-------
&EPA
Medical Waala
Oemonalrallon Program
Class 4 - Used Sharps
Sharps that have been used in animal or human patient care or
treatment or in medical, research, or industrial laboratories,
including hypodermic needles, syringes (with or without the attached
needle), pasteur pipettes, scalpel blades, blood vials, test tubes,
needles with attached tubing, and culture dishes (regardless of
presence of infectious agents). Also included are other types of
broken or unbroken glassware that were in contact with
infectious agents, such as used slides and cover slips.
Class 5 - Animal Waste
Medical Waale
Demonstration Program
Contaminated animal carcasses, body parts, and bedding of animals
that were known to have been exposed to infectious agents during
research (including research in veterinary hospitals), production
of biologicals, or testing of Pharmaceuticals.
<&EPA Class 6 - Isolation Wastes
Medical Waate
Oemonalrallon Program
Biological waste and discarded materials contaminated with blood,
excretion, exudates, or secretions from humans who are isolated
to protect others from highly communicable diseases, or isolated
animals known to be infected with highly communicable diseases.
-11-
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&EPA Class 7 - Unused Sharps
Medical Wasl*
Demonstration Program
Hypodermic needles, suture needles, syringes, and
scalpel blades
&EPA Wastes Not Subject to the
M.OC..W.... Requirements of the Regulations
Demonstration Program
Wastes Excluded by Statute Are:
- Domestic Sewage
- Hazardous Waste
- Household Waste
Wastes Excluded or Exempt From the Rule Are:
- Treated and Destroyed Waste (e.g., Incinerator Ash)
- Etiologic Agents Shipped Pursuant to Other Federal
Regulations
- Human Remains Intended for Interment or Cremation
- Samples Collected for Enforcement Purposes
-12-
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4^ EPA Treatment and Destruction
M.d.e..w..i. Exemption
Demonstration Program
RMW That Has Been Both Treated and Destroyed is No Longer RMW
Treated RMW - RMW That Has Been Treated to Substantially Reduce
or Eliminate Its Potential for Causing Disease
Destroyed RMW - RMW That Has Been Ruined, Torn Apart, or
Mutilated Through Processes Such as Thermal Treatment,
Melting, Shredding, Grinding, Tearing or Breaking, So That
It is No Longer Generally Recognizable as Medical Waste
& EPA Generator Standards
Medical waste
Demonstration Program
Standards Apply to Generators of RMW in a Covered
State
Intermediate Handlers Who Treat or Destroy RMW Must
Comply With These Standards
Transporters (Transfer Facilities) Who Consolidate or
Remanifest RMW Must Also Comply With These
Standards
-13-
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& EPA Generator Standards
General Requirements
Generators Must Properly Segregate, Package, Label, and
Mark all RMW Intended for Transport Off-site
Generators Must Use the Medical Waste Tracking Form or
Appropriate Logs to Document Each Shipment of RMW
Generators Must Maintain the Necessary Records and Submit
Exception Reports as Required
Generators Who Incinerate RMW On-site Must Submit
Additional Reports
&EPA Generator Standards
Types of Generators
Generators Include, but are Not Limited to, the Following:
- Hospitals (Including On-site Laboratories); Medical Clinics
Including Drug Treatment Centers
- Clinical and Research Laboratories That Perform Health
Related Analysis Including Universities
- Physicians' Offices, Dental Offices, and Veterinary Practices
- Long-term Health Care Facilities Including Nursing Homes,
Hospices, and Non-residential Medical Day Care Facilities
- Funeral Homes, Ambulance Services, Blood Banks, and Dialysis
Centers
- Miscellaneous: Commercial and Military Vessels at Port in
Covered States
-14-
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Pre-Transport Standards
Segregation Requirements
Generators Must Segregate RMW That is Intended for Transport
Off-site
RMW Must be Segregated into the Following Categories:
- Sharps and Their Residual Fluids (Classes 4 and 7)
- Fluids (in Quantities Greater Than 20 cc)
- All Other RMW
Mixtures of RMW With Other Solid Waste Must Be Handled as RMW
Additional Requirements May Apply to Mixtures of RMW With
Hazardous Waste and Radioactive Waste
4^ EPA Pre-Transport Standards
Packaging Requirements
RMW Must be Packaged in Containers That are:
- Rigid
- Leak-resistant
- Impervious to Moisture
- Resistant to Tearing or Bursting
- Sealed to Prevent Leakage
In Addition to the Above Requirements:
- Sharps Must be Packaged in Puncture-Resistant Containers
- Fluids Must be Packaged in Break-Resistant, Tightly Lidded
or Stoppered Containers
Generators May Use One or More Containers to Meet These
Standards
-15-
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Pre-Transport Standards
Storage Requirements
Any Person Who Stores BMW Prior to Treatment or Disposal
On-site or Transport Off-site Must:
- Store the Waste in a Manner That Protects the Integrity
of the Container and Does Not Provide a Breeding Place
or Food Source for Insects or Rodents
- Protect the Container From Water, Rain, and Wind
- Maintain the Waste in a Non-putrescent State
- Lock Outdoor Storage Areas
- Limit Access to On-site Storage Areas
Pre-Transport Standards
Labeling Requirements
Each Container of Untreated RMW Must Be Labeled
(Identification of Its Contents) as Follows.
- The Label Must Contain the Words "Medical Waste" or
"Infectious Waste" or Display the Universal Biohazard Symbol
- When a Red Plastic Bag is Used, as an Inner Container,
a Label is Not Necessary
The Label Must be Water-Resistant and Affixed or Printed
on the Outside of the Container
Containers of Treated RMW Need Not Be Labeled
-16-
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^ EPA Pre-Transport Standards
Marking Requirements
Each Package of BMW Must Have Attached on Its Outer
Surface an Identification Tag Marked as Follows:
- Generator's or Intermediate Handler's Name and Address
- Transporter's Name and Address
- Date of Shipment
- Identification of Contents as Medical Waste
Each Inner Container, Including Sharps and Fluid Containers,
Must be Marked with the Generator's or Intermediate
Handler's Name and Address
Pre-Transport Standards
D.mon.,r.,,onProor.m Decontamination Requirements
All Non-rigid Containers and Inner Liners Must Be Managed as
RMW and Must Not Be Reused
Any Rigid Container to Be Reused Must Be Decontaminated Prior
to Reuse if It Exhibits Any Visible Contamination
If Container Cannot Be Decontaminated and Rendered Free of
Visible Contamination It Must Be Managed and Disposed of as RMW
Inner Liners Used in Conjunction With Reusable Containers Must
Be Disposed of With the RMW They Contain
-17-
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&EPA Medical Waste Tracking Form
Who Must Use a Tracking Form
Generators Who:
- Generate 50 Pounds or More of RMW in Any Calendar Month
- Generate Less Than 50 Pounds of RMW in a Calendar Month
but Make Any Single Shipment of More Than 50 Pounds
Intermediate Handlers Who:
- Change the Composition or Category of the RMW
- Repackage the RMW
Transporters (Including Transfer Facilities) Who:
- Consolidate and/or Remanifest RMW
- Repackage the RMW
Medical Waste Tracking Form
Parties Initiating a Form
Must Complete and Sign the Tracking Form for Each
Shipment of RMW
Must Prepare the Number of Copies That Will Provide:
- The Generator (Initiator) with a Copy
- Each Transporter with a Copy
- Each Intermediate Handler with a Copy (if Applicable)
- The Destination Facility with Two Copies; One for Its Records
and One for the Party Initiating the Form
Must Obtain the Handwritten Signature of the Initial Transporter
and Date of Acceptance on the Completed Tracking Form
-18-
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&EPA Generator Standards
Tracking Form Exemptions
Generators of Less Than 50 Pounds Per Month Are Exempt From
the Use of the Tracking Form When They:
- Use a Transporter Who Has Notified EPA and Who Uses the Logs
to Document Each Shipment
- Personally Transport the RMW to a Receiving Facility
- Ship Sharps to a Destination Facility Via the U.S. Postal Service
Generators of 50 Pounds or More Per Calendar Month Are Exempt
From the Use of the Tracking Form When RMW is Transported
Between Satellite Facilities
4^ EPA Generator Standards
Recordkeeping Requirements
Generators Must Maintain the Following Records:
- Copies of All Signed Tracking Forms and/or Shipping Logs
- Copies of All Exception Reports
Generators Must Maintain These Records for at Least Three (3)
Years from the Date:
- The Signed Tracking Form was Received by the Initial
Transporter
- The Exception Report was Filed
Generators Must Maintain Any Records Relevant to an
Enforcement Action Until the Resolution of that Enforcement Action
-19-
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Generator Standards
On-Site Treatment and Destruction
Generators Who Treat and Destroy RMW On-site, Other Than by
Incineration, Must Maintain the Following Records:
- Quantity, by Weight, of RMW That is Treated and Destroyed
- Percent, by Weight, of the Total Waste Treated and Destroyed
That is RMW
For Waste Accepted from Off-site Sources for Treatment and
Destruction, the Generator Must Also Maintain the Following
Information:
- Identification of the Off-site Source
- The Date the Waste was Accepted
- Quantity, by Weight, of Waste Accepted
- The Date the Waste was Treated and Destroyed
^ EPA Generator Standards
On-site Incinerator Requirements
Generators Must Maintain Incinerator Operation Logs
Generators Accepting RMW From Off-site Sources for On-site
Incineration Must Maintain Information That Identifies the
Generator and the Amount of Waste Accepted
Generators With On-site Incinerators Must Submit Two Reports
to EPA Summarizing Information Collected During the First and
Third 6-Month Periods of the Demonstration Program
-20-
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^ EPA Transporter Standards
General Requirements
Each Transporter Accepting RMW Generated in a Covered
State Must:
- Notify EPA and That Covered State of its Intent Prior to
Commencing Such Activity
- Operate and Maintain Vehicles for Transport of RMW in
Accordance With All Applicable Requirements
- Comply With All Tracking Form and Logging Requirements
- Maintain All Required Records of RMW-Related Activities
- Prepare and Submit Requisite Reports to EPA and the States
&EPA Transporter Standards
Vehlcle Requirements
Vehicles Used to Transport RMW Must:
- Have a Fully Enclosed, Leak-Resistant Cargo Carrying Body
That Is Capable of Being Locked
- Be Marked With Identification Information on Both Sides and
Rear, Including:
- Company Name
-- Company's State Permit or Identification Number
-- "MEDICAL WASTE" or "REGULATED MEDICAL WASTE"
- Not Subject RMW to Mechanical Stress or Compaction During
Loading and Unloading and During Transit
-21-
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^ EPA Transporter Standards
Use 0| the Tracking Form
Transporters Accepting BMW Accompanied by a Tracking
Form Must:
- Ensure That the Tracking Form is Properly Completed and
Accurate
- Inspect the Shipment to Ensure it is Properly Packaged,
Labeled, and Marked
- Sign and Date the Tracking Form and Return a Signed Copy
to the Generator Representative
Ensure That the Remaining Copies Accompany the RMW
During Transit
Destination Facility Standards
General Requirements
These Standards Apply to All Facilities that Accept RMW that is
Generated in a Covered State for Treatment, Destruction,
Off-site Incineration or Disposal
All Such Facilities are Required To:
- Operate and Manage All Accepted RMW in Accordance With
Applicable Requirements
- Comply With All Tracking Form Requirements
- Maintain All Required Records of RMW-Related Activities
- Prepare and Submit Requisite Reports to EPA and State
Agencies (e.g., Discrepancy Reports)
These Standards Apply to Such Facilities Even if the Facility is
Located in a Non-Covered State
-22-
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Program Enforcement
_ Sdrious viol3tions
Demonstration Program «« «^r«««» w «*>*»%» **
Serious Violations Requiring Formal Enforcement Actions
Include:
- Transporting, or Delivering/Offering for Transportation RMW
Without a Tracking Form
- Improper Labeling of the RMW
- Failure of the RMW Transporter to Comply With One-Time
Notification to EPA
- Failure of Generators to File Exception Reports
- Failure of Owners/Operators of Intermediate Handling
and Destination Facilities to File Discrepancy Reports
&EPA EPA Implementation Efforts
Madlcal Watt*
Demonstration Program
Short-term Initiatives Will Include:
- Develop and Distribute Educational and Outreach Materials
- Participate in Workshops and Conferences
- Assist States' Implementation of the Regulations
- Assist in the Training of State Personnel
1 Long-term Initiatives Will Include:
- Develop Data Management System
- Develop Guidance for States Not Participating
- Prepare and Submit the Required Reports to Congress
- Evaluate the Success of the Demonstration Program
-23-
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dEPA EPA and ATSDR Health
Effects Assessment
EPA and ATSDR are Evaluating the Health Effects Posed By the
Mismanagement of Medical Waste
- Researching Past Incidents of Exposure
- Identifying Past and Potential Health and Environmental
Effects
- Reviewing Systematically the Available Literature
- Meeting With Experts to Identify and Evaluate the Risks
Epidemiological Evidence to Date Has Not Been Found to Indicate
Mismanaged Medical Waste Poses a Significant Human Health
Problem
-24-
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RESOURCE CONSERVATION AND RECOVERY ACT
- HAZARDOUS WASTE REGULATIONS -
Definition of Hazardous Waste
o A Solid Waste
o Not excluded from regulation
o And either:
A listed hazardous waste
A mixture containing a listed hazardous waste
An unlisted waste possessing any of the four
characteristics
Exclusions
These are NOT considered hazardous wastes:
o Household garbage
o Municipal resource recovery waste
o Agriculture residues
o Waste discharged to the sewer
CHARACTERISTICS
Ignitability
Corrosivity
Reactivity
EP Toxicity
A solid waste which exhibits any of these characteristics is
a hazardous waste whether or not listed
-25-
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LISTS OF HAZARDOUS WASTES
Nonspecific sources
o Solvents
o Electroplating wastes
o Metal-heat treating wastes
o Air emission scrubber sludges
Specific Sources
o Wood Preserving
o Inorganic Pigments
o Organic Chemicals
o Pesticides
o Explosives
o Iron and Steel
Commercial Chemical Products (when discarded or burned)
o product itself
o off-specification species
o spill residue and debris
ANTINEOPLASTICS
The following antineoplastics are listed as hazardous waste
and therefore regulated when discarded:
Chlorambucil
Mitomycin C
Streptozotocin
Uracil Mustard
Daunomycin
Melphalan
-26-
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GENERATOR STATUS AND REQUIREMENTS
Small Quantity Generators of Hazardous Waste
Generators of less than 100 kilograms (220 Ibs) of hazardous
waste per month are excluded from the hazardous waste
regulations:
o wastes must be disposed in a State licensed or
permitted facility
o consult State to determine whether lower limit exists
Acutely hazardous waste (i.e., certain commercial chemical
products) are subject to a lower one kilogram per month
exclusion
Generators of 100-1000 Kilograms per Month
Must comply with the regulations, but are exempt from
certain reporting requirements
Generators of 1QQO Kilograms OILJMore per Month
Must comply with the following requirements:
o Notify EPA and obtain a Federal ID number
o Prepare a manifest for off-site shipments of hazardous
waste
o Treat, store, and dispose of hazardous waste in a
Federally permitted facility
o Federal reporting and recordkeeping requirements
-27-
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DO NOT:
o burn hazardous waste in pathological or resource
recovery incinerators, or boilers unless you are a
small quantity generator (<100 kilograms per month)
o transport hazardous waste off-site without a manifest
o store hazardous waste on-site for 90 days without a
permit (180 days for generators of 100-1000 kilograms
per month)
o provide hazardous waste for shipment by a non-licensed
transporter
DO:
o call the RCRA/Superfund Hotline if you need information
1-800-424-9346 (toll free)
o call your State department of public health or
environmental protection for information on State
requirements
-28-
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NATIONAL INSTITUTES OF HEALTH (NIH)
NIH has developed standard operating procedures
for management and disposal of infectious waste.
Infectious waste is defined as wastes contaminated
with infectious agents.
The following wastes are managed as infectious waste:
o surgery and autopsy wastes (including
pathological and clinical specimens)
o contaminated research animals and bedding
o contaminated laboratory wastes
o contaminated and unused needles and syringes
o patient care wastes contaminated with
blood, secretions, excretions, or exudates
Infectious wastes are segregated from the
general waste stream and packaged according
to the following standards:
o dedicated boxes with a plastic
liner (at least 3 mil)
o wet materials are placed in two liners
o boxes are labelled "medical/pathological waste"
o box is printed with biohazard symbol
o waste must be identified as either
experimental animal waste, patient
care waste, or laboratory waste
Infectious waste is incinerated on-site.
Autoclaved (steam sterilized) medical waste
is discarded in the general waste stream.
-29-
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Antineoplastics are segregated from
the general waste stream and incinerated
on-site. Antineoplastics covered under
RCRA are managed as hazardous chemical waste
management.
-30-
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PROPOSED
OSHA REQUIREMENTS
for
HEALTH CARE FACILITIES
OVERVIEW OF OSHA
REQUIREMENTS
1) OSHA REQUIREMENTS ARE PRIMARILY
FOR PROTECTION OF HEALTH CARE
WORKERS WORKING WITH PATIENTS AND
PATIENT RELATED ITEMS.
2) FACILITY MAY BE CITED FOR NON-
PROTECTION OF OTHER EMPLOYERS'
EMPLOYEES TO THE EXTENT THAT THEY
CAN CONTROL THE HAZARD.
HEALTH CARE FACILITY
STANDARD INDUSTRIAL CLASSIFICATION
CODE (SIC) 80 (HEALTH SERVICES)
STANDARD INDUSTRIAL CLASSIFICATION
CODE 7261 (FUNERAL SERVICES and
CREMATORIES)
-31-
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OSHA REGULATIONS COVER ALL HEALTH
CARE WORKERS, for example:
- Physicians, nurses, dentists, dental
workers, and others whose work
involves direct contact with body
fluid.
OSHA REQUIREMENTS protect health
care workers from occupational exposure
to blood-borne diseases. It addresses:
- Personal protection
- Housekeeping
- Sanitation and waste disposal
- Speciications for accident prevention
- General duty clause for health
care facilities
PERSONAL PROTECTION
-32-
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PERSONAL PROTECTIVE
EQUIPMENT
Gloves
Gowns
Masks and Eye protectors
Protective Shields and
Barriers
The following procedures require use
of personal protective equipment
- Invasive procedures
_ Phlebotomy (blood drawing) gloves
- Postmortem procedures
HOUSEKEEPING
All places of employment,
passsageways, storerooms, and
service rooms shall be kept
clean and orderly and in sanitary
condition.
Keep the floor of every workroom
clean and dry.
Room cleaning where body fluids
are present.
-33-
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SANITATION
and
WASTE DISPOSAL
CONTAINER STANDARDS
- LEAK RESISTANT
- CLEANED and MAINTAINED in a
sanitary condition
- EQUIPPED with a SOLID. TIGHT-
FITTING cover
SHARP INSTRUMENTS and
DISPOSABLE ITEMS
Disposable sharps should be placed
in puncture resistant containers
Such a container should be accessible
to personnel where needles are used,
including patient rooms.
-34-
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Specifications for accident prevention
signs and tags:
- Biological hazard tags need to
identify the actual or potential
presence of a biological hazard
GENERAL DUTY CLAUSE
- Hepatitis B vaccination
- Linen
- Reusable equipment (Cleaning
standard sterilization disinfection)
- Handwashing
-35-
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NUCLEAR REGULATORY COMMISSION (NRC)
NRC regulations address disposal of
low level radioactive medical waste
Animal carcasses and liquid scintillation
fluids containing <0.50 microcuries/gram
of tritium or C14 may be discarded.
Animal carcasses and liquid scintillation
fluids containing >0.50 microcuries/gram
or other radiological components must be
disposed in accordance with NRC regulations
contained in 10CFR20.
Medical waste with a half-life <65 days
(except iridium ) may decay in storage.
The waste must be held for a minimum of
10 half lives. For example, waste with
a half-life of 6 days must be held for 60 days.
Waste must meet background levels at the
container surface before disposal. All
radiation warning labels must be removed
or obliterated before disposal.
Must keep the following records for three (3)
years:
o date of storage
o storage date
o background levels
o instruments used
o nuclides disposed
o date of disposal
o contact person
-36-
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CENTERS FOR DISEASE CONTROL (CDC)
CDC epidemiologically defines outbreaks
of disease in the health care environment
(and the community) and develops
strategies for prevention and control.
CDC is NOT a regulatory agency.
CDC INFECTIVE WASTE CATEGORIES
o Isolation Wastes
o Microbiological Cultures and Stocks
o Blood and Blood Products
o Pathological Wastes
o Sharps
CDC recommends the following waste disposal
procedures to reduce risks of AIDS and
Hepatitis B:
o Incineration or decontamination of
infective waste before disposal
in a sanitary landfill
o Disposal of sharps in puncture-proof
containers
o Blood-contaminated items should be
placed in leak-proof bags
o Blood and body fluids may be discharged
to the sewer
-37-
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Joint Commission
on
Accreditation of Healthcare Organizations
(JCAHO)
JCAHO establishes standards for:
o Safety
o Patient care
o Staffing
o Training programs
Health care organizations that meet the
standards receive a 3 year JCAHO accreditation
Requires a management process for handling hazardous and infectious
materials within the organization:
o Labeling of containers
o Space and equipment requirements
o Waste stream segregation
o Training
Labeling of Containers
o Types of containers
- new products
in use and transfer
accumulation
shipping
o Printed Information
product name
chemical name
manufacturer information
precautions
personal protective equipment
hazard class
regulatory labels
-38-
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Waste Stream Segregation
o Chemically incompatible materials
o Waste from food and food preparation areas
o Waste from patient care areas
Training
The following employees must receive training:
o Employees who use and/or are
exposed to hazardous and
infectious materials
o Employees who handle these wastes
o Emergency response teams
o Supervisory personnel
Training programs must address:
o Regulatory requirements
o New employee orientation
o Annual continuing education
Each employee should know their role in:
o Internal disaster plan
o Emergency response plan
o Contingency plans
-39-
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JCAHO requires Health care facilities to establish a
Safety Committee
Safety Committee Responsibilities:
o Analyze identified issues
o Develop recommendations for resolution
o Infection control
o Risk management
o Quality assurance
-40-
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MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Malnka, P.C.
WASTE MANAGEMENT & DISPOSAL
A. Overview & Perspectives
B. Waste Categories & Designations
C. Regulatory Framework & Recap
D. Infectious Waste
1. Types, characteristics, definitions & designations
2. Sources
3. Generation factors & quantities
E. Infectious Waste Treatment & Disposal Alternatives
1. On-slte treatment
a. Steam sterilization
b. Shreddlng/chlorlnation
c. Incineration
d. Other
e. Emerging technologies
2. Off-site treatment & disposal
a. Contract disposal
b. Shared Incinerator
c. Regional incineration
F. Other "Special" Wastes
1. Chemical (hazardous) waste
a. Sources and quantities
b. Treatment & disposal alternatives
c. Incineration
2. Antineoplastlc waste
a. Bulk & contaminated
b. Treatment & disposal alternatives
3. Low-level radioactive
a. Sources and quantities
b. Treatment & disposal alternatives
c. "Mixed waste"
G. Planning an Integrated Waste Management Program
1. Concerns & objectives
2. Step 1 -Surveys & data collection
a. Waste characterization & composition
b. Waste quantification
c. Regulatory data
d. Other data
e. Summary
-41-
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3. Step 2 -Technical & Economic Evaluations
a. Disposal options & variables
b. Incinerator options & add-ons
c. Siting
d. Other variables & Issues
e. Economics
4. Planning recommendations
H. Assessment of Waste Management Practices
1. Compliance & conformance
2. Economic Incentives
-42-
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Waste
Management
And
Disposal
-43-
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Medical Waste Disposal
IsA
National Dilemma
Waste Management Regulations
vs.
Incinerator Regulations
"Infectious" Waste Quantities Are
Increasing
while
Viable Disposal Options Are
Decreasing
-44-
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Hospital And Institutional Waste
General
"Special"
"Special" Waste
Infectious
Pathological
Chemical/Hazardous
Radioactive
Sharps
Other
-45-
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Medical Waste
Regulatory
Update
Hospital "Hazardous"
Waste Management
Overall Framework
Infectious Wastes
Chemical Waste
Cytotoxlc Waste
Radioactive Waste
JCAHO
States, "Guidelines" and
MWTA of 1988
(RCRA Sub-Title J)
USEPA and States
RCRA (40CFR260-265,
40CFR122-124)
USEPA, VA Directives and
"Guidelines"
NRC Stds for Protection
Against Radiation (10CFR20)
and NESHAPS (40CFR61)
-46-
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JCAHO Standards
A "System" Is Required to Safely
Manage Hazardous Materials And
Wastes From Points Of Entry
To Final Disposal
JCAHO Accreditation Manual
For Hospitals (AMH)
Standard IC.2 -Infection Control
e Standard PL1.10 -Hazardous Waste
Management
JCAHO Requirements for Hazardous/
Infectious Waste Management
e Policies/Procedures for
Identification/Management
e Establishment of Committees -
Annual Review
e Job Training
Compliance With Laws/Regulations
-47-
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Infectious Waste
Management And
Disposal
Blohazardous Waste
Biological Waste
Blomedlcal Waste
Contaminated Waste
Infectious Waste
Medical Waste
Pathogenic Waste
Pathological Waste
Red Bag Waste
Regulated Waste
RMW
Infectious Waste Requires
Of the Following
e Presence of Virulent Pathogen
e Sufficient Concentration of Pathogen
e Presence Of A Host
e Portal of Entry
e Host Susceptibility
-48-
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Infectious Waste Generation
Parameters
Regulatory "Definitions"
Interpretations Of Definitions
Internal Policies And Protocols
e Waste Management Effectiveness
CDC Infectious Waste Designation
e Microbiology Lab Waste
Pathological Waste
e Sharps
e Blood/Blood Products
Ret: 1985 Handwashing Guide/1987 Mortality Weekly
-49-
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EPA Infectious Waste
"Guide" Designations
Isolation Waste
Cultures and Stocks of Etlologlcal Agents
Human Blood and Blood Products
Pathological Waste
e Contaminated Sharps
Contaminated Animal Carcasses,
Parts and Bedding
Ref: 1989 EPA Guide for Infectious Waste Management
EPA Infectious Waste
"Optional" Categories
Surgery and Autopsy Wastes
Dialysis Unit Wastes
Contaminated Equipment
Miscellaneous Laboratory Wastes
Ret: 1989 EPA Guide tor Infectious Waste Management
-50-
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Hospital Departments Designated
Infectious Waste Sources
Autopsy Department
Emergency Department
Intensive Care Units
Isolation Rooms
Clinical Laboratories
Morgue
Ret: Proposed EPA Regulations in 1978 Fed Register
Hospital Department Sources (Cont'd)
e Obstetrics Department (Incl Patient Rooms)
Pathology Department
Pediatrics Department
Surgery Department (Incl Patient Rooms)
Ref: Proposed EPA Regulations in 1978 Fed Register
-51-
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Medical Waste Tracking Act (MWTA)
Regulated Medical Waste (RMW)
1. Cultures & Stocks
2. Pathological Wastes
3. Human Blood & Blood Products
4. Sharps
5. Contaminated Animal Wastes
MWTA Potentially Excluded Waste Types
6. Waste from Surgery or Autopsy
7. Other Laboratory Wastes
8. Dialysis Wastes
9. Discarded Medical Equipment & Parts
10. Isolation Wastes
("Other Medical Wastes may be added")
-52-
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"Universal Precautions"
or
"Universal Blood and
Body-Fluid Precautions"
OSHA HBV/HIV Standards
"Infectious" Waste
Generation
% Of Total
CDC Guidelines 3-5
EPA Guidelines (1986) 7-15
Proposed EPA Regs (1978) 20-35
All Patient "Contact" Waste 60-80
e Hauler/Disposal Facility 0-100
Restrictions
-53-
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INFECTIOUS WASTE ACCORDING TO THE CDC
"There is no epidemiologic evidence to suggest that most hospital waste is any
more infective than residential waste. Moreover, there is no epidemiologic
evidence that hospital waste has caused disease in the community as a result
of improper disposal. Therefore, identifying wastes for which special
precautions are indicated is largely a matter of judgment about the relative
risk of disease transmission. The most practical approach to the management
of infective waste is to identify those wastes with the potential for causing
infection during handling and disposal and for which some special precautions
appear prudent. Hospital wastes for which special precautions appear prudent
include microbiology laboratory waste, pathology waste, and blood specimens or
blood products. While any item that has contact with blood, exudates, or
secretions may be potentially infective, it is not usually considered
practical or necessary to treat all such waste as infective. Infective waste,
in general, should either be incinerated or should be autoclaved before
disposal in a sanitary landfill. Bulk blood, suctioned fluids, excretions,
and secretions may be carefully poured down a drain connected to a sanitary
sewer. Sanitary sewers may also be used to dispose of other infectious wastes
capable of being ground and flushed into the sewer."
