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Re: medical waste incinerator stack testing



  >Yes, there is a very good reason to
  >be suspicious of re-tests for medical
  >waste incinerators for metals.
  
  I would be suspicious (beyond my normal bounds of suspicion - which is
  constant) only if no reason was given, or there was a claim of "inconsistant
  performance" or a failure to pass compliance levels.  If they just said they
  were going to retest without explanation, it should send up a whole lot of
  red flags.  On the other hand, if they provide a logical, proven reason . .
  ..
  
  Of course, "In order to find the truth, at one point you must doubt
  everything."  On my office wall and I stare at it briefly everytime I start
  an audit.
  
  >Specifically,
  >mercury thermometers and other mercury-laden
  >devices and batteries can appear (or not appear)
  >in the waste stream at any time. If there is no
  >"scrubbing" equipment and no carbon or lime
  >injection into the stack (which can divert the
  >mercury into the ash instead of into the air)
  >then stack measurements of mercury would
  >sometimes be very high, other times relatively
  >low...
  
  While true to some extent, this is a medium-large system burning in excess
  of one ton per hour of waste (at least, given the description here).  For
  that one ton, you'll have at least 10+ hoppers of mixed waste trash enter
  the system - which is rarely sorted.  Given that a normal metals emission
  test lasts two hours, and you have to do three sampling periods per test
  series (six hours total), you tend to get a fairly decent portrait of what
  is going on.  You will have fluctuations, but that is normal.  If the
  control technology is a wet-basis (colder effluent stream) or specifically
  targets Hg, then the fluctuations are smoothed out considerably.
  
  HOWEVER, I have seen some systems try to force feed only their cardboard and
  non-redbag waste during a compliance test - which bias all the metals, HCl,
  and some organics low.  Just because they work at a hospital does not mean
  they always care . . . :<(    You'll always have a few idiots trying to scam
  by - and that is why we have a lot of these laws, audit procedures,
  observers, etc.
  
  Sam McClintock
  Director, En-Vision Inc.
  mac@ensanity.com