DCN 87-239-001-30-06
EPA Contract No. 68-02-4330
Work Assignment No. 30
                       HOSPITAL WASTE COMBUSTION STUDY

                            DATA GATHERING PHASE

                             FINAL DRAFT REPORT
                                Prepared for:
                                Ray Morrison
                         Pollutant Assessment Branch
                Office of Air Quality Planning and Standards
                    U.S. Environmental Protection Agency
                Research Triangle Park, North Carolina  27711
                                Prepared by:
                             Radian Corporation
                            Post Office Box 13000
                Research Triangle Park, North Carolina  27711
                                October 1987

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                   -      .
                 '''
                •j: 'ce or 4,r i_._jji:v Panning anrl  Stancards
                Research Triangle Pa-x. .\orrh Carolina 27711
                             18  •'•:/  :<
               ANNOUNCEMENT OF DISTRIBUTION OF DRAFT HOSPITAL
             WASTE  INCINERATOR REPORT AND REQUEST FOR COMMENTS

     Enclosed for your review is a copy of the final draft report entitled
"Hospital Haste Combustion Study - Data Gathering Phase" prepared for the
Environmental Protection Agency (EPA) by the Radian Corporation.  This
draft report summarizes readily available information on the hospital waste
combustion  industry including waste characterization, industry technology,
multipoliutant air emissions data, emission control technologies, current
regulation  and control strategies, and hospital waste combustor population
characteristics, including suggested model  plant parameters for use in
exposure model ing.

     This study of muUipollutant emissions from the combustion of hospital
waste was initiated by EPA's Office of Air Quality Planning and Standards
in response to increasing concerns over the potential  public health impacts
from the disposal  of hospital  wastes, including incineration and other
methods of disposal.  Hospital wastes contain many of the materials- found
in municipal waste in addition to the "red" and "orange" bag waste.  These
nospita' wastes contain both potentially toxic and infectious material.
Concerns are not only for the release of toxic air emissions such as dioxins
and dibenzofurans, other products of incomplete combustion, and inorganic
pollutants such as hydrogen chloride, but also for the possibility that
infectious micro-organisms (e.g., viruses)  may survive the combustion
processes.

     We would like for you and your staff to  review, use and comment, on
this draft hospital  waste combustion report.   We  would like for you to
provide not only yo'ur comments and suggestions but also  any additional
data or information you might  have concerning facility population, trace
air emissions, process and control  equipment, proposed or projected control
regulations and control  technology, etc.   He  plan to revise the draft report
to address your comments and suggestions  and  include,  where applicable,  the
information and data you send.  Since there is a  general  lack  of information
and data pertaining to hospital  waste combustion, the  additional  information
and data you provide will  be most useful  in addressing the  need to regulate
hospital waste combustion emissions.

     °leise forward by April  ^3,  1983 your  comments, suggestions  and data
to:  Rayourn Morrison, Acting  Chief, Program  Analysis  and Technology Section,
'1D-12,  U.S. (invironnentai  3rotection Agency,  Research  Triangle
Park, North Carolina 27711.

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     If you have any questions pl'ease contact me (910-541-5330; FTS 629-
5330) or David Cleverly (919-541-5332; FTS 629-5332).
                                    Sincerity,
                                    Rayburn Morrison, Acting Chief
                                     rogram Analysis and Technology Section
                                    Pollutant Assessment Branch
Enclosure

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                              TABLE OF CONTENTS

Section                                                               Page
 1.0      INTRODUCTION	1-1
 1.1      DESCRIPTION OF THE INDUSTRY	1-1
 1.2      WASTE CHARACTERIZATION	1-4
 1.3      REFERENCES	1-13
 2.0      PROCESSES AND  EQUIPMENT	2-1
 2.1      INCINERATOR TECHNOLOGY	2-2
          2.1.1  Excess  A1r  Incinerators	2-2
          2.1.2  Controlled  A1r  Incinerators	2-6
          2.1.3  Rotary  Kiln Incinerators	2-10
 2.2      WASTE FEED  AND ASH HANDLING  SYSTEMS	2-12
 2.3      WASTE HEAT  RECOVERY	2-15
 2.4      REFERENCES	2-17
 3.0      AIR EMISSIONS/FACTORS  FOR HOSPITAL WASTE  INCINERATORS	3-1
 3.1       FORMATION MECHANISMS	3-1
          3.1.1  Acid Gases	3-1
                3.1.1.1  Hydrochloric Acid	3-3
                3.1.1.2  Sulfur Dioxide	3-3
                3.1.1.3  Nitrogen Oxides	3-3
          3.1.2  Particulate Matter	3-4
          3.1.3  Trace Metals	3-7
          3.1.4  Organic Emissions	3-8
                3.1.4.1  Dioxins and Furans	3-10
                3.1.4.2  Low Molecular Weight Organic Compounds	3-12
                3.1.4.3  Carbon Monoxide	3-13

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                        TABLE OF CONTENTS (CONTINUED)
Section                                                               Page
 3.2      EMISSIONS TEST DATA	3-13
          3.2.1  Acid Gases	3-15
          3.2.2  Participate Matter	3-18
          3.2.3  Trace Metals	3-22
          3.2.4  Organic Emissions	3-24
          3.2.5  Pathogens	3-28
 3.3      REFERENCES	3-31
 4.0      CONTROL TECHNOLOGIES AND EFFICIENCIES	4-1
 4.1      SOURCE. SEPARATION	4-1
 4.2      COMBUSTION CONTROL	4-2
          4.2.1  Acid Gas Control	.....4-3
          4.2.2  Participate Matter Control	4-5
          4.2.3  Trace Metals Control	4-7
          4.2.4  Polycycllc Organic Matter (POM), D1ox1n and Furans...4-11
                 4.2.4.1  Equilibrium Considerations	4-12
                 4.2.4.2  Kinetic Considerations	4-14
                 4.2.4.3  Fuel Effects	4-18
                 4.2.4.4. Air Distribution Effects in Controlled
                            Air  Incinerators	4-21
                 4.2.4.5  Thermal Environment	4-23
                 4.2.4.6  POM, 01 oxin and Furan  Summary	4-28
 4.3      FLUE GAS CONTROLS	4-28
          4.3.1  Fabric  Filters  (Baghouses)	4-29
          4.3.2  Scrubbers	4'31
          4.3.3  Afterburners	4-*0
 4.4      REFERENCES	4'41
                                      11

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                        TABLE OF CONTENTS (CONTINUED)

Section

 5.0      REGULATORY STATUS AND STRATEGIES	5-1

 5.1      FEDERAL REGULATIONS AND PROGRAMS	5-1

 5.2      STATE REGULATIONS AND PROGRAMS	5-3

 5.3      FOREIGN REGULATIONS	5-7

 5.4      REFERENCES	5-10

 6.0      HOSPITAL WASTE INCINERATOR MODEL PLANTS	6-1

 6.1      POPULATION CHARACTERISTICS	6-1

          6.1.1  Model Incinerator Stack Parameters	6^5

          6.1.2  Model Incinerator Operating Parameters	6-15

. 6,2      REFERENCES	6-21

APPENDIX A - STATE REGULATIONS PERTAINING TO INFECTIOUS WASTE
             MANAGEMENT	A-l
                                     iii

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                               LIST OF  FIGURES
Figure                                                                Page
 2-1       Multiple-Chamber Pathological  Waste  Incinerator	2-4
 2-2       In-Line Multiple-Chamber Incinerator	2-5
 2-3       Schematic for Controlled Air  Incinerator	2-7
 2-4       Adiabatic Temperature Versus  Excess Air for a  Controlled
            Air Incinerator	2-9
 2-5       Schematic for Rotary Kiln Incinerator	2-11
 2-6       Schematic and Example Picture  of a Mechanical  Loading
            System	2-13
 3-1       Impact of Temperature and Fuel  Nitrogen on  NO   Emissions
            for Excess  Air Conditions	3-5
 3-2       Process Schematic for Hospital  Waste  Combustion..	3-9
 3-3       Hypothetical  Mechanisms  of Oioxin Formation Chemistry	3-11
 4-1       Fraction of As and Sb Collected with  Fume as a Function
            of the Extent of Total  Ash  Vaporization (Data Points)	4-8
 4-2       Concentration of Selected Elements  in Ultrafine
            Particulates as a Function  of Reciprocal  Particle
            Diameter	4-10
 4-3       Adiabatic Equilibrium Species  Distribution	4-15
 4-4       First Stage Hydrocarbon  Production	4-17
 4-5       One Possible  Formation Mechanism for  2,4,7,8 - TCDD	4-19
 4-6       Benzo(a)Pyrene Emissions from  Coal, Oil, and Natural  Gas
            Heat-Generation Processes	4-20
 4-7       Variation of  Adiabatic Flame  Temperature with  Percent
            Theoretical  Air and Percent  Moisture in the  MSW	4-25
 4-8       Hydrocarbon Breakthrough as a  Function of Percent
            Theoretical  Air	4-27
 4-9       Typical  Fabric Filter System	4-30
 4-10      Open Spray Tower Scrubber	4-33
                                     iv

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                         LIST OF FIGURES (CONTINUED)
Figure                                                                Page
 4-11     Fixed Orifice Scrubber	4-34
 4-12     Baffle Impingement Scrubber	4-35
 4-13     High Energy Venturi Scrubber	4-36
 4-14     Teller Dry Scrubbing System	4-39
 6-1       Distribution of Hospital  Sizes According to Bed Number	6-3
 6-2       Distribution of Incinerator Units in N.Y.  Database
            According to Selected Waste Feed Rate Ranges	6-4
 6-3       Distribution of Incinerator Units 1n N.Y.  Database with
            Waste Feed Rates Less than 200 Ib/hr According to
            Selected Feed Rate Ranges...	6-6
 6-4       Average,  High and Low Stack Heights According to Selected
            Feed Rate Ranges	6-7
 6-5       Average,  High and Low Stack Gas Exit Temperature According
            to Selected Feed Rate Ranges	6-9
 6-6       Average,  High and Low Stack Diameter According to Selected
            Feed Rate Ranges	6-10
 6-7       Average,  High and Low Stack Gas Exit Velocities According
            to Selected Feed Rate Ranges	6-11
 6-8       Average,  High and Low Stack Diameters According to Selected
            Feed Rate Ranges	6-12
 6-9       Annual Operating Hours According to Selected Feed Rate
            Changes	6-17

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                               LIST OF TABLES
Table                                  '                               Page
 1-1      Hospital  Waste Characterization	1-6
 1-2      Canadian  Characterization of Biomedical  Waste	1-7
 1-3      Incinerator Institute of America Solid Waste
            Classifications	1-9
 1-4      Ultimate  Analyses of Four Plastics	1-12
 3-1      Pollutants of Interest.	3-2
 3-2      Test Site Design and Operating Parameters for Detailed
            Tests	3-14
 3-3      Data/Factors for Hydrochloric Acid Emissions from Hospital
            Waste Incinerators	3-16
 3-4      Data/Factors for SO- arid NO  Emissions from Hospital Waste
            Incinerators	3-19
 3-5      Data/Factors for Particulate Emissions from Hospital Waste
            Incinerators	3-20
 3-6      Data/Factors for Trace Element Emissions from Hospital
            Waste Incinerators	3-23
 3-7      Data/Factors for Dioxin Emissions from Hospital Waste
            Incinerators	3-25
 3-8      Data/Factors for Furan Emissions from Hospital Waste
            Incinerators	3-26
 3-9      Fabric Filter Dioxin/Furan Ash Analysis	3-27
 3-10     Emission  Factors for Selected Organic Low Molecular Weight
            Organics from Hospital Waste Incinerators	3-29
 3-11     Emissions/Factors for Carbon Monoxide and Hydrocarbon
            Emissions from Hospital Waste Incinerators	3-30
 5-1      Guideline Emission Limits for Incinerators Burning
            Hospital Waste	5-6
 5-2      Acceptable Annual Ambient Concentrations Reported for
            Selected Pollutants	5-8
                                     vi

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                         LIST OF TABLES (CONTINUED)

Table

 5-3      Foreign Emission Regulations for Hospital Waste	5-9

 6-1      Summary of Model Incinerator Stack Parameters	6-14

 6-2      Summary of Emissions Factors and Rates for Hospital
            Incinerator Model Sizes	6-18
                                      VII

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                              1.0  INTRODUCTION

     This report contains the results of a study of air emissions from
hospital  waste combustion.   It represents an effort to gather currently
available data in a manner that will  allow the EPA to assess the need for
and feasibility of regulating multipollutant emissions from hospital waste
combustion.  The work was performed by Radian Corporation under contract to
EPA's Pollutant Analysis Branch of the Office of Air Quality Planning and
Standards
     During the course of this study, information was gathered from state
and local environmental agencies, from vendors of incineration equipment,
from the open technical literature, from the American Hospital Association,
and from visits to three incineration facilities.  Information was sought
concerning feed characteristics, combustor designs and operating
characteristics, emissions of-air pollutants, applied and potential control
technology, numbers and locations of hospital waste combustors, and
applicable regulations.  In addition, parameters needed to model exposure
and health risk have been developed for use in EPA's Human Exposure Model.
     The remainder of Section 1  is devoted to a description of the industry
(Section 1.1) and characterization of hospital waste (Section 1.2).
Section 2.0 contains information about the processes and equipment used for
hospital waste combustion.  Data gathered concerning air pollutants emitted
from hospital waste incinerators and their formation in the combustion
                         •
process are presented  in Section 3.0.  Section 4.0 contains a discussion of
control techniques and possible  control efficiencies.  Environmental
regulations affecting hospital waste combustion are presented in
Section 5.0.  Model plants suitable for EPA's use  in assessing regulatory
strategies are developed in Section 6.0.

1.1  DESCRIPTION OF THE  INDUSTRY

     "Hospital waste incineration" refers to the combustion of wastes
produced by a hospital or hospital-type facility.  These wastes  include both
                                     l-l

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infectious wastes (i.e., materials which come in contact with hospital
patients and which have a potential to carry disease-producing organisms)
and non-infectious or general housekeeping wastes.  Based on the experience
of hospitals in Illinois, only about 15 percent of a typical hospital's
waste is considered infectious while the remaining 85 percent can be
considered to be general refuse.1  However, because of the difficulty (and
expense) in segregating infectious from non-infectious waste, the two waste
types are generally mixed together, resulting in a considerably larger
volume of waste which  is considered infectious.  In many States, laws have
been enacted in the past ten years which prohibit the disposal of infectious
wastes in landfills.   To qualify  for disposal, wastes must  first be rendered
innocuous.  The three  methods commonly available to hospitals for
sterilization are autoclaving, treatment with ethylene oxide, and
incineration.  Due to  limitations  associated with autoclaving (i.e., limited
capacities, handling problems, and questionable effectiveness) and ethylene.
oxide units (i.e., worker health  risks),  incineration has become the most
practical waste  sterilization and disposal  option for many  hospital
            2
facilities.
      Incineration reduces waste  volumes by  up  to  90 percent.  Hence, the
volume  and  cost  of ultimate disposal  of residual wastes  in  a  landfill can  be
reduced  significantly  by  this method.  An  additional  benefit  of  incineration
systems,  in some  cases, is  that  they  can  be designed  for heat recovery with
the  potential  to  supply a portion of  the  hospital's  steam or  hot water
requirements.
      The total  capacity for hospital  waste incinerators  in  the  United
States  is uncertain.   As of 1985, there were a reported  6,872 hospitals  in
 the  nation with 1,318,000 beds.3  Estimates of waste  generation  rates  (taken
 from References 15 and 16)  range from about 8 to  13 Ib/bed/day.   Using  the
 high end of this range and an occupancy rate of 69  percent, the total
 hospital waste generation rate is estimated at about 5,900  tons per day.
 However, not all of this waste is sent to incinerators,  as  discussed above.
 To estimate total incinerator capacity,  this waste  rate would need to be
 reduced by the amount  of general waste that is segregated and sent via trash
                                       i-2

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disposal  to landfills.  Unfortunately,  it is not possible to estimate these
quantities based on the information gathered to date.  As a point of
reference, however, the total  capacity of municipal  solid waste incinerators
in the United States in 1986 was estimated at about 49,000 tons of refuse
per day out of a total national refuse production rate of about 340,000 tons
        4
per day.
     With regard to geographic distribution, hospitals are located in every
State as well as the District of Columbia.  At least one hospital was
located in almost all metropolitan and non-metropolitan statistical areas in
1985 according to American Hospital Association statistics in Reference 2.
Of the total number of hospitals, approximately 53 percent were located in
metropolitan statistical areas with the balance in non-metropolitan areas.
     Detailed statistics are available only for community hospitals, which
comprised over 83 percent of the total  hospital population in 1985.  During
the 1975 to 1985 period, the number of community hospitals declined by
2.4 percent; the total number of beds increased by 6.2 percent, however,
reflecting hospital closures,  mergers,-and conversion to nonacute-care
facilities.   Although the occupancy rate for community hospitals declined
from 75 to about 65 percent, the number of surgical  operations (which
produce higher levels of infectious waste) increased by almost 21 percent.
Taking these off-setting factors into account, the overall hospital waste
generation rate appears to have remained relatively constant over this
10-year period.  No factors were identified which would significantly change
this trend in the near future.
     No comprehensive information was found during this study regarding the
total population of hospital waste incinerators in the nation.  One
manufacturer's representative estimated that over 90 percent of operating
hospitals have an incinerator, on-site,  if only a small retort-type unit for
pathological or special wastes.   The number of larger, controlled air type
incinerators operating on hospital wastes was not known.  However, based on
discussions with two of the leading controlled-air incinerator
manufacturers, it is estimated that at least 1,200 of these systems have
                                                                 78
been installed at United States hospitals over the past 20 years.  '   This
                                     1-3

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implies that there are approximately 5,000 or more retort-type incinerators
which have been installed.  While some of these units have been retired,  a
                                                     9
great majority are felt to be currently in operation.
     Some insight into population patterns among hospital  waste incinerators
was gained by examining a recent New York (NY) State database which was
developed from an in-state survey of over 400 incinerator units.   This
database, and the analysis conducted by Radian Corporation during this
study, are described in detail in Section 6.1.  Highlights of the analysis
are as follows:

     o    Almost 60 percent of the NY incinerators have design feed
          capacities of less  than 200 Ib/hr.

     o    The population  distribution is bimodal with respect to feed
          capacity, with  peaks in the 50 to 74 Ib/hr range and in the  100  to
          124  Ib/hr range.

      o    About  one-half  of  the  NY  incinerator capacity is above 600  Ib/hr
          feed  rate and  about one-third  is  above  1,000 Ib/hr  feed rate.

A comparison of the New  York and total U.S.  hospital  populations indicates
that  the two populations  have similar overall  shapes  although  there  is a
greater proportion  of large  hospitals above the  500-bed size  in  NY  than  in
the nation  as a whole.

 1.2  WASTE  CHARACTERIZATION

      Hospital waste is characteristically heterogeneous,  consisting of
 objects of many different sizes  and composed of many different materials.
•The daily activities  and procedures within a hospital  can vary dramatically
 from day-to-day, thus making it  difficult to predict what will be  thrown
 away.  During the course of this study,  very little data  were found to be
 available on the composition of hospital waste.   This is  due to  the fact
                                     1-4

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that the amount of sampling and analysis required to generate representative
cha'racterization data would be extensive and costly.  In addition, industry
practice for many years has been to utilize the simplified waste
classification system developed by the Incinerator Institute of America
(IIA), discussed below, rather than sample and analyze waste.  Table 1-1
contains one general breakdown of the composition of typical hospital
waste.
     Based on the experience of hospitals in Illinois, it is estimated that
about 85% of a hospital's waste stream can be categorized as general refuse,
while the remaining 15% is contaminated with infectious agents.    This is
only a generalization, however, and actual wastes from a given hospital can
vary significantly from day to day and from hour to hour.  For example,
refuse collected after a major surgical procedure, such as a heart
transplant, may contain significantly more infectious wastes and disposable,.
plastics than is usually generated in a routine operation.    Also, because
of the difficulty in effectively segregating infectious and non-infectious
waste at the point of generation, the infectious waste is generally mixed
with a considerably larger portion of the hospital's general waste, thereby
                                                  12
creating more waste that is considered infectious.
     Most of the public attention concerning hospital waste management has
centered on the infectious waste portion.  Unfortunately, a number of
general and vague terms are used to refer to these wastes including
"pathological waste,"  "biological waste," "hazardous waste," "biomedical
waste," and "contaminated-waste."  In Canada, the term biomedical waste is
popular and a color-code classification scheme for the waste has been
developed as shown  in  Table 1-2.  In the United States, all these categories
                                                      14
of wastes are generally classified as "red bag" waste.
      In Europe, hospital wastes are divided into the general categories of
normal housekeeping wastes and "hazardous" wastes.  The latter category
consists of bacterially infected pathological waste, oil and chemical waste,
and radioactive isotopic contaminated waste.    A typical cross-section of
this type of waste  has  included the following items:
                                     1-5

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                TABLE  1-1.  HOSPITAL WASTE CHARACTERIZATION3
                                          Approximate   L
                  Product               Percent by Weight


                  Paper                         65
                  Plastic                      30
                  Moisture                      10
                  Other                          5


Reference 13.

Percentages do not necessarily add to 100  since  they  are  approximations.
                                     1-6

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         TABLE  1-2.   CANADIAN  CHARACTERIZATION  OF  BIOMEDICAL WASTE'
      Waste  Class
 Component Description
Typical Component
  weight percent
    (as fired)
          Al
       (Red  Bag)
          A2
     (Orange  Bag)
          A3 a
     (Yellow Bag)
        .  A3b
     (Yellow Bag)
       Lab Waste
          A3c
     (Yellow Bag)
      RID on DNA
          81
      (Blue bag)
Human Anatomical
Plastics
Swabs, Absorbents
Alcohol, Disinfectants

Animal Infected
Anatomical
Plastics
Glass
Beddings, Shavings,
Paper, Fecal Matter

Gagze, Pads, Swabs
Garments, Paper,
Cellulose
Plastics, PVC, Syringes
Sharps, Needles
Fluids, Residuals
Alcohols, Disinfectants

Plastics
Sharps
Cellulose Materials
Fluids, Residuals
Alcohols, Disinfectants
•Glass

Gauze, Pads, Swabs
Plastics, Petri Dishes
Sharps, Glass
Fluids

Non-infected
Animal Anatomical
Plastics
Glass
Beddings, Shavings,
Fecal Matter
       95-100
          0-5
          0-5
        0-0.2
       80-100
         0-15
          0-5

         0-10
        60-90
        15-30
          4-8
          2-5
        0-0.2

        50-60
          0-5
         5-10
         1-20
        0-0.2
        15-25

         5-30
        50-60
         0-10
         1-10
       90-100
         0-10
          0-3

         0-10
Reference 16.
                                     1-7

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              Artificial linens
              Paper
              Flowers
              Waste  food
              Cans
              Diapers
              Plastic  cups
              Syringes
              Scalpels
              Tweezers
              Rubber gloves
              Pathological objects
              Blood  test  tubes
              Test  tubes  from miscellaneous  service
              Petri  dishes
              Dropper  bottles
              Medicine bottles
              Drop  infusion  equipment
              Transfusion equipment
              Suction  catheters
              Bladder  catheters
              Urinal catheters
              Colostomi bags

     The general practice in  the United States is to  classify wastes
according to the IIA system described in Table 1-3.   The popularity of this
system is reinforced by the fact that most incinerator manufacturers  rate
their equipment  in terms of these categories.
     While useful for  general design purposes, the IIA classification scheme
does not address concerns such as the plastics content of waste or possible
hazardous components.   Hospital  wastes typically can  contain about 20
                                                                  18
percent plastics with  levels  as high as 30 percent being reported.    The
types of plastic most  commonly encountered include polyethylene,
                                     1-8

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  TABLE 1-3.  INCINERATOR INSTITUTE OF AMERICA SOLID WASTE CLASSIFICATIONS*
Type 0    Trash, a mixture of highly combustible waste such as paper,
          cardboard,  cartons, wood boxes,  and combustible floor sweepings
          from commercial and industrial  activities.   The mixtures contain
          up to 10 percent by weight of plastic bags,  coated paper,
          laminated paper, treated corrugated cardboard,  oily rags,  and
          plastic or  rubber scraps.

          This type of waste contains 10 percent moisture,  5 percent
          incombustible solids and has a heating value of 8,500 Btu  per
          pound as fired.

Type 1    Rubbish, a  mixture of combustible waste such as paper,  cardboard
          cartons, wood scrap, foliage,  and combustible floor sweepings,
          from domestic,  commercial, and industrial  activities.  The mixture.
          contains up to  20 percent  by weight of restaurant or cafeteria
          waste, but  contains little or no treated papers,  plastic,  or rubber
          wastes.

          This type of waste contains 25 percent moisture,  10 percent
          incombustible solids, and  has heating value  of 6,500 Btu per pound
          as fired.

Type 2    Refuse, consisting of an approximately even  mixture of rubbish and
          garbage by  weight."

          This type of waste is common to  apartment  and residential
          occupancy,  consisting of up to 50 percent  moisture, 7 percent
          incombustible solids, and  has a  heating value of 4,300 Btu per
          pound as-fired.'

Type 3    Garbage, consisting of animal  and vegetable  wastes fr-m
          restaurants, cafeterias, hotels, hospitals,  markets and like
          installations.

          This type of waste consists of up to 70 percent moisture,  up to
          5 percent incombustible solids,  and has a  heating value of 2,500
          Btu per pound as-fired.

Type 4    Human and animal remains,  consisting of carcasses, organs, and
          solid organic wastes from  hospitals, laboratories, abattoirs,
          animal pounds,  and similar sources, consisting of up to 85 percent
          moisture, 5 percent incombustible solids,  and having a heating
          value of 1,000  Btu per pound as  fired.
                                    1-9

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  TABLE-1-3.   INCINERATOR INSTITUTE OF AMERICA SOLID WASTE CLASSIFICATIONS5

  :•                              (CONTINUED)
          Byproduct waste, gaseous, liquid or semiliquid,  such as tar,
          paints, solvents, sludge, fumes, etcs., from industrial
          operations.  Btu values must be determined by the individual
          materials to be destroyed.
Type 5
Type 6
          Solid bydproduct waste, such as rubber, plastics, wood waste,
          etc., from industrial operations.  Btu values must be determined
          by the individual materials to be destroyed.
 Reference 22.
                                     1-LO

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                                      19
polypropylene,  and polyvinyl  chloride.     Potential  combustion products from
the burning of these plastics,  including hydrochloric acid and toxic air
contaminants,  are discussed in  Section  3.1.   Ultimate analyses for four
common plastics are shown in Table 1-4.
     Hospital  waste may contain potentially toxic components.  For example,
red bag waste in the United States may  contain potentially toxic compounds
generated by hospital operations that are currently exempt from regulations
                                                        20
under the Resource Conservation and Recovery Act (RCRA).    Such chemicals
include waste Pharmaceuticals,  cytotoxic agents used in chemotherapy, and
                       ? 1
anti-neoplastic agents.    Mercury from dental clinics and other heavy
metals used in hospitals may also be air emission concerns if they enter the
combustor along with other hospital wastes.
                                     1-11

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               TABLE 1-4.  ULTIMATE ANALYSES OF FOUR PLASTICS'
                                (Weight Percent)

Moisture
Carbon
Hydrogen
Oxygen
Nitrogen
Sulfur
Chlorine
Ash
Higher heating
value, Btu/lb
Polyethylene
0.20
84.38
14.14
0.00
0.06
0.03
tr
' 1.19
19,687
Polystyrene
0.20
86.91
8.42
3.96 ' '
0.21
0.02
tr
0.45
16,419
Polyurethane
0.20
63.14
6.25 •
•17.61
5.98
0.02
2.42
4.38
11,203
Polyvinyl
Chloride
0.20
45.04
5.60
1.56
0.08
0.14
45.32
2.06
9,754
Reference 23.
                                     1-12

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1.3  REFERENCES
 1.   Brenniman,  G.  R.,  R.  J.  Allen,  and P.  J.  Graham,  "Disposal  of Infectious
     Hospital  Waste:  The Problems in Illinois."  The Environmental
     Professional.  Vol.  6, 1984,  pp. 250-251.

 2.   Reference 1.

 3.   American  Hospital  Association.   Hospital  Statistics:  1986 Edition.
     Chicago,  Illinois,  1986, p.  2.

 4.   Radian Corporation.  Municipal  Waste Combustion Study:  Characterization
     of Municipal  Waste Combustion Inustrv.  EPA 530-SW-87-021h, July 1987,
     pp.  2-5.

