Document O3z8M8wpq6VGxYKXQvVKwGxBj

FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Inspection Date(s): Facility or Site Name: Facility/Site Physical Location: (city, state, zip code) Mailing address (if different from above): Facility/Site Contacts: Website: RCRA ID Number: Latitude, Longitude: 14 September 2023 Inspection Announced: No Fairleigh Dickinson University - Florham Campus Fairleigh Dickinson University - Florham Campus, Building #11 285 Madison Ave Madison, NJ 07940 Michael Reed, Armark District Manager for Facilities Reed.Michael@Armark.com (484) 685-2013 Michael DiArchangel, Armark Operations Manager DiArchangel.Michael@Armark.com (201) 693-8023, (973) 443-8926 https://www.fdu.edu/campuses/florham-campus/ https://www.aramark.com/our-services/facilities-management-services NJD986621985 40.774440586827644, -74.43345706643493 Facility/Site Personnel Participating in Inspection: Michael Reed Armark District Manager for Facilities Michael DiArchangel Armark Operations Manager James Mizvesky Edith Myers, PhD Chemistry Lab Supervisor Biology Department Chair Reed.Michael@Armark.com (484) 685-2013 DiArchangel.Michael@Armark.com (201) 693-8023, (973) 443-8926 (973) 443-8766 Inspector(s): Carl F. Plssl US EPA, Enforcement Officer/Engineer Plossl.Carl@epa.gov (212) 637-4088 Additional Inspection Report Elements: None Inspection Report Author: Carl F. Plssl CARL PLOSSL Digitally signed by CARL PLOSSL Date: 2023.11.22 11:07:32 -05'00' 1 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Supervisor Leonard Grossman SECTION I - INTRODUCTION Purpose of the Inspection Objective A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. The facility has been previously inspected for RCRA compliance 12 times, last by NY State in 2018, and has had a notification history as a large quantity, small quantity, and, most recently, a very small quantity generator: 2 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Opening Conference I, EPA Region 2 RCRA inspector Plssl, arrived at the Barn, the Public Safety and Campus Facilities Building on the Florham Campus of Fairleigh Dickinson University at ~1:15 pm on September 14, 2023, for an unannounced inspection of the University. I announced and identified myself inside the campus security office and was directed upstairs to the Campus Facilities Office. There, I was met by the Michaels, Reed and DiArchangel, District Manager for Facilities and Operations Manager, respectively. Both were Aramark employees. We discussed the facility past and current operations, waste management and disposal practices, and the nature of federal RCRA inspections. Messrs. Reed and DiArchangel were not familiar with hazardous waste inspections. Note: Building 11, the Barn, and associated storage space, including the box truck storage space, is covered under a separate RCRA ID number, and is the subject of a separate inspection report. Facility/Site Description From Fairleigh Dickinson University: About FDU The largest private university in New Jersey, FDU is a not-for-profit, nonsectarian, multicampus institution. Founded in 1942, FDU achieved four-year status in 1948 and approval as a university in 1956. The University offers over 100 undergraduate and graduate degree programs, including doctoral programs in pharmacy, nursing practice, clinical psychology and school psychology; and an AACSBaccredited business school. Degree programs are offered on two New Jersey campuses and at two FDU locations outside the U.S.: Wroxton College, in Oxfordshire in England, and the Vancouver Campus, in British Columbia, Canada. 3 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT FDU's 12,000+ full- and part-time students pursue quality career-oriented programs on schedules tailored to their needs -- days, evenings and weekends. The curriculum reflects a mission of global education and a foundation of a nationally-renowned Core. The Florham Campus emphasizes a well-rounded academic experience rich in choices and balanced by dynamic extracurricular activities. Whatever your major, your education will prepare you to problem solve effectively, think creatively and communicate persuasively -- skills that will prepare you for a lifetime of success. FDU Florham is primarily a residential campus, supported by a strong student life program. It boasts active fraternities