id States       Center for Environmental
            •onmental Protection    Research Information
            'CV          Cincinnati OH 45268
            riology Transfer    ..            CERI 89:247
&EPA     Seminar-
           Medical and Institutional
           Waste Incineration:

           Regulations, Management,
           Technology, Emissions, and
           Operations

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                                          CERI 89-247
                                        November 1989
MEDICAL AND INSTITUTIONAL WASTE INCINERATION:
    REGULATIONS, MANAGEMENT, TECHNOLOGY
            EMISSIONS, AND OPERATIONS
                  Seminar Handout
          Center for Environmental Research Information
             U.S. Environmental Protection Agency
                  Cincinnati, Ohio 45268

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                        TABLE OF CONTENTS



WORKSHOP AGENDA	   V

SPEAKER BIOGRAPHIES	  ix


MEDICAL WASTE REGULATORY AND GUIDELINES UPDATE  	   1

WASTE MANAGEMENT AND DISPOSAL	  41

INCINERATION FUNDAMENTALS	  87

ALTERNATE INSTITUTIONAL WASTE INCINERATION
     TECHNOLOGIES  	  Ill

INCINERATION SYSTEMS AND EQUIPMENT  	  125

INCINERATOR EMISSIONS, AIR POLLUTION  CONTROL,
     RISKS, AND TESTING  	  145

INCINERATOR REGULATORY AND PERMITTING ISSUES	  164

PERFORMANCE, OPERATIONS, PROCUREMENT,  AND
     ACCEPTANCE 	  169

EVALUATING AND UPGRADING CURRENT SYSTEMS  	  183


SUPPLEMENTAL READING:

     HOSPITAL/INFECTIOUS WASTE  INCINERATION  DILEMMAS
          & RESOLUTIONS  	  188

     INFECTIOUS WASTE TREATMENT &  DISPOSAL
          ALTERNATIVES  	  202

     STATE-OF-THE-ART HOSPITAL  & INSTITUTIONAL WASTE INCINERATION:
          SELECTION, PROCUREMENT AND
          OPERATIONS  	  223
                             -iii-

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                      U.S. ENVIRONMENTAL PROTECTION AGENCY

          WORKSHOP ON MEDICAL AND INSTITUTIONAL WASTE INCINERATION:
        REGULATIONS, MANAGEMENT, TECHNOLOGY, EMISSIONS, AND OPERATIONS
                               WORKSHOP AGENDA

DAY ONE

12:00 p.m.            Registration

 1:00 p.m.            Introduction

 1:15 p.m.            State Experience with Medical and Institutional Waste Incineration
 1:45 p.m.            Medical Waste Regulatory and Guidelines Update
                    Jacqueline Sales, HAZMED,
                    Silver Spring, MD

                    Regulations, Standards, Guidelines
                           EPA
                           Other Federal, e.g. NIH, CDC, OSHA, RCRA, NRC
                           Other, e.g. JCAHO, NFPA

 3:15 p.m.            Questions/Discussion

 3:30 P.M.            BREAK

 3:45 p.m.            Waste Management and Disposal, Part 1
                    Larry Doucet/John Bleckman, Doucet & Mainka, P.C.
                    Peekskill, NY

                           Sources, Quantities  and Characteristics
                           Treatment and Disposal Alternatives

 5:00 p.m.            Questions/Discussion

 5:15 p.m.            ADJOURN
                                       -v-

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DAY TWO
 8:30 a.m.              Waste Management and Disposal, Part 2
                      Larry Doucet/John Blcckman

                             Planning and Implementing Treatment
                             & Disposal Programs

 9:15 a.m.              Incineration Fundamentals
                      Larry Doucet/John Bleckman

                             Combustion and Control Fundamentals
                             Time, Temperature, and Turbulance
                             Incineration Capacity and Sizing
                             Selection and Design Criteria
10:15 a.m.             Break

10:30 a.m.             Alternate Institutional Waste Incineration Technologies
                      Larry Doucet/John Bleckman

                             Multiple Chamber
                             Rotary Kiln
                             Controlled Air
                             Other
11:15 a.m.             Questions/Discussion

11:30 a.m.             Incineration Systems and Equipment, Part 1
                      Larry Doucet/John Bleckman

                              Waste Handling and Loading
                              Residue Removal and Handling

12:15 p.m.             Questions/Discussion

12:25 p.m.             LUNCH

 1:30 p.m.             Incineration Systems and Equipment, Part 2
                      Larry Doucet/John Bleckman

                              Heat Recovery
                              Stacks and Breeching Systems
                              Controls and Instrumentation

 2:15 p.m.             Incinerator Emissions, Air Pollution Control, Risks, and
                      Testing
                      Larry Doucet/John Bleckman
                                           -vi-

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DAY TWO. Continued


 3:00 p.m.             Questions/Discussion

 3:15 p.m.             BREAK

 3:30 p.m.             Incinerator Regulatory and Permitting Issues
                      Larry Doucet/John Bleckman

 4:15 p.m.             Procurement, Performance, Acceptance, and Operations
                      Larry Doucet/John Bleckman

 4:45 p.m.             Evaluating and Upgrading Current Systems
                      Larry Doucet/John Bleckman

 5:00 p.m.             Questions/Discussion

 5:15 p.m.             ADJOURN
                                  -vii-

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SPEAKER BIOGRAPHIES
        -ix-

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                          JOHN BLECKMAN
                      Doucet & Mainka,  P.C.
                      Consulting Engineers
                       2123 Crompond Road
                      Peekskill, NY  10566
                          914-736-0300
     John Bleckman received both his Bachelor and Masters degrees
at Cornell University.   He has nearly 20 years  of  experience in
consultation, engineering and management of health care facilities,
with  emphasis on  issues  in  energy  and  the  environment.    Mr.
Bleckman  has  had   documents  featured  in  a  wide   range  of
publications,  including the  Wall Street  Journal   and  documents
prepared by  the World Health  Organization.   He  works with Doucet
& Mainka, P.C.
                         LAWRENCE DOUCET
                      Doucet & Mainka, P.C.
                       Consulting Engineers
                        2123  Crompond Road
                       Peekskill, NY  10566
                           914-736-0300
     Lawrence  Doucet  received a Bachelor of  Science at the U.S.
Merchant Marine  Academy,  and earned his Masters in  Environmental
Engineering at City College  of New York.  Mr. Doucet has 20 years
of comprehensive experience  in the fields of incineration, waste
management, waste heat recovery, and air pollution control.   He has
worked for numerous hospitals, universities and research  facilities
involved in treatment of infectious, pathological,  toxic chemical,
chemotherapy,  and low-level  radioactive  waste.    Mr.  Doucet has
worked on numerous projects with the U.S. EPA relative to hazardous
waste management, storage, and incineration.  Currently,  Mr.  Doucet
is a Principal Executive  with  Doucet & Mainka, P.C.
                               -XI-

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                        JACQUELINE SALES
                             HAZMED
                         818 Roeder Road
                            Suite  310A
                     silver  Spring, MD   20910
                          301-588-1637
     Jacqueline Sales is a  two-time  recipient of the prestigious
EPA Special  Act Award.   She  received  her Bachelor  and Masters
degrees from Howard University in Washington,  DC.  Ms. Sales is an
expert in the management of hazardous waste, biological testing and
analysis, and  infectious waste,  where  she has provided extensive
guidance  to Federal,  State  and  local  agencies  on policy  and
regulations.    She  has been  a  Faculty Member  of  the  American
Hospital  Association  since  1985.  Ms.  Sales is  the founder and
president of HAZMED,  an environmental  engineering and consulting
firm  specializing  in infectious waste management  and  hazardous
waste regulation development, implementation, and policy.
                               -xii-

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MEDICAL WASTE REGULATORY AND GUIDELINES UPDATE

Jacqueline W. Sales
Hazardous and Medical Waste Services, Inc. [HAZMED]
     Environmental Protection Agency (EPA) Medical Waste Program

     A.  Historical Perspective

          1. EPA 1986 infectious waste guidance document
          2. Beach wash-ups of medical waste debris

     B.  Medical Waste Tracking Act of 1988

          1.   Two year demonstration program
          2.   Tracking system for medical waste
          3.   Implementation date July 30, 1989

     C.  List of Medical Wastes tracked under the EPA
         Program

          1.   Cultures and stocks of infectious
               agents
          2.   Pathological Wastes
          3.   Human blood and blood products
          4.   Sharps  (used and unused)
          5.   Contaminated Animal Wastes

     D.  Waste excluded from regulation

          1.   Domestic sewage
          2.   Hazardous waste
          3.   Household waste
          4.   Treated and destroyed waste
          5.   Human remains
          6.   Samples collected  for enforcement
               purposes

     E.  Enforcement authorities  - RCRA Subtitle  C

     F.  Generator standards

          1.   Must segregate, package, and label
               all regulated medical waste to be
               shipped off-site.
          2.   Must use medical waste tracking
               form or log.
          3.   Must maintain records.

