United States Office of Air Quality EPA-450/4-89-002
Environmental Protection Planning and Standards Jamiarv iQSQ
Agency Research Triangle Park. NC 27711 January 1989
Air
PROCEEDINGS:
NATIONAL WORKSHOPS ON
HOSPITAL WASTE INCINERATION
AND HOSPITAL STERILIZATION
SAN FRANCISCO BALTIMORE
MAY 10-12,1988 MAY 24-26,1988
SPONSORED BY:
STAPPA/ ALAPCO
U.S.EPA
NESCAUM
CAPCOA
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PROCEEDINGS
HOSPITAL WASTE INCINERATION AND HOSPITAL
STERILIZATION WORKSHOPS
Sponsors:
California Air Pollution Control Officers Association
Northeast States for Coordinated Air Use Management
State and Territorial Air Pollution Program Administrators/
Association of Local Air Pollution Control Officials
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
May 10.-12, 1988
Golden Gateway Holiday Inn
San Francisco, CA
May 24-26, 1988
Hotel Belvedere
Baltimore/ MD
U.S. Environmental Prelection Agency
Region 5,Library (Fl-^;-
77 West Jackson £(.:•': . _i
Chicago, IL 6CSCM•:. .-..>'
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This report has been reviewed by the Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, and has been
approved for publication as received from the contractor. Approval
does not signify that the contents nescessarily reflect the views
of the Agency, neither does mention of trade names or commercial
products constitute endorsement or recommendation for use.
EPA-450/4-89-002
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PROCEEDINGS
HOSPITAL WASTE INCINERATION AND HOSPITAL
STERILIZATION WORKSHOPS
Sponsors:
California Air Pollution Control Officers Association
3232 Western Drive, Cameron Park, California 95682
Stewart J. Wilson, Executive Secretary
Northeast States for Coordinated Air Use Management
85 Merrimac Street, Boston, Massachusetts 02114
Michael J. Bradley, Executive Director
Nancy L. Seidman, Special Projects Director
Catherine Fedorsky, Training Coordinator
David A. Ernst (Jason M. Corte.ll and Associates Inc.)/ Editor
State and Territorial Air Pollution Program Administrators/
Association of Local Air Pollution Control Officials
444 N. Capitol Street NW, Washington, DC 20001
S. William Becker, Executive Director
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
David Painter, Project Coordinator
May 10-12, 1988
Golden Gateway Holiday Inn
San Francisco, CA
May 24-26, 1988
Hotel Belvedere
Baltimore, MD
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PUBLICATION POLICY
These Proceedings contain technical papers and discussions
published mostly as they were presented at the CAPCOA/NESCAUM/
STAPPA/ALAPCO/USEPA Hospital Waste Incineration and Hospital
Sterilization Workshops. The opinions expressed herein are not
necessarily the official positions of the organizations with
which the authors are associated, nor do the opinions expressed
herein necessarily have the endorsement or support of CAPCOA,
NESCAUM, STAPPA/ALAPCO, or USEPA.
Papers and discussions appearing in these Proceedings may be
reproduced provided that proper credit i-s given to the
author(s) and to CAPCOA, NESCAUM, STAPPA/ALAPCO, and USEPA.
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PROCEEDINGS OF THE HOSPITAL WASTE INCINERATION AND HOSPITAL
STERILIZATION WORKSHOPS
EXECUTIVE SUMMARY
INTRODUCTION
Public agencies responsible for regulating waste disposal are devoting
increasing attention to hospital waste incineration. Generation of hospital
waste is increasing with growth in the health care industry as well as new
developments in medical technology. Although modem controlled-air
techniques allow efficient air pollution control, many older incinerators are
still in use. Because of a lack of controls and poor dispersion characteristics
from the stack, many hospital incinerators may be high risk point sources.
Hospital waste incineration is one aspect of solid waste management. Many
states have only recently begun to inventory hospital waste incinerators and
issue permits. Agencies are approaching hospital waste incineration using
experience gained in the regulation of municipal waste combustion and, in
some cases, hazardous waste management. The evaluation of hospital waste
incineration facilities brings together complex issues of technological
capability, economic and political feasibility, public opinion, risk assessment,
and environmental impact.
These Proceedings are the product of twin workshops on hospital waste
incineration held on May 10-12, 1988 in San Francisco, California, and May
24-26, 1988 in Baltimore, Maryland. The workshop sponsors were California
Air Pollution Control Officers Association, Northeast States for Coordinated
Air Use Management, State and Territorial Air Pollution Program
Administrators/ Association of Local Air Pollution Control Officials, and the
U.S. Environmental Protection Agency Office of Air Quality Planning and
Standards. More than 130 representatives of 82 government agencies and 10
private organizations in the United States and Canada, with jurisdictions in 35
states and provinces, attended one or both workshops.
The primary goals of the workshops were to present the most advanced
research and policies on hospital waste incineration being pursued in the
regulatory sector, encourage the formation of networks among those involved,
and improve permitting and enforcement through exchange of information.
Hospital waste sterilization was also included because it is a related source of
increasing regulatory concern. The structure of the workshops was designed
for maximum interaction among the participants. From these discussions
emerged several themes for future action involving research needs,
approaches to waste management, and permitting policies.
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WORKSHOP SESSIONS
The workshop sessions on the first day were devoted to defining the problem
and discussing technological solutions. On the second day the sessions
discussed policy issues and evolving regulatory requirements.
The workshop sessions included six main topics:
Manufacturers' Panel Discussion
Source Data and Stack Testing
Topics of Special Concern
Agency Permitting Experiences
Agency Regulations and Guidelines
Hospital Sterilizers
In the Manufacturers' Panel Discussion, panelists outlined the historical
development, design, and costs of hospital incinerators and their air pollution
control systems. The importance of the "three T's" — retention time and
temperature in the secondary chamber, and combustion turbulence — in
minimizing emissions has been established. These parameters are especially
important for small (less than 10,000 cfm) incinerators.
Panelists identified the major cause of high emissions as poor operating
practices rather than technological inadequacy. Poor operation may also
cause incomplete burnout. Participants identified needs for consistent
regulations and for operator training. Several participants stated that
operator training is important to include as a permit requirement. Further
development of training and testing procedures is needed.
Representatives of four jurisdictions presented the second main topic, Source
Data and Stack Testing. They provided an overview of emissions data, how
testing is conducted, and results of recent surveys. Stack testing is extremely
costly. Participants discussed the effectiveness of design requirements and
combustion guarantees as alternatives to extensive compliance testing.
Participants also expressed concern that control of emissions of metals may
be poor.
A similar discussion took place regarding the value of continuous emission
monitoring (GEM). The costs of GEM systems are prohibitive for small units.
Facilities with good operating practices and basic instrumentation (e.g.
continuous temperature monitoring) may not need GEM. Agencies should
decide in advance how GEM data will be used, and should provide guidelines on
GEM requirements and operation. Practical GEM systems are available for
many pollutants including opacity, but not yet for HC1.
The third session examined Topics of Special Concern, including pathogen
survival, risk assessments, and regional facilities. Destruction of pathogens
requires a higher temperature than does other waste. Tests have detected no
pathogens at the stack, but the question of survival of spores is unresolved.
iv
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Another unresolved issue is the regulation of infectious waste when it is mixed
with other waste. For example, pathogens can originate not only from
hospitals, but also at clinics, dental offices, and the like, and enter the
municipal waste stream. Public protest is likely at the slightest hint of risk
from pathogens.
The issue of regional versus local facilities engendered much discussion but no
decision. Regional incinerators can offer lower disposal costs due to
economies of scale, but may entail higher waste transportation costs.
Forthcoming state regulations will likely favor regional facilities. The costs
of control equipment and CEM will also encourage the use of regional
facilities. However, if existing incinerators (especially small units) are phased
out, and fees at regional facilities are high, illegal dumping of waste could
increase.
Also discussed were the regulation of acid gases, toxic substances and criteria
pollutants, and mechanisms of dioxin formation.
The next two topics, Agency Permitting Experiences and Agency Regulations
and Guidelines, were significant in meeting the primary goals of the
workshops. Precedents for permits and policy decisions are evolving as
agencies struggle to develop rules from case-by-case permitting experiences.
Agencies differ widely in their current practices for reviewing permit
applications. An agency may consider many conditions in its permits. These
include the following areas mentioned by workshop participants.
1. Requirements for risk assessment
2. Requirements for dispersion modeling
3. Opportunities for source separation
4. Requirements for waste packaging and transportation
5. Choice of substances to regulate
6. Possible "special waste" status for biomedical waste
7. Combustion controls
8. Requirements for operator training and certification
9. Requirements for stack testing
10. Requirements for CEM
Other topics discussed in the session on Agency Permitting Experiences
included waste handling and ash disposal. Prospects for containerization
systems are uncertain at present. Source separation schemes offer benefits in
theory, but can be difficult and costly to implement. Some agencies are
considering designation of biomedical waste as a "special waste" with
requirements stricter than for those municipal waste, but more lenient than
the requirements for hazardous waste.
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Canadian agencies are working toward a National Code of Practice on the
Management of Biomedical Wastes. This effort will take about two years. The
Code will specify practices for transportation and ultimate disposal of
biomedical wastes, ensuring the destruction of pathogens, and technical
control requirements (e.g. acid gas scrubbing will probably be required).
Canadian agencies are seriously considering regional facilities.
Environment Canada is in the first phase of an optimization testing program
on a large regional incinerator. The tests will differ from compliance testing
in that combustion conditions will be varied to define operating conditions
that minimize pollutant emissions. Guidelines for handling and disposal of
biomedical waste, issued by the Ontario Ministry of the Environment, were
also presented and are included in the Proceedings.
This session led into the next topic, Agency Regulations and Guidelines, which
examined regulatory strategies in the United States. The presenters examined
possible regulatory approaches, some already being implemented, in addition
to the topics of the previous session. These included the regulation of small
facilities which cannot afford to install state-of-the-art controls. Some
states exempt small facilities. Retrofit requirements are expected to force
small facilities to close. Fewer, larger facilities would require fewer agency
resources to regulate than a larger number of smaller units.
In small group discussions, participants evaluated case studies of hospital
waste incinerator permitting. The small groups also discussed a
comprehensive model rule, which is included in the Proceedings. While the
workshops did not formally endorse the model rule, many of the concepts
discussed received widespread support. Specific requirements in a rule might
include the items listed above as possible permit conditions.
Because knowledge of the air pollution and health impacts of hospital
sterilizers is much less developed than for incinerators, agencies which have
had experience with sterilizers presented information on how to regulate and
permit these facilities. Hospital sterilizers typically use ethylene oxide (EtO),
a highly toxic gas, to sterilize reuseable materials and supplies. This process
entails occupational risks. OSHA regulations require exposure monitoring,
employee training, medical surveillance, communication of EtO hazards to
employees, and precautions for safe handling and storage of EtO. Hospitals
usually control occupational exposure by venting, which converts the problem
into one of ambient exposure. Panelists reviewed recent permit decisions that
will require emission controls for EtO sterilizers.
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IONS FOR FUTURE EFFORTS
One purpose of the workshops was to identify important topics and trends in
order to assist agencies in focusing their resources for the next few years.
These future directions are grouped below under three headings: Technical
Problems (areas requiring scientific research and development), Approaches to
Waste Management (program development and management for the overall
solid waste problem), and Regulatory Policies (improvements in permitting
and enforcement).
Technical Problems
• Waste constituents
Develop procedures to determine composition and variability of
waste in a cost-effective manner.
Determine the sources of Cl, metals, and pathogens.
• Combustion
Improve understanding of combustion and its relationship to design
parameters.
Improve understanding of mechanisms of dioxin formation.
Improve understanding of pathogen survival.
• Ash
Improve and standardize testing methods.
Devise and evaluate disposal alternatives.
• Monitoring
Develop HC1 monitoring technology.
Reduce costs of GEM.
• Risk assessment
Refine and standardize assumptions and procedures.
Improve knowledge of toxicity levels.
Improve methods for analyzing multiple exposure pathways.
Develop national guidance on acceptable risks and ambient levels
for HC1.
Approaches to Waste Management
• Introduce/improve operator training and certification
• Improve the practicality of source reduction/source separation.
• Continue the investigation of alternatives for ash disposal.
• Improve the evaluation of risks and benefits of regional facilities versus
onsite incineration.
• Improve education of the public on relative risks and benefits of all
disposal alternatives.
Regulatory Policies
• Establish testing and monitoring requirements to optimize gathering of
meaningful data versus cost.
• Establish combustion, stack, and control device requirements that
encourage good design and operation; discourage reliance on numerical
parameters alone.
• Assess the impacts of small facilities, and assess alternatives for
disposal of their waste streams.
• Include operator training requirements as permit conditions.
• Coordinate air quality and solid waste permitting and evaluation.
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Vlll
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PROCEEDINGS OF THE HOSPITAL WASTE INCINERATION AND HOSPITAL
STERILIZATION WORKSHOPS
TABLE OF CONTENTS
Executive Summary ill
Table of Contents vii
Workshop Agenda (San Francisco) 1
Workshop Agenda (Baltimore) 4
Session I: Overview of the Problem
Summary of Discussion (San Francisco) 9
Summary of Discussion (Baltimore) 10
Session II: Manufacturers' Panel Discussion
Development of Controlled Air, Factory Packaged
Incineration Tech.xology in USA Gene White 13
Controlled Air Incineration for
Biohazardous Waste: "Technology and
Regulatory Economic Impacts" Steve Shuler 21
Summary of Discussion (San Francisco) 41
Summary of Discussion (Baltimore) 43
Session III: Source Data and Stack Testing
Measurement of Source Emissions P. K. Leung 49
Source Data and Stack Testing
in California Gary M. Yee 57
Hospital Incineration Testing
in New York State Robert Waterfall 69
Biomedical Waste Incinerator Programs
in Ontario Vlado Ozvacic 73
Summary of Discussion (San Francisco) 87
Summary of Discussion (Baltimore) 89
iz
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Session IV: Topics of Special Concern — Pathogen Survival,
Risk Assessments, and Regional Facilities
Potential Risk Posed by Hospital
Incinerators in New Jersey... Joann Held 93
Pathogen Survival at Hospital/Infectious
Waste Incinerators . Mike Tierney 101
Hospital Waste Management in Canada.... David Campbell 115
Summary of Discussion (San Francisco) 139
Summary of Discussion (Baltimore) 140
Session V: Agency Permitting Experiences
Presentation of Emission Data and
Description of Air Quality Impacts
from Hospital Incinerators . Lynn Fiedler 145
Permitting New Hospital Waste Incinerators
in Michigan Randal Telesz 153
Chattanooga-Hamilton County
Permitting Experience J. Wayne Cropp 169
Maryland's Permitting Experience Tad Aburn 179
Summary of Discussion (San Francisco) 187
Summary of Discussion (Baltimore) 190
Session VI: Agency Regulations and Guidelines
Hospital Waste Incineration:
a New York State Perspective Wallace Sonntag 195
Hospital/Infectious Waste Management.... Jim Salvaggio 209
Guidelines for the Handling and Disposal
of Biomedical Wastes from Health Care
Facilities and Laboratories John Manuel 241
Summary of Discussion (San Francisco) 261
Summary of Discussion (Baltimore) 265
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Session VII: Discussion Groups - Case Examples
Hypothetical Model Rule and
Suggestions for Discussion Group Leaders 269
Case I: Health Spot Hospital 271
Case II: Mercy Hospital 283
Case III: Three Example Permits 289
Discussion Leader's Report
(San Francisco) Lynn Fiedler 295
Discussion Leader's Report
(San Francisco) Nancy Seidmari 296
Discussion Leader's Report
(San Francisco) Wallace Sonntag 297
Discussion Leader's Report
(San Francisco) Joann Held 297
Discussion Leader's Report
(Baltimore) Chris James 299
Discussion Leader's Report
(Baltimore) Randal Telesz 300
Discussion Leader's Report
(Baltimore) David Painter 301
Discussion Leader's Report
(Baltimore) Wallace Sonntag 302
Summary of Discussion (San Francisco) 303
Summary of Discussion (Baltimore) ; 305
Session VIII: Hospital Sterilizers - Nature of the
Problem and State Permitting Experience
OSHA Regulations Regarding
Ethylene Oxide Elizabeth Gross 313
Use of Ethylene Oxide by Hospital Sterilizers
in the San Francisco Bay Area Tim Smith 317
St. Luke's Hospital Ethylene Oxide Sterilizer:
A Case Study Danita Brandt 323
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Permitting of Ethylene Oxide Sterilizer
at St. Luke's Hospital Randal Telesz 327
Atmospheric Persistence of
Eight Air Toxics Darrell Graziani 335
Summary of Discussion (San Francisco) .« 345
«
Summary of Discussion (Baltimore) 347
Session IX: Wrap-up
Summary of Discussion (San Francisco) 351
Summary of Discussion (Baltimore) 353
Attendance List (San Francisco) 356
Attendance List (Baltimore) 361
xii
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AGENDA
HOSPITAL INFECTIOUS WASTE INCINERATION AND
HOSPITAL STERILIZATION WORKSHOP
MAY 10-12, 1988
GOLDEN GATEWAY HOLIDAY INN
SAN FRANCISCO, CA
SPONSORS:
California Air Pollution Control Officers Association (CAPCOA)
State and Territorial Air Pollution Program Administrators/
Association of Local Air Pollution Control Officials
(STAPPA/ALAPCO)
U.S. Environmental Protection Agency (EPA)
Hay 10: Nature of Hospital/Infectious
Waste Incineration Problem
7:30-8:30 REGISTRATION
Moderator; Wayne Cropp, Chattanooga APC
8:30 Opening Remarks
Dave Howekamp - EPA Region IX
Milt Feldstein - Bay Area AQMD
8:45 Overview of the Problem
David Painter - US EPA OAQPS
Anders Carlson - New York DOH
Lloyd Yandell - Kaiser Hospital, San Francisco
10:00 BREAK
10:15 Manufacturers' Panel Discussion
Steve Shuler - Ecolaire Corporation
Bob Lee - Consumat Systems Inc.
James Kidd - Cleaver Brooks
Noon LUNCH
Moderator: Mike Trutna, EPA OAQPS
1:00 - Source Data and Stack Testing
P.K. Leung - Environment Canada
Gary Yee - California ARB
Bob Waterfall - New York DEC
Vlado Ozvacic - Ontario Ministry of Environment
2:30 BREAK
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2:45 - Topics of Special Concern - Pathogen Survival,
Risk Assessments, Regional Facilities
Joann Held - New Jersey DEP
Mike Tierney - Wisconsin DNR
Dave Campbell - Environment Canada
4:00 - Open Discussion
Moderator; Mike Trutna, EPA OAQPS
5:00 ADJOURN
May 11: Hospital/Infectious Waste
Incineration Regulatory Experiences
Moderator; Don Ames/ California AMB
8:00 - Agency Permitting Experiences
Lynn Fiedler - Michigan DNR
Wayne Cropp - Chattanooga APC
Jim Salovich - Bay Area AQMD
George Aburn - Maryland Air Mgmt. Adm.
10:15 BREAK
10:30 - Agency Regulations and Guidelines
Wally Sonntag - New York DEC
Jim Salvaggio - Pennsylvania DER
Dan Speer - San Diego AQMD
John Manuel - Ontario Ministry of the Environment
12:30 LUNCH BREAK
Moderator: Wayne Cropp, Chattanooga APC
1:30 - Discussion Groups - Case Examples
Discussion Leaders - Lynn Fiedler, Joann Held,
Wallace Sonntag, Nancy Seidman
3:00 BREAK
3:15 - Discussion leaders report on their groups
3:45 - Open Discussion
5:00 ADJOURN
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May 12: Hospital Sterilizers and Site Visit
Moderator: David Painter/ EPA OAQPS
8:00 - Nature of the Problem
David Painter - EPA OAQPS
Elizabeth Gross - Dana-Farber Cancer Institute
Tim Smith - Bay Area AQMD
9:00 - State Permitting Experiences
Eric Wade - New York DEC
Danita Brandt - Michigan DNR
Darrell Graziani - Hillsborough County (Florida) APC
10:30 BREAK
10:45 - Open Discussion
11:15 - Wrap-up
11:30 LUNCH BREAK
12:15-3:30 Stanford University Hospital Site Visit
3:30 ADJOURN
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AGENDA
HOSPITAL INFECTIOUS WASTE INCINERATION AND
HOSPITAL STERILIZATION WORKSHOP
MAY 24-26, 1988
HOTEL BELVEDERE
BALTIMORE, MD
SPONSORS:
Northeast States for Coordinated Air Use Management (NESCAUM)
State and Territorial Air Pollution Program Administrators/
Association of Local Air Pollution Control Officials
(STAPPA/ALAPCO)
U.S. Environmental Protection Agency (EPA)
May 24: Nature of Hospital/Infectious
Waste Incineration Problem
7:30-8:30 REGISTRATION
Moderator; Michael Bradley, NESCAUM
8:30 Opening Remarks
Jesse Baskerville - US EPA Region III
Michael Bradley - NESCAUM
8:45 Overview of the Problem
David Painter - US EPA OAQPS
Ray Morrison - US EPA OAQPS
Anders Carlson - New York DOH
Leland Cooley - University Hospital, Baltimore City
10:00 BREAK
10:15 Manufacturers' Panel Discussion
Steve Shuler - Ecolaire Corporation
Jeff Gray - Consumat Systems Inc.
James Kidd - Cleaver Brooks
Noon LUNCH
Moderator: Mike Trutna, EPA OAQPS
1:00 - Source Data and Stack Testing
P.K. Leung - Environment Canada
Gary Yee - California ARE
Bob Waterfall - New York DEC
Vlado Ozvacic - Ontario Ministry of Environment
2:30 BREAK
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2:45 - Topics of Special Concern - Pathogen Survival,
Risk Assessments, Regional Facilities
Joann Held - New Jersey DEP
Steve Klafka - Wisconsin DNR
Dave Campbell - Environment Canada
4:00 - Open Discussion
Moderator: Mike Trutna
5:00 ADJOURN
May 25: Hospital/Infectious Waste
Incineration Regulatory Experiences
Moderator: George Ferreri, Maryland Air Mgmt. Adm.
8:00 - Agency Permitting Experiences
Randy Telesz - Michigan DNR
Jim Weyler - Chattanooga APC
Tim Smith - Bay Area AQMD
Tad Aburn - Maryland Air Mgmt. Adm.
10:15 BREAK
Moderator: Chris James, Rhode Island DEM
10:30 - Agency Regulations and Guidelines
Wally Sonntag - New York DEC
Jim Salvaggio - Pennsylvania DER
Robert Pease - South Coast AQMD
John Manuel - Ontario Ministry of the Environment
12:30 LUNCH BREAK
Moderator: Michael Bradley, NESCAUM
1:30 - Discussion Groups - Case Examples
Discussion Leaders - Randy Telesz, Wally Sonntag,
David Painter, Chris James
3:00 BREAK
3:15 - Discussion leaders report on their groups
3:45 - Open Discussion
5:00 ADJOURN
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May 26: Hospital Sterilizers
and Site Visit
Moderator: David Painter, EPA OAQPS
8:00 - Nature of the Problem
David Painter - EPA OAQPS
Elizabeth Gross - Dana-Farber Cancer Institute
Tim Smith - Bay Area AQMD
9:00 - State Permitting Experiences
Eric Wade - New York DEC
Randy Telesz - Michigan DNR
Darrell Graziani - Hillsborough County (Florida) APC
10:30 BREAK
10:45 - Open Discussion
11:15 - Wrap-up
11:30 LUNCH BREAK
12:30-3:30 Johns Hopkins University Site Visit
3:30 ADJOURN
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SESSION I
OVERVIEW OF THE PROBLEM
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SESSION I: OVERVIEW OF THE PROBLEM
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: What is the status of regional incineration in New York? Is there
pressure from upstate hospitals to have regional incinerators?
A: (A. Carlson, NY DOH) There is state legislation to consider regional
management of waste as part of the overall state plan. The options
include using current municipal waste combustion facilities, having a
consortia of participating hospitals, or letting hospitals build their own
incinerators. No hospital is being forced to look into only one option.
Q: Please describe "universal precautions." Everything in some hospitals is
being handled as infectious waste.
A: (L. Yandell, Kaiser Hospital, San Francisco, CA) The intent of
universal precautions is risk management and liability reduction. Under
CDC guidelines, everything in contact or indirect contact with
something that had contact with a patient will be handled and
transported as infectious waste or hazardous waste. It is the cheapest
long-range risk management program.
Q: What is the total volume of waste you are experiencing at Kaiser
Hospital (San Francisco)?
A: (L. Yandell, Kaiser Hospital, San Francisco, CA) At clinics the figures
come out to about 7 pounds per patient visit and at hospitals 21-23
pounds per bed site. This does not include specialties like CD surgery
which may add another 9 pounds or more.
Q: Are the figures represented just for hospitals?
A: (A. Carlson, NY DOH) Yes. The New York survey only included
hospitals. It does not include veterinarians, free-standing family
practices, and some elderly housing.
A: (L. Yandell, Kaiser Hospital, San Francisco, CA) Patients are being
sent home earlier than in past years. Wastes that used to be generated
only at hospitals may appear in residential waste. In 1989 a Joint
Commission will look at the impact of home care on medical waste in
San Francisco.
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SESSION I: OVERVIEW OF THE PROBLEM
SUMMARY OF DISCUSSION (BALTIMORE)
Q: Many early incinerators had short (e.g. 30 ft) stacks; modern ones have
stacks 85 ft or higher. What is the effect of stack height on risk
assessment results?
A: (O. Painter, EPA) No definitive answer is available yet. EPA is
examining data on the impact of various stack heights.
Q: Was autoclaved waste compacted? If not, would compaction help solve
problems of waste storage and handling?
A: (L. Cooley, University Hospital, Baltimore, MD) General waste was not
compacted until after autoclaving. This would not solve the basic
problem which is that objects remain recognizable in the waste after
autoclaving. Municipal incinerator operators are sensitive to public
protest and often refuse to accept waste with recognizable medical
objects, even if they do not suspect contamination from the hospital.
Q: What is the status of EPA efforts to improve operator training?
A: (D. Painter, EPA) EPA is organizing a course, to be conducted by a
contractor, in cooperation with the State of Maryland. This effort has
only just begun..
Q: Is the course for the actual operators, and is it required by the State of
Maryland?
A: (D. Painter, EPA) Details have not been worked out, and there is no
current requirement.
(G. Aburn, MD DOH) Maryland would like to require such training in
the future.
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SESSION II
MANUFACTURERS' PANEL DISCUSSION
11
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DEVELOPMENT OF CONTROLLED AIR, FACTORY
PACKAGED, INCINERATION TECHNOLOGY IN USA
By Gene White
White & Associates
Schwenksville, PA
215-287-9529
Typical features of the controlled air system are as follows:
a) Emission levels of particulates are consistently low
without the use of hot gas cyclones or refractory
filters.
b) The incinerator is automatically loaded, preventing
overloading and protecting the operator from the
effects of explosion of aerosols, blowbacks and
noxious fumes.
c) Waste of varying calorific values can be accepted.
d) Loading is automatic and there is little risk of
operator error.
The old design incinerators in use in the USA up to the mid
1970s were of cast iron or steel and were lined with refractory
brick. Figure 1 shows their design.
F i qure 1.
Grate
The waste was manually charged through a hinged door and initial
ignition was by paper or oil-soaked cloth. Waste was burned on
a grate with air rising through the grate from an air inlet below.
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Features of this method were as follows:
a) The rate of combustion air flow and of burning could
not be controlled and it gave off considerable smoke
and high "flyash" emission.
b) The loading method permitted overloading which re-
sulted in excessive temperatures causing damage to
the refractory brick lining.
c) The operator was not protected during loading.
d) The grate had to be replaced frequently.
A refinement was the addition of:
a) A burner for initial ignition of waste and for the
burning of pathological waste.
b) A forced draft fan to increase turbulence and mixing
in the burning chamber.
c) A reversal chamber to attempt to remove "flyash", on
the premise that by reversing the direction of the
emission flow larger particles of "flyash" would be
deposited.
The incinerator continued to have a grate and to be charged
manually. Figure 2 shows how this method worked.
Figure 2
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The benefits were that there was a thermal switch which cut off
the fuel supply when a given temperature was achieved thereby
saving fuel, it was possible to ignite waste automatically and
there was a slight reduction in "flyash".
The next development step was the addition of an after-burning
chamber to the incinerator. See figure 3.
Figure 3
The smoke and emission generated by the unit in Figure 2 was
passed through a passage into the after burning section where
more air was added in the presence of another burner in an
attempt to burn off the smoke.
For the burning of paper and cardboard the system was partially
•successful. However, where the waste contained more than 2-3%
plastics considerable quantities of smoke were emitted. As a
great amount of air was still used the "flyash" content remained
high.
To limit the amount of smoke and "flyash" emitted, wet scrubbers
or water traps, larger after burning chambers and refractory
filter blocks were used.
There was however an increased risk of damage to refractory
filters caused by loading abuse and over enthusiastic cleaning,
performance on high plastic content waste was not good. The
principal disadvantage however was that they were expensive to
run and maintain.
15
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The development of the new incineration system in the early
1960s was in two stages. The immediate problem was to eliminate
the polluting effect of incineration and later with increases in
energy costs to utilize the energy generated, thereby reducing
fuel consumption.
Three factors were highlighted as the causes of emission
pollution. They were:
a) "Flyash" was caused by the driving of large amounts
of air through the waste to cause efficient; burning.
b) Smoke was primarily caused by the rapid volatilzation
of plastic or organic matter, combined with poor mixing
in the after-burning chamber.
c) Overloading of the incinerator caused the rate of
burning to exceed the available combustion air supply
causing smoke.
A way was also sought to eliminate danger to the operator. The
result is shown in figure 4.
MAIN STACK
BMEECHINO TO
FlUt GAS STACK
INDUCED OH AM f.VN
MAM LOADER
HEAT HECOVtHY BOILER
16
-------
The formula chosen was to have two burning chambers. In the
first, only a small amount of combustion air was admitted, causing
only partial burning of the waste. The smoke and gases produced
percolated upward through the waste-bed into the second chamber,
leaving volatile matter in the waste-bed. The first chamber used
only about one-sixteenth of the amount of air used in the primary
chamber of conventional incinerators and the velocity of gases
leaving the firebed was extremely low, less than 0.3m per second.
The result is that the waste was thermally decomposed under "calm"
or "acquiescent" conditions leaving a sterile ash residue.
The gases entering the second (upper) chamber from the first chamber
consisted of carbon particles (smoke), hydrogen, methane, carbon
monoxide, basic monomers, carbon dioxide and water vapor, in pro-
portions which effectively made it an acceptable fuel gas for the
secondary chamber. These gases were burned in a high intensity
after-burning chamber. As there was little or no "flyash" this
chamber burned turbulently as air and gases were mixed. This
system is capable of burning 100% plastics continuously without
smoke.
The classic grate was dispensed with and the waste was loaded onto
and burned on a flat refractory hearth.
A specially designed air entry system'prevented air inlets under
the waste becoming blocked. Chimney stack emissions were low and
the incinerator proved capable of smokeless operation, even when
operating on widely varying types of waste.
Using an automatic ram loader it was possible to avoid overloading
and to eliminate operator risk when loading.
The burning rate of the system is commensurate with the loading
rate when the system is fully operational.
Having achieved temperatures of 1600°F in burning the gases emitted
from the primary chamber, the heat generated can be used to generate
steam and hot water for use by hospitals and industry. This is
achieved by the hot emission from the incinerator being passed through
a specially designed heat recovery boiler where hot water and steam
are produced.
Figure 5 indicates a modern, 500 Ib/hr, packaged, controlled air
incinerator, system, capable of burning high and low heat release
waste. One and two second retention secondary chambers are indicated,
operating temperatures 1800 F to 2000 F modulated fuel-air, with
cubic footage of both chambers shown. Obtainable particulate
emissions would be the Federal regulation of 0.08 without gas
scrubbing.
17
-------
Figure 5
!>S*CCTION I CLOKXII
U'SJ. OPcHINf-
435 Ib/hr Type 0 waste 8500 BTU/lb
One (1) second retention secondary
chamber
SECOND
-T- RETENTION
, SECONDARY
-ffl—-
Chamber Volumes:
Secondary 105 cu ft
_ Primary 105 cu ft
435 Ib/hr Type 0 waste 8500 BTO/lta
Two (2) second retention secondary
chamber
Chamber Volumes:
Secondary 210 cu ft
Primary 105 cu ft
>SH I EKOVH 0000
I)' 50. OCCNIMi
RETENTION
SECONDARY
18
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20
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CONTROLLED AIR INCINERATION
FOR
BIOHAZARDOUS WASTE
"TECHNOLOGY AND REGULATORY ECONOMIC IMPACTS"
Presented by
Steve Shuler
at the
Hospital Waste Incineration & Hospital Waste Sterilizers Workshop
San Francisco, CA - May 10-12, 1988
Baltimore, MD - May 24-26, 1988
V) ECOLAIRE P O. Box 240707
COMBUSTION PRODUCTS, INC. c&XZ
A Joy Technologies Company Phone |7W| 588-i62o
Telex 572-549
fax |704| S8a-5903
21
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CONTROLLED AIR INCINERATION
WASTE FEED
CARBON DIOXIDE. WATER VAPOR
AND EXCESS OXYGEN AND NITROGEN TO ATMOSPHERE
ivOLATlES AND MOISTURE if,
' , .• •. ' 1 » ••* r '* *• l'*'t?*.*rtsf-i
VOLATILE CONTENT IS BURNED IN UPPER CHAMBER
MAIN BURNER
FOR MINIMUM COMBUSTION TEMPERATURE
MAIN FLAMEPORT AIR
STARVED-AIR CONDITION
IN LOWER CHAMBER
ASH AND NON-COMBUSTIBLE CONTENT
CONTROLLED UNDERFIRE
AIR FOR BURNING DOWN "FIXED
CARBON" CONTENT OF WASTE
ECOLAIRE
COMBUSTION PRODUCTS, INC.
A Joy Technologies Company
22
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Open burning, commonly referred to as the first incinerator,
contains features which modern incineration systems are designed
to control during the combustion process, i.e., starved air,
excess air, volatiles, and ash. As shown in the preceding graph,
the primary combustion chamber is designed to operate in an
oxygen deficient atmosphere; whereas, the secondary combustion
chamber operates in an oxygen rich atmosphere. Objective
operational results are to achieve maximum burn-out (minimal
fixed carbon in the ash), minimal particulate emissions, and
maximum destruction efficiency while consuming minimal fossil
fuel to maintain operating temperatures.
The principle of controlled air modular incineration systems is
to precisely control the combustion air within the primary
combustion chamber which also enables precise control of the
temperature and rate of volatization of the waste. The basis of
this is defined as "less -than theoretical air" which results in
the formation of a mixture of dense smoke and combustible organic
vapors. Further, operation of the primary combustion chamber in
this manner results in non-turbulent conditions with minimal ash
carry-over.
Theoretical combustion air is the precise amount of air required
for complete combustion and is otherwise known as
"stoichiometric" air. The secondary combustion chamber is
designed to operate with precisely controlled excess combustion
air which also achieves maximum turbulent mixing with the dense
smoke and combustible organic vapors originating from the primary
combustion chamber to attain complete combustion and maximum
destruction efficiency of toxic materials while also maintaining
operating set point temperatures with minimal fossil fuel input.
Typical operating temperatures are in the range of 1400-1600°F
for the primary combustion chamber and 1800-2000°F for the
secondary combustion chamber.
23
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Waste chemistry is represented by the following
Carbon (C)
Hydrogen (H)
Oxygen (0)
Moisture
Inorganics
with traces of:
Nitrogen (N)
Sulfur (S)
Chlorine (Cl)
Combustion reactions are:
O -x «_»2 •
H4. 1/9 n. ' •
T L 1 ft
-------
Control System furnished by small "Mom 6 Pop" firms
25
-------
Modern electronic control cabinet
26
-------
TO MIBMULIC mDIW I ' I
•X HWO.UB ITlTCK(l) '
Control Schematic
27
-------
Although most regional "Mom & Pop" incinerator fabricators have
been forced to either upgrade their technology or go out of
business, we still have a number of these systems being sold.
Controls for these systems are typically not much more than a
timer as depicted in the preceding photograph. Modern
incineration systems, however, employ complete control logic for
all operating elements of the system, including alarms and
automatic shut-down when systems malfunction or begin to operate
outside set point control parameters.
Reputable manufacturers employ various control schemes for their
systems. A typical state-of-the-art control system is shown in
the preceding schematic. This control scheme includes modulating
primary air, modulating secondary air, and modulating secondary
fuel. The graphs show that as temperature rises (high volatile
waste materials) in the primary, combustion air is decreased
proportionately. Also shown, as temperature decreases (low BTU
heat of combustion waste materials) combustion air automatically
increases to achieve proper volatiles release. The reciprocal of
this is applied to the secondary combustion chamber modulating
air control; i.e., increase in temperature res-ults in an increase
in combustion air, and a decrease in temperature activates a
decrease in combustion air.
In the event the temperature in the secondary combustion chamber
drops below the operating set point, a modulating burner will
automatically compensate for the temperature deficiency.
Control logic for modulating primary air, secondary air, and
secondary fuel is a communication loop originating from a
thermocouple.
These systems typically operate as follows:
Modulating Primary Air:
Thermocouple—^Temperature Controller—»Systems Central Control
Logic—^Combustion Air Blower—^Metering Valve—»Under Fire Air
Modulating Secondary Air:
Thermocouple—^Temperature Controller—^Systems Central Control
Logic-->Combustion Air Blower—^Metering Valve—>Flame Port Air
Modulating Secondary Fuel:
Thermocouple—^Temperature Controller—^Systems Central Control
Logic--»Air Metering Valve/Fuel-Air Ratio Valve--?»Burner
-------
Small, Manually Operated Incineration System
* (8) Hr./Day design duty
29
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Modern Incineration System - factory assembled
-10-12 Hr/Day Design Duty
*Feeder
-Internal Ash Ram
"2-second Retention Secondary Combustion Chamber
"Energy Shrouds
30
-------
Modern Continuous Duty Incineration System
*Under Construction
*Ram Feeder
^Internal Ash Ram
AAutomatic Ash Removal
"Burn Only Application
31
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Modern, Continuous Duty Incineration System
"Under Construction
"Continuous Feeder with Cart Dumper
-Internal Ash Ram
-Automatic Ash Removal
-Waste Heat Recovery Boiler
Note: Old, Decommissioned Incinerator on left
32
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KT •» PIU.OI
PROCESS DIAGRAM FOR
STANFORD UNIVERSITY
S-0704D
33
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In the preceding photographs systems are shown which range from
very simple manually operated incinerators to very complex
continuous duty installations with continuous feeders, automatic
ash removal, and waste heat recovery boilers. All of these
systems have one common feature, a large secondary combustion
chamber.
Today's regulatory trend is to require a specified retention time
in the secondary combustion chamber at a given temperature.
Typically these are:
* 1/2 second at 1800°F
* 1 second at 1800°F
* 1 1/2 seconds at 1800°F
* 2 seconds at 1800°F
* 2 seconds at 2000°F
Other regulatory parameters specify maximum allowable particulate
emission levels, CO, HC1, ash quality, etc.. A close study of
existing and proposed regulatory emissions and ash quality
allowable standards demonstrates that we are responding to
emotions and public and political pressure, along with a gross
lack of actual data from which to develop thes« standards.
Further, it. has been demonstrated that each individual state is
developing a separate standard which is more stringent than the
standard previously developed by neighboring states. This could
be called one-upmanship.
The EPA, industry leaders, combustion specialists, and concerned
consumers are desirous of a uniform national regulatory standard
which is realistic, applicable, and not grossly exaggerated.
The preceding process diagram for Stanford University depicts a
state-of-the-art continuous duty design incineration system with
a variable venturi wet scrubber to remove HC1 and reduce
particulate levels. To meet California standards, the scrubber
was not necessary as tests have proven. However, in anticipation
of public pressure, the scrubber was added from the very
beginning. Further, an Environmental Impact Statement was
required prior to issuing a permit to construct. Perhaps this is
not so bad, despite the typical $50,000 or more cost for an
E.I.S.. However, once sufficient data has been established,
should this requirement not be dropped to avoid the cost of
generating a redundant document on each new application to
construct?
Proposed regulations in some instances now require air pollution
control devices which do not yet exist -- at any price. Surely
they can be invented, but who can afford them? Further, the big
question is "Are they really necessary?" The best example was
provided recently by a combustion/air pollution expert who
equated a proposed regulatory standard as requiring scrubbing the
exhaust gases sufficiently clean to equate the allowable emission
to be the size of one postage stamp per cubic mile.
34
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Following is a summary of the capital and operating cost impact
in which various current and proposed regulatory standards are
requiring. These cover the monitoring and recording devices for
various pollutants and two scrubbing technologies.
Despite the superior designs a given manufacturer may execute in
his incineration equipment, product line, the key element in a
successful operation is the human operator. It is not uncommon
for an institution to install a system with an installed cost of
$1,000,000 or more and assign the lowest paid wage individual as
the system operator. The manufacturer will perform the complete
task of training this individual; however, this is not the
worker's focus. Thus, a bad system will frequently result from
operating parameters being changed for the benefit of someone who
could care less. We, as an industry, promote establishing a
national regulatory requirement for operator and supervision
training certification.
35
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STACK GAS MONITORS
Types and Application
In-Situ;
* Probe .Attached Gas Analyzer
* Analysis Inside Stack
Ex-Situ;
* High Temperature and/or.Very Dirty and Wet Flue Gas
* Analysis Outside Stack •
* Sample Pulled Through Heat-Traced Line into Container to
Monitors
Extractive:
* High Temperature and/or Very Dirty and Wet Flue Gas
* Analysis Outside Stack
* Sample Pulled Through Heat-Traced Line into Air
Conditioned Building or Cabinet to Extractive
Monitors
* Sample Chilled and Filtered for HZO Removal
* Can Sequence Between (2) or More Sources
* Sequences Backpurge, Calibration, and Sample
Intervals with Separate Lines to Each Probe
36
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GAS MONITOR CERTIFICATION
* EPA TESTING PROTOCOL
* PROOF OF ACCURACY
* When measuring SOj, NOX, and CO, guidelines are to correct
for Dilution Air to a specified standard; i.e. 10% 02 or 3%
C02
37
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STACK GAS SCRUBBER
Project Cost Impact
* Waste at 8500 BTU/lb
* Retention 2-seconds at 1800°F
* 3 58 SCFM Dry Flue Gas
I - Variable Venturi Wet Scrubber:
Incinerator
Waste Burn
Rate (Ib/hr)
415
550
695
835
1,110
1,395
1,675
2,230
2,790
3,350
Flue
Gas
( SCFM )
1,500
2,000
2,500
3,000
4,000
5,000
6,000
8,000
10,000
11,000
Scrubber
$
w/o Boiler
i 60
85
98
113
128
145
170
195
235
280
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
Scrubber
$
w/ Boiler
i 50
60
73
85
97
112
128
150
190
230
,000
,000
,000
,000
,000
,000
,000
,000
,000
,000
* Venturi Operating Pressure: 30 In. H*O
* Particulate Size:
10% Less than 1/2 micron(s)
20% Less than 1 micron(s)
55% Less than 3 micron(s)
80% Less than 6 micron(s)
* Application Operating Range:
0.03 G/DSCF Corrected to 7X O«
95% HC1 Removal or (50) PPM
70X S02 Removal or (30) PPM
Removal of Condensation of Heavy Metals
* Texas Test Result
0.0179 G/DSCF Front and Back Half, Uncorrected
25 PPM HC1
Less than (5) PPM VOC
Less than (0.4) PPM Chlorine
14X Average Oj
4X COj
180% Excess Air
Note: 1.) Above prices furnished by Anderson 2000 Inc.
2.) Prices do not include installation
3 a
-------
STACK GAS SCRUBBER
Project Cost Impact
II - Dry Scrubber/Bag House:
.$375,000-$!,000,000
* Minimal economy of scale (10,000 ACFM and Above)
* Most Efficient
* Limited vendors for systems less than (2,700) Ib/hr
burn rate
Note; Above prices are typical of Interel or Western
Precipitation
III - Annual Maintenance/Consumables/Power Consumption:
A) Wet Scrubber:
* Up to 58% of original capital equipment cost
B) Dry Scrubber/Bag House:
* Up to 40X of original capital equipment cost
39
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40
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SESSION n: MANUFACTURERS' PANEL DISCUSSION
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: What can regulators do to assist manufacturers?
A: (J. Kidd, Cleaver Brooks) Regulators can:
1) Help define to manufacturers what they want. Regulations that
change in mid-stream hurt production.
2) Define how good is good.
3) Define design requirements.
4) Take a proactive stand with the public to explain and review the
status of activities.
Q: What kind of standards would manufacturers like to see?
A: (J. Kidd, Cleaver Brooks) There are many, but two important areas are
training and qualifications, and design requirements. 1800° F is very
near 1000° C; it can be arbitrary. It makes no difference to
manufacturers.
Q: Does the requirement for a 2 second residence time apply to the
secondary chamber only?
A: (J. Kidd, Cleaver Brooks) Yes. It applies from where the gas enters the
secondary chamber to the point of exit.
Q: Where is the temperature monitor located?
A: (S. Shuler, Ecolaire Corp.) The point of measurement is between the
last introduction of air into the upper chamber, and its exit. How one
measures temperature differs by state.
Q: Kansas may be discussing a requirement for 3 seconds at 2000° F.
A: (R. Lee, Consumat Systems Inc.) There is little difference between 1 or
2 seconds residence time. Three seconds complicates matters. One
should consider the end result rather than a time value, i.e. what are you
trying to achieve? Agencies should encourage manufacturers to help
achieve this goal
. (J. Kidd, Cleaver Brooks) Residence time alone does not indicate
anything about what happens in combustion which entails time,
temperature, and turbulence. Two seconds at 1800° F is good with an
inefficient system.
(R. Lee, Consumat Systems Inc.) Consistency of regulations would help
rather than the variety now seen state-by-state.
(J. Kidd, Cleaver Brooks) The Waste Combustion Assistance Council, a
manufacturers' organization recently formed in Washington, D.C., will
probably approach this issue.
41
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Q: Incinerator operators lack a strong understanding of how the control
equipment is put together. APCA is a good vehicle to get the word out.
Wages must be high enough so that facilities can keep qualified people.
Water treatment and wastewater treatment plant operators have
continuous training, to make sure the equipment is run by people who
know what they are doing.
Q: What exemptions exist for small facilities?
A: (J. Kidd, Cleaver Brooks) Some states have exemptions for facilities
that meet mechanical and process guidelines. Market forces will force
many small, exempted facilities to close. From a regulator's
standpoint, fewer larger facilities with decent equipment are probably
preferable to numerous small incinerators.
Q: There is an ASME Training Committee looking into the issue of operator
training. The Committee is made up of regulators, unions,
manufacturers, designers, and industry. What constitutes proper
training has not yet been determined. This Committee is only
considering municipal waste incineration.
Q: What is the cost impact of GEM requirements?
A: (R. Lee, Consumat Systems Inc.) The cost of CEM is prohibitive for
smaller units. $3QO,OOp-$400,000 for monitoring is not unusual. Smaller
units cannot afford to install or maintain CEM.
Q: Please elaborate on the comment that regulators should do a better job
of monitoring and enforcement.
A: (J. Kidd, Cleaver Brooks) Regulators must define what type of
monitoring is wanted. Continuous temperature monitors are fairly
cheap (a couple of thousand dollars). If the right system is present, the
right temperature, and the right geometry, CEM with its high costs is
unnecessary.
42
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SESSION H: MANUFACTURERS' PANEL DISCUSSION
SUMMARY OF DISCUSSION (BALTMORE)
Q: Water or steam injection have been used to improve ash quality. But
water spray can destroy the refractory. How serious is this problem?
Shouldn11 sprays be used to control temperature, not ash quality?
A: (S. Shuler, Ecolaire Corp.) There was no implication that water should
be injected from above for either purpose since the resulting thermal
shock does degrade the refractory. Underfire air ports can be used to
inject small amounts of steam, not water, in order to fracture slag with
thermal shock. Temperature should be regulated by controlling
combustion air, not by using water.
Q: In general, how do costs for monitoring equipment compare with total
incinerator costs? For example, an 800 Ib/hr facility with scrubber, and
monitoring for O2> CO, and opacity.
A: (S. Shuler, Ecolaire Corp.) The total incinerator plant with typical
features and options could cost $500,000-$700,000. A wet scrubber
system could cost in the same range. A complete set of monitoring
equipment could cost $300,000-$400,000. So adding everything related
to air pollution can easily double (or even more) the cost of the
incinerator.
Q: What would be the costs for the same scenario except with a dry
scrubber plus baghouse instead of a wet scrubber?
A: (S. Shuler, Ecolaire Corp.) The cost of the dry scrubber/baghouse could
be $375,000-$! million. Note that systems differ widely in design, life
expectancy, and amount of maintenance required. Most such systems
are too big for most hospitals: a flow rate of 10,000 cfm, which is small
for a dry scrubber/baghouse, implies a charging rate of about 2500 Ib/hr.
Q: Can incinerators handling both municipal and infectious waste produce
sterile ash without recognizable objects?
A: (J. Gray, Consumat Systems, Inc.) Manufacturers recommend not
mixing the two types of waste because infectious waste requires higher
temperatures to ensure destruction of pathogens. If an incinerator
produces ash with recognizable objects, the charging rate is too high.
Q: How is ash handled within the incinerator?
A: (S. Shuler, Ecolaire Corp.) The ash ram strokes once just before each
waste feed, so the burning ash is pushed in pulses toward the ash
hopper. To minimize the amount of fixed carbon remaining in the ash, a
properly engineered system takes 4-6 hours from charging of waste to
the time the ash from that waste enters the quench pit. The pit
contains water to cool the ash and to keep uncontrolled air from
entering the combustion chamber.
43
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Ash is removed to a disposal container via either a drag chain conveyor
or an ash hoe (which works like a backhoe). The waste hauler picks up
the container, discharges it to his truck using a front-end loader, and
puts the container back.
Q: Is there any exposure of ash to the atmosphere?
A: (S. Shuler, Ecolaire Corp.) Possibly, once the ash is in the disposal
container. The volume of ash is 80-85% less than the volume of waste,
so the quantity is low, and the frequency of hauling is not high — 2 to 3
times per week. Thus, the ash could be stored for a few days, but
typically would be covered.
Q: Facilities accepting boxed waste have a better record of avoiding
leaking waste and overfeeding. Ram-fed bags can compress, be ripped,
and cause fires on contact with hot incinerator surfaces. Massachusetts
may require boxes for waste, though some consider this to be
unreasonable.
A: (J. Gray, Consumat Systems, Inc.) Containerization (or lack thereof) of
waste is a problem. Ideas are needed in how to handle wastes efficiently
and safely. One possibility is development of regional facilities as
opposed to an incinerator at each hospital. However, the need to
transport waste should also be minimized.
Q: Proper operation requires avoiding excessive air. How can operators be
kept from overfeeding air to the primary chamber? What percentage air
is recommended?
A: (S. Shuler, Ecolaire Corp.) Operators should not have access to controls
for excess air (either positive or negative) Instead, it should be a
programmed parameter. A typical desired parameter, based on
theoretical considerations, is 80% of stoichiometric air in the primary
chamber, and 120% in the secondary.
Q: Complete burnout is important to prevent recognizable objects and
minimize fixed carbon in ash. Should there be a standard, e.g. 95%
burnout or 5% fixed carbon?
A: (Unidentified speaker) Operator training and design guarantees would
be preferable. Improper operation is the main problem. Only
adequately educated, technically trained, properly motivated operators
can solve problems of unbumed waste in ash. Operator certification,
and even chief engineer or supervisor certification, are needed.
Q: The Consumat facility discussed in this session used a costly spray dryer
and dry scrubber. Why not use air cooling of the flue gas, then dry
scrubbing only?
A: (J. Gray, Consumat Systems, Inc.) Both options were considered and
the choice was judgmental. Air cooling/dry scrubbing may be best at
other facilities.
44
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Q: Can incinerators comply with RCRA if RCRA were to be applied to
hospitals?
A: (S. Shuler, Ecolaire Corp.) Volume thresholds apply for RCRA
applicability. RCRA control efficiencies cannot be achieved with
standard combustion processes, but can be achieved in a proper facility.
The permitting process is arduous and its cost can exceed the cost of the
incinerator.
45
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-------
SESSION III
SOURCE DATA AND STACK TESTING
47
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48
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MEASUREMENT of SOURCE EMISSIONS
by
P.K. Leung of Environment Canada
FORWORD
The purpose of this paper is to provide a brief,
general discussion on stack testing to those who are not
familiar with the subject. Detailed Canadian stack emission
data will be presented by my fellow panelist, Mr. Vlado
Ozvacic of the Ontario Ministry of Environment (MOE). Later
today, Mr. Dave Campbell of Environment Canada will present
a paper on the federal government's hospital waste incine-
rator program.
INTRODUCTION
Sampling for stack emissions from an industrial
process involves more than just climbing to the top of a
chimney, inserting a probe into the stack and obtaining
instantaneous emission data. Prior to the commencement of
the actual field testing work, two to three technical
experts must spend at least one to two months performing
numerous tasks such as:
* setting objectives for the stack testing program
* coordinating with program participants
* performin pre-test quality assurance work on sampling
equipment and data logging systems
* preparing, decontaminating, and proofing manual sampling
trains
* analyzing reagents for impurities
The pre-test work can be likened to preparing for a
mountaineering expedition in which careful planning and
meticulous preparation are essential for achieving the
ultimate goal — to obtain representative and meaningful
emission data.
