The U.S. Environmental Protection Agency (EPA) recently 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. 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. 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.