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     G.   Types of generators

          1.    Hospital,  medical clinics,  drug
               treatment  centers
          2.    Clinical and research laboratories
          3.    Physician's offices,  dental
               offices, and veterinary practices
          4.    Nursing homes,  hospices,  etc.
          5.    Funeral homes,  dialysis centers
          6.    Military vessels at port

     H.   Transporter requirements

          1.    Must notify EPA
          2.    Comply with vehicle requirements
          3.    Comply with tracking form
               requirements
          4.    Maintain records
          5.    Submit reports to EPA

     I.   Destination Facility Requirements

          1.    Operate and manage regulated medical waste in
               accordance with applicable requirements.
          2.    Comply with tracking form requirements.
          3.    Maintain required records.
          4.    Prepare and submit reports to EPA and
               State agencies.

     J.   EPA implementation efforts

          1.    Outreach
          2.    Training
          3.    Assistance to states
II.   Occupational Safety and Health Administration (OSHA)
     Requirements

     A.   Addresses protection of health care workers

     B.   Requires personal protective equipment

     C.   Establishes housekeeping standards

     D.   Establishes sanitation and waste disposal standards

     E.   Contains general duty clause.

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III.  Nuclear Regulatory Commission (NRC)  requirements

     A.   Addresses disposal of low level  radioactive medical
         waste.

     B.   Certain medical waste may be decayed in storage
         before disposal.


IV.  Centers for Disease Control (CDC) Guidelines

     A.   Establishes guidelines for prevention and
         control of disease outbreaks.

     B.   CDC guidelines address proper procedures
         to protect workers from acquiring blood-
         borne diseases such as AIDS and Hepatitis B.


 V.  Joint Commission on Accreditation of Healthcare
     Organizations (JCAHO) Standards

     A.   Establishes standards for healthcare facility
         certification.

     B.   Standards address safety, patient care, staffing, and
         training programs.

     C.   Requires a process for handling hazardous and  infectious
         materials.

VI.  National  Institutes of Health (NIH)

     A.   Develops standard operating procedures for management
         and disposal of infectious waste.

     B.   The following wastes are managed as infectious:

          1.   Surgery and autopsy wastes
          2.   Contaminated research animals and bedding
          3.   Contaminated laboratory wastes
          4.   Contaminated and unused needles and syringes
          5.   Patient care wastes contaminated with blood,
               secretions, excretions, or exudates.

     C.   Infectious wastes are subject to certain packaging and
         labeling standards.

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VII.  Resource Conservation and Recovery Act (RCRA)

      A.  RCRA regulations cover management and handling of
          hazardous waste.

      B.  Hazardous wastes are either listed, exhibit one or more
          of the characteristics, or are commercial chemical
          products.
      C.  Generators of 100 kg per month or more of hazardous
          waste are subject to certain storage, permitting,
          tracking, and recordkeeping requirements.

      D.  Generators of less than 100 kg per month of hazardous
          waste are exempt from the Federal program (State
          regulations may be more stringent).

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&EPA     Historical Background Events
               Leading to Passage of MWTA
 • Medical Waste Has Been Historically Regulated as General Refuse
   Under RCRA Subtitle D
 • "EPA Guide for Infectious Waste Management" Was Issued in 1986
 • Numerous Wash-ups of Debris Occurred During the Summers of
   1987 and 1988:
   - Some Resulted in Beach Closures
   - Medical Waste Was a Small Portion of the Total
 • Beach  Closures and Resulting Economic Impacts Heightened Public
   and Congressional Concern
 • Medical Waste Tracking Act of 1988 Was Passed by Congress and
   Signed by the President
               Sources of Medical Waste That
                Washed Up On Our Beaches
  • Mismanagement of Municipal Solid Waste (Including
    Medical Waste)
  • Sewer Discharge and Combined Sewer Overflows
  • Illegal Drug Use
  • Beach Litter (Including Refloatables)
  • Commercial and Military Shipping and Pleasure Boating
  • Illegal Dumping Activities
                                -5-

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                  Medical Waste Tracking Act
  Medical Wade                f\t
Demonstration Program             *"
   • Signed by the President on November 1, 1988
   • Requires EPA to:
    - Establish a 2-year Demonstration Program
    - List the Types of Medical Waste to Be Tracked
    - Develop a Tracking System for RMW
    - Provide for States to Petition In or Opt Out
    - Prepare Reports to Congress
   • Deadline for Program Implementation: July 30, 1989
 \>EPA           List of Medical Waste
                       Types to Be Tracked
           • EPA is Required by the MWTA to Include the
             Following Waste Types:
             1. Cultures and Stocks
             2. Pathological Wastes
             3. Human Blood and Blood Products
             4. Sharps
             5. Contaminated Animal Wastes
                                -6-

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     EPA      List of Medical Waste Types
   M.d.e..w....        to Be Tracked (Continued)
Demonstration Program
   • EPA May Exclude the Following Waste Types if They
    Do Not Substantially Threaten Human Health or the
    Environment When Mismanaged:
     6. Waste from Surgery or Autopsy
     7. Other Laboratory Wastes
     8. Dialysis Wastes
     9. Discarded Medical Equipment and Parts
     10.  Isolation Wastes
   • EPA May Also Add Other Medical Wastes Based on a
     Finding That They Pose a Threat to Human Health or
     the Environment
 «rEPA          Enforcement Authorities
  Medical Watt*
Demonstration Program

  • Similar to RCRA Subtitle C in Inspection and Enforcement Authorities
  • Applies to All Generators (Including Federal Facilities) in Covered
    States
  • Penalties:
    - Criminal - $50,000 Per Violation, Per Day, or Up to 5 Years
      Imprisonment
    - Civil - $25,000 Per Violation, Per Day
                               -7-

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 &EPA         Standards for the Tracking
   M.«..iw..i.    ancj Management of Medical Waste
Demonstration Program
   •  These Regulations Apply to:
     - RMW That is Generated in a Covered State
     - Generators of RMW in a Covered State
     - Transporters and Owners or Operators of Intermediate
      Handling Facilities or Destination Facilities Who
      Transport, Offer for Transport, or Otherwise
      Manage RMW, Even if Such Transport or Management
      Occurs in a Non-Covered State

   •  Persons Claiming Non-Regulatory Status Must Demon-
     strate, Through Shipping Papers or Other Documentation,
     That the RMW Was Generated in  a Non-Covered State
 \vEPA           List of Medical Wastes
   Medical Watte                *n Uo TfaokaH
Demonstration Program              lw Ut?  I I ClUIWU

              • Cultures and Stocks

                Human Pathological Waste

              • Human Blood and Blood Products

              • Used Sharps

              • Research Animal Waste

              • Certain Isolation Waste

              • Certain Unused, Discarded Sharps
                                -8-

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&EPA           List of  Medical Wastes
                  to be Tracked (Continued)
   Waste Types Not Specifically Listed in the Regulations
   Include:
   - Surgery and Autopsy Waste
   - Other Laboratory Waste
   - Dialysis Waste
   - Contaminated Medical Equipment and Parts
   Many of  the Specific Waste Items of Concern Are
   Already  Included in Waste Classes 1-5 (e.g., Tissues
   From Surgery)
    Other Waste Items Have Been Specifically Listed
    (e.g., Contaminated Slides and Cover Slips From Laboratories)
\>EPA          List of Medical Wastes
                   to be Tracked (Continued)
 • The Wastes Not Captured:
   - Generally Pose Little Potential to Cause or
     Transmit Disease
   - Pose Little Potential to Cause Physical Harm
   - Have Not Been Responsible for Beach Closures

 • The List Represents a Virtual Consensus of Opinion of
   the State and Federal Public Health and State Waste
   Management Officials Who Participated in the
   Development of the Rule
                                  -9-

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  <&EPA      Class 1 - Cultures and Stocks
    Medical Waal*
 Demonstration Program
    Cultures and stocks of infectious agents and associated biologicals,
    including:  cultures from medical and pathological laboratories;
    cultures and stocks of infectious agents from research and industrial
    laboratories; waste from the production of biologicals; discarded
    live and attenuated vaccines; and culture dishes and devices used to
    transfer, inoculate, and mix cultures.
  XV EPA      class 2 - Pathological Wastes
    Morflml \Mmntm                               ^*
    Medical Wast*
 Demonalratlon Program
  Human Pathological wastes, including tissues, organs, body parts,
  and body fluids that are removed during surgery or autopsy, or
  other medical procedures, and specimens of body fluids and their
  containers.
  &EPA          Class  3 - Human  Blood
   Medical Waal*
Demonstration Program

