After Getting the Dust Out - Then What?

Potential Consequences of Improper Disposal of Hazardous Pollutants

Pulse Jet Pointers Vol. 7, No. 2

After Getting the Dust Out - Then What?

Potential Consequences of Improper Disposal of Hazardous Pollutants

Pulse Jet Pointers
Vol. 7, No. 2

I asked my daughter, an environmental attorney, to address the question of what happens to the worn bags and cartridges saturated with dust, which must be disposed of by our customers. Or, for that matter the dust itself, which is collected day after day in Beckert & Hiester Dust Collectors.

Quite often we receive calls from customers asking if they can take their blinded bags or cartridges out on the back parking lot and blow them out with an air hose. Some want to send bags to the laundry. Others like to clean their cartridges with a water hose as many cartridge media will now withstand washing.

Let us first assume the rare case where some type of rejuvenation is cost effective from a labor standpoint, and the media is not worn so there will be no subsequent dust leakage once reinstalled.

OK, the maintenance man is out there on the back lot with air and water hoses. Is he properly clothed and equipped with an adequate breathing device? Is he down wind and downstream of the plant and nearby neighbors? Is the EPA anywhere in sight? Is he really going to get away with it? Read the letter on the reverse side. Then tell your customers to send the old bags and cartridges to the proper disposal sites right along with the collected dust - if neither or either cannot be recycled in a safe and legal manner.

Best Regards,

Bruce Beckert

Dear Mr. Beckert:

This letter is in response to your inquiry regarding the potential consequences of improperly disposing of hazardous pollutants. As you are aware, there are a number of federal and state laws regulating the proper use, storage and disposal of hazardous pollutants. This letter, however, will only generally address the potential liability the generator of hazardous pollutants may have for improperly disposing of hazardous pollutants under the Comprehensive Environmental Response, Compensation and Liability Act, 42 U.S.C. § 9601, et. seq. (generally referred to as "CERCLA" or "Superfund".)

Under CERCLA, persons who generate or participate in the disposal of hazardous pollutants which damage or threaten the environment, may be held jointly and severally liable for costs incurred by either the government or private parties which respond to or abate the damage or threat. Jointly and severally liable means each person who generated or participated in the disposal of hazardous pollutants is subject to liability for the entire cost of cleanup.

CERCLA also imposes notification requirements in the event of any release of a "reportable quantity" of a hazardous pollutant to the environment. Furthermore, the act authorizes the Environmental Protection Agency or a state to unilaterally order responsible parties to respond to and remedy release or disposal site problems. Failure to comply with such an order, without good cause, subjects the recalcitrant party to liability for up to three times the cost of the ordered cleanup.

In short, improperly disposing of hazardous pollutants is not only environmentally irresponsible, but it can result in substantial penalties and cleanup liabilities under CERCLA. In addition, any party that knowingly violates or fails to comply with a federal environmental statute, may also be subject to criminal penalties.

If you would like more detailed or specific information regarding CERCLA or other federal environmental statues, please let me know. I would be happy to provide additional information.

Anne M. Beckert

EMAIL	Beckert & Hiester, Inc. P.O. Box 1885 Saginaw, MI 48605-1885 Local and International - 989-792-3443 or 989-793-2420 Toll Free - 800 332-4031 Fax - 989-793-2971 or 989-791-4781
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