Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Medical Waste Incinerators
Federal RegisterFeb 27, 1995
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 60
[AD-FRL-5150-9]
RIN 2060-AC62
Standards of Performance for New Stationary Sources and Emission
Guidelines for Existing Sources: Medical Waste Incinerators
AGENCY: Environmental Protection Agency (EPA).
ACTION: Proposed standards and guidelines, and notice of public
hearing.
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SUMMARY: Today, EPA is proposing standards and guidelines for new and
existing medical waste incinerators (MWI's) that will reduce air
pollution from MWI's. Once implemented, these standards and guidelines
will protect public health by reducing exposure to air pollution.
This proposal would add subparts Ec and Cc to 40 CFR part 60.
Subpart Ec would limit emissions from new and modified MWI's. The
proposed standards would implement sections 111(b) and 129 of the Clean
Air Act (Act) as amended in 1990, and would require new MWI's to
control emissions of air pollutants to levels that reflect the degree
of emission reduction based on maximum achievable control technology
(MACT). In addition, this notice includes proposed standards for
fugitive fly ash/bottom ash emissions, MWI operator training and
qualification, siting, and permitting.
Subpart Cc would establish emission guidelines and compliance
schedules for use by States in developing State regulations to control
emissions from existing MWI's. The proposed emission guidelines
implement sections 111(d) and 129 of the Act, and would initiate State
action to develop State regulations. These State regulations would
control air pollutant emissions from existing MWI's to levels that
reflect the degree of emission reduction based on MACT. In addition,
this notice includes proposed guidelines for fugitive fly ash/bottom
ash emissions, equipment inspections, training and qualification of MWI
operators and permitting.
DATES: Comments. Comments must be received on or before April 28, 1995.
Public Hearing. The EPA will hold at least one public hearing in
Washington, D.C. in mid- to late-March 1995. Additional hearings may
also be held. A Federal Register notice will be published within the
next 2 weeks to announce the details of the hearing(s) and to confirm
the date(s) and location(s) for the hearing(s).
ADDRESSES: Comments. Comments on the proposal should be submitted (in
duplicate, if possible) to: The Air and Radiation Docket and
Information Center, ATTN: Docket No. A-91-61, U.S. Environmental
Protection Agency, 401 M Street, SW., Washington, DC 20460.
Commenters wishing to submit proprietary information for
consideration should clearly distinguish such information from other
comments, and clearly label it ``Confidential Business Information.''
Submissions containing such proprietary information should be sent
directly to the following address, and not to the public docket, to
ensure that proprietary information is not inadvertently placed in the
docket: Attention: Mr. Rick Copland, c/o Ms. Melva Toomer, U.S. EPA
Confidential Business Manager, 411 W. Chapel Hill Street, Room 944,
Durham, North Carolina 27701. Information covered by such a claim of
confidentiality will be disclosed by the EPA only to the extent allowed
and by the procedures set forth in 40 CFR part 2. If no claim of
confidentiality accompanies a submission when it is received by the
EPA, the submission may be made available to the public without further
notice to the commenter.
Background Information Documents. Two ``Fact Sheets'' are available
that succinctly summarize the proposed standards and guidelines. The
Fact Sheets are suggested reading for persons requiring an overview of
the proposal. The Fact Sheets can be obtained by (1) calling Ms. Julia
Latta at (919) 541-5578 or (2) accessing the EPA's Technology Transfer
Network (TTN) electronic bulletin board. See SUPPLEMENTARY INFORMATION
for instructions on accessing the TTN (electronic bulletin board). The
background information documents (BID's) for the proposed standards and
guidelines may be obtained from the docket; from the U.S. EPA Library
(MD-35), Research Triangle Park, North Carolina 27711, telephone number
(919) 541-2777; or from the National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161, telephone number
(703) 487-4650. See SUPPLEMENTARY INFORMATION for a listing of these
documents.
Docket. Docket No. A-91-61, containing supporting information used
in developing the proposed standards and guidelines, is available for
public inspection and copying between 8:00 a.m. and 4:00 p.m., Monday
through Friday, at the Air and Radiation Docket and Information Center,
U.S. Environmental Protection Agency, 401 M Street, SW., Washington, DC
20460, telephone (202) 260-7548, fax (202) 260-4000. A reasonable fee
may be charged for copying.