In designing a source emission survey, a manager
must examine the following five important aspects of the
testing program:
1. Objectives
2. Target parameters to be measured
3. Sampling and analytical protocols
4. Quality assurance and quality control
5. Resource Requirement
49
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OBJECTIVES
To assure that the objectives of the programs are
understood, the program manager must communicate with all
the participants (such as the regulatory agency, the plant
operators, the sampling team, and the analytical labora-
tory). He/she must should set realistic goals for the stack
testing program by considering factors such as:
* the resource limitations (PY, $, time)
* the capability, availability, cost, and turn-around time
of the source testing team and analytical laboratory
* the end-use of the emission data
* the timing of the program
TARGET PARAMETERS
After establishing the objectives, the manager
should make a wish list of target parameters to be measured.
A list of candidate target compounds for a stack test may
contain:
* Total particulates and selected heavy metals
* Mercury
* Trace organics e.g. dioxins, furans, and PAHs
* Mutagenic substances
. * Micro-organisms (survival tests)
* Radioactive elements
* Gases e.g. 02, C02, CO, NOx, HCl, and non-methane total
hydrocarbons
In addition to the stack parameters, the manager
should also decide on the process parameters and other
samples to be collected during the stack tests. For example:
* Process operating parameters such as temperature and
pressure readings, % excess air and pollution control
device data
* Feed characteristics (type, heat content, feed rate etc.)
* Ash samples
* Liquid effluent samples
50
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SAMPLING/ANALYTICAL PROTOCOLS
The program manager should contact at least three
stack testing consultants for quotes. He/she should obtain
references and find out if the stack testing team and the
analytical laboratory have previous hand-on experience with
the protocols to be used. For compliance testing, it is
important that the regulatory agency approves the methods to
be used by the consultant, as well as any modifications made
to the methods.
The emission samples are usually extracted from
ports located high on the stack, in general, a series of
three tests is required to determine the average emission
rate of each target compound under each set of plant opera-
ting conditions. For the 'regular' target compounds such as
total particulates, an experienced sampling team may be able
to conduct three runs in one day. However, for more 'exotic'
compounds such as dioxins, one run (four hours of actual
sampling time) per day is the norm. To save time, one may
collect a group of compounds having similar chemical charac-
teristics in a single samplng train during each run.
However, there are limitations. For example: Samples from
the total particulate train (with 5 % aqua-regia solution in
the impingers instead of water, see Figure 1) can be ana-
lyzed to provide both particulate and heavy metal emission
results. However, a MM 5 train (see Figure 2) can only pro-
vide emission data for trace organics but not for particu-
lates.
Sampling/analytical guidelines or protocols may be
obtained from organizations such as NESCAUM, Environment
Canada, EPA, Provincial and State regulatory agencies, and
ASME. The users of these protocols should be aware that the
methodologies for some compounds, such as PAHs, are still
in the development stage and that the emission results
generated may be of unknown accuracies (as opposite to known
precisions).
51
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QUALITY ASSURANCE/QUALITY CQNTflQL PROGRAMS
It is a common mistake to assume that a QA/QC
program is optional and should be implemented only if there
is left-over fund from the main testing program. Unfortuna-
tely, emission data without adequate QA/QC support are
often subject to questioning and difficult to defend. In
many cases, the data are considered meaningless and the
testing effort wasted. The program manager should reject
those testing teams and analytical laboratories that do not
already have their own in-house QA/QC programs in place. In
compliance testing situations, the manager should also be
prepared to accept QA/QC scrutiny from the regulatory
agency.
Sampling and analytical QA/QC protocols are usual-
ly available from the regulatory agencies. Technical infor-
mation on QA/QC procedures and data quality objectives can
also be found in a joint NESCAUM-EPA publication entitled
"Recommended Guidelines for Stack Testing at Municipal Waste
Combustion Facilities". The document, compiled by Workgroup
members from both the private and public sectors in Canada
and US, contains also sampling and analytical methodologies
for various trace metals, trace organics, and combustion
gases.
52
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RESOURCE REQUIREMENTS
The level of effort required is usually determined
by the complexity of the stack testing program. A relatively
simple program may involve the measurement of stack emis-
sions by a team of two over a period of three to four days
using established sampling techniques, such as the EPA
Method 5 (Particulate), at an easily accessible site.
On the other hand, a large-scale research and
development type program may require the manager to coordi-
nate simultaneous sampling activities at several stacks and
process streams. Each sampling teams may be required to
provide state-of-the-art manual sampling equipment for
various species of contaminants (e.g. VOST and MM5 sampling
trains for trace organics), real-time continuous emission
monitors, and QA/QC programs to support the manual and
continuous sampling work.
The following is an example of cost break-down for
a research and development type of program (Environment
Canada's National Incinerator Testing and Evaluation Program
at the Quebec City Municipal Incinerator):
Budget Items Percentage of total O&M cost
. Travel and living 7.3
Equipment rental 8.8
Consumables and misc. 11.0
Chemical analysis 20.9
Non-field labour 21.2
Field labour 30.8
As shown above, the analytical and labour cost
contribute significantly to the overall cost of the program.
In designing a stack testing survey, the manager should
therefore total up the number of tests desired, estimate the
labour and analytical cost, and modify his/her wish list
accordingly. At approximately $100 an hour for a consultant
and $1,000 for each organic sample, scientific curiosity may
just have to take second place to practicality.
53
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I/I
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'54
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56
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SOURCE DATA AND STACK TESTING IN CALIFORNIA
Gary M. Yee
Air Pollution Specialist
California Air Resources Board
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco, CA
May 10-12, 1988
57
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Noncriteria
Pollutant Sampling Methods
Pollutant
Semi-Volatile
Organics
Volatile Organics
Trace Organics
HCL
Metals
Sampling Method
Modified Method 5
Bag Sample•
Modified Method 5
Method 5
Method 5
Incinerator A
Design and Operating Parameters
Type : 2 Chambered
Controlled Air
Burners : Primary
: Secondary
Beat Recovery : Boiler
/Steam Generation
Emission Controls : None
Combustion Temperature : 1100 °F primary
: 1800 °F secondary
Waste feed rate : 783 Ib/hr
58
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INCINERATOR A
Schematic of Hospital Refuse Incinerator
and Sampling Locations
SA.MPIE PORTS
NATURAL RAS .
20
80
3-PASS HEAT
EXCHANGER
SECONDARY
CHAMBER
PRIMARY
CHAMBER
HOSPITAL REFUSE
NATURAL GAS
\
Incinerator A
Metals, HCL and PM Emissions
Arsenic
Cadmium
Chromium (total)
Iron
Manganese
Nickel
Lead
HCL
Particulates
gm/hr
0.04
0.73
0.11
1.81
0.07
0.05
9.94
6.05 Ib/hr
1.91 Ib/hr
926 ppmv
0.09 gr/dscf
59
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Incinerator A
Dioxin and Furan Emissions
(2,3,7,8) substituted
Toxic
Dioxins
ng/m3
no/sec
Equivalence
TCDD
PeCDD
HxCDD
HpCDD
Total
Furans
TCDF
PeCDF
HxCDF
HpCDF
NO
1.9
11.7
57 . 7
71.3
1.7
19.6
63.8
133.0
NO
2.6
16.1
79.3
98.0
2.3
26.9
87.8
183.0
NO
2.6
0.5
2.4
5.5
2.3
26.9
2.6
5.5
Total
218.1
300.0
37.3
Incinerator B
Design and Operating Parameters
Type : 2 Chambered
Controlled Air
Burners : Primary
: Secondary
Heat Recovery : Boiler
/Steam Generation
Emission Controls : Baghouse
Combustion Temperature : 1600-1800 °F primary
: 1800-2000 °F secondary
Waste feed rate : 980 Ib/hr
60
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.
Schematic of Hospital Refuse
Incinerator and Samcling Locations
Baghouse Inlet
Semi-volatile,
HCL and PM
Sampling Trains
Oloxln
Sampling Train
Analyzer
BAGHOUSE
D1a. 18"
Damaged Heat
••—Exchanger
Gas Temperature
450°F
Boiler
Secondary
Chamber
1800-ZOOO'F
Gas Temperature
Baghouse outlet
dloxln sampling
train and gas van
••-analyzer line
Baghouse outlet
semi-volatile,
HCL and PM
••-sampling trains
10 Fan and Huffier
Primary
Chamber
1600-1800°F
Gas Temperature
Natural Gas
Incinerator B
Metals, HCL and PM Emissions
Arsenic
Cadmium
Chromium (total)
Iron
Manganese
Nickel
Lead
HCL
Particulates
gm/hr
0.07
1.51
0.08
1.62
0.10
NO
12.89
7.89 Ib/hr
0.05 Ib/hr
gm/ton
0.14
3.08
0.16
3.31
0.20
ND
26.31
521 ppmv
0.002 gr/dscf
61
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Incinerator B
Dioxin and Furan Emissions
(2,3,7,8) substituted
Dioxins
TCDD
PeCDD
HxCDO
HpCDD
Total
Furans
TCDF
PeCOF
HxCDF
HpCDF
Inlet
ng/sec
0.3
1.5
9.0
44.6
55.4
2.1
18.1
54.4
121.2
Outlet
ng/sec
0.4
1.8
7.4
29.6
38.8
2.4
17.1
45.0
88.7
Toxic
Equivalence
0.4
1.8
0.2
0.9
3.3
2.4
17.1
1.4
2.7
Total
195.8
153.2
23.5
Incinerator C
Design and Operating Parameters
Type : 2 Chambered
Controlled Air
Burners
Heat Recovery
Emission Controls
Combustion Temperature
Waste feed rate
Primary
Secondary
None
Wet Scrubber
1700-2000 °F primary
1900-2100 °F secondary
550-805 Ib/hr
62
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INCINERATOR C
Schematic of Refusn Incinerator
and Sampling Location
Exhaust
Stack
Cap •*
Dump Stack •»
* Sampling
«. Ports
Muffler *
Reheat
Burner V
Sampling
Ports
*Yentur1
Scrubber
I.D. Fan \
Control
Chamber
19000F - 21000F »
3 t C
Primary
Chamber
1700°F - 2000°F
Incinerator C
Metals, HCL and PM Emissions
Arsenic
Cadmium
Chromium (total)
Iron
Manganese
Nickel
Lead
HCL
Particulates
759 ppmv
0.05 gr/dscf
1.86 ppmv
0.003 gr/dscf
•63
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Incinerator C
Dioxin and Furan Emissions
(2,3,7,8) substituted
Dioxins
TCDD
PeCDD
HxCDD
HpCDD
Total
Furans
TCDF
PeCDF
BxCDF
HpCOF
Inlet
ng/sec
0.08
0.37
1.32
4.69
6.46
0.82
3.51
7.53
14.47
Outlet
ng/sec
0.02
0.10
0.49
1.72
2.33
0.21
1.37
3.86
5.11
Toxic
Equivalence
0.02
0.10
0.02
0.05
0.19
0.21
1.37
0.12
0.15
Total
26.33
10.55
1.85
Incinerator D
Design and Operating Parameters
Type : 2 Chambered
Controlled Air
Burners : Primary
: Secondary
Heat Recovery : Boiler
/Steam Generation
Emission Controls : none
Combustion Temperature : 1450 °F primary
: 1400-1600 °F secondary
Waste feed rate : 369-593 Ib/hr
64
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IMCINERATOR D
Schematic of Hospital Refuse
Incinerator and Sampling Locations
2-Psss
Heat Exchanger
In1«t I500°F .
Outlet 450°F
* Sampling Ports
*• Dump Stack
Diversion Damper (3'x3')
Position A, Dump Stack
Mode, Boiler Bypass
Position B, Dump Stack
Closed, Boiler and Fan
in Operation
Control Chamber
1600-2300°F
Trash Ram
Primary Chamber
1300°F
Incinerator D
Metals, HCL and PM Emissions
Arsenic
Cadmium
Chromium (total)
Iron
Manganese
Nickel
Lead
HCL
Particulates
gm/hr
0.002
0.31
0.05
4.81
0.12
ND
5.58
5.79 Ib/hr
1.38 Ib/hr
gm/ton
0.01
1.55
0.25
24.0
0.6
ND
27.9
315 ppmv
0.057 gr/dscf
65
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Incinerator D
Dioxin and Furan Emissions
(2,3,7,8) substituted
Toxic
Dioxins
ng/m3
ng/sec
Equivalence
TCDD
PeCDD
HxCDD
HpCDD
Total
Furans
TCDF
PeCDF
HxCDF
HpCDF
0.20
21.17
64.56
246.23
332.16
7.52
98.70
215.37
428.37
0.14
14.60
44.10
169.00
227.84
6.05
67.60
213.90
292.40
0.14
14.60
1.32
5.07
21.13
6.05
67.60
6 .42
8.77
Total
750.0
579.95
88.84
Incinerator E
Design and Operating Parameters
Type : Single Chamber
Afterburner
Burners
Heat Recovery
Emission Controls
Combustion Temperature
Waste feed rate
Primary
Secondary
none
none
600-800 °F Primary
1400-1600 °F Afterburner
70-100 Ib/hr
66
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Incinerator E
Metals, HCL and PM Emissions
Arsenic
Cadmium
Chromium (total)
Iron
Manganese
Nickel
Lead
HCL
Particulates
gm/hr
0.01
0.26
ND
0.59
0.03
ND
3.59
1.5 Ib/hr
0.12 Ib/hr
gm/ton
0.29
7.43
ND
16.86
0.86
ND
102.57
770 pprav
0.04 gr/dscf
Incinerator E
Dioxin and Furan Emissions
(2,3,7,8) substituted
Dioxins
ng/m:
na/sec
Toxic
Equivalence
TCDD
PeCDD
HxCDD
HpCDD
Total
Furan s
TCDF
PeCDF
HxCDF
HpCDF
0.02
0.22
1.17
9.39
10.80
0.22
8.89
10.90
31.25
0.004
0.038
0.196
1.575
1.813
0.038
1.492
1.829
5.242
0.004
0.38
0.006
0.047
0.095
0.038
1.492
0.055
0.157
Total
51.26
10.550
1.742
67
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Comparison of Selected
Emissions From Incinerators
Heat Dioxins Cadmium Lead
Incinerator Control Recovery (ng/sec) (gm/hr) (gm/hr)
A no yes 43 0.7 9.-9
B yes yes 27 1.5 12.9
C yes no 2 0.5 11.6
D no yes 110 0.3 5.6
E no no 2 0.3 3.6
68
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HOSPITAL INCINERATOR TESTING
IN NEW YORK STATE
Robert Waterfall '
New York Department of
Environmental Conservation
Division of Air
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco, CA
May 10-12, 1988
69
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THE PROGRAM
• Existing site survey
• Preliminary test
• Complete test series (tentative)
SURVEY QUESTIONS
• Charge rate?
• Hours of operation?
• Ram feed?
* Atmospheric damper?
• Heat recovery?
• Method 5 site?
SURVEY RESULTS
• 25 sites contacted in upstate New York
• 11 with heat recovery
• 4 with method 5 site
PRELIMINARY TEST
• Albany Medical Center
• Just completed in April 1988
• Contaminants:
Arsenic Mercury
Cadmium HC1
Chromium CEMs
Lead Organics
ALBANY MEDICAL CENTER INCINERATOR
• Ram feed
• 1280 Ib/hr capacity
• 900 Ib/hr average
• Ash removed daily
• 60% red bag/40% cardboard
70
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ANTICIPATED UPGRADE
• Larger secondary
• Continuous Ash removal
• Venturi and packed scrubbers
• Stack gas reheat
PRELIMINARY TEST RESULTS
(All results are at 7%
Cadmium 4.25 mg/dscm
Chromium <0.4 mg/dscm
Lead 3.57 mg/dscm
Mercury 8.45 mg/dscm
Chlorobenzene 0.04 mg/dscm
HC1 2000 ppm
S(>2 <100 ppm
NOX -150 ppm
PRELIMINARY RESULTS AT-A-GLANCE
• Particulate — High
• Combustion gases — Cyclic
• SO2 and NOX — Low
• Organics — Benzene, Chlorobenzene
OPERATING INSIGHTS
• High BTU loads
• Red bag contents
• Manually tinud loading
• Water injection
COMBUSTION GASES
NOX r, co r,
Poor burnout
Load just charged
NOX I, CO 1, 02T
Clean operation
Combustion stable
71
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COMPLETE TEST SERIES
• Planned for NYC in summer 1988
• Funding questionable
• Varied operation
• Contaminants:
Dioxins CC>2
Metals 02
Particulate CO
Organics S02
' HC1 NOX
72
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BIOMEDICAL WASTE INCINERATOR PROGRAMS IN ONTARIO
(Biomedical Waste Workshops, San Francisco,
May 10-12, 1988, Baltimore 24-26, 1988)
Vlado Ozvacic
Air Resources Branch
Ontario Ministry of the Environment
Background:
There are over 130 biomedical waste incinerators (BWIs)
located on hospital premises in Ontario. Some hospitals
burn only general waste in their incinerators -
pathological waste, which can be defined as the waste
containing human or animal tissue or is infected with
communicable disease or contains body fluids, is sent away
for incineration. Waste generated in cancer-treating
hospitals may contain more chlorinated plastics in
comparison to other hospitals.
BWIs in Ontario are small and could be classified into
batch types or semi-continuously fed two-chamber types. The
s.emi- continuous incinerators are charged with waste
periodically throughout the operational period via a ram-
feeding mechanism. Most incinerators are operated four to
ten hours a day, five days a week. Almost all incinerators
contain either afterburners or secondary stage burners,
complying with the Ministry's 1974 design criteria for the
combustion gas residence time of 1/2 second at 1000°C. A
typical batch incinerator may contain one or more chambers
with a primary burner and an additional burner in. a small
compartment within the primary chamber for pathological
waste. Some of the existing incinerators comply with the
Ministry's 1986 design criteria of one second residence
time at 1000°C for the combustion gas.
Operators of new BWIs in Ontario are required to
continuously monitor opacity and total organic matter or
carbon monoxide, to control the operation of the
incinerator and to minimize the air emissions (1).
There are no measured air emission data for a number of
toxic pollutants from any type of BWI in Ontario today.
Some preliminary measurements of total hydrocarbons in
the stacks of these incinerators indicated that unburned
organic matter may be emitted into the air and that the
emission quantities may depend on the operational cycle and
incinerator design. A testing program to examine this
dependance of emissions on the operating conditions and to
develop air emission data base for BWIs has been in
progress in Ontario since 1987.
73
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The testing of Continuous Emission Monitors at BWIs
New BWIs in Ontario must be equipped with continuous
emission monitors (CEM) for opacity and total hydrocarbons
(THCs) or carbon monoxide (CO), to provide for optimum
operation and to minimize the air emissions from these
incinerators.
Several factors including high temperature, corrosive
nature of the exhaust gases and the intermittent operation
of BWIs could present difficulties in deciding on the level
of sophistication of instrument package and its cost. In
order to examine these factors and to specify appropriate
policy guidelines, the Air Resources Branch conducted CEM
experiments using commercial instruments* at two BWIs in
Toronto in 1987.
The two incinerators in the study, denoted as A and B, are
both recently built two-chamber, ram-fed types.
Incinerator A is a Consumat C-325 model, controlled air
two-chamber type, designed to burn 267 kg/h of biomedical
waste. The primary chamber is operated with excess air. The
secondary chamber is sized to provide 1/2 second residence
time at 1000°C for the combustion gas. The incinerator
stack emissions are visible occasionally when the waste
containing high level of plastics is burned. The waste for
incineration contains small anatomical parts, infectious
laboratory waste, including residuals of body fluid samples,
swabs, disinfectants, alcohols, needles sharps, small
containers and general waste.
Incinerator B is a Trecan Combustion's two-chamber
controlled air model Trecaire 11, designed to burn 160
kg/h of BWI or 55 kg/h of pathological waste (Figure 1).
The primary chamber is operated under starved air condition
and the secondary chamber provides 1/2 second residence
time at 1000°C for the combustion gas.
The choice of CEMs for the study was based on the
simplicity of design and low cost in comparison to more
sophisticated monitors.
The opacity meter was a double-pass type, even though less
expensive single-pass opacity meters could be used at some
BWIs. Double-pass instrument was necessary for this study
because of (unexpected) opacity emissions during the
incinerator dormant (noncombustion) periods and, hence,
inability to zero single-pass monitors on daily basis. The
instrument, a Sick RM 61 Transmissometer, utilizes a split-
beam measurement technique with a folded path optical
system. The projection windows were flushed with filtered
air continuously to avoid dust deposition. The cost of the
opacity instrument package including the meter, high
temperature mountings, air blower and calibration filters
74
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was $8000 in 1987.
The initial calibration of the transmissometer and the
zero-calibration reflector was performed on a weekend when
the stack was clear. Subsequent daily calibration checks
were carried out by inserting the zero-ca 1ibration
reflector to simulate the clear stack condition, and the
measurement span was cjiecked with a neutral density filter.
Flame ionization technique was used to measure THCs - the
analyzer was a heated Ratfish RS5. The extracted sample was
transported through a probe and heat-traced both the
primary filter and the sample line. The analyzer was
calibrated with purified air and a mixture of propane in
nitrogen. The calibration checks of the analyzer were
frequently done by injecting the gases directly into the
analyzer whereas daily injections into the probe ahead of
the primary filter were used to determine the calibration
drifts. The cost of the instrument package was estimated at
about $16000 in 1987.
The monitor for carbon monoxide was an extractive type,
measuring a preconditioned gas sample. The gas sample was
aspirated from the stack with a steam eductor, and the
mixture of the sample and steam was transported to a
condenser to remove water prior to entering the analyzer.
The analyser was a NOVA 7200 with electrochemical sensor.
The calibration drifts for the whole measurement system
were performed daily. The cost of the system including the
steam ejector, sample lines, condenser and the analyser was
$8000 in 1987. . . . -
Both extractive monitors, THC and CO, were recalibrated
whenever daily drifts exceeded 2% of the gas calibration
values.
Stack gas temperatures were measured with a K-thermocouple
placed in a ceramic shield. The thermocouple calibrations
checks were done in the field periodically by comparing its
readings with another thermocouple.
Calibration Drifts:
The monitoring systems showed a reasonably low calibration
drifts except for the THC system at the incinerator A
(Table 1). The high 13% average drift of this system was
due to frequent fouling of the instrument capillary tube,
requiring weekly cleaning of the FID detector. There was no
fouling at the incinerator B where the THC concentrations
were lower than at the incinerator B.
CEM Results:
The main result of the CEM study was a successful
75
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demonstration that the continuous monitoring of opacity,
THCs and CO in BWI stacks is feasible using commercially
available instruments of reasonably low cost. THC
monitoring systems may require frequent servicing at
incinerators emitting higher quantites of THCs - the
alternate CO monitoring systems require less maintenance.
*
The instrument readings reflected the incinerator
operations. Examples of typical 24-hour traces of opacity,
THCs and CO at the incinerator A are shown in Figures 2,3
and 4. In the case of opacity, the instrument-traced peaks
were confirmed by visual observation of stack emissions.
These peaks occurred approximately one minute after each
ram push and lasted 1/2 minute on the average.
Opacity levels were significant when the incinerator was
not operated. These dormant incinerator emissions peaked
during the ash cleanout prior to the incinerator start-up
(Figure 2). At 8 AM, the secondary burner was lit, the
waste feeding started at 10 AM. Feeding stopped at 8 PM and
the secondary burner was shut down at 10 PM. The peaks on
Figure 2 during the incinerator operation corresponded to
waste loading.
Similar behavior was noted for THCs and CO shown in Figures
3 and 4, respectively. Dormant emissions were also noted at
the incinerator B, even though at a lower level than at the
incinerator A.
It is suspected that the dormant emissions at both
incinerators were a result of pyrolysis of unburned ash
left in the furnace overnight, sustained by air drafts
through open doors or other openings in the fu-rnaces.
The average values of all three pollutants during the
operational and nonoperational periods at the two
incinerators are shown in Figures 5 and 6.
BWI Testing Program
The purpose of testing the BWIs in Ontario is to develop
data base required for the specification of standards for
air emissions and ash disposal; for the evaluation of
design criteria for these incinerators; for the
specification of air emission abatement equipment and for
risk analyses. Hence, the BWI testing program was designed
to measure air and ash emissions, the efficiency of air
emission abatement equipment and the effect of combustion
gas residence time and temperature in the secondary
chambers or afterburners. The process and waste data have
been collected during testing.
The testing program includes 10 BWIs; batch and semi-
-------
continuous; two-chamber incinerators with either starved
air or excess air in primary chambers; different
incinerator makes; different gas residence time in
secondary chambers; different PVC content and the increased
content of other plastics in the waste; the incinerators
equipped with either dry scrubbers and baghouses or liquid
scrubbers.
Five classes of air pollutants are measured at each
incinerator, using separate sampling trains/systems for
each class;
- Organics such as dioxins (PCDDs), furans (PCDFs),
polyaromatic hydrocarbons (PAHs), polychlorinated
biphenyls (PCBs), ch1oropheno1s (CPs) and
chlorobenzenes (CBs). One out of the total of three
samples collected at each incinerator is being
tested for mutagenicity (Ames test).
- Volatile organics - initially, semiquantitative
scans will be made in order to specify specie for
analyses.
- Trace metals and radioactivity - similarly to tests
for volatile organics, species for analyses will be
determined after making semiquantitative scans.
- Gaseous pollutants by CEM, including HC1, NOX, SOX,
CO, C02, 02 and THCs.
- Microorganisms. The tests also involve challenging
the incinerators with the known quantity of Bacillus
Cereus spores.
The program was designed by various branches of the
Ministry of the Environment. Ministry laboratories provide
chemical analyses and other laboratory measurements; the
Laboratory Services Branch coordinates the analytical work.
An outside commercial laboratory is performing the analyses
for volatile organics. Clayton Environmental Consultants
carry out stack sampling, process observation and prepare
the reports. The Air Resources Branch provides CEM and the
overall program coordination.
The BWI testing program is divided into four phases. The
testing of three incinerators has been completed, however,
only some analytical results are available to date.
Results of the BWI Testing Program:
The CEM plots of opacity, CO and HC1 taken at Humber
Memorial Hospital (No.2) and Womens' College Hospital
77
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(No.3) are shown in Figures 7 - 12. The incinerator No.2 is
an old batch type made by Plibrico, while No.3 incinerator
is the two-chamber type already discussed in the CEM
program description as incinerator B.
The concentrations of all three pollutants were the highest
at the start of the batch at the incinerator 2, and they
gradually decreased towards the end of the batch. The
concentrations were more evenly distributed throughout the
testing period at the semi-continuous1y fed No. 3
incinerator. HC1 concetrations were dependent on the feed
rate at the same hospital and this dependance is
illustrated in Figure 13.
The preliminary results of the tests completed at the
first three hospitals are available for some species. They
are shown in Table 2.
No microrganisms were found in air emissions at either of
the three incinerators during or before the burn (backgroud
sampling).. No spores were found in the ash, only some
bacterial growth in the ash sample extracts was reported.
The only positive bacteria results were obtained in the
samples of air around one of the tested incinerators.
No radioactivity (alpha, beta or gamma rays) was reported
to be present above the method detection limit on either
particulates or impinger extracts in the samples analysed
to date.
Vlado Ozvacic
Reference: Continuous Emission Monitoring for Biomedical
Waste Incinerators, Draft Policy Guideline,
Ministry of the Environment, 1988.
78
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IttcJt bit - 11th Moor
// // // ////////// // I / / / I /// / / / / / / / / / / / / / / / / / S / / /
Incinerator A
Incinerator B
Opacity
0.4
1.1
THC CO
-13 0.1
0.4 -0.3
TABLE 1. AVERAGE CEM DRIFT (2 full scale per day)
79
-------
INCINERATOR A
OMOnr. U X* IM7
22 24
INCINERATOR A
trot KtoMctMeM COHC. a j»i» I
nee -
1000 -
TOO •
too
0 2 4 ( • 10 U 14 l« 1* JO tX 24
INCINERATOR A
1007
0 2 « • i 10 12 I* '• 10 JO a: 24
80
-------
400
390 -
COMPARATIVE MONITORING DATA
NoncombtnUon Pwtodi
90 -
Opacity (X)
1HC (ppm nM«han«)
V7J InebMrator B
CO (ppm)
390
COMPARATIVE MONITORING DATA
Combustion P*Hod>
300 -
290 -
200 -
190 -
100 -
90 -
«•« 1.73
IMC (ppm IM(IMM)
E23 bwlMntor B
CO (ppm)
81
-------
100
M
80 •
70 •
M -
90 -
40 -
90 •
JO -
10
0
HOSPITAL NO. 2 INCINERATOR
P«bnrary 10. tfM
- — OMCITV
3
Dm (tain)
7.
g
1
M -
19 -
•0 -
M -
10 -
0
HOSPITAL NO. 3 INCINERATOR
tfanfl J.1MI
O I
— tftan
>,A.A A -
.-—L_
a a
HIM (Mm)
82
-------
1900
1400
1300
1200
1100
1000
700 -i
HOSPITAL NO. 2 INCINERATOR
February 10. If89
HOSPITAL NO. 3 INCINERATOR
3.H
V WASICIOKXNO
83
-------
HOSPITAL NO. 2 INCINERATOR
r«brwory 10. 1988
HCL
9000
MOO
2400
»00
1100
1MO
1400
1900
1000
N
HOSPITAL NO. 3 INCINERATOR
ttandtai 1000
a A
-------
MS.
HO
TOO
we
400
HOSPITAL NO. 1 INCINERATOR
HCt, Cine. «•. Wwt* mm
OdAN
04INM
0 JIM 07
ta
aen a
B4W9*
: It
•ME it
too
TOO
•00
1100
CM)
1300
14
1900
Incin. Total PCDD/PCDF PCBs CBs PAHs HC1
No. Particul.
g/kg ng/DSCM
1
2
3
1
1
13
10- 30 ND 4-13 ND 487
32-260 NA NA NA 612
NA NA NA NA 1250
THC S02 NO C02
ppm X
3 25 68 7
18 23 63 6
14 30 100 8
NOTE: No Bicroorganisas or radioactivity were detected
PCDD/PCDF - total dioxins and furans with 4 and »ore chlorines
CBs - chlorobenzenes
PABs - poljaroaatic hydrocarbons
g/kg - gra» emitted per kilograa of waste
ng/DSCM - nanograas per dry standard cubic aeter
ppa(Z) - parts per aillion(percent) by voluae
TABLE 2. Preliminary results of stack testing at BVIs
85
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86
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SESSION IH: SOURCE DATA AND STACK TESTING
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: Tests on municipal incinerators in New York found that heat recovery
devices have significant effects upon dioxin formation. Please elaborate.
A: (R. Waterfall, NY DEC) Tests done in New York and elsewhere show
that as the gases cool down more dioxin would he found. Three sites
were tested: a large waterwall, a small modular, and an ESP. An
increase of dioxin and furans content of the flue gas was found between
the boiler and the control equipment.
Q: Didn't GARB data say the opposite, that after the scrubber less dioxin
was found?
A: (G. Yee, GARB) No. Of the five boilers tested, GARB did not test
across the heat recovery boilers. With a heat recovery boiler the
temperature after the secondary chamber drops to a range where dioxin
formation is possible. Incinerators without heat recovery, where stack
temperatures are 1200°-1400°, should have lower dioxin levels after the
secondary chamber. For facilities with control devices (bag houses and
scrubbers), dioxin levels were lower -after the controls, regardless of
heat recovery.
Q: Please comment on pathogen testing.
A: (V. Ozvacic, ON Min. of Env.) Ontario used three sampling trains: one
for stack emissions, another during the combustion period (a pre-burn
sample), and an ambient air sample used for combustion. Bacteria
counts came from the waste. Pre-burn samples and ambient air showed
bacteria growth. The ambient air sample counts were due to samples
being taken from the air where the waste bags were stored. No bacteria
counts were taken from the combustion emissions.
(G. Yee, GARB) GARB conducted pathogen baseline testing of a filter
sample, stack emissions, and a blank. The test indicated no pathogens or
growth. However, there was some growth on the blank due to
contamination. The results are currently being analyzed on a seventh
test of infectious waste incineration for a heat recovery boiler with a
magnesium hydroxide scrubber. The plan in the future is to spike a
known quantity within a waste stream and measure the destruction
efficiency through the incinerator.
Q: Where does the lead come from?
A: (V. Ozvacic, ON Min. of Env.) Perhaps the source is printed material in
the general waste.
(G. Yee, GARB) Lead may come from radioactive types of medicines
kept in lead containers.
87
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Q: It seems that heat recovery causes precipitation of dioxin within the
flue. For those not using heat recovery the dioxin formation may be
occurring in the atmosphere instead as the dispersing gases cool down.
Are there data to support this theory?
A: (G. Yee, GARB) This is a good possibility if there is no heat recovery,
but dispersion of gases would reduce any formation of dioxins in the
plume. Measurements at stacks may not truly reflect the potential total
emissions downstream in the ambient air.
(P.K. Leung, Env. Can.) A joint study by Environment Canada and EPA
will be beginning in September. From this study, we may be able to
determine where dioxin is formed in the process. EPA's Combustion
Facility in Cincinnati, Ohio, is also conducting a theoretical study on the
mechanics of dioxin formation in combustion sources.
(V. Ozvacic, ON Min. of Env.) Lab and plant studies at the University
of Waterloo in Germany show that dioxin can be formed from the
precursors at intermediate temperatures between 200° and 500° C when
stack gases are not sufficiently cooled. At the Prince Edward Island
facility's secondary chamber, on the inlet to the boiler, there were
significant dioxin emissions coming out of the boiler. Silica on the fly
ash may be promoting the growth or the coupling of various chemicals
into dioxin formation. Also, pyrolysis was noted on the inlet to the
boiler. This pyrolysis could have given rise to dioxin formation in the
boiler. Maybe the temperature were too high. Again, scrubbers can
remove dioxin formed in the heat recovery system. But then you have
them in your lime, in your baghouse catch, or in the liquid.
88
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SESSION HI: SOURCE DATA AND STACK TESTING
SUMMARY OF DISCUSSION (BALTIMORE)
Q: There is evidence in the literature that bis-chloromethyl ether (BCME),
a potent carcinogen, may be formed in poorly performing incinerators as
a reaction product of aldehydes and HC1. Has BCME been sought in
tests? Secondly, have chlorobenzenes been sought? They are associated
with PVC in the waste and may be good dioxin surrogates. There is
evidence that if chlorobenzenes are destroyed, dioxins will not be a
problem.
A: (G. Yee, CARS) These compounds have not been sought. However,
California data reported high benzene concentrations, possibly due to
xylene. Xylene is used commonly in hospitals, and during combustion is
transformed into benzenes. Using chlorobenzenes as an indicator, as has
been proposed by EPA, can be misleading for overall assessment. Only
good basic design and combustion can assure clean operation.
Q: Can an emission or concentration limit for CO be used as a surrogate for
THC?
A: (V. Ozvacic, ON Min. of Env.) Ontario has a 100 ppm THC standard,
but THC can be hard to measure. CO monitoring is favored because of
its simplicity and reliability.
Q: What are the sources of Hg emissions?
A: (V. Ozvacic, ON Min. of Env.) It is difficult to determine. Perhaps
batteries are a major contributor. Agencies may want to consider
requiring hospitals to separate batteries from other waste.
Q: Some agencies are advocating higher retention times in the secondary
chamber. Do the data justify doubling the time (from 1 to 2 seconds) or
are these "seat of the pants" judgments?
A: (V. Ozvacic, ON Min. of Env.) Two seconds at 1000° C are needed to
destroy dioxins, which are the main concern. Thermodynamically, dioxin
should not exist above 500-600° C., but silica formed in fly ash may
catalyze dioxin formation. Municipal incinerator data indicate that
1 second is not long enough.
(G. Yee, CARB) These parameters should not be defined as standards,
but only as "Time-Temperature-Turbulence" design criteria.
(P.K. Leung, Env. Can.) The University of Dayton is conducting a study
along these lines to improve understanding of combustion. For
information contact EPA in Cincinnati.
Q: Even if organics are destroyed by suitable time-temperature conditions,
they may recombine as the gases cool (especially in a heat-recovery
boiler) and form dioxins. To eliminate this possibility, New York will
require a residence time standard plus a very low HC1 limit.
89
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90
-------
SESSION IV
TOPICS OF SPECIAL CONCERN:
PATHOGEN SURVIVAL, RISK ASSESSMENTS, AND REGIONAL FACILITIES
91
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92
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POTENT IRL RISK POSED BV HOSPITRL INCINERATORS IN NEW JERSEY
by
Joann L. Held
Neui Jersey Department of Enuironmental Protection
Trenton, New Jersey
presented at
Hospital Infectious Waste Incineration and Hospital Sterilization
Workshops
Son Francisco - May 10,1988
Baltimore - May 24,1988
Summary
One objectiue of the New Jersey air toHics program is to
identify source categories which pose potentially unacceptable risk
and then deuelop state-of-the art yuidelines for these sources. If
necessary, regulations will be written to address enlstlng sources.
One source category that has already received some attention Is
hospital incinerators - both new and existing, fl simple risk eualuatlon
of three eHisting incinerators has been done using emission factors
developed for incinerators In California and Canada. The preliminary
results indicate that diOHin and hydrogen chloride emissions from
these Incinerators may be of concern, although they do not pose an
immediate hazard.
NEW JERSEY INCINERATORS
Four hospitals In the northeast portion of the state were
identified for a preliminary assessment of the risk posed by hospital
incinerators. These incinerators were:
Location Feed Rate
St. Michaels Medical Center Newark 430 Ib/hr
Montclair Community Hospital Montclair 30 Ib/hr
Iruington General Hospital Iruington 25 Ib/hr
Beth Israel Hospital Passaic 1 Ib/hr
None of these incinerators is equipped with controls. Combustion
93
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chamber temperatures ranging from 1500 to 2300 F.
EMISSION FACTORS
Since no stack test Information Is auailable for the New Jersey
incinerators, stack tests for similar facilities were sought. Two sets
of data were Identified.
1. F.C. Powell, 1987, "flir Pollutant Emissions from the Incineration of
Hospital Wastes: The fllberta Enperience." JflPCfl. 37. PP. 836-839.
This report describes test results from 14 hospital incinerators
In the Prouince of fllberta. Ten of these units were uncontrolled. The
feed rate ranged from 85 to 2500 Ib/hr. Hydrogen chloride (HCI) and
particulate emissions are reported.
2. USEPfl, 1987, "Hospital Waste Combustion Study: Data Gathering
Phase." Final draft report, EPfl Contract No. 68-02-4330.
Section 3.2 of this report contains test data from four large
hospital incinerators (two in California, one In British Columbia, and
one In Illinois). It also contains a summary of the Powell paper
described aboue. The feed rate for these large incinerators ranged
from 800 to 2200 Ib/hr. Three units are uncontrolled, although both
controlled and uncontrolled emissions are reported for the fourth unit.
The following emissions are reported:
HCI, S02, NOH, CO, Total Particulate
fit, Cd, Cr, Fe, Mn, Ni, Pb
Total HC, Low molecular weight organics (8 species)
Tetra, Penta, HOMO, Hepta, Octa and Total PCOO
Tetra, Penta, Heiia, Hepta, Octa and Total PCOF
Emission factors for this exercise were chosen on the basis of
unit size (represented by feed rate) wheneuer possible. The Beth
Israel Hospital Incinerator was dropped from the analysis because
none of the stack test reports were for such small units. The HCI and
particulate emission factors from twelve fllberta incinerators were
used because these particular incinerators were in about the same
size range as the New Jersey incinerators, with feed rates of 85 to
740 Ib/hr (compared to the three larger New Jersey incinerators
which haue feed rates of 25 to 430 Ib/hr). For the remaining
pollutants the factors reported by EPfl for the two California units and
the unit in British Columbia were used since no other data were
94
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readily available. The information on the Illinois incinerator was
Inadequate for use in this study.
Hydrogen Chloride and Particulate Emission Factors
The emission factors used for this eualuatlon are reported
below.
Contaminant (Ib/Ton) Source
HCI 14.6- 99.4 12fllbertal)nits
Particulate 1.69 - 36.49 12 fllberta Units
fl range of factors mas used because there was no clear trend
between specific particulate and HCI emission rates and unit size. In
fact, the highest particulate emissions were associated with the
smallest units.
Metal Emission Factors
The following emission factors were used.
Contaminant (Ib/Ton) Source
flrsenic 3E-4 2 Calif. +
Cadmium 68E-4 2 Calif. +
Chromium 20E-4 2 Calif. +
Iron 183E-4 2 Calif. +
Lead 580E-4 2 Calif. +
Manganese 11E-4 2 Calif. +
Nickel 5E-4 2 Calif. +
B.C. Units
B.C. Units
B.C. Units
B.C. Units
B.C. Units
B.C. Units
B.C. Units
These factors are the highest reported for the two California units and
the unit In British Columbia. The highest value was chosen because
the highest particulate emissions were associated with the smallest
units and the New Jersey units are generally much smaller than these
three units. It is very likely that the emissions for the New Jersey
units are higher than estimated here.
BlQHin and Furan Emission Factors
Rs a first estimate of the risk posed by these incinerators, only
the emissions of the Tetra homologue group of dioHins was used. The
highest emission factor for TCOO was 2.07E-6 Ib/Ton. In a follow-up
95
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study, other homologues and the furons may be eualuated.
Uolatile Organic Compound fUOCl Emission Factors
Total hydrocarbons were measured but only eight low molecular
weight orgonics were speciated in the California stack tests. The
eight orgonics were ethane, ethylene, propane, propylene,
trichlorotrlfluoroethane, tetrochloromethone, trlchloroethylene and
perchloroethylene. Risk factors were only auailable for the last two
substances, so they were the only UOCs Included In the analysis. The
emission factors were:
Contaminant Ob/Ton) Source
Perchloroethylene 2.5E-4 2 California Units
Trichloroethylene 2.4E-5 2 California Units
Criteria Pollutant Emission Factors
Emission factors were also auailable for sulfur dloHlde,
nitrogen oHides, and carbon monoHlde. fill of the emissions were low,
in fact .the carbon monoHlde emissions were below the detection limit
(50 ppmu for these tests). Howeuer, these emissions were still
euoluated because they may serve as a useful frame of reference
when comparing hospital incinerators to other types of combustion
sources. The emission factors used were:
Contaminant (Ib/Ton) Source
S02 3.01 2 California Units
NOH 7.82 2 California Units
CO <1.7 2 California Units
THE CALCULATIONS
Estimating Emission Aates
Emission rates for the 15 substances considered In this
eualuatlon were calculated for each of the three New Jersey
Incinerators using the following formula:
Emission Aate (Ib/hr) - Feed Aate (Ib/hr) H Emission Factor (Ib/ton)
-2000
96
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Dispersion Modeling
The Industrial Source Complen (ISC) model was used to predict
maximum 1-hour, 24-hour and annual auerage ground leuel
concentrations. Newark meteorological data were used along with
urban dispersion coefficients. No downwosh analysis was performed
since plot plans were not ouailable for these hospitals. Because the
stacks inuolued are relatiuely short, downwash Is likely to cause
higher ground leuel concentrations than predicted by the model.
The potential ambient impacts are summarized below, flnnual
auerage concentrations are reported for carcinogens and for criteria
pollutants with annual or quarterly standards. MaHimum 24-hour
concentrations are reported for substances which haue
non-carcinogenic health effects associated with chronic or
sub-chronic etiposure. MaHimum 1-hour concentrations are reported
for substances with known aduerse health effects associated with
acute exposure to ambient concentrations.
LONG-TERM EHPOSURE TO CRRCINOGENS
Rnnual Ruerage Concentration (ug/m3)
Contaminant Montclalr Irulngton St. Michaels
flrsenic 9.0E-6 4.1E-6 2.7E-6
Cadmium 2.0E-4 9.4E-5 6.5E-5
Chromium 6.0E-5 2.8E-5 1.8E-5
Nickel 1.5E-5 6.8E-6 4.7E-6
Perchloroethylene 7.4E-6 3.4E-6 2.3E-6
Trichloroethylene 7.2E-7 3.3E-7 2.2E-7
TCDD 6.2E-8 2.9E-8 1.9E-8
CHRONIC EHPOSURE TO NON-CRRCINOGENS
MaHimum 24-Hr Concentration (ug/m3)
Contaminant Montclair Irulngton St. Michaels
Iron 0.006 0.002 0.002
Manganese 0.0004 0.0001 0.0001
Perchloroethylene 8.2E-5 3.0E-5 2.2E-5
Trichloroethylene 7.9E-6 2.8E-6 2.0E-6
97
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Contaminant
Partlculate
Sulfur DioHide
Nitrogen OHides
Lead
Contaminant
Particulate
Sulfur DioHide
Lead
EHPOSURE TO CRITERIA POLLUTANTS
flnnual Ruerage Concentration (ug/rn3)
MontcloJr Iruington St. Michaels
0.06-1.1 0.02-0.51 0.02-0.34
0.10 0.04 0.03
0.24 0.11 0.07
1.7E-3 O.OE-4 5.2E-4
*
MaHlmum 24-Hr Concentration (ug/m9)
Montclair Iruington St. Michaels
0.67-12.2 0.19-4.4 0.14-3.1
1.1 0.30 0.26
0.019 0.007 . 0.005
Contaminant
HCI
Nitrogen OHides
flCUTE EHPOSURE ESTIMATES
MaHlmum 1-Hr Concentration (ug/m3)
Montclair Iruington St. Michaels
13.2-09.7 3.1-21.1 2.0-19.3
7.2 1.7 1.5
Carbon MonoHlde < 1.0
RISK EUflLUflTION
<0.3
<0.3
The enposure estimates described aboue were compared to
auailable standards, guidelines and other reference numbers. These
are described below.
Carcinogens
Using unit risk factors derlued by the USEPR Carcinogen
Assessment Group from the 95% upper-bound of the risk model, the
following range of risk was calculated. The unit risks represent the
incremental risk associated with a life-time etiposure to 1 ug/m3 of
the contaminant.
Contaminant
Arsenic
Cadmium
Chromium
Nickel
Unit Risk
4.3E-3
3.5E-3
1.2E-2
4.QE-4
Range of Calculated Risk
1.2E-0 to3.9E-0
2.3E-7 to 7.0E-7
2.2E-7 to7.2E-7
2.3E-9 to7.2E-9
98
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Contaminant Unit Risk Range of Calculated Risk
Perchloroethylene 4.1E-6 9.E-13 to3.E-12
Trlchloroethylene 1.4E-5 3.E-11 to 1 .E-10
TCOO 3.3E+1 6.3E-7 to 2.0E-6
Of these seven carcinogens, only TCDD exceeds one in a million risk.
Houieuer, the particulate emission factors may be low and if future
tests show that the cadmium and chromium emissions are higher than
estimated, then the incremental risk for these two metals may also
exceed one In a million.
Hydrogen Chloride
The moHimum predicted ambient one-hour concentration of HCI is
90 ug/m3. This Is uery close to the odor threshold for HCI which has
been reported to be as low as 98 ug/m3. Stinging and burning
sensation In the eyes has been reported at about 4200 ug/m3. The
moHimum short-term concentration for the three New Jersey
Incinerators is only about 2% of this effect level. These two reference
values seem to indicate that emissions of HCI from hospital
incinerators require further investigation.
Criteria Pollutants
The moHimum estimated concentrations of the criteria pollutants
are generally less than or equal to 1% of the associated National
Rmbient Rlr Quality Standards (NflflQS), with the eHception of the 24-hr
concentration of particulate. The moHimum estimated 24-hour
concentration of 12.2 ug/m3 is about 5% of the old NflflQS for Total
Suspended Particulate (260 ug/m3). If it is assumed that all of the
particulate matter is inflatable, then the particulate concentration
rises to 0% of the PM-10 standard (150 ug/m3).
Non-criteria Pollutants
Reference doses for chronic etiposure to iron, manganese,
perchloroethylene and trlchloroethylene are not readily available.
However, the predicted concentrations are so low - less than 0.01
ug/m3 - that It Is unlikely that there are adverse health consequences
associated with these emissions.
99
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PATHOGEN SURVIVAL AT HOSPITAL/INFECTIOUS WASTE INCINERATORS
Presented at:
Hospital/Infectious Waste Incineration and
Hospital Sterilization Workshops
San Francisco - Baltimore
May, 1988
Prepared by:
Steven Klafka, Environmental Engineer
Michael Tlerney, Environmental Engineer
Bureau of A1r Management
Wisconsin Department of Natural Resources
101
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INTRODUCTION
In Hlsconsln, air pollution control permits are Issued for Infectious waste
Incinerators by the Department of Natural Resources (WDNR), Bureau of Air
Management. Since February of 1988 new solid waste rules have eliminated the
need for a solid waste license to be Issued to Incinerator operators. As a
result, the review of the air permit applications have addressed what might
typically be considered a solid waste management Issue - the release of
Infectious pathogens during Incinerator operations.
SOURCES OF PATHOGENS
The release of Infectious organisms from blomedlcal solid waste Incinerator
operations could potentially occur at three locations:
1. During waste transport and handling operations,
2. From the Incinerator stack, or
3. From the residual ash.
DEFINITION OF INFECTIOUS HASTE
The factors needed to transmit an Infectious disease Include the following1:
Presence In the waste
Virulence or strength
Portal of entry
Dose
Resistance of host
H1th consideration given to these factors, a preliminary 11st of medical
wastes to be treated as Infectious during facility permitting has been
developed by the Wisconsin DNR2. This 1s based In large degree on
recommendations by the Center for Disease Control and the U.S. EPA.1'*
Infectious wastes are defined under s. NR 500.03(67), W1s. Adm. Code, to be:"A
solid waste which contains pathogens with sufficient virulence and quantity so
that exposure to the waste by a susceptible host could result 1n an Infectious
disease".
Typical hospital and health care facility wastes which may be considered
Infectious are:
1. Microbiological laboratory wastes Including cultures and equipment which
has come In contact with cultures of Infectious agents;
2. Blood, blood products and bodily fluids Including those from dialysis
units;
3. Sharps Including needles and laboratory glass wastes;
4. Surgical, autopsy and obstetrical wastes which have had contact with
patient blood or body fluids;
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5. Wastes which have had contact with patients 1n communicable disease
Isolation; and
6. Human and animal tissue containing pathogens with sufficient virulence and
quantity so that exposure to the waste by a susceptible human host could
result In an Infectious disease.
Hospitals, clinics and nursing homes handle wastes In-house on the assumption
that disease can be transmitted to staff and other patients.6'7'8 It would
be Inconsistent not to extend similar precautions to protect solid waste
handlers and the community at large. Once this premise is accepted it becomes
a question of to what degree can solid waste be segregated to reduce or
eliminate infectious waste. The problem is complicated, since some categories
of Infectious waste, such as needles, bandages, even I.V. and bodily fluid
collection apparatus are found In municipal solid waste as a result of their
use tn home care practices. Large portions of Infectious hospital wastes,
such as patient isolation wastes, are Identical in appearance to nonlnfectlous
gene'ral wastes. Obviously, separation of much of the potentially Infectious
waste requires cooperation-with medical care establishments to establish
standards as opposed to a typical industry/regulatory enforcement approach.
There appear to be few people 1n regulatory environmental agencies or
consulting firms with backgrounds In microbiology or related para-medical
areas. This results 1n a lack of perspective on the infection process or how
diseases are transmitted. One example Is that It can be accurately stated
that Infectious wastes contain fewer microorganisms than municipal wastes.8
While true, this statement Ignores the fact that we live in a sea of
microorganisms that are present in our soil, food; and the external and
Interior potions of our bodies.6 The potential to cause disease Is a
qualitative property of microorganisms more than a quantitative property.
Some of .the waste categories designated as infectious would be more properly
called "potentially infectious." For example, preserved pathological tissue
1s designated for Incineration from an aesthetic sense than infectious disease
concerns. Overall It should be recognized that the designation of Infectious
and nonlnfectlous waste 1s a relative term. Establishing the six categories
as Infectious waste, controls what we believe are the most likely wastes to
contain quantities of Infectious organisms. However, It cannot be stated that
other hospital wastes or municipal wastes will not contain infectious
organisms.
RELEASE OF PATHOGENS DURING WASTE TRANSPORT AND STORAGE
Transmission of disease from infectious waste could potentially occur, through
needle sticks, spills, Inhalation of aerosols and dust and ingestlon of
infectious agents.3>7>8 The incidence of hepatitis B among medical care
workers may be an Indicator that this disease could be spread by careless
handling of Infectious waste. However, there Is no epidemiologlc evidence
that Infectious waste disposal practices have caused disease in the
community.4'6'7
Prudent disposal practices include the use of containers which avoid injuries
from sharps or spills of bodily fluids, and keeping all infectious wastes
enclosed before treatment. The use of hard containers for sharps and the
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bagging and boxing of wastes has become a common practice for wastes
transported to off-site Infectious waste Incinerators. The additional use of
refrigeration for waste transport or storage 1s an unresolved Issue, since the
need for refrigeration Is a variable related to the amount of materials that
can blodegrade within the Infectious waste component.
RELEASE OF PATHOGENS FROM INCINERATOR STACKS
Most stack, tests on Infectious waste Incinerators confirm that under good
operating conditions waste pathogens are not released from the
stack.10'"'12'13 However, stack testing for destruction of biological
Indicators In pathological Incinerators has been limited or unpublished. The
series of Incinerator stack tests dating from the 1960s through the 1970s by
Manuel S. Barbel to, et al, used highly temperature resistant bacterial spore
forms to establish the effectiveness of Incineration In destroying biological
organisms. These nonpathogenlc bacteria (Bacillus sp.) spore forms have
traditionally been used to test the effectiveness of steam and gas sterilizers
since they represent the most temperature (and perhaps chemical) resistant
life forms among microorganisms. The most cited research Is from the Barbel to
and Shapiro paper from 1977 where they concluded that a minimum exposure to
1,400'F 1n the primary and 1,600°F In the secondary was necessary to assure
destruction of the test spores. The Incinerator tested provided a total of
1.2 seconds of exposure, but this recommendation didn't address residence
times, only temperature, and was followed by a recommendation to stack test
each new Incinerator with spores.11
H1scons In ONR Infectious waste Incineration guidelines have concluded that
control of the physical design parameters at 1,800'F with a minimum secondary
temperature of 2 seconds provides ample safety to assure total destruction of
biologicals. However, this Department Is following with Interest, current
spore stack testing of blomedlcal waste Incinerators by the Ontario Ministry
of Environment and proposed testing 1n California by the California A1r
Resources Board (CARB). Me feel these tests are useful to further confirm the
safety of design parameters of Infectious waste Incinerators, but we do not
feel routine stack testing with spores Is a necessary precaution. It should
also be remembered that spore testing, while traditional and useful, 1s
conservative representing a much more highly temperature resistant life form
than the vast majority of Infectious agents that are nonspore formers. Viral
agents like hepatitis B and the AIDS virus HIV are fragile organisms difficult
to even maintain in the laboratory and are easily destroyed by the adverse
temperatures encountered In an Incinerator.
