[Pharmwaste] Haz Waste incineration

Holcomb, Sarah, NMENV sarah.holcomb at state.nm.us
Thu Jul 30 18:10:54 EDT 2009


Hi Rudy,

I've been told by our Hazardous Waste Bureau that since the medicines
are coming from households and not businesses, these programs would fall
under the Household Hazardous Waste exemption under Part 261.4(b)1, even
if the medications are classified as hazardous waste. 

 

~Sarah

 

Message: 2

Date: Thu, 30 Jul 2009 10:30:49 -0400

From: "Rudy Vingris" <rvingris at woh.rr.com>

Subject: [Pharmwaste] RE: Air Quality?   Pharmwaste Digest, Vol 45,

            Issue 13

To: <pharmwaste at lists.dep.state.fl.us>

Message-ID: <20090730143056205.VTVE8759 at hrndva-omta01.mail.rr.com>

Content-Type: text/plain;        charset="us-ascii"

 

I am writing in response to Sarah Holcomb's question about studies of
air quality from the incineration of pharmaceuticals.  I don't know of
any specific studies but I would like to provide the following thoughts
on your comments of compliance with RCRA.  

 

If the envisioned incinerator is going to be used to incinerate any RCRA
hazardous waste pharmaceutical, it will need to meet all the
requirements for TSDF and hazardous waste incinerators found in 40 CFR.
261.  These are extensive and complex requirements.  I do not believe
that the cost to comply with these regulations could be justified in a
small scale project to incinerate a small amount of RCRA pharmaceutical
waste.  In addition to RCRA the incinerator would also have to meet Air
Pollution regulations (most likely a Title V permit) to burn any type of
waste.  

 

I think it would be much more cost effective to make use of existing
commercial capacity to destroy these wastes.  

 

Rudy Vingris

Consultant

 

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Sarah Holcomb

Environmental Scientist/Specialist

Surface Water Quality Bureau

New Mexico Environment Department

5500 San Antonio NE, Albuquerque, NM 87109

505-222-9587

P  Please consider the environment before printing this e-mail 

 



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