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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


Company Overview


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.


Typical Process Flow Diagram for a High-

Temperature Rotary Kiln


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)


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.


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.


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


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


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.

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