[Pharmwaste] RE: pharmaceutical incineration - air permitting exemption for portable burn units limited to "contraband"

Tue Nov 13 16:55:03 EST 2012

Elizabeth, et al

The closest thing to a comprehensive list is a product pioneered by
Charlotte Smith.  It's part of a commercial product/service that I don't
believe is available without cost.  In any case, the last version of it I
saw only addressed the RCRA aspects of waste designation.  While it can help
exclude hazardous waste from the mix it does not address the other emissions
influencing factors which can lead to out of compliance situations.  Note
the need for trained operators.  Unless the operator is trained to handle
feed rate/configuration correctly the unit has little hope of meeting
permitted conditions.  I believe the way the permit is written it excludes
packaging and pills containing inert solids (ash <1%).  If, and that's a
mighty big "if" the company operates these things the way they're permitted,
it's going to be a very sloppy and labor intensive job.  I don't see a
functional liquid feed system, do you?  It looks like liquids would have to
be poured into the open combustion chamber.  At that point what's the
difference between one of these things and a burn pit?

Fred

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Bartlett,
Elizabeth
Sent: Tuesday, November 13, 2012 1:27 PM
To: 'Barry Fernandez'; Price, John L. "Jack"; 'Lucy, Burke';
Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: RE: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

I used to work in hazardous waste combustor permitting in a past life, so I
decided to take a quick look at the permit for this unit.

The original construction permit was issued in January 2012 for the Drug
Terminator and the MediBurn 20, but was later modified in August 2012 to
change the manufacturer/unit to the: SuperNova "ELIMINATOR", Incinerator -
Model No. SN500 - ( Small, Portable "OSWI") With this change, they added
diesel and propane as fuel sources (was originally just wood and charcoal).

OSWI = Other Solid Waste Incinerator regulated under 40 CFR 60, Subpart
EEEE.

I dug around a little bit more to see if there were any emission test
results and found the compliance page that has links to both the original
and modified permits:
<http://appprod.dep.state.fl.us/air/emission/aces/ACES_facility.asp?txtFacID
=9597>
http://appprod.dep.state.fl.us/air/emission/aces/ACES_facility.asp?txtFacID=
9597

The permit limits annual operating hours, and there is also a restriction
that the unit cannot be used to treat medical waste or hazardous waste.
Initial emissions testing must be conducted within 180 days of initial
operation with annual retesting.  They are required to test for metals,
particulate, dioxins/furans, NOx and SOx, HCl and opacity.  It is my
understanding that stack testing can be fairly expensive.

They are required to maintain records of the type and quantities of material
product burned in the unit, but I don't know how detailed the inventory
would need to be.  In reading this, I was wondering whether there was a
comprehensive list of pharmaceuticals that could assist operators in
determining/verifying that they are not burning medical or hazardous wastes.

Just some thoughts.

Elizabeth Bartlett, Engineer IV

Program & Technical Support Section

Bureau of Waste Cleanup

Florida Department of Environmental Protection

2600 Blair Stone Rd, MS 4535

Tallahassee, FL  32399-2400

850-245-7501

elizabeth.bartlett at dep.state.fl.us

Program and Technical Support website:
http://www.dep.state.fl.us/waste/categories/wc/pages/ProgramTechnicalSupport
.htm 

Interstate Technical and Regulatory Council website: itrcweb.org

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Barry
Fernandez
Sent: Tuesday, November 13, 2012 3:34 PM
To: Price, John L. "Jack"; 'Lucy, Burke'; Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: RE: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

Hello All:

If you go to the following link:
http://appprod.dep.state.fl.us/air/emission/apds/default.asp  and do a
search by permit no. for: 7775707-001-AC you will have the option of
downloading a Florida air permit issued for both the Drug Terminator and
it's smaller, 55-gallon cousin "MediBurn20". Basically it allows for the
portable incineration of small quantities of pharmaceuticals. I don't think
it defines what a small quantity is, nor do I think it addresses RCRA
hazardous vs non-haz. The permit in question doesn't mention any generator
limitations (i.e.: contraband from law enforcement, take-back events, etc.).
I had the opportunity to see the larger incinerator, though I did not see it
in operation. I think I have some pictures if interested.

I have no affiliation, just sharing the info. I hope it helps.

Best Regards,

Barry Fernandez, President

Clean Fuels of Florida, Inc.
2635 NE 4th Avenue
Pompano Beach, FL 33064

Office: (954) 791-9588

 <http://www.clean-fuels.net/> www.clean-fuels.net 

From: Price, John L. "Jack" [mailto:John.L.Price at dep.state.fl.us] 
Sent: Tuesday, November 13, 2012 10:26 AM
To: 'Lucy, Burke'; Pharmwaste at lists.dep.state.fl.us
Cc: George, Larry; Perrigan, Glen
Subject: [Pharmwaste] RE: pharmaceutical incineration - air permitting
exemption for portable burn units limited to "contraband"

Burke: Our RCRA group received this email and attached Determination memo
from EPA regarding the use of portable burn units for the disposal of
pharmaceuticals collected at community and other take-back collection
events.  There is a federal exemption from air permitting for these units
for destroying "contraband".  However, according to EPA, that exemption does
not apply when burning drugs from take-back events.  In Florida, it appears
that some law enforcement agencies that use these units are not aware that
the air permitting exemption is limited to contraband.  We are going to
provide this clarifying information to our law enforcement agencies.

BEGIN EPA EMAIL (note: cc list deleted)

From: Kristin Fitzgerald [mailto:Fitzgerald.Kristin at epamail.epa.gov] 
Sent: Wednesday, October 03, 2012 2:55 PM
To: Chabot, Patricia M - DNR
Cc: 
Subject: RE: Agenda Items for today's RIN Call - Pharmaceutical Burning;
Followup from MN

Here is the letter Region 6 Applicability Determination memo that Charlene
Spells mentioned on the call today. In addition to the memo I sent earlier,
this memo points out that the "contraband exemption" for law enforcement
burning drugs is only for contraband drugs and that drugs collected during
take-back events are NOT contraband. Also she suggested I include her
contact info, in case anyone wants to follow up with her:

Charlene E. Spells
U.S. EPA
OAQPS/SPPD 
RTP, NC 27711
Phone: (919) 541-5255 Fax: (919) 541-3470
spells.charlene at epa.gov

thanks,
Kristin

(See attached file: 6-30-11 AMP ADEQ EEEE Final.pdf)

**************************************************************
Kristin Fitzgerald
US EPA
Office of Resource Conservation and Recovery 
(formerly Office of Solid Waste)
mail code: 5304P
phone: 703-308-8286
fax: 703-308-0522

END EPA EMAIL

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

 <mailto:john.l.price at dep.state.fl.us> john.l.price at dep.state.fl.us

 <http://www.dep.state.fl.us/waste> 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
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is communications and may therefore be subject to public disclosure.

Please take a few minutes to share your comments on the service you received
from the department by clicking on this link DEP Customer Survey
<http://survey.dep.state.fl.us/?refemail=John.L.Price@dep.state.fl.us> .

From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy, Burke
Sent: Tuesday, November 13, 2012 9:37 AM
To: Pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] RE: pharmaceutical incineration

Re: 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.

Local Charity Purchases Drug Disposal Device

http://www.wbko.com/news/headlines/Local-Charity--178122731.html

The Save Our Kids Coalition of Bowling Green has purchased a "Drug
Terminator", which will provide Kentucky State Police with a way to dispose
of the prescription medication they receive from a very successful program.

Burke

From: pharmwaste-bounces at lists.dep.state.fl.us
[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
Cc: 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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