1    Basic Plant Design    An approved plant must have four distinct sections that demonstrate three principles of Turbulence, Residence Time and Temperature are inbuilt in the plant design .The regulated sections may include but not limited to:

Overall plant layout.
Feed chamber/ charging
Primary Combustion Chamber.
Secondary Combustion Chamber.
Particulate Scrubbers
Acid Gas Scrubbers
The stack/ chimney.
2    Feeding And Charging    Controlled hygienic, mechanical or automatic feeding methods have to be used which will not influence the air temperature in the primary and secondary chambers of the incinerator negatively.

No waste is to be fed into the incinerator:

1.    Until the minimum temperatures have been reached.
2.    If the minimum combustion temperatures are not maintained.
3.    Whenever the previous charge has not been completely combusted in the case of batch feeding.

4.    Until such time as the addition of more waste will not cause the design parameters of the incinerator to be exceeded.

3    Primary Combustion Chamber    The primary combustion chamber must:

1.    Be accepted as the primary combustion zone.
2.    Be equipped with a burner/s burning gas/fuel or low sulphur liquid fuels. Other combustion methods will be judged on merits.

3.    Ensure primary air supply is controlled efficiently
4.    Ensure minimum exit temperature is not less than 850oC

4    Secondary Combustion Chamber (Afterburner).    The secondary combustion chamber must:

1.    Be accepted as secondary combustion zone.
2.    Be fitted with secondary burner/s burning gas or low sulphur liquid fuel or any suitable fuel.

3.    Ensure secondary air supply is controlled efficiently.
4.    Ensure flame contact with all gases is achieved.
5.    Ensure residence time is not less than two (2) seconds.
6.    Ensure the gas temperature as measured against the inside wall in the secondary chamber & not in the flame zone, is not less than 1100oC.

7.    Ensure the oxygen content of the emitted gases is not less than 11%.
8.    Ensure both primary and the combustion temperatures are maintained until all waste has been completely combusted

5    Particulate Removers    A mechanical particulate collector must be incorporated after secondary combustion chamber for removal of particulate pollutants entrained in the flue gas stream. The particulate collectors may include any of the following or a combination thereof:

Cyclone separator
Electrostatic precipitators
Fabric filters
6    Chimney / Stack    1.    The chimney should have a minimum height of 10 meters above ground level and clear the highest point of the building by not less than 3 meters for all roofs. The topography and height of adjacent buildings within 50 meters radius should be taken into account.

2.    If possible the chimney should be visible to the operator from the feeding area.
3.    The addition of dilution air after combustion in order to achieve the requirement of these guidelines is unacceptable.

4.    The minimum exit velocity should be 10 m/s and at least twice the surrounding wind speed (Efflux velocity = wind speed x 2) whichever is higher to ensure no down washing of exiting gases.

5.    Point for the measurement of emissions shall be provided.

7    Instrumentation    Instrument for determining the inside wall temperature and not burner flame temperature must be provided for both primary and secondary chambers.

2.    An audible and visible alarm must be installed to warn the operator when the secondary temperature drops to below the required temperature.

3.    In addition to the above the following instruments may also be required.
A carbon monoxide and/or oxygen meter/recorder
A smoke density meter/recorder
A gas flow meter/recorder
A solid particulate meter/recorder
Any other instrument or measurement that may be considered necessary

8    Location / Siting    1.    Must be sited in accordance with the relevant local municipal authority planning scheme, the topography of the area and be compatible with premises in the neighborhood,

2.    Must be housed in a suitably ventilated room.

9    Emission Limits    1.    Combustion efficiency:

Combustion efficiency (CE) shall be at least 99.00%
The Combustion efficiency is computed as follows;

C.E=             % CO2           x 100
% CO2 + CO

2.    The temperature of the primary chamber shall be 800 ± 50o C

3.    The secondary chamber  gas residence time shall be at least 1 (one) second at 1050 ± 50o C, with 3% Oxygen in the stack gas.

4    Opacity of the smoke must not exceed 20% Viewed from 50 meters with naked eyes
5.    All the emission to the air other than steam or water vapour must be odourless and free from mist, fume and droplets.

6.    The Authority may require that the certificate holder have tests carried out by an accredited institution to determine stack and/or ground level concentrations of the following substances.

Cadmium and compounds as     Cd
Mercury                                      Hg
Thallium                                     Tl

Chromium                                  Cr
Beryllium                                    Be
Arsenic                                       As
Antimony                                    Sb
Barium                                        Ba
Lead                                            Pb
Silver                                          Ag
Cobalt                                         Co
Copper                                        Cu
Manganese                                  Mn
Tin                                               Sn
Vanadium                                     V
Nickel                                           Ni
Hydrochloric                                HCL
Hydrofluoric acid                         HF
Sulphur dioxide                           S02

7.    A 99.99% destruction and removal efficiency (DRE) for each principal organic hazardous constituent (POHC) in the waste feed where:

DRE = [(Win – Wout)/Win]*100
Where: Win = mass feed rate of the POHC in the waste stream fed to incinerator, and
Wout = mass emission rate of POHC in the stack prior to the release to the atmosphere.

