
8. Medical Surveillance records will be kept in the Safety Office.

8.0 Drills

1. Evacuation drills are conducted yearly at the Boiler Plant under the supervision of the Safety Manager. Evacuation routes are blocked to test employee response to alternate routes. Employees meet in a designated area and a roll call is taken. The roll call will be compared to the work schedule that is kept in the Safety Office to ensure that all occupants have evacuated.
2. Tabletop exercises are conducted every two years at the Boiler Plant under the supervision of the Safety Manager. Spill release scenarios and appropriate emergency response actions are discussed. Appropriate changes to the Emergency Response Plan are made by the Safety Manager.
3. All records of drills are kept in the Safety Office.

9.0 Hazardous Chemicals on site

Aboveground Storage Tanks (ASTs)

Two ASTs are located behind the boiler plant approximately 50 ft from the railroad tracks.

The two boiler ASTs contain 50,000 gallons each of fuel oil #2. The boiler tanks are double lined and have a pad catchment basin and an oil/water separator. The fueling pad catchment basin also has an oil/water separator. In addition, the tanks have a high-level switch that closes the flow control valve and shuts down the pump when activated. Each tank is surrounded by a secondary containment structure that has a capacity of 55,000 gallons.

Flammable Storage Room

The flammable storage room is located on the west side of the boiler plant adjacent to the main building. The following chemicals are stored in the building:

• 80-pound cylinder of acetylene
• 80-pound cylinder of oxygen
• 55-gallon drum of ST-2A (contains methyl alcohol)
• 5-gallon can of gasoline

Chemical Storage Room

The chemical storage room is located in the main building. The following chemicals are stored in this room:

• 50-gallons of paint
• 5-gallons paint thinner
• 40 aerosol spray cans
• 110-gallons SVA-S66 (corrosive)
• 110-gallons B4 (corrosive)
• 110-gallons B3 (corrosive)
• 55-gallons CW-VA (corrosive)
• 55-gallons BL-180 (corrosive)

10.0 Spill Control Equipment

The following equipment is available for handling chemical spills:

• Absorbent pillows, socks, and mats
• Plastic bags, gloves
• Lite-Dry absorbent in bags
• Paper towels
• 85-gallon overpack drum
• Goggles
• Air-purifying respirators
• Small portable surface pumps
• Portable generator
• Light tree
• Sewer plugs
• Backhoe, farm tractor, dump truck
• Truck with tailgate lifts
• Bucket truck
• Small trailer
• Sewer flushing machine
• Buses
• Two-way radios
• Barricades
• 15-minute SCBA
• Straw bales
• Level B/C chemical suits
• Tyvek suits

Safety Office (emergency response van)

• Absorbent pillows, socks, and mats
• Paper towels
• Plastic bags
• Gloves
• Goggles
• Plastic sheeting
• Warning signs
• Duct tape
• Flashlight & batteries
• pH paper
• HF spill pads
• Air-purifying respirator and cartridges
• Tyvek suits and booties
• Portable gas detector
• Absorbent clay
• Shovel
• Mercury cleanup materials

Boiler Plant

• Absorbent pillows, socks, and mats
• Plastic bags
• Gloves
• Paper towels
• Goggles
• Oil-only booms

Pollution Prevention Plan

1.0 Program

Introduction

The university produces many waste streams including hazardous waste, spills and leaks, water discharges, obsolete inventory, municipal solid waste, air emissions, energy waste, and evaporative losses. Pollution prevention emphasizes reducing or eliminating these wastes at the source through efficient use or conservation of raw materials and energy. This includes all pollution: hazardous and nonhazardous, across all environmental media (air, water, soil) and from all sources. The second priority is to reuse or recycle generated wastes. As a last resort, pollution should be disposed of in a manner that reduces risk to public health, safety, and the environment. This plan identifies current pollution prevention practices and recommends additional methods to reduce or eliminate wastes generated at the university. It is a written guide used to chart the progress of the program. Pollution preventions can protect the environment, save money, increase productivity, improve public image, create a healthier work environment, and reduce the risk of liability. The plan encourages the purchase of environmentally friendly products and technologies, use of less toxic products and materials, purchase of more products containing recycled materials, promotes efforts to prevent the generation of waste at the source and initiates recycling programs.

Organization

Pollution Prevention Coordinator

The pollution prevention coordinator is responsible for developing a pollution prevention plan for the university, establishing a pollution prevention team, conducting meetings, and ensuring the university is working toward its goal to reduce pollution. The pollution prevention coordinator acts as the key liaison to top management and strives to obtain inter-departmental cooperation and resources on a continuing basis. The Environmental Specialist will serve as the pollution prevention coordinator for the university.

Pollution Prevention Committee

A Pollution Prevention Committee will be organized to oversee the Pollution Prevention Program at the university. The committee will perform the following functions:

• Define goals, objectives, and strategies.
• Review processes and operations to determine where and how toxic substances are used and hazardous wastes are generated.
• Recommend methods to eliminate or reduce waste at the source.
• Develop ways to involve suppliers and contractors.
• Acknowledge and reward employee contributions to the pollution prevention effort.
• Monitor the progress of the pollution prevention program on campus.

Members will include the Environmental Health and Safety Director, Environmental Specialist, Director of Housekeeping, Assistant Director of Facilities Management, and representatives from the Art Department, Chemistry Department, and Purchasing. The Committee will report to the Assistant Vice President of Facilities. Meetings will be held quarterly.

Employee Participation

In order to have an effective pollution prevention program at the university participation and cooperation of employees is essential. Employee support will be solicited through committees, suggestion programs, and training sessions. Employees who suggest pollution prevention measures that prove feasible will be recognized for their contributions. The form of recognition will be determined by the Pollution Prevention Committee.

Training

Ensuring that employees and students are adequately trained in pollution prevention principles is an important element of the pollution prevention program. The goal is to make employees and students aware of waste generation, its impact on the university and the environment, and ways waste can be reduced and pollution prevented. Training will be conducted by the Environmental Specialist and the Environmental Health and Safety Director.

Pollution Prevention Strategies

The overall goal of the Pollution Prevention Program is to significantly reduce the quantity and toxicity of pollution released and waste generated at the university. The following strategies are designed to achieve this goal:

1. Prevent or reduce pollution at the source.
2. Reuse waste that cannot be reduced.
3. Recycle waste that cannot be reduced at the source or reused.
4. Waste that cannot be reduced, reuse, or recycled should be disposed of in an environmentally safe manner.
5. Prevent spills and accidental releases of hazardous materials.
6. Prevent raw material/product losses.
7. Replace or reduce toxic substances with less hazardous materials.
8. Reduce the quantity of hazardous waste.
9. Reduce the amount of solid municipal waste.
10. Implement acquisition and procurement policies that promote pollution prevention, reduce waste, and minimize effects on natural resources.
11. Reduce the use of CFCs, HCFCs, and Halons.
12. Reduce air emissions.
13. Minimize pollution by using energy conservation principles.
14. Increase water conservation.
15. Properly manage the handling of chemicals.
16. Promote and instill a pollution prevention ethic through education and training.
17. Minimize use of petroleum products by exploring the use of less polluting energy sources.
18. Buy more environmentally friendly and recycled products.

2.0 Air Pollution

Stationary Source Permit

VDEQ issued a permit of operation on July 29, 1996, to construct and operate five gas/distillate oil-fired boilers, two gas-fired boilers, three emergency diesel generators and three distillate oil storage tanks. This permit supersedes the permit dated January 12, 1979 and April 23, 1995 (as amended February 14, 1996.) The purpose of the permit is to ensure that air emissions from this equipment does not exceed specified limits.

Current Practices

1. Nitrogen oxide (NOx) emissions from boilers 1, 2, and 3 will be reduced by use of low NOx burners with external flue gas recirculation. These three boilers are currently under construction. Nitrogen oxide (NOx) emissions from boilers 4, 5, 7, and 8 (existing) will be controlled by use of low-NOx burners. Boilers 1, 2, 3, 4, and 5 are in the Power Plant. Boilers 7, and 8 are in Dedmon Center. The gap in the numbering sequence occurred because the emergency diesel generator is referenced as #6 in the old permit dated February 14, 1996. The new boilers are more energy efficient and part of the stack gases is returned to the boilers and burned a second time to reduce air emissions. A new permit is under review through VDEQ for a revision or modification for boiler #4 that should include the use of oil as a fuel source besides natural gas.

2. The permit states that air emissions compliance testing for the boilers will be done upon completion of construction, which has not occurred to date. No air emissions testing are required for the three emergency diesel generators and three distillate oil storage tanks. Three different sampling scenarios must be followed to comply with the permit.

a. The emissions testing will consist of Total Suspended Particulate, PM-10, Sulfur Dioxide, Nitrogen Oxides, Carbon Monoxide, and visible emissions for boilers 1, 2, and 3 (combined.)
b. The emissions testing will consist of Total Suspended Particulate, PM-10, Sulfur Dioxide, Nitrogen Oxides, Carbon Monoxide, and visible emissions for boilers 1, 2, 3, 4, and 5 (combined.)
c. The emissions testing will consist of Total Suspended Particulate, Sulfur Dioxide, Nitrogen Oxides, and visible emissions for boilers 7, and 8 (combined.)

3. The contractors doing the installation will perform the emissions testing. No periodic air emissions testing are required by the permit after the initial test. Emissions of pollutants will be calculated based on fuel consumption.

4. Emissions from the operation of boiler 1, 2, and 3 (combined) shall not exceed the limits specified below:

Total Suspended Particulate	3.2 lbs/hr	0.8 tons/yr
PM-10	3.2 lbs/hr	0.8 tons/yr
Sulfur Dioxide	113.7 lbs/hr	14.0 tons/yr
Nitrogen Oxide	22.5 lbs/hr	8.6 tons/yr
Carbon Monoxide	22.0 lbs/hr	8.6 tons/yr

5. Emissions from the operation of boiler 1, 2, 3, 4, and 5 (combined) shall not exceed the limits specified below:

Total Suspended Particulate	3.3 lbs/hr	0.9 tons/yr
PM-10	3.3 lbs/hr	0.9 tons/yr
Sulfur Dioxide	113.7 lbs/hr	14.0 tons/yr
Nitrogen Oxide	23.9 lbs/hr	9.7 tons/yr
Carbon Monoxide	23.1 lbs/hr	10.2 tons/yr

6. Emissions from the operation of boiler 7 and 8 (combined) shall not exceed the limits specified below:

Total Suspended Particulate	Nitrogen Oxide	0.13 tons/yr
Sulfur Dioxide	8.4 lbs/hr	1.3 tons/yr
Nitrogen Oxide	2.4 lbs/hr	0.7 tons/yr

7. Because emissions are under one hundred tons per year, a Title V air permit is not required.

8. After the initial air emissions compliance test, visible emissions shall not exceed 10 percent opacities, except during one six-minute period in any one hour in which visible emissions shall not exceed 20 percent opacity from the #1 boiler stack (associated with boilers 1, 2, and 3) and the #2 boiler stack (associated with boiler 4.) Visible emissions from the #3 boiler stack (associated with boiler 5) and the #4 boiler stack (associated with boilers 7 and 8) shall not exceed 20 percent opacities, except during one six-minute period in any one hour in which visible emissions shall not exceed 60 percent. These conditions apply at all times except during start-up, shutdown, or malfunction. The visible emissions are to be determined by EPA Method 9 in reference to 40 Code of Federal Regulation Part 60, Appendix A. Another condition is the maximum sulfur content of the oil burned in the boilers shall not exceed 0.5 percent by weight per shipment.

9. Emissions testing from the boilers will determine if additional actions are necessary. If limits are exceeded, then measures will be taken to modify the process or reduction equipment will be installed such as a scrubber or bag-house to reduce emissions.

10. Visible emissions will be checked by the contractor when construction is completed. The Boiler Plant Supervisor will check visible emissions periodically. VDEQ will also check visible emissions quarterly.

11. The Power Plant produces a quarterly report for fuel consumption that is given to VDEQ. This report is used to detect if a possible fuel leak has occurred, and fuel consumption directly effects air emissions produced.

Recommendations

1. Ensure that equipment is operated in accordance with the permit and that emissions do not exceed specified limits.
2. Maintain records showing dimensions of the 50,000-gallon storage tanks and an analysis showing the capacity of each vessel.
3. Use the energy generators only for power during interruptions of service from the normal power supplier and for periodic testing.
4. Periodically check visible emissions and maintain records.
5. Ensure that the maximum sulfur content of the oil does not exceed 0.5 percent by weight per shipment. Obtain a certification from the fuel supplier with each shipment of oil.
6. Train boiler operators in the proper operation and maintenance of combustion equipment and maintain records.
7. Develop written operating procedures and maintenance schedule for the boilers.
8. Maintain records of all emissions data and operating parameters necessary to demonstrate compliance with the permit.
9. Submit fuel quarterly reports to VDEQ at the end of each quarter.

Fugitive Emissions

Fugitive emissions are caused by volatilization from open vessels, spills, shipping containers, and leaks from pumps, valves and building ventilation systems. Fugitive emissions are not vented or directed through a stack.

Current Practices

1. Caps are placed on containers to prevent spills and reduce fugitive emissions.
2. Preventive Maintenance Programs and regular inspections have been established to find problems before they happen. This prevents leaks and prolongs equipment life.
3. Fluorescent lights are recycled. This reduces mercury emissions into the atmosphere.
4. Oil waste storage cans are provided to users for solvent soaked rags.
5. The spray paint booth in the Theater Department is equipped with filters to catch over sprays.
6. Drums containing mineral spirits and refrigeration oil are kept closed and covers are kept on parts cleaners.
7. The only under ground storage tank in use has a leak detection system that consists of a fuel alarm for annular space, which performs a monthly automated leak detection test. The double lined tank was installed with an overfill drop tube and vapor recovery equipment. The tank was installed with a catchment basin. There is automatic overfill protection.
8. For manual filling, the doubled lined 10,000-gallon above ground storage tank has a containment basin and a seven-gallon catchment basin for spill protection. The tank has a level sensing device and alarm console that will sound an audible alarm and shut off the fuel transfer pump automatically when the tank level reaches 95% of capacity.
9. The double lined 50,000-gallon above ground storage tanks has a leak detection system that uses a floating device, which will set-off an alarm to warn of rapid fuel lose. The tanks have a containment basin with an oil/water separator. The fueling containment pad has an oil/water separator. A high-level switch that when activated, closes the flow control valve and shuts down the pump is also installed on the tank.

Recommendations

1. Continue conversion to latex paints and glues.
2. Encourage personnel to car pool and drive fuel efficient cars.
3. Avoid evaporating unused solvents in chemical fume hoods.
4. Regularly tune and change air filters on campus vehicles.
5. Routinely check HVAC equipment for leaks.
6. Practice energy conservation to minimize use of fossil fuels.
7. Purchase low emissions carpets, drapes, furniture, laser printer and copiers.
8. Use non-bleached paper products.

Chlorofluorocarbons (CFCs)

°ÄÃÅÀÏÆæÈËÂÛ̳ has developed a CFC Plan. The purpose of the plan is to reduce pollutants by reducing emissions of CFCs and HCFCs to the lowest achievable levels during the service, repair, or disposal of appliances at the university. The plan describes the university's preparation for the phaseout of CFCs. Strategies for maintaining, converting, or replacing existing equipment with appliances that use alternative refrigerants are described.

Current Practices

1. All equipment that used R-11 has been replaced with units that use R-22 and all stocks of R-11 have been removed.
2. Equipment that uses R-12, R-500, R-502 will be maintained until a major breakdown occurs then replaced with an R-22 unit.
3. The university will continue to use and purchase equipment containing R-22.
4. Automobile air conditioners that use R-12 will be maintained as long as possible and converted to R-134a if a major breakdown occurs.
5. Maintaining, replacement, or conversion of equipment to alternative refrigerants will be made on a case by case basis taking into consideration the age of the equipment and cost of repair.
6. The university has three Halon 1301 tanks; one is scheduled for removal.
7. All technicians who service appliances that could reasonably release CFCs or HCFCs are certified by an EPA approved program.
8. Intentionally venting CFCs or HCFCs into the atmosphere while servicing or disposing of appliances is prohibited.
9. The university has two EPA certified refrigerant recovery/recycling units.

Recommendations

1. Ensure that new HVAC technicians are certified.
2. Maintain proper service records of refrigerants leaks.
3. Ensure refrigerants are removed from appliances prior to disposal and records are maintained.
4. The garage should purchase its own recovery/recycling unit.

3.0 Water Pollution

Wastewater

1. °ÄÃÅÀÏÆæÈËÂÛ̳ discharges wastewater into the Pepper’s Ferry Regional Wastewater Treatment Authority’s (PFRWTA) sewerage collection and treatment system in accordance with the conditions set forth in the permit issued on April 15, 1996. PFRWTA is a secondary treatment facility.

2. The following limitations and sampling requirements are imposed for Outfall 1 (last manhole on Clement Street at intersection with Adams Street) and Outfall 2 (manhole at Norwood Street and Muse Hall):

Parameter	Limit	Frequency	Sample Type
Flow	0.100 mgd	Continuous	Meter
Temperature	120 degrees Fahrenheit	Weekly	Grab
pH (minimum)	5.0 (standard pH units)	Weekly	Grab
pH (maximum)	10.5 (standard pH units)	Weekly	Grab
BOD5	300 mg/l	Monthly	24-hr composite
Total Suspended Solids	250 mg/l	Monthly	24-hr composite
Oil and grease	100 mg/l	Monthly	Grab
Metals*		Semi-Annual	24-hr composite

The university shall not introduce any pollutant into the sanitary sewer system that causes interference with the operation of the Waste Authority.

