2.3 Medical Waste Incineration: (Reformatted 1/95)
2.3 Medical Waste Incineration: (Reformatted 1/95)
Medical waste incineration involves the burning of wastes produced by hospitals, veterinary
facilities, and medical research facilities. These wastes include both infectious ("red bag") medical
wastes as well as non-infectious, general housekeeping wastes. The emission factors presented here
represent emissions when both types of these wastes are combusted rather than just infectious wastes.
Three main types of incinerators are used: controlled air, excess air, and rotary kiln. Of the
incinerators identified in this study, the majority (>95 percent) are controlled air units. A small
percentage (<2 percent) are excess air. Less than 1 percent were identified as rotary kiln. The rotary
kiln units tend to be larger, and typically are equipped with air pollution control devices. Approximately
2 percent of the total population identified in this study were found to be equipped with air pollution
control devices.
- Controlled air,
- Rotary kiln.
Combustion of waste in controlled air incinerators occurs in two stages. In the first stage, waste
is fed into the primary, or lower, combustion chamber, which is operated with less than the stoichiometric
amount of air required for combustion. Combustion air enters the primary chamber from beneath the
incinerator hearth (below the burning bed of waste). This air is called primary or underfire air. In the
primary (starved-air) chamber, the low air-to-fuel ratio dries and facilitates volatilization of the waste, and
most of the residual carbon in the ash burns. At these conditions, combustion gas temperatures are
relatively low (760 to 980C [1,400 to 1,800F]).
In the second stage, excess air is added to the volatile gases formed in the primary chamber to
complete combustion. Secondary chamber temperatures are higher than primary chamber temperatures--
typically 980 to 1,095C (1,800 to 2,000F). Depending on the heating value and moisture content of
the waste, additional heat may be needed. This can be provided by auxiliary burners located at the
entrance to the secondary (upper) chamber to maintain desired temperatures.
Waste feed capacities for controlled air incinerators range from about 0.6 to 50 kg/min (75 to
6,500 lb/hr) (at an assumed fuel heating value of 19,700 kJ/kg [8,500 Btu/lb]). Waste feed and ash
removal can be manual or automatic, depending on the unit size and options purchased. Throughput
capacities for lower heating value wastes may be higher, since feed capacities are limited by primary
Air Air
Excess Air
Condition
Starved-Air
Condition in Lower
Lower Chamber
Chamber
Controlled
Waste
Underfire Air
Feed
for Burning
Down Waste
chamber heat release rates. Heat release rates for controlled air incinerators typically range from about
430,000 to 710,000 kJ/hr-m3 (15,000 to 25,000 Btu/hr-ft3).
Because of the low air addition rates in the primary chamber, and corresponding low flue gas
velocities (and turbulence), the amount of solids entrained in the gases leaving the primary chamber is
low. Therefore, the majority of controlled air incinerators do not have add-on gas cleaning devices.
Figure 2.3-2 presents a schematic for an excess air unit. Typically, waste is manually fed into the
combustion chamber. The charging door is then closed, and an afterburner is ignited to bring the
secondary chamber to a target temperature (typically 870 to 980°C [1600 to 1800°F]). When the target
temperature is reached, the primary chamber burner ignites. The waste is dried, ignited, and combusted by
heat provided by the primary chamber burner, as well as by radiant heat from the chamber walls.
Moisture and volatile components in the waste are vaporized, and pass (along with combustion gases) out
of the primary chamber and through a flame port which connects the primary chamber to the secondary or
mixing chamber. Secondary air is added through the flame port and is mixed with the volatile
components in the secondary chamber. Burners are also installed in the secondary chamber to maintain
adequate temperatures for combustion of volatile gases. Gases exiting the secondary chamber are
directed to the incinerator stack or to an air pollution control device. When the waste is consumed, the
primary burner shuts off. Typically, the afterburner shuts off after a set time. Once the chamber cools,
ash is manually removed from the primary chamber floor and a new charge of waste can be added.
Incinerators designed to burn general hospital waste operate at excess air levels of up to
300 percent. If only pathological wastes are combusted, excess air levels near 100 percent are more
common. The lower excess air helps maintain higher chamber temperature when burning high- moisture
waste. Waste feed capacities for excess air incinerators are usually 3.8 kg/min (500 lb/hr) or less.