8.    The average dioxin and furan concentration in the emissions should not exceed 80ng/m3 total dioxins and furans if measured for a period of 6 to 16 hours.

Note:
All pollutant concentrations must be expressed at Oo C and 1.013 x 10 5 N/m2, dry gas and 11% oxygen correction.

Oxygen correction is computed as:

Es =     21 – Os    x EM
21 – OM

Where:    Es    = Calculated emission concentration at the standard percentage oxygen concentration
EM    = Measured emission concentration
Os    = Standard oxygen concentration
OM    = measured oxygen concentration

10    Operation    1.    Materials destined for incineration should be of known origin and composition and must be only incinerated in a furnace that is registered for the particular type of waste.

2.    A record must be kept of the quantity, type and origin of the waste to be incinerated.
3.    The incinerator must be preheated to working temperature before charging any waste.
4.    The incinerator must not be overcharged.
5.    The incinerator must be in good working order at all times and must not be used if any component fails. Any malfunction should be recorded in a log book and reported to the relevant authority.

6.    The incinerator operator and all relevant staff must be trained to the satisfaction of the relevant control authority.

11    Housekeeping    The site where the incinerator is built must:

1.    Have running water.
2.    Have a solid floor.
3.     Have lighting if 24hrs operation
4.    Have fly ash containerization and storage before disposal.

12    Health & Safety (Protective Gear)    1.    Staff handling waste must be well trained on safe handling of hazardous wastes
2.     Staff must be provided with appropriate  protective gear such as, gas mask, aprons, gumboots, helmets, gloves, goggles.

3.     Caution and Warning signs must be provided.
4.     Fire fighting equipment must be provided
5.     There should be no smoking or eating on the site.

The medical waste incineration industry was given birth to in the late 1980s by the confluence of two high profile media circuses: one – the HIV hysteria – and two – multiple media accounts of bags of syringes, needles, plasma bags, IV tubing, bottles of pills and even body parts washing up on the shores of some of the most popular resort beaches on the East Coast stretching from Maine to Florida. In 1987, in Indianapolis, Indiana, 12 children were found playing with HIV-infected vials of blood that came from an unsecured dumpster used by a medical clinic.

In a classic case of the cure being worse than the disease, the knee-jerk response was a widespread call to burn hospital waste so that the various avenues of incompetence, corruption and profiteering that led to dirty needles washing up on exclusive beaches could be closed down through a back door. Little thought was applied to the consequences of incineration, until plumes of black clouds began billowing from hospital complexes. Neighbors complained, air pollution research showed that those emissions were indeed dangerous and the Environmental Protection Agency (EPA) became involved.

Eventually the number of incinerators contracted dramatically, but in part because “centralized” incinerators became an easy solution. Hospitals washed their hands of the matter by allowing their waste to be burned in someone else’s backyard.

As a result, Stericycle, headquartered in Lake Forest, Illinois, became the king of the medical waste incineration industry, operating six large incinerators throughout the country, including one of the largest medical incinerators west of the Mississippi in the heart of the most heavily populated part of Utah, the North Salt Lake subdivision of Foxboro, a few miles from my house. Stericycle now receives the medical waste of eight surrounding states there.

The relationship between Stericycle and Foxboro has always been tense. Efforts to shutter Stericycle were launched as long as 10 years ago by a handful of citizens concerned about the toxic brew that billows out of Stericycle’s short smokestack. It’s no surprise that burning medical waste, just like burning fossil fuels or just about anything else, creates a pollution potpourri of hazardous chemicals and gases, heavy metals and particulate matter.

Indeed, citizens’ concerns are validated by hundreds of studies showing multiple adverse health outcomes among people exposed, including higher rates of cancers like childhood leukemia and adverse pregnancy outcomes that I have written about in a previous essay.

The repercussions of the toxic incinerator emissions are made even more disturbing when adding the realization that the medical waste incineration industry was born on a false premise – that hospital pathogens must be incinerated. An EPA report dating back 25 years cites numerous studies showing hospital waste presents no more risk of spreading infection than household waste – which harbors virtually all the same viruses and bacteria. In fact, according to the Society for Hospital Epidemiology of America, “Household waste contains more microorganisms with pathogenic potential for humans on average than medical waste.” So why single out medical waste? Scalpels and needles can be shredded without incineration.

Many of the toxic chemicals and heavy metals in hospital waste are not destroyed by incineration. In fact, burning medical waste is the worst possible way to manage it.

