Environmental Auditing Of Municipal Facilities The activities of local government can present environmental risks or liabilities that are created knowingly through violation of environmental regulations.They can also be created by past practices that pose athreat to the environment. Environmental risk is normally associated with industry. However, many localgovernments conduct activities that can pose environmental risks or liabilities. Environmental regulationssuch as the Resource Conservation and Recovery Act(RCRA), Clean Air Act (CAA), Clean Water Act(CWA), Toxic Substance Control Act (TSCA), and theEmergency Planning and Community Right-To-KnowAct (EPCRA) can affect municipal operations. DuPage County is one such local government thatdiscovered that it had activities that could pose a risk orpotential liability. The County found out after the factthat a transporter of hazardous waste, generated by theCounty, was taking the waste to a landfill which eventually become part of the Superfund program. Super-fund is the Nation's program to clean up uncontrolledhazardous waste sites. Superfund, also known as theComprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), provides forthe cleanup of a hazardous substance released into theenvironment, usually after the substance was disposedof improperly. It is intended to remedy environmentaldamages that have already been committed. As the generator of the hazardous waste, the Countywas still a responsible party that contributed to thesuperfund site and, therefore, was partly responsiblefor action to clean up the site. The County, thus, became a deminimus (minor) contributor to the super-fund site. Since the County's contribution of hazardouswaste was minimal it was able to reach a settlement onit's cost participation in the cleanup. Still the Countyhad to pay a substantial dollar amount to reach thissettlement. One might ask how they could prevent the super-fund action if they did not know they were contributingwaste to the landfill. There are proactive steps thatevery government should consider in reviewing its environmental risks. The point is to take a proactive rolerather than waiting for the regulators to place the organization in a reactive stage. The County decided to reduce environmental riskand exposure through an environmental managementprogram. The first step with an environmental management program is generally initiated with an environmental audit. Environmental compliance audits assess a facility's compliance with environmental lawsand regulations. The reasons for conducting an auditvary, but the objective is to provide management withinformation to better manage compliance with environmental laws and regulations. The cost of the environmental management program would have easily paidfor itself when weighed against the cost of settlementon the superfund site. Environmental auditing is a common practiceamong large, regulated entities such as industrial corporations, hospitals, federal facilities, and utilities. However, DuPage County is a regulator that adopts, administers and enforces regulations. As a regulator theCounty is in an awkward position to be audited forenvironmental compliance. Many of the facility managers were administering environmental programssuch as waste water treatment or solid waste management. Normally, an environmental audit of a facility isconducted by an independent party. However, facilitymanagers can become uneasy about having someoneconduct an audit of their facility. Therefore, a combination self-assessment and third party approach to theaudit was undertaken. The County had a number offacility managers that were familiar with the environmental regulations. Their participation in the environmental audit process was crucial. The County also hiredan environmental consulting firm to manage the environmental audit process. The consultant provided assistance in terms of providing additional support for thefacility managers. Initially, questionnaires were sent tovarious facility managers to allow them to provide preliminary information that could be used to determineenvironmental regulatory issues that affected their facilities. The environmental questionnaires enabledCounty personnel to collect and supply environmentaldata about their individual facilities. In addition, it alsoallowed for a quick means of initial data collection,encouraged County personnel to actively participate in February 1995 / Illinois Municipal Review I Page 15 the audit process and lowered the overall cost of theenvironmental audit program. The data collected from the environmental questionnaire provided a basis for conducting the on-site audits.The audit generally began with a meeting between thefacility manager and the environmental auditor. Theaudit included a review of the facility "paper trail"associated with waste management and disposal. A sitewalkover was conducted to observe operation, housekeeping, material storage and handling, and general siteconditions. A review of maintenance and inspectionrecords, health and safety records, sampling and analysis records and pollution controls was conducted, ifapplicable. Upon completion of the site audit, the auditor conducted an exit interview with the facility manager to give a verbal summary of the findings. A followup report was then prepared that discussed the areas ofnoncompliance and the recommendations. Municipal operations involve a variety of activitiesthat are affected by environmental regulations. Thetype of DuPage County facilities that are affected byenvironmental regulations include: the animal shelter,automotive repair shop, capital plant, waste watertreatment facilities, water purification facility, the convalescent center, print shop, sheriff's department crimelaboratory, highway department, landscape waste composting facility, materials recycling center and variousadministrative offices. Each municipal jurisdiction will have different facilities which will be affected by environmental regulations. For example, numerous activities can generatehazardous waste. The following list shows the typicalwaste streams generated by small quantity generators.
The type of environmental issues that were identified as having an impact on DuPage County included: use of toxic or hazardous chemicals, generation of solid,special and hazardous waste, emergency response torelease of hazardous chemicals, notification requirements under the Community Right-to-Know Act, airemissions permitting for power generation, polyclorinated biphenyls on site, underground storage tankmanagement, emergency response plans for employeesdealing with hazardous chemicals, past activities thatcould create subsurface contamination and identification of asbestos containing materials on site. All of theissues were minor, but had the potential to pose environmental risk to the County. All issues were immediately dealt with by the County. Environmental risks can develop even with a wellthought out environmental management plan. However, DuPage County is well on its way to reducing itsoverall environmental risks and exposure through aproactive environmental management program. Thegame plan is to remain proactive and stay on top of itsenvironmental risks through a periodic review of itsenvironmental practices. Page 16 / Illinois Municipal Review / February 1995
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