RELEASE OF PATHOGENS FROM INCINERATOR ASH
During poor operating conditions, pathogens In municipal waste have been shown
to survive the Incineration process. Good burnout of Infectious waste is
needed to encourage complete destruction of waste pathogens.'4 In this
case, the use of ash quality requirements for Incinerators may be
appropriate. Such requirements may Include that there be no visible
combustibles In the ash or a maximum fixed carbon content not be exceeded
(I.e., 5 percent, by weight)2. This requires that close attention be given
to not overcharging the incinerator.
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1 U.S. EPA, EPA Guide for Infectious Waste Management, p.2-1, May, 1986.
2 Wisconsin Department of Natural Resources, Bureau of Air Management, Draft
Guidelines for Infectious Waste Incinerators, April 22, 1988.
3 Gordon, J., Forum: Infectious Waste - A Growing Problem for Infection
Control, ASEPSIS - The Infection Control Forum, Vol. 9, No. 4.
4 Rutala, W., Forum: Infectious Waste - A Growing Problem for Infection
Control, ASEPSIS - The Infection Control Forum, Vol. 9, No. 4.
5 Rutala, W., Sarubbi, F.,: Management of Infectious Waste from Hospitals,
Infection Control, p. 198-204, 1983, Vol. 4, No. 4.
6 CDC, Guidelines for Handwashlng and Hospital Environmental Control, 1985.
7 CDC, Recommendations for Prevention of HIV Transmission in Health Care
Settings. MMWR Supplement, August 21, 1987, Vol. 36, No. 2S.
8 Department of Labor/Department of Health and Human Services, Joint
Advisory Notice on Protection Against Occupational Exposure to Hepatitis B
Virus (HBV) and Human Immune Deficiency Virus (HIV). October 19, 1987.
' Kalnowskl, G., Wlegand, H., Ruden, Hennlng: 'On the Microblal
Contamination of Hospital Waste. Zentralblatt fuer Bacteriologic,
Microbiologic, und Hygine (West Germany) 1983, pages 364-379.
10 Kelly, N., Allen, R., Brenniman, G., Kusek, J.,: An Evaluation of
Bacterial Emissions from a Hospital Incinerator, Proceedings Vlth World
Congress on Air Quality, 16-20 May 1983, Paris, France, Vol.2, May 1983,
pages 227-232.
" Barbeito, M., Gremillion, G., Microbiological Safety Evaluation of an
Industrial Refuse Incinerator, Applied Microbiology, p. 291-295, Feb., 1968.
12 Barbeito, M., Shapiro, M., Microbiological Safety Evaluation of a Solid
and Liquid Pathological Incinerator, Journal of Medical Primatology,
6:264-273, 1977.
13 Barbeito, M., Taylor, L., Seiders, R., Microbiological Evaluation of a
Large-Volume Air Incinerator, p. 490-495, Applied Microbiology, March 1968,
Vol. 16, No. 3.
14 Peterson M., Stutzenberger F.,: Microbiological Evaluation of Incinerator
Operations. Applied Microbiology, July 1969, Vol. 18, No. 1, pages 813.
7447M
105
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STATE OF WISCONS
DATE: April 22, 1988 FILE REF: 4530
TO: Donald Theiler - AM/3
FROM: Michael Tierney -
Steven Klafka - AM/3
SUBJECT: Design and Operating Guidelines for Infectious Waste Incinerators
At the January meeting of the Natural Resources Board there was considerable
discussion on the issue of solid waste incineration, including the burning of
infectious hospital wastes. Afterwards, we were instructed to develop design
and operation guidelines for new hospital waste incinerators. These
guidelines would address the handling of infectious waste, emissions control
and operator training. Subsequently, the proposed rules controlling hazardous
air pollutants (Chapter NK 445, Wis. Adm. Code) were amended to require both
new and existing infectious waste incinerators to control emissions of Table 3
known and suspected human carcinogens to the level which is lowest achievable
emission rate, or LAER.
Attacned are guidelines for the design and operation of infectious waste
incinerators. These guidelines define LAER for Table 3 pollutants associated
with the incineration of infectious wastes from hospitals and other health
care facilities such as nursing homes and medical clinics. These guidelines
also define infectious wastes, address proper waste and ash handling
procedures, specify incinerator monitoring and testing requirements, and
recommend operator training requirements.
Within the guidelines, lowest achievable emission rates for the Table 3
pollutants is expected if the recommendations are followed under B.
Incinerator Design and Operation and F. Air Pollution Control Requirements.
The organic compounds listed in Table 3 are reduced the greatest by good waste
combustion. Minimum operating temperature and combustion gas residence time
are specified. Solid phase pollutants and residual organic compounds listed
in Table 3 are further controlled by particulate (TSP) control equipment and
flue gas scrubbing equipment for hydrogen chloride (HC1).
The design and emission control requirements for large incinerators (i.e.,
1,000 pounds per hour capacity or greater) are similar to those expected of
new municipal waste incinerators. Under the proposed rules, municipal
incinerators are also required to achieve LAER. The emission control
technologies likely to achieve emission limitations specified for TSP and HC1
are fabric filter baghouses in combination with dry or wet scrubbing, or steam
injection wet scrubbers and potentially, high pressure drop venturi
scrubbers. Medium sized incinerators (i.e., 200 to 1,000 pounds per hour
capacity) would likely use venturi/packed bed wet scrubbers. Small
incinerators do not require control equipment since it has yet to be proven
feasible.
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Donald Theiler - AM/3 - April 22, 1988
The design and associated emissions of infectious waste incineration
facilities has only recently come under close scrutiny. Few facilities have
emissions control equipment or have had extensive testing for hazardous air
pollutants. This is especially true for small, batch feed systems under
200 pounds per hour in capacity. These LAER guidelines are based upon the
information on existing incinerators we were able to obtain from other states,
U.S. EPA, Canada, incinerator vendors and designers. As further information
comes available, these guidelines will need to be updated. In the meantime,
we obtained no information which indicates that these requirements are not
achievable.
It should be noted that the design guidelines are directed primarily at the
traditional two stage starved-air hospital waste incinerators. This does not
preclude the use of rotary kiln combustors or municipal waste incinerators to
burn infectious waste.
MT:SK:sb/3197E
cc: J. Rickun - AM/3
D. Packard - AM/3
P. Didier - SW/3
R. Renaud - SW/3
107
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Wisconsin Department of Natural Resources
Bureau of Air Management
Draft Guidelines
for Infectious Waste Incinerators
April 22, 1988
The following guidelines are for incinerators used to treat infectious
wastes. These guidelines are intended to minimize the potential for adverse
public health and environmental impacts due to improper waste handling,
excessive stack emissions or improper ash management. Requirements for
incinerator design and operation, and air pollution control are established in
order to achieve the lowest achievable emission rate for stack pollutants of
concern. These guidelines apply to infectious waste incinerators of all sizes.
Issues addressed in these guidelines include:
A. Definition of Infectious Wastes
B. Incinerator Design and Operation
C. Ash Handling and Quality
D. Stack Design
E. Waste Handling Procedures
F. Air Pollution Control Requirements
G. Performance Monitoring and Testing
H. Operator Qualifications
A. Definition of Infectious Wastes
Infectious wastes are defined under s. NR 500.03(67), Wis. Adm. Code, to
be: "A solid waste which contains pathogens with sufficient virulence and
quantity so that exposure to the waste by a susceptible host could result
in an infectious disease".
Typical hospital and health care facility wastes which may be considered
infectious are:
1. Microbiological laboratory wastes including cultures and equipment
which has come in contact with cultures of infectious agents;
2. Blood, blood products and bodily fluids including those from dialysis
units;
3. Sharps including needles, laboratory glass wastes and glass pipets;
4. Surgical, autopsy and obstetrical wastes which have had contact with
patient blood or body fluids;
5. Wastes which have had contact with communicable disease isolation
wastes; and
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6. Human and animal tissue containing pathogens with sufficient
virulence and quantity so that exposure to the waste by a susceptible
human host could result in an infectious disease.
*
Incinerator Design and Operation
1. Waste Charging
The waste charging system of any infectious waste incinerator shall
be designed so large amounts of air cannot enter the furnace and
disrupt the combustion process as waste is charged. This may include
a lockout mechanism on batch fed units to prevent charging after
start-up, or a ram feed system equipped with a closing and virtually
air tight lid.
2. Auxiliary Burners
a. The primary waste burning chamber or zone shall be equipped with
an adequately sized auxiliary fuel burner to:
1) Ignite waste in a batch fed unit;
2} Preheat the chamber up to operating temperatures on a
continuously fed unit; and
3) Maintain minimum chamber temperatures while wastes are
burned.
b. Any secondary combustion chamber or combustion zone shall be
equipped with an .adequately sized auxiliary fuel burner to
maintain required combustion temperatures.
3. Residence Times and Operating Temperatures
All infectious waste incinerators shall be equipped with a secondary
combustion chamber or combustion zone which provides for a minimum of
two seconds residence time at 1800°F or greater after turbulent
mixing with secondary combustion air to minimize trace organic and
visible emissions.
4. Start-Up Procedures
a. Batch fed infectious waste incinerators shall be designed and
operated so that during start-up:
1) Precautions are taken to avoid charging the incinerator
above its capacity;
2) The waste is ignited with an auxiliary fuel burner;
3) The secondary combustion chamber or combustion zone is
preheated to at least 1800°F before waste ignition;
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4) There is no further waste charging after waste ignition;
5) There is an automatic lockout of the charge door after the
waste is.ignited to allow for sufficient time to allow
complete burnout of the waste.
b. Continuous feed infectious waste incinerators shall be designed
and operated so that during start-up:
1) The primary waste burning chamber is brought up to the
operating temperature prior to charging waste;
2) The secondary combustion chamber or combustion zone is
preheated to at least 1800°F; and
3) There is an automatic lockout mechanism which prevents
charging if primary or secondary combustion chamber or
combustion zone temperatures fall below design levels.
5. Shutdown Procedures
Every incinerator shall be designed so that during shutdown the
secondary combustion chamber or combustion zone temperature is
maintained above 180Q°F until the waste is completely burned.
C. Ash Handling and Quality
1. Ash Handling
All ash removal from the incinerator shall occur in an enclosed
area. There.shall be no visible emissions to the outside air when
ash is removed from the facility or during transport to the ash
disposal site. Ash shall be completely enclosed during transport.
2. Ash Quality
All incinerated waste shall be "completely burned" per Sec. NR
506.11, Wis. Adm. Code, such that the fixed carbon content does not
exceed 5%, by weight, by proximate analysis, and there are no visible
unburned combustibles.
D. Stack Design
1. Stack Height
All incinerator stacks shall be located and of sufficient height to
assure compliance with applicable air standards, and to avoid the
flow of stack pollutants into any building ventilation intake plenum.
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2. Emergency (Dump) Stack
Any stack which emits incinerator pollutants prior to the air
pollution control shall not be used when waste is burning, except ts
protect the air pollution control equipment during unavoidable
malfunctions.
E. Waste Handling Procedures
1. Any waste designated as infectious waste under these guidelines, if
delivered to an incinerator from another facility, shall be double
bagged in red plastic bags and boxed in leak-proof corrugated
cardboard. The outside container should be labelled with a visible
biohazard emblem. Packaging integrity must be maintained until
burning.
A single bag which meets the ASTM 165 gram dart drop test
(Method D-1709-75) may be substituted for the double bags. Rigid
reusable leak-proof containers may be substituted for the cardboard
boxes.
Sharps shall be transported in puncture-proof containers.
2. All infectious waste containers transported to another facility shall
be enclosed in vehicles.
3. Any infectious waste transported to the incinerator from another
facility shall be refrigerated below 42°F if the time between
packaging and burning exceeds 92 hours.
4. All carts and reusable equipment used for transporting infectious
waste shall be steam cleaned after each use. Water drained from
these operations shall be disposed of in a sanitary sewer.
5. No infectious waste shall be stored outside where it is exposed to
the elements or accessible to the general public.
F. Air Pollution Control Requirements
1. Total Suspended Particulates (TSP)
a. All incinerators with a capacity of 1000 pounds per hour or
greater shall be equipped with control equipment to comply with
a TSP emission limitation of 0.01 grains per dry standard cubic
foot corrected to 7% Og, including condensible TSP.
b. All incinerators with a capacity of 200 pounds per hour or
greater shall be equipped with control equipment to comply with
a TSP emission limitation of 0.02 grains per dry standard cubic
foot corrected to 7% 02, including condensible TSP.
Ill
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c. All incinerators with a capacity less than 200 pounds per hour
and 4,800 pounds per day shall comply with a TSP emission
limitation of 0.06 grains per dry standard cubic foot corrected
to 7% 0£, including condensible TSP.
*
d. The inlet temperature to any particulate control equipment shall
not exceed 300° F.
2. Hydrogen Chloride (HC1) - All incinerators with a capacity of 2UO
pounds per hour or greater shall be equipped with control equipment
to comply with an HC1 emission limitation of 50 parts per million dry
volume corrected to 7% 03 over any continuous one hour period.
3. Carbon Monoxide (CU) -All incinerators shall not exceed a CU
emission limitation of 75 parts per million dry volume corrected to
7% Q£ over any continuous three hour period.
4. Stack Flue Gas Opacity - All incinerators with a capacity of
200 pounds per hour or greater shall not exceed 5% opacity as
measured by U.S. EPA Method 9.
G. Performance Monitoring and Testing
1. Temperature Monitoring - All incinerators shall be equipped to
continuously monitor and record representative operating temperatures
in the primary combustion chamber and the exit of the secondary
combustion chamber or combustion zone.
2. Stack Tests - Every incinerator shall be stack tested for TSP, HC1
and CO during the initial shakedown period after construction, and
every two years thereafter. These tests shall include a
determination of the emissions of Arsenic, Cadmium, Total Chromium,
Lead and Nickel.
3. Records shall be kept of the weight of waste charged to the
incinerator each day.
4. Ash Tests - During the shakedown period after construction there
shall be a verification of compliance with the burnout requirements
(visible combustibles) of s. NR 506.11, Wis. Adm. Code and ash
management requirements of s. NR 502.09, Wis. Adm. Code.
H. Operator Qualifications
1. A trained incinerator operator shall be present at the facility in
which an incinerator is located whenever waste is being burned.
2. Operator training shall include a program of study approved by the
Department prior to air permit issuance or renewal. This program
shall include:
a. Proper waste handling procedures;
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b. Identification of waste types acceptable for incineration;
c. Incinerator design and waste combustion theory;
d. Proper incinerator start-up, operation, shutdown, and
maintenance procedures;
e. Work safety procedures, including infectious disease control
procedures for the facility;
f. Applicable air pollution, solid waste, and wastewater management
regulations;
g. Air pollution control equipment operation and maintenance; and
h. A minimum of 24 hours of hands-on incinerator operation under
the supervision of another trained operator or the incinerator
manufacturer's representative.
3. Operator training shall include a review of incinerator operation and
maintenance procedures every year. This review shall last eight
hours or more and its content approved by the Department.
4. Every operator shall have visible proof of completion of the required
initial training and annual review posted near the incinerator
equipment.
3197E
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114
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HOSPITAL WASTE MANAGEMENT IN CANADA
David Campbell
Department of Environment
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
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SPEAKING NOTES
MR, CHAIRMAN, LADIES & GENTLEMEN,
AS STATED, MY TOPIC IS HOSPITAL WASTE MANAGEMENT IN
CANADA,
1 PLAN TO ADDRESS THIS SUBJECT BY GIVING A GENERAL
OVERVIEW OF 2 AREAS IN WHICH ENVIRONMENT CANADA IS
WORKING WITH THE PROVINCES IN THIS FIELD,,
THE 1ST AREA IS A STATE OF THE ART REPORT AND CODE OF
PRACTICE ON BlOMEDICAL WASTES.
THE 2ND AREA IS A HOSPITAL WASTE INCINERATOR TESTING
PROGRAM IN WHICH WE ARE PRESENTLY COMPLETING THE
FIRST PHASE,
BUT FIRST I PREFER TO START A SUBJECT SUCH AS THIS,
BY CENTERING DOWN ON WHERE THIS WASTE PROBLEM RELATES
TO THE OVERALL WASTE PROBLEM IN CANADA,
IF WE LOOK AT SLIDE 1,
SLIDE 1 WASTE GENERATION IN CANADA
THE QUANTITY OF BlOMEDICAL WASTES IS SMALL BUT IF ONE
CONSIDERS THAT THESE WASTES ARE GENERATED IN HEALTH
CARE FACILITIES, THEN THEIR IMPORTANCE FAR EXCEEDS
THEIR NUMBER,
-------
FROM THE POINT OF VIEW OF AN INCINERATOR ENGINEER WE
USED TO VIEW HOSPITAL WASTE IN 4 CATEGORIES:
(1) KITCHEN WASTES
(2) GENERAL WASTES (OFFICES, WAITING ROOMS, ETC,)
(3) ANATOMICAL WASTES (TISSUE)
(4) PATHOLOGICAL WASTES (INFECTIOUS WASTES)
BlOMEDICAL WASTES ARE COMPOSED OF THE LAST 2
CATEGORIES AND REPRESENT ABOUT -10% OF HOSPITAL
WASTES,
FROM A PRACTICAL POINT OF VIEW MANY HOSPITALS HAVE
DIFFICULTY EFFECTIVELY SEPARATING THESE WASTES SO
THAT BlOMEDICAL WASTES CAN CONTAIN A LOT OF NON-
_ INFECTIOUS WASTES,
IN 1986 ENVIRONMENT CANADA COMPLETED A STATE OF THE
ART REPORT ON BlOMEDICAL WASTES AND IN THE REPORT,
GENERATORS AND GENERATION RATES ARE COVERED,
SLIDES 2, 3 & 4 SHOW HOW HOSPITAL WASTES ARE
DETERMINED,
SLIDE 2 HOSPITAL DISTRIBUTION IN CANADA
SLIDE 3 HOSPITAL WASTE GENERATION RATES
SLIDE 4 BlOMEDICAL WASTE GENERATION IN CANADA
THESE TABLES REPRESENT HOW OUR DATA BASES ARE
OBTAINED,
IN SUMMARY THEN, WE ARE DEALING WITH 20,000
TONNES/YEAR OF BlOMEDICAL WASTE FROM HOSPITALS OR
APPROXIMATELY 10% OF WASTE GENERATED AT A HOSPITAL.
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THE STATE OF THE ART REPORT ALSO DEALS WITH CURRENT
MANAGEMENT PRACTICES IN CANADA,
THE AUTHORS HAD DIFFICULTY OBTAINING GOOD DATA IN
THIS AREA, BECAUSE MANY JURISDICTIONS INCLUDE
HOSPITAL WASTE IN WITH THE GENERAL WASTES,
HOWEVER, THERE ARE GOOD EGS, WITHIN REGIONS WHICH
PROVIDE US WITH A GOOD IDEA OF HOW THESE WASTES ARE
MANAGED,
IN THE PROVINCE OF ALBERTA A RECENT STUDY PROVIDED
DATA ON HOSPITAL WASTE MANAGEMENT WHICH IS SHOWN IN
SLIDE 5,
SLIDE 5 ALBERTA HOSPITAL WASTE SURVEY
THESE DATA POINT TO PRACTICES AND ATTITUDES TOWARDS
HOSPITAL WASTE MANAGEMENT THAT ARE WORTH NOTING,
FIRST, AUTOCLAVING, A SEEMING PANACEA FOR INFECTIOUS
WASTES IS VERY LITTLE USED.
SECOND, THERE is EXTENSIVE LANDFILLING OF BIOMEDICAL
WASTE,
ALTHOUGH ALL AREAS ARE NOT THE SAME IN CANADA, IN
GENERAL WE CAN EXPECT SIMILAR PRACTICES ACROSS THE
COUNTRY,
THE LAST SECTIONS OF THE REPORT COVER THE BEST
MANAGEMENT TECHNOLOGIES AND RECOMMENDATIONS, THESE
ARE CONSIDERED UNDER 4 HEADINGS AS SHOWN IN SLIDE 6.
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SLIDE 6 HOSPITAL WASTE WORKSHOP
UNDER THE FIRST HEADING - ON-SITE HANDLING,
THE VARIOUS PRACTICES WERE DISCUSSED FOR BAGGING AND
MOVING BlOMEDICAL WASTES WITHIN THE HOSPITAL
PERIMETER,
ALTHOUGH THERE ARE MANY IMPORTANT PRACTICES IN THIS
AREA, ONE NEED STOOD OUT,
THE NEED FOR COLOUR-CODED BAGS AS SHOWN IN SLIDE 7,
SLIDE 7 COLOUR CODING FOR BlOMEDICAL WASTE
COLOUR CODING OF BAGS is IMPORTANT BECAUSE IT WOULD
INCREASE SAFETY, PARTICULARLY IF THERE IS MORE
MOVEMENT TOWARDS REGIONAL INCINERATORS, WHICH•APPEARS
TO BE THE TREND,
THIS TREND WILL RESULT IN A GREATER NUMBER OF PEOPLE
HANDLING THE WASTES PRIOR TO DISPOSAL AND WILL
INCREASE THE RISK OF EXPOSURE,
IN ADDITION, AN ACCIDENT EN ROUTE COULD SPILL THESE
WASTES ON THE HIGHWAY AND EXPOSE CLEAN-UP CREWS TO
DANGERS,
THE USE OF COLOUR-CODED BAGS WOULD REDUCE THESE
DANGERS,
THE NEXT HEADING IS ON-SITE TREATMENT AND DISPOSAL,
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HERE, AUTOCLAVES, CHEMICAL DISINFECTION, IRRADIATION,
GRINDING AND INCINERATION WERE DISCUSSED,
THE NEEDS THAT WERE EXPRESSED IN THIS AREA WERE FOR:
1) AN AGREEMENT ON THE USE OF THE SANITARY SEWER
FOR DISPOSAL OF LIQUID BlOMEDICAL WASTES;
PRESENTLY, SOME JURISDICTIONS ALLOW DISCHARGE TO. THE
SEWER, WHILE OTHERS ARE NOW CALLING FOR DISINFECTION
PRIOR TO DISCHARGE,
2) AN AGREEMENT IS NEEDED ON THE USE OF THE "HOT
HEARTH" INCINERATORS FOR ANATOMICAL WASTES UNTIL
ALTERNATIVES ARE PROVEN SAFE,
SLIDE 8 HOT HEARTH INCINERATOR
SLIDE 9 COMPARISON OF TYPE 1 AND TYPE 4 WASTE
IN MOST JURISDICTIONS, THESE INCINERATORS CONTINUE TO
OPERATE, ALTHOUGH PROBLEMS HAVE ARISEN DUE TO THE
BURNING OF NON-ANATOMICAL WASTES IN "HOT HEARTH"
INCINERATORS,
ALSO, ANATOMICAL WASTES HAVE BEEN CHARGED DIRECTLY
INTO THE NEWER CONTROLLED-AIR INCINERATORS AND SO
FAR, THIS HAS NOT BEEN PROVEN SAFE,
SLIDE 10 CQNSUMAT UNIT
THE ROYAL JUBILEE HOSPITAL IN VICTORIA HAS A
CONTROLLED-AIR INCINERATOR RATED AT AROUND
2000 L3S/HR.
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IT WAS TESTED IN 1980 FOR BACTERIAL ACTIVITY IN THE
RESIDUE*- AFTER A TEST-BURN WHICH INCLUDED CHARGING
ANATOMICAL WASTES,
THE RESULTS OF FOUR TESTS WERE INCONCLUSIVE,
ALTHOUGH THE PRACTICE WAS NOT CONDONED, IT WAS NOT
REJECTED EITHER, BY THE DATA,
THEREFORE, THE NEED EXISTS TO FURTHER THESE STUDIES
TO DETERMINE IF THE CONTROLLED-AIR INCINERATOR CAN
SAFELY ACCOMMODATE BOTH ANATOMICAL AND PATHOLOGICAL
WASTES,
THE THIRD HEADING IS TRANSPORTATION OFF-SlTE.
CONSIDERABLE HEAT WAS GENERATED OVER WHETHER
INFECTIOUS WASTES WERE BEI-NG TRANSPORTED OFF-SITE FOR
DISPOSAL,
SOME PARTIES MAINTAINED THAT HOSPITALS DISINFECTED
ALL WASTES PRIOR TO TRANSPORT,
OTHERS REALIZED THAT THEY WERE BEING EXPORTED BECAUSE
THEY WERE INFECTIOUS WASTES.
IN ADDITION, THE DEFINITION OF BlOMEDICAL WASTE
VARIED FROM HOSPITAL TO HOSPITAL AND THEY DID NOT
DIRECTLY MESH WITH THE DEFINITION OF INFECTIOUS WASTE
UNDER THE TDGR.
AS A RESULT, TWO NEEDS EMERGED:
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1) THE NEED FOR A COMMON DEFINITION OF BlOMEDICAL
WASTES FOR HOSPITALS,
2) THE NEED TO ENSURE THAT BlOMEDICAL WASTES
TRANSPORTED OFF-SITE FOLLOW THE TDGR,
(THIS LATTER NEED IS NOW BEING MET AS
PATHOLOGICAL AND INFECTIOUS HOSPITAL WASTES ARE
BEING CONSIDERED FOR POSSIBLE INCLUSION AS A
"WASTE TYPE" IN THE AMENDMENTS TO THE TDGR),
THE FINAL HEADING IS OFF-SlTE TREATMENT AND DISPOSAL,
THE. THREE METHODS LANDFILL, SANITARY SEWER AND
REGIONAL INCINERATORS WERE REVIEWED AND DISCUSSED,
CONSIDERABLE CONTROVERSY SURROUNDS THE USE OF
LANDFILLS AND SANITARY SEWERS FOR THE DISPOSAL OF
BIOMEDICAL WASTES,
PROPONENTS ARGUE THAT PATHOGENS DO NOT SURVIVE MORE
THAN 24 HOURS IN A LANDFILL SITE AND THAT THERE IS NO
RECORDED INJURY FROM THIS PRACTICE,
CRITICS ARE EQUALLY ADAMENT THAT SCAVANGERS COULD
PICK UP INFECTIOUS MATERIALS BEFORE THEY ARE BURIED
AND ENDANGER THE PUBLIC,
BECAUSE OF THIS DEBATE, THERE is A NEED FOR
GUIDELINES ON THE PROPER USE OF LANDFILLS AND SEWERS
FOR BlOMEDICAL WASTES BACKED BY INFORMATION ON THE
SAFETY OF THESE PRACTICES,
122
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THE REGIONAL INCINERATOR DEBATE IS NO LESS HEATED,
THESE INCINERATORS WILL DIFFER FROM THE ON-SITE UNITS
IN THAT THEY WILL PROBABLY BE MUCH LARGER AND WILL
REPRESENT A POTENTIALLY SIGNIFICANT SOURCE OF
POLLUTANTS,
A COMPARISON OF HOSPITAL WASTES VS, MUNICIPAL WASTES
IS SHOWN IN SLIDE 11,
SLIDE 11 HOSPITAL VS MUNICIPAL WASTE
THE HIGH LEVEL OF PLASTICS, GENERATE HIGH EMISSION
LEVELS OF HYDROGEN CHLORIDE.
THEY WILL ALSO INCREASE THE. EMISSIONS OF DIOXINS AND
FURANS.
HOWEVER, THERE is VERY LITTLE DATA ON EMISSION RATES
FROM INCINERATORS WITH GAS-SCRUBBING EQUIPMENT,
THE ROYAL JUBILEE HOSPITAL IN VICTORIA (WHICH DOESN'T
HAVE SCRUBBERS) EMITTED HCX LEVELS AVERAGING 1200
PPM,
AND
THE DECOM INCINERATOR IN GATINEAU QUEBEC WAS ABOVE
700 PPM HCL, (IT DOESN'T HAVE SCRUBBERS EITHER),
PRESENT GUIDELINES ARE BETWEEN 100-500 PPM AND FUTURE
GUIDELINES WILL CALL FOR LEVELS WELL BELOW 100 PPM,
123
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THIS WILL MEAN THAT FUTURE HOSPITAL WASTE
INCINERATORS.WILL PROBABLY REQUIRE GAS SCRUBBERS,
ALSO DIOXIN AND FURAN LEVELS WERE ABOVE 200 NG/M3 AND
NEW STANDARDS ARE PROPOSING LEVELS AT ,50 NG/M^,
(TEF NEW INTERNATIONAL METHOD)
SLIDE 12 STACK DISCHARGE LIMITS
SLIDE 12 GIVES THE PROPOSED STACK DISCHARGE LIMITS
FOR MUNICIPAL WASTE INCINERATORS IN CANADA,
HAZARDOUS WASTE INCINERATORS WILL BE SIMILAR,
IN LINE WITH THESE NEW REGULATIONS WHAT WE WOULD LIKE
TO KNOW, AS A FORERUNNER TO THE NEW REGIONAL HOSPITAL
INCINERATORS, IS THE LEVELS OF DIOXIN AND FURAN FROM
THESE CONTROLLED-AIR INCINERATORS WITH GAS-SCRUBBING
EQUIPMENT,
THIS WILL ENABLE US TO BETTER DESIGN AND REGULATE
FUTURE INCINERATORS,
BASICALLY, THAT'S THE PROBLEM THAT WE ARE CONFRONTED
WITH, THE QUESTION THAT REMAINS TO BE ANSWERED IS
"WHAT ARE WE GOING TO DO ABOUT IT?"
SLIDE 13 GIVES A SUMMARY OF THESE NEEDS,
SLIDE 13 SUMMARY
THE FIRST THREE NEEDS SHOWN HERE ARE GOING TO BE MET
BY A NATIONAL CODE OF PRACTICE ON THE MANAGEMENT OF
BIOMEDICAL WASTES,
124
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TERMS OF REFERENCE FOR THIS CODE HAVE BEEN SUBMITTED
TO THE CANADIAN COUNCIL OF RESOURCE AND ENVIRONMENT
MINISTERS (CCREM) WASTE COMMITTEE AND A DECISION WILL
BE.TAKEN IN JUNE ON THE COURSE THAT THIS STUDY WILL
TAKE,
IT WILL EITHER BE COMPLETED BY ONE OF 2 WAYS,
THE FIRST INVOLVES DOING THE WORK IN-HOUSE BY
ENVIRONMENT CANADA, USING A POLICY STEERING GROUP
MADE UP OF MEMBERS FROM THE PROVINCES AND MEMBERS
FROM INSTITUTIONS SUCH AS THE CANADIAN HOSPITAL
ASSOCIATION,
THE SECOND METHOD WOULD ENTAIL EMPLOYING THE SERVICES
OF A STANDARDS ORGANIZATION, SUCH AS THE CANADIAN
STANDARDS ASSOCIATION, OR CSA AS IT'S COMMONLY KNOWN
TO ACT AS THE FACILITATOR IN PLACE OF ENVIRONMENT
CANADA,
THIS LATTER ROUTE TENDS TO BE FAVOURED BY GOVERNMENTS
SINCE AN INDEPENDENT THIRD PARTY FACILITATOR ALLOWS
EACH AGENCY TO EXPRESS ITSELF MORE FULLY WITHOUT
"STEPPII
AGENCY,
"STEPPING ON THE TOES" OF THE WORK OF A SISTER
HOWEVER, THAT AWAITS A DECISION WHICH WILL BE TAKEN
IN JUNE, THE NORMAL TIME PERIOD FOR THIS CODE TO SEE
THE LIGHT OF DAY WOULD BE 2 YEARS,
THE FOURTH NEED IS FOR ADDITIONAL INCINERATOR
PERFORMANCE DATA,
125
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IN THIS AREA WE ARE INVOLVED IN TWO PROJECTS, THE
FIRST IS THE TESTING OF THE DECOM INCINERATOR PLANT
IN GATINEAU QUEBEC,
HERE, ENVIRONMENT CANADA is ASSISTING QUEBEC IN
ANALYZING THE ORGANIC COMPONENT OF THE STACK SAMPLE
AS PART OF THE DECOM COMPLIANCE TEST,
DECOM BURNS BIOMEDICAL WASTE FROM THE U,S, (50%)
ONTARIO (40%) AND QUEBEC (10%),
THE INCINERATOR BEING TESTED IS A 600 KG/HR SlMONS
CONTROLLED-AIR INCINERATOR (SlMONS IS OUT OF
FLORIDA),
IT WAS MODIFIED TO INCLUDE A FLAKT DRY SCRUBBER AFTER
FAILING TO MEET QUEBEC'S EMISSIONS STANDARDS WITHOUT
A SCRUBBER.
THE RESULTS OF THESE TESTS WILL BE AVAILABLE BY THE
FALL OF THIS YEAR, AND WILL CONSIST OF THE DATA SHOWN
ON SLIDE 14,
SLIDE 14 DECQH EMISSION DATA
THE SECOND PROJECT IS THE OPTIMIZATION TESTING OF ONE
OF THREE INCINERATORS WHICH WE HAVE CLASSIFIED AS
REGIONAL INCINERATORS,
ALL OF THESE INCINERATORS HAVE CONTROL EQUIPMENT AND
ARE SHOWN ON SLIDE 15,
126
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SLIDE 15 INCINERATOR CANDIDATES
THE TESTS WILL DIFFER FROM THE NORMAL COMPLIANCE
TESTING IN THAT COMBUSTION CONDITIONS WILL BE VARIED
TO ACHIEVE OPTIMUM OPERATING CONDITIONS THAT MINIMIZE
POLLUTANT EMISSION LEVELS SIMILAR TO THE NITEP
TESTING PROGRAM,
A SUBMISSION HAS BEEN MADE FOR FUNDS TO COMPLETE THIS
WORK WHICH IS PROJECTED TO BEGIN AT THE END OF THIS
YEAR FOLLOWING COMPLETION OF THE GROUNDWORK,
SLIDE 16 CONCLUSION
SO IN SUMMARY, WE ARE LOOKING AT A 2-3 YEAR PERIOD IN
WHICH WE PLAN ON OBTAINING EMISSION DATA ON HOSPITAL
WASTE INCINERATORS WITH SCRUBBERS AND A NATIONALLY
ACCEPTED CODE OF PRACTICE ON THE HANDLING, TREATMENT
AND DISPOSAL OF BIOMEDICAL WASTES,
THAT CONCLUDES MY REMARKS ON HOSPITAL WASTE
MANAGEMENT IN CANADA,
127
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HOSPITAL VS MUNICIPAL WASTE
WASTE TYPE
1) DRY CELLULOSIC SOLIDS
2) WET CELLULOSIC SOLIDS
3) PLASTICS
4) RUBBER
5) NON-COMBUSTIBLES
6) PATHOLOGICAL
TOTAL
HEAT VALUE
HOSPITAL
MUNICIPAL
45.1
18.0
14.2
0.7
20.4
1.6
54.2
12.2
7.4
26.2
100%
6000 BTUS/LB
100%
4335 BTUS/LB
CONCLUSIONS
1) NATIONAL DEFINITION REQ'D
2) COLOUR CODING OF BAGS REQ'D
3) POLICY ON DISCHARGE TO LANDFILLS & SEWERS
4) ADDIT'L INCINERATOR PERFORMANCE DATA
135
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DECOM TESTING PROGRAM
ANALYSIS FOR DIOXINS, FURANS, RGBs, CHLOROBENZENES, CHLOROPHFNOLS AND
BENZO-A-PYRENE (AS A SURROGATE FOR POLYAROMATIC HYDROCARBONS).
SOURCE
PROCEDURE
No. OF SAMPLES
GAS
BOTTOM ASH
FLY ASH
QUENCH WATER
THREE MM5 SAMPLE TRAINS
ONE MM5 BLANK TRAIN
COMPOSITE OF SAMPLES TAKEN
DURING EACH TEST
COMPOSITE SAMPLE COLLECTED
DURING EACH TEST
SAMPLE COLLECTED DURING
EACH TEST
3 FILTER & RESIN (COMPOS
3 IMPINGERS
1 BLANK TRAIN (COMPOS.)
INCINERATOR CANDIDATES
NAME (LOCATION)
DECOM (GATINEAU,
QUEBEC)
FOOTHILLS (CALGARY,
ALBERTA)
UNIV. OF ALBERTA
HOSPITAL (EDMONTON,
ALBERTA)
TYPE
CONTINUOUS CHARGE
CONTROLLED AIR
CONTINUOUS CHARGE
CONTROLLED AIR
ROTARY KILN
AIR POLLUTION
CONTROL
BOILER & FLAKT
SCRUBBER
BOILER AND
SCRUBBER
BOILER AND
SCRUBBER
CAPACITY
(kg/h)
600
1135
2 x 600
tic
-------
CONCLUSIONS
1) COMPLIANCE TESTING OF DECOM INCINERATOR
2) OPTIMIZATION TESTING OF A REGIONAL BIOMEDICAL
WASTE INCINERATOR
3) CODE OF PRACTICE ON THE HANDLING, TREATMENT &
DISPOSAL OF BIOMEDICAL WASTES
137
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SESSION IV: TOPICS OF SPECIAL CONCERN:
PATHOGEN SURVIVAL, RISK ASSESSMENTS,
AND REGIONAL FACILITIES
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: How are additive risks considered?
A: (J. Held, NJ DEP) Some agencies do not consider additive risks. They
are difficult to define and assess objectively, so judgments must be
made. For example, a long list of risks which are just under 1:10~6 is
less comfortable than a long list of risks which are lilO"1^.
139
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SESSION IV: TOPICS OF SPECIAL CONCERN —
PATHOGEN SURVIVAL, RISK ASSESSMENTS,
AND REGIONAL FACILITIES
SUMMARY OF DISCUSSION (BALTIMORE)
Q: In comparing risks, the effects of metals should be included. They may
be a greater concern than dioxins.
Q: Waste management is needed at each stage. According to newspaper
reports, hospitals have succeeded in recycling some materials.
A: (D. Painter, EPA) Recycling may work in theory, but separation of
wastes may be too onerous a task to expect from the staff to whom it is
likely to be assigned, i.e. overworked and underpaid nurses.
Q: One second at 1800° F should not be a performance standard since it
does not account for turbulence. "Four 9's" were achieved in RCRA
tests of a well-designed industrial incinerator with fluidized-bed
combustion.
Q: How is 02 monitoring used to control combustion? Is it used as a
secondary parameter (after temperature) for controlling air input and
burner operation?
A: (S. Shuler, Ecolaire Corp.) Current technology is based on temperature,
but research is in progress toward using other parameters, possibly 02
and CO.
Q: To develop an approach to regulating HC1, Texas considered corrosion
impacts due to Cl in coastal areas. Ambient monitoring of Cl on the
coast indicated concentrations of 2-3 ug/m3, so the Texas ACB is using
a judgmentally established standard of 0.1 ug/m3.
A: (J. Lauber, NY DEC) New York has commented on EPA1 s revised draft
RCRA regulations, which specify an annual average of 15 ug/m3 for Cl.
Q: Performance tests should not be relied on uncritically because the
constituents of the waste usually are unknown. Instead, one should
emphasize fully modulated burners (more generally, full combustion
modulation of secondary chamber burners, not just cutback of air),
instrumentation, incinerator maintenance, maintenance of monitors, and
good air pollution controls.
Q: How do New Jersey DEP data on impacts of hospital waste incinerators
compare with the impacts of municipal or hazardous waste incinerators?
A: (J. Held, NJ DEP) New Jersey DEP has not made a formal comparison,
but As, Cd, Cr, and Ni from hospital incinerators appear to be roughly 2
orders of magnitude less than from municipal incinerators. For dioxins,
the risks are about the same, with slightly less risk from municipal
incinerators.
140
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Q: How is population exposure considered? For example, municipal
incinerators are usually located outside of town, while hospital
incinerators are near a population of sick patients.
A: (J. Held, NJ DEP) New Jersey DEP did not consider exposure of
subgroups because everyone deserves the same protection. But in the
future the agency may consider acute effects and apply larger safety
factors for short term exposure of sensitive populations, especially for
HC1 and
141
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142
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SESSION V
AGENCY PERMITTING EXPERIENCES
143
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PRESENTATION OF EMISSION DATA AND
DISCRIPTION OF AIR QUALITY IMPACTS
FROM HOSPITAL INCINERATORS
Lynn Fiedler
Michigan Department of Natural Resources
Air Quality Division
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
145
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My name is Lynn Fiedler/ Randy Telesz and I am a senior engineer with the
Michigan Department of Natural Resources, Air Quality Division.
Today I am here to discuss our experience irt permitting new hospital waste
incinerators in Michigan.
In the past the review of a hospital incinerator involved insurinq the
particulate emissions would not violate the National Ambient Air Quality
Standards and determining the FSD incrempnt consumption. The particulate
emission limit is 0.2 pounds per 1000 pounds of exhaust gases corrected to
50 percent excess air. We also looked for 12OO F and 1/2 second retention
time in the secondary chamber.
In 1986, we began to question whether or not a more in-depth review staould
be done on hospital incinerators. This was because of our over increasing
knowledge of the toxic emissions from municipal solid waste incinerators
and compliance with Michigan's Rule 901.
Our review of municipal waste incinerators indicated that the burning of
plastics and paper cause the emission of many potential carcinogens and
other toxic pollutants. The waste streams in a hospital tends to be very
similar to that of a municipal waste incinerator. The percentage of
plastjr is much higher in the hospital waste stream. The hospital units
tend to have poor combustion due to constant variation in the type of waste
being burned and the amount of waste being fed into the unit. These units
also tend to have poor dispersion because of short stacks and varying
building heights.
(picture) Like this!
Mirh.iyan'"; Rule 901 prohibits the emission of any air contaminant that may
cause injurious effects to human health and welfare. In addition, the
emission shall not interfere with the comfortable enjoyment of life and
property.
Armed with these two points, we entered into phase I of permitting in the
Winter of 1986.
About this time we received two applications for large units with heat
recovery. Both units were to be located in very large hospitals equipped
with tall stacks.
We asked both applicants to demonstrate compliance with Rule 901 by
quantifying the emissions from their units. We also asked for a
demonstration that 1800 F and a 1 one second retention time could be
achieved and maintained. Needless to say the applicants were less than
pleased when this information was requested. Tfiey were very concerned they
were being treatfid differently and this request would cost them
considerable time and money.
To assist them WF? idenf.if Jed HC1, cadmium, arssnic, chromium, dio::ins, and
furans as the pollutants of most concern. We chose these pollutants from
146
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our review of municipal incinerators. We had found in the our reviews thc't
these pollutants were of a magnitude and toxicity to be of concern.
While the two applicants were busy trying to gather data we continued to
investigate the emissions and their impacts. During the spring months we
received the Royal Jubilee test and other supporting articles. This
information really confirmed our suspicions and renewed our determination
to have these applicants address our concerns. With this emission data we
also did some dispersion modeling of various sized units.
The dispersion modeling results were not surprising and entered us into
Phase two of permitting.
We found the impacts from the smaller units were as high if not higher than
the larger units due to lower airflows, shorter stacks, and other problems
with dispersion. In July of 1986 we required all units regardless of size
to quantify emissions and demonstrate 1800 and 1 second. By-now all hhp»
applicants and the suppliers were less than pleased. It really amazed us
that these health care officials acted no differently and were in many
cases appeared more reluctant to address the issue of toxics than their
industrial counterparts. In fact, an equipment vendor, on behalf of the
permit applicants, took his concerns before the Michigan Air Pollution
Control Commission, the permitting authority. The vendor requested the
permits be issued with no additional controls or requirements and without
addressing the toxics issue. The commission not only denied the request
but they directed the Air Quality Division staff to continue to investigate
and to work with the hospitals. In January of 1*587, we held an
informational meeting on hospital incineration and air quality requirements
for hospital administrators and equipment vendors. We prepared a report
which described the toxic emission problems from hospital incinerators.
This report is available. Let me know if you'd like a copy.
Back to phase two. The emission quantification process was not going very
well. The data supplied by the applicants and suppliers was quite sketchy
and being used in a piecemeal fashion. Some of the applicants argued the
average values should be used and the majority insisted the lowest numbers
of al1 the tests represented their proposal. Those who argued the most
that their meticulous pre-sorting procedures would result in low emissions
were found to have some of the highest HC1 levels. To assist the
applicants and to insure the worst case operations were represented, our
division began to quantify the emissions for permitting the units.
Test data from those tests listed were used. These tests, which represent
a range of unit sizes, provided the only data available to us at the time.
The data were put into common units and normalised to 12 percent C02 for
comparison.
The newt step was to perform a statistical analysis for each pollutant.
The value representing the 95 percentile was selected for use as.the
emission rate. This means 95 percent of the time the emissions frorn the
unit would be expected to be less than this calculated value and 5 percent
of the hi me they would be expected to be greater. The 95 per cm tile WOB
selected as a compromise between the 99 percentile used for determining
emission rates for municipal incinerators and the mean vcdue the applicants
147
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requested. We believed at that time the 95 percentile would provide good
protection of the ens'ironment and also provide the applicant with an
adequate margin of safety for continuous compliance.
For example, 26 data points were used in the hydrogen chloride?
calculations. They ranged from 170 ppm to 1490 ppm. The 95 percentile
value was determined to be 1399 ppm. The mean value for the data was 741
parts per million. The uncontrolled emission rate for HC1 from a municipal
incinerator is around 100 ppm.•
The same procedure was then performed on these pollutants.
As new information is received, the emission rates are revised. This slide
shows how the 95 percentile for HC1 has increased since tfit- original
calculation. We received some test data that was quite high and I will be
discussing that test in a couple of minutes.
The emission rates are then used to determine the maximum impacts at ground
-level and at the air intakes. This is necessary to protect tfe patients,
visitors and the people living near the hospital. The dispersion unit uses
a modified Industrial Source Complex model to estimate the maximum impacts
within 300 feet of the stack.
This slide illustrates a unit with a tall stack which had poor dispersion
because of the hospital configuration.
This is the reason the impact at air intakes and open windows is evaluated.
The impacts are then reviewed to determine if they are environmentally
acceptable. In Michigan, an emission which represents a risk of less than
1 in 1 million or is less than one percent of the TLV has been accepted as
demonstrating compliance with Rule 901.
Phase 3 began with the permit applicants evaluating the alternatives to
reduce the impacts from their proposed units. The alternatives are
installing taller stacks or installing control equipment. The third item
listed was an option available for the two units which had already
completed construction.
Dispersion modeling is done to determine the stack height necessary to
reduce the impacts to an acceptable level. As you can see the addition of
33 feet was necessary to reduce the risk from chromium to acceptable
levels. Six hospitals have chosen this alternative. In some cases
structural limitations do not allow this option.
Three hospitals are planning on installing control equipment to reduce the
emissions. Two have chosen wet scrubbers and one applicant is pursuing a
dry scrubber/baghouse system.
Two hospitals had completed installation of their unit and were confident
the emissions from their units would be much less than the 95 percentile
value because of their- measures to limit FVC plastic usage and pr<=—sort the
wv^tf?. Thr?y rr?qur^terJ to t>=> al loi-JFd ^n 'st^rk t**=t *~o determine the
emissions from their units. We required the highest plastic content,
148
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typical waste be burned during testing. The HC1 values from one unit
tested ranged from 1900 to 2700 pprn. These values are significantly higher
than the 1399 ppm predicted. These values were used in recalculating the
HC1 emission rate.
When a permit is issued the permit conditions specified must be binding to
set limits on emissions and operations. They must also be legally
enforceable to insure compliance. For these types of units, the emission
rates representing the 95 percentile are specified in the permit conditions
provided that these rates are environmentally acceptable. We have also
been requiring a continuous temperature monitor to insure 1800 F is
maintained for a minimum of one second on a one hour average. The
temperature shall not drop below 1600 F at any time. The units are
required to shut down if the temperature cannot be maintained. The units
are also required to use auxiliary fuel to preheat the secondary combustion
zone at 1BOO F before any waste is added.
Phase 4 is where we are heading now. Currently a commltte*? rs wording en
toxics regulations for all air pollution sources in the state. They hope
to be completed this summer. The Departments of Fviblic Health and Natural
Resources have set up a committee to draft new hospital incinerator
regulations. We are also beginning to set. up a testing program for testing
toxics from these units.
149
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PERMITTING IN MICHIGAN
MICHIGAN DNR
AIR QUALITY DIVISION
Lynn Fiedler
HISTORIC REVIEW
• Particulates
• 1400 F & 1/2 sec
1986
• Knowledge of MWS
• Rule 901
HOSPITAL WASTE VS. MWS
• Similar Waste
• Poor Combustion
• Poor Dispersion
RULE 901
• Health & Welfare
• Comfortable Enjoyment
PHASE 1 - WINTER 1985/86
TWO APPLICATIONS
• U of Mich (1500 pph)
• St. Mary's (1100 pph)
APPLICATION REQUIREMENTS
• Quantify Emissions
• 1800 F & 1 sec
TOXIC EMISSIONS
HC1
Cadmium
Arsenic
Chromium
Dioxins
Furans
EMISSIONS/IMPACTS
• Royal Jubilee Test
• Articles
• Dispersion
150
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PHASE 2 - JULY 1986
ALL UNITS
Application Requirements
• Quantify Emissions
• 1800 F & 1 sec
Emission Quantification
• Applicants & Suppliers
• Air Quality Division
Test Data
Royal Jubilee
Alta Bates
Illinois
Erlanger
Oak Forest
Queen of the Valley
Statistical Analysis
• 95% Emission Rate
• Margin of Safety
• Protect Environment
HCI Emission Rate (pprav @ 12% CO2)
95% 1399
Mean 741
Additional Pollutants
Cadmium
Arsenic
Chromium
Dioxins
Furans
Acceptable Concentrations
• Risk of 1 in 1 million
• 1% of TLV
Maximum Impact
Modeling Review
• Ground level
• Air Intakes
151
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Recalculating HC1 (ppmv @ 12% C02)
Date 95%
11/86 1399
5/88 1768
PHASE 3 - ALTERNATIVES
• Taller stacks
• Control equipment
• Additional testing
TALLER STACKS
Chromium Risk Level
Stack
Height
35 feet
68 feet
Ground
Level
5
.6
Air
Intake
83
.9
ADDITIONAL CONTROL
•. Wet Scrubber
• Dry Scrubber/Baghouse
ADDITIONAL TESTING
• Worst Case Waste
• High Levels
PERMIT CONDITIONS
• Binding
• Legally Enforceable
PHASE 4 - FUTURE PROJECTS
• Toxics Regulations
• Hospital Incinerator Regulations
• Testing Programs
-------
PERMITTING NEW
HOSPITAL WASTE INCINERATORS
IN MICHIGAN
Randal Telesz
Michigan Department of Natural Resources
Air Quality Division
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Hotel Belvedere
Baltimore/ MD
May 24-26, 1988
153
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AGENDA
Informational Meeting Regarding Hospital Waata Incineration,
January 12, 1987
Lav Building Auditorium
Lansing, Hiehigaa
INTRODUCTION AND EXPLANATION OF ^^*P QUALITY REGULATIONS REGARDING
HOSPITAL INCINERATORS - Gerald Avery, Supervisor, Permit Section, Air
Quality Division. Departaent of Natural Reaoureea
FRESENTATION OF EMISSION DATA AND DESCRIPTION OF AI3. QUALITY IMPACTS
FROM HOSPITAL INCINERATORS - Lynn Fiedler, Environmental Engineer, Southeast
Permit Unit, Air Quality Division, Departaent of
Natural Resources
OF DISPERSION MODELING PROCEDURES FOR HOSPITAL INCINERATORS -
Lou Poeslujfca, Chief, Air Quality Evaluation Unit, Air Quality Division,
Department of Natural Resources
EXPLANATION OF INFORMATION NECESSARY FOR A COMPLETE PERMIT APPLICATION -
Randal Telesa, Environmental Engineer, Northwest Permit Unit, Air Quality
Division, Departaent of Natural Resources
SUMMARY OF HAZARDOUS WASTE REGULATIONS PERTAINING TO HOSPITAL
INCINERATORS - *-fr" Paksl, Lab Scientist, Waste Evaluation Unit,
Hazardous Waste Division, Departaent of Natural Resources
SUMMARY AND WRAP-UP - Gerald Avery
QUESTION AND ANSWER SESSION
154
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Hospital Incinerators
Page 2
January 12. 1987
many other Incinerators: The available taat data was insufficient to perform
statistical analysis for nitrogen oxides, PCBs, and mercury. Sulfur dioxide and arsenic
have also been Included in the list because of their known presence from incinerating
municipal solid waste and their expected presence from incinerating hospital waste. No
hospital test data was found on these two pollutants; therefore, values based on
municipal waste incineration were used since this is the best available data.
WHAT ABE THE PROJECTED AZ2 QUALITY IMPACTS OR THE HOSPITAL AH INTAKES AND GROUND LEVEL?
Answer;
The pollutants which are of major concern, baaed on the Air Quality Division's analysis,
are hydrogen chloride and chromium. The permit review has been completed for the
Allegan Hospital in Allegan. Based on the 95th percentlle emission rates at the
proposed stack height of 35 feet, the hydrogen chloride ground level concentration was
slightly higher than the accepted level, and at the air intakes it was projected to be
48.3 times higher. The chromium was 5.1 and 83.0 times the accepted level at ground
level and the air Intakes, respectively. The upper portion of table 2 includes the
impacts for all the pollutants at the original stack height. Dispersion modeling was
completed to determine the stack height necessary for the hydrogen chloride and chromium
concentrations at both the ground level and air Intakes to be less than the accepted
level. The stack .height was determined to be 68 feet. The bottom portion of table 2
Includes the impacts for all the pollutants at the revised stack. Table 3 provides the
building heights, original stack heights and the revised stack heights for the hospitals
which have provided sufficient information for dispersion modeling.