 5.   Reference 3,  p.  xvii.

 6.   Private communication between E. Aul,  Radian Corporation and R. Laine,
     Southern  Corporation, August 25, 1987.

 7.   Consumat  Systems,   Inc.  Installations List.  Richmond,  Virginia.
     Received  by Radian Corporation in June 1987.  p.  1.

 8.   Private communication between E. Aul,  Radian Corporation and S. Shuler,
     Ecolaire  Combustion  Products,  Inc., August 25, 1987.

 9.   Reference 6.

10.   Reference 1.

11.   Doyle, B.W.,  D.A.   Drum, and J.D. Lauber.   "The Burning Issue  of Hospital
     Waste  Incineration." presented at  Israel   Ecological Society  Third
     International Conference, Jerusalem,  Israel, June  1986.

12.   Brunner,  C.R. "Biomedical Waste Incineration."  Presented at the 80th
     Annual Meeting of  the Air Pollution Control Association, New York,
     June 21-26, 1987.

13.   Jenkins,  A.C. "Evaluation Test on  a Hospital Refuse Incinerator at Saint
     Agnes  Medical Center, Fresno,  CA."  California Air Resource  Board,
     Stationary Source  Division, January 1987.

14.   Reference 12.

15.   Faurholdt, B. "European Experience with  Incineration of Hazardous and
     Pathological  Wastes."   Presented at the 80th Annual Meeting  of  the Air
     Pollution Control   Association, New York,   June 21-26, 1987.
                                    1-13

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15.   Doucet  L G.  "Controlled Air Incineration:  Design,  Procurement,  and
     Operational  Considerations." Technical  Document Series,  Technical
     Document Number: 055872, January 1986.

17.   Reference 16.

18.   Murnyak, G.R., and D.C. Gazenich. "Chlorine Emissions from a Medical
     Waste Incinerator." Journal of Environmental Health, Sept/Oct 1982.

19.   Reference 16.

20   Darling, C., R. Allen,  and G. Brenniman. "Air Pollution Emissions From A
     Hospital Incinerator."  Presented at the International Union of Air
     Pollution Prevention Associations Annual Meeting, Paris, France,
     May 16-20,  1983.

21.   Reference 15.

22.   Reference 16.

23   Kaiser,  E.R.  and  Carotti,  A.  "Municipal Incineration of Refuse with Two
     Percent  and Four .Percent  Additions of  Four  Plastics: Polyethylene,
     Polyurethane,  Polystyrene,  and  Polyvinyl Chloride,  "Proceedings of  the
     1972  National  Incinerator Conference".  June 1972. pgs.  230-45.
     California  Air resources  Board.  Air Pollution Control  at  Resource
     Recovery Facilities.   May 24,  1934.
                                       .1 - L 4

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                         2.0  PROCESSES AND EQUIPMENT

     The primary objectives of hospital waste incinerators are (1) to render
the waste innocuous, and (2) to reduce the size and mass of the waste.
These objectives are accomplished by exposing the waste to high temperatures
over a period of time long enough to destroy threatening organisms and by
burning all  but the incombustible portion of the waste.  As discussed in
Section 1.1, incineration has become the most practical sterilization and
disposal option for many hospital facilities.
     The design of a hospital waste incinerator, like any combustion system,
requires consideration of a number of interrelated factors including
residence time, temperature, and turbulence (i.e., the three "T"'s of
combustion).  Other factors which can influence combustion performance are
fuel feeding patterns, air supply and distribution, heat transfer, and ash
disposal.1 -Like municipal solid waste (MSW), hospital waste is a difficult
fuel to combust relative to conventional fuels such as oil, gas,  coal, or
wood.'  Some  of the problems associated with hospital wastes which must be
considered by the combustion system designer and equipment operator are:

     o    Fuel of non-homogenous and variable composition - The physical and
          chemical composition of hospital waste is highly variable.
          Furthermore, the waste feed consists of chemically diverse
          articles of different sizes and shapes.  Hospital waste is seldom
          pre-processed; it is burned in bulk on -. mass feed basis.  These
          factors pose problems in feeding, flame stability, particle
          entrainment and emissions control.

     o    Variable ash content - Hospital waste contains varying amounts of
          glass, metals and ceramics which are not consumed in the
          combustion process.  Fluctuations in ash composition and
          combustion temperatures can lead to clinker  formation,  slagging
          and  fouling in some systems.  To avoid these problems,  primary
          combustion chamber temperatures are generally maintained below
          about 1800°F.2  However, this tends to reduce carbon burnout and
          the overall energy utilization efficiency.

                                     2-1

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    o    Low heating value  - Hospital wastes often have low heating values
         due to excessive moisture contents.  This causes flame stability
         problems and,  in some cases, it becomes necessary to fire an
         auxiliary  fuel  to  maintain proper combustion conditions.
         Alternately, dry waste batches  (especially those with a high
         plastics content)  can produce high  flame temperatures which result
         in overheating of  the hearth or other combustion system
         components.  To avoid these problems, the combustion conditions
         (principally excess air,  air distribution, and auxiliary  fuel
         firing  rate) must  be controlled closely.

     o    Corrosive  materials  - Hospital  wastes contain varying  amounts  of
         fluorine  and  chlorine,  principally  from plastics.   These  materials
         can  corrode combustion  equipment,  especially convective  heat
         transfer  tubes.  To  avoid corrosion,  it is necessary  to  use
         corrosion-resistant  materials  of  construction  and  to  maintain
          steam temperatures and  pressures  at low levels.

2.1  INCINERATOR TECHNOLOGY

     There  are three major  types  of incinerators  currently used to
incinerate  hospital wastes  in the United States:  excess  air,  starved air,
and rotary  kiln.  The design and operating principles  for each  of these
three major types are discussed in thi? section.

2.1.1  Excess Air Incinerators

     Excess air  incinerators are small modular units which typify older,
existing hospital incinerators.  They are also referred to as "pyrolitic
incinerators" and "multiple chamber incinerators" in the literature.  These
incinerators appear as  a compact cube from the outside with a series of
chambers and baffles on the inside.  The two principal design configuration
                                      2-2

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far excess air incinerators,  the in-line and retort types, are illustrated
in Figures 2-1 and 2-2,  respectively.
     In both types of excess  air incinerators,  combustion of the waste
begins in the primary,  or ignition, chamber.  The waste is dried, ignited,
and combusted by heat provided by a primary chamber burner as well as by hot
chamber walls heated by flue  gases.  Moisture and volatile components in the
waste feed are vaporized and  pass,  along with combustion gases, out of the
primary chamber and through a flame port connecting the primary chamber to
the secondary or mixing, chamber.  Secondary air is added through the flame
port and is mixed with  the volatile components  in the secondary chamber.
Burners are also fitted to the secondary chamber to maintain adequate
temperatures for combustion of the volatile gases.  Incinerators designed to
burn general hospital waste operate at total excess air levels of up to
300 percent; if only pathological wastes (i.e., animal and human remains)  i:-
are combusted, excess air levels near 100 percent are more common.
     For in-line incinerators, combustion gases pass in a straight-through
fashion from the primary chamber to the secondary chamber and out of the
incinerator with 90 degree flow direction changes only in the vertical
direction.  The configuration of retort incinerators, on the other hand,
causes the combustion gases to follow a more "tortuous" path through the
incinerator with 90 degree flow direction changes in both the horizontal and
vertical directions.  These flow direction changes, as well as contraction and
expansion of the combustion gases, enhance turbulent mixing of air and
gases.   In addition, fly ash and other particulate matter drop  from the gas
stream as a result of the direction and gas velocity changes and collect on
chamber floors.  Gases exiting the secondary chamber are directed to the
incinerator stack.
     Retort incinerators are described as "unwieldy" by one source in sizes
above 500 Ib/hr capacity while in-line incinerators are felt to  be most
suitable in capacities of 750 Ib/hr or greater:
                                     2-3

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                                                 VMM 111!
        Source:  Reference  3.
Figure 2-1.  Multiple-chamber pathological  waste incinerator.
                                2-4

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Source:   Reference  4.
 Figure 2-2.  In-line multiple-chamber incinerator.
                          2-5

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2.1.2  Controlled Air Incinerators

     Controlled air incineration has become the most widely used hospital
waste incinerator technology over the past 10 to 15 years and now dominates
the market for new systems at hospitals and similar medical facilities.
This technology is also known as "starved air" incineration, "two-stage"
incineration, and "modular" combustion.  While there are some similarities
in operating principles between excess air and controlled-air incinerators,
overall equipment design and appearance are quite different, as illustrated
in Figure 2-3.
     Like excess air  incinerators,  combustion of waste  in controlled air
incinerators occurs  in  two stages.  Waste is  fed into the primary, or  lower,
combustion chamber which  is operated,  as. the  name  implies, with less than  the
full amount  of  air required for combustion.   Under  these sub-stoichiometric
conditions,  the waste is  dried, heated, and pyrolized,  thereby  releasing
moisture  and volatile components.   The non-volatile, combustible  portion  of
the  waste is burned  in the  primary  chamber  to release heat  while  the
non-combustible portion accumulates as ash.   Depending  on  the  heating  value
of the waste and  its moisture  content, additional  heat  may  be  provided by
 auxiliary burners  to maintain  desired temperatures. Combustion air  is added
 to the primary chamber either  from below  the  waste through  the floor  of the
 chamber or through the sides  of the chamber.   The  air  addition rate  is
 usually 40 to 70 percent of stoichiometric requirements.
      Because of the  low air addition rates in the  primary  chamber,  and
 corresponding low flue gas velocities and turbulence levels,  the amount of
 solids entrained in  the gases leaving the primary chamber  are minimized.   As
 a result, most controlled air incinerators can meet current State and local
 particulate matter emission limits without add-on gas  cleaning devices.
      Moisture, volatiles, and combustion gases from the primary chamber flow
 upward through a connecting section where they are mixed with air prior to
 entering the secondary, or upper combustion  chamber.   If the primary  chamber
 gases  are sufficiently hot, they will self-ignite  when mixed with air.  A
 second burner  is  located near the  entrance to the  upper chamber, however, to
                                       2-t>

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                  QA« OWCNAHOC
                        MOM A flr COM»U»T10N AM »OHTS
      Source:   Reference  10.
Figure 2-3.  Schematic for controlled air incinerator,
                           2-7

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pravide additional heat for ignition of the combustible gases and to
maintain a flame in the chamber at all times of operation.  Mixing of these
gases with air is enhanced by the flow direction changes and contraction/
expansion step which the gases undergo as they pass from the lower to upper
chambers.  The air injection rate in the secondary chamber is generally
between 100 and 140 percent of total stoichiometric requirements (based on
the waste feed).11  Thus, the total air added to both chambers can vary
between 140 and 210 percent of stoichiometric requirements (i.e., between 40
and 110 percent excess air).
     The secondary chamber burner is located near the entrance to this
chamber to maximize the residence time of gases at high temperatures in this
chamber.  Bulk average gas residence times  in the secondary chamber
typically range from 0.25 to 2.0 second.  Design exit gas temperatures
generally range from 1400 to 2000°F.12  Natural gas or distillate oil are
the normal fuels  used  for both primary and  secondary chamber burners.
Temperatures  in the primary and secondary chambers are monitored by
thermocouples and controlled automatically  by modulating  the air flow to
each chamber.  Thermocouples are normally located near the exits of  these
chambers.  In the primary  (air-starved) chamber, combustion air  flow is
increased to  increase  temperature;  in  the secondary  (excess air) chamber,
air  flow  is decreased  to  increase  temperature.  The  logic for this control
scheme  is  illustrated  in  Figure 2-4.   Flue  gases exiting  the secondary
chamber are sent  either  directly  to a  stack,  to air  pollution control
equipment  (if required),  or  to  a  waste heat recovery boiler.
     Both  the primary  and  secondary chambers  are usually  lined with
refractory material.   One  manufacturer,  however, offers  a membrane water
wall  in the primary  chamber.   Most  chambers are cylindrical  although some
are  rectangular  or  box-like.   Smaller units (i.e., with  waste feed
capacities  less  than  500 Ib/hr)  are usually vertically oriented  with both
chambers in  a single  casing.   Larger units  generally include  two separate
horizontal  cylinders  located one  above the  other.     Some manufacturers
offer  a third chamber for final  air addition to  the  combustible  gases  and  a
                                      2-8

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                AMABATC TEMPERATURE OF A CELLULOSE WASTE
                 -4O  -IO   0   10  44   to  (O  10O  I1O
         Source:   Reference  15.
Figure 2-4.  Adiabatic temperature  versus excess air
             for a  controlled  air  incinerator.
                           2-9

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fourth chamber for gas conditioning (i.e.,  gas cooling and condensation of
vapors) to minimize effects on downstream heat recovery equipment.
     Waste feed capacities for controlled air incinerators range from about
75 to 6500 Ib/hr of Type 0 waste (at 8500 Btu/lb).  Capacities for lower
heat content wastes may be higher since feed capacities are limited by
primary chamber heat release rates.  Heat release rates for controlled air
incinerators typically range from about 15,000 to 25,000 Btu/hr-ft .

2.1.3  Rotary Kiln  Incinerators

     Like other incinerator types, rotary kiln incineration consists of a
primary chamber in  which waste  is heated and volatized and a secondary
chamber in which combustion of  the volatile fraction  is completed.   In this
case,  however, the  primary chamber consists of a  horizontal, rotating  kiln.
The  kiln  is  incl ined. si ightly so that  the waste material migrates  from the
waste  charging end  to  the  ash discharge end as the kiln rotates.   The  waste
migration, or  throughput,  rate  is controlled  by the rate of rotation and  the
angle  of  incline,  or rake, of the  kiln.  Air  is injected  into the  primary
chamber and  mixes  with the waste as  it rotates through the kiln.   A  primary
chamber burner is  generally present  for heat-up purposes  and to maintain
desired temperatures.   Both the primary and  secondary chambers  are usually
lined  with  refractory brick,  as shown  in the  schematic drawing  in
Figure 2-5.
      Volatiles and combustion gases  from the  primary  chamber  pass  t:> the
secondary chamber where combustion is  completed by the addition of
additional  air and together with the high  temperatures maintained  by a
 second burner.  Like other incinerators,  the primary  chamber  is operated  at
 sub-stoichiometric conditions and  the secondary  chamber at
 above-stoichiometric conditions.  Due to the turbulent motion  of  the waste
 in the lower primary chamber,  particle entrainment  in the flue  gases is
 higher for kiln incinerators  than for controlled-air  or excess  air
 incinerators.  As  a result,  rotary kiln incinerators  generally  require stack
 gas clean-up to meet  applicable particulate matter and/or opacity limits.
                                      2-LO

-------
             •OT»«T KK.M
         Source:   Reference  18
Figure 2-5.   Schematic for rotary  kiln  incinerator.
                           2-11

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2.£  WASTE FEED AND ASH HANDLING SYSTEMS

     Feed systems for hospital waste incinerators range from manually
operated charging doors to fully automatic systems.  Ash removal systems
also range between periodic manual removal of ash by operators to continuous
automated quench and removal systems.  In general, automated systems are
prevalent among large continuously-operated incinerators while manual
systems are employed on smaller incinerators or those which operate on an
intermittent basis.  Waste feed and ash removal systems are discussed below
for each of the major incinerator design types.
     For excess air  incinerators, waste loading is almost always
accomplished manually by means of a charging door on the incinerator.  The
charging door  is attached  to the primary chamber and may be located either
at the end farthest  away from the flame port (for burning general wastes) or
on the side.(for units  hand!ing pathological wastes such as large animals or
cadavars).  As much  as  10  percent of the  total air supplied to  excess air
units  is drawn through  these charging doors.19  Ash removal from excess  air
units  is accomplished manually with  a rake and shovel  at the completion  of
the  incinerator  cool-down  period.  Typical operation for an excess  air
incinerator calls  for  incinerator heat  up  and waste charging at the  end  of
the  operating  day, waste combustion  and burnout by morning, and cool-down
and  ash  cleanout during the  following day.
     Controlled-air  incinerators  may be equipped with  either manual  or
mechanical  loading devices.   For  units  with  capacities less than 200  Ib/hr,
manual  loading through  a charging door  in  the  primary  chamber  is the
typically  the  only option.  Mechanical  loaders,  on  the other hand,  are
standard features  for  incinerators  with capacities  above 500  Ib/hr  waste.
For  units  between  these size ranges, mechanical  feed loaders  are usually
available  as  an  option.21   Most mechanical  loader designs  currently offered
employ a hopper and  ram assembly,  as illustrated  in  Figure 2-6.   In this
 system,  waste  is loaded into a charging hopper and the hopper  cover is
closed.   The  fire door isolating the hopper from the  incinerator opens  and  a
 ram coires forward to push the waste into  the front section of the
                                     2-12

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                  STEP 2
                  RAM COMES FORWARD
                  STEP 3
                  RAM REVERSES TO CLEAR PIRE OOOB
                  STEPS
                  RAM RETURNS TO START
             Source:  Reference  22.
Figure  2-6.   Schematic and  example picture of a mechanical  loading  system.
                                    2-13

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incinerator.  After reaching the end of its travel,  the ram reverses and
retracts to the point where it just  clears the fire door.  The fire door
closes and the ram retracts to its starting position.  These operations are
normally controlled by an automatic control panel.  For smaller
incinerators, waste loading into the charging hopper is usually accomplished
manually, bag by bag.  Larger systems frequently use such waste loading
devices as car dumpers, conveyors, skid-steer tractors, or pneumatic
systems.
      In addition to improving personnel and fire safety, mechanical loaders
limit the amount of ambient air which can  leak  into the incinerator during
waste feeding operations.  This is important for controlled air incinerators
since excess air in-leakage can cause lower temperatures,  incomplete
combustion,  and smoking at  the  stack.  Mechanical loaders  also permit  the
feeding of  smaller waste  batches  at more  frequent,  regular intervals.   As
the  intervals become  shorter, this, feeding procedure approximates  continuous
or  steady-state operation and helps to dampen  fluctuations in  combustion
            24
conditions.
      Ash  removal  techniques  for controlled air  incinerators also  range from
manual  to mechanical  systems.   For smaller units  below about  500  Ib/hr
capacity  (and  units  constructed before  the mid-1970s),  operators  must  rake
and shovel  ash  from  the primary combustion chamber  into disposal  containers:
For larger systems,  mechanical  ash removal may  be accomplished by extension
of the  waste charging ram,  augmented  by  internal  transfer rams.   The
positive displacement action of the  rams  pushes the ash along the bottom of
the primary chamber  until it reaches  a  drop  chute.   Another mechanical
 system offered by one manufacturer uses  a "pulsed hearth" whereby ash  is
moved across the chamber floor by pulsations  created by end-mounted air
cushions.25  After falling through the  drop  chute,  ash either falls into a
drop cart positioned within an air-sealed enclosure or into a water quench
 trough.  The drop cart is removed manually,  generally after spraying  the
 ash with water for dust  suppression.   In the water  trough system, quenched
 ash  is removed either by a drag conveyor or a backhoe trolley system.
                                      2-14

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     When estimating air emissions for controlled air incinerators with
 - &
manual ash removal, it is important to recognize that operating, and hence
emission, rates will vary over time.   A typical  operating cycle for such a
                 27
unit is given by:

           Operation                                Duration
          Ash-clean-out                           15-30 minutes
          Preheat                                 15-60 minutes
          Waste loading                           12-14 hours (maximum)
          Burn-down                               2-4 hours
          Cool-down                               5-8 hours

The waste loading period of 12 to 14 hours per operating day is a maximum
value; a more typical value would be 5 to 6 hours since this corresponds to
                                            28
waste incineration during one shift per day.
     Since rotary, kiln systems operate.in a continuous mode, the waste feed
system and ash removal system which service these incinerators must also be
                                        29
of a continuous or semi-continuous type.    A charging hopper and ram system
is commonly used to load waste into the kiln.  After travelling through the
kiln, ash is discharged on a continuous basis either into an ash cart or
water quench system.  Both this feed system and ash removal system are
described above for controlled air incinerators.
2.3  WASTE HEAT RECOVERY

     Waste heat recovery operations are generally not considered for excess
air  incinerators due to the smaller gas flow rates, lower temperatures,
higher particulate matter loadings, and intermittent operations that
characterize these systems.  For controlled air and rotary kiln
incinerators, however, the relatively higher stack gas temperatures and flow
rates can make heat recovery economically attractive in cases where steam or
hot  water generation rates can be matched with the needs of the hospital.
For  most systems, heat is recovered by passing hot gases through a waste
                                    2-15

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heat boiler to generate steam or hot water.   Boiler equipment can range from
a spool piece with heat exchange coil inserted in the stack to a single-drum
0-type watertube waste heat boiler.  Most manufacturers,  however, use
conventional firetube boilers because they are low in cost and simple to
operate.30  Options for these boilers include supplemental firing of oil or
natural gas and automatic soot-blowing systems.  Outlet temperatures from
waste heat boilers are generally limited to about 400°F by stack gas dew
point considerations.  As mentioned  above, one manufacturer also offers a
waterwall membrane in the primary chamber to enhance heat recovery.
     Other methods to improve overall system efficiency in controlled air
incinerators and, thereby, to reduce the need for expensive auxiliary fuels,
are modulating burners and air  preheating.    EPA-sponsored testing programs
of controlled air incinerators  equipped with these types of systems have
shown  that  heat recovery efficiencies are typically limited to about 50 to
                                      32
60 percent  of the theoretical maximum.
                                       2-16

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2.4  REFERENCES
 1.   Radian Corporation.  Municipal  Haste Combustion Study: Data Gathering
     Phase.  EPA Contract No. 68-02-3889.  November 1986.  p. 1-11.
 2.   Brunner, C. R.  "Biomedical Waste Incineration."  Presented at the 80th
     Annual Meeting of the Air Pollution Control Association.  New York, New
     York.  June 21-26, 1987.  p. 10.
 3.   Block, S. S. and J. C. Netherton.  Disinfection. Sterilization, and
     Preservation.  Second Edition.   1977.  p. 729.
 4.   Reference 3.  p. 727.
 5.   Reference 3.  p. 730.
 6.   Reference 3.  p. 728.
 7.   Reference 3.  p. 730.
 8.   Doucet, L. G.  Controlled Air Incineration: Design. Procurement, and
     Operational Considerations.  Prepared for the American Society of
     Hospital Engineering.  Technical Document No. 55872.  January 1986. •
     p. 1.
 9.   Reference 2, p. 11.
10.   Reference 2.  p. 15.
11.   Reference 2, p. 11.
12.   Reference 8, p. 5.
13.   Basic, J. N.  "Multiple Stage Combustion Design Can Minimize Air
     Pollution Problems."  Presented at the 80th Annual Meeting of the Air
     Pollution Control Association.   New York, New York.  June 21-26, 1987.
     p. 3.
14.   Reference 2.  p. 12.
15.   Reference 2.  p. 16.
16.   Reference 8.  p. 14.
17.   Reference  14.
18.   Reference  15.
                                    2-17

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19\  Reference 6.  p. 730.
20.  Reference 2.  p. 10.
21.  Reference 8.  p. 6.
22.  Consumat Systems Inc.   Consumat Waste Handling  System Technical  Data
     Sheet.  Richmond, Virginia.   Received by Radian Corporation  in  June
     1987.  p. 1.
23.  Reference 8.  p. 7.
24.  Reference 8.  p. 6.
25.  Reference 8.  p. 8.
26.  Reference 8.  p. 8.
27.  Reference 8.  p. 14.
28.  Allen, R. J, G.  R.  Brenniman, and C. Darling.  "Air Pollution Emissions
     from  the  Incineration of Hospital Wastes."  Air Pollution Control
     Association Journal. Volume 36, No. 7, July 1986.
29.  Reference 2.  p. 12.
30.  Reference 8.  p. 9.
31.  Reference 8.  p. 9.
32.  Reference 8.  p. 9.
                                      2-18

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          3.0  AIR EMISSIONS/FACTORS FOR HOSPITAL WASTE INCINERATORS
  /•.•

     Many sources of information were used to collect available hospital
incinerator emissions data.   A survey of pertinent literature was performed
and contacts were made within EPA,  State and local government organizations,
trade organizations, and incinerator vendors.
     Table 3-1 contains a list of pollutants covered by this study.   The
compounds shown here are those for which emissions data could be located  for
hospital incinerators.  As expected, data for some pollutants was plentiful.
while few data were found for others.  One large data gap in the current
hospital waste incinerator emissions data base is for lower molecular weight
organic compounds.  In addition, emission data were located only for larger
controlled air incinerators; data were not located for the smaller
retort-type incinerators which comprise a large portion of the total
population by number.
     This section contains brief descriptions of" formation mechanisms for
pollutants for which data were found in this study.  Where applicable,
information on formation mechanisms for these compounds has been borrowed
from the municipal solid waste (MSW) literature.  Next, the emissions test
data are presented along with other data which were found as part of the
study.  A discussion relating emissions data to design and operating factors
follows.  Finally, the emissions factors developed for each pollutant are
presented.

3.1  FORMATION MECHANISMS

3.1.1  Acid Gases

     The acid gases considered in this study were hydrogen chloride, sulfur
dioxide, and nitrogen oxides.  A brief description of the formation
mechanism and factors which  influence their  formation is presented next.
                                    3-1

-------
                                       TADLE  3-1.   POLLUTANTS MEASURED/TESTED
         Trace
         Metals
               Polycycllc
                Organic
                 Matter
  Low Molecular Weight
   Organic Compounds
   Add Gases
      Others
GJ
I
ro
Arsenic

Cadmium

Chrcmlum

Iron

Manganese

Nickel

Lead
                       Dloxins

                       Furans
Ethane

Ethylene

.""ropane

Propylene

Trichlorotrlfluoroethane

Trlchloroethylene

Tetrachloroethylene
Hydrochloric Add

Sulfur Dioxide

Nitrogen Oxides
Partlculate Matter

Carbon Monoxide

Pathogens

Viruses

-------
     3.1.1.1  Hydrogen Chloride.   Based on thermodynamic considerations,
 . ft           ^^i^wi^^^™^^^^^^^^™^^^^^^^^^—^—
chlorine which is chemically bound within the hospital  waste in the form of
polyvinyl  chloride (PVC) or other compounds will be predominately converted
to hydrogen chloride (HC1), assuming there is hydrogen available to react
with the chlorine.  Considering the high hydrogen content of hospital  waste
due to its high paper, plastics,  and moisture content,  there should be a
ready supply of hydrogen available in most cases.
     Swedish studies have found that 60 to 65 percent of the fuel-bound
chlorine in MSW is converted to HC1.   There is no apparent thermodynamic
reason for the less than full conversion.  HC1  has also been shown by other
                                                                    2
studies to be the predominate chlorine product at high temperatures.

     3.1.1.2  Sulfur Dioxide.  Sulfur, which is chemically bound within the
materials making up the hospital  waste, is oxidized during the combustion
process to form S02.  The rate of S02 emissions is, therefore* directly  .
proportional to the sulfur content of the.waste.  Some SO- removal may take
place through reaction of the SO- with alkaline reagents also present within
the waste; however, the amount of removal is expected to be negligible due
to the high HC1 content of the flue gas.  Because it is a stronger acid than
SO-, HC1 will react more quickly with available alkaline compounds than S02
and, because of the high HC1 content of flue gases, will likely tie-up the
alkaline compounds before they have a chance to react with SO-.

