Date: Thu, 18 Mar 2010 14:56:04 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: Re: Waste Evaporation

From: Bradley Randall Grams <bgrams**At_Symbol_Here**>
Date: March 18, 2010 2:50:24 PM EDT



Generally speaking, evaporation from a fume hood for purposes of disposal is treatment (by evaporation) of hazardous waste without a permit, and is a violation of U.S. EPA's Resource Conservation and Recovery and Clean Air Acts (RCRA and CAA, respectively), respectively.  It is also technically a violation of the State's respective RCRA and CAA equivalent programs.


While I understand that it is likely de minimis amounts of chemical, it is against the law, and the laws for very small generators of hazardous waste are extremely minimal (e.g., your municipal waste haulers in many cases have programs for you to dispose of such wastes, whether in industry or as a household). 


Finally, please note, that as such behavior seeks to avoid Federal, State, and potentially local, statutes and regulations, it may be considered a criminal act in your State.







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