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.
                                ii

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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.
                                  111

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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.
                                   vi

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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.

                                 vii

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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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8

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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.
                                    10

-------
           SESSION II




MANUFACTURERS' PANEL DISCUSSION
               11

-------

-------
           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.
                             13

-------
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
                             14

-------
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

-------
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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REDUCTION INC
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20

-------
                    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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
KT •» PIU.OI
                                                                   PROCESS DIAGRAM FOR
                                                                   STANFORD UNIVERSITY
                                                                       S-0704D
           33

-------
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

-------
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

-------
                       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

-------
                    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

-------
                       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

-------
40

-------
           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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                                 s
                                '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

-------
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

-------
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

-------
(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

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                           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

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          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

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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.
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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.
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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.


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90

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                         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
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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
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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
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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
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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
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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
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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.
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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
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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.
                                      106

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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
                                     108

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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;

                                 109

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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.
                                     110

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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;
                                     112

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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
                                    113

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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
                  115

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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,

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            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.
                             117

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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.
                             118

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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,
                            119

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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.
                             120

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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:
                 121

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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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                             128

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                          134

-------
        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

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              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

-------
    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

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             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?

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     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
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                                                                         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.
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                                      Ytttota eon to b* retained by applicant
                                                          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

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     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

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 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

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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

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186

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            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

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     (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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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.

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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
                               213

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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
                               214

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       HOSPITAL/INFECTIOUS WASTE MANAGEMENT
                   Prepared by



PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES



             OFFICE OF PUBLIC LIAISON



                   January 1988
                     215

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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.
                                    216

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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.
                                  217

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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.
                                   218

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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.

                                   219

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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.


                                   220

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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.

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     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
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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
                                  233

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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 '
                             236

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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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                            - 5 -
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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                                         - 6 -


              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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                                        - 8 -
            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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                            - 9 -


                         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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                                 - 10 -
                             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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                                 - 13 -
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
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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

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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 >»
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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.
                               291

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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
                                  292

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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.
                                   295

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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.
                                   296

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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

-------
     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.
                                    298

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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.
                                   299

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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.
                                   300

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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.
                                   301

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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."
                                   302

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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.
                                   303

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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.
                              304

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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.
                                   305

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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.
                                   306

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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

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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

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        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

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             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

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 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

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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

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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

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     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

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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

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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

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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

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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

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                   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

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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

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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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