WHAT IS A DISPERSION MODEL?
Answer; - .Jj
A dispersion model is a set of equations used to estimate how pollutants emitted from a
source will travel and spread with time and distance. To do this, the model must
consider;
1. Factors that define the source - such as emission rate, stack height, building
height, stack exit temperature and stack exit velocity.
2. Factors that determine where pollutants will travel and how they will spread, such
as wind speed, wind direction and the mixing capability of the atmosphere.
The end result is an estimate of the concentration or amount of pollutant, averaged for
an interval of time, at a specific point.
155
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Hospital Incinerators
Fags 3
January 12. 1987
BOW IS A DISPERSION MODEL USED IN THE PERMIT PROCESS?
Answer;
A dispersion model is a tool in Che permit process. It is used to estimate the impact
of a facility on ambient air, prior to the facility being boilt. The model estimates
Impact based on design parameters. The predicted Impact is compared to a standard or
criterion. If the estimated impact is less than the standard* the modeling effort is
satisfied. If the estimated impact exceeds the standard, a design change is usually
needed to allow the facility to pass a subsequent modeling test.
WHAT ABE SOME OF THE POTENTIAL ALTERNATIVES TO SAFELY DISPOSE 0? HOSPITAL WASTE?
Answer;
Ronald A. Drake, Chief, Engineering Plan Review Section* Division of Health Facility
Licensing and Certification, Michigan Department of Public Health, has informed the Air
Quality Division that hospitals are presently disposing of their solid waste by
incineration, t«««i*-tn-t-iig «nd contracting with commercial incineration firms. Mr. Drake
indicated that the majority of small hospitals are currently landfillIng their solid
waste and that tandftiling is an environmentally acceptable method of disposing of these
materials. However, there is a concern about the extra handling and transportation of
the infections hospital waste which is associated with landfllling. Therefore, many
hospitals are in the process of switching to incineration as the preferred method of
disposing of hospital waste. The Air Quality Division believes that the Incineration of
hospital waate is an acceptable alternative, provided that the hospital incinerator is
operated in a manner which provides a retention time of the combustion products of 1
second at a temperature of 1800*? and is equipped with a sufficiently high stack to
provide proper dispersion of the emitted air pollutants. The stack must be high enough
to prevent the direct impactlon of the incinerator emissions into the hospital air
intake units and to prevent the downwashlng of the incinerator emissions onto the ground
level area surrounding the hospital. T"*r^lll"g acid gas scrubbers and bag filter
collectors may be a preferred alternative for some of the larger hospital facilities,
since installing stacks which conform to good engineering practice heights is quite
expensive for incinerators located at hospitals with tall buildings. Other alternatives
which merit further study include incineration at municipal resource recovery facilities
with air pollution control equipment and at regional hospital incineration facilities
which could be located away from the tall hospital buildings. The Air Quality Division
has recently met with the Michigan Department of Public Health (MDPH) to discuss the
concerns associated with the incineration of hospital waste and the difficulty that the
hospital industry is experiencing in permitting new Incinerators. As a result of this
discussion, a OUR and MDPH task force is currently being established to study and
develop recommendations on how hospitals should in the future dispose of their solid
waste.
156
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Hospital Incinerators
Page 4
January 12. 1987
WHAT INFORMATION WOULD THE MICHIGAN AIR POLLUTION CONTROL COMMISSION AND THE AIR QUALITY
DIVISION NEED TO PROPERLY EVALUATE THE AIR QUALITY IMPACTS FROM HOSPITAL WASTE
INCINERATORS?
Answer;
Rule 203 of the Commission's rules requires a permit applicant to submit a considerable
antoont of information, SOM of which includes: (a) th« expected composition of the air
contaminant stream from a proposed air pollution source; (b) th« location and elevation
of the ealssion point and other factors relating to the dispersion and diffusion of the
contaminant in the outer air, the relation of the emission point to nearby structures
and window openings, and other information necessary to apprise the possible effects of
the air contaminant; and (c) data demonstrating the effect of the air contaminant
emissions on human health and the environment.
The Air Quality Division has compiled a more specific list of the information that would
be necessary to properly evaluate the air quality Impact from hospital incinerators.
Attachment 1 is a copy of this list. The Air Quality Division hopes that this list will
help the hospital permit applicants to better understand what information is necessary,
assist the hospitals la submitting complete air quality permit applications, and
expedite the review and approval of these types of permit applications. Attachment 2 is
an example of the appalicatlon form. Application forma may be obtained by contacting
the Air Quality Division.
HOW MANY PERMIT TO INSTALL APPLICATIONS ARE PENDING FOR NEW HOSPITAL INCINERATORS?
Answer;
Ten permit to install applications for new hospital incinerators have been submitted and
are currently being evaluated by the Michigan Air Pollution Control Commission's staff,
Table 4 contains a listing of these applications, along with information regarding the
date the application was received, the permit application number, the permit applicant,
the location of the proposed hospital incinerator, the incinerator manufacturer, and the
capacity of the proposed incinerator.
WHAT HAS BEEN THE CHRONOLOGY OF EVENTS REGARDING THE AIR QUALITY DIVISION'S EVALUATION
OF HOSPITAL INCINERATORS DURING THE PAST YEAR?
Answer:
November of 1985 through February of 1986 - The Air Quality Division began receiving
information which indicated that emissions of acids, heavy metals and organlcs from
hospital incinerators could pose a significant health risk.
157
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Bospital Incinerators
Page 5
January 12. 1987
February 26, 1986 - Air Quality Division permitting staff concluded that the data
concerning toxic emissions from hoapital incinerators were of sufficient concern to
warrant a thorough review for the larger hospital incinerator applications which had a
design rate of aore than 1000 pounds per hour of waste.
April of 1986 through June of 1986 - Additional emission data concerning hospital
incinerators was received and reviewed by the Air Quality Division which indicated that
all hospital incinerators, -ttn»i.nHng the smaller units, could pose serlou* health risks
to patients la the hospitals and the public who live in the area surrounding the
hospitals.
July 1986 - The Air Quality Division began requesting all hospitals which were proposing
to install new incinerators to quantify their emissions of known toxic pollutants and to
address the feasibility of adding additional air pollution control equipment.
July 1986 through November 1986 - The Air Quality Division had many telephone contacts
and meetings with various people involved in the permitting of hospital incinerators.
The Air Quality Division continued to perform a more.detailed analysis to better
quantify the emissions from hospital incinerators and their impacts on the air intake
vnits for hospital* and the area immediately surrounding the hospitals.
lovember, 1986 - The Air Quality Division performed a statistical analysis of the
available emission data to determine the 95 percentlle emission rates. This information
is used to calculate the ia-stack concentrations and through dispersion modeling, the
ground level. concentrations'..
November 1986 through January 1987 - Dispersion modeling was completed to determine the
necessary stack heights for those units whose applications were complete.
January 6, 1987 - The Air Quality Division's evaluation of Permit to Install Number
19-861, for the new incinerator at AUegan General Hoapital was completed. The hospital
had originally proposed a 35 foot stack, but agreed to install a 68 foot stack in order
to assure that the operation of the incinerator will not cause any adverse effects on
health or the environment.
-------
IA3L2 I
sos?mi ocixzaAToa session SATZS
BASED ON A7AHA3L2 TEST DA1A.
Basad an statistical
analysis of east data
Pollutant 95 Pm
Cadmium2 0.49 17 ag/s3
Carbon JSonoxida3'4'6 . 1245.90
Chromium2 0.2871
Olozlaa2 333 og/m3
784 ag/»3
t3t4'5'7 1399 ppmr
Sicrogma OaddM3 • 229 ppwr
PC32 8.98 og/m3
Mar cur/* 0.003 Bg/«a
Salfor Dioadd* 86 pp«r
Ars«nlcL- 12 ag/m3
, dry)
Jacksoa Cotmer Seaff Imort
Jub±l«« Boapieal eaac data
3Alea Bac»a Hospital cast data
.Uliaoij east data
gAloaga Corporation east data from Erlangsr lUdical C«atar
.Oak Forsst Hospital east data
Qua«a of cfa* Tallsy Hospital etst data
Fraparad by Ljnan. Fiadlar
159
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TABLE 2
BASED OR 95 PERCENT HZ EMISSION FACTORS
Original Stack Height • 35 Feet
Pollutant
HCL
Chrosiun
Arsenic
PCBa
Oloxiaa &
Forana
Haceaaary
Pollutant
HCL
Cadaius
Arsenic
Mercury
PCBa
Dioxina &
Fur ana
Concentration (ug/«9)
f/Hr. Ground Laval Air Intaka Accented Aab.
3.55
8.23x102-4
4.32x102-4
2.00x102-5
5.00x102-5
1.50x102-5
1.90x102-6
Stack Height •
•73.3
7.24x102-4
4.23x102-4
1.76x102-5
7.15x102-5
1.32x102-5
1.27x102-6*
68 Feet
3380
1.18x102-2
6.39x102-3
2.86x102-4
1.44x102-3
2.14x102-4
2.07x102-7*
70
5.60x102-4
8.30x102-5
2.30x102-4
0.5
1 x 102-3
2.30x102-6*
Concentration (ug/at9)
f/Hr. Ground Level Air Intake Accepted Anb.
3.55
8.23x102-4
4.82x102-4
2.00x102-5
5.00x102-5
1.50x102-5
1.90x102-6
17.6
8.84x102-5
5.16x102-5
2.14x102-6
1.38x102-5
1.61x102-6
1.53x102-?*
61.7
1.28x102-4
7.47x102-5
3.10x102-6
5.21x102-5
2.33x102-6
1.49x102-6*
70
5.60x102-4
8.30x102-5
2.30x102-4
0.5
1 x 102-3
2.30x102-6*
Fraction of Accepted .
Ground Level Air Int;
1.1
1.3
5,1
0,1
1.4x102-4
1.3x102-2
0.6
Fraction of
Ground Level
0.3
0.2
0.6
1.0x102-2
2.8x102-5
1.6x102-3
0.1
48.3
21.1
83.0
1,2
2.9x102-:
0.2
9
Accepted
Air Ine
0.9
0.2
0.9
1 xlOE-2
1.0x102-
2.3x102-
6.5x102-
*Baaed on 2, 3, 7, 3 - TOO Toxic Equivalents
160
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TABLE 3
HOSPITAL STACK AND BUILDING HEIGHTS
Hospital •
A
B
C
D
E
G
I
Height (ft)
28
135
70
212.2
95
74
12
Suck Height (ft)
35
138
SO
227.5
122.5
94
25
Stack Height Necessary
68
Modeling not completed
Modeling not completed
Modeling not completed
157.5
Modeling not completed
50
161
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psmnc ?SMrr TO XSRZUL APSIICAJIOHS sss. SOS?IIAL oci2i3u.ro*s
AsoLicatioti
**?* y «^i«^^^
?.ic*iv«d
i:/4/83
1/Z9/36
3/13/86
3/30/86
7/.11/86
8/23/86
8/22/86
10/22/86
11/6/86
Application
ifuob«r
26-831
2-861
13-86Z
16-861
20-861
26-861
27-361
30-861
32-861
Facilier
UairorsiCT
o£ Micaijan
Sc. Sard's
Sospieal
On-Siet
Tacaaologias
8«7«r
Hospital
Bnctaniut cli
Hospital
William
VA«MM«M»» 9«a«M
Air ?ore«
B**«
Piwdng
Hospital Assn.
Tnghani MaHlftaT
Cantar
Location
Ana Arbor
Sajiaaw
3o Siea
Salaetad
Tpsilanci
Grand Sapids
BLoral Oak
losco Cotmcy
HUaa
•
T *^«^is«
lac.. 5££r.
Basic Swr'l.
Saf .
Consuoat
Shsnandoaa
JAS. lacia.
S«rr.
Consomac
Mora* 3olg*r
Bftsscon
Atlas
Ccnsnmc
Inc. Caoacisy
(??H)
1,300
1 ,100
120
300
173
300
Unknown
340
290
11/6/86
33-661 CoHoalcr Saalta
C«acar of Branch
Coldwaear
Coasaaac
162
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ATTACHMENT 1
SUPPLEMENTAL INFORMATION REQUIRED FOR A COMPLETE AP-2 PERMIT APPLICATION
FOR THE INSTALLATION OF HOSPITAL WASTE INCINERATORS
1. A plot plan of the site with scale, Indicating building locations and
dimensions [length, width, and height(s)]; building air intake vent
locations and height(s); and stack locatlon(s), exit dimension(s), and
height(s).
2. A detailed written description of the incinerator covered by this permit
application including a copy of the manufacturer's literature. Indicate the
length, width, and height; or the length and diameter (in feet) of each
chamber.
3. A detailed description of the amount, type, and source of each hospital
vasts stream which will be burned. Include the higher heating value and the
net heating value (In BTUs per pound) and the ultimate analysis for the
hospital waste. All assumptions, calculations, and other documentation used
to derive these values must also be provided.
4. The msrlimm and normal operating schedule for the Incinerator, in hours per
day and days per year. . . •
5. The temperature profile and the retention time at 1800*7 for the normal and
"worst case" waste conditions. All assumptions, calculations, and other
documentation used to derive these values must also be provided.
6. A description of the temperature monitoring and recording system to ensure
that 1800*7 and a gas retention time equal or over one second are achieved
and maintained.
7. Describe in detail the'procedures and the methods used to Insure that 1800*?
is achieved and maintained during incinerator startup and shutdown and
during periods when high moisture/low BTU waste is charged into the
incinerator. Please include the type and «**^Tn™n fuel firing rate of the
auxiliary fuel. If fuel oil la to be used, Include the fuel type and
mayfTntm sulfur content. All assumptions, calculations, and other
documentation used to derive these values must also be provided.
8. The volumetric flow rate In actual cubic feet per minute and in dry standard
cubic feet per minute, at 70*7, corrected to 12Z CO., and the expected
temperature (in *7) of the exhaust gases for each stack exit point (s).
Please provide the percentages of carbon dioxide, moisture, and excess air
in the exhaust gases when operating at «*ytign design conditions. All
assumptions, calculations, and other documentation used to derive these
values must be provided.
9. A description of the combustion controls (such as flame out sensors; air and
fuel controls; and chamber temperature monitors). Indicate if you are
planning to install carbon monoxide (CO), oxygen (0 J, carbon dioxide (CO ),
opacity, or other pollutant monitors, and if so, please describe how these
monitors are tied into the combustion controls. Pleaae provide the
16?
-------
combustion controls or monitors a«t points for normal operation and for
triggering an alarm, the method of alerting the controller of abnormal
operations (lights* alarms , etc.), and the exact location In the ay a tea to
be monitored. Also please describe the combustion control strategy and how
all the air supply fans and combustion controls are Integrated.
10. A discussion of the physical and economic (the Installation and operational
costs) feasibility of Installing and operating an acid gas scrubbing system
and a high efficiency partlculata collector on the incinerator. ALL
assumptions > calculations, and other documentation used to derive these
parameters must also be provided.
11. A complete description of the emission control equipment for the Incinerator
including expected efficiency and guaranteed efficiency in percent for each
pollutant controlled. All assumptions, calculations, and other
documentation osed to derive these values must also be provided.
12. A statement indicating whether a bypass of the emission control equipment
and main stack is provided. If there is a bypass, include a complete
description of the circumstances that would cause a bypass and hov long the
incinerator would operate in the bypass mode.
13. The location and specifications of the stack sampling ports. A description
of say rain protection devices on the stack(s) .
14. A description of the ash fomfi **g system including amount of ash collected
(in pounds per hour or pounds per batch) , method to prevent air emissions,
method of transport, and disposal location*
15. A complete description of the preventatlve maintenance and malfunction
abatement program (s) for the incinerator, emission control system(s), and
monitoring system(s).
*16. The iMTlimim uncontrolled and controlled emission rates (in pounds per hour
and tons per year) of each of the following pollutants. All assumptions,
calculations, stack tests, and other documentation used to derive these
values must also be provided. Please keep in mind that the »••*•''•"• emission
rates may become legally binding permit conditions. The emission rate
estimates should provide a reasonable margin of safety to ensure that your
incinerator can continuously operate at or below these levels.
a. Particulate
b. Sulfur Dioxide
c« Hitrogea Oxides, expressed as NO.
d. Carbon Monoxide
e. Polychlorinated Blphenyls (PGBs)
f . Mercury
g. Arsenic
I*
164
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1.
j. Total polychlorinated dibenzo-p-dioxlns (PCDDs), Tetra through Octa
isomers
k. Total polychlorinated dlbenzofurana (PCDFs), Tetra through Octa isomers
1. Hydrogen Chloride
*17. For each of th« above pollutants, a demonstration that these proposed
emissions will not cause injurious effects to human health and safety. (The
Michigan Air Pollution Control Commission Rule 901 prohibits the emission of
any air contaminant that may cause injurious effects to human health or
safety.) Tour demonstration must include the effects on people outside the
hospital due to ground-level impacts, and the effects on patients and other
people inside the.hospital (and any other nearby buildings) due to impacts
at air Intakes* windows, and other building openings.
*Upon request, the Air Quality Division (AQD), DNR, can supply statistical
emission rate data (Item 16) which has been compiled from the available test
data, and the AQD can evaluate the acceptability and safety of the emissions
(Item 17) using the technical methods which have been developed and utilized by
the Michigan Air Pollution Control Commission. The supplier of the incinerator
should be able to submit the information requested in items 1-15 with some
assistance from the- hospital administrators on items 1,3, and 4.
Air Quality Division
Permit Section
January 9, 1987
165
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ATTACHMENT 2
AIR QUALITY DIVISION
MICHIGAN DEPARTMENT OF NATURAL RESOURCES
P.O. SOX 30023, LANSING, MICHIGAN 48909
APPLICATION TO THE AIR POLLUTION CONTROL COMMISSION
far authority to conitnict, iiutall, or altar and for p«rmi> ta eparat* on ineinarater
1. 'CUMIT TO •• IttUKO rot fBtuuut* LMMM Hm*u
MAIUMO AOOMUSl
Stmt. Citf «r VUl*t», Zip Ca4»i
1. CQUimCNT OM •MOCXU LOCATIONS
jcrwf. cur or r« 0^ OMOAMlZATtOMt
^
Carparalia*
Q PwmaraM*
Knowntal A.
1. aCMKftAU MATUMC O* •lUiNCSSk
Q
T. Make «f
C«i«
R«n4 C«MCity (Ih/Tw)
•. Ty*« •*«•»!•
| BTU/la. M Urea
PRIMARY COMBUSTION OUuafft
i. VolMM (m. ftJ
Srfacttv* Grat* 4 Hearth ATM (*•. ft.)
£>«•••
Adjustaal* Q TCJ Q N<
TOM! HMT
(STUAr/eu. ft.)
X Air
Air
Un4«Hir«
StCONOARY COMBUST10H CHAMBtR (Mate
10.
(cu. ff.)
G*«
Tin* *f
(SM) '
BURNSRS
ti.
CaMciry (BTlHi»> »
Caaoeity (BTU/hr) »
IS. BrMchi<«|t
Pa iM4lHeat««m in «>t«il
Q NO
I*. muBMT sTATua-a* CQUIVWCMTI
r<:*«-*,
(
(
(
(
) CamttiKtion «r imMilotf** IMI trart^
) C«M*t««ri«i «r
C«ii«*Mnt is m ba aitarW
G^N^HMaw 1*1 pBV>iy ^wTVa*VBI
M. M«W« o* MIOH e»»»c« A« IN in A*OV«.
AM »«i.buTiaM COMTMOI.
MCH.
«. rv*<« OK »»INT MAMC AMO TITU* 0*> OWNCH OH AUTHOHIZKO MCMaCK a*> FIIIMi
rW«W .—_______—_——_____«__« • O»M«« •poravcd and
SioMtur*..
FORM A«»X
10/75
(INSTMUCnOMS POM COMM.2TINO THIS FORM AM8 ON RCVCMSC SIOO
166
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APPLICATION INSTRUCTIONS
tins fern in triplicate; complete application requires specifications and drawings in duplicate. This application must bo signed by the
or authorized neabor of firm. Additional comments on us* of tim application or* notod below.
T. Nome of owner of incinoreter. If loosed, stete nemo of lessee.
3. Address et which the incinerator is koine, installed.
T. Name of the •onufeeturer of the incinerator —' * *——'•
, Initial or i
i. State «!••• of incinerator and rated
capeaity of Incinerator In pounds of nkieriel burned par hour.
•. Stete typo of wosto to bo burned in the tnoiiMrofor •nd tfw 9TU por poun*1 volwo of tno «osto to bo bumoo1. Staro 4oily amount af w«sto
to bo bomod ONO" ohook wnothor this is •stiwotoo' or th* sotiiol OMOMM.
tt. Oiook typoo of 'ok ooilution control •o.wifMMnr tn b« instoHoo1 in tnn tnviMrotor. If "owW" is chockon*. ins«ft tho typn (in»cti«l, w«t
swnbbor). SMnofoonmr ono1 •ffieivnoy of th« •^uisoMnt.
Mu. aViofly oosoribo thn woo •MrroiMio'ina the plant inaltio'ino, »«•*« footors as *• topsotoony of thn aroa, s'isMMwa t« th« prooMty lin«, son-
teoj of tno ofooy oto«
TT. H ttm •ap4loofion is lor NMO*Ifl*ot<«n of m ««istin« unit, ••sariho in «oratl tn« prvoosoo' «o4ifl«ation to bo •oo'o.
6UIOI TO IHC1H8RATOR CLASSIFICATION SYSTEM
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167
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CHATTANOOGA - HAMILTON COUNTY
PERMITTING EXPERIENCE
J. Wayne Cropp
Director
Chattanooga - Hamilton County
Air Pollution Bureau
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco, CA
May 10-12, 1988
169
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I. Definitions
A. Pathological waste - Chattanooga definition
(adopted in 1973)
All or parts of organs, bones, muscles, other
tissues and organic wastes of human or animal
origin, laboratory cultures and infective
dressings and other similar material.
B. Use of term "pathological" is a misnomer because of the
"breath" of items covered in local ordinance under what
is normally a more limited term.
C. Possible designations of "infectious" waste
1. pathological wastes - tissues, organs, body
fluids
2. human blood and blood products - serum, plasma
.3. contaminated animal carcasses, body parts, and
bedding
4. cultures and stocks of infectious agents and
associated biologicals - culture dishes
5. contaminated sharps - hypodermic needles,
syringes, scalpel blades
6. isolation wastes
7. miscellaneous contaminated wastes - soiled
dressings, sponges, underpads, surgical gloves,
slides, specimen containers, dialysis unit wastes
170
-------
D. Types of solid waste designated as infectious
Source/Type of Solid Waste CDC EPA JCAH CITY
Pathological yes yes yes yes
*
Blood & blood products yes yes n/a yes
Animal waste, contain. n/a yes n/a yes
Microbiological yes yes yes yes
Sharps yes yes no yes
Isolation HP yes yes yes
Other waste no HP no yes
HP - hospital policy
CDC = Center for Disease Control
JCAH = Joint Commission on Accreditation of Hospitals
171
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II. Chattanooga Permit System
A. Have utilized incinerator Institute of America
solid waste classification scheme for designation
of waste classification
«>
1. pros
a. extensively used in USA
b. used by equipment manufacturers
2. cons
a. does not address plastics content or
hazardous components
III. Chattanooga Standards
A. Regulatory emission limit - particulate
1. 0.1 Ibs. per 100 Ibs. charged
a. for entire burn cycle
2. 0.20 grains @ 12% C02
a. excluding fuel used
b. more stringent than simple correction
for C02.
B. Design criteria
1. multiple chamber required
2. primary chamber - 800*F
3. secondary chamber - 1500'F
4. other designs may be considered, other than
above three criteria, if mass standard can be
achieved
5. no visible emissions allowed from any
"pathological" unit
C. Licensing requirement
1. required for person in responsible charge
2. $10.00 fee for administering standardized test
3. may be revoked for
a. willful violation
b. violation through incompetent operation
172
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IV. Erlanger Case Study
A. Background
1. public health care facility
.a. 754 beds
b. operations - regional tertiary care center
2. operated one Consumat pathological waste
incinerator
a. 85 pounds per hour
B. Permit application
1. permit applied for in January 1982
2. two continuous feed, Basic (John Basic design)
Model 1250 heat recovery incinerators
3. Type 0 and 1 waste only - Incinerator Institute of
America designation (did not include pathological)
C. Special permit conditions imposed (BACT)
1. tight operations requirements but no add-on
controls required
2. 0.08 gr/dscf
3. 1625°F (secondary chamber)
D. Units constructed and tested
1. constructed - 1983
2. tested for TSP - February 1984
E. Annual inspection - 1986
1. all facilities inspected annually.
2. March 1986 - temperature requirements violated on
numerous occasions over past year
3. NOV issued (April 1986)
4. modifications made to system by July 1, 1986
a. grate system replaced
b. increased burner capacity
5. resolved enforcement action - no penalty
173
-------
F. New York City test burn
1. September 1986
a. "trial burn" of hospital waste conducted
b. came from 11 hospitals, over 14,000 Ibs.
»
2. "for-profit" proposal under consideration
3. November 1986
a. employee reported to county and news media
b. concerned about AIDS due to injury during the
trial burn
G. Enforcement investigation
1. had burned out-of-state waste on September 11-12,
1986
2. had been burning hospital's own "red bag waste"
after July 86 modifications
a. permit violation
b. only Type 0 and 1 waste allowed
3. had violated temperature requirements on 42
occasions between July 1986 and November 1986
a. documented in company's written logs
4. had violated temperature requirements during
."trial burn"
5. enforcement action initiated
H. Consent decree negotiations
1. control equipment
a. dry lime acid scrubber, baghouse
2. increased secondary chamber temperature
requirement to 1800°F
3. specified residence time - 1 second (secondary)
4. continuous temperature recorder required
5. assessed penalty - $72,500
6. are not burning waste for others
174
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V. Compliance Program at Area Hospitals
A. Disposal and operational practices
1. penalized another hospital for burning
"pathological" waste in general refuse unit -
$15,000
a. no mass, temperature or opacity violations
recorded
2. initiated tests at all units (pathological and
general refuse)
a. had not previously required tests of small
units
3. compliance status poor, at best
a. equipment not functioning at manufacturers
representations
4. dioxin tests not required due to lack of standard
- associated costs
5. tested for: particulates, hydrogen chloride,
chlorine, temperatures (primary & secondary),
residence time, and opacity
B. Testing requirement reaction
1. one hospital incinerator shutdown, 100% Opacity
(continuous feed)
2. seven food stores shutdown incinerator (general
incinerator regs.)
3. one storage company shutdown incinerator (general
incinerator regs.)
C. Testing program reviewed
1. local requirements
2. proposed Tennessee regulations considered
a. HC1, residence time
3. spore tests at two hospitals
175
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VI. Proposed State Regulations
Ac Regulatory emissions limits
1. 0.1 gr/dscf for particulate - corrected to 12% C02
2. HC1 - air quality impact not to exceed 70.0 mg/m3
on a 24-hour basis
3. opacity not to exceed 10% (6-minute average)
except not to exceed 20% during one 6-minute
period in any hour
B. Design criteria
1. multi-chamber
2. solid hearth (or equally effective)
3. secondary chamber - 1600°F
4. residence time
a. new units must meet 1.0 second
C. Burning of antineoplastic drugs
1. new or existing
a. 1.5 seconds residence time
b. 1800°F secondary temperature
D. Charging systems
1. batch loading systems must have a lockout
2. others must have an automatic loading device with
an interlock
176
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VII. Pathological Incinerator Testing Summary
Hospital
Type
Results
Batch
Charge
B
Batch
Charge
Batch Continuous
Charge Charge
Unit 1 Unit 2
City
Regulation
1) Particulate
total Ibs. per 180 rain. 0.13 0.07
average Ibs per hour n/a n/a
0.19* n/a n/a
n/a 0.25 0.20
0.1 Ibs/100 Ibs charge
0.1 Ibs/100 Ibs charge
2) Rule 7.4 Allowable
0.28
0.32
0.51
1.25
1.25
3) Avg. gr/dscf
8 12X C02 - Fuel
a 12% co,
4") HCl
Ibs. per 180 min.
average Ibs. per hour
5) C12
Ibs. per 180 min.
average Ibs. per hour
6) Primary
Temperature °F
7) Secondary
Temperature °F
0.09
0.06
1.42
n/a
0.01
n/a
0.14
0.03
2.12
n/a
0.02
n/a
0.49
0.06
1.28
n/a
0.05
n/a
0.02
n/a
12.23
n/a
<0.02
0.02
n/a
8.56
n/a
<0.02
n/a
**
None
None
None
None
450-1300 350-680
330-800 1115-1636 1351-1781
1650-1800 1800-1900 1650-1860 1858-2089 1798-2143
800°F
1500°F (A, B, C)
1800°F (0>
8) Retention Time
Seconds
0.97
0.19
1.03
2.10 2.10
None
9) Spore Test NO No trace
10) VE X 0 (
* Ibs. per 240 min.
** 0.10 gr/dscf (state)
0.08 gr/dscf ("0" Consent Decree)
Complete n/a n/a
Destruction
None
No VE
177
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VIII. Lessons Learned
A. Do not accept manufacturers' representations without
further inquiry.
B. Require individual tests on all units.
C. Information about pathogen survival and low level
nuclear waste has been hard to come by.
D. Primary issue for us became plastics content and
resulting emissions.
1. dioxins and furans
E. Medical solid waste practices are often poor.
F. Do not allow solid waste problem to become an air
pollution problem.
1. require tight controls - up front
17fl
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MARYLAND'S PERMITTING EXPERIENCE
Tad Aburn
Maryland Department of
Health and Mental Hygeine
Air Management Division
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Hotel Belvedere
Baltimore/ MD
May 24-26, 1988
179
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DEFINITION OF INFECTIOUS WASTE
"Infectious waste* means any material or item of a
disposable nature known or suspected to be contaminated with
organisms capable of producing disease in humans, biological
and laboratory waste, pathological waste/ and sharps such as
needles.
Also includes animals and animal contact items such as
bedding contaminated with organisms that may be pathogenic to
humans.
MARYLAND'S POLICY
REGARDING THE DISPOSAL OF
INFECTIOUS WASTE
1. Landfilling and municipal incinerators.
2. Hospital waste versus infectious waste.
3. On-site versus off-site incineration.
4. Autoclave and other alternative disposal methods.
CURRENT STATUS OF
MARYLAND'S PROGRAM
1. Currently have 116 on-site incinerators.
2. One commercially available incinerator has special service
for physicians offices and other small generators.
3. One regionalized 100 ton per day unit at proposal stage.
4. Acid gas scrubbers.
5. Existing Guidelines - proposed regulations.
MARYLAND'S PROPOSED
AIR TOXICS REGULATION
1. Applies to infectious waste incinerators.
2. Three Basic Requirements.
• Estimate emissions.
• Best available control technology for toxics (T-BACT)
for new sources.
180
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• Demonstrate that emissions "Do not unreasonable
endanger human health" by use of:
(a) Conservative screening analysis
(b) More sophisticated analysis
*(c) "Risk Management" for Carcinogens
PERMITTING EXPERIENCES
1. Analyze commercial hospital waste incinerator with a
1000 Ib/hr unit.
2. Applying for a second 1000 Ib/hr incinerator.
3. Industrialized area/ 30 foot stacks, and no proposed acid
gas scrubber.
SCREENING ANALYSIS - 3 STEPS
1. Estimate emissions.
• EPA emission factors - screen with higher values
2. Estimate highest off-property concentrations.
• Conservative screening dispersion model (AMA TM 86-02)
• ISC-LT and ISC-ST for more detailed dispersion
modeling
3. Compare off-property concentrations to screening levels
for each substance discharged.
SCREENING ANALYSIS RESULTS
Off-Property Screening
Substances Concentration Level
Considered (ug/m3) (ug/m3)
Hydrogen Chloride 6100 (1-hr) 70 (1-hr)
Dioxins and Furans 620xlO~7 (annual) 3xlO~7 (annual)
Cadmium 0.014 (annual) 0.006 (annual)
Chromium 0.0014 (annual) 0.0008 (annual)
Arsenic 0.00062 (annual) 0.002 (annual)
• HCL, Dioxins, Cadmium and Chromium did not screen out.
• Other substances and short-term screening levels for
listed substances are not included as they all "screened
out."
181
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MORE DETAILED ANALYSIS
• "Special screening level" for HCL - 150 ug/m3 (3 min.
average)
• Complex modeling
• Average emissions for annual concentrations
• Highest emission rate for HCL (3 min. average)
• Adjust stack height
RESULTS OF MORE DETAILED ANALYSIS
(80 Ft. Stack To Avoid Downwash)
Off-Property Screening
Substances Concentration Level
Considered (ug/ra3) (ug/m3)
Hydrogen Chloride 500 (3 min.) 150 (3 min.)
Dioxins and Furans 2xlO~7 (annual) 3xlO~7 (annual)
Cadmium 0.001 (annual) 0.006 (annual)
Chromium 0.0001 (annual) 0.0008 (annual)
Arsenic Screened out Screened out
• Even with a 200 foot stack, HCL emissions resulted in a
level almost double its special screening level (250 ug/m3
compared to 150 ug/m3 - both 3 min. averages).
ROUGH REVIEW OF EPA MODEL UNIT
1. Characteristics of larger model plant.
• No acid gas controls
• 1000 Ib/hr
• 78 foot stack
• 450 to 1144°F exit velocity
2. Review used EPA emission factors, EPA "Reference Air
Concentration" (RAC) for HCL and our modeling.
3. Results
• EPA's model unit caused concentrations all most twice
as high as the proposed RAC.
182
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4. Conclusions
Many larger infectious waste incinerators across the
country may have HCL problems.
TSSTTES
1. Acid gas controls.
2. Acceptable HCL levels in the ambient air.
3. HCL emission rates.
4. . Continuous emission monitoring.
5. National policy on acid gas controls for infectious waste
incinerators.
183
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BRIEF SUMMARY OF DRAFT AIR TOXICS REGULATIONS
February 1988
This summary describes the major provisions of Maryland's draft air toxics regulations.
It discusses the pollutants and sources covered as well as the three major requirements.
Toxic air pollutants include a large number of carcinogens and non-carcinogens for which
no national or state ambient air quality standards have been established. The draft
regulations call carcinogens "Class I TAPs" and other toxics "Class n TAPs."
The number of substances regulated as toxic air pollutants will be larger for new than for
existing sources. For existing sources, the draft regulations contain a specific list of
pollutants. For new sources, there is a somewhat longer list of Class I TAPs
(carcinogens) and an open-ended definition of Class n TAPs that is based on the term
"health hazard" in the State Right-to-Kriow laws.
The sources governed by the regulations are identified in the sections concerning
applicability. In general, the regulations will apply to any source required to get an air
quality permit. Certain small sources are exempt, and there are specific exemptions for
fuel burning equipment, char broilers, and gasoline stations.
There are three major requirements:
1. The requirement to quantify emissions of toxic air pollutants.
2. A requirement that most new sources use the best available control technology for
toxics (T-BACT).
3. The requirement that a source not unreasonably endanger human health.
The requirement to quantify TAP emissions will require new sources to quantify any TAP
discharged. For existing sources, however, the requirement is limited to specifically
listed TAPs. The regulations specify deadlines for existing sources to submit emissions
information.
The T-BACT requirement is very flexible and allows the Department to consider both the
toxicity of substances discharged and the costs of controlling emissions on a case-by-case
basis.
The third requirement is also called the "ambient impact" requirement, because in order
to demonstrate compliance, a source must show that it will not increase concentrations
of TAPs in the ambient air by more than certain levels. Existing sources must comply
with the ambient impact requirement by 1990 or 1992 depending on which TAPs are
discharged.
The ambient impact requirement is the most complex part of the regulations, because
there are several options a source may use to demonstrate that its emissions do not
unreasonably endanger human health. The primary option is to demonstrate that the
source will not increase ambient concentrations by more than applicable "Screening
Levels." The second option is a "Second Tier Analysis." There is a third option for Class
I sources, involving a "Special Permit."
184
-------
Screening Levels are established for both carcinogens and for other toxic effects.
Screening Levels for carcinogenic effects are called "Risk Based Screening Levels" since
they are developed using risk assessment. The Risk Based Screening Level represents a
maximum individual lifetime cancer risk of one in 100,000. Screening Levels for other
toxic effects may be based on Threshold Limit Values (TLV-Based Screening Levels). If
no TLV is available, the regulations contain procedures for developing Screening Levels
based on toxicity data establishing thresholds for various health effects (Threshold-Based
Screening Levels). Since these Screening Levels are developed using methods that may
not be appropriate for every substance, the regulations also provide that the Department
may adopt Special Screening Levels to more adequately reflect toxic effects other than
cancer.
Screening Levels are intended to be conservative so that public health will be protected
even though only one source is evaluated at a time. However, a mechanism is provided in
the "Second Tier Analysis" to consider multiple sources of a TAP and to develop a less
conservative though still protective Acceptable Ambient Level to replace a Screening
Level for noncarcinogenic effects.
The Second Tier option also provides for the development of "Insignificant Risk
Concentrations" in cases where new data indicates that a Risk-Based Screening Level
should be revised. This option will involve a re-analysis of the dose response data for a
carcinogen.
Finally, the Special Permit option for Class I TAPs involves a reassessment of the
exposure to a carcinogen and the acceptable risk level. Screening Level analysis assumes
that a person will be continuously exposed for 70 years to the highest TAP concentration
predicted to occur off the source's property. Since this assumption is very conservative,
the Special Permit option provides for the opportunity to use more realistic exposure
assumptions. In addition, if necessary, the Special Permit provides the opportunity to
accept risks that may exceed one in 100,000.
185
-------
186
-------
SESSION V: AGENCY PERMITTING EXPERIENCES
SUMMARY OF DISCUSSION (SAN FRANCISCO)
*
Q: What has been the permitting experience of burning infectious waste in
a municipal waste incinerator?
A: (Unidentified speaker) New York is inclined to support the burning of
infectious waste in municipal burners because the burning conditions in
the new facilities are at least as good as what we are proposing for
hospital waste incinerators. However, there is a problem of the grates
being too large (body parts can fall through). The disadvantage is in
operation — there is not enough control. Pathological and infectious
wastes will get mixed up with municipal waste if the waste is picked up
from commercial establishments, be it doctors, dentists, or clinics.
(Unidentified speaker) Workers are not enthusiastic about touching the
infectious material. Agencies have to encourage people in municipal
waste incineration to accept these materials, perhaps through separate
streams, or by using boxes for infectious waste.
(M. Tierney, WI DNR) Wisconsin encourages each facility to bum its
own waste so the regulators would not have to make the distinction of
what is or is not infectious waste.
(N. Coleman, OK DOH) Oklahoma allowed one municipal waste
incinerator to burn hospital waste. There are special provisions in their
permit. The hospital cannot compact the waste prior to sending it to
the facility. The municipal waste incinerator must keep it as a separate
waste stream, cannot use grappling hooks as a means of loading it into
the incinerator, but must use a manual loading system, and have the
capacity to disinfect the loading area with live steam. There was initial
opposition from the hospitals on not compacting the waste because this
meant higher hauling costs, but this has been resolved. A new proposal
exists to build a process facility adjacent to the municipal waste
incinerator to offer steam sterilization of all waste prior to going into
the municipal waste combustbr.
(W. Sonntag, NY DEC) Landfills are out; there is no space available.
Most communities will have to install some type of incinerator. In that
case, the burning conditions will be the same, whether it is a hospital or
a municipal facility. The costs should be about the same for both. They
may as well combine everything and send it to a municipal incinerator.
The costs will probably be higher than they are now, but currently the
landfills are inadequate and landfilling costs too low. To upgrade the
landfills, the costs will have to increase. The costs will then be more
consistent with the cost of incineration.
187
-------
(N. Seidman, NESCAUM) The issue of small/local vs. large/regional
facilities has been raised in some of the NESCAUM states. Larger
facilities could be better funded, more able to afford the control
equipment, and have better trained operators. However, the problem is
siting. It is very difficult to site a municipal waste incinerator on the
East Coast. If you try to convince the public that you can burn
municipal waste correctly and that you are going to burn pathological
waste occasionally, it could set the public against your incinerator, no
matter what technical advantages combined burning offers.
Q: Regarding smoke stack heights, are we entering into another "The
Solution to Pollution is Dilution?" How does this compare to other
"smokestack industries?" Are stack heights varied in other smokestack
industries or just for hospital incinerators?
A: (L. Fiedler, MI DNR) Michigan requires BACT. For HC1, we are letting
hospitals dilute as a solution. We are getting it away from air intakes
and away from hospital patients. In looking at the health impacts, we
found that HC1 was the factor that was driving the stack height up.
Hospitals can meet the requirements for metals, dioxins and furans, but
the HC1 was the problem.
(G. Abura, MD DOH) Maryland's policy is that dilution is not the
solution. Stacks should be designed for no downwash. Stacks may not be
raised for carcinogens because this may increase the total risk by
dispersing the emissions and the risk. Raising the stack is a last resort.
(P.K. Leung, Env. Can.) The same discussion is occurring in Canada.
BACT eventually implies zero pollution, but until then dilution is
necessary. Combine the two until the ambient impact is acceptable.
Q: Acid gas control reduces the stack exit temperature, leading to less
dispersion of HC1 emissions. Without scrubbers and heat recovery you
could have high temperature, high plume rise, and better dispersion. Is
there a substantial reduction in ambient HC1 concentrations with a
scrubber?
A: (L. Fiedler, MI DNR) Perhaps agencies should consider proposed stack
heights with and without control equipment, and do dispersion modeling
to make sure the impacts are acceptable.
Q: Do agencies use toxic equivalency factors?
A: (G. Aburn, MD DOH) Maryland does not, but instead tries to show that
dioxin and furan emissions are acceptable using conservative
assumptions. Maryland took the homologue group and treated the whole
group as though it were as toxic as the 2,3,7,8 isomer of that group.
(Unidentified speaker) In California, CARB used the factors that were
developed by the California Department of Health Services.
188
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(G. Yee, GARB) At the International Los Vegas meeting on dioxin,
there appeared to be wide discrepancies among the different scenarios
of the toxic equivalent units from the international level. A Research
Committee was formed to examine the problem and come up with a
consistent scenario.
Q: Wisconsin and Minnesota are considering the impacts of bioaccumulation
of toxics in the environment. Are any other states working on
bioaccumulation of dioxins, furans, cadmium, or other pollutants?
A: (G. Abum, MD DOH) New York has materials which show that actual
exposures to dioxins (due to emissions into the atmosphere) are higher
from non-inhalation routes, than they are from inhalation. The New
York contact is Pat Levin.
(N. Seidman, NESCAUM) EPA is working with Minnesota and Vermont
on the Vicon municipal waste incinerator and the whole issue of
bioaccumulation. The preliminary data should be released in June.
Vermont and Detroit, Michigan are completing preoperational
monitoring.
(A. Jackson, MN PGA) A health risk assessment in Minnesota was just
released. .Contact Jeff Stevens at the University of Minnesota for
further information on bioaccumulation. The Citizens Board will
determine what Minnesota will do with the assessment.
Q: After looking at the routes of exposure, all the models and assumptions,
and going through health risk assessments done on municipal waste
combustion, how significant are the risks? There seems to be quite a
range of risks noted from inhalation. Depending upon what numbers are
used, the variation in the overall risk can be quite dramatic.
A: (T. Smith, BAAQMD) The models for non-inhalation pathways are
usually borrowed from radiation modeling. The factors and parameters
considered are fairly esoteric. Guidelines or assumptions are needed.
(G. Shiroma, CARS) South Coast AQMD's contract study should
provide suggested guidelines for these esoteric input parameters. GARB
is coordinating with South Coast AQMD in writing guidelines on how to
assess risk for resource recovery facilities, municipal waste
incinerators, and hospital waste incinerators. This document is to be
used by regulators and consultants to guide a potential applicant. The
draft is due in August and a workshop is planned for September.
189
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SESSION V: AGENCY PERMITTING EXPERIENCES
SUMMARY OF DISCUSSION (BALTMORE)
Q: What are the general problems with continuous emission monitoring
(CEM)?
A: (G. Aburn, MD DOH) The main problems are reliability of data, and
maintenance of equipment. CEM for opacity is currently practical, but
CEM for HC1 needs further development.
Q: What is the Bay Area AQMD position on secondary chamber retention
time versus temperature, especially in existing incinerators?
A: (T. Smith, BAAQMD) The manufacturers' concern is consistency of
requirements rather than how strict the requirements are. A safety
margin is needed, and there is agreement that 2 seconds provides that
"cushion."
Q: For existing incinerators the data do not show a need for retrofitting as
long as the incinerators are operated properly, e.g. no visible emissions.
GARB data should provide useful insight on this.
A: (G. Ferreri, MD DOH) Until recently Maryland had an odor-oriented
time/temperature requirement (6.3 seconds at 1400° F), and design of
the secondary chamber was based primarily on odor control. A retrofit
requirement would in effect mean phasing out existing units.
Q: To control dioxin it must be condensed, e.g. with an acid gas scrubber
plus baghouse. However, the biggest problem is operator training.
A: (J. Weyler, Chattanooga-Hamilton Co. APCB) There is a need for a
manual for operator training, not in incinerator operation — that is the
manufacturer's job — but in the regulations and how to spot problems.
Q: Michigan required 1 second at 1800° F based on experiences with
municipal waste incinerators. If temperature decreased, PCDDs
increased. Data for PCDDs and PCDFs from hospital incinerators are
very limited. Michigan planned to do more testing in the 1600-1800°
range since refractory materials are less costly if designed for the lower
temperatures. Tests at 2 seconds and 2000° F show that cyclotoxics are
destroyed. One must remember the mission — what one is trying to
destroy.
Q: Since 1984 Massachusetts has had a standard of 1 second at 1600°. The
state discovered recently that its regional offices interpreted this
differently, e.g. 1 second absolutely, or 1 second corrected for
temperature. What f> done elsewhere?
A: (T. Smith, BAAQMD) Bay Area AQMD requires that the minimum
temperature specified be maintained for the retention time. The agency
inquired of the manufacturers, who stated that the specified
temperature should occur "after the last introduction of air."
190
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(R. Telesz, MI DNR) Michigan requires temperature to be maintained
on a 1-hour average basis for that 1 second.
Q: la a colder climate, common sense dictates that the incinerator be
enclosed in a building. Massachusetts requires as GEP that new
facilities be enclosed to allow easier maintenance and testing in all
seasons.
A: (R. Telesz, MI DNR) In Michigan as well, the climate requires enclosed
incinerators. Also, employee unions favor enclosed facilities.
Q: We can learn from hazardous waste incineration experience. For
example, the 25-year old incinerator at Niagara Falls is equipped with a
scrubber for HC1 but no participate controls. Burning waste with 62%
Cl content, it achieved no detectable PCDD as long as residence time
was over 2 seconds at 1000-1200° C. This unit maintained less than 50
ppm CO emissions and 99.95% combustion efficiency. Combustion
efficiency is the key, and CO is a good indicator.
Q: What caused the violations reported in Tennessee — low temperature
due to overcharging?
A: (J. Weyler, Chattanooga-Hamilton Co. APCB) One of the problems is
what is to be burned. The manufacturer designed the unit for mostly dry
waste, but the hospital burned all its wastes so the water content was
higher than design conditions.
Q: Hospital waste should be surveyed at intervals for changes in the
constituents, e.g. precautions against the AIDS virus have resulted in
more vinyl latex gloves and PVC being discarded.
Q: For each panelist: What is considered BACT on new incinerators?
A: (T. Smith, BAAQMD) The District has not made BACT determinations,
but the HC1 limit is 30 ppm.
(G. Ferreri, MD DOH) If Maryland were to determine BACT, it would
probably be an acid gas scrubber followed by a baghouse.
(J. Weyler, Chattanooga-Hamilton Co. APCB) BACT has been
established only on the Erlanger incinerator. This facility is designated
for a charging rate of up to 1250 Ib/hr.
(R. Telesz, MI DNR) Michigan has not done a PSD determination on an
incinerator. In performing a BACT-like review of the University of
Michigan facility, the agency has called it "state of the art.11
Q: For each panelist: What are the stack testing requirements?
A: (T. Smith, BAAQMD) Tests for particulates and HC1 are required. No
dioxin testing or GEM are required due to the cost.
(G. Ferreri, MD DOH) Maryland has done tests for particulates only,
plus tests at one hospital for metals. No tests for PCDDs or PCDFs
have been required due to the cost. Extensive testing at one hospital is
being used to build a database.
191
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(J. Weyler, Chattanooga-Hamilton Co. APCB) All facilities must test
for particulates, HC1, and CO2, must monitor primary and secondary
temperatures and must calculate retention time during the test. These
provisions are not yet statutorily required in the County, but State
approval is anticipated.
(R. Telesz, MI DNR) Some tests for PCDF and PCDD have been done
but Michigan is hesitant to require them because of the cost. HC1 and
metals are tested at most facilities. Michigan has required future
testing (e.g. every 5 years) for HC1 because (1) the amount of Cl in the
waste stream is increasing, and (2) in the future EPA will lift its ban on
PVC in food and packaging materials, and the percentage of PVC in the
waste stream is expected to increase.
Q: What are appropriate de minimis levels for (1) requiring testing, and (2)
requiring controls?
A: (T. Smith, BAAQMD) Testing should be required to determine
compliance. The issue of CEM requirements is complex. It would make
sense to have one regional faculty with a well supervised CEM
operation, but this is unlikely to be realized. CEM is too expensive to
require it of every facility. The decision is a philosophical, one of
balancing needs, rather than application of a defined threshold.
(G. Ferreri, MD DOH) All units are tested, no matter how small,
because manufacturers' data submitted to the agency have been
inaccurate. The particulate regulation, which specifies 0.1 lb/100 Ib
charged, is set up so that the facility needs to test in order to comply.
(R. Telesz, MI DNR) The risk limitation is 1 in a million. If the facility
cannot meet this, they must relocate the stack or increase its height. If
this is not feasible, they must install controls. A similar process applies
to HC1 through a TLV-related standard.
Q: Is waste analysis required before a stack test?
A: (R. Telesz, MI DNR) Most companies do not analyze waste as part of a
compliance test. In Michigan, inspectors observe the waste for PVC.
(J. Weyler, Chattanooga-Hamilton Co. APCB) In the County, an
Agency inspector gathers a representative sample of the waste during
the test.
Q: How can opacity be monitored if a wet scrubber is in use?
A: (R. Telesz, MI DNR) The usual procedure in Michigan is to wait for the
steam to dissipate and then read opacity visually. Opacity testing is
required on larger units but not smaller ones because of the cost.
Recently Lear-Siegler has been developing a new method which involves
sampling the plume, reheating a portion of it, and then reading the
opacity.
(J. Weyler, Chattanooga-Hamilton Co. APCB) No hospital incinerators
in the County have wet scrubbers. They probably will not be used due to
the potential for corrosion by HC1, and their vulnerability to poor
operation.
192
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SESSION VI
AGENCY REGULATIONS AND GUIDELINES
193
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HOSPITAL WASTE INCINERATION:
A NEW YORK STATE PERSPECTIVE
Wallace E. Sonntag, P.E.
New York Department of
Environmental Conservation
Division of Air Resources
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
195
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REGULATORY BASIS: PARTS 219 and 222
• Adopted 1972 and 1973
• Still in effect
• Apply to smoke/ odors, and particulates
• For types 0-4 waste
ISSUES
• Complaints
Smoke
Odor
• Public Concern
All incineration
AIDS
• Legislative Concern
• Landfill Problem
Closures: 47 of 354 permitted
Rejection of red bags
• Commercial Facilities
• Plastics
• Existing regulations are obsolete
INTERIM GUIDANCE — October, 1986
• To identify good engineering practice for new applications
INFECTIOUS WASTE LEGISLATION — July, 1987
• Propose BACT incineration regulation by September 1, 1988
• New facilities comply 90 days after adoption
• Existing facilities comply by January 1, 1992
INFECTIOUS HOSPITAL WASTE CATEGORIES
Surgical — isolation
Obstetrical — isolation
Pathological
Biological — isolation
Blood and blood products — isolation
Serums and vaccines
Renal Dialysis
Laboratory — pathogens
Animal body parts — pathogens
Sharps
196
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CONTINUOUS MONITORING
• Temperature
Primary combustion chamber
Secondary combustion chamber
Outlet
• Contaminants
Opacity
CO (for over 500 Ib/hr charge)
STACK TESTING
• Frequency
Start-up
Annual
• Measurements
Particulates
HC1
CO
02
DATA AND CALCULATIONS
• Basic data
Waste .
Design
Combustion air
Control
Gas cleaning
• Impact
Dispersion model
On and off site
OPERATOR TRAINING AND CERTIFICATION
• Training
Must submit program
Plant operation only by trained operators
• Certification mandatory when program implemented
INSPECTION AND REPORTING
• All components of facility
• Annual
• For DEC
• By P.E.
UNKNOWNS
• Particulates: Can existing facilities meet 0.015 gr/dscf
at 7% 02?
• HC1: Operational control?
• Opacity: Meet 10% all the time?