   (1)  Liquid waste human blood; (2) products of blood; (3) items
   saturated and/or dripping with human blood; or (4) items that were
   saturated and/or dripping with human blood that are now caked with
   dried human blood;  including serum, plasma, and other blood
   components, and their containers, which were used or intended for
   use in either patient care, testing and laboratory analysis, or the
   development of Pharmaceuticals.  Intravenous bags are also included
   in this category.
                                      -10-

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 SEPA            Class 4 - Used Sharps
   Medical Waste                                         •
Oamonslrallon Program

   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.
 &EPA           Class 5 - Animal Waste
   Medical Waste
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 Waste
Demonstration 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 Waal*
Demonstration Program
  Hypodermic needles, suture needles, syringes, and
  scalpel blades
&EPA        Wastes Not Subject to the
  ...die.. 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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                   Treatment and  Destruction
Demonstration Program                 l™JVdl IQJIIUII

   •  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
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
<>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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4^ EPA          Pre-Transport Standards
                         Storage Requirements
   Any Person Who Stores RMW 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
  &EPA          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
                         Markl"9 Requirements
  • Each Package of RMW 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
                     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
                        Part1*5 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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                      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
                       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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&EPA            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
  M.O-IC.IW..I.              General Requirements
Demonstration Program
  • 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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                      Transporter Standards
                        Use of the Tracking Form
 • Transporters Accepting RMW 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
&EPA      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
   Medical waau
Demonatratlon Program
   • 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
   Medical 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
     ' 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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&EPA         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 1000 Kilograms or More 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:
DO:
     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
          call the RCRA/Superfund Hotline if you need information
          1-800-424-9346 (toll free)

          call your State department of public health or
          environmental protection for information on State
          reguirements
                               -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 djuty 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 lor 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)

- Handwashlng
               -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/chlorinatlon
                    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.     Antlneoplastlc 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
                 Standard PL1.10 -Hazardous Waste
                               Management
JCAHO Requirements for Hazardous/
    Infectious Waste Management
           Policies/Procedures for
           Identification/Management
           Establishment of Committees -
           Annual Review
           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
          AM Of the Following
      •     Presence of Virulent Pathogen

      •     Sufficient Concentration of Pathogen

      •     Presence Of A Host

      •     Portal of Entry

      •     Host Susceptibility
                    -48-

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   Infectious Waste Generation
             Parameters
    •     Regulatory "Definitions"
    •     Interpretations Of Definitions
    •     Internal Policies And Protocols
    •     Waste Management Effectiveness
CDC Infectious Waste Designation

    •     Microbiology Lab Waste
    •     Pathological Waste
    •     Sharps
    •     Blood/Blood Products

    Ret:  1985 Handwashlng 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
•     Contaminated Sharps
•     Contaminated Animal Carcasses,
      Parts and Bedding

Re):  1989 EPA Guide tor Infectious Waste Management
    EPA Infectious Waste
    "Optional" Categories

•     Surgery and Autopsy Wastes
•     Dialysis Unit Wastes
•     Contaminated Equipment
•     Miscellaneous Laboratory Wastes

Ref: 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

      Ref: Proposed EPA Regulations in 1978 Fed Register


Hospital Department Sources (Cont'd)

      •     Obstetrics Department (Incl Patient Rooms)
      •     Pathology Department
      •     Pediatrics Department
      •     Surgery Department (Incl Patient Rooms)

      Ret: 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
•     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 Handwashinq & Hospital Environmental Control". 1985," NTIS PB85-923404, 1985.

      COC, "Reconmendations 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  SUMHARY
      U"fi«rf Sum
      CAtirotfranlll
      *«">ev
QM.or ol Solid Wnir
    '9mcv R»ioo»ne
    icn DC HXOO
Mi, 19RG

rni«.-]9<» in
     Solid WnU
     EPA Guide  for
     Infectious Waste
     Management
     The purpose of this document Is 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; howeverf 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.

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 I.   Designation  of  Infactlom  Waste


      EPA  recommends  that  the  following categories  o'  waste  be

 designated  as  infectious  wastei
  Waste Category
   Isolation wastes
  Cultures and stocks  of
  Infectious agent*  and
  associated btologlcals
i  Human blood and blood
  products
  Pathological wast*
  Contaminated tharpi
  Contaminated animal
  carcasses, body parts.
  and bedding
                                           Examples *
' refer to Centers  Cor  Disease
  Control (CDC), Guidelines
  for Isolation Precautions  in
  Hospitals, July  1933

• specimens front medical- and
  pathology laboratories

• culture* and stocks of Infectious
  agents from clinical, research.
  and Industrial laboratories;
  disposable culture dishes, and
  devices used to  transfer,  Inoculate
  and mix cultures

• wastes fro™ production of  biological*

• discarded live and attenuated
  vaccines
• wast* blood, serum, plasma,
  and blood products
  tissues, organs, body parts,
  blood, and body fluids removed
  during surgery, autopsy, and
  biopsy
  contaminated hypodermic needles,
  syringes,  scalpel blades, pastcur
  pipettes,  and broken glass
• contaminated animal carcasses,
  body parts,  and bedding of animal:
  that were Intentionally exposed
  to pathogens
     The EPA has Identified an  op t I o n a 1  Infectious  vast*

category which consists of ml seellancous  contaminated wastes.

While there Is not a unanimity  of  opinion regarding the hazards

posed by these wastes, EPA believes  that  the  decision whether

to handle these wastes as "infectious'  should be made by a

responsible authorized person or  committee  at the Individual

facility.  However, the Agency  recommends that wastes fron

patients known to be infected with  blood-borne diseases

should be managed as Infectious waste  (for  example, dialysis

waste front known hepatitis B patients).
                                                                                     Miscellaneous  Contaminated
                                                                                             Wastes
                                                                                 Wastes  from  surgery  and  autopsy
                                                                                 Miscellaneous  laboratory  wastes
                                                                                  Dialysis unit wastes
                                                                                 Contaminated equipment
                                               Examples
                                       *  soiled  dressings,  sponges,
                                         drapes,  lavag*  tubes,
                                         drainage  sets,  undtrpads,
                                         and  surgical  gloves
                                        specimen  containers, slides,
                                        and cover slips; disposable
                                        gloves, lab  coats, and  aprons
                                         tubing,  filters,  disposable
                                         sheets,  towels,  gloves,
                                         aprons,  and  lab  coats
                                       *  equipment  used In patient
                                         care,  medical  laboratories,
                                         research,  and  In the productlo
                                         and  testing  of certain
                                         Pharmaceuticals
 •Thes* materials are examples of wastes covered by each category.
 The categories are not limited to these materials.
   Ref:    U.S.EPA, Guide for Infectious Waste Hanagetnent. NTIS PB86-19°13, May 1986.

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I
yi
-j
il.   Segregation of Infectious  Waste
     EPA recommendsi
 •   segregation of Infectious waste at the point of origin
 •   segregation of Infectious wast* with multiple hazards
    as necessary (or management and treatment
 •   use of distinctive!  clearly marked 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 type* of  solid or semi-solid
      infectious waste
    - puncture-resistant container* (or sharp*
    - bottles, flasks, or tanks (or 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 Barkings
 •   closing the top of each bag by folding or tying as appropriate
    (or the treatment or transport
 •  placement of liquid wastes  in capped or tightly stoppered
    bottles or (lasks
  •  no compaction of infectious waste  or  packaged  Infectious w«,
     before treatment

 IV.  Storage of Infectious Waste
      CPA reconmendsi
 *  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  area
    door, waste containers, freezers, or- refrigerators

V.  Transport of Infectious Waste
    CPA recommendsi
 •  avoidance of mechanical 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 seal-rigid
    containers before transport off-site
 •  transport of infectious waste In closed leak-proof  trucks or
    dumpsters
Reft
  U.S.EPA. Cutda fcp Infectious Ua«t« Manaoane^. MTIS PB86-19913. Hay 1986.

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 VI.  Treatment of  Infectious Waste

      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  process

      used for treating Infectious waste

   •   monitoring of  all treatment processes  to assure  efficient  and

      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
en
CO
t
                                                              Treatment of Infectious Waste  tcont'd)

                                                                  EPA recommends:

                                                              •  the following treatment methods  for miscellaneous

                                                                 contaminated wastes (when a decision  is made  to manage

                                                                 these wastes as  Infectious):

                                                                 - wastes from surgery and autopsy -   incineration or stcara
                                                                                                       ster11ization

                                                                 - 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 of 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)
     Rcf
U.S.EPA, Cutde for infectious Uaste Management. NTIS PB86-19913,  May 1986.

