approximately 80 percent is released for resale and the vendor assumes all subsequent liability. Reactivation is attractive principally because it is less costly than disposal and/or the purchase of freshly made activated carbon.

Landfilling is less expensive than incineration and is the preferred option if the carbon is not suitable for reactivation. However, the contaminants adsorbed on the carbon can leach out, and the generator can be expected to retain liability for the landfill operation. Permitted hazardous waste landfills suitable for disposal of spent activated carbon include several operated by Clean Harbors, Waste Management Inc., and American Ecology.

Incineration is the most expensive of the three options but the one with the least potential liability. At least two commercial hazardous waste incinerators, Clean Harbors in Aragonite, Utah, and Veolia in Port Arthur, Texas, are permitted to burn spent activated carbon and have experience in doing so. Permits might be required to handle activated carbon contaminated with the agent by-products discussed in Chapter 4, although there is no question that they would be destroyed by incineration. The agent by-products are similar to those in the hydrolysate from Newport that are being burned successfully at Veolia’s incinerator in Port Arthur, Texas.

Finding 5-1. Reactivation is an attractive alternative to landfilling or incineration for disposing of unexposed carbon if the carbon reactivation contractor accepts liability for subsequent use and disposal.

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