Volatiles and combustion gases pass from the primary chamber to the secondary chamber. The
secondary chamber operates at excess air. Combustion of the volatiles is completed in the secondary
chamber. Due to the turbulent motion of the waste in the primary chamber, solids burnout rates and
particulate entrainment in the flue gas are higher for rotary kiln incinerators than for other incinerator
designs. As a result, rotary kiln incinerators generally have add-on gas cleaning devices.
Auxiliary
Fuel
Ash
Removal
Medical waste incinerators can emit significant quantities of pollutants to the atmosphere. These
pollutants include: (1) particulate matter (PM), (2) metals, (3) acid gases, (4) oxides of nitrogen (NOx),
(5) carbon monoxide (CO), (6) organics, and (7) various other materials present in medical wastes, such
as pathogens, cytotoxins, and radioactive diagnostic materials.
Particulate matter is emitted as a result of incomplete combustion of organics (i. e., soot) and by
the entrainment of noncombustible ash due to the turbulent movement of combustion gases. Particulate
matter may exit as a solid or an aerosol, and may contain heavy metals, acids, and/or trace organics.
Uncontrolled particulate emission rates vary widely, depending on the type of incinerator,
composition of the waste, and the operating practices employed. Entrainment of PM in the incinerator
exhaust is primarily a function of the gas velocity within the combustion chamber containing the solid
waste. Controlled air incinerators have the lowest turbulence and, consequently, the lowest PM
emissions; rotary kiln incinerators have highly turbulent combustion, and thus have the highest PM
emissions.
The type and amount of trace metals in the flue gas are directly related to the metals contained in
the waste. Metal emissions are affected by the level of PM control and the flue gas temperature. Most
metals (except mercury) exhibit fine-particle enrichment and are removed by maximizing small particle
collection. Mercury, due to its high vapor pressure, does not show significant particle enrichment, and
removal is not a function of small particle collection in gas streams at temperatures greater than 150C
(300F).
Acid gas concentrations of hydrogen chloride (HCl) and sulfur dioxide (SO2) in MWI flue gases
are directly related to the chlorine and sulfur content of the waste. Most of the chlorine, which is
chemically bound within the waste in the form of polyvinyl chloride (PVC) and other chlorinated
compounds, will be converted to HCl. Sulfur is also chemically bound within the materials making up
medical waste and is oxidized during combustion to form SO2.
Oxides of nitrogen (NOx) represent a mixture of mainly nitric oxide (NO) and nitrogen dioxide
(NO2). They are formed during combustion by: (1) oxidation of nitrogen chemically bound in the
waste, and (2) reaction between molecular nitrogen and oxygen in the combustion air. The formation of
NOx is dependent on the quantity of fuel-bound nitrogen compounds, flame temperature, and air/fuel
ratio.
Failure to achieve complete combustion of organic materials evolved from the waste can result in
emissions of a variety of organic compounds. The products of incomplete combustion (PICs) range from
low molecular weight hydrocarbon (e. g., methane or ethane) to high molecular weight compounds (e. g.,
polychlorinated dibenzo-p-dioxins and dibenzofurans [CDD/CDF]). In general, combustion conditions
required for control of CO (i. e., adequate oxygen, temperature, residence time, and turbulence) will also
minimize emissions of most organics.
Emissions of CDDs/CDFs from MWIs may occur as either a vapor or as a fine particulate.
Many factors are believed to be involved in the formation of CDDs/CDFs and many theories exist
concerning the formation of these compounds. In brief, the best supported theories involve four
mechanisms of formation.2 The first theory states that trace quantities of CDDs/CDFs present in the
2.3-6 EMISSION FACTORS (Reformatted 1/95) 7/93
refuse feed are carried over, unburned, to the exhaust. The second theory involves formation of
CDDs/CDFs from chlorinated precursors with similar structures. Conversion of precursor material to
CDDs/CDFs can potentially occur either in the combustor at relatively high temperatures or at lower
temperatures such as are present in wet scrubbing systems. The third theory involves synthesis of
CDDs/CDFs compounds from a variety of organics and a chlorine donor. The fourth mechanism
involves catalyzed reactions on fly ash particles at low temperatures.
To date, most MWIs have operated without add-on air pollution control devices (APCDs). A
small percentage (approximately 2 percent) of MWIs do use APCDs. The most frequently used control
devices are wet scrubbers and fabric filters (FFs). Fabric filters provide mainly PM control. Other PM
control technologies include venturi scrubbers and electrostatic precipitators (ESPs). In addition to wet
scrubbing, dry sorbent injection (DSI) and spray dryer (SD) absorbers have also been used for acid gas
control.