Ref: CDC. "Guideline for HandwasMnq & Hospital Environmental Control". 1985," NTIS PB85-923404, 1985.
CDC, "Recomnendatlons for Prevention of HIV Transmission In Health-Care Settings." Morbidity and
Mortality Weekly Report. Vol. 36. August 21, 1987.
-54-
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EXECUTIVE SUMMARY
Unltnl SHIM
Olid el Solid Wnir
nd E"»ntncv Blltxjni
Wnhington DC 70400
M» 19BG
EPA Guide for
Infectious Waste
Management
(Jl
The purpose o£ this document la to provide guidance on
the management of infectious waste. The document presents
the EPA perspective on acceptable infectious waste management
practices. Discussions are limited to technologies that are.
typically and frequently used for treating and managing
infectious waste; however, the EPA in no way intends to
imply that alternative methods or new technologies are not
available or acceptable.
EPA Recommendations for Infectious Waste Management
The EPA recommends that a responsible person or committee
at the facility prepare an Infectious Waste Management Plan
outlining policies and procedures for the management of
infectious waste. This plan should Include the following
elements:
Designation
Segregation
Packaging
Storage
Transport
Treatment
Disposal
Contingency Planning
Staff training
Ref: U.S.EPA, Guide for Infectious Waste Management. NTIS PB86-19913, May 1986.
-------
1. Designation of Infectlom Waste
EPA recommends that the following categories of waste be
designated as Infectious wastei
Waste Category
Isolation wastes
Cultures and stocks of
infectious agent* and
associated blologlcals
t/l
disposable
glove*, lab coats, and aprons
tubing, filters, disposable
sheet*, towels, gloves,
aprons, and lab coats
equipment used In patient
care, medical laboratories,
research, and In the product to
and testing of certain
Pharmaceuticals
'These material* are examples of waste* covered by each category.
The categories are not limited to these materials.
Ref: U.S.EPA, Guide for Infectious Waste Management. NTIS PB86-19913, May 1986.
-------
11. Segregation of Infectious Wast*
EPA recommendsi
segregation of Infectious wast* et the point of origin
segregation of infectious wast* with Multiple hazards
as necessary for management end treatment
use of distinctive, clearly narked containers or plastic bags
for infectious waste
use of the universal biological hazard symbol on infectious
waste containers, as appropriate
III. Packaging of Infectious Waste
EPA recommendsi
selection of packaging materials that are appropriate for
the type of wastei
- plastic bags for many types of solid or semi-solid
Infectious waste
- puncture-resistant containers for sharps
- bottles, flasks, or tanks Cor liquids
use of packaging that maintains its integrity during storage
and transport
* use of plastic bags that are impervious, tear resistant, and
"distinctive in color or markings
closing the top of each bag by folding or tying as appropriate
for the treatment or transport
placement of liquid wastes In capped or tightly stoppered
bottles or flasks
no compaction of Infectious waste or packaqeil Infectious *«,
before treatment
IV. Storage of Infectious Haste
EPA recommendsi
* minimizing storage time
* proper packaging that ensures containment of Infectious
waste and- the exclusion of rodents and vermin
limited access to storage area
posting of universal biological hazard symbol on storage are*
door, waste containers, freezers, or refrigerators
V. Transport of Infectious Haste;
EPA recommends!
avoidance of mechaalcal loading devices which may rupture
packaged wastes
frequent disinfection of carts used to transfer wastes within
the facility
placement of all infectious wast* into rigid or semi-rigid
containers before transport off-site
transport of infectious wast* In closed leak-proof trucks or
dumpsters
Ml U.S.EPA, Cutd* for Infectious w.sf
MTIS PBa6-l9913. May 1986.
-------
VI. Treatment of Infectious Haste
For the purposes of this document. EPA defines treatment
as any method, technique or process designed to change the
biological character or composition of, waste.
EPA recommends«
establishing standard operating procedures for each procoss
used for treating Infectious waste
monitoring of all treatment processes to assure efficient A
effective treatment
use of biological indicators to monitor treatment (other
Indicators may be used provided that their effectiveness
has been successfully demonstrated)
the following treatment techniques for each of the six
Infectious waste categories (table 1):
I
ui
oo
Treatment of Infectious Waste (cont'd)
EPA recommends:
the following treatment methods tor miscellaneous
contaminated wastes (when a decision Is made to manage
these wastes as infectious):
- wastes from surgery and autopsy - incineration or steam
sterilization
- miscellaneous laboratory wastes - Incineration or
steam sterilization
- dialysis unit wastes - incineration or steam sterilization
- contaminated equipment - incineration, steam sterilization,
or gas/vapor sterilization
VII. Disposal 6f Treated Infectious Waste
EPA recommends:
contacting State and local governments to Identify approved
disposal options (institutional programs must, conform to State
and local requirements)
discharge of treated liquids and ground up solids (such as
pathological waste or small animals) to the sewer system
land disposal of treated solids and incinerator ash
rendering body-parts unrecognizable before land disposal (for
aesthetic reasons)
Ref: U.S.EPA, Guide for Infectious Waste Management. NTIS PB86-19913, May 1986.
-------
RDCOMENDED TBCHNIQUnS FOR TREATMRTT OF INFECTIOUS WASTEa
Type of Infectious Waste15
Isolation wastes
Cultures and stocks of
infectious agents and
associated biologicals
Human blood and blood
products
Pathological wastes
Contaminated sharps
Contaminated animal carcasses,
body parts, bedding:
* carcasses and parts
* bedding
Rcccmrended Treatment Techniques
Steam Thenwl Chemical
Sterilization Incineration Irv\ctlv*tion Disinfection0 Other
X
X
X
**
X
Xe
X
X
X
X
X
X
X
X
X
X
Xd
xf
a. The reccrnrended treatment techniques are those that are most appropriate and, generally, in cannon use;
alternative treatment technique nwy be used to treat infectious waste, if it provides
effective treatment.
b. See Chapter 2 for descriptions of infectious waste types.
c. Chemical disinfection is most appropriate for liquids.
d. Discharge to sanitary sewer for treatment in municipal sewerage system (provided that secondary treatment
is available)
e. For aesthetic reasons, steam sterilization should be followed by incineration of the treated waste or by grinding
with subsequent flushing to the sewer system in accordance with State and local regulations.
f. Handling by a mortician (burial or cremation).
Ref: U.S.EPA, Cutcte for tnf«ctlou« Waste Management. HTIS PB86-19913, Hay 1986.
-------
Infectious Waste
Treatment Alternatives
Steam Sterilization
Shredding/Chemical Disinfection
Incineration
Other (Small Scale) Systems
Dry Heat Sterilization
Gas/Vapor Sterilization
Irradiation
Emerging/Developing Technologies
Steam Sterilization System
Waste Transport/Treatment Containers
Autoclavable Bags
Autoclave Chamber
Ventilation
Container Dumper
Biological/Temperature Indicators
Steam Sterilization
Technologies
Gravity Systems
Pre-Vacuum Systems
Retort Systems
Combination Autoclaves/Trash Compactors
-60-
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Steam Sterilization Performance
Based upon Direct Steam Contact
Permeation of Entire Mass with Heat
and Moisture
Factors:
Air Evacuation
Physical Barriers
Density of Materials
Autoclaving Is NOT
Recommended For:
Sealed Containers
Bulk Fluids
Pathological Waste
e Hazardous Chemicals
Chemonuclear Waste
Antlneoplastlc Waste
-61-
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Saturated
Steam
Inlet
Pressure
Vess e I
Trap Pa sses
Ai r-Steam
Mixtures
And Re ta i n s
Pu re Steam
Air
GRAVITY STEAM STERILIZATION SYSTEM
Ref: Block. S. S.. Disinfection. St.riliiatlon and Pr««erv«ttpn. Lea and Febiger. Philadelphia. 1977.
-62-
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Autoclaving System
Advantages
LAW Costs
Low Space Requirements
Ease of Implementation
Simplicity
Autoclaving System
Disadvantages
Limited Capacity
Not Suitable For All Wastes
Waste Handling System/Bags
Odor Control
Volume Unchanged
Appearance/Form Unchanged
-63-
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Shredding/Chlorination Systems
Small-Scale Sharps/
Lab Waste Processing Systems
Large-Scale Total Infectious
Waste Processing System
Shredding/Chlorination
Disinfection System
e Waste Feed Conveyor
Pre-Shredder
Hammermlll
Debris Conveyor/Separator
HEPA Filtration System
Sodium Hypochlorlte System
-64-
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CHLORINE SOLUTION
WASTE-
CONVEYOR
PRE-SHREDOER
HAMMERMLL
CHLORINE
GENERATOR
COLLECTKN
CART
CHLORINE
STORAGE TANK
£FFl_UENT
TOSEV^R
WASTE
SHREDDING/CHLORINATION DISINFECTION SYSTEM
Ref: Medical SafeTec, Inc.
-------
Shredding/Chlorination System
Advantages
Substantial Volume Reduction
Suitable For Many Wastes
Relative Simplicity
Alters Waste Form And Appearance
Shredding/Chlorination
System Disadvantages
Relatively High Costs
Waste Handling
Limited Capacity
Liquid Effluent Contaminants
Room Noise and Chlorine Levels
Limited Experience
Single Manufacturer
-66-
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Incineration Systems
Waste Handling and Loading
Incinerator
Burners and Blowers
Ash Removal and Handling
Breeching, Blowers and Dampers
Stacks(s)
Air Pollution Control
Waste Heat Recovery
Controls and Instrumentation
Incineration System
Advantages
Disposal Of Most Waste Items And Forms
Suitable For Large Volumes
Largest Weight And Volume Reductions
Sterilization And Detoxification
Heat Recovery
Unrecognizable Residues
Favorable Life-Cycle Costing
Incineration System
Disadvantages
High Capital Costs
High M&R Costs And Requirements
Stack Emissions And Concerns
Siting Difficulties
Permitting Difficulties
Public Opposition
-67-
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To
Atmosphere
To
Atmosphere
t
i
Stack!
i Air i
! Pollution '
'1 Control I"
i System i
Ash
MAJOR COMPONENTS OF AN INCINERATION SYSTEM
Ref: Hospital Incineration Operator Training Course Manual.
EPA-450/3-89-004, March 1909.
-68-
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Other (Small Scale) Systems
Dry Heat Sterilization
Gas/Vapor Sterilization
Radiation
"Emerging" Technologies?
Glass Slagging
High-Temperature Plasmas
Shredding/Radiation
Shredding/Chemical Injection
Wet Oxidation
etc.
-69-
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Off-Site Disposal Options
Contract Haulage And Disposal
Another Hospital's Incinerator
Regional or Shared-Service Incinerator
Private Development Facility
Cooperative Development Facility
Off-Site Disposal Advantages
Negligible Capital Investment
Relative Simplicity of Implementation
Avoid On-Slte Disposal Permitting
Off-Site Disposal Disadvantages
Location Reliable And Reputable Firm
Potential Liabilities And Concerns
High Costs
Manifesting And Tracking
-70-
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Regional or Shared-Service
Facility Pros And Cons
Advantages
Favorable Economics
Single Permit
Centralized Operations
Disadvantages
Siting and Permitting Difficulties
Waste Transport Requirements
"Hazardous" Designation
(Compared To Individual)
Off-Site Disposal
Contractor Considerations
Capabilities & Capacities
Experience & Track Record
Permits & Certifications
Insurance & Indemnification
Infectious Waste
Disposal Costs
On-Slte Incineration: $0.05 -$0.20/lb
Off-Site Disposal: $0.30 -$2.00/lb
-71-
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Institutional Chemical
Waste Sources
Clinical & Research Laboratories
Patient-Care Activities
Pharmacy (Spills & Out-dated Items)
Physicians' Offices (Out-dated Items)
Physical Plant Department
Buildings & Grounds Department
Hazardous Waste Management
Options
Recycling/Recovery
Chemical Treatment
Physical Treatment
Thermal Treatment
Disposal
Chemical Waste Minimization
Process Modification
Eliminate Use
Substitution
Volume Reduction
Reclaim/Recycle
Recovery
Distillation
Waste Exchange
-T2-
-------
Hazardous (Chemical) Waste
Listed
Characteristics
Ignltabie
Corrosive
Reactive
Toxic
(Extraction Procedure)
Chemotherapy Waste
Disposal Criteria
Regulated (Bulk)
7 cytotoxlc drugs listed as
acutely toxic (40CFR261.33f)
Contalners/vlals with 3%
capacity or greater
Unregulated
Contalners/vlals with less
than 3% capacity
Trace-contaminated
-73-
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Sources of Radioactive
Hospital Waste
Research Laboratory Activities
Clinical Laboratory Procedures
Nuclear Medicine
Diagnostic Applications
Radiotherapy
Forms of Radioactive
Institutional Waste
Solid Waste
Animal Carcasses
Clinical Items
Contaminated "Dry" Materials
Uquld Waste
Scintillation Fluids (LSC)
Biological & Chemical Research Chemicals
Decontamination of Radioactive Spills
Radioactive Waste Disposal
Concentration and Confinement
Decay-in-Storage
Dilution and Dispersion
Discharge to Sewer
Volume Reduction and Dispersion
Incineration
Off-Site Disposal
-74-
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Planning an
Integrated Waste
Management Program
Waste Disposal
Planning Concerns
Risks And Concerns - Safety And Health
Regulations And Accreditation
Off-Site Liabilities And Exposure
Costs
Waste Disposal
Program Objectives
Compliance With Regulations And Standards
Manageable And Enforceable
Flexibility
Safety And Security
Environmental Integrity
Cost Effectiveness
-75-
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Waste Disposal Evaluations
Task 1: Data Collection
1. Waste Characterization
2, Waste Quantification
3. Waste Management Practices
4. Slte(s)
5. Utilities
6. Costs
7. Regulatory And Permitting Requirements
8. Summary And Review
Institutional Waste Forms
Qlasses Examples
Dry And Solid - Paper, Plastic, Cloth
- Cage Waste
Pathological - Carcasses/Tissues
- Body Parts/Cadavers
Liquid - Solvents/Chemicals
- Blood/Body Fluids
Waste Characterization
General Parameters
Composition/Constituents
Forms
Categories
Physical Parameters
Chemical Parameters
Heating Values
-76-
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Waste Characterization
Composition/Components
Heating Value
Moisture
Ash
Plastics - PVC
Physical Form
Proximate Analysis
Weight Percentages Of
Moisture
Volatlles
Fixed Carbon
Non-Combustibles
Ultimate Analysis
Weight Percentages Of Elemental Constituents
Carbon
Hydrogen
Oxygen
Nitrogen
Chlorine
Sulfur
Metals
etc.
-77-
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WASTE DATA CHART
Material
Type 0 Waste
Type 1 Waste
Type 2 Waste
Type 3 Waste
Type 4 Waste
Acetic Acid
Animal fats
Benzene
Brown paper
Butyl sole composition
Carbon
Citrus rinds
Coated milk cartons
Coffee grounds
Corn cobs
Corrugated paper
Cotton seed hulls
Ethyl Alcohol
Hydrogen
Kerosene
Latex
Linoleum scrap
Magazines
Methyl alcohol
Naphtha
Newspaper
Plastic coated paper
Polyethylene
Polyurethane (foamed)
Rags (linen or cotton)
Rags (silk or wool)
Rubber waste
Shoe Leather
Tar or asphalt
Tar paper Vs tar-Vj paper
Toluene
Turpentine
l/3 wax-J/i paper
Wax paraffin
Wood bark-
Wood bark (fir)
Wood sawdust
Wood sawdust (pine)
B.T.U.
value/lb. as
fired
8,500
6,500
4,300
2,500
.1,000
6,280
17,000
18,210
7,250
10,900
14,093
1,700
11,330
10,000
8,000
7,040
8,600
13,325
61,000
18,900
10,000
11,000
5,250
10,250
15.000
7,975
7,340
20,000
13.000
7,200
8,400-8,900
9,000-11,000
7,240
17,000
11,000
18.440
17,000
11,500
18,621
8,000-9.000
9,500
7,800-8.500
9.600
YVt. in Ibs.
per cu. ft.
(loose)
8-10
8-10
15-20
30-35
45-55
50-60
7
25
40
5
25-30
10-15
7
25-30
45
70-100
35-50
7
7
40-60
2
10-15
10-15
62-125
20
60
10-20
7-10
12-20
12-20
10-12
10-12
We. in Ibs.
per cu. ft.
65.8
55
138
49.3
0.0053
50
45
49.6
41.6
60
2
52
53.6
54-57
Content by weight
In percentage
ASH
5
10
7
5
5
0.5
0
0.5
1
30
0
0.75
1
2
3
5
2
0
0
0.5
MOISTURE
10
25
50
70
85
0
0
0
6
1
0
75
3.5
20
5
5
10
0
0
0
0 0
20-30 1
22.5 i 5
0 i 0
0 ! 0
1.5
2.6
0
S
2
20-30
21
1
2
0.5
0
3
0
3
3
3
3
6
0
0
5
5
0
7.5
0
1
0
0
1
0
10
10
10
10
The above chart shows the various B.T.U. values of materials commonly encountered in incinerator designs. The values
given arc approximate and may vary based on their exact characteristics or moisture content.
Ref: Incinerator Institute of America, Incinerator Standards. 1968.
-78-
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MA WASTE CLASSIFICATIONS
I
-J
Clmlf tot Ion of Wastes
Typ« Description
0 Trash
1 Rubbish
2 Refust
3 Garbage
4 Animal
solldt and
organic
wittat
Principal Components
Highly combustible
waste, paper, wood,
cardboard cartons,
including up to 10%
treated papers, plastic
or rubber scraps;
commercial and
Industrial sources
Combustible waste,
paper, cartons, rags.
wood scraps, combus-
tible door sweepings;
domestic, commercial
and industrial sources
Rubbish and garbage;
residential sources
Animal and vegetable
wastes, restaurants.
hotels, markets;
Institutional,
commercial and club
sources
Carcasses, organs,
solid organic wastes;
hospital, laboratory,
abattoirs, animal
pounds and similar
sources
Approximate
Composition
% by Weight
Trash 100%
Rubbish 80%
Garbage 20%
Rubbish 50%
Garbage 50%
Garbage 65%
Rubbish 35%
100% Animal
and Human
Tissue
Moisture
Content
%
10%
25%
50%
70%
85%
Incombustible
Solids %
5%
10%
7%
5%
5%
B.T.U.
Vatue/lb.
of Refute at
Fired
8500
6500
4300
2500
1000
Reft Incinerator Institute of America, Incinerator Standards. 1968.
-------
IIA WASTE GENERATION FACTORS
CLASSIFICATION
INDUSTRIAL
BUILDINGS
COMMERCIAL
BUILDINGS
RESIDENTIAL
SCHOOLS
INSTITUTIONS
HOTELS, ETC
MISCELLANEOUS
BUILDING TYPES
Factories
Warehouses
Office Buildings
Department Stores
Shopping Centers
Supermarkets
Restaurants
Drug Stores
Banks
Private Homes
Apartment Buildings
Grade Schools
High Schools
Universities
Hospitals
Nurses or Interns Homes
Homes for Aged
Rest Homes
Hotels 1st Class
Hotels Medium Class
Motels
Trailer Camps
Veterinary Hospitals
Industrial Plants
Municipalities
QUANTITIES OF WASTE PRODUCED
Survey must be made
2 Ibs. per 100 sq. ft per day
I Ib. per 100 sq. ft. per day
4 Ibs. per 100 sq. ft per day
Study of plans or survey required
9 Ibs. per 100 sq. ft per day
2 Ibs. per meal per day
5 Ibs. per 100 sq. ft per day
Study of plans or survey required
5 Ibs. basic & 1 Ib. per bedroom
4 Ibs. per sleeping room per day
10 Ibs. per room & % Ib. per pupil per day
8 Ibs. per room & h Ib. per pupil per day
Survey required
15 Ibs. per bed per day
3 Ibs. per person per day
3 Ibs. per person per day
3 Ibs. per person per day
3 Ibs. per room and 2 Ibs. per meal per day
\Vi Ibs. per room & 1 Ib. per meal per day
2 Ibs. per room per day
6 to 10 Ibs. per trailer per day
Study of plans or survey required
Ref: Incinerator Institute of Awerfca. Incinerator Standards. 1968.
-80-
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Waste Quantification
Data Methods
Empirical Factors And Approximations
Off-Site Haulage/Disposal Records
Billing Records
Volumes And Frequencies
Truck Scales
Surveys And Weighing Programs
Waste Survey Variables
Disposal Area(s) vs.
Weighing vs.
Cart/Bulk Volumes vs.
Random vs.
Specific Identification vs.
One Day vs.
Specific Sources
Estimating
Ind. Containers
(Bags)
Continuous
Approximations
Week(s)
-81-
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Waste Disposal Evaluations
Task 2: Technical And Economic Evaluations
1. Matrix Of Alternatives
2. Technical Evaluations
3. Schematics
4. Economic Analysis
5. Selection
Typical Disposal
Option Variables
Degree Of On-Site Treatment
None
Selected
Maximum
Alternate Technologies/Combinations
Treatment Technology Options/Add-Ons
Redundancy And Back-Up
Siting
Typical Incineration
System Options
Operating Period
Retention Time
Ash Removal
Waste Heat Recovery
Monitoring And Recording
Degree Of Automation
Redundancy
-82-
-------
Waste Burning Options
Flammable Solvents
Cytotoxlcs (Antl neoplasties)
Bulk
Trace Contaminants
Low-Level Radioactive
Site Selection
Space And Accessibility
Waste And Residue Handling
Flue Gas Handling
Visibility And Aesthetics
Acceptability
Operations
Cost Estimating
Capital
Annual Operating and Maintenance
Life-Cycle
-83-
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Waste Disposal
Planning Recommendations
Consider The Total Economic Picture
Consider Contingencies and Outages
Consider Future Scenarios and Changes
Consider Non-Economic Issues
Assessments of Waste
Management Practices
and
Protocols
Help Wanted
Waste Watcher:
Full-Time Position,
No Experience Necessary,
On-The-Job Training
-84-
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A Case For Segregation
600-Bed Hospital
12,000 Ib/d Total Waste
Under Present "Policies"
60% Infectious (7,200 Ib/d)
Infectious Waste Disposed
Off-Site At $0.30/lb
Segregation Case Study
Continued
Present Disposal Costs $674,000/yr
(@ 60% Infectious)
Potential Disposal Costs $337,000/yr
(@ 30% Infectious)
Potential Savings $337,000/yr
Costs For 5 "Waste Watchers" $120,000/yr
Net Annual Savings $217,000/yr
-85-
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THIS PAGE INTENTIONALLY
BLANK
-------
MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Malnka, P.C.
II. INCINERATION FUNDAMENTALS
A. Overview & Perspectives
B. Combustion Fundamentals
1. Combustion reactions
2. Combustion processes & controls
a. Perfect, theoretical or stolchiometric
b. Starved-alr, sub-stoichlometrlc or incomplete
c. Complete combustion
d. Excess air
e. Two-stage combustion
f. PIC's
C. 3 Ts of Combustion
1. Time
a. Solids
b. Gases
2. Temperature
a. Primary
b. Secondary
c. Control
3. Turbulence
a. Mechanical
b. Aerodynamic
D. Incinerator Sizing & Rating
1. Primary chamber criteria
a. Heat release
b. Burning rate
c. Waste type, form & size
2. Secondary chamber criteria
3. Chamber shapes of configurations
E. Incineration Capacity Determination
1. Capacity selection criteria & factors
2. Operating cycles/modes
3. Burn rate vs. charge rate
F. Calculations
1. Equipment sizing
2. Mass balances
3. Heat balances
4. Flue gas handling systems
5. Other
-87-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
Incineration
Fundamentals
What Is Incineration?
"Burn To Ashes"
Combustion Process
-89-
-------
Incineration
Thermal Oxidation
Thermal Destruction
High Temperature Destruction
Resource Recovery
Incineration
Combustion Process
Controlled
Engineered
Hjgh Technology
Proven
Modern Incineration
Only About 30 Years Old
-90-
-------
Combustion Process
Waste Chemistry
Carbon (C)
Hydrogen (H)
Oxygen(0)
Moisture
Inorganics
Nitrogen (N)
Sulfur (S)
Chlorine (Cl)
Etc.
Hydrocarbons
Combustibles
Carbon and Hydrogen
Fuel
-91-
-------
Actual Combustion
Hydrocarbons L Carbon Dioxide
Plus J Water Vapor
Oxygen j Heat
Perfect, Theoretical Or
Stoichiometric Combustion
Carbon + Oxygen ^ Carbon Dioxide
Hydrogen + Oxygen + Water
Perfect Combustion
C * 02 _»> C02
H2 * 0.5 O2 +> H2O
-92-
-------
Combustion Reactions
C * O2 -* CO2
H2 * 0.5 O2 *> H2O
O & N + Unchanged
Moisture ^ Unchanged
Inorganics -^ Ash
Starved-Air, Sub-Stoichiometric or
Incomplete Combustion
Carbon Dioxide
Hydrocarbons k Water Vapor
plus ^ Carbon Monoxide
O2 Deficiency f PICs
Less Heat
Sub-Stoichiometric Air
Less Than Theoretical Air
Smoke, Volatlles, And Hydrocarbons
Formed
Reduced Temperatures
Carbon to CO2 Releases 14,400 Btu/lb
Carbon to CO Releases 4,300 Btu/lb
-93-
-------
TEMPERATURE
MAXIMUM
TEMPERATURE
DEFICIENT AIR
EXCESS AIR
PERCENT EXCESS AIR
CONTROL OF TEMPERATURE AS A FUNCTION OF EXCESS AIR
Ref: McRee, R.f "Operation and Maintenance of Controlled Air Incinerators." Joy Energy Systems, Inc.
(formerly Ecolaire Environmental Control Products) Undated.
-94-
-------
TWO-STAGE INCINERATION
4000
u.
LU
DC
13
f-
<
cc
LU
OL
S
LLI
3000
2000
1000
EXCESS AIR percent
0 100 200
-../.
STARVED AIR RANGE
PRIMARY COMBUSTION CHAMBER
SECONDARY COMBUSTON CHAMBER
EXCESS AIR RANGE
PRIMARY AND SECONDARY
COMBUSTION CHAMBERS
300
2000
1500
1000
o
o
111
CC
ID
CC
tu
Q.
5
LU
500
100
200
300
400
STOICHIOMETRIC AIR percent
Ref: Joy Energy System, Inc. (Formerly Ecolaire Combustion Products, Inc.)