     3.1.1.3  Nitrogen Oxides.   Nitrogen oxides or NO  represents the
                                                     A
mixture of NO and NO-.  However,  in combustion systems, predominantly NO is
produced due to kinetic limitations in the oxidation of NO to NO-.  N0x is
formed by one of two general mechanisms.  "Thermal NO " is the result of the
reaction between molecular nitrogen and molecular oxygen, both of which
enter the combustion zone in the combustion air.  "Fuel NO " results from
                                                          A
the oxidation of monoatomic nitrogen which enters the combustion zone
chemically bound within the fuel  structure.
                                     3-3

-------
  '"  Although the detailed mechanism of thermal  NOX formation is not well
understood, it is widely accepted that the thermal  fixation in the
combustion zone is described by the Zeldovich equations:

                    N2 + 0——NO + N

                    N + 02—-NO + 0

     The first reaction is the rate limiting step and is strongly
endothermic due to the requirement of breaking the N2 triple bond.   It is
the high endothermicity of this process which has led to the term thermal
NO  .  The  reaction rates of these equations are highly dependent on both .the
mixture stoichiometric ratio  (i.e., the molecular equivalent air-to-fuel
ratio, with rich  and  lean describing  the  fuel amount) and  the flame
temperature.  The maximum NOX occurs  at slightly lean fuel mixture ratios
due to the excess availability of oxygen  for reaction within the hot flame
zone.  A rapid decrease  in NOX formation  is seen for ratios which are
slightly higher or lower  than this.   The  rate of thermal NOX formation  is
extremely  sensitive  to  the flame  temperature, dropping almost an order  of
magnitude  .with every 100°C drop  in  flame  temperature.
      The mechanisms  by  which  nitrogen compounds  (primarily organic)
contained  in  liquid  and  solid fuels  evolve  and  react to  form NOX  are much
more  complex  than the Zeldovich  model,  and  the  empirical data are less
conclusive.
      The  impact  of  temperature  and  fuel  nitrogen on  NOX  emissions for  excess
 air conditions  is shown in  Figure 3-1.   The figure indicates  that thermal
 NO  formation is  extremely  sensitive to temperature, but fuel NOX formation
   x
 is not.
 3.1.2  Particulate Matter
      Particulate matter (PM) is emitted as a result of incomplete combustion
 and by the entrapment of noncombustibles in the flue ?as stream.  PM may
                                     3-4

-------
                3140    2813
 T(°F)

2509    2310   2112    1941
    10.00Q
      1000
      100
   Q_
   Q.
   a  10
       1.0
      0.1
   MAX
   EXPECT
   ED
   ADIA-
   BATIC
   TEMP.
                                            0.5% FUEL N
           301 EXCESS AIR

           r- 0.5 SEC.

                 THERMAL NO
                    FUEL N
         0.45    0.50   0.55    0.60    0.65    0.70

                               103/T(K"1)
  Source:  Reference 3.
Figure 3-1.   Impact of temperature and fuel  nitrogen on NOX emissions
            for excess air conditions.
                              3-5

-------
ex\st as a solid or an aerosol, and may contain heavy metals or polycyclic
organics.  Depending on the method used to measure the PM in the flue gas,
lower boiling point volatile compounds (i.e., boiling point below 100 C) may
or may not be included in the measurement.
                                          ^
     There are three general sources of PM :

     o    inorganic substances contained  in the waste feed that are carried
          into the flue gas from the combustion process,

     o    organometallic  substances formed by  the reactions of precursors  in
          the waste feed, and

     o    uncombusted  fuel  molecules.

 Inorganic matter  is not destroyed  during  combustion; most of  this material
 leaves  the  incinerator .as ash.   Some,  however,  becomes  entrained  in  the
 stack gas as  PM.
     Organometallic compounds  present  in  the waste  stream which  is being
 incinerated  can  be volatilized and oxidized  under  the high  temperatures and
 oxidizing conditions  in  the incinerator.   As a result  inorganic  oxides  or
 salts of metals  can be formed  from the metallic portion.   Elemental  analysis
 of flyash  from MSW incinerators has shown that particulate  emissions are
 largely inorganic in  nature and that  they are  from one-third  to  one-half
 soluble in  water.  The water soluble  phase is  principally  chloride  and
 sulfate salts of Na,  P,  Ca, Zn, and NH4*.  The insoluble phase is comprised
 of oxides,  silica, and phosphate salts of Al,  Si,  Ca,  Pb,  Zn, and Fe along
 with some insoluble carbon compounds.5  To the extent that a particular
 hospital waste is similar to municipal waste,  the resulting ash might be
 expected to be similar.  (See Section 1.2 for discussion of hospital waste
 composition and categorization.)  The fuel molecules themselves can also
 contribute significantly to PM formation.  It is known that pyrolitic
 reactions can lead to the  formation of large organic molecules.  Inorganics,
                                     3-6

-------
wh,ich may act as nucleation sites, may then further induce growth..  The
 -*•                                                           5
result can then be an organic particle with an inorganic core.
     In general, good combustion conditions which depend on residence time,
temperature, and turbulence lead to lower PM emissions.  As the residence
time increases, particle size and the mass of PM tend to decrease.  Smaller
particulate sizes and lower PM emissions are also associated with higher
temperatures since, at higher temperatures, oxidation rates are increased so
that more of the combustible PM is oxidized to gaseous products.

3.1.3  Trace Metals

     The amount of trace metals in the flue gas is directly related to the
quantity of trace metals contained in the incinerator waste.  Some of the
trace metal sources in the waste include surgical blades, foil wrappers,
plastics, and printing inks.  Plastic objects made of PVC contain cadmium
heat stabilizing compounds.  In addition, cadmium, chromium, and lead may
also be found in inks and paints.
     Some metals are selectively deposited on the smaller particulate sizes
which are emitted.  This is known as fine-particle enrichment.  Although
such data were not found for hospital incinerators, metals generally thought
to exhibit fine-particle enrichment are As, Cd, Cr, Mn, Ni, Mo, Pb, Sb, Se,
V, and Zn.   Results of one study performed at a MSW facility indicate that
trace metals are found predominately in the respirable particulate fraction,
even when the bulk of the particulate matter emissions are in the
                       g
nonrespirable fraction.
     There are three general factors affecting enrichment of trace metals on
                g
fine particulate :

     o    particle size,
     o    number of particles, and
     o    flue gas temperatures.
                                    3-7

-------
    influence of particle size on trace metal  enrichment of fine particles
is thought to be due to specific surface area  effects (i.e.,  the ratio of
particle surface area to mass).  Particles with large specific surface areas
are expected to show more enrichment since there is more surface area for
condensation per unit mass of PM.  The influence of the number of particles
is simply due to the increased probability of contact associated with higher
particle population.  There is some evidence that less enrichment occurs at
higher flue gas temperatures.10  Higher temperatures are thought to lead to
increased activity levels which  in turn makes the metals less likely to
condense and bond with PM.  Mercury, due to its high vapor pressure, does
not show significant particle enrichment; rather it  is thought to leave
largely in the vapor form due to high  typical  exit gas temperatures.  For
example, the results of one study performed at a MSW facility indicated that
less than 25 percent of the mercury emissions were found to be  in the
particulate  phase of the  stack gas.  .                        .

3.1.4  Organic  Emissions

     Figure  3-2  presents  a  schematic  of  the processes which are  involved
during hospital  waste  combustion in a two-stage  incinerator.  After  startup,
the  hospital waste  is  heated  by  the burning gases  being  combusted  in  the
primary  chamber and by the  natural  gas or oil  burner operating  in  that
chamber.   During startup,  heat is-supplied  by  the  fossil  fuel burner  alone.
Upon heating,  waste fragments emit  steam,  volatile matter, and  PM.   These
materials  are  swept from the  bed by natural convection  and by entrainment
with underfire air.   It is  the burning of volatile matter above the  waste
bed  which  provides  the heat which  continues  the pyrolysis and volatile
matter evolution from the waste.  The amount  of radiant heat  transfer to the
waste  is strongly dependent on the local  flame temperature of the  compounds
 being  combusted; the flame temperature,  in turn,  is  a function  of  moisture
 content,  volatile matter heating value,  and the local  air stoichiometry.
 Not all  the volatile matter is combusted in the primary chamber.  Combustion
 gases  are swept from the primary chamber to the secondary chamber  where
                                     3-8

-------
                                                  CO + OH — C02 +

                                                  OH + H  — H20
                                                                                 C02. H20.  02.
OJ
I
vD
         HOSPITAL-
         WASTE
     HIGH  TEMPERATURE

     HIGH  0.  H.  OH  RADICALS


      0
 H  + OH — CO + H20 +  OH + H


-------
volatile matter combustion continues, augmented by the heat generated by a
second fossil fuel burner.  The volatile matter combustion process is
controlled by chemical kinetics and proceeds through complex reactions
involving 0, H, and OH radicals.  The kinetics of these processes is
strongly temperature dependent.  An efficient burning process will result in
a high degree of conversion of volatile organics to C02 and H20.  Failure to
achieve the  requirements which lead to efficient combustion can result  in
high emission rates of combustion products  in an unreacted or partially
reacted state.
     The unreacted or partially reacted combustion products discussed in
this report  include the  chlorinated  isomers of dibenzo-p-dioxin  (COO) and
dibenzofuran (CDF), lower  molecular weight  organic compounds for  which
emissions data were available,  and carbon monoxide  (CO).   A brief
description  of the  formation  mechanism  and  factors which  influence  the
formation of these  compounds  is presented  in  the  following subsections.
Other  important  classes  (e.g.,  PIC.s,  BaP,  PCBs,-PAH,  POM)  are  not included
due  to lack  of emissions data.

      3.1.4.1  Dioxins and Furans.   Many factors  are  believed to be  involved
 in  the formation of CDDs and CDFs  and many different theories  exist
 concerning  the formation of these  compounds.   The best supported theories
 are illustrated  in Figure 3-3.12   The first theory shown  involves the
 breakthrough of  unburned COD/CDF  present in the  feed.13  A few measurements
 of MSW feed streams have "indicated the presence  of trace  quantities of
 CDD/CDF in   the refuse feed. . No such measurements have been maae for
 hospital  waste streams but some potential  for CDD/CDF in  the feea may exist
 due to similarities in the wastes.
      The second mechanism shown in Figure 3-3 involves the more plausible
 combination of precursor  species which have structures similar to the
 dioxins and furans to form the CDD/CDF compounds.  Such a reaction would
 involve the combination of chlorophenols or polychlorinated biphenyls to
 form CDD/CDF.  These precursors can  be produced by pyrolysis in
 oxygen-starved zones, such as those  which exist in multichamber
                                     3-10

-------
I.    DIOXIN  IN  REFUSE
     Cl
     Cl
                  O
                                   Combustion
                                      Zone
Unreacted
 CDD/CDF
II.   FORMATION  FROM  RELATED CHLORINATED PRECURSORS
             OH
      To
     ci
          Chlorophenol
                                                          Cl
                                                                   }	Cl
                 PCB
III.   FORMATION FROM  ORGANICS AND CHLORINE DONOR
      PVC          Chlorine donor
      Lignin   *   NaCl,  HC1, C12
IV.   SOLID  PHASE  FLY ASH REACTION


               Precursor
               ^
                 +     Cl Donor —
                                    low
                                              CDD/CDF
                                                       CDD
Source:   Reference  12.

    Figure 3-3.   Hypothetical Mechanisms of CDD/CDF Formation Chemistry,
                                    3-11

-------
incinerators.14  The potential for PVC-bearing wastes,  a typical  component
of hospital waste, to form precursors during combustion has been  studied by
several researchers.  '
     The third mechanism shown in Figure 3-3 involves the synthesis of
PCDD/PCDF from a variety of organics and a chlorine donor.    The simplest
mechanisms here involve the combination of those species which are
structurally related.  Many plausible combustion intermediates can also be
proposed which lead to precursors and eventually to CDD/CDFs.  Analysis of
intermediates formed during the combustion of complex fuels such as coal or
wood indicate yields of unchlorinated dioxin and furan species.  These
compounds could become chlorinated  in systems such as hospital waste
incinerators where  high concentrations of molecular chlorine exist in the
combustion zone.
     The  final mechanism presented  in Figure 3-3 involves  catalyzed reactions
on  fly  ash particles  at low  temperatures.   In research  sponsored by the
Ontario Ministry  of Environment,  formation .of CDDs/CDFs were observed when
the thermolysis products of  PVC  combusted  in  air were  heated to  300 C  in  the
presence  of  clean fly  ash.18   These results  are not yet published, pending
attempts  to  reproduce  these  findings.
     There is  a growing  consensus of opinion  that  the  formation  of dioxins
and furans in  combustion  furnaces requires  excess  air.     Excess air
combustion leads  to lower  combustion temperatures  which favor  in-situ
chlorine  formation over HC1.   The additional  presence  of  chlorine  is  then
believed  to  promote the formation of dioxins and  furans.
      CDDs and CDFs may exist in both the vapor phase  and  as fine particulate
 in hospital  waste incinerator emissions.  They may be  split between  phases
with as much as 80 percent in the vapor phase.20   At  temperatures  below
 300°F, they condense onto the fine particulate.

      3.1.4.2  Low Molecular Weight Organic Compounds.   Low molecular weight
 organic compounds  (LC) are a product of incomplete combustion of the
 volatiles which are evolved  f-om the waste.  They may be present due to
 some of the same mechanisms  previously discussed above for dioxins and furan
                                     3-12

-------
(i-.e., they may be compounds which were present in the fuel, combinations of
precursors, or the dioxin and furan precursors themselves).   LCs are
produced when the combustion conditions are other than optimal.  In general,
the optimum combustion conditions can be characterized by the three T's;
time, temperature, and turbulence.  Time refers to the amount of time which
the fuel is subject to combustion conditions; temperature refers to the
temperature at which the combustion takes place or that combustion products
are exposed to; and turbulence refers to the degree of mixing between oxygen
and the fuel.  The longer the time, the higher the temperature, and the
greater the degree of turbulence in the zone where the organics are
combusted,  the better the combustion and the lower the LC emissions will be.

     3.1.4.3  Carbon Monoxide.  Carbon monoxide (CO) is also a product of
incomplete combustion in the final combustion zone depicted in Figure 3-2.
As shown, CO is one chemical reaction away from being CO- which represents
complete combustion.  Its presence can also be related to the time,
temperature, and turbulence conditions of combustion.  In this case, the
three T's are specific to the conditions which exist above the" region in
which the LCs are oxidized.

3.2  EMISSIONS TEST DATA

     Data were acquired from four comprehensive emissions tests of hospital
incineration units.  '''    In addition, results of several less
detailed tests at hospital incinerator units were located through the
literature.  A description of each of the four units for which
comprehensive information was obtained and the operating conditions recorded
during the emissions tests are presented in Table 3-2.  As shown, all of the
units are large incinerators near the upper end of the size range for
hospital incinerators.  The smallest unit for which comprehensive test
results were found is an 800 Ib/hour unit and the largest was a 2000 Ib/hr
unit.  Over the period of the comprehensive emissions tests, the units
operated at 82 to 98 percent of feed rate design capacity.  The Illinois
                                     3-13

-------
              TABLE 3-2.
TEST SITE DESIGN AND OPERATING PARAMETERS FOR COMPREHENSIVE EMISSION TESTS
I
1-"
4=.
	 . 	 • 	


Incinerator Mfg.
Mc
-------
incinerator operated at 500 to 800 Ib/hr feed rate during the test; its
maximum design capacity is not known.
     All of the units for which comprehensive emissions tests were conducted
are starved air incinerators with two  combustion chambers.  The operating
temperatures for the four units are similar.   The secondary combustion
chamber operating temperature range is slightly lower for the Illinois
hospital incinerator than for the other units.  It should be noted, that the
secondary chamber temperature data for the Illinois unit include both
start-up and shutdown periods.  Thus,  the lower end of this range most
likely corresponds to these transient  operating conditions.
     The stack parameters for all of the units are within what was
determined to be the normal design range (see Section 6.0).  Unfortunately,
little information is available regarding the operating conditions of the
Illinois unit.  No information was available  regarding the characteristics
of the hospital wastes .which.were incinerated by any of these units.
     No emissions data were located for the smaller retort-type incinerators
which comprise a large portion of the  total population by number.  In terms
of waste throughput, and hence total emissions, they represent a smaller
share.  However, it is important to remember  that the emission data and
factors discussed in this section are  based on the performance of relatively
large controlled air incinerators.  More data is needed to accurately
characterize emissions from smaller retort incinerators.

3.2.1  Acid Gases

     Hydrogen Chloride.  Table 3-3 contains a summary of the hydrogen
chloride (HC1) emissions data which were gathered during this study.
Emissions factors are also shown for each of the units.  Additional data
beyond what is presented are also available through states which require
testing for HC1 emissions.  The HC1 emissions results of Table 3-3 are
presented with the results of the comprehensive emissions tests placed above
                                                                     25
those units for which information was  obtained from a survey article.    The
emissions data obtained from the survey article are for units located in
Canada.  For the purposes of presentation, the results of the summary
                                    3-15

-------
TABLE 3-3.   DATA/FACTORS  FOR  HYDROGEN CHLORIDE EMISSIONS
            FROM HOSPITAL WASTE  INCINERATORS
Hospital
Cedar Sinai3
High
1 Ml I
1 flUI
^ WV
Average
St. Agnes
High
1 nw
I.XJW
Average
Roya] Jubilee0
High
1 At
i nw
L. \J •»
Average
Illinois Unitd
High
Low
^ \J rW
Average
Athabasca
Bonnyville
Will ingdon
Lacombe
Ft. McMurray
St. Michaels
Queen El izabeth II
Queen Elizabeth II
Queen Elizabeth II
Add On
Control Device/
Heat Recovery
Fabric Filter


None

None


None

None
None
None
None
None
None
None
None
None
Incinerator
Feed Rate
(Ib/hr)
980


783

1,930


500-800

85
130
130
150
265
465
575
700
700
HC1
Concentra-
tion
(ppmv)
521.0
403.0

462.0
926.0
764.0
845.0
1,520.0
983.0

1,252.0
1,490.0
170.0
550.0
41.0
62.2
308.0
234.5
700.0
2,095.0
115.0
287.0
378.0
Emissions
Factor
(Ib/ton
feed)
17.6
13.7

15.7
40.2
33. T
36.7
65.7
42.5

54.1
10.6*
6-6!
_P
8.6e
68.1
16.5
24.3
14.6
48.6
99.4
22.3
19.1
25.3
                           3-L6

-------
          TABLE 3-3.  DATA/FACTORS FOR HYDROGEN CHLORIDE EMISSIONS
                FROM HOSPITAL WASTE INCINERATORS (CONTINUED)
Hospital
Misericordia
Misericordia
Royal Alex
Royal Alex
Foothills
Lethbridge Gen.
Univ. of Alberta
Univ. of Alberta
Add On Incinerator
Control Device/ Feed Rate
Heat Recovery (Ib/hr)
None
None
None/Yes
None/Yes
None
Wet Scrubber/Yes
Wet Scrubber/Yes
Wet Scrubber/Yes
740
740
1,160
1,200
2,500
1,060
1,400
1,400
HC1
Concentra-
tion
(ppmv)
670.0
687.3
553.0
562.0
702.0
44.6
64.7
25.4
Emissions
Factor
(Ib/ton
feed)
63.1
63.1
84.5
79.6
72.8
5.9
0.7
4.4
 Reference 21.
Reference 22.
Reference 23.
 Reference 24.
e8ased on emissions factors  presented  in  Reference  24.
 Reference 25.
                                    3-17

-------
article are shown in order of ascending feed rate.   As shown,  there is no
   •.-
correlation between the unit feed rates and the HC1  emissions.   This is
understandable because, as previously stated, the level  of HC1   emissions
should be directly related to the percentage of chlorine-containing
compounds in the waste fed to the unit.  Unfortunately,  no information was
given regarding the percent chlorine in the wastes being burned.
     Two of the units  for which emissions data are available have scrubbers
which are used for acid gas control.  These units have the lowest emissions
rates of those shown.  The type of scrubbers used was not identified in
Reference 25.

     Sulfur Dioxide and Nitrogen Oxides.  Table 3-4 summarizes the emissions
data and calculated emission factors for S02 and NOX-  As can be seen, there
are limited data available for these compounds.  The only two sources  found
were the state of California test reports.
     On a concentration basis, the emission  rates for the pollutants in
Table 3-4 are relatively  low.  For the  highest S02 concentration, 50 ppmv,
an equivalent SO- emissions  rate of 0.15 Ib/million Btu  is determined  by
assuming a mean heat  content of  10,000  Btu/lb  for hospital waste.  A mean
heating value of 5,000 Btu/lb corresponds to an SO- emissions rate of
0.3 Ib/million Btu.   The  corresponding  maximum NOX emissions rates  (based on
the 270 ppmv  rate)  are 0.4  and 0.8 ID/million  Btu for heat contents of
10,000 and  5,000 Btu/lb,  respectively.

3.2.2  Particulate  Matter

A great deal  of  PM  emissions data  have been  collected.   Some of  the most
readily  available  data are  shown in  Table  3-5.  Much  of  this data  has  been
collected  because  many states  require  hospital  incineration units  to  meet
PM emission  limits.   Testing is, therefore,  carried  out  on  a routine  basis.
 In addition,  as  previously  stated,  vendors  frequently offer guarantees
 regarding  PM emissions.
                                     3-L8

-------
             TABLE 3-4.   DATA/FACTORS  FOR  S02 AND NOX  EMISSIONS
                      FROM HOSPITAL  WASTE  INCINERATORS
Cedar Sinai
Medical Center
Los Anaeles. CA
Pollutant
Sulfur Dioxide
High
Low
Average
Nitrogen Oxides
High
Low
Average
(ppmv)

50
25
37

270
160
217
(Ib/ton
feed)

3.01
1.51
2.22

7.82
4.64
6.29
St. Agnes
Medical Center
Fresno. CA
(ppmv)

20
19
19

155
155
155
(Ib/ton
feed)

1.54
1.47
1.47

5.75
5.75
5.75
Emissions
Factor
(Ib/ton
feed)

3.01
1.47
1.85

7.82
4.64
6.02
 Reference  21.
^Reference  22.
                                   3-19

-------
TABLE 3-5.  DATA/FACTORS FOR PARTICULATE  EMISSIONS
         FROM HOSPITAL WASTE INCINERATORS9
Hospital
Cedar Sinai3
High
Low
Average
St. Agnesb
High
Low
Average
Royal Jubilee0
High
Low
Averaga
111 i no is Unit
High
Low
Average
Athabasca
Will ingdon
Bonnyville
Lacombe
Ft. McMurray
W.C. McKen.
Red Deer
St. Michaels
Queen Elizabeth II
Add -On
Control Device/
Heat Recovery
Fabric Filter/No
None/No
None/No
None/No
None/No
None/No
None/No
None/No
None/No
None/No
None/Yes
None/No
None/No
Incinerator
Feed Rate
(lb/hr)
980
783
1930
500-800
85
130
130
150
265
275
410
465
575
Particulate
Loading
(gr/dscf)
0.002
0.001
0.001
0.090
0.080
0.080
0.028
0.022
0.025
0.170
0.020
0.040
0.050
0.070
0.080
0.070
0.050
0.020
0.080
0.080
0.030
Emissions
Factor
(Ib/ton
feed)
0.10
0.05
0.07
5.45
4.S4
5.15
1.82
1.37
1.60
3.20^
2.00*
2.60e
26.92
1.69
11.85
5.87
13.28
3.20
36.49
1.70
6.12
                       3-20

-------
              TABLE 3-5.  DATA/FACTORS  FOR  PARTICULATE  EMISSIONS
                 FROM HOSPITAL WASTE  INCINERATORS9  (CONTINUED)
Hospital
Queen Elizabeth II
Misericordia
Misericordia
Royal Alex
Royal Alex
Foothills
Lethbridge Gen.
Univ. of Alberta
Add-On Incinerator
Control Device/ Feed Rate
Heat Recovery (Ib/hr)
None/No
None/No
None/No
None/Yes
None/Yes
None/No .
Wet Scrubber/Yes
Wet Scrubber/Yes
700
740
740
1,160
1,200
2 , 500
1,060
1,400
Particulate
Loading
(gr/dscf)
0.030
0.060
0.100
0.030
0.070
0.060
0.040
0.020
Emissions
Factor
(Ib/ton
feed)
2.70
2.97
4.76
3.41
3.30
1.76
2.12
1.23
Reference 21.
 Reference 22.
Reference 23.
 Reference 24.
eBased on emissions factors presented in Reference 24.
fAll of the information from Athabasca to Univ.  of Alberta are from
 Reference 25.
gAll the incinerators identified in this table were two-stage controlled air
 units.  The University of Alberta unit had a rotating  hearth for a primary
 chamber; all  other units had a fixed primary chamber.
                                     3-21

-------
 .-,,  The PM emission results in Table 3-5 include the results of the
comprehensive emissions tests (the first four hospitals) and test results
obtained from the survey article.26  These units are the same units for
which HC1 data were presented.  The data shown from the survey article are
arranged in order of ascending feed rate to show any effect of unit size on
PM emissions.  The emission  factors in Table 3-5 show no clear trend between
specific PM emission rates and unit size.  It is interesting to note that
the highest emission factors  (above 10 Ib/ton feed) are associated with  the
smaller  units  (below 400 Ib/hr).   Based  on the information  in Section 2.1,
these units may well be excess air incinerators.  Unfortunately, no design
information is available to  confirm this hypothesis.
     Emissions results  for units  operating with  PM  control  equipment are_
also shown  in  Table  3-5.  The  Cedar Sinai unit,  which was  installed with a
fabric  filter  for  PM control,  had the  lowest  PM  emissions  factor of those
presented.  The  control  efficiency for the  filter was 98  percent.   The  other
two  units  which  had  PM control  equipment are  the Lethbridge General and
University of  Alberta  units.  The emissions  factors for these  two  units are
considerably  higher  and are  not  markedly different  from incinerators
operated without PM  control  equipment.  This  may be explained  by  the  fact
that these units were  operated for acid gas  control and not for PM removal.
Unfortunately  no inlet data were given for  these units  so the  control
efficiency could not be determined.

 3.2.3   Trace Metals

      Table 3-6 contains a summary of the available trace metal  emission data
 for hospital  waste incinerators.  An emissions factor based on the waste
 feed rate to the unit is also given for each of the emissions rates
 presented.  In addition, for the  Cedar  Sinai uni't, results for upstream and
 downstream of the fabric filter  are presented.
      No additional trace metals  data were identified by the study.  Because
 two of  the reports are from California, a state recently beginning to
                                      3-22

-------
                                      TABLE 3-6.   DATA/FACTORS  FOR TRACE ELEMENT EMISSIONS  FROM HOSPITAL  WASTE  INCINERATORS
PM
Device
a d
CeJjr Slnal '
High
Low
Average
High
Low
Average
b,d
St . Agnes
High
Low
Average
Royal
• c d
Jubilee
High
Low
Average


Y
Y
Y
N
N
N


N
N
N



N
N
N

As
Cd
gr/dscf Ib/con
(xlO~6) 


0.103
0.112
.0.109
140
59
92


67
46
55



52.4
24.7
38.6
Ib/con


0.053
0.050
0.051
68.0
• 29.0
44.4


40.9
24.8
31.9



33.2
15.5
24.4
Cr
gr/dscf
(xlO~6)


0.069
0.016
0.046
7.46
2.15
4.09


11
5
a



30.9
16.3
23.6
Ib/con


0.032
0.008
0.021
3.63
1.02
1.98


6.07
2.88
4.69



19.5
10.2
14.9
Fe
gr/dscf


0.516
0.474
0.502
153
85
65


166
68
130



292
284
238
Ib/ton
(xlO-4>


0.245
0.227
0.238
72.6
41.2
55.3


101.6
39.8
75.1



183
180
182
Mn
gr/dscf
(xlO~6)


0.112
0.103
0.109
9.23
6.74
8.30


7
3
' 5



18.1
12.3
15.2
Ib/con
(xlO~4)


0
0
0
4
3
1


3
1
2



11
7
9


.05}
.051
.051
.37
.29
.96


.93
.58
.88



.4
.8
.6
Nl
gr/dscf
<»10~6)


0.645
0.593
0.628
2.34
2.22
2.28


5
3
4



8.0
5.8
6.9
Ib/con



0.304
0.214
0.267
1.12
1.08
1.10


2.80
1.58
2.38



5.0
3.6
4.3
PI.
gr/dscf

-------
require testing, it can be assumed that future tests will  be a source for
additional data.
     Analysis of the Cedar Sinai data indicate that there is a substantial
reduction in trace element emissions across the fabric filter.  No
statements can be made relative to trends in the data relative to
incinerator size.

