[Pharmwaste] RE: National take-back program - what kind ofincinerators?

Vollmer, Art, NMENV art.vollmer at state.nm.us
Fri Aug 27 14:32:54 EDT 2010


New Mexico Environment Dept air quality folks had this take on portable
incinerators such as the Drug Terminator:
 
Looking at the emissions from the double chambered units (we do not have
an adequate description of the unit to assure that it is double
chambered) that the NMPB wants to use, it is apparent that even at 8760
hr/yr, that these units fall below permitting requirements.  There do
not appear to be either NSPS or NESHAP requirements for this type of
unit that burn at this rate.  We looked at 40 CFR 60, subparts  Cb, Ce,
E, Ea, Eb, Ec, 4A, 4B, 4C, 4D, 4E, and 4F.  While some of the combustion
components may be HAPs, they are unlikely to reach the 10 tons of one,
or 25 tons combined that are required to be a major source.  We are not
aware of area source requirements for drug burning units, although the
NSPS does talk about regulations applying to area sources.
 
When looking at the potential emissions, we selected to use AP-42
external combustion emission factors for LPG, natural gas, and diesel.
The Inciner8 uses fuel for both a gen set and presumably for the burner
but we do not know how fuel is partitioned between the two, and do not
have information of the horsepower of the gensets.   The genset is to
run internal fans, we are guessing maybe 25 hp.  For the diesel
emissions, we calculated for No.2 and No. 6 diesel, using the maximum
manufacturer's fuel consumption rate.  We used 8760 hours per year.  The
rates for them are low for all emissions (typically below a half ton per
year) although if we assume the use of No. 6 diesel at 4% sulfur by
weight, we get about 8.8 tpy emissions for SOx.
 
We had to make more than a few assumptions to determine waste loading.
We have heard that about 1.5 drums of drugs were collected at a recent
effort in Rio Rancho.  We are assuming 55 gallon drums.  Assuming a 1.3
gm/cm3 weight for your average pills, a full drum will have a net weight
of 600 pounds.  Assuming 100 drums (30 tons) are collected and burned
annually, and using emission factors from AP-42, 2.3 Medical Waste
Incineration (7/93), the highest emission rate will be for PM, about 140
pounds per year.
 
There are two very important caveats for these burners, however (even
though they may not be enforceable).  The first is no burning of plastic
containers, drugs only.  Plastics will emit dioxins and furans when
burned.  The second is no burning of anything that could be considered
infectious wastes - used syringes or needles.  In addition to this, the
ash from burned pharmaceuticals is considered a special waste by the SWB
and must be controlled and disposed of accordingly.  So both used
syringes/needles and pharm ash needs to be disposed of according to SWB
regulations.  Syringes and needles (used) may be considered hazardous
waste.
 
1) Would process efficiency as measured by a conversion of volatile
solids be required?
NO.  While this is not required, the equipment purchased to perform the
burning of pharmaceuticals should be operated according to
manufacturer's instructions.  Burning should not occur until the
recommended burn temperature is achieved. 
 
2) What would the design of such units have to conform too, these are my
ideas (applicable codes and standards including but not limited to the
American National Standards Institute, local zoning, most recent
applicable building code (international at this point?), any local
building codes, any others???? Are their incinerator codes?
We do not enforce other people's codes, not ANSI, UPC, UEC, fire,
zoning, building, etc.  There are incinerator regulations under the CAA
but none appear to apply to this situation at the present time.  The
NMED Air Quality Bureau regulations, NMAC20.2.62 for municipal
incinerators, and NMAC20.2.63 for biomedical waste incinerators, do have
guidelines for permitted municipal and medical incinerators, but do not
specifically mention the burning of pharmaceuticals, and are not
applicable to these units.
 
3) What applicable requirements, if any, would be necessary for
particulate matter or other emissions?
The PM and other emissions for fuel burning are likely to be below
permitting levels.  NMAC20.2.61 requires that the opacity level of the
smoke plume leaving the incinerator stack does not exceed 20%, but the
applicability of this regulation does not require a permit.  
 
4) Would setbacks from other buildings or flue gassing be required?
Since this type of incinerator will not require a permit, unless
additional information suggests it does, there are no air quality
setbacks required.  However, there may be fire codes or local
regulations requiring setbacks for combustion units near buildings.  
 