* = During the months of October and March, sample wastewater discharge for the following toxic metals: Cadmium, Chromium, Copper, Lead, Nickel, Silver, and Zinc.

3. On June 27, 1996, at a meeting between °ÄÃÅÀÏÆæÈËÂÛ̳ and the Water/Wastewater Utilities it was decided that Manhole 10 be included in the sampling scheme. Manhole 10 receives wastewater from the entire university. The following limitations and sampling requirements are imposed for Outfall 10 (under the Dedmon Center bridge):

Parameter	Limit	Frequency	Sample Type
Flow	0.100 mgd	Continuous	Meter
Oil and Grease	100 mg/l	Monthly	Grab

4. In October of 1993, °ÄÃÅÀÏÆæÈËÂÛ̳ performed a baseline survey of wastewater discharge from eight manholes by request of Water/Wastewater Utilities, City of Radford, and the Pepper’s Ferry Regional Wastewater Treatment Authority for 30 volatile organics, 57 toxic organics (acids, bases, neutral compounds), 19 pesticides, and 7 PCBs. Out of the 904 sample analyses, 52 samples had a detectable level, but were well below established guidelines. The remaining 852 sample analyses were below the detection limit.

5. On April 11, 1994, °ÄÃÅÀÏÆæÈËÂÛ̳ requested the City of Radford, Water/Wastewater Utilities for a change in the permit for Outfall 3, because of relocation of the Printing Department, a small darkroom, and a freshman Biology laboratory. On May 27, 1994, PFRWTA issued a notice granting permission to terminate the monitoring of Outfall 3. Based on an inspection of the facilities in question, wastewater monitoring was not required at the new facilities.

6. On June 9, 1994, °ÄÃÅÀÏÆæÈËÂÛ̳ requested the City of Radford, Water/Wastewater Utilities for a change of the permit. Based on analysis of monitoring between September 1993 and April 1994, °ÄÃÅÀÏÆæÈËÂÛ̳ requested the following changes to the Industrial Wastewater Discharge Permit: Outfall 4, Outfall 5, Outfall 6, Outfall 7, and Outfall 8 monitoring be terminated based on historical data that demonstrated levels below permissible limits. Therefore sampling did not justify the expense and manpower required to continue monitoring. On July 2, 1994, the City of Radford and PFRWTA agreed on the termination of monitoring of the above-mentioned outfalls, but to continue sampling of Outfalls 1 and 2.

7. The following strategies were used to reduce oil & grease, BOD, TSS, and TIS from Outfalls 1 & 2:

• Increased frequencies of clean-outs for the grease traps at Dalton Hall and Muse.
• Lowered temperature on the Aqua-Stat system in Muse.
• Repaired pulper units in Dalton Hall.
• Sealed the drain in the waste grease storage room.
• Informed workers not to pour bulk grease and thick gravies into the sanitary sewer system.
• Increased the amount of cardboard fed into the pulper units.
• Substituted reduced fat items for high fat items.
• Installed a 1500 gallon grease trap and a new 35 G.P.M. grease recovery unit at Dalton Hall.
• Implemented a food compost system where approximately 50% of solid wastes were collected.
• Removed the pulper unit from Dalton Hall to reduce BOD.
  8. The university does not discharge pollutants from a point source directly into a body of water. Therefore, the university does not require a NPDES permit.

9. The boiler plant blows down 50-150 gallons of water per day into the sanitary system. Samples taken at the outfall next to the boiler have revealed no problems.

10. Back-flow preventers were installed on the main water lines, main fire protection systems, water coolers, outside spigots, and sinks where chemicals are used.

Recommendations

1. Explore methods to further reduce oil & grease and BOD in manholes 1 and 2. Investigate the feasibility of installing a bioremediation grease trap.
2. Continue to inform personnel and students not to pour hazardous materials down the drain.
3. Overflow water from the boilers due to floods, breaks, etc. should be pumped directly into the sanitary system.
4. Increase the amount of food waste for composting and install a new grease trap in Muse Hall.
5. Complete the installation of back-flow preventers on outside spigots.

Water Conservation

Current Practices

1. Water is turned off when not in use and leaks are reported quickly.
2. The irrigation system has a rain sensor and automatic cutoff to prevent over watering. The system is pressurized and periodically checked for leakage. The New River is used as the main source of water.
3. Preventive Maintenance Programs have been established to find leaks.
4. The steam tunnels are inspected weekly for leaks. Water makeup for steam generation is monitored daily, which notes any substantial lose, and prompts an investigation into the possible problem.
5. Aerators are installed on sink faucets.
6. Water saving shower heads have been installed to reduce the amount of flow.
7. Water saving flush valves are being installed to save one gallon per minute.

Recommendations

1. Ensure that low flow shower heads, aerators, and water saving flush valves are being installed.
2. Reuse water from the car wash and wash automobiles sparingly.
3. Use front loading instead of top loading washing machines.
4. Turn off water taps when not in use.
5. Fix plumbing leaks promptly.
6. Explore the possibility of reusing domestic water for irrigation, cooling, or toilet use

4.0 Soil Pollution

Underground Storage Tanks

Current Practices

1. The following seven underground storage tanks were closed out, because of the age of the tanks, and the potential for leaks to the environment:
   1. Tank #1 had a 10,000-gallon capacity that held gasoline and was installed in 1971. Tank #1 was last used 2-16-94. The tank was removed from the ground and closed on 9-29-94. VDEQ approved the closure on March 10, 1995.
   2. Tank #2 had a 1,000-gallon capacity that held used oil and was installed in 1966. Tank #2 was last used 11-25-91. The tank was removed from the ground and closed on 9-29-94. VDEQ approved the closure on March 10, 1995.
   3. Tank #3 had a 20,000-gallon capacity that held #6 fuel oil and was installed in 1966. The tank was removed from the ground and closed from 05-31-94 to 06-2-94. VDEQ approved the closure on October 16, 1995.
   4. Tank #4 had a 20,000-gallon capacity that held #6 fuel oil and was installed in 1966. The tank was removed from the ground and closed from 05-31-94 to 06-2-94. VDEQ approved the closure on October 16, 1995.
   5. Tank #5 had a 20,000-gallon capacity that held #6 fuel oil and was installed in 1966. The tank was removed from the ground and closed from 05-31-94 to 06-2-94. VDEQ approved the closure on October 16, 1995.
   6. Tank #6 had a 30,000-gallon capacity that held #2 fuel oil and was installed in 1978. Tank #6 was last used 09-08-95. The tank was closed in ground using a flowable fill. VDEQ approval of the closure is pending and excepted because no problems were incurred.
   7. Tank #7 had a 550-gallon capacity that held gasoline and was installed in 1956. Tank #7 was last used in 1965. The tank was closed in place in 1965, which was before the regulations went into effect. Therefore, no further action is required.
2. Twelve monitoring wells were established as part of the tank closures. Five monitoring wells have been closed to prevent the potential for groundwater contamination. Two monitoring wells were lost during the excavation of an underground storage tank. The remaining five are scheduled to be closed by the end of 1997 to prevent the potential for groundwater contamination.
3. A double walled fiberglass 10,000-gallon under ground storage tank was installed in March of 1994 at Facilities Management. The tank is designed to store gasoline for °ÄÃÅÀÏÆæÈËÂÛ̳’s automobiles. A leak detection system (TLS-350) consists of a fuel alarm for annular space, which performs a monthly automated leak detection test. The system also monitors volume, ullage (empty space), height in inches, water volume in gallons, water content in inches, and temperature. The tank was installed with an overfill drop tube and vapor recovery equipment. The tank was installed with a catchment basin. There is automatic overfill protection.

Recommendations

1. Develop a spill contingency plan.
2. Ensure that a monthly inventory test is performed on the UST at Facilities Management.
3. Close remaining monitoring wells.

Above Ground Storage Tanks

Current Practices

1. Five above ground storage tanks are currently on campus. The tanks are designed to meet current regulations and reduce the potential for environmental contamination.
   1. A double lined, 500-gallon waste oil above ground storage tank is located outside the Motor Pool in Facilities Management. The tank was manufactured by Lube Cube, who certified the tank to be leak-free. Necessary Oil performs regular pickups.
   2. A double lined, 500-gallon above ground storage tank was installed in November of 1994, and is located outside the Motor pool in Facilities Management. The tank holds diesel fuel. The tank has a covered containment basin to reduce rainfall collection and a catchment basin for receiving fuel. There is automatic overfill protection for fueling and a direct reading liquid gauge.
   3. Two double lined 50,000-gallon ASTs were installed in August of 1995, at the Boiler House. The tanks are designed to hold #2 fuel oil. A Rosemount Smart Tank Hydrostatic Tank Gauging System was installed to provide on-line measurements of mass, density, standard density, volume standard volume, level, and temperature. The tanks were hydrostatic pressure tested for leaks and the results were satisfactory. A direct reading liquid gauge was installed. The tanks have a leak detection system that uses a floating device, which will set-off an alarm to warn of rapid fuel lose. The tanks have a containment basin with an oil/water separator. The fueling containment pad has an oil/water separator. A high-level switch that when activated, closes the flow control valve and shuts down the pump is also installed on the tank.
   4. A single lined, 10,000-gallon above ground storage tank was installed in June of 1996, at the Dedmon Center. The tank is used to store #2 fuel oil for the Dedmon Center boilers. For manual filling, the tank has a containment basin and a seven-gallon catchment basin for spill protection. A direct reading liquid gauge was installed. The tank has a level sensing device and alarm console that will sound an audible alarm and shut the fuel transfer pump off automatically when the tank level reaches 95% of capacity. Froehling & Robertson, Inc. performed a post magnetic particle test and found no problems.

Recommendations

1. Provide a catchment basin for the waste oil tank.
2. Develop a spill contingency plan.
3. Investigate a potential storm drain problem at the Dedmon Center receiving dock, where #2 oil is received. The receiving dock is on a slant. Therefore, a potential spill could collect in a storm drain. Although the drain can be blocked with a manual gate, a quarter inch gap could allow flow past the gate.

Municipal Solid Waste

Current Practices

1. Solid waste is disposed of in a Subtitle D sanitary landfill located in Pulaski County. The landfill is permitted to receive construction, demolition, debris waste, and non-hazardous industrial waste. The landfill is lined with 60 mil plastic membrane and two-foot low permeability clay. Leachate is collected and goes to the local POTW at Peppers Ferry. Samples are analyzed monthly. Ground water is monitored periodically.
2. An active recycling programs is in place at the university. Approximately 20% of the waste stream is recycled.
3. To prevent heavy metal contamination of the landfill, fluorescent light bulbs, ballasts, and batteries are recycled.
4. Hazardous waste is disposed of through licensed contractors.
5. Containers are completely emptied before disposal.
6. Pesticide containers are triple rinsed before disposal.
7. Old latex paints are reused instead of being disposed in the landfill.

Recommendations

1. Support Montgomery County in its attempt to join with the New River Resource Authority (NRRA.) °ÄÃÅÀÏÆæÈËÂÛ̳ is with the NRRA. This would benefit °ÄÃÅÀÏÆæÈËÂÛ̳ because Montgomery County has a Material Recovery Facility, which would cut pre-sorting costs. This would also reduce hauling by 20 miles because recyclables now go to Roanoke. The NRRA, however, has an established and permitted landfill with adequate space and longevity.
2. Buy durable goods that can be reused.
3. Buy only reusable, recyclable, or refillable containers.
4. Avoid disposable products of any kind.
5. Sell or donated goods instead of throwing them away.
6. Compost lawn clippings and food scrapes.
7. Avoid plastics when possible.
8. Stop junk mail.
9. Recycle as much as possible.

5.0 Hazardous Materials

Hazardous Waste Program

Current Practices

1. A Hazardous Waste Program has been written for the university. The manual describes how hazardous waste should be handled at the university. By following proper procedures for hazardous waste disposal, the quantities of harmful chemicals entering the environment is dramatically reduced.
2. The Safety Office is budgeted for the campus-wide hazardous waste disposal program. This strategy encourages departments to dispose of hazardous waste properly.
3. Two storage lockers have been purchased to store hazardous waste properly. Each unit is provided with a spill containment system. The lockers are inspected weekly.
4. °ÄÃÅÀÏÆæÈËÂÛ̳ has filed a Notification of Regulated Waste Activity to comply with Section 3010 of the Resource Conservation and Recovery Act and Virginia Hazardous Waste Management Regulations VR 672-10-1. °ÄÃÅÀÏÆæÈËÂÛ̳’s EPA identification number is VAD988186904. The university is considered a small quantity hazardous waste generator.
5. Hazardous waste is disposed of through a licensed hazardous waste management service. The university is currently using Veolia ES Technical Solutions, L.L.C. for hazardous waste disposal.

Recommendations

1. Reduce the quantities of hazardous waste generated at the university by following proper waste reduction procedures, e.g., buying non-toxic products.
2. Provide proper storage containers to areas producing hazardous waste.
3. Pick up hazardous waste in a timely manner.
4. Ensure that all departments are aware of the hazardous waste program.
5. Train appropriate personnel in hazardous waste disposal procedures.
6. Detoxify chemicals as a last step in laboratory experiments.

Hazardous Waste Reduction

Alternatives to hazardous waste disposal are needed because of concerns about the environment and the rising cost of land filling and incineration. One strategy that is increasingly being used is to reduce the volume of waste generated. Waste reduction saves money, reduces the amount of hazardous materials in the work place, and decreases the amount of pollutants in the environment. Waste reduction activities include the use of smaller quantities, using less hazardous materials, and the redistribution of surplus chemicals that may become waste. Recognizing the importance of waste reduction, Virginia Hazardous Waste Regulations require that generators take steps to minimize the amount and toxicity of chemical waste.

Current Practices

1. Chemicals are purchased in the smallest quantities needed for immediate use. This reduces storage space, potential for chemical accidents, cost of disposal, and environmental pollution. Disposal costs can easily offset any savings incurred from purchasing larger quantities.
2. Whenever possible, hazardous chemicals are replaced with less hazardous chemicals to reduce the amount and toxicity of waste.
3. Donations and samples of chemicals are not accepted unless an immediate use is planned.
4. Processes are modified to generate less hazardous waste by using smaller amounts of chemicals, substituting less hazardous material, recycling the material in the process, making equipment changes, and using more instrument techniques.
5. Efforts are being made to recycle hazardous waste and to reduce the quantity of pollutants in the environment. For example, waste mercury and oil are recycled into usable materials and silver is recovered from photographic waste.

Recommendations

1. When hazardous materials are supplied for research purposes written agreements should include a provision for the return of unused amounts to the supplier.
2. Commonly used chemicals should be stored in a departmental central stockroom. This can reduce the volume of chemicals because workers can check the stockroom before ordering new chemicals.
3. Each department should maintain an inventory of chemicals. The inventory should be examined before chemicals are purchased. An inventory can reduce unknowns, chemical degradation, and duplicate purchases.
4. A chemical surplus program should be developed to exchange unneeded chemicals among laboratories. A list of available chemicals should be distributed periodically to all departments. This can result in significant savings on purchasing new chemicals and reduce disposal costs.
5. Laboratories and chemical stockrooms should be cleaned out periodically. Some chemicals degrade over time forming explosive by-products. Labels can be obliterated by corrosion or fall off. The disposal of explosives and unknowns can be very expensive.
6. When laboratory workers leave the university, all chemicals under their control should be identified and made available to other laboratories. Ensuring that all chemicals are identified to prevent the accumulation of unknowns is important.
7. Reduce or eliminate the hazard at the point of generation. Experiments should include consideration for the disposal of starting material and end products. If possible, chemical experiments should be designed to render waste less hazardous or nonhazardous at the end of the experiment. For example, neutralization of acids and bases should be part of laboratory experiments. This can reduce the volume and toxicity of waste and may avoid difficult disposal problems.
8. Using micro scale techniques can reduce the quantity of hazardous waste generated in teaching laboratories. These scaled-down experiments use smaller quantities of reagents and can lead to significant savings in costs of chemicals, energy, apparatus, space, and disposal costs.
9. The volume of waste can be reduced by separating nonhazardous from hazardous chemicals, evaporating aqueous solutions to concentrate toxic metals, and completely using materials such as paint and pesticides.
10. Unused chemicals (never opened) and gas cylinders should be returned to the manufacturer or surplused.