• CO: Meet 100 ppmv hourly average @ 7%
197
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APPLICABILITY
• Type
New facilities
- Proposed modifications
- Existing
• Owners
Municipal/Private solid waste incineration facilities
Medical care facilities
Commercial facilities
• Size
Medical/Commercial: Under 50 tons/day
Municipal/Private: All
• Location: All of New York State
• Effective date: 90 days after promulgation/ approximately
February, 1989
• Criteria: PC issuance
EMISSION LIMITATIONS
• Particulate: 0.015 gr/dscf at 7% Q£
• HC1: 90% or 50 ppmv at 7% Q2
DESIGN REQUIREMENTS
•• Time/Temperature: At least 1 second at 1800° F or
equivalent
• Auxiliary burner and interlocks: Designed to maintain 1
second at 1800° F secondary, 1400° primary
• HC1 control: Outlet temperature less than 300° F or
equivalent
OPERATING REQUIREMENTS
• Opacity: 10% (6 minute average)
• CO: 100 ppm (1 hour average)
• Temperature:
1800* F secondary
1400° F primary
300° F outlet
OTHER WASTES
• Body parts
Up to 5%
Not identifiable in ash
• Radioactive: Needs 6 NYCRR 380 permit
• Hazardous: Needs 6 NYCRR 373 permit
198
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KEY COMPONENTS
• Waste
• Hardware
• Air pollution control
• Operation
PROPOSED REGULATIONS
• Incinerators: Infectious Waste Incineration Facilities
6 NYCRR Subpart 219-3
• Statutory Authority: Environmental Conservation Law
Sections 3-0301, 19-0301, 19-0303, 19-0306
199
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HOSPITAL WASTE
• Variable composition
Dressings
Paper
Plastics
Bedclothes
Laboratory materials
Cytotoxic drugs
Radioactive materials
• Problems of variability
Heating value
Infectious
Hazardous
Radiological
Body parts
Density
Moisture
EMISSIONS OF CONCERN
• In the past
Particulates
Concentration
Opacity
• Now
Concentration
Opacity
Metals
Organics
Odors
Toxics (chlorinated)
Chemotherapeutic agents
Radioactive materials
Acid gases
PATHOGEN DESTRUCTION
• Limited data
• Gas emissions - 1800° F
• Ash - 1400° F
FOR AIR EMISSIONS/ NON-INFECTIOUS = INFECTIOUS
• Concerns
Plastics
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
Thomas C. Jorllng
Commissioner
M E M 0 R A N D U M
TO: Regional Air Pollution Control Engineers
Bureau Directors
Section Chiefs .
FROM: Mr. Hovey (Originator: W. Sonntag) «
SUBJECT: Guidelines for Medical Care Waste-Incineration 88-AIR-21A
DATE: January 1, 1988
Background'
On July 27, 1987, Articles 19 and 27 of the Environmental Conservation Law (ECL)
were amended, relative to the management of infectious waste. For infectious
waste incineration, this new legislation requires:
1. By September 1, 1988, proposal of a regulation requiring best
available control technology.
2. Within ninety days of adoption of final regulation, compliance of
proposed new incinerators with the regulation.
3. By January 1, 1992, compliance of existing incinerators with the new
regulation.
These amendments to the ECL have resulted from a growing concern over the
environmental impact of infectious waste disposal. The operators of both
sanitary landfills and municipal waste incinerators have generally been unable
to accept infectious waste. As a. result, the red bags have, at times, piled up,
representing a potential environmental problem.
Although the new legislation requires best available technology only for
infectious waste incineration, it is the Department's position that such control
should be required for all incineration of medical care waste (except garbage)
for the following reasons:
Concern with the burning of medical care waste relates to plastics,
anticancer drugs and radioactive materials as well as pathogens;
The proportions of the above materials of concern in non infectious
and infectious medical care waste are approximately the same;
Non infectious and infectious medical care waste are generally mixed;
There is no way of knowing whether the waste going to the incinerator
is infectious or non-infectious.
201
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Existing Parts 219 and 222 were adopted in 1972 and 1973 to provide for the
general regulation of refuse and pathological waste incineration. Part 222
applies in New York City, Nassau and Westchester Counties and Part 219 applies
in the rest of the State. At the time of adoption, there was little concern
with toxic emissions from these incinerators. Therefore, these regulations
limit only emissions of particulate matter and smoke; Part 222 requires
maintenance of 1AOO°F at the furnace outlet to destroy odors.
Purpose
The purpose for issuing this memorandum is to provide an interpretation of the
legislative requirement for "best available control technology" for infectious
waste incineration. The standards described here are expected to be proposed
for regulation by September 1, 1988. This will be of value to medical care
facilities planning to install incinerators. Adoption of the revised
incinerator regulation, while subject to the public hearing process, is not
expected to make obsolete, equipment installed in compliance with this program
memorandum.
This guideline does not supplant Parts 219 and 222.
Permitting (Reference 6 NYCRR 617 and 621)
For uniformity of permitting new hospital waste incinerators throughout the
State, employ the following procedures:
1. All applications for Permits to Construct are to be considered "Type
I" or "unlisted" actions. Applications for replacement incinerators
are not to be considered Type II actions based on the fact that they
were approved according to the old Incinerator Institute of America
classification of Types 0 to A waste, rather than "hospital" waste,
which contains infectious material and significant quantities of
chlorinated plastics.
2. All applications should be considered as having the potential for
significant effect on the environment, based on Section 617.ll(a)(1),
(A), (5), (7). Therefore, a determination of environmental
significance must be made carefully for each application. A public
notice describing the proposed project and the determination of
environmental significance should be placed in the Environmental
Notice Bulletin for both "negative" and "positive declarations."
3. Strict adherence to Parts 617 and 621 must be assured by Regional DRA
staff.
A. Municipal incinerators designed and operated in accordance with this
program memorandum may also be eligible to burn hospital waste. If
the facility owner so chooses, he should apply for a permit or permit
modification, describing the waste to be burned. Such application
should then be processed as described here.
202
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Rationale for Standards to be Proposed
Particulate Matter
Best available particulate control technology for municipal waste incinerators
has been defined by the DEC Advisory Board on Operating Requirements for
Municipal Solid Waste Incinerators as 0.015 grains per dry standard cubic foot,
corrected to 7 percent oxygen. This very low particulate concentration was
based on:
The need to collect small particles to which toxic organics may
attach;
The ability of current technology to provide that degree of control.
The same current technology is also available for hospital waste incineration.
However, baghouses are likely to predominate, particularly for smaller
installations. On this basis then, best available particulate control
technology for hospital waste incinerators is 0.015 grains per dry standard
cubic foot, corrected to 7 percent oxygen.
Temperature and Residence Time
Studies used in the development of a regulation for municipal refuse combustion
have indicated that chlorinated plastics should be burned in an oxidizing
atmosphere at a minimum of 1600°F for one second to assure the destruction of
toxic organic compounds. This memorandum recommends that those parameters be
met, but with a margin of 200°F as follows:
For a two chamber incinerator, the average temperature/residence time
in the secondary chamber alone should be at least 1800°F and one
second. No credit for residence time may be taken for burning within
the primary chamber.
For a single chamber incinerator, such as a water tube boiler, the
source owner should demonstrate by calculations and/or test data that
the conditions of 1800°F and one second residence time are met within
the combustion chamber.
Carbon Monoxide
The most widely accepted measure of complete combustion is carbon monoxide (CO).
At the present time, indications are that CO concentrations of less than 100 ppm
are attainable but the relationship of averaging time and charging method has
not yet been fully explored. For this guidance, a CO value of 100 ppm hourly
average, corrected to 7 percent oxygen (0>), applies.
Loading and Operating Controls
Batch fed incinerators should incorporate an interlock system which will:
Prevent charging until the secondary chamber exit temperature reaches
1800°F.
Prevent recharging until the combustion and burndown cycles are
complete.
203
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Nonbatch fed incinerators should incorporate a mechanical loader and an air lock
system to prevent opening the incinerator to the room environment. The volume
of the loading system must consider the incinerator capacity to assure complete
burning of the waste. Interlocks must prevent charging the waste until the
secondary chamber exit temperature reaches 1800°F.
Auxiliary burners alone should be capable of raising the combustion chamber-exit
temperature to a minimum of 1800°F. The firing rate of these burners should be
modulated automatically to maintain this minimum temperature.
Acid Gas Control
The DEC Advisory Board on Operating Requirements for Municipal Solid Waste
Incinerators has defined best available technology for hydrogen chloride control
as 90 percent reduction or 50 ppm, exit concentration from incinerator whichever
is less restrictive. A guideline for sulfur dioxide control has not been
quantified because sulfur is not normally a significant component of either
hospital or municipal waste. However, scrubbers that will provide 90 percent
hydrogen chloride reduction may be expected to provide 60 to 70 percent sulfur
dioxide reduction.
Equipment that will provide 90 percent hydrogen chloride reduction is readily
available, using wet and dry scrubber and spray dryer technology. The allowable
incinerator exit concentration of 50 ppm hydrogen chloride is to provide relief
from the need to control very low emissions of hydrogen chloride.
Type 4 Waste
Because of its high density and moisture content, pathological (Type 4) waste
will normally burn more slowly than hospital waste, making it more suitable for
burning alone in a crematory. However, some hospital waste incinerators are
designed to provide for the acceptable burning of Type 4 waste. For your
guidance then, Type 4 waste may be burned with hospital waste only if the
incinerator has been satisfactorily tested while burning that mixture.
"Satisfactorily tested" means that the Type 4 waste must be completely destroyed
and not be identifiable in the residue. Permits issued should restrict charging
rates, by waste type, to the rates shown satisfactory by test.
Radioactive Waste
Both the products of combustion and the ash from burning radioactive waste are
radioactive. Therefore, radioactive waste, whether decayed or not, may not be
burned in an incinerator unless that incinerator has been permitted by the DEC
Bureau of Radiation.
Continuous Monitoring and Recording
The secondary chamber exit temperature should be continuously measured and
recorded to assure the maintenance of at least 1800°F. Flame from the auxiliary
burner must not impinge on the thermocouples. Consideration is being given to
the need for monitoring carbon monoxide and oxygen. Records should be submitted
annually.
204
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Opacity
Opacity should be limited to less than 10 percent during any consecutive six
minute period except that a maximum of one six minute period per hour of less
than 20 percent is allowed, as determined by EPA Method 9.
Calculations
Calculations and data, including references, should be provided relative to the
following:
Waste - Provide the following information for each waste or mixture to be
burned at one time (if all wastes are mixed uniformly, provide only
once)
Burning rate (maximum) - pounds per hour, tons per year
Heating value of waste (maximum, average) (how determined), BTU/per
pound
Moisture (maximum, average), percent
Pathological waste (Type A), percent (by weight)
Infectious waste (DOH designation), percent (by weight)
Plastics, percent (by weight)
Incinerator and combustion air - Provide the following information for each
waste or mixture to be burned at one time:
Describe inlet and exit temperatures, residence times and flue gas
velocities in each chamber. Residence time equals combustion chamber
volume divided by volumetric flue gas flow at its average temperature.
Describe anticipated excess/deficiency air requirements in primary and
secondary chambers, percent.
Describe combustion air flow, cfm and pressure drop, inches H-0
relative to fan provided.
Demonstrate that flame from auxiliary burners will not impinge on
thermocouples.
Impact of emissions -
Provide dispersion model for particulate matter and HC1 for both
onsite and offsite receptors.
Testing
Because of its composition and attendant heating value, hospital waste does not
conform to Type 0 through A waste used in the definition of "incinerator" in
Part 200. Therefore, the existing list of DEC approved incinerators is invalid
for the burning of hospital waste. Further, the inability of any incinerator to
meet this guideline's particulate emission limitation makes an approved
205
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incinerator list meaningless. For those reasons, each facility in which
hospital waste is to be incinerated should be tested while burning 100 percent
hospital waste as a condition of the Permit to Construct. If the incineration
facility is shown to be in compliance with the 0.015 grain per dscf guideline,
no further particulate testing will be required. If the facility meets only the
particulate limitation of Parts 219 or 222, further testing will be required
when the forthcoming hospital incineration regulation is adopted. Obviously,
failure to meet the particulate limits of Parts 219 and 222 will preclude the
issuance of the Certificate to Operate.
Owners of incinerators burning hospital waste should provide results of measure-
ments made at startup and annually thereafter, of carbon dioxide and carbon
monoxide concentrations in the secondary chamber, to assess combustion
efficiency.
Owners of incinerators burning hospital waste should provide results of measure-
ments made at startup of secondary chamber: (1) inlet temperature (to evaluate
average temperature and residence time) .and (2) hydrogen chloride concentration
(to evaluate the impact on receptors).
The Bureau of Toxic. Air Sampling will continue to evaluate and maintain records
of incinerator test reports.
All test methods must be acceptable to the Commissioner.
Operator Certification
In order to operate an incineration facility acceptably, all operators should be
trained and certified by the equipment manufacturers or their designated
representatives. Operators are to be knowledgeable with respect to:
Proper operation and maintenance of equipment;
Environmental permit conditions and the impact of plant operations;
Operator safety.
Inspection
Experience has shown incinerator performance to be highly variable, depending on
both operators and incinerator condition. These problems could be exaggerated
in burning plastics. Therefore, an annual inspection report, attesting to the
condition and operation of the incinerator and the calibration of instruments
covered by this guidance, should be prepared by a qualified engineer and
submitted to the DEC by the source owner. DEC staff should inspect annually
each incinerator covered by this guidance against those inspection reports,
while the incinerator is operating.
Summary of Guidelines
Applicability - New or modified incinerators burning waste (except garbage) from
medical care facilities Statewide.
Permitting - Follow Part 617 and 621 - All actions "Type I" or "unlisted" -
Publish in ENB.
-------
Particulate Emissions - 0.015 gr/dscf at 77. CL (EPA Method 5).
Temperature & Residence Time - Secondary or single chamber design 1800°F and one
second - Minimum 1800°F at exit.
Carbon Monoxide - 100 ppm ho*urly average at 7% 0_.
Loading and Operating Controls - Batch fed: interlocks for charging - Nonbatch
fed: mechanical loader with interlocks - Modulating, auxiliary burners to raise
and maintain secondary or single chamber exit temperature to 1800°F.
Acid Gas Control - Less restrictive of 90 percent HC1 reduction or 50 ppm HC1.
Type U Waste - Pathological waste (Type 4) may only be burned with hospital
waste if tested and found acceptable. Permits to limit wastes by type.
Radioactive Waste - Excluded unless permitted by DEC Bureau of Radiation.
Continuous Monitoring and Recording - Required to show secondary or single
chamber exit temperature at least 1800°F. Possible need to monitor CO and 0_.
Submit records annually.
Auxiliary Burners - Required to raise secondary or single chamber temperature to
1800°F and maintain there when needed.
Opacity - Hourly average less than 10 percent. Maximum continuous 6 minute
average less than 20 percent.
Calculations - Waste composition and parameters, incinerator parameters, fan,
impact analysis.
Testing - Particulates - test all units while burning hospital waste, at
startup.
- Secondary chamber inlet temperature and HC1 concentration - test at
startup.
- Secondary chamber CO- and CO concentrations - test at startup and
annually thereafter.
Operator Certification
Proper operation and maintenance
Permit conditions
Operator safety
Inspection
- Annual report by owner.
- Annual review of report and inspection by DEC.
Attachment
cc: Regional Directors of Environmental Quality Engineering
87-2-80
207
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208
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HOSPITAL/INFECTIOUS WASTE MANAGEMENT
James M. Salvaggio
Pennsylvania Department of
Environmental Resources
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
209
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BACKGROUND
LANDFILLING OF INFECTIOUS WASTE PROHIBITED
RECENTLY PROPOSED HOSPITAL/INFECTIOUS WASTE INCINERATORS
"Commercial"
Bedford County
* Application Submitted - 12/29/86
* Capacity - 600 Ibs/hr.
MEGA
* Application Submitted - 7/8/87
* Capacity - 4000 Ibs/hr.
On-Site "Captive"
SmithKline Beckman
* Application Submitted - 9/87
* Capacity - 750 Ibs/hr.
Moses Taylor Hospital
* Application Submitted - 11/17/87
* Capacity - 167 Ibs/hr.
LEGISLATIVE ACTIVITY
HOUSE RESOLUTION NO. 28
Legislative Hearings on Safety & Environmental Impact
HOUSE BILL 1387
One Year Moratorium on Incinerator Permits
Mass Burn
Infectious and Pathological Waste
Refuse Derived Fuel
Local Municipality Override
>150% of Local Need - Referendum
210
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SENATE BILL 474
Comprehensive Plan
Volume Waste
Adequacy of Existing incinerators
Geographic Location
Siting Criteria
Expansion of Environmental Regulations
Moratorium of Permits
STATUTORY AUTHORITY
SECTION 6.1(A)
... No person shall construct/ assemble/ install or modify
any stationary air contamination source . . . unless such
person has applied to and received from the Department written
approval . . .
SECTION 5.
ENVIRONMENTAL QUALITY BOARD
The Board shall have the power and its duty shall be to: (1)
adopt rules and regulations/ for the prevention/ control/
reduction and abatement of air pollution . . . regardless of
whether such source is required to be under permit by this act.
SECTION 6.1(D)
The Department may refuse to grant approval ... if it appears
from the data available to the Department that the proposed
source . . . are [is] likely to cause air pollution . . .
SECTION 3 (5)
Air Pollution. The presence in the outdoor atmosphere of any
form of contaminant including but not limited to the
discharging from stacks, chimneys ... of smoke, soot, fly ash
. . . gases . . . toxic or radioactive substances ... in such
place, manner, or concentration inimical or which may be
inimical to the public health safety or welfare or which is,
or may be injurious to human(s) ... or which unreasonably
interferes with the comfortable enjoyment of life or property.
211
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REGULATORY AUTHORITY
NEW SOURCES
25 PA. Code Section 127.12(a)(4)
Show that the source will comply with all applicable
requirements of this article and those requirements promulgated
by the Administrator of the United States Environmental
Protection Agency pursuant to he provisions of the Clean Air
Act.
25 PA. Code Section 127.12(a)(5)
Show that the emissions from a new source will be the minimal
attainable through the use of the best available technology.
25 PA. Code Section 127.1
Best Available Technology. Equipment/ devices/ methods/ or
techniques which will prevent/ reduce or control emissions of
air contaminants to the maximum degree possible and which are
available or may be made available.
EXISTING SOURCES
25 PA. Code Section 123.12
No person shall cause/ suffer or permit the emission ... of
particulate matter from any incinerator/ at any time/ in such a
manner that . . . exceeds 0.1 grains per dry standard cubic
foot, corrected to 12% carbon dioxide.
AIR QUALITY PROGRAM
NEW INCINERATORS
Administrative Hold on Issuance of
New Incinerator Permits
June/ 1987 until February/ 1988
212
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Permitting Criteria for
Hospital/Infectious Waste Criteria
Best Available Technology Requirements
Operating Requirements
Ambient Impact Limitations
Monitoring, Testing and Record-Keeping Requirements
Operating Training Requirements
Compliance Assurance Plan
PURPOSE
Explains how we intend to ensure compliance with
permitting criteria.
Communicates to industry what can be expected if
permitting criteria are violated.
Establishes statewide, consistent enforcement response to
violation of he permitting criteria.
CONTENTS
Permitting Process
Surveillance Activities
* Inspection Frequency
* Stack-Testing Schedule
* Continuous Emission Monitoring
Enforcement
* Penalty Provisions
* Mandated Shutdown Conditions
Local Coordination
EXISTING INCINERATORS
Concerns
Increased Reliance on Existing Incinerators
Adequacy of Existing Incinerators Unknown
Adequacy of Existing Incinerator Regulations
Unknown Number of Existing Incinerators
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Action Plan
Upgrade Inspection of Previously Permitted Incinerators
Estimate Residence Time and Temperature
Estimate Emission
Determine Adequacy of Equipment
Identify and Inspect Unpermitted Incinerators
Prepare Revised Regulations
Develop Compliance Assurance Plan
SUMMARY
Area of Considerable Public Interest
Adequate Statutory Authority
Regulatory Authority for New Incinerators is Adequate
In Process of Upgrading Regulatory Authority and Program
Activities for Existing Incinerators
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HOSPITAL/INFECTIOUS WASTE MANAGEMENT
Prepared by
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
OFFICE OF PUBLIC LIAISON
January 1988
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INTRODUCTION
Waste generated in health care facilities such as hospitals, clinics,
laboratories, pharmaceutical companies, health care practitioners and
similar institutions may include infectious waste, small quantities of
hazardous waste, chemotherapeutic wastes and general refuse. Bacteria,
viruses and fungi in these wastes, if improperly stored, transported,
processed or landfilled could be a danger to workers and the community
at large. In addition, hospital-type waste has the potential to
generate toxic air pollutants if improperly incinerated.
The Department regulates the handling and disposal of infectious waste
— any material that is suspected to be contaminated by disease-
producing microorganisms or materials. This includes items such as
bandages, discarded syringes, and laboratory apparatus as well as
material such as body parts, specimens, and laboratory animal
carcasses.
To minimize emissions from incinerators burning this combination of
wastes, the Department regulates the burning of:
infectious waste from any source; OR
- any waste generated in hospitals or health care facilities, whether
or not it is infectious.
Summary of Provisions for Hospital/Infectious Waste- Management
The Department has long required special handling of these wastes and has
recently strengthened its regulations and policies to ensure safe
handling of all wastes which have the potential to transmit disease.
Requirements include:
Storage and transportation of infectious waste more stringent than
those applicable to ordinary municipal waste.
Mandatory incineration of body parts, animal carcasses and similar
wastes; waste blood may go to a sewage plant, but only if it provides
adequate (secondary) treatment.
Proper sterilization of infectious wastes before disposal, if they
are not incinerated.
New incinerators burning any hospital-type waste (including
infectious waste) will be required to meet air quality standards which
are among the most stringent in the country, as well as apply for a
permit as a waste processor. This will allow the Department to examine
the environmental suitability of the incinerator's location.
No landfill can accept the sterilized infectious waste or ash from
hospital waste incinerators unless DER has approved a specific permit
modification. New rules will require that by the end of the decade
all municipal waste landfills, including those accepting this waste,
meet very stringent requirements such as a double liner.
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The guidelines for air emissions from hospital/infectious waste
incinerators were finalized on January 21, 1988. The new municipal
waste regulations which govern handling of ash residue were approved by
the Environmental Quality Board on December 15, 1987.
Public Involvement: In Permit Decisions
The public participation process for waste processing, waste disposal
and air quality permits are clearly defined in their respective laws
and regulations. Since hospital waste incinerators must get both
waste and air quality permits, the public participation procedure will
be coordinated. At a minimum, procedures will include:
- notification of the community when the Department gets an
application, along with publication of the notice in the Pennsylvania
Bulletin;
- opportunity for a public hearing accessible to the host community;
and
- publication of the permit decision;
Any final Department action is appealable to the Environmental
Hearing Board.
The Department is committed to timely and meaningful public
notification and input. To the extent of our legal jurisdiction, we
are fully prepared to include in a permit's conditions those
requirements we feel appropriate to address those concerns brought to
us in a public forum, and will deny .any permit application if necessary
to protect health and safety.
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PROVISIONS
INFECTIOUS WASTE HANDLING
The municipal waste rules presently contain general provisions to
prevent waste storage areas and collection vehicles from causing health
problems and nuisances such as odors, dust, and vectors (rats and
insects which carry disease). The Department has strengthened those
rules with special requirements for infectious and chemotherapeutic
waste.
The new rules make it explicit that it is illegal to mix this waste in
with ordinary garbage. Infectious/chemotherapeutic waste must be
segregated and stored separately in labelled, distinctively-colored,
closed and leakproof bags and/or containers in areas to which only
authorized persons have access. Infectious waste can only be stored
for one to three days depending upon waste composition (longer if
refrigerated or frozen).
INFECTIOUS WASTE TRANSPORTATION
Requirements for hauling infectious waste are intended to prevent the
release of disease-carrying organisms and to ensure easy identification
in case of emergency. Existing regulations contain provisions
addressing the safety of all municipal waste transportation. For
example, trucks must be routinely inspected and cleaned. The drainage
from equipment cleaning areas is also regulated to avoid water
pollution from this runoff. The new rules make these requirements more
explicit, and strengthen provisions for this special handling waste.
While existing rules require labelled, leakproof, double bags and
prohibit compaction of this waste, the new regulations specify the
thickness of the double bags, and require infectious waste to be
transported in separate, conspicuously identified trucks. Trucks must
have a decontamination unit on board in case of emergencies.
Ash from incinerators must be transported in a covered vehicle. It is
now and will continue to be illegal for a hauler to take sterilized
infectious waste and incinerator ash to a facility that is not
specifically authorized by the Department to accept it.
SAFEGUARDS FOR STERILIZATION
Present rules require that all infectious waste that is not incinerated
be sterilized before disposal. Most often, this is done by the
generator; unsterilized infectious waste then need not be trucked
through a community.
The intention of sterilization is to kill all life stages of the
pathogenic organisms. There are several approved sterilization
methods using heat, steam, gas, chemicals or radiation. A processing
facility must perform routine monitoring to ensure the sterilizer is
working properly. It is illegal for waste processors/haulers to take
waste to a disposal facility which is not specifically authorized to
accept it.
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The new rules specify that waste blood cannot be disposed of in a
municipality's sewage treatment system unless the waste will receive
secondary treatment.
REGULATION OF HOSPITAL WASTE INCINERATORS
Incineration continues to be the most effective and least costly way to
process infectious waste; it also reduces the volume of waste that must
be buried. All municipal waste incinerators are regulated by both air
quality and waste processing regulations.
Air Quality
Many hospitals have their own incinerators. There are about 120
incinerators permitted for hospital waste in the Commonwealth,
including 8 commercial facilities. Incinerators that were built before
1972 and never significantly modified are not required to have a
permit, but must still abide by the Department's regulations for
existing incinerators. These regulations prohibit visible emissions
and set a limit for particulate matter. Usually, operating factors
such as combustion chamber temperature are checked in an inspection as
well to make sure the incinerators are operating properly.
The Department believes that new hospital waste incinerators can and
therefore should meet more stringent standards. Pennsylvania's
regulations (Chapter 127) require that all new air pollution sources
reduce emissions as much as possible by employing "Best Available
Technology" (BAT), which is based on the maximum degree of reduction
continuously achievable for each pollutant, using available control
techniques. In order to. facilitate consistency in the review of permit
applications, the Department has issued BAT criteria guidance documents
for various source categories.
The Department's BAT guidance for hospital waste is among the most
extensive and toughest in the nation. The criteria will be applicable
to new and modified incinerators burning any hospital-type waste,
whether or not it is infectious, AND to any waste that is suspected of
being infectious, whether or not it is generated by a health care
facility. As the name implies, the "best available" criteria will be
revised as control technology improves. The Department may incorporate
conditions more stringent than the BAT criteria into specific plan
approvals, but in no case will the level of protection be less than
that set forth in the criteria.
The BAT criteria document does not specify control devices, but
describes the pollutant emission limits and operating practice
requirements demanded of a new hospital waste incinerator. The BAT
guidance is based on extensive evaluation of the capabilities and
reliability of available process, pollution control, monitoring and
testing technology.
The biggest concern the Department has with hospital waste incinerator
emissions is not pathogens, which are destroyed by relatively low
temperatures, but harmful chemicals produced by the combustion process.
The BAT criteria are actually intended to keep the levels of these
chemicals within the recommended guidelines.
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The Best Available Technology criteria apply to new and modified new
sources. This includes brand new facilities, as well as most
incinerator modifications which might change or increase emissions or
where the capital investment is over 50% of the cost of a new
incinerator. (The BAT criteria for crematoria and animal hospitals will
be determined on a case-by-case basis, incorporating appropriate
requirements from the general guidance.) Facilities burning more than
50 tons of waste per day must also meet permitting conditions for
municipal waste incinerators.
A proposed hospital waste incinerator must undergo a plan review
before construction. The Department will examine its design to
ensure all applicable standards are capable of being met, and then
issue a permit and enforce that permit and operating standards.
Toxics Exposure. Of most concern to the public is the potential for
toxic air chemical contaminant releases. Hospital wastes when burned
improperly have the potential to release harmful organic pollutants
such as dioxins. NO incinerator will be allowed to be constructed that
cannot meet ambient air concentration limits for dioxins/furans, and
for six heavy metals and their compounds (arsenic, beryllium, cadmium,
hexavalent chromium, nickel, lead and mercury).
For potential carcinogens, the Department has used inhalation exposure
levels based upon US Environmental Protection Agency Health Assessment
Documents data that corresponds to a one in a million risk of a
maximally exposed individual developing cancer. These risk estimates
are likely to be higher than the actual risk because the worst case
scenario is chosen- at practically every juncture. For the two non-
carcinogens, lead and mercury, the Department has used levels which are
a small fraction of the Acceptable Daily Intake established by the
federal Centers for Disease Control.
As with municipal waste incinerators, the Department will require
owners of proposed hospital waste combustors to conduct ambient air
impact analyses for these toxic pollutants. The analysis will predict
the concentrations of pollutants in the air at ground level. The
maximum concentration cannot exceed levels in the guidelines. Once the
plant is operating, the assumptions made about the stack emissions must
be verified by actual measurements, and tested periodically. Any
problem causing an incinerator to exceed guideline levels for any one
toxic contaminant must be corrected.
Temperature and Residence Time. High temperatures are essential in the
secondary chamber of an incinerator to destroy the compounds in gases
released during the burning of the waste. The BAT criteria requires a <
temperature of 1800 degrees Fahrenheit in the secondary chamber and for
gases in the exhaust stack. Temperature must be monitored and recorded
continuously.
Residence time refers to the length of time gases are held in the
secondary chamber. A period of 2 seconds will be required, twice that
for ordinary municipal waste incinerators. The longer residence time
is to ensure complete destruction of gases that may be created by the
high concentration of plastics in the waste stream.
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Start-up and shut-down periods are critical times during operation. If
the wastes are loaded before the unit has reached a high enough
temperature, combustion won't be efficient and air contaminants could
be released. The PA criteria prohibit any waste in the chamber until
the required temperatures are reached. All wastes must be burned
completely before the incinerator can be turned off.
Waste Loading and Combustion Chamber Charging. Problems in obtaining
efficient burning of the waste often arise because the waste is loaded
incorrectly. For example, too much waste will reduce the available
oxygen needed to support combustion. Opening the door to a chamber
while waste is being burned lowers the temperature, as any good cook
knows. The BAT criteria contain two requirements addressing this
problem:
an interlock, which is a device preventing the charging of
an incinerator unless the secondary chamber temperature is established
and is holding at 1800 degrees.
automatic loaders for all but the smallest units, to ensure that
the combustion chamber cannot be overloaded and to prevent the door
being opened during the cycle. (Small units generally are batch-fed,
receiving a set amount of waste at one time rather than fed waste
continuously.)
Stack Standards. Available new incinerators range in size from the
very small, appropriate for an average hospital, to the large units
more likely to be installed at a site taking waste from many different
facilities. For nontoxic pollutants, the criteria contain different
stack emission limits for each of three size classes of incinerators,
based on the most appropriate technology for each. The emission limits
become more stringent for the larger units, in some cases more
stringent than those EPA requires for hazardous waste incinerators.
ALL incinerators must meet the same toxic pollutant ambient impact
analyses and operating requirements described above. This size
distinction was adopted because:
o many of the smallest units intended for on-site incineration
would simply not be affordable to hospitals if the emission limits
were more stringent for that class. There is a health and safety
benefit to on-site incineration, because infectious waste never
has to travel through the community.
o emission limits are expressed in terms of concentration, which
is usually measured as the number of molecules of pollutant for
every million molecules of oxygen or other element in the exhaust.
The total number of pollutant molecules may be no greater from a
smaller facility even if. the concentration limit is higher because
there are fewer molecules of exhaust gas against which to count
them.
The Department will require continuous monitoring and recording for
many factors. This will not only give the operator instant information
on emissions and other parameters but will give the permittee and the
Department recorded data from which to diagnose and correct any
operating problems, as well as on which to base enforcement actions.
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It should be pointed out in discussing emission limits that a limit
based on an average over a short period of time, like minutes and
hours, is in effect much more stringent than one based on an average
over a longer period of time.
For setting stack limits, incinerator classes are those with the
capacity to burn: 1) under 500 pounds of waste per hour; 2) between
500 and 2000 pounds per hour; and, 3) over 2000 pounds per hour.
Carbon monoxide (CO); Minimizing CO indicates good combustion and
also minimizes toxic organics. The BAT criteria for hospital
incinerators are much more stringent than for other municipal waste
combustors, since they prohibit more than 100 parts per million
averaged over an hour.' The municipal waste standard is 100 parts per
million averaged over eight hours. The limit is the same for all
classes, and continuous monitoring is required for all but the smallest
units.
Combustion efficiency: This is a "redundant" measurement calculated
from parameters (CO and Carbon dioxide) already required to be
monitored for the largest sized units. The largest units must meet the
very stringent combustion efficiency standard of 99.9 percent averaged
hourly rather than the eight hour average for other municipal waste
incinerators and monitored continuously. The oxygen corrected CO level
can also effectively monitor combustion efficiency. The CO requirement
of 100 ppm corrected to 7 percent Oxygen is equivalent to a combustion
efficiency level of 99.9 percent.
Hydrochloric acid (HC1); Most states do not require controls on
this acid gas. For the larger two classes and for municipal waste
incinerators, the permitting criteria require no more than 30 parts
per million (or a reduction of 90%). For the smallest class, HC1 is
measured differently, but limits are equal to that required of
hazardous waste incinerators. Continuous monitoring is required for
the largest class of units.
Sulfur dioxide (SO2): Except for the smallest units, a limit of 30
parts per million averaged hourly, or a reduction of 70%, is imposed.
Particulates; An excess of these small particles of solid material
would indicate poor combustion, and would create a visible plume.
Minimizing particulates also minimizes release of toxic metals. The
largest units must meet the same standards as other municipal waste
incinerators, .015 grains of particulate per dry cubic foot of exhaust
gas. Mid-sized units must meet a .03 grain standard and smaller units
a .08 standard, which is still equal to EPA standards for hazardous
waste incinerators.
Opacity: Opacity is another indicator of good combustion. Zero
opacity means the exhaust is invisible, while exhaust with 100% opacity
would produce a thick plume of smoke. The opacity limit is the same for
all classes, no more than 10% averaged over three minutes and never
more than 30%. This must be monitored continuously in all but the
smallest units.
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Testing for Toxics; The largest hospital incinerators must test no
Less often than every 6 months for the metals and every 12 months for
dioxins. Mid-sized units must test annually for all toxics, while
testing frequency for the smallest units will be determined by the
Department individually.
Malfunctions. There are several factors which are so important to air
quality that the Department is requiring that the feed to an
incinerator (except batch-fed units) must be shut off if any one of
them is exceeded for over 15 minutes: 1) temperature in the secondary
chamber falling below 1800 degrees; 2) carbon monoxide over 150 parts
per million; 3) flue gas oxygen below 6%; or, 4) opacity over 10%. The
problem must be corrected before waste loading can continue.
The Department is to be notified immediately by telephone of equipment
failure or other problems which result in emissions above requirements.
The Department must be notified in writing within 5 days about these
problems and the measures taken to correct them. It should be noted
that any short-terra increase in toxics at ground levels due to a 15
minute malfunction is so insignificant as to be unmeasurable in terms
of increased risk to human health.
Operator Training. The Department will require applicants to submit
the contents of operator training material for approval. Prior to
start-up of the facility, the applicant must verify that its operators
have been properly trained. Facilities cannot be operated by anyone
that has not been so qualified.
The Department will also be developing a detailed enforcement strategy
to specify the type and frequency of inspections, monitoring and test
review procedures and specific actions the Department will take upon
any violation.
Facilities already in existence are usually not required to retrofit to
meet the same standards as new ones because the same technology for
pollution control may not be available or would be immensely costly to
install. However, the Bureau of Air Quality Control wants to assess
any potential health risk in Pennsylvania due to emissions of existing
hospital waste incinerators. The Bureau plans to visit every health
care facility in the Commonwealth to locate and evaluate all hospital
waste incinerators. The Department will then have the data to make a
decision on whether it is necessary to revise regulations for existing
hospital waste incinerators.
Waste Management
The existing municipal waste regulations contain detailed plan
submission and operating requirements for waste processing facilities,
including incinerators. Under current policy, the Department may also
require submission of nonenvironmental socioeconomic information from
waste processors to use in making its permitting decision. Of course,
incinerators must abide by rules applicable to waste storage and
transportation of ash.
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In addition to requirements which run the gamut from insurance to
signs, the new rules contain specific siting prohibitions for waste
processors such as hospital waste incinerators: they cannot be located
in a 100 year floodplain, within 300 feet of an important wetland,
within 300 feet of an occupied dwelling without a waiver, within 100
feet of a perennial stream, and within 50 feet of the property line.
Under existing regulations, a log must be kept of the types and
quantities of waste incinerated. Prior to initial disposal and
periodically thereafter, ash sample analyses must be reviewed by the
Department to ensure it is suitable for the intended disposal.
Ash from all hospital incinerators (old and new) is considered a
"special handling" waste and must be taken to a landfill that has an
approved permit modification from the Department to take this waste.
Disposal of Infectious/Hospital Waste Incinerator Ash. Incinerator ash
residue and sterilized infectious waste must be landfilled.. Landfilling
of properly sterilised waste from hospitals poses no more risk than
other municipal waste. The amount of hospital-type waste being
landfilled is small in proportion to the total amount of municipal
waste. Hospital incinerator ash may be even less intrinsically harmful
because it is unlikely ash will have processed tires, batteries,
discarded paint and other problem household wastes. Recent studies
seem to confirm that the ash from a properly operated incinerator
contains no disease-producing microorganisms.
In approving an application for disposal of special handling waste, the
Department will ensure that the disposal facility is making sure the
waste has been properly processed. Many landfills approved to accept
sterilized infectious waste require a waste tracking system even though
it is not required by the Department.
An application for disposal of these special wastes must include a
detailed description of the type and source of waste and of the
sterilizing or incinerating process. The Department requires ash to be
tested under conditions that simulate a landfill and may, if necessary,
impose special disposal conditions in a permit to prevent leaching of
heavy metals.
By the end of the decade, the Department intends that only landfills
that meet the new stringent municipal waste disposal regulations
continue to operate. Most design and operating requirements for these
landfills will be similar to those for hazardous waste landfills. The
new regulations require all landfills to be re-permitted within two
years of the date the rules are effective. This means that even
expansions at existing landfills will have to meet the stringent
requirements for liners and leachate collection systems, waste sampling
and recording, groundwater monitoring, financial responsibility, and
the like. The only exceptions are that the Department cannot
reasonably require waste already deposited to be excavated to install a
liner or that an already operating facility meet many siting
requirements. The Department will continue to require a special
application from facilities to dispose of sterilized infectious waste
and hospital incinerator ash.
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1/21/38
BEST AVAILABLE TECHNOLOGY
AND
CHAPTER 127 FLAN APPROVAL CRITERIA
FOR
HOSPITAL/INFECTIOUS WASTE INCINERATORS
APPLICABILITY
This document specifies the plan approval requirements for
hospital/infectious waste incinerator facilities including Best
Available Technology (BAT) as required by 25 Pa. Code 127.12(a)(5).
This document is not intended to be a comprehensive listing of the
Chapter 127 requirements. Rather, it elaborates on selective
provisions of Chapter 127. The applicable capacity refers to the
facility rather than the individual unit. However the emission
limitations are applicable to individual units.
This criteria is not applicable to crematory incinerators or
incinerators located in any hospital or in any medical care facility
if the units will be used to incinerate only general refuse, provided
that the applicant demonstrates that the proposed incinerator will
burn only general refuse and the infectious, hazardous., and
chemotherapeutic wastes will be segregated and disposed of
satisfactorily. The permitting criteria for such incinerators will be
determined on a case-by-case basis incorporating the requirements of
this Criteria as appropriate.
This Criteria will be periodically revised as control technology
improves.
In addition to these applicable permitting requirements,
facilities capable of burning hospital/infectious wastes at rates
greater than or equal to 50 tons per day shall also meet the
permitting criteria established for municipal waste incineration and
resource recovery facilities capable of burning municipal wastes at
rates greater than or equal to 50 tons per day.
DEFINITIONS
INCINERATOR - Any device specifically designed to provide the
controlled combustion of wastes with the products of combustion
directed to a flue as defined at 25 Pa. Code Section 121.1.
HOSPITAL WASTE - Wastes generated in any hospital or any health care
facility or any pathological wastes (except for human and animal
remains burned in a crematory incinerator), chemotherapeutic wastes or
infectious wastes generated in any facility.
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INFECTIOUS WASTE - Waste that contains or may contain any disease
producing microorganism or material.
Infectious wastes include, but are not limited to, the following:
(a) Those wastes that are generated by hospitalized patients who
are isolated in separate rooms in order to protect others from their
severe and communicable disease.
(b) All cultures and stocks of etiologic agents.
(c) All waste blood and blood products.
(d) Tissues, organs, body parts, blood and body fluids that are
removed during surgery and autopsy, and other wastes generated by
surgery or autopsy of septic cases or patients with infectious
diseases.
(e) Wastes that were in contact with pathogens in any type of
laboratory work, including collection containers,, culture dishes,
slides, plates and assemblies for diagnostic tests; and devices used
to transfer, inoculate and mix cultures.
(f) Sharps, including hypodermic needles, suture needles,
disposable razors, syringes, pasteur pipettes-, broken glass and
scalpel blades.
(g) Wastes that were in contact with the blood of patients
undergoing hemodialysis at hospitals or independent treatment centers.
(h) Carcasses and body parts of all animals which were exposed
to zoonotic pathogens.
(i) Animal bedding and other wastes that were in contact with
diseased or laboratory research animals or their excretions,
secretions, carcasses, or body parts.
(j) Waste biologicals (e.g., vaccines) produced by
pharmaceutical companies for human or veterinary use.
(k) Food and other products that are discarded because of
contamination with etiologic agents.
(1) Discarded equipment and equipment parts that are
contaminated with etiologic agents and are to be discarded.
CHEMOTHERAPEUTIC WASTE - All waste resulting from the production or
use of antineoplastic agents used for the purpose of stopping or
reversing the growth of malignant cells. Chemotherapeutic waste shall
not include any waste containing antineoplastic agents that are listed
as hazardous waste under 25 Pa Code Section 75.261 (relating to
criteria, identification, and listing of hazardous waste).
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HOSPITAL/INFECTIOUS WASTE INCINERATOR FACILITY - Any combination of
hospital/infectious waste incinerators located on one or more
contiguous or adjacent properties and which is owned or operated by
the same person or by persons under common control.
CREMATORY INCINERATOR - Any incinerator designed and used solely for
the burning of human remains or animal remains.
BEST AVAILABLE TECHNOLOGY REQUIREMENTS
A. Emission Limitations
1. Facilities with capacity <500 Ibs/hr:
a. Particulate matter emissions shall not exceed 0.08 grain per
dry standard cubic foot of exhaust gas, corrected to 7% ©2-
b. Carbon monoxide (CO) emissions shall not exceed 100 ppmv,
hourly average/ corrected to 7% ©2 on a dry basis.
c. Hydrochloric acid (HC1) emissions shall not exceed 4 Ibs/hr
or, shall be reduced by 90% (by weight) on an hourly basis.
d. Visible air contaminants shall not be emitted in such a
manner that the opacity of the emissions is equal to or
greater than 10% for a period or periods aggregating more
than 3 minutes in any one hour; or equal to or greater than
30% at any time.
2. Facilities with capacity >500 Ibs/hr and £2000 Ibs/hr:
a. Particulate matter emissions shall not exceed 0.03 grain per
dry standard cubic foot of exhaust gas, corrected to 7% ©2-
b. Carbon monoxide (CO) emissions, as measured at a location
upstream of the control devices, shall not exceed 100 ppmv,
hourly average, corrected to 7% ©2 on a dry basis.
c. Hydrochloric acid (HC1) emissions shall not exceed 30 ppmv,
hourly average, corrected to 7% O2 on a dry basis; or, shall
be reduced by 90% by weight on an hourly basis.
d. Sulfur dioxide (SO2) emissions shall not exceed 30 ppmv,
hourly average, corrected to 7% O2 on a dry basis; or shall
be reduced by 75% (by weight) on an eight-hour basis.
e. Visible air contaminants shall not be emitted in such a
manner that the opacity of the emissions is equal to or
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greater than 10% for a period or periods aggregating more
than 3 minutes in any one hour; or equal to or greater than
30% at any time.
3. Facilities with capacity >2000 Ibs/hr:
a. Particulate matter emissions shall not exceed 0.015 grain
per dry standard cubic foot of exhaust gas, corrected to 7%
b. Carbon monoxide (CO) emissions, as measured at a location
upstream of the control devices, shall not exceed 100 ppmv,
hourly average, corrected to 7% ©2 on a dry basis.
c. Hydrochloric acid (HC1) emissions shall not exceed 30 ppmv,
hourly average, corrected to 7% ©2 on a dry basis; or, shall
be reduced by 90% (by weight) on an hourly basis.
d. Sulfur dioxide (802) emissions shall not exceed 30 ppmv,
hourly average, corrected to 7% 02 on a dry basis; or shall
be reduced by 75% (by weight) on an eight-hour basis.
e. Combustion efficiency (C.E.) shall be at least 99.9 percent
on a hourly basis, computed as follows:-
C.E. = . [COol _ x 100
[C021 + [CO]
[CO?] = Concentration of carbon dioxide
[COJ - Concentration of carbon monoxide
f . Visible air contaminants shall not be emitted in such a
manner that the opacity of the emissions is equal to or
greater than 10% for a period or periods aggregating, more
than 3 minutes in any one hour; or equal to or greater than
30% at any time.
B. Operating Requirements
1. The secondary chamber shall be maintained at a temperature of
1800°F. The temperature of 1800°F shall be maintained for at
least 2 seconds with a minimum secondary chamber residence time
of 1 second. The ducting between the secondary chamber and heat
recovery system or the breaching and a portion of the stack
(tertiary chamber) may if desired, be included for the residence
time demonstration. The temperature exiting the tertiary chamber
shall be maintained at 1800°F. A thermocouple shall be
appropriately located to confirm the temperature. The auxiliary
(secondary and tertiary) burners of the incinerator should be
designed such that without the assistance of the heat content of
the waste, a minimum temperature of 2000°F can be maintained for
at least 2 seconds.
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2. The firing of the burners and the combustion air shall be
modulated automatically to maintain a secondary chamber exit
temperature of 1800°F.
3. The incinerator shall be equipped with an automatic loader except
for units with capacities less than or equal to 300 Ibs/hr and
equipped with the interlocks specified in paragraph B.4.
However, a sealed feeding device capable of preventing combustion
upsets during charging will be required for the units with
capacity less than 300 Ibs/hr.
4. For batch fed incinerators, interlocks should be provided to
prevent charging until: (1) the secondary chamber exit
temperature is established and holding at 1800°F; and, (2) the
combustion cycle is complete.
5. For non-batch fed incinerators, the charging of waste to the
incinerator shall automatically cease through the use of an
interlock system if:
a. The incinerator's secondary temperature drops below 1800°F
for a 15 minute period, or
b. The carbon monoxide emissions are equal to or greater than
150 ppmv, corrected to 7% 02 on a dry basis for a 15 minute
period, or
c. The flue gas oxygen level drops below 6% (wet basis) for a
15 minute period, of
d. The opacity of the visible emissions is equal to or greater
than 10% for a period of 15 minutes.
OTHER CHAPTER 127 REQUIREMENTS
C. Ambient Impact Analyses
Ambient impact analyses shall be conducted for: a) arsenic and
compounds; b) beryllium and compounds; c) cadmium and compounds; d)
hexavalent chromium and compounds; e) lead and compounds; f) mercury
and compounds; g) nickel and compounds; h) polychlorinated
dibenzo-p-dioxins (PCDD) and polychlorinated dibenzofurans (PCDF)
expressed as 2,3,7,8 tetrachlorinated dibenzo-p-dioxin (TCDD)
equivalents using toxicity equivalents factors (TEFs) described in
Appendix A. Using available emission factors, the emissions from the
facility shall be estimated and the analyses shall be conducted by
performing dispersion modeling using the facility's exhaust
characteristics. The analyses shall be conducted in accordance with
the procedures stipulated in Appendix C.
-------
If the application is subject to "Prevention of Significant
Deterioration" (PSD) requirements, the analyses shall be conducted in
accordance with the "Guidelines on Air Quality Modeling" dated
January, 1983 (as revised). The applicant should discuss the modeling
requirements with the Department prior to starting any modeling study.
The analysis must show that predicted concentrations do not
exceed the following annual ambient concentrations. Levels exceeding
these concentrations have been determined by the Department to be
unacceptable.
Ambient Concentration
Contaminants (ug/ml)
Arsenic and compounds 0.23 x 10~3
Beryllium and compounds 0.42 x 10"3
Cadmium and compounds 0.56 x 10 ~3
Hexavalent Chromium and compounds 0.83 x 10"4
Lead and compounds 0.50
Mercury and compounds 0.08
Nickel and compounds . 0.33xlO~2
PCDD & PCDF expressed as
2,3,7,8 TCDD equivalents 0.30 x 10~7
Compliance shall be verified by stack sampling as described in
paragraph F. Using the actual stack emission rates, the exhaust
parameters from each test and the dispersion modeling techniques
specified in'the application as approved by the Department, the
calculated maximum annual ambient concentrations shall not exceed the
above levels.
P. Monitoring Requirements
The primary chamber temperature and secondary chamber exit
temperature shall be continuously measured and recorded. Sensors
shall be located such that flames from the burners do not impinge on
the sensors.
Incinerators with a capacity larger than 500 Ibs/hr shall be
equipped with instruments for the continuous monitoring and recording
of Oj, CO and opacity. Continuous monitoring and recording for CC^,
is also required for facilities with a capacity greater than or equal
to 2000 Ibs/hr.
The Department reserves the right to require the owner/operator
of facilities with a capacity less than 2000 Ibs/hr, to install SO2
monitors at a time after the initial compliance tests if it is deter-
mined to be necessary. The Department also reserves the right to re-
quire facilities with a capacity greater than 2000 Ibs/hr, to install
HC1 and SC>2 monitors at any time if it is determined to be necessary.
The Oo, CO and COj monitors, when required, shall be co-located
upstream of the air pollution control devices. If the applicant
230
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chooses to comply with SO2 and HC1 emission limitations by meeting the
75% and 90% reduction requirement, the SC>2 and HC1 monitors, when
required, shall be located upstream and downstream from the air
pollution control device. If the applicant chooses to monitor the two
locations with a single detector, the two locations should be sampled
at an interval acceptable to the Department.
Continuous monitoring shall be conducted in accordance with 25 Fa
Code Chapter 139 and be approved by the Department.
The Department reserves the right to require, at a later date,
the owner/operator to provide telemetering of continuous monitoring
data to the Department.
E. Start-up and Shut-down Requirements
No waste shall be charged to the incinerator until equilibrium at
the required temperature has been attained in the chambers. The
control equipment shall be operational and functioning properly prior
to the introduction of waste into the incinerator and until all the
wastes are incinerated.
During shutdowns the required temperatures are to be maintained
in the chambers using auxiliary burners until the wastes are
completely combusted.
A.detailed procedure for normal system start-up and shut-down
shall be submitted as a part of the application for approval including
the duration of preheat and burn-out cycles.
F. Testing Requirements
1. Facilities with capacity <500 Ibs/hr:
Source tests shall be conducted for: a) particulate matter; b)
HC1; c) CO; d) arsenic and compounds (expressed as arsenic); e)
beryllium and compounds (expressed as beryllium).; f) cadmium and
compounds (expressed as cadmium); g) hexavalent chromium and compounds
(expressed as chromium); h) lead and compounds (expressed as lead); i)
mercury and compounds (expressed as mercury); j) nickel and compounds
(expressed as nickel); and k) FCDD and PCDF (expressed as
2,3,7,8 TCDD equivalents).
The Department reserves the right to require the owner or
operator to conduct further source tests at any time if it is
determined to be necessary by the Department after the initial
compliance tests.
2. Facilities with capacity >500 Ibs/hr and £2000 Ibs/hr:
Source tests shall be conducted for: a) particulate matter; b)
HC1; c) CO; d) SO2; e) arsenic and compounds (expressed as arsenic);
231
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f) beryllium and compounds (expressed as beryllium); g) cadmium and
compounds (expressed as cadmium); h) hexavalent chromium and compounds
(expressed as chromium); i) lead and compounds (expressed as lead); j)
mercury and compounds (expressed as mercury); k) nickel and compounds
(expressed as nickel); and 1) PCDD and PCDF (expressed as 2,3,7,8 TCDD
equivalents).
The owner or operator shall conduct source tests at any time or
interval of time as may be prescribed by the Department. At a minimum,
source tests shall be conducted for the above specified pollutants
every year. As a data base is established and the emissions
consistently show compliance the schedule may be altered.
3. Facilities with capacity >2000 Ibs/hr:
Source tests shall be conducted for: a) particulate matter; b)
HC1; c) CO; d) SO2; e) arsenic and compounds (expressed as arsenic);
f) beryllium and compounds (expressed as beryllium) g) cadmium and
compounds (expressed as cadmium); h) hexavalent chromium and compounds
(expressed as chromium); i) lead and compounds (expressed as lead); j)
mercury and compounds (expressed as mercury); k) nickel and compounds
(expressed as nickel); and 1) PCDD and PCDF (expressed as 2,3,7,8 TCDD
equivalents).
The owner or operator shall conduct source tests at any time or
interval of.time as may be prescribed by the Department. At a minimum,
source tests shall be conducted:
a. For all pollutants specified in F.I of this criteria except
PCDD and PCDF - every six months, and
b. For PCDD and PCDF - every year.
c. For HC1 and SO2 (if monitors are required) - as required by
the Department for the initial certification and system
performance audits of the continous monitors.
As a data base is established and the emissions consistently show
compliance the schedule may be altered.
All tests are to be conducted in accordance with the Department's
source testing procedures described in "Source Testing Manual,
Revision No. 1" (as revised) dated January, 1983. Source testing
procedures are to be approved by the Department prior to testing.
G. Record Keeping and Reporting Requirements
Continuous emission/parameter data gathered from the monitors
shall be submitted to the Department quarterly. The data shall be
retained for at least two (2) years following the date of record and
shall be made available to the Department during facility inspections.