While merely landfilling is a less than perfect solution, the possibility of contamination of usable groundwater is theoretical, not a certainty. Whereas with incineration, the emissions enter the air shed we all breathe from, guaranteeing public exposure, especially for those closest to the incinerator. The ash left over from incineration may be a smaller volume than the original waste, but it is much more toxic, and eventually has to be landfilled anyway.

Incineration does not prevent disease; it actually spreads disease. Incineration not only does not remove toxins; it actually creates new ones and concentrates, mobilizes and redistributes existing ones. Emissions from incinerators are probably the most toxic type of air pollution there is, contaminated with the deadliest compounds known to science, designated by the EPA as “HAPs” (hazardous air pollutants), which includes dioxins, benzene, PAHs (polycyclic aromatic hydrocarbons), furans, heavy metals and radioactive elements. Medical incinerators have even more deadly compounds not found in any other source, like residuals from chemotherapy drugs and even prions, the highly infective proteins that cause the 100 percent fatal human “Mad Cow” disease (which are much more common in human tissue than previously realized, and not reliably deactivated by incineration).

State health departments and environmental agencies are fond of claiming that toxicology assessments of the concentrations of many of these toxins are small enough to be written off as “safe.” The Utah State Health Department measured dioxin levels in the soil around Stericycle and declared the levels to be below any threshold of concern. If the devil is often in the details, in this case, the devil lies in the ignorance of the details.

Those toxicology assessments ignore the biologic complexity of the exposure. Many of these toxins are bioaccumulative, meaning they build up in the human body insidiously over time, and in even higher concentrations in certain critical organs and tissues.

Lipophilic (fat-like) toxins like dioxins highly concentrate in human breast milk. Nursing infants consume 10 to 20 times as much dioxin as the average adult. No toxicology assessments are ever based on the amount of dioxins in the human breast milk of people who live near incinerators, yet that undoubtedly is where dioxins wreak their greatest havoc on public health. Nor do those assessments consider the consequences of lipophilic toxins crossing the placenta that will primarily end up in the developing fetal brain because fat comprises about 60 percent of brain structural matter, and is the primary fat reservoir in the fetus.
Recently a new documentary was released that significantly raises the stakes in the long and sorry saga of this dying industry whose flagship corporate villain is Stericycle. The film features an undercover interview with an anonymous former Stericycle employee giving a credible, extraordinarily detailed account of fraudulent, illegal management practices far beyond what prompted the criminal investigation by state and federal law enforcement. The whistle-blower alleges shocking disregard for public and employee safety by Stericycle management – including directing employees to ignore the Geiger counter giving radioactive readings of the waste and to burn it anyway. Furthermore, he stated, the Geiger counter didn’t work much of the time.

While radioactivity is an inherent part of hospital waste, one of the few appropriate provisions in Stericycle’s permit is a prohibition of burning anything radioactive, and with good reason. No amount of radiation exposure is safe. Quoting from an article in the New England Journal of Medicine, “Mutagenic effects theoretically can result from a single molecular DNA alteration . . . every molecule of a carcinogen is presumed to pose a risk.”
In fact, the medical community is now much more cautious about the radioactive burden of many of our common diagnostic tools, like CAT scans, because of this growing recognition. Even low dose radiation exposure can damage chromosomes, alter gene expression and lead to cancer, brain diseases, immune disorders, birth defects and miscarriages – all of which North Salt Lake residents believe they have experienced in excess in their neighborhoods.

The ex-employee described management deliberately rigging the company scales and ignoring their permitted weight limit, a likely reason the state caught them exceeding their dioxin limit by 400 percent. Add to this the revelation that Erin Brockovich’s investigative team found dioxin concentrations in Foxboro homes to be inversely proportional to the distance from the incinerator. The home closest to Stericycle had 17 times the level of dioxins in its attic that would be considered average for an industrial area.
Incineration is widely recognized by international health organizations as an unnecessary, dangerous means of handling waste. Over 98 percent of medical incinerators have closed in the last 15 years – leaving a handful of communities like Foxboro to take most of the “hits for the team.” Utah’s governor, Gary Herbert, could close Stericycle on the basis of necessary public health protection, but he is loath to do so because he functions under the fog of the conservative mindset, that protection of business inherently has priority.

The whole medical incineration industry was a huge mistake right from the start, but Stericycle seems to have achieved immortality simply because someone is making money from it. The gnawing outrage of Stericycle is just a microcosm of the endemic failure of countless public policies held hostage to capitalism. Science, common sense, proportion, justice and human decency get thrown under the bus initially by fear and ignorance, and held there in perpetuity by ideology, exploitation and greed. We watch the same play over and over again with a different cast, be it gun control, the wealth gap, ISIS, our war addiction, GMO labeling, chemical and pesticide dysregulation, factory farming – and of course, the climate crisis. It makes me wonder whether we are not already living on the planet of the apes.