THERMAL DESTRUCTION OF IGNITABLE
HAZARDOUS WASTE.
A CASE STUDY IN REGULATORY INTERPRETATION
Robert J. Schoenberger, Vice President
Michael H. Corbin, Section Manager
Roy F. Weston, Inc.
West Chester, Pennsylvania 19380
Steven J. Wittmer, Environmental Engineer
Alice L. Lenthe, Project Engineer
Merck, Sharp, & Dohme
West Point, Pennsylvania 19486
INTRODUCTION
Since November 1980 when facilities which disposed of treated hazardous waste or stored hazardous waste were required to obtain interim status permits, the regulatory requirements have been
under continual interpretation and change. Some objectives of the Resource Conservation and Recovery Act (RCRA) are to: 1) control environmental impact; and 2) to reduce the quantity of hazardous wastes requiring land disposal. These objectives must be kept in perspective when reviewing
the management options available for treatment or disposal.
Beginning in 1982 many existing industries and commercial hazardous waste facilities have been
undergoing final permitting for their hazardous waste facilities under RCRA Part B requirements.
This permitting process is quite complex and requires careful front-end planning to control future
constraints and complications which arise during the permitting process. One objective often pursued
internally at an industry is to minimize the number of facilities which are permitted and to structure
the permit in a manner which does not place unacceptable constraints and restrictions on the operation of these facilities.
This paper discusses a case history to obtain a RCRA Part B Permit for a facility which thermally
destructs ignitable hazardous waste on-site. The Part B Permit application was prepared for the
Merck, Sharp and Dohme facility, West Point, Pennsylvania. This manufacturing facility is a combination of pharmaceutical production and research activity. Mainly because of the research, some
quantities of a wide variety of hazardous waste are generated. To accommodate the full scope of
hazardous waste management, the Part B includes not only thermal destruction but also the requisite
storage and bulking facilities. The industry, like many others nationwide, is proposing to utilize an
existing thermal processing device for the destruction of a major portion of their hazardous waste.
The RCRA classification of hazardous waste is based upon the potential human health and environmental interactions given in Table I. Through mid 1984 characteristics have been developed for
only the first four hazardous characteristics in Table I. As with many companies, the subject of the
case history generated other aqueous and solid wastes which were not ignitable by either characteristics or by listing. The thermal approach was selected because it accomplishes a complete destruction
of the waste material, yet provides an opportunity for recovery of the energy value from these wastes.
BACKGROUND
The pharmaceutical firm of Merck, Sharp and Dohme Division of Merck Company, Inc. (MSD)
is located in West Point, Pennsylvania, approximately 40 miles north of Philadelphia. At its 315-
acre site the company manufactures and packages pharmaceutical formulations, veterinary products,
and biologicals, and also is engaged in extensive research activity. Hazardous wastes are generated
as by-products of manufacturing and maintenance activities and as a result of research activity.
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