232
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The Department shall be notified by telephone immediately
following any failure of process equipment, failure of any air
pollution control equipment, failure of any monitoring equipment, or a
process operational error which results in an increase in emissions
above any allowable emission rate. In addition, the Department shall
be notified in writing of the problem and measures taken to correct
the problem as expeditiously as possible but no later than five (5)
days following such failure.
H. Operator Training Requirements
Prior to the start-up, all incinerator operators shall be trained
by the equipment manufacturers' representatives and/or another
qualified organization as to proper operating practices and
procedures. The content of the training program shall be submitted to
the Department for approval. The applicant shall submit a copy of a
certificate verifying the satisfactory completion of a training
program prior to issuance of the operating permit. The applicant
shall not operate the incinerator without an operator who has
satisfactorily completed the training program.
I. General Application Requirements
The plan approval application shall include a description of each
specific waste and approximate quantity of each such wastes which will
be charged to the incinerator. The application shall, as a minimum,.
contain the final design specifications of the incinerator and the
associated air pollution control devices with dimensioned drawings
indicating the locations of burners, air injection ports and monitors.
The application shall also include an estimate of potential and actual
emissions of the non-typical air contaminants. These contaminants
shall include: a) HC1; b) PCDD and PCDF (expressed as 2,3,7,8 TCDD
equivalents (estimated as potential and actual emissions)); c)
arsenic; d) beryllium; e) cadmium; f) hexavalent chromium; g) nickel;
h) lead; and, i) mercury. The application shall also include a set of
calculations for estimating secondary chamber residence time using the
procedures contained in Appendix B and the results of ambient impact
analyses conducted using the modeling procedures contained in
Appendix C.
Approved by:
K.
5ureau of Air Quality Control
January 21, 1988
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APPENDIX A
2,3,7,8 - TCDD Toxicity Equivalence Factors (TEFs)
Homoloque/Congener
Mono through trichloro dioxins and
Dibenzofurans
2,3,7,8-TCDD
Other TCDDs
2,3,7,8-PeCDD
Other PeCDDs
2,3,7,8-HxCDDs
Other HxCDDs
2,3,7,8 HpCDDs
Other HpCDDs
OCDDs
TEF
2,3,7
Other
2,3,7
Other
2,3,7
Other
2,3,7
Other
OCDFs
,8-TCDF
TCDFs
,8 PeCDFs
PeCDFs
,8-HxCDFs
HxCDFs
,8-HpCDFs
HpCDFs
0
1
0.01
0.5
0.005
0.04
0.0004
0.001
0.00001
0.1
0.001
0.1
0.001
0.01
0.0001
0.001
0.00001
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APPENDIX - B
RESIDENCE TIME CALCULATION GUIDANCE
The review of all incinerators shall include verification of the
residence time stated on the application. This guidance shall be
followed to assure that these calculations are handled in a uniform
manner.
STEP 1. Estimate the total heat input to the system:
Total system heat input (Btu/hr) =* [Maximum waste
firing rate (Ibs/hr) x Maximum heating value (Btu/lb)]
•»• Average primary burner heat input + Average secondary
burner input.
Note: Use the average burner inputs required after the
onset of waste burning.
Use a waste heating value of 8500 BTU/lb.
STEP 2. Estimate the system heat loss (prior to heat recovery):
System heat loss = Shell loss + sensible heat in ash +
sensible heat in unburned carbon + latent heat.
The heat loss may be assumed to be 20% of total heat
input.
STEP 3. Calculate the net heat available (Q) to raise the
temperature of the products of combustion:
Q (Btu/hr) = (Total system heat input) - (system heat
loss)
STEP 4. Calculate the weight of product of combustion (M)
M = Q/{Cp x (T0 - Ti)}
CTJ = average specific heat (Btu/lb °F), assume a value
* of 0.28.
T0 = exit temperature (°F), use the design temperature
of 2000 °F as To.
Tj_ = ambient air temperature (°F), assume the ambient
temperature to be 70°F.
STEP 5. Calculate the volume of product of combustion (F):
F(SCfs) « M
d x 60 x 60
235
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d (Ib/cu. ft.) = density of exhaust gases at 70°F, use
a value of 0.075.
F'(acfs) = F x (T^ + 460)
530
F' @ design temperature = F x 2460
530
STEP 6. Calculate the volume of secondary chamber and tertiary
chamber (if tertiary chamber is included for the 2
second residence time demonstration). Tertiary chamber
is the area between secondary chamber and heat recovery
system or breaching area/part of the stack..
STEP 7. Residence time = Chamber volume
F1
For a minimum 1 sec secondary chamber residence time,
secondary chamber volume = >i
F'
For a minimum 2 sec Qdesign temperature 2000°F,
secondary + tertiary chamber volume = >2 '
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APPENDIX C
DISPERSION MODELING PROCEDURES
I. PROCEDURE FOR DETERMINATION'OF STACK HEIGHT ADEQUACY AND BUILDING
INFLUENCES ON STACK PLUME DISPERSION
In the absence of any outside interference on the dispersion of
stack plumes, the PTPLU dispersion model can be used to make a
conservative screen of ground level concentration. Most of the time
influences do exist, and they must be considered. First the building
or buildings of potential influence must be determined. When more
than one building is likely to influence the stack plume dispersion,
the controlling influence needs to be determined. Except in
infrequent cases the determination of potential building influence
shall be made of buildings on site at the facility.
The building influence can be determined as follows:
A. DETERMINE POSSIBLE BUILDING INFLUENCE;
1. Determine the height (H) and projected width (W) of the
tallest building at the facility.
2. Draw a circle with a radius of 10 H or 10 W (whichever is
less) around the building.
3. Disregard any possible building influence if the stack is
not within the circle, as determined in step 2, above.
4. Working closer to the stack from the distance of the
tallest building, repeat steps 1, 2, and 3 above to
determine which other buildings may also exert an influence
on the stack.
5. If no buildings are considered significant enough to exert
an influence on the stack, skip the remaining sections in
this APPENDIX and use METHOD A for dispersion modeling.
B. DETERMINE BUILDING CAVITY HEIGHT;
1. Calculate the building cavity height (Hc) for all
significant buildings (found by the procedure in Section A)
by use of the following formula:
Hc = H + 0.5 L, where L is the lesser of the building
height or projected width.
2. Select the building with the largest cavity height as the
one which would exert the greatest influence.
237
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C. CHECK STACK HEIGHT ADEQUACY:
1. Check to insure that stack design would not obstruct good
dispersion of substance (i.e., no rain caps, elbows, etc.).
2. If the physical stack height is greater than He, and if the
distance of 10 L (the building wake region) does not extend
beyond the plant boundary, skip the rest of the appendix,go
to page C-4 and use METHOD A.
3. Calculate the effective stack height, HQ, using the
following formula:
He s Hs + % where Hs is physical stack height and H^ is
momentum plume rise calculated by the following equations
(Ref: Regional Workshops on Air Quality Modeling; Summary
Report, EPA-450/4-82-015, Appendix C, page C-2, (Amended
October 1983)):
1/3
where b •« ( 1/3 + u/vs),
u = critical wind speed (m/s),
(assume 7.5 m/s)
x = downwind distance (m) (assume 2 building
heights or projected widths downwind,
whichever is less),
Fm = momentum flux =(Ta/Ts) Vs2*d2/4
Ta - ambient air temperature (°K) (assume
293°K),
Ts - stack exit temperature (°K),
Vs - stack exit velocity (m/s); and
d ss stack inner diameter (m).
4. If He is greater than Hc and if the distance of 10 L (the
wake region) does not extend beyond the plant boundary, skip
the rest and use METHOD A found in page C-4.
5. Go to page C-4 and use METHOD B for all remaining cases.
The PTPLU-2 dispersion model (METHOD A) may be used for screening if:
(1) there are no building influences predicted by the procedure in
Section A above, or (2) the stack height is adequate and there are no
building wake effects beyond the property line (according to Section C
above).
238
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II. DISPERSION MODELING PROCEDURES
For screening purposes, the PTPLU dispersion model may be used
for evaluation of point sources in cases where no building influences
are expected. Some judgement must be made, however, in cases where
stack designs (rain caps, elbows, etc.) may result in poorer
dispersion. Where building influences may be of concern, as
determined earlier, conservative estimates of the maximum ground level
annual ambient concentrations within a building cavity region or
building wake effect region should be made and compare these values
with the acceptable ambient concentration for the substance.
METHOD A: [PTPLU- 2 (Version 6 from EPA UNAMAP) Model)]
1. Use the following assumption: Ambient temperature 293°K, mixing
height 1500 m, and a receptor height of 2m.
2. Enter the stack parameter data in metric units: stack
temperature (°K), stack flow ( m3/sec), stack area (m2) and the
emission rate (g/sec).
3. The model will predict hourly ground level concentrations for
the substance (ug/m3) for each of six stability classes at
various downwind distances from the stack.
4. Determine the maximum hourly concentration predicted and convert
this value to an annual concentration by multiplying the hourly
concentration by a factor of 0.15.
METHOD B (Building Influences);
1. For building cavity situations, as determined in APPENDIX C-l
calculate the maximum ground level concentration (in ug/m3)
expected in the cavity by the formula:
where X = the maximum annual concentration (y.g/m3),
Q - is the emission rate (g/sec),
U SB the wind speed (m/sec),
A ~ the building area (height of building times its
projected width) (m2); and
1.5 is a coefficient recommended by EPA.
2. For building wake effect regions extending beyond the facility
property line, as determined in APPENDIX C-l, calculate the
maximum ground level ambient concentration (ug/m3) in the wake
effect region by using the ISCST model with representative
"worst case" meteorological conditions [refer to Regional
Workshops on Air Quality Modeling: A Summary Report,
EPA-450/4-82-015, Appendix C, pages C-4 through C-6 (amended
October 1983) for guidance].
239
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3. If predicted values of "X" exceed the acceptable ambient
concentration in either Step 1 or 2, the applicant shall use
dispersion models approved by the Department.
240
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GUIDELINES FOR THE HANDLING AND DISPOSAL
OF BIOMEDICAL WASTES FROM
HEALTH CARE FACILITIES AND LABORATORIES
John Manuel
Waste Management Branch
Ministry of the Environment
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
241
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TABLE OF CONTENTS
Page
INTRODUCTION
1.0 DEFINITION AND CLASSIFICATION OF WASTE 2
1.1 Biomedical Waste 2
1.1.1 Pathological Waste 2
1.1.2 Infectious Waste 2
1.2 Other Biomedical Waste Requiring Special Handling 3
2.0 PACKAGING OF BIOMEDICAL WASTE 3
2.1 Red Bag 3
2.2 Orange Bag 3
2.3 Yellow Bag 4
2.4 Sharps - Hard Shell Container 4
2.5 Waste - Non-Infectious 4
3.0 DISPOSAL OF BIOMEDICAL WASTE 4
3.1 Incineration 4
3.1.1 Pathological Waste 4
3.1.2 Infectious Waste • 5
3.2 Steam Decontamination (Autoclave) 5
3.3 New Technology for Decontamination 5
3.4 Disposal of Other Types of Biomedical Waste 5
3.4.1 Decontaminated Waste Requiring Special Handling 5
3.4.2 Sharps (e.g. needles, scalpels, etc) 5
3.4.3 Radioactive, Chemical, Organic Waste 5
3.5 Liquid Infectious Waste Disposal 5
3.6 Blood 6
3.7 Waste - Non-Infectious - Requiring Special
Handling 6
4.0 RIGID OUTER CONTAINER - FOR UNTREATED
PATHOLOGICAL OR INFECTIOUS BIOMEDICAL WASTE 6
5.0 STORAGE OF BIOMEDICAL WASTE 6
5.1 Refrigerated Storage of Anatomical Waste 7
6.0 PROTECTION OF PERSONNEL 7
7.0 ON-SITE DISPOSAL OF WASTE 7
8.0 OFF-SITE DISPOSAL - CARRIER'S CERTIFICATE 7
9.0 SHARING OF EXISTING INCINERATOR FACILITIES
BY OTHER HOSPITALS 8
10.0 INTER-HOSPITAL TRANSPORTATION OF BIOMEDICAL
WASTE 8
REFERENCES 9
APPENDICES
A.I SAFETY PROCEDURES FOR PERSONNEL HANDLING
INFECTIOUS WASTE 10
A.II GUIDELINES FOR VEHICLES TRANSPORTING
ANATOMICAL OR INFECTIOUS WASTE 12
242
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INTRODUCTION
The title of these guidelines has been changed to reflect
current usage. Previously the terms "pathological" and
"institutional" were used to refer to what is now accepted to
be "bioraedical" waste. The term "biomedical" waste used
throughout these guidelines now includes pathological waste,
infectious waste, hazardous waste, and other waste generated
in health care facilities and laboratories that requires
special handling.
Some years ago, two separate groups in Metro Toronto became
concerned about existing practices of waste disposal from
hospitals and veterinaries. The Ontario Hospital Association
was concerned about the increasing amounts of biomedical
waste being generated by hospitals and also by the fact that
existing hospital incineration facilities were rapidly
becoming overloaded. At the same time, Metro Toronto public
health officials were concerned about the limited biomedical
waste disposal facilities available in the community.
These guidelines for the handling and disposal of bioraedical
waste supersede the February, 1982 edition of the Ministry of
the Environment guidelines for the handling and disposal of
pathological wastes and institutional wastes. These new
guidelines cover the special precautions associated with the
handling, storage, collection, transportation and disposal of
biomedical waste from health care facilities and labora-
tories. The guidelines have been developed to minimize the
risk of adverse environmental effects and the risk to public
health in Ontario. Non-hazardous waste from offices,
kitchens and mechanical plant which does not require special
handling is not considered biomedical waste.
The 1986 guidelines should be followed unless other measures
taken are directed, or expressly permitted, by other applic-
able Ontario or Federal legislation. It should be noted that
such other legislation may impose more stringent requirements
which may be mandatory in nature.
Persons involved with the managing, handling, storing, tran-
sporting and disposing biomedical waste should become very
familiar with Ontario Regulation 309 with respect to:
Waste Management System Certificate of Approval
Manifesting (transporting of waste)
Ontario waste generator registration number
Liquid discharging to a municipal sanitary sewer
Landfilling of solid waste
These guidelines do not address the disposal of wastes from
veterinarian facilities and animal care centres.
This document is based on Ministry of the Environment Policy
#14-05
243
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I
- 2 -
GUIDELINES FOR THE
HANDLING AND DISPOSAL OF BIOMEDICAL WASTES
FROM HEALTH CARE FACILITIES AND LABORATORIES
1.0 DEFINITION AND CLASSIFICATION OF WASTE
1.1 Biomedical Waste
Biomedical waste originates in health care facilities,
doctors' offices, diagnostic and research laboratories and
mortuaries. This waste may be hazardous to public health and
may include anatomical waste such as human or animal tissue
and body parts.
Biomedical waste for the purposes of these guidelines
includes both pathological waste and infectious waste.
Communicable diseases are defined in schedules of the Ontario
Health Protection and Promotion Act 1983 and the Canada
Animal Disease and Protection Act.
1.1.1 Pathological Waste
Pathological Waste is a waste that is any of the following:
(1) Human anatomical waste including any part of the
human body with the exception of extracted teeth,
hair, nail clippings and the like.
(2) Animal anatomical waste which is all or part of a
carcass suspected of being infected with a disease
communicable to humans or animals.
1.1.2 Infectious Waste
Infectious waste is waste of any type which is contaminated
or suspected to be contaminated with the causative agents of
infectious disease or their toxic products and capable of
infecting or causing disease in susceptible individuals or
animals exposed to them.
To be classified as "infectious"/ waste should not merely
contain pathogens but should also be capable of transmitting
infection. An understanding of the factors necessary for
transmission of infection is useful in classifying waste as
infectious.
Infectious waste may include:
(1) Human anatomical;
(2) Animal anatomical;
; (3) Non-anatomical;
| (4) Microbiological;
,| (5) Blood, blood products, and body fluids suspected to
J contain microbial agents of disease;
:;3 (6) Waste generated by patients in isolation (for
J communicable diseases).
1 244
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- 3 -
1.2 Other Biomedical Waste Requiring Special Handling
Waste other than those biomedical waste categories described
above may be generated from time to time and shall be
disposed of properly. These are:
(1) Hospital and health care waste considered not to be
infectious.
(2) Non-anatomical waste that has been decontaminated
in a device approved for that specific purpose.
(3) Sharps (e.g. needles, scalpels, etc.).
(4) Radioactive waste/ chemical and chemotherapy waste,
and organic waste (solvents) are not included in
these guidelines. Reference should be made to
other publications dealing with the safe handling
and disposal of these waste categories.
2.0 PACKAGING OF BIOMEDICAL WASTE
Biomedical waste generated in health care facilities and
laboratories shall always be properly segregated, packaged
and colour coded to facilitate further handling, storage,
decontamination or transportation.
2.1 Human Anatomical Waste - RED BAG
- 3 mil. Thickness
(MOE Designated Type A Class 1 Waste)
Human anatomical waste shall be double bagged, inner bag
separately closed, outer bag RED and labelled, and con-
tents kept refrigerated. The bagged waste may be stored in
a rigid outer container that is colour coded RED or
contents identified with an appropriate tag or label, for
ease of mechanical handling for transportation and disposal.
2.2 Animal Anatomical Waste, Infectious - ORANGE BAG
- 3 mil. Thickness
(MOE Designated Type A Class 2 Waste)
Infectious or contaminated animal anatomical waste shall be
double bagged, inner bag separately closed, outer bag
ORANGE and labelled with the approved biohazard symbol,
and contents kept refrigerated. For ease of mechanical
handling for transportation and disposal, the bagged waste
may be stored in a rigid outer container that is colour coded
ORANGE or the contents in the container identified with a
tag or label stating that the "WASTE IS CONTAMINATED WITH
AGENTS OF COMMUNICABLE DISEASE".
245
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- 4 -
t f
2.3 Non-Anatomical Waste, Infectious - YELLOW BAG
- 3 mil. Thickness
(MOB Designated Type A Class 3 Waste)
Infectious or contaminated non-anatomical waste shall be
double bagged, inner bag separately closed, outer bag
YELLOW and labelled with the approved biohazard symbol.
Infectious or contaminated liquids shall be placed in impact
resistant/ hard-shell, sealed containers prior to bagging.
For ease of mechanical handling for transportation and
disposal, the bagged waste may be stored in a rigid outer
container that is colour coded YELLOW or the contents in
the container identified with a tag or label stating that the
•WASTE IS CONTAMINATED WITH AGENTS OF COMMUNICABLE DISEASE".
2.4 Sharps - Hard Shell Container - BLACK BAG
- 3 mil. Thickness
Only rigid, hard shell containers shall be used to package or
contain discarded sharps (needles, scalpels, etc.) prior to
disposal. The sharps container shall be enclosed in
double, BLACK opaque plastic bags of 3 mil. thickness.
Such packaged sharps shall be segregated from other waste and
shall not be compacted in a waste compactor. Corrugated
cardboard boxes are not recommended for packaging discarded
I sharps.
."3 •
2.5 Waste - Non-Infectious - BLACK BAG
. - - 3 mil. Thickness
Hospital and health care waste requiring special handling
and considered not to be infectious (excluding office,
kitchen and mechanical plant vaste). Waste requiring special
handling shall be contained in double, BLACK opaque
plastic bags of 3 mil. thickness and may be landfilled. This
waste shall not be compacted in a waste compactor.
3.0 DISPOSAL OF BIOMEDICAL WASTE
___^———______—____^_
3.1 Incineration
The following biomedical waste categories shall always be
incinerated (except for 3.2) prior to disposal of the ash in
a landfill.
3.1.1 .Pathological Waste
- Human anatomical waste
(see 1.1.1(1) and 1.1.2(1))
Animal anatomical waste
(see 1.1.1(2) and 1.1.2(2))
246
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3.1.2 Infectious Waste
Human anatomical waste
Animal anatomical waste
- Non-anatomical
Microbiological
Blood, blood products and body fluids
Waste of patients in isolation
3.2 Steam Decontamination (Autoclave)
An acceptable alternate treatment to the incineration of
infectious non-anatomical waste is steam decontamination in
an autoclave under conditions of steam pressure, steam temp-
erature and exposure time defined in the Laboratory Safety
Manual guidelines, Laboratory Services Branch of the Ministry
of Health (Appended).
3.3 New Technology for Decontamination of Waste
Subject to the approval of the appropriate provincial autho-
rity, alternate means of decontaminating biomedical waste
may be considered. Approval will be considered on a case-by-
case basis. The Ministries of Environment, Health and Labour
should be approached in this regard.
3.4 Disposal of Other Types of Biomedical Waste
3.4.1 Decontaminated Waste Requiring Special Handling
Non-anatomical waste that has been decontaminated in a device
approved for that specific purpose may be landfilled. This
decontaminated waste shall be contained in double BLACK
opaque plastic bags of 3 mil. thickness. This waste shall
not be compacted before disposal in a landfill.
3.4.2 Sharps (e.g. needles, scalpels, etc.)
Sharps should be handled and disposed of in a safe manner
that will prevent injury and/or infection. This bagged waste
shall not be compacted before disposal in a landfill.
3.4.3 Radioactive, Chemical, Organic Waste
(See 1.2.4)
3.5 Liquid Infectious Waste Disposal
When liquid infectious waste is discharged to the municipal
sanitary sewer, Regulation 309 requires that the discharger
be registered with the Ministry of the Environment. In
special, high risk cases the liquid waste shall not be
discharged to the sewer. It shall either be contained in a
securely sealed unbreakable container or absorbed into a
solid carrier and included with the solid infectious waste.
High risk waste shall be incinerated.
247
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3.6 Blood
Blood or blood products known, or suspected, or likely to
contain agents of a communicable disease must be collected
and decontaminated by means of an approved method, or incin-
erated. It is not acceptable to discharge any blood to the
| storm sewer and this practice is prohibited.
3.7 Waste'- Non-Infectious - Requiring Special Handling
No'n-inf ectious hospital and health care waste may be
landfilled. This bagged waste shall not be compacted before
disposal in a landfill.
4.0 RIGID OUTER CONTAINER - FOR UNTREATED PATHOLOGICAL OR
INFECTIOUS BIOMEDICAL WASTE
Untreated (contaminated), bagged biomedical waste transported
to an off-site incinerator or other disposal facility
approved for the receipt of this bagged waste shall, be
transported in a hard shell container that is either a:
(1) tape sealed, disposable, heavy-duty corrugated
cardboard carton fitted with an inner leakproof
plastic liner. This carton must be fed into the
incinerator unopened; or a
(2) reusable plastic or metal container with a tight
fitting lid. The entire empty container and lid
shall be decontaminated and washed after each use
as described in the Laboratory Safety Manual. (See
references).
The rigid, outer container shall be colour coded and carry
the appropriate biohazard symbol and label. Only a carrier
in possession of a valid waste system certificate of approval
;| for biomedical waste transportation and in possession of an
Ontario manifest form shall transport this untreated waste.
1 5.0 STORAGE OF BIOMEDICAL WASTE
When storage of biomedical waste is unavoidable in a health
care facility, the following factors must be considered:
Access shall be limited to authorized personnel.
Integrity of the packaging maintained.
- Duration of storage.
Temperature of storage.
Security of storage area with particular reference
to security from entry, tampering, and vermin.
Identification of the storage area. The storage
?rea should be clearly marked and kept remote from
food services and other clean areas.
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1 " 7 "
5.1 Refrigerated Storage of Anatomical Waste
I Facilities that store anatomical waste, either human or
animal, shall use a lockable, closed cold storage facility or
a lockable, domestic type deep freeze unit in which the
anatomical waste is accumulated prior to disposal by inciner-
ation. This waste shall be stored at a temperature of 4°C or
lower.
I 6.0 PROTECTION OF PERSONNEL
j The Occupational Safety Act administered by the Ministry of
Labour and the Health Protection and Promotion Act admini-
stered by the Medical Officer of Health advise that
personnel designated for the collection and/or segregation
and/or packaging of infectious waste shall be fully informed
of the potential hazard to health and shall be trained in the
applicable handling procedures and necessary safety pre-
cautions. Employers shall advise their employees by letter
which may be used to inform their personal physicians of the
nature of their individual occupations and its particular
$ hazards so that each physician will be alerted to the possi-
'' bility of the patient contracting an occupational illness.
Consideration shall also be given for appropriate
' immunization of all personnel handling infectious wastes.
Hospitals, institutions, and operators of waste management
systems shall conform to the legislation and accepted
precautionary health care codes of practice.
7.0 ON-SITE DISPOSAL OF WASTE
} The on-site handling and disposal of biomedical waste in
hospitals, other institutions and 'laboratories is the
responsibility of the administration. This responsibility
may be delegated to the Infection Control Committee or other
designated personnel. For smaller facilities, guidance may
be provided by an existing governing organization.
t
8.0 OFF-SITE DISPOSAL - CARRIER'S CERTIFICATE
Any person engaged in the transportation of waste to a
disposal site is operating a Waste Management System. The
operator of a Waste Management System is subject to the
Environmental Protection Act, RSO 1980, and Ontario
Regulation 309, as amended, and other Provincial and Federal
Acts and Regulations. Licensed biomedical waste haulers,
holding valid Waste Management Systems Certificates of
Approval issued by the Ministry of the Environment, shall not
accept untreated pathological or infectious bioraedical waste
for transportation to an Ontario registered disposal site
unless the biomedical waste is properly identified, packaged,
colour coded, and the rigid outer container is colour coded
and labelled with the approved biohazard logo and description
of contents manifested in compliance with the Ontario
manifest form requirements.
249
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9.0 SHARING OF EXISTING INCINERATOR FACILITIES BY OTHER
HOSPITALS
Recent amendments to Regulation 309 under the Environmental
Protection Act permits the sharing of hospital incinerators
by other hospitals. The use of any hospital incinerator is
subject to the incinerator being capable of meeting current
Ministry of the Environment emission criteria. Owners of
exempted hospital incinerators must provide an annual report
on the use and condition of the incinerator. (See Regulation
309. S26).
10.0 INTER-HOSPITAL TRANSPORTATION OF BIOMEDICAL WASTE
Inter-hospital transportation of bioraedical waste for the
purpose of incineration only may be permitted if a hospital
owned vehicle is used for this purpose. The vehicle owner
shall be in possession of a valid Waste System Certificate of
Approval issued by the Ministry of the Environment for this
specific restricted purpose.
Biomedical waste being transported between two health care
facilities must be packaged and contained in a rigid outer
container as specified in Section 4.0. The vehicle operator
shall be in possession of a completed Ontario manifest form
when transporting biomedical waste.
Ministry of the Environment
Waste Management Branch
;; February 1986
JM/bjb
1242R
250
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REFERENCES
Ontario Occupational Health and Safety Act, RSO 1980.
Ontario Health Protection and Promotion Act, 1983.
- CDC/NIH. 1984 Guideline on Biomedical Waste.
MOE Certificate of Approval. See Environmental Protection
Act, RSO 1980. Sections 8, 24, 26, 27, 40, and 136(4)
Ontario Regulation 309, Ontario Gazette, September 28, 1985.
General, Waste Management, under the Environmental Protection
Act.
Transportation of Dangerous Goods Act (Canada).
Animal Disease and Protection Act (Canada), as amended.
Laboratory Safety Manual, 1982.
Laboratory Services Branch, Ontario Ministry of Health,
Canadian Standards Association, Standard CSA Z317.10-M1981,
Handling of Waste Materials Within Health Care Facilities
A Guide for the Safe Preparation and Disposal of
Antineoplastic Agents, Ontario Hospital Association, 1982.
Guidelines for the Handling of Recombinant DNA Molecules and
Animal Viruses and Cells, 1980. Medical Research Council of
Canada.
U.S.E.P.A. Guidelines for Infectious Waste Management, 1985.
Biosafety in Microbilogical and Biomedical Laboratories,
1984.
U.S. Department of Health and Human Services.
251
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APPENDIX I
SAFETY PROCEDURES FOR PERSONNEL
HANDLING INFECTIOUS WASTE
1. Personnel who are involved with the collection, segregation,
packaging, storage, transportation or disposal of waste and who are
accidentally exposed to potentially infectious materials via the
percutaneous route, ingest ion, or contamination of mucous membranes
should:
a) determine the source and content of the material involved;
b) determine the details regarding any disinfection or sterilization of
the material, before the exposure;
c) complete the accident/incident report form attached;
d) report this incident to his or her immediate supervisor;
e) report this incident to an occupational health nurse or a
physician;
f) report this incident to the Ministry of the Environment if the
incident occurs outside the institutional buildings or at the waste
disposal facility.
2. Personnel who are involved in the collection, segregation, packaging,
storage, transportation, or disposal of waste and who become ill
following exposure to potentially infectious or toxic wastes should:
a) report the illness to his or her immediate supervisor;
b) report the illness to an occupational health nurse or a physician.
Where this disease is reportable, the occupational health nurse or
physician should report it to the local Medical Officer of Health of the
health unit or municipality in which the person is resident.
Reportable diseases are cited in the Regulations under the Health
Protection and Promotion Act (Ontario) and the Animal Disease and
Protection Act (Canada).
NOTE: "via the percutaneous route", refers to the transfer of
infectious or toxic material through the skin or puncture by
needle, glass or stick, or contamination of cuts, abrasions, or
scratches.
Instructions for Completing Accident Incident Report Form
The form should be completed by the operator/employee immediately
after being involved in an accident/incident/spill resulting in his/her
accidental exposure to waste infected with an agent of a communicable
disease or where a spill of biomedical and infectious waste has
occurred. A report should be made in all cases of accident involving
injury and in all cases involving accidental exposure to infectious
252
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- 11 -
aerosols or exposure to cytotoxic or radioactive substances contained
in the waste of health care facilities, laboratories and -similar activi-
ties, and in the operation of waste handling and disposal systems and
landfills.
A copy of the biomedical waste handling report should be submitted to
the employer/public health nurse/personnel physician, as is appro-
priate. In case of personal injury, separate Workers' Compensation
Board (WCB) forms must also be completed and submitted within 48
hours of the time of injury.
253
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Ontario
Section A
Biomedlcal Waste Handling
Report on Personnel
Accident / Spill / Incident / Inju
Location of Accident
Address
City Town
Prov./State
Time Of Occurrence
Name of Parson Involved or Injured
Address
City/Town
Home Tel. No.
Postal Code
Business Tel. No.
Name of Employer
Business Address
CityTown
Postal Code
ProvVState
Telephone No.
Name of Person Incident Reported to:
Date & Time Incident Reported
Occup. Heaim Nurse/Physician
Personal Physician
Workman's Compensation Board
Location of Accident / Spill / Incident / Injury
O Hospital Ward /Patient Area
O Hospital Laboratory
O Hospital Waste Collection
D Hospital Waste Storage
D Hospital Incinerator
D Hospital Autodave
O Hospital Compactor
D Licensed Laboratory .'SCS
D Lab. Autodave
D Lab.Checn/Oisintegrator
D Lab. Waste CoHectton
D Lab. Waste Storage
D Hauling ' Transportation (Private)
D Incineralor (Private)
D Autodave (Private)
D Transfer Station
D Landau
D Equipment Maintenance
O Equipment Repair
D Road Accident
D SpiN/Breakage of Container
D Beg Leak/Burst
D Explosion
Details of Accident / Spill / Incident / Injury
Incident; Hazard Involved
O Infectious
O Cytotoxic / Chemotherapy
D Chemical Toxic
D Physical / ki)ury
O Radioactive
D Heat
D Steam
D Aerosol
D Explosion
I"! nth" (Sf-eifyf
Incident; Type
D Breakage
D Spillage
D Aerosol
D Ingesnon
D Physical Exposure
In
=
cldent; Equipment Involvetd
Glassware
Needle / Syrmge / Scalpel
Needle / Culler / Container
Autoclave / Oven
Incineralor
Cham/Disintegrator
Hoist /Can-
Container
Waste Handling Device
Compactor
Truck /Vehicle
OltMr iSaaoiul
n|ury Site on Person
D Hands
D Other Limbs
3 Facial Areas. Mouth, Neck
7) OMwr (Sp«afy) . . _
Injury; Type
Q Animal Sue
O Skin Penetration
D Self Inoculation
D Eye Accident
D Chemical Burn
O Superficial Injury
D Other (Specify) _
Activity at Tim* of Incident
Waste Reception / Preparation
Waste Handling / Transportation
Waste Storage
Driving Vehicle
Transfer Waste to / from Vehicle
Loading Incinerator
Loading.' Emptying Autodave
Loading
Other (Specify)
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Section B - Remedial Action Taken Following Accident / Incident
(This Section to be Completed by Employer)
As concerns employee(s):
As concerns incident:
Indicate MRC Level ol Contamination, if known
A B C D EIF
(See MRC Guidelines)
Describe nature ol Biomedical Waste Involved:
Recommendations made:
Name of Employee(s) Involved:
255
Employee Signature
Supervisor' Employer Signature
Date
Date
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- 12 -
APPENDIX II
GUIDELINES FOR VEHICLES TRANSPORTING
ANATOMICAL OR INFECTIOUS WASTE
1. Any person engaged in the hauling of waste to a treatment or disposal
site is operating a WASTE MANAGEMENT SYSTEM.
2. The operator of a WASTE MANAGEMENT SYSTEM is subject to Ontario
Regulation 309 and the Environmental Protection Act and other legisla-
tion* The vehicle owner and/or operator is required to be in posses-
sion of a valid Certificate of Approval issued by the Ministry of the
Environment prior to operating any WASTE MANAGEMENT SYSTEM
involving the hauling of bioraedical waste.
3. In addition to the standards outlined in the above-mentioned
legislation, and the Certificate of Approval, the operator hauling
anatomical or infectious waste must conform to the requirements
governing the handling, packaging and transportation of wastes
outlined in CSA Standard Z317.10-M1981, "Handling of Waste Material
Within Health Care Facilities".
4. All transportation vehicles hauling anatomical or infectious waste shall
be specially designed to accommodate the special interest to be served
by the vehicle. The following features shall be provided in the storage
compartment:
a) The storage compartment must be insulated and must be kept
refrigerated at a temperature of 4°C or lower. The independent
refrigeration system must continue to be operable even when the
vehicle is parked or inoperable.
b) Walls and floor shall be metal surfaced to ensure effective cleaning
and disinfecting.
c) The floor shall be sealed and leakproof. A liquid retaining lip
shall be provided above the floor level at the door opening.
d) No windows or ventilating openings shall be provided opening into
the storage compartment.
e) Only one lockable door shall be provided in the storage
compartment.
f) An interior light shall be provided.
g) The approved biological hazard symbol shall be prominently
displayed on the outside left and right vertical surfaces of the
storage compartment consistent with the requirements of the
legislation.
h) The vehicle shall not be used for any other purpose than
transporting bioraedical waste and shall not be driven in any area
other than is specified in the Ministry of the Environment
Certificate of Approval.
256
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5. The storage compartment door shall be kept locked at all times during
transportation of waste or when the vehicle is parked, except for
normal entry. Suitable holes shall be provided in the mating parts of
the compartment door lock to accommodate, where necessary, the wire
and seal used by the Medical Officer of Health having jurisdiction.
6. The operator, as a condition of approval, must develop an Accident/
Spill/Incident protocol and have it approved by the Ministry of the
Environment. The protocol must specify disinfecting materials, other
supplies and their quantities, stored in the vehicle cab for accident
and spill clean-up, as well as a list of procedures and the reporting
protocol. The protocol must be followed in the event of all accidents
or spills that occur during handling or transportation. Staff must be
specifically trained in the implementation of this protocol. All
accidents or incidents must be reported to the responsible Medical
Officer of Health and to the Ministry of the Environment, preferably
on the same day' and not later than 24 hours after the occurrence. A
spill must be reported immediately.
7. All waste accepted for transportation shall be appropriately bagged in
colour-coded bags and transported in hard shell, leak-proof containers
to avoid spills.
8. On the conclusion of each day's work, the interior compartment of the
empty vehicle shall be decontaminated following the procedure given in
the Laboratory Safety Manual 1982, Ministry of Health. The vehicle
compartment shall be kept locked while the vehicle is parked.
257
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3
v?
- 14 -
APPENDIX HI
COMMON CONTAMINATED WASTES FROM
HEALTH CARE FACILITIES AND MEDICAL LABORATORIES*
Culture dishes
Pipettes
Syringes and other sharps
Tissue culture bottles and flasks
Membrane filters in plastic dishes
Collection bottles, bags, cups, and tubes used in handling blood, urine,
feces, saliva, exudates, or excretions
Micro-titer plates used for hemagglutination testing, complement fixation, or
*5 antibody titer
Slides and plates from immunodiffusion testing
Slides and cover slips from blood specimens or tissue or colony picking
.Disposable gloves, masks, clothing, bedding
Swabs, capillary tubes, and spreaders used to take or transfer samples
containing pathogens
Tubes, cards, tabs and assemblies used for diagnostic purposes to speciate
enteric or other pathogens
Transfusion and dialysis equipment
Source: "Draft Manual for Infectious Waste Management", U.S. EPA,
SW-957, September 1982
258
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- 15 -
APPENDIX V
TYPES OF INFECTIOUS WASTE
Experts in the biological safety field have concluded that infectious wastes
can be classified in the following categories*. Certain of these wastes
(e.g., biomedical wastes and sharps) are not necessarily always infectious,
but they are included in the list because they should always be handled in
accordance with prudent management practices that minimize the hazards
and address the special problems of these wastes.
0 isolation wastes
0 cultures and stocks of etiologic agents
0 blood and blood products
0 pathological wastes, placenta
0 other wastes from surgery and autopsy
0 contaminated laboratory wastes
0 sharps, needles, scalpels
0 dialysis unit wastes
0 dialysis unit wastes
0 animal carcasses and animal body parts
0 animal bedding and other waste from animal rooms
0 discarded biologicals, Pharmaceuticals
0 contaminated food and other products
0 contaminated equipment
* Source: U.S. Federal Register, December 18, 1978. Environmental
Protection Agency, Proposed Rules, "Hazardous Waste
Guidelines and Regulations"
259
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260
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SESSION VI: AGENCY REGULATIONS AND GUIDELINES
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: What are the costs and practicality of telemetering at a facility?
A: (J. Salvaggio, PA DER) On larger size units, Pennsylvania will probably
require that the data be telemetered back to the Department. As we
get more of these facilities, we will have more data to process
manually, which is time-consuming and subject to error. Pennsylvania
would like to have automatic transfer of the data to the Department on
a quarterly basis or more frequently, so we can review it and take the
appropriate enforcement action.
Q: To comment on New York's particulate standard of 0.15 gr/dscf,
Wisconsin now requires 0.1 for larger units. This standard is fairly easily
achieved by baghouses. A recent 800 Ib/hr dual unit in New York is
going to be using baghouse and low-pressure-drop scrubber technology.
The entire control equipment costs are $75,000-$100,000. This facility
plans to meet New York emission limits quite easily. New York
regulations appear to be right on the mark for BACT.
A: (Unidentified speaker) Manufacturers assert that it is still difficult to
meet 0.15 gr/dscf when corrected for O2/CO2. The test data being
generated in California and Ontario are useful because many agencies do
not have funds for such research.
Q: California has received claims from incinerator manufacturers that they
can meet 0.05 gr/dscf corrected.
A: (S. Shuler, Ecolaire Corp.) Such claims indicate poor judgment; 0.05
gr/dscf corrected without air pollution control equipment is unattainable.
Incinerators reviewed by California seem to be a fairly good cross
section for determining what is achievable with or without air pollution
control devices. It is not uncommon with Method 5 to attain 0.08
gr/dscf and in some remote conditions perhaps a little less. Because of
liability and commercial constraints, one does not necessarily make this
claim.
Q: Are you saying that outside of California people are not familiar with
the drastic difference in the test method when you modify Method 5?
You take an impinger catch and put an added filter on the rear end of
the sample train.
A: (S. Shuler, Ecolaire Corp.) The problems are more far-reaching than
that. Many applicants and reviewers do not have the experience to
evaluate manufacturers' claims. Some small "mom and pop" firms do
not have the technical capability to produce what is required.
(G. Yee, GARB) California shares this concern. An example is a
facility that was built under a hearing board variance, and problems had
to be addressed afterward. It is disconcerting to the customer to have
to redesign the facility.
261
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Q: At the Stanford facility, economics determined the choice of materials,
but this may be short-sighted. The long-term plan is to replace some of
the carbon steel components with stainless steeL
Q: Operator training and certification are definitely needed. The Waste
Combustion Assistance Council would like a properly managed training
and certification program. Some manufacturers have their own
programs, but there is a high turnover of personnel at facilities. The
operators are usually not technically-oriented individuals. This is
equivalent to the situation in the boiler industry prior to licensing of
operators. A modern incinerator is a fairly sophisticated device. Four
technically-oriented certified people should be onsite around the clock.
A: (S. Hickerson, Emcotek) The problem is not just incineration and rules,
but overall management of the waste. The difficulty in attaining
reductions is not just the removal levels, but water handling and effluent
management. Compliance officers should be more concerned in areas
that are critical to how the controls will work in the long haul, whether
it is a cyclic operation or a continuous one.
Q: Regarding residence time and temperature, it is important to have
minimum design or operating criteria in the regulation. But meeting
these criteria does not ensure complete combustion. In GARB tests,
most of the incinerators have been designed to meet these criteria.
However, toxics have still been detected at the stack. The research on
which these criteria were based was directed at destruction and removal
efficiency of the original compound and not at the possible products of
reformation reactions. Conversion of the toxin to a different, stable
compound is required.
Existing baghouses and scrubbers are not necessarily designed for
controlling toxins. The efficiencies with toxins of these controls are
fairly low to moderate for the ones CARB has tested. However, they
are highly efficient in removing the types of pollutants they were
designed for, e.g. participates.
Q: Pennsylvania plans to test new incinerators for toxics (as often as every
six months for larger units). Toxic testing is fairly expensive. How
comprehensive a test will be required?
A: (J. Salvaggio, PA DER) Pennsylvania is permitting close to 40 units per
year. The cost of repeated testing was of concern, yet testing was also
one of the major concerns of the public. The waste supply will vary day
to day. How can you be confident that what you are permitting and
testing will be achie /able over the life of that unit? The only way is to
generate the data. We have not been able to identify an alternative way
of developing the data base that gives us the assurance that what we are
doing is in fact protecting the public health.
262
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Pennsylvania will require the equivalent of an acceptance test on the
larger units once every six months and on middle size units once every
year. All the units have to do dioxin testing for the acceptance test,
then once a year for all source sizes. Smaller units get an exemption
once they meet the acceptance test. Units will be retested if there is a
reason to suspect something, e.g. if there is a continual opacity problem.
Q: The costs of testing are extremely high. How much do we actually learn
and where is the point of diminishing returns?
Q: Regarding Pennsylvania's policy of encouraging on-site incineration,
California's experience on compliance testing which includes toxics
monitoring is that the costs reach upwards of $80,000 per test. Doesn't
this expense for an on-site facility discourage a waste generator from
siting an incinerator?
A: (J. Salvaggio, PA DER) Yes. The original mandate was to push towards
regional incinerators, but Pennsylvania learned as a result of the
applications we were receiving that the public is just not ready to
accept a regional incinerator. There was tremendous opposition to
commercial facilities, so we wanted to provide some capability of
on-site incineration and we included that in the regulation. We
estimated the cost at about $35,000 per test, but the cost may decrease
as more testing is conducted.
Q: Regarding Canada's color-coding for waste separation: in the United
States, less separation is occurring as hospitals throw everything into
red bags. What are the chances of success with five color coded
categories?
A: (J. Manuel, ON Min. of Env.) Canada does not see any problem with
multiple color bags because the colors are used in different facilities.
Red bags in the U.S. are yellow in Canada. Blue bags are for veterinary
use, red for tissue, and yellow for npnanatomical infectious waste.
Sharps go into puncture resistant containers and then into the regular
garbage can used with all the other wastes. The only difference is this
bag of waste is not compacted and goes directly to the landfill. With all
the precautions, there will be a much larger disposal of general waste
into the red and yellow bags. The only solution is education of the
hospital staff.
In 1985, the regulation required that all incinerators in hospitals had to
report on the wastes they were burning daily. An annual report was
required from each facility. Additionally, each facility was
professionally assessed each year by a consultant who carries out the
stack testing. The costs were enormous and the data were a waste of
time. The consultants and engineers need education on how to do the
testing. Even though the regulation required it, we abandoned this after
one year because the costs were too high and it just doesn' t work.
263
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(D. Campbell, Env. Can.) One of the strongest driving forces behind the
color coding in hospitals is a certification program. If hospitals follow
the codes and guidelines that are issued by Ontario or the federal
government it gives them points toward certification. They are
certified each year. Some hospitals do not get full certification, but
following the code guidelines is a way for them to get points.
264
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SESSION VI: AGENCY REGULATIONS AND GUIDELINES
SUMMARY OF DISCUSSION (BALTIMORE)
Q: Turbulent mixing in typical incinerators seems to be non-optimal, and
new designs or alternative technologies are needed to optimize overall
combustion. Autoclaving should also be considered. Agencies should
examine new burner designs which do not use a primary chamber burner
online.
Q: Why did South Coast AQMD require a dioxin test when it otherwise
sought to reduce costs and took care not to impose a financial hardship
on small facilities? This could cause units of under 500 Ib/hr to close.
A: (R. Pease, SCAQMD) The original intent was to have a regional facility
built, but the facilities originally proposed were opposed at the local
level. The public would not accept the uncertainty regarding whether
and how much dioxin emissions would occur.
Costs differ between research testing and compliance testing. Agency
policy is that if the risk analysis predicts a risk of less than 1 in 1
million, then the facility is allowed to test only for total dioxin and
assume for impact analysis that all dioxin is 2,3,7,8 TCDD. If the risk is
greater than 1 in 1 million, the analysis must consider homologues,
isomers, etc. and may have to recalculate risk.
Q: What is the cost of a "screening" type test for total dioxin?
A: (R. Pease, SCAQMD) The cost is on the order of $10,000-$15,000 per
unit.
265
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266
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SESSION VII
DISCUSSION GROUPS - CASE EXAMPLES
267
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268
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Sample Hospital Incineration Regulation
(for discussion group leaders)
Hospital Incineration Workshops - May, 1988
Please react to the following hypthetical model rule for
permitting hospital waste incinerators. Provide applicability criteria
(e.g., firing type, waste streams, characteristics, size of unit) to
which the rule's provisions should apply. What additions and/or changes
should be made?
HYPOTHETICAL MODEL RULE:
Item
NEW/MODIFIED Units
EXISTING Units
Temperature
Residence Time
Design
Pollutants
Metals (Cd, Or, Pb, Hg, Ar)
Dioxins/Furans
CO
PM
HC1
Pathogens (AIDS, hepatitis B)
Waste management/separation
Stack height adjustments
Source monitoring
Operator procedures
Stack testing
Inspection/reporting
Additional criteria
Requirement
Case by case BACT
1800F
2 sec
good combustion and turbulence
multi-chamber
Set specific limits as
necessary or set specific
limits (equivalency)
100 ppm (1 hr ave)
0.015 g/dscf (12% CO or 7%02)
acid gas scrubbing
no additional controls
containers for sharps,paper
recycling
for noncarcinogens only and
downwash prevention
temperature (primary and
secondary) opacity, CO, 02
certification, established O&M
procedures
start-up, annual retest
annual, source record keeping
public hearings, worst case
risk assessment
269
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Hospital Infectious Waste Incineration
and Hospital Sterilization Workshops
May, 1988
Suggestions for Discussion Group Leaders
1. Do these cases include information that your agency requires in
permits? process data? modeling data? site information? special
conditions? What additional information does your agency require?
2. What special conditions do you currently require for infectious
waste incineration? for sterilizers?
3. What do you expect to require in the near future (1-2 years) for new
and existing sources?
4. What guidance (technical and policy) does your agency need to permit
incinerators and sterilizers?
5. Policy guidance: Do you need general information on hospital waste
disposal, e.g., disposal options, regional vs. local facilities? sample
regulations? other?
6. Technical guidance: Do you need information related to emission
control technologies, air toxics impacts, modeling determinations, etc.?
7. Is the issue of hospital waste similar or different to other
stationary source permitting in your agency?
270
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Hospital Waste Incineration and Hospital Sterilization Workshops
May 1988
CASE I
Health Spot Hospital, Inc.
Permit to Install Application
Health Spot Hospital, Inc. (hereinafter "Health Spot") proposes to
install an ethylene oxide (EtO) sterilizer to sterilize materials which
will be used mainly in the operating room of the hospital. this
sterilizer is basically an enclosed chamber into which these mater la IB
are placed and exposed to a mixture of EtO and dichlorodif luoromethane
(Freon 12). When these materials are properly sterilized, the chamber
is evacuated by a water-sealed vacuum pump and the materials removed and
placed into a ventilated storage area for future use. The EtO/ Freon 12
gases from the vacuum pump are ducted to the side of the building and
exhausted outside. In addition, there is a hood over the sterilizer to
exhaust the BtO which remains in the chamber and a hood over the drain
from the water-sealed vacuum pump to exhaust the EtO which was absorbed
by the water in the vacuum pump. The cost of the sterilizer is $75,000.
The following are the process steps for a sterilization cycle:
/
1. The materials are placed into the sterilizer and the door is
sealed.
2. The vacuum pump is turned on until a vacuum of 20" Kg Is
achieved.
271
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Health Spot Hospital. Inc.
Permit to Install Application
Page 2
3. Steam la added to achieve a 60 X relative humidity inside the
chamber.
4. The BtO/Frecn 12 gas mixture is pumped into the chamber and
the chamber is heated to a temperature of 120 »F. A positive
pressure of 7 peig la achieved. The materials remain under
this condition for a period of 2-3 hours.
5. The vacuum pump is turned on and the chamber evacuated until a
vacuum of 20" Hg is achieved. This takes about 30 minutes.
6. Ambient room air Is allowed to bleed into the chamber until
atmospheric pressure is achieved. This takes about 10
minutes.
7. The vacuum pump is again turned on and the chamber evacuated
until a vacuum of 20" Hg is achieved. This takes about 10
8. Ambient room air is allowed to bleed into the chamber until
atmospheric pressure is achieved. This take about 10 ninutea.
9. Steps 7 and 8 are repeated one more time.
10. The door is opened and the start lined materials are removed
and placed into a ventilated storage area for future use in
the hospital.
Sterilizer: 20 cubic feet gas capacity
Vacuum pump: 2 SCFM capacity (See Note 1)
Once-through water-ring design
272
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Health Spot Hospital, Inc.
Permit to Install Application
Page 3
Exhaust airflow: Hood over sterilizer: 200 SCFM
Hood over drain: 100 SCFM
Vacuum pump discharge: 16 feet above ground
2" diameter duct
Hood exhaust: Both airstreams combined to single discharge point
16 feet above ground
There is one fan for both hoods and both are operated
simultaneously
6" diameter duct
Building height: 60 feet
Distance from building to sidewalk: 50 feet
Location of closest fresh air Intake: on top of roof, 110 feet north of
the vacuum pump discharge duct
Area «W
-------
Health Spot Hospital, Inc.
Permit to Install Application
Page 4
Maximum process operating schedule: 1 cycle / 8-hr shift
2 shifts / day
5 days / week
,52. weeks / year
Sterilizing gas: Volume basis:
RtO: 27 X Preen 12: 73%
Height basis:
BtO: 12 X Freon 12: 88X
Sterilizing gas usage per sterilization cycle:
BtO: 0.686 Ib
Freon 12: 5.038 Ib
Jjfl Bnlsaicnn from sterilizer per sterilization cycle:
1. Missions from vacuum pump (See Note 2):
inrjmri
1st 22.89 ft* 203238 ppmv 0.484 Ib
2nd 13.37 ft* 65233 ppmv 0.099 Ib
3rd 13.37 ft' 21380 ppmv 0.033 Ib
2. Bnissions at end of cycle:
Amount in gaseous form in the chamber which IB exhausted when
the door is opened and the •wfc*r1*fo removed (captured by the
4
hood over the sterilizer):
0.016 Ib
-------
Health Spot Hospital, Inc.
Permit to Install Application
Page 5
3. EtO which remains in the materials which have been sterilized
la slowly evaporated during the next several weeks in the
ventilated storage area:
0.054 Ib
BtO
-------
Health Spot Hoepital, Inc.
Permit to Install Application
Page 6
RtO mnximim concentration at building intake:
See Note 5
1. Modeling assumed a continuous emission at the highest 1-hour
rate.
Vacuum punp Hoods
Annual: 15 ug/M' See Hotes 2 and 4
24-hour: 90 ug/M»
8-hour: 155 ug/lP
1-hour: 225 ug/M»
10-min: 450 ug/M*
2. Modeling aseuned an emission for 1 hour out of 8 hours.
Vacuum punp Hoods
Annual: 2 ug/M' See Hotes 2 and 4
24-hour: 17 ug/M*
8-hour: 30 ug/H*
1-hour: 225 ug/M*
10-min: 450 ug/M»
Note 2: In reality, approximately 15 X of the BtQ is absorbed by the
water in the water-sealed vacuum pump. However, with neutral pH water,
the hydrolization of EtO to ethylene glycol for all practical purposes
does not occur during the tine that the BtO is in the water. Despite
the >»
-------
Health Spot Hospital, Inc.
Permit to Install Application
Page 7
purposes of the EPA conference, assume that all of this BtO is exhausted
from the vacuum pump. As will be described at the conference, a small
modification to the vacuum pump,- so that there is total water
recirculation, is a reasonable change which makes it technically easier
to control this 15% of the EtO which would otherwise be exhausted
through the hood located over the drain.
Note 3: When modeling the emissions as a building source, the area from
the building to 25 feet past the sidewalk is considered to be in the
cavity. The »»^»i««» concentration will be found at all
locations within this building cavity. In that this is a public
hospital and the public and patients have access to the grounds of
Health Spot as well as the sidewalk and the street, it is appropriate to
look at concentrations and exposures of air pollutants at all points
within the Hril^Ttg cavity. In reality, when the «»^««-t«Tn comes from a
single point (the discharge point of the vacuum pump) , the concentration
of air pollutants at some points within the building cavity may be even
greater than the modeled values. Looking at on-property concentrations
is different than the treatment of a normal industrial site, Typically,
OSHA has Jurisdiction over exposures to workers Inside the fenced in
property of tta employer, and thus, air pollution regulatory agencies
are not involved with exposures within this area.
