[Pharmwaste] RE: pharmaceutical incineration

[Gilliam, Allen]

Burke,

ALL of ours is currently collected at different (~50 participating LE agencies across the state twice/yr), collected & transported again to 3 or 4 more centralized collection sites where our National Guard (along with a LE agent) collects the entire trove and travels to the southern-most part of AR to a licensed TSDF, Clean Harbors.  To date, this TSDF is incinerating these UEMs free of charge as a public service.

Mileage for just a two-day take-back event?  I can only guesstimate >2,000 miles or ~$7,000+ (residential, LE & finally the National Guard, counting round trips).  But that's more than worth one child's life.

Allen g

From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy, Burke
Sent: Friday, August 10, 2012 2:12 PM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: pharmaceutical incineration

On a related note, I'm very curious where your respective state/local home-generated pharmaceutical waste goes.

Of course the Univ. of Michigan LCA<http://pubs.acs.org/doi/pdfplus/10.1021/es203987b> study circulated here last May didn't study "terminator" style emissions but it did compare trash disposal to the big diesel trucks' emissions hauling the collections to a distant regulated haz waste incinerator as Allen put it.  That LCA concluded trash disposal is more environmentally preferred.  However, the study assumed all home-generated pharmaceutical waste is sent to one of 22 hazardous waste incinerators in the U.S. and it's interesting, as Jennifer pointed out, that Minnesota for one is fortunate to have 10 WTE's available probably no more than 2.5 hours away one way.  I suspect the respective states/local governments send their home-gen pharma waste to more than just 22 hazardous waste incinerators, making it one of the bigger flaws of the LCA study.  Please share, I'm very curious.

Our (California) household hazardous waste facilities typically comingle their (relatively small amounts of) pharmaceutical waste with hazardous waste and ship it out of state for incineration but others just ship it to incinerators, which are not necessarily hazardous waste incinerators.  Our voluntary guidelines say, "Advanced arrangements shall be made with the medical or hazardous waste hauler on the fee schedule, medical or hazardous waste incineration options..." (even though this doesn't seem to envision the potential for autoclaving, which does little for pharmaceutical waste).  RCRA exempts household waste from hazardous waste regulation through consolidation.  By California standards, at best it's up to interpretation whether it's no longer considered household waste once consolidated, thus could be considered medical waste as opposed to solid waste.  From what I've been able to gather, Pennsylvania and Massachusetts require sorting out and incinerating only the home-generated pharmaceuticals that are hazardous, Colorado sends it to an approved medical waste treatment or disposal facility - "or other solid waste management program as authorized by the Department," and Rhode Island treats it as medical waste.

So, where/how does your pharma waste go?

Burke


Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov<mailto:Burke.Lucy at CalRecycle.ca.gov>
916.341.6592

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 10:29 AM
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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