-95-
-------
Perfect Combustion
Complete Combustion
Goal is Complete Combustion
Excess Air Required
Good Controls Required
PICs Are Inevitable
Excess Air
Needed For Complete Combustion
Typically 100-300% (Solids)
Too Much » Inefficiencies
Too Little » Poor Combustion
-96-
-------
Too Much Excess Air
Lower Temperatures
More Auxiliary Fuel
More Entralnment
Larger Flue Gas Volumes
More Horsepower
Less Efficiency
Too Little Excess Air
Poor Combustion
Increased Emissions
Actual Combustion
CO2 + H2O
+ Excess Air
* PICs
+ Inorganics
-97-
-------
PICs
Products
of
Incomplete
Combustion
PICs
Unburned HCs
Reformed Molecules
Trace Concentrations
t Ubiquitous To Combustion
Combustion
Perfect, Theoretical or Stoichiometric
Starved Air, Partial Pyrolysis
or Sub-Stolchiometric
Excess Air
Two-Stage
Complete
-98-
-------
Basic Combustion Principles
Temperature
Time
Turbulence
3 Ts Of Combustion
Time
Temperature
Turbulence
Time
Retention or Residence Time
Solids
Ash Burnout
Hours
Function of design of operations
Gases
Complete combustion
Seconds
Function of volume
-99-
-------
Temperature
Primary Chamber
Secondary Chamber
Function of Heat Balance
Easiest of 3 Ts to Control
Temperature Control
Combustion Air Modulation
Auxiliary Fuel
Waste Feed
Water Injection
Turbulence
Mixing of Combustion Reactants
Increased Combustion Efficiencies
Mechanical-Solids
Aerodynamic - Gases
-100-
-------
Mechanical Turbulence
Hand Pokers
Grates
Rams
Rotary Kiln
Pulse Hearths
Aerodynamic Turbulence
High Velocity Air Injection
Baffles and Restrictions
Directional Changes
Cyclonic Flow
Suspension Firing
Turbulence Factor:
Demonstrated Methodology
And
Proven Principles
-101-
-------
Incinerator Design Principles
3TS
Heat Release Rate
Burning Rate
e Waste Type, Form and Size
Primary Chamber Sizing
e Heat Release Rate (Btu/cu ft/hr)
e Burning Rate (Btu or Ib/sq ft/hr)
Heat Release Rate:
(Btu/lb of Waste) x (Ib/hr of Waste)
(cu ft of Primary Chamber Volume)
Burning Rate:
flb/hr of Waste)
(sq ft of Primary Chamber Floor)
-102-
-------
INCINERATION CAPACITIES
AS A FUNCTION OF WASTE TYPES
(AUXILIARY HEAT
CONTROLS-*
CAPACITY
CONTROLS
CAPACITY
2000
TYPE4 TYPE 3
4000<
TYPE2
6000 I
TYPE1
12000
HEAT CONTENT
BTU/POUND
MAXIMUM BURNING RATES
FOR SPECIFIC TYPES OF WASTE IN POUNDS PER HOUR
(MClMCIUTOft'
UOOCU
TTPgO
TTHIt
TTT93
X40
47»
147*
t«00
Gvwrle Hed»l» (net r*lat«d t» mtf tpaelffe vwdor)
-103-
-------
MAXIMUM BURNING RATE LBS/SQ FT7HR
OF VARIOUS TYPE WASTE
CAPACITY
Lbs./Hr.
100
200
300
400
500
600
; 700
800
900
1000
LOGARITHM
2.00
2.30
2.48
2.60
2.70
2.78
2.85
2.90
2.95
3.0d
, #1 WASTE
FACTOR 13
26
30
32
34
35
36
37
38
38
39
#2 WASTE
FACTOR 10
20
23
25
26
27
28
28
29
30
30
#3 WASTE
FACTOR 8
16
18
20
21
22
22
23
23
24
24
£4 WASTE
NO FACTOR
10
12*
14*
15*
16*
17*
18*
18*
18*
18*
Ref:
The maximum burning rate in Ibs./sq. ft./hr. for Type 4 Waste depends to a
great extent on the size of the largest animal to be incinerated. Therefore when-
ever the largcs. animal to be incinerated exceeds 1/3 the hourly capacity of the
incinerator, use a rating of 10£ sq. ft/hr. for the design of the incinerator.
Above Figures calculated as follows:
MAXIMUM BURNING RATE LBS. PER SQ. FT. PER HR. FOR
TYPES #1. £2 fc £3 WASTES USING FACTORS AS NOTED
IN THE FORMULA.
BR=FACTOR FOR TYPE WASTE x LOG OF CAPACITY/HR.
#1 WASTE FACTOR 13
#2 WASTE FACTOR 10
#3 WASTE FACTOR 8
BR=MAX. BURNING RATE LBS./SQ. FT./HR.
I.E.-ASSUME INCINERATOR CAPACITY OF
100 LBS./HR, FOR TYPE #1 WASTE
BR=13 (FACTOR FOR £1 WASTE) X LOG 100 (CAPACITY/HR.)
13 X 2 = 26 LBS./SQ. FT./HR.
Incinerator Institute of America Incinerator Standards. 1968
-104-
-------
Secondary Chamber
Design Criteria
Retention Time
Temperature
Turbulence
Secondary Chamber Sizing
Retention Time (cu ft/sec)
Turbulence
Regulatory Requirements/Formulas
Retention Time:
(cu ft Secondary Chamber Volume)
(Actual cu ft/sec Flue Gas Flow)
-105-
-------
TYPICAL CONTROLLED AIR INCINERATOR PROFILES
Ref: Doucet, L. G., State-of-the-Art Hospital & Institutional Waste Incineration: Selection. Procurement
and Operations. 1980
-106-
-------
Incineration
Capacity
Selection
Incineration Capacity
Determination
Selected Operating Hours
Waste Generation Rates
Waste Types
Waste Forms
Waste Load Sizes
Incinerator Operating Modes
Single Batch
Intermittent Duty
Continuous Duty
-107-
-------
Intermittent Duty Operating Cycle
with Manual Ash Removal
Clean-Out
Preheat
Loading
Burndown
Cool Down
15-30 minutes
15-60 minutes
12-14 hours
2-4 hours
5-8 hours
Incineration System Calculations
Sjzlng
Heat Release
Retention Time
Combustion
Mass Flows
Combustion Air
Flue Gas Volumes
Heat Balance
Operating Temperatures
Auxiliary Fuel & Excess Air
Flue Gas System Sizing
Velocities
Pressure Losses
Draft
-108-
-------
TYPICAL INTERMITTENT DUTY OPERATING CYCLE
WITH MANUAL ASH REMOVAL
COOL-DOWN
CLEAN-OUT
PREHEAT
START CHARGING
BURN-DOWN
WASTE
CHARGING
LAST CHARGE
Ref: Ooucet, L. C., State-of-the-Art Hospital & Institutional Waste Incineration: Selection. Procurement
and Operations. 1980
-109-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Malnka, P.C.
III. ALTERNATE INCINERATION TECHNOLOGIES
A. Multiple Chamber Incinerators
1. Principles & background
2. Types
a. Retort
b. In-line
3. Design and operating criteria
4. Applications
B. Rotary Kiln Incinerators
1. Principles & background
2. Design and operating criteria
3. Applications
C. Controlled Air Incinerators
1. Principles & background
2. Design & operating criteria
3. Variations and developments
4. Applications
D. Other
1. Alternate & emerging technologies
2. "Innovative" technologies
-111-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
Alternative
Incineration
Technologies
Basic Institutional
Incinerator Technologies
Multiple-Chamber (IIA)
Retort
- In-Llne
Rotary Kiln
Controlled Air
"Innovative" Systems
-113-
-------
Multiple-Chamber Incinerators
Incinerator Institute of America (HA)
Developed In mid-1950s
Very High Excess-Air Levels
Retort and In-line Designs
Multiple-Chamber Incinerators
Retort
In-Line
-114-
-------
PRIMARY COMBUSTION CHAMBER
CHARGING DOOR
FLAMEPORT
SOLID
REFRACTORY
HEARTH
UNOERHEARTH CHAMBER
SECONDARY COMBUSTION
CHAMBER
UNDERHEARTH PORT OUT
SECONDARY MIXING
CHAMBER
UNDERHEARTH PORT IN
RETORT TYPE MULTIPLE CHAMBER INCINERATION
-115-
-------
IN-LINE MULTIPLE CHAMBER INCINERATION SYSTEM
DY-PASS DAMPER-
Today's Automatic Incineration System.
CHARGING DOOR
BAROMETRIC DAMPER
OVER FIRE AIR
BLOWER
TEI^ERATUR
COW IOLLER \i
AIR NOZZLES
PRIMARY
X SECONDAR
CAST IRON GRATES
\
COMBUSTION
CHAMBER
DOWN PASS
-------
INCINERATOR INSTITUTE
OF AMERICA (IIA)
INCINERATOR CLASSIFICATIONS
CLASS I
Portable, packaged, completely assembled, di-
rect fed incinerators, having not over 5 cu. ft.
storage capacity, or 25 Ibs. per hour burning
rate, suitable for Type 1 or Type 2 Waste.
CLASS IA
Portable, packaged or job assembled, direct fed
incinerators, 5 cu. ft. to 15 cu. ft. primary cham-
ber volume, or 25 Ibs. per hour up to but not
including 100 Ibs. per hour burning rate, suit-
able for Type 1 or Type 2 Waste.
CLASS II
Flue fed incinerators, with more than 2 sq. ft.
burning area, suitable for Type 1 or Type 2
Waste. (Not recommended for industrial wastes.)
This type of incinerator served by one flue to
function both as a chute for charging waste and
to cany the products of combustion.
CLASS HA
Flue fed incinerators, with more than 2 sq. ft.
burning area, suitable for Type 1 or Type 2
Waste. (Not recommended for industrial wastes'.)'
This type of incinerator served by two flues, one
for charging waste, and one for carrying the prod-
ucts of combustion.
CLASS in
Direct fed incinerators with a -burning rate of
100 Ibs. per hour and over, suitable for Type 1
or Type 2 Waste.
CLASS IV
Direct fed incinerators with a burning rate of
75 Ibs. per hour or 'over, suitable for Type 3
Waste.
CLASS V
Municipal incinerators.
CLASS VI
Crematory and pathological incinerators, suit-
able for Type 4 Waste.
CLASS VH
Incinerators designed for specific by-product
wastes. Type 5 or Type 6.
Ref: Incinerator Institute of America Incinerator Standards. 1968
-117-
-------
MULTIPLE-CHAMBER INCINERATOR DESIGN FACTORS
item And symbol
Primary combuition tone:
'Grate loading. LQ
ndcd value
Average arch height. H.
Lenglh-to-width ratio (approx):
Retort
In-line
Secondary combustion gone:
Cat velocities:
Flame port at 1.000'F. Vpp
Mixing chamber at 1.000'F. V.yx-
Curtain wall port at 950'F, Vcwp
Combustion chamber at SOOT. V^£
Mixing chamber downpass length, LMC,
from top of ignition chamber arch to top
of curtain wall port.
Length-to-width ratios of flow cross
sections:
Retort, mixing chamber, and combus-
tion chsmbe r
In-line
10 Log Rc; Ib/hr-ft* where Rc equal* the
refute combuiiion rate in Ib/hr (refer to
Figure Hit
Rc - Lc: f,2
4/3 (Ac)'4'11: ft (refer Co Figure 3«2)
Up to 500 Ib/hr,2:l; over 500 Ib/hr. I. 75:1
Diminishing from about 1.7:1 for 750 Ib/hr
to about 1:2 for 2.000 Ib/hr capacity. Ovcr-
quarc acceptable in unit' of more than 11 ft
ignition chamber length.
Allowable
deviation
Combuition air:
Air requirement batch-charging opera-
tion
Combuiiion air distribution:
Overfire air port4
Underfire air port*
Mixing chamber air porn
Port airing, nominal inlet velocity
pressure
Air inlet ports oversize factors:
Primary air inlet
Underfire air inlet
Secondary air inlet
55 ft/sec
25 ft/sec
About 0.7 of mixing chamber velocity
5 to 6 ft/sec; always less than.10 ft/tec
Average arch height, ft
Range - 1.3:1 to 1.5:1
Fixed by gas velocities due to constant
incinerator width
Furnace temperature:
Average temperature, combustion
products
Auxiliary burners:
Normal duty requirements:
Primary burner
Secondary burner
Draft requirements:
Theoretical stack draft. Dy
Available primary air Induction draft,
O^. (Assume equivalent to inlet ve-
locity pressure. )
Natural draft, slack velocity, V.
Basis: 100% excess air. 50% air require-
ment admitted through adjustable ports;
50% air requirement met by open charge
door and leakage
70% of total air required
10% of total air required
20% of total air required
0. I inch water f age
1.2
1.5 for over 500 Ib/hr to 2.5 for 50 Ib/hr
2.0 for over 500 Ib/hr to 5.0 for SO Ib/hr
1.000'F
« 10?
105
4. 20%
» 20%
f 20%
3.000 to 10.000 1B|U
4. 000 to II. 000 /ch«
,b
moi.,ure
0. 15 to 0.-3S Inch water ga'ge
0.1 Inch water gage
Less than 30 ft/sec at 900T
4 20'F
Ref: U.S. Oept. HEW, Air Pollution Engineering Manual. 2nd Edition, PHS Pub. AP-40, Air Pollution Control
District, County of Los Angeles, 1973 -118-
-------
Rotary Kiln Incinerators
Versatile and Good Ash Quality
Costly and Maintenance Intensive
Waste Processing ("Auger" Loader)
Infectious Waste Shredding Problems
-119-
-------
ROTARY KILN INCINERATOR
14
P
7
_v^
^"'J7*
1 Waste to Incinerator
2 Auto-cycle feeding system:
feed hopper, pneumatic feeder, slide gates
3 Combustion air in
4. Refractory-lined, rotating cylinder
5 Tumble-burning action
6 Incombustible ash
7 Ash bin
8 Auto-control Burner Package:
programmed pilot burner
9 Self-compensating instrumentation-controls
10 Wei-Scrubber Package:
stainless steel, corrosion-free wet scrubber;
gas quench
11 Exhaust (an and stack
12 Recycle water, fly-ash sludge collector
13 Support frame
14 Support piers
15 Afterburner chamber
16 Prccooler
-120-
Ref: C. E. Raymond, Inc.
-------
Controlled Air Incinerators
Modular, "Starved Air", and Pyrolytlc
Two-Stage Combustion
Air deficient primary stage
Excess-air secondary stage
Most Widely Used Technology
Controlled Air Incinerators
Modular Combustion Units
e Starved Air Incinerators
Two-Stage Combustion Units
"Pyrolytlc" Incinerators
"Stuff-and-Burn" Units
-121-
-------
COMBUSTION GASES
AUXILARY
IGNITION
BURNER
SECONDARY CHAMBER
Volatile Content is Burned
Under Excess Air Conditions
PRIMARY CHAMBER
(Starved Air Condition)
Volatiles and Moisture
MAIN BURNER
FOR MAINTAINING
MINIMUM COMBUSTION
TEMPERATURE
MAIN FLAMEPORT AIR
ASH AND
NON-COMBUSTIBLES
CONTROLLED UNDERFIRE
AIR FOR BURNING
FIXED CARBON-
PRINCIPLE OF CONTROLLED-AIR INCINERATION
Ref: Joy Energy Systems, Inc. (Formerly Ecolaire) Article: "Principles of Controlled Air Incineration."
Undated.
-122-
-------
Control Panel
Secondary Combustion
Air Blower
Mechanical
Charge System
.Stack
Secondary Chamber
Ash Removal
Door
Primary.
Burner
Primary Chamber
Primary Combustion
Air Burner Blower
MAJOR COMPONENTS OF A CONTROLLED-AIR INCINERATOR
Ref: Hospital Incineration Operator Training Course Manual.
EPA-450/3-89-004, March 1989.
-123-
-------
"Innovative" Systems
Avante Garde Designs
Unusual Applications
Many Unproven/Experimental
"Perpetual Motion" Machines
-124-
-------
MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Malnka, P.C.
IV. INCINERATION SYSTEMS & EQUIPMENT
A. Hearths, Grates & Combinations
B. Refractory & Unlngs
C. Auxiliary Fuel Systems
1. Primary chamber
2. Secondary chamber
3. Controls
D. Waste Handing & Loading
1. Handling & transport alternatives
2. Waste loading systems
3. Waste charging systems
E. Residue Removal & Handling
1. Alternative removal systems
2. Alternative handling systems
F. Waste Heat Recovery
1. Potential benefits
2. Alternative systems
3. Auxiliaries
G. Chemical Waste Incineration
1. Regulatory considerations
2. Alternative methods & systems
3. Design considerations
H. Radioactive Waste Incineration
1. Alternatives
2. Regulatory Considerations
I. Flue Gas Handling Systems
1. Stack design & construction
2. Stack height determination
3. Breeching systems
4. Draft & draft control
5. Dampers
J. Controls, Instrumentation & Monitoring
1. Combustion controls
2. C&l systems
3. Monitoring & recording
4. Continuous emissions monitoring (CEM)
-125-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
Incineration
Systems And
Equipment
Basic Incinerator Burning Surface
Refractory Hearths
Cold
Hot
Grates
Fixed
Moving
Combinations
Refractory
Containment Of Combustion Process
Reradiatlon
Support Burning Mass And Residues
Protection Of Personnel And Environment
-127-
-------
Incinerator Linings
Refractory
Castable
Fire Brick
Insulation
Casings
Air Jacketing
Shrouding
Auxiliary Fuel
Ignition
Pre-Heat
Maintain High Temperatures
Burn-Down
-128-
-------
Primary Chamber Auxiliary Fuel
Ignition
Pre-Heat
Low Energy Waste
Secondary Chamber
Auxiliary Fuel
Pre-Heat
High Temperature Maintenance
Flame Presence
Burner Controls
Manual Switch
e Timer Switch
Automatic On-Off Or High/Low
e Modulation
Modulation With Air Blowers
-129-
-------
Waste
Handling
Waste Handling System
Collection And Transport
Interim Storage
Pro-Treatment
Incinerator Loading
-130-
-------
Incinerator
Loading
Incinerator Loading Systems
Hopper/Ram Loaders
Auger Feeders
e Top Loaders
e High-Volume Loaders
Incinerator Charging Methods
e Manual
Tilt Carts
e Cart Dumpers
e Tractors
e Conveyors
-131-
-------
CMIrtl
HOPPER/RAM LOADER SYSTEM
R«f: Doucet, L. G., VFP» Mr» Protection Handbook.
"Waste Handling System and Equipment," 16th Edition,
Chapter U, Section 12, 1985
Ref: Induatronfcs, Inc.
START
STEP I
STEP 2
STEP 3
STEP 4
STEP S
LOADER SCHEMATIC
RAM REVERSES TO CLEAR FIRE 000ft
RAM RETURNS TO START
««f: Consunat Energy Systems, Inc.
ROTARY KILN
AUGER FEEDER
-132-
-------
Residue
Handling
Residue Handling
Incinerator Discharge/Removal
Collection/Containment
Sampling And Analysis
Disposal
Ash Removal Technologies
Manual
Bomb-Bay Doors
Batch Ejectors
Continuous Systems
Stokers
Transfer Rams
Pulse Hearths
Ash Handling Methods
e Fully Manual
Semi-Automatic (Carts)
Fully-Automatic
Drag Conveyors
Back-Hoes or Scoops
-133-
-------
Waste Heat Recovery
Comparative Energy Values (As-Fired)
Propane Gas
Distillate Fuel Oil
Bituminous Coal
Wood
Mixed Paper
Medical Waste
22,000 Btu/lb
19,500 Btu/lb
12,000 Btu/lb
8,500 Btu/lb
7,500 Btu/lb
7,000 -9,000 Btu/lb
-134-
-------
Reasons For Heat Recovery
Favorable Economics
Regulatory Requirement
Energy Grant
Conditioning For APC System
Waste Heat Recovery
Fire-Tube Boilers
Water-Tube Boilers
Fl red-Boilers
Combined
Separate
-135-
-------
Chemical Waste Incineration
Options
Dedicated Incinerator
Boiler Firing
Co-Disposal In Solid Waste
Incinerator
Alternates for Co-incinerating Chemical
Waste in Solid Waste Systems
Bulk Loading (Containers)
Injector Nozzles
Dedicated Liquid Waste Burner
Dual-Fired Burner (Fuel & Waste)
Chemical Waste Incineration
System
e Collection & Transport
e Storage/Holding Tank
Pumping System
Burner or Injector System
Controls, Safeguards, & Monitors
e Special Enclosure
-136-
-------
Enclosure Room
Fire Rated
Special Ventilation
e Explosion Proof Electrical
NFPA30: "Flammable and Combustible
Uqulds Code"
Ignitable (I) Hazardous
Waste Incineration
e Flammablllty - Flashpoint <140F
e Incinerator Not "Hazardous"
e Part B Permit Required For
TSD Operations
"Hazardous" Waste Incineration
» RCRA Regulations
e Part B Permitting
e Trial Burn Testing
Continuous Monitoring
-137-
-------
RCRA (Sub-Part O)
Incineration Requirement
Part B Permit
Trial Burn Test
99.99% destruction and removal
efficiency (ORE)
Participate <0.08 graln/dscf
@ 7% CO2
HCI <4 Ib/hr or 99% removed
Continuous Monitoring and Control
POHCs
Principal
Organic
Hazardous
Constituents
Part B Permit
Waste S & A Plans
Inspection
Contingency Plans
Record Keeping
Personnel Training
Security Plans
Closure Plans
Liability Coverage
Etc.
-138-
-------
Radioactive Waste Incineration
NESHAPs Dose Levels and
10% of 10CFR20 Levels
Biomedlcally Exempt
DIS for 10 Half-lives
Mixed Waste
e RCRA and NRC Regulations
e NESHAPS
-139-
-------
Flue Gas Handling
Breeching
High Temperature
Low Temperature
Stacks
Main
Abort, Dump Or By-Pass
Dampers
Draft Inducers
Stack Height Determination
e Surroundings
e Building And Fire Codes
e Draft Requirements
e Entrapment Avoidance
e Ambient Modeling/Dispersion
Stack Accessories
Exit Cone
Spark Arrester
Test Ports (with platform)
Ladder with Safety Cage
Lightning Protection
Aircraft Warning Lights
Clean-Out Door
Drain
Instrumentation
-140-
-------
Stack Construction
High Temperature - Refractory
e Low Temperature - FRP
e Masonry
Special
Incinerator Draft
Natural
e Forced
e Induced
Balanced
Draft Controls
Barometric Damper
e Modulating Damper
Variable Speed Fan
-141-
-------
Controls, Instrumentation
and
Monitoring
Combustion Controls
Waste Charging (Fuel)
Burner Modulation
Air Modulation
Draft Modulation
Integration Of All The Above
C & I Systems
Mechanical/Electrical Systems
Solid State PC's System
Tough Screen
Self-Checking/Self-Calibration
Modems
-142-
-------
Typical Monitoring and Recording
Temperatures
Primary/Secondary Chambers
Boiler Inlet/Outlet
APC Inlet/Outlet
Pressures
Primary Chamber (Draft)
APC Pressure Drop
Boiler Pressure Drop
Combustion Air Manifolds
Scrubber Water
Flows
Scrubber Water and Slowdown
Auxiliary Fuel
Recovered Steam
Scrubber pH
Emissions
Gas Monitor Certification
» EPA Testing Protocol
» Proof of Accuracy
-143-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Malnka, P.C.
V. EMISSIONS, APC & RISKS
A. Incinerator Emissions
1. Paniculate
2. Gaseous
3. HCI
B. Air Pollution Control
1. Wet scrubbers
a. Scrubber types & applications
b. Design & operational criteria
c. Scrubber system components
d. Reheating
2. Dry scrubbers
a. Fabric filters (baghouse filters)
b. Electrostatic preclpltators (ESPs)
c. "Dry" scrubbers
d. Gas conditioning
C. Ambient Impact Assessments
1. Methodologies
2. Health & environmental risks
VI. INCINERATOR REGULATIONS & PERMITTING ISSUES
A. Regulatory Categories
1. Equipment & components
2. Operating conditions
3. Stack emissions
4. Monitoring & recording
5. Testing
6. Permitting & recertlflcation
7. Operator training/certification
8. Risk/environmental assessments
B. BACT & Regulatory Justification
C. Public Hearings & Acceptance
1. Public concerns
2. The real Issues
-145-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
Incinerator
Emissions
Incinerator Emissions
Participate
Gaseous
Participate Emissions
Combustible
Char
Soot
Mineral (Inorganics)
Metals
Silicates
Salts
-147-
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Gaseous Emissions
Combustible
Hydrocarbons
CO
PCDO And PCDF
Non-Combustibles
Nitrogen Oxides
Acid Gases
Volatile Metals (Uncondensed)
Excess Air
Gaseous Emissions
Dry and Wet
Combustibles
Noncombustlbles
Hazardous Compounds
Products of Incomplete
Combustion
CO, NOx, H2O, etc.
Volatlles, CO, HCs, etc.
NOx, SOx, HCI, etc.
POHCs
PICs, Dloxlns, Furans, etc.
-148-
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HCI Emission Concerns
Corrosion/Deterioration
Equipment
Other Structures
e Regulatory
Mass Rates
Flue Gas Concentration
Ambient Concentrations
Emission Control Equipment
e "Possible" Precursor of PCDD/PCDF
Formation
Polyvlnyl Chlorides (PVC)
e Hydrogen Chloride (HCI)
e 2-3lb PVC= 1 IbHCI
e "PVC" Plastics Are -30-50% PVC
e PVC Plastics = -10% Total Plastics
-149-
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Air
Pollution
Control
Incineration Air Pollution Control
Wet Scrubbers
Spray tower
Impingement tray
Venturl
Ionizing wet scrubber
Packed tower
Dry Scrubbers
Baghouse filter
Electrostatic preclpitator
Electrified granular filter
"Dry scrubber"
-150-
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Wet Scrubbers
Spray Towers
Venturl Scrubbers
Packed-Bed Scrubbers
Venturi Scrubber System Components
Quench Mist Eliminator
Venturi Sub-Cooler
Separator Water System
Packing Section Caustic Feed
-151-
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OUTLET
QUENCH SECTION
LIQUID FEEDS
VENTURI
LIQUID DISTRIBUTOR
PACKING
PACKING SUPPORT
WETTED ELBOW
COMBINATION CYCLONIC
SEPARATOR AND PACKED
BED ABSORBER
INLET
LIQUID DISCHARGE
VENTURI SCRUBBER SYSTEM
Ref: Andersen 2000, Inc.
-152-
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Stack
Combustion
Gases from
Secondary
Chamber
Makeup
Water -
Caustic
Feed "
_/1V
I
-TtV.
Packed
Bed
OUUOUkXMJ
Fan
Scrubber
Liquor
Recycle
Tank
r
I
I
L_
T
Discharge
' (Slowdown)
Pump
VENTURI SCRUBBER WITH PACKED BED
Ref: Hospital Incineration Operator Training Course Manual.
EPA-450/3-89-0(K. March 1989.
-153-
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Dry Scrubbers
Fabric Filters
Electrostatic Preclpltators
"Dry" Scrubbers
Dry Infection
Spray Dryer
Flue Gas Conditioning
Air Attenuation
Evaporative Cooling
Heat Exchanger
-154-
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Clean Air Plenum
Blow Pipe
Housing
Bag Retainer.
Dirty Air Inlet and Diffuser*.