Toxic Chemicals

Current Practices

1. A Chemical Hygiene Plan has been written for the university. The Chemical Hygiene Plan is designed to prompt the safe handling of chemicals in laboratories. It describes the proper use and storage, incompatibilities, waste management techniques, and training methods. If laboratories follow the guidelines in the plan, the amount of pollution entering the environment can be significantly reduced.
2. A Hazard Communication Program has been established to inform non-laboratory workers of potential occupational hazards associated with chemicals in their workplace. Ways to protect themselves from exposure through chemical substitution, personal protective equipment, and engineering techniques are described. This is directly related to Pollution Prevention because it informs the worker through training of proper chemical handling and storage techniques, waste disposal techniques, and emergency procedures if a spill occurs.
3. Polychlorinated Bi-phenyls (PCBs) are contained in most ballasts manufactured prior to 1979. A large majority of the ballasts have been replaced with non-PCBs ballasts through regular preventive maintenance programs. All PCBs ballasts are sent to a recycling company. The PCBs capacitor is removed and incinerated. The remaining asphalt, copper, and steel are recycled. Non-PCBs ballasts containing DEHP are also recycled. There are no PCBs transformers under university control on the campus.
4. Although °ÄÃÅÀÏÆæÈËÂÛ̳ is not using radioactive materials at this time, the university is licensed to handle radioactive materials for teaching and research purposes. A comprehensive Radiation Safety Plan has been written in case the need arises. The plan includes procedures for the proper use and disposal of radioactive materials. By following this plan, the potential for radioactive contamination of the environment can be greatly reduced.
5. All buildings on campus have been surveyed for asbestos. Abatement projects are performed by licensed asbestos contractors. Housekeepers have been trained in asbestos awareness.
6. Lead based paints are removed by licensed contractors. Batteries are recycled. Lead paint is not used.
7. Pesticide toxicity is kept to a minimum. Restricted use pesticides are not used. Irrigation injection is used to replace spraying of pesticides or pesticides are applied in dry powdered form, then watered into the soil.
8. A Chemical Spill Plan has been written for the university. The purpose of this plan is to minimize hazards to human health, property, and the environment from unplanned releases of hazardous chemicals.

Recommendations

1. Train personnel in chemical handling procedures, asbestos awareness, and lead paint awareness.
2. Conduct periodic inspections to ensure compliance with the Chemical Hygiene Plan and Hazard Communication Program.
3. Ensure that all PCB ballasts have been replaced with non-PCB ballasts.
4. Develop a lead paint program to protect workers and the environment from lead pollution.
5. Investigate the use of integrated pest management techniques to reduce the use of pesticides.
6. Centralize the purchase, storage, and distribution of chemicals through a single location on campus.
7. Buy non-toxic chemicals whenever possible.
8. Never pour toxic chemicals into the sanitary sewer system, storm drains, trash, or on to the soil.
9. Develop a chemical surplus program for the university.

6.0 The RRRs to Waste Minimization

The RRRs to waste minimization are reduce, reuse, and recycle. Reduce means to use less, reuse is to use a material again without changing it, and recycle is to put material back into service once it has been changed. The RRRs minimize the amount of waste produced at the university and reduce disposal problems. They are also less polluting, save money, and are more energy efficient than taking new materials from the environment.

Reduce

The best way to practice pollution prevention is to eliminate and minimize the generation of waste through source reduction. To reduce waste output, reducing waste input is necessary. Reducing material input lowers the amount of resources used at the university and reduces the amounts of waste landfilled or recycled.

Current Practices

1. The following types of reduction are currently in place at the university:
   1. Limit over stocking by ordering items as needed and rotating inventory utilizing first in, first out procedures.
   2. Properly handle raw materials and maximizing the use of raw materials.
   3. Substitute nonhazardous chemicals for hazardous chemicals.
   4. Photocopy reports on both sides of paper.
   5. Scale down the volumes of chemicals used in laboratories and using instruments instead of wet chemistry procedures.
   6. Proper labeling of containers and using all chemicals sparingly.
   7. Segregate hazardous waste from nonhazardous waste.

Recommendations

1. Send E-mail instead of office memos.
2. Correct first drafts on the computer rather than printing it.
3. Cancel junk mail as much as possible.
4. Buy products without excessive packaging.

Reuse

Reusing materials minimizes waste generation and reduces costs.

Current Practices

1. The following types of reuses are currently in place:

1. Using paper with print only on one-side for scrap paper.
2. Chemicals are shared among departments.
3. Gas cylinders and empty 55-gallon drums are returned to the manufacturer.
4. Equipment is reused until it is unserviceable.
5. Canvas is reused in the Art Department.

Recommendations

1. Reuse manila file folders.
2. Reduce the use of "disposable items" in the cafeteria.
3. Develop a university wide chemical surplus program to reuse unneeded chemicals.
4. Buy rechargeable batteries whenever possible.
5. Reuse water in the car wash facility.

Recycling

Recycling is the last stage in the waste minimization process. Recycling uses discarded material as a raw material for producing a new product. The purpose of recycling is to save resources and reduce the solid waste stream leaving the university. Radford University started a voluntary recycling program in 1990 and has recycled approximately 1,500 tons to date.

Current Practices

1. 1. The university is currently recycling the following materials:
   1. 55-gallon drums
   2. Aluminum cans
   3. Bimetal cans
   4. Batteries
   5. Cardboard
   6. CFCs
   7. Cooking grease
   8. Fluorescent lights
   9. Food waste
   10. Glass
   11. Lawn waste
   12. Light ballasts
   13. Mixed paper
   14. Mercury
   15. Newspapers
   16. Phone books
   17. Scrap metal
   18. Silver
   19. Styrofoam
   20. Toner cartridges
   21. Tires
   22. Used oil
   23. Wooden pallets
2. Recycling containers are located at strategic locations throughout the campus.

Recommendations

1. Ensure that there are an adequate number of recycling containers on campus.
2. Train personnel concerning the recycling program on campus.
3. Develop postings and handouts concerning recycling.
4. Explore other options including:
   1. Aerosol cans
   2. Antifreeze
   3. Computer floppy disks & compact disks
   4. Computer monitors
   5. Concert, masonry waste
   6. Office paper
   7. Plastic containers
   8. Polystyrene packing & peanuts
   9. Sawdust
   10. Smoke detectors
   11. Used oil filters
5. Purchase more materials with recycled content.
6. Relocate some recycling containers to ensure maximum use by personnel & students.

7.0 Energy Conservation

The purpose of energy conservation is to reduce air pollution produced by the generation of electricity. Energy consumption is a prime source of air pollutants that contribute to acid rain, smog, and global warming. By conserving energy and using more energy-efficient equipment the university can reduce pollution and save money.

Cooling and Heating

Current Practices

1. The campus HVAC system is computer automated to control temperatures. The system monitors kilowatts used and will shut down parts of the system to conserve energy during peak periods.
2. An economizer modes mixes cold outside air with the building air, rather than switching to the air-conditioning cycle.
3. A night-set-back is an automated system in use that cuts back the normal set temperatures for occupancy, to unoccupied setting after a designated time and returns to the occupancy mode at a designated time. The system will also monitor the temperature throughout the day and adds heated or cooled air when needed, instead of running continuously.
4. A hot water reset was installed to monitor the outside air temperature and calculate heating requirements to determine amounts of heating required to reach the desired temperature.
5. Chiller resets have been installed in several locations to monitor outside air temperature then calculates cooling requirements to determine amounts of cooling required to reach the desired temperature.
6. Carbon dioxide sensors have been installed in several rooms to monitor the levels of carbon dioxide via the number of persons per room. The amount of fresh air introduced into the system is based on the carbon dioxide level. This reduces the amount of energy to heat or cool the fresh air makeup.
7. Free-Cooling units are used. Water recirculated from heating is returned to a heat exchanger where the chiller water is returned. Through convection, the chiller water is warmed, and the heated water is cooled with no mechanical means except a recirculation pump to move the water.
8. Hot water heaters are set at 120 oF instead of 140 oF.
9. An economizer is used on the boilers. The device heats makeup water for the boilers through convection by heating the water using stack gas.
10. Steam tunnel pipes are insulated to reduce thermal loss.
11. All buildings on campus are being retrofitted with energy efficient windows.
12. Filters on air conditioners are replaced on a routine schedule.

Recommendations

1. Ensure that thermostats are set at 68 oF in the summer and 78 oF in the winter.
2. Explore new technologies such as geothermal heat pumps and solar thermal water heating.
3. Continue to install carbon dioxide sensors and energy efficient windows.
4. Investigate the prevalence of supply fan over sizing. Ideally, fan systems should be 10 percent oversized to accommodate degradation of the system and changes within the room.
5. Use more efficient shower heads and washing machines to conserve hot water and heating energy.

Lighting and Appliances

Current Practices

1. Lighting has been upgraded to be more energy efficient. Magnetic ballasts have been replaced with electronic ballasts. This reduces electric usage and does not produce as much heat. Therefore, less energy is used for cooling.
2. T12 florescent lights that operate at 35-40 watts have been replaced with T8 lamps that operate at 32 watts.
3. Approximately seventy percent of the campus is complete.
4. The quantity of ballasts have been reduced by 50 percent.
5. °ÄÃÅÀÏÆæÈËÂÛ̳ is a Green Light partner. Green Lights is a program sponsored by the EPA that encourages major corporations and other organizations to reduce pollution by installing energy-efficient lighting technologies.
6. Motion sensor detectors that control lighting are installed in most classrooms.
7. Exit lights are being changed from 25 watts to 6 watts LED lights.
8. Converting 100 watts incandescent lights to 13 watt fluorescent lamps.
9. Campus Lighting Control is an automated system that is photosensitive. The lights will not turn on during low light conditions because they are controlled by sunup to sundown times calculated daily.
10. Energy Star computers are purchased.
11. Equipment is turned off when not in use.

Recommendations

1. Complete upgrade of campus lighting to more energy efficient fluorescent lamps.
2. Install motion detectors in all classrooms.
3. Complete exit light change over to LED lights.
4. Complete conversion of incandescent lights to fluorescent lamps.
5. Explore new technologies such as solar lighting.
6. Encourage campus personnel to turn lights off when not in use and reduce lighting in offices.
7. Consider posting "turn off lights" signs by light switches.
8. Purchase more Energy Star office equipment such as computers, monitors, printers, fax machines, and copy machines.
9. Use timers on some equipment to shut them down during off hours.
10. Select more energy efficient appliances such as refrigerators, freezers, water heater, dishwashers, clothes washers, air conditioners, and heat pumps.
11. Schedule building cleaning to minimize time lights are on and spaces are conditioned.
12. Leave at least one inch on each side of refrigerators and freezers to allow for adequate air flow to carry heat away.
13. Install refrigerators and freezers away from heat sources and out of direct sunlight.
14. Keep condenser coils clean.

Transportation

Current Practices

1. Fuel efficient vehicles are purchased for fleet use.
2. Campus vehicles are regularly tuned, air filters changed, and tires inflated to proper pressure.
3. Engine oil and oil filters are changed on a routine basis; "SG" rated oil is used.

Recommendations

1. Explore the use of alternative fueled vehicles such as natural gas, propane, alcohol, electricity, or solar to reduce air pollution. 
2. Encourage personnel to carpool and drive fuel efficient cars. 
3. Purchase electrically powered golf carts instead of gasoline powered.
4. Encourage campus personnel to walk more and drive less.
5. Train personnel on proper driving techniques that save energy.

8.0 University Departments - Assessment

To determine potential sources of pollution at the university the following list was generated of possible chemical users, associated waste streams, energy conservation practices, and recyclables.

All Departments

• Aluminum
• Cardboard
• Chemicals
• Empty containers
• Energy conservation
• Glass
• Hazardous waste
• Housekeeping
• Inventory control
• Maintenance programs
• Paper
• Plastic
• Photocopies
• Toner cartridges

Art Department

• Clay
• Mineral spirits
• Metal waste
• Oil-based paints
• Photography
• Rags

Biology Department

• Acids
• Bases
• Cleaners
• Preservatives
• Solvents
• Toxic chemicals

Boiler Plant

• Air emissions
• Cleaners
• Energy conservation
• Fuels
• Rags
• Solvents

Bowling Alley

• Solvents
• Waxes

Campus Card and ID

• Inks
• Silver
• Solvents

Carpenter Shop

• Glues
• Paints
• Sawdust
• Solvents
• Stains
• Wood preservatives

Central Warehouse

• Inventory control
• Cardboard
• Pallets
• Shrink wrap

Chemistry Department

• Acids
• Bases
• Cleaners
• Metals
• Solvents
• Toxic chemicals

Communication Department

• Batteries

Electrical Shop

• Ballasts
• Fluorescent lights
• Heavy metals

Food Services

• Acids
• Aluminum
• Cardboard
• Cleaners
• Food waste
• Grease
• Pallets
• Tin cans

Health Services

• Biological

Housekeeping

• Cleaners and strippers

HVAC

• CFCs
• Refrigeration oil
• Refrigerants

Geography Department

• Ammonia

Geology Department

• Solvents
• Inorganic compounds

Landscaping

• Fertilizers
• Herbicides
• Mowers
• Water conservation

Laundry

• Detergents
• Water conservation

Mason/Plaster

• Paints
• Solvents
• Muriatic acid
• Sheet metal

Material Management

• Inventory control (first in, first out)
• Cardboard

Motor Pool

• Antifreeze
• Batteries
• Brake fluid
• Car parts
• Grease
• Mineral spirits
• Oil
• Rags
• Transmission fluid
• Used filters

Nursing Department

• Infectious waste
• Mercury
• Pharmaceuticals
• Toxic chemicals

Paint Shop

• Mineral spirits
• Oil-based paint
• Rags

Photocopy

• Toner cartridges
• Paper

Planning and Construction

• Ammonia

Plumbing Shop

• Heavy metal
• Scrap metal
• Glue
• Water conservation

Pool

• Disinfectants
• Toxic chemicals
• Water conservation

Police Department

• Batteries
• Scrap metal

Printing Services

• Film
• Inks
• Photo chemicals & silver
• Solvent

Psychology Department

• Waste solvent

Student Life and Student Newspaper

• Film
• Marker pens
• Paper
• Photo chemicals & silver

Steam Tunnels

• Asbestos
• Water conservation

Theater Department

• Glues
• Metal
• Paints
• Plastics
• Wood

Assessment Form

The purpose of the assessment form was to determine existing pollution prevention activities in each workplace. This survey formed the basis for identifying pollution prevention opportunities at the university. The following form was disseminated campus-wide:

Pollution Prevention Form

The provisions of House Joint Resolution 453, adopted by the 1995 General Assembly, mandated that Pollution Prevention be created. Subsequently, the Department of Environmental Quality requested that all state agencies comply, which includes °ÄÃÅÀÏÆæÈËÂÛ̳. Pollution Prevention is the way of the future. Pollution Prevention can save money, lower operating costs, improve public image, create a healthier work environment, reduce the risk of liability, and protect the earth for generations to come. Therefore, °ÄÃÅÀÏÆæÈËÂÛ̳’s Environmental Health & Safety Department has established this checklist to evaluate your work area. Please fill out all information as soon as possible and return to Mr. Ross Roberson, P.O. Box 6909. Any questions concerning this mater should be direct toward Mr. Ross Roberson, Environmental Inspector at extension 5855 or Mr. Tom Smithwick, Safety Director at extension 5860. Thank you for your time.

NAME:

DATE:

PHONE:

FACILITY RESPONSIBILITIES:

JOB DESCRIPTION:

Check the chemicals used or wastes generated at your facility:

acids	air emissions	aluminum	ammonia	anitfreeze
asbestos	ballasts	bases	batteries	biological
brake fluid	car parts	bardboard	CFOs	clay
cleaners	detergents	disinfectants	fertilizers	film
fluorescent lights	food waste	fuels	glass	glues
grease	heavy metals	herbicides	infectious waste	inks
inorganics	mercury	metal waste	mineral spirits	muriatic acid
oil	paint	paper	photo chemicals	plastic
rags	scrap metal	sheet metal	silver	solvents
stains	strippers	toner cartidges	used filters	waste solvent
wood

Are there any other chemicals used or wastes generated not listed above, if so list them?

Check types of recycling currently in practice at your facility?

aluminum	antifreeze	batteries	cardboard	ballasts
film	fluorescent lights	oil	paper	silver
mercury

Are there any other types of recycling currently in practice at your facility, if so list them?  

What types of waste reduction is currently in practice at your facility?

What is in the future for your facility for waste reduction?

What types of recycling is in the future at your facility?

9.0 University Departments - Strategies

The following pollution prevention strategies were developed through inspections and interviews with departmental heads and supervisory personnel.

Art Department

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Substituted low odor mineral spirits for turpentine and the Print Making shop substituted water-based inks for solvent-based inks.
3. Preventive Maintenance inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Undergraduates are required to take a laboratory safety course that covers chemical usage and health hazards.
5. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper. Painted canvases are painted over and repainted. Students routinely reuse solvents from paint brush cleaning as a thinner. Collage course uses waste, trash, old paint, and paper to make art. Video Art reuses video camera film. Photography reuses slide borders until unserviceable.
6. Students buy their own supplies, which promotes conservation. Raw materials are properly handled to avoid spills, leaks or contamination. All chemicals are used sparingly. The computer laboratory uses a digital camera, which uses no film or chemicals.
7. Old computers and hardware are pooled for reuse or sold at surplus.
8. Solvent waste is segregated to increase recyclability. Silver is recovered from spent fixers. Hazardous waste is disposed of properly.
9. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
10. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. Two rooms have automated lighting.
11. Solvent soaked rags are placed in oily waste cans.
12. Cardboard, paper, silver recovered from film, and toner cartridges are recycled.

