[Pharmwaste] RE: pharmaceutical incineration

[Gilliam, Allen]

Ross,

I totally agree with your surmise and am not disputing this danger.  I'm unsure the danger issue has been fully disclosed to the police agencies.  They just want to destroy the contraband.

But, if there's a large number of law enforcement agencies across the U.S. already using some form of this terminator for "disposal" of contraband (which runs the gamut of illegally manufactured drugs like cocaine and meth to include the collected evidence of "pharm-parties" and from individuals carrying around prescription drugs not in their name), aren't our take back programs basically bringing in some of the same drugs that some law enforcement agencies already incinerating at their facility?

Just thinking of the holistic picture here of the negative impacts of burning our non-renewable fossil fuels to transport UEMs to take-back programs, thence to WTE units (which AR has none) or distant haz waste incinerators.

Thank you Fred, for the analogy.  It fits...

Allen g

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bunnell, Ross
Sent: Friday, August 10, 2012 1:05 PM
To: 'pharmwaste at lists.dep.state.fl.us'
Subject: [Pharmwaste] FW: pharmaceutical incineration

All humor aside, I think we need to keep in mind that there is more to consider here than air emissions and the effect that a small unit like this would have on the environment at large.

More specifically, with a unit like this, which has a stack at or close to human nose level, this is also a worker exposure issue.  While a unit like this one could probably (I say probably) destroy most pharmaceuticals to a high degree of efficiency (if operated correctly), there are other pharmaceuticals that might be resistant to thermal destruction, that might form toxic combustions products (dioxins, furans, PAHs, etc.), or that might create inorganic emissions (e.g. arsenic fume from burning arsenic trioxide).  In my opinion this is actually the more relevant and germane issue.  I'm not sure I'd like to be the junior police officer that is tasked with the job of running this thing, even if I was standing upwind.

Shipping the stuff to a trash-to-energy plant makes a lot more sense to me (no worker exposure, the combustion unit has sophisticated air pollution control equipment run by knowledgeable staff and has a tall stack, etc.).

--Ross Bunnell, CT DEEP

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[mailto:pharmwaste-bounces at lists.dep.state.fl.us]> On Behalf Of Gilliam, Allen
Sent: Friday, August 10, 2012 1:29 PM
To: Volkman, Jennifer (MPCA); Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] RE: pharmaceutical incineration

As a preeminent scientist with EPA in Las Vegas has stated (something to the affect), "We're probably doing more harm to the environment via all the combustion engine emissions being discharged from individual household vehicles to the big diesel trucks' emissions hauling the collections to a distant regulated haz waste incinerator".

Has anyone put a pencil to that comparison to the relatively small emissions from the "terminator"?

Just another fed reg where you cannot mention common sense in the same breath without creating an oxymoron, seems to me, painted road-kill raccoons et. al.

Allen g

From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[mailto:pharmwaste-bounces at lists.dep.state.fl.us]> On Behalf Of Volkman, Jennifer (MPCA)
Sent: Friday, August 10, 2012 12:05 PM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] RE: pharmaceutical incineration

In MN, they'd have to be fully permitted according to the applicable AQ standards, SW or HW, I'm not sure of the specifics. Either way, the permitting requirements make it not feasible. Enforcement would shut them down. We're fortunate to have 10 WTE's available, including a medical waste incinerator and a few that are coal/RDF plants and half of them are approved to accept household generated pharm waste. All of them could be permitted to accept it if they choose. I should check what the longest travel distance would be, probably 2.5 hours one way. Some county law enforcement entities consolidate waste between them so that they each only have to make a trip every few years.
________________________________
From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [pharmwaste-bounces at lists.dep.state.fl.us] on behalf of Fredrick L. Miller [millerfl at tricity.wsu.edu]
Sent: Friday, August 10, 2012 10:56 AM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Subject: [Pharmwaste] RE: pharmaceutical incineration
Not in Washington.  I doubt they'd ever be able to meet pollution control and permit requirements here.  They certainly would never pass muster with our actively interested and VERY vocal citizens.

>From a regulatory standpoint, how do they fit in non-attainment areas?  What's the mechanism for working with various airshed PCAs?  They're combusting MSW, at best, and depending upon the source of the materials combusted, perhaps RCRA waste.  How are those hurdles overcome and the RCRA aspect controlled for?  I'm very curious as I've had people in states outside Washington propose similar operations and I've always advised against it on regulatory (pain) grounds.  If you've found a wrinkle in the CAA that allows for reasonable size burners that can meet all those regulatory challenges I'd be most grateful to see what you've got.

Fred


From: pharmwaste-bounces at lists.dep.state.fl.us<mailto:pharmwaste-bounces at lists.dep.state.fl.us> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[mailto:pharmwaste-bounces at lists.dep.state.fl.us]> On Behalf Of Hoffman, Deb
Sent: Friday, August 10, 2012 5:39 AM
To: Pharmwaste at lists.dep.state.fl.us<mailto:Pharmwaste at lists.dep.state.fl.us>
Cc: midwestpsc at googlegroups.com<mailto:midwestpsc at googlegroups.com>
Subject: [Pharmwaste] pharmaceutical incineration

Greetings,

Here in Ohio, we're discussing the usage of the portable incinerators, from an air pollution standpoint.  I've been working with a colleague in the Ohio EPA Division of Air Pollution Control.  I'd like to know if anyone is aware of any recent research on the effectiveness of portable incinerators, or if they are being used in other states.  And if you would like to share incineration options in your state, I would be interested in hearing them.

Thank you,
Deb


Deb Hoffman
Environmental Specialist
Division of Materials and Waste Management
Ohio EPA
614.728.5353


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