3.2.4  Organic Emissions

     Chlorinated Dibenzo-D-Dioxins (CDDs) and Chlorinated Dibenzofurans
(CDFs).  Tables 3-7 and 3-8 contain summaries of the available emissions
data for CDD and CDF compounds  from hospital  incinerators.  An emissions
factor based on waste  feed rate to the unit is also given for each of the
emissions rates presented.  The homolog emission data from three emissions '
tests  are shown.   Limited  isomer  emission data were available for the Cedar
Sinai  and St. Agnes tests.  For the Cedar Sinai unit results  from both
upstream  and downstream of the  fabric  filter  are presented.
     At this time,  these  are  the  only  reported CDD  and CDF emissions test
results for  hospital  incinerator  units which  are known to exist.  An
additional  unit  located at Stanford University Medical Center in California
was  also  recently  tested  for  CDDs and  CDFs.27  The  results of this test  were
not  available  as  of the writing of this  report.  The California Air  Resource
Board  (CARB)  has  recently begun to require  testing  for CDDs and CDFs at
newly  installed hospital  'incinerators  so  additional data will be avai^.ble
through  CARB in the future.
     Analysis  of the  emissions  data  presented for  the unit  at Cedar  Sinai
 indicates that for most  of the  dioxin  and  furan  homologs,  a slight reduction
occurs across  the fabric  filter.   The  subgroups  for which  this  reduction was
not  seen  are the TCDD and TCDF  homologs.   Results  of  ash  analyses  are
presented in Table 3-9.
      No  statements can be made  relative  to trends  in  the  data related  to
 unit size or operating characteristics because too little  is  known  about the
 operation of each of the facilities during testing.
                                      3-24

-------
                            TABLE  3-7.   DATA/FACTORS FOR CHLORINATED MMHteOFtntAttS EMISSIONS FROM HOSPITAL WASTE INCINERATORS
U>
 I
Ul

a d
Cedar Slnal '
Hedlcal Center
Los Angeles, CA
(Fabric Filter)
(ng/nM3)
(Tetra) TCDF
High
Low
Average
(Penta) PeCDF
High
Low
Average
(Hexa) HxCDF
High
Low
Average
(Hepta) HpCDF
High
Low
Average
(Octa) OCDF
High
Low
Average
Total PCDF
High
Lou
Average
Reference 21.
Reference 22.
Reference 23.

6
5
5

18
1*
16

27
20
23

51
49
50

39
26
32

130
129
129




.09
.85
.97

.30
.50
.40

.40
.40
.90

.10
.40
.25

.20
.50
.85

.00
.00
.50



(Ib/ton
feed)
(»10 )

0.13
0.12
0.12

0.38
0.30
0.34

0.57
0.42
0.49

1.05
1.02
1.04

0.81
0.55
0.68

2.69
2.67
2.68



Cedar Slnal
Hedlcal Center
Los Angeles. CA
(Uncont rol led)

-------
                             TABLE 3-8.   DATA/FACTORS FOR CHLOR.NATED OH.mO-p-tm.XlH* EMISSIONS FROM HOSPITAL WASTE INCINERATORS
 I
N>

a d
Cedar Sinai
Hedlcal Center
Lit Aiigele*. CA
(tb/lun
f.eg)
(ng/nM ) (»10 )
(Tetra) TCUD
High
Low
Average
(Pent a) PeCOO
High
Low
Average
(Hexa) HxCDD
High
Low
Average
(Uepta) HpCOD
High
Low
Average
(Octa) OCDD
High
Low
Average
Total PCDO
High
Low
Average
67.10
56.50
61.80
101.00
80. tO
91.70
118.00
90.90
104.45
110.00
109.00
109. SO
49.10
38.00
43.55
43*. 00
106.00
270. SO
1.38
1.17
1.28
2.12
1.67
1.89
2.1.4
1.88
2.16
2/27
2.25
2.26
1.02
0.7d
0.90
8.98
8.01
8. SO
Cedar Slnal
Medical Center
Lot Angeles, CA
(ng/nM1)
79.8
3S.S
. S9.2
106.0
68.9
92.6
163.0
116.0
144.0
204.0
1S2.0
169.7
163.0
67.7
10S.1
69S.O
441.0
570.7
(Ib/ton
feed)
(.10 )
l.SS
0.65
1.12
2.06
1.91
1.74
3.03
2.12
2.71
3.79
2.82
3.19
3.03
1.24
1.97
10.74
8.09
10.74
b.d
St. Agne>
Hedlcal Center
Fresno. CA
(Uncont rol led)
(ng/nM3)
78.7
64.9
71.8
136.0
130.C
133.0
202.0
170.0
186.0
232.0
160.0
196.0
166.0
150.0
1S8.0
785.0
704.0
744.5
(Ib/ton
feed)
<«10*>
2.07
1.81
1.94
3.79
3.42
3.61
5.63
4.46
5.04
6.46
4.19
5.33
4.35
4.19
4.27
21.87
18.51
20.19
c,d
Royal Jubilee
Hospital
Victoria. BC
(Unconc rol led)
(ng/nM*)
34.9
18.9
26.975
53.1
48.3
46.175
57.5
29.8
42.925
35.4
20.8
25.725
27.7
7.7
13.8
196.5
117.3
155.6
(Ib/lon
feed)
(»10 )
0.93
O.SO
0.73
1.45
0.90
1.24
1.51
0.82
1.15
0.96
0.55
0.70
0.75
0.21
0.37
5.36
3.25
4.19
Crnls* lun»
Factor
(Uncoil! rol led)
(Ib/ton Iced)
(niu")
201
0.50
1.26
3.79
0.90
2.20
5.63
0.82
2.97
6.46
0.55
3.07
4.35
0.21
2.21
21.87
3.25
11.71
'Reference 21.
b
Reference 22.
°Reference 23.
               High and low values'ace result* of Individual test. runs.

-------
             TABLE  3-9.  FABRIC FILTER DIOXIN/FURAN ASH ANALYSIS
                       FOR CEDAR SINAI INCINERATOR3

Loadings
(ng/g)
Dioxins
Tetra
Penta
Hexa
Hepta
Octa
Total PCDD
Furans
Tetra
Penta
Hexa
Hepta
Octa
Total PCDF

1.6
3.7
8.9
33.6
65.7
114.0

13.6
19.0
22.6
42.2
43.5
141.0
Reference 21.
                                    3-27

-------
  .   Low Molecular Weight Qrqanics.   Table 3-10 contains  emissions  factors
for the low molecular weight organics for which emissions results were
identified.  These factors were determined from information collected at
three of the comprehensive test sites.

     Carbon Monoxide.  The CO emissions data which were identified during
this study are presented in Table 3-11.  Also presented are the hydrocarbon
(HC) data which were found.  It should be noted that the HC data are
reported as propane.  The CO concentrations measured were below the
detection limit of 50 ppmv and are, therefore, reported as less than
50 ppmv.
     A comparison of the HC emissions  factors of Table 3-11 to the LC
factors of Table 3-10 suggests that only  a small portion of the total HC
measured is comprised of the compounds listed  in Table 3-10.  A definitive
conclusion can not be reached, however,  because the results presented are
from different tests.

3.2.5   Pathogens

     As  part  of  a  recent  test,  15  samples were  taken  from  the  stack  of  a
hospital waste  incinerator which had  been charged with hospital  waste
containing pathogenic material28.   Bacteria  with  a  mean  concentration of
231  colonies/m3  of gas  sampled were found in the  stack as  opposed  to an
ambient mean  level  of  148 colonies/m3.  However,  due  to  experimental
uncertainty,  no  statistically  significant difference  could be  found  between
the two measurements.
      In another study,  a two-stage hospital  incinerator  was  charged  with
known  concentrations .of bacterial  colonies in order to determine the minimum
operating  temperature required to  prevent the release of bacteria  or their
 spores to  the environment29.   The  conclusions reached by the study were
 that,  to prevent release of viable organisms to the atmosphere,  a  primary
 chamber operating temperature of 1400°F  is required and  a secondary chamber
 operating temperature of 1600°F is needed.
                                      3-28

-------
TABLE 3-10.   EMISSION FACTORS FOR SELECTED  ORGANIC  LOW MOLECULAR WEIGHT
               ORGANICS FROM HOSPITAL  WASTE INCINERATORS


Ethane
Ethylene
Propane
Propylene
Tri chl orotri fl uoroethane
Tetrachl oromethane
Trichloroethylene
Tetrachl oroethylene
Emissions Factor
(Ib/ton feed)
<0.003
<0.02
<0.024
<0.022
8.25 x 10"5
9.91 x 105
2.39 x 105
2.49 x 104
Reference
Source
23
23-
23
23
21, 22
21, 22
21, 22
21, 22
                                3-29

-------
     TABLE 3-11.  EMISSIONS/FACTORS  FOR CARBON  MONOXIDE AND HYDROCARBON
                 EMISSIONS FROM HOSPITAL WASTE  INCINERATORS
Cedar Sinai
Medical Center
las Anaeles. CA
Pollutant
Carbon Monoxide
High
Low
Average
HC (as Propane)
High
Low
Average
(ppmv)

<50C
<50
<50

7
3
4
(Ib/ton
feed)

<1.32
<1.32
<1.32

0.29
0.12
0.17
St. Agnes
Medical Center
Fresno, CA
(Ib/ton
(ppmv) feed)

<50 <1.69
<50 <1.69
<50 . <1.69

4 0.21
1 0.05
2 0.11
Emissions
Factor
(Ib/ton
feed)

<1:69
<1.32
<1.51 .

0.29
0.05
0.14
 Reference 21.
 Reference 22.
C8elow the lower detection limit of 50 ppmv
                                      3-30

-------
3.. 3  REFERENCES
 1.  Kaiser, E. R. and Carotti, A.  "Municipal Incineration of Refuse with Two
     Percent and Four Percent Additions of Four Plastics:  Polyethylene,
     Polyurethane, Polystyrene, and Polyvinyl Chloride,  "Proceedings of  the
     1972 National. Incinerator Conference". June 1972.  pp. 230-245.
     California Air Resources Board.  Air Pollution Control at Resource
     Recovery Facilities.  May 24, 1984.

 2.  Reference 1.

 3.  Heap, M. P., Lanier, W. S. and Seeker, W. R., "The  Control of NO
     Emissions from Municiple Solid Waste Incinerators," Energy and
     Environmental Research Corporation.

 4.  Edwards, J. B.  Combustion:  Formation and Emission of Trace Species. Ann
     Arbor Science Publishers, Inc., Ann Arbor, Michigan,  1977.  (Second
     Printing), p. 65-68.  California Air Resources Board.  Air Pollution
     Control at Resource Recovery Facilities.  May 24, 1984.

 5.  Henry, W. M., R. L. Barbour, R. J. Jakobsen, and P. M. Schumacher.
     Inorganic Compound  Identification of Fly Ash Emissions from Municipal
     Incinerators.  PB 83-146175.  U. S. Environmental Protection Agency,
     Research Triangle Park, North Carolina.   October 1982.

 6.  California Air Resources Board.  Air Pollution Control at Resource
     Recovery Facilities.  May 24, 1984.

 7.  Reference 6.

 8.  Jacko, R. 8. and D. W. Neuendorf.  "Trace Metal  Particulate Emission Test
     Results from a Number of Industrial and Municipal Point Sources."  APCA
     Journal Volume 27,  No. 10, October 1977.  p. 989.

 9.  Reference 6.

10.  Block, C. and R.  Dams.  "Inorganic Composition of Belgian Coals and Coal
     Ashes," Environmental  Science and Technology. Vol.  9,  No.  2,  February
     1975.  pp.  146-150  as  cited in reference 23.

11.  Gallorini,  M.,  et al.   CEP Consultants Ltd.   Heavy Metal  Contents in the
     Emission of Solid Waste Refuse Incineration.   1981.   p.  56.

12.  Reference 3.

13.  Germanus,  0.   "Hypothesis Explaining  the Origin  of Chlorinated Dioxins
     and Furans  in Combustion Effluents."   Presented  at the Symposium on
     Resource Recovery,  Hofstra University,  Long  Island,  New York,  1985.
                                    3-31

-------
14.  Axelrod,  0., MO.  "Lessons Learned from the Transformer Fire at the
   *  Binghampton (NY) State Office Building."  Chemosphere 14 (6/7),
     p.  775-778.

15.  01ie,  K., M. V. 0. Berg, and 0. Hutzinger.  "Formation and Fate of PCDD
     and PCDF Combustion Processes."  Chemosphere 12 (4/5), p. 627,  1983.

16.  Hutzinger, 0., M. J. Blumich, M. V. 0. Berg, and K. 01ie.  "Sources and
     Fate of PCDO and PCDFs: An Overview."  Chemosphere 14 (6/7), p. 581,
     1985.

17.  Reference 3.

18.  Technical Report, "Municiple Waste Combustion Study; Recycling of Solid
     Waste," Prepared by Radian Corporation for U.S. Environmental Protection
     Agency.  EPA Contract 68-02-4330, p. 5-6.

19.  Remarks of Dr. T. Galdfarb at  the Conference "Health, Environmetnal and
     Financial  Impacts of Trash Incineration" George Mason University
     November  15,  1986,  Fairfax,  Virginia.

20.  Doyle, B. W.  Drum,  D. A., and  Lauber, J. D., "The  Smoldering Question of
     Hospital Waste,"  Pollution Engineering Magazine,.July 1985.

21.  Jenkins, A.,  "Evaluation  Test  on  a Hospital Refuse  Incinerator at Cedar
     Sinai  Medical  Center.   Los Angeles,  CA," California Air  Resources Board,
     April  1987.

22.  Jenkins,  A.,  "Evaluation  Test  on  a Hospital Refuse  Incinerator at Saint
     Agnes  Medical  Center,  Fresno,  CA," California Air  Resources  Board,
     January  1987.

23.  Bumbaco,  M. J.,  "Report on  a Stack Sampling Program to Measure the
     Emissions  of  Selected  Trace  Organic  Compounds,  Particulates, Heavy
     Metals,  and HC1  from-the  Royal  Jubilee  Hospital Incinerator.   Victoria,
     B.C."   Environmental  Protection Programs  Directorate.  April 1983.

24.  Darling,  C.,  Allen,  R., Brenniman, G.,  "Air Pollution Emissions  from a
     Hospital  Incinerator,"  Proceedings from  the Vlth World Conference on Air
     Quality,  May  1983,  p.  211.

25.  Powell,  F.  C.,  "Incineration of Hospital  Wastes the Alberta  Experience,"
     Journal  of the Air  Pollution Control  Association,  Volume 37, No.  7,
     July  1987,  p.  836.

26.  Reference  25.

27.  Meeting  Notes from  Ecolaire  Presentation,  August 4,  1987,  at Radian
     Corporation.
                                      3-32

-------
28.  Kelly, H., Brenniman, G., and Kusek, J., "An Evaluation of Bacterial
   .'"  Emissions from a Hospital Incinerator," Proceedings from Vlth World
     Conference on Air Quality, Vol. 2, May 1983, pp. 227-234.

29.  Barbcitto, M. S., Shapiro, M., "Microbial  Safety Evaluation of a Solid
     and Liquid Pathological  Incinerator," Journal of Medical Primatology,
     July 1977, pp. 264-273.
                                    3-33

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                 4.0  CONTROL TECHNOLOGIES AND EFFICIENCIES

     To date, hospital  waste incinerators have operated largely without
requirements for add-on pollution control equipment or special  combustion
modification techniques.  Municipal  waste incinerators, on the  other hand,
have received closer scrutiny in recent years and consideration has been
given to potential  emission control  techniques.   The process equipment and
systems used to incinerate these two types of wastes are similar in design
and operation,  at least for the larger controlled air incinerators.  This
section extrapolates knowledge which has been gained from municipal waste
incinerators to hospital waste incinerators and  considers the applicability
of various emission control techniques.
     There are three broad categories of methods which may be applied to "the
control of emissions from waste incinerators:

     (1)  Source Separation,
     (2)  Combustion Control, and
     (3)  Flue Gas Controls (add-on control devices).

The application of each of these categories of emission control to hospital
waste incinerators is addressed in this section.

4.1  SOURCE SEPARATION

     Source separation refers to both the segregation of infectious and
non-infectious wastes and the removal of specific compounds from the waste
stream prior to incineration.  As discussed in Section 1.2, it  is estimated
that about 85 percent of a hospital's waste stream can be categorized as
general refuse, while the remaining 15 percent is contaminated  with
infectious agents (according to the experience of hospitals in  Illinois).
Thus, segregation of wastes at the point of generation can reduce the volume
of infectious waste significantly.  During a visit of project personnel to
the Iredale Hospital in Statesville, North Carolina, such waste segregation
practice was observed through the use of colored trash bags.  The extent of
infectious waste reduction was not known.

                                     4-1

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     After segregation of infectious and non-infectious wastes,  further
segregation of the non-infectious portion could be possible.  Plastics and
metal-containing components of the waste could be segregated and possibly
lower HC1, polychlorinated dibenzo-p-dioxins (PCDDs), polychlorinated
dibenzo-p-furans (PCDFs), and trace metal emission rates.  However, no data
are available on the effectiveness of such practices at hospital waste
incinerators in lowering these emissions.  Another approach to possibly
lower HC1 and PCDD/PCDF emission rates would be to use low chlorine content
plastics within hospitals.  This could be accomplished if the health care
industry were to use plastics such as polyethylene and polystyrene in place
of polyvinyl chloride, which contains over 45 weight percent chlorine.
Again, no data are available to  indicate the effectiveness of such practices
on emissions from hospital waste incinerators.

4.2  COMBUSTION CONTROL

     Data presented  in Section 3 illustrate that  there is significant
variation  in the uncontrolled emission  rates from hospital  incinerators.
These variations are  partially due  to variability in chemical and  physical
properties  of hospital wastes, partially due to variations  in incinerator
design,  and partially  due  to variation  in operating  practices.  This  section
addresses  how waste  combustion processes  influence  emission  rates  for  the
pollutants  of  interest and how combustion process control may be used  as  an
emission control  strategy,   The  general  format  is to address each  pollutant
group  separately,  discussing  how combustion  processes  influence the  emission
rate and how the  adjustable process parameters  may  be  used  to reduce
emissions and  achieve emission  control.
      The following sections provide discussions of  the relationships between
 combustion processes and emissions of major pollutants-of concern, namely:

      o    acid gases,
      o    particulate matter,
      o    trace metals,  and
      o    polycyclic organic matter (including dioxin  and fr.rans).
                                      4-2

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4.2.. 1  Acid Gas Control

     The primary acid gas that will be emitted from a hospital waste
incinerator is hydrochloric acid.  As stated in Section 3.1, based on
thermodynamic equilibrium considerations, any chlorine content in the waste
will be effectively converted to HC1, assuming that there is sufficient
hydrogen available.  Therefore, based on the thermodynamic and kinetic
consideration presented in Section 3.1, combustion modification does not
appear to be a viable control approach for hydrochloric emissions from
hospital incineration units.
     From a combustion control standpoint, emissions of S02 are similar to
HC1.  Therefore, combustion modification is not a viable approach for SO-
emissions.
     The NO  emissions from a hospital waste incinerator are relatively low
           A
when compared to those from a pulverized coal-fired boiler (0.9 to 1.0
Ib/million Btu, uncontrolled).  NO  emissions from hospital waste
                                  A
incinerators are low because of their low combustion temperatures and
two-staged combustion design.  The low temperatures decrease the thermal NO
                                                                           A
production and the two-staged design helps to reduce the fuel NO  which is
formed.  However, in some regions even the NO  levels which are shown in
Section 3.0 are of concern.  In such cases there are two potential control
options which may be considered.
     The two options available control NO  emissions in the combustion zone
where they are created.   Neither are presently being applied to hospital
incinerators but both could potentially be used.  The first is flue gas
recirculation (FGR) which retards NO  formation; the second is reburning
which destroys the NO  which is created in the combustion zone.
     Flue gas recirculation is a technology which has been used for the
control of NO  in boilers.  FGR introduces a thermal diluent and reduces
combustion temperatures.  However, lowering of flame and furnace
temperatures could be counter to the control of PCDD/PCDF.  The significance
of  the detrimental impact of reduced bulk temperatures on PCDD/PCDF
emissions has yet to be determined.  Testing recently completed on the
                                     4-3

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Pittsfield MSW incinerator by the State of New York could provide
information addressing the impacts of FGR when they become available.
Information gained from this test and other future tests could be used to
further evaluate the potential application of FGR to hospital incinerator
units.
     Reburning is a term used for a control technique which uses a
hydrocarbon-type fuel as a reducing agent.  Hydrocarbon radicals react with
NO  to form nitrogen-containing radicals which, in turn, form N2 by reaction
with NO  in the absence of oxygen.  This control technology is being
developed for use in fossil  fuel-fired boilers because only minor
modifications are required to the main heat release zone.  Thus, with
reburning the main heat release zone can be optimized for efficient
combustion, eliminating problems with  impact on PCDD/PCDF emissions.  The.
effectiveness of reburning for NOX control in boilers has been shown  to  be a
function of:

           Initial NO  level:  the  reduction  decreases as  the  initial NO level
          decreases.

           Fuel  type:  nitrogen-free reburning  fuels  are  most  effective,
           particularly  at  low initial  NO levels.

           Temperature:  reburning effectiveness  increases  as  the  temperature
           of  the reburning zone  increases.

           Residence time:  gas residence time  in the reburning zone of
           approximately 0.5 seconds  is required to maximize the
           effectiveness of reburning.

      Two aspects of the reburning process make it attractive for hospital
 incinerators.  First, it is a relatively effective control  technique,
 providing NO  reductions on the order of 50  percent.   Second, the process of
 burning the secondary fuel  results .in a significant increase in  the
                                     4-4

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concentration of 0, H and OH radicals.   Even though the local stoichiometry
is fuel-rich the high.radical  concentrations drive the gas speciation
towards the equilibrium state.  Thus,  reburning not only provides an
approach for destroying NO, it also creates an environment which should
destroy any dioxins or furans created  in the primary flame zone.  Extensive
research and development efforts would  be required to develop reburning for
hospital incineration but the potential  exists for a multi-purpose
combustion control technology.

4.2.2  Particulate Matter Control

     As stated previously, particulate  matter exiting the furnace consists
of both inorganic material entrained into the combustion gases and organic
materials which were not completely burned.  In evaluating the influence of
combustion control on PM emissions, it  is necessary to separate the organic
and inorganic fractions and to distinguish between the volatile and
non-volatile inorganic contributions.
     When waste is fed into an incinerator, it is heated by radiant energy
from the hot furnace walls and from burning combustion products above the
bed.  The waste is dried and, as the temperature increases, a
devolatilization  (pyrolysis) process begins.  The released volatile matter
is entrained by the underfire air and begins to burn.  Heat transfer from
the burning volatiles to the bed material helps to ignite the waste in the
bed and sustain the combustion process.   The non-volatile, inorganic
constituents of the waste yenerally remain in the ash pit.  Non-volatile
inorganics can contribute  to the PM emission rate if an ash-containing
particle is entrained by the underfire air and bed combustion products as
they pass through  the waste bed  into the primary chamber.
     An ash-containing particle  in the bed will be subjected to a series of
forces  including  a drag force tending to accelerate the particle to the
local air velocity and a gravity force tending to hold the particle in the
bed.  The drag force is proportional to the frontal area of the particle
times the velocity differential  squared.  The opposing gravity force is
                                    4-5

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simply gravitational acceleration times particle density times particle
volume.  Assuming a spherical particle, the gravity force varies with the
diameter cubed.  The ratio of drag force to gravity force will vary
inversely with particle diameter.  Thus, particles with relatively large
surface-to-volume ratio are more likely to be entrained into the primary
chamber flow field.
      If it is assumed that the ash content of hospital waste is
approximately 25 percent and that emitted PM is totally inorganic, then the
uncontrolled PM emission rate data presented earlier  in Table 3-5 may be
used  to estimate the extent of entrainment.  The PM emission rates were
shown  to vary from  36.5 to 1.37  Ib/ton  refuse.  This  indicates that between
92.7  and 99.7 percent of the ash remains  in the ash pit.
      Before addressing the volatile  inorganic and organic fractions, it is
important to place  the PM emission rate data into perspective.  As discussed
above,  available data .indicate that  less  than 10 percent-of the input ash
exits the furnace  as PM and, in  some instances, that  fraction  is  less than
one  percent.   In a  pulverized coal-fired  utility boiler, however,
approximately  80 percent of  the  coal  ash  exits  the  furnace  as  fly  ash.  Even
accounting  for  the  lower ash content and  higher heating value  of  coal
relative  to  hospital waste,  the  PM emission  rates  (on either  a gr/DSCF  or
lb/106 million  Btu basis)  will  be  much lower  for  a  hospital  incinerator than
for  a utility  boiler.
      The  volatile  inorganic  material.in the  feed  will also  contribute  to  the
 total PM  emission  rate,  'it  is  convenient to  discuss  combustion control  of
 this PM fraction in the context of trace metal  emission even  though  all  of
 the  trace metals emitted may not be  associated  with the particulate.   A
discussion  of trace metal  emissions  is presented  in Section 4.2.3.
      Finally,  organic compounds are  also associated with  emitted  PM.   The
 organic components are generally heavy hydrocarbons such as soot, products
 of incomplete combustion (PICs), or polycyclic organic matter (POM).   An
 extensive discussion of POM emissions  and potential combustion control  is
 presented in Section 4.2.4.  Combustion phenomena responsible for POM,
 dioxin, and furan  formation are also responsible for the formation of soot.
                                     4-6

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Thus,  combustion modifications to minimize PCDD and PCDF emissions should
also be effective for other organic particulate emissions.

4.2.3   Trace Metals Control

     In Section 3.G, the available trace metal  emissions data from hospital
incinerators were discussed and it was pointed out that many of the volatile
metals of concern tend to selectively deposit on the smaller particles.  The
physical  processes responsible for these phenomena are extremely complex, as
is the potential influence of combustion processes on the associated
phenomena.  The following will provide only a brief review of key features
which  may be significant relative to hospital incineration combustion
control.
     The majority of the available research concerning the process of fine •-.
particle metal  enrichment has been performed on pulverized coal-fired
utility boilers.  Those conditions are somewhat different than the
conditions found in hospital incinerators but the basic processes should be
similar in both systems.  It has been found that the distribution of
volatile metals among the different size fractions of ash is influenced by
the amount of ultra-fine particles produced during combustion.  Figure 4-1
illustrates this point in a plot of the fraction of arsenic and antimony
collected with the ultra-fine particles (referred to as fume) versus the
fraction of the total ash appearing in the ultra-fine mode.  A surface
deposition model to interpret these data was developed and its predictions
for the amount of trace metal deposited in the small size mode is presented
as the solid lines on Figure 4-1.
     The  issue of how uniformly the metals are distributed as a function of
particle  size has health effect implications as well as being an issue of
engineering significance.  Based on the probable mechanism of fine
particulate formation, it was suspected that the trace metals would tend to
concentrate on the surface of fine particles rather than being uniformly
distributed throughout the particle size range.  The reasoning was that
refractory oxides which were vaporized in the flame would be the first
                                    4-7

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0.02
                          0.04    0.10    0.14

                         rr»ct1« of Toul AM
                                                0.18
       Source:   Reference 1.


Figure 4-1    Fraction of As and Sb collected  with fume as a
              function of the extent of  total  ash vaporization
              (data points).
                                 4-8

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species to condense and would become the nuclei  for the fine participate
matter.  As the combustion gases cooled, volatile salts of alkali metals and
other volatile trace species would be expected to condense on the outer
surface of these particles.  A group at MIT, led by Professor Adel Sarofim.
has confirmed this theory in several experimental studies.  Figure 4-2
illustrates their findings in a plot of the concentration of selected
species versus reciprocal particle diameter.  The elements Fe and Mg, which
form the core of the particles, show no size dependence while those present
as a surface coating show concentration variation proportional to 1/d.  Note
that the trace metals of concern for hospital incinerators were  largely
present as surface coatings.
     The key to the above observation is that the ultra-fine particles
present a very high specific surface area and thus receive a
disproportionate share of the condensing elements.  Any process  that
enhances refractory oxide vaporization would be expected to increase the
number of sub-micron particles and to enhance the fine particle  enrichment
process.  It has been speculated that fuel-rich combustion,, used  for NO
                                                                       A
control in boilers and also used in controlled air incinerators,  could
increase the refractory oxide vaporization  rate.  The basis of this
speculation was contained  in models used to successfully predict  the extent
of refractory oxide vaporization under excess air conditions.  These oxides
(SiCL, MgO, CaO, Fe-O,) were assumed to vaporize at combustion conditions  as
a result of chemical reduction to the more  volatile suboxide  (SiO) or metal
(Mg, Ca, Fe) within the locally reducing atmosphere within a coal particle.
These  models assumed that  the following reaction reached equilibrium

                    M0n + CO  	»• M0n_1 +• C02

at the surface of mineral  inclusions and that the reduced oxide  or metal
(MO  ,) then diffused to  the char particle  surface.  Under fuel-rich
conditions, the gases surrounding the coal  particle would be  reducing, which
should accelerate the vaporization  process.  Experiments  to confirm  this
speculation were performed.  They measured  the aerosol size distribution  in
                                     4-9

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       10*
        10'
                 40      20
                                   O *
                                         » 10
         '0.00       0.03     0.06
                    ln»«rt» 01«Mt«P
                                    0.09
                                            0.12
        Source:   Reference 1.
Fiure 4-2.  Concentration  of  selected elements
              in  ultrafine  particulates as a function
              of  reciprocal  particle diameter.
                            4-10

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the convective section of a well-defined pilot scale facility operated under
a variety of combustion conditions.   Their results indicate that staged
combustion conditions increased the  sub-micron particulate matter
concentration by 50 percent when firing lignitic coals.
     The above information provides  important clues relative to the
mechanisms responsible for trace metal enhancement on sub-micron
particles.  It does not, however, define a combustion control approach to
minimize trace metal emissions.  Incinerators operated with-extremely high
temperatures in fuel-rich zones should have relatively higher concentrations
of sub-micron particles which could  potentially increase the trace metal
enrichment process.  Therefore, the  use of controlled air, or two-stage,
incineration with its lower primary  combustion temperatures should reduce or
minimize trace metal emissions.