Recommendations

1. Recycle Styrofoam, aluminum cans, old clay and used photographic film and paper.
2. Mish Mish has a product called Max Oil-based Paint, which cleans-up with soap and water. The paint ranges from $4.89 to $10.79 per tube depending upon color. This would save the students money because they require no solvents for cleanups. This would also cut down on hazardous waste disposal costs of waste solvents and contaminated rags.
3. Continue to search for an environmentally friendly substitute for mineral spirits.
4. Use water-based glues rather than solvent-based glues, whenever possible.
5. Use lead-free glazes for pottery.
6. Use pre-mixed clays.

Biology Department

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Substituted detergents instead of solvents for glassware cleaning, whenever possible. Sodium hypochlorite is used instead of sodium dichromate, alcohol instead of benzene, formaldehyde-free products for preserving specimens rather than formaldehyde.
3. Raw materials are properly handled to avoid spills, leaks or contamination. Chemicals are pre-weighted for undergraduate usage.
4. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper.
5. Chemical volumes used in laboratory experiments are scaled down. Instruments are used more than wet chemistry. All chemicals are used sparingly. Waste destruction is the final procedure for many experiments; an example is the neutralization of acids. Secondary containers are properly labeled to reduce waste.
6. Solvent waste is segregated to increase recyclability. Hazardous waste is disposed of properly.
7. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty gas cylinders are exchanged on a 1:1 basis.
8. Bulk chemicals are directly pumped to lower the risk of spillage. Pumps are dedicated to reduce cleaning.
9. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
10. Aluminum cans, cardboard, paper, and toner cartridges are recycled.

Recommendations

1. Recycle Styrofoam.
2. Conduct periodic laboratory inspection to ensure proper handling of chemicals. This can reduce the potential to release chemicals into the environment.
3. Continue to substitute less hazardous chemicals for more hazardous chemicals.

Boiler Plant

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Water-based or latex paint has been substituted for solvent-based and oil-based, where applicable. All paints used are lead-free.
3. Preventive Maintenance Program has been established to find problems before they happen. This prevents leaks and prolongs equipment life. The steam tunnels are inspected weekly for leaks. If other problems are noted, they are reported to the responsible party for repair. Storage tank containment areas are inspected after periods of rainfall to note any leaks or to remove rainwater via an oil-water separator, to ensure holding capacity. Water makeup for steam generation is monitored daily, to note any substantial loss.
4. Raw materials are properly handled to avoid spills, leaks or contamination. Funnels are dedicated to specific equipment to prevent cross contamination.
5. Reports are photocopied on both sides of the paper. Paper with print on one-side is used for scrap paper. Piping removed is reused whenever possible.
6. Containers are completely emptied to maximize raw materials. Secondary containers are properly labeled. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty 55-gallon drums are returned to the manufacturer.
7. Bulk chemicals are stored in barrel saddles with an attached spigot. Drip pans are utilized to prevent spillage. Funnels and spigot are dedicated to reduce cleaning or cross contamination.
8. The oil storage tanks are equipped with low flow and high volume automatic shut off. The two 50,000-gallon oil storage tanks will be equipped with leak detection by means of a floating device that will set-off an alarm to warn of rapid fuel lose. The three new boilers are equipped with low nitrous oxide burners to increase burning efficiency.
9. Solvent waste is segregated to increase recyclability. Solvent soaked rags are properly containerized for hazardous waste disposal.
10. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. Steam pipes are insulated to conserve energy.
11. Aluminum, batteries, cardboard, metal, oil, and paper wood are recycled.

Recommendations

1. Recycle antifreeze and toner cartridges.
2. Improve general housekeeping for the 55-gallon drums dispensing area. Ensure all drums have drip pans.
3. Investigate the use of less hazardous boiler water treatment chemicals.
4. Investigate the use of non-drip transfer pumps.

Bowling Alley

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Raw materials are properly handled to avoid spills, leaks or contamination.
3. Containers are completely emptied to maximize raw materials.
4. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
5. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
6. Chemicals were evaluated and no substitutions are currently available.
7. Aluminum cans, glass, and paper are recycled.

Recommendation

1. Continue to search for less hazardous chemicals.

Carpenter Shop

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Water based paint are substituted for solvent or oil-based paint as much as possible, which remove the need for mineral spirits. Lead and cadmium free paints are used.
3. Regular inspections are preformed to find problems before they happen. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Paper with print only on one-side is used for scrap paper. Door stops, door closers, panning devices, exit devices, lumber, and plywood are reused until non-serviceable.
5. Reports are photocopied on both sides of paper.
6. All chemicals are used sparingly. Containers are completely emptied to maximize raw materials.
7. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
8. Aluminum cans, batteries, cardboard, metal, wood, oil, paper, and Styrofoam are recycled.

Recommendations

1. Use a closed container for soaking and cleaning paint brushes. This will save raw materials and reduce air emissions.
2. Collect mineral spirits soaked rags and contact cement contaminated rags for hazardous waste disposal.
3. Substitute water-based paint for solvent-based paint, whenever possible.
4. Continue to explore possible reuses of sawdust.

Chemistry and Physics Department

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures. Minimum quantities are ordered.
2. Substituted detergents instead of solvents for glassware cleaning, whenever possible. Sodium hypochlorite is used instead of sodium dichromate, and alcohol instead of benzene.
3. Raw materials are properly handled to avoid spills, leaks or contamination. Chemicals are pre-weighted for undergraduate usage.
4. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper.
5. Chemical volumes used in laboratory experiments are scaled down. Instruments are used more than wet chemistry. All chemicals are used sparingly. Waste destruction is the final procedure for many experiments; an example is the neutralization of acids. Secondary containers are properly labeled to reduce waste.
6. Solvent waste is segregated to increase recyclability. Hazardous waste is disposed of properly.
7. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty gas cylinders are exchanged on a 1:1 basis.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
9. Aluminum cans, cardboard, paper, silver, mercury, and toner cartridges are recycled.

Recommendations

1. Conduct periodic laboratory inspection to ensure proper handling of chemicals. This can reduce the potential to release chemicals into the environment.
2. Mercury thermometers should be substituted with non-mercury thermometers.
3. A chemical surplus program should be developed to exchange unneeded chemicals among laboratories. A list of available chemicals should be distributed periodically to all departments. This can result in significant pollution reduction.
4. Ensure that ethers are dated to prevent the formation of dangerous peroxides.
5. Continue to search for less hazardous chemicals.
6. Increase in-lab destruction of waste chemicals as part of the final step in laboratory experiments.

Communication Sciences and Disorders

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper.
5. Instruments are used more than wet chemistry. All chemicals are used sparingly. Solvent waste is segregated to increase recyclability.
6. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
8. Paper and toner cartridges are recycled.

Recommendation

1. Recycle aluminum cans and batteries.

Dedmon Center Pool

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Paper with print only on one-side is used for scrap paper.
5. Reports are photocopied on both sides of paper. All chemicals are used sparingly.
6. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty 30-gallon drums are returned to the manufacturer and empty gas cylinders are exchanged on a one to one basis.
7. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. The pool is always manned during filling to ensure no overfilling. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. Half the available lighting is used to save energy and light bulbs.

Recommendations

1. Substitute a less hazardous disinfectant for gas chlorine.
2. Purchase a chlorine gas monitor.

Electrical Shop

Current Practices

1. Preventive Maintenance Programs are performed to find problems before they happen. This prevents leaks and prolong equipment life.
2. Raw materials are properly handled to avoid spills, leaks or contamination.
3. Paper with print only on one-side is used for scrap paper.
4. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
5. Containers are completely emptied to maximize raw materials. Empty 55-gallon drums are returned to manufacture.
6. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
7. Aluminum, batteries, PCB & Non PCB ballasts, cardboard, fluorescent bulbs, metal, oil, and paper are recycled.

Recommendations

1. Photocopy reports on both sides of the paper.
2. Recycle clear and green glass and mercury switches.
3. Collect mineral spirits soaked rags and contact cement contaminated rags for hazardous waste disposal.
4. Substitute lead-free solders for lead-based solders.

Electronic Machine Repair

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Low lead-based solders are used.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Paper with print only on one-side is used for scrap paper.
6. Containers are completely emptied to maximize raw materials. Empty 55-gallon drums are returned to manufacture. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
8. Aluminum, batteries, and cardboard are recycled.

Recommendations

1. Recycle batteries, paper, silver, and toner cartridges.
2. Neutralize acid soaked rags or paper before disposal.
3. Recycle cathode ray tubes and computer monitors.
4. Substitute lead-free solders for lead-based solders.

Fashion Department

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. All chemicals are used sparingly. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Secondary containers are properly labeled to reduce waste.
5. Containers are completely emptied to maximize raw materials. Empty chemical containers are given to the Chemistry Department for reuse.
6. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
7. Aluminum, cardboard, and paper are recycled.

Recommendation

1. Recycle toner cartridges.

Food Services at Dalton Hall

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Styrofoam has been substituted for paper for carry out items.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
4. Pallets are returned to the Distribution Center on a 1:1 basis. Milk crates are returned to the manufacturer. Disposable items have been replaced with non-disposables whenever possible.
5. Raw materials are properly handled to avoid spills, leaks or contamination.
6. Containers are completely emptied to maximize raw materials. Empty 55-gallon drums are returned to manufacture. Plastic wraps associated with laundered uniforms are returned to laundry facilities for reuse.
7. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. The exhaust fans used are on timers.
9. Grease traps have been installed to reduce the amount of oil and grease in the wastewater. Waste food collection has been implemented to reduce the amount of BOD in the wastewater.
10. Grease is sent to a renderer.
11. Cardboard, paper, metals, tin cans, and toner cartridges are recycled.

Recommendations

1. Recycle shrink wrap.
2. Investigate integrated pest management techniques to find environmentally friendly substitutions for pesticides currently being used.
3. Continue to search for less hazardous chemicals for the acid descaler.

Food Services at Muse Hall

Current Practices

1. Over stocking is limited by ordering items that degrade quickly as needed and rotating inventory utilizing first in, first out procedures.
2. Recycled Styrofoam has been substituted with paper.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
4. Grease waste is used at another plant for raw material. Pallets are returned to the Distribution Center on a 1:1 basis. Milk crates are returned to the manufacturer.
5. Raw materials are properly handled to avoid spills, leaks or contamination.
6. Containers are completely emptied to maximize raw materials.
7. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. The exhaust fans used are on timers.
9. Grease traps have been installed to reduce the amount of oil and grease in the wastewater.
10. Aluminum, cardboard, grease, tin cans, and paper are recycled.

Recommendations

1. Return coat hangers to National Linen Services for reuse.
2. Recycle shrink wrap.
3. Recycle broken forks, spoons, metal trays, and any other metals.
4. Waste food collection should be implemented to reduce the amount of BOD in the wastewater.

Geology Department

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
3. Empty 55-gallon drums are returned to the manufacturer on a 1:1 basis.
4. Reports are photocopied on both sides of paper. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Containers are completely emptied to maximize raw materials. All chemicals are used sparingly. Paper usage is maximized by generating as many copies of short documents out of a single sheet of paper, as possible.
6. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
8. Hazardous waste is disposed of properly.
9. Aluminum, cardboard, oil, paper, packaging material, Styrofoam, toner cartridges, and old exams are recycled.

Recommendation

1. Properly label secondary containers to reduce waste and better utilize raw materials.

Health Services 

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolong equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination. Chemicals are pre-weighted for undergraduate usage.
4. Undergraduates are taught laboratory safety before handling chemicals.
5. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper. Food products and leftovers are reused as much as possible.
6. Chemical volumes used in laboratory experiments are scaled down. Instruments are used more than wet chemistry. All chemicals are used sparingly. Waste destruction is the final procedure for many experiments; an example is the neutralization of acids. Secondary containers are properly labeled to reduce waste. Rarely used chemicals are borrowed and returned.
7. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty gas cylinders are exchanged on a 1:1 basis.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
9. Paper and toner cartridges are recycled.

Recommendations

1. Recycle aluminum cans.
2. Keep mercury thermometers in secondary containers to prevent breakage and contamination.
3. Substitute mercury thermometers with non-mercury thermometers.

Housekeeping

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Substituted non-bleached towels for bleached towels.
3. All housekeepers are responsible for reporting maintenance problems as soon as possible, and are evaluated on this skill, annually. Housekeeping trains personnel on proper handling, usage and dilution ratios of chemicals used to avoid spills, leaks or contamination. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
5. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
6. Environmentally friendly products are purchased whenever possible. Environmental Safety office is contacted before purchasing chemicals for possible substitutions.
7. Aluminum, batteries, cardboard, newspaper, and paper are recycled.

Recommendations

1. Properly label secondary containers to reduce waste and better utilize raw materials.
2. Continue to purchase environmentally friendly products, whenever possible.

HVAC Department

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Non-alkaline chemicals have been substituted for alkaline descalers.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life. Inventory control of CFCs is in place. Personnel document quantities used to determine amounts recovered or replenished.
4. Paper with print only on one-side is used for scrap paper.
5. All chemicals are used sparingly. Propylene glycol has been substituted for ethylene glycol.
6. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Bulk chemicals are directly pumped to lower the risk of spillage and pumps are dedicated to reduce cleaning.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Water from the cooling towers is recycled. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. HVAC systems are automated for energy conservation.
9. Metal, oil, and CFCs are recycled.

Recommendation

1. Purchase the most energy efficient units whenever possible.

Jewelry Department

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Potassium liquor sulfur was substituted for sodium cyanide. Solders are lead and cadmium free.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Undergraduates are taught laboratory safety before handling chemicals.
6. Paper with print only on one-side is used for scrap paper.
7. Reports are photocopied on both sides of paper. Secondary containers are properly labeled to reduce waste.
8. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Empty gas cylinders are exchanged on a 1:1 basis.
9. Hazardous waste is disposed of properly.
10. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
11. Aluminum, metal, oil, paper, and silver toner cartridges are recycled.

Recommendations

1. Use oil-based paints that cleanup with soap and water. This would save the students money because they require no solvents for cleanups. This would also cut down on hazardous waste disposal costs of waste solvents and contaminated rags.
2. Use nontoxic paints that are lead and cadmium free.
3. Use an environmentally preferred degreaser for cleanups.
4. Ensure that students receive more information on environmentally friendly products.

Landscaping

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Peladow chemical has been substituted for salt as an ice remover, because it is more effective, and reduces the amounts used. Peladow reduces waste because it does not harm vegetation or concrete.
3. A Preventive Maintenance program is currently under development to find problems before they happen.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Items are separated for the tube grinder at the landfill to make mulch.
6. All mowers are purchased with mulching decks.
7. Irrigation injection is used to replace spraying of pesticides or pesticides are applied in dry powder form, then watered into the soil.
8. Reports are photocopied on both sides of paper.
9. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Pesticide containers are tripled rinse with the rinsate utilized for application. All pesticides are used sparingly. Pesticide toxicity is kept at a minimum and restricted-use pesticides are not used. Old pesticides are disposed of as hazardous waste.
10. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. The irrigation system has a rain-sensor to prevent over-watering and has an automatic cutoff. The irrigation system is pressurized and is periodically checked for leakage. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
11. Aluminum, batteries, biodegradable (brush & leaves), cardboard, glass, metal, paper, and Styrofoam are recycled.

Recommendations

1. When purchasing new equipment, evaluate the fuel efficiency, a rating of 10 is the best.
2. Use paper with print only on one-side, for scrap paper or notes.
3. General housekeeping should be improved when handling pesticides to minimize contamination. Funnels should be used when transferring chemicals to prevent spills.
4. Properly labeling secondary containers of pesticides will maximize raw materials and reduce the amounts of unknown hazardous waste for disposal.
5. Investigate the use of integrated pest management techniques and products to find environmentally friendly substitutions.
6. Provide a secondary containment system for pesticide storage.

Mason/Plaster/Paint Department

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. All masonry paint is latex. Latex traffic paint has been substituted for oil-based. Water-based has been substituted for solvent-based and oil-based paint campus wide where applicable. Oil-based paint is used only for high traffic areas, and bathrooms. All paints are lead-free.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination. Funnels are dedicated to specific equipment to prevent cross contamination.
5. Paper with print on one-side is used for scrap paper. Water damage ceiling tiles are repainted and reused whenever possible.
6. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Solvent waste is segregated to increase recyclability. Solvents are not evaporated from old paints. Old paints are bulked and surplused.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
9. Aluminum, batteries, cardboard, glass, metal, oil, paper, Styrofoam, and wood are recycled.

Recommendations

1. Recycle D-cell batteries.
2. Photocopy reports on both sides of the paper.
3. Place solvent soaked rags in a flammable storage container for disposal as hazardous waste.

Motor Pool

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Preventive Maintenance is performed to find problems before they happen. This prevents leaks and prolongs equipment life. The carwash and bays have an oil water separator in place to minimize wastewater pollution.
3. Used antifreeze is reused to top off old machinery.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. At least twelve inches of freeboard is maintained on the solvent parts washer to prevent evaporation.
6. Paper with print on one-side is used for scrap paper.
7. Containers are completely emptied to maximize raw materials. Secondary containers are properly labeled. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions. Oil filters are drained for at least 24 hours before disposal.
8. Solvent waste is segregated to increase recyclability. Asbestos dust from brake jobs is captured and collected for proper disposal.
9. Bulk chemicals are directly pumped to lower the risk of spillage and pumps are dedicated to reduce cleaning. Spigots and funnels are used when dispensing materials to reduce the possibility of spills. Drip pans are used to collect oils and fluids. Hand cleaner is utilized, instead of mineral spirits to clean grimy hands.
10. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. The sink for hand washing has an automatic shut-off. The car wash has an automatic shut-off. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. The car wash is automated.
11. Aluminum, batteries, cardboard, car parts and metal, oil, paper, and tires are recycled.

