[Pharmwaste] RE: Haz Waste incineration

Rudy Vingris rvingris at woh.rr.com
Fri Jul 31 12:57:50 EDT 2009


Yes, that is an exemption States can use for hazardous wastes.  As other
have written, the application of the exemption can vary by State.  
 
While the incinerator could be exempted from hazardous waste permitting, I
would recommend you talk to your State's Air Pollution board to determine
what if any permitting would be required. Permitting requirements are
generally determined based on the types and amounts of emissions which are
closely related to the type and capacity of the unit.  
 
Rudy Vingris
Consultant
 
  _____  

From: Holcomb, Sarah, NMENV [mailto:sarah.holcomb at state.nm.us] 
Sent: Thursday, July 30, 2009 6:11 PM
To: rvingris at woh.rr.com
Cc: pharmwaste at lists.dep.state.fl.us
Subject: 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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