Medical Waste Combustor Rule

[DrBillC@aol.com]

Mike:

How large a source of dioxin medical waste combustors are is an issue that is
up for grabs right now.  In the EPA dioxin reassessment, the Agency estimated
generation of about 5100 grams/yr, TEQ bsed on a very limited sample of
combustors.  On the other hand, the American Hospital Association in its
comments estimated that it was closer to 150 grams.  Data gathering goes on,
but that discrepancy and others led EPA, the AHA and I believe NRDC to ask
the courts to agree to postpone the mandated date for issuing medical waste
combustor regs by one year.  “Newt and his Congress” are not the issue.

One of the major issues will be a “small combustor exemption.”  Many, if not
most of the really large capacity devices are equipped with modern control
technology, where it is most cost effective.

Yet, it is design and control technology that is the most critical variable
involved in reducing dioxin generation, not “the plastic being burned.”  Even
if you remove all the plastic from the feed to med waste combustors you are
still left with as much chlorine in the waste as you have normally in
municipal solid waste combustion.  The source of that chlorine is salt from
biological waste or hospital solutions.

As you’ve seen discussed at this list, there are alternatives to combustion
for treatment of hospital waste.  Just like combustion, they all have
strengths and weaknesses, and I would urge you to investigate them.  I’d
start with EPA in the Air Office to follow the progress of the reg.
 Technical work is being done at Research Triangle Park.

Bill Carroll
Chlorine Chemistry Council