Recommendations

1. Recycle antifreeze, hydraulic oil, brake fluid, and oil filters.
2. Perform a periodic safety inspection to ensure compliance with the Hazard Communication Plan. This will reduce pollution by finding problems before they happen.
3. Replace the two solvent parts washers with a less toxic and environmentally friendly alternative.
4. Reuse empty 55-gallon drums for waste oil or waste antifreeze collection drums.
5. Place solvent soaked rags in a flammable storage container for disposal as hazardous waste.
6. Provide a catchment basin for the 500-gallon waste oil above ground storage tank.
7. Investigate the feasibility of reusing the car wash waste water.
8. Increase the mileage between oil and filter changes.
9. Substitute propylene for ethylene glycol antifreeze.
10. Investigate the use of a commercial laundry to service rags for reuse.

Planning and Construction

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Contractors are specified to use water-based paint as a substitute for solvent-based and oil-based applications. Contractors are specified to use oil-based paints only for high traffic areas, and bathrooms. Contractors are specified to use paints that are lead-free.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Reports are photocopied on both sides of the paper. Paper with print on one-side is used for scrap paper.
6. Containers are completely emptied to maximize raw materials. All chemicals are used sparingly. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Solvent waste is segregated to increase recyclability.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
9. Aluminum, metal, and toner cartridges are recycled.

Recommendation

1. Explore alternatives to the ammonia blue print machine.

Plumbing Department/Steam Tunnels

Current Practices

1. Lead free solders are used when working with plumbing for drinking water.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
5. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
6. Aluminum, batteries, scrap metal, oil, and sheet metal are recycled.

Recommendation

1. Explore methods to reduce water flow in showers and toilets.

Police Department

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper.
5. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
6. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
7. Batteries, cardboard, paper, shell casings, old door hardware, and toner cartridges are recycled.

Recommendations

1. Recycle aluminum cans.
2. Explore using environmentally friendly bullets for target practice.

Printing Services

Current Practices

1. Over stocking is limited by ordering items as needed and rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination. Process baths that spoil easily are protected by keeping them containerized. Fixer baths are covered to protect them from degradation.
4. An electronic imaging processor has been installed for plate making. This reduces the need for chemicals. Personal computers with commercial publishing capabilities are used to set up and edit jobs before printing. An Image setter is used to output images without the need to develop the negatives. A Plate Burner is used to make plates which uses a halide lamp instead of chemicals. Both sides of the plate are used for print making.
5. Paper with print only on one-side is used for scrap paper. Reports are photocopied on both sides of paper. Paper scraps are given to the Art Department for reuse. Bad batches of printed paper are reused to start-up of new batches. Cardboard boxes are reused as storage.
6. Plates and negatives are saved for one year, in case a minor changed is required or if duplication is needed.
7. Nine inks are used to mix colors, instead of buying individual colors. All chemicals are used sparingly. Secondary containers are properly labeled to reduce waste.
8. Containers are completely emptied to maximize raw materials. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
9. Soap or detergent solutions are used whenever possible. Solvents are used only for cleaning inks and oil.
10. Bulk chemicals are directly pumped to lower the risk of spillage and dedicated to reduce cleaning.
11. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift. The bookmaker has an automatic shut-off and the color copier has a standby mode.
12. A silver recovery unit is used to recover silver from the fixer before disposal. Aluminum, cardboard, film, oil, paper, silver, and toner cartridges are recycled.

Recommendations

1. A trial should be done with soy-based inks as a substitution for solvent-based inks in the printing press.
2. Instead of disposing of old ink, combine the used inks to make black or backprint ink, or blend in small amounts to regular inks when mixing or making colors.
3. Recycle plastic wrap.
4. Continue to substitute lass hazardous materials for hazardous materials whenever possible.

Psychology Department

Current Practices

1. Over stocking is limited by ordering items that degrade quickly as needed and rotating inventory utilizing first in, first out procedures.
2. Substituted Caro-safe for formaldehyde as a preservative.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Reports are photocopied on both sides of the paper. Paper with print on one-side is used for scrap paper. Shredded paper is used as bedding for the rats. Old newspapers are reused to line the rat’s cages. E-mail for internal memos and other correspondence is used to reduce the amount of hard-copies generated.
6. Containers are completely emptied to maximize raw materials. Chemical volumes used in laboratory experiments are scaled down. Instruments are used more than wet chemistry. All chemicals are used sparingly. Waste destruction is the final procedure for many experiments; an example is the neutralization of acids. Secondary containers are properly labeled to reduce waste. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
8. Aluminum, cardboard, paper, Styrofoam, and toner cartridges are recycled.

Recommendations

1. Segregate solvent waste to increase recyclability.
2. Ensure that hazardous waste is disposed of properly.

Student Life and Student Newspaper

Current Practices

1. Over stocking is limited by rotating inventory utilizing first in, first out procedures.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
3. Raw materials are properly handled to avoid spills, leaks or contamination.
4. Reports are photocopied on both sides of the paper. Paper with print on one-side is used for scrap paper.
5. Containers are completely emptied to maximize raw materials. All chemicals are used sparingly. Secondary containers are properly labeled to reduce waste. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
6. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
7. A silver recovery unit is used to capture silver before disposing of fixers. Aluminum, cardboard, glass, paper, silver, and toner cartridges are recycled.

Recommendations

1. Substitute environmentally friendly magic markers (nontoxic) for volatile organic markers, whenever possible.
2. Recycle old film and negatives to recover the silver.

Theatre Department

Current Practices

1. Over stocking is limited by ordering items that degrade quickly as needed and rotating inventory utilizing first in, first out procedures.
2. Water based paint are substituted for solvent or oil-based paint, which in turn eliminate the need for mineral spirits. Nontoxic paints are used which are lead and cadmium free.
3. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life.
4. Raw materials are properly handled to avoid spills, leaks or contamination.
5. Reports and curriculums are photocopied on both sides of the paper. Paper with print on one-side is used for scrap paper. E-mail for internal memos and other correspondence is used to reduce the amount of hard-copies generated. Wood, nails, nuts, bolts, and any other building material used for props are reused until non-serviceable.
6. Containers are completely emptied to maximize raw materials. All chemicals are used sparingly. Secondary containers are properly labeled to reduce waste. Caps are placed on containers to prevent spills, collection of rain water, and reduce fugitive emissions.
7. Solvent waste is segregated to increase recyclability. Hazardous waste is disposed of properly.
8. Water conservation is utilized by turning off water when not in use and leaks are reported quickly. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
9. Aluminum, cardboard, and paper are recycled.
10. Asbestos-covered theater light cords have been replaced with non-asbestos cords.

Recommendations

1. Recycle toner cartridges.
2. Continue to explore possible reuses of sawdust.

Warehouse Services

Current Practices

1. Over stocking is limited by ordering items that degrade quickly as needed and rotating inventory utilizing first in, first out procedures. Minimum amounts are ordered.
2. Regular inspections are performed to find problems before they happen. This prevents leaks and prolongs equipment life. Stand-up fork trucks are inspected monthly when charged, and all other fork trucks are inspected weekly.
3. Raw materials are properly handled to avoid spills, leaks or contamination. Items are inspected for damage upon arrival.
4. Empty 55-gallon drums are returned to manufacture. Pallets are reused, then recycled.
5. Energy conservation is utilized by turning off power when not in use and powering down all equipment at the end of the work shift.
6. Toner cartridges are returned to the manufacturer for ink refills or sold as surplus. Aluminum, cardboard, metal, Styrofoam, and wood are recycled.
7. Surplus materials are sold. Items that no longer can be reused are sold at public auctions. This program began in July of 1995. °ÄÃÅÀÏÆæÈËÂÛ̳ sold 1647 lots in 1996. Items sold were tables, chairs, couches, computers and parts, printers, kitchen equipment, vehicles, exercise equipment, film projectors, televisions, VCRs, cameras, and unused chemicals to include: floor wax, buffers, and paint.

Recommendations

1. Recycle shrink wrap.
2. Explore the possibility of joining a waste exchange to reclaim or reuse unwanted materials.

Refrigerant Recycling Rule

1.0 Introduction

Chlorofluorocarbons (CFCs) released into the atmosphere can damage the ozone layer that protects the earth from the penetration of harmful ultraviolet radiation. Penetration of ultraviolet light can cause health and environmental concerns including increased incidences of skin cancers and cataracts and damage to crops and marine organisms. This rule is designed to reduce emissions of CFCs and HCFCs to the lowest achievable levels during the service, maintenance, repair, or disposal of appliances at Radford University. This program is in compliance with the refrigerant recycling requirements of Section 608 of the Clen Air Act of 1990, as amended on May 14, 1993, August 19, 1994, November 9, 1994, and July 24, 2003.

2.0 Definitions

Appliance-Any device that uses CFCs or HCFCs as a refrigerant.

High pressure appliance-Any appliance that uses a refrigerant with a boiling point between -50 and 10 C at atmospheric pressure. This includes but is not limited to: R-12, R-22, R-114, R-500, and R-502.

Low pressure appliance-An appliance that uses a refrigerant with a boiling point above 10 C at atmospheric pressure. This includes but is not limited to: R-11, R-113, and R-123.

Major repair-Repair that involves the removal of the compressor, condenser, evaporator, or auxiliary heat exchanger coil.

MVAC-Motor Vehicle Air Conditioner.

Service involving refrigerant-Any service (including repair or maintenance) in which the release of refrigerant from an appliance to the atmosphere can reasonably occur.

Small appliance-Products that are fully manufactured, charged, and hermetically sealed in a factory with 5 pounds or less of refrigerant. This includes refrigerators, freezers, room air conditioners, packaged terminal heat pumps, dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.

Very high pressure appliance-An appliance that uses a refrigerant with a boiling point below -50 C at atmospheric pressure. This includes equipment using R-13 and R-503.

3.0 Responsibilities

1. Mr. Tom Manning, Director of Facilities Operations, will serve as the Refrigerant Manager for the university. Mr. Manning is knowledgeable in the HVAC/R operations of the university.
2. The Safety Manager, Mr. Tom Smithwick, will assist the Refrigerant Manager by developing rules and regulations to ensure compliance with applicable federal, state and local regulations concerning the use of refrigerants.

4.0 Technician Certification

1. All technicians who service, repair, or dispose of appliances that could reasonably release CFCs or HCFCs must pass an EPA approved exam given by an EPA approved certifying organization. Apprentices are exempt from certification requirements provided the apprentice is closely and continually supervised by a certified technician.
2. Certifications for appliances will be issued according to the following types:
   1. Type I- servicing small appliances
   2. Type II- servicing or disposing of high or very high pressure appliances (except small appliances and MVACs)
   3. Type III- servicing or disposing of low pressure appliances
   4. Universal- servicing all types of equipment
3. Technicians who repair or service CFC-12 and HFC-134a MVACs must be trained and certified by an EPA approved organization.
4. Technicians will carry a wallet sized card as proof of certification. The card must include the name of the certifying program, date the organization became a certifying program, name of the person certified, type of certification, a unique number for the certified person, and the following text: "(Name of Person) has been certified as a (Type) technician as required by 40 CFR part 82, subpart F."

5.0 Recovery and Recycling Equipment

1. Recovery/recycling equipment manufactured after November 15, 1993, must be certified by an EPA-approved testing organization.
2. Equipment manufactured before November 15, 1993 must meet the standards in the first column of Table 1.
3. A label must be placed on the equipment stating the following: "This equipment has been certified by ARI/UL to meet EPAs minimum requirements for recovery/recycling equipment intended for use with (category of appliance)."

6.0 Certification by Owners of Recovery/Recycling Equipment

1. A statement must be issued to the appropriate EPA Regional Office certifying that approved recovery/recycling equipment has been acquired, the equipment is being used properly, and the equipment is being used by certified technicians. This statement must be signed by the owner of the equipment or another responsible officer.
2. The certification statement must include the name and address of the service establishment, the name of the equipment manufacturer, equipment model and serial number, and equipment date of manufacturer.

7.0 Refrigerant Sales Restrictions

1. The sale of refrigerants in any size container is restricted to certified technicians. This restrictions excludes refrigerants contained in refrigerators or air conditioners with fully assembled refrigerant circuits , and pure HFC refrigerants, such as R-134a.
2. Only certified MVAC technicians (Section 609 certified technicians) can purchase CFC-12 in containers smaller than 20 pounds. MVAC technicians are only allowed to purchase refrigerants for use in motor vehicle ACs. Technicians certified for stationary refrigeration and AC equipment (Section 608 technicians) may buy containers of CFC-12 larger than 20 pounds.
3. The sale of ozone depleting refrigerants (such as HCFC-22) approved for use in stationary refrigeration and AC equipment are restricted to Section 608 certified technicians.

8.0 Prohibitions on Venting

1. Intentionally venting ozone-depleting compounds (CFCs and HCFCs) used as refrigerants into the atmosphere while repairing, servicing or disposing of appliances is prohibited.
2. Releasing minimal quantities of refrigerants during good faith attempts to recover/recycle refrigerants when following these regulations and where certified equipment is used are not subject to the prohibition.
3. Allowable emissions during servicing and disposal should be at the "lowest achievable level." Efforts should be made to maximize recycling of CFCs and HCFCs.
4. Refrigerants emitted during normal operations of air conditioning and refrigeration equipment are not subject to the prohibition. However, substantial leaks above a certain size in large equipment must be repaired.
5. Small releases of refrigerant which result from purging hoses or from connecting or disconnecting hoses to charge or service appliances are not considered violations. Recovery/recycling equipment manufactured after November 15, 1993 must be equipped with low-loss fittings.

9.0 Refrigerant Leaks

1. Leaking equipment with charges greater than 50 pounds must be repaired when those leaks together would result in the loss of more than a certain percentage of the equipment's charge over a year. The trigger for repair is the current leak rate rather than the total quantity of refrigerant lost.
2. Commercial and industrial process refrigeration sectors must be repaired when the annual leak rate exceeds 35 percent of charge.
3. All other sectors, including comfort cooling, leaks must be repaired when the annual leak rate exceeds 15 percent of total charge.
4. Leaks must be repaired within 30 days of discovery unless a one-year retirement or retrofit plan has been developed. The plan must be kept at the site of the equipment.
5. Records will be kept of the quantity of refrigerant added to equipment containing more than 50 pounds of refrigerant. These records will be used to determine the yearly leak rate.

10.0 Service Practices

1. Before appliances are opened, the refrigerant in either the entire unit or the part to be serviced must be transferred to a system receiver or to a certified recovery/recycling machine.

2. Persons opening equipment, except small appliances and MVACs, must evacuate the unit to the following levels (in inches of mercury vacuum relative to standard atmospheric pressure of 29.9 inches of Hg):

Type of Appliance	Recovery/recycling equipment manufactured before 11/15/93	Recovery/recycling equipment manufactured after 11/15/93
HCFC-22, containing less than 200 lbs	0	0
HCFC-22, containing 200 lbs or more	4	10
Other high pressure units, less than 200 lbs (CFC-12, -500, -502, -114)	4	10
Other high pressure units, 200 lbs or greater(CFC-12, -500, -502, -114)	5	15
Very high pressure units (CFC-13, -503)	0	0
Low pressure units (CFC-11, HCFC-123	25	25 mm Hg absolute

3. Persons who simply add refrigerants to top-off appliances are not required to evacuate the systems.

4.  The following exceptions to evacuation requiements are allowed:

a. If evacuation to the above levels is not possible due to leaks or the refrigerant would be substantially contaminated, the technician opening the appliance must:

• Isolate leaking from non-leaking components whenever possible.
• Evacuate non-leaking components to the levels in Table 1.
• Evacuate leaking components to the lowest level that can be attained without substantially. contaminating the refrigerant. This level cannot exceed 0 psig.

b. If the repair is not major and evacuation to the atmosphere is not performed after repair, the appliance must:

• Be evacuated to at least 0 psig before it is opened if it is a high or very high pressure appliance or;
• Be pressurized to 0 psig before it is opened if it is a low pressure appliance. Methods that require subsequent purging (e.g., nitrogen) cannot be used except with appliances containing R-113.

5. Technicians evacuating small appliances such as household refrigerators and window air conditioners must:

• Recover at least 80% of the refrigerant when using recovery/recycling equipment manufactured before Nov. 15, 1993 or the compressor in the appliance is not working OR;
• Recover at least 90% of the refrigerant when using recovery/recycling equipment manufactured after November 15, 1993 and the compressor is operating, OR;
• Evacuate the small appliance to four inches of mercury vacuum.

11.0 Reclamation Requirements

1. Refrigerant recovered/recycled may be returned to the same equipment or to other equipment owned by the university without restrictions.
2. If refrigerant changes ownership it must be reclaimed to the ARI 700-1993 standard of purity and chemically analyzed to verify that it meets this standard unless the refrigerent was used only in a MVAC and will be used in the same type of appliance. Records of the name and address of the reclamation facility must be maintained.

