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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