ToClean Air Outlet
and Exhauster
Tubular Rlter Bags
Dirty Air Plenum
'^ "Ash Hopper
- V
gX\ _ Rotary Valve Air Lock
PULSE JET TYPE BAGHOUSE FILTER
Ref:
»
Sources,"
, "ControUcd rechniqu^s for Particulate Emission, from
1. EPA-450/3-81-005B. (NTIS PB 83-127498) Septetnbcr 1982
-155-
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Rappers
Discharge
electrodes
I , 4 Flue gas
in
Collection
electrodes
Hoppers
ELECTROSTATIC PRECIPITATOR
Ref: U.S. Environmental Protection Agency, APTI Course SI:412B, "Electrostatic Precipitator Plan Review,"
Self-Instructional Guidebook. EPA-450/2-82-019. July 1983
-156-
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Feeder
Injector
Suck
Combustion ^
Incinerator
Waste
Heat
Boiler
(h
Contactor
Reactor
Solid
Residue
Sorbent
Storage
Blower
Feeder
Pneumatic
Una
Stack
Combustion
Incinerator
Waste
Heat
Boiler
Injector
Combustion"
Air Duct
Expansion/
Reaction
Chamber
Solid
Residue
DRY INJECTION ABSORPTION SYSTEMS
Ref:
Hospital Incineration Operator Training Course Manual.
EPA-450/3-89-004, March 1989.
-157-
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Lime
Storage
Lime
Slaker
Slurry
Mixing
Tank
Slurry
Feed
Tank
Combustion
Gases
Stack
SPRAY DRYER ABSORPTION SYSTEM
Ref:
Hospital Incineration Operator Training Courte Ma
EPA-450/3-89-004, March 1989.
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DRY SCRUBBER SYSTEM
ASH AND
ggACTIOM
PHOOOCT
Major Reactions
CWOHh + ZHCI
Cs(OH)> + 2HF
CaSOi + Hrf
CaSCX-f H»0
BaghouM Fflt«r or
Electrostatic Pr«clpltator
afltafine materials:
Ca (OH),Calcium Hydroxide
(hydratedGme)
Na,CO,Sodium Carbonate
(soda ash)
NaOHSodium Hydroxide
(caustic soda)
Sodium Sesqufcarbonate (Irona)
NH,Ammonia
Prtnclpsi System Components An:
Ev»pontar/n»Gtot(*pny dryer)
So^ sepeniton equipment fl)»gftouse or precipiiator)
Sortent storage end leedhg equipment
Control systems
2. Rotefyrtomiztf is us«d bit horizontal
Juetworfc eonflgundon
Ref: Power, July 1986 (Int»r«l Corp.)
-159-
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Ambient Impact Assessment
1. Emissions Estimate
2. Ambient Modeling
3. Risk Estimates
Ambient Impact Assessment
Modeling/Risk Assessment
e Risk Analyses
Health Risk And Environmental
Assessment Reports
Worst-Case Condition
Maximum Exposed Individual (MEI)
Short-Term (1-hr) For Irritants
e Long-Term (Annual) For Carcinogens
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INCINERATOR RISK ANALYSIS PROCESS
Step
1
2
3
4
5
Step Name
Waste material source
Control - Input mix
Parameters
Identity of each substance
Amount of each substance
Measure - Input waste stream
Combustion process Process type, time, temperature
Control - Combustion process -
Measure - Process parameters
Stack Release
Control -
removal
Measure -
Waste stream
processes
Concentration
at
the stack
Dispersion to air
and surface
Dose To critical organs
Measure - Remote air
and
Height, location, removal of waste
stream products
Waste stream removal efficiency
Terrain, weather patterns
Intake to lung, wholebody, ingestion
Dose level via each pathway
concentration
deposition
Population exposed at each
dose level
Measure - Actual population
at each dose level
Dose to effect transformation Dose at each level to each organ for
each disease and resulting effect
in excess of backgound levels
Number at each dose level, time pro-
file of exposure, levels from other
Competing sources and ambients
Measure - Epidemiological
or direct experiments in
humans at levels of dose
encountered
Risk estimate
Measure - Latent and
immediate health
effects
Premature death
illness, etc.
Maximum individual risk
collective risk
Models Required In Place Of Measurement
Estimate of amount and identity
of unidentified waste streams
In-service/in-test performance model
feed rate, etc.
Destruction removal efficiency model
Models of PICs
Interaction of chemicals during
combustion
Dispersion models
Deposition models
Metabolic models
Environmental dose commitment
model for persistent substances
Population averaging models
Differential metabolism for ambient
levels via inhalation, ingestion, etc.
Dose/effect extrapolation for doses
below measured effect levels
Conversion of tests in animals
or other media to man
Extrapolation models vs. uncertainty
and need for margins of safety
Additional risk of premature death
and illness
Ref: U.S.EPA, "RCRA Incinerator Regulation Support" Documents
-------
RANGES OF UNCERTAINTY IN MODEL ASSUMPTIONS
AND THE DEGREES OF CONSERVATISM INVOLVED
STEP
MODEL
IsJ
I
1. Waste Characterization
Identification In-Service
Concentration Estimate
2. Pathways.
Diffusion Models
3. Metabolic Pathways and Fate.
Inhalation Models
Retention Models
4. Dose Estimate.
Exposure Time Profile
Maximum vs.Average Individual
Persistence In Environment
5. Dose-Effect Relationship.
Extrapolation From'Animal To Man
Choice of Scaling Model
Metabolic Differences
Extrapolation From High To Low Dose
Choice Of Model*
Margins of Safety In ADIs*
6. Individual Risk Estimate.
Real vs Hypothetical Individual
7. Population Risk Estimate
Integration vs Averaging Models
UNCERTAINTY
FACTOR RANGE
£l to 3
-1 to 3
+2 to +10
-2 to +4
+2 to +10
5 to 80
-1 to -4
+40
-2 to +100
+1000
+10 to +1000
+4 to +20
-2 to +10
BASIS
Heterogeneity
Of Wastes
Conservatism
In Models
Variation From Average
Worst To Best Case
Hypothetical MEI
Measured Range
Persistence Not Taken Into
Account For Ingestion
Factor Of +5 for Surface/Weight
Ratio Over Weight Ratio
Human Less Sensitive Than Mice
95% Linerized Multistage
Model vs Nonlinearized
Built In
Personal Mobility
Model Oversimplification
* Use either, but not both. The first is for non-threshold dose-effect relationships, the latter
for threshold types
+ Overestimate Of Risk, - Underestimate Of Risk, +1 or -1 Indicates No Uncertainty
Ref: U.S.EPA, "RCRA Incinerator Regulation Support" Documents
-------
Risk Assumptions
Maximum Exposure
24 hr/d, 365 d/yr for 70 yrs
Running In Place
Acceptable Risk Level
One Per Million
Theoretical Death Risks
Individual Action
Smoking Cigarettes
1 Hospital X-Ray
1 Cal.-Rlch Dessert
Coast-to-Coast Drive
1 Diet Soft Drink
Crossing A Street
Death Risk
0.07 x 10-6
1.0 x 10-6
3.5 x 10-6
70.0 x 10-8
4.0 x 10-8
2.0 x 10-8
Basis
Cancer
Cancer by Radiation
Cancer & Cholesterol
Accident
Cancer by Saccharin
Accident
10-6 = 1 per million
-163-
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Incinerator Regulations
And
Permitting Issues
Infectious Waste Incineration
Regulatory Categories
Equipment And Component Requirements
Incinerator Operating Conditions
Stack Emissions
Monitoring And Recording
Testing (Stack Emissions And Ash)
Health Risk Or Environmental Assessment
Permitting And Recertlflcation
Operator Training
Typical Equipment And
Component Requirements
Design And Combustion Calculations
Alr-Lock Type And Interlocked
Waste Loaders
Modulating Burners
e Enclosed Ash Removal Systems
Etc.
-164-
-------
Typical Regulated
Operating Conditions
Primary Chamber Temperature
e Secondary Chamber Temperature
e Secondary Chamber Retention Time
e Preheat Temperature
e Burndown Temperature And Duration
e APC System Performance
Typical Regulated
Stack Emissions
Opacity
Partlculate
Acid Gases (HCI and SO2)
Carbon Monoxide (CO)
Metals (12-14 Different)
Dloxlns (PCDD) And Furans (PCDF)
Typical Monitoring And
Recording Requirements
e Loading Rates
e Primary And Secondary Temperatures
e Flue Gas Constituents (CEM)
-O2, CO, CO2, HCI, SO2, etc.
Capacity
e APC System Operations
-165-
-------
Typical Testing Requirements
Flue Gases
Regulated Pollutants
Startup for "Permit to Operate"
Retestlng
Ash Residues
Constituents
Frequency
Permitting And Recertification
Permits To Install And Operate
Health Risks And Environmental Assessment
Multi-Departments
Annual Inspection Reports
Periodic Re-Testing
Operator Training
Certified Program
Operation And Maintenance
Environmental Impacts
-166-
-------
Best Available Technology (BAT)
e Beat Available Control Technology (BACT)
e Lowest Achievable Emission Rates (LAER)
e BACT
e Regulatory Impact Assessment (RIA)
e Cost/Benefit Assessment
BACT
Statutorily Defined
Requires Analysis of:
Environmental Benefits
Capital and Operating Costs
Energy Requirements
Facility Impacts
etc.
-167-
-------
Public
Hearings
Public Concerns
Environmental Impacts
Health And Weil-Being
e Aesthetics And Visibility
e Traffic Levels
e Property Levels
e NIMBY
1940s Technology vs. Modern Technology
"Proven" Technology vs. Latest Technology
State-of-Art Technology vs. Adequate Technology
What Are The Real Issues?
Emotionalism vs.
False Perceptions vs.
Hidden Agenda vs.
Rationalism
Informed Opinions
Legitimate Concerns
-168-
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MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP
Presented by: Lawrence G. Doucet, Doucet & Malnka, P.C.
John Bleckman, Doucet & Mainka, P.C.
VII. PERFORMANCE, OPERATIONS, PROCUREMENT & ACCEPTANCE
A. Incinerator Performance
1. Problems & Inefficiencies
2. Causes of poor performance
a. Selection/design deficiencies
b. Fabrication/Installation deficiencies
c. Operational/maintenance deficiencies
B. Recommended Procurement Steps
C. Acceptance
1. Operating tests
2. Performance tests
3. Emissions/compliance tests
4. Performance bonds
D. Operations & Maintenance
1. Normal operating conditions
2. Operational deficiencies
3. Operator Instructions
4. Service contracts
VIII. EVALUATING & UPGRADING EXISTING SYSTEMS
A. Reasons for Upgrading
B. Typical Considerations
-169-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
Incinerator
Performance
Success Rate: 75%
Incineration Performance Problems
Objectionable stack emissions
Inadequate capacity
Poor burnout
Excessive repairs and downtime
Unacceptable working environment
System Inefficiencies
-171-
-------
Incineration System
Performance Problems
Inadequate Capacity
Cannot Accept "Standardize Waste
Containers
e Low Hourly Charging Rates
e Low Dally Burning Rates (Throughput)
Incineration System
Performance Problems
Poor Burnout
e Low Waste Volume Reduction
e Recognizable Waste Items
In Ash Residue
e High Ash Residue Carbon
Content (Combustibles)
Incineration System
Performance Problems
Objectionable Stack Emissions
Out of Compliance with Regulations
Visible Emissions
Odors
HCI Gas Deposition/Deterioration
Entrapment Into Building Air Intakes
-172-
-------
Incineration System
Performance Problems
Unacceptable Working Environment
Ousting Conditions and
Fugitive Emissions
Excessive Waste Spillage
High Heat Radiation and
Exposed Hot Surfaces
Exflttratlon of Combustion
Products
Incineration System
Performance Problems
System Inefficiencies
Excessive Auxiliary Fuel Usage
Low Steam Recovery Rates
Excessive Operating Labor Costs
Waste Characterization Deviations
Reducing Incinerator Capacities
e Heating Values Excessive
e Moisture Excessive
e Volatlles Excessive
e Densities Excessive
e Ash Formation Tendencies
-173-
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20 COMMON PROBLEMS FOUND
IN SMALL WASTE-TO-ENERGY PLANTS
Results of 1983 Survey-of 52 Heat Recovery
Incineration Systems C5-50 TPD) Conducted
by U.S. Army Construction Engineering
Research Laboratory.
PROBLEMS PERCENT OF
INSTALLATIONS
REPORTING
1. Castable Refractory 71%
2. Underflre Air Ports 35%
3. Tipping Floor 29%
it. Warping 29%
5. Charging Ram 25%
6. Fire Tubes 25%
7. Atr Pollution 23%
8. Ash Conveyor 23%
9. Not On-LIne 21%
10. Controls 19%
11. Inadequate Waste Supply 19%
12. Water Tubes 17%
13. Internal Ram 15%
Ik. Low Steam Demand 13%
15. Induced Draft Fans i2%
16. Feed Hopper 10%
17. High pH Quench Water 8%
18. Stack Damper 4%
19. Charging Grates 2%
20. Front-End Loaders 2%
Concensus
17% Very Pleased
71% Generally Satlsfled-MInor Improvements Needed
12% Not Happy
sx L
March 1985
-174-
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Reasons for Poor Performance
Selection and/or Design Deficiencies
Fabrication and/or Installation Deficiencies
Operational and/or Maintenance Deficiencies
Typical "Specification"
"Furnish Incinerator to
Burn X Ib/hr of
Waste In Compliance
With Regulations"
Microwave Oven Mentality
e Order From Catalog
e Plug It In
e Cook Away
-175-
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5ANI-.SOOT- STACKS
&y
5PAND -X
_ j - *- .__....« ___ ^ ___ _______
FV ee <£ l&ftel ? at ?
._ ex
MCTttCft FOR.
-176-
-------
Principle No. 1
Incineration Technology
Is Not
an
Exact Science
Principle No. 2
There Is
No
"Universal"
Incinerator
Principle No. 3
Each
Application
Is
Unique
Principle No. 4
All
Manufacturers
Are Not
Equal
-177-
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Incineration
System
Procurement
Incineration System
Implementation Steps
1. Evaluations and Selections
2. Design (Contract) Documents
3. Contractor Evaluation and Selection
4. Construction and Equipment Installation
5. Startup and Final Acceptance
6. Operation and Maintenance
Bid/Proposal Evaluation:
Least Cost Or Value Assessment?
-178-
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FIVE PHASES FOR
A SUCCESSFUL INCINERATION SYSTEM
vO
PHASE 1
FEASBUTY EVALUATIONS
* SYSTEM SELECTION
BASK STEPS
Cock
tagutofent
Etc.
00-Stew.Ofl-S*
TtchooloQMK
Etc.
Analyses
4. SchMtafc Dnwingi
5. RsooiMMndBloni
6. Seteeion
PHASE 2
CONTRACT DOCUMENTS*
BD SOLICITATION
BASIC STEPS
1. OMfiA OOOUBMAll
4.R>kAiMiMMnl
6. Awtrtn Of HvjMrt
BUivPnpoi«)
RequlmmrHi
PHASE 3
CONSTRUCTION t
MSTAUATION
BASIC STEPS
Corincl OocuflMnli
PHASE 4
START-UP. TESTMGt
FMAL ACCEPTANCE
BASIC STEPS
2. Opmtor Tearing
4. PatenMnco Tiring
Cn»c*
Buowul
HMRMwery
PHASE 5
SUCCESSFUL SYSTEM
OPERATIONS* PERFORMANCE
BASIC STEPS
IPMirfcQpMtor
3l MMllMMt flf OpmlM
AopMtrSmtoContKl
r«
SamnlSWH
-------
Incineration
Operations And
Maintenance
Incinerator Operating Conditions
High Temperature* and Spikes
e Thermal Shocks
Slagging Residues
e Exploding Items
e Corrosive Gases
e Mechanical Spelling
Common Reasons For
O&M Deficiencies
e Unqualified Operators
e Negligent Operators
e Inadequate Operator Supervision
e Inadequate Operator Training
e Inadequate O&M Manuals
e Inadequate Recordkeeplng
e Inadequate Preventive Maintenance
Program
e Equipment Usage When Repairs
Are Needed
-180-
-------
Excerpt From Operating Instructions
For An Institutional Incinerator
"The Incinerator causes some smoke and
noise and may produce odor while It's
being loaded. Try to use It when tt will
Inconvenience others as little as possible."
Operator Instructions
e Training Problems
e Operating and Maintenance Manuals
e Operating and Maintenance Charts
e Periodic Retraining
-181-
-------
Incinerator Testing
Operating Test
e Performing Test
e Emissions/Compliance Test
e Trial Burn Test
Operating Tests
e Normal Conditions
e Failure Simulations
e Alarms, Safeties and Cut-Outs
Performance Test
e Capacity
e Burnout
e Energy Recovery
e Fuel Usage
-182-
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Incineration System
Upgrading, Modernization
And Retrofitting
Reasons For Upgrading
Eliminate Problems
e Improve Performance
e Regulatory Compliance
Costs
Permitting Difficulties
Evaluating And Upgrading
Existing System
Incineration System
Operational Audits
-183-
-------
Typical Incinerator
Modernization Considerations
Revised Performance Objectives
Furnace Arrangement/Configuration
e Furnace Lining/Construction
Burner/Blower Capacities
e Combustion Controls
e Instrumentation/Monitoring
e Waste Loading
e O&M Considerations
-184-
-------
Infectious Waste Incineration
Status Summary
Increasing Demands
e Increasing Developments
e Increasing Deterrents
Successful Incinerators
e Design Them Conservatively
e Keep Them Simple
e Build Them Tough
e Treat Them Well
-185-
-------
THIS PAGE INTENTIONALLY
BLANK
-------
SELECTED PAPERS
HOSPITAL/INFECTIOUS WASTE INCINERATION
DILEMMAS & RESOLUTIONS
Lawrence G. Doucet
Doucet & Malnka, P.C.
Presented at the 1st National Symposium
on Incineration of Infectious Wastes
Washington, D.C., May 6, 1988
INFECTIOUS WASTE TREATMENT & DISPOSAL
ALTERNATIVES
Lawrence G. Doucet
Doucet & Malnka, P.C.
Presented at the Symposium on Infection
Control: Dilemmas and Practical Solutions
Philadelphia, PA, November 3-4,1988
STATE-OF-THE-ARTHOSPITAL &
INSTITUTIONAL WASTE INCINERATION:
SELECTION, PROCUREMENT AND
OPERATIONS
Lawrence G. Doucet
Doucet & Malnka, P.C.
Presented at the 75th Annual Meeting of
the Association of Physical Plant Administrators
of Universities and Colleges, Washington, D.C.,
July 24, 1988
-187-
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HOSPITAL/INFECTIOUS WASTE INCINERATION DILEMMAS & RESOLUTIONS
Presented By
LAWRENCE G. DOUCET, P.E.
at the
1st National Symposium On
INCINERATION OF INFECTIOUS WASTES
Washington, D.C.
May 6, 1988
-188-
-------
HOSPITAL/INFECTIOUS WASTE INCINERATION DILEMMAS & RESOLUTIONS
Lawrence G. Doucet, P.E.
DOUCET & MAINKA, P.C.
INTRODUCTION
Infectious waste management and disposal are becoming increasingly important
issues to hospitals, universities, research facilities and similar institutions.
Major reasons include increasingly stringent and changing regulations, rapidly
escalating treatment and disposal costs, growing difficulties in locating
suitable disposal facilities, and heightened sensitivities to the potential
risks and liabilities associated with improper infectious waste management and
disposal.
Broadening legislation, more restrictive guidelines and other factors have
substantially increased the percentages of waste to be managed and disposed as
"potentially infectious" at most hospitals and other institutions. Order-of-
magnitude increases are being experienced at numerous hospitals across the
country. Simultaneously, regulations and guidelines for infectious waste
treatment and disposal are becoming increasingly restrictive.
In light of these trends, hospitals and other infectious waste generators are
being pressured by apparently opposing regulatory forces and other factors.
Regulations and guidelines enacted to protect the general public against
"potential" hazards from improper infectious waste disposal are forcing more and
more hospitals and other institutions to consider on-site incineration as the
only viable disposal method. On the other hand, guidelines and other
restrictions intended to protect the general public against "potentially
dangerous" incinerator emissions are concurrently making on-site, infectious
waste incineration increasingly restrictive, if not prohibitive, for many of
these same hospitals and institutions. This situation is literally out of
control, without direction and accelerating to a state of crisis. Prompt
actions are needed to resolve this situation in a rational manner based upon
comprehensive regulatory impact assessment.
INFECTIOUS WASTE GENERATION TRENDS
Infectious waste, which is also commonly called "contaminated," "biohazardous,"
"biological," "biomedical," "pathogenic" and "red bag" waste, is loosely defined
as any waste material that is a potential health hazard because of "infectious
characteristics." It is more specifically defined on state and local levels.
Approximately 30 states currently designate or define "infectious" waste for
regulatory or policy-making purposes, and at least 7 states include infectious
waste under their hazardous waste regulations.
State and local designations and definitions for "infectious" waste are widely
varying and often vague and ambiguous. On a nationwide basis, there are great
differences in the types and quantities of waste requiring management and
disposal as "infectious" for regulatory compliance. For example, infectious
waste would typically comprise about 3 to 5 percent of a hospital's total waste
stream according to regulations based upon early CDC guidelines(1) , roughly 10
percent of total waste according to regulations based upon the 1986 U.S.EPA
Guide for Infectious Waste Management (2), and up to about 20 to 35 percent of
total waste according to legislation based upon U.S.EPA regulations proposed in
-189-
-------
1978 <3) . Furthermore, site-specific and individual interpretations of the
regulatory language also substantially affect infectious waste percentages. It
is not uncommon for regulatory agencies and individual institutions to have
widely divergent opinions as to which waste stream components and sources should
be regulated as infectious.
Without question, "infectious" waste generation rates have been increasing
steadily, if not dramatically, throughout the country over the past few years.
In all likelihood, this trend will continue at an escalating rate for at least
the next several years. The major reasons for this include:
Broadening Legislation
AIDS Fears and Precautions
Tightening Instituional Policies
Off-site Disposal Limitations
Broadening Legislation
A recent survey by the National Solid Wastes Management Association (NSWMA)(4)
determined that roughly 20 states are planning to either promulgate new
infectious waste legislation or tighten existing infectious waste legislation
and/or guidelines within the year.
AIDS Fears and Precautions
Recent studies have predicted a doubling of isolation waste every year for at
least the next several years due to increased AIDS patients and related concerns.
Many hospitals have thus begun categorizing all patient-contact waste as
potentially infectious. As much as 70 to 90 percent of total hospital waste are
typically included in this category.
Last Augusti the CDC issued "Recommendations for Prevention of Human Immuno-
deficiency Virus (HIV) Transmission in Health-Care Settings"(5) . Referred to
as "Universal Precautions," these basically recommend that "all patients be
considered potentially infected with HIV and/or other blood-borne pathogens."
It seems likely that most hospitals will begin categorizing all patient-contact
waste as potentially infectious to achieve compliance with these Guidelines.
Tightening Institutional Policies
In light of increasing liabilities and punitive provisions associated with
infectious waste legislation, as well as public image concerns in a competitive
hospital market, waste management policies and protocols at many institutions
are effectively broadening the designations of "infectious" waste to Include
more sources and materials than might normally be covered by applicable
regulations and guidelines. Likewise, more and more institutions are tending to
be over-conservative in their infectious waste segregation practices such that
significant quantities of general, non-infectious, waste are Intermixed with
red bag waste. These practices also drive "infectious" waste quantities to
higher levels.
-190-
-------
Off-Site Disposal Limitations
The present fear of hospital waste is rampant. In some metropolitan areas,
general waste haulers, landfill operators and municipal waste incineration
facilities have refused to handle or dispose of any hospital waste. In other
areas, some hospitals have gone to great lengths and expense to autoclave their
infectious waste only to find that it would still not be accepted at the local
landfill or municipal incinerator because the waste bags were still "red"
colored and perceived to be Infectious.
Some municipal waste incineration (resource recovery) facilities impose severe
fines on and, sometimes, terminate services to hospitals that allow "infectious"
waste to be intermixed in their general waste streams. Therefore, such
hospitals are forced to great lengths to assure that any items remotely
resembling patient-contact or contaminated waste, Including such things as baby
diapers, sanitary napkins from public facilities, plastic tubing and any items
colored with red stains, dyes or medicines, are segregated from their general
waste. Surveys at some of these hospitals have determined that such segregated
waste, which effectively become "infectious," are typically 2 to 3 times the
quantities defined under the regulations and/or guidelines.
ON-SITE INCINERATION INCENTIVES
As a result of substantially increasing "infectious" waste quantities,
tightening legislation and off-site disposal limitations and restrictions, on-
site incineration has clearly emerged as the preferred, most viable infectious
waste disposal option for most hospitals and Institutions. First of all, from a
technological standpoint, incineration offers several major advantages as
compared to other treatment technolgies. More importantly, it may be the only
treatment method with a processing capacity suitable for the "infectious" waste
generation rates of most hospitals and other institutions. Incineration not
only sterilizes pathogenic waste constituents but also provides typical weight
and volume reductions of 90 to 95 percent. In addition, it converts obnoxious
waste, such as animal carcasses, to innocuous ash, provides the potential for
waste heat recovery and, in some cases, can be used for simultaneously disposing
of hazardous chemicals and low-level radioactive waste.
On-site Incineration attractiveness is also greatly enhanced by various current
and developing legislation. About half of the states and several major cities
currently mandate that infectious wastes be treated on-site, restrict its off-
site transport and/or prohibit it from being landfilled. Many additional states
are planning similar, restrictive legislative measures within the next few
years. Likewise, virtually all states either require, recommend or advocate
incineration as the preferred method for treating infectious waste.
Furthermore, incineration is the only treatment technique recommended in the
U.S.EPA Guide for virtually all designated Infectious waste types.
Off-site disposal difficulties and limitations probably contribute the greatest
incentives for many hospitals and other institutions to consider or select
on-site incineration as the preferred infectious waste treatment method. It has
become increasingly difficult, if not impossible, to locate reliable, dependable
infectious waste disposal service contractors. Many institutions able to obtain
such services are literally required to transport their infectious waste across
the country to disposal facilities. Furthermore, such services are typically
very costly, if not prohibitive. Off-site disposal contractors are typically
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charging from about $0.30 to about $0.80 per pound of infectious waste, and some
are charging as much as $1.50 per pound. For many hospitals and other
institutions, this equates to hundreds of thousands of dollars per year.
Several hospitals are paying more than a million dollars per year.
About 3,500 hospitals currently incinerate their infectious waste on-site.
However, based upon conservative estimates, on the order of 5,000 new and
upgraded incineration systems will be needed within the next few years to handle
the demands imposed by Increasing "infectious" waste quantities and changing
regulatory requirements <6>.
ON-SITE INCINERATION LIMITATIONS
Despite the increasing attractiveness, incentives and needs for hospitals and
other institutions to incinerate their infectious waste on-site, regulatory
restrictions, socio-political opposition and other factors are concurrently
making on-site incineration increasingly prohibitive, if not impossible. These
are discusssed as follows:
Regulatory Restrictions
In an effort to protect the environment and public welfare against potentially
unacceptable emissions, an increasing number of state and local pollution
control agencies are proposing and promulgating extremely restrictive regulations
and criteria for permitting and operating infectious waste incinerators. Unfortun-
ately, many such regulations appear to have no technical basis. They are also
often reflective of unproven technology, unrealistic and sometimes unattainable.
As an example, one northeastern state recently proposed:
Stack emission limitations more stringent than can be achieved with even
"best available control technologies" (BACT)
Instrumentation and monitoring devices that are not only superfluous,
redundant, and very costly, but also, in a few instances, unproven or not
commercially available for the required applications
Exceptionally high incinerator operating temperatures which must be
maintained at all times, even without wastes being burned
Stack testing, modeling and risk assessment analysis requirements that are
far more severe than comparable requirements for hazardous waste
incinerators under RCRA regulations, and which are more costly than the
installed equipment.