12.0 Disposal of Appliances

1. The refrigerant must be recovered according to servicing requirements (Table 1) for equipment that is typically dismantled on-site before disposal (e.g., retail food refrigeration, central residential AC units) .
2. Equipment used to recover refrigerants from appliances prior to their final disposal must meet the following performance standards:
   1. For small appliances, 90% of the refrigerant must be recovered if the compressor is working, 80% if the compressor is not working
   2. MVACs must be reduced to or below 102 mm of mercury before disposal.
3. The final person in the disposal chain (e.g., scrap recycler, landfill owner) is responsible for ensuring that refrigerant is recovered from equipment that is usually disposed of with the charge intact (e.g., household refrigerators and ACs, MVACs). Persons "upstream" can remove the refrigerant prior to disposal if they provide documentation of its removal to the final person. The final person must maintain a signed statement from the person who is disposing of the equipment.
4. Appliances delivered for disposal must be accompanied by a signed certification (PDF) that the units have been evacuated of refrigerants according to EPA regulations. Certification for each unit must include the name and address of the person who recovered the refrigerant, and the date the refrigerant was recovered, or a copy of a contract stating that the refrigerant will be removed prior to delivery.
5. Appliances that may contain refrigerants must be delivered separate from other wastes and must be in condition suitable for inspection by landfill staff to verify certification.
6. Technician certification is not required for individuals removing refrigerant from appliances in the waste stream.

13.0 Disposal of Refrigerants, Oils,. and Containers

1. Refrigerants that are reclaimed/recycled are not considered hazardous waste.
2. Used oils contaminated with CFCs are not considered hazardous waste if:
   1. They are not mixed with other waste.
   2. They are subjected to CFC reclamation/recycling procedures.
   3. They are not mixed with used oils from other sources.
3. Used oils will be contained in a 55-gallon drum and sent to a recycling company. The drum will be contained in a secondary container or surrounded by a dike.
4. Disposable cylinders will be recycled. When the cylinder is empty, assure that all pressure is released to zero PSI. The cylinder should be made useless by puncturing a hole in the side of the container.

14.0 Recordkeeping

1. Service records documenting the date, type of service, and the quantity of refrigerant added to appliances that contain 50 or more pounds of refrigerant will be kept by the Refrigerant Manager.
2. The university will certify to the EPA that they own and are properly using certified recovery/recycling equipment and that all technicians are certified.
3. The Refrigerant Manager will maintain copies of signed statements verifying that refrigerant was removed according to EPA regulations prior to disposal of any appliance.
4. Certified technicians will keep a copy of their certification at the university. A list of certified technicians will be kept by the Refrigerant Manager.
5. The Refrigeration Manager will maintain records of the name and address of any facility to which refrigerant is sent. If refrigerant is recovered and sent to a reclamation facility, the name and address of that facility will be kept on file.

15.0 Enforcement

1. EPA will perform random inspections to ensure compliance with these regulations and may assess fines of up to $32,000 per day for any violation.
2. Authorized EPA representatives may require certified technicians to demonstrate their ability to properly perform recovery/recycling procedures. Failure to properly demonstrate this procedure or follow any of the provisions of this plan may result in revocation of the technician's certificate.
3. Employees who deliberately vent CFCs to the atmosphere will be disciplined under the Employees Standards of Conduct.

Spill Prevention Control and Countermeasure Plan (SPCC) & Oil Discharge Contingency (ODC) Plan

1.0 Introduction

Purpose

The purpose of this Spill Prevention Control and Countermeasure/Oil Discharge Contingency (SPCC/ODC) Plan is to provide university personnel with information and guidance necessary to prevent oil and fuel discharges and to safely and properly respond to a spill incident, should one occur. This document has been formatted to meet both Federal requirements for SPCC Plans as specified in 40 CFR Part 112 and Virginia requirements for ODC Plans as specified in 9 VAC 25-91-10 et seq. The SPCC/ODC Plan also addresses the Virginia requirements for pollution prevention for aboveground storage tank (AST) systems.

Implementation

Spill prevention measures are to be implemented to reduce the likelihood of a harmful petroleum release to the environment. Spill response procedures are to be implemented to prevent and control any discharges of oil that should occur in accordance with Federal and State regulations. Harmful discharges of oil are prohibited by 40 CFR Part 110.9. Article 11 of the Virginia Water Quality Regulations require that all oil spills be contained and remediated.

Regulatory Background and Applicability

In December 1973, the United States Environmental Protection Agency (EPA) promulgated regulations which established procedures, methods, and equipment to prevent the discharge of oil from non-transportation-related facilities into or upon the navigable waters of the United States. These regulations, which are contained in 40 CFR Part 112, were issued pursuant to Section 311(j)(1)(c) of the Federal Water Pollution Control Act (as amended). These regulations require facilities to develop and implement a SPCC plan if any of the following apply:

• Petroleum storage in excess of 1,320 gallons above ground.
• Petroleum storage in excess of 660 gallons above ground in a single container.
• Petroleum storage in excess of 42,000 gallons underground.

In January 1992, Virginia Regulation 680-14-07 - Oil Discharge Contingency Plans and Administrative Fees For Approval became effective. This regulation was rescinded and subsequently reissued as part of 9 VAC25-91-10 et seq. The regulation establishes state requirements for the development of ODC Plans to protect the environment as well as public health and safety. These plans must establish procedures to prevent, detect, and respond to a worst-case discharge of petroleum from a University. These regulations apply to all facilities in Virginia with an aggregate above ground petroleum storage capacity in excess of 25,000 gallons.

Definitions

Spill Event-A discharge of oil, as defined in 40 CFR Part 110.1, which includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping (40 CFR Part 110, Section 110.1).

Harmful Discharge-Discharge of such quantities of oil to navigable waters or shorelines which (a) violates applicable water quality standards, or (b) causes a film or sheen upon or discoloration of the surface of the water or beneath the surface of the water or upon adjoining shorelines (40 CFR Part 110, Section 110.3). Harmful discharges of oil are prohibited by 40 CFR Part 110.9.

Reportable Quantity–A reportable quantity represents the minimum quantity of material spilled that must be reported to a regulatory agency when released. Federal and sate definitions of reportable quantities for oil releases are as follows:

1. 1. Federal regulations require reporting of any "harmful discharge" and;
   2. State regulations require reporting of any oil spill greater than 25 gallons.

Sheen-An iridescent appearance on a water surface (40 CFR Part 110, Section 110.1).

Sludge-An aggregate of oil and any other matter of any kind in any form other than dredged spoil having a combined specific gravity equivalent to or greater than water (40 CFR Part 110, Section 110.1).

Navigable Water-Navigable waters are defined in 40 CFR Part 116.2 as "waters of the United States, including territorial seas," including but not limited to the following:

1. 1. All waters that are, were, or may be used as a means to transport interstate or foreign commerce;
   2. Tributaries of navigable waters including wetlands;
   3. Interstate waters including wetlands; and
   4. All other waters of the United States such as intrastate lakes, rivers, streams, mudflats, sandflats, and wetlands, the use, degradation or destruction of which affect interstate commerce.

Emergency Levels–The °ÄÃÅÀÏÆæÈËÂÛ̳ Emergency Operations Plan defines three levels of emergency situations as summarized below:

Emergency Event Level 1 is normally a minor or isolated event that can be responded to or quickly resolved by campus police, regional law enforcement, and or fire department using internal resources or limited external assistance.

Emergency Event Level 2 are events or emergencies that have or may have the potential to affect all or part of the RU campus and may require assistance from off campus agencies such as fire department, police, city, state, or federal departments.

Emergency Event Level 3 may be classified as a campus, regional, state, or national emergency that affects the campus and surrounding community and has the capacity to threaten or adversely affect life, health, and or property on or near the °ÄÃÅÀÏÆæÈËÂÛ̳ Campus.

Certifications

Facility

This Spill Prevention Control and Countermeasure and Oil Discharge Contingency (SPCC/ODC) Plan shall be implemented to commit staff and resources to prevent, control, and counteract the effects of spills or discharges of oil or oil products in order to minimize hazards to human health and the environment. This SPCC/ODC Plan has been prepared in accordance with 40 CFR Part 112 - Oil Pollution Prevention and 9 VAC 25-91-10 et seq. - Facility and Aboveground Storage Tank (AST) Regulation. This Plan shall, as required by law, be made available to the Regional Administrator or his duly authorized representative during normal working hours. I am at a management level with authority to commit the resources necessary to implement this plan and hereby approve it.

Signature:
Date:
Name: Jorge Coartney
Title:  Director, Facilities Operations

Engineer

I hereby certify that I have examined the facility, and, being familiar with the provisions of 40 CFR Part 112, attest that this SPCC/ODC Plan has been prepared in accordance with good engineering practices.

Signature:
Date:
Name:  Ian D. Shaw, P.E.
Virginia Registration No. 034023

2.0 Facility Information

General Facility Information

Facility Name:  °ÄÃÅÀÏÆæÈËÂÛ̳
Mailing Address:  P.O. Box 6909
Radford, Virginia 24142
Street Address:  501 Stockton Street
Radford, Virginia 24142

Owner/Operator:  °ÄÃÅÀÏÆæÈËÂÛ̳/Commonwealth of Virginia

Phone Number:  (540) 831-7790

University Normal Working Hours: Typically 24-hours a day, seven days a week. Actual manned hours at the Boiler Plant, Dedmon Center, and Facilities Management varies based upon system demand.

Contact Name: Safety Director

Location

The university is located within the City of Radford, Virginia. The Boiler Plant is located off E. Main St (U.S. Route 11) between the street and the Norfolk Southern Railway Company tracks. The Dedmon Center is located at the end of University Drive to the north of E. Main St. Both the Boiler Plant and Dedmon Center are located on flat land to the south of the New River that comprises a portion of the river’s flood plain. Both facilities are situated above the 100-year flood level.

Description

°ÄÃÅÀÏÆæÈËÂÛ̳ operates AST systems at three areas: the Boiler Plant, the Dedmon Center, and the Facilities Management area. An Underground Storage Tank (UST) system is also operated at the Facilities Management area.

Boiler Plant

Two 50,000-gallon aboveground No. 2 fuel oil tanks (tank #1 closest to building, & tank #2) are located at the Boiler Plant.

The Boiler Plant occupies a small area between E. Main St., the University Street Bridge, and Norfolk Southern Railway Company tracks/right-of-way. Boilers at the facility are used to generate steam for heating, cooking, and various other operations at the University. Natural gas is the primary boiler fuel. However, No. 2 fuel oil is stored at the facility as back up boiler fuel and as fuel for an emergency generator. The Boiler Plant has two oil/water separators which treat storm water runoff from the AST system prior to discharge to a storm drainage ditch. One separator is associated with the tank truck unloading area and the other is associated with the tank and piping secondary containment systems.

Dedmon Center

A 10,000-gallon aboveground No. 2 fuel oil tank (tank #3) is located at the Dedmon Center. The Dedmon Center is situated on flat land along the bank of the New River amid various athletic fields. A natural gas fired boiler system is present at the Dedmon Center for heating. As with the Boiler Plant, No. 2 fuel oil is stored as a back up boiler fuel and as fuel for two emergency generators.

Facilities Management

A 2,000-gallon aboveground diesel fuel tank (tank #4), a 500-gallon aboveground used oil tank (tank #5), and a 10,000 gallon underground gasoline tank are located at Facilities Management. The Facilities Management area is located on a bank above the New River floodplain. 

Total Oil Storage

Aboveground: 112,500 gallons
Underground:  10,000 gallons

Spill History

No reportable spills have occurred at the university within the past year.

3.0 Responsibilities

Boiler Plant

The Boiler Plant operators are responsible for the day to day operation and maintenance of the oil storage tank systems at the Boiler Plant and Dedmon Center. These tasks include routine inspections; maintenance of the tanks, piping, and containment systems; coordination of fuel deliveries; and initial response to spill events as appropriate.

Motor Pool

Motor Pool personnel are responsible for the day to day operation and maintenance of the oil storage tank systems at the Facilities Management Area. These tasks include routine inspections; maintenance of the tanks, piping, and containment systems; coordination of fuel deliveries; and initial response to spill events as appropriate.

Safety Director

The Safety Director is responsible for coordinating training efforts, coordinating periodic reviews/updates to the SPCC/ODC Plan, notifying regulatory agencies as required, serving as liaison between internal departments and external agencies, and coordinating waste disposal.

Campus Police

Any major spill will be reported to the university police dispatcher. A police officer will confirm the spill while waiting for the Safety Director to arrive.

Emergency Coordinator (EC)

The University Emergency Coordinator, serving as the Incident Commander should a release occur, is responsible for emergency actions and notifies outside agencies for assistance. The EC will also initiate the Emergency Operations plan and call members of the Emergency Operations Center if necessary.

Facilities Management

Facilities Management will provide and coordinate the resources to assist in operation and maintenance of the storage tank systems and to respond to a spill event as circumstances require.

Notifications

The following  individuals are authorized to make required notifications and to implement containment and clean up actions and to ensure that response actions are undertaken in accordance with applicable Federal, state and local requirements.

Regulatory Notifications and Waste Disposal

Primary:  Safety Director
Office: 540-831-7790

Coordinator of Emergency Actions and Outside Agencies/Contractors

Primary: Todd Branscome, Emergency Coordinator
Office: 540-831-7155

Alternate 1:  Colleen Roberts, RU Chief of Police
Office (24hr): 540-831-5500

Alternate 2:  Larry Brown, Captain
Office (24hr): 540-831-5500

4.0 Facility Assessment

Spill Scenarios and Worst Case Discharge

There are several circumstances that could potentially lead to oil spills at Radford University. Appendix A summarizes possible spill scenarios resulting from equipment failure, worst-case spill volumes, and the location to which the spill would likely drain. Most spill situations will result from leaks at valves, pipe connections, etc. and will typically involve a relatively small quantity of product released. However, a catastrophic tank failure could result in the release of a large quantity of oil that could impact human health, physical property, and the environment. Both the volume of the material spilled and the location to which the spilled material flows determine the actual severity of spill.

As shown in Appendix A, the worst-case discharge for the Boiler House is a rupture of one of the two 50,000 gallon tanks at the Boiler Plant. Based upon a sloshing factor of 22-percent, the actual volume potentially escaping containment would be 11,000 gallons. The worst case discharge associated with tank filling is assumed to be 2,000 gallons based upon the use of tanker trailers with a single compartment volume not exceeding 2,000 gallons. However, the most typical release that could occur during transfer would involve small quantities when hoses are connected/disconnected. The bulk of any material spilled during transfer would be contained at the transfer areas or in spill containment buckets on the tanks.

Evaluation of Containment and Diversion Structures

Appendix A also provides a description the containment and diversionary structures for the potential equipment failures described in the previous section. In accordance with 40 CFR 112.7 (d) university management has determined that use of the containment and diversionary structures will be capable of controlling typical spill events. Should a spill occur that escapes a containment system, the spill response measures specified in this plan will be implemented to minimize any impacts.

Facility Drainage

Boiler Plant

Any spilled material or runoff from the Boiler Plant ASTs will flow to a storm water drainage ditch approximately 50 feet to the north of the ASTs. Spills could reach the ditch by the following scenarios:

1. Oil released from containment flows through the drain, through the respective oil/water separator to the drainage ditch.
2. Oil escapes containment and enters four grate inlets SE of the tanks adjacent to the Art Annex, garage, and boiler and proceeds to the storm sewer that discharges to the drainage ditch.
3. Oil escapes containment and flows directly to the drainage ditch. This drainage ditch flows approximately 2200 feet to the east paralleling the Norfolk Southern Railway Company tracks. The ditch then feeds into a storm sewer that flows under the Dedmon Center complex and into the New River.

Dedmon Center

Any spilled material or runoff from the Dedmon Center AST will flow to the storm drain system for the Dedmon Center Complex as listed below:

1. Oil released from containment flows through the dike drain, into a trench drain to the east that discharges to the storm sewer.
2. Oil escapes containment and enters the trench drain that discharges to the storm sewer.
3. Oil escapes containment and flows along the driveway to three curb inlets approximately 250 feet to the east. The distance from the AST to the main storm drain line is approximately 250 feet. Once the material enters the storm drain it will flow approximately 400 feet prior to discharge to the New River.

Facilities Management

Any spilled material or runoff from the Facilities Management area will flow into two curb inlets (north and south of the tanks) and on to a storm water detention basin located north of the facility. This basin discharges to a ditch on the north side of Stockton Street and flows approximately 1800 feet through a sediment control basin to the New River.

Bulk Storage Tanks

The aboveground oil tanks at °ÄÃÅÀÏÆæÈËÂÛ̳ are constructed of steel and are compatible with the products they store and the conditions of storage. The tanks meet the requirements of UL 142 and the general requirements of NFPA 30. All aboveground storage tanks are equipped with secondary containment structure to control spilled material as listed in Table 1. The underground storage tank at the Facilities Management area is constructed of fiberglass and meets regulatory requirements for underground fuel tanks. Each tank is also equipped with various fail-safe devices as listed in Table 1.

Dikes

Drainage of rainwater from the AST dikes is performed using the following procedures:

1. The drain valves are normally sealed closed.
2. Accumulated rainwater is inspected for the presence of an oily sheen to ensure compliance with applicable water quality standards and to prevent a harmful discharge.
3. If no sheen is observed the bypass valve is opened and the water is drained. Once all water is drained the valve is resealed.
4. If a sheen is present the oil is either removed prior to discharge or the water is collected for treatment/disposal. (Complete removal of an oil sheen may not be necessary where drained liquids are treated by oil/water separation. However, the effluent from the separator should be closely monitored and the flow stopped if a sheen on the separator discharge is noted.)
5. Records of drainage events are recorded on the Dike Drainage Form. The completed forms are filed by Boiler Plant personnel and kept on record for five years.

