This is an ongoing summary of key federal and state environmental compliance requirements that are or may be applicable to University of Wisconsin System campus operations. The provides additional detail on potentially applicable environmental compliance programs and requirements for University of Wisconsin campuses.
UWSA endeavors to keep this listing as current and complete as possible; however, our office makes no claim that it covers all applicable aspects of environmental and hazardous materials program requirements. Resources and links are provided for the convenience of the user.
The Wisconsin Department of Natural Resources (WDNR) and the United States Environmental Protection Agency (EPA) hold educational institutions to the same environmental standards applied to businesses and the rest of the regulated community. University and college administration must make a genuine commitment to environmental compliance and communicate this commitment to their staff. Under Wis. Stats. 291.91, inspectors have legal authority to enter a regulated facility without warning and without delay. UWSA has developed a checklist to assist campuses in preparing for a RCRA or other environment, health and safety compliance audit:
ADDITIONAL RESOURCES
- WDNR Hazardous Waste Generator Checklists
- Wisconsin Administrative Code (categorized by agency)
- eCFR: Electronic Code of Federal Regulations (categorized by title)
The WDNR regulates air emissions under the Wisconsin air pollution control permit program. Air emission permits for some heating and cooling plants located on University of Wisconsin campuses are managed directly by the Wisconsin Department of Administration (DOA). Related inquiries should be directed to the DOA-DFD Architecture & Engineering Bureau, Heating Plant Engineering contact. Contact the Risk Manager with questions about other types of air permits (e.g., construction, operation, registration, general) or exemptions.
The federal Emergency Planning and Community Right-to-Know Act (EPCRA) is administered by the Wisconsin Department of Emergency Management (WEM), under Wisconsin Administrative Code, Chapters WEM 1-3. UWSA has developed a guide to EPCRA, which is intended to provide information on how EPCRA affects University of Wisconsin System campuses in Wisconsin. The covers the following topics:
- Emergency Planning Notification for Extremely Hazardous Substances
- Emergency Notification of Release and Wisconsin Spill Reporting Requirements
- SDS Chemical List Submission
- Tier II Emergency and Hazardous Chemical Inventory Reports
- Toxic Chemical Inventory Release (TRI) Reporting
ADDITIONAL RESOURCES
- Wisconsin Emergency Management EPCRA Resources
- US EPA EPCRA Information and Resources
- US EPA Emergency Policy and Guidance
- US EPA Revisions to EPCRA Hazard Categories and Minor Revisions (June 2016)
Under the federal Oil Pollution Act, the EPA requires some oil storage facilities to maintain Spill Prevention, Control and Countermeasure plans in order to prevent discharges into navigable waterways. Under the SPCC rule, oil is widely defined and includes, but is not limited to: petroleum; fuel oils; mineral oils; oil refuse and sludge; animal fats, oils and greases; vegetable oils and greases; and other synthetic oils and greases.
A facility is subject to the SPCC regulations and required to prepare and implement an SPCC plan if it has an aggregate aboveground capacity greater than 1,320 gallons in containers 55-gallons or more in size, or an underground capacity greater than 42,000 gallons, and there is a reasonable expectation of a discharge into a navigable waterway or adjoining shoreline. Please see the UWSA Spill Prevention, Control & Countermeasure page for more information on the plan requirements.
The Department of Agriculture, Trade and Consumer Protection (DATCP) regulates petroleum and hazardous liquid storage tanks, both aboveground and underground, under Wisconsin Administrative Code Chapter 93. Owners of underground tanks may be subject to annual permitting requirements as well as Class A/B/C training requirements for tank operators.
Resources for tank owners and operators are available on the DATCP Petroleum/Hazardous Liquids Storage Tank website.
STORMWATER
The WDNR regulates point source and nonpoint source stormwater pollution through the Wisconsin Pollutant Discharge Elimination System (WPDES) program, which includes construction, industrial and municipal separate storm sewer system (MS4) permits. For more information on stormwater management at University of Wisconsin campuses, contact the UWSA Capital Planning & Budget Office. Contact the UWSA Office of Risk Management with permit or regulatory questions.
DRINKING WATER
Under the federal Safe Drinking Water Act (SDWA), the EPA sets drinking water standards and endeavors to protect public drinking water supplies and ensure drinking water safety. The WDNR manages activities and programs related to drinking water quality and safety through the Bureau of Drinking Water and Groundwater. In addition, local public health departments and water utilities work collaboratively to ensure safe drinking water for communities across the state.
Disclaimer
This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.