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 Technology Creating a Better Environment 1 April 13, 2015 - Clean Harbors Company Confidential Company Overview 2 April 13, 2015 - Clean Harbors Company Confidential Rotary Kiln Incineration Technology 3 • 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. April 13, 2015 - Clean Harbors Company Confidential Typical Process Flow Diagram for a HighTemperature Rotary Kiln 4 April 13, 2015 - Clean Harbors Company Confidential 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) 5 April 13, 2015 - 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. 6 April 13, 2015 - Clean Harbors Company Confidential Advantages of Rotary Kiln Incineration Technology versus Stepped-Hearth Technology 7 • 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. April 13, 2015 - Clean Harbors Company Confidential Comparison of Emission Standards Emission Standard Dioxin/Furan Large Existing Municipal Waste Combustors1 (2006) 0.5-1.0 (ng/dscm TEQ) PM HW Incinerators Phase II2 (2005) 0.20 or 0.40 plus off-gas CO; or quench to 400F (ppmv) 25 34 (mg/dscm) Hg (ug/dscm) Semi-Volatile Metals cadmium and lead Emission Standard THC Large Existing Municipal Waste Combustors1 (2006) HW Incinerators Phase II2 (2005) 50 - 250 100 none 10 10 Facility-specific based on air permit. Generally 10 165 - 230 Facility-specific based on air permit 31 Facility-specific based on air permit none 99.99% (ppmv) 50; or 85% reduction of emissions 130 435 230 Opacity (pct) NOx (ppmv) (ug/dscm) Low Volatility Metals antimony, arsenic, beryllium, and chromium none 92 SO2 (ppmv) (ug/dscm) HCl and Cl2 (ppmv) 29; or 95% reduction of emissions 1) Source: Federal Register 05/10/2006 2) Source: Federal Register 10/12/2005 8 April 13, 2015 - Clean Harbors Company Confidential 32 Destruction/Removal Efficiency Clean Air Act MACT Performance Test Burn Results MACT Parameter Dioxin/Furan Units ng TEQ/dscm corrected to 7% O2 Mercury ug/dscm corrected to 7% O2 Lead and Cadmium (SVM) ug/dscm corrected to 7% O2 Arsenic, Beryllium, Chromium ug/dscm (LVM) corrected to 7% O2 CO; or ppmv, dry basis, corrected to 7% O2 Phase II Standard (effective 10/12/2008) 0.20 or 0.40 0.20 or 0.40 provided that the provided that the combustion gas combustion gas temperature at the temperature at the inlet to the initial inlet to the initial pm pm control device control device is 400 is 400 degF or degF or lower. lower. 130 130 AG DE EL KP 0.0042/0.0026 for conditions 1 and 2 during last CPT 0.0024 0.084 Train I <0.026 Train II <0.007 6.8 59.4 127.2 8.1/<31.9 56.97 240 230 0.84 148.4 31.1 23/<29.0 2.2 97 92 <2.05 9.2 2.1 10/<35.4 1.83 100 100 4.93 <1.3 <0.56 32.7/3.4 NA ppmv, dry basis, corrected to 7% O2 10 10 0.2 0.9 <0.29 1.8/0.6 2.37 Hydrochloric Acid and Chlorine ppmv, dry basis, corrected to 7% O2 77 32 2.2 0.5 0.4 21/<16.9 19.8 0.015 0.013 (34 mg/dscm) 0.0017 (3.85 mg/dscm) 0.001 0.0005 0.0013 3.51 mg/dscm 99.99% 99.99% 100% >99.99% >99.99% THC Particulate Matter DRE 9 Current Standard gr/dscf, corrected to 7% O2 April 13, 2015 - Clean Harbors Company Confidential >99.9999% >99.99998% Conclusions • Both Stepped Hearth and Rotary Kiln Incineration Technologies have a role in managing solid waste. • Rotary Kiln Technology offers superior DRE and “ThreeT’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. 10 April 13, 2015 - Clean Harbors Company Confidential