A study by the Hospital Association in that state determined that compliance with
the proposed regulations would increase incineration system capital cost
requirements by nearly 100 percent and would add as much as $150,000 to $450,000
to annual operating costs.
Obviously, the effect of these, as well as similar regulations being promulgated
in other states, is to severely inhibit on-site incineration feasibilities.
What is most disturbing, however, is that there appears to be no evidence or
documentation which show that there will be any significant environmental
benefits or reduced health risks if these proposed regulations are enacted.*
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"Capricious rulemaking" and "unofficial policymaking" are regulatory activities
which also inhibit or restrict the Implementation of new on-site incineration
systems. "Capricious rulemaking" basically involves the seemingly arbitrary,
unpredictable and frequent changing of permit conditions and requirements.
"Unofficial policymaking" basically involves the setting of permit conditions
and requirements that are different from published, or "written," regulatory
policies. Possibly because infectious waste legislation and policies of many
agencies are in a state of flux, these activities appear to be increasingly
commonplace.
Socio-Political Opposition
It seems that public opposition to incineration has increased dramatically
within the last several years. This is apparently due to the workings and
campaigns of various environmental extremists, political opportunists and
various special-interest groups. Many so-called environmentalists are more
interested in stopping incineration at any cost, regardless of the overall
environmental consequences. In fact, several environmentalists and pseudo-
experts have become national celebrities because of their willingness to expound
on the "evils" and (potential) health hazards associated with incinerator
emissions. Although such opinions are sometimes half-truths, exaggerations and
without technical or scientific merit, they are usually taken very seriously by
the general public and are widely reported by the press.
Because of a proclivity for seeking and reporting sensational, newsworthy
events, the press is often negligent in differentiating between facts and
opinions. Statements relative to the "dangers" and "risks" of incineration are
often reported in an unfiltered, unchecked manner. At best, sensational but
unsubstantiated opinions from unqualified, special-interest oriented
individuals are presented on an equivalent basis with statements that are
factual and well-documented. To the general public, such contradictory
"viewpoints" appear to be little more than differences of opinion.
For those seeking to permit new incineration facilities and gain acceptance at
public hearings, the starting premise is almost always "guilty until proven
innocent." It is likewise becoming more and more difficult, if not impossible,
for permit applicants to "prove" or otherwise demonstrate that properly designed
and operated incineration systems are environmentally benign and pose no
significant increased risks. The major reason for such difficulties is that
most public opposition is emotionally based. Issues such as fear, mistrust and
the "not-in-my-backyard" (NIMBY) syndrome cannot be effectively countered with
scientific data or logic. Consequently, since most regulatory agencies tend to
take a passive or neutral position at public hearings, an increasing number of
infectious waste incinerator permits are being denied or indefinitely postponed.
Residue Disposal Restrictions
A growing national trend is for various general waste haulers and/or associated
landfill operators to claim that infectious waste incinerator ashes are
"hazardous." This is despite the fact such materials are neither classified as
hazardous under state or federal regulations, nor does there exist data or
documentation which show these ashes to be hazardous or contain significant
concentrations of hazardous constituents. It appears that such "hazard" claims
may primarily be economically motivated. By charging very high rates for the
handling and disposing of incinerator ashes as "hazardous waste," off-site'
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disposal firms may be seeking to offset revenues which they are losing because
of on-site incineration activities. These high ash disposal charges also
substantially reduce the economic Incentives for hospitals and other
institutions to install or operate infectious waste Incinerators.
Fallacies and Misconceptions
It is likely that most of the regulatory trends, over-reactions and perceived
fears are the result of various misconceptions relative to hospital/infectious
waste management and incineration. Some of the misconceptions and
misunderstandings are at least based upon a modicum of technical data and
rationale, but many have no technical merit whatsoever. Unfortunately, most of
the opportunists and special interest groups seldom make efforts to distinguish
between known facts, reasonable hypothesis, hypothetical speculations or
imaginary situations when expounding or lobbying on their positions. In
addition, despite best intentions, many of those formulating and promulgating
regulations and guidelines in the various states simply do not have adequate
technical background or documentation to make such distinctions or judgements.
They, therefore, often take the most over-conservative, if not worst-case,
positions when drafting their regulations and guidelines.
The following are some of the more common fallacies and misconceptions:
Fallacy No. 1 - Hospital/Infectious Waste is More Hazardous
than Municipal Solid Waste (MSW)
Those expounding this assumption point out that hospital waste is more hazardous
not only because of infectiousness but also because it may contain more plastics
than MSW, as well as (potential) incidental quantities of radioactive waste,
chemical waste and chemotherapy, or cytotoxic, agents. It has also been claimed
that the high plastic content, particularly PVC plastics, of hospital waste creates
a greater potential for emiting dioxins and furans during incineration.
Obviously, this assumption has directly resulted in increasing difficulties and
exhorbitant costs relative to off-site transport and disposal of hospital waste.
As noted, some regulatory agencies have even incorporated hospital/infectious
waste under their hazardous waste rules and regulations. In some states, this
assumption has also served as a basis for the inclusion of hospital/infectious
waste incinerators under the BACT provision - in direct correlation to MSW
incineration facilities.
The fact is that properly managed hospital waste is far less hazardous than MSW.
First of all, according to the CDC, "there is no epidemiological evidence to
suggest that hospital waste is any more infective than residential (MSW) waste."(DM)
Almost without exception, and as required to maintain accreditation(7),
hospitals and other healthcare organizations segregate, sterilize, or otherwise
destroy "potentially infectious" waste, i.e., blood and blood products, micro-
biology laboratory waste, pathology waste, sharps and waste from patients on
isolation, per CDC recommendations.
Although some hospitals generate radioactive waste through diagnostic,
therapeutic and research activities, the treatment and disposal of these are
highly regulated by the Nuclear Regulatory Commission (NRC).<8) All
radioactive waste materials must be thoroughly accounted for, and it is
extremely unlikely that any low-level radioactive materials could be
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"incidentally" disposed in a hospital's general waste stream.
Hospital chemical wastes are regulated according to state and/or federal
hazardous waste regulations. These basically comprise a complex set of
requirements for monitoring and regulating hazardous wastes from cradle to
grave. Although very small amounts of disposed chemicals, including
miscellaneous items contaminated with trace amounts of chemicals and cytotoxic
agents, may find their way into the general waste stream, such quantities are
extremely small - particularly in comparison to chemicals, ranging from
household cleaners to Pharmaceuticals, paint thinners, garden chemicals and used
motor oils, routinely discarded in MSW streams. Also according to accreditation
requirements, hospitals must establish a program and appoint a responsible
individual for managing all hazardous materials (and wastes) "from entry to
final disposal." This includes making every effort to eliminate such disposed
chemicals, while there is usually no such control on MSW.
The same can be said with respect to metals disposed in MSW as compared to
hospital waste streams. MSW waste typically comprises about 10 percent metals,
or as much as five times more than in hospital waste. In addition, high
concentrations of metals are usually segregated from the hospital waste
incinerated on-site, while there is virtually no control over metals typically
disposed in MSW. Furthermore, MSW contains much higher percentages of items
such as batteries, electrical components and the like which tend to have more
toxic heavy metal constituents.
While it is true that most hospital waste contains more plastics than MSW, the
mere presence of plastics is not environmentally unacceptable. A recent study
by the New York State Energy Research and Development Authority on a MSW
incineration facility in Pittsfield, Massachusetts reported that "there is no
statistical relationship between the amount of PVC plastic in the waste and the
levels of dioxins or furan emission when burning under good combustion
conditions." Furthermore, the fact that most plastics have substantially higher
heating values and burn more rapidly than other waste stream components is also
not necessarily bad for the environment. These petroleum-based products, when
burned in a properly designed, controlled and operated incineration system, can
serve to improve combustion and system efficiencies by helping to maintain
elevated temperature levels while minimizing supplemental fuel usage.
Fallacy No. 2 - Hospital/Infectious Waste is as Hazardous (or Toxic)
as Chemical Waste
Those expounding this viewpoint cite arguments similar to those in Fallacy No. 1,
above, except that they tend to emphasize potential chemical and radioactive
hazards. The regulatory consequences and impacts on hospitals are comparable to
those noted above, except that in some states, hospital/infectious waste
incinerator regulations are more stringent than those for hazardous chemical
waste incinerators.
As per above, facts are that hospital wastes are far less hazardous than
hazardous chemical wastes.
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Fallacy No. 3 - Infectious Waste Incineration Is More Hazardous
than General Waste Incineration
Based upon various, recent state regulations and guidelines dealing with
hospital/infectious waste incineration, it appears that many believe that the
incineration of infectious waste results in more hazardous or more
concentrations of toxic emissions than comparable systems Incinerating only
non-infectious, or general, waste. For example, a regulation recently
promulgated in one state spells out highly stringent criteria and permitting
requirements for "hospital/infectious waste Incinerators," but this regulation
specifically excludes, or exempts, "incinerators located in any hospital or in
any medical facility...used to incinerate only general refuse."
The assumption that infectious waste burns differently from non-infectious waste
and, therefore, requires special legislation is nonsensical. There is
essentially very little difference between infectious and non-infectious waste
except for the presence of disease producing microorganisms, or pathogens.
Blood and body fluid contamination are the chief sources of such pathogens, and
there is no technical or scientific reason for discarded paper or plastic items
to burn differently or less efficiently simply because of the presence of such
blood or fluid contamination.
A possible related concern may be a fear that microorganisms may survive the
incineration process and be discharged into the environment. However, this is
also a fallacious assumption. It is well documented that no microorganisms
can survive normal incineration temperatures. In fact, the kill rate is nearly
instantaneous at temperatures exceeding 1400°F.
COMMENTARY & RECOMMENDATIONS
The basic objectives of most of the developing and changing infectious waste
legislation and guidelines are certainly valid; that is, to protect the
environment and public welfare. However, it seems obvious that many of these
are being proposed and enacted Impetuously and without regard to economic
implications or assessments of actual risks and/or expected benefits. For
example, most legislation being enacted to safeguard against improper infectious
waste disposal activities are largely the result of increased public awareness
and concerns of "potential" hospital waste hazards, as stimulated by widely
reported incidents of "red bag" waste being dumped in landfills, abandoned
buildings, along roadsides and even in oceans and waterways. However, as noted,
according to the CDC and most epidemiologists and other experts, "there is no
epidemiologic evidence to suggest that most hospital waste Is any more infective
than residential waste. Moreover, there is no epidemiologic evidence that
hospital waste disposal practices have caused disease in the community" (1)(4).
Furthermore, excluding reports of infections caused by needlesticks, the only
published incident of an infectious waste treatment method being associated with
infectious disease transmission concerned a waste disposal chute connected to a
hydropulping system.
The basic objectives of the infectious waste incinerator regulations being
proposed and promulgated by most regulatory agencies are also valid. Improperly
designed and operated incinerators of almost any type, age or capacity may
potentially result in unacceptable emissions. However, best available data
clearly show that properly designed and operated systems are envlronmenally
benign and pose insignificant increased risks. The mere fact that some toxic
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contaminants can be measured in hospital waste incinerator stacks does not
necessarily or automatically mean that their concentrations are harmful to the
environment or public welfare. For example, because dioxins and furans have
been "measured" in the stacks of several hospital waste incinerators, these
contaminants have been the cause of much opposition to new systems. However,
their reported concentrations are literally at molecular levels, and modeling
and risk assessment analyses of these routinely show resultant increased health
risk levels to be orders-of-magnitude less than acceptable (one in a million)
levels.
While on the subject of dioxins and furans, it is worth noting that these have
been detected in trace amounts in combustion processes that occur everywhere.
Research has verified their presence in not only incinerator emissions but also
in emissions from fossil-fuel fired boilers, gasoline and diesel powered
automobiles and trucks, fireplaces, charcoal grills and even cigarettes. (9> In
1986, 26 international scientists and physicians convened by the World Health
Organization concluded that modern "refuse-burning" plants are very minor
sources of dioxins and furans in the environment, (less than one percent) when
considering the current body burden of dioxins and furans in the populations of
developed countries (10) . (For comparison, hospital waste incinerator emissions
comprise only a tiny fraction of total emission from "refuse-burning" plants.)
In addition, studies and current literature have not reported any scientifically
proven, permanent adverse health effects from dioxins and furans.
It is likely that many of the concerns and fears of hospital waste incinerator
emissions stem from selective extrapolation of data and conclusions from reports
covering municipal solid waste incineration facilities and incinerators burning
hazardous industrial wastes. In addition, some regulators and anti-incinerator
advocates affirm their positions by citing objectionable performance and
emissions data from hospital waste incinerators of obsolete designs, as well as
from those which are obviously improperly designed, controlled and operated.
Clearly, prompt and rational measures are needed to relieve hospitals and other
institutions across the country from the crushing effects of the opposing
regulatory forces. More and more waste quantities are required to be treated as
"infectious," of which smaller percentages are truly infectious; but,
simultaneously, viable treatment and disposal options are being eliminated or
made cost-prohibitive. Certainly such relief measures must not be at the
expense of the environment or public welfare; however, it is strongly advocated
that such remediation involve the enactment or revision of legislation,
requirements and guidelines that are based upon a comprehensive assessment of
environmental benefits and economic Implications. In fact, such assessments,
which are termed "regulatory impact analyses" (RIA), are statutorily required of
the U.S.EPA prior to their promulgating any new regulations.
The specific point that most regulatory agencies seem to be using to justify
their positions in setting severe, often unattainable hospital/infectious waste
incinerator regulations or policies is that "legislation" or "statutes" require
the application of BACT. However, by most definitions, BACT requires taking
into account such factors as energy, costs, economic and environmental impacts.
Such accounting is essentially what is normally provided under RIA. Such
analyses are necessary not only to establish a sound basis for setting
regulatory policies but also for justifying the setting of specific technical
requirements, such as incinerator emission limits and operating conditions. For
example, without such analysis, an agency cannot justify whether setting a
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particulate emission limit of 0.015 grains/dry standard cubic-foot (gr/dscf)
will provide any significant reduction in health risk levels, or other
environmental improvements, as compared to a standard of 0.10 gr/dscf, or other
intermediate level. Certainly, the cost differences between these various
levels are substantial and would have major impacts on the viabilities of the
technology. Many regulating agencies have taken a short-sighted, short-cut
approach to the BACT issue by selecting a 0.015 gr/dscf particulate limit level
simply because this is considered BACT for MSW incinerators using "dry scrubber"
emission control technology. This is despite the fact that this emission
control technology has never been successfully demonstrated on a hospital waste
incinerator application.
Other examples of setting regulatory criteria without justification include
incinerator operating temperatures and retention times. Most regulatory agencies
seem to be proposing secondary chamber retention times of at least 2 seconds.
However, the fact is that there are no studies or data to show that 2 seconds
(alone) provides significantly better emissions (or performance) than 1 second.
Some manufacturers have proprietary designs whereby secondary chamber turbulent
mixing is sufficiently high to provide superior gas phase combustion within 1
second (or less) than other manufacturers' systems with poor turbulent mixing at
2 seconds or more.
The fundamental bases for the incinerator regulations and criteria of many
states appear to be "copy cat" or "upmanship" actions. For example, some state
agencies simply make reference to or copy documentation, criteria and guidelines
from other states in order to support their own policies. Also, it often
appears that some states set emission levels and criteria "a little more
stringent" than other states only because they want to be considered a little
more prudent or more concerned about the environment. However, as noted, the
basic problem is that the documents, guidelines and regulations being "mimicked"
or "bettered" have not been based upon RIA or other assessments.
Clearly, actions and cooperation are needed from both the regulatory and Institutional
sectors in order to relieve the tightening legislative bind and resolve the
present dilemmas. Specific recommendations for each of these are as follows:
State and local regulatory sectors should -
1. Develop or commission RIA and other supporting documentation prior to
proposing and/or promulgating new legislation. If not yet done, subject
existing legislation to RIA review. Make appropriate ammendments and/or
revisions should existing legislation be found excessively restrictive and
without significant benefits. If resources are limited, consider combining
forces with other agencies or neighboring states. If enough states become
involved, the U.S.EPA should possibly be requested to provide needed
support and documentation.
2. Establish and enforce responsible permitting procedures. Assure that
"capricious rulemaking" and "unofficial policymaking" do not take place.
Also, process permit applications with consistency and reasonable promptness.
3. Be prepared and willing to take a hard stand and an active position at
public hearings. Even if all environmental concerns and risks are
demonstrated or proven to be non-existent or negligible, there will
continue to be special-interest groups and environmental extremists
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who will protest and try to impede the implementation and permitting of
incineration facilities. Strive to identify, properly assess and
responsibly act upon the genuine environmental and technological Issues.
However, actively endorse and approve incinerator permit applications
in such cases where protests and objections are supported by only
emotional issues or selfish concerns.
Hospitals and other institutions should -
1. Take an active role to help resolve the tightening regulatory bind.
Through state and regional hospital and environmental associations,
technical societies and other representative groups, stay abreast of
proposed legislation and guidelines and challenge those which are
unrealistic, unreasonable and which cannot be supported from a technical or
scientific basis. Demand that existing and proposed legislation and
guidelines be subject to RIA, or other environmental assessment/cost-
benefit analyses, as well as peer reviews and public commenting.
2. Challenge regulatory agencies that act irresponsibly or inconsistently with
regard to permitting procedures. Insist that the regulators abide by
"written" policies and requirements.
3. Contest waste haulers and disposal firms that are charging "hazardous
waste" rates for disposing of incinerator ashes. Such practices are
potentially scandalous, possibly unethical and should not be allowed to
continue unchallenged.
As of this writing, a few state hospital associations have begun implementing
some of the above recommendations. However, more importantly, the American
Society for Hospital Engineering (ASHE) has recently formed a committee and has
initiated activities to develop R1A and related background documentation
relative to hospital/infectious waste management and incineration. Other
groups, including the U.S.EPA and the Waste Combustion Equipment Council, of the
NSWMA, have expressed interest in endorsing and participating in this project.
It is anticipated that the results of this ASHE project will prove invaluable
to the state hospital associations and the regulatory sector.
In final summary, failure to resolve this situation expeditiously and
responsibly may have far-reaching and major, adverse consequences on the country
as a whole. It must be recognized that with respect to waste management and
disposal, there is no such thing as a zero risk, particularly in our modern,
industrialized society. In addition, in the evaluation of disposal options,
risks from incineration must be viewed and assessed in comparison to the risks
associated with other, alternate treatment and disposal technologies.
Unnecessary and insupportable restrictions and prohibitions which effectively
eliminate incineration as a cost-effective and environmentally safe disposal
technology may likely result in more severe environmental consequences and other
problems.
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REFERENCES
(1) Centers for Disease Control, U.S. Dept. of Health & Human Services,
"Guideline for Handwashing & Hospital Environmental Control, 1985,"
NTIS PB85-923404, 1985.
(2) U.S.EPA, Guide For Infectious Waste Management, EPA 530-SW-86-014,
NTIS PB86-199130, May 1986.
(3) U.S.EPA, "Hazardous Waste-Proposed Guidelines and Regulations...,"
Federal Register, December 18, 1978.
(4) Centers for Disease Control, U.S. Dept. of Health & Human Services,
"Recommendations For Prevention of HIV Transmission in Health-Care
Settings," Morbidity and Mortality Weekly Report, Vol. 36, August 21,
1987.
(5) Hilton, C., "Summary of State Infectious Waste Management Survey,"
presented at the Infectious Waste Handling & Disposal Seminar, Washington,
D.C., November 17, 1987.
(6) Doucet, L.G., "Infectious Waste Incineration Market Perspectives &
Potentials", presented at the Wastes-to-Energy '87 Conference, Washington,
D.C., September 22, 1987.
(7) Joint Commission on Accreditation of Healthcare Organizations, Accreditation
Manual '-for Hospitals, "Plant, Technologicy and Safety Management,"
Standard PL6: Hazardous Materials and Wastes, 1987.
(8) NRG, "Standards for Protection Against Radiation," 10 CFR 20.
(9) "Environmental Health Letter," December 1, 1978, p. 6.
(10) World Health Organization Summary Report, Working Group on Risks to Public
Health of Dioxins from Incineration of Sewage Sludge and Municipal Solid
Waste, Naples, March 15-27, 1986.
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INFECTIOUS WASTE TREATMENT & DISPOSAL ALTERNATIVES
Presented By
LAWRENCE G. DOUCET, P.E.
at the
SYMPOSIUM ON INFECTION CONTROL:
DILEMMAS AND PRACTICAL SOLUTIONS
November 3-4, 1988
Sponsored by the
Eastern Pennsylvania Branch of the
American Society for Microbiology
Philadelphia, PA
June 12, 1989
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INFECTIOUS WASTE TREATMENT AND DISPOSAL ALTERNATIVES
Lawrence G. Doucet, P.E.
DOUCET & MAINKA, P.C.
Consulting Engineers
2123 Crompond Road
Peekskill, NY 10566
INTRODUCTION
Infectious waste management and disposal issues are of prominent
national concern. Widely reported illegal disposal incidences and beach
washups over the last few years have stirred public fears and anger.
Politicians and legislators have responded by enacting stringent
legislation for the management, manifesting and disposal of infectious
waste.
As a result of recent legislation and guidelines on a state and
national level, as well as other concerns, the quantities of waste to be
managed and disposed as potentially infectious at many hospitals and
other institutions have increased enormously. At some hospitals,
"infectious" waste quantities have increased from a level of about 3
percent of total solid waste to nearly 90 percent of total solid waste.
Such rapid and voluminous increases have created severe
difficulties for many hospitals to locate or select reliable,
safe and cost-effective alternatives for treating and disposing
of their infectious waste.
On-site infectious waste treatment technologies, such as steam
sterilization, shredding with chlorination, incineration, and off-site
disposal services have comparative advantages and disadvantages which
substantially affect their viabilities on a case-by-case basis.
Technological, environmental, regulatory, economic and socio-political
factors must all be carefully considered prior to selecting and
implementing one of these alternatives.
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INFECTIOUS WASTE GENERATION
The first and most important step in evaluating and selecting an
infectious waste treatment and disposal program is to identify or define
the types, sources and quantities of waste which require management and
disposal as potentially infectious. Such definitions must not only
consider present generation rates but also potential future increases due
to policy or regulatory changes. Inaccurate estimates or projections could
result in the procurement of a waste treatment system of either inadequate
capabilities or which is excessively complex and costly.
There are five primary factors which influence or determine the
quantities of waste which require treatment and disposal as potentially
infectious. These are:
1. Regulatory Definitions and Guidelines
Federal, state and local designations and definitions for "infectious"
waste vary widely and are sometimes vague and ambiguous.
2. Interpretations of the Regulations and Guidelines
Site-specific and individual interpretations of regulatory
definitions, and the intentions of such definitions, can substantially
affect infectious waste generation rates. Regulatory agencies and
individual institutions may have widely divergent opinions as to which
waste stream components and sources need to be regulated as
infectious.
3. Waste Management Policies and Protocols
Individual hospitals and other institutions establish protocols and
procedures for segregating and managing infectious waste in compliance
with regulatory and accreditation requirements. The conservatism of
such policies also varies widely. For example, many hospitals have set
a policy whereby all patient-contact waste is considered potentially
infectious in line with their own interpretations of CDC "universal
precaution" guidelines.
4. Waste Management Program Effectiveness
The ability to implement and effectively administrate an infectious
waste segregation program can substantially impact the quantities of
waste requiring treatment and disposal as "infectious" waste.
The best protocols and written procedures are no better than the
personnel assigned to implement them. Sloppy and unsupervised waste
handling and packaging procedures could easily result in large
quantities of (non-infectious) trash being intermixed with infectious
waste items. Likewise, infectious waste items could also be
inadvertantly intermixed with general trash and cause other problems.
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5. Off-Site Haulage and Disposal Restrictions
This factor is the most significant of all. Regardless of regulatory
requirements or other in-house programs, local restrictions or
prohibitions by general waste haulers, sanitary landfill operators or
municipal waste incineration facilities can effectively result in all
of the waste from a hospital being considered "infectious." There is
little recourse should the municipal waste transporters and disposal
firms within a municipality or region refuse to handle or dispose of
any hospital waste by unilaterally claiming that all of it is
"infectious." This has happened in several municipalities.
The quantities or generation rates of infectious waste resulting from
the above factors are site-specific. The variations can range from as
little as 3 percent of total solid waste to as much as 100 percent of total
solid waste. Table 1 shows typical, approximate ranges for these
factors.
TABLE 1
INFECTIOUS WASTE GENERATION COMPARISONS
APPROXIMATE
INFECTIOUS WASTE
TYPICAL GENERATION RANGES
PARAMETERS (PERCENTAGES OF TOTAL WASTE)
Centers for Disease \a 3-5%
Control (CDC) Designations
\b
U.S.EPA Guidelines 7 - 15%
\c
Designated Departments 20 - 35%
\d
All Patient-Contact Waste 60 - 90%
Hauler/Disposal Facility Restrictions 0 - 100%
\a Reference 3
\b Reference 7
\c Proposed U.S.EPA RCRA, Sub-Title C, Hazardous Waste
Regulations, 1978; Departments include Autopsy, Emergency,
ICU's, Isolation Rooms, Clinical Labs, Obstetrics (including
patient rooms), Pathology, Pediatrics & Surgery (including
patient rooms)
\d Based upon site specific - interpretations of "Universal
Precautions" per CDC "Recommendations for Prevention of HIV
Transmission..." Morbidity & Mortality Weekly Report,
Vol. 36, August 21, 1987
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INFECTIOUS WASTE TREATMENT TECHNOLOGIES
The only proven technologies for treating and disposing of the large
and increasing quantities of infectious waste being generated at many
hospitals and other institutions are steam sterilization, or autoclaving,
shredding with chlorination and incineration. Other technologies, such as
dry heat sterilization, gas/vapor sterilization and radiation are either
too limited in capacity or are unproven for processing large waste volumes.
Innovative or emerging technologies, such as glass slagging systems, high-
temperature plasma systems and systems combining shredding and radiation
are in the development stage and are years away (if ever) from being proven
or made commercially available. Alternative infectious waste treatment
technologies are shown on Table 2.
TABLE 2
ALTERNATIVE INFECTIOUS WASTE TREATMENT TECHNOLOGIES
STEAM STERILIZATION
Gravity Systems
Pre-Vacuum Systems
Retort Systems
Combination Trash Compactor/Autoclave Units
SHREDDING/CHLORINATION
Small Scale Sharps/Lab Waste Processing Systems
Large Scale Total Infectious Waste Processing Systems
INCINERATION
Multiple Chamber Systems
Controlled Air Systems
Rotary Kiln Systems
Innovative Systems
OTHER (SMALL SCALE) SYSTEMS
Dry Heat Sterilization
Gas/Vapor Sterilization
Radiation
EMERGING TECHNOLOGIES
Glass Slagging
High-Temperature Plasmas
Shredding/Radiation
Etc.
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The principal, proven technologies are as follows:
1. Steam Sterilizatioj)
Autoclaving basically involves a system whereby steam is brought into
contact with waste materials in a controlled manner and for sufficient
duration to kill pathogenic micro-organisms which may be contaminating
the waste. The different types of autoclave systems and designs
relate to steam contact efficiencies and waste volumes which can be
processed, or sterilized, within the shortest possible time periods.
Sterilization performance, or efficiency, is a direct function of
steam penetration into the packages of waste being treated by the
system. Factors such as waste type and density, packaging materials
and waste loading procedures directly affect steam penetration and the
exposure times necessary for effective sterilization. Inadequate
steam penetration is usually the limiting factor in achieving
sterilization within a reasonable time period.
