Be Prepared for EPA Inspections, Says CMI
(12/09/2005)

OMAHA, Neb. - Rather than waiting for inspectors from the U.S. Environmental Protection Agency to appear in your office, state correctional administrators should adjust their environmental protocols and avoid last-minute negotiations.

The Virginia Department of Corrections learned this lesson recently, and is currently finalizing the paperwork for an EPA settlement after inspectors visited 15 prisons and "discovered non-compliance with environmental regulations."

"We were already disposing of things in accordance with federal law, we just didn't have the paperwork when the EPA inspector showed up," says Bert Jones, the Virginia DOC's director of architecture and engineering services. "It wasn't like we were dumping drums of hazardous materials in the swamp."

Jones speaks about Virginia's recent experience at the Oct. 19 meeting of the Construction Maintenance Institute for Criminal Justice Agencies (CMI) in Omaha. "My goal is to help prevent other states from having to go through the same thing we went through," say Jones, who is also on the CMI board of directors.

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Virginia undertook the effort in connection with the settlement for violations of the Clean Water Act, Clean Air Act and the Resource Conservation & Recovery Act. An example of one violation: the DOC needed to update the manifests for drums containing waste stain from a furniture shop.

What does it mean to go through the EPA settlement process? "When the EPA comes in, they give you a report on your violations and say, 'Go fix them.' The timeline was 90 days for each facility. Not long," Jones told Correctional News.

"We went through the process of identifying and implementing a supplemental environmental project, which is one of the options that EPA gives you," he says. Rather than paying fines, the DOC took money that otherwise would have paid the fines and instead put it toward a supplemental environmental project. In addition, the department added a new Pollution Prevention Unit to the existing Environmental Services Unit.

"There are now five individuals that are responsible for supporting the field and helping identify pollution-prevention opportunities within the department," Jones says. "That's something that's above-and-beyond regulations, which is why it was approved as a supplemental environmental project."

Jones reports that the Virginia DOC is now in compliance with EPA regulations and is confident future inspections won't create the same headaches. "If you take a proactive approach to dealing with the environment - not always and easy thing to do in corrections because we have so many conflicting priorities - it's a lot easier to do it up front than with the EPA breathing down your neck," Jones says.

Bert Jones is just one of many correctional professionals and industry representatives scheduled to present at the CMI conference and technology exposition. Other topics include ACA physical plant standards, CCTV/DVR/wireless, mold and IAQ, construction costs and trends, and using fly-ash in construction.

Participants also may tour the Nebraska Correctional Youth Facility, a unique facility specifically designed to house youthful offenders sentenced as adults. To get more information on the CMI conference, visit the organization's Web site.

www.cmi-cja.org

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