Note 4: In terms of magnitude of emissions, the emissions from the
vacuum pump represent the majority of the emissions. The emission of
BtO which occurs when the sterilizer chamber door is opened, and the BtO
277
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Health Spot Hospital, Inc.
Permit to Install Application
Page 8
remaining in the chamber exhausted, la not significant when compared to
the amount of BtO exhausted by the vacuum pump. Therefore, for the
purposes of the EPA conference, this smaller emission can be neglected.
The same holds true for the BtO which comes off of the sterilized
materials in the ventilated storage area. On an hourly basis, this
<*arinn1on is insignificant in comparison to the one hour emission of BtO
from the vacuum pump. Of course, from an OSHA viewpoint of looking at
BtO concentrations in the workplace, these emissions are of great
concern. In that setting, a full review of these emissions is
rranted.
Note 5: For the same reasoning that the public win be inside the
hospital as visitors or patients, it is appropriate to look at the
concentrations of air pollutants at the hospital air intakes. Such
polluted air is subsequently distributed throughout the part of the
building served by that particular air intake.
If additional information is required, please contact Mr. Jonathan L.
Trout, Chief, Southeast Permit Dnit, Air Quality Division, Michigan
Department of Hatural Resources, at (517) 373-7023.
278
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JI
Health SpofHospltal, Inc.
Permit to Install Application
Page
279
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Health Spot Hoepital
Michigan Review
Page 1
The Health Spot Hoepital Permit to Install Application would not be
approved as submitted in Michigan. The major deficiencies are a lack of
the use of the best available control technology (BACT) for volatile
organic nrmpcmnrtn (VOC) and a demonstration that the emissions would not
cause injurious effects to human health and welfare.
The first problem is with the ethylene oxide (EtO) which is temporarily
absorbed by the water in the water-sealed vacuum pump. In that this is a
once-through system, the clean water will take approximately 15 X of the
BtO out of the gas stream. However, once the water reaches the air in the
drain, almost all of the EtO will go into the air. Given the amount of
contact tine in the neutral pH water, there will be almost no hydroliaatioh
of StO to ethylene glycol. Nhile it is prudent to have a hood over the
floor drain so that the BtO coming from the drain does not build up in
concentration in the steriliser room, this method of worker exposure
control does not lend itself to ambient air pollution control because the
BtO is now much more diluted than in the gas stream going to the vacuum
pump. A better approach is to install a total water recirculation vacuum
pump so that all of the BtO leaving the steriliser' chamber during operation
of the vacuum pump actually goes to the vacuum pump.
The BtO in the vacuum pump exhaust is extremely concentrated. In the first
purge, the concentration is 203,238 parts per million, by volume (ppmv).
In the second and third purges, it , is 65,233 ppmv and 21,380 ppmv,
respectively. This highly concentrated gas stream lends itself to very
efficient control. There are acidic scrubbers on the market which have
demonstrated control efficiencies for BtO of 99.9 X to 99.98 X. Also, the
cost of these controls is very reasonable, approximately $15,000 for this
hospital sterilizer. When that cost is compared to the $75 ,,000 cost of the
280
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Health Spot Hospital
Michigan Review
Pace 2
sterilizer, the percentage Increase of the equipment with a control device
10 believed to be reasonable. Also, the operating cost is not expected to
exceed $500 per year.
While the cost of control is approximately $15,000 to $20,000 per ton of
BtO removed, we believe that this is a reasonable cost because of the
carcinogen potential of EtO.
Based upon the modeling results of the uncontrolled emission of BtO which
do not give any credit for the intermittent nature of the emissions, the
calculated risk of additional cancer from BtO la 100 in one million (10-4)
at ground level and 500 in one ^in«*> (5*10-*) at the hospital air intake.
This level of increased risk from the BtO sterilizer is not acceptable in
Michigan.
However, after first using the application of best available control
technology, the BtO emissions would be reduced to a level, both at ground
level as well as the hospital Intake, which would represent an Increased
cancer risk of approximately one in one million (10-*) or less. This
controlled level would be acceptable in Michigan.
Under the circumstance of a very low exhaust volume from the vacuum pump,
there would be little difference in the ground level and air intake
itrations of BtO if the vacuum pump exhaust point were changed to the
top of the building rather than the second floor. Therefore, with the
addition of the acid scrubber, the planned exhaust location would not need
to be changed.
While there is some small amount of BtO being emitted from the hood over
the sterilizer and from the ventilated storage area, this amount is much
smaller in aagnitude than the amount emitted from the vacuum pump. In
281
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Health Spot Hoepital
Michigan Review
Page 3
addition, the EtO concentration would be nuch smaller and would not lend
itself to cost effective control. Therefore, we would not be concerned
*
with these emission points, but instead would concentrate on the vacuum
pump emission.
Michigan does not generally consider the intermittent nature of the
emission of a carcinogenic compound. This position is taken because of the
lack of scientific knowledge on the actual mechanism of the onset of cancer
cells in the human body. Therefore, until a scientific basis is derived
for understanding the effect or lack of effect of an intermittent exposure
of a carcinogenic compound, we believe that the prudent course of action is
to look at the worst case example of an emlunion being continuous.
282
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Hjspical Infectious Waste Incineration and Hospital Sterilization Workshops
. May 1988
CASE II.
Mercy Hospital
Permit to Install Application
Mercy Hospital, on the campus of Southern Michigan College, is proposing to
install a new hospital incinerator capable of burning up to 1500 pounds per
hour of pathological and infectious waste. The proposed unit will be a
controlled air type incineration system with primary, secondary, and
tertiary combustion chambers. It will be installed in the new Replacement
Hospital Building (attachment 1).
Description
Haste will be brought to the incineration room as it is collected during
the day. The waste will be double bagged and there will be no sorting of
material. The incinerator will be preheated to a temperature of 1200
degrees F in the secondary chamber. The interlock system does not allow
for waste to be fed into the unit until the 1200 degree F temperature is
achieved. The waste will be charged into the primary chamber by a
hopper/ram loader assembly. The primary chamber operates between 1500 to
1800 degrees F and at near stoichiometric air conditions. The flue gases
pass through the secondary and tertiary chambers where additional air is
added. If necessary, the natural gas-fjred burners in these chambers
provide additional heat to insure complete combustion. While waste is
being burned, the gases will be at 1800 degrees F for a minimum of 1.0
second. The flue gases then pass through a two-pass, firetube waste heat
boiler. The boiler will generate about 7500 pounds per hour of steam at 15
psig saturated. After exiting the boiler the gases are exhausted through a
227 foot stack, 15 feet above the building roof. The maximum operating
schedule will be 16 hours per day, 5 days per week, 52 weeks per year.
Tiegerictic-.n
Fuel: 7,500,000 pounds/year waste from hospital & research activities
Capacity: 1500 pounds per hour of waste
Primary: 896 cf volume with maximum heat release of 14,250 BTD/cf/hr
Normal operating temperature 1500-1800 degrees F
Secondary: 150 cf volume with 35-70% excess air added
Normal operating temperature 1600-2000 degrees F
Tertiary: Total 3808 cf volume with 35-70% excess air
Normal operating temperature 1600-2000 degrees F
f
Exhaust: 6533 acfm at 450 degrees F, 6.0% C02, and 6.14% Moisture
1899 dscfm at 12% C02
Stack: 227 feet above ground level, 24 inch diameter
Building: 202 feet above ground level
Air Intake: 112 feet above ground level, 330 feet from stack (attach. 1)
283
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Emissions and Impacts for Mercy Hospital Incinerator
Emissions Ibs/hr ug/m3
Particulate 2.1 85303.8
Hydrogen Chloride 15.O 612898.5
Cadmium 3.5E-03 143.0
Chromium 8.4E-04 34.2
2378 TCDD Tox Equiv 2.4E-07 9.8E-03
The toxic equivalents were
'determined assuming the
homologue distribution from
Run #3 of the Royal Jubilee
Hospital test arid an equal
occurence of isomers within
each homologue as described
by Hart (1982).
Maximum Ground Level Concentrations in ug.'in3 (Sae Note 1)
Pollutant\Ave Time Annual 24-Hour 8-Hour 1-Hour
Particulate
Hydrogen Chloride
Cadmium
Chromium
2378 TCDD Tox Equiv
10-Min
0.25
1.76
4.11E-04
9.83E-05
2.81E-08
2.2?
16.36
3 . 82E-03
9.12E-04
2.61E-07
4.93
35.19
8.21E-03
1.96E-03
5.61E-07
14.39
102 . 80
2 . 40E-02
5 . 73E-03
1.64E-06
28.73
205.60
4 . 80E-02
1.15E-02
3.28E-06
Maximum Air Intake Concentrations in ug/m3 (See Note 2)
PollutantNAve Time Annual 24-Hour 8-Hour 1-Hour
Particulate O.46 7.57 2O.72 . 64.47
Hydrogen Chloride 3.3O 54.04 147.97 460.48
Cadmium 7.69E-04 1.26E-02 3.45E-02 0.11
Chromium 1.S4E-04 3.01E-03 S.25E-O3 2.57E-02
2378 TCDD Tox Equiv 5.25E-08 8.61E-07 ' 2.36E-06 7.34E-06
10-Min
129.03
921.65
0.22
5.14E-02
1.47E-05
284
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Note 1 When modeling the emissions as a building source, the area within.
1000 feet from the building (5 times the building height) is considered to
be in the building cavity. The maximum concentration will be found at all
locations within this building cavity. ' In that this is a public hospital
and the public and patients have access to the grounds of Mercy Hospital as
well as the sidewalks and streets, it is appropriate to look at
concentrations and exposures of air pollutants at all points with the
building cavity. In reality, when the emission comes from a single point
such as an incinerator stack, the concentration of air pollutants at some
points within the building cavity may be even greater than the modeled
values. Looking at on-property concentrations is different than the
treatment of a normal industrial site. Typically, OSHA has jurisdiction
over exposures to workers inside the fenced property of the employer, and
thus, air pollution regulatory agencies are not involved with exposures
within this area.
Mote 2 Because the public will be inside the hospital as visitors or
patients, it is appropriate to look at the concentrations of air pollutants
at the hospital air intakes. The polluted air is subsequently distributed
throughout the part of the building that is served by that particular air
intake
If additional information is required, please
contact Lynn Fiedler, Senior Engineer, Southeast Permit (fait, Air Quality
Division, Michigan Department of Natural Resources, at (517) 373-7023.
285
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286
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Michigan Peview
Mercy Hospital Permit Application
The Mercy Hospital Permit to Install Application, as submitted, would not
be approved in Michigan. The major deficiency is the lack of a
demonstration that the emissions from the incinerator would not cause
injurious effects to human health and welfare. In addition, the applicant
is not proposing to operate the equipment in a manner which will reduce
emissions.
Eased upon the modeling results shown in Table 1, the uncontrolled
emissions of cadmium, chromium, and 2,3,7,8-TCED toxic equivalents result
in calculated risks of additional cancer of 1.5, 2.5 and 1 in one million
at ground level and 3, 4.7, and 2 in one million at the air intakes,
respectively. The Michigan Air Pollution Control Commission has previously
accepted a risk of 1 in one million as being a level at which a carcinogen
would not be considered to cause injurious effects to human health, and
thus comply with the Michigan Rules. Therefore, the emission of cadmium,
chromium and 2,3,7,8-TCDD toxic equivalents would not be considered to be
environmentally acceptable. In addition, the emission of hydrogen chloride
is at a level of concern. Hydrogen chloride is an irritant and She 1-hour
averaging period has been deemed appropriate in Michigan. The proposed
emission of hydrogen chloride is 1.5 tines greater than the accepted level
at ground level and 6.6 times greater at the air intake. Therefore, the
emission of hydrogen chloride would not be considered to be environmentally
acceptable.
Another item of concern is the combustion of waste at start-up: It is the
belief of the Michigan Air Quality Division that the unit should maintain a
temperature of at least 1800 F for a minimum of one second in the secondary
combustion zone. The temperature must average on an hourly basis 1800 F
and should not be less than 1600 at any time waste is being combusted. Any
time the temperature monitor indicates a temperature approaching the
minimum temperature of 1600 F, auxiliary fuel shall be added to the
process. In the event that it is not possible to maintain 1600 F, all
waste feed must be terminated immediately. This procedure is designed to
insure complete combustion and thereby minimizing the emission of dioxins
and furans.
fof the AppT
There are alternatives for the permit applicant which include raising the
stack or installing control equipment. Dispersion modeling studies were
completed to determine the minimum stack height that the unit must be
equipped with to comply with all of the air quality regulations and which
is necessary to assure that excessive concentrations of toxic air
contaminants will not be introduced into the hospital air intake system.
The stack height necessary for the proposed unit was determined to be 375
feet. Because of structural constraints this alternative was not available
to the permit applicant. The applicant has elected to install a venturi
scrubber and packed tower absorber system to control the particulate
(thereby controlling the cadmium and chromium) and acid gas emissions. In
addition, larger natural gas burners will be installed to insure that the
proper temperature is maintained when waste is combusted.
287
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Michigan Psrmit Review
Pollutant
Concentration (ug/m-3)
Ground
Air ! Accepted !
!
HC1 (1-Hour Ave) i
Cadmium
Chromium
2378 Tox
(Annual) !
(Annual) !
Eq (Annual).'
4
9
2
Level
102.80
.11E-04
.83E-05
.BiE-08
1
1
!
: 7
: i
; 5
Intake
460.48
.69E-04
. 84E-04
. 25E-08
!
1
,' 2
! 3
! 2
Ambient
70
. 67E-04
.95E-05
. 3OE-08
Fraction of Accept
Ground
Level
1.47
1.54
2.49
1.22
Air
Intake
6. 58
2.83
4.65
2.29
Calculation for an intermittent, emission of metals.
No credit given for other pollutants because of taxicity data basis.
Credit is given for 16 hrs vs. 24 hrs per day. (max credit to 8 hrs)
Credit is also given for 5 days per week vs. 7 days, (max credit to 5 days.)
Cadmium
Chromium
Accepted based
on 24 hrs 7 days
5.60E-04
8.30E-05
Accepted based
on 16 hrs 5 days
2.67E-O4
3.95E-O5
288
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Hospital Infectious Waste Incineration
and Hospital Sterilization Workshops
May, 1988
CASE III.
This case study is based on three permits granted by the New York
Department of Environmental Conservation, Division of Air Resources in
Region 9, Buffalo, NY. Thanks to Henry Sandonato, P.E. of the NY DEC
Region 9 Office who assisted in preparation of this case study.
EXAMPLE I.
Roswell Park Memorial Institute is a cancer' research institute and
hospital run by the New York State Health Department. Roswell Park is
is surrounded by a residential neighborhood. (Map attached.) Example
I. describes a Kellog Mann PBS unit which was originally started up in
June, 1968 and was permitted by the NY Department of Health. The unit
now burns mainly Type 4 waste since Type 1 waste is burned at the newer
Consumat unit also owned by Roswell Park (see Example II.)
Process Equipment Description
Fuel: Type 4 Waste
Capacity:
1. The original permit from 1968 allowed for 490 Ib/h of Type 1
waste and 50 Ib/h of Type 4 waste burned for 16 h/d and 260 d/y
2. The unit now burns 50 Ib/h of type 1 and 4 waste for 8 h/d and
260 d/y
The stack height is 138 ft and is 5 feet above the nearest existing
structure. The stack is 18 inches in diameter. The building housing
the unit is 664 ft above mean sea level.
Burners and Exit Conditions
The primary chamber has one Incinomite H-1000-3 rated at 1 MBtu/h fired
with natural gas.
The secondary chamber has two N-American 138B burners'rated at 600,000
Btu/h fired with natural gas.
None of the burners have actuated temperature settings.
The unit's exit temperature is 275F. The exit velocity 22 f/s with an
exit flow rate of 2300 acfm.
The incinerator must achieve a particulate emission rate of 0.50 lb/100
Ib of refuse charged.
Special Conditions
The special conditions for the unit were for radioactive refuse
and were contained in a letter dated 11/21/79. This letter lists
allowable limits for approximately 20 radioactive isotopes expected in
the waste; most are metal species. The letter is available from the NY
DEC.
289
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EXAMPLE II.
This Consumat C-325-PA Unit was built at Roswell Park for burning
Type 1 waste replacing the Kellog unit permitted in 1968 (Example I.)
The Consumat unit was permitted in 1986 under NT Air Guide #21,, dated
January 1987. The site is located next door to the existing Kellog
unit.
Process Equipment Description
Fuel: The Unit is permitted for incinerating Type 1 and 4 waste.
Capacity:
1. The unit is permitted for 1600 Ib/h of Type 1 waste at 8 h/d for
360 d/y.
2. The unit is permitted for 825 Ib/h of Type 4 waste for 8 h/d and
360 d/y.
The stack height is 120 ft and is 20 feet above existing structures.
The stack diameter is 42 inches. The building housing the unit: is 580
ft above mean sea level.
Burners
The primary chamber has four Eclipse burners rated at 750,000 Btu/h
fired with natural gas.
Secondary chamber has one Eclipse burner rated at 2.5 MBtu/h fired with
natural gas.
Both burners have actuated temperature settings. The primary chamber is
set for 1600F; the secondary chamber is set for 1800F.
The unit's exit temperature is 800-1000F. The exit velocity 22 f/s and
the exit flow rate is 12,722 acfra.
The incinerator must achieve a particulate emission rate of 0.1 gr/dscf.
Special Permit Conditions (set by Air Guide $21)
1. The unit must be preheated to 1500 F before charging refuse.
2. The normal operating temperature will be a minimum of 1800F.
3. Ash will not contain more than 5% combustible matter.
4. A lock out device is required to prevent charging refuse below
1500F.
5. A dual temperature recorder will be included to record primary
and secondary temperatures.
6. Operating instructions shall state that no red bag waste or
type 4 waste be loaded until 1800F is reached.
7. The breeching shall contain provision for connection of future
control equipment.
8. Ports for a smoke monitor must be included in the stack
installation should monitoring equipment be required in the future.
9. Stack sampling ports are required.
290
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EXAMPLE III.
Buffalo General Hospital is the largest private hospital in
Buffalo. Buffalo General is expanding, adding additional beds and
modernizing their facility. A new boiler house is being built. The
amount of waste the hospital is generating is increasing at a time when
their private haulers are restricting the waste they-will take.
This permit involves the installation of a new solid waste
incinerator at the Buffalo General Hospital which will result in the
removal of an existing incinerator at the site and phasing out of
operation an incinerator located at a nearby hospital. Start-up of the
new unit is planned for August 1988. The Unit will be a Consumat
Systems C-760-PA. The unit is under construction at a site just off the
attached map.
The special permit conditions listed below note the ongoing
development of New York regulations. These regulations may require
retrofitting of the unit with additional control equipment. Buffalo
General has agreed to meet any additional conditions established this
year.
Process Equipment Description
Fuel: The unit is permitted for Type 1 and 4 waste.
Capacity:
1. For Type 1 waste: 2800 Ib/h, 8 hr/d for 312 d/y
2. For Type 4 waste: 100 Ib/h capacity with the expected amount
charged to be 50 Ib/h waste for 4 h/d and 312 d/y.
The stack height is 110 ft and is 80 feet above the nearest existing
structure. The stack diameter is 56 inches. The building is located
660 ft above mean sea level.
Burners
The primary chamber has two North American 4422 burners each rated at
one MBtu/h fired with natural gas.
The secondary chamber has two North American 4422 burners each rated at
three MBtu/h fired with natural gas.
All burners are set for actuated temperature conditions. The primary
chamber is set for 1600F; the secondary chamber is set for 1800F.
Exit Conditions and Emissions Limits
The unit's exit temperature is 700 F with an exit velocity of 30 f/s and
an exit flow rate of 30,870 acfm.
TSP Emissions are permitted at 12.12 Ib/hr (actual emissions) and annual
emissions of 45,400 Ib/y (23 tons/y.)
The incinerator must achieve a particulate emission rate of 0.1 gr/dscf.
Special Conditions
1. The unit must be able to heat to 1500 F before any refuse is
charged.
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2. The ash must not contain more than 53 combustible matter.
3. Stack testing will be required for combinations of Type 1 and
Type 4 refuse unless an incinerator model is chosen on the NTS
Incinerator List that is approved for Type 4 waste.
4. The unit must meet a particulate emission standard of 0.10
gr/dscf corrected to 12% C02.
5. The secondary chamber must be designed to operate at 1800 F
and a one-second retention time.
6. The loader must be fitted with interlocks to prevent charging
waste until the secondary chamber exit temperature is at least 1600 F.
7. Space must be available should acid gas control be required in
the future.
3. Pathological waste may only be burned with hospital waste if
tested and found acceptable.
9. Continuous monitoring and recording of secondary chamber exit
temperature is required.
10. The exit temperature must be at least 1600 F. and records
must be submitted annually to show the-exit temperature has been
maintained.
11. Average opacity must be less than 10% during any consecutive
six-minute period per hour or less than 20% is allowed, as determined by
EPA Method 9.
12. The CO concentration must be sampled annually and results
submitted to the DEC with a report of the condition and operation of the
incinerator. This report shall be prepared by a qualified engineer and
include a calibration of the instruments.
13. A stack test protocol must be submitted 90 days prior to
startup of the unit. The unit must be stack tested for participates,
HC1, and CO concentration at startup and within 60 days after the
protocol has been approved. DEC must be given the opportunity to
observe the complete stack test.
These conditions are a result of Guidelines for Medical Care Waste
Incineration issued by the Division of Air Resources in Albany. A copy
of this information will be included in the Proceedings of the
Workshops.
According to this guideline, additional air pollution controls
will be required in the future after hearings are held during the
Summer, 1988 and a new incinerator regulation is adopted.
For further information on these permits please contact the NY DEC
Region 9 office at 600 Delaware Avenue, Buffalo, NY 14202, (718) 847-
4565. For further information on the New York regulations please
contact Wally Sontag, NY DEC, 50 Wolf Road, Albany, NY 12233, (518) 457-
2044.
NESCAUM
ny case st; 5/5/88
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HOSPITAL INFECTIOUS WASTE INCINERATION WORKSHOPS - MAY 1988
Case Study from the New York Dept of Environmental Conservation
MANUFACTURER
CAPACITY (Ib/h)
Type 1 Waste
restrictions
Type 4 Waste
restrictions
STACK
stack he1ght(0, above
existing structures
stack diameter (In)
building site (f) -
above mean sea level
BURNERS
Primary
capacity (Btu/h)
actuated temp
fuel
Secondary
capacity (Btu/h)
actuated temp
fuel
EXIT CONDITIONS
exit temp (F)
exit velocity (f/s)
exit flow (acfm)
TSP limit
Example 1
Roswell Park '68 Unit
Kellog Mann PBS
490
16h/d,260d/y
50
501b/h;8h/d.260d/v
136
5
18
664
1-lnclnomrteH- 1000-3
1 .000,000
no
natural gas
2-N. American 138B
600,000
no
natural oas
275
22
2.300
0.50 lb/1 00 Ib refuse
charoed
Example II
Roswell Park '86 Unit
Consumat 325-PA
1.600
8h/d,360d
825
8h/d,360d
120
20
42
580
4- Eclipse
750.000
yes
natural gas
1 -Eclipse
2.500.000
yes
natural gas
1.800
22
12.722
O.t0g/dscf
Example III
Buffalo General
Consumat 760-PA
2.800
8h/d.312d
100
501b/h:4h/d.312c
110
80
56
660
2-N. American 4422
1 .000.000
yes
natural gas
2-N. American 4422
3.000.000
yes
natural oas
700
30
30.870
O.IOg/dscf
NESCAUM
ny cases; 5/5/88
293
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PttVAIl.
ROSWELL PARK MEMORIAL INSTITUTE
BUFFALO IME\A/ YORK
294
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SESSION VH: DISCUSSION LEADERS REPORT
ON THEIR CASE STUDY GROUPS (SAN FRANCISCO)
Report by Lynn Fiedler, Michigan DNR
Case Study #2
The group decided there were too few set points specified in the whole
system. There was only one temperature set point and none for
pressure. There was no documentation of how retention time and
temperature were calculated. Retention time calculations should be the
manufacturer's responsibility to provide, but the permitting agency
should check the calculations. There should be more pollutants
(especially CO) listed in the special conditions for the emission rates.
Looking at the air intakes is valid and many thought this was something
that they might start doing. It is partly an OSHA problem, but still
cannot be ignored.
Does the ash need to go to a special landfill? It is a solid waste
problem, but perhaps air agencies should be involved to avoid just
trading one problem for another.
Case Study #3
. The group was confused about the temperatures. The three different
units had three different exhaust temperatures specified in the special
conditions, which should be more specific on where this temperature was
located. In general, more details were needed. As the conditions are
stated, they could not be defended in a public hearing.
The additive effects of toxics were not addressed. The three
incinerators are close together and perhaps their combined impact
should be analyzed.
Conditions 8 and 10 are confusing and need to be more specific.
Example I mentions radiation. The group was interested in state policies
and practices on radiation. One state has detection limit requirements,
i.e. commercial units can bum radioactives, but there must be no
detection in the stack. This is only for commercial-size units because
the cost is prohibitive for smaller units. Other states have no authority
to regulate such emissions. Air agencies should consider who should
handle the issue.
Model Rule
Existing units would shut down if this rule ever goes into effect.
The rule possibly should include PMio- There should be more GEM
required, e.g. for temperature and CO. Test methods, emissions limits,
etc. should be better specified.
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The group discussed the problem of everything being thrown in at once.
Perhaps differential loadings, e.g. five regular bags and then a red bag,
should be part of the operational procedures, although enforcement
would be difficult.
Compliance testing should be conducted with "normal" rather than
"worst case" waste. The group decided that testing should be
comprehensive at startup, with reduced testing requirements each year
thereafter to look at the toxics problem. There should be a size cut off
— under a certain size, rules would take effect to deal with dispersion.
Certain pathogens should not be tested, since their sources cannot be
accounted for.
Report by Nancy Seidman, NESCAUM
Considering the downtime of an incinerator (10-20% of the time) due to
add gas buildup, degradation of materials, and molten glass congealing
on grates, perhaps facilities need to think about what they are going to
do with their waste if the incinerator is out of operation.
Regarding operators and training, were the operators in the case studies
assigned to one job only or to diverse operation and maintenance
responsibilities? Permit conditions should take into account whether the
facility was going to have a dedicated operator. At larger facilities it
might be realistic.
Regarding.temperature conditions, what is the goal of a dual chambered
type of incinerator? If it is pyrolysis in the primary chamber, the
air-to-fuel ratio will be below stoichiometric. Then perhaps
temperature is not the critical factor, and requiring temperature
conditions in the primary chamber can be self-defeating. However,
temperature conditions for the secondary chamber can be very
important.
On testing and costs, stack testing at all facilities might force the use
of regional facilities due to excessive costs to smaller facilities. Tests
conducted under ideal conditions may provide at that moment in time an
accurate measurement of what the incinerator is doing. Days later all
the protocols may not apply. Overemphasis on stack testing may not be
what agencies had in mind. But with GEM, we do not know exactly what
we are asking for. Are they enforceable permit conditions? What will
agencies do with all these monitoring data?
Why is arsenic on the list of metals? Where would it be in the waste
feed? More generally, if certain materials could be kept from the waste
stream, how would emissions change? HC1 and lead levels may be
affected. Dioxin may not be determined by chlorine that was in the
PVC waste, but by multiple sources of chlorine in the waste stream.
Separation of PVC probably would not eliminate dioxin as an emissions
problem.
The group discussed waste shredding options, and whether an RDF
approach for hospitals (as with wood waste) would have any benefits.
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Chemotherapeutics are a RCRA waste and should not be going to an
infectious waste incinerator. Drained IV bags which had chemotherapy
drugs in them are acceptable.
The group held the opinion that hospitals' primary concern is patient
care and that source separation may be low priority or unacceptable for
them.
a
Recommendations for training are (1) that bioaccumulation should be
discussed and addressed further and (2) staff should be trained who are
reviewing the permits. Agencies are forced to rely upon data provided
by the manufacturer. Perhaps applicants expect regulators to be design
engineers and to review plans in greater detail. Many smaller agencies
do not have adequately trained staff to review these permits.
Report by Wallace Sonntag, New York DEC
The case study permits needed more detail on design conditions,
operating schedules, GEM information, description of 8ACT, test
information, and cost figures. After the statement "multi-chamber"
add "or equivalent alternative technology." Agencies should be
prepared for advances in technology.
Requirements for permits vary from state to state. Permitting hospitals
is similar to permitting toxics. Otherwise, there is not much difference
from regulating any other stationary source.
Regarding specific pollutants, Cd, Cr, Pb, Hg, and As should be
evaluated on a case-by-case basis. The group favored trying to design
the system to preclude the formation of dioxins and furans and therefore
avoid the need for testing. New York will hold hearings on this
approach. Particulate levels of 0.015 gr/dscf corrected to 12% appear
achievable. Most of the group would like to control HC1, but did not
favor additional controls or limits on pathogens at present.
Most of the group agreed that waste management by source separation
is not being practiced except in Ontario.
It is apparent that there is widespread ignorance among agency staff
regarding hospital sterilization.
Report by Joaxm Held, New Jersey DEP
The group discussed how to handle intermittent operation for permitting
purposes. If an analysis to determine control requirements assumes
intermittent operation, then the permit should include conditions
limiting operation to the same level. Most agencies assume operations
occur 24 hours per day, 365 days a year, and do the analysis.
EtO sterilizers may require analysis of both acute and chronic health
effects. The group was surprised at how long it takes to sterilize
something. EtO comes out in a spike, a very different emission pattern
from that of many of the combustion sources agencies are used to
297
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looking at where the source is continuous. Agencies may want to look at
the annual average concentration for carcinogenesis, but at the .spike for
acute health effects.
Case #3
Only particulate levels were given. The group would ask for additional
information on emissions of toxics and criteria pollutants.
When looking at the permit conditions for the third incinerator, the
group would consider additional permit conditions. One should he a
statement on what can or cannot be incinerated, and when. Add
emission limits in tons per year, total operations per year, operating
schedule, etc. If type 1 and type 4 wastes are to be burned together,
testing should be required. GEM perhaps should be required on a
case-by-case basis.
California and Maryland will have compliance requirements on existing
sources.
Questions that were brought up by the group include: (1) Is PVC the
only type of plastic that produces HC1 emissions? (2) How are hospitals
disposing of radioactive waste? (3) How are agencies addressing PMio
emissions?
Suggestions that the group made include: (1) having size classifications,
(2) testing only larger facilities annually while reducing the frequency or
types of pollutants tested for by the smaller facilities, and (3) given the
context of unit size and what types of emissions are associated with the
0.015 gr/dscf particulate standard, this standard does not seem to be a
reasonable requirement for every agency.
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SESSION VH: DISCUSSION LEADERS REPORT
ON THEIR CASE STUDY GROUPS (BALTIMORE)
Report by Chris James, Rhode Island DEM
The group considered the model rule and two questions:
(1) Should requirements be less stringent for existing units?
(2) Should there be a size cutoff below which small units are exempt
from requirements?
The group agreed on the model rule but differed on specific approaches.
The consensus was that control equipment is not feasible for small
units. Some favored shutting down small incinerators in favor of
regional facilities, as small units tend to have poor combustion control
and to be located in areas with high population exposure. Others
favored phasing out existing units, but then alternative disposal must be
provided, lest illegal disposal increase as with hazardous waste.
Illinois, in an apparent loophole in its regulations, would allow a
proposed mobile incinerator to travel a circuit, parking one day per
week at each hospital.
Ohio reported no problems siting commercial incinerators.
California suggested considering a lower size cutoff for existing units
based on risk. If the risk is above a threshold, they would be required to
install controls or shut down. LAER is recommended for new units.
California is also considering spore testing to determine whether
pathogens survive.
California has found that while hospital administrators are willing to
spend large sums for medical hardware (CAT scanners, etc.) they balk at
similar expenses to protect public health with incinerator controls.
New York stated that state or federal grants exist for hospital
incinerators, and should be considered as a way to encourage
replacement of old units.
One member cautioned that in calculating retention time the maximum
BTU input should be used, not the average input. Another stated that
present technology incinerators are not the whole solution. Alternatives
could include 3 or 4 stage incinerators, fluidized bed combustion, or
non-incinerator options.
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Report by Randal Telesz, Michigan DNR
Model Rule
The group variously interpreted the model rule as implying Federal
BACT, state-of-the-art controls, or requiring that a standard, be met.
No member advocated a state-based BACT rule.
Temperature: The majority selected 1800°, with one state each
choosing 1600° and 1500°. Rather than having a single temperature
regulation, temperature requirements should be matched to the
equipment (e.g. adjustable for fluidized bed units, and 1800° for
controlled air units).
Residence Time: Most specified 1 second, but three specified
2 seconds. If a proposed facility applied under a 1 second rule but
wanted to bum toxics, the group might require the design to be
expandable to increase residence time.
Design: The criterion should be good combustion with turbulence.
Pollutants: Metals should be subject to review. Dioxins should be
reviewed case-by-case as needed. A reasonable CO limit would be
100 ppm. Some incinerators would not be able to attain 50 ppm if
required. No state has considered PM^Q. For TSP, three states require
0.08 gr/dscf at 12% CO2, two states had 0.03-0.04, one had 0.02, and all
agreed that 0.015 is too strict.
Case Study *2
The group decided that enough information had been provided to do the
review. Special conditions to be imposed included GEM for CO, and
possibly CO2 or 02 or both. If a scrubber is installed, pH monitoring
would be helpful. If CEM for HC1 were available at low cost, it should
be required, especially on units of over 500 Ib/hr. Given the choice
between CEM, and sampling once per year for HC1, the group chose
CEM.
The group specified that charging rates must be controlled to avoid
temperature peaks, and that the unit should be preheated to operating
temperature before charging. If minimum temperatures are not
maintained, problems with bottom ash may result. Ash should be tested
for bumables.
In seeking precedents, most states compare hospital waste with
municipal waste, but one state used hazardous waste for comparison.
EPA should provide guidance to help state agencies lobby their
legislatures for authr rity to regulate hospital waste.
For existing units, more stringent regulation is one to two years away in
most states. The majority are now considering either ambient
concentration limits or control requirements. Small incinerators will
probably be subject to the same regulations but will be phased out if
they cannot comply by a cutoff date.
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Report by David Painter, EPA OAQPS
Model Rule
Temperature: The group favored 2 seconds (over 1 second) as a safety
factor, absent empirical data on feed variability and pathogen survival.
Interlocks should be required so that waste cannot be charged until the
primary chamber temperature reaches 1500° and the secondary reaches
1800*.
Size Cutoff: The group decided that a dry scrubber and baghouse should
be required if HC1 emissions exceed 4 Ib/hr. If the plastics content of
waste increases, the cutoff should be decreased because of potential
PCDD emissions. The group favored scrubbers in all cases but
recognized questions of practicality, e.g. should scrubbers be required
for a unit operating 6 hr/day, 2 days/wk, as opposed to an identical unit
operated continuously.
Monitoring: Temperature and CO monitoring should be required. An
opacity monitoring requirement in the absence of scrubbers would be
useful as an incentive to install scrubbers. Opacity monitoring would
also be useful for units which are operated at night. The agency should
also impose record-keeping requirements.
Case Study #3
Unit l: The height of the stack above the building is too low; therefore
its impact should be modeled. The stack exit temperature is also too
low, but the information is vague. More data are needed from the
applicant.
Unit 2: Modeling is also needed for this stub stack. More information is
needed on burner modulation. An annual stack test and provision and
space for future air pollution controls would be required.
Unit 3: This stack should also be modeled as it is clustered with the
other two. The stack exit velocity of 30 fps should be doubled because a
scrubber if required would decrease the stack exit temperature and
reduce dispersion.
GEM would be required for CO. The opacity requirement would be
tightened from 10% to perhaps 5%. The group criticized as vague the
proposed 5% limit on combustibles in ash. Questions that would have to
be answered include the details of the test protocol, how frequently to
test, and how to account for variations in the ash.
The group also questioned item #3 concerning stack testing if
combinations of types 1 and 4 waste are burned, because this provision
could be used as a loophole to avoid stack testing. Regular testing of
both the front and back halves should be required.
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Report by Wallace Somtag, New York DEC
Model Rule: The group generally agreed with the requirement for
2 seconds residence time at 1800°.
Design: Regulations for multichamber incinerators should be written to
require good combustion turbulence, but should allow alternatives for
innovative technology. Stack height increases should be allowed for
noncarcinogens only, i.e for pollutants which can be rendered harmless
by dilution.
Testing: The group compared the case study with New York DEC
requirements for testing TSP and HCL More than half the group
disagreed with the case study provision for testing only participates and
CO. A 100 ppm hourly average for CO was thought to be acceptable.
Stack testing might be done annually, but definitely should be done upon
startup.
Controls: For particulates control, the group was comfortable only with
a baghouse, but this may be unacceptable on small units. Acid gas
scrubbing is needed, at a minimum, on the large units. The benefit of
acid gas scrubbers is flue gas cooling, which condenses metals and
semivolatiles. No additional controls for pathogens would be needed.
•.
The issue of containers for sharps is really a solid waste problem, not an
air quality problem.
Monitoring: The group agreed with the recommendation for monitoring
primary and secondary temperatures, opacity, CO, and 02. Opacity
monitoring might not be needed with particulate control. However, an
opacity monitor would be useful in the event of an incinerator
malfunction. CEM reports should be provided quarterly to the agency.
Public Comment: A public hearing should be held. Most agencies
provided at least one notice of agency action, and Ohio has up to three.
Small Sources: The group favored a lenient policy of not shutting them
down "if public health is not endangered."
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OPEN DISCUSSION OF CASE STUDIES
SUMMARY OF DISCUSSION (SAN FRANCISCO)
*
Q: In response to Ms. Seidman's comment that the hospital's first
responsibility is to its patient: under most state laws, a publicly held
corporation's first responsibility is to its shareholders to produce a
profit.
A: (Unidentified speaker) A hospital's responsibility starts with the
administrators and often filters down to the staff. The problems are in
the designs of these incinerators, not the people who work there.
Q: There is a plastic that has 2-3% chloride in it, compared to about the
40% chloride in PVCs.
A: (G. Abum, MD DOH) Expect to see chlorine in CFG styrofoam.
Q: Burning radioactive wastes does not destroy them. Burning may allow
reduction of the volume of waste contaminated with radiation, which
would reduce the transportation and disposal costs.
A: (M. Tiemey, WI DNR) On radioactive wastes, Wisconsin defers to the
Nuclear Regulatory Commission to permit the facilities. Hospitals do
separate radioactives and deposit them into low-level waste depositories.
(W. Sonntag, NY DEC) New York hospitals have definite handling and
disposal methods for low-level radioactive waste. There are well
regulated procedures. If material is very "hot" it is sent to special
facilities.
(N. Seidman, NESCAUM) Some facilities have a geiger counter. If
trucks arriving for disposal of their wastes have high enough readings,
they are turned away from the facility.
(S. Shuler, Ecolaire Corp.) On low-level radioactive waste, the
information on permitting, regulating, and incinerating of radioactive
waste is extensive. Contact Charlotte Baker with the University of
California at Irvine. Ms. Baker held an international conference on
incineration of hazardous waste, low-level radioactive waste and mixed
waste.
Q: On ash handling: in Washington ash is tested and potentially goes to a
hazardous waste facility.
Q: On the 0.015 gr/dscf participate standard, does the cost involved really
justify the extra risk reduction?
A: (D. Campbell, Env. Can.) As a result of BACT requirements, an
incinerator with scrubber achieves 0.01-0.02 gr/dscf.
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The 0.015 gr/dscf particulate level removes most of the metals, dioxin,
and furans from the waste stream. That is probably why it is set so low.
(G. Shiroma, GARB) GARB is collecting information on the control
measures for hospital waste incineration, the associated costs, and what
the reduced risk is estimated to be for California facilities.
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OPEN DISCUSSION OF CASE STUDIES
SUMMARY OF DISCUSSION (BALTIMORE)
Q: Short stacks should not automatically he allowed if there are no
carcinogenic emissions. Applicants often submit proposed short stacks
because they have not given sufficient thought to stack height. A
criterion is needed for stack height, perhaps analogous to EPA's rule of
allowing a high stack as long as it is lower than the GEP height.
Q: Regarding the scrubber requirement for units emitting over 4 Ib/hr, why
not use a venturi scrubber rather than a dry scrubber plus baghouse?
A: (D. Painter, EPA) A venturi scrubber is an option. The tradeoff
between the baghouse and the venturi scrubber is one of pressure drop
versus cost. The biggest problem is finding air pollution controls for
units of under 10,000 cfm. The real issue is grain loading not flow rate.
Q: How frequently should stack testing be conducted?
A: (W. O1 Sullivan, NJ DEP) One approach is to test comprehensively at
startup, then test at intervals (maybe annually) in a more focused way to
minimize costs. Annual tests might be for particulates, HC1, and CO.
Q: In comparing venturi scrubbers to packed scrubbers, the latter control
metals more effectively. But there is a risk of Cd contamination with
the water discharge from any scrubber.
A: (W. O1 Sullivan, NJ DEP) A similar problem arose in New Jersey with
Hg in the water. The scrubber effluent required treatment before it
could be discharged to the municipal sewer system. High levels of Hg
remained in the sludge.
(J. Lauber, NY DEC) The hazardous materials issue is analogous to that
encountered with municipal solid waste. Metals concentrate in the fly
ash. In dry scrubbers a mixture of lime and fly ash is nonhazardous since
the lime and ash form a cement-like matrix which traps the metals. So
dry scrubbers are a favorable alternative.
Q; A previous presentation reported test results showing ash to be
hazardous. Did that system have lime injection?
A: (Unidentified speaker, NY DEC) No. It was a 2000 Ib/day existing
incinerator with a baghouse only. The fly ash tested well above the
cutoff for EP toxicity. At a 115 tons/day municipal solid waste
incinerator with dry lime injection, of 12 extraction tests of ash, two
were over the limit.
The New York DEC solid waste staff has discussed liming of hazardous
ash so that it will pass the EP toxicity test. However, there is only a
narrow range of pH in which leaching is inhibited, so this method must
be used only with care.
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Q: The energy grants mentioned previously are for heat recovery systems,
but heat recovery may increase PCDD emissions.
A: (J. Lauber, NY DEC) Anything that decreases the temperature (heat
recovery usually implies 400°-450°) will remove condensibles.
Theoretical approaches are not well developed, but empirically any
temperature decrease (based on experience with scrubbers) will provide
control.
Q: In a scrubber there is a "rapid quench" effect, whereas m a heat
recovery boiler there is a slow transition through the optimum
temperature for PCDD formation.
A: (J. Lauber, NY DEC) The evidence is that dioxins exist in two phases
— gas and particle. When the temperature drops in the scrubber the
vapor condenses on the particles, and then the baghouse removes the
particles. So the "middle" doesn't matter if the "back end" is
controlled. Good combustion plus good controls will give good results.
Q: What should be done to ensure adequate turbulence in the combustion
chambers?
A: (C. James, RI DEM) Some jurisdictions (e.g. Ontario) have guidelines on
Reynolds numbers.
(W. Sonntag, NY DEC) One researcher suggests a Reynolds number of
10,000 for adequate turbulence.
Q: Sludge must not be allowed to build up in the scrubber.
A: (W. O1 Sullivan, NJ DEP) A specific gravity limit can be used to control
the scrubber bleed to minimize sludge buildup.
Q: In a wet scrubber one can test the scrubbing water for dioxins. Pilot
tests show that if combustion is good there are no dioxins in the water;
therefore, scrubber water can be sampled to check incinerator
operation. If breakthrough occurs in the scrubber, dioxins should appear
in the water.
Q: Hospital directors in Michigan have said that they do not have a
mechanism to hear the concerns of their administrators responsible for
waste disposal. Such a mechanism would make a big contribution toward
solving hospital waste problems.
Q: How does one approach the idea of "good" turbulence?
A: (D. Painter, EPA) For municipal waste combustion one derives a CO
profile of the combustion zone, but this is difficult and costly. Also, it
may not be valid given the variability of the waste. A previous speaker
had recommended measuring fixed carbon in the ash. If the result is less
than the manufacturer's guaranteed level then combustion is assumed to
be good. However, there are still unresolved issues of how to sample
and analyze ash to ascertain the fixed carbon content.
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Q: Have any regulations on hospital waste incineration been promulgated in
the last year or two?
A: (Unidentified speaker) Pennsylvania and Philadelphia have. Some other
jurisdictions have guidelines. New York has a proposed regulation and
expects to have the final regulation in September, 1988.
Q: What guidelines are available for new incinerators?
A: (K. Shannon, Ohio EPA) The Ohio EPA uses the following guidelines.
Particulates: BAT (Best Available Technology, analogous to RACT)
is 1 lb/100 Ib charged.
HC1: 4lb/hr
Temperature: 1600° in secondary chamber. No standard for residence
time.
Units over 400 Ib/hr capacity must have mechanical feed and a lockout
that prevents waste feed if the temperature in the secondary
chamber is less than 1600°.
Battelle Memorial Institute is evaluating BAT for Ohio. Battelle will
make recommendations on temperature, residence time, need for air
pollution controls (for acid gas and perhaps NOjJ and dioxin standards,
and regulation of existing incinerators as well as new facilities.
(W. O1 Sullivan, NJ DEP) Tennessee also has regulations.
Q: What information is available on particle size distribution?
A: (W. Sonntag, NY DEC) According to Anderson 2000, the particles are
very small, e.g. titanium dioxide particles tested were all smaller than
2 microns. Sampling is difficult.
(R. Telesz, MI DNR) Michigan is considering the particle size issue.
(J. Lauber, NY DEC) At a hospital waste incineration conference in
Washington, DC, a paper discussed airflow control to minimize the
transport of large carbon particles into the secondary chamber. Too
high a temperature in the primary chamber causes particles to be
carried too far. Incinerators should be designed to keep particles in the
primary chamber since they are harder to burn than gases.
(W. O'Sullivan, NJ DEP) Tests on a controlled air incinerator in New
Jersey found that all particulates were under 10 microns and a
"considerable amount" were under 2 microns, so one can consider total
particulates to be fines.
(R. Waterfall, NY DEC) As a practical matter, old impactors for
participate sampling are obsolete. New equipment uses gas recycling
for isokinetic sampling, but requires impractical port sizes (e.g. 6 inch
diameter port in a 20 inch duct). A new method under study involves
recycling of gas to maintain a steady flow. The nozzle velocity can be
varied according to duct velocity, and a multicyclone is used for
sampling.
307
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Q: What information is available on pathogens in ash?
A: (J. Lauber, NY DEC) EPA should survey European standards on hospital
waste to gain insight on pathogen survival.
Q: Is ash disposal considered in the permit review process?
A: (W. O' Sullivan, NJ DEP) Not by the air agency in New Jersey. The
solid waste agency has its own regulations.
(Unidentified speaker) La Philadelphia, the proponent must apply for
separate air and solid waste permits, and the two agencies must agree
on ash disposal
(R. Telesz, MI DNR) In Michigan, when air permits are issued, the solid
waste agency requires a test and then acts on the results.
Q: Perhaps ash should be treated as hazardous but should not be so
designated. Call it a "special waste" instead.
A: (D. Painter, EPA) European agencies are doing something like this with
ash from municipal waste combustion. They are considering burying ash
in- caverns. However, as with any landfill, this option still involves
potential ash emissions to the atmosphere during transportation or at
the disposal site. Designation of waste may determine which landfill is
used, but the important issue is the overall impacts of disposal, not
necessarily the choice of landfill.
Q: Which agencies conduct a- comprehensive risk assessment for air or
multimedia impacts?
A: (W. O'Sullivan, NJ DEP) [By a show of hands at the session] 14 out of
45 do risk assessment for air, and a few do multimedia/multipathway
risk assessments. Some of the latter few agencies do such studies only
for certain facilities.
Q: At the Commerce facility, ash collected by the dry scrubber/baghouse
was left in an open shed. This raises the issue of particulate emissions
when the ash dries out. According to manufacturers, chlorine salts
could be formed at units with wet scrubbers, and emissions are possible
when the ash dries. What emission information is available?
A: (W. O'Sullivan, NJ DEP) Studies have found salts from the scrubber to
be a large proportion of the particulate catch unless there is a good
demister.
In Philadelphia, ash from ash piles blew into a neighborhood. The ash
failed the EP toxicity test and the incinerator was shut down.
Q: Incineration of trash just concentrates the metals, and they still go to
the landfill. What are the alternatives?
308
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A: (J. Lauber, NY DEC) The New York State University at Stony Brook
has experimented with municipal waste ash from the Westchester
facility. With 15% Portland cement it forms a cinder block. They are
building reefs with the blocks. After one year in a marine environment
the material does not leach. Reports are available.
Q: The process emissions from manufacturing cinder blocks are a concern.
Q: Are any states not using a technology-based (BACT or LAER type)
review for new hospital waste incinerators?
A: (R. Morrison, USEPA) [Results by a show of hands in the session:]
Letter-of-the-regulation emission limit only: 8 states.
BACT/State-of-the-art review: 22 states.
Therefore, there is still a need for Federal guidelines.
309
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310
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SESSION VIII
HOSPITAL STERILIZERS - NATURE OF THE PROBLEM
AND STATE PERMITTING EXPERIENCE
311
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312
-------
OSHA REGULATIONS REGARDING ETHYLENE OXIDE
Elizabeth Gross
Dana-Farber Cancer Institute
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
313
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I. OSHA - 1910.1047 Ethvlene Oxide -
PEL - 1 ppm, taken as an 8-hour, time weighted average (TWA)
ACTION LEVEL - 0.5 ppm S1EL.: 5 ppm, 15 min. TWA
EXPOSURE MONITORING -
Gen. - Breathing zone samples, representative of employee's
exposure.
Full shift measurements.
Each job classification.
Exposure Measurements
Date
Operation involved
Sampling and analytical methods
Number, duration and results of samples
Type of protective devices
Name, social security number and exposure of employee
Maintain thirty years
Training Program - Initially and at least Annually
OSHA Standards
Operations where EtO is present
Medical surveillance program
Methods to be used to detect presence or release of
EtO (i.e. monitoring devices)
Physical and health hazards of EtO
Methods of protection
Policy
Procedure book
- Emergency plan
- Protective equipment
Labeling system
Limited Use of Respirators
Where engineering controls are unfeasible such as:
1. During interval necessary to install or
implement engineering controls.
2. Maintenance/repair activities.
3. Emergencies.
Must be provided by employer
314
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Must foUow OSHA 29 CFR 1910.134 requirements for
respirator program which includes:
Selection, fit, use, cleaning and maintenance of
respirators.
Medical Surveillance
Performed by or under supervision of a licensed
physician.
Offered upon initial assignment and yearly thereafter
where EtO known (likely to be).
2. 0.5 ppm
at least 3Q days/year
Offered in emergency situation and to those who
believe they have signs of overexposure or are
concerned about the reproductive effects of EtO.
Required elements of program*
Medical/work history
Comprehensive physical
Complete blood count
ComnmnicatjLon jof EtO Hazards to Employees
Signs for regulated areas must state:
DANGER
ETHYLENE OXIDE
CANCER HAZARD AND REPRODUCTIVE HAZARD
AUTHORIZED PERSONNEL ONLY
RESPIRATORS AND PROTECTIVE CLOTHING HA? BE
REQUIRED TO BE WORN IN THIS AREA
Temporary Regulated Areas must also be posted.
Containers of EtO must be labeled:
CAUTION
CONTAINS ETHYLENE OXIDE
CANCER AND REPRODUCTIVE HAZARD
315
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precautions for Safe Use and Handling and Storage
A. Highly flammable
Vapors -» explosive mixtures in air
Store in cool, well-ventilated i.e., safety cabinet
- Remove all sources of ignition
Remember clothing if wet with EtO -» flammable
No food or beverages or smoking
Fire extinguishers, showers, access
-------
USE OF ETHYLENE OXIDE BY
HOSPITAL STERILIZERS IN THE
SAN FRANCISCO BAY AREA
Tim Smith
Bay Area Air Quality Management District
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco, CA
May 10-12, 1988
317
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USE OF ETHYLENE OXIDE BY
HOSPITAL STERILIZERS IN THE
SAN FRANCISCO BAY AREA
Tim Smith
Eugene Wiliner
Bay Area Air Quality Mgt. District
May 1988
THREE PART DISCUSSION
(1) Results of BAAQMD Survey of Hospitals
(2) Types of Sterilizers in Use in BAAQMD
(3) Overview of Issues Involved in Evaluating New and Existing
Sterilizers
HOSPITAL STERILIZER SURVEY
* Hospitals are much smaller EtO users than commercial
sterilizers (medical equipment, spices/ etc.)
* Little data on actual usage
* Goal of Survey: Evaluate priority of hospital sterilizers
relative to other categories in the BAAQMD Toxic Pollutant
Inventory
Scope of Survey
* Approximately 100 hospitals in the Bay Area
* Survey sent co each hospital requesting
(1) Usage of EtO or 12/88
(2) Make/model/ chamber volume
(3) Nature of sterilization cycle
(4) Area there any emission controls?