Transfer Operations and Pumping

Fuel oil is transferred from the Boiler Plant and Dedmon Center ASTs to the boilers and emergency generators via aboveground steel pipe systems. All supply lines are operated on suction from fuel pumps on the various pieces of equipment. A containment system is provided for the Boiler Plant piping which directs any oil leaks to the tank containment oil/water separator system. Fuel is transferred from the Facilities Management gasoline, diesel, and oil tanks as follows

1. Gasoline is pumped from the UST to the dispenser via underground piping.
2. Diesel fuel is pumped from the AST via a dispenser mounted directly on the tank.
3. Used oil is poured directly into the used oil AST via a fill port on the top of the tank.

General guidelines used by the university are as follows:

1. Pipelines not in service or on standby for an extended period are capped or blank flanged and marked as to their origin.
2. All pipe supports are properly designed to minimize abrasion and corrosion and to allow for expansion and contraction.
3. All aboveground pipelines and valves are periodically inspected with the ASTs (Pressure testing for piping is conducted as warranted.).
4. Underground piping is cathodically protected in accordance with UST regulations.
5. Warning signs are posted as needed to prevent vehicles from damaging aboveground pipelines.

Tanker Unloading Rack

The tanker unloading racks at both the Boiler Plant and Dedmon Center consist of a single nozzle located adjacent to the product transfer pump and the AST(s). The product transfer pumps are also used to transfer fuel from the tankers to the AST(s).

At the Boiler Plant the tankers park on a concrete apron that is sloped to a sump. The sump drain is closed while transfer is in progress. The transfer pump and related equipment is constructed on a steel skid with spill containment that drains back to the tanker apron.

Tanker trucks park in a service area at the Dedmon Center that slopes to a trench drain. A slide gate is placed into the drain outlet prior to transfer. The transfer pump and nozzle is located within a small concrete berm within the main AST containment dike.

Tanker trucks park adjacent to the Diesel Fuel AST and Gasoline UST during filling. Both tanks are equipped with spill containment and overfill protection systems.

During transfer warning signs or traffic cones are placed around the tanker to prevent vehicle departure before complete disconnection of transfer lines. Additionally, all drains and outlets on the tanker are checked prior to line disconnection to avoid spills.

Natural Resources at Risk

An evaluation of sensitive areas in the vicinity of °ÄÃÅÀÏÆæÈËÂÛ̳ was performed by reviewing the USGS quadrangle and information on natural resources and historic areas provided by the Virginia Department of Game and Inland Fisheries, Virginia Department of Conservation and Recreation, and the Virginia Department of Historic Resources. The location of any water intake stations located along the New River was confirmed, as well as public and/or private wells. A summary of this information is provided below.

The New River is located to the north of °ÄÃÅÀÏÆæÈËÂÛ̳ and flows within ±1/4-mile of the various oil storage tanks. Various natural resources and municipal services that could be affected by a spill are associated with the New River. The Department of Conservation and Recreation's Division of Natural Heritage reported that one endangered species; the Virginia fringed mountain snail (Polygyriscus virginianus), and two species of concern, the green floater (Lasmigona subviridis) and the hellbender (Cryptobranchus alleganiensis) are documented within the vicinity of °ÄÃÅÀÏÆæÈËÂÛ̳. The Virginia fringed mountain snail habitat is generally restricted to limestone fragments mixed with clay soil. The green floater, a freshwater mussel, and the hellbender, an aquatic salamander, have been documented in the New River. A specific habitat location for these species near °ÄÃÅÀÏÆæÈËÂÛ̳ has not been documented.

The Department of Historic Resources (DHR) reported numerous archaeological sites near °ÄÃÅÀÏÆæÈËÂÛ̳. There are six identified archaeological sites in the vicinity of the Facilities Management Area and the Dedmon Center. There are another 10 archaeological sites along the New River within five river miles of °ÄÃÅÀÏÆæÈËÂÛ̳.

According to the Montgomery County Health Department, the City of Radford is supplied by a public water system. A file search conducted by the Health Department identified no other public or private water supply wells that would be impacted by an oil release from the University.  Water intakes for both the City of Radford and the Blacksburg, Christiansburg, VPI Water Authority are located on the New River. The City of Radford water intake is located greater than two miles upstream of °ÄÃÅÀÏÆæÈËÂÛ̳. A pumping station is located near °ÄÃÅÀÏÆæÈËÂÛ̳; however, the pumping station nor the water intake would be influenced by a release from the facility. Based on the Virginia Water Quality Standards, the section of the New River that a discharge from the facility would enter is the New River Basin Section 2b. The Blacksburg, Christiansburg, VPI Water Authority water intake is located approximately 4.3 miles downstream from Radford University.

Based on recent subsurface site investigations, site reconnaissance, and the United States Geological Society (USGS) topographical map for the site, depth to groundwater is estimated to be approximately 25-50 ft below grade. No open conduits to groundwater exist and the soils generally have a surface layer of dark brown and brown loam and subsoil of yellowish red clay that extends to a depth approximately five feet below ground surface. Based on the relative impermeability for the surface soils in the area and the short response time (60-min.) for the spill response contractor (LCM) to recover any released product, groundwater impact from a release should be negligible.

As noted, there are natural and municipal resources that may be influenced in the event of a release at °ÄÃÅÀÏÆæÈËÂÛ̳. The spill response actions outlined in this plan will be implemented in an effort to prevent oil from reaching the New River and to minimize any impact to the New River and its resources should a release to the river occur.

5.0 Prevention and Preparedness

Material Handling

Material handling procedures have been implemented to reduce the likelihood of a spill during product transfer operations. The following is a portion of the University’s standard operating procedure for the receipt of fuel oil at the Boiler Plant and Dedmon Center.

1. Check tank levels prior to filling.
2. The truck driver will park within the spill containment area.
3. Close the containment area drain valve (Boiler Plant) or slide gate (Dedmon Center).
4. Turn on the transfer pump and reset gallon meter.
5. The driver will connect the suction hose to the tanker.
6. The suction hose plug valve (and the air discharge line at the Boiler Plant) is opened. (Oil splash bucket is placed under the air line.)
7. The driver will open the oil valves to the suction hose.
8. Check for leaks and check that valves to the tanks are positioned appropriately.
9. The driver will start transfer and remain with the tanker until the oil is unloaded.
10. Close the plug valves on the suction line and disconnect supply hose.
11. Check for oil in the tanker containment area. If none is present open the valve/slide gate.
12. Check tank containment for oil.
13. At the Boiler Plant take the oil splash bucket to the plant for storage.

The same general procedure is used at the Facilities Management Area. However, fuel is either pumped/discharged directly from the tanker to the diesel fuel and gasoline tanks or directly pumped from the used oil tank by a used oil hauler. Any material spilled during transfer will be contained and collected.

Inspections, Testing and Records

Routine inspection, testing, and preventive maintenance procedures have been implemented at the Boiler Plant and Dedmon Center to identify potential problem situations before a release can occur. University personnel will review and document the inspection of the oil storage tanks and equipment using the forms located in Appendix B and as described below. Boiler Plant personnel will keep completed forms on file for a minimum of five (5) years.

Inspections

The following daily and weekly inspections will be performed at the °ÄÃÅÀÏÆæÈËÂÛ̳ oil storage tanks. While inspecting, assure there is sufficient light to view all sides of the equipment. Any problems identified during the inspection shall be noted in the comment section of the form along with measures taken to correct the problem.

Daily Inspection:  A brief visual inspection of the tank systems including the tanks, containment, pipes, valves, and transfer areas will be performed each day that the areas are manned. The Facilities Management UST will be inspected to the extent possible by checking manways and adjacent groundsurface. These daily observations will prevent an oil spill or leak from going unnoticed and will aid in identification of potential equipment failures. A record of these inspections will be noted on the Daily Inspection Form (PDF).

Weekly Inspection:  All tank system components will be inspected more thoroughly on a weekly basis using the Weekly Inspection Checklist (PDF).

Testing

In addition to daily and weekly visual inspections, periodic integrity testing of the aboveground tank and piping systems is required. Tank integrity testing consisting of visual inspections and/or non-destructive shell thickness testing are required. A formal visual inspection and/or non-destructive inspection should be performed every 5 years. Inspection and/or testing procedures should follow those outlined in American Petroleum Institute (API) standard 653, Tank Inspection, Repair, Alteration, and Reconstruction or similar testing protocols. Such testing procedures could include thorough internal inspections, external inspections, and/or ultrasonic shell thickness testing.

The Facilities Management area UST is subject to leak detection testing as required by UST regulations. Pipeline pressure testing is also required at five-year intervals in accordance with the general provisions of NFPA 30. That is, the lines shall be subject to a hydrostatic test at 150-percent of the maximum working pressure or a pneumatic test at 110-percent of the maximum working pressure.

Preventive Maintenance

In the event that defects are detected during the course of the above inspections/testing or if an oil discharge is detected facility personnel will:

• Identify the nature of the defect through visual inspections, pressure testing.
• Attempt to correct the defect if safely possible.
• Hire an outside contractor to perform repairs when needed.

Recordkeeping

All inspection forms, and testing results will be kept on file at the Boiler Plant for a minimum of five (5) years.

Leak Detection

°ÄÃÅÀÏÆæÈËÂÛ̳ has implemented a leak detection-monitoring program for its oil storage tanks to detect any potential release to groundwater. As all aboveground tanks and piping are off the ground surface, the daily visual inspection program will also serve as the leak detection-monitoring program at these facilities. As previously noted, a leak detection-monitoring program has been implemented for the Facilities Management UST system as required by UST regulations.

Note: As all aboveground tanks and associated piping are off the ground surface, no inventory records for the ASTs are required to be kept and reconciled for pollution prevention purposes.

Security

The oil storage facilities are well lit including all product transfer areas, and the bulk storage tanks. Starter controls on pumps in non-operating or standby status are locked or electrically isolated in the off position. The °ÄÃÅÀÏÆæÈËÂÛ̳ Police Department periodically patrols the facilities and Boiler Plant and Facilities Management personnel will report unauthorized entry or suspicious activity to the University Police. As an additional security measure, a camera system monitors the storage tanks at the Boiler Plant.

Training

Those personnel who may be involved in an oil spill prevention and response have received appropriate training as listed below:

1. Safety Director, Environmental Inspector, Fire Safety Specialist - These personnel have received 40-hour OSHA Hazardous Waste Operations and Emergency Response training.
2. Boiler Plant Personnel - Personnel at the Boiler Plant have received training in the proper procedures for handling oil, inspecting the oil storage facilities, and the other general requirements of the SPCC/ODC Plan. The Boiler Plant personnel have received at least 24 hours of hazardous materials response training.
3. Emergency Response Assistants - The Emergency Response Assistants have received 24 hours of hazardous materials response training.
4. °ÄÃÅÀÏÆæÈËÂÛ̳ Police Officers - University Police officers have received hazardous material first responder training and are familiar with the reporting requirements of the SPCC/ODC Plan.
5. Facilities Management and Dedmon Center Personnel- Individuals in these areas have been trained in the proper procedures to report an oil spill.

In addition to the above training, Facility Management personnel including the Safety Manager and Boiler Plant personnel will review the SPCC/ODC Plan on at least an annual basis. This training will include a review of the spill prevention, notification, and response procedures included in the plan, a review of any spill incidents during the past year, and review of any changes in the SPCC/ODC Plan.

Response Exercises

Periodic announced and unannounced emergency response exercises will be performed as part of the spill preparedness program. These exercises present an emergency response scenario and challenge the participants to respond using the concepts developed during the training process. Outside of a real emergency, a simulated emergency is the most effective process for evaluating the emergency response plan. The objectives and purposes of these exercises include the following:

• Evaluate emergency plans and response capabilities.
• Provide basis for improving plans and procedures.
• Provide and evaluate training for participants.
• Improve coordination and relationships.

The various types of exercises conducted include communications drills, tabletop exercises, and full-scale response exercises (involving public agencies as appropriate). These drills may be unannounced and will be designed to evaluate the ability of personnel to complete the following:

• Follow proper notification procedures;
• Identify appropriate response actions;
• Implement appropriate response actions; and
• Interact with response contractors and local agencies.
• Communication and tabletop exercises will be performed periodically as part of the SPCC/ODC Plan review. Full-scale exercises will be performed on an as needed basis as deemed necessary by the Safety Manager.

Plan Review

Internal Reviews

The SPCC/ODC Plan must be periodically reviewed and amended in accordance with Federal and State Regulations. The plan must be amended whenever a significant change at the Boiler Plant, Facilities Management, or Dedmon Center occurs. Significant changes may include the following:

• New construction or change in facility design, storage capacity, or materials stored;
• A change in operation and maintenance activities which would affect the probability of a spill event; or
• decrease in the availability of private personnel/equipment necessary to address a worst case discharge.
• DEQ must be notified of any significant change within 30 days of such a change.

At a minimum the following review frequency shall be followed:

1. In accordance with 40 CFR Part 112.5(b) a complete review and evaluation of the SPCC/ODC Plan shall be performed every 3 years. The SPCC plan shall be amended within 6 months of the review to include any changes to the facility and to include improved spill controls as applicable.
2. In accordance with 9 VAC 25-91-170.E the SPCC/ODC Plan must be reviewed, updated as necessary and resubmitted for DEQ approval every 5 years. The revised plan should be submitted to DEQ 90 days prior to the expiration of the current plan.

Any amendment to the SPCC/ODC Plan for physical changes to the facility or improved spill controls as noted above must be certified by a registered professional engineer.

Regulatory Agency Reviews

Environmental Protection Agency (EPA) reserves the right to amend the SPCC/ODC Plan and DEQ reserves the right to modify/deny approval of the Plan as described below.

• The EPA Regional Administrator shall review and has the authority to require amendment to the SPCC/ODC Plan if a spill in excess of 1,000 gallons is released to a surface water body in a single incident or if two discharges of harmful quantities of oil occur within a 12-month period.
• DEQ may request modifications to or deny approval of the Plan under the following circumstances:
  • A significant change in University operations occurs.
  • The University is unable to implement the plan during a release.
  • There has been a significant change in technology.

6.0 Spill Response

Notification of Release

University Personnel
Level 1 Emergency

1. Notify Area Personnel - Notify personnel in the spill area (Boiler Plant, Dedmon Center, or Facilities Management). Spill will typically be handled by properly trained area personnel.
2. Contact Safety Director - Contact Safety Manager if assistance with proper response procedures is required.
   Note: If spill situation worsens or additional assistance is required, follow notification procedures for level 2-3 emergencies.

Level 2-3 Emergencies

1. Notify University Police Department - The person detecting the spill shall immediately notify the University Police Dispatcher at 831-5500.
2. Notify Emergency Personnel - The University Police Dispatcher will notify the appropriate University personnel including:
   1. Safety Director or alternate.
   2. Emergency Coordinator or alternate.
   3. Boiler Plant Operator.
   4. Appropriate Facilities Engineering personnel.
3. The Safety Director or alternate will be immediately notified of a spill exceeding 25 gallons or that enters or threaten to enter the storm drains or New River.

Regulatory Agencies

1. The Safety Director or alternate shall perform all required regulatory notifications. A list of regulatory agencies that must be notified in the event of a spill (including the agency phone number and the circumstances under which they should be notified) is provided below. When notification is required the respective agencies must be notified within 24 hours.
   1. Virginia Department of Environmental Quality, West Central Regional Office
      540-562-6700
      Any oil spill in excess of 25 gallons or that reaches a surface water body.
   2. Virginia Department of Emergency Services
      800-468-8892
      Any oil spill in excess of 25 gallons or that reaches a surface water body.
   3. EPA Region III
      215-814-9016
      Any oil spill that reaches a surface water body (navigable water).
   4. National Response Center
      800-424-8802
      Any oil spill that reaches a surface water body (navigable water).
   5. Radford LEPC
      540-731-3617
      Any oil spill in excess of 25 gallons or that reaches a surface water body.
2. The information to be reported to regulatory agencies includes the following:
   1. The date and time of the spill.
   2. An estimate of the quantity of material released and the time or duration of the event.
   3. The exact location of the spill, including the name of the waters involved or threatened and/or other medium or media affected by the release or spill.
   4. The source of the release.
   5. The name, address, and telephone number of the party in charge of, or responsible for, the facility or activity associated with the release.
   6. The extent of actual and potential water pollution.
   7. The party at the release site who is in charge of operations at the site and the telephone number of this party.
   8. The steps being taken or proposed to contain and clean up the spill and any precautions taken to minimize impacts.

Local Police and Fire Department

°ÄÃÅÀÏÆæÈËÂÛ̳ has an agreement with the City of Radford Fire Department that the Fire Department will assist the University in spill response activities when needed. Under such circumstances the Chief of the Radford City Fire Department will serve as the senior response official directing the response effort. The Radford City Police Department may also be notified of significant spills that cannot be controlled by University Personnel. The City of Radford Fire and/or Police Department spills local police and fire department should be notified if any of the following criteria are met:

• Fire, smoke, violent ruptures, and/or explosions.
• Leaks (hazardous or not) which enter or threaten to enter drainage ditches or water courses.
• Any incident where oil crosses University property lines or threatens to do so.
• A situation exists of such a nature (i.e., a continuing danger to life and health exists at the scene of the incident) that, in the judgment of the Responsible Person should be reported even though it does not meet the above criteria.

