Environmental Management Plan

Updated March 1, 2014
EHS#4

1. Purpose and Scope

The purpose of this document is to describe the Environmental Management program at Boston University (BU) and the Boston Medical Center (BMC), and to define the interactions, roles, and responsibilities of the Environmental Management Division with respect to other BU and BMC departments.

The Environmental Management program at BU and BMC is the sum of the personnel, policies, and activities which promote compliance with environmental regulations and environmental stewardship. Environmental Management is a division of Environmental Health and Safety (EHS).

2. Definitions

• Boston University (BU): the Charles River Campus (CRC) and Medical Campus (MED).
• Environmental Protection Agency (EPA): The branch of the federal government tasked with protection of the environment. The EPA promulgates and enforces environmental regulations on a national level.
• Hazardous Waste: Refers to chemical wastes which are governed under federal or state regulations due to their hazardous characteristics. In Massachusetts, waste oil is considered a hazardous waste.
• Industrial Wastewater: Water from industrial activities including laboratory and facility operations. Industrial wastewater generally undergoes pretreatment and is discharged to the sanitary sewer. At BU and BMC, industrial wastewater discharges are managed under the provisions of an institution-specific Sewer Use Discharge Permit.
• Massachusetts Department of Environmental Protection (DEP): The branch of the state government tasked with protecting the environment. The DEP promulgates and enforces environmental regulations on a state level. The DEP regulations must be at least as strict as the national EPA regulations. In many circumstances (e.g., hazardous waste, water emissions, air emissions, and underground storage tanks), the DEP regulations overlap with and even exceed EPA regulations.
• Massachusetts Department of Public Health: The branch of the state government which promulgates and enforces biological waste regulations.
• Massachusetts Water Resources Authority (MWRA): The local Publicly Owned Treatment Works responsible for managing the sewer effluents for greater Boston. MWRA regulates industrial wastewater discharges and issues Sewer Use Discharge Permits.
• Medical/Biological Waste: Human and animal tissues and fluids, infectious organisms, contaminated items, and sharp medical/research implements.
• Stormwater: Precipitation—including rain and snowmelt—as well as water from washing cars, overwatering lawns, and other sources. Stormwater is of concern as it flows either directly or via discharge piping into surface waters such as rivers, lakes, and streams.
• Underground Storage Tank: A storage tank that is partially or completely buried in the earth. At BU and BMC underground storage tanks are used to store fuel oil.
• Universal Waste: A subset of federal and state hazardous waste for which the regulatory burden is slightly less onerous. They are called “universal” because they are generated universally across industrial sectors and include things like fluorescent bulbs (due to mercury content) and mercury-containing devices such as switches, pesticides, and certain batteries.

References

The Environmental Management program is responsible for ensuring BU and BMC compliance with a number of regulations, standards, and best practices, including, but not limited to, those listed below.

3.1. Regulations

3.1.1. Federal Regulations

• Oil Spill Prevention, 40 CFR 112
• Hazardous Chemical Waste, 40 CFR 260
• Air Emissions, 40 CFR 60,70
• Water Emissions, 40 CFR 403
• Polychlorinated Biphenyls (PCBs), 40 CFR 761

3.1.2. State Regulations

• Underground Storage Tanks, 527 CMR 9
• Massachusetts Contingency Plan, 310 CMR 40
• Hazardous Chemical Waste, 310 CMR 30
• Medical/Biological Waste, 105 CMR 480
• Air Emissions, 310 CMR 7
• Water Emissions, 360 CMR 10, 314 CMR 7&12, 257 CMR 2

3.2. Other Standard Operating Procedures (SOPs)

• Boston Medical Center Environmental Management System
• Boston University Environmental Health and Safety Policy Manual

3.3. Supplementary Documents

• Boston Medical Center Integrated Contingency Plan
• Boston University Medical Campus (MED) Integrated Contingency Plan
• Boston University Charles River Campus (CRC) Integrated Contingency Plan
• Boston Medical Center Sewer Use Discharge Permit
• Boston University Medical Campus Sewer Use Discharge Permit
• Boston University Charles River Campus Sewer Use Discharge Permit
• Boston Medical Center Air Plan Approvals
• Boston University Charles River Campus Title V Operating Permit

4. Roles & Responsibilities

Each office at Boston University and Boston Medical Center has different roles and responsibilities regarding environmental and waste management.

Environmental Management Division:

• Serving as the liaison between governmental environmental authorities and BU/BMC.
• Developing policies and procedures for BU/BMC that ensure compliance with environmental regulations and responsible environmental stewardship.
• Managing the disposal of regulated wastes—including chemical, biological, and radiological wastes—at BU/BMC.
• Serving as environmental subject matter experts for other departments, such as Facilities Management & Planning, affected by environmental regulations and considerations.
• Providing training in environmental management to relevant staff at BU/BMC.
• Inspecting and tracking compliance with environmental programs at BU/BMC.
• Preparing most regulatory-driven environmental plans, permits, reports, and submittals for BU/BMC.
• Responding to environmental and waste-related incidents at BU/BMC, including site management, internal and external notification, and remediation.
• Working with the BMC Green Committee and BU Sustainability to promote sustainable operations and practices.
• Tracking changing and emerging environmental rules and regulations.