4.2.4  Polycvclic Organic Matter (POM). PCDDs. and PCDFs

     Available data from MSW incinerators indicate that the PCDD and PCDF
emission rate is closely related to  efficiency of the combustion process.
Generally speaking, when the flame temperature and combustion efficiency are
increased, PCDD and PCDF emission rates are seen to decrease.  Due to the
overriding toxiological importance of these pollutant species, an extensive
discussion will be presented on how  poor combustion conditions can lead to
POM, dioxin and furan emissions and  how the combustion process may be
controlled to minimize these emissions.
     The vast majority of the information on dioxin and furan emissions has
been obtained only recently and primarily consists of stack emission rate
measurements from municipal waste combustors.  This information is taken
primarily from testing results at large industrial and municipal
incinerators; little work has been done on smaller hospital waste
incinerators.  There is also essentially no data from experimental programs
specifically designed to identify the combustion processes responsible for
PCDD/PCDF formation or to verify the effectiveness of proposed combustion
control approaches.  In the absence  of direct data, discussion of how
                                     4-11

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combustion modification may be used to control  PCDO or PCDF emissions must
be' considered theoretical in nature.
     The PCDD and PCDF compounds are dicyclic,  nearly planar, aromatic
hydrocarbons within the broad category of POM.   Polycyclic organic matter
emissions have been the subject of  intense investigation for many years with
multi-ring compounds such as benzo(a)pyrene (BaP) being the primary species
of interest.  Therefore, the following discussion is based on available
information on how POM emissions are influenced by the combustion process
and makes the implicit assumption that variation in POM emission implies
variation in dioxin and furan emission.

     4.2.4.1  Equilibrium Considerations.  If waste material is mixed with
air and allowed to react for sufficient time, the concentration of the
resultant products is determined by the elemental composition of the mixture
(moles of C, H, N, 0, Cl, etc.), the reaction temperature, and the
thermodynamic properties of the species.  Consider first the case of
oxidizing conditions  (excess air)  in which the overall oxidation process  is
represented by:

                    Waste

where  rij, r\2 and  n3 are  the stoichiometric coefficients required to balance
the reaction and  are  dependent  on  the  chemical structure of  the waste.  The
equilibrium  level  of  the unreacted  waste  in  the  combustion products  is
related  to  the  concentrations  of C02>  02  and H20 by the equilibrium
constant:
                          K
                           P ~         "
                                      P
                                       02
                                     4-12

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wh,ere P represents the partial pressure of a given constituent and K  is the
equilibrium constant.  The equilibrium constant is related fundamentally to
a measurable thermodynamic property called the Gibbs free energy (Ac) by:

                         K  = EXP (&G/RT)

where T is temperature and R  is the universal gas constant.  Gibbs free
energy values are compiled in many sources.  For typical stack gas CO^, ^0
and 0- concentrations of 8 percent, the Gibbs free energy required for there
to be 1 ppb equilibrium level of waste at 1,000°K is roughly 40 Kcal/mole.
The Gibbs free energy of furan at 800°K is reported to be 492 Kcal/mole.
Thus, Gibbs free energy considerations predict an equilibrium furan partial
pressure of less than 10     .  The Gibbs free energy values for dioxins are
even larger than that for furan; thus, the equilibrium concentration under
oxidizing conditions is even  less.  These considerations show.that given
sufficient reaction  time and  mixing, the fundamental equilibrium limit for
dioxins and furans may be considered zero for overall fuel-lea.i conditions,
even at moderate incineration temperatures.
     Since PCDDs and PCDFs can be formed in hospital incinerator:, it is
important to identify conditions where their presence is thermodynamically
favored.  An obvious area to  examine is the high temperature, oxygen starved
environment which is characteristic of isolated regions within poorly mixed
combustion processes.  An initial area to examine is high temperature
pyrolysis without air whtch  is the limit case for poor mixing.
     TRW, Inc. performed an extensive series of equilibrium calculations for
                                    4
incineration of military pesticides.   An initial set of calculations
indicated that solid carbon  (graphite) was a predominant species.
Recognizing the kinetic limitations of graphite formation, a second set of
calculations were performed eliminating graphite as a possible product
species.  Those results indicated greater than 1 ppm concentrations of a
wide variety of POM  species  as well as chlorobenzenes and chlorophenols
(potential precursors to dioxins and furans).
                                     4-L3

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     The issue of poor mixing can also be addressed by examining the
equilibrium product distributions for various chlorinated benzene/air
mixtures.5  Sample results are shown in Figure 4-3 as concentration versus
percent theoretical air assuming that the mixture is at the adiabatic flame
temperature.  With at least 45 percent theoretical air, formation of light
hydrocarbon gases (CH4, C2H2> etc.) is avoided.  At 20 percent theoretical
air, the formation of benzene or toluene as equilibrium products is avoided.
This leads to the postulation that POM, dioxins and furans are
thermodynamically favored only if the incinerator creates very fuel-rich
(and hence oxygen-poor) pockets of gas at low temperatures in the presence
of chlorine.
     The above discussion illustrates two significant aspects of combustion
control for POM.  First, existence of these species
(either in the flame or the exhaust)  indicates a combustion process
characterized by  insufficient mixing  and by local fuel-rich pockets of gas.
These  are the conditions which characterize the primary combustion chambers
of controlled air  incinerators.  However, at  reasonable temperature levels,
there  is no thermodynamic barrier  to  achieving essentially zei=o emission
levels for  these  species  and  their precursors.

     4.2.4.2  Kinetic  Considerations.  However, at  reasonable temperature
levels, there is  no  thermodynamic  barrier to  achieving emission levels for
these  species and  their  precursors that  are below the  current limits of
detection  (i.e.,  part  per trillion levels).   The  preceding discussion
addressed  equilibrium  formation  of POM under  excess  air and starved air
conditions.   It  is  important  to  recognize that combustion  of  any fuel
proceeds  through  a  complex  series  of  reaction steps  leading toward  (but not
necessarily reaching)  the product  distribution predicted  by equilibrium
calculations.   Some  of these  steps may be kinetically  limited,  however,
causing certain  reactions to  be  effectively  terminated at  an  intermediate
state.
      Consideration  of  equilibrium  conditions  (?ee Figure  4-3)  indicate that
light  hydrocarbon gases  are thermodynamically not favored  at  mixture ratios
                                      4-14

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     0     20
60     80    100    120
PERCENT THEORETICAL AIR
163   180   200
Source:   Reference 5.
    Figure 4-3.   Adiabatic equilibrium species distribution.
                                 4-15

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above 45 percent theoretical air.  Chemical kinetic limitations may,
however, result in substantial concentrations of unburned hydrocarbon at
stoichiometric ratios well above 45 percent.  Experimental data obtained in
the development of the EPA's low-NOx heavy oil burner may be used to
illustrate this fact.6  Figure 4-4 indicates the measured total hydrocarbon
(THC) concentration exiting the fuel-rich zone of a two-stage heavy oil
flame.  As shown, substantial THC was detected at first stage stoichiometric
ratios below 80 percent theoretical air.  The principal factor responsible
for this hydrocarbon breakthrough was depressed flame temperature due to
heat loss through the furnace walls.  The kinetic rates of chemical
processes vary exponentially with local temperature.  Similar experiments,
conducted in a higher temperature environment, showed negligible THC
concentrations until the  fuel-rich zone stoichiometry was less than about"
60-65 percent theoretical air.
     In the above tests,  the  transition from fuel-rich to fuel-lean
conditions was achieved through the use of multiple air jets designed .to
achieve thorough mixing of  air with the effluent from the fuel-rich zone.
By changing the split between primary and  secondary air,  it was possible to
vary the fuel-rich zone stoichiometry while maintaining a constant overall
excess air condition.   In many respects, this  is similar  to the basic design
in a controlled air  incinerator.  An important observation  is  that whenever
the  primary zone stoichiometry was  sufficiently fuel-rich to cause
hydrocarbon breakthrough  in  the  primary zone exhaust, there was a
precipitous increase  in the  boiler  exhaust  smoke level.   The important point
relative to hospital  incineration  is that  the  presence of substantial
hydrocarbon concentrations  in fuel-rich regions can easily  result  in the
formation of  soot and organic particulate  matter.   The secondary chamber
must be designed to  accommodate  these materials to  achieve  complete
burn-out.
     Equilibrium product  distribution calculations  for very fuel-rich
conditions  indicate  ppm level  concentrations  of chlorobenzenes and
chlorophenols.   In  one  study,  the  likely chemical  kinetic processes leading
to formation  of  PCDDs was reviewed  and  it  was  concluded that the prime
                                      4-16

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    10,000
 •3

  V
  a
  a
 3    1000
  a

  o
  
-------
diojtfn precursors  are  chlorinated phenols.7  They suggested a kinetic path
for  forming  2,4,7,8-TCDO,  as  illustrated  in Figure 4-5.  The process
proceeds by  removal  of hydrogen  from  the  OH group; joining of two phenols to
form a reactive  2-phenoxyphenol;  followed by an elimination reaction to  form
dioxin.
     The above discussion  provides  several  important  insights into  the
combustion processes controlling the  formation of POM, dioxins  and  furans.
Those  same insights  indicate  important  incinerator design  and operating
parameters which can be used  to  minimize  emission of  those species.
Equilibrium  and  kinetic considerations  both  indicate  that  an essential
feature  required for the formation  of POM,  dioxin or  furans is  a  fuel-rich
pocket of gas.   Defining how  rich that  pocket must be to form these species
will depend  on  the local gas  temperature.  Increased  temperature  reduces the
thermodynamic stability of the species  (and their precursors) as  well  as
.accelerating the kinetic rate of destruction  reactions.  The discussion
suggests that these POM compounds are,  in all  likelihood,  formed  in the
primary  chamber of controlled'air hospital incinerators.   However,  these
compounds  must  pass through the secondary chamber before being  emitted to
 the atmosphere.   The residence time and temperature  characteristics of this
 second chamber will dictate,  in large measure,  the  extent  to which  these
 materials  are destroyed before flue gases are emitted.

      4.2.4.3  Fuel  Effects.  A third issue to be examined  is  whether the
 chemical form of hospital waste has a significant  impact  on  POM,  dioxin or
 furan emissions.  It  is difficult  (if not impossible) to  accurately quantify
 the chemical form of  this waste being fed into an  incinerator over the time
 period required to  extract a  sample for  POM analysis.  There are, however,
 data quantifying  POM  emissions  from gas,  oil and coal-fired boilers.
 Figure 4-6  shows  benzo(a)pyrene  (BaP) emission data  from different size
 boilers firing  coal,  oil  or  natural gas.  The shaded  area in this  figure
 represents  coal-fired boiler results.  Units with heat inputs greater than
 1010 cal/hr were  utility  boilers while units in the  107 cal/hr range were
 small stoker-fired  or hand-stoked  coal furnaces.  The measured BaP emissions
                                      4-18

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      OH
 Cl
            Cl
      Cl
          II

      o  '"•

           Cl
Source:   Reference  7.
Cl
                                  Cl
                                  Cl
                                                         Cl
                                                       Cl
                                    Vci:..
                                                       Cl
                                                                         I »
                                                                        ' ii; o
                                                                                      *  UCI
             Figure 4-5.   One  possible  formation mechanisn for 2,4,7,8 - TCDD.

-------
   105
                                                OCOAL

                                                COIL
                                                4 CAS
                                                < EMISSION LESS
                                                 «. THAN VALUE PLOTTED

                                                  >TESTS ON SAME
                                                 J UNIT
    10-2
                              101           109         1Q10

                             GROSS HEAT INPUT TO FURNACE. olAr
Source:   Reference 3.
        Figure 4-6.  Benzo(a)pyrene emissions from coal,  oil, and
                     natural gas heat-generation processes.
                                       4-20

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from gas and oil-fired boilers were generally on the same order as those
from coal-fired utility boilers.
     Utility boilers burn pulverized coal  in large diffusion flames which
are very similar to the flame types in gas- and oil-fired boilers.  The
flame produced by a hand-stoked boiler is  similar to that in a poorly
designed and operated mass fed MSW incinerator.
     As noted in Figure 4-6,  the BaP emission rates from gas-, oil- and
                                                                          o
coal-fired boilers with similar flame shapes are generally below 1 g/Mcal.
For comparison with other data in this report 1 g/Mcal  is approximately
equal to 500 ng/m  which is on the same order as the PCDD and PCDF emission
rates indicated in Tables 3-7 and 3-8 for  hospital incinerators.  The BaP
emission rates from the hand-stoked coal  boilers are as much as 5 orders of
magnitude above the levels produced by the diffusion flames.  These
comparisons suggest that the chemical  structure of the fuel  may have a
relatively minor influence on POM emissions but that other parameters
related to the manner in which the fuel is burned can have a significant
influence.  This underlines the fact that  combustion controls, throucn
careful incinerator design and operation,  have the potential to achie.e
significant PCCD and PCDF emission reductions.
     Using the waste burning process description of Section  3.1.4.1 in
conjunction with the equilibrium, chemical kinetic, and fuel composition
considerations of this section, it is possible to identify a variety of
combustion control approaches for POM, PCDD and PCDF emissions.  A
discussion of the design or operating conditions which lead  to the formation
of the fuel-rich pockets which improve the potential for POM, PCDD and PCDF
formation follows.

     4.2.4.4  Air Distribution Effects in  Controlled Air Incinerators.
Controlled air incinerators will  be used for the purpose of discussing air
distribution effects on combustion control techniques for control of POM,
PCDD, and PCDF.  This type unit is chosen  because of its wide use in the
past 10 to 15 years and because currently  it is the most widely sold design
type.  These units are also similar to excess air incinerators because of
                                     4-21

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their two-stage design.  This discussion will  therefore also have some
relevance to excess air units.  The discussion will be presented by
discussing the design and operation of these units by combustion stage.
     Primary Combustion.  As stated in Section 2.1.2, waste is fed into the
primary combustion chamber which is operated with less than the full  amount
of air required for combustion.  The air addition rate is usually 40  to 70
percent of stoichiometric requirements.  Under these sub-stoichiometric
conditions the waste is dried, heated, and pyrolized, thereby releasing
moisture and volatile components.  The primary chamber can therefore  be
considered a large fuel-rich pocket from the standpoint of POM, PCDD  and
PCDF formation.  The production of these compounds and their precursors can
therefore be considered optimum in the primary stage.
     Waste is fed to the primary combustion chamber by either manual  or
mechanical loading devices.  Manual loading is done by charging a bag at a
time into the primary chamber while most mechanical loaders employ a  hopper.
and ram assembly.  Both feed mechanisms are non-continuous feed processes
which deliver the feed  in a batch-type manner.  Therefore, the potential for
an extremely fuel-rich  system exists when waste is initially charged  to the
incinerator.  A dynamic air supply system which can follow the transient is
required  if the system  is to maintain  its stoichiometric set point.  Failure
to maintain a consistent air  fuel ratio will make control in the secondary
combustion chamber more difficult.
     Most incinerators  control combustion in the primary combustion chamber
by measuring the temperature  in  the primary chamber and adjusting the air
flow rate to that chamber to  meet a temperature set-point.  When
temperatures are too low, air  is added  to accelerate the burning process.
Conversely, the air  rate  is decreased  when  the temperature  is  too high.
     In conclusion,  the operation of  the primary combustion chamber is  such
that a  fuel-rich combustion environment exists.  Smooth control of the
air-to-fuel ratio, accounting  for transients due to  the feed mechanism, are
needed  in order to minimize  the  amount of fluctuation  in the gas rate  and
conditions  entering  the secondary combustion chamber.
                                     4-22

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     Secondary Combustion.  Moisture,  volatiles and combustion gases from
the primary chamber flow upward through a connecting section where they are
mixed with air prior to entering the secondary combustion chamber.  If the
gases from the primary chamber are hot enough they will self-ignite when the
additional air is added.  However, a burner is located near the entrance to
the secondary chamber to provide additional heat when it is needed.  The air
injection rate into the second chamber is generally between 100 and 140
percent of total  stoichiometric requirements.  Thus, the total combustion
process in the incinerator operates at between 40 to 110 percent excess air.
     If operation of the secondary air flow is kept at design levels,  the
amount of oxygen added to the combustion process is sufficient to complete
the combustion process without exceeding the lean fuel flammability limits.
The critical issue is that the fuel-rich exhaust from the primary chamber
must be mixed on a molecular level for the complete destruction of all  POM,
PCDD and PCDF, and potential precursors to be destroyed.  Simply blowing
additional air into the secondary chamber is not sufficient to insure high
combustion efficiencies.  Consequently, great care must be taken in
designing the secondary air chamber such that complete and thorough mixing
will occur.  One design approach to increase mixing currently in use is to
introduce air at right angle to the flow of primary chamber gases and to use
a series of staggered manifolds on either side of the gas.  A second design
approach is the enlargement of the secondary combustion chamber.  This
approach leads to greater residence times at temperature while also
increasing the chance for mixing.
     From an operational standpoint, the primary air flow rate control,
proportionment of combustion air between the primary and secondary chambers,
and the extent of mixing in the secondary chamber,  all could have a
significant impact on POM, .PCDD and PCDF emissions.  Further research is
required to better understand how design and operating parameters influence
these emissions.

     4.2.4.5  Thermal Environment.  In the EPA's Tier 4 study, it was
observed that trends in PCDD and PCDF emissions could be detected based on
                                      4-23

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the combustion temperature (see Reference 9).   It was also noted in this
report that MSW incinerators burning high moisture content waste tended to
have low combustion temperatures and higher PCDO/PCOF emissions.  The
following discussion considers the theoretical relationship between
temperature and emission rates for PCDDs, PCDFs, and other POMs.
     Thermal environment and chemical kinetic processes are intimately
related to each other.  Flame temperature rise is the result of chemically
converting fuel to combustion products while the rate of the chemical
reactions is exponentially dependent upon the local temperature.   In the
discussion of equilibrium considerations it was shown that formation of
fuel-rich pockets of gas was an essential ingredient for production of POM,
PCDD and PCDF.  Figure  4-3  illustrated that the equilibrium total
hydrocarbon concentration was less than  1 ppm for mixtures with more than
45  percent theoretical  air.   In the  discussion of kinetic processes,
Figure 4-4 showed that  substantial hydrocarbons can persist in  80  percent.
theoretical air mixtures  if there  is heat .extraction from the fuel-rich
gases.  Thus,  removing  heat from combusting gases tends to increase  the
stoichiometric  ratio  at which  hydrocarbon species will persist".
     An  important  set  of  variables  influencing  flame temperature  is  the
excess oxygen  level  in  the  combustor and the  moisture content of  the waste.
To  illustrate  these  effects,  a  series  of adiabatic  flame  temperature
calculations  were  performed as  a  function of  percent theoretical  air.   To
demonstrate  that  flame temperature is  controlled  by combustion  of waste
volatile  matter,  methane  was used  as the fuel  for these calculations.   To
simulate  the  moisture content of  the waste,  various quantities  of liquid
water (0-40 percent)  was  added to  the  "fuel."  Results  from these
calculations  are  presented in Figure 4-7.9   As  shown,  increasing  the
combustion air from 150 to 200 percent of  the theoretical  requirement
decreases the adiabatic flame temperature  by approximately  300°C  (540  F).
At 150 percent theoretical  air (50 percent  excess air),  increasing the
moisture content  from 0 to 40 percent  decreases the adiabatic flame
 temperature by approximately 150 C  (270 F).
                                      4-24

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                                     Adiabatic Flame  Temperatures
                                     of CH4/H-0(1)  -  Air
                                     Mixtures:   L,  •  298K
    1000
        50
100
      150          200

Percent Theoretical  Air
250
300
Source:   Reference  9.
     Figure 4-7.   Variation  of adiabatic flame temperature with
                  percent  theoretical air and percent moisture
                  in  the MSW.
                                  4-25

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     The important operational consideration is to maintain the excess air
in a range which is h'igh enough to insure that oxygen is available for fuel
burnout but low enough to prevent excessive depression of the flame
temperature.  The requirement for operation within an excess air window is
illustrated in Figure 4-8 which shows the measured total hydrocarbons in the
exhaust of a highly cooled laboratory furnace as a function of excess air
level.10  It should be noted that the data in this figure are
hardware-specific and that the acceptable excess air operating window will
vary with both incinerator design details and characteristics of the waste
being burned (e.g., heating value, moisture content and halogen content).
     The moisture content of hospital waste is dependent on the daily
operation of the hospital.  As illustrated in Figure 4-7, adjusting the
excess air level can offset the thermal  influence of large variations in
moisture content.  The thermal influence of adding 40 weight percent water
to the fuel may be offset by decreasing  excess air level by about 20
percent.  From a combustion control  standpoint, hardware could be developed
to continuously monitor  the exhaust  gas  H20 content and that data used  in a
control  system to  appropriately adjust the excess air level.  Research  is
required to define the proper mode of excess  air control but it is likely
that minimum POM,  dioxin and  furan emissions  control would be achieved  by
adjusting excess  air  rates  in  the primary  and secondary chambers.
     An  additional operational consideration  influencing thermal  environment
and  possibly having  a major impact on POM,  PCDO and PCDF emissions is the
unit start-up  procedure.'  Some facilities  may have greatly different  warm-up
periods  depending  on  operator awareness.   Based on considerations presented
earlier  in  this  section, extensive warm-up using  auxiliary  fuel  (natural  gas
or  distillate  oil)  should be  the  preferable  operating procedure.  The
start-up period  may  have little  impact on  steady-state  emission  rates but a
substantial mass  of  POM, PCDD and PCDF could  be emitted during  start-up with
cold walls.   By  the  same token,  sufficient air and  temperature  levels should
be  maintained  during burn-down periods to  assure  complete  combustion.
                                     4-26

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   4000-
   2000-
CM
O
O

4->

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  .   4.2.4.6  POM. Dioxin and Furan Summary.   The above discussion
illustrates that emissions of POM, PCDD and PCDF are the products of
incomplete combustion.  A critical component  in the pollutant formation
process is formation of fuel-rich pockets of gas.  The primary combustion
chamber in a controlled air incinerator is operated as a large fuel-rich
pocket.  To maximize the extent of combustion, the following steps can be
taken:

     o    Control the combustion  air supply to the primary chamber to
          minimize transients in  the outlet flow rate and composition;

     o    Proportion  combustion air between the  primary and  secondary
          chambers to maintain desired temperatures; and

     o    Promote efficient  mixing of  air  and  combustion gases  in  the
          secondary  chamber.

      Each of  these  combustion  parameters  are  adjustable during' the
 incinerator design  and/or as part of  the  unit  operating procedure.   The
 assertion  that PCDD and PCDF emission  reduction  can  be  achieved by
 combustion  control  is clear  but  the  types  of  modifications  likely  to be
 effective  will depend upon the specific  design and operating conditions  of  a
 given  model and size.  That  is,  combustion modifications must be tailored to
 the specific  type of incineration hardware under consideration.  Appropriate
 control  strategies  for existing  facilities must be evaluated on a
 case-by-case  basis  and some processes may require extensive hardware
 modification  and/or altered operational  procedures.

 4.3  FLUE GAS CONTROLS

      Add-on devices may be employed for post-combustion treatment of flue
 gas.  As shown in Section 3.0, two devices presently in use on hospital
 incinerators  are fabric filters  (baghouses)  and wet scrubbers.  Due tn
                                      4-28

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economic reasons, these techniques are presently only applied to units at
the high end of the incinerator size range, if at all.  Another potential
add-on control not presently in use would be dry scrubbers.  Dry scrubbers
provide acid gas and organic emissions control and, when coupled with fabric
filters, offer good particulate control as well.  In addition, after-burners
are potential controls for organic compound emissions.

4.3.1  Fabric Filters (Baqhouses)

     Fabric filters offer very high efficiencies for particle removal from
flue gas with attainable efficiencies greater than 99.9 percent.  At least
one study concluded that baghouses are the best PM control device for refuse
incinerators.  Currently, there are at .least four conventional incinerator
installations utilizing baghouses in the U. S.    Similar efficiencies would
be expected for hospital waste incinerators because of the similar nature of
the wastes.
     Fabric filters rely on porous glass fabric to facilitate removal of
very fine PM.  Figure 4-9 shows a typical arrangement.  Collected PM is
"shaken," either mechanically or by air, from the bag and disposed of with
bottom ash from the incinerator.  Some advantages and disadvantages of
                         12
baghouses are as follows:

     Advantages

     1.   High PM removal efficiencies can be obtained.

     2.   High efficiencies for finer  PM means good removal of those metals
          which concentrate on fine PM.

     3.   There are no wastewater disposal requirements.

     4.   Variations  in flue gas flow  rate or chemical composition do not
          usually affect fabric filter performance.
                                     4-29

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                I  (  Iff  I  !  l
Dirty Air
Fabric Flltara
Claan Air
                                                  Compraasad Air
                        Claan Air PUnum
                    Oust Conveying   Rotary
                       Syatam      Dlacharga
             Figure 4-Q.  Typical fabric filter system.
                              4-30

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  .   5.   Submicron particle collection  improves as the thickness of the
         dust  layer on the collection surface increases.

     Pi sadvantages

     1.   Fabric  filters  are designed only  for PM control and do little to
         control gaseous  pollutants.

     2.   High  pressure drops may  occur  if  bags become plugged with solids
         which could  lead to large  power requirements.

     3.   The upper temperature  limit of most widely  used filter media  is
         about 260°C  (500°F).

     4.   Sparks  carried  by the  flue gas can cause  fires  in  the fabric
         filter.

     5.   The dew point  of the 'flue  gas  must be considered.  An excursion
         below the dew  point can  result in condensation  and hence  blinding
         of bags.   In addition, due to  the typically high HC1 content  of
         hospital waste  incinerator flue gases, condensation  can  lead  to
         the formation  of corrosive HC1 acid.

4.3.2  Scrubbers

     Wet scrubbers  currently  in  use  offer  lower efficiencies for  the
collection  of PM  but  higher efficiencies for  acid  gas removal.  Wet
scrubbers basically  use  liquid  to  effect transfer  of  pollutants  from  a  gas
to a liquid stream.   Scrubber design and the  type  of  liquid  solution  used
largely determine contaminant removal  efficiencies.   Plain water
efficiencies for  the  removal of  acid gases  are  in  the range  of 30  percent,
while the addition  of Ca(OH)2  to the scrubber  liquor  has  been  shown to
                                    4-31

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result in efficiencies of 93-96 percent.13  In general,  high gas-side
pressure drops must be used to obtain high efficiencies  for PM control.
     There are basically three types of wet scrubbers:

     (1)  low energy  (spray tower),
     (2)  medium energy (impingement scrubbers such as packed column, baffle
          plate, and  liquid impingement), and
     (3)  high energy (venturi).