5) If a mobile unit is used, what would AQB require as far as permitting
or registration?
You mean portable; we don't regulate mobile sources such as cars or
trains that emit while they move.  At a minimum, a detailed No Permit
Required request needs to be filed for each type or model unit used, but
not for each and every unit.  This request will have to provide
information about the size of the incinerator, the size of any generator
set that is used by the unit, operating temperature, type and rate of
fuel use, anticipated size of an average burn load, and number of burn
loads per year.  This will allow the Air Quality Bureau to determine if
this unit can operate without a permit. 
 
6) If stationary, outside of Bernalillo County, what would AQB require,
for example plans, registration fees, etc.?
The Air Quality Bureau will require the same information as required for
a portable unit.
 
7) Would AQB also be concerned about the unregulated use of the Drug
Terminator at police stations?
Not at this time, due to their small size, but we encourage education
about burning plastics and the hazardous compounds that would result.

 
Art Vollmer
Compliance Program Manager
NMED Hazardous Waste Bureau
Phone: (505) 476-6004
P   Please consider the environment before printing.
 

________________________________

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam,
Allen
Sent: Friday, August 27, 2010 11:51 AM
To: pharmwaste
Subject: RE: [Pharmwaste] RE: National take-back program - what kind
ofincinerators?


no visible smoke, no particulate matter and a quick vortex generating
high heat incineration.  yeh, I suppose it would fry a mosquito or two
flying directly over its exhaust.
 
"Contraband or prohibited goods are exempt from the MSW NSPS in 40 CFR
60.2887(p):  Units that combust contraband or prohibited goods. Your
incineration unit is excluded if the unit is owned or operated by a
government agency such as police, customs, agricultural inspection, or a
similar agency to destroy only illegal or prohibited goods such as
illegal drugs, or agricultural food products that can not be transported
into the country or across State lines to prevent biocontamination. The
exclusion does not apply to items either confiscated or incinerated by
private, industrial, or commercial entities."
 
Once handed over to one our participating law enforcement agencies or
left in a secured drop box, un-used/expired meds are deemed "contraband"
quoted from one of our local police chiefs.
 
One of our air division's guru's stated, your police officer can even
take the box of pharmas out to your city's animal control incinerator
and toss it in.
 
the unit looked at is Elastech's cyclonic drum "Drug Terminator" @
http://www.u-p-i.com/drug_terminator.htm .  They say over 2,000 law
enforcement agencies around the country are already using them.
 
And, yeh, to agree with Jack, "we're getting to the same place so it
doesn't matter what horse you're riding on".  I TOTALLY agree.
 
As a caveat though, our Office of the Drug Director's "Czar" has not
signed off on the procurement of any of these yet.  Hopefully it's in
their immediate plans.  As of today, excepting 3 other established
"terminator" sites in the state, the majority of the take-back
contraband is hauled all the way to the southern edge of the state to
our only permitted haz waste incinerator, Clean Harbors.  
 
The State's Office of Drug Director's correspondence/request to ADEQ's
director for concurrence is "in the mail".
 
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 Stevan
Gressitt
Sent: Thursday, August 26, 2010 4:01 PM
To: pharmwaste
Subject: Fwd: [Pharmwaste] RE: National take-back program - what kind of
incinerators?




	But at this time we are not using portable mosquito foggers to
claim to dispose of used drugs. 
	
	
	On Wed, Aug 25, 2010 at 8:23 AM, Price, John L. "Jack"
<John.L.Price at dep.state.fl.us> wrote:
	

		Allen: I like the "friendly" competition between Ark and
Maine! 

		 

		It sounds like the program will be using portable
incineration units. Can you provide any details like brand, model? Does
"scattering mobile incinerators around the state" give any of your air
reg people heartburn (it would to ours!)? 

		 

		We found the same thing in FL: Diversion trumps
environment. The last pharm take back bill proposed in FL was about
diversion first with an environmental footnote. But that's OK - it gets
us to the same place so it doesn't matter what horse we ride.

