The following is a memorandum written by Cornell's director of biosafety and given to Cornell's president to provide background on the State University Construction Fund incinerator upgrade project and to respond to questions raised by the community.
To: President Hunter Rawlings
From: Larry J. Thompson, DVM, PhD, director of biosafety
Date: May 13, 1996
Re: Incinerator Upgrade Project
This memo is to address some of the questions that have arisen concerning the project to upgrade the present incinerator by replacing the old incinerator and by the addition of air pollution control equipment and a waste heat recovery boiler. Since 1957, the College of Veterinary Medicine (CVM) has had an incinerator adjacent to the necropsy facility, where post-mortem examinations of animals are performed. In its mission to control and reduce animal disease, the CVM must use the incinerator to dispose of large amounts of animal remains, some with diseases potentially infectious to humans and most with diseases potentially infectious to other animals. The only alternative to incineration is landfilling. Both the CVM and the State University Construction Fund (SUCF) consider landfilling to be a feasible but unacceptable choice, one that does not guarantee that the infectious nature of the remains will be destroyed. The CVM currently incinerates approximately 250,000 lbs. of animal remains yearly, along with approximately 350,000 lbs. of waste bedding (wood chips, straw, etc.) from research animals. The United States Environmental Protection Agency (EPA) has recently acknowledged that there are no alternatives to incineration of animal remains, although several alternative technologies exist for other types of Regulated Medical Waste (RMW), especially the plastic-based RMW. The remains of rats or mice may be handled with these alternative technologies but cattle, horses and other large animals are problematic.
The upgraded incinerator will be permitted to incinerate RMW and will be in full compliance with all applicable EPA and New York State Department of Environmental Conservation (DEC) regulations, which have been promulgated to safeguard public health and the environment. The incinerator upgrade project has been designed by licensed engineering consultants who are expert in the technical aspects of incineration and air-pollution control technology, and who are well versed in all applicable DEC and EPA regulations. In addition, Cornell facilities and staff have had significant input into the project. The financial backing of the SUCF and Cornell will assure continued compliance with existing and future regulations.
The upgraded incinerator will be equipped with state-of-the-art air pollution control equipment to meet the very stringent DEC air quality regulations concerning the emission of dioxins, heavy metals and other pollutants of concern. Within the first 60 days of operation, on-site stack emission testing for pollutants of concern will be performed in accordance with DEC criteria, as required in our construction and operation permits, and annually thereafter to further ensure safe operation of the incinerator and compliance with regulations. The upgraded incinerator will have continuous monitoring of all parameters required by DEC, which include combustion chamber temperatures, carbon monoxide content of flue gas, oxygen content, and opacity. We will be required to submit quarterly and annual reports to the DEC, including verification of operating parameters, weights of each load charged, time between loads, and readouts of the continuously monitored parameters. If there are malfunctions, they must be corrected before more material can be loaded into the incinerator. A report of each malfunction and its correction must be filed with the DEC.
Because of the proximity of the incinerator to the necropsy facility, animal remains can be quickly and safely transferred to the incinerator. By recent New York State Department of Health regulations, some of these animal remains meet the definition of RMW. The present incinerator requires this upgrading in order to incinerate RMW, the definition of which includes both infectious animal remains as well as plastic-based medical waste (needles, syringes, etc.). Currently the plastic-based RMW is shipped off-site. Thus the upgrade to the incinerator will allow Cornell to handle all its medical waste on an in-house basis. In addition to minimizing the handling of animal remains, the existing location allows for the energy-conserving measure of recovering heat from the incineration process and utilizing it in the campus central-heating system. The current incinerator does not recover this waste heat.
The incinerator is of the "two stage" design with a first or primary chamber where the material to be incinerated is introduced and ignited. The gases then flow to a second chamber where complete combustion is achieved. The upgraded incinerator will be able to be charged with material only if the primary chamber temperature is greater than 1,400 degrees F and the secondary chamber is more than 1,800 degrees F, as required by DEC regulations. At startup each day, no material can be charged into the incinerator until operating temperatures are obtained.
The proposed stack height of 177 feet was used in the air-quality modeling study, which found both on-site and off-site air-quality impacts of all regulated pollutants to be within applicable DEC standards. Although plastic-based medical waste will comprise only approximately 15 percent of the upgraded incinerator's anticipated waste stream, the air-quality modeling study was performed using a 100 percent plastic-based medical waste stream, thus adding an extra margin to the design and greater flexibility for final use. Even if we decided to incinerate 100 percent plastic-based RMW, the design of the incinerator and scrubbers would still have all the emissions within all applicable state and federal regulations.
In the air modeling study, the use of the term "rural" to describe the area within a three-kilometer radius surrounding the incinerator site is terminology prescribed by the EPA, which defines rural areas as having fewer than 750 people per square kilometer. Based on the 1990 census, the population within a three-kilometer radius area surrounding the incinerator site is approximately 250 people per square kilometer. Also for the modeling study, complete meteorological information (as judged by the DEC) was not available from the weather station here in Ithaca and thus the nearest station with five years of complete meteorological data was used in the analysis (Syracuse airport). Additional upper-atmosphere data were obtained from additional sources (Albany), again acceptable to the DEC.
As a final piece of information, incinerators of a very similar design are located both at SUNY-Upstate Medical Center (University Hospital) and the adjacent Crouse-Irving Memorial Hospital just off Interstate 81 within the city of Syracuse, where the population per square kilometer is much greater.