Texas Universities Address Hazardous Waste Violations in EPA Settlement

The U.S. Environmental Protection Agency (EPA) announced settlements with three Texas universities over hazardous waste violations at university facilities.

Under the settlements, Baylor University, Texas A&M University and Texas Christian University all agreed to correct violations and pay a civil penalty. EPA discovered the violations by analyzing data the facilities are required to submit under the Resource Conservation and Recovery Act (RCRA), as well as analysis of additional records that the universities voluntarily provided.

Under RCRA, facilities producing hazardous waste are regulated as small- or large-quantity generators. From 2011 to 2014, while Baylor claimed to be a small-quantity generator, at times it generated more hazardous waste than is allowed under this criteria. The reason this is important is that large-quantity generators have much more stringent employee training requirements, and need to prepare detailed contingency plans for first responders. Baylor also at times generated hazardous wastes without identifying them as such. In addition to paying a civil penalty of $11,330, Baylor corrected existing violations and will revise its standard operating procedures to ensure the lab will comply with RCRA. Baylor will also purchase and donate equipment to the Waco Fire Department to aid in identifying explosives, narcotics, and toxic chemicals during emergency responses.

Similar violations were found at Texas Christian University (TCU) facilities in Fort Worth, Texas. TCU improperly operated as a large-quantity generator because it produced more than a kilogram per month of acutely hazardous waste, which are certain wastes that are more toxic in smaller quantities. During these incidents, TCU did not notify the state of Texas as required of large-quantity generators. Also, between 2011 to 2015, TCU did not make adequate or accurate hazardous waste determinations of its waste streams. TCU agreed to correct violations and pay a civil penalty of $30,591.

EPA discovered violations at four Texas A&M University campuses: Commerce; Kingsville Citrus Center in Weslaco, Texas; Veterinary Medical Diagnostic Laboratory in Amarillo, Texas; and the Geochemical and Environmental Research Group in College Station, Texas. Violations included generating enough hazardous waste to qualify as a large-quantity generator but not registering as one, generating acutely hazardous waste without proper notification, and not filing required paperwork. Under four separate settlements, Texas A&M agreed to correct all violations and pay a combined penalty of $141,912.

The Resource Conservation and Recovery Act, passed by Congress in 1976 gives EPA the authority to control hazardous waste from "cradle-to-grave." RCRA sets national goals for protecting human health and the environment from the potential hazards of waste disposal, conserving energy and natural resources, reducing the amount of waste generated, and ensuring wastes are managed in an environmentally sound manner.