Environmental Compliance Audit

GEI Consultants, Inc. was selected by Mitchell College to conduct an environmental compliance audit. The following is an outline of the environmental laws and regulations which were included in this project. These programs satisfied both a United States Environmental Protection (EPA) audit as well as Connecticut Health and Educational Facilities Authority (CHEFA) audit.

1. Air Quality

GEI identified air pollutant emissions sources and gathered sufficient information on installation dates, capacity of units, fuel types, and annual quantities of fuels combusted in order to compile an emissions inventory. That information was subsequently used to estimate potential and actual emission rates of regulated pollutants using EPA emission factors and other relevant information. The potential and actual emission rate estimates were used to perform a regulatory compliance evaluation.

2. Asbestos

Available asbestos compliance documents were reviewed to assess compliance with the referenced laws and regulations as applicable. Recommendations were provided as applicable relative to plans, surveys, procedures, training, etc.

3. OSHA Hazard Communication

Mitchell College is required to have a hazards communication program that includes identifying hazardous chemicals used, labeling containers, maintaining an information site for Material Safety Data Sheets (MSDS), and training workers in chemical safety. Mitchell’s current program was reviewed and recommendations were made as appropriate.

4. Hazardous Waste

GEI reviewed hazardous waste management procedures to determine compliance with the Resource Conservation and Recovery Act (RCRA). This included an assessment to determine if all wastes had been characterized to determine if any were classified as hazardous. Based on this evaluation, GEI made compliance recommendations.

5. Biomedical Waste

The college was assessed to determine if biomedical waste was generated, and if so, if biomedical wastes were managed in compliance with this regulatory program.

6. Wastewater

Potential regulated wastewater discharges at the college included: compressors, boiler blow downs, shop sinks, floor drains, chemical discharges, non-contact cooling wastewater, domestic wastewater, and storm water. An inventory of wastewater discharges was made with the assistance of appropriate Mitchell college staff. The inventory was assessed with CTDEP discharge regulations and permit requirements, and recommendations were made relative to applicable permit requirements and/or changes to discharge practices.

7. Underground Storage Tanks

Mitchell College has several underground fuel oil storage tanks. These tanks were assessed relative to CTDEP’s underground tank requirements regarding registration, construction, age, monitoring, and record keeping. As appropriate, GEI made compliance recommendations.

8. Spill Prevention Control and Countermeasure (SPCC)

SPCC requirements pertain to the aboveground storage of petroleum, which if released, could migrate to a navigable water body. An inventory of aboveground petroleum storage at the college was made to determine if SPCC requirements applied.

9. CERCLA

Mitchell College is not listed as a CERCLA site; therefore, this law was not applicable with theexception of release reporting andcommunity right-to-know issues. After reviewing chemical use and storage, and past spill history, GEI assessed applicability and compliance with these aspects of CERCLA.

10. Inland Wetlands

The Town of New London files were reviewed for existing permits, compliance requirements, and potential violations.

A report was prepared summarizing the findings of the environmental audit. It was organized by regulatory program. The current environmental practices were summarized and compared to regulatory requirements. Deficiencies were presented and an action plan to achieve compliance was prepared.