Wet scrubbers use gas-liquid absorption to transfer pollutants from a gas to a liquid stream.
Scrubber design and the type of liquid solution used largely determine contaminant removal efficiencies.
With plain water, removal efficiencies for acid gases could be as high as 70 percent for HCl and
30 percent for SO2. Addition of an alkaline reagent to the scrubber liquor for acid neutralization has
been shown to result in removal efficiencies of 93 to 96 percent.
Wet scrubbers are generally classified according to the energy required to overcome the pressure
drop through the system. Low-energy scrubbers (spray towers) are primarily used for acid gas control
only, and are usually circular in cross section. The liquid is sprayed down the tower through the rising
gas. Acid gases are absorbed/neutralized by the scrubbing liquid. Low-energy scrubbers mainly
remove particles larger than 5-10 micrometers (m) in diameter.
Medium-energy scrubbers can be used for particulate matter and/or acid gas control. Medium
energy devices rely mostly on impingement to facilitate removal of PM. This can be accomplished
through a variety of configurations, such as packed columns, baffle plates, and liquid impingement
scrubbers.
Venturi scrubbers are high-energy systems that are used primarily for PM control. A typical
venturi scrubber consists of a converging and a diverging section connected by a throat section. A liquid
(usually water) is introduced into the gas stream upstream of the throat. The flue gas impinges on the
liquid stream in the converging section. As the gas passes through the throat, the shearing action
atomizes the liquid into fine droplets. The gas then decelerates through the diverging section, resulting
in further contact between particles and liquid droplets. The droplets are then removed from the gas
stream by a cyclone, demister, or swirl vanes.
A fabric filtration system (baghouse) consists of a number of filtering elements (bags) along with
a bag cleaning system contained in a main shell structure with dust hoppers. Particulate-laden gas passes
through the bags so that the particles are retained on the upstream side of the fabric, thus cleaning the gas.
A FF is typically divided into several compartments or sections. In a FF, both the collection efficiency
and the pressure drop across the bag surface increase as the dust layer on the bag builds up. Since the
system cannot continue to operate with an increasing pressure drop, the bags are cleaned periodically.
The cleaning processes include reverse flow with bag collapse, pulse jet cleaning, and mechanical
shaking. When reverse flow and mechanical shaking are used, the particulate matter is collected on the
inside of the bag; particulate matter is collected on the outside of the bag in pulse jet systems. Generally,
reverse flow FFs operate with lower gas flow per unit area of bag surface (air-to-cloth ratio) than pulse jet
systems and, thus, are larger and more costly for a given gas flow-rate or application. Fabric filters can
achieve very high (>99.9 percent) PM removal efficiencies. These systems are also very effective in
Particulate collection in an ESP occurs in 3 steps: (1) suspended particles are given an electrical
charge; (2) the charged particles migrate to a collecting electrode of opposite polarity; and (3) the
collected PM is dislodged from the collecting electrodes and collected in hoppers for disposal.
Charging of the particles is usually caused by ions produced in a high voltage corona. The
electric fields and the corona necessary for particle charging are provided by converting alternating
current to direct current using high voltage transformers and rectifiers. Removal of the collected
particulate matter is accomplished mechanically by rapping or vibrating the collecting electrode plates.
ESPs have been used in many applications due to their high reliability and efficiency in controlling total
PM emissions. Except for very large and carefully designed ESPs, however, they are less efficient than
FFs at control of fine particulates and metals.
Dry sorbent injection (DSI) is another method for controlling acid gases. In the DSI process, a
dry alkaline material is injected into the flue gas into a dry venturi within the ducting or into the duct
ahead of a particulate control device. The alkaline material reacts with and neutralizes acids in the flue
gas. Fabric filters are employed downstream of DSI to: (1) control the PM generated by the incinerator,
(2) capture the DSI reaction products and unreacted sorbent, and (3) increase sorbent/acid gas contact
time, thus enhancing acid gas removal efficiency and sorbent utilization. Fabric filters are commonly
used with DSI because they provide high sorbent/acid gas contact. Fabric filters are less sensitive to PM
loading changes or combustion upsets than other PM control devices since they operate with nearly
constant efficiency. A potential disadvantage of ESPs used in conjunction with DSI is that the sorbent
increases the electrical resistivity of the PM being collected. This phenomenon makes the PM more
difficult to charge and, therefore, to collect. High resistivity can be compensated for by flue gas
conditioning or by increasing the plate area and size of the ESP.
