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

Volkman, Jennifer (MPCA) Jennifer.Volkman at state.mn.us
Wed Sep 1 19:44:36 EDT 2010


In the Midwest, it looks like disposal varies state-to-state, but there is some coordination going on between states where the logistics make sense.  In MN they are working with one of our statewide disposal contractors for the non-CS and the pharms from all of the MN events will go the same end facility.  I believe there are 11 events scheduled in 6 counties.  The CS is likely going a different route, but we are still working like crazy to get it all set up.  DEA is paying for disposal for these events if the participating counties use their contractor.  There is not enough time to set up multiple contractors, it was just simpler this way.  There may be other counties doing events to take advantage of the advertising, but I think they are on their own for disposal, and they may choose different disposal options.

DEA here has been very good to work with, probably because we had already established a good working relationship.  They have made modifications to the standard protocol issued by HQ to allow more flexibility in how pharms are managed on-site to help with event logistics/traffic flow and to accommodate local sheriff's policies on possession.  A lot has happened in the past 2 weeks to give me hope that we all (DEA, County sheriff, County HHW, HW contractors, MPCA) will be able to pull this off with only minor upsets, if any.  The amount of time invested by each partner to get to this point has been enormous.  I am not sure how other states are managing to do this.  Good luck to us all!

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: Wednesday, September 01, 2010 12:16 PM
To: Bunnell, Ross; pharmwaste at lists.dep.state.fl.us
Cc: Goodyear, Richard, NMENV
Subject: RE: [Pharmwaste] RE: National take-back program - what kind ofincinerators?

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<mailto: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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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.

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