Good Survey Response
* About 90% returned the survey
* 77 had sterilizers
* 13 did not
* 10 have not responded
-------
BAY AREA
AIR QUALITY
MANAGEMENT DISTRICT
a) GENERAL AIR FLOW PATTERN
IN HOSPITAL STERILIZATION AREA
CORE
ROOM
STERILIZATION
ROOM
b) LOCAL EXHAUST VENTILATION SYSTEM
(FROM AMSCO, 19S5)
CORE STERILIZATION
ROOM ROOM
TO EXHAUST
PORT
BLOWER
VENT ON
LIQUID/GAS-
SEPARATOR
:c
5
\i
SAFETY VALVE
VENT
FIGURE 3-4. TYPICAL HOSPITAL STERILIZER VENTILATION SYSTEM
319
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TYPES OF STERILIZERS
* Table-Top
* Built-in
Table-Top
* Sizes — Typical is 4 cubic feet
* Uses 100% EtO in 4.5 ounce cans
* Almost all in BAAQMD are made by 3M
* None have air pollution controls
Built-in
* Sizes — 8 to 70 ft3 (typically 30)
* Use 12/88 EtO/Freon in 135 pound tanks
* Most in BAAQMD are by two manufacturers
(1) American Sterilizer (AMSCO)
(2) Castle
* None have air pollution controls
Distribution of Emissions
Usage of EtO can be emitted from:
(1) Sterilization chamber vent
(2) Vent drain (if water-sealed pump)
(3) Aeration chamber vent
Estimates of Distribution
EPA/Commercial Sterilizers: 50/45/5
Radian Corp. for BAAQMD: 25/50/25
Anyone else have data on this??
Usage of EtO
Usage per Sterilizer (#/year)
Built-in 80-1200 (Avg. = 360)
Table-top 23-270 (Avg. * 70)
320
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Usage per Sterilizer (#/day)
Built-in 0.2-3.3 (Avg. =1.0)
Table-top 0.06-0.7 (Avg. =0.2)
Pounds per Bed = ???????????????
Ambient Concentrations Near Sterilizers
* SCAQMD: 9 Parts per Trillion Average in South Coast Basin
* SCAQMD: 80 ug/ra3 (140 ppt) Ann. Avg. for a 1/2 Pound per
Day Unit
* BAAQMD: PTPLU Run: 300 Parts per Trillion (Annual
Average) for a 1 Pound/Day Unit
* Emission Occur Over Minutes — Short-term peaks are much
higher than annual average
Cancer Potency for EtO
» 100 x 10~6 at one ug/m3
» 180 x 10~6 at one ppb
» 0.18 x 10~6 at one ppt
Potent Carcinogen
* By Comparison
PERC, Methylene Chloride, TCE/ are 0.5 - 5 x 10~6 at
one ug/m3
California DHS Benzene Value - 53 x 10~6
Risks
* Even small table-top models probably exceed one in million
* Typical models probably exceed ten in a million without
controls
NEW SOURCE ISSUES
1. Do health risks warrant controls?
2. What control efficiency can be achieved? With acid
scrubbers? With catalytic oxidation?
3. What are the costs of control relative to the cost of the
sterilizer itself?
321
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EXISTING SOURCE ISSUES
1. Do the health risks warrant controls? Should more lenient
standard apply?
2. Retrofit Issues
(1) Degree of variation in flow, cone.
(2) Capture efficiency
(3) Space for control equipment
(4) Cost to retrofit recirculating pumps
(.5) Overall disruption to the industry
322
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ST. LUKE'S HOSPITAL
ETHYLENE OXIDE STERILIZER
A CASE STUDY
Danita Brandt
Michigan Department of Natural Resources
Air Quality Division
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
323
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MICHIGAN DNR
AIR QUALITY DIVISION
Danita Brandt
ST. LUKE'S HOSPITAL
ETHYLENE OXIDE STERILIZER
A CASE STUDY
PERMIT APPLICATION
• Submitted Feb. 2, 1987
• EtO Sterilizer and Aerator
PROPOSED PROCESS
• EtO/Freon gas
• Water-sealed vacuum pump
• 3 emission points
• Discharge from second floor
APPLICABLE RULES
Rule 201 - Permits
Rule 203 - Information
Rule 702 - VOCs/BACT
Rule 901 - Human Health
ACCEPTABLE CONCENTRATIONS
• Risk of 1 in 1 million
• 1% of TLV
NON-CRITERIA REVIEW
Ethylene Oxide
AAC » 0.03 ug/m3
Freon 12
AAC - 49.5 mg/m3
EMISSIONS
EtO 0.50 pounds per hour
Freon 3.67 pounds per hour
DISPERSION MODELING
• Ground Level Concentration
• Air Intakes
324
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RESULTS
GLC 4.00 ug/m3
Intake 29.71 ug/m3
PERMIT REVISION
• Reelrculating vacuum pump
• Acid Scrubber - 99.9+%
• Final EtO Removal System = 99.9+%
COST
Equipment and Piping
$15,500.00
RE-EVALUATION
GLC 0.004 ug/m3
Intake 0.030 ug/m3
APPROVED PERMIT
• 0.26 ppm emission limit
• No visible emissions
• Testing
• Monitoring
TESTING RESULTS
Concentration:
To scrubber - 200,000 ppm
To resin bed - 2 ppm
To atmosphere - Non-detectable
325
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326
-------
PERMITTING OF ETHYLENE OXIDE STERILIZER
AT ST. LUKE'S HOSPITAL
Randal Telesz
Michigan Department of Natural Resources
Air Quality Division
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Hotel Belvedere
Baltimore, MD
May 24-26, 1988
327
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This is how a hospital sterilizer is reviewed in the State
of Michigan. St. Luke' s is the first hospital sterilizer
to be permitted by our Air Quality Division.
In January of 1987, St. Luke's Hospital decided to replace a small ethylene
oxide sterilizer with a larger unit and a new aerator. The hospital contacted
the Michigan Occupational Safety and Health Agency for information
regarding occupational exposure limits from the new sterilizer. It was at this
time that the hospital was informed by MIOSHA that the DNR also required a
permit prior to installation, so their application was submitted to us on
February 2, 1987.
This is the sterilizer on the far right, with the new aerator next to it. The
sterilizing chamber is 8.8 cubic feet. The unit that was removed had a 4 cubic
foot chamber. The unit is used to sterilize non-wettable surgical instruments
and medical equipment.
The sterilizer would use a mixture of ethylene oxide and
dichlorodifluoromethane - which is Freon 12. This mixture is 12% ETO, 88%
Freon by weight.
A water sealed vacuum pump would be used to pull a vacuum on the
chamber and to exhaust the sterilizing gas at the end of the cycle. The
applicant claimed that the ETO would be absorbed by the water in a
water separator which would then be discharged to a floor drain., This
floor drain had a small vent hood to remove any residual ETO from the
drain area at a rate of 100 cfm. The applicant believed that most of the
ETO would be absorbed in the water and converted to ethylene glycol.
However, the ETO does not hydrolize that fast and is eventually emitted
somewhere downstream of the drain.
328
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In addition to the floor drain exhaust, a hood would be located above the
sterilizer door, venting at 200 cfm to remove any residual ETO from the
chamber when the door is opened. This exhaust stream would be
combined with the floor drain exhaust.
The third emission point would be from the aerator which had a 100 cfm
fan and would exhaust separately from the combined floor drain and
door hood.
The two proposed exhaust systems would discharge out the side of the second
floor of the hospital.
Upon receipt of the application, I had to determine which rules and
regulations applied to the proposed source.
Rule 201 of the Michigan Air Pollution Control Commission Rules
requires a permit prior to installation of any source of an air
• contaminant.
Rule 203 requires the applicant to provide all information pertinent to
the evaluation of the equipment.
Rule 702 limits the emissions of volatile organic compounds and requires
Best Available Control Technology to be applied to all new VOC sources.
Rule 901 prohibits the emissions of any air contaminant which may
cause injurious effects to human health and unreasonable interference
with the enjoyment of life and property.
To protect human health, Michigan has developed acceptable ambient
concentrations for non-criteria pollutants, or toxics. For pollutants
considered to be carcinogens, the AAC is that annual concentration which
would result in an increased cancer risk of one in one million on a lifetime
basis. For pollutants which have a Time Weighted Average - Threshold Limit
Value, Michigan limits the ambient concentration to 1% of the TLV using an
8 hour averaging time.
329
-------
Michigan has considered ETO a carcinogen since 1982. The AAC for ethylene
oxide is 0.03 ug/m^ based on Risk Assessment. This is much more limiting
than the AAC for Freon 12, which based on 1% of the TLV is 49.5 mg/m3.
These two AAC' s must be met by the applicant' s source.
For our evaluation of the sterilization process, we made several assumptions
with regards to emissions. This was necessary because accurate emission data
was not provided by the applicant.
The applicant told us they would be using 0.50 Ibs of ETO per cycle and that
90% of the gas would be exhausted during the first evacuation which lasted
about 20 minutes. We assumed nothing was absorbed by the materials being
sterilized. Three to four additional air washes and purges which last 10 -
15 minutes each, removed 99.98% of the ETO from the chamber. We made
the assumption that all of the 0.5 Ib of ETO that was put into the chamber
was exhausted in one hour at 300 cfm. We calculated the Freon emission rate
using the gas weight ratio.
Using the 0.50 Ib/hr emission rate for ETO, dispersion modeling was done to
determine the maximum ground level concentration on the hospital grounds as
well as the concentrations at any air intakes. The source was modeled using
an Industrial Source Complex model and was modeled as both a volume and a
stack source because the applicant wanted to discharge their exhaust
horizontally out the side of the building.
The maximum GLC is determined on the hospital grounds because of public
access. The Michigan Air Quality Division has looked at concentrations of air
pollutants at hospital air intakes since the early 70's. The ETO is being
exhausted to the atmosphere because of the occupational exposure limits so
we don't want to see the pollutant being drawn back into the work place as
well as the rest of the hospital through the air intakes ... as is illustrated
here with a hospital incinerator.
330
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This is what the dispersion modeling showed. Modeled as a stack source,
which was the worst case, the GLC for ETO, located 25 meters from the
hospital, was 4.0 ug/m3. This represents a risk of 1 in 10,000. The maximum
intake concentration, 29.71 ug/m3, occurred 12 meters from the exhaust point
on the roof of a 3-story portion of the hospital. This intake concentration
represents a risk of 1 in 1,000. These results agree with our experiences in
modeling hospital incinerators which show intake concentrations to be about
five times the maximum GLC. The maximum GLC for Freon 12 was
0.53 ug/m3, which was less than the AAC of 49.5 mg/m3; therefore, the
uncontrolled Freon emissions were environmentally acceptable.
The applicant was informed that their ETC emissions and the risk associated
with the ambient concentrations were unacceptable, and a permit would not
be granted for the equipment as proposed. The applicant was responsible for
proving that BACT would be employed to control the emissions and that the
resulting emissions would not cause injurious effects to human health or
safety.
The applicant proposed the following adendum to their application:
First, they would replace the once through water-sealed vacuum pump
and water separator with a recirculating pump utilizing mechanical
seals. This would concentrate the ETO exhaust stream which could then
be easily controlled.
The proposed control equipment consisted of a total recirculating
packed column acid scrubber with a 99.9% or greater removal efficiency
for the sterilizer exhaust and wash cycles.
The scrubber discharge would then join the door hood and aerator
exhausts, and the combined air flow would pass through the final ETO
removal system. This is a proprietary solid reactant bed, where the ETO
is absorbed, reacts and remains in the pores of the solid. The removal
efficiency for this is also 99.9% or greater.
331
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The control equipment was designed for an air flow of 255 cfm and an exhaust
concentration of 260,000 ppm from the sterilizer's first evacuation.
(pic)
This is the rear view of the sterilizer. There are 2 lines exhausting from the
sterilizer. The first is a I1/*" line which goes from the sterilizer through the
vacuum pump to the scrubber. The second is a copper line which bypasses the
vacuum pump and goes directly to the scrubber. This line is used when the
positive pressure is being reduced to zero because of problems experienced
with water getting into the pump oiL
(pic)
This is the new vacuum pump. The pump runs all the time with an inlet valve
that can be closed for the bypass.
(pic)
This is th scrubber. It has 2 packed columns, and a 10 foot3 recirculating tank
which contains a IN sulfuric acid solution.
(pic)
This is the final ETO removal system. It holds 235 pounds of solid reactant.
The inlet from the scrubber is a 1V4" line and the inlet from the aerator and
door is a 6" duct, both in the top of the picture. The 6" outlet is from the
bottom in front.
$15,500 was the cost of the new vacuum pump, the acid column, the
recirculation tank, recalculation and return pumps, final ETO removal system,
a fan and motor for the exhaust, control panels and all piping.
All of the equipment was installed by hospital personnel, so it was hard to add
the installation costs. The supplier also provides annual maintenance services
which include changing the acid solution, neutralizing it, and disposing of the
weak glycol solution offsite. The scrubber is then recharged with H^O and
acid catalyst, but I don11 know what these services cost.
332
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We re-evaluated the emissions from the sterilizer and assumed 99.9% removal
efficiency for each piece of control equipment.
Dispersion modeling showed the maximum GLC to be 0.004 ug/m3 and the air
intake concentration to be 0.03 ug/m3. If you recall, the first modeling
showed a GLC of 4.0 ug/m3 and the intake concentration to be 29.71 ug/m3.
The controlled emissions resulted in ambient concentrations at the ground
level and intake that were less than or equal to the AAC of 0.03 ug/m3.
The final permit was approved in December of 1987 for the sterilizer, aerator
and associated control equipment with the following conditions:
1) An emission limit of 0.26 ppm. This is the stack concentration that
results in the ambient concentrations we just looked at,
2) No visible emissions are allowed from the sterilizer,
3) Testing may be required for final operating approval,
4) and lastly, the applicant must monitor the ETO concentration prior to
and after the solid react ant bed. This must be done at least once a year
to determine the breakthrough of the reactant bed for replacement.
The supplier has estimated the life of the solid reactant to be 3-10 years.
This shows the final discharge from the side of the second floor. At the time
this picture was taken, the stack extension was not complete. However, the
final stack is 6" and discharges vertically about 8" below the 45* roof.
Testing of the ETO emission control system at St. Luke' s Hospital was done
last month.
During a normal operating cycle, gas samples were taken at the inlet
and outlet of both the scrubber and the gas/solid reactor. These samples
were analyzed onsite, using a gas chromatograph which was calibrated
to . 1 ppm.
333
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The samples were collected when the vacuum pump began to produce a
negative pressure in the sterilizer to evacuate the ETO from the
chamber.
The ETO concentration of 200,000 ppm to the scrubber agrees with the
typical gases expected which is approximately 20 - 26% ETO by volume
in the chamber.
The 2 ppm ETO concentration to the solid reactor bed did not include
the emissions from the door hood and aerator.
The final concentration to the atmosphere was non-detectable showing
the efficiency of the control equipment to be better than originally
estimated.
334
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ATMOSPHERIC PERSISTENCE OF EIGHT AIR TOXICS
By Larry T. Cupitt
Presented by:
Darrell Graziani
Hillsborough County Air Pollution Control
Presented at:
HOSPITAL INFECTIOUS WASTE/INCINERATION
AND HOSPITAL STERILIZATION WORKSHOP
Golden Gateway Holiday Inn
San Francisco/ CA
May 10-12, 1988
335
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HOTE: EXCERPTS
These Proceedings contain Section 2 only (Conclusions)
as presented by Darrell Graziani,
Hillsborough County Air Pollution Control.
ATMOSPHERIC PERSISTENCE OP EIGHT AIR TOXICS
by
Larry T. Cupitt
Atmospheric Sciences Research Laboratory
U.S. Envirormental Protection Agency
Research Triangle Park, NC 27711
A1MOSPHERIC SCIENCES RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
336
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SECTION 2
CONCLUSIONS
Relationships have been developed which describe the atmospheric
lifetimes of potentially hazardous chemicals in terns of their probable
removal mechanisms. These relationships have been applied to eight air
toxic chemicals identified by EPA in Intent to List notifications. The
eight chemicals and their estimated atmospheric lifetimes are tabulated
below.
TABLE 1. ESTIMATED ATMOSPHERIC LIFETIMES OF EIGHT AIR TOXICS
Chemical Name Atmospheric Lifetime
Methylene chloride 131 days
Chloroform 181 to 378 days
Carbon tetrachloride . 50 years
Ethylene dichloride 46 to 184 days
Trichloroethylene 4 days
Perchloroethylene 119 to 251 days
1,3-butadiene 4 hours
Etnylene oxide 217 to 578 days
For all the chemicals except carbon tetrachloride, the dominant
removal mechanism was reaction with hydroxyl (OH) radicals. Removal
rates for carbon tetrachloride were so slow that the dominant removal
mechanism could not be determined, and the lifetime given is one reported
elsewhere1 based upon modeling. Average tropospheric conditions for OH
337
-------
reactions were defined and utilized as the basis of the predicted
atmospheric lifetimes for the other chemicals, in the case of ethylene
oxide, questions regarding the atmospheric stability of the chemical and
the lack of ambient data were addressed and resolved.
338
-------
The estimated lifetime of butadiene is very short. The tabulated
lifetimes were calculated for "average" conditions as were described
above. Obviously, the actual lifetime of such a reactive compound will
depend upon the specific conditions at the time of release. Because
the estimated lifetime is so short, the actual degradation of any real
emissions is very dependent upon time of day, sunlight intensity, actual
temperature, etc. While the lifetime during the middle of the day in the
sunnier under polluted conditions could be much shorter than the estimated
4 hours, the lifetime of emissions at night could be essentially infi-
nite. After sunset, there will be no hydroxyl radicals generated and the
small amounts of residual ozone present in the evening will have little
effect on the butadiene concentrations. On average then, 1,3-butadiene
has an estimated lifetime of around 4 hours.
EXHYLENE OXIDE
Ethylene oxide (oxirane) is the smallest possible organic epoxide.
The nature of the chemical structure induces a high strain energy in the
three-merabered ring, and this strain energy influences the reaction
kinetics and products.66 Ethylene oxide finds its use as an intermediate
in the synthesis of ethylene glycol and as a sterilant or pesticide.53
The chemical is a mutagen and suspect carcinogen, having been classified
as being probably carcinogenic to hunans by EPA's Carcinogen Assessment
Group.67
While ethylene oxide has been monitored in the workplace, data on
ambient concentrations of ethylene oxide is very sparse. Brodzinsky and
Singh57 did not report finding any measurements published during the
period 1970-80. At this point, no ambient measurements are known.
•Two investigators have recently measured the reaction rate constant
for ethylene oxide with OH radicals.13'66 The experimentally determined
rocm temperature rate constants were 5.3 and 8.0 x 10~!4 on3 molecule'1
s"1. An activation energy of 2.9 kcal mol"1 was measured by one of the
339
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investigators across the temperature range 297 K to 435 K. While one
should be careful in extrapolating the temperature dependency outside the
measured range, it is still reasonable to assume a similar activation
energy across the small range to 260 K. Such an assumption does cause
greater uncertainty in any lifetime estimates, however. The larger rate
constant and the reported activation energy were used to estimate the
rate constants shown in Table 13. The choice of the larger rate constant
means that the estimated lifetimes are actually on the low side of the
possible values.
TABLE 13. ETHYLENE OXIDE REACTION RATE CONSTANTS AND LIFETIMES
Temperature
K
288
263
260
OH Reaction Rate Constant
W14 o»3 molec-1 s-1
6.9
4.3
4.0
Assumed [OH]
10*> raolec cm""3
1.0
1.0
0.5
Lifetime
days
167
217
578
Of the eight chemicals named in "Intent to List" notifications,
ethylene oxide is the most soluble in water. When the concentrations of
a chemical in water and air are expressed in the sane, units (e.g., moles
liter"1), the ratio of the aqueous phase concentration to the vapor phase
concentration is defined as the dinensionless solubility parameter, a.
This value has recently been measured at 288 K and found to be 6.2.56
This means that ethylene oxide does distribute preferentially into the
aqueous phase. Even without considering revolatilization of the chemi-
cal, however, rain out will still not be effective in removing the
chemical from the environment: the estimated lifetime due to rain out is
hundreds of years.* Experimental measurements and theoretical modeling of
rain out effects have demonstrated little impact from rain out for gases
which are even far more soluble than ethylene oxide.56
340
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Nor should the chemical distribute into the aqueous phase on ambient
aerosols and be removed by deposition of the aerosol. Even a worst case
condition of 150 wg m~3 of aerosol, all of it being water, will reduce
the gas phase concentration by only one part in one billion. If rapid
hydrolysis reactions were to occur to the ethylene oxide dissolved in the
aqueous aerosol, that chemical process could increase significantly the
loss by this mechanism. Half lives of ethylene oxide in the aqueous
phase have been reported68 to fall between 200 and 400 hours for a wide
variety of types of water (e.g., sterile distilled water, sea water,
fresh water, sterile and non-sterile river water). Such long lifetimes
suggest that hydrolysis reactions in aqueous aerosols are also not likely
to be fast.
No other removal process are known which can rapidly deplete the
ethylene oxide from the air. Results from smog chamber irradiations69'70
in both natural sunlight and artificial illumination (private ccmnunica-
tion, Dr. E. Edney, Northrop Services, Inc., Research Triangle Park,
North Carolina) are consistent with a slowly reacting organic chemical:
they suggest that there is not sane overlooked chemical or photolytic
process occurring to remove ethylene oxide. The estimated lifetime,
therefore, can be calculated simply from the OH radical removal rate.
From Table 13, one estimates the lifetime as 217 to 578 days.
This estimate of lifetime is in disagreement with a previous EPA
report by Bogyo et al.71 and a monograph72 by SRI International for the
National Cancer Institute. Those references conclude that "ethylene
oxide is highly reactive and does not persist in the environment" and
that epoxides like ethylene oxide are "expected to degrade rapidly* in
the environment. The SRI conclusion is based upon an extrapolation of
the work by Bogyo et al. Bogyo's conclusions are based upon a few liquid
phase experiments which may not be applicable and upon a single 1976
publication by Darnall et al.73 in which the "reactivity" of various
organics was ranked according to their reactivity with OH radicals.
Citing the Darnall reference, Bogyo et al. state "ethers as a class
341
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(epoxides are a type of ether) have been classified among the most
reactive hydrocarbons." That sentence implies that the conclusion of
"rapid" removal is based upon a doubtful analogy with unstrained ethers.
Darnall et al* do not rank any ethers at all! The only reference to
ethers is found in a table copied from an earlier publication7'* which
concluded that ethers were capable of producing significant quantities of
ozone. It also illustrates a misinterpretation of the literature: the
word "reactivity" used in the .paper cited by Darnall et al. referred to
the ozone forming potential, and not necessarily the rate of ronoval.
The conclusion that ethylene oxide "does not persist" is not warranted,
in light of the recent kinetic data.
It is interesting that ethylene oxide, with an estimated lifetime as
long as 1.5 years, has not been observed in the ambient atmosphere.57 A
study75 of breakthrough volumes in Tenax concluded that there was no safe
sampling volume for ethylene oxide when using Tenax. it is not surpris-
ing, therefore, that previous data from Tenax measurements did not
include ethylene oxide. Although Singh et al.21'22 have carried out a
great deal of ambient measurements using a different technique, ethylene
oxide was never one of the chemicals which they attempted to measure. In
a recent EPA field study using samples collected in polished stainless
steel canisters, all attempts to measure ethylene oxide were confounded
by an interference from the water peak (private communication, T. A.
Hartlage, U.S. EPA, Research Triangle Park, NC). A variety of other
methods have been reported in the literature for use in analyzing for
ethylene oxide.67»76-79 These methods all have reported sensitivities
from 0.05 parts per million to greater than 3 parts per million. The
1982 estimate*^ for production in the U.S. was 5000 million pounds, or
2270 million kilograms. Assuming that the total Northern Hemispheric
production is twice that of the U.S. and that one-fourth of all the
material produced is vented to the atmosphere, one calculates am annual
input to the Northern Hemisphere of 1.14 x 1012 grams, if the OH radical
decay rate is taken as 1/1.5 year"1 and the transfer rate to the Southern
Hemisphere is assumed^ to be 1/1.2 year*"1/ one estimates a background
342
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concentration in the Northern Hemisphere to be around 240 ppt. This
value is a factor of 200 to 12,000 below the quoted analytical detection
limits. Even if excursions of factors of 10 to 100 above geochenical
background were to occur in urban areas (analogous to some of the
observations of sinyh et al.21>22 for other pollutants), the concentra-
tions would still likely be below the detection limit.
It is not surprising then, that no ambient data on ethylene oxide
have been reported. Nor does the lack of ambient data argue that there
must be some rapid, but unknown, removal mechanism. Until additional
data arrive to modify these conclusions, it is appropriate to assign
ethylene oxide an atmospheric lifetime of from 0.6 to 1.5 years.
343
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344
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SESSION VIH: HOSPITAL STERILIZERS
NATURE OF THE PROBLEM AND STATE PERMITTING
SUMMARY OF DISCUSSION (SAN FRANCISCO)
Q: For which existing EtO sterilizers does the Bay Area AQMD require
permits-and what special conditions are put on them?
A: (T. Smith, BAAQMD) The Bay Area AQMD just drafted a letter to tell
them that they need permits. Part of the initial survey was to get an
idea of what the emissions were and from that we decided permitting
was necessary. A permit applicability section was added to our
regulations; it is a very broad "catch-all" which provides that if a
pollution control officer deems that there is an appropriate quantity of
toxics present at a given facility, the agency can request a permit
application within 90 days.
Q: Is anyone considering the safety issues of the exhaust systems? That is,
a fan blowing an explosive mixture near ignition sources?
A: (E. Wade, NY DEC) There is no explosion hazard when using an EtO
sterilizer. They are small units and use small concentrations.
(D. Graziani, Hillsborough Co., FL) We know of no explosions in our
jurisdiction.
(D. Painter. EPA) EPA is not very worried about having an explosion
with the 1288 mixture.
Q: How much does a new sterilizer cost?
A: (Unidentified speaker) The AMASCO unit costs about $30,000.
Q: How are those using risk assessment estimating the concentrations? Is
the assumed exposure to a one hour maximum or to an annual average
because of the batch process?
A: (D. Graziani, Hillsborough Co., FL) It is a problem because we are
using modeling. Since it is a batch process, they claim it is coming out
in the first 20 minutes. How can this be modeled? Will we need some
site specific monitoring outside the plant? We use the PTPLU model.
This gives the worst case impact, and we assume 2 or 3 times the
distance of the area of impact as the exposed population. Stack heights
are probably 20-25 feet above the building.
(D. Brandt, MI DNR) Michigan takes the one hour worst case emission
rate and models as a continuous emission with an annual averaging
time. This gives a very high number. Michigan treats all carcinogens
the same way and gives no credit to intermittent emissions.
345
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(Eric Wade, NY DEC) New York attempts to estimate realistic
exposures likely to occur during the year. For short-term values of EtO,
we would use the maximum emissions to occur during the cycle for a
one-hour period. For an annual risk assessment model, we would take
the maximum emissions to occur during the year given the constraints of
the process.
(Tim Smith, BAAQMD) Use of annual average concentrations for a risk
assessment is reasonable. In laboratory tests, the animals were probably
dosed with a constant concentration throughout their lives. Until
someone gives them some intermittent spikes over their lifetime and
comes up with a cancer potency, we probably won' t know whether our
risk assessments are worth anything. In the interim, the best thing is to
use the annual average concentration.
Q: Will there be a clearinghouse for this type of information?
A: (D. Painter, EPA) Contact the EPA Control Technology Center in
Research Triangle Park, NC.
346
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SESSION VHI: HOSPITAL STERILIZERS
NATURE OF THE PROBLEM AND STATE PERMITTING
SUMMARY OF DISCUSSION (BALTIMORE)
Q: What is the status of the new H^Q^ process?
A: (D. Graziani, Hillsborough Co., FL) Its effectiveness is limited and it
has only been demonstrated on a small scale. It will not replace the EtO
process.
Q: Because sterilization is a batch process the discharge to the atmosphere
is intermittent. How persistent in the environment is EtO?
A: (D. Graziani, Hillsborough Co., FL) Cupitt 1987 [excerpts reprinted in
these Proceedings; see presentation by Darrell Graziani] estimated that
EtO lasts for 217 to 578 days.
(D. Painter, EPA) Ultraviolet photolysis can affect the persistence of
EtO in the atmosphere. Its life in wastewater may be longer.
Q: EtO hydrolyzes in the presence of water to ethylene glycoL Could this
reaction be employed in an air pollution control, e.g. for fugitives?
A: (D. Painter, EPA) EtO is soluble in water but it may reach equilibrium
rapidly, so pH may have to be altered in order to drive the reaction to
produce ethylene glycoL Applicability as a control technique is
uncertain.
(R. Waterfall, NY DEC) A very large catheter manufacturing plant in
Glens Falls, New York, installed an acid hydrolysis scrubber for EtO.
Q: What are the water pollution impacts of EtO?
A: (R. Telesz, MI DNR) When the water goes into the sewer, the EtO
aerates out into the headspace and vents. It is probably gone by the
time the water reaches the treatment plant.
Q: A study by Hillsborough County (Florida) of 17 hospital facilities
indicates a need for EPA to promulgate a NSPS for sterilizers, analogous
to the NSPS for wood stoves.
Q: Regarding Freon emissions: substitution of CO2 or N2 for Freon could
be a significant issue.
A: (J. Gray, Consumat Systems, Inc.) A switch to N2 is feasible. The gas
mixture is well below the explosive range when using N2. Problems have
arisen with the use of CO2, so CO2 is not being used.
A possible approach is to require Freon controls on large facilities, and
follow the NSPS specifying N2 and a scrubber on small units.
347
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Q: Could sterilizers be vented to existing hospital incinerators?
A: (J. Gray, Consumat Systems, Inc.) Sterilization is a batch process with
2-20 cycles per day. Hospital staff would not be able to coordinate
incineration and sterilization.
Q: Could sterilizer emissions be controlled with a small afterburner to flare
off the EtO/N2 mixture?
A: (D. Graziani, HUlsborough Co., FL) This apparently has not been tried,
but it seems feasible.
348
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SESSION IX
WRAP-UP
349
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350
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SESSION K: WRAP-UP DISCUSSION
SUMMARY OF DISCUSSION (SAN FRANCISCO)
*
Q: Except in a non-attainment area, it is usually not necessary to look at
particulates. Are the particulates being used as a "back door" means of
estimating how well the organics are controlled?
A: (D. Painter, EPA) The 0.015 gr/dscf is based on actual test data. If you
are doing a BACT determination, you must consider that.
Dry scrubbers, ESPs, and bag houses have also demonstrated control
levels down to that area. Particulate collection at that efficiency will
also filter dioxins. This high degree of control is generally desirable.
Q: There are policy questions on how to control the smaller units and
whether there should be a size threshold for exemptions. Small units
may expose a local population to high risks. Large regional facilities
may expose a larger population to lower risks, and they raise
transportation issues.
Q: What is the status of federal regulations?
A: (D. Painter, EPA) EPA is in the beginning stages of writing
regulations. The Source Category Survey leads into Phase I which is a
much more detailed look at the industry. For the next step under the
Clean Air Act there are two sections that apply: sections lll(b) (NSPS)
and lll(d). The NESHAP process (section 112) is also a possibility.
However, under NESHAP, it is very hard to promulgate regulations, so
the alternative is section 111.
A model to follow may be municipal waste combustion, which can be
regulated as coke ovens are: call it municipal waste emissions and
monitor parameters such as particulates and CO. Particulates are an
indicator of the performance of "tail end" controls. CO indicates
combustion control, and good combustion is the strategy needed to
control dioxins.
Congress has not taken action. Clean Air Act amendments will probably
take another year to a year and a half. RCRA may be applied to
hospitals and hospital waste incineration.
351
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SESSION DC: WRAP-UP DISCUSSION
SUMMARY OF DISCUSSION (BALTIMORE)
«j
Q: The final disposal of ash receives inadequate attention.
A: (D. Painter, EPA) EPA is doing research on ash toxicity. A study
expected to show that ash toxicity was no problem concluded the
opposite, so efforts have been increased. EPA favors incineration to
reduce the volume to be landfilled. For information call the Air
Research Laboratory at EPA Control Technology Center, Research
Triangle Park, North Carolina (919) 541-0800.
(V. Ozvacic, ON Min. of Env.) Canadian agencies are studying the
leaching of metals from ash. The Ontario Ministry of the Environment
has guidelines on trace metals and organics, so they are studying the
question of ash toxicity. Environment Canada has also done research in
this area.
(T. Dydek, TX ACB) A paper on leaching of metals from municipal
waste ash appeared in the Journal of the Water Pollution Control
Federation for November, 1987 (Volume 59, page 979).
Q: Anecdotal evidence suggests that ash may contain identifiable objects
even if it meets a 5% fixed carbon criterion.
Q: Florida has permitted several municipal waste incinerators with dry
scrubbers and baghouses, that can meet a specification of 1800° for
2 seconds. What problems should be expected in burning hospital waste
in these facilities?
A: (D. Painter, EPA) Workers do not want to handle waste when they see
red bags.
Waste must be charged carefully since a sudden, excessive load of
medical waste could cause upset, slagging, or unbumed objects in the
ash. Also, the plastic red bags can ignite prematurely in the charging
area.
Regional facilities must deal with potential waste transportation
problems.
Wisconsin favors a dedicated facility for hospital waste, so that the
staff is familiar with and trained specifically for hospital waste.
The use of buckets in Wisconsin to collect sharps seems to be a good
idea.
In Washington (state), a municipal facility is burning large amounts of
hospital waste, resulting in community concern. The state agency is
addressing the questions raised.
352
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Q: (Unidentified speaker) Prince George's County, Maryland, requires
that waste be boxed after it is bagged, and then be delivered to a
specialized commercial incinerator. Worker concerns (leakage,
breakage, injury from sharps) are resolved if the waste is boxed. This
technique minimizes public concern and worker exposure, and could be
included in a Federal rule or state regulations.
353
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354
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ATTENDANCE LISTS
355
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Hospital Infectious Waste Incineration/
Hospital Sterilization Workshop
May 10-12, 1988
San Francisco, CA
Attendee List
Robert C. Adrian
California Air Resources Board
1102 Q Street
Sacramento, CA 95814
Hardip Ahluwalia
San Joaquin County Air Pollution
Control District
P.O. Box 2009
Stockton, CA 95201
Donald Ames
Technology Assessment Section
California Air Resources Board
1102 Q Street
Sacramento, CA 95812
Fred Austin
Fuget Sound Air Pollution Control
Agency
200 West Mercer Street, Room 205
Seattle, WA 98119-3958
Clint Ayer
Department of Environmental Quality
811 SW Sixth Avenue
Portland, OR 97204
Danita Brandt
Michigan Department of Natural
Resources
Air Quality Division
P.O. Box 30028
Lansing, MI 48909
Jean Bush
California Air Pollution Control
Officers Association
3232 Western Drive
Cameron Park, CA 95682
Alan Butler
Washington State Department of
Ecology
4350 150th Avenue, NE
Redmond, WA 98052
Dave Campbell
Department of Environment
13th floor, Place Vincent Massey
Ottawa, Ontario K1A OH3
Canada
G. Anders Carlson
New lork State Department of Health
2 University Place
Albany, NY 12203
Leslie Carpenter
Washington Department of Ecology
4350 150th Street, HE
Redmond, WA 98052
Nancy Fees Coleman
Oklahoma State Department of Health
Air Quality Service
P.O. Box 53551
Oklahoma City, OK 73152
J. Philip Cooke
Benton-Franklin-Walla Walla Counties
Air Pollution Control Authority
650 George Washington Way
Richland, WA 99352
David Craft
Monterey Bay Unified Air Pollution
Control District
1164 Monroe Street, Suite 10
Salinas, CA 93906
J. Wayne Cropp
Chattanooga-Hamilton County Air
Pollution Control Bureau
3511 Rossville Boulevard
Chattanooga, TN 37407
356
-------
Dean Delorey
Idaho Department of Health and
Welfare
Air Quality Bureau
450 West State Street
Boise, ID 83720
Henry Elliott
Emcotek
8220 Doe Avenue
Visalia, CA 93291
Catherine Fedorsky
Northeast States for Coordinated Air
Use Management
85 Merrimac Street
Boston, MA 021U
Lynn Fiedler
Michigan Department of Natural
Resources
Air Quality Division
P.O. Box 30028
Lansing, MI 48909
Sergio Figuracion
Kern County Air Pollution Control
District
2700 M Street, Suite 275
Bakersfield, CA 93309
Fred 0. Gray
Spokane County Air Pollution Control
Authority
West 1101 College Ave, Room 230
Spokane, WA 99201
Darrel J. Graziani
Environmental Protection Commission
U10 North 21st Street
.Tampa, FL 33604.
Elizabeth Gross
Dana-Farber Cancer Institute
44 Binney Street
Boston, MA 02115
Joann Held
New Jersey Department of
Environmental Protection
Division of Environmental Quality
401 East State Street, CN 027
Trenton, NJ 08625
Joan Heredia
Santa Barbara County Air Pollution
Control District
5540 Ekwill Street, Suite B
Santa Barbara, CA 93111
Steve Hickerson
Emcotek
8220 Doe Avenue
Visalia, CA 93291
Nolan Hirai
Hawaii Department of Health
Environmental Permits Branch
P.O. Box 3378
Honolulu, HI 96801
Ann Hobbs
Northern Sierra Air Quality
Management District
10433 Willow Valley Road
Nevada City, CA 95959
Anne Jackson
Minnesota Pollution Control Agency
520 Lafayette Road, North
Street Paul, MN 55155
Richard G. Johnson
Sacramento County Air Pollution
Control District
9323 Tech Center Drive, Suite 800
Sacramento, CA 95826
Sharon Johnson
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, NC 27611
Robert Joregenson
Colorado Department of Health
Air Pollution Control
4210 East 11th Avenue
Denver, CO 80220
James C. Eidd
Cleaver Brooks
Box 421
Milwaukee, WI 53209
357
-------
Robert S. Lee
Consumat Systems, Inc.
15 Earle Road
Mechanicsville, VA 23111
P. K. Leung
Source Monitoring
Environment Canada
River Road Laboratories
Ottawa, Ontario K1A OE7
Canada
John Manuel
Waste Management Branch
Ministry of the Environment
5th Floor, 40 St. Clair Avenue West
Toronto, Ontario M4.V 1P5
Canada
Henry Marschall
Emcctek
8220 Doe Avenue
Visalia, CA 93291
Melanie A. Marty
California Department of Health
Services
OEHHA/ HES/ ATU
2151 Berkeley Way
Berkeley, CA 94704
Vernon Miyamoto
Hawaii Department of Health
Laboratories Branch
1250 Punchbowl Street, 4th Floor
Honolulu, HI 96873
Berkeley L. Moore
Illinois Environmental Protection
Agency
2200 Churchill Road
Springfield, IL 62794-9276
Steve Morris
Municipality of Anchorage
P.O. Box 196650
Anchorage, AK 99519-6650
Todd Nishikawa
Placer County Air Pollution Control
District
11484 B Avenue
Auburn, GA 95603
Carl S. Norstedt
San Bernadino Air Pollution Control
District
15505 Civic Drive
Victorville, CA 92392
Terry Nyman
Northwest Air Pollution Authority
207 Pioneer Building
Mount Vernon, WA 98273
Vlado Ozvacic
Ontario Ministry of the Environment
880 Bay Street, 4th Floor
Toronto, Ontario M5S 1Z8
Canada
David Painter
US Environmental Protection Agency
Office of Air Quality Planning and
Standards
MD-13
Research Triangle Park, NC 27711
William Prastka
Southwest Air Pollution Control
Authority
1308 NE 134th Street
Vancouver, WA 98685
Pat Randall
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
Bruce W. Risley
Sacramento City Toxics Commission
1750 Howe Avenue, #520
Sacramento, CA 95826
Sayed Sadredin
San Joaquin County Air Pollution
Control District
P.O. Box 2009
Stockton, CA 95201
Joe Salovich
Bay Area Air Quality Management
District
939 Ellis Street
San Francisco, CA 94109
358
-------
James Salvaggio
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Harrisburg, PA 17120
Jon Sandstedt
Alaska Department of Environmental
Conservation
P.O. Box 0
Juneau, AK 99811-1800
Andrew Segal
San Diego Air Pollution Control
District
9150 Chesapeake Drive
San Diego, CA 92123
Nancy Seidman
Northeast States for Coordinated Air
Use Management
85 Merrimac Street
Boston, MA 02114
James Semerad
North Dakota Department of Health &
Consolidated Laboratories
1200 Missouri Avenue, Room 304-
Box 5520
Bismarck, ND 58502-5520
Genevieve Shiroma
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
Steve Shuler
Ecolaire Combustion Products, Inc.
11100 Nations Ford Road
Charlotte, NC 28224
Tim Smith
Bay Area Air Quality Management
District
Permits Services Division
939 Ellis Street
San Francisco, CA 94.109
Wallace Sonntag
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road
Albany, NT 12233-3254
Daniel Speer
San Diego Air Pollution Control
District
9150 Chesapeake Drive
San Diego, CA 92123
Tom Stauch
Denver Air-Quality 6 Environmental
Protection
605 Bannock Street
Denver, CO 80202
Mike Tierney
Wisconsin Department of Natural
Resources
Bureau of Air Management
Box 7921
Madison, WI 53707
Richard Wachs
Merced County Air Pollution Control
District
P.O. Box 471
Merced, CA 95341
Eric Wade
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road
Albany, NT. 12233-3255
Robert Waterfall
New Tork Department of Environmental
Conservation
Division of Air
50 Wolf Road, Room 138
Albany, NT 12233-3257
Paul Willhite
Lane Regional Air Pollution Authority
255 North 5th, Suite 501
Springfield, OR 97477
Gene Willner
Bay Area Air Quality Management
District
939 Ellis Street
San Francisco, CA 94109
359
-------
James A. Wilson
Olympic Air Pollution Control
Authority
120 East State Avenue
Olympia, WA 98501
Jay R. Witherspoon
Bay Area Air Quality Management
District
939 Ellis Street
San Francisco, CA 94109
Lloyd Tandell
Kaiser Hospital
2425 Geary Boulevard
San Francisco, CA 94115
Gary lee
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
360
-------
Hospital Infectious Waste Incineration/
Hospital Sterilization Workshop
May 24-26, 1988
Baltimore, MD
Attendee List
Tad Aburn
Maryland Department of Health &
Mental Hygiene
Air Management Administration
201 W. Preston Street, 2nd Floor
Baltimore, MD 21201
E. L. Anderson
Metropolitan Dade County
Department of Environmental Resources
Management
111 NW First Street, Suite 1310
Metro Dade Center, FL 33128
Barry D. Andrews
Florida Department of Environmental
Regulation
2600 Blairstone Road
Tallahassee, FL 32301
John Ault
Prince Georges County Health
Department
Division of Air Quality
10210 Greenbelt Road
Seabrook, MD 20706
Jesse Baskerville
US Environmental Protection Agency
Region III
8^1 Chestnut Building
Philadelphia, PA 19107
Max Batavia
South Carolina Department of Health &
Environmental Control
Bureau of Air Quality Control
2600 Bull Street
Columbia, SC 29201
Michael Bradley
Northeast States for Coordinated Air
Use Management
85 Merrimac Street
Boston, MA 02114
Frank D. Buckman
New York Department of Environmental
Conservation
Bureau of Air Research
50 Wolf Road, Room 134
Albany, NY 12233-3259
Lawrence L. Bunn
South Carolina Department of Health &
Environmental Control
Bureau of Air Quality Control
2600 Bun Street
Columbia, SC 29201.
David Campbell
Department of Environment
13th floor, Place Vincent Massey
Ottawa, Ontario K1A OH3
Canada
Sibyl Carley
Jacksonville Bio-Environmental
Services Division
421 West Church Street, Suite 412
Jacksonville, FL 32202
G. Anders Carlson
New York Department of Health
2 University Place
Albany, NY 12203
Lawrence Caukler
New Jersey Department of
Environmental Protection
Division of Environmental Quality
401 E. State Street, 2nd Floor
Trenton, NJ 08625
Joyce A. Chandler
District of Columbia Environmental
Control Division
5010 Overlook Avenue SW
Washington, DC 20032
361
-------
Edgar Chase
Fairfax County Health Department
Air Pollution Control Division
10777 Main Street, Suite 100A
Fairfax, VA 22030
Leland Cooley
University Hospital
University of Maryland
Green Street
Baltimore, MD 21201
Ruben Dagold
Baltimore Department of Health
303 Fayette Street, 4th Floor
Baltimore, MD 21202
Craig Dunlop
Massachusetts Department of
Environmental Quality Engineering
75 Grove Street
Worcester, MA 01564.
Jim Dusek
Fairfax County Health Department
Air Pollution Control Division
10777 Main Street, Suite 100 A
Fairfax, VA 22030
Tom Dydek
Texas Air Control Board
6330 Highway 290 East
Austin, TX 78723
James Eddinger
US Environmental Protection Agency
Office of Air Quality Planning &
Standards
MD-13
Research Triangle Park, NO 27711
David Ernst
Jason M. Cortell and Assoc., Inc.
24A Second Avenue
Wai than, MA 02154.
Koorosh Farhoudi
Kentucky Division of Air Quality
18 Reilly Road
Frankfort, KT 4.0601
Richard Fram
New York Department of Environmental
Conservation
Region 2
47-40 21st Street
Long Island City, NT 11101
Donna Gorby-Lee
Montgomery County Regional Air
Pollution Control Agency
451 West Third Street
P.O. Box 972
Dayton, OH 45422
Darrel Graziani
Hillsborough County Air Pollution
Control
1410 North 21st Street
Tampa, FL 33605
Elizabeth Gross
Dana-Farber Cancer Institute
44- Binney Street
Boston, MA 02115
Barbara Hardy
Fairfax County Health Department
Air Pollution Control Division
10777 Main Street, Suite 100A
Fairfax, VA 22030
Joann Held
New Jersey Department of
Environmental Protection
Division of Environmental Quality
401 East State Street, CN027
Trenton, NJ 08625
L. C. Hinther
Kansas Department of Health &
Environment
Bureau of Air Quality & Radiation
Control
Forbes Field
Topeka, KS 66620
Thomas Huynh
Philadelphia Air Management Services
500 South Broad Street
Philadelphia, PA 19146
362
-------
Christopher James
Rhode Island Department of
Environmental Management
Division of Air 6 Hazardous Materials
291 Promenade Street
Providence, RI 02908
Stephen Jenness
US Army Environmental Hygiene Agency
HSHB-ME-A
Aberdeen Proving Ground MD 21010-5422
Timothy L. Jones
Indiana Department of Environmental
Management
105 South Meridian Street
Indianapolis, IN 4.6206
Martha Keating
US Environmental Protection Agency
Office of Air Quality Planning and
Standards
MD-13
Research Triangle Park, NC 27711
Michael W. Kendall
Baltimore County Bureau of Air
Quality Management
300 East Tovsontown Boulevard
Tovson, MD 21204
Steven Klafka
Wisconsin Department of Natural
Resources
Bureau of .Air Management
P.O. Box 7921
Madison, WI 53707
Jack D. Lauber
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road
Albany, NT 12233-3255
C. C. Lee
US Environmental Protection Agency
26 West Martin Luther King Street
Cincinnati, OH 45268
P. K. Leung
Source Monitoring
Environment Canada
River Road Laboratories
Ottawa, Ontario K1A OE7
Canada
Kevin Macdonald
Maine Department of Environmental
Protection
Bureau of Air Quality
State House-Station 17
Augusta, ME 04333
John Manuel
Waste Management Branch
Ministry of the Environment
5th Floor, 40 St. Glair Avenue West
Toronto, Ontario M4V 1P5
Canada
Scott Mason
Maine Department of Environmental
Protection
Bureau of Air Quality
State House-Station 17
Augusta, ME 04333
Charles C. Masser
US Environmental Protection Agency
Air and Energy Engineering Research
Laboratory
MD-63
Research Triangle Park, NC 27711
Michael Mayenschein
Baltimore Department of Health
303 Fayette Street, 4th Floor
Baltimore, MD 21202
John C. McCarthy
Jefferson County Air Pollution
Control District
914 East Broadway
Louisville, KI 40204
Rayburn M. Morrison
US Environmental Protection Agency
Office of Air Quality Planning &
Standards
MD-13
Research Triangle Park, NC 27711
363
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Carol B. Moser
Mecklenburg County Department of
Environmental Protection
1200 Blythe Blvd.
Charlotte, NC 28203
Leslie Nickels
Chicago Department of Health
Daley Center, Room 236
50 West Washington.Street
Chicago, IL 60602
William 0'Sullivan
New Jersey Department of
Environmental Protection
Division of Environmental Quality
Engineering & Technology
4.01 East State Street, 2nd Floor
Trenton, NJ 08625
Vlado Ozvacic
Ontario Ministry of the Environment
800 Bay Street, 4th Floor
Toronto, Ontario M5S 1Z8
Canada
David Painter
US Environmental Protection Agency
Office of Air Quality Planning and
Standards
MM 3
Research Triangle Park, NC 27711
Tom Parks
Massachusetts Department of
Environmental Quality Engineering
5 Commonwealth Avenue
Woburn, MA 01801
Mangu Patel
Illinois Environmental Protection
Agency
Division of Air Pollution Control
2200 Churchill Road, PO Box 19276
Springfield, IL 62794-9276
Robert Pease
South Coast Air Quality Management
District
9150 Flair Drive
El Monte, CA 91731
John L. Perrault
Vermont Agency of Natural. Resources
Air Pollution Control Program
Building 3 South, 103 S. Main Street
Waterbury, VT 05676
David F. Porter
West Virginia Air Pollution Control
Commission
1558 Washington Street, East
Charleston, WV 25311
Roger Powell
US Environmental Protection Agency
Office of Air Quality Planning &
Standards
MM 5
Research Triangle Park, NC 27711
Karen A. Randolph
District of Columbia Environmental
Control Division
5010 Overlook Avenue SW
Washington., DC 20032
Carl Rivkin
Maryland Department of Health &
Mental Hygiene
Air Management Administration
201 West Preston Street
Baltimore, MD 21201
Don Robinson
Utah Department of Health
Bureau of Air Quality
288 North 1460 West
P.O. Box 16690
Salt Lake City, UT 84116
Baidya Nath Sahay
New York City Department of
Environmental Protection
Bureau of Air Resources
295 Lafayette Street
New York, NY 10012
James M. Salvaggio
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Harrisburg, PA 17120
364
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Henry L. Sandonato
New York Department of Environmental
Conservation
600 Delaware Avenue
Buffalo, NT 14202
Mary B. Schwenn
Forsyth County Environmental Affairs
Department
537 North Spruce Street
Winston-Salem, NC 27101
Lori A. Scriven
Arkansas Department of Pollution
Control & Ecology
8001 National Drive
P.O. Box 9583
Little Rock, AR 72209
Kathleen Shannon
Ohio Environmental Protection Agency
1800 Watermark Dr
Columbus, OH 43215
Michael H. Sherman
Alabama Department of Environmental
Management
1751 Federal Drive
Montgomery, AL 36102
Steve Shuler
Ecolaire Combustion Products, Inc.
11100 Nations Ford Road
Charlotte, NC 28244
Tim Smith
Bay Area Air Quality Management
District
Permit Services Division
939 Ellis Street
San Francisco, CA 94109
Wallace E. Sonntag
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road
Albany, HI 12233-3254
Donald Squires
Massachusetts Department of
Environmental Quality Engineering
Division of Air Quality Control
One Winter Street, 8th Floor
Boston, MA 02108
Edwin J. Taylor
Allegheny County Health Department
Bureau of Air Pollution Control
301 39th Street
Pittsburgh, PA 15208
Randal S. Telesz
Michigan Department of Natural
Resources
Air Quality Division
Stevens T. Mason Bldg., Box 30028
Lansing, MI 48909
Jeffrey Twaddle
Toledo Environmental Services
26 Main Street
Toledo, OH 43605
Robert C. Vachula
Massachusetts Department of
Environmental Quality Engineering
Division of Air Quality Control
436 Dwight Street
Springfield, MA 01103
Eric L. Wade
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road
Albany, NY 12233-3255
Robert Waterfall
New York Department of Environmental
Conservation
Division of Air
50 Wolf Road, Room 138
Albany, NY 12233-3257
James J. Weyler
Chattanooga-Hamilton County Air
Pollution Control Board
3511 Rossville Boulevard
Chattanooga, TN 37407
365
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Anne E. Williams
Prince Georges County Health
Department
Division of Air Quality
10210 Greenbelt Road
Seabrook, MD 20706
Gary M. Tee
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
Carl York
Maryland Department of Health &
Mental Hygiene
Air Management Administration
201 West Preston Street, 2nd Floor
Baltimore, MD 21201
Steve Zervas
New Hampshire Department of
Environmental Services
Air Resources Division
64 North Main Street, Caller Box 2033
Concord, NH 03302-2033
366
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TECHNICAL REPORT DATA
(Please read Instructions on the reverie before completing/
1. REPORT NO. 2.
EPA-450/4-89-002
4. TITLE AND SUBTITLE
Proceedings: National Workshops on Hospital Waste
Incineration and Hospital Sterilization
7. AUTHORtS)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
NESCAUM
85 Merrimac Street
Boston, HA 02114
12. SPONSORING AGENCY NAMC AND A OCR CSS
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and standards
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO
S ae»ORT DATE
January 1989
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NC
10. PROGRAM ELEMENT NO.
1 1. CONTRACT/GRANT NO
A001-8888-74
13. TYPE Of REPORT ANO PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
19. SUPPLEMINTAAY NOTES
EPA Project Officer: David F. Painter
16. ABSTRACT
The primary goals of the workshops were to present the most
advanced research and policies on hospital waste incineration being
pursued in the regulatory sector, encourage the formation of
networks among those involved, and improve permitting and
enforcement through exchange of information. Hospital waste
sterilization was also included because it is a related source of
increasing regulatory concern. The agenda was specifically
structured to provide insight into the magnitude and nature of the
problems associated with these sources, and the responsive actions
taken by State and local agencies to develop regulations and issue
permits.
17.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
o. COS ATI Field Croup
Hospital Waste Incineration
Infectious Waste
Ethylene Oxide
Sterilization
Regulations
18. DISTRIBUTION STATEMENT
Release Unlimited
19 SECURITY CLASS < Hut RfOt"n
Not Classified
Jt NO Of "AGES
366
20 SECURITY CLASS i This paw
Not Classified
22 ao'C£
SPA Form 2220-1 (R««. 4-77) PWCVIOUS COITION is OBSOLETE
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