Enforcement and Inspection

Quick List of Potential Violations at K–12 Schools

The most violated regulations are those covered under the following federal acts:
1. Clean Air Act
2. Clean Water Act
3. Safe Drinking Water Act
4. Resource Conservation and Recovery Act /Solid Waste Disposal
5. Oil Pollution Act
6. Superfund/Comprehensive Environmental Response, Compensation, and Liability Act
7. Federal Insecticide, Fungicide, and Rodenticide Act
8. Toxic Substances Control Act
9. Occupational Safety and Health Act
10. Food and Drug Act

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Potential asbestos violations include failure to:

  • Prepare and maintain an Asbestos Management Plan (even if the school is asbestos-free), maintain copies of the Plan in offices of the school and the local education agency, and at least annually notify parents, teachers, and employee organizations that the Plan is available for review (keeping a copy of the notification in the Plan).
  • Describe in the Asbestos Management Plan steps taken for annual notification of workers, building occupants, or their legal guardians about asbestos-related activities.
  • Appoint a designated person to oversee and ensure compliance with the Asbestos Hazardous Emergency Response Act (AHERA), and provide asbestos training to custodial and maintenance staff.
  • Identify all locations of suspected asbestos-containing building materials.
  • Take and analyze bulk samples, conduct six-month periodic surveillance and triennial re-inspections, and post warning labels in routine maintenance areas.
  • Notify the EPA of plans for renovation/demolition involving removal or disturbance of asbestos-containing materials greater than 160 square feet or 260 linear feet. Use trained and accredited asbestos personnel.

Potential hazardous waste violations include failure to:

  • Make proper hazardous waste determinations.
  • Label hazardous waste containers properly.
  • Close hazardous waste containers when not in use.
  • Segregate incompatible hazardous wastes.
  • Properly manage and dispose of hazardous wastes.
  • Use hazardous waste manifests.

Potential oil storage tank violations include failure to:

  • Monitor underground storage tanks (USTs)
  • Upgrade/replace/close USTs by December 22, 1998
  • Provide secondary containment for regulated aboveground storage tanks (ASTs) and develop and maintain a Spill Prevention, Control, and Countermeasure Plan (SPCC)
  • File annual Emergency Planning and Community Right-to-Know Act (EPCRA) Tier 2 chemical  inventory information with the local fire department, Local Emergency Planning Commission, and State Emergency Response Commission (for USTs and ASTs holding more than 1,320 gallons).

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 Potential underground injection control violations include failure to:

  • Comply with the ban on cesspools (no septic, leaching pit only) serving 20 or more persons.
  • Inventory and obtain authorization for septic systems serving 20 or more persons and discharge to a leach field or cesspool/leaching pit.
  • Inventory and obtain authorization for outdoor stormwater drain discharges to a dry well(s).
  • Inventory and obtain any required permits for shop or laboratory drain discharging to a dry well, septic system, or leach field.

Potential pesticide violations include failure to:

  • Apply pesticides according to label instructions, including commercial pesticides requiring application by a certified applicator.

Potential  chlorofluorocarbon (CFC) violations include failure to:

  • Ensure that all refrigeration air-conditioning equipment is serviced by personnel certified to handle and recover CFC refrigerants.

Potential combustion source violations include failure to:

  • Obtain applicable permit(s) for combustion products from boilers.
  • Notify and report the installation of new boilers greater than 10 million BTUs/hour.

Potential polychlorinated biphenyls (PCBs) violations include failure to:

  • Properly manage PCB oil and/or PCB-contaminated wastes, including (but not limited to) marking, recordkeeping, storage, inspection, and disposal requirements.

In addition, the EPA stresses that additional local, state, and tribal regulations may also apply and may be more stringent than the federal requirements.

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