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                                             RECOMMENDED TRCHNIOXJES FOR TREATMFNT OF INFECTIOUS WASTED
Type of Infectious Waste15

Isolation wastes
Cultures and stocks of
infectious agents and
associated blologlcals
Human blood and blood
products
Pathological wastes
Contaminated sharps
Contaminated animal carcasses,
body parts, bedding:
* carcasses and parts
* bedding
ReccmTended Treat/rent Techniques
Steam Thenrwl Chemical
Sterilization Incineration Inactivities Disinfection0 Other
X

X

X
xe
X


xe

X

X

X
X
X


X
X


X










X

X










Xd
xf





           a.   The reccmrended treatment techniques are those that are neat appropriate and,  generally, in coiiron use;
               alternative treatment technique rwy 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 treat/rent  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, Cutde for Infectious Waste Management. NT1S PB86-19913, Hay 1986.

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      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
         f     Bulk Fluids
         t     Pathological Waste
         •     Hazardous Chemicals
         •     Chemonuclear Waste
         •     Antlneoplastlc Waste
                 -61-

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                                      Saturated
                                      Steam
                                      Inlet
                                 Pressure
                                 Vesse I

                                 Trap  Passes
                                 Ai r-Steam
                                 Mixtures
                                 And Re ta i n s
                                 Pure Steam
                           Air
          GRAVITY STEAM STERILIZATION SYSTEM
Ref:  Block. S. S., Disinfection. Sterilization and Preservation. Lea and Febiger, Philadelphia. 1977.
                      -62-

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    Autoclaving System
        Advantages
•     Low 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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Shreddlng/Chlorinatlon Systems
         Small-Scale Sharps/
         Lab Waste Processing Systems
         Large-Scale Total Infectious
         Waste Processing System
     Shredding/Chlorination
       Disinfection System
   •     Waste Feed Conveyor
   •     Pre-Shredder
   •     Hammermlll
   •     Debris Conveyor/Separator
   •     HEPA Filtration System
   •     Sodium Hypochlorlte System
                -64-

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                                                    CHLORINE SOLUTION
U1
I
                   WASTE
                   CONVEYOR
PRE-SHREDOER


 HAMMERMILL
                             CHLORIN
                          GENERATOR
                                                                                      COLLECTION
                                                                                       CART
                WASTE
                               SHREDDING/CHLORINATION DISINFECTION SYSTEM
                     Ref:   Medical SafeTec, Inc.

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Shredding/Chlorinatlon  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
                                                        Slack
            To
        Atmosph

            f
                                                                              Stack
                                                           r Waste")
                                                         •—i  Heat  »--
                                                            _Boller J
 i   Air   t
 ! Pollution '   ,
"i Control ,
 i System i
 i	1
                                                      Ash
                MAJOR COMPONENTS OF AN INCINERATION  SYSTEM
R«f:    Hospital Incineration Operator Training Course Manual.
       EPA-450/3-89-004. March 1989.
                                          -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

      o     Insurance & Indemnification
            Infectious Waste
             Disposal Costs
t     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
               -72-

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Hazardous (Chemical) Waste
       Listed

       Characteristics
              Ignltable
              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

•     Liquid Waste
             Scintillation Fluids (LSC)
             Biological & Chemical Research Chemicals
             Decontamination of Radioactive Spills
Radioactive Waste Disposal
       Concentration and Confinement
             Decay-ln-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
 Classes             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
      t      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
CofTcc grounds
Corncobs
Corrugated paper
Cotton seed hulls
Ethyl Alcohol
Hydrogen
Kerosene
Latex
Linoleum scrap
Magazines
Methyl alcohol
Naphtha
Newspaper
Plastic coaled paper
Polyethylene
Polyurethane (foamed)
Rags (linen or cotton)
Rags (silk or wool)
Rubber waste
Shoe Leather
Tar or asphalt
Tar paper '/> tar-J/4 paper
Toluene
Turpentine
'/j wax-V5 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
1 1 ,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
1 1 .000
18.440
17,000
11,500
18.621
8.000-9.000
9,500
7,800-8.500
9.600
\Vt. in Ibs.
per cu. f(.
(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
\Vl. 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 wcigbt
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 I 0
1.5
2.6
0
5
2
20-30
21
1
2
0.5
0
3
0
3
3
3
3
6
5
0
0
5
5
0
7.5
0
1
0
0
1
0
10
10
10
10
The above chan 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
CtmlflcBtton of Wattes
Typ« Description
0 Trith
1 Rubbish
2 Refusa
3 Garbage
4 Animal
solids and
organic
wines
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
Antmal 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%
8.T.U.
Value/lb.
of Refuso as
F(re
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                       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
1 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
1 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 Aoerfca, !nctnerator 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-Slte 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-

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  Waste Burning Options
•     Flammable Solvents
•     Cytotoxlcs (Antlneoplastics)
             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-Tlme 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)

o      Potential Savings                 $337,000/yr

•      Costs For 5 "Waste Watchers"     $120,000/yr

•      Net Annual Savings               $217,000/yr
                        -85-

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MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP

^resented by:        Lawrence G. Doucet, Ooucet & Malnka, P.C.
                    John Bleckman, Doucet & Malnka, P.C.
       INCINERATION FUNDAMENTALS

       A.     Overview & Perspectives

       B.     Combustion Fundamentals
             1.     Combustion reactions
             2.     Combustion processes & controls
                    a.      Perfect, theoretical or stolchlometric
                    b.      Starved-alr, sub-stolchlometrlc 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-

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       Incineration
      Fundamentals
   What Is Incineration?


•    "Burn To Ashes"
•    Combustion Process
            -89-

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         Incineration
•     Thermal Oxidation
•     Thermal Destruction
•     High Temperature Destruction
•     Resource Recovery
         Incineration

•     Combustion Process
•     Controlled
•     Engineered
•     hflgh Technology
•     Proven
    Modern Incineration
      Only About 30 Years Old
              -90-

-------
Combustion Process
        Waste Chemistry

        Carbon (C)
        Hydrogen (H)
        Oxygen (O)
        Moisture
        Inorganics
        Nitrogen (N)
        Sulfur (S)
        Chlorine (Cl)
        Etc.
    Hydrocarbons
   •     Combustibles
   •     Carbon and Hydrogen
   •     Fuel
          -91-

-------
      Actual Combustion




  Hydrocarbons  ^  Carbon Dioxide
              •\
    Plus        m   Water Vapor

   Oxygen      W     Heat
    Perfect,  Theoretical Or

  Stoichiometric Combustion



Carbon * Oxygen  —*•  Carbon Dioxide

Hydrogen + Oxygen -+•  Water
      Perfect Combustion
       C * O2     -+. C02
       H2 * 0.5 O2 —*• H2O
             -92-

-------
       Combustion Reactions
       c * 02

       H2 * 0.5 O2

       O &  N

       Moisture

       Inorganics
 C02

 H2O

 Unchanged

 Unchanged

 Ash
Starved-Air,  Sub-Stoichiometric or
       Incomplete  Combustion
    Hydrocarbons
       plus
    O2 Deficiency
Carbon Dioxide
Water Vapor
Carbon Monoxide
PICs
Less Heat
         Sub-Stoichiometric Air
            Less Than Theoretical Air

            Smoke, Volatlles, And Hydrocarbons
            Formed

            Reduced Temperatures
                 Carbon to C02 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., "Operation and Maintenance of Controlled Air Incinerators." Joy Energy Systems, Inc.
      (formerly Ecolaire Environmental Control Products)  Undated.
                                       -94-

-------
                            TWO-STAGE INCINERATION
    4000
LL
ID
DC
ID
cc
LU
a
5
LU
f-
    3000
2000
    1000
                        EXCESS AIR —percent


                   0             100            200
                /
               /
     /

"/•
         h    /
              /
        /
         t/
         k-
                             STARVED AIR RANGE


                          • •  PRIMARY COMBUSTION CHAMBER

                          —  SECONDARY COMBUSTON CHAMBER



                            EXCESS AIR RANGE


                        	  PRIMARY AND SECONDARY

                               COMBUSTION CHAMBERS
                                                                  300
                                                                     2000
                      100
                                200
300
                                                                    1500
                                                                1000
                                                                    500
                                                                           O
                                                                           o
                                                                           LLI
                                                                           C
                        cc
                        0)
                        0.
                        2
                        ID
                                                    400
                       STOICHIOMETR1C 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

e     Poor Combustion
e     Increased Emissions
    Actual  Combustion
 HCs
 * Inorganics
 +02
 * Excess Air
              -97-

-------
             PICs
            Products
               of
           Incomplete
           Combustion
             PICs


      •      Unburned HCs
      •      Reformed Molecules
      •      Trace Concentrations
      9      Ubiquitous To Combustion
         Combustion
      Perfect, Theoretical or Stoichiometric
      Starved Air, Partial Pyrolysls
      or Sub-Stolchlometrlc
•     Excess Air
•     Two-Stage
•     Complete
              -98-

