Addressing Campus Compliance Obligations Through System-wide Self-audits 
State University of New York System 

The State University of New York (SUNY) System is the largest in the country, with 64 campuses across the state, ranging in size and complexity from large universities with major research facilities to two-year community colleges. SUNY faces a myriad of environmental regulations, and maintaining compliance requires constant effort. In 2002, the SUNY System took advantage of EPA’s Self-Audit Policy and entered into an agreement with the EPA Region II office. The agreement required participating schools to conduct environmental compliance audits of their operations, disclose the results to EPA, and correct any violations discovered. In return, the participating campuses received amnesty from fines for disclosed violations.

The SUNY System hired Woodard & Curran to conduct audits of the 58 participating campuses, draft a preliminary findings document for each campus, and prepare final audit reports that facilitated SUNY’s disclosure to EPA. Every audit was completed on time and on budget and no scope changes were submitted, and none of the participating campuses was fined for disclosed violations.

Many individual campuses hired Woodard & Curran to implement corrective actions for compliance deficiencies discovered during the audit, and to perform additional follow-on compliance tasks, such as:

• Preparing emergency response plan, including Integrated Contingency Plans and stand-alone Oil Spill Prevention Control and Countermeasure Plans, and providing plan implementation training;
• Providing air permitting services, including developing permitting strategies, preparing Title V and State permit applications, record keeping and reporting assistance, and preparing a refrigerant guidance documents to help one campus manage its refrigerant use;
• Conducting wastewater and stormwater surveys for several campuses, preparing discharge options reports, and providing wastewater management and engineering support;
• Designing and delivering training programs, including initial and annual hazardous waste management training, universal waste training, DOT hazardous materials training, Oil SPCC training, lab safety training, and emergency response training;
• Assisting with regulated medical waste issues;
• Performing an engineering analysis on an air/propane system;
• Drafting SOPs on mixed radioactive/hazardous waste, and solvent recovery and elementary neutralization hazardous waste treatment requirements; and
• Investigating an oil release from a petroleum storage tank.

Woodard & Curran was also invited to speak on sustainability at two SUNY campuses. The discussions focused on practical, easily implemented, and cost-effective sustainability ideas that campus staff, faculty, and students could work on together to minimize environmental impacts. The presentations included specific examples from a variety of colleges and universities, including creative suggestions concerning energy conservation, waste minimization, green construction, and environmentally preferable purchasing.

* Images courtesy of The University at Buffalo.