BU Facilities Management and Planning (FMP) / BMC Facilities and Energy Management (FEM):

• Overseeing the daily operation, maintenance, testing, and general management of environmentally significant installations including:
  • Fuel storage tanks
  • Fuel burning equipment (e.g. boilers and emergency generators)
  • Equipment that contains refrigerant gases
  • Industrial Wastewater pretreatment systems
  • Stormwater management infrastructure
  • Building heating and cooling systems
  • Building plumbing and ventilation systems
• Issuing internal notification prior to the addition or significant alteration of any environmentally significant installation.
• Tracking the quantities and types of fuel used at BU/BMC.
• Tracking the consumption of water and energy at BU/BMC.
• Providing adequate space and facilities to manage regulated wastes including chemical, biological, and radioactive wastes.
• Carrying out operations, including construction and renovation activities in conformance with existing BU/BMC policies, including maintenance schedules, disposal practices, incident notification, and record keeping.
• Managing the disposal of recyclable materials including paper, cardboard, and surplus furniture.

Office of General Counsel:

• Providing advice and counsel relative to environmental regulation, or in the event of an environmental incident.
• Negotiating with environmental regulators in the event of an enforcement action taken against BU/BMC in response to an environmental incident.

Research and Clinical Departments:

• Generating and accumulating wastes according to BU/BMC policies and procedures.
• Providing internal notification in the event of an environmental incident.
• Completing all required environmental training sessions.

5. Special Requirements

The special requirements are as follows:

5.1. Equipment and Supplies

• Chemical spill kits and materials
• Oil spill kits and materials
• Emergency response equipment, including absorbent materials, containment drums and berms, and personal protective equipment (PPE)
• Dedicated storage rooms for chemical, biological, and radioactive waste
• Drums, containers, and labels for managing chemical, biological, and radioactive waste
• Radiation detectors
• Industrial wastewater pretreatment and monitoring systems
• Stormwater collection and drainage systems
• Emission stacks for fuel burning equipment
• Run-time meters for emergency generators
• Secondary containment structures for oil storage installations
• Overfill, corrosion protection, and leak detection equipment for underground storage tanks
• Recycling equipment, including cardboard bailers, solvent distillation equipment, and silver-recovery equipment
• Amalgam separators at dental facilities
• Air pollution control equipment including the woodshop bag house

5.2. Safety

Environmental Management operations require compliance with all applicable BU/BMC safety policies and procedures implemented through Environmental Health and Safety.

5.3. Training

The Environmental Management Division of EHS provides training to the BU/BMC community, including:

• Oil and Waste Management/SPCC for FMP staff
• Universal Waste training for FMP staff
• Hazardous Waste training to BU/BMC departments who do not receive Laboratory Safety Training
• Department of Transportation (DOT) training to custodial leads and others who sign biological waste shipping papers

Staff members in Environmental Health and Safety receive OSHA training and Resource Conservation and Recovery Act (RCRA)/DOT training from a third party vendor annually, which allows them to be first responders to environmental incidents and to sign and manage dangerous goods shipping papers.

5.4. Monitoring

• Sewer Use Discharge Permits for industrial wastewater require sampling of industrial wastewater systems multiple times each year.
• Some operating permits for fuel burning equipment require air monitoring.
• Contaminated site cleanup typically requires a monitoring schedule for soil and ground water to document cleanup activities.
• Sampling is often necessary to characterize a waste product prior to disposal.

5.5. Personal Protective Equipment (PPE)

Environmental Management operations require compliance with all applicable BU/BMC safety policies and procedures implemented through Environmental Health and Safety.

5.6. Medical Surveillance

Staff members in the Environmental Management Division receive Hazardous Materials physical examinations annually through the Occupational Health Center or the Research Occupational Health Program.

5.7. Other Prerequisites

Each campus (BMC, BUMC, CRC) must employ wastewater operators licensed by the State of Massachusetts at a grade at least as high as the highest-graded treatment process on that campus.

6. Applicability

All BU/BMC affiliated locations.

7. Procedures and Instructions

In general, the Environmental Management Division provides guidance, oversight, and training to help departments such as FMP carry out their operations.

The Environmental Management program can only be administered through cooperation between the Environmental Management Division and the various other departments at BU/BMC that conduct environmentally sensitive operations. Building operation and maintenance, solid waste management, research and clinical laboratory work, and many other campus activities require input and direction from the Environmental Management Division in order to ensure compliance with the various environmental regulations.

Procedures for specific environmental programs are described in detail in the BU Environmental Health and Safety Policy Manual and the BMC Environmental Management System policies.

8. Forms

Forms and signage exist for a variety of Environmental Management processes. The attached Environmental Management functional chart further illustrates the disciplines within the division.

Forms also exist for environmental management processes including, but not limited to, inspections, equipment testing and maintenance, tracking environmental samples, and transporting dangerous goods and wastes.

9. Records Management

Environmental Management records are maintained either by the Environmental Management Division of EHS, or by a department that operates or maintains environmentally significant equipment.

10. SOP Revision History