     Low energy scrubbers  (spray towers) are usually circular in
cross-section (see  Figure  4-10).  The liquid is sprayed down the tower as
the gases rise.  Large particles are removed by impingement on the liquor
pool, and finer particles  are  removed as the flue gas rises through  the  -
tower.   Low  energy  scrubbers mainly  remove particles  in the 5-10 micron
range.
     Medium  energy  devices mostly  rely  on  impingement to  facilitate  removal
of  PM.   This can be accomplished through  a variety of configurations, two  of
which are diagrammed in  Figures  4-11 and  4-12.
      High energy  scrubbers utilize a venturi mechanism  for  PM removal
 (Figure 4-13).   The flue  gases impinge  on  the  liquor  stream in  the venturi
 section.  As the  gases pass through the orifice,  the  shearing action
 atomizes the liquor  into  fine  droplets.  As  the gas leaves  the  venturi
 section it  decelerates,  resulting  in further contact  between  particles  and
 liquid  droplets.   The droplets are then removed  from  the  device by the
 centrifugal  action in the de-entrainment section.
      Like baghouses, wet scrubbers offer both  advantages  and  disadvantages.
 Some of the major advantages and disadvantages of wet scrubbers are:

      Advantages

      1.   Particle collection and gas absorption can  be accomplished
           simultaneously with proper design.
                                     4-32

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               CUan  Q«»
                 Outlet
  Liquid
Distributor

      Dirty
     Qa» lnl«t
                                Liquor
                                Drain
 Figure 4-10.  Open  spray tower scrubber.
                   4-33

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                    Clean
                      Outlet
     Dirty Qaa
       Inlet -H
Constant-Level^
  Flow Nozzle
                                    R«turn«d
                                    Entralnad
                                    •Droplata

                                   .Centrifugal
                                   D«-Entralnm«nt
                                      Section
              Fixed
              Orifice

              Liquor Outlet

              Liquor
             R.tervolr
                  I
Liquor
 Drain
1
          Figure 4-11.  Fixed orifice scrubber.
                        4-34

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lmplng«m«nt
Baffl* Pl«t«
      Olrty Q««
        lnl«t
                    Cl««n
                      Outl«t
                                    0«-Entralnm«nt
                                       Section
                                       Liquor
                                       InUt
                                      Humldlfleatlon
                                          Wattr
                                     Sprayt
        Figure 4-12.  Baffle impingement scrubber.
                       4-35

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                             Claan Oaa
                               Outlat
         Dirty Oaa
  Liquor
   Inlat '
  .Liquor
Olitrlbutlon
    W«lr
       Vanturl
       Section
0«-Cntralnm«nt
    Section
                                Liquor  to
                               fUclrculatlon
                             Pump and Olapotal
        Figure 4-13.  High energy venturi scrubber.
                           4-36

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2.   High collection efficiencies can be obtained for any particle size
     range with sufficient energy input.

3.   Viscous materials can be collected without plugging.

4.   High temperature gaseous effluent streams can be handled.

5.   Moisture content and/or dew point of the effluent gas is not
     critical to scrubber operation.

6.   Heat transfer,  chemical reactions, and evaporation are
     characteristics of wet scrubber  operations that can be varied to
     improve pollutant removal  efficiencies.

7.   Capital costs are relatively low.

Disadvantages

1.   High energy input is required for collection of the finer dust
     particles.

2.   Corrosion and erosion are characteristic of all wet processing.

3.   An effluent liquor disposal system is required.

4.   Discharge of a water-saturated gas stream can produce a visible
     steam plume.

5.   Re-entrainment of PM may be a problem.

6.   Wet scrubbers are not effective for control of insoluble gaseous
     organics.
                                4-37

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     Dry scrubbers combined with fabric filters applied to MSW incinerators
have received considerable attention recently.  In these systems, a lime
slurry is injected into the scrubber where it contacts the flue gas.  The
water is evaporated and dry salts result from the reaction of lime with
constituents of the flue gas.  The salts, unreacted lime, and particulate
matter are collected in fabric filters downstream of the reactor.   It has
been theorized that filter cake build-up provides available reaction sites
for continued reaction with pollutants from the flue gas.
     Test results from MSW incinerators for dry scrubbing/fabric filter
systems show enhanced PM emission reduction in all particle size ranges
compared to wet scrubbers operating with even larger pressure drops.  Acid
                                                       1 7 — ? 1
gas and metal removal efficiencies have also been high.  "    Also  of
interest are the  low dioxin/furan emissions from the dry scrubbing  system.
     A diagram of a commercially available system, the Teller System,  is
shown in Figure 4-14.22   In  this system a dry venturl  is located between the
dry scrubber (quench reactor)  and the  baghouse.  The dry venturi reportedly
causes agglomeration of  small  particles formed in the  dry scrubber  which
results  in  reduced pressure  drop in the baghouse.  This reduced  pressure
drop translates to longer cleaning cycles which are associated with higher
removal  efficiencies for  small  particles.
     Advantages cited  for dry  scrubbing  followed by fabric  filtration
include  the following:

      (1)   Insensitive  to 'changes  in  inlet particulate  loading  or
           characteristics within  the  combustion chamoer.

      (2)   Effective  and efficient  particle  capture  in  the  submicron range.

      (3)   Efficient  S02 and HC1  removal.

      (4)  Produces  agglomerated,  dry particulates  that can  easily  be
           disposed.
                                      4-38

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                          omen
                          IIICI0I
                                     III ,
I
UJ
VD
riui us
                          SOtlDS
                                         WIICI
                                         HMf
                                          USISOII      SOLIDS
                                           III
            Source:   Reference 23.
                                 Figure 4-14.   Teller dry scrubbing system.

-------
  '-.  (5)   Because flue gas is  not  saturated  with  moisture,  there  is  no
          visible plume exiting the stack.

     (6)   Reduction of organic emissions  due to low operating  temperatures.

     Disadvantages cited include the following:

     (1)   Exit gases are reduced by an average of 180°F and this  can affect
          gas plume rise, thus affecting  pollutant dispersion.

     (2)   Reagents can be costly.

4.3.3  Afterburners

     A third combustion chamber on some incinerators acts as an afterburner.
This control device can be expected to further reduce organic emissions.
The most likely  location  for  such a device would be before the scrubber.
Direct flame afterburners operating at a 2,000°F temperature and 1.0 second
residence time can typically  achieve greater than 98 percent destruction
even for chlorinated  organics.
                                    4-40

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4.4,  REFERENCES
 1.  Haynes, 8. S., M. Neville, R. J. Quann, and A. F. Sarofim, J. Colloid.
     Interface Sci.. 87, 266-278 (1982)

 2.  Linak and Peterson (1985).

 3.  Stull, R. 0., E. F. Westrum, and G. C. Sinke:  The Chemical
     Thermodynamics of Organic Compounds, Wiley (1969(.

 4.  Shih, C. C., R. F. Tobias, J. F. Clausen, and R. J. Johnson:  Thermal
     Degradation of Military Standard Pesticide Formulations, TRW Report
     24768-6018RU-00, U. S. Army Medical R&D Command, (December 1974).

 5.  Kramlich, J. C., W. D. Clark, W. R. Seeker, and G. S. Samuelsen,
     Theoretical Evaluation of Exhaust Emissions of CO and THC as Indicators
     of Incineration Performance, Final Report, Work Assignment 3, EPA
     Contract No. 68-02-3113, 1984.

 6.  England, G. C., M:. P. Heap, D. W. Pershing, J. L. Tomlinson, and
     T. L. Corley, "Low-NO  Combustors for High Nitrogen Liquid Fuels,"
     Proceedings of the Joint Symposium on Stationary Combustion of NO
     Control.  Vol. V, Fundamental Combustion Research and Advanced
     Processes.  EPA Report No.  IERF-RTP-1087a, 1980.

 7.  Shaub, W. M. and W. Tsand,  "Dioxin Formation  in  Incinerators," Environ.
     Sci. Technol.. 17, 1983, pp. 721-730.

 8.  National Environmental Research Center, "Scientific and Technical
     Assessment Report on Particulate Polycyclic Organic Matter (PPOM),"
     EPA-600/6-74-001, March 1984.

 9.  Final Report.  "Municiple Waste Combustion Study Data Gathering Phase,"
     prepared for Morrison, R.,  EPA, by Radian Corporation, November 1986.

10.  Reference 5.

11.  California Air Resources Board.  Air Pollution Control at Resource
     Recovery Facilities.  May 24, 1984.

12.  Devitt, T. W., et al.  PEDCo Environmental, Inc.  Air Pollution
     Emissions and Control Technology for Waste-As-Fuel Processes.
     October 1979.

13.  Reference 10.

14.  Reference 11.
                                     4-41

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15.  -..Reference 11.

16.   Reference 11.

17.   Cleverly, David H.  Emissions and Emission Control  in Resource
     Recovery.  Office of Resource Recovery,  NYC Department of Sanitation.
     December 9, 1982.

18   Teller, A. J.   Dry System Emission Control for Municipal  Incinerators.
     Proceedings of National Waste Conference,  1980.  ASME.  New York,  as
     cited in Reference 109.

19.   Teller, A. J.   The Landmark Framingham,  Massachusetts Incinerator,
     presented at The Hazardous Materials Management Conference,
     Philadelphia,  Pennsylvania.  June 5-7, 1984.

20.   Teller, A. J.   New Systems for Municipal  Incineration Control.
     National Waste Processing Conference, 1978.  ASME., as cited in
     Reference  109.

21.   Teller, A. J.   Teller  Systems Incineration  - Resource Recovery Flue Gas
     Emission Control.  Presented at Acid Gas  and Dioxin Control for Waste
   .  to Energy  Facilities.  Washington, D.C.   November 25-26, 1985.

22.   Reference  9.

23.   F.R.   (October 21,  1983.)  48:48932.  Standards of Performance for New
     Stationary Sources:  VOC  Emissions from the SOCMI Air Oxidation Unit
     Processes.
                                     4-42

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                     5.0  REGULATORY STATUS AND STRATEGIES

     Regulatory strategies in the United States to control air emissions
from hospital  waste incinerators have not been addressed to date at the
Federal  level  but have been a focus of attention at the State level.
Because of their relatively small size,  emissions from hospital  waste
incinerators are not subject to Federal  regulations which control  emissions
from larger MSW incinerators and solid waste-fired boilers.  Instead,
hospital waste incinerators are subject to a "patchwork quilt" of State and
local guidance and regulations.  Currently, most States recommend, but do
not require, the control of particulate matter (PM) emissions and opacity
for hospital waste incinerators.  However, with the growing public concern
over handling and disposal of hospital wastes, several States have developed
emission limit regulations for incinerators which are now in the proposal
stage.
     This section discusses the current regulatory environment for hospital
waste incinerators at both the Federal and State level.  The information
presented on State programs is accurate as of June 1987.  However, due to
the rapidly changing nature of these programs, this information is expected
to become quickly out-of-date.
     In addition to Federal and State regulations in the United States, this
section also reviews regulations which have been established for hospital
waste incineration in Canada and European countries.

5.1  FEDERAL REGULATIONS AND PROGRAMS

New Source Performance Standards

     Hospital waste incinerators are not currently a source category subject
to New  Source Performance Standards  (NSPS).  However, they would be  subject
to NSPS for industrial, commercial,  and institutional steam generating units
(i.e.,  boilers) at 40 CFR Part 60 Subpart Db if units have a heat input
capacity above 100 million Btu/hr and recover heat to generate steam or heat
                                     5-1

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water (or other heat transfer media).  At 8,500 Btu per pound of Type 0 (see
Table 1-3) waste, a hospital incinerator must be sized to feed over 11,700
Ib/hr of waste to be subject to the boiler NSPS.  The largest system offered
for on-site hospital waste  incineration is approximately 6,000 Ib/hr
capacity, and most units are well below this size.  Hence hospital  waste
incinerators will not be impacted by the current boiler NSPS.
     EPA  is currently evaluating NSPS for smaller boilers with capacities
below 100 million Btu/hr.   The lower size cutoff is one of the factors to be
determined during the rulemaking process although boilers as low as 10
million Btu/hr are being actively evaluated.  A lower size cutoff below 50
million Btu/hr would affect at least a  fraction of new, modified, or
reconstructed hospital  waste  incinerators.  The pollutants being evaluated
for the small boiler NSPS  are PM, opacity, NOX, and S0r  Proposal of  this
standard  is  scheduled for  June 1989.
     NSPS limiting  PM emissions  to  0.08 gr/dscf (equivalent  to about 0.18
Ib/million  Btu)  corrected  to 12  percent C02 have  been promulgated at 40 CFR
Part 60  Subpart  E  for  incinerators  having a design capacity  of 50 ton/day
 (i.e.,  4,167  Ib/hr)  or  greater and  which  burn  more than  50 percent municipal
type waste.   This  waste is defined  as  "waste consisting  of a mixture of
paper,  wood,  yard  wastes,  food wastes,  plastics,  leather, rubber, and  other
combustibles,  and  noncombustible materials  such as glass  and rock."
Although  hospital  waste would seem  to  qualify  under  this  definition, the
 size  limit for Subpart  E would  apply to only  the  largest  of  hospital waste
 incinerators.

 National  Emission  Standards for  the Hazardous  Air Pollutants

      Of the 12 NESHAPs promulgated  pursuant to Section  112  of the  Clean  Air
 Act,  which address seven hazardous  pollutants, none  pertain  to hospital
 incinerators.
                                     5-2

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Resource Conservation and Recovery Act Requirements

     As a first step in fulfilling the Congressional  mandate to establish a
hazardous waste management system, EPA published proposed regulations in the
Federal Register on December 18,  1978, which included a proposed definition
and treatment methods for infectious waste.    During  the public comment
period for this rulemaking,  EPA received approximately sixty comments which
specifically addressed the infectious waste  provisions of the proposed
            2
regulations.
     On May 19, 1980, EPA published the first phase of the hazardous waste
regulations.  The Agency stated in the preamble to the regulations that the
sections on infectious waste would be published when  work on treatment,
storage, and disposal standards was completed;   While the Agency has
evaluated management techniques for infectious waste, considerable evidence
that these wastes cause harm, to human health and the  environment is needed
to- support federal rulemaking.

Prevention or Significant Deterioration Requirements
     Hospital waste incinerators are not among the 28 named prevention of
significant deterioration (PSD) source categories.  Even though waste
generation rates vary among hospitals, emissions from incinerators are
typically less than 250 tons per year.  Therefore, in most states best
available control technology (BACT) is not required for emitted pollutants.
Pennsylvania is one of the few states that require BACT for all sources.

5.2  STATE REGULATIONS AND PROGRAMS

State Requirements for Waste Handling

     Most states have requirements for licensing of hospital that may
include general requirements for infectious waste disposal.  Usually, these
general requirements are limited in scope and do not apply to other sources
                                     5-3

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of.infectious waste, such as crematoria.    The only restriction on the
pathological or biomedical waste incinerators in many states is that they
not create a public nuisance.  That has meant that no odors are to be
generated and that the opacity is to be low.
     A majority of states have passed hazardous waste legislation to control
the treatment, storage, and disposal of infectious waste (as part of their
hazardous waste program).  Some states have already promulgated regulations
controlling infectious waste, while other states are preparing such
regulations.  Since there is no unanimity of opinion on the hazards posed by
infectious waste and appropriate techniques for safe disposal of these
wastes, state control varies.   Most states do not have specific
requirements for hospital incineration that limit pollutant air emissions.
     To determine what efforts different states have taken to regulate
infectious wastes,  the National Solid Wastes Management Associations (NSWMA)
Infectious Waste. Task Force  surveyed the state health and environmental
agencies  in January  1987.  The general purpose of the survey was to
determine where  treatment and disposal of infectious waste are subject to
regulations distinct  from those that apply  to municipal solid waste  (MSW).
The survey's results  indicated  the  following:

     o    The  solid waste and/or health departments  in  28  states do  define
           infectious  waste  items and subject these  items to  special  rules or
           recommendations  in management.

     o     Some states such  as Massachusetts and  Louisiana  expect  to  revise
           their definitions  soon to capture all  generators  of  infectious
           wastes and not just hospitals.

     o     In general, hospitals and health-care facilities are prevented
           from disposing of wastes in  a landfill  without  rendering the
           wastes non-infectious.

      o    Thirteen states have written or endorsed specific guidelines or
           requirements for transporting untreated infectious wastes.
                                     5-4

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State Air Emission Requirements

     Radian has contacted several states to clarify their infectious waste
management requirements; the information collected from the states is
presented in Appendix A.  The appendix contains an updated list of
infectious waste regulations and requirements as well  as a list of state
offices that may be contacted for additional information.  Where data were
missing from non-contacted states, data available from the EPA Guide for
Infectious Waste Management were listed.  Most states  did not list a
specific regulation concerning the incineration of hospital or infectious
waste.
     Pennsylvania has recently established best available control technology
guidance for hospital infectious waste incineration.   These guidelines
require stack emission limitations on particulate matter, carbon monoxide,
hydrochloric acid and visible air contaminants.  The  guidelines are listed
in Table 5-1 along with guideline emission limits set  by New York, New
Jersey, Connecticut, and Illinois.

State Air Toxics Programs

     A majority of states and localities use some form of ambient guidelines
or standards for the control of emissions of toxic air pollutants from
hospital incinerators.  Several states regulate new hospital  waste
incinerators in a manner similar to that required by  the Resource
Conservation and Recovery Act (RCRA)  hazardous waste  incineration
regulations, i.e.; 100 ppm CO, 90% control or 4 Ib/hr  HC1 emissions,  and
                                                            Q
0.08 gr/dscf (corrected to 12 percent C02) for particulates.    The city of
Philadelphia is requiring that new hospital incinerators have scrubbers,
which are used to control acid gases  and toxic air contaminants.
     The State of Pennsylvania also requires ambient  impact analyses for
arsenic, cadmium, hexavalent chromium, lead, mercury,  nickel,
polychlorinated dibenzo-p-dioxins, and polychlorinated dibenzofurans.  The
acceptable ambient air concentrations for these pollutants are listed in
                                     5-5

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                                    fAUI.t  b-l.   OIIDEIINL  tMISSION LIMITS FOR INClNlRATORS 11URNING HOSPITAL HASTE"
          State/Foe Ulty
          York
                                        Hartlculatu Hatter
                                    0.10 gr/dscf (at 12*
                                                                                           Pollutant
                                                                        Opacity
                              hourly averaje <10X;
                               maximum continuous'
                              6-mlnute average <20X
                                                                                                   IC1
                                                                                                                         CO
                                                                                                                                               SO
                                                                                                            i..  -
      I'cnnsylvanla
      (Facility Mitt)
      Capacity <300 Ib/hr)
      I'onnsylvanla    :
      (Facility with capacity
      >iO(t  Ib/hr. <1000  Ib/hr)
0.08 gr/dscf (at 12X
                                     0.02 gr/dscf  («t 7»
hourly average <10X;
 maximum continuous
3-mlnute average <30X
                              hourly average <10S;
                               maximum continuous
                              3-mlnute average <30*
  <41b/hr or shall
 be reduced by 90*
     by weight


  30 pprov hourly
average (at 7* 0_)
or shal 1 be reduced
 by 90S by weight
 100 ppmv hourly
average (at 7* 0
                                                  100  ppmv  hourly
                                                average  (at 7S 0^)
                         30  ppmv huii i I y
                       average (at '* 0.,)
                       or shal I  be i-uiiuri.il
                        by 70S by wui.jlil
tn
 i
      I 'enn sylvan I a
      (FacUlty with
      capacity  >1000  Ib/hr)
                                    0.015  yr/dsc»  (at 7»
                              hourly average <10X;
                               maximum continuous
                              3-mlnute average  <30t
                           30 ppmv  hourly
                         average  (at  7*  0.)
                         or  shal 1 be  reduced
                          by 90S  by weight
                         100 ppmv  hourly
                      average  (at 7* 0^,1
                         30 ppmv hourly
                       average (at H 0.,)
                       or shal I  bo i uducu.
                        by 70S by wul.|lil
       How Jersey
                                     0.02  gr/6000 Ib/lu )
                                     0.05  yr/scf  (at 12*
                                                                            30*
       IIllnuls
       (I acll Ity tilth capac Ity
       ,2000 Ib/hr. <6000 lL/t,r)
                                     O.Ob .ji/scf (at 12X
                                                                            30*
                                                                                500 ppm at 5(1*
                                                                                         air
       Illinois
       (I act I Ity wltli
       .opacity <2000  Ib/lu )
                                   0.1-0.20 (jr/icf (at
                                                                            30%

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Table 5-2.  The values listed were extracted from data submitted by State
agencies to Radian Corporation for this study.
     The State of New York has drafted operating guidelines for hospital
waste combustion.  These guidelines require stack emission limitations for
particulate matter, carbon monoxide, hydrochloric acid, and visible air
contaminants.  Also, continuous monitoring and recording of temperature in
the secondary chamber are required to show an exit temperature of at least
1600°F.
     New York State generally requires emission tests for priority pollutant
plus 10 toxic air contaminants (including dioxins).  In addition, the State
requires demonstration of compliance with acceptable ambient air quality
levels for toxic air contaminants (or acceptable risk assessments for
                                                        1112
carcinogens) under its Air Guide policy (see Table 5-2).  '
     In the State of California each local air quality district can
establish its own emission limit requirements.  Presently, guidelines, on
emission limits MSW and hazardous waste facilities are serving as guidelines
for hospital waste incineration.  However, California is in the process of
developing new restrictions that pertain directly to hospital waste
incineration.

5.3  FOREIGN REGULATIONS

     In Canada, air pollution regulations are established by each provincial
government.  Table 5-3 lists emission limits established in Alberta, Canada
and technical requirements established in European countries.  This study
did not include the investigation per se of foreign procedures or
regulations.  However, the data presented in Table 5-3 were extracted from
References 13 and 14.
                                     5-7

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            TABLE 5-2.  ACCEPTABLE ANNUAL AMBIENT CONCENTRATIONS

                        REPORTED FOR SELECTED POLLUTANTS3
Metal /Compound
Arsenic and Compounds
Cadmium and Compounds
Hexavalent Chromium
and Compounds
Lead and Compounds
Mercury and Compounds
Nickel and Compounds
2,3,7,8-TCDDC
Pennsylvania
0.23 x 10"3
0.56 x 10"3
0.83 x 10"4
0.50
0.08
0.33 x 10"2
0.30 x 10"7
New York
0.67
2.0
0.167
1.5b
0.167
3.3
_d
References 20 and 21; all concentrations in ug/m .

bFederal standard for lead; not yet officially adopted by New York State,
 but currently being applied to determine compliance status.

cTetrachlorinated dibenzo-p-dioxin equivalents

Emission sources of chlorinated dibenzofurans and dibenzodioxins are
 reviewed on a case-by-case basis by the Department of Health (DOH).   The
 NY State OOH has determined that basing an acceptable ambient level  on
 TCDDs does not adequately represent.publ :c health risks for the dioxin
 compounds.
                                    5-8

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        TABLE 5-3.  FOREIGN EMISSION REGULATIONS FOR HOSPITAL WASTE1
    Pollutant
Alberta, Canada
    European3.
 Particulate matter
0.20 kg/1000 kg    .
of gaseous effluent

0.60 kg/1000 kg
of gaseous effluent
  200 mg/Nm  dry
at 7% CO- maximum
 HC1
100 ppm at 50%
excess air
  300 mg/Nm  dry
at 7% CO- maximum
 CO
                            500 mg/Nm  dry
                          at 7% CO- maximum
 SO,
                            200 mg/Nm  dry
                          at 7% CO- maximum
  HF
                            5 mg/Nm  dry
                           at 7% CO- maximum
  Opacity
                          Not  to  exceed  30%
 References  22  and  23.

3For  incinerators with  a  capacity  of  greater  than  227  kg/h.

"For  incinerators with  a  capacity  of  less  than  227 kg/h.
                                    5-9

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5.-.4  REFERENCES
 1   EPA Guide for Infectious Waste Management.  Office of Solid Waste and
     Emergency Response.  EPA-530/SW-86-014  Washington, DC.  May, 1986.

 2.  Reference 1.

 3.  Reference 1, p. VI.

 4.  Referece 1, p. 1-3.

 5   Vogg H., Metzger M., Stieglitz E., "Recent Findings on the Formation
     and Decomposition  of PCDD/PCDF in Solid Municipal Waste Incineration
     presented at International Solid Waste and Public Cleansing Association
     specialized seminar on  Emissions of Halogenated Organics form Municipal
     Solid Waste Incineration, January 22, 1987, Copenhagen, Denmark.

 6.  Reference 1, p.  1-3.

 7.  Pettit,  C.  L.,   "Infectious Waste State Programs  Survey."  Waste Age,
     April  1987, pp.  115-128.

 8.  Reference 7.

 9.  Reference 5.

 10.  Lauber,  J.D.,  "Controlled Commercial/Regional  Incineration of
     Biomedical  Wastes."  Presented at  the  Incineration of  Low Level
     Radioactive and  Mixed  Wastes, 1987 Conference,  St.  Charles,  Illinois,
     April  21-24,  1987.

 11.  Reference  10.

 12.  New York State Air-Guide-1.   N.Y.S.  P^artment of Environmental
     Conservation  1985-86 Edition, July,  1986  printing.

 13   Powell,  F.C.,  "Air Polutant  Emission  from the Incineration  of  Hospital
     Wastes,  The Alberts Experience."  J.  Air Pollution Control  Association,
      Vol.  37, No.  7,  July 1987.

 14   Faurholdt,  B., "European Experience  with  Incineration of Hazardous and
      Pathological  Wastes."   Presented at  the 80th Annual Meeting  of the Air
      Pollution Control  Association, New York,  New York, June 21-26,  1987.

 15.   BAT and Chapter 127 Plan Approval Criteria Hospital/Infectious Waste
      Incinerators, Draft.  Pennsylvania Department of Environmental  Resource
      Bureau of Air Quality Control.  Harrisburg,  P.A.  June 9,  1987.
                                    5-10

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16..   Regulation of Medical  Care Waste - Incineration Memorandum from
  '   Mr.  Hovey (Originiator:  W. Sonntag).   New York State Department of
     Environmental Conservation.   Albany,  NY,  January 1,  1987.
17.   Reference 10, p.  14.
18.   Environmental Register No. 230:  Proceedings of Illinois Pollution
     Control  Board, December 18,  1980.
19.   U.S. Environmental  Protection Agency,  Federal  Register 39:20792,
     1974.
20.   Reference 15.
21.   Reference 12, p.  27 to 31.
22.   Reference 13, p.  837 to 838.
23.   Reference 14, p.  0-4.
                                     5-11

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                6.0  HOSPITAL WASTE INCINERATOR MODEL PLANTS

     One of the objectives of this study was to develop input parameters for
modeling hospital  incinerator units.  The parameters developed in this study
will be used as inputs to EPA's  Human Exposure Model (HEM).  Results of the
HEM analysis will  then be used to provide a preliminary estimate of chronic
exposure to emissions from hospital waste incinerators.  This objective was
accomplished by developing input data for model incinerators which are felt
to be representative of the general population instead of using actual
hospital incinerator sites and stack parameters.  This approach was taken
because of the difficulty involved in characterizing the capacity and
location of all hospital incinerators on a national level.
     The approach used was to analyze a segment of the population for which
detailed information could be obtained regarding unit capacity, stack
parameters, and operation.  In this case, a recent database of hospital
incinerators in the State of New York was located during the study and used
as a population segment.  Through analysis of the distribution of
incinerator capacities in the New York population, model plants were
identified.  The appropriate stack parameters (height, diameter, gas
velocity, and temperature) were then determined by further evaluation of
this data set.  Finally the emissions factors of Section 3.0 were applied to
to these model plants to estimate the short term and long term emissions
rates.
     This section contains a brief discussion of the relationship between
hospital populations and incinerator populations.  Next, the model
incinerator capacities and stack parameters are determined.  Finally, the
corresponding emissions rates for pollutants of concern are presented for
the model plants.

6.1  POPULATION CHARACTERISTICS

     As discussed in Section 1.1, there are currently over 6,000 hospitals
in the United States (US) and it is estimated that over 90 percent of these
                                    6-i

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facilities operate incinerator equipment of some kind,  if only a small
retort-type unit.  The population of controlled air incinerators is smaller
but still  substantial.  The development of a national  inventory of hospital
incinerators was not feasible for this study.  Instead,  an analysis of a
subset of the population for which the necessary information was available
was performed.  A recent New York (NY) State database was located during the
study which contained information gained through an in-state survey of
incinerator units.1  This database contained unit size,  location, annual
operation, and stack parameters for 433 incinerators located in NY.
     To estimate the "representativeness" of the NY hospital population
relative to the US population, the distribution of hospital sizes was
examined.  The distribution of hospital sizes according to bed number is
presented for both NY and the US  in Figure 6-1.2  Both these distributions
have similar  shapes  for hospital  sizes between 0 and 500 beds.  There is a
greater proportion of hospitals above  the 500 bed size in NY than  in the US
population.   This  is  probably due to  the fact that NY has several  densely
populated areas.   Therefore,  a model  incinerator capacity which corresponds
to  hospitals  with  greater  than 500  beds  is needed since there  are  several
densely populated  areas  in  the U.S. and  the  potential impact of  these
incinerator  units  on the  associated populations will likely be  of  interest
to  EPA.
      No  information  was  found during  this  study which relates  hospital  size
to  the use  of incinerator or  to  incinerator  capacity.  Therefore,  a
correlation  between  hospital  size and incinerator capacity  could  not  be
developed.   A study  of  the population distribution  of incinerator  units
within the  NY incinerator database  was therefore undertaken.   Figure  6-2
presents  the results of this  investigation.   As  shown, 59.6 percent of  the
population  are units with design feed capacities of less  than  200  Ib/hr.
Assuming  that there  is  some correlation between  hospital  size  and
 incinerator capacity this would   indicate that an even greater majority  of
 the national  population of incinerators have capacities  in  this range.   A
model  incinerator should therefore be chosen from  within  the  less than
 POO Ib/hr capacity range.
                                     6-2

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                                          I//N
50-99
100-199     200-299    300-399    400-499
                NUMBER OF BEDS
          New Yorfc
i500
                                                                      U.S.
                        Figure 6-1.  Distribution  of hospital sizes according to bed number.