The major factors affecting DSI performance are flue gas temperature, acid gas dew point
(temperature at which the acid gases condense), and sorbent-to-acid gas ratio. DSI performance
improves as the difference between flue gas and acid dew point temperatures decreases and the sorbent-
to-acid gas ratio increases. Acid gas removal efficiency with DSI also depends on sorbent type and the
extent of sorbent mixing with the flue gas. Sorbents that have been successfully applied include hydrated
lime (Ca[OH]2), sodium hydroxide (NaOH), and sodium bicarbonate (NaHCO3). For hydrated lime, DSI
can achieve 80 to 95 percent of HCl removal and 40 to 70 percent removal of SO2 under proper operating
conditions.
The primary advantage of DSI compared to wet scrubbers is the relative simplicity of the sorbent
preparation, handling, and injection systems as well as the easier handling and disposal of dry solid
process wastes. The primary disadvantages are its lower sorbent utilization rate and correspondingly
higher sorbent and waste disposal rates.
In the spray drying process, lime slurry is injected into the SD through either a rotary atomizer or
dual-fluid nozzles. The water in the slurry evaporates to cool the flue gas, and the lime reacts with acid
gases to form calcium salts that can be removed by a PM control device. The SD is designed to provide
sufficient contact and residence time to produce a dry product before leaving the SD adsorber vessel.
The residence time in the adsorber vessel is typically 10 to 15 seconds. The particulates leaving the SD
(fly ash, calcium salts, and unreacted hydrated lime) are collected by an FF or ESP.
Emission factors and emission factor ratings for controlled air incinerators are presented in
Tables 2.3-1, 2.3-2, 2.3-3, 2.3-4, 2.3-5, 2.3-6, 2.3-7, 2.3-8, 2.3-9, 2.3-10, 2.3-11, 2.3-12, 2.3-13, 2.13-14,
and 2.3-15. For emissions controlled with wet scrubbers, emission factors are presented separately for
low-, medium-, and high-energy wet scrubbers. Particle size distribution data for controlled air
2.3-8 EMISSION FACTORS (Reformatted 1/95) 7/93
incinerators are presented in Table 2.3-15 for uncontrolled emissions and controlled emissions following
a medium-energy wet scrubber/FF and a low-energy wet scrubber. Emission factors and emission factor
ratings for rotary kiln incinerators are presented in Tables 2.3-16, 2.3-17, and 2.3-18. Emissions data are
not available for pathogens because there is not an accepted methodology for measurement of these
emissions. Refer to References 8, 9, 11, 12, and 19 for more information.
Silver Thallium
EMISSION EMISSION
Control Levelb lb/ton kg/Mg FACTOR lb/ton kg/Mg FACTOR
RATING RATING
Uncontrolled 2.26 E-04 1.13 E-04 D 1.10 E-03 5.51 E-04 D
Low Energy Scrubber/FF
Medium Energy Scrubber/FF 1.71 E-04 8.57 E-05 E
FF
Low Energy Scrubber
High Energy Scrubber 4.33 E-04 2.17 E-04 E
DSI/FF 6.65 E-05 3.32 E-05 E
DSI/Carbon Injection/FF 7.19 E-05 3.59 E-05 E
DSI/FF/Scrubber
DSI/ESP
a
References 7-43. Source Classification Codes 5-01-005-05, 5-02-005-05. Blanks indicate no data.
b
FF = Fabric Filter
DSI = Dry Sorbent Injection
ESP = Electrostatic Precipitator
Table 2.3-9 (English And Metric Units). EMISSION FACTORS FOR SULFUR TRIOXIDE (SO3)
AND HYDROGEN BROMIDE (HBr) FOR CONTROLLED AIR MEDICAL WASTE INCINERATORSa
SO3 HBr
EMISSION EMISSION
Control Levelb lb/ton kg/Mg FACTOR lb/ton kg/Mg FACTOR
RATING RATING
Uncontrolled 4.33 E-02 2.16 E-02 D
Low Energy Scrubber/FF
Medium Energy Scrubber/FF 5.24 E-02 2.62 E-02 E
FF
Low Energy Scrubber
High Energy Scrubber
DSI/FF
DSI/Carbon Injection/FF 4.42 E-03 2.21 E-03 E
DSI/FF/Scrubber 9.07 E-03 4.53 E-03 E
DSI/ESP
a
References 7-43. Source Classification Codes 5-01-005-05, 5-02-005-05. Blanks indicate no data.
