Environmental compliance audit for

A Major North Carolina University

Project Approach

The project involved conducting a comprehensive, multi-media environmental audit of a major university in North Carolina following the guidelines of the US EPA’s self-audit policy as published in Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, Volume 65, Number 70, Federal Register 19618, April 11, 2000, and using the concepts of an effective Environmental Management System (EMS).

The intent of the audit was to develop an assessment of the University’s performance respective to compliance with applicable environmental regulations and ordinances, as well as provide a foundation for development or modification of environmental strategies as they relate to future University activities and proposed environmental regulations. The results of the environmental audit were used to perform a gap analysis on areas deemed deficient or requiring additional attention.  By conducting the audit under the EPA’s self-audit policy, the University was able to disclose and correct compliance violations through systematic discovery and thereby not be subjected to economic and gravity-based penalties from EPA.

Scope of Work

 The Audit Team conducted the audit of the University’s academic and support facilities and operations in accordance with the guidelines of the EPA’s self-audit policy and any other applicable local, state, and federal standards.  The scope of our audit focus ranged from undergraduate and graduate academic facilities and departments in the arts, sciences and medicine, to facility support areas including energy services, housing and grounds maintenance, athletic facilities, and a hazardous waste treatment, storage and disposal facility.  Elements of the environmental audits included:

• Site visits to over 200 undergraduate and graduate laboratories and support shops within the University’s on and off-campus academic facilities for inspection of hazardous waste management;
• Site visits to facility maintenance shops, energy service facilities, athletic facilities, service stations, grounds maintenance facilities,  and other facility support areas for evaluation of compliance with local, state, and federal regulations pertaining to air emissions, wastewater discharges, hazardous waste management, and toxic/hazardous substances management ;
• Evaluation of campus-wide compliance with Clean Water Act regulations, including Oil Spill Prevention, Control and Countermeasure Plans and stormwater management
• Following the site visits, performance of a closing briefing with pertinent facility personnel to discuss the audit findings.  During the briefing, observations made during the site visits were discussed, with obvious non-compliance issues identified and recommendations for corrective action presented.  In addition to the non-compliance issues, areas of suspected non-compliance and other observations were discussed, with suggestions for further evaluation or modifications to existing practices made;
• Preparation of an audit report for the University that summarized the audit findings, classified the findings as principal concerns (obvious violations), secondary concerns (if continued, could increase the likelihood of a regulatory violation), or observations (noted for documentation purposes only), denoted the applicable regulatory citation (if any) for each finding, provided recommendations for corrective action, and outlined the schedule for corrective action or status of the corrective action (if already performed).