[Pharmwaste] Haz Waste incineration

Gilliam, Allen GILLIAM at adeq.state.ar.us
Fri Jul 31 08:44:59 EDT 2009


Sarah,

Interpretations differ from state to state and seemingly can vary even
within a state's own haz waste division on numerous issues.  If your
state gave you that opinion, I'd keep a-taking-back and don't look back.

Our only take-back program's organizers sent a written request to our
state's haz waste (and air too) division but, never got a response so we
don't even know what their opinion might have been.  No responses from
either division to a written request?  "dam the torpedoes, full speed
ahead" (local law enforcement fully engaged).  Going on a ton of meds
incinerated in almost two years, right Nancy?

Allen g    
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Holcomb,
Sarah, NMENV
Sent: Thursday, July 30, 2009 5:11 PM
To: rvingris at woh.rr.com
Cc: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Haz Waste incineration


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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