Norfolk Southern Railway Company

The Norfolk Southern Railway Company (NS), Virginia Division Chief Dispatcher (540-981-4739) shall be notified of any spills that reach the railroad right-of-way and/or when response actions carry over to the right-of-way. The Chief Dispatcher can then direct and control train traffic as needed to facilitate response actions.

Emergency Response Contractors

1. °ÄÃÅÀÏÆæÈËÂÛ̳ has a standing agreement with a local spill response contractor that can be mobilized to the site when needed. This contractor is listed below:
   1. Company Name: LCM Corporation
   2. Business Phone: (540) 344-5583
   3. 24-Hour Phone: (800) 774-5583
2. The Contractor is located in Roanoke, Virginia and can mobilize to the University in 60 minutes. A copy of the agreement of understanding between the University and the Contractor is available in the Safety Office along with a listing of emergency response equipment.

General Spill Response Procedures

A suggested procedure for response to a spill event is presented below. Personnel responding to a spill will assess the release prior to the start of any response action. Refer to the MSDS for proper material handling equipment, materials, and procedures. Aggressive actions such as attempting to stop the flow or cleanup procedures will be performed by properly trained individuals. Individuals at the university with proper training include Safety Office and Boiler Plant personnel.

The university maintains personal protective equipment (PPE) and spill response equipment at several locations on campus. Those facility personnel trained for response actions have been trained in the use of PPE and spill response equipment.

1. Evacuation:  If the spill requires special equipment and containment is extremely hazardous, then all personnel are to evacuate the area and wait for outside assistance from the Radford City Fire Department and/or Emergency Response Contractor.
2. Stop the Flow:  Isolate source of the leak or spill if safe to do so. Shut off flow of oil by closing valves, shutting off pumps, isolating plugs, and/or other appropriate methods. Generally, valves to control flow are found at the base of above ground storage tanks, near a coupling point or at a transitional point.
3. Shut Off Ignition Sources:  All possible sources of ignition are to be shut off (motors, electrical equipment, electrical circuits, open flames, and any other possible sources of sparks or fire).
4. Notify/Warn Personnel:  If the spill is not readily contained or exceeds 25-gallons notification of University and outside personnel must be made as outlined in the above section and the Radford University Emergency Operations Plan.
5. Contain the Spill:  If it is safe to do so, contain spilled oil in the smallest possible area. There are several containment methods that may be quickly implemented during a release. Small spills may simply be contained with the use of absorbent material (granular material, pads, booms, etc). Larger spills may often require the construction of earthen or timber dams and/or berms to contain the flow.
6. Product Recovery and Disposal: Product recovery and disposal measures shall be undertaken once the spill source has been corrected and the flows contained. Removal and recovery of spilled oil should be initiated and proceed as rapidly as circumstances permit. The Safety Office will supervise the recovery and disposal of spilled materials. Disposal of spilled materials will be performed in compliance with local, state, and federal regulations. Product may be recovered by one of the suggested measures listed below:
   1. Product may be recovered from sumps, reservoirs or containment structures with the use of a pump or skimmer with discharge into an appropriate container.
   2. Product may be recovered from behind booms or from basins using a floating skimmer pump with discharge into an appropriate container.
   3. Small quantities of product may be recovered using absorbent materials, which are then placed into drums or similar containers.
   4. Oil scavenging/recycling contractors may be called in to recover large quantities of spilled materials.
7. Use Good Judgment: The response actions presented in the above paragraphs outline general methods that may be utilized to contain spilled material. Since spills can occur in an infinite number of situations and circumstances, it is impossible to provide specific instructions for every event. Therefore, response personnel must exercise their own good judgment and common sense when implementing spill containment measures to achieve the primary objective of safely confining the spilled material to minimize impact to human health, physical property and the environment.

Specific Spill Response Scenarios

Spills Limited to Ground Surface

General

1. Assess the nature of the release and determine a) if the spill has escaped the containment structure and b) if the spill volume escaping containment exceeds 25 gallons.
2. Notify appropriate university personnel.
3. Other university personnel, Radford City Fire Department, and/or emergency response contractors shall be notified and mobilized as necessary. The Safety Office will notify regulatory agencies. The Police Department will contact university personnel, emergency response agencies and the spill contractor if in-house personnel cannot handle the spill. The decision to call the spill contractor will be made in consultation with the Safety Manager and will be based on the amount of the spill and the potential threat to the environment.
4. If you have the proper training, isolate the spill source by closing valves, shutting down pumps, installing temporary plugs, or using other appropriate methods.
5. If spilled material is contained within a secondary containment structure, recover the material for reuse or disposal. If spilled material is not contained within a secondary containment structure and you have the proper training, use the following steps to contain and control the spill.

Boiler Plant

1. Place absorbent booms, pads, sandbags, earthen berms, and/or excavated sumps/reservoirs at the down gradient end of the spill to prevent further migration.
2. Protect grate inlets in driveway and building ramp by surrounding the inlets with absorbent booms, berms, etc.
3. Prevent migration of oil into the storm drainage ditch to the north of the ASTs using booms, pads, earthen berms, etc.
4. Clean up the spilled materials using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.
5. Once the spilled material is contained the material should be recovered for reuse or disposal as appropriate.

Dedmon Center

1. Place absorbent booms, pads, sandbags, and/or earthen berms at the down gradient end of the spill to prevent further migration.
2. Protect trench drain outlet at the service entrance by installing slide gate and protect curb inlet(s) in driveway with absorbent booms or berms.
3. Prevent migration of oil into the storm drainage system that discharges to the New River.
4. Clean up spilled materials using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.
5. Once the spilled material is contained the material should be recovered for reuse or disposal as appropriate.

Facilities Management

1. Place absorbent booms, pads, sandbags, earthen berms etc. at the down gradient end of the spill to prevent further migration.
2. Protect curb inlets in the servicing areas by surrounding the inlets with absorbent booms, berms, etc.
3. Prevent migration of oil through the storm drainage system to the detention pond.
4. Clean up the spill using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.
5. Once spilled material is contained, the material should be recovered for reuse or disposal as appropriate.
6. Notify Facilities Management once the spilled material has been contained and recovered so that the appropriate repairs can be made.

Oil Spills to Storm Drains, Ditches, or Surface Water Bodies

General

1. Assess the nature of the release and confirm that spilled material has reached a storm drain, drainage ditch, or surface water body.
2. Immediately notify the University Police so that notifications of outside agencies can be made. The Police Department will notify the Safety Office, appropriate university personnel, and emergency response agencies. The Safety Office will notify regulatory agencies.
3. The Police Department will call the spill contractor if in-house personnel cannot handle the spill. The decision to call the spill contractor should be made in consultation with the Safety Director. The decision will be based on the amount of spilled material and the potential threat to the environment.
4. If you have the proper training, isolate the spill source by closing valves, shutting down pumps, installing temporary plugs, or other appropriate method.
5. For spills reaching the storm drainage system the following steps shall be used by properly trained individuals (40-hour HAZWOPER) to contain and control the spill.

Boiler Plant

1. Any spilled material entering the grate inlets at the building driveway or ramp can be recovered at the drain outlet (east of tank containment dikes). This will be done by Boiler Plant or Safety Office personnel at the university or by the spill contractor.
2. If there is no flow of water at the time of the spill the material can be contained with absorbent booms or an excavated sump or berm.
3. If the spill occurs during a precipitation event the use of floating booms or the construction of an underflow dam may be required. Allow for the flow of storm water under the barrier. A series of barriers may be required to completely contain the spilled oil.
4. Any spilled material that enters the storm drainage ditch to the north of the ASTs can be recovered in a similar manner. Every effort should be made to contain the spilled material before it enters the storm sewer flowing under the Dedmon Center.

Dedmon Center

1. If there is no or low flow in the storm sewer, plug a downstream manhole outlet, if safe, using a plug or absorbent material. Safety office personnel or the spill contractor will seal the manhole. Appropriate personal protective equipment will be worn. The Safety Office must approve the use of respirators. Recover oil and water using pumps or skimmers.
2. If there is a high flow of storm water, place floating booms or baffles into a downstream manhole to contain oil while allowing the storm water to flow under the baffle/boom and out of the manhole. Such recovery efforts may be required at more than one manhole. The placement of booms or baffles will be performed by the Safety Office or the spill contractor.
3. If oil reaches the storm drain outlet to the New River oil should be contained at the Outfall if possible using floating booms and baffles with skimmer pumps. Again a series of barriers may be necessary to contain the oil. Additional downstream containment measures may be necessary and should be directed as needed based upon river and oil flow conditions. The spill contractor and/or hazardous materials teams will perform spill containment procedures on the New River with assistance from the Safety Office.

Facilities Management Area

1. Safety Office personnel or the spill contractor will attempt to contain and recover oil at the storm water detention basin. If there is little or no flow into the basin, plug the outlet and recover spilled material. If there is high flow, then place floating booms or baffles in the basin to contain oil while allowing storm water to flow out of the structure.
2. If oil reaches the ditch flowing from the basin to the New River, the spill should be contained using underflow dams, floating booms, baffles, etc. prior to the outfall to the river. This will be done by Safety Office personnel or the spill contractor.
3. If oil reaches the river, it should be contained as close as possible to the outfall using floating booms and baffles with skimmer pumps. A series of barriers may be necessary to contain the oil. Additionally, downstream containment measures may be necessary and should be directed as needed based upon river and oil flow conditions. The spill contractor and/or hazardous materials teams will perform spill containment procedures on the New River with assistance from the Safety Office.
4. Once downstream flow of oil has been contained, continue controlling the source of the leak so that no additional oil enters the water body.
5. Recover oil from drainage ditches and the riverbank using absorbent materials or other appropriate means.
6. Once the spilled material has been contained and recovered Facilities Management shall be notified so that the appropriate repairs can be made.

Incident Termination

The emergency is terminated when the situation is manageable, and there is no longer a discharge or threatened discharge of any materials. Termination of the incident will be made by the Emergency Coordinator at the university in consultation with the Safety Director. The magnitude and duration of emergency response will depend on a variety of factors including the quantity of material released, the extent of the impact, and threat to property, human health, and the environment. Follow up cleanup measures may be required by federal, state, and/or local government agencies to address impacted soil, surface water, shorelines; and/or groundwater.

Disposal

All wastes generated during response activities must be recovered and reused or otherwise disposed of in accordance with federal, state, and local regulations. The Safety Office will handle the recovery and disposal of hazardous materials. General guidelines for handling typical waste streams generated during response activities are listed below. DEQ can be consulted as necessary for additional guidance. There is no time restriction for on-site staging of non-hazardous petroleum wastes. However, these materials should be removed as soon as practical. Any hazardous wastes generated typically must be removed from the site within 180 days.

1. Recovered Oil and Impacted Water:  Recovered fuel oil and impacted water should be collected and placed into drums, tank trucks, or temporary storage tanks. A fuel recycler may manage recovered oil while impacted water should be characterized for off-site treatment/disposal.
2. Impacted Soil:  Soil or debris should be placed into drums, roll-off boxes or stockpiled on a bermed plastic liner and covered. Impacted soil should be stored on-site only until proper treatment/disposal requirements are identified and proper disposal arrangements can be made.
3. Impacted Equipment and Materials:  Impacted equipment and materials should be temporarily stored and disposed as described above or can be decontaminated (rinsed, steam-cleaned, washed, etc.) and reused or recycled. All cleaning should be done in a controlled area, and all liquids from the cleaning should be collected and disposed of properly. Any supplies that are depleted or destroyed as the result of the spill or subsequent response measures shall be replaced as soon as possible.

Post Discharge Review

Within two weeks of a spill incident, a formal review will be performed with the Safety Director, Police Director, and appropriate University staff. This post discharge review will be conducted to evaluate the cause of the spill, the success and/or failure of the response measures utilized and to identify possible actions to prevent recurrence. Information resulting from this review will be used to improve and/or update the Plan if needed. A Hazardous Materials Incident Report (Appendix B) will be completed at this time and will document the spill and countermeasures taken. The form will be maintained on file at the Safety Office and the appropriate facility for five years.

Appendix A - Potential Equipment Failures

Boiler Plant

 

50,000 gal #2 Fuel Oil ASTs

  

Description/ Secondary Containment:  Horizontal, cylindrical, double-walled steel ASTs with steel saddles. Tanks are situated in separate concrete containment dikes with capacities of 60,000 gallons. Each dike is drained with a normally closed valve (PIV) through an oil/water separator.

Fail Safe Devices:  Each tank is equipped with a level gauge and high level alarm.

Description of Discharge:  Tank overfill, slow line/valve leaks, or failure of tank/lines.

Max. Vol./Rate of Discharge:  50,000 gallon gradual to instantaneous discharge with 11,000 gallons escaping the dike.

Spill Direction:  Spilled material will flow into grate inlets feeding into a storm drainage ditch or directly to the ditch

Fuel Oil Unloading Area

Description/ Secondary Containment:  Concrete area sloped to sump that is closed during transfer with a volume of 1200 gallons. Transfer pumps are located on a steel skid that drains to the unloading area.

Fail Safe Devices:  The transfer system includes an automatic high level shut off.

Description of Discharge:  Transfer hose/piping leak or failure of transfer equipment/tanker.

Max. Vol./Rate of Discharge:  2000 gallons gradual to instantaneous discharge with up to 1000 gallons escaping containment.

Spill Direction:  Spilled material will flow into grate inlets feeding into a storm drainage ditch.

Dedmon Center

 

10,000 gal. #2 Fuel Oil AST

  

Description/ Secondary Containment:  Horizontal, cylindrical, steel AST with steel saddles. Tank is situated in concrete containment dike with a capacity of 12,000 gallons. The dike is drained with a normally closed valve.

Fail Safe Devices:  Each tank is equipped with a level gauge and high level alarm.

Description of Discharge:  Tank overfill, slow line/valve leaks, or failure of tank/lines.

Max. Vol./Rate of Discharge:  10,000 gallon gradual to instantaneous discharge with 2200 gallons escaping containment.

Spill Direction:  Southeast to trench drain to storm sewer or east to curb inlet to storm sewer.

Facilities Management

 

10,000 gal. Gasoline UST

  

Description/ Secondary Containment:  Double-walled fiberglass tank.

Fail Safe Devices:  Tank is equipped with overfill protection, spill containment basin, and leak detection system.

Description of Discharge:  Tank overfilling.

Max. Vol./Rate of Discharge:  50 gallons instantaneous.

Spill Direction:  To curb inlets, to detention basin, to New River.

 

2,000 gal. Diesel Fuel AST

  

Description/ Secondary Containment:  Horizontal, cylindrical, double-walled, steel AST with integral secondary containment dike mounted on steel skids.

Fail Safe Devices:  Tank is equipped with a level gauge and overfill protection system.

Description of Discharge: Tank overfill, slow line/valve leaks, or failure of tank/lines.

Max. Vol./Rate of Discharge:  2,000 gallons gradual to instantaneous with up to 440 gallons escaping containment.

Spill Direction:  To curb inlets, to detention basin, to New River.

 

500 gal. Used Oil AST

  

Description/ Secondary Containment:  Horizontal, rectangular, double-walled steel AST with steel skids.

Fail Safe Devices:  Tank liquid level is visible during filling.

Description of Discharge:  Tank overfill, slow line/valve leaks, or failure of tank/lines.

Max. Vol./Rate of Discharge:  500 gallons gradual to instantaneous.

Spill Direction:  To curb inlets, to detention basin, to New River.

 

Oil Transfer Area

  

Description/ Secondary Containment:  Paved areas adjacent to tanks.

Fail Safe Devices:  Diesel fuel tanks equipped with overfill protection and spill prevention equipment.

Description of Discharge:  Transfer hose/piping leak or failure of transfer equipment/tanker.

Max. Vol./Rate of Discharge:  2000 gallons gradual to instantaneous discharge with up to 1000 gallons escaping containment.

Spill Direction:  To curb inlets, to detention basin, to New River.
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Appendix B - Spill Notification Checklist

Agency/Organization	Telephone Number	Person Contacted	Date/Time	Initials
Fire Department/Rescue Squad	911
Department of Emergency Management	(800) 468-8892
DEQ West Central Regional Office	(540) 562-6700
National Response Center	(800) 424-8802
EPA Region III	(800)-438-2474
Emergency Response Contractor:  LCM Corporation	(800) 774-5583
Local Emergency Plan Commission (LEPC)	(540) 731-3617
Public Water Supply	N/A
New River Valley Medical Center	(540) 731-2000
Natural Resources Downstream:	New River
Wildlife Refuge:	N/A
Norfolk Southern Railway	540-981-4739
Park:	N/A

The person performing notifications during a discharge should be prepared to give the facility name, phone number, facility location (street address or directions), city or county, name of person in charge, facility mailing address, estimate of the volume discharged, type of product, source of discharge, name of the water body affected or threatened, weather conditions, any injuries, or evacuations, and what emergency containment has been undertaken.

Appendix C - Daily Inspection Form

Please see the PDF of the Daily Inspection Form.

Appendix D - Weekly Facility Inspection

Please see the PDF of the Weekly Inspection Form.