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 8 -
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                 100-199    200-299    300-399    400-599
                               WASTE FEED RATE (Ib/hr)
                                                                         600-999
ilOOO
              Distribution of incinerator units in  N.Y. database according to  selected
              waste feed  rate ranqe-.

-------
     A further breakdown of the NY incinerator population by unit capacity
is'shown in Figure 6-3.   As can be seen,  the population is bimodal  in this
capacity range with peaks for units between 50 and 74 Ib/hr and 100
and 124 Ib/hr.  A detailed analysis of these two size ranges reveals that
the majority of units in each of the ranges are 50 and 100 Ib/hr,
respectively.  Since a 100 Ib/hr feed rate is closer to the median  of this
population segment than  the 50 Ib/hr feed rate, a model incinerator of 100
Ib/hr capacity was chosen to represent the small incinerator population.
     A study of the capacity distribution for the incinerators in the NY
database was also undertaken.  Figure 6-4 presents the results of this
investigation.  As can be seen, incinerator units which burn 1,000  Ib/hr  or
greater make up 33.5 percent of the incineration capacity.  Units which burn
600 Ib/hr or greater make up 52 percent of the incineration capacity.  A
model unit size of 1,000 Ib/hr was chosen to represent this half of the
incineration population.  The 1,000 Ib/hr model size was chosen because it
represents the. median point within the population of units with feed rates
of 600 Ib/hr or above (see Figure 6-2) and is an order of magnitude greater
than the 100 Ib/hr model incinerator capacity.

6.1.1  Model  Incinerator Stack Parameters

     The stack parameters required as inputs to the HEM include stack
height, diameter, and exit gas temperature and velocity.  The NY incineator
database was used to determine values for each of these stack parameters.
The approach taken was to evaluate a given stack parameter as a function  of
the previously presented incinerator capacity ranges of Figure 6-2.  From
this analysis, the variation of a given parameter was evaluated as a
function of  unit capacity.   If the given stack parameter appeared to be a
function of  unit capacity, then a value based on units in a similar capacity
range  to the model was chosen.  If the parameter of interest was not a
function of  unit size, then  a mean value based on the entire population of
units  was  used.
                                      D-D

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                                          50-74     75-99    100-124   125-149   150-174   175-199


                                              WASTE FEED  RATE (Ib/hr)
             Figure 6-3.  Distribution of incinerator units in N.Y.  database with waste feed rates  less than

                         200 Ib/hr according to selected feed rate  ranges.

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            8.1
                            r	•  '  f  •  •——i	•  • r  •  •——r
              0-99      100-199    200-299     300-399    400-599    600-999
                                      WASTE FEED RATE (Ib/hr)
                                                                                 f
                                                                              21000
                Figure  6-4.  Capacity distribution of incinerator units in N.Y. database
                            according to selected feed rate ranges.

-------
  -,  Stack Height.  The average, high, and low stack height values for a
given feed rate range are shown as a function of feed rate ranges in
Figure 6-5.  The data shown are for incinerators with feed rates ranging
from 1 to 2,700 Ib/hr.  As can be seen, stack heights vary greatly within a
given capacity range.  In fact, within a given capacity range, low stack
height values of 8 feet were observed within the database.  Although this
height appears to be unrealistic, no reasons were identified which could be
used to discount  its use.  One possible explanation is that this is the
height of the stack above the nearest adjacent building and not above the
base of the  incinerator.  Its  inclusion as part of an average value for HEM
modeling purposes should not be a concern, however, because of its
conservative effect on the stack height estimates.  A lower stack height
should correspond to higher exposure levels for the population and therefore
a conservative estimate of the  associated risk.
     The results  presented in  Figure 6-5  show little variation in the
average stack height  across the  range  of  unit capacities.  The highest  of
the  average  stack heights  is 87  feet  and  the  lowest  is 66  feet.  An average
stack  height of  78  feet  is therefore  recommended  as  the HEM input value
regardless  of  unit  size.
      Stack Gas Temperature.  The average, high,  and  low exhaust gas
temperature values  within  a given  feed rate  range are  shown as a  function  of
 feed rate  ranges in Figure 6-6.   As can be  seen,  the  low  in all cases  is
400°F.   Analysis of the NY database indicated several  vent streams  with exit
gas  temperatures of less th?n  400°F.   Because it was  known that  outlet
 temperatures for units which  have heat recovery equipment are limited  to
 approximately  400°F by the stack gas dew point,  units  with exit  gas
 temperatures which were below 400°F were excluded from analysis.   A high
 value of 2,220°F is shown.  Little variation is seen in  the average exhaust
 gas temperatures over the entire capacity range.  For the entire population,
 the high value of the average temperatures  is 1,237°F and the low value is
 1,081°F.   The average stack gas temperature for the entire database is
 1,144°F.   This temperature is recommended for both the 100 and 1,000 Ib/hr
 model incinerators.  Because heat recovery is known to be employed on larger
                                     6-8

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'/,
1
99 200-299 300-399 400-599 600-999 ilOOO
V /\  HIGH
WASTE FEED RATE (Ib/hr)
         AVERAGE
                                                                   VTA   LOW
Figure 6-7. Average, high arid low stack gas exit velocities, according to selected feed  rate  ranges

-------
01

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to
c
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oc


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150 -
140 -
130 -
1 OO -_
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110 -
100 -
90 -
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                   0-99
                        100-199
                          V/\  HIGH
200-299    300-399     400-599     600-999



  WASTE FEED RATE (!b/hr)      	

    IX \l  AVERAGE           V77A  LOW
21000
             Figure 6-8. Average, high and  low stack  diameters according to  selected foed rate ranges.

-------
units,  an additional  1,000 Ib/hr model  unit with an exit stack gas
temperature of 450°F  is recommended to  reflect this situation.  An exit gas
temperature of 450°F  is chosen because  it provides a comfortable margin
above the 400°F acid  dew point.   This temperature also corresponds to a
known unit located at the University of Michigan.
     Stack Gas Exit Velocity.   The average, high, and low stack gas exit
velocities for a given feed rate range  are shown as a function of feed rate
ranges  in Figure 6-7.  Once again, the  variation within a given capacity
range is quite large.  In general, the  average stack velocities shown also
increase with the capacity of the unit.  This is understandable in view of
the increasing volumetric flow rate of  stack gases with increasing
incinerator capacity  and the need to maintain adequate draft and a slight
negative pressure in  the primary chambers of most incineraors.  Therefore",
the average stack gas velocity that applies to the selected model
incinerator will be used.  Exit  gas velocities of 16.4 and 32.1 ft/sec are
recommended for the 100 and 1,000 Ib/hr model incinerators, respectively.
The exit gas velo.city for the 1,000 Ib/hr heat recovery model  is assumed to
be the  same as the non-heat recovery unit.
     One might expect to see a decrease in the exit gas velocity for the
model incinerator equipped with  heat recovery.  This is assumed not to be
the case because of the need to  maintain adequate draft and a  slight
negative pressure in  the primary combustion chamber.  Instead, stack
diameter is reduced to maintain  adequate velocity and, hence,  draft.
     Stack Diameter.   The-average, high, and low stack diameter values for a
given feed rate range are shown  as a function of feed rate ranges in
Figure  6-8.  As was the case for the other stack parameters, the stack
diameters vary greatly within a  given size range.
     If the same approach used to determine the velocities is  used to
determine the stack diameter,  diameters of 25 and 34 inches for the 100 and
1,000 Ib/hr models are determined, respectively.  Unfortunately, these
diameters are not realistic when the volumetric flow rate associated with
the two models are considered; the volumetric flow for a 1,000 Ib/hr unit is
expected to be 10 times greater than the volumetric flow from a 100 Ib/hr
                                    6-13

-------
                              TAHLE 6-1.   SUMMARY OF  MODEL  INCINERATOR STACK  PARAMETERS
         Stack Heights
                       100  Ib/hr Model
                       Incinerator With
                       Ho Meat Recovery
                                        (24)
             1,000  Ib/hr Model
             Incinerator With
             No Heat Recovery
                                                  ?Q

                                                  (24)
                                                                                           1.500 Ib/hr Model
                                                                       1,000 Ib/hr Modt.1   Univ. of Michigan
                                                                        Incinerator With    Incinerator With
                                                                         Heat Recovery       Heat Recovery
                                        ?8

                                        (24)
                                                                                                  227

                                                                                                  (69)
o\
         Exit  Gas Temperature
1,144
 (891)
                                                1,144
                                                 (891)
                                        450
                                       (506)
                                                                                                   cn
                                                                                                  450
                                                                                                 (506)
Exit Gas Velocity
  (ft/sec)
  (m/s)
17.1
                                                         24.5
                                       24  5
                                                                                                   .,
                                                                                                   35
 Stack Diameter
   (In)
   (m)
                                      (0.0635)
                      66
                   (1.676)
                                      (0.940)
                                                                                                 (0.610)

-------
unit.  Instead, the diameter for the 100 Ib/hr model  was chosen as a base
  tf
point.  The diameter for the 1,000 Ib/hr unit was then determined by
assuming a gas flow rate 10 times greater than the velocities previously
determined.  The resultant diameter for the 1,000 Ib/hr model unit is 66
inches.  For the case of the 1,000 Ib/hr heat recovery model, the diameter
was again adjusted for temperature while holding the velocity constant.  The
resultant diameter using this procedure is 37 inches.
     The results of the stack parameter analysis of the NY database are
summarized in Table 6-1.  In conclusion, model incinerators of 100 and
1,000 Ib/hr, with two cases for the 1,000 Ib/hr model, are recommended.  The
recommended stack height, stack exit gas temperature, and velocity values
for each of these models are shown in the table.  For comparison purposes,
the stack parameters used in model.ing a 1,500 Ib/hr controlled air
incinerator operated by the University of Michigan (UM) hospitals are also
presented in this table.  This unit was equipped with a waste heat firetube
boiler.  Most of the UM parameters are.within the general range of the
recommended model incinerator stack parameters; the exception to this rule
is stack height where the UM parameter is well above the recommended model
values.  Based on the NY database, manufacturer literature, and site visits
conducted during this study, the UM stack height appears unusually high.
One possible explanation is that the UM incinerator was located on the top
of the hospital, as is sometimes done, and that the total height above the
ground was used as the stack height.

6.1.2  Model Incinerator Operating Parameters

      The operating parameters required as inputs to the HEM  include the
annual operating hours and hourly and yearly emissions rates.  In order to
determine values for each of these operating parameters, the NY incinerator
database was used to determine the annual operating hours associated with
each  of the model incinerators.  Next the hourly emissions rates were
determined for each of the models by combining the emissions factor of
Section 3.0 with the model capacities previously developed.  Finally the
                                    6-15

-------
yearly  emissions  rates  for  each of  the models was determined by applying the
annual  operating  hours  to the  hourly emissions rates.
      Annual  Operating Hours. The  average  annual operating hours for a given
feed  rate  range  are  shown as a function of  feed rate ranges  in Figure 6-9.
As  can  be  seen,  the  number  of  annual operating hours increases with
increasing unit  capacity.   Smaller  units  (less than 200  Ib/hr), which
operate approximately  1,000 hrs/year,  can be  characterized  as operating  five
days  a  week for  about  4 hours  each  day.   Larger units  (greater than
600 Ib/hr),  which operate  approximately 2,350 hrs/year,  can  be characterized
as  operating five days  a week  for 8 to 10 hrs each day.   Therefore, annual
operating  operating  hours  of 1,000  and 2,350  are  recommended for  the  100 and
 1,000 Ib/hr model sizes, respectively.
      Hourly Emissions  Rates.   The emissions factors  previously developed in
Section 3.0 are  shown  in Table 6-2  along  with the corresponding  hourly  and
yearly  emissions rates for each of the model  incinerators.   High  and  low
emissions  rates  are  given  for  each  of  the compounds  for'which data exist.
 For compounds where  only one datum point  exists,  only  one rate  in shown.
      Different particulate matter (PM) emissions  rates were used  for  the two
model capacities because,  as previously stated,  for  units of less than  400
 Ib/hr capacity a larger variation in PM emissions was  seen  over  those of
 larger units.  The high and low emission  rates corresponding to  this
 breakpoint are shown.   A controlled PM emissions  rate  is also  shown.   This
 rate is based on the baghouse data from the St.  Agnes  emission  test.   It
 should be noted, that the yearly emissions  rates  are ba?3d  on  annual
 operation of 1,000 and  2,350 hrs/year for the 100 and  1,000 Ib/hr model
. incinerators, respectively.
                                      6-16

-------
en
I
        to
        K
        D
        O
        I
        z u
        w «
        Q.O
        of
        Z
                                               1414
                                                           1910
                                                                       2157
                                                                                                2088
                                                                       ' f

                      0-99      100-199    200-299    300-399    400-599     600-999     ilOOO

                                               WASTE FEED RATE (Ib/hr)
                       fiijure 6-9.  Annuu'l opera tiny hours according to' selected fe«.-d r'dte changes.

-------
                                   IAUU 0-2.   SUMMARY 01  (MISSIONS FAUUKS AND RAUS FOK HOSPITAL IHCINLKATOR MOl.tl. Sl/i:
01
CD

Hourly Lmlsilons Rates (kg)
Group/Compound
Add Qflstis.
Hydrochloric Add
High
Low
Sulfur Dioxide
Hlyh
Low
Nitrogen Ox Idea
High
Low
Articulate MalLm:
Uncontrolled (100 Ib/hr)
High
Low
Uncontrolled (1.000 Ib/hr)
High
Low
Controlled (all size*)
High
Low
Trace Hotdls (tlncontrol lud)
Arsenic
High
Low
Cadmium
High
LOW
Chromium
Hlyh
Low
Iron
High
Low
Hlyh
Low
Nickel
High
Low
Factor
(kij/Mg lend)

49.700
3.300
1.505
0.735
.3.910
2.320

13.460
0.845
2.725
0.685
0.025
0.005

1.07 x 10"*
3.55 x IO"3
1.40 x 10"?.
1.24 x 10"J
3.04 x 10~*
5.10 x 10
9.15 x IO"3
1.99 x 10
5./0 x 10~*
7.90 A 10'5
2.50 x 10"*
5.40 A 10
100 Ib/hr
Model

2.2564
0.1498
0.0683
0.0334
0.1775
0.1053

0.6111
0.0384

0.0011
0.0002

4.86 x 10~j?
1.61 x 10"°
1.54 x 10"*
5.63 x 10
1.38 x lO"*
2.32 x 10"°
4.15 x 10"*
9.03 x 10"'
2.59 x Id"*
3.59 x 10"°
1.14 x 10"S
2.45 x 10'°
1,000 Ib/hr
Model

22.5638
1.4982
0.6833
0.3337
1.7751
1.0533


1.2372
0.3110
0.0114
0.0023

4.86 x 10"*
1.61 x 10~s
1.54 x 10"*
5.63 x 10"'
1.38 x 10"*
2.32 x 10"5
4.15 x 10~3
9.03 x 10
2.59 x lo"r
3.59 x 10"J
1.14 x id"*
. 2.45 x I0's
Yearly Inilbbluns Rate* (kg)
100 lb/lud
Modul

2.256.J8
149.82
66.33
33.37
177.51
105.33

611.08
38.36

1.14
0.23

4.86 A lo"3
1.61 x 10"J
1.54 x 10"'
5.63 x 10"
1.38 x 10"^
2.32 x 10"J
4.15 x lo"'
•j.03 x 10
/.59 A lo"^
3.59 A If."3
1.14 A In"2
2.45 > in"'
1,000 lb/hib
Mode 1

53.024.93
3.520.77
1.605.68
784.17
4.171.58
2.475.21


2.907.30
730.83
26.67
5.33

2.14 x 10"'
3.79 x 10"'
3.63
1.32
3.24 x 10"'
5.44 x 10"*
9.76
2.12
t>.0tt x 10"'
8.43 x 10
2.07 x 10"'
•j./6 x IO"2

-------
                               TAULt  0-2.   SUMMAKY 01 IMIbSIONS  FACIOKS AHU KAIES FOK IIOSIM1AL  INC1NERA10H MODEL SUtS  (CONl ItJUtl))
O\




Group/Compound
Lead
Htijh
Low
Ploxlns
(Tutrd)TCDD •
High
Lou
(Penta)HCUD
High
Lou
(Mexa)HxCOD
High
Lou
(Hepta)H«£DD
High
Loo
(Octa)DCDO
High
LOM
Total PCOD
High
Low
Furans
(Tetra)TCDF
High
Lou
(Penta 1PCOF
High
Lou
(Hoxa)HxCDF
High
Low
(H6pta>HeCI>F
High
Lo«
(Octd)DCUF
High
I OK
lotdl PCDF
Hlijh
LOH

Emissions
factor
(kg/My feoU)
2.80 * 10"^
1.52 x 10"'

5.35 x 10"'
.2.00 x 10"°
3.80 x 10"'
5.50 x 10"°
7.60 x 10"'
1.35 x 10"'
1.92 x 10"^
1.60 x 10"'
2.74 x 10~(j
1.70 x 10"'
0.26 x 10~!j
7.15 x 10"'

1.04 x 10"!j
2.50 x 10"'
1.90 x 10"6,
4.50 x 10"'
2.82 x 10~!)
4.10 x 10"'
3.23 x 10"!j
2.7b x 10"'
2. IB x 10~*
l.llb « 10"'
l.uy A 10~*
l.l.i * 10"°
Hourly Emissions

100 Ib/lir
Model
1.27 > 10"^
6.90 x 10"'

2.43 x 10^
9.08 x 10 lu
1.73 x 10-*
2.50 x 10
3.45 x 10'|!
6.13 x 10"a
8.69 x 10~jj
7.26 x 10"S
1.24 x 10"'
7.72 x ia"9
2.84 x ID''
3.25 x 10"U

4.70 x 10"^
1.14 x 10"U
8.60 x 10"^
2.04 x 10"°
l.'d x 10"?
1.86 x 10'°
1.47 x 10"'
1.25 x 10"°
9.b7 x 1U~"
4.77 x 10"y
4. 'Jo A 10"'
/.3H x 10"B
Rdtes (kg)

1.000 Ib/hr
Model
1.7V x 10"^
6.90 x 10"'

2.43 x 10"'
9.08 x 10~*
1.73 x 10"'
2.50 x 10"°
3.45 x 10"'
6.13 x 10"u
8.69 x 10"'
7.26 x 10"°
1.24 x lO'Ji
7.72 x 10"°
2.84 x 10"^
3.25 x 10"'

4.70 x 10"'
1.14 x 10''
8.60 x 10"?
2.04 x 10"'
1.28 x 10"^
1.86 x 10"'
1.47 x 10"^
1.25 x 10"'
9.87 x 10"'
4.77 x 10-8
4.96 x lll"!j
7.38 x 10"'
Yearly Emissions

100 lu/hr
Model
1.2700
6.90 * 10"1

2.43 x 10"^
9.08 x 10"'
1.73 x 10"^
2.50 x 10""
J.45 x 10"-!
6.13 x 10"°
8.69 x I0"ji
7.26 x 10"°
1.24 x 10"*
7.72 x 10"°
2.84 x 10"*
3.25 x 10~*

4.70 x 10~J!
1.14 x 10"S
B. 60 x 10" J!
2.04 x 10"b
1.2B x 10"*
1.U6 x 111"1
1.47 * 1()~*
1.25 x \U~*

-------
at
 I
to
o
                             I ABLE 6-2.
                                        Sl«MARY OF EMISSIONS FACTORS ArC RATE'. FOR .OSPITAL INCINERATOR MODEL SIZES (U1NTINUFD)
	
Hourly Emissions Rates (kg)
Group/Compound
|ft- Holbziildl Oruanlca
Ethane
Ethylene
Propane
Propylone
Trtchlorotrll luoroelhylene
Tetrachlorome thane
TrlchJoroethylene
Tetrachloroothylene
Carbon Monoxide
High
1 ON
Emissions
Factor
(krj/Mg (ecu)
0.001S
0.0100
0.0120
0.0110
4,13 x \Q-_l
4.96 x 10 I
1.20 x 10 j!
l.?5 x 10~5
0.85
0.66
100 Ib/hr
Model
O.OU01
O.UOOS
O.OOOS
0.0050
1.87 x 10"£
2.2S x 10~°
5.43 x 10'' .
5.65 x 10''
0.03b4
0.0300
1.000 Ib/hr
Model
0.0007
0.0045
0.0054
0.0050
1.87 x 10"*
2.25 x 10"*
5.43 x 10"?
5.65 x 10"°
0.3836
0.2996
Yearly Emissions Rdtos (kg)
100 Ib/lir*
Model
0.07
0.45
0.54
0.50
1.87 x 10,
2.25 x 10~2
5.43 x 10"*
5.65 x 10
38.36
29.26
1.000 lb/l.ib
Mudel
l.oO
10.67
12.80
H./4
4.40 x 10",
s.29 x 10";
1.27 x 10";
1.33 x 10"z
901.53
704.15
	 	 — . 	 • — • 	
*Based on 1.000 hours of yoarly operation.


bBased on 2,350 hours of yearly operation.

-------
5.2  REFERENCES
 1.  Private communication between T.  Moody,  Radian Corporation and Howe,
     Gordon, and Sontag, New York State Department of Environment
     Conservation,  June 9, 1987.

 2.  Summary Report, Hospital Statistics, American Hospital Association.
     1986 Edition.

 3.  Doucet, L. G., and Maiuka, P. C., Hospital Incinerator Emissions. Risk
     and Permitting - A case Study.  Presented at the 80th Annual Meeting of
     APCA, New York, New York, June 21-26, 1987.
                                    6-21

-------
APPENDIX A

-------
                                                                  AI'I'LNUIX A
                                         STATE REGULATIONS PERTAINING TO INFECTIOUS WASTE MANAGEMENT
Slate
Alaba
Alaska
Arkansas
                           Statutory  Authority and
                             Regulation  Citation
                      1975 Code of Alabama.
                      Section 22-21-20.   Alabama Sta
                      Board ui' Health  Kules  and
                      Regulations for  Nursing Hume*
                      and Hospitals.
                     No  regulations.
                     Laws ol Alaska,  Title  44.
                     Chapter 46;  Title  46.
                     Chapter 3.
                      Arizona  Hi-vised Statutes,
                      Title  3o.  Article 2.
                      General  Hospitals.   Regulation
                      R9-10-220,  Environmental Seivices,
                      Subsect Ion E.
                      Act  414  of 1961.  as amended by
                      Act  444  of I96!> and Act 454 of
                      1965.  Rules and  Regulation* for
                      Hospitals  and Related
                      lust ituL iuiis In Arkansas.
     Suimiary of Requirements
All infectious waste generated
by nursing homes and hospitals
must be incinerated on site.
Policy is to recommend treatment
of infectious waste prior to
disposal.
All Infections waste generated
by medical and veterinary
facilities must be incinerated
prior to final disposal.
The state has statutory authority
to legulate infectious waste,
but has not yet promulgated
regulat ions.

All infectious waste must be
either (1) autoclaved and
disposed of In an approved
sanitary landfill, or
(2) Incinerated In an approved
Incinerator.  Variances are
given fur disposal of untreated
waste when there is  Insufficient
treatment capacity.

All infectious waste generated
by hospitals and related
instliutions must be Incinerated
or Jispused uf by other approved
methods.  Revisions  are expected
III I'JBG.                         '
                                                        State  Agency
Bureau of I.Lceiisure an>l Cert ll'icat lun
State Health Department
Room b)2
State Office Building
Montgomery, Alabama  361JU-17U1
(205) 261-MUb

Alabama Department uf Environmental
  Management
Land Division
1/bl Federal Drive
Montgomery, Alabama  36130
(205) 271-I7UU

Air and Solid Uaste Management
Department of Environmental  Conservation
Pouch O
Juneaii. Alaska
(907) 46i-'JLGb
Bureau of Health Care  Institution
  Liceilsure
Arizona Department  ut  Health Service's
1740 Uest Adams Street
Phoenix, Arizona   BbUU/
(602) 2i5-llli
Department ut  Heullh
Division ot  Ik-ulili Fj.:iliiies
4815 U. M..il.li...ii lili.-^-i
LitUv Kuck.  Aikuu^a^  /J2UJ-^
(iUl) ool :-j.j|

-------
                                                                     APPENDIX A (CONTINUED)
          Scat*
          California
          Colorado
 I
10
           Connect Icut
           Dalaware
                                     Statutory Authority and
                                       Regulation Citation
                                             Suiimary of Requirements
                               The Solid Uaste Management Act
                               (23/) of 1971.   Arkansas Hazardous
                               Uaste Management Act of 1979
                               (Act 406 of 1979).
California Health and Safety Code
Chapter 6.i, Article 2.
Section 21117.5 California
Administrative Code. Title 22.
Division 4. Chapter 10:  Minimum
Standards for Management of
Hazardous and Extremely Hazardous
Uastei Infectious Waste RegulalIons.
effective November 16. 1985.*

Colorado Revised Statutes, 1973. as
amended: Title 25. Article 15.
Parts  1, 2. and 1:  Hazardous Uaste
Management Act.
                               Chapter 4. Regulations Governing
                               General Hospitals.
 Connecticut General  Statute*  of
 197V.  Public  Act  79-605.
 Code  22A-4481 and 22A-115.
 Delaware Code.  Title 7,  Chapter 60:
 Solid Uaste Act.   Delaware Solid
 Uaste Disposal  Regulations.
 August 1974.
                                        The state has statutory authority
                                        to regulate Infectious waste as a
                                        hazardous waste, but has not yet
                                        promulgated regulations.
Infectious waste must be
incinerated. sterlUzed or treated
by other approved method*.
The state has statutory authority
to regulate Infectious waste as a
hazardous waste, but has not yet
promulgated regulations.
                                        Pathological waste must  be
                                        Incinerated.  Otf-slte disposal  In
                                        approved  sites  Is possible.
The state has statutory authority
to regulate  Infectious waste as  a
hazardous waste,  but. has not yet
promulgated  regulations.
 Infectious  waste  disposal  is
 approved  on a  case-by-case basis.
 Hone  has  been  allowed to go to
 landfills untreated  since  the
 approval  process  was Initiated.
 Revised regulat luiis  have been
 pruuused.
                                                                                               State Agency
Solid Uaste Management Division
Department of Pollution control and
  Ecology
P.O. Bon 9581
8001 National Drive
Little Rock, Arkansas  12219
(501) 562-7444

California Department of Health
  Services
Hazardous Materials Management Sectlun
714/744 P Street
Sacramento, California  95814
(916) 124-1798
Uaste Management Division
Colorado Department of Health
4210 E. llth Avenue
Denver. Colorado  80220
(101) 120-8111 Ext. 4164

Division of Health Facilities
   Regulations
Colorado Department of Health
4210 E. llth Avenue
Denver. Colorado  8022O
(101) 120-8111 Ext. 6106

Hazaidous  Uaste Management
Department of Environmental Protection
State Office Building
 165 Capitol Avenue
Hartfurd.  Connecticut 06106
 (201) 566-4H6V or  566-5712

Uaste Management  Suction
Department ot Natural Resources and
   Eiivi roiuiieui •* I Com i-ol
89 KIIIC Highway
 P.O.  box  HOI
 lli.vc.'.  Del..ujiu   I'J'JIU
 CJ02)  /J6  Wttl

-------
                                                           APPENDIX A  (CONTINUED)
State
District of
  Columbia
Florida
Georgia
Hawaii
Idaho
                           Statutory Authority and
                             Regulation Citation
                                             Summary of Requirements
District of Columbia Hazardous
Waste Management Act of 1977.
O.C. Law 2-64.
                     Florida Resource Recovery and
                     Management. Act (Florida Statutes
                     Annotated. Title 21. Public Health,
                     Chapter 403, Part IV. Enacted by
                     the Laws uf 197*. Chapter 342. as
                     amended).  Florida Resource
                     Recovery and Management Regulations:
                     Rule* of the Department of
                     Environmental Regulation,
                     Chapter 17-7.04.*
Code of Georgia. Annotated,
Title 4). Chapter 43-16:  Solid
Uaste Management Act of 1972, as
amended.  Georgia Department of
Natural Resources Rules and
Regulations for Solid Uaste
Management, Chapter 391-3-4, 1972.
as amended through 19/4.

