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

Smith, Charlotte csmith at pharmecology.com
Tue Nov 13 17:46:46 EST 2012


Hi Fred,

You are correct that our information would not address all the issues being discussed, including packaging emissions. And it is likely that RCRA hazardous waste will be in consumer returns, although they may not be regulated as RCRA depending on the state.

Best regards,

Charlotte A. Smith, R. Ph., M.S.
Senior Regulatory Advisor
WM Healthcare Solutions
Tel 713-725-6363
877-247-7430

Waste Management
1001 Fannin
Houston, TX 77002

Please stop and see us at Booth 1259 during ASHP 2012.


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From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Fred Miller
Sent: Tuesday, November 13, 2012 3:55 PM
To: Pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] RE: pharmaceutical incineration - air permitting exemption for portable burn units limited to "contraband"

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> [mailto:pharmwaste-bounces at lists.dep.state.fl.us]<mailto:[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<mailto: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

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<mailto: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> [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<mailto: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
www.clean-fuels.net<http://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<mailto: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<mailto: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
john.l.price at dep.state.fl.us<mailto:john.l.price at dep.state.fl.us>
www.dep.state.fl.us/waste<http://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 e-mail 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> [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<mailto: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> [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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