-------
Basic Combustion Principles
       •     Temperature

       •     Time

       •     Turbulence
     3 Ts Of Combustion




       •     Time

       •     Temperature

       •     Turbulence
             Time




 9     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
  •     Waste Type, Form and Size
    Primary Chamber Sizing

  •     Heat Release Rate (Btu/cu ft/hr)
  •     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:

          (Ib/hr of Waste)
 (sq ft of Primary Chamber Floor)
               -102-

-------
                             INCINERATION CAPACITIES
                          AS A FUNCTION OF WASTE TYPES
        2800
                 AUXILIARY HEAT
                   CONTROLS
                    CAPACITY
HEAT RELEASE
 CONTROLS
 CAPACITY
              TYPE 4   TYPE 3
                             12000

                     HEAT CONTENT
                      BTU/POUND
                             MAXIMUM BURNING RATES

                  FOR SPECIFIC TYPES OF WASTE IN POUNDS PER HOUR
INCtNUUTOM *
MOML
30
00
r*
100
100
too
230
Yn««o
3M
sn
sn
no
MM
1MO
10M
TYTtl
an
4M
738
•78
147ft
ino
9400
»«t
000
tea
no
1000
1«0
MM
**°°
TTMIt
or*
m
•00
ino
1«00
aoo
am
TVT«3
MS
47»
•00
•00
100
1*00
mo
TTM4
X4O
460
•00
aoo
uoo
IflOO
2000
*C«Mr
-------
                  MAXIMUM BURNING RATE LBS/SQ FTyHR
                        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
3.00
#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 ihe 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  IS
                £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
rCLEAN-OUT
    PREHEAT

           START  CHARGING
          BURN-DOWN
                                                            WASTE
                                                            CHARGING
                                       LAST CHARGE
Ref:   Ooocet, L. G., State-of-the-Art Hospital & Institutional Waste Incineration: Selection. Procurement
     and Operations. 1980
                                   -109-

-------
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-

-------
        Alternative

        Incineration

       Technologies
     Basic Institutional
 Incinerator Technologies
•     Multiple-Chamber (IIA)
            Retort
            In-Llne

«     Rotary Kiln

•     Controlled Air

•     "Innovative" Systems
            -113-

-------
Multiple-Chamber  Incinerators

  o     Incinerator Institute of America (MA)
  •     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
UNDERHEARTH 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
                                            X1SECONDAR?%URNER
                    CAST IRON GRATES
                          \
                 COMBUSTION
                 CHAMBER
         \   gftl x «s, vvxv^x\^ A x x- v x VVNX>C\\V\VV>?S^X\Xy
         t: *"'••• *•••••*• '..•* » t-;*:••"••• i-v % •'•: *.*.•.".*."•.•••  «•••-*-  ••'.-*

-------
                            INCINERATOR INSTITUTE
                                OF AMERICA (HA)
                       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 1A
   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 carry 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 aymbol
             Primary tombuiiion tone:
              Crate loading. L£

              Cralc arc*. AQ
              Average arch height. H.
              Lenglh-lo-widlh ratio (approx):
               Retort
               In-line
                                                               Recommended value
            Secondary combuilion tone:
              Caa velocitlei:
               riame port at  I.OOOT.  Vpp
               Mixing chamber at I.OOOT.
               Curtain wall port at 9SOT. Vcwp
               Combuilion chamber at 100'f. V^-j
              Mixing chamber downpan length,
              from lop of Ignition chamber arch to (op
              of curtain wall port.
              Lenglh-lo-widlh ratioi of flow cron
              • cciioni:
               Retort, mixing chamber, and combui-
               lion chamber
               In-line
  10 Log Rr: Ib/hr-ft* where  Rc cquali the
  rcfuie combuilion rale In Ib/hr  (refer lo
  figure 141)
  Re  -  LG: H*
  4/3 (Ac)4'": fl (refer lo Figure 34Z)
  Up to SOO Ib/hr.2:1; over 500 Ib/hr.  I. 75:1
  Dimlniihiiuj from about 1.7:1  (or 750 Ib/hr
  lo about 1:Z for 2.000 Ib/hr capacity. Ovcr-
  •quarc  acceptable in unit! of more than 11 fI
  Ignition chamber length.
                                            Allowable
                                            deviation
            Combutlion air;
             Air requirement batch-charging opera-
             tion
             Combuilion air diilribution:
              Ovcrfirc air poru
              Underfirc air porn
              Mixing chamber air  porn
             Port aizing,  nominal inlet velocity
             prciaure
             Air  Inlet pom  oveniie factori:
              Primary air inlel
              Underfirc air inlet
              Secondary air inlel
  SS fi/icc
  25 ft/aec
  About 0.7 of mixing chamber velocity
  i lo 6 fl/iec: alwaya leaa than. 10 fi/acc
  Average arch height, fl
 Range - 1.3:1 lo 1.5:1

 rixed by gai velociliei due lo conilanl
 Incinerator width
           furnace temperature;
            Average temperature, combuition
            product!
 Baiii: ion cxccii air.  50% air require-
 ment admitted through adjuilable porti:
 50% air requirement met by open charge
 door and leakage
 70% of lolal air required
 10% of total air required
 20% of total air required
 0.1 Inch walcr gage
 1.2
 I. 5 for over SOO Ib/hr lo 2. 5 for SO Ib/hr
 2.0 (or over SOO Ib/hr to S. 0 for SO Ib/hr
«  10%
•  10%
«. 20%
« 20%
  20%
           Auxiliary burneri:
            Normal duly rcquiremcnli:
              Primary burner
              Secondary burner
           Prafl requirement!:
            Theorclical alack draft.  Dj
            Available primary air Induction draft.
            D^.  (Aiiume equivalent lo inlel ve-
            locity prenure.)
            Natural draft. Hack velocity,  V^
 i.ooo*r
3.000 to 10.000 1B|U per ib 0,
<.000tol2.000/lh«
0. IS lo O.-JS Inch water ga'ge
0.1 Inch walcr gage

Leu than 30 fl/iec al 100T
                                            4 IOT
Ref:     U.S.  Dcpt. HEW. Air  Pollution Engineering Manual.  2nd Edition. PHS Pub.  AP-«0. Air Pollution Control
         District. County of  Los Angeles, 1973         -118-

-------
  Rotary Kiln Incinerators


o     Versatile and Good Ash Quality
o     Costly and Maintenance Intensive
«     Waste Processing ("Auger" Loader)
«     Infectious Waste Shredding Problems
                -119-

-------
                              ROTARY KILN  INCINERATOR
                                13





14



-mr 	 lit—

7 £
$?$$&



12




14



   1  Waste to"lncinerator
   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 Sell-compensating Instrumentation-controls
10 Wet-Scrubber Package:
   stainless steel, corrosion-free wet scrubber;
   gas quench
11 Exhaust fan and stack
12 Recycle water, fly-ash sludge collector
13 Support frame
14 Support piers
15 Afterburner chamber
iG Prccoolcr
                                                -120-
Ref:    C. £. 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

•      Starved Air Incinerators

•      Two-Stage Combustion Units

•      "Pyrolytlc"  Incinerators

•      "Stuff-and-Burn" Units
              -121-

-------
                     ''  COMBUSTION GASES
     AUXIURY
     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
Joy Energy systems.
undated.
                                                         Con.oUed
                                    -122-

-------
                   Control Panel
                                                  .Stack
                                                          Secondary Chamber
                  Secondary Combustion
                  Air Blower
      Mechanical
      Charge System
             Primary.
             Burner
                    Primary Combustion
                    Air Burner Blower
                                                                      Viewport



                                                                        Secondary Burner
  Viewport
                                                                               Ash Removal
                                                                               Door
Primary Chamber
             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/Experlmental
•     "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-

-------
              Incineration

             Systems And

              Equipment
  Basic Incinerator Burning Surface
           Refractory Hearths
                 Cold
                 Hot

           Grates
                 Fixed
                 Moving

           Combinations
               Refractory


•     Containment Of Combustion Process

•     Reradlatlon

•     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
   •      Timer Switch
   •      Automatic On-Off Or High/Low
   •      Modulation
   •      Modulation With Air Blowers
               -129-

-------
           Waste
          Handling
  Waste Handling System

•     Collection And Transport
•     Interim Storage
•     Pre-Treatment
•     Incinerator Loading
             -130-

-------
          Incinerator
           Loading
Incinerator Loading Systems

 •     Hopper/Ram Loaders
 •     Auger Feeders
 •     Top Loaders
 •     High-Volume Loaders
Incinerator Charging Methods
       •    Manual
       •    Tltt Carts
       •    Cart Dumpers
       •    Tractors
       •    Conveyors
              -131-