b
FF = Fabric Filter
DSI = Dry Sorbent Injection
ESP = Electrostatic Precipitator
Table 2.3-10 (English And Metric Units). EMISSION FACTORS FOR HYDROGEN FLUORIDE AND CHLORINE
FOR CONTROLLED AIR MEDICAL WASTE INCINERATORSa
TCDF
2,3,7,8- 2.40 E-07 1.20 E-07 E 3.85 E-08 1.97 E-08 E 1.26 E-08 6.30 E-09 E 4.93 E-09 2.47 E-09 E
Total 7.21 E-06 3.61 E-06 B 1.28 E-06 6.39 E-07 E 4.45 E-07 2.22 E-07 E 1.39 E-07 6.96 E-08 E
PeCDF
1,2,3,7,8- 7.56 E-10 3.78 E-10 E 1.04 E-09 5.22 E-10 E
2,3,4,7,8- 2.07 E-09 1.04 E-09 E 3.07 E-09 1.53 E-09 E
Total 6.18 E-09 3.09 E-09 E
HxCDF
1,2,3,4,7,8- 7.55 E-09 3.77 E-09 E 8.96 E-09 4.48 E-09 E
1,2,3,6,7,8- 2.53 E-09 1.26 E-09 E 3.53 E-09 1.76 E-09 E
2,3,4,6,7,8- 7.18 E-09 3.59 E-09 E 9.59 E-09 4.80 E-09 E
1,2,3,7,8,9- 3.51 E-10 1.76 E-10 E
Total 5.10 E-09 2.55 E-09 E
HpCDF
1,2,3,4,6,7,8- 1.76 E-08 8.78 E-09 E 1.79 E-08 8.97 E-09 E
1,2,3,4,7,8,9- 2.72 E-09 1.36 E-09 E 3.50 E-09 1.75 E-09 E
Total 1.91 E-09 9.56 E-10 E
OCDF - Total 7.42 E-08 3.71 E-08 E 4.91 E-10 2.45 E-10 E
Total CDF 7.15 E-05 3.58 E-05 B 8.50 E-06 4.25 E-06 E 4.92 E-06 2.46 E-06 E 1.47 E-06 7.37 E-07 E
a
References 7-43. Source Classification Codes 5-01-005-05, 5-02-005-05. Blanks indicate no data.
b
Hazardous air pollutants listed in the Clean Air Act.
c
FF = Fabric Filter
DSI = Dry Sorbent Injection
d ESP = Electrostatic Precipitator
Table 2.3-14 (English And Metric Units). CHLORINATED DIBENZOFURANS EMISSION FACTORS
FOR CONTROLLED AIR MEDICAL WASTE INCINERATORSa
Scrubber
Cut Diameter Uncontrolled Cumulative Mass
Cumulative Mass % Less Than
(μm) % Less Than Stated Size
Stated Size
0.625 31.1 0.1
1.0 35.4 0.2
2.5 43.3 2.7
5.0 52.0 28.1
10.0 65.0 71.9
a
References 7-43. Source Classification Codes 5-01-005-05, 5-02-005-05
Table 2.3-16 (English And Metric Units). ROTARY KILN MEDICAL WASTE INCINERATOR EMISSION FACTORS
FOR CRITERIA POLLUTANTS AND ACID GASESa
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U. S. Environmental Protection Agency, Rochester, New York, September 1991.
3. C. R. Brunner, "Biomedical Waste Incineration", presented at the 80th Annual Meeting of the Air
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U. S. Environmental Protection Agency, Research Triangle Park, North Carolina, June 1990.
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p. 729.
8. Medical Waste Incineration Emission Test Report, Cape Fear Memorial Hospital, Wilmington,
North Carolina, U. S. Environmental Protection Agency, December 1991.
9. Medical Waste Incineration Emission Test Report, Jordan Hospital, Plymouth, Massachusetts,
U. S. Environmental Protection Agency, February 1992.
10. J. E. McCormack, Evaluation Test Of The Kaiser Permanente Hospital Waste Incinerator in San
Diego, California Air Resources Board, March 1990.
11. Medical Waste Incineration Emission Test Report, Lenoir Memorial Hospital, Kinston,
North Carolina, U. S. Environmental Protection Agency, August 12, 1991.
12. Medical Waste Incineration Emission Test Report, AMI Central Carolina Hospital, Sanford,
North Carolina, U. S. Environmental Protection Agency, December 1991.