In systems whereby steam pressure alone is used to evaluate air from
the autoclave chamber, termed gravity systems, only about 15 minutes
of direct steam contact is typically required with steam temperatures
of about 250°F, which is equivalent to about 250 psi of steam
pressure. However, actual cycle times for gravity systems are usually
about 60 to 90 minutes (per load) in order to allow for full steam
penetration into the most densely packed waste loads. Other designs
using vacuum pumps to evacuate air from the chamber, termed pre-vacuum
systems, have more rapid and efficient steam penetration. Therefore,
cycle times for pre-vacuum systems range from only about 30 to 60
minutes (per load).
Retort type autoclave systems, basically comprise large volume chambers
designed for high steam pressures, and hence, minimal cycle times. At
least one commercial disposal firm on the west coast uses retort
autoclaves for treating infectious waste.
A unique, autoclave system variation features a combination, integral
pre-vacuum sterilizer and general waste compactor. After the
autoclave cycle is completed, sterilized infectious waste is
automatically ejected into the trash compactor section. All treated
waste and trash is then compacted into a close-coupled, roll-off type
container for off-site disposal.
Two types of packaging are viable for autoclaving infectious waste as
follows:
Heat-resistant autoclavable bags, typically made of polypropylene
plastic, which are sturdy and will not melt at steam
temperatures. This type of bag needs to be opened prior to
autoclaving to allow steam penetration into the waste.
Heat-sensitive, low-density polyethylene bags which will melt at
steam temperatures. Such melting facilitates steam penetration
and air evacuation. The use of these bags requires secondary
containment to prevent spillage of waste from the melted bags.
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In order to assure that the autoclave systems are Loaded, operated and
maintained properly, temperature probes and frequent biological
challenging are required. Biological challenging involves the
insertion of heat resistant spore samples (such as bacillus
stearothermophillus) into worst-case waste loads in order to monitor
and verify sterilization efficiencies. Some states have imposed
stringent requirements for such challenging and monitoring.
The principal advantages of steam sterilizations systems include low
capital and operating costs, relatively small space requirements and
simplicity of operations.
The principal disadvantages of steam sterilization systems are that
they have relatively limited capacity, may require special waste
packaging and handling and need special provisions to prevent odor and
drainage problems. Autoclaving is not recommended or suitable for all
wastes, including pathological waste, such as carcasses and body
parts, high liquid content waste, such as bulk fluids and blood, and
waste contaminated with volatile chemicals, such as chemotherapy
waste.
A potentially serious problem of using autoclaves to treat infectious
waste is that of disposing of the treated waste. After autoclaving,
waste appearances are basically unchanged, and color-coded bags and
international biohazard symbols remain intact and visible. Needles,
syringes, IV tubing, red colored and blood stained waste items and the
like may be totally sterile, but are still recognizable and possibly
not acceptable for disposal with general waste. Compacting autoclaved
infectious waste tends to break open waste bags and other containers
and expose and spill their contents. Consequently, waste haulers and
landfill operators may not accept autoclaved waste even if they are
proven to be sterilized.
2. Shredding with Chlorination
Within the last few years, a technology featuring a combination of
shredding and chemical sterilization has been widely promoted by a
midwestern firm. Two models are available. One is designed for
relatively small and limited quantities of laboratory waste and
sharps. The other is a relatively large capacity system designed for
treating almost all infectious waste generated in a hospital.
With the large capacity system, waste is manually loaded onto an
inclined, conveyor belt which feeds a high-torque, low-speed shredder.
Waste is discharged from the bottom of this shredder into a high-speed
hammermill which granulates the waste. During both shredding stages,
waste is continuously sprayed and saturated with sodium hypochlorite
solution. An inclined, perforated conveyor at the discharge of the
hammermill separates the granulated waste, or debris, from the excess
liquids, or slurry. The slurry is collected in a basin and piped to a
sewer drain, and the solids are discharged into a cart where they are
retained for off-site disposal. Reportedly, sodium hypochlorite
contact time in the system and cart is sufficient for sterilization.
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The sodium hypochlorite can be generated on site in an electrolysis
process from water and salt pellets, or it can be purchased in bulk
quantities. The standard, or base, generator furnished with the
system requires about 24 hours to generate sufficient sodium
hypochlorite solution for about 90 minutes of operation.
To prevent airborne contamination from the process, a blower draws air
from the discharge hoods of the feed and debris conveyors and
maintains a negative pressure on the entire system. The air passes
through a series of prefilters and a (chlorine resistant) HEPA filter
before being discharged to atmosphere.
The principal advantages of shredding/chlorination systems are that
they are relatively simple, provide a substantial volume reduction,
alter the waste appearance and form such that all items are
unrecognizable and are suitable for most types and forms of infectious
waste, except pathological remains. Hourly processing capacity is
about 800 to 1,000 pounds, but it reportedly can be as high as 2,000
pounds. Daily throughput is a function of system sodium hypochlorite
generation capacity or purchase. Waste volume reduction is estimated
to be about 5 to 1, but it reportedly can be as high as about 8 to 1.
The principal disadvantages of shredding/chlorination systems are that
they have relatively high costs, relatively limited throughput
capacities and potential problems with slurry contaminants, workplace
chlorine concentrations and noise levels. A standard, large capacity
system can cost as much as a small to medium capacity incineration
system. The slurry discharged to sewer may have concentrations of
metals, organics and other contaminants such that a discharge permit may
be required. In addition, special precautions may be needed to assure
compliance with occupational workplace standards and requirements.
Another important consideration is that shredding/chlorination
systems are currently only offered by a single manufacturer, and only
a single, large capacity, operational system is currently in
existence. This larger system is installed at a midwestern hospital
which incinerates most of its waste on-site. However, it has been
reported that two large capacity systems have been purchased by the
Ontario Ministry of the Environment for demonstration purposes. Also,
it should be noted, that there are several, reportedly successful small
capacity systems in operation.
3. Incineration
Incineration is basically a process using controlled, high temperature
combustion to destroy organics in waste materials. Modern
incineration systems are well engineered, proven, high technology
processes designed to maximize combustion efficiencies and
completeness with minimum emissions.
There are four basic hospital/institutional waste incineration
technologies suitable for disposing of infectious waste. These are as
follows:
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1. Multiple-Chamber Incinerators
This technology was developed in the mid-1950's and it was
virtually the exclusive type of hospital/institutional waste
incineration system installed through the mid-I9601s. This type
of system is also termed Incinerator Institute of America, or
IIA, technology. Multiple-chamber incineration processes are
designed for very high excess-air levels and have settling
chambers in order to control combustion and help limit emissions.
However, virtually all of these systems need air pollution
control devices in order to comply with emission regulations. In
addition, they cannot meet the current performance and operating
requirements in many states without substantial upgrading and the
addition of state-of-art combustion control equipment.
Very few multiple-chamber incinerators are being built today, but
almost all of the existing incinerators that are more then 25
years old are of this type. The smaller capacity systems feature
solid hearths which were strictly designed for burning
pathological waste. Many hospitals have attempted to use these
small capacity, solid hearth pathological incinerator systems for
burning infectious waste. However, severe operating and emission
problems usually result from this type of misoperation. Some of
the other larger capacity, multiple-chamber units were built with
grates in the solid waste (primary) burning chamber. When
infectious waste is burned in these systems, uncombusted waste
materials fall through the grates into the ash pit. Operators
are exposed to potential hazards when cleaning infectious items
and sharps from the ash pits under the grates.
2. Rotary Kiln Incinerators
A rotary kiln incinerator basically features a cylindrical,
refractory-lined, combustion chamber which rotates on a slightly
inclined, horizontal axis. Waste is loaded at one end of the
kiln, and the rotation moves the waste slowly towards the
opposite end where it is discharged as ash. The kiln rotation
helps promote good burnout and a superior ash quality. Rotary
kiln systems require secondary combustion chambers and air
pollution control equipment in order to comply with emission
regulations.
Rotary kiln incinerators are widely used in industrial
applications for burning hazardous waste. This is largely
because the technology is very versatile and suitable for most
types and forms of waste, including solids, sludges, liquids and
even fumes. Within the last few years, these systems have been
widely promoted for burning hospital waste. However, today there
are only about half-dozen rotary kiln incinerators installed in
hospitals and similar institutions across the country.
One of the reasons why there are so few rotary kilns
installations at hospitals is that they have relatively high
capital and operating costs. For comparable capacities, they are
roughly twice as costly as other institutional waste incineration
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technologies. Rotary kilns also have relatively high maintenance
and repair requirements because of the abrasive and scraping
effects of waste being tumbled and dragged along the refractory
lining of the kiln as it rotates.
Another potentially major problem with using rotary kilns for
incinerating infectious waste on-site is that, in most
applications, the waste is required to be processed as it is
being loaded. This is usually accomplished with a special type
of loader, termed an "auger feeder," which uses a teethed, screw
mechanism, that shreds, crushes and extrudes waste into the
kiln. Such processing spills and disperses the contents of
infectious waste bags and containers within the feeding
mechanism, thus creating potential maintenance and clean-up
hazards.
3. Controlled Air Incinerators
This is also commonly called modular combustion and starved air
incineration. Controlled air incineration is basically a two-
stage combustion process. Solid waste is burned in a starved
air, or reducing, environment in the first stage, or the primary
chamber. Combustion products and volatile gases generated from
the solid waste in the primary chamber are burned under excess
air conditions in the second stage, or secondary chamber.
The first controlled air incinerators were installed in this
country in about 1962. The technology was initially popular
because of its relatively low costs, but its popularity grew
quickly primarily because most systems could readily comply with
air pollution control regulations without needing emission
control equipment. On the order of 7 to 10 thousand controlled
air incinerators have been installed in the last twenty years,
and more than 95 percent of all the hospital/infectious waste
incinerators installed in the past 20 years have been this type
of system. It should be noted, however, that no controlled air
incinerators will be able to comply with the stringent emission
control regulations being legislated in many states without air
pollution control equipment.
4. Innovative Systems
This type of incineration technology includes a wide range of
"designs," "new" developments, unusual applications and avante
garde systems offered by various "progressive" manufacturers and
promoters. Although many such systems are continually being
"developed" and may appear promising on the surface, the majority
have never been demonstrated in actual operation. Some "designs"
are based upon reincarnations of old failures, and some defy the
laws of physics and thermodynamics. Anyone considering a new
technology or "innovative" system should understand that there is
a wide difference between an idea or conceptual schematic and a
proven application.
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An incineration system is an integration of various components of
which the incinerator proper is only a single element. All components must
be properly designed and coordinated to function with the other components
in order for the system to operate successfully. Incineration system
components include waste handling and loading systems, burners and blowers,
ash removal and handling systems, waste heat recovery systems, emission
control systems, breechings and stack systems and controls and
instrumentation.
There have been numerous developments over the last several years
which have improved incineration system operations and efficiencies. For
example, waste loaders have recently been developed for accepting larger
waste capacities. Some newer loader designs can hold as much as an hour's
worth of loading at one time. Burner and blower systems are available with
state-of-art controls and full-integration so as to minimize auxiliary fuel
usage and provide maximum combustion control during the full cycle of
system operations. Modern ash removal systems featuring backhoes and
scoops have been developed which appear to be more reliable and less
maintenance intensive than cart and drag type conveyor systems. Some
manufacturers have developed controls and instrumentation packages with
solid-state programmable controllers, graphic displays and even touch-
screens.
The addition of a waste heat recovery boiler to an incineration system
is not nearly as cost-effective as it was ten years ago; in fact, nowadays,
it is rare for a hospital/institutional waste incinerator to be justified
strictly on the basis of heat recovery benefits. On average, about 3 to 4
pounds of steam can be recovered for each pound of infectious waste
incinerated. However, at the higher operating temperatures required by
many states, about 5 to 6 pounds of steam can be recovered for each pound
of waste incinerated. Although such recovery rates are seldom sufficient
to provide a rapid return-on-investment for a total system, the addition of
a heat recovery system may have other advantages. For example,
incineration with heat recovery is usually considered more acceptable, or
less objectionable, to the general public than one without heat recovery.
Also, a heat recovery system may help to condition flue gases upstream of
an air pollution control system. Finally, energy grants may be available
for systems with heat recovery.
In many states, new legislation requires that hospital/infectious waste
incinerators be equipped with air pollution control systems and equipment
meeting "Best Available Controlled Technology," or BACT. Such systems are
very sophisticated and energy intensive as needed to achieve extremely
stringent particulate and acid gas, or hydrogen chloride (HCl), emission
levels. The most proven and widely used emission controls systems
applicable to hospital/infectious waste incinerators are high-energy
venturi scrubbers with packing sections, sub-coolers, mist eliminators,
caustic feeders (pH controllers) and water recirculation systems. Fired
reheaters are also available for eliminating visible steam plumes from the
stacks of systems with wet scrubbers.
There have been recent attempts to develop relatively small capacity
"dry" scrubbing systems which use baghouse filters and alkaline injectors
for combination high efficiency particulate removal and (moderately
efficient) acid gas removal. However, not only are such "dry" systems
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nearly twice as costly and space intensive as wet scrubber systems, but
also, to date, none have been used successfully on any on~ni.ta
hospital/infectious waste incineration system in the country. Nonetheless,
some state regulatory agencies are essentially requiring that such "dry"
systems be installed on all new infectious waste incinerators.
By and large, on-site incineration has emerged as the preferred, most
viable infectious waste treatment option for most hospitals and
institutions. From a technological standpoint, incineration offers several
major advantages as compared to other treatment technologies. More
importantly, it may be the only treatment method with a processing capacity
suitable for the infectious waste generation rates of most hospitals and
other institutions. Incineration not only sterilizes infectious waste but
also provides typical weight and volume reductions of 90 to 95 percent.
Incineration of total hospital waste minimizes many difficulties and
problems associated with the segregation of infectious waste. In addition,
it converts obnoxious waste, such as animal carcasses, to innocuous ash,
provides the potential for waste heat recovery and, in some cases, can be
used for simultaneously disposing of hazardous chemicals and low-level
radioactive waste.
On-site incineration attractiveness is also greatly enhanced by
various current and pending legislation. About half of the states and
several major cities currently mandate that infectious waste be treated on-
site, restrict its off-site transport and/or prohibit it from being
landfilled. Many additional states are planning similar, restrictive
legislative measures within the next few years. Virtually all states
either require, recommend or advocate incineration as the preferred method
for treating infectious waste. Furthermore, incineration is the only
treatment technique recommended in the U.S.EPA Guide for virtually all
designated infectious waste types.
Off-site disposal difficulties and limitations probably contribute the
'greatest incentives for many hospitals and other institutions to consider
or select on-site incineration as the preferred infectious waste treatment
method. It has become increasingly difficult, if not impossible, to locate
reliable, dependable infectious waste disposal service contractors. Many
hospitals able to obtain such services are literally required to transport
their infectious waste across the country to disposal facilities.
Furthermore, such services are typically very costly, if not prohibitive.
Off-site disposal contractors are typically charging from about $0.30 to
about $0.80 per pound of infectious waste, and some are charging as much as
$1.50 per pound. On the other hand the total, annual owning and operating
costs for hospital/infectious waste incinerators in states with even the
most stringent legislation range from about $0.05 to about $0.2 per pound
of waste incinerated. This is inclusive of system amortization costs,
utility costs, operating labor, ash disposal, testing and maintenance and
repair.
A major disadvantage of on-site incineration, compared to other
treatment technologies, are its high capital, operating and maintenance
costs. However, more importantly, regulatory restrictions, socio-political
opposition and related permitting difficulties have made on-site
incineration increasingly prohibitive, if not impossible, in more and more
sections of the country. In an effort to protect the environment and
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public welfare against potentially unacceptable emissions, an increasing
number of state and local pollution control agencies are enacting extremely
restrictive regulations and criteria for permitting and operating
infectious waste incinerators. Unfortunately, many such regulations appear
to have no technical basis, and they are often unrealistic and sometimes
unattainable.
It is likewise becoming more and more difficult, if not impossible,
for permit applicants to prove or otherwise demonstrate that properly
designed and operated incineration systems are environmentally benign and
pose no significant increased risks. The major reason for such
difficulties is public opposition. Issues such as fear, mistrust and the
"not-in-my-backyard" (NIMBY) syndrome cannot be effectively countered with
scientific data or logic. Consequently, since most regulatory agencies
tend to take a passive or neutral position at public hearings, an
increasing number of infectious waste incinerator permits are being denied
or indefinitely postponed.
Table 3 summarizes the major components of the three principal
treatment technologies, and Table 4 summarizes their comparative advantages
and disadvantages.
OFF-SITE TREATMENT AND DISPOSAL
There are basically only three options potentially available as an
alternative to on-site treatment. These are as follows:
1. Contract Disposal
This involves paying a fee to an independent, commercial firm to
transport and dispose of infectious waste at an off-site facility.
Almost all of the contractors use incineration for disposal. Some
contractors provide waste transport and incinerate at their own
facilities, and others only provide transport and use the incineration
facilities of another contractor. Some disposal contractors have
arrangements to use, or share, on-site incineration facilities at
various hospitals. Contract disposal rates are typically set at a
cost per pound or a cost per box basis. Contractors often furnish
packaging materials and boxes as part of their services. Some offer
refrigerated trucks for longer term, interim storage and transport.
2. Disposal at another Institution's Incinerator
Some hospitals have excess incineration capacity and offer disposal
services to other regional hospitals, clinics and medical facilities.
Such services are on a fee arrangement or shared cost basis which is
typically very competitive with contract disposal rates. Excess
incineration capacity at most hospitals is only incidental to their
existing operations, but at some hospitals it is a planned investment
opportunity.
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3. Disposal at a Regional Incineration Facility
A regional incineration facility, as opposed to a contractor owned
facility, is basically developed, owned and operated on behalf of and
under the control of an independent hospital group or
association. An association could develop, administrate and
finance such a facility through either a private developer
or through their own internal organization. The facility
could be either at a neutral site or at the site of a
membering hospital.
The advantages of off-site treatment and disposal include simplicity
and relatively short implementation time. It avoids problems and
uncertainties of siting and permitting an on-site treatment system.
Building space and associated support services are not required. In
addition, off-site treatment and disposal eliminates major capital
investment requirements for on-site treatment facilities.
As discussed, a major difficulty with off-site treatment and disposal
services in many parts of the country is locating reliable, reputable and
affordable contractors and facilities. At present, there is a severe
shortage of off-site incineration capacity on a national level. Most
existing, permitted facilities are operating at peak capacity. Some states
have moratoriums on new, off-site, contract incineration facilities, and,
in the other states contractors are finding it extremely difficult to site
and permit new facilities.
Despite potentially attractive economic incentives, most hospitals are
hesitant or reluctant to incinerate waste from other hospitals. They
appear to have major concerns as to potential liabilities and adverse
neighborhood reactions to such operations. Furthermore, there are few, if
any, operational regional incineration facilities. The implementation of
such facilities has also been stymied by siting and permitting problems.
Also, as discussed, another major disadvantage of off-site transport
and disposal, as compared to on-site treatment, are the high annual costs.
The costs for off-site, contract disposal are many times greater than those
for on-site incineration. The differential is such that many on-site,
hospital waste incineration systems realize payback periods of less than 2
years due to off-site disposal cost savings.
The Medical Waste Tracking Act of 1988 (Act) and comparable
legislation in many states also impose difficulties and additional,
increasing costs for the off-site disposal of infectious waste. Packaging,
manifesting and tracking requirements, as well as the severe penalties
associated with the violation of the requirements, are significant
deterrents to off-site disposal. It has been estimated that the costs for
many hospitals to administrate and adhere to the manifesting and tracking
requirements under the Act will be greater than those for incinerating
their infectious waste on-site. Civil penalties for noncompliance are as
much as $25,000 per violation, and criminal penalties are as much as
$50,000 and 5 years imprisonment per violation.
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A regional incineration facility, as compared to individual, on-site
incineration facilities, has the advantage of favorable economics,
centralized control and operations and the need to obtain only a single
permit. However, as noted, locating a site that can be permitted for
incinerating infectious waste with minimal public opposition is extremely
difficult and may be comparable to siting a nuclear power plant. In
addition, packaging, manifesting and tracking requirements could also have
a major impact on the hospitals using the regional facility, even if they
own and operate it.
The comparable advantages and disadvantages of the various off-site
treatment and disposal alternates are shown on Table 5.
A schematic of the infectious waste treatment and disposal
alternatives discussed above is shown on Figure 1.
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TABLE 3
PRINCIPAL INFECTIOUS WASTE TREATMENT SYSTEM COMPONENTS
AUTOCLAVING SYSTEM
SHREDDING/CHLORINATION SYSTEM
INCINERATION SYSTEM
tr\
I
Waste Transport/Treatment
Autoclavable Bags
Autoclave Chamber
Ventilation System
Container Dumper (Optional)
Biological/Temperature Indicators
Waste Feed Conveyor
Pre-Shredder
Hammermill
Debris Conveyor/Separator
HEPA Filtration System
Sodium Hypochlorite System
Waste Handling & Loading
Incinerator
Burners & Blowers
Ash Removal & Handling
Breeching, Blowers, Dampers & Stack(s)
Air Pollution Control
Waste Heat Recovery
Controls & Instrumentation
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TABLE 4
PRINCIPAL
TREATMENT TECHNOLOGIES
INFECTIOUS WASTE TREATMENT TECHNOLOGY COMPARI-SONS
ADVANTAGES
DISADVANTAGES
AUTOCLAVING
Low Costs
Low Space Requirements
Ease of Implementation
Simplicity of Operation
Limited Capacity
Not Suitable for all Wastes
Waste Handling System/Bags
Odor Control
Waste Volume Unchanged
Waste Appearance &
Form Unaltered
SHREDDING/CHLORINATION
i
to
-J
I
Substantial Volume Reduction
Suitable for Many Wastes
Relative Simplicity
Alters Waste Forms
Relatively High Costs
Manual Waste Handling
Limited Capacity
Liquid Effluent Contaminants
Room Noise & Chlorine Levels
Single Manufacturer
Limited Experience
INCINERATION
Disposes of Most Waste Types & Forms
Suitable for Large Volumes
Largest Weight & Volume Reductions
Sterilization & Detoxification
Heat Recovery
Relatively High costs
High M&R Requirements
Stack Emissions & Concerns
Permitting Difficulties
Public Opposition
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TABLE 5
OFF-SITE INFECTIOUS WASTE TREATMENT & DISPOSAL COMPARISONS
i
N)
CO
I
OFF-SITE DISPOSAL
Commercial Facility
Another Institution's
Incinerator
Regional Facility
ADVANTAGES
Negligible Capital Investment
Minimal (On-Site) Space Requirements
Simplicity
Short Implementation Time
Avoid On-Site Disposal Permitting
DISADVANTAGES
Locating Reliable & Reputable Firms
& Facilities
Potential Liabilities & Concerns
High Annual Costs
Special Packaging Requirements
Manifesting & Tracking
REGIONAL OR SHARED-SERVICE
INCINERATION FACILITY
(vs. Individual On-Site
Incinerators)
Favorable Economics
Single Permit
Centralized Operations
Siting & Permitting Difficulties
Special Packaging & Transport
Requirements
Manifesting & Tracking
"Hazardous" Designation (some states)
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FIGURE 1
INFECTIOUS WASTE TREATMENT & DISPOSAL ALTERNATIVES
WASTE CATEGORIES
I
IS)
(-
VO
INFECTIOUS WASTE
PATHOLOGICAL WASTE
PRINCIPAL ON-SITE
TREATMENT TECHNOLOGIES
AUTOCLAVING
SHREDDING/
CHLORINATION
INCINERATION (ASH)
OFF-SITE TRANSPORT
SPECIAL WASTE
HAULER/CONTRACTOR
GENERAL WASTE
HAULER
OFF-SITE TREATMENT
& DISPOSAL
CONTRACT DISPOSAL
SERVICES (COMMERICAL)
Incineration
Autoclavlng
ANOTHER INSTITUTION'S
INCINERATOR
REGIONAL INCINERATOR
Private Development
Cooperative Development
SANITARY LANDFILL
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EVALUATION AND SELECTION
Two steps are recommended for evaluating infectious waste treatment
and disposal options and alternatives or for planning a waste management
program. These are as follows:
1. Data Collection, Confirmation & Summary
The initial step is to compile and consolidate all data and
information necessary for identifying and evaluating the options and
alternatives. Such data typically include waste characterization and
quantification, waste handling practices and procedures, site
availability and constraints, utility availability, costs for labor,
utilities and off-site disposal and the latest regulatory
requirements. This also includes a review of in-house policies
regarding infectious waste management and disposal, particularly with
regard to the likelihood of their being revised in the near and long-term.
Waste characterization and quantification are the key parameters in
formulating a waste management and disposal plan and selecting the
best disposal alternative. The efforts required for collecting such
data can vary widely, ranging from the use of empirical factors and
approximations to the implementation of extensive waste weighing and
survey programs. Likewise, such survey programs can range widely in
complexity and scope. They require careful planning, organization and
coordination to obtain the needed data at minimum cost and effort.
2. Technical and Economic Evaluations
After all relevant data have been compiled and confirmed, this step
involves the identification and evaluation of all waste disposal
options and alternatives. A typical matrix of options would include
varying degrees of on-site treatment, different types of waste
treatment technologies and equipment, various potential treatment
system add-on features and redundancies. It would not be unusual for
a dozen or more viable options to be identified for any particular
facility.
Other factors which need to be considered include such parameters as
back-up capabilities and contingencies, future facility growth, future
waste generation scenarios, potential liabilities and public image.
The important disposal option variables are shown on Table 6.
It is important that the advantages, disadvantages and limitations of
the various on-site treatment technologies and off-site disposal options be
thoroughly understood. In short, these assessments provide the foundation
for ultimately selecting and implementing the best, most cost effective
alternative.
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TABLE 6
TYPICAL DISPOSAL OPTION VARIABLES
DEGREE OF ON-SITE TREATMENT
None
Selected
Maximum
ALTERNATE TECHNOLOGIES/COMBINATIONS
TREATMENT TECHNOLOGY OPTIONS/ADD-ONS
REDUNDANCY & BACK-UP
SITING
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SELECTED BIBLIOGRAPHY & REFERENCES
1. Centers for Disease Control, U.S. Dept. of Health & Human
Services, "Recommendations For Prevention of HIV
Transmission in Health-Care Settings," Morbidity and
Mortality Weekly Report, Vol. 36, August 21, 1987.
2. Cheremisinoff, P.N., Banerjee, K., Sterilization Systems,
Technical Publishing Co., 1985.
3. Centers for Disease Control, U.S. Dept. of Health & Human
Services, "Guideline for Handwashing & Hospital
Environmental Control, 1985," NTIS PB85-923404, 1985.
4. Doucet, L.G., "Hospital/Infectious Waste Incineration
Dilemmas & Resolutions," presented at the 1st National
Symposium on Incineration of Infectious Wastes, Washington,
D.C., May 6, 1988.
5. Doucet, L.G., "State-of-the-Art Hospital & Institutional
Waste Incineration: Selection, Procurement and Operations,"
presented at the 75th Annual Meeting of The Association of
Physical Plant Administrators of Universities and Colleges,
Washington, D.C., July 24, 1988.
6. Perkins, J.J., Principles and Methods of Sterilization in
Health Sciences, Published by Charles C. Thomas, 1983.
7. U.S.EPA, Guide For Infectious Waste Management, EPA 530-SW86-014,
NTIS PB86-199130, May 1986.
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STATE-OF-THE-ART HOSPITAL & INSTITUTIONAL WASTE
INCINERATION: SELECTION. PROCUREMENT AND OPERATIONS
Lawrence G. Doucet, P.E.
DOUCET & MAINKA, P.C.
Presented At The
75th Annual Meeting of
the Association of Physical Plant Administrators
of Universities and Colleges
Washington, D.C.
July 24, 1988
Revised, Updated and Issued as a
Technical Document (No. 055872)
Through the American Society for Hospital Engineering
January 1986
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STATE-OF-THE-ART HOSPITAL & INSTITUTIONAL WASTE INCINERATION:
SELECTION. PROCUREMENT AND OPERATIONS
BY
LAWRENCE G. DOUCET, P.E-
DOUCET & MAINKA, P-C.