-------
              Coauol
              fuel
                    >r Fire Protection Handbook.
      "Vaste Handling SysMM and Equipment," 16th Edition,
      Chapter U, Section 12, 1985
Ref:  Industronfcs, Inc.
                           START
                           STEP  I
                          STEP 2
                          STEP  3
                         STEP 4
                         STEP  S
                                                                        LOADER SCHEMATIC
                                              WASTE tOAOCO WTO HOPPER
                                            RAW ftevCftSCS TO CLEAR FIRE DOOR
                                            HRE DOOR CLOSES
                                    J
                                               RETURNS TO START
                                     Ref: 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

e     Manual
•     Bomb-Bay Doors
•     Batch Ejectors
•     Continuous Systems
            Stokers
            Transfer Rams
            Pulse Hearths
   Ash Handling Methods

 •      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
0     Energy Grant
o     Conditioning For APC System
    Waste Heat Recovery

 •     Fire-Tube Boilers
 •     Water-Tube Boilers
 •     Flred-Bollers
            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

       •     Collection & Transport
       •     Storage/Holding Tank
       •     Pumping System
       •     Burner or Injector System
       •     Controls, Safeguards, & Monitors
       •     Special Enclosure
                       -136-

-------
        Enclosure Room

  •     Fire Rated
  •     Special Ventilation
  •     Explosion Proof Electrical
  •     NFPA30:    "Flammable and Combustible
                    Uqulds Code"
     Ignitable (I) Hazardous
       Waste Incineration
  •      Flammabllity - Flashpoint <140F
  •      Incinerator Not "Hazardous"
  •      Part B Permit Required For
         TSD Operations
"Hazardous" Waste Incineration

   »     RCRA Regulations
   •     Part B Permitting
   •     Trial Burn Testing
   •     Continuous Monitoring
                -137-

-------
          RCRA (Sub-Part 0)
       Incineration Requirement
•     Part B Permit
•     Trial Burn Test
            99.99% destruction and removal
            efficiency (ORE)
            Paniculate <0.08  graln/dscf
            @ 7% C02
            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
  •     Blomedlcally Exempt
  •     DIS for 10 Half-lives
          Mixed Waste

  •     RCRA and NRC Regulations
  •     NESHAPS
               -139-

-------
     Flue Gas Handling
•     Breeching
            High Temperature
            Low Temperature

•     Stacks
            Main
            Abort, Dump Or By-Pass

•     Dampers

•     Draft Inducers
Stack Height Determination


•     Surroundings

•     Building And Fire Codes

•     Draft Requirements

•     Entrapment Avoidance

•     Ambient Modeling/Dispersion
     Stack Accessories
      Exit Cone
      Spark Arrestor
      Test Ports (with platform)
      Ladder with Safety Cage
      Ughtnlng Protection
      Aircraft Warning Ughts
      Clean-Out Door
      Drain
      Instrumentation
                -140-

-------
     Stack Construction

•     High Temperature - Refractory
•     Low Temperature - FRP
•     Masonry
•     Special
      Incinerator Draft

      •     Natural
      •     Forced
      •     Induced
      •     Balanced
        Draft Controls

•      Barometric Damper
•      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-Checklng/Self-Callbratlon
            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-

-------
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.     Participate
             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 & recertlflcatlon
              7.     Operator training/certification
              8.     Risk/environmental assessments

       B.     BACT & Regulatory Justification

       C.     Public Hearings & Acceptance
              1.      Public concerns
              2.     The real Issues
                                   -1A5-

-------
     Incinerator

      Emissions
Incinerator Emissions


   e    Participate

   •    Gaseous
Paniculate Emissions
   Combustible
         Char
         Soot

   Mineral (Inorganics)
         Metals
         Silicates
         Salts
           -147-

-------
          Gaseous Emissions
            Combustible
                  Hydrocarbons
                  CO
                  PCDD 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-

-------
        HCI  Emission Concerns
•     Corrosion/Deterioration
             Equipment
             Other Structures

•     Regulatory
             Mass Rates
             Flue Gas Concentration
             Ambient Concentrations
             Emission Control Equipment

•     "Possible" Precursor of PCDD/PCDF
      Formation
•      Polyvlnyl Chlorides (PVC)

•      Hydrogen Chloride (HCI)

•      2-3 Ib PVC=  1 IbHCI

•      "PVC" Plastics Are -30-50% PVC

•      PVC Plastics = -10%  Total Plastics
                    -149-

-------
                 Air

              Pollution

               Control
Incineration Air Pollution Control
   •     Wet Scrubbers
                Spray tower
                Impingement tray
                Venturl
                Ionizing wet scrubber
                Packed tower

   •     Dry Scrubbers
                Baghouse filter
                Electrostatic preclpltator
                Electrified granular filter
                "Dry scrubber"
                  -150-

-------
                  Wet Scrubbers

                 Spray Towers
                 Venturl Scrubbers
                 Packed-Bed Scrubbers
     Venturi Scrubber System Components
•     Quench
•     Venturi
•     Separator
•     Packing Section
•     Mist Eliminator
•     Sub-Cooler
•     Water System
•     Caustic Feed
                        -151-

-------
                                                       OUTLET
                                  INLET
            QUENCH SECTION
            LIQUID FEEDS
            VENTURI
            LIQUID DISTRIBUTOR
            PACKING
            PACKING SUPPORT
            WETTED ELBOW
           COMBINATION CYCLONIC
           SEPARATOR AND PACKED
           BED ABSORBER
                                                  LIQUID DISCHARGE
                             VENTURI  SCRUBBER SYSTEM
Ref:    Andersen 2000, Inc.
                                      -152-

-------


Combustion
Gases from
Secondary
Chamber




r


Makeup ^
Water
Caustic /tv
Feed

L


Waste
Heat
Boiler




	















—



1




r



i — *


J



>
Scrubbe
Uquor
Recycle
Tank

^
Pumj



1
y




i


i
t
r
1
I
?-
>
Stack
I a
Water
1
1 / \ Mist
L.Y | Eliminator
^"^ M *F ^ ^"^ ^ .x~ LWB^M^
'S///SS/ • ( r1


1 >-. Packed

* kAAJUkAXM



Discharge
"*" (Slowdown)
	 1
1
1
1
J
                   VENTURI SCRUBBER WITH PACKED BED
Ref:   Hospital Incineration Operator Training Course Manual.
      EPA-450/3-89-OCK, March 1989.
                                       -153-

-------
       Dry Scrubbers

•     Fabric Filters
•     Electrostatic Preclpltators
•     "Dry" Scrubbers
             Dry Injection
             Spray Dryer
   Flue Gas Conditioning

•     Air Attenuation
•     Evaporative Cooling
•     Heat Exchanger
            -154-

-------
             Clean Air Plenum
                Blow Pipe
                                                               Housing
              Bag Retainer
         Dirty Air Inlet and Diffused.  •
                                                                   Todean Air Outlet
                                                                   and Exhauster
Tubular Filter Bags
                                                                 Dirty Air Plenum
                                                      Rotary Valve Air Lock
                          PULSE JET TYPE BAGHOUSE FILTER
Ref:
       U.S. Environmental Protection Agency,  "Controlled Techniques for Paniculate Emissions from
       Stationary Sources,"  Volume 1.  EPA-450/3-81-005a.   (NTIS PB 83-127498)  September 1982
                                           -155-

-------
                                                      Rappers
           Discharge
           electrodes
                                                                           ', * , 4    Rue gas
                                                                                        in
                                                                                 Collection
                                                                                 electrodes
                                      Hoppers
                                   ELECTROSTATIC  PRECIPITATOR
Ref:    U.S.  Environmental Protect ion Agency, APTI Course SI:412B, "Electrostatic Precipitator Plan Review,
       Self-Instructional Guidebook.  EPA-450/2-82-019.  July 1983
                                             -156-

-------
                        Sorbent
                        Storage
                                 Blower
                     Feeder
                                         (Rector
                                                                                    Stack
Combustion ^
Incinerator

Waste
Heat
Bolter



Contactor
Reactor

..fh
^V*
Particulato

Device



1
Solid
Residue
                                                                          10
                                                                         Fan
               Sorbent
               Storage
                       Blower
           Feeder
                                  Pneumatic
                                    Una
                                                                                   Stack
Combustion
Incinerator

Waste
Heat
Boiler


Injector

CombustlorT
Air Quct
Expansion/
Reaction
Chamber
                                                           Solid
                                                          Residue
                        DRY INJECTION ABSORPTION  SYSTEMS
Ref:    Hospital Incineration Operator Training Course Manuel.
       EPA-450/3-89-004. March 1989.
                                      -157-

-------
      Lime
     Storage
Slurry
Mixing
Tank



Slurry
Feed
Tank


<
                                                                               Stack
                   Combustion
                     Gases
                                                         Solid
                                                        Residue
                      SPRAY DRYER ABSORPTION SYSTEM
Ref:    Hospital Incineration Operator Training Course Manual.
       EPA-450/3-89-004. March 1989.
                                         -158-

