of this book. From a chemical point of view, it is feasible to reduce the volume or the hazardous characteristics of many chemicals by reactions within the laboratory. In fact, it is becoming common practice to include such reactions as the final steps in an experimental sequence. Such procedures, as part of an academic or industrial experiment, usually involve small amounts of materials, which can be handled easily and safely by the laboratory worker. Chemical deactivation as part of the experimental procedure can have considerable economic advantage by eliminating the necessity to treat small amounts of surplus materials as hazardous waste. Furthermore, the handling and deactivation of potential waste by the laboratory worker benefit from the expertise and knowledge about the materials of the person who has generated them.

The question of what is considered treatment under RCRA regulations has posed a dilemma for laboratory workers. RCRA regulations define treatment as "any method ... designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render the waste non-hazardous or less hazardous ... " (U.S. Congress, 1978). Under RCRA, treatment, with very limited exceptions, must be permitted by EPA.

The regulatory procedures and costs to be a "permitted" treatment facility are beyond the resources and mission of most academic and industrial laboratories. Yet it is prudent to carry out small-scale "treatment" as a part of laboratory procedures. This fact has been recognized by state agencies and some regional EPA offices through "permit-by-rule," that is, by allowing categorical or blanket permitting of certain small-scale treatment methods. For example, elementary acid-base neutralization is usually allowed, as is treatment that is the last step of a chemical procedure. Most EPA regions also allow treatment in the waste collection container. It is important to note that treatment restrictions apply only to wastes that are addressed by EPA regulations.

A bill has been promoted in Congress to allow small-scale treatment by laboratory personnel. However, specific legislation has not been enacted at this time. The fact that regional EPA offices have interpreted such small-scale reactions differently further complicates decisions at the laboratory level. Because illegal treatment can lead to fines of up to $25,000 per day, it is most important that, before carrying out any processes that could be considered treatment, the responsible laboratory worker or the institution's environmental health and safety office check with the local, state, or regional EPA to clarify its interpretation of the rules.

(Section 7.D below provides methods for small-scale treatment of common chemicals.)

7.B.6 Disposal Options

Decisions on the ultimate disposal method are an important part of the on-site planning for handling of waste. The method of collection has an impact on, for example, how waste will be stored so as to most efficiently accomplish its transfer to the treatment, storage, and disposal facility (TSDF). Waste generators often use several disposal options because each has its own advantages for specific wastes. Disposal in the sanitary sewer, though appropriate in some cases, is becoming an unacceptable option in many communities. At the same time the options for landfill disposal are also disappearing rapidly. Incineration is becoming the most common disposal method. However, the long-term outlook for this method may be limited by increasing environmental concerns as well as the difficulty in obtaining permits for commercial incineration facilities. Waste minimization is the management strategy of the future. (See Chapter 4, section 4.B, for step-by-step instructions on source reduction and Chapter 7, section 7.C, for general information on minimizing hazardous waste.)

7.B.6.1 Incineration

Incineration is becoming the disposal method of choice for several reasons. It promises to give the generator the best assurance of long-term safety from liability. It also leads to a minimum amount of residues that must be disposed of in landfills. However, at this time, incineration is still one of the more expensive disposal options. It is becoming increasingly difficult to obtain a permit to establish a commercial incinerator because of local opposition (the "not in my backyard" syndrome) and environmental concerns centering on questions regarding the effectiveness of the incineration process.

Nevertheless, most disposal companies are moving toward incineration disposal, particularly for the kinds of hazardous waste generated by laboratories. Their typical variety of different wastes, usually in small quantities, makes incineration a favorable option. Laboratory waste can often be incinerated in its shipping Lab Packs without any further handling. Commingled flammable solvents are commonly blended with the incinerator fuel and thus destroyed as they provide energy for the burning process.

Earlier editions of this book were optimistic that small laboratory incinerator systems would be developed for efficient destruction of waste at the point of

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