INTRODUCTION
On-site Incineration is becoming an increasingly important alternative
for the treatment and disposal of institutional waste. Incineration re-
duces the weight and volume of most institutional solid waste by upwards of
90 to 95 percent, sterilizes pathogenic waste, detoxifies chemical waste,
converts obnoxious waste, such as animal carcasses, into innocuous ash and
also provides heat recovery benefits. At most institutions, these factors
provide a substantial reduction in off-site disposal costs such that on-site
incineration is highly cost-effective. Many systems have payback periods
of less than one year. In addition, on-site incineration reduces
dependence upon off-site disposal contractors which, in turn, minimizes
potential exposures and liabilities associated with Illegal or improper
waste disposal activities.
Clearly, the most important factor currently affecting the importance
of on-site incineration for healthcare organizations and research
institutions across the country relates to infectious waste management and
disposal. First of all, recent legislation and guidelines have dramati-
cally increased the quantities of institutional waste to be disposed as
"potentially infectious". For many institutions, particularly hospitals,
incineration is the only viable technology for processing the increased,
voluminous quantities of waste. Secondly, about half of the states and
several major cities currently mandate that Infectious waste be treated
on-site, restrict its off-site transport and/or prohibit it from being
landfilled. Many additional states are planning similar, restrictive
legislative measures within the next few years.
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Off-site disposal difficulties and limitations probably contribute the
greatest incentives for many healthcare and other institutions to consider
or select on-site incineration as the preferred infectious waste treatment
method. It has become increasingly difficult, if not impossible, to locate
reliable, dependable infectious waste disposal service contractors. Many
institutions able to obtain such services are literally required to trans-
port their infectious waste across the country to disposal facilities.
Furthermore, such services are typically very costly, if not prohibitive.
Off-site disposal contractors are typically charging from about $0.30 to
about $0.80 per pound of Infectious waste, and some are charging as much
as $1.50 per pound. For many hospitals and other institutions, this
equates to hundreds of thousands of dollars per year, and several are
paying in excess of a million dollars per year.
INCINERATION TECHNOLOGIES
Before the early 1960's, institutional incineration systems were
almost exclusively multiple-chamber types, designed and constructed
according to Incinerator Institute of America (IIA) Incinerator Standards.
Since these systems operated with high excess air levels, most required
scrubbers in order to comply with air pollution control standards.
Multiple-chamber type systems are occasionally Installed at modern facili-
ties, because they represent proven technology. However, the most widely
and extensively used incineration technology over the past 20 years is
"controlled air" Incineration. This has also been called "starved-air"
incineration, "two-stage" incineration, "modular" combustion and
"pyrolytic" combustion. More than 7,000 controlled air type systems have
been installed by approximately two dozen manufacturers over the past two
decades.
Controlled air incineration is generally the least costly solid waste
incineration technology - a factor that has undoubtedly influenced its
popularity. Most systems are offered as low cost, "pre-engineered" and
prefabricated units. Costly air pollution control equipment is seldom
required, except for compliance with some of the more current, highly
stringent emission regulations, and overall operating and maintenance
costs are usually less than for other comparable incineration technol-
ogies.
The first controlled air incinerators were installed in the late
1950's, and the first U.S. controlled air incinerator company was formed in
1964. The controlled air incineration Industry grew very slowly at first.
The technology received little recognition because it was considered
unproven and radically different from the established and widely accepted
IIA Incinerator Standards.
Approximately every five years the controlled air incineration
industry has gone through periods of rapid growth. In the late 1960's,
this was attributable to the Clean Air Acts, in the early and late 1970's
to the Arab Oil embargos, in the early I9601s to the enactment of hazardous
waste regulations, and, recently, to the enactment of infectious waste
disposal regulations. Dozens of "new" vendors and equipment suppliers
appeared on the scene during each of these growth periods. However,
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increased competition and rapid changes in the technology and market
structure forced most of the smaller and less progressive companies to
close. Generally, the controlled air incineration industry has been in a
state of almost constant development and change, with frequent turnovers,
mergers and company failures.
Today there are approximately a dozen listed "manufacturers" of
controlled air incinerators. However, only about half of these have es-
tablished successful track records with demonstrated capabilities and
qualifications for providing first-quality installations. In fact, some
of the "manufacturers" listed in the catalogs have yet to install their
first system, and a few are no more than brokers who buy and install
incinerator equipment manufactured by other firms.
Controlled air incineration is basically a two-stage combustion
process. Waste is fed into the first stage, or primary chamber, and
burned with less than stolchiometric air. Primary chamber combustion
reactions and turbulent velocities are maintained at very low levels to
minimize partlculate entrainment and carryover. This starved air burning
condition destroys most of the volatiles in the waste materials through
partial pyrolysis. Resultant smoke and pyrolytic products, along with
products of combustion, pass to the second stage, or secondary chamber.
Here, additional air is Injected to complete combustion, which can occur
either spontaneously or through the addition of auxiliary fuel. Primary
and secondary combustion air systems are usually automatically regulated,
or controlled, to maintain optimum burning conditions despite varying
waste loading rates, composition, and characteristics.
Rotary kiln type incineration systems have been widely promoted
within the past few years. A rotary kiln basically features a cylindrical,
refractory-lined combustion chamber which rotates slowly on a slightly
Inclined, horizontal axis. Kiln rotation provides excellent mixing, or
turbulence, of the solid waste fed at one-end - with high quality ashes
discharged at the opposite end. However, in general, rotary kiln systems
have relative high costs and maintenance requirements, and they usually
require size reduction, or shredding, in most institutional waste
applications. There are only a handful of rotary kiln applications in
hospitals and other institutions in the U.S. and Canada.
"Innovative" incineration technologies also frequently appear on the
scene. Some of such systems are no more than reincarnations of older
"failures", and others feature unusual applications and combinations of
ideas and equipment. Probably the best advice when evaluating or consid-
ering an innovative system is to first investigate whether or not any simi-
lar successful installations have been operating for a reasonable period of
time. Remember, so called innovative systems should still be designed and
constructed consistent with sound, proven principles and criteria.
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SIZING AND RATING
Classifications systems have been developed for commonly encountered
waste compositions. These systems identify "average" characteristics of
waste mixtures, including such properties as ash content, moisture, and
heating value. The classification system published in the HA Incinerator
Standards is the most widely recognized and is almost always used by the
incinerator manufacturers to rate their equipment. In this system, shown
in Figure 1, wastes are classified into seven types. Types 0 through 4
are mixtures of typical, general waste materials, and Types 5 and 6 are
industrial wastes requiring special analysis.
Primary Combustion Chambers
Heat Release Rates
Incinerator capacities are commonly rated as pounds of specific waste
types, usually Types 0 through 4, that can be burned per hour.
Incinerators usually have a different capacity rating for each type. For
example, an incinerator rated for 1,000 pounds per hour of Type 1 waste
may only be rated for about 750 pounds per hour of Type 0 waste or about
500 pounds per hour of Type 4 waste. Such rating variations exist because
primary chamber volumes are sized on the basis of internal heat release
rates, or heat concentrations. Typical design heat release values range
from about 15,000 to 25,000 Btu per cubic foot of volume per hour
(Btu/cu-ft/hr). In order to maintain design heat release rates, waste
burning capacities vary inversely with the waste heating values (Btu/lb).
As heating values increase less waste can be loaded.
Since Type 3 waste, food scraps, and Type 4 (pathological) waste have
heat contents of only 3,500 and 1,000 Btu per pound, respectively, it
might be assumed that even higher capacity ratings could be obtained for
these waste types. However, this is not the case. The auxiliary fuel
inputs required to vaporize and superheat the high moisture contents of
Types 3 and 4 wastes limits effective incineration capacities.
In essence, primary chamber heat release criterion establishes primary
chamber volume for a specific waste type and charging rate. Heat release
values are simply determined by multiplying burning rate (Ib/hr) by heating
value (Btu/lb) and dividing by primary volume (cu-ft).
Burning Rates
The primary chamber burning rate generally establishes burning
surface, or hearth area, in the primary chamber. It indicates the maximum
pounds of waste that should be burned per square foot of projected surface
area per hour (Ib/sq-ft/hr). Recommended maximum burning rates for var-
ious waste types are based upon empirical data, and are published in the
IIA Incinerator Standards. Figure 2 tabulates this criteria.
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Secondary Combustion Chambers
Secondary chambers are generally sized and designed to provide
sufficient time, temperature, and turbulence for complete destruction of
combustibles in the flue gases from the primary chamber. Unless specified
otherwise, secondary chamber design parameters are usually manufacturer
specific. Typical parameters Include:
Flue gas retention times ranging from 0.25 seconds to at least 2.0
seconds.
Combustion temperatures ranging from 1,400°F to as high as 2,200°F.
Turbulent mixing of flue gases and secondary combustion air through
the use of high velocity, tangential air Injectors, Internal air
injectors, abrupt changes in gas flow directions, or refractory
orifices, baffles, internal injectors and checkerwork in the gas flow
passages.
Retention times, temperatures, and turbulence are interdependent. For
example, secondary chambers that are specially designed for maximum
turbulence but that have relatively short retention times may perform as
well as other designs with longer retention times but less effective
turbulence. On many applications, increased operating temperatures may
allow for decreased retention times, or vice versa, without significantly
affecting performance. Regulatory standards and guidelines often dictate
secondary chamber retention time and temperature requirements.
. Flue gas retention time (sec) is determined by dividing secondary
chamber volume (cu-ft) by the volumetric flue gas flow rate (cu-ft/sec).
Flue gas flow rates are basically a function of waste type, combustion air
quantities and operating temperatures. They can be calculated or measured.
However, during normal Incinerator operations, flue gas flow rates vary
widely and frequently.
Shapes & Configurations
Primary and secondary chamber shapes and configurations are generally
not critical as long as heat release rates, retention time, and air
distribution requirement are satisfactory. Chamber geometry is most*'
affected by the fabrication and transport considerations of the equipment
manufacturers. Although some primary and secondary chambers are
rectangular or box-like, most are cylindrical.
Controlled air incinerators with a capacity of less than about 500
pounds per hour are usually vertically oriented, with primary and secondary
chambers Integral, or combined, within a single casing. Larger capacity
controlled air incinerators are usually horizontally oriented and have non-
integral, or separated, primary and secondary chambers. A few controlled
air Incinerator manufacturers offer systems with a third stage, or tertiary
chamber, following the second stage. One manufacturer offers a fourth
stage, termed a "reburn tunnel," which is primarily used to condition flue
gases upstream of a heat recovery boiler.
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Most manufacturer "variations" are attempts to improve efficiency and
performance. However, some of these may be no more than "gimmicks" that
offer no advantages or improvements over standard, conventional systems.
Adherence to proper design fundamentals, coupled with good operations, are
the overall keys to the success of any system. Acceptance of unproven
variations or design deviations is usually risky.
SELECTION AND DESIGN FACTORS
Highly accurate waste characterization and quantification data are not
always required for selecting and designing incineration systems. However,
vague or incomplete data can be very misleading and result in serious
problems.
Waste characterization involves identification of individual waste
constituents, relevant physical and chemical properties and presence of any
hazardous materials. A number of terms commonly used to characterize waste
can be very misleading when used in specifications. As examples, vague
terms such as "general waste," "trash," "biological waste," "infectious
waste" and "solid waste" provide little information about the waste
materials. An incineration system designed for waste simply specified as
"general" waste would probably be inadequate if waste contained high
concentrations of plastics. Likewise, the term "pathological" waste is
frequently, but incorrectly, used to include an assortment of materials,
including not only animal carcasses but also cage waste, laboratory vials
and biomedlcal waste items of all types. "Pathological" incinerators are
usually specifically designed for burning animal carcasses, tissues and
similar types of organic wastes. Unless the presence of other materials is
clearly specified, resultant burning capacities may be inadequate for waste
streams to be incinerated.
Waste characterization can range from simple approximations to complex
and costly sampling and analytical programs. As discussed, the most fre-
quently used approximation method is to categorize "average" waste mixtures
into the five IIA classes, Types 0 through 4. The popularity of this waste
classification system is enhanced by the fact that most of the incinerator
manufacturers rate their equipment in terms of these waste types. However,
it should be noted that actual "average" waste mixtures rarely have the
exact characteristics delineated for any of these indicated waste "types".
The other end of the characterization spectrum Involves sampling and
analysis of specific "representative", waste samples or items in order to
determine "exact" heating values, moisture content, ash content and the
like. This approach is not generally recommended because it is too costly
and provides no significant benefit over other acceptable approximation
methods.
Virtually all components found in typical institutional type solid
waste have been sufficiently well characterized in various engineering
textbooks, handbooks and other technical publications. An example is
presented in Figure 3. In many cases, a reasonably accurate compositional
analysis of the waste stream, in conjunction with such published data and
information, could provide reliable and useful characterization data.
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A key factor is that Incineration systems must be designed to handle
the entire range of the waste stream properties and characteristics, not
just the "averages." System capacity and performance may be inadequate if
the waste data does not indicate such ranges.
Capacity Determination
One of the primary criteria for selecting incineration system capacity
is the quantity of waste to be incinerated. Such data should include not
only average waste generation rates, but also peak rates and fluctuation
cycles. The most accurate method of determining such data is a comprehen-
sive weighing program over a period of about two weeks. However, the most
common procedure has been to estimate waste quantities from the number and
volume of waste containers hauled off-site to land disposal. Large errors
have resulted from such estimates because of failures to account for
container compaction densities or from faulty assumptions that the waste
containers were always fully loaded.
Three major variables affect the selection of incineration system
capacity, or hourly burning rate: waste generation rates; waste types,
forms, and sizes; and operating hours.
The quantity of waste to be Incinerated is usually the primary basis
for selecting system capacities. When waste generation rates are grossly
underestimated, incineration capacity may be Inadequate for the planned, or
available, periods of operation. In such cases, the tendency is to over-
load the system, and operational problems ensue. On the other hand,
grossly overestimating waste generation rates can be equally bad. Since
incineration systems must be operated near their rated, or design, capaci-
ties for good performance, an oversized system must be operated less hours
per day than may have been anticipated. Such reduced operating hours
could cause difficult problems with waste handling operations, particularly
if waste storage areas are marginal. Furthermore, if waste heat recovery
is necessary to justify system economics, insufficient waste quantities
could be a serious problem.
Since incinerators are primarily sized according to heat release
rates, waste heating value is a fundamental determinant of capacity.
However, the physical form, or consistency, of waste may have a more
significant impact on burning capacities. For example, densely packed
papers, books, catalogs and the like, may have an effective incinerabillty
factor of only about 20 percent compared to burning loosely packed paper.
Likewise, animal bedding, or cage waste, typically has high.ash formation
tendencies that may reduce burning rates by as much as 50 percent.
Furthermore, highly volatile wastes, such as plastics and containers of
flammable solvents, may require burning rate reductions of as much as 65
percent to prevent smoking problems.
The physical size of individual waste items and containers is also an
Important factor in the selection of incineration capacity. One rule-of-
thumb is that an average Incinerator waste load, or largest item, should
weigh approximately 10 percent of rated, hourly system capacity. On this
basis, a minimum 300 pounds per hour Incinerator would be required for,
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say, Type 1 waste packaged in up to about 30 pound containers or bags.
This capacity would be required regardless of the total daily quantity of
Type 1 waste requiring incineration.
A typical daily operating cycle for a controlled air incinerator
without automatic ash removal is as follows:
Operating Steps Typical Durations
Clean-out 15 - 30 minutes
Preheat 15 - 60 minutes
Waste loading 12 - 14 hours
Burn-down 2-4 hours
Cool-down 5 - 8 hours
It is important to note that waste loading for systems with manual
clean-out is typically limited to a maximum of 12 to 14 hours per operating
day.
Burning Rate vs. Charging Rate
When evaluating incineration equipment, it is important to distinguish
between the terms "burning or combustion rate" and "charging or loading
rate." Manufacturers may rate their equipment or submit proposals using
either term. "Burning rate" refers to the amount of waste that can be
burned or consumed per hour, while "charging rate" is the amount of waste
that can be loaded into the incinerator per hour. For systems operating
less that 24 hours per day, "charging rates" typically exceed "burning
rates" by as much as 20 percent. Obviously, failure to recognize this
difference could lead to selecting a system of inadequate capacity.
INCINERATOR SYSTEM AUXILIARIES
The incinerator proper is only a single component in a typical
incineration "system." Other components, or sub-systems, which require
equal attention in the design and procurement process, include:
Waste handling and loading systems
Burners and blowers
Residue, or ash, removal and handling systems
Waste heat recovery boiler systems
Emission control systems
Breeching, stacks and dampers
Controls and instrumentation
Features of the major sub-systems are as follows:
Waste Handling and Loading Systems
Incinerators with capacities less than about 200 pounds per hour are
usually available only with manual loading capabilities. Manual loading .
entails charging waste directly into the primary chamber without the aid of
a mechanical system. Units with capacities in the 200 to 500 pound per
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hour range are usually available with mechanical loaders as a special
option. Mechanical loaders are standardly available for most incinerators
with capacities of more than about 500 pounds per hour.
The primary advantage of mechanical loaders is that they provide
personnel and fire safety by preventing heat, flames and combustion
products from escaping the incinerator. In addition, mechanical loading
systems prevent, or limit ambient air Infiltration into the incinerator.
In most cases, air infiltration affects combustion conditions and, if
excessive, substantially lowers furnace temperatures and causes smoking at
the stack and into charging room areas. Infiltration also Increases
auxiliary fuel usage and usually accelerates refractory deterioration.
Several states have recently enacted regulations requiring mechanical
loaders on all institutional waste Incinerators.
Mechanical loaders enable incinerators to be charged with relatively
small batches of waste at regulated time intervals. Such charging is
desirable because it provides relatively stabilized combustion conditions
and approximates steady-state operations. Limiting waste batch sizes and
loading cycles also helps protect against over-charging and resultant
operating problems.
The development of safe, reliable mechanical loaders has been a major
step toward modernizing institutional waste incineration technology. The
earliest incinerators were restricted to manual charging, which limited
their capacities and applications. Of the loader designs currently
available, most manufacturers use the hopper/ram system. With this system,
waste is loaded into a charging hopper, a hopper cover closes, a primary
chamber fire-door opens and a charging ram then pushes the waste into the
primary chamber.
Hopper/ram systems are available with charging hopper volumes ranging
from several cubic-feet to nearly 10 cubic yards. The selection of proper
hopper volume is a function of waste type, waste container size, method
of loading the hopper and incinerator capacity. An undersized hopper
could result in spillage during waste loadings, an inability to handle
bulky waste items, such as empty boxes, or the inability to charge the
incinerator at rated capacity. On the other hand, an oversized hopper
could result in frequent incinerator overcharging and associated opera-
tional problems.
A few manufacturers have recently developed mechanical loader systems
which are capable of accepting as much as an hour's worth of waste loading
at one time. These systems use internal rams to charge the primary chamber
at intervals, as well as to prevent hopper bridging. Although these
systems have had reportedly good success, they are still generally in the
developmental stage.
One particular rotary kiln manufacturer uses an integral shredder at
the bottom of the waste feed hopper. This system is termed an "auger
feeder". It basically serves to process waste into a size that is com-
patible with the kiln dimensions.
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With small capacity incinerators, less than about 500 pounds per hour,
waste is usually loaded manually, bag by bag, into the charging hopper.
Larger capacity systems frequently employ waste handling devices such as
conveyors, cart dumpers and, sometimes, skid-steer tractors to charge waste
into the hopper. Pneumatic waste transport systems have been used to feed
incinerator loading hoppers at a few institutions, but these have limited
success.
A cart-dumper loader basically combines a standard hopper/ram system
with a device for lifting and dumping waste carts into the loading hopper.
Several manufacturers offer these as Integrated units. Cart dumpers can
also be procured separately from several suppliers and adapted or retro-
fitted to almost any hopper/ram system. Cart-dumper loader systems have
become increasingly popular because using standard, conventional waste
carts for incinerator loading reduces extra waste handling efforts and
often eliminates the need for intermediate storage containers and
additional waste handling equipment.
Most modern hopper/ram assemblies are equipped with a water system to
quench the face of the charging ram face after each loading cycle. This
prevents the ram face from overheating due to constant, direct exposures to
high furnace temperatures during waste injection. Without such cooling,
plastic waste bags or similar materials could melt and adhere to the hot
ram face. If these items did not drop from the ram during its stoking
cycle, they could ignite and be carried back into the charging hopper,
where they could ignite other waste remaining in the hopper or new waste
loaded into the hopper. For additional protection against such possible
occurrences, loading systems can also be equipped with hopper flame
scanners and alarms, hopper fire spray systems and/or an emergency switch
to override the normal charging cycle timers and cause Immediate injection
of hopper contents into the incinerator.
Residue Removal and Handling Systems
Residue, or ash, removal has always been a particular problem for
institutional type incineration systems. Most small capacity incinerators
(less than about 500 pounds per hour) and most controlled air units
designed and installed before the mid-19701s, must be cleaned manually.
Operators must rake and shovel ashes from the primary chamber into outside
containers. Small capacity units can be cleaned from the outside, but
large capacity units often require operators to enter the primary chamber
to clean ashes. The practice of manual clean-out is especially
objectionable from many aspects, including:
Difficult labor requirements.
Hazards to operating personnel because of exposures to hot furnace
walls, pockets of glowing ashes, flaming materials, airborne dusts and
noxious gases.
Daily cool-down and start-up cycling requirements which substantially-
increase auxiliary fuel usage and reduce available charging time.
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Detrimental effects of thermal cycling on furnace refractories.
Severe aesthetic, environmental and fire safety problems when handling
hot, unquenched ashes outside the incinerator.
Possible regulatory restrictions
In multiple-chamber incinerators, automatic ash removal systems usu-
ally feature mechanical grates, or stokers. In rotary kiln systems, ash
removal is accomplished via the kiln rotation. However, automatic,
continuous ash removal has historically been difficult to achieve in
controlled air systems which have conventionally featured stationary, or
fixed, hearths.
Early attempts at automatic ash removal in controlled air incinerators
employed a "bomb-bay" door concept. With these systems, the bottom of the
primary chamber would swing open to drop ashes Into a container or vehicle
located below. Serious operating problems led to the discontinuance of
these systems. More recent automatic ash removal systems use rams or
plungers to "push" a mass of residue through the primary chamber and out a
discharge door on a batch basis. Most of these systems have had only
limited success.
Controlled air incinerator automatic ash removal systems that have
shown the most promise use the waste charging ram of the hopper/ram system
to force waste and ash residues through the primary chamber to an internal
discharge, or drop, chute for removal. Although charging rams usually
extend no more than about 12 to 18 inches into the furnace during loading,
this is sufficient to move materials across the primary chamber via the
repetitive, positive-displacement actions of the ram. With proper design
and operations, the waste should be fully reduced to ash by the time it
reaches the drop chute. For incinerators with capacities greater than
about 800 to 1000 pounds per hour, internal transfer rams are usually
provided to help convey ashes through the furnace to the drop chute.
Transfer rams are necessary because the ash displacement capabilities of
charging rams are typically limited to a maximum length of about 8 feet.
Primary chambers longer than about 16 feet usually have two or more sets of
internal transfer rams.
The most innovative residue removal system uses a "pulse hearth" to
transfer ashes through the Incinerator. The entire floor of the primary
chamber is suspended on cables and pulses intermittently via sets of end-
mounted air cushions. The pulsations cause ash movement across the chamber
and toward the drop chute.
After the ashes drop from the primary chamber through the discharge
chute, there are two basic methods, other than manual, for collecting and
transporting them from the incinerator. The first is a semi-automatic
system using ash collection carts positioned within an air-sealed enclosure
beneath the drop chute. A door or seal gate at the bottom of the chute
opens cyclically to drop ashes into ash carts. Falling ashes are sprayed .
with water for dust suppression and a minor quenching. Because of weight
considerations, ash cart volumes are usually limited to about one cubic-
yard.
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Loaded ash carts are manually removed from the ash drop enclosure and
replaced with empty carts. After the removed carts are stored on-site long
enough for the hot ashes to cool, they are either emptied Into a larger
container for off-site disposal or are brought directly to the landfill and
dumped. Adequate design and proper care are needed when dumping ashes into
larger on-site containers to avoid severe dusting problems. In addition,
some ashes could still be hot and may tend to Ignite when exposed to
ambient air during the dumping operations.
The second method of ash removal is a fully automatic system using a
water quench trough and ash conveyor that continuously and automatically
transports wet ashes from the quench trough to a container or vehicle.
With these systems, the discharge chute terminates below water level in a
quench trough in order to maintain a constant air seal on the primary
chamber. Most manufacturers use drag, or flight, type conveyors, but a few
offer "backhoe" or "scoop" type designs to batch grab ashes from the quench
trough. The important factor is that the selected ash conveyor system be
of proven design and of heavy-duty construction for the severe services of
ash handling.
Waste Heat Recovery
In most incineration systems, heat recovery is accomplished by drawing
the flue gases through a waste heat boiler to generate steam or hot water.
Most manufacturers use conventional firetube type boilers for reasons of
simplicity and low costs. Both single and multi-pass firetube boilers have
been used successfully at many installations. Several facilities Incorpor-
ate supplemental fuel-fired waste heat boilers so that steam can be gener-
ated when the incinerator is not operating. Also, automatic soot blowing
systems'are being installed on an increasing number of firetube boilers, in
order to increase on-line time and recovery efficiencies.
One manufacturer uses single-drum, watertube type waste heat boilers
on incineration systems. Watertube boilers are also used by other
manufacturers on installations where high steam pressures and flow rates
are required. Another manufacturer offers heat recovery systems with
waterwall, or radiant sections, in the primary chamber. These waterwall
sections, which are usually installed in series with a convective type
waste heat boiler, can increase overall heat recovery efficiencies by as
much as 10 to 15 percent.
Many incinerator manufacturers typically "claim" system heat recovery
efficiencies for their equipment ranging from 60 to as high as 80 percent.
However, studies and EPA-sponsored testing programs have shown that real-
istic heat recovery efficiencies are typically on the order of 50 to 60
percent. The amount of energy, or steam, that can be recovered is
basically a function of flue gas mass flow rates and inlet and outlet
temperatures. Depending on boiler type and design, gas inlet temperatures
are usually limited to a maximum of 2,200°F. Outlet temperatures are
limited to the dewpoint temperature of the flue gases in order to prevent
condensation and corrosion of heat exchanger surfaces. Depending upon flue
gas constituents, incinerator dewpoint temperatures are usually on the
order of 400"F.
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For estimating purposes, about 3 to 4 pounds of steam can be recovered
for each pound of typical institutional type solid waste incinerated.
However, the economic feasibilities of providing a waste heat recovery
system usually depend upon the ability to use the recovered energy. If
only half of recovered steam can be used because of low seasonal steam
demands, heat recovery may not be cost-effective.
Some controlled air incinerator manufacturers offer air preheating, or
"economizer packages," with their units. These primarily consist of metal
jacketing, or shrouds, around sections of the primary or secondary chambers.
Combustion air is heated by as much as several hundred degrees when pulled
through the shrouds by combustion air blowers. This preheating can reduce
auxiliary fuel usage by as much as 10 to 15 percent. In addition, the
shrouding on some systems also helps limit incinerator skin, temperatures
to within OSHA limits.
For safety and normal plant shutdown, waste heat boilers are equipped
with systems to divert flue gases away from the boiler and directly to a
stack. One such system comprises an abort, or dump, stack upstream of the
boiler. Another system includes a bypass breeching connection between the
incinerator and stack. Modern, well-designed bypass systems are equipped
with isolation dampers either in the dump stack or in the bypass breeching
section. In systems without isolation dampers, either hot flue gases can
bypass the boiler or ambient air can dilute gases to the boiler. Because
of these factors, boiler isolation dampers may improve overall heat
recovery efficiencies by at least 5 percent.