13. A. Jenkins, Evaluation Test On A Hospital Refuse Incinerator At Cedars Sinai Medical Center,
Los Angeles, California, California Air Resources Board, April 1987.
14. A. Jenkins, Evaluation Test On A Hospital Refuse Incinerator At Saint Agnes Medical Center,
Fresno, California, California Air Resources Board, April 1987.
15. A. Jenkins, et al., Evaluation Retest On A Hospital Refuse Incinerator At Sutter General
Hospital, Sacramento, California, California Air Resources Board, April 1988.
16. Test Report For Swedish American Hospital Consumat Incinerator, Beling Consultants,
Rockford, Illinois, December 1986.
19. Medical Waste Incineration Emission Test Report, Borgess Medical Center, Kalamazoo,
Michigan, EMB Report 91-MWI-9, U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, December 1991.
20. Medical Waste Incineration Emission Test Report, Morristown Memorial Hospital, Morristown,
New Jersey, EMB Report 91-MWI-8, U. S. Environmental Protection Agency, Office of Air
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21. Report Of Emission Tests, Burlington County Memorial Hospital, Mount Holly, New Jersey, New
Jersey State Department of Environmental Protection, November 28, 1989.
22. Results Of The November 4 And 11, 1988 Particulate And Chloride Emission Compliance Test
On The Morse Boulger Incinerator At The Mayo Foundation Institute Hills Research Facility
Located In Rochester, Minnesota, HDR Techserv, Inc., November 39, 1988.
23. Source Emission Tests At ERA Tech, North Jackson, Ohio, Custom Stack Analysis Engineering
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24. Memo to Data File, Hershey Medical Center, Derry Township, Pennsylvania, from Thomas P.
Bianca, Environmental Resources, Commonwealth of Pennsylvania, May 9, 1990.
25. Stack Emission Testing, Erlanger Medical Center, Chattanooga, Tennessee, Report I-6299-2,
Campbell & Associates, May 6, 1988.
26. Emission Compliance Test Program, Nazareth Hospital, Philadelphia, Pennsylvania, Ralph
Manco, Nazareth Hospital, September 1989.
27. Report Of Emission Tests, Hamilton Hospital, Hamilton, New Jersey, New Jersey State
Department of Environmental Protection, December 19, 1989.
28. Report of Emission Tests, Raritan Bay Health Services Corporation, Perth Amboy, New Jersey,
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29. K. A. Hansen, Source Emission Evaluation On A Rotary Atomizing Scrubber At Klamath Falls,
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31. Stack Emission Testing, Erlanger Medical Center, Chattanooga, Tennessee, Report I-6299,
Campbell & Associates, April 13, 1988.
32. Compliance Emission Testing For Memorial Hospital, Chattanooga, Tennessee, Air Systems
Testing, Inc., July 29, 1988.
34. Compliance Testing For Southland Exchange Joint Venture, Hampton, South Carolina, ETS,
Inc., July 1989.
35. Source Test Report, MEGA Of Kentucky, Louisville, Kentucky, August, 1988.
36. Report On Particulate And HCl Emission Tests On Therm-Tec Incinerator Stack, Elyra, Ohio,
Maurice L. Kelsey & Associates, Inc., January 24, 1989.
37. Compliance Emission Testing For Particulate And Hydrogen Chloride At Bio-Medical Service
Corporation, Lake City, Georgia, Air Techniques Inc., May 8, 1989.
38. Particulate And Chloride Emission Compliance Test On The Environmental Control Incinerator
At The Mayo Foundation Institute Hills Research Facility, Rochester, Minnesota, HDR Techserv,
Inc., November 30, 1988.
39. Report On Particulate And HCl Emission Tests On Therm-Tec Incinerator Stack, Cincinnati,
Ohio, Maurice L. Kelsey & Associates, Inc., May 22, 1989.
40. Report On Compliance Testing, Hamot Medical Center, Erie, Pennsylvania, Hamot Medical
Center, July 19, 1990.
41. Compliance Emission Testing For HCA North Park Hospital, Hixson, Tennessee, Air Systems
Testing, Inc., February 16, 1988.
42. Compliance Particulate Emission Testing On The Pathological Waste Incinerator, Humana
Hospital-East Ridge, Chattanooga, Tennessee, Air Techniques, Inc., November 12, 1987.
43. Report Of Emission Tests, Helene Fuld Medical Center, Trenton, New Jersey, New Jersey State
Department of Environmental Protection, December 1, 1989.