		 

		Jack

		 

		John L. (Jack) Price

		Environmental Manager

		Waste Reduction MS 4555

		Florida Department of Environmental Protection

		2600 Blair Stone Road

		Tallahassee, FL  32399-2400

		Phone:850.245.8751

		Fax: 850.245.8811

		john.l.price at dep.state.fl.us
<mailto:john.l.price at dep.state.fl.us> 

		www.dep.state.fl.us/waste
<http://www.dep.state.fl.us/waste> 

		Please Note:  Florida has a very broad public records
law.  Most written communications to or from state officials regarding
state business are public records available to the public and media upon
request.  Your e-mail is communications and may therefore be subject to
public disclosure.

		 



		The Department of Environmental Protection values your
feedback as a customer. DEP Secretary Michael W. Sole is committed to
continuously assessing and improving the level and quality of services
provided to you. Please take a few minutes to comment on the quality of
service you received. Simply click on this link to the DEP Customer
Survey
<http://survey.dep.state.fl.us/?refemail=John.L.Price@dep.state.fl.us> .
Thank you in advance for completing the survey.
		

		From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Gilliam,
Allen
		Sent: Tuesday, August 24, 2010 2:34 PM
		To: pharmwaste at lists.dep.state.fl.us
		Subject: [Pharmwaste] National take-back program

		 

		Currently working with this group to help make Arkansas
one of the top take-back states in the country (gotcha beat, Gressitt!)
.  142 law enforcement agencies signed on as of today.  Will hopefully
be looking at scattering incinerator units throughout the state.

		 

		See below short TV clip with our "Drug Czar", Fran
Flener talking about the national take-back day on 9/25.  Talk about an
organizer!

		 

	
http://www.todaysthv.com/news/local/story.aspx?storyid=114588&catid=2

		 

		It took, what Nancy?  8 months to get your take back
program started, focusing on the environmental protection?  It took less
than 2 months for this statewide campaign to begin rolling focusing on
drug diversion.

		 

		Allen g

			 


		---
		Note: As a courtesy to other listserv subscribers,
please post messages to the listserv in plain text format to avoid the
garbling of messages received by digest recipients.
		---
		TO SUBSCRIBE, go to:
http://lists.dep.state.fl.us/cgi-bin/mailman/listinfo/pharmwaste
		TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please
send an e-mail to pharmwaste-unsubscribe at lists.dep.state.fl.us -- the
subject line and body of the e-mail should be blank.
		If you believe you may be subscribed with a different
email address, please visit the subscriber listing at
http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
		FOR PROBLEMS:  Contact List Administrator
Laurie.Tenace at dep.state.fl.us
		SEND MAIL to the list server at:
pharmwaste at lists.dep.state.fl.us
		
		




	-- 
	
	Stevan Gressitt, M.D.
	Faculty Associate, University of Maine Center on Aging
	Academic Member, Athens Institute for Education and Research
	Athens, Greece
	Founding Director, Institute for Medicine Safety
	University of New England, College of Pharmacy
	Department of Pharmaceutical Sciences 
	Associate Professor of Clinical Psychiatry
	University of New England, College of Osteopathic Medicine
	716 Stevens Avenue 
	Portland, Maine 04103
	gressitt at gmail.com  
	Cell: 207-441-0291 
	www.benzos.une.edu <http://www.benzos.une.edu/>  
	www.safemeddisposal.com/
	
	




	-- 
	
	Stevan Gressitt, M.D.
	Faculty Associate, University of Maine Center on Aging
	Academic Member, Athens Institute for Education and Research
	Athens, Greece
	Founding Director, Institute for Medicine Safety
	University of New England, College of Pharmacy
	Department of Pharmaceutical Sciences 
	Associate Professor of Clinical Psychiatry
	University of New England, College of Osteopathic Medicine
	716 Stevens Avenue 
	Portland, Maine 04103
	gressitt at gmail.com  
	Cell: 207-441-0291 
	www.benzos.une.edu <http://www.benzos.une.edu/>  
	www.safemeddisposal.com/
	
	




Confidentiality Notice: This e-mail, including all attachments is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited unless specifically provided under the New Mexico Inspection of Public Records Act. If you are not the intended recipient, please contact the sender and destroy all copies of this message. -- This email has been scanned by the Sybari - Antigen Email System. 



-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://lists.dep.state.fl.us/pipermail/pharmwaste/attachments/20100827/bb318e6b/attachment-0001.htm


More information about the Pharmwaste mailing list