In response to the Jan. 21 article “Waste doubles on campus,” I would like to point out several factual inaccuracies that, if accepted as written, could result in legal penalties.
Any facility, other than a household, that produces solid waste legally classified as hazardous falls under the jurisdiction of the Resource Conservation and Recovery Act (RCRA). Requirements under this RCRA vary based on the amount of waste produced. However, all facilities that generate any hazardous waste have responsibilities under the RCRA and should consult those requirements carefully.
Blending compatible waste for disposal is not considered treatment under RCRA. Those blended wastes are often incinerated by professional waste disposal companies. Those blended wastes are not used on campus for fuel.
Mixing a waste with an acid or a base to neutralize is considered a treatment and may not be performed by individuals or facilities without a Treatment, Storage and Disposal (TSD) permit from EPA/DEQ. Mississippi State University has no such permit and may not perform treatments on waste unless specifically approved by EPA/DEQ for research purposes.
While there are other misstatements and inaccuracies in the article, I choose to focus my comments here solely on the items that could result in fines or other legal action if taken as written.
If your readers have questions regarding RCRA or our hazardous waste management activities and policies on campus, I invite them to visit our Web site at www.msstate.edu/dept/compliance, attend a training session offered by our office or contact us directly at 325-3294.
Tracy S. Arwood is the director of the office of regulatory compliance.