and sororities, diverse student activities, and dynamic Division III and intramural athletics programs. Resident students are joined in class by undergraduate commuters and by adult, graduate, and certificate students, utilizing first-class educational resources either retrofitted into the campus' distinctive and appealing original buildings, or newly built especially in the most recent decades. From Aramark Facility Manage Services: We create a set of services that are tailored to deliver on your highest priorities. From daily operational support to complex technical challenges, we deliver on your business goals. As your needs change and grow over time, we adapt with you. We're your trusted consultant and your go-to partner for innovative industry solutions. Innovative and sustainable solutions designed to optimize resources and proactively manage your budget Efficient and effective programs that ensure the delivery of quality solutions Customized services that ensure your environments are safe and engaging Proven processes to prevent the avoidable and prepare for the unexpected Service relationships that are responsive and adaptive to your changing needs According to Messrs. Reed and DiArchangel: General o Aramark took over 1 August 2023 o Aramark handles dining facilities, waste management, and environmental compliance o A subcontractor, EWMA, also manages (and transports) hazardous waste https://www.ewma.com/ o Aramark will likely oversee EWMA operations at FDU o An additional subcontractor, Collins Building Services, provided cleaning and waste management services o Facility managed as a very small quantity generator 4 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT o All vehicle maintenance is off-site o Main academic programs of note: Chemistry Biology Art Department All labs are located in the Science Building o Facilities, including Aramark, share the Barn with Public Safety Hazardous wastes regularly generated: o Expired lab chemicals o Lab wastes, mainly spent solvents (e.g., HPLC waste) o Used oil o Spent fluorescent lamps o Old paints and spent cleaning and painting solvents o Spent lead acid batteries o E-wastes Waste dispositions: Manifest Date 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 6/26/2023 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 11/21/2022 Waste Qty 1 11 80 80 100 20 150 1 4 30 2 1 1 2 1 100 4 1 10 22 1 1 Units Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Pounds Waste (kg) 0 5 36 36 45 9 68 0 2 14 1 0 0 1 0 45 2 0 5 10 0 0 D001 D001 D001 D001 D001 D001 D002 D002 D011 D022 D001 D001 D001 D001 D001 D001 D001 D001 D001 D002 D002 D003 D002 D002 D002 D002 D022 D008 F002 D002 D002 D002 D002 D003 D003 D007 U133 Waste Codes D007 D008 D022 F002 F003 F003 F005 F002 F003 D003 5 D022 F003 F003 D018 TSDF ID PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 NJD002200046 PAD067098822 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 MTN* 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948800JJK 022948808JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT See Appendices for additional manifest records. Records requested: o See Appendices o On site records had last HW manifest 06/28/2021 #0221176824 SECTION II - OBSERVATIONS The accompanying FAIRLEIGH DICKINSON UNIVERSITY FLORHAM Inspection Photos.pptx document is the complete set of inspection observations made during the facility walkthrough with Messrs. Reed and DiArchangel. SECTION III - AREAS OF CONCERN Concerns On site record availability (new management possibly a mitigating circumstance) Hazardous waste transported from satellite accumulation areas to storage room, both internal to the Science Building, possibly without HW training Fire extinguisher inspections may lack thoroughness (based on observed fire extinguisher with Feb 2017 inspection date in the Science Building, C.A.A. Hazardous Waste Storage) The majority of the HPLC equipment spent solvent/hazardous waste containers were not closed (Main Campus: Science Building - S-10 Instrument Lab) One example of incompatible chemical storage (S-2A Chemistry Stock Room) o Sulphuric acid with acetone, ethyl [rest of the label was obscured], and 3 unidentified chemical containers (see Inspection Photos, Slide 39) Inadequate storage space provided for the storage and/or staging of class lab chemicals and