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

[Ed Gottlieb]

I question the utility of an incineration system that can't take any
plastics.  Our first collection included large numbers of blister packs.
 It would be totally impractical to pop the pills out of blister packs
into the barrel.  And, how would liquids that come in plastic bottles be
handled?  We took in cases of medicated IV bags and many bottles of
cough syrup.  

Regarding estimates of quantities received, we really need more data. 
I think every collection should weigh what is sent for incineration,
noting if packaging is or isn't included.  At our one day, one site
event we weighed what every car dropped off, with all packaging.  What
could be recycled was later removed leaving over 1700 pounds net for the
incinerator.  That was 22 barrels and 20 cases of IV's.



Ed Gottlieb
Pretreatment Coordinator
Ithaca Area Wastewater Treatment Facility
525 3rd Street
Ithaca, NY  14850
(607) 273-8381


>>> Stevan Gressitt <gressitt at gmail.com> 9/1/2010 9:04 AM >>>
Art thanks for this .

On Fri, Aug 27, 2010 at 2:32 PM, Vollmer, Art, NMENV <
art.vollmer at state.nm.us> wrote:

>  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
CFR60.2887(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 
>>
>> 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
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>> is communications and may therefore be subject to public
disclosure.
>>
>>
>>
>>
>> *The Department of Environmental Protection values your feedback as
a
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>> Please take a few minutes to comment on the quality of service you
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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
>>
>>
>>
>>
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>>
>
>
> --
> 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 
> 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 
> www.safemeddisposal.com/ 
>
>
>
>
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-- 
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 
www.safemeddisposal.com/