1 April 21, 2023 - Clean Harbors Company Confidential
A Brief Primer on the Value of Rotary Kiln Incineration Technology relating to Pharmaceutical Waste Destruction
Presented to:
PSI Seminar Series on Pharmaceutical Waste Management
People and TechnologyCreating a Better Environment
2 April 21, 2023 - Clean Harbors Company Confidential
Company Overview
3 April 21, 2023 - Clean Harbors Company Confidential
Rotary Kiln Incineration Technology
• Rotary Kiln Incineration Technology has been in commercial operation since the 1960’s especially in Europe.
• The USEPA adopted Rotary Kiln Technology as the Official Treatment Technology for Organic Hazardous Wastes and for PCBs under the Resource Conservation and Recovery Act “RCRA” in 1980 and the Toxic Substances Control Act “TSCA” in 1978, respectively.
• There are currently 10 commercial rotary kiln Incinerators operating in the United States today with a total aggregate annual treatment capacity of approximately 650,000 tons.
4 April 21, 2023 - Clean Harbors Company Confidential
Typical Process Flow Diagram for a High-
Temperature Rotary Kiln
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Incineration Operating Parameters Guaranteeing Proper Destruction of Organic Wastes
• Time, Temperature and Turbulence “The Three T’s” serve as effective indicators of efficient and compliant incinerator performance.
• Rotary Kiln Incinerators offer superior conformance with the Three T’s by virtue of the Kiln design which typically employs:• counter-current air flow coupled with high operating
temperatures ( in the range of 1800 to 2000 Degrees F)• long waste residence time in the rotating kiln• Excellent waste tumbling/mixing and turbulence
generated by the rotating kiln and low-NOx combustion burner employing turbulence enhancement nozzles.
• Addition of a Secondary Combustion Chamber to enhance organics destruction (Operating Temperature typically 1850 to 2000 Degrees F)
6 April 21, 2023 - Clean Harbors Company Confidential
Incineration Operating Parameters Guaranteeing Proper Destruction of Organic Wastes
• All Commercial High Temperature Incinerators are required to conduct periodic stack tests to assure compliance with Federal CAA MACT Standards.
• The Stack Tests confirm:
– Destruction/ Removal Efficiency “DRE” typically portrayed as 99.99 or 99.9999%
– Conformance with CAA MACT Emission Standards for heavy metals, CO, THC, Particulate Removal and Dioxin Formation and Control
– Data from Stack Tests inputted into Statistical Risk Models to assure compliance with cancer and non-cancer risk avoidance levels – typically less than 1 in 100,000 risk of cancer to humans from rotary kiln incinerator emissions.
7 April 21, 2023 - Clean Harbors Company Confidential
Advantages of Rotary Kiln Incineration Technology versus
Stepped-Hearth Technology
• The USEPA selected Rotary Kiln Technology as the standard for destruction of solid organic hazardous and toxic wastes under RCRA and TSCA.
• USEPA’s Clean Air Act MACT Standards for Commercial and Captive Hazardous Waste Incinerators recognize Rotary Kiln Technology as the Best Performing Incineration Technology for the destruction of solid, organic hazardous and toxic waste.
• There are no commercial hazardous waste incinerators of the hearth design operating in North America today.
8 April 21, 2023 - Clean Harbors Company Confidential
Comparison of Emission Standards
Emission Standard Large Existing
Municipal Waste Combustors1
(2006)
HW Incinerators Phase I I 2 (2005)
Emission Standard Large Existing Municipal Waste
Combustors1 (2006)
HW Incinerators Phase I I 2 (2005)
Dioxin/Furan (ng/dscm TEQ)
0.5-1.0 0.20 or 0.40 plus off-gas quench to 400F
CO; or (ppmv)
50 - 250 100
PM (mg/dscm)
25 34 THC
(ppmv)
none 10
Hg (ug/dscm)
50; or
85% reduction of emissions
130 Opacity (pct)
10 Facility-specific based on air permit. Generally
10
Semi-Volatile Metals cadmium and lead (ug/dscm)
435
230 NOx (ppmv)
165 - 230 Facility-specific based on air permit
Low Volatility Metals antimony, arsenic, beryllium, and chromium (ug/dscm)
none 92 SO2 (ppmv)
31 Facility-specific based on air permit
HCl and Cl2 (ppmv)
29; or
95% reduction of emissions
32 Destruction/Removal Efficiency
none 99.99%
1) Source: Federal Register 05/10/2006 2) Source: Federal Register 10/12/2005
9 April 21, 2023 - Clean Harbors Company Confidential
Clean Air Act MACT Performance Test Burn
Results
MACT Parameter Units Current Standard Phase II Standard (effective
10/12/2008)
AG EL KP
Train I Train IIDioxin/Furan ng TEQ/dscm
corrected to 7% O2
0.20 or 0.40 provided that the combustion gas
temperature at the inlet to the initial
pm control device is 400 degF or
lower.
0.20 or 0.40 provided that the combustion gas
temperature at the inlet to the initial pm control device is 400
degF or lower.
0.084 <0.026 <0.007 0.0042/0.0026 for conditions 1 and 2 during
last CPT
0.0024
Mercury ug/dscm corrected to 7% O2
130 130 6.8 59.4 127.2 8.1/<31.9 56.97
Lead and Cadmium (SVM) ug/dscm corrected to 7% O2
240 230 0.84 148.4 31.1 23/<29.0 2.2
Arsenic, Beryllium, Chromium (LVM)ug/dscm corrected to 7% O2
97 92 <2.05 9.2 2.1 10/<35.4 1.83
CO; or ppmv, dry basis, corrected to 7% O2
100 100 4.93 <1.3 <0.56 32.7/3.4 NA
THC ppmv, dry basis, corrected to 7% O2
10 10 0.2 0.9 <0.29 1.8/0.6 2.37
Hydrochloric Acid and Chlorineppmv, dry basis, corrected to 7% O2
77 32 2.2 0.5 0.4 21/<16.9 19.8
Particulate Matter gr/dscf, corrected to 7% O2
0.015 0.013 (34 mg/dscm) 0.0017 (3.85 mg/dscm)
0.001 0.0005 0.0013 3.51 mg/dscm
DRE 99.99% 99.99% 100% >99.9999% >99.99998% >99.99% >99.99%
DE
10 April 21, 2023 - Clean Harbors Company Confidential
Conclusions
• Both Stepped Hearth and Rotary Kiln Incineration Technologies have a role in managing solid waste.
• Rotary Kiln Technology offers superior DRE and “Three-T’s” Combustion Management especially for refractory organic compounds that are hard to destroy.
• Rotary Kiln Incinerators meet stringent USEPA, EC and WHO emissions standards and these Standards will become more stringent as the USEPA evaluates existing MACT emissions limits.
• Our industry believes that Pharmaceutical Waste Generators will find Rotary Kiln Incineration Technology, which is the USEPA Standard for the Destruction of Organic Hazardous and Toxic substances, to be the destruction technology of choice for expired and discarded pharmaceutical waste.