9.D.10 Transportation of Chemicals and Hazardous Waste

Transportation of both hazardous materials and hazardous waste is primarily regulated by the Department of Transportation (DOT), under authority of the Hazardous Materials Transportation Act. The RCRA rules include some additional requirements for transportation of hazardous waste.

The DOT regulations applicable to transport of laboratory chemicals include those governing packaging, labeling, marking, placarding, and reporting of discharges. A transporter is defined as any person engaged in the off-site transportation of hazardous materials or waste. These regulations apply not only to those who actually transport, but also to those who initiate or receive hazardous waste shipments. Those who prepare hazardous materials for transportation must also meet certain training requirements. These requirements have been recently promulgated under the Hazardous Materials Transportation Uniform Safety Act. For institutions whose laboratory operations are at a single site, transportation within that site is not regulated, as long as that transport involves no travel along public ways. Most institutions, however, have developed policies for on-site transportation covering labeling, segregation of incompatibles, containment and double containment, and other necessary safeguards to prevent accidental release to the environment or injury to persons during transportation, even if not required by governmental regulation.

If off-site transportation of any hazardous material, including shipments of small samples to colleagues, is contemplated, the laboratory worker should consult the institution's environmental health and safety office and/or the EPA/DOT regulations.

9.D.11 Underground Storage Tanks

Subtitle I of RCRA was enacted to control and prevent leaks from underground storage tanks storing hazardous substances, including petroleum products. It is not uncommon to discover underground storage tanks that may have been installed many years ago in or near laboratory buildings. Inventorying of these tanks and establishing systems for leak detection, record-keeping, reporting, cleanup or other corrective action, and ultimately closure, are required by RCRA regulations. All new tanks installed must meet EPA and state design specifications for the tanks themselves and associated piping and cathodic protection systems. All underground storage tanks must comply with the regulations for new tanks by December 22, 1998.

9.E THE CLEAN AIR ACT

The Clean Air Act (CAA) regulates emissions into the air. Under the 1990 amendments to the CAA, emissions of sulfur dioxide, volatile organic compounds (VOCs), hazardous air pollutants (HAPs), and ozone-depleting chemicals (ODCs) are being more rigorously regulated. Institutions with large research laboratory operations will be affected by these rules, given their use of a variety of volatile chemicals and solvents that result in VOC or HAP emissions. Laboratory managers should work closely with the institution's office of environmental health and safety in addressing issues of CAA regulatory application and compliance. Under the structure of the CAA, states and local air quality districts are responsible with EPA for developing emissions standards for local areas. These standards may vary. For example, areas with serious air pollution problems may develop stricter emissions controls.

Colleges, universities, or other institutions with research laboratories that have the potential to emit one or more of the listed hazardous air pollutants in amounts greater than 10 tons/year of a single hazardous air pollutant or 25 tons/year of total hazardous air pollutants will be considered a major source and covered by the regulations. The "tons per year" calculation is based on total potential emissions by facilities in a contiguous area and under common control, including such sources as power plants and boilers, and, in a few states or localities, fume hoods. Thus, many of the larger research institutions will be affected by these new standards. EPA will be establishing emission standards based on "maximum achievable control technologies" for each source category. The 1990 amendments also require EPA to establish a special source category for research or laboratory facilities. EPA has not yet issued specific laboratory-directed regulations, but, as noted above, laboratories that are part of a large university or research institution will be regulated as part of that combined major source.

Laboratories should also be aware of regulatory provisions relating to stratospheric-ozone-depleting substances. The list of such substances can be found at 40 CFR 82, Appendixes A and B to Subpart A. The list includes as "Class I" substances most common freons, carbon tetrachloride, and methyl chloroform. The regulations prohibit the movement in interstate commerce of these substances and other listed ozone-depleting substances.

It is clear, however, that CAA enforcement, which has, up to now, largely focused on industrial emissions, will focus increasingly on emissions from universities and other research institutions. Laboratory researchers should work closely with the institution's environmen-



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