other materials resulting in an increased potential for spillage and incompatibilities (S-2A Chemistry Stock Room) o As explained to me, each class employs one or more small, open, blue bins for all student lab in-use materials. The bins are stored on shelves in the stock room. Observed class bins included several with a disordered mix of chemicals and other materials (see Inspection Photos, Slides 35-37) Inconsistencies in management of fume hoods and chemical storage practices in the Science Building's lab spaces (e.g., sashes observed wide open with stored chemicals under hood when not in use, hoods used for longer-term storage) Spent chemicals stored/accumulated in the photography lab without a hazardous waste determination (and without proper management and disposal) The evident use of flammable mineral spirits in printing and other art applications not addressed in subsequent audit (see Appendix 3). 6 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Closing Conference Mr. DiArchangel and I reviewed my findings and we discussed any follow up. Mr. DiArchangel provided several follow up emails (see Appendix 3). In addition, as the Art Department lacked any supervising party at the time of the inspection, I requested an audit. Mr. Reed responded the following day with: Prior to departure yesterday, you asked that someone inspect the Arts Department classrooms, workspaces and offices to insure that all cleaning chemicals were stored, utilized and disposed of safely. We have arranged for FDU's compliance and waste management specialists (EWMA) to conduct this assessment, the afternoon of Monday, 18 September. We will provide feedback upon completion. Further information was provided by Mr. Reed on 19 September 2023: Hope all is well. We were able to partner with FDU's compliance and waste management specialists (EWMA) for the assessment of the Arts Department classrooms, workspaces, offices and photography lab. During this assessment, we learned that there are no chemicals involved with cleaning the paint supplies and brushes. They utilize soap and water for this purpose. As far as the photography lab is concerned, the chemicals in that space are being evaluated for removal by a hazardous waste specialist that is being recommended by EWMA. We will provide further details on this analysis and removal within the next few business days. INSPECTION PHOTOGRAPHS: See FAIRLEIGH DICKINSON UNIVERSITY FLORHAM Inspection Photos.pptx FACILITY MAP: See Appendix 1 MANIFEST RECORDS: See Appendix 2 FOLLOW UP EMAILS: See Appendix 3 7 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Appendix 1: FDU - Florham Campus Map 8 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT 9 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Appendix 2: FDU - Manifest Records Manifest Date Waste Qty Units Waste (kg) Waste Codes 6/26/2023 1 Pounds 0 D001 6/26/2023 11 Pounds 5 D001 D002 6/26/2023 80 Pounds 36 D001 D002 D007 D008 6/26/2023 80 Pounds 36 D001 D002 D022 F002 F003 6/26/2023 100 Pounds 45 D001 D002 F003 F005 6/26/2023 20 Pounds 9 D001 D022 F002 F003 6/26/2023 150 Pounds 68 D002 6/26/2023 1 Pounds 0 D002 D008 6/26/2023 4 Pounds 2 D011 6/26/2023 30 Pounds 14 D022 F002 11/21/2022 2 Pounds 1 D001 11/21/2022 1 Pounds 0 D001 11/21/2022 1 Pounds 0 D001 D002 11/21/2022 2 Pounds 1 D001 D002 D003 11/21/2022 1 Pounds 0 D001 D002 D022 F003 11/21/2022 100 Pounds 45 D001 D002 F003 11/21/2022 4 Pounds 2 D001 D003 11/21/2022 1 Pounds 0 D001 D003 D018 11/21/2022 10 Pounds 5 D001 D007 11/21/2022 22 Pounds 10 D002 11/21/2022 1 Pounds 0 D002 U133 11/21/2022 1 Pounds 0 D003 11/21/2022 6 Pounds 3 D005 D007 11/21/2022 1 Pounds 0 U007 5/25/2022 4 Pounds 2 D001 5/25/2022 8 Pounds 4 D001 D002 D005 F003 5/25/2022 40 Pounds 18 D001 D002 D007 5/25/2022 50 Pounds 23 D001 D002 D011 D022 F002 F003 5/25/2022 50 Pounds 23 D001 D002 D022 F003 F005 5/25/2022 1 Pounds 0 D001 D002 F002 5/25/2022 20 Pounds 9 D001 D007 5/25/2022 1 Pounds 0 D001 U009 5/25/2022 20 Pounds 9 D002 5/25/2022 2 Pounds 1 D002 D003 5/25/2022 8 Pounds 4 D002 D007 F002 5/25/2022 10 Pounds 5 D004 D022 F002 5/25/2022 1 Pounds 0 D009 U151 9/1/2021 4 Pounds 2 D001 9/1/2021 2 Pounds 1 D001 D002 9/1/2021 1 Pounds 0 D001 D002 U404 9/1/2021 3 Pounds 1 D001 D003 9/1/2021 160 Pounds 73 D001 D022 F002 F003 U108 U213 9/1/2021 1 Pounds 0 D001 U117 9/1/2021 2 Pounds 