-------
                    DRY SCRUBBER SYSTEM
                                                ASH AMD
                                                ggACTtON
                                                PRODUCT
                                                TO DISPOSAL
                            Baghouse Flltar or
                            Electrostatic Preclpltator
                                                               Major Reactions
                                                               Ca(OH), + 2 Ha
                        CaCd + 2 H,0
                        CaF«4-2HiO
                        CaSOi + mO
    aacaCne materials:
      Ca (OH),—Calcium Hydroxide
        (hydratedOme)
      Na,CO,—Sodium Carbonate
        (soda ash)
      Na OH—Sodium Hydroxide
        (caustfcsoda)
      Sodium Sesqtflcartxjnata (trona)
      NH,—Ammonia
                                        Principal System Components An:
                                        • evaporutor/ntctot (spray dryar)
                                        • So&to separation eqv&menl (bagtouse or predpftator)
                                        • Sortant storage and feeding equipment
                                        • Control systatns
^teua wte«dinHuMnaal«»dhtrtbuMK Into tt»au»g«i
                                                  steiy
2. Rotoy*t«n
-------
     Ambient Impact Assessment
      1.    Emissions Estimate
      2.    Ambient Modeling
      3.    Risk Estimates
      •    Ambient Impact Assessment
      •    Modeling/Risk Assessment
      •    Risk Analyses
    Health Risk And Environmental
         Assessment Reports

•     Worst-Case Condition
•     Maximum Exposed Individual (MEI)
•     Short-Term (1-hr) For Irritants
•     Long-Term (Annual)  For Carcinogens
                    -160-

-------
                           INCINERATOR  RISK ANALYSIS PROCESS
Step

1


2


3
Step Name
Parameters
4

5
Waste material source         Identity of each substance
  Control - Input mix         Amount of each substance
  Measure - Input waste stream
Combustion process            Process type,  time,  temperature
  Control - Combustion process -
  Measure - Process parameters
Stack Release

  Control - Waste stream
    removal processes
  Measure - Concentration at
    the stack
Dispersion to air
and surface
Dose To critical organs
  Measure - Remote air
   concentration and
   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
  Measure - Epldemiological     each disease and resulting effect
   or direct experiments in     in excess of backgound levels
   humans at levels of dose
   encountered
Height, location,  removal of waste
    stream products
Waste stream removal efficiency
Terrain, weather patterns

Intake to lung, wholebody, ingestion
Dose level via each pathway
                                      Number at each dose level,  time pro-
                                        file of exposure, levels  from other
                                        Competing sources and amblents
        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 1n  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
N>
 I
1.  Waste Characterization
                  Identification  In-Service
                  Conpentration 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

Jl to 3
-1 to 3

+2 to +10
                                                           ±2
                                                           -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
     * Use either,  but  not both. The first is for non-threshold dose-effect
     for threshold  types
     + Overestimate Of  Risk,  - Underestimate Of Risk, +1 or -1 Indicates No
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

                relationships,  the  latter

                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
Cancer
Cancer by Radiation
Cancer & Cholesterol
Accident
Cancer by Saccharin
Accident
10-6 =  1 per million
                           -163-

-------
        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 Recertlflcatlon
      Operator Training
        Typical Equipment And
       Component Requirements


•     Design And Combustion Calculations

•     Alr-Lock Type And Interlocked
      Waste Loaders

•     Modulating Burners

•     Enclosed Ash Removal Systems

•     Etc.
                   -164-

-------
           Typical Regulated
         Operating Conditions
•     Primary Chamber Temperature
•     Secondary Chamber Temperature
•     Secondary Chamber Retention Time
•     Preheat Temperature
•     Burndown Temperature And Duration
•     APC System Performance
           Typical Regulated
            Stack Emissions
•     Opacity
•     Paniculate
•     Acid Gases (HCI and S02)
•     Carbon Monoxide (CO)
•     Metals (12-14 Different)
•     Dloxlns (PCDD) And Furans (PCDF)
        Typical Monitoring And
        Recording Requirements

•     Loading Rates
•     Primary And Secondary Temperatures
•     Flue Gas Constituents (CEM)
      -O2, CO, C02, HCI, S02, etc.
•     Capacity
•     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)

•      Best Available Control Technology (BACT)

e      Lowest Achievable Emission Rates (LAER)
e      BACT

•      Regulatory Impact Assessment (RIA)

e      Cost/Benefit Assessment
                    BACT
             Statutorlly Defined

             Requires Analysis of:
                    Environmental Benefits
                    Capital and Operating Costs
                    Energy Requirements
                    Facility Impacts
                    etc.
                     -167-

-------
                  Public
                Hearings
            Public Concerns

      •     Environmental Impacts
      •     Health And Well-Belng
      •     Aesthetics And Visibility
      •     Traffic Levels
      •     Property Levels
      •     NIMBY

e     1940s Technology vs. Modern Technology
e     "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-

-------
MEDICAL & INSTITUTIONAL WASTE MANAGEMENT & INCINERATION WORKSHOP

Presented by:        Lawrence G.  Doucet, Doucet & Malnka, P.C.
                   John Bleckman, Doucet & Malnka, 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-

-------
             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
•     Low Hourly Charging Rates
•     Low Dally Burning Rates (Throughput)
          Incineration System
        Performance Problems
Poor Burnout
•     Low Waste Volume Reduction
•     Recognizable Waste Items
      In Ash Residue
•     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
      Dusting Conditions and
      Fugitive Emissions
      Excessive Waste Spillage
      High Heat Radiation and
      Exposed Hot Surfaces
      Exfiltratlon 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

•     Heating Values Excessive
•     Moisture Excessive
•     Volatlles Excessive
•     Densities Excessive
e     Ash Formation Tendencies
                -173-

-------
                   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          71%
        2.  Underflre Air  Ports          35%
        3.  Tipping Floor                 29%
        
-------
          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

            •     Order From Catalog
            •     Plug It In
            •     Cook Away
                        -175-

-------
   SANl-SOOT- 5TACKf
        5PAKJP-X
TITLE  field
SCALE- J£
          BY
 MCTUCftfOg.
-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


 FEA5BBJTY EVALUATIONS
   & SYSTEM SELECTION

      BASIC STEPS

 I.OsaCofccian
  •Waste
  •Ste(D
  •RegutaHens
  •Etc.

i kJentfcaoon o( Atenoims

 • On-Ste vs. Of^Ste
 • Design Vuidiam/Oplions

 •Etc

3. Technical & Eoonaaical
  Analyses

4. Sehanaic Drawings

S. Rdoonvncndflkons

6. Setecion
                                            PHASE 2

                                        CONTRACT DOCUMENTS A
                                           BD SOLICITATION

                                             BASIC STEPS
 •htarawfatn

IfntCec***
  Dnnrings A Spscrfications

3.1*8nnillok«br
  Appicalon-
S-PuUeHMrtngi'


 BidsorPropcMb
                                   PHASE 3

                                  CONSTRUCTION ft
                                   MSTALLATON

                                    BASIC STEPS
 • Coti Breakdown
 •PeynenlTenns
 •Nogofafau

2. Shop taring I
 Subtotal Review

X Periodic Fttlel repecfon
  tOtumiiam
                                                                           CankidOecuaMnli

                                   PHASE 4

                                START-UP, TESTMGft
                                 FMAL ACCEPTANCE

                                    BASIC STEPS
  CaBnfeo

2. Operator Tinning

1 Operational Tailing

4. Pwlonnanco Testing
                                                                                                           •FMlUaga
                                                                                                                                            PHASES
                               SUCCESSFUL SYSTEM
                           OPERATIONS A PERFORMANCE

                                  BASIC STEPS

                            I.OueflMOpeaM
                                                                                                                                       9i ItanMovioi ol QpwtoQ
                                                                                                                                       "Usntotoyin
                                                                                                                                        SemriSua

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              Incineration
            Operations And
              Maintenance
   Incinerator Operating Conditions

•     High Temperatures and Spikes
•     Thermal Shocks
•     Slagging Residues
•     Exploding Items
•     Corrosive Gases
•     Mechanical Spelling
         Common Reasons For
           O&M Deficiencies

•     Unqualified Operators
•     Negligent Operators
•     Inadequate Operator Supervision
e     Inadequate Operator Training
e     Inadequate O&M Manuals
e     Inadequate Recordkeeplng
e     Inadequate Preventive Maintenance
      Program
•     Equipment Usage When Repairs
      Are Needed
                     -180-

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 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 It will
    Inconvenience others as little as possible/
         Operator Instructions

•     Training Problems
•     Operating and Maintenance Manuals
•     Operating and Maintenance Charts
•     Periodic Retraining
                     -181-

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     Incinerator Testing

•     Operating Test
•     Performing Test
•     Emissions/Compliance Test
•     Trial Burn Test
      Operating Tests

e     Normal Conditions
e     Failure Simulations
e     Alarms, Safeties and Cut-Outs
      Performance Test

      •     Capacity
      •     Burnout
      •     Energy Recovery
      •     Fuel Usage
             -182-

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   Incineration System
 Upgrading, Modernization
     And Retrofitting
  Reasons For Upgrading

•    Eliminate Problems
•    Improve Performance
•    Regulatory Compliance
           Costs
           Permitting Difficulties
 Evaluating And Upgrading
      Existing System
    Incineration System
    Operational Audits
            -183-

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           Typical Incinerator
     Modernization Considerations
•     Revised Performance Objectives
e     Furnace Arrangement/Configuration
e     Furnace Unlng/Constructlon
•     Burner/Blower Capacities
•     Combustion Controls
•     Instrumentation/Monitoring
•     Waste Loading
•     O&M Considerations
                   -184-

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     Infectious Waste Incineration
            Status Summary

•     Increasing Demands
•     Increasing Developments
•     Increasing Deterrents
        Successful Incinerators

      e     Design Them Conservatively
      •     Keep Them Simple
      •     Build Them Tough
      •     Treat Them Well
                   -185-

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    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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HOSPITAUINFECTIOUS WASTE INCINERATION DILEMMAS & RESOLUTIONS

                          Presented By

                   LAWRENCE G. DOUCET, P.E.

