From:
List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject:
Re: Waste Evaporation
Date:
Mar 18, 2010 18:56 UTC
Reply-To:
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Message-ID:
<legacy-2010-20100318f@ilpi.com>
In-Reply-To:
Date: March 18, 2010 2:50:24 PM EDT
Hi:
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.
Thanks!
Cheers,
Brad