1 D002 9/1/2021 1 Pounds 0 D002 U020 9/1/2021 5 Pounds 2 D005 D007 D008 D022 9/1/2021 1 Pounds 0 D009 9/1/2021 1 Pounds 0 U138 10/22/2020 50 Pounds 23 D001 D002 D007 10/22/2020 100 Pounds 45 D001 F002 F003 F005 10/22/2020 4 Pounds 2 D002 10/22/2020 30 Pounds 14 D002 D004 D007 10/22/2020 20 Pounds 9 D005 D007 D022 F002 9/24/2018 7 Pounds 3 D001 9/24/2018 65 Pounds 29 D001 D002 9/24/2018 10 Pounds 5 D001 D002 D038 F005 9/24/2018 10 Pounds 5 D001 D002 F003 9/24/2018 1 Pounds 0 D001 D003 9/24/2018 5 Pounds 2 D001 D022 F003 9/24/2018 10 Pounds 5 D001 F003 9/24/2018 40 Pounds 18 D001 F003 F005 9/24/2018 1 Pounds 0 D001 U117 9/24/2018 1 Pounds 0 D002 9/24/2018 1 Pounds 0 D002 D007 9/24/2018 15 Pounds 7 D009 9/24/2018 20 Pounds 9 D011 D022 F002 9/24/2018 1 Pounds 0 P075 7/20/2018 10 Pounds 5 D001 TSDF ID PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 PAD067098822 NJD002200046 PAD067098822 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 NJD002200046 MTN* 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948694JJK 022948800JJK 022948808JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 022948800JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 023909427JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 022948928JJK 017907469JJK 017907469JJK 017907469JJK 017907469JJK 017907469JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 017907091JJK 018892940JJK 10 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Appendix 3: Follow Up Emails From: Mr. Michael Diarchangel Sent: Friday, September 15, 2023 8:02 AM To: Plossl.Carl@epa.c Cc: Dick Frick <rfrick@fdu.edu>; Reed, Michael <Reed-Michael1@aramark.com>; Craig Gorczyca <craig.gorczyca@ewma.com>; Scott Curcio <scott.curcio@ewma.com> Subject: FW: [External]RE: FDU Madison Waste Manifest Good morning Carl, As requested, attached is Fairleigh Dickinson University hazardous waste manifest. Below is the email that was sent to me by EWMA which is the company that handles and manages all of Fairleigh Dickinson's environmental compliance and waste management. I will also forward you the email with the most recent hazardous waste manifest. Thank you, Michael DiArchangel Plant & Operations Maitenance Manager Aramark - FDU Florham Campus 285 Madison Ave, ML-BB2-02 Madison, NJ 07940 Office (973) 443-8926 From: Craig Gorczyca <craig.gorczyca@ewma.com> Sent: Thursday, September 14, 2023 2:22 PM To: Mr. Michael Diarchangel <diarchan@fdu.edu> Subject: [External]RE: FDU Madison Waste Manifest Mike: The is the hazardous waste manifest from 6/8/21 which I got from your database. It should be in the Haz Waste binder as well. The other manifests have been non-hazardous manifests between then and up until last month. FDU just made a hazardous waste shipment last month which I will send over shortly. -craig 11 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Carl, Attached is the most recent hazardous waste manifest. As per the below email Fairleigh Dickinson University has had (2) hazardous waste shipments over the past (3) years. Thank you, Michael DiArchangel Plant & Operations Maintenance Manger Aramark - FDU Florham Campus 285 Madison Ave, ML-BB2-02 Madison, NJ 07940 Office (973) 443-8926 From: Craig Gorczyca <craig.gorczyca@ewma.com> Sent: Thursday, September 14, 2023 2:33 PM To: Mr. Michael Diarchangel <diarchan@fdu.edu> Subject: [External]RE: FDU Madison Waste Manifest Here is the other hazardous waste manifest that hasn't been input in the FDU database yet. We just got it. That's it. There has been only 2 hazardous waste shipments within the past 3 years. Craig Gorczyca CHMM Director, Compliance & Waste Management EWMA 100 Misty Lane, P. O. Box 5430 Parsippany, NJ 07054 P: (973) 560-1400 x145 M: (973) 703-6649 www.ewma.com INNOVATIVE | EXPERIENCED | RESPONSIVE 12 RCRA Compliance Branch FAIRLEIGH DICKINSON UNIVERSITY - FLORHAM CAMPUS INSPECTION REPORT Hello Carl, Attached are a few photos of actions we took from the inspection. (3) photos of the universal waste storage where we organized and boxed the loose light bulbs. (1) photo of the fire extinguisher that was replaced for the chemistry storage room in the science building. Thank you, Michael DiArchangel Michael DiArchangel Plant & Operations Maintenance Manager Aramark - FDU Florham Campus 285 Madison Ave, ML-BB2-02 Madison, NJ 07940 Office (973) 443-8926 13