                             at the

                    1st National Symposium On
               INCINERATION OF INFECTIOUS WASTES
                        yVashlngton, D.C.
                          May 6, 1988
                             -188-

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       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*n , 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-

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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 shou_^
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 August,  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-

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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


                                    -191-

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 charging  from about  $0.30  Co 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.'


                                        -192-

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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,
 ipredictable 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.

Soclo-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 unflltered, 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"


                                      -193-

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disposal firms may be seeking to offset revenues which they are losing because
of on-slte 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 quidelines.

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."(1>(4>
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


                                       -194-

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"incidentally" disposed in a hospital's general waste stream.

Hospital chemical wastes are regulated according to state and/or federal
 .azardous 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 thinner8, 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 MSU 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.
                                     -195-

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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 environmenally
benign and pose insignificant increased risks.  The mere fact that some toxic
                                        -196-

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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
 nvironment or public welfare.  For example, because dioxins and furans have
jeen "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 dlesel 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 (IO) .  (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


                                    -197-

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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 rulemaklng" and "unofficial pollcymaking" 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


                                          -198-

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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 R1A, 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 RIA 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)   NRC, "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.
                                       -200-

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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
                        201

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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.
                                 -202-

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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 Sterilization

     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.
                                          -206-

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     In ordor  t;o assure thmt  the autoclave systems arc  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.
                                         -207-

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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 prefliters 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:
                                         -208-

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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-1960's.   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


                                      -209-

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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.
                                     -210-

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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
                                    -211-

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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-Hi. to
hospital/infocLioua wasto incineration system in the country.  Nonotholoac,
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
                                     -212-

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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.
                                      -213-

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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.
                                     -214-

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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.
                                    -215-

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                                                            TABLE 3
                                  PRINCIPAL INFECTIOUS WASTE TREATMENT SYSTEM COMPONENTS
         AUTOCLAVING SYSTEM
                                    SHREDDING/CHLORINATION SYSTEM
                                          INCINERATION SYSTEM
i
KJ
91
I
Waste Transport/Treatment


Autoclavable Bags


Autoclave Chamber


Ventilation System


Container Dumper (Optional)


Biological/Temperature Indicators
•  Waste Feed Conveyor


•  Pre-Shredder


•  Hammennill


•  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
•  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
        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
CD
I
         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
K>
   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.
                                     -220-

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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
                       -221-

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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.
                                     -222-

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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
                           -223-

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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  1980's  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,
                                    -225-

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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 particulate entralnment and carryover.  This starved air burning
condition destroys most of the volatiles in the waste materials through
partial pyrolysls.  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.
                                     -226-

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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
HA 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 checkervork 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 biomedical 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 I1A 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 chat 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 incinerability
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 dally 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 dewpolnt 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 A 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, venturl 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
dewpolnt 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
dtoxins 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 pf 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:
                                     -238-

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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."
                                    -239-

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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 unsupervlsed 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.
                                     -240-

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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 fall completely.
                                    -241-

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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
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.

     A.   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.
                                    -243-

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                              FIGURE 1
                     CLASSIFICATION OF WASTES
I
ro
Classification of Wastes
Type 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
SO
32
34
35
36
37
38
38
39
#2 WASTE
FACTOR 10
20
23
25
26
27
28
28
29
30
30
#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  & #3 WASTES USING FACTORS AS NOTED
  IN THE FORMULA.

  BR=FACTOR FOR TYPE WASTE x LOG OF CAPACITY/HR.
              #1 WASTE FACTOR IS
              #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.)
                IS X 2 = 26 LBS./SQ. FT./HR.
Ref:  11
                           -245-

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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
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-Vi paper
Toluene
Turpentine
}/3 wax-% paper
Wax paraffin
Wood bark
Wood bark (fir)
Wood sawdust
Wood sawdust (pine)
D.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
1 1 ,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
\V(. 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 4

             INCINERATION SYSTEM PERFORMANCE PROBLEMS
 MAJOR PERFORMANCE
   DIFFICULTIES

 1.  OBJECTIONABLE STACK
     EMISSIONS
            EXAMPLES
• OuC of compliance vich air pollution control
  requlations

• Visible emissions

• Odors

• Hydrochloric acid gas (UC1) deposition and
  deterioration

• Entrapment of stack emissions into building
  air intakes
 2.  INADEQUATE CAPACITY
• Cannot accept "standard" size vaste containers

• Low hourly charging rates

• Lov daily burning rates (throughput)
 3.  POOR BURNOUT
• Low waste volume reduction

• Recognizable waste items in ash residue

• High ash residue carbon content (combustibles)
 4.  EXCESSIVE REPAIRS
     & DOWNTIME
• Frequent breakdowns and component failures

• High maintenance and repair costs

• Low system reliability
 5.  UNACCEPTABLE WORKING   • High dusting conditions  and fugitive emissions
     ENVIRONMENT
                            • 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          71%
 2.  Underfire Air Ports          35Z
 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
    71% 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 )
                                                                       (i)
•  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
polystytene) or flammable
solvents Chan 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 periodlce 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

                                       2b2

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REFERENCES

1.   Bleckman,  J.,  O'Reilly, L.  Welty C.  Incineration for Heat Recovery
     and Hazardous  Waste Management.   Chicago:   American Hospital
     Association, 1983.

2.   Boegly, W. J., Jr., "Solid Waste Utilization - Incineration
     with Heat Recovery," prepared for Argonne National
     Laboratory under Contract W-31-109-Eng-38 with the U.S. DOE,
     Publication No. ANL/CES/TE 78-3, April 1978.

3.   Cooley, L. R., McCampbell,  M. R., Thompson, J. D.  "Current
     Practice of Incineration of Low-Level Institutional
     Radioactive Waste," prepared for U.S. DOE, Publication No.
     EGG-2076, February 1981.

4.   Doucet, L. G.  NFPA Fire Protection Handbook "Waste Handling
     Systems and Equipment," Chapter 14,  Section 12, 1985.

5.   Doucet, L. G., "Incineration:  State-of-the-Art Design,
     Procurement and Operational Considerations," Technical
     Document No. 055872, American Society for Hospital
     Engineering - Environmental Management File.

6.   Doucet, L. G., Knoll, W. G., Jr.  The Craft of Specifying
     Solid Waste Systems.  Actual Specifying Engineer, 1974 May,
     PP. 107-113.

7.   Doucet, L. G., "Institutional Waste Incineration Problems
     and Solutions," Proceedings of Incineration of Low Level &
     Mixed Wastes Conference, St. Charles, IL, April 1987.

8.   Ducey, R. A.,  Joncich, D. M., Grlggs, K. L., Sias, S. R.
     "Heat Recovery Incineration:  A Summary of Operational
     Experience," Technical Report No. CERL SRE-85/06, prepared
     for U.S. Army Construction Engineering Research Laboratory,
     March 1985.

9.   English, J. A. II,  "Design Aspects of a Low Emission, Two-
     Stage Incinerator," Proceedings 1974 National Incinerator
     Conference, ASME, New York, NY.

10.  Environmental Protection Agency.  "Small Modular
     Incinerator Systems with Heat Recovery:  A Technical,
     Environmental and Economic Evaluation," prepared by  Systems
     Technology Corporation, EPA Publication SW-177c, 1979.

11.  Hathaway, S. A.  "Application of the Packaged Controlled
     Air-Heat Recovery Incinerator of Army Fixed Facilities and
     Installations," Technical Report No. CERL-TR-E-151,  prepared
     for U.S. Army Construction Engineering Research Laboratory,
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