Hawaii Environmental Laws and
Regulations. Vol. I, Title 19,
Chapter 342, Part V. as amended
by Chapter 230. Laws of 1974.
Title II, Department of Health,
Chapter »H. Solid Ua*te
Management Control kvgulation*,
November 1981.

Idaho Code, Title 39. Chapter I.
Idaho Solid U^atu M.*liai;eilu.'liL
Regulations, Title I, Chapter o.
The District has statutory
authority to regulate Infectious
waste as a hazardous wa*te. but
has not yet promulgated
regulation*.
                                        Infectious waste must be
                                        Incinerated or treated by an
                                        approved treatment method before
                                        being placed la a landfill.
Infectious waste Is considered a
special waste.  Policy Is to
.require Incineration or
autoclavlng before land disposal.
                                                             All Infectious waste must be
                                                             treated or otherwise rendered
                                                             safe before disposal.  Double
                                                             bagging Is considered a means of
                                                             rendering an untreated waste
                                                             safe.
                                                             All &olid wa*te must lme managed
                                                             to prevent health hazards.
                                                             public nui&duce*. and pollution
                                                             of the environment during
                                                             treatment, storage and disposal.
                                                             Policy is LO recuiunend' that-
                                                             infectluu» u^sie be double
                                                             bagged prior to di^pu&al.
                                                                                                                     State  Agency
Department of Consumer and Regulatory
  Affair* and Environmental Control
  Division
5010 Overlook Avenue, SU
Washington, DC  20032
(202) 767-8414

Solid Uaste Management Program
Department of Environmental Regulation
Twin Tower* Office Building, bill Klour
2600 Blair Stone Road
Tallahassee. Florida  32301
(904) 48o-030U

and

Department of Health and Rehatii 1 itat Ive
  Services
1317 Winewood Boulevard
Tallahassee, Florida  32301
(904) 488-2905

Land Protection Branch
Environmental Protection Division
Department of Natural Resources
Room 724
270 Uashington Street. SU
Atlanta. Georgia  30334
(404) 656-2833
                                        Air and  Solid  Uaste  Permit Section
                                        Department  of  Health
                                        Amelco Building.  3rd Floor
                                        641 Halekau Uila  Street
                                        Honolulu.  lUwuii   40313
                                        Hazardous  M^tcri^l*  bureau
                                        Department  ol  Health jiiJ Ucll'are
                                        Slalu  Hou^i.-
                                        Uoiie.  Ul^hu   lli/JU
                                        (2Ud)  J3

-------
                                                           APPENDIX  A  (CONTINUED)
State
Illinois
Indiana
 Iowa
 Kansas
 Kentucky
                           Statutory Authority and
                             Regulation Citation
                                             Summary  of  Requirement*
                                                                                               State Agency
Illinois Revised Act 101-105,
January 1985.  State of Illinois
Rule* and Regulations 35.
Subtitle G. Subpart F.
Sectlona 700.601-700.605.  .

Indiana Code. Title 11. Article 7.
Environmental Management Act.*
                     Refuse Disposal Act:  Recodlfled
                     a* Indiana Solid Waste Disposal
                     Law 1C-16-9-30.  Rule 310 IAC 4.
 Iowa Code  1985. Section 4S5B.304.
 900—100.3(2)  Iowa Administrative
 Code (IAC)
 Kansas Statutes  Annotated.
 Chapter 65,  Article 14.  as  amended.
 Kansas Administrative Regulations.
 Title 28.   Public Health.
 Article 29.  Regulation 27.
 Effective Hay 1984.
 Kentucky Revised Statutes.
 224.005(227)(a).
All Infectious hospital waste must
be rendered limocuo/us by
sterilization or Incineration
before disposal.
The state has statutory authority
to regulate Infectious waste as a
hazardous waste, but has not yet
promulgated regulations.
Regulations are being drafted.
Written approval must be obtained
before disposal of Infectious waste
In a sanitary landfill.  A 5-year
permit system was established In
April. 1987.*

Land disposal of  Infectious waste
Is prohibited unless a  special
waste authorization  Is  granted
that requires autoclavlng or
formalin  treatment before land
disposal.
 Infectious  waste  must  be
 Incinerated,  treated before land
 disposal, or  ground to the sewec.
 Untreated  Infectious waste may be
 sent to a hazardous waste land
 disposal facility or to • sanitary
 landfill with authorization from
 the Department.

 The state has statutory authority
 to regulate Infectious waste as a
 hazardous waste,  but has not yet
 promulgated regulations.
Division ot Land Pollution Control
Environmental Protection Agency
2200 Churchill Road
Springfield. Illinois  62706
(217) 782-6762 or 782-6760

Division of Land Pollution Control
State Board of Health
1110 West Michigan Street
Room A104
Indianapolis. Indiana  46206
(117) 241-9100
Air  and Haste  Permit  Branch
Program Operations  Division
Iowa Department  of  Uater.
   Air and Waste  Management
Henry A.  Wallace Building
900  East  Grand Street
DCS  Koines,  Iowa  50119
 (515) 281-8692

Solid Waste  Management Section
Department of  Health and Environment
Forbes Field,  Building 121
Topeka.  Kansas 66620
 (911) 862-91bO.  Ext.  109
 Division of Waste Management
 Cabinet of Natural Resources and
   Environmental Protection
 18 Rellly Road
 Frankfort. Kentucky  4U601
 (502) 564-6710

-------
                                                                     APPENDIX A (CUIITINUKD)
                                    Statutory Authority  and
                                      Regulation  Citation
                                             Suiunary of Requirements
                                                                                                Slate Agency
         Louisiana
 I
Ui
         Maine
         Maryland
                              Cert I t'icate of  Heed  and  LlCtrnsure
                              Law. an  revised,  (originally
                              eftecllve January  1,  1473).
                              "02  Kentucky Administrative
                              Regulat ions. 20:009.  Hospital
                              Facility Regulation.
                              Louisiana Revised  Statutes,
                              Act  t49. 30:   1133,
                              Environmental  Affairs  Act.*
                               Title  3d  ot  Main  Revised
                               Statutes  Allliulated.
Annotated Maryland Coe'e  Healili
Environment Article, Si c: ions
9-210(g) and 9-229. effective
July 1. 19B4.

Amended Guidelines for the Dispo
uf Infectious Waste, elfeclive
July 1. I'jfl*.
                                        Hospitals must have an  incinerator
                                        capable uf destroyInn infectious
                                        waste.  Hospitals which satisfy
                                        the treatment, packaging,  and
                                        transpoitattun requirements  can
                                        secure waivers to incinerate the
                                        waste in city facilities.  Revised
                                        rcgs effective 6/4/8S require  that
                                        shaip waste (needless,  glass,  etc.)
                                        be separated from other Infectious
                                        waste.  Sharp waste Is  to  be
                                        packaged In rigid containers fur
                                        either incineration or  disposal  in
                                        approved landfills.

                                        The state has 'statutory authority
                                        to regulate Infectious  waste as  a
                                        hazardous waste, Lint has not yet
                                        promulgated regulations.   Policy
                                        Is to allow disposal of treated
                                        Infectious waste in selected
                                        sanitary landfills.  Revisions
                                        are expected.

                                        The state has statutory authority
                                        to regulate Infectious  waste as  a
                                        hazardous waste, but has not yet
                                        promulgated regulations.
Int'eui
of in
                                                                             a landfill.
                                                                                         aiuiot be disposed
                                                                       lncinuraii.nl is the preferred
                                                                       method of liealmeut.
                                        Division for Licensing  and  Regulation
                                        Department of Human Resources
                                        273 E. Main Street
                                        Frankfort. Kentucky   40601
                                        (502) S64-2bOO
                                        Hazardous Waste  Division
                                        Department uf  Natural  Resources
                                        P.O. Box ttObu
                                        Baton Rouge. Louisiana  7UH04
                                        
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                                                          APPENDIX A  (CONTINUED)
Since
Michigan
'Minnesota
 Mississippi
 Missouri
Massachusetts
                           Statutory  Authority  and
                             Regulation Citation
Massachusetts General Lavs.
Chapter 111, Subjections 1 aiul
51-16. and Chapter 111D.
105 CMK 110.154 and 110.154.
Hazardous Infectious Uaste Disposal
Regulations) and 105 CMR 180.275.
Regulation for Disposal of
Infectious Materials from
Independent Laboratories.
Massachusetts General Laws.
Chapter 21-C.*

Massachusetts General Laws.
Chapter 21-C.*
 Minnesota Statutes  Annotated.
 Chapters  115A and 116.  inacted
 by Laws of 1980.  fes amenoed.
 Minnesota Code of Agency Rules.
 Title 6.  Part *.  as amended
 SU1-12 and SU6-2vlll.

 Ho laws or regulations pertaining
 to Infectious waste management.
 Missouri Hospital Licensing l.t,u.
 Chapter 191 of Missouri Revised
 Statutes. Kules and Regulatinns
 for Hospitals.
                                             Summary  of  Requirements
                                                                                               State Agency
Infectious waste must be
Incinerated ur treated before
disposal.
The state has statutory authority
to regulate Infectlous waste as a
hazardous waste, but has not yec
promulgated regulations.

As of December 28.  1985. Michigan
deleted  Its list of  Infectious
wastes from the regulations.
 Land disposal of  Infectious waste
 Is  prohibited.
 Infectious waste generated by
 hospitals must be either
 Incinerated or auiocleved bel'ore
 being sent to a landfill permitted
 to accept the ujsle.  Uaste  Is
 required to be treated, on site.
 The stale expects to revise
Massachusetts Department of Public
  Health
150 Tremont Street
Boston. Massachusetts  02111
(617) 727-270U
Division of  Solid  and Hazardous  Uaste
1 Uinter Street
boston. Massachusetts  02108
(617)  292-5582

Office of  Hazardous Uaste Management
Michigan Derailment of Natural Resources
P.O.  Bo>  30018
Lansing. Michigan  48909
 (517)  171-12>u

Division  of  Solid and Hazardous Uaste
Minnesota  Pollution Control
 1915 Uest  County Road B-2
 Roseville. Mliuwsota  55111
 (612) 296-7J7J
 Division of Solid/Hazardous Uaste
   Management
 Bureau of Pollution Control
 Department of Natural Resources
 P.O. Bon 10185
 Jacksuii. Mississippi  1920V
 (601) 961-5171

 Missouri Deuai-luieiit ot Health
 Bureau of Husuital 1.in-using
 P.O. BOM 570    '
 Jefferson Guy. Missouri   65102
 (1U) 751-27TJ

-------
                                                                    APPENDIX A (CONTINUED).
         State
                                    Statutory Authority and
                                      Regulation Citation
                                             Summary of Requirements
                              Missouri Hazardous Waste Management
                              l.au. Chapter 26U ol Revised
                              Statutes at Missouri. 1*35, as
                              amended.
                                        The state has statutory authority
                                       .to regulate infectious waste as a
                                        hazardous waste,  but has not yet
                                        promulgated regulations.
                                                       State Agency
                                        Waste Management Program
                                        Department of Natural Resources
                                        P.O.  Box 176
                                        Jefferson City, Missouri  b51u2
                                        (314) 751-3241
         Montana
 I
-J
         Nebraska
Missouri Solid Waste Management
Law. Chapter 260.200 of Revised
Statutes of Missouri. 197b.
Missouri Solid Waste Management
Rules and Regulations, 10CSRBO.
Chapters 1-5.

Montana Solid Waste Management
Act of 1976.  Administrative Rules
of Montana, Title 16. Chapter 14.
Subchapter i. Solid Waste
Management/Refuse Disposal.
Montana Hazardous Waste Act of
1981.
                              Nebraska Environmental Protection
                              Act. Section 81-1501 through
                              81-1540.
                                                                      Sterilized infectious waste may be
                                                                      disposed of in any permitted
                                                                      solid waste landfill.
Policy is Co recomnend treatment
of Infectious waste before Land
disposal.
The state has statutory authority
to regulate infectious waste as a
hazardous waste, but has not yet
promulgated regulations.

The state has statutory authority
to regulate infectious waste as a
hazardous waste, but has not yet
promulgated regulations.
.Solid and  Hazardous Waste
 Management Bureau
 Department of  Health and Environmental
   Sciences
 Cogswell Building.  Room B201
 Helena. Montana  59620
 (406) 444-2821
                                                                                Land Quality Division
                                                                                Department of Enviruiuiiental Control
                                                                                State House Station
                                                                                P.O. Box 94877
                                                                                Lincoln. Nebraska  68509
                                                                                (402) 471-2186
         Nevada
Nevada Revised Statutes,
Chapter 459, Hazardous Waste
Disposal and Solid Waste Disposal.
Regulations Governing Solid Waste
Management, Effective 1977.
The state has statutory authority
to regulate infectious waste as a
hazardous waste, but has not yet
promulgated regulations.
 Division of Environmental Protection
 Department of Conservation and Natural
   Resources
 Capital Complex
 Carson City. Nevada  B'J/10
 (702) 88S-467U
                                                                      Infectious waste generated by
                                                                      hospitals may be placed in a land
                                                                      disposal facility only under
                                                                      approval of the Department.      (

-------
                                                                   APPENDIX A (CONTINUED)
         State
         Hew Jersey
 I
OO
          Hew Me«lco
          Hew York
                                    Statutory Authority and
                                     Regulation Citation
                                             Summary  of  Requirement*
                                                                                               State Agency
         Hew Hampshire
New Hampshire Revised Statutes
Annotated lit-. 1979.   Health
facilities Rulei and Regulations.
effective February 198*.   Cener.l
Requlcementi for all Facilities.
HEP-801.
Hew Jersey Statues Annotated.
Title 13:  Conservation and
Development. Chapter 1E-1.
Hew Jersey Administrative Code.
Title 7. Chapter 26. as amended.
Hew regulations dealing with
hazardous wastes enpected.*

New Jersey Health Care Facilities
Planning Act.  New Jersey
Administrative Code B:43-B-3.6.«
 Hazardous Uaste Act. Section
 74-4-3.  as  amended  through  1981.
 Environmental  Conservation Law.
 Article 27.   Title 6 NCRR
 part 364.   Collection and Transport
 of Industrial. Commercial, and
 Certain Other Uastes.*

 Parts 219 and 222:  General
 Regulation of Refuse and Uaste
 Incineration.*
Infectious waste generated by
health care facilities must be
Incinerated.
Infectious waste inust be rendered
nonlnfectlous In accordance with
the standards of the New Jersey
Department of Health.
All  Infectious waste generated
by hospitals must -be treated before
land disposal.  Infectious waste
that Is not autoclaved or
Incinerated can be double-bagged
for  land disposal by a method
approved by the Department of
Environmental Protection.

No  specific regulations on
Infectious waste.  Incineration
or  sterilization of  Infectious
waste  followed by land disposal
Is  recommended.
 Anyone transporting a hospital
 waste off-site  (including
 Infectious waste)  must have a
 waste transporter's permit.


 These regulations  limit emissions
 of paniculate  matter and smoke.
Bureau of Health Facilities
  Administration
Division of Public Health
Department of Health and Welfare
6 Hazen Drive
Concord. New Hampshire  03101
(603) 271-4492

Division of Uaste Management
Department of Environmental Protection
33 East Hanover Street
Trenton. Hew Jersey  0862i
(609) 292-9877
                                                                                                              Hew Jersey Department of Health
                                                                                                              Division of Health Facilities Evaluation
                                                                                                              CN 370
                                                                                                              Trenton. Hew Jersey  0862S
                                                                                                              (609) 292-783*
 Solid and Hazardous Uaste Management
   Programs
 Health and Environment Department
 P.O.  Bon 968
 Santa Fe. Hew Mexico  87*04-0968
 (505) 827-5271 or 827-0020

 Division of Solid and Hazardous Uaste
 Department of Environmental Conservation
 SO Uolf Road. Room 417
 Albany. New York  12233
 (518) 457-3254

 New York State Department of
   Environmental Conservation
 50 Uolf Road
 Albany. New York  12233
 (518) 457-561U

-------
                                                            APPENDIX A (CONTINUED)
State
North Carolina
North Dakota
Ohio  .
Ok1ahoma
 Oregon
                           Statutory Authority aiui
                             Regulation Citation
                     10 NYCKR 405.1(b)(S):  Handling  of
                     Potentially  Infections Waste.'
                     North Carolina Solid and  Hazardous
                     Waste Act, as revised,  July  l'JU3.
                     10 NCAC  IOC, Solid Waste  Management .
                     July 1.  1985.
                     No governing statute or  regulations.
                     Ohio Revised  Code.  Title  37,
                     Chapter  14, as  amended.   Ohio
                     Administrative  Code,  Regulations
                     3745-27  and 371.5-37,  effective
                     July 24.  1976.
Oklahoma Statues, Title 63, 1'JUl,
Section 1-2001 et seq., Oklahoma
Controlled Industrial Waste
Disposal Act.'
Oregon KevlseJ Statutes,
(Jhaulei1 45'J, as amended.  Oiegmi
AJminl^liul tve Rules. Chapter 114U.
Uivi:. ion 61.
                                             Suinnary of Requirement!
                                                                                                Slate Agency
                                        The various categories of
                                        potentially Infection* waste and
                                        acceptable methods of disposal
                                        for each are presented.  All
                                        waste must be autoclaved or
                                        Incinerated prior to disposal.

                                        Iiitectlous waste must be treated
                                        by an approved method prior to
                                        disposal In a landfill.
                                        Policy is to require autoclaving
                                        or incineration of all  infectious
                                        waste generated by hospitals and
                                        nursing homes.  No untreated
                                        infectious waste may be disposed
                                        of in a landfill.  Every hospital
                                        and nursing home must have  access
                                        to a double-chambered,  approved
                                        Incinerator in order to be
                                        1Icensed.

                                        The state has statutory authority
                                        to regulate Infectious  waste as a
                                        hazardous waste, but has not yet
                                        promulgated regulations.
The state has statutory authority
to regulate infections waste as a
hazardous waste, but has not yet
promulgated regulations.  Current
policy is based on CDC guidelines.
Infectious waste regulations are
being drafted.

Land disposal ot infectious waste
is controlled through the
pern.! 11 ing process for land
disposal facilities.            '
                                        New York State Department of Health
                                        Office of Health Services Management
                                        Nelson A. Rockefeller Empire State Plazd
                                        Corning Tower. Room 1821
                                        Albany. New York  12217
                                        (518) 474-2121

                                        Solid and Hazardous Waste
                                        Management Bianch
                                        Division of Health Services
                                        Department of Human Resources
                                        P.O. Box 20*1
                                        Raleigh. North Carolina  27602
                                        (919) 733-217B

                                        Division ot He.ilih Facilities
                                        Department of Health
                                        State Capitol Building
                                        Blsmark. North Dakota  5B5U5
                                        (701) 224-2152
Division of Solid and Hazardous Waste
  Management
Ohio Environmental Protection Agency
161 East Broad Street
Columbus. Ohio  43215
(614) 466-7220

Institutional Services, Medical
  Facilities
Department of Health
P.O. 5J551
100U N.E. lUth Street, 4th Floor
Oklahoma City. Oklahoma  73152
(405) 271-6811

Hazardous -i I id ^ol 1>I Wjile Division
lii-pai iinciii ul Hisvir	iu--m.il Quality
P.O. box ltou
I'ui'l land, inutuli  VI'Ml

-------
                                                           APPENDIX A (CONTINUED)
Scat*
Pennsylvania
 I
I—
o
 Rhode  Island
 South Carolina
 Scutli Dakota
                           Statutory Authori~.y and
                             Regulation Cll..t.on
Pennsylvania Statutes,
b2 PS 901-1059, Public Ueltaie
Cod*.  Pennsylvania CoJe. Title 28.
Chapter 1*7.7*, Pennsylvania Stale
Health Department Regulation*:
Disposal of Bacterial and
Pathological Hastes that arc •
Generated In Hospitals and Medical
Care Facilities.*

25 Pa. Code 127.12(a)(5)«
Rhode  Island Hazardous Waste
Management Act of  197B.

Hazardous Uaste Rules and
Regulations  for Hazardous Uaate
Generation,  Transportation.
Treatment, Storage and Disposal
Effective July  18. 198*.

Cude of  Laws of South Carolina,
 1976,  Sections  **-56-10  through
 **-So-l*0, Hazardous Wastes.
 South U.kuia Cudit'led Laws,
 Chapter 3*A-6-2, Solid Uaste
 Disposal Act.
                                             Summary of Requirements
                                                                                               State Agency
Current policy l»'to allow off-slt«
sterilization of infectious waste.
New regulations are being drafted.
Best Available Technology
requirements for hospital/
Infections waste Incinerator
facilities Include stack emission
limitations, ambient Impact
analyses, operating, testing and
monitoring requirements.  Tnese
regulations are in draft review.
effective June 9, 1987'.

Infectious waste Is regulated as
a hazardous waste.
 The  state has  statutory  authority
 to regulate  Infectious waste  as  a
 hazardous waste,  but  has not  yet
 promulgated  regulations.   The
 stale recommends  that Infectious
 hospital waste be Incinerated or
 otherwise treated before land
 disposal.

 The state has  statutory  authority
 to regulate  Infectious waste  as  a
 hazardous waste,  but  l-as not  yet
 promulgated  regulations.
                                                                                                             Bureau of Uaste Management
                                                                                                             Department of Environmental Resources
                                                                                                             Fulton Building. 8th Floor
                                                                                                             P.O. Bo« 2063
                                                                                                             Harrlsburg, Pennsylvania
                                                                                                             (717) 787-6239
                                                                                                     Bureau of Air Quality Control
                                                                                                     Department of Environmental Resources
                                                                                                     Fulton Building, 18th Floor
                                                                                                     P.O. Bo* 2061
                                                                                                     Harrlsburg. Pennsylvania   17120
                                                                                                     (717) 787-*32*
                                        Division of  Air  Hazardous Materials
                                        Department of  Environmental Management
                                        20*  Cannon Building
                                        75 Davis Street
                                        Providence.  Rhude Island  02903
                                        (401)  277-2797
                                                                                                              Bureau of Solid and Hazardous Uaste
                                                                                                              South Carolina Department of Health and
                                                                                                                Environmental Control
                                                                                                              2600 Bull Street
                                                                                                              Columbia, South CarolIna  29201
                                                                                                              (801) 75B-50B1
                                                                                                              Office of Air Quality and Solid Ua»le
                                                                                                              Department of Uater and Natural
                                                                                                                Resources
                                                                                                              Joe Fuss Building
                                                                                                              523 East Capitol AVUIIIIU
                                                                                                              Pierre. South Uakut..
                                                                                                              (605)  173 3153

-------
                                                           APPEIIU1X A  (CONTINUED)
State
Tennessee
Texas
 Utah
 Ve rmont
                           Statutory Authority and
                             Regulation Citation
Tennessee Hazardous Waste
Management Act of 1977. as amended.
Tennessee Solid Waste Disposal Act.
as amended.*
Tennes»ee Code Annotated,
6011-201 through 217 Minimum
Standards and Regulations for
Huspltals, 1974.*

Revised Civil Statutes of the
State of Texas Annotated, Article
4477-7 Texas Solid Waste Disposal
Act: and Article 4477-1, Texas
Sanitation and Health Protection
Law, as amended.  Texas
Administrative Code  325.136(b)(1),
Texas Department of  Health,
Municipal Solid Waste Management
Regulations, effective July  1483,
as amended.*

Utah Code Annotated. Title  2o,
Chapter  14, Utah  Solid and
Hazardous Waste Act, Effective
June,  1981.
 Vermont Statutes Annotated.
 Title 10,  Chapter 159.   Hazardous
 Waste Management Regulations.  a»
 amended September 13. 1984,
 Section o6(J2C2)(a).(l4) .
                      Code of Vn-ginia. Title 32.1.
                      Chapter t>. Article 3.  Virginij
                      Kegulal iuii:» Governing Disposal •
                      of  Solid Waste, April, 1971.
                                             Summary of Requirements
                                                                                                State Agency
The state is initiating rulemaklng
actlun.
All Infectious waste generated
by hospitals must be Incinerated
in closed  incinerators on
elevated platforms.

Infectious waste  is  regulated as  a
special waste.  Incineration Is  the
preferred method  of  treatment.
Untreated waste may  be double
bagged and disposed  of  In  a Type  I
municipal  landfill.
 The  stale  has  statutory authority
 to regulate Infectlous'waste as a
 hazardous  waste,  but has not yet
 promulgated regulations.
 Infectious waste Is regulated as a
 hazardous waste.
                                         Infectious wastes are. not  as
                                         regulated us hazardous wastes.
                                         W..:.ie generators must have special
                                         peimlssiuii to dispose of
                                         iu>iununici|>.il waste.   Kules do
                                         not piedudc  land disposal of
                                         untreated  intention's  waste.'
Division ot Solid Waste Management
Tennessee Department of Public Health
  and Environment
Customs House, 4th Floor
601 Broadway Street
Nashville. Tennessee   371M9-5403
(615) 741-3424

Hospital Licensing Boar.t
283 Plus Park
Nashville, Tennessee   37210
(615) 367-6200

Bureau of  Solid  Waste  Management
Texas Department of Health
1100 West  49th Street,  T601A
Austin. Texas 78756  -  3199
(512) 458-7271
 Bureau of Solid and Hazardous Waste
 Department of Health
 P.O.  Box 45500
 Salt  Lake City. Utah  84145-0501
 (801) 533-4145

 Hazardous and Solid Waste Management
   Division
 Department of Water Resources and
   Environmentjl Engineering
 Agency of Environmental Conservation
 State Office Building
 Montpelier. Vermont  u5bU2
 (802) 828-33M5

 Division ot Solid iiiJ Hazardous Wa^iu
   Management
 Department ui Health
 M.mrui- building.  Ilih Floor
 1U1 Ho rill  Ulh Si .-eel
 Kiclnii.JiiJ.  Viiciiiia  .'JL'I'J
 (tlU'i) i^5-L'ou/

-------
                                                                    APPENDIX A (CONTINUED)
         State
         Washington
         West Virginia
         Wisconsin
 I
h-
to
          Wyoming
                                    Statutory Authority and
                                      Regulation Citation
                                             Summary  of  Requirements
                                                                                               State Agency
Revised Code of Washington.
Hazardous Waste Disposal
Chapter 70.105.
Revised Code of Washington,
Hospital Licensing and Regulation
Statute, Chapter 70.41.
Washington Administrative Code.
248-180-170, Hospital Rules and
Regulations.

Code of West Virginia. Chapter 20,
Article SE. Effective July 7, 1981.
Wisconsin Statutes Annotated,
Chapter  144, a» amended.
                               Chapter NR  181, and guidance
                               summary 'Handling and Disposal
                               of  Pathological Waste.'
 No regulations pertaining  to
 Infectious waste, management.
The state has statutory authority
to regulate Infectious waste as a
hazardous waste,  but has not yet •
promulgated legulatlonst
Infectious waste generated by
hospitals oust be Incinerated or
disposed of by other approved
methods.  Approved methods Include
autoclavlng, retorting, or double
bagging before land disposal.

Infectious waste must be autoclaved
and/or-Incinerated before land
disposal.  Infectious waste
regulations are being revised.

The state has statutory authority
to regulate infectious.waste as a
hazardous waste, but has not yet
promulgated regulations.
                                        Policy  Is to recommended
                                        Incineration of Infectious waste.
                                        Infectious waste'which as been
                                        autoclaved or sterilized may be
                                        bagged  anil disposed of In an
                                        engineered landfill.
Hazardous Waste Section
Department of Ecology
Mall Stop PV-11
Olympla, Washington  98504-8711
(206) 459-6322

Department of Social and Health Services
Facility Licensing Certification Section
  of the Health Services Division
Mall Stop ET-31
Olympla, Washington
(206) 753-7039

State Health Department
1800 Washington Street. East
Charleston, West Virginia   25305
(304) 348-2970

Bureau  of Solid Waste Management
Department of Natural Resources
P.O. Bon  7921
Madison, Wisconsin   53707
(608) 266-2111
                                         Solid Waste Management Program
                                         State of Wyoming
                                         Department of Environmental Quality
                                         Herschler Building
                                         122 West 25th Street
                                         Cheyenne, Wyoming  82002
                                         (307) 777-7752

                                         Department of Health and Social Services
                                         Division of Health and Medical Services
                                         4th Floor Hathaway Building
                                         Cheyenne. Wyoming  84U02
                                         (307) 77V-7121
          'Denotes regulatlou> as of June. 1987.

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