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

Wed Sep 1 13:15:38 EDT 2010

I can't take any credit for the air analysis of the portable drug
incinerators; that goes to Richard Goodyear of NMED's Air Quality
Bureau.  I'm just a hazardous waste guy.  Contact Richard (
richard.goodyear at state.nm.us ) if you have any technical questions
regarding his analysis.

Does anyone know if there is a coordinated plan for disposing of all the
drugs to be collected during the National Take-Back Day later this
month?   Is DEA collecting them all or will each community dispose of
them as they see fit?

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 Bunnell,
Ross
Sent: Wednesday, September 01, 2010 8:32 AM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: FW: [Pharmwaste] RE: National take-back program - what kind
ofincinerators?

I have no doubt now (especially after Art's fine analysis) that portable
incinerator units would not qualify as major sources.  However, I think
it is also relevant to look at worker exposure issues, here.  Contrast
these units to, say, a trash-to-energy plant.  The trash-to-energy
plant's emissions are much larger, but this kind of plant also
(typically) has a tall stack, a buffer zone to the property line, and
must meet certain air emissions standards at the property line, all of
which serve to prevent human exposure to pollutants that may be in the
emissions.  The portable units, on the other hand, are (more or less) at
ground level, in the immediate vicinity of the workers that are
operating them and anyone else that may be hanging around (perhaps
pregnant moms and children at an event where they are "roasted" on the
same day their collected - hey, kids, bring yer marshmaller stix!).

All kidding aside, I'd be more interested in worker exposure type
monitoring of these units - e.g., whether they exceed any OSHA PELs or
ACGIH TLVs when used to destroy pharmaceuticals.

--Ross Bunnell, Sanitary Engineer 3

CT Department of Environmental Protection (DEP)

Bureau of Materials Management and Compliance Assurance

Waste Engineering & Enforcement Division

Tel.  860.424.3274

Fax  860.424.4059

ross.bunnell at ct.gov

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Vollmer,
Art, NMENV
Sent: Friday, August 27, 2010 2:33 PM
To: pharmwaste
Subject: RE: [Pharmwaste] RE: National take-back program - what kind
ofincinerators?

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 

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