What is a medical waste incinerator?
Medical waste incineration burns wastes produced by hospitals, veterinary facilities, and medical research facilities. These wastes include both infectious (red bag) medical wastes as well as non-infectious, non-hazardous wastes. Infectious waste contains pathogens that could lead to an infectious disease in individuals exposed to the waste. Incineration sterilizes medical waste and reduces its volume by up to 90 percent.
What kind of medical waste can Stericycle accept?
Stericycle has permits to treat non hazardous medical waste and other non-medical wastes. These include:
- Non-hazardous medical waste, including laboratory waste, glassware, and sharps.
- Surgical specimens and tissues, animal tissues and carcasses, blood, and body fluids.
- Infectious wastes from veterinaries, mortuaries, research, and industry.
- Expired and unused pharmaceuticals and contraband.
- Outdated consumer commodities, proprietary packaging, and records.
- Recalled medical equipment and supplies.
- Agriculture (APHIS) waste and municipal solid waste contaminated with infectious waste.
- Other non hazardous waste approved by the Director that is appropriate for a medical waste incinerator.
Stericycle cannot treat:
- Hazardous waste
- Municipal waste
- Radioactive waste
- PCB waste
How does the Division of Air Quality determine Stericycle’s emission limits?
The Utah State Plan (306 KB) establishes emission limits for Hospital Medical Infectious Waste Incinerators (HMIWI). The Plan lists emission limits in Tables 4A and 4B (pp. 19-22).
The Plan includes compliance, performance testing, and monitoring requirements to ensure HMIWIs meet these limits. It sets maximum and minimum operating parameters and minimum frequency for data measurement and data recording. Stericycle is required to use EPA Reference Methods for its emissions testing.
How does DAQ monitor Stericycle’s emissions?
DAQ uses stack tests to help determine Stericycle’s compliance with emission limits and the effectiveness of the facility’s capture and control technologies. At present, Stericycle must perform stack tests:
- Annually for hydrochloric acid.
- Every three years for particulate matter and carbon monoxide.
- Every five years for dioxin/furan, sulfur dioxide, nitrogen oxides, lead, cadmium, and mercury.
The operating parameters recorded during these tests become the required continuous operating parameters for the facility. This ensures continuous compliance with the emission limits for these pollutants.
Stericycle is required to continuously monitor and record these operating parameters. DAQ verifies this continuous monitoring during regular inspections and also checks equipment to make sure it is calibrated and accurate. The Division makes unannounced compliance inspections each year, as well as onsite audits of Stericycle stack tests.
Stericycle must submit deviation reports to DAQ when it goes outside any of these operating parameters. They are also required to submit six-month monitoring reports and annual compliance certifications.
What is an emergency bypass?
An emergency bypass diverts emissions to a relief stack whenever there is an equipment malfunction or power outage and waste is burning in the incinerator. Incinerators of all types use bypass stacks to protect the incinerator and its air pollution control equipment from damage. The emergency bypass cuts off the waste feed until operations return to normal.
When the bypass stack is open and the incinerator is running, Stericycle vents emissions directly into the atmosphere, bypassing some of the air pollution control equipment. A bypass does not necessarily result in exceedances because emissions still pass through the incinerator’s secondary combustion chamber, which controls some, but not all, of the emissions.
The bypass stack can be open for several reasons:
- Startup of the incinerator prior to charging with waste.
- Shutdown of the incinerator after all waste has been burned out of the incinerator.
- Sudden malfunctions which result in immediate shutdown of the incinerator when waste is burning in the incinerator.
- During periods of maintenance when the incinerator is not operating.
Stericycle must monitor and report all emergency bypasses due to malfunction or power outage in their six-month monitoring reports. Emissions from these bypass events are exempt from the emission limits, provided Stericycle fed no additional waste into the incinerator after the bypass stack opened. These bypass events usually last 5-10 minutes. Stericycle typically reports 6-10 bypasses due to malfunction or power outage each year.
Are these bypass emissions cause for concern?
Pollutant levels during bypass events are extremely low due to the short-term nature of bypass events and the low overall emission rates from the incineration process.
Do Stericycle’s emission limits protect the public health?
The standards and guidelines in the Utah Plan for HMIWIs regulate emissions of pollutants considered carcinogenic or capable of causing toxic effects (128 KB) following exposure at sufficient concentrations. Stericycle’s emission limits are equivalent to Maximum Achievable Control Technology (MACT) standards.
While there are no federal MACT standards that apply to Stericycle, federal New Source Performance Standard (NSPS) limits are equivalent to MACT standards and apply to Stericycle’s operations. The Utah State Plan (128 KB) contains these federal emission limits. EPA and DAQ emission limits and source performance standards for medical waste incinerators are technology based, not health-based.
Governor Gary Herbert recently directed the Utah Department of Health to undertake a three-tiered study on the potential health impacts from Stericycle. This study will include an examination of possible health effects of dioxin and furan releases from the facility along with analyses of soil samples from the surrounding area.
Are there safer technologies for the treatment of medical wastes than incineration?
According to the EPA, there is no known safe alternative to incineration, including autoclaving, for red bag medical waste. Autoclaving is not suitable for treating pathological tissue, chemotherapy waste, and sharps. In addition, the State does not have the legal authority to dictate technology to an existing source unless federal standards require it.
What permits does Stericycle hold?
Stericycle has a Solid Waste Permit (10 MB) from the Division of Waste Management and Radiation Control and a Title V Operating Permit from the Division of Air Quality. Although Stericycle is a minor source of air pollution, it is required to have a Title V Operating Permit under Clean Air Act requirements for Hospital Medical Infectious Waste (HMIW) incinerators.