Chemical Waste Incineration
An increasing number of institutions are disposing of chemical waste
in their incineration systems. Incinerated chemicals are usually flammable
waste solvents that are burned as fuels with solid waste. A simple method
of firing solvents has been to inject them through an atomizer nozzle into
the flame of an auxiliary fuel burner. Larger capacity and better designed
systems use special, packaged burners to fire waste solvents. Such burners
are either dedicated exclusively for waste solvent firing or have capabili-
ties for switching to fuel oil firing when waste solvents are not available.
Waste solvent firing is usually limited to the primary chamber In order to
assist in the burning of solid wastes and to maximize retention time by
fully utilizing secondary chamber volumes. Injectors and burners must be
located and positioned so as not to have impingement on furnace walls or
other burners. Such impingement results in poor combustion and often
causes emission problems.
Chemical waste incineration systems must also include properly
designed chemical waste handling systems. These include a receiving and
unloading station, a storage tank, a pump set to feed the injector or
burner, appropriate diking and spill protection, monitoring and safety
protection devices. Most of these components must be enclosed within a
separate, fire-rated room that is specially ventilated and equipped with
explosion-proof electrical fixtures.
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When transporting, storing and burning chemical waste, local, state
and federal hazardous waste regulations must be followed. If the Incin-
erated waste is regulated as a "hazardous waste," very costly trial burn
testing, (Part B) permitting and monitoring equipment are required. In
addition, obtaining the permits could delay starting a new facility by as
much as 12 to 18 months. Incinerators burning chemical solvents which are
only hazardous due to "ignitability" are not likely to be considered
"hazardous waste incinerators," and the costly and lengthy hazardous waste
incinerator permitting process is avoided. However, the storage and
handling of these solvents will likely require a hazardous waste (Fart B)
permit.
At many institutions, bottles and vials of chemical wastes are often
mixed with solid waste for Incineration. If the quantities, or concentra-
tions, of such containers and chemicals are very small with respect to the
solid waste, incinerator operations may be unaffected. However, whenever
solid waste loads are mixed with excessive concentrations of chemical con-
tainers, serious operating problems are likely, including rapid, uncon-
trolled combustion and volatilization resulting in heavy smoke emissions
and potentially damaging temperature excursions. In addition, glass vials
and containers tend to melt and form slag that can damage refractory and
plug air supply ports.
Emission Control Systems
In general, only controlled air incinerators are capable of meeting
the stringent emission standard of 0.08 grains of particulate per dry
standard cubic foot of flue gas (gr/DSCF), corrected to 12 percent carbon
dioxide, without emission control equipment. However, no incineration
systems can meet the emission limits being recently enacted by many states
which require compliance with Best Available Control Technology (BACT)
levels. The BACT particulate level identified by many of the states is
0.015 gr/DSCF, corrected to 12 percent carbon dioxide. However, this is a
controversial level which is being challenged by some in that it is only
applicable to municipal waste incineration technology. Compliance with a
0.015 level will likely require a very high pressure drop, energy inten-
sive, venturi scrubber system. Although "dry scrubbers," which comprise
alkaline injection into the flue gas stream upstream of a baghouse filter,
may also achieve a 0.015 level, as of this writing, this technology has
yet to be demonstrated on an institutional waste incineration system.
Most institutional solid waste streams, particularly hospitals,
include significant concentrations of polyvinyl chloride (PVC) plastics.
Upon combustion, PVC plastics break down and form hydrogen, chloride (HC1)
gas. The condensation of HC1 gases results in the formation of highly
corrosive hydrochloric acid. Therefore, flue gas handling systems, and
particularly waste heat boilers, must be designed and operated above the
dewpoint of the flue gases. Protection of scrubbing systems typically
includes the provision of an acid neutralization system on the scrubber
water circuitry and the use of acid resistant components and materials.
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Some states have identified BACT for HC1 emissions as either 90
percent removal efficiency or 30 to 50 PPM, by volume, in the exhaust
gases. For most well-designed wet scrubbers, 99 percent removal effi-
ciencies are readily achievable. With respect to minimizing emissions of
products of incomplete combustion (PIC's), such as carbon monoxide and even
dioxins and furans, the keys are proper furnace sizing, good combustion
controls designed to accommodate varying waste compositions and charging
rates, good operations and proper care and adjustment of system components.
Inadequacies in any of these could result in objectionable emissions.
INCINERATION PERFORMANCE AND PROCUREMENT
Success Rates
Incineration is considered proven technology in that a great many
systems readily comply with stringent environmental regulations and per-
formance requirements. Properly designed and operated incineration
systems provide "good" performance if they satisfy specific user objectives
in terms of burning capacity, or throughput, burnout, or destruction, en-
vironmental Integrity and on-line reliability. However, many incineration
systems of both newer and older designs perform poorly. Performance
problems range from minor nuisances to major disabilities, and needed
corrective measures range from simple adjustments to major modifications or
even total abandonment. Furthermore, performance problems occur as fre-
quently and as extensively in small, dedicated systems as in large, complex
facilities. The most common incineration system performance problems are
shown on Figure 4.
It has been estimated that roughly 25 percent of incineration systems
installed within the last 10 years either do not operate properly or do not
satisfy user performance objectives. A 1981 University of Maryland survey
of medical and academic Institutions incinerating low-level radioactive
wastes indicated that only about 50 percent of the institutions surveyed
(23 total) "reported no problems," and about 47 percent of the institutions
(20 total) reported problems ranging from mechanical difficulties to
combustion difficulties. A survey conducted by the U.S. Army Corps of
Engineers Research Laboratory in 1985 at 52 incineration facilities
reported that 17 percent of the users were "very pleased with their
systems," 71 percent were "generally satisfied with the performance of
their systems" (but indicated that minor changes were needed to reduce
maintenance and improve efficiency) and 12 percent were "not happy with
their systems" (reporting severe problems). Results of this Army survey
are summarized on Figure 5.
Fundamental Reasons for Poor Performance
Underlying causes or reasons for poor incineration system performance
are not always obvious. When performance difficulties are encountered, a
typical reaction Is often to "blame" the incinerator contractor for
furnishing "inferior" equipment. While this may be the case on some
installations, there are other possible reasons which are more common and
sometimes more serious. Generally, incineration system performance
problems can be related to deficiencies or inadequacies in any or all of
three areas:
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1. Selection and/or design - Before procurement
2. Fabrication and/or installation - During installation
3. Operation and/or maintenance - After acceptance
Examples of deficiencies in these three areas are as follows:
1. System Selection and/or Design Deficiencies
Deficiencies in this area are usually the result of basing incinera-
tion system selection and design decisions on incorrect or inadequate
waste data, as well as failures to address specific, unique facility
requirements. The resultant consequences are that system performance
objectives and design criteria are also inadequate. An example of this
is the procurement of an incineration system of inadequate capacity
because of underestimated waste generation rates. Not so obvious exam-
ples include the relationships between operating problems and inadequate
waste characterization data.
Since incinerators are designed and controlled to process specific
average waste compositions, vague identification of waste types or wide
variances between actual waste parameters and "selected" design parameters
often result in poor system performance. Significant deviations in param-
eters such as heating values, moisture, volatility, density and physical
form could necessitate a capacity reduction of as much as two-thirds in
order to avoid objectionable stack emissions, unacceptable ash quality and
other related problems. Figure 6 Indicates examples of Improper waste
characterization affecting incineration capacity.
The establishment of good performance objectives based upon sound data
and evaluations is only the initial step towards procuring a successful
installation. The next step would be to assure that system design criteria
and associated contract documents are adequate to satisfy the performance
objectives. A prime example of design inadequacies is the failure to
relate incinerator furnace volumes to any specific criteria auch as
acceptable heat release rates. Another example is the specification of
auxiliary components, such as waste loaders and ash removal systems, that
are not suitable for the required operating schedules or rigors.
2. Fabrication and/or Installation Deficiencies
Deficiencies in this area relate to inferior workmanship and/or mater-
ials in either the fabrication or installation of the system. The extent
and severity of such deficiencies are largely dependent upon the qualifica-
tions and experience of the incinerator contractor. Unqualified incinera-
tion system contractors may be Incapable or disinterested in providing a
system in compliance with specified criteria. This could be either be-
cause of general inexperience in the field of incineration or because of a
disregard of criteria that is different from their "standard way of doing
business or furnishing equipment."
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It is typical for even the most experienced and qualified incineration
system contractors to deviate to some extent from design documents or
criteria. This is largely because there are no such things as "standard"
or "universal" incineration systems or "typical" applications or
facilities. Unless design documents are exclusively and entirely based
upon and awarded to a specific, pre-selected incinerator manufacturer,
different manufacturers usually propose various substitutions and alternate
methodologies when bidding a project. The key to evaluating such proposed
variations is to assess whether they comply with fundamental design and
construction criteria and whether they reflect proven design and applica-
tion. On the other hand, allowing such variations without proper
assessment could have unfortunate consequences.
The number and severity of fabrication and installation deficiencies
are also directly related to quality control efforts during construction
phases of a project. For example, a review of contractor submittals, or
shop drawings, usually helps assure compliance with contract documents
before equipment is delivered to the job site. Site inspections during
installation work may detect deficiencies in design or workmanship before
they lead to operational problems and performance difficulties. In
addition, specific operating and performance testing as a prerequisite to
final acceptance is a key element in assuring that a system is installed
properly.
Figure 7 lists some of the most common reasons for deficiencies in the
fabrication and Installation of incineration systems.
3. Operational and/or Maintenance Deficiencies
Deficiencies in this area are basically "self-inflicted" in that they
usually result from Owner, or user, omissions or negligence, and related
problems occur after a system has been successfully tested and officially
accepted.
Successful performance of even the best designed, most sophisticated
and highest quality incineration systems is ultimately contingent upon the
abilities, training and dedication of the operators. The employment of
unqualified, uncaring, poorly trained and unsupervised operators is one of
the most positive ways of debilitating system performance in the shortest
time.
Incineration systems are normally subject to severe operating
conditions, and they require frequent adjustments and routine preventive
maintenance in order to maintain good performance. Failures to budget for
and provide such adjustments and maintenance on a regular basis leads to
increasingly bad performance and accelerated equipment deterioration. Also
operating incineration equipment until it "breaks down" usually results in
extensive, costly repair work and substantially reduced reliability.
Figure 8 lists some of the most common operational and maintenance
deficiencies which could result in poor incineration system performance.
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The above problems are usually inter-related, and they usually occur
in combination. They occur as frequently and as extensively in small,
dedicated facilities as in large, complex facilities. They may range in
severity from objectionable nuisances to major disabilities. Also,
required corrective measures may range from minor adjustments to major
modifications or even total abandonment.
Selection and design deficiencies are probably the most common as well
as the most serious causes of problem incineration systems. Reputable
incinerator contractors usually make every effort to satisfy specified
design and construction criteria and meet their contractual obligations.
Operating and maintenance deficiencies can usually be corrected. However,
once a system has been installed and started, very little can be done to
compensate for fundamental design inadequacies. Major, costly modifica-
tions and revisions to performance objectives are usually required.
The relatively frequent occurrence of design deficient systems may
largely be attributable to a general misconception of the incineration
industry as a whole. Incinerators are often promoted as standard, off-the-
shelf equipment that can be ordered directly from catalogs, shipped to
almost any job-site and, literally, "plugged in". This impression has been
enhanced by many of the incinerator vendors in a highly competitive market.
Exaggerations, half-truths and, sometimes, false claims are widespread
relative to equipment performance capabilities. In addition, attractive,
impressive brochures often suggest that implementation of an incineration
system is simpler than it really is.
Incineration systems are normally subject to extremely severe
operating conditions. These include very high and widely fluctuating
temperatures, thermal shock from wet materials, slagging residues 'which
clinker and spall furnace materials, explosions from items such as aerosol
cans, corrosive attacks from acid gases and chemicals and mechanical
abrasion from the movement of waste materials and from operating tools.
These conditions are compounded by the complexity of the incineration
process. Combustion processes are complicated in themselves, but in
incineration this complexity is magnified by frequent, unpredictable and
often tremendous variations in waste composition and feed rates. To
properly manage such severe and complex operating conditions, incineration
systems require well-trained, dedicated operating personnel, frequent and
thorough inspections, maintenance and repair, and administrative and
supervisory personnel attuned to these requirements.
At many facilities, the practice is to operate the incineration system
continuously until it breaks down because of equipment failures. This type
of operation accelerates both bad performance and equipment deterioration
rates. Repairs done after such breakdowns are usually far more extensive
and costly than those performed during routine, preventive maintenance
procedures. Also, items which are typically capable of lasting many years
can fail in a fraction of that time if interrelated components are
permitted to fail completely.
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KEY STEP
A first step in procuring a good incineration system is to view the
incineration "industry" in a proper perspective. There are four basic
nrlncloles to bear in mind:
principles to bear in mind:
1. Incineration technology is not an "exact" science - it is still
more of an art than a science, and there are no shortcuts, simplistic
methods or textbook formulas for success.
2. There is no "universal" incinerator - no design is universally
suited for all applications. Incinerators must be specifically selected,
designed and built to meet the needs of each facility on an Individual
basis. Manufacturers' catalogs identify typical models and sizes, but
these are rarely adequate for most facilities without special provisions or
modifications.
3. There is no "typical" incinerator application - even institu-
tions of similar type, size and activities have wide differences in waste
types and quantities, waste management practices, disposal costs, space
availability and regulatory requirements. Each application has unique
incineration system requirements that must be identified and accommodated
on an individual basis.
4. Incinerator manufacturers are not "equal" - there are wide diff-
erences in the capabilities and qualifications of the incinerator equipment
manufacturers. Likewise, there are wide differences in the various systems
and equipment, which are offered by different manufacturers.
RECOMMENDED PROCUREMENT STEPS
Figure 9 outlines six steps, recommended for implementing an inciner-
ation system project. Each is considered equally important towards mini-
mizing or eliminating the deficiencies discussed above and for increasing
the likelihood of obtaining a successful installation.
Performance difficulties on most problem incineration systems can
usually be traced to a disregard or lack of attention to details in the
first two steps; namely, 1) evaluations and selections and 2) design
documents. For example, many facilities have been procured strictly on the
basis of "purchase orders" containing generalized requirements such as:
"Furnish an incineration system to
burn Ib/hr of institutional
waste in compliance with applicable
regulations."
Obviously, the chances for success are marginal for any incineration
system procured on the basis of such specifications.
-242-
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On many projects, incinerator contractor evaluation and selection,
under Step 3, involve no more than a solicitation of prices from a random
listing of vendors with the award of a contract to that firm proposing a
system for the "least cost." There are two basic problems with this
approach. First, the selected incinerator contractors are assumed to have
equivalent capabilities and qualifications. Second, "least cost"
acceptance assumes that the equipment offered by each of the contractors is
equivalent, or identical. A comparative "value" assessment of proposals
usually results in the procurement of a superior quality system for a
negligible price difference. It is not uncommon to see cost proposals
"low" by no more than 10 percent, but the equipment offered of only half
the quality of the competition.
Again, although incineration is considered a proven technology, in
many ways it is still more of an art than a science. There are no
shortcuts, textbook formulas or shortcut methods for selecting and
implementing a successful system, and there are no guarantees that a system
will not have difficulties and problems. However, the probabilities of
procuring a successful, cost-effective system increase proportionally with
attention to details and utilization of proven techniques, methodologies
and experience.
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FIGURE 1
CLASSIFICATION OF WASTES
r-o
A
«*
r
Classification of Wastes
Typ« Description
0 Trash
1 Rubbish
2 Refuse
3 Garbage
4 Animal
solids and
organic
wastes
Principal Components
Highly combustible
waste, paper, wood,
cardboard cartons,
including up to 10%
treated papers, plastic
or rubber scraps;
commercial and
industrial sources
Combustible waste,
paper, cartons, rags.
wood scraps, combus-
tible floor sweepings;
domestic, commercial
and industrial sources
Rubbish and garbage;
residential sources
Animal and vegetable
wastes, restaurants,
hotels, markets;
institutional,
commercial and club
sources
Carcasses, organs,
solid organic wastes;
hospital, laboratory,
abattoirs, animal
pounds and similar
sources
Approximate
Composition
% by Weight
Trash 100%
Rubbish 80%
Garbage 20%
Rubbish 50%
Garbage 50%
Garbage 65%
Rubbish 35%
100% Animal
and Human
Tissue
Moisture
Content
%
10%
25%
50%
70%
85%
Incombustible
Solids %
5%
10%
7%
5%
5%
B.T.U.
Value/lb.
of Refuse as
Fired
8500
6500
4300
2500
1000
Ref: 11
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FIGURE 2
MAXIMUM BURNING RATE LBS./SQ. FT./HR.
OF VARIOUS TYPE WASTES
CAPACITY
Lbs./Hr.
100
200
300
400
500
600
700
800
900
1000
LOGARITHM
2.00
2.30
2.48
2.60
2.70
2.78
2.85
2.90
2.95
3.00
#1 WASTE
FACTOR IS
26
30
32
34
35
36
37
38
38
39
#2 WASTE
FACTOR 10
20
23
25
26
27
28
28
29
30
30
J£S WASTE
FACTOR 8
16
18
20
21
22
22
23
23
24
24
#4 WASTE
NO FACTOR
10
12*
14*
15*
16*
17*
18*
18*
18*
18*
The maximum burning rate in Ibs./sq. ft/hr. for Type 4 Waste depends to a
great extent on the size of the largest animal to be incinerated. Therefore when-
ever the largest animal to be incinerated exceeds 1/3 the hourly capacity of the
incinerator, use a rating of 10# sq. ftyhr. for the design of the incinerator.
Above Figures calculqted as follows:
MAXIMUM BURNING RATE LBS. PER SQ. FT. PER HR. FOR
TYPES #1, #2 fe #3 WASTES USING FACTORS AS NOTED
IN THE FORMULA.
BR=FACTOR FOR TYPE WASTE x LOG OF CAPACITY/HR.
#1 WASTE FACTOR 13
#2 WASTE FACTOR 10
#3 WASTE FACTOR 8
BR=MAX. BURNING RATE LBS./SQ. ' FT./HR.
I.E.-ASSUME INCINERATOR CAPACITY OF
100 LBS./HR, FOR TYPE #1 WASTE
BR=13 (FACTOR FOR #1 WASTE) X LOG 100 (CAPACITY/HR.)
13 X 2 = 26 LBS./SQ. FT./HR.
Ref: 11
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FIGURE 3
WASTE DATA CHART
Material
Type 0 Waste
Type 1 Waste
Type 2 Waste
Type 3 Waste
Type 4 Waste
Acetic Acid
Animal fats
Benzene
Brown paper
Butyl sole composition
Carbon
Citrus rinds
Coated milk cartons
Coffee grounds
Corn cobs
Corrugated paper
Coitcm seed hulls
Ethyl Alcohol
Hydrogen
Kerosene
Latex
Linoleum scrap
Magazines
Methyl alcohol
Naphtha
Newspaper
Plastic coated paper
Polyethylene
Polyurethane (foamed)
Rags (linen or cotton)
Rags (silk or wool)
Rubber waste
Shoe Leather
Tar or asphalt
Tar paper V6 tar-^S paper
Toluene
Turpentine
'/i wax-% paper
Wax paraffin
Wood bark
Wood bark (fir)
Wood sawdust
Wood sawdust (pine)
B.T.U.
value/lb. as
fired
8,500
6,500
4,300
2,500
.1,000
6,280
17,000
18,210
7,250
10,900
14,093
1,700
11,330
10,000
8,000
7,040
8,600
13,325
61,000
18,900
10,000
11,000
5,250
10,250
15,000
7,975
7,340
20.000
13,000
7,200
8,400-8,900
9,000-11.000
7.240
17,000
11,000
18.440
17,000
11,500
18,621
8,000-9,000
9,500
7,800-8.500
9.600
Wt. in Ibs.
per cu. ft.
(loose)
8-10
8-10
15-20
30-35
45-55
50-60
7
25
40
5
25-30
10-15
7
25-30
45
70-100
35-50
7
7
40-60
2
10-15
10-15
62-125
20
60
10-20
7-10
12-20
12-20
10-12
10-12
Wt. in Ibs.
per cu. ft.
65.8
55
138
49.3
0.0053
50
45
49.6
41.6
60
2
52
53.6
54-57
Content by weight
in percentage
ASH
5
10
7
5
5
0.5
0
0.5
1
30
0
0.75
1
2
3
5
2
0
0
0.5
0
20-30
22.5
0
0
1.5
2.6
0
0
2
2
20-30
21
1
2
0.5
0
3
0
3
3
3
3
MOISTURE
10
25
50
70
85
0
0
0
6
1
0
75
3.5
20
5
5
10
0
0
0
0
1
5
0
0
6
5
0
0
5
5
0
7.5
0
1
0
0
1
0
10
10
10
10
The above chart shows the various B.T.U. values of materials commonly encountered in incinerator designs. The values
given arc approximate and may vary based on their exact characteristics or moisture content.
Ref: 11
246
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FIGURE H
INCINERATION SYSTEM PERFORMANCE PROBLEMS
MAJOR PERFORMANCE
DIFFICULTIES
1. OBJECTIONABLE STACK
EMISSIONS
EXAMPLES
Out of compliance with air pollution control
requlations
Visible emissions
Odors
Hydrochloric acid gas (HC1) deposition and
deterioration
Entrapment of stack emissions into building
air intakes
2. INADEQUATE CAPACITY
Cannot accept "standard" size waste containers
Lou hourly charging rates
Lou daily burning rates (throughput)
A. EXCESSIVE REPAIRS
& DOWNTIME
5.
UNACCEPTABLE WORKING
ENVIRONMENT
3. POOR BURNOUT Low waste volume reduction
Recognizable waste items in ash residue
High ash residue carbon content (combustibles)
Frequent breakdowns and component failures
High maintenance and repair costs
Low system reliability
High dusting conditions and fugitive emissions
Excessive waste spillage
Excessive heat radiation and exposed hot
surfaces
Blowback of smoke and combustion products from
the incinerator
6. SYSTEM INEFFICIENCIES Excessive auxiliary fuel usage
Low steam recovery rates
Excessive operating labor costs
Ref: 7
247
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FIGURE 5
20 COMMON PROBLEMS FOUND
IN SMALL WASTE-TO-ENERGY PLANT'S
Results of 1983 Survey of 52 Heat Recovery
Incineration Systems (5-50 TPD) Conducted
by U.S. Army Construction Engineering
Research Laboratory.
PROBLEMS PERCENT OF
INSTALLATIONS
REPORTING
1. Castable Refractory 71Z
2. Underfire Air Ports 35%
3. Tipping Floor 29%
4. Warping 29%
5. Charging Ram 25%
6. Fire Tubes 25%
7. Air Pollution 23%
8. Ash Coveyor 23%
9. Not On-Line 21%
10. Controls 19%
11. Inadequate Wast Supply 19%
12. Water Tubes 17%
13. Internal Ram 15%
14. Low Steam Demand 13%
15. Induced Draft Fans 12%
16. Feed Hopper 10%
17. High pH Quench Water 8%
18. Stack Damper 4%
19. Charging Grates ' 2%
20. Front-End Loaders 2%
Concensus
17% Very Pleased
71Z Generally Satisfied-Minor Improvements Needed
12% Not Happy
Ref: 8
248
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FIGURE 6
WASTE CHARACTERIZATION DATA DEFICIENCIES NECESSITATING SYSTEM CAPACITY REDUCTIONS
ACTUAL WASTE CHARACTERIZATION DEVIATIONS
FROM SELECTED "DESIGN" VALUES
HEATING VALUES (Btu/lb) EXCESSIVE
TYPICAL EXAMPLES
Greater concentrations of paper
and plastic components (or less
moisture) than originally
identified and specified
BASIC REASONS FOR REDUCED CAPACITIES
Incinerator volumetric heat
release rates (Btu/cu-ft/hr)
exceed design limits < 2)
(U
MOISTURE CONCENTRATIONS EXCESSIVE
Greater concentrations of high
water content wastes, such as
animal carcasses or food scraps
(garbage), than originally
identified and specified
Increased auxiliary fuel firing
rates and additional time
required for water evaporation
and superheating
VOLATILES EXCESSIVE
Greater concentrations of plastic
(such as polyethylene and
polystyrene) or flammable
solvents than originally identified
and specified
Rapid (nearly instantaneous)
releases of combustibles
(volatiles) in large quantities
along with excessively high
temperature surges
DENSITIES EXCESSIVE
Computer printout, compacted
waste, books, pamphlets and blocks
of paper
Difficulties in heat and flames
penetrating and burning through
dense layers of waste
HIGH ASH FORMATION TENDENCIES
Animal bedding or cage wastes -
wood chips, shavings or sawdust
Ash layer formation on surface
of waste pile insulates bulk
of waste from heat, flames
and combustion air
1) Failure to reduce capacities, or hourly waste loading rates, to accommodate indicated
deviations would likely result in other more serious operational problems.
2) Based upon accepted, empirical values, primary chamber heat release rates should be in
the range of 15,000 to 20,000 Btu/cu-ft/hr.
Ref: 7
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FIGURE-7
COMMON REASONS FOR FABRICATION & INSTALLATION DEFICIENCIES
Incineration equipment vendor (manufacturer) unqualified
Equipment installation contractor (GC) unqualified
Inadequate Instructions (and supervision) from the manufacturer for
system installation by the GC.
No clear lines of system performance responsibility between the
manufacturer and the GC
Failure to review manufacturer's shop drawings, catalog cuts and
materials and construction data to assure compliance with contract
(design) documents
Inadequate quality control during and following construction to
assure compliance with design (contract) documents
Payment schedules inadequately related to system performance
milestones
Final acceptance testing not required for demonstrating system
performance in accordance with contract requirements
Ref: 7
250
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FIGURE 8
COMMON REASONS FOR OPERATIONAL & MAINTENANCE DEFICIENCIES
Unqualified operators
Negligent, irresponsible and/or uncaring operators
Inadequate operator training programs
Inadequate operating and maintenance manuals
No record keeping or operating logs to monitor and verify performance
Inadequate operator supervision
Lack of periodice inspections, adjustments and preventative maintenance
Extending equipment usage when repairs and maintenance work are needed
Ref: 7
251
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FIGURE 9
RECOMMENDED INCINERATION SYSTEM IMPLEMENTATION STEPS
1. EVALUATIONS & SELECTIONS
o Collect and consolidate waste, facility, cost and regulatory data
o Identify and evaluate options and alternatives
o Select system and components
2. DESIGN (CONTRACT) DOCUMENTS
o Define wastes to be incinerated - avoid generalities and
ambiguous terms
o Specify performance requirements
o Specify full work scope
o Specify minimum design and construction criteria
3. CONTRACTOR SELECTION
o Solicit bids from prequalified contractors
o Evaluate bids on quality and completeness - not strictly least cost
o Evaluate and negotiate proposed substitutions and deviations
o Negotiate payment terms
o Consider performance bonding
4. CONSTRUCTION AND EQUIPMENT INSTALLATION
o Establish lines of responsibility
o Require shop drawing approvals
o Provide inspections during construction and installation
5. STARTUP AND FINAL ACCEPTANCE
o "Punch-out" system for contract compliance
o Require comprehensive testing: system operation, compliance with
performance requirements and emissions
o Obtain operator training
6. AFTER FINAL ACCEPTANCE
o Employ qualified and trained operators
o Maintain operator supervision
o Monitor and record system operations
o Provide regular inspections and adjustments
o Implement preventive maintenance and prompt repairs - consider
service contract
Ref: 7
252
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