FOR FURTHER INFORMATION CONTACT: Mr. Rick Copland at (919) 541-5265 or
Mr. Fred Porter at (919) 541-5251, Emission Standards Division (MD-13),
U.S. EPA, Research Triangle Park, North Carolina 27711.
SUPPLEMENTARY INFORMATION: Incineration is a common method of medical
waste disposal in the United States and around the world. However,
while it is a very effective method of medical waste treatment with
regard to rendering waste non-infectious, incineration results in the
production of air pollutants. The EPA estimates that there are about
3,700 MWI's currently in operation in the United States. While these
incinerators are small in size relative to municipal waste combustors,
their large number makes MWI's a significant source of air pollution.
The EPA recently released a draft report reassessing the health effects
of exposure to dioxin. In the draft report, currently undergoing public
review, MWI's are identified as a significant source of dioxin
emissions. In addition, MWI's emit substantial quantities of hydrogen
chloride (HCl), lead (Pb), cadmium (Cd), and mercury (Hg).
Today's proposed standards and guidelines will result in greater
than 95 percent reduction in air pollution from MWI's. Once
implemented, these standards and guidelines will protect public health
by reducing exposure to air pollution.
The EPA, the Sierra Club, and the Natural Resources Defense Council
(NRDC) have filed a consent decree with the U.S. District Court for the
Eastern District of New York (Nos. CV-92-2093 and CV-93-0284) that
requires the EPA Administrator to sign a notice of proposed rulemaking
not later than February 1, 1995 and a notice of final rulemaking not
later than April 15, 1996.
The EPA will hold at least one public hearing to provide interested
parties an opportunity for oral presentation of data, views, or
arguments concerning the proposal. Additional hearings may also be held
(see discussion of public hearing above).
The EPA seeks full public participation in arriving at its final
decisions and strongly encourages comments on all aspects of this
proposal from all interested parties. Whenever applicable, full
supporting data and detailed analysis should accompany all
[[Page 10655]] comments to allow the EPA to adequately respond to the
comments.
The key documents used to develop the proposed standards and
guidelines include:
1. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Industry Profile Report for New and
Existing Facilities,'' EPA-453/R-94-042a, July 1994;
2. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Process Description Report for New
and Existing Facilities,'' EPA-453/R-94-043a, July 1994;
3. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Control Technology Performance
Report for New and Existing Facilities,'' EPA-453/R-94-044a, July 1994;
4. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Model Plant Description and Cost
Report for New and Existing Facilities,'' EPA-453/R-94-045a, July 1994;
5. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Environmental Impacts Report for New
and Existing Facilities,'' EPA-453/R-94-046a, July 1994;
6. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Analysis of Economic Impacts for New
Sources,'' EPA-453/R-94-047a, July 1994 (see also item 9 below);
7. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Analysis of Economic Impacts for
Existing Sources,'' EPA-453/R-94-048a, July 1994 (see also item 9
below);
8. ``Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Regulatory Impact Analysis for New
and Existing Facilities, EPA-453/R-94-063a, July 1994 (see also item 9
below); and
9. B. Strong and S. Shoraka-Blair, MRI, to R. Copland, EPA/ESD.
January 30, 1995. Regulatory Impacts of the Proposed New Source
Performance Standard (NSPS) and Emission Guidelines (EG) for Medical
Waste Incinerators (MWI's). Docket A-91-61, II-B-108.
An electronic copy of the items listed below are available from the
EPA's TTN electronic bulletin board. The TTN is accessible 24 hours per
day, 7 days per week, except Monday morning from 8:00 a.m. to 12:00
p.m. EST, when the system is updated. The TTN contains 12 electronic
bulletin boards, and information relating to this proposal is contained
in the Clean Air Act Amendments (CAAA) bulletin board. Instructions for
accessing the TTN can be obtained by calling (919) 541-5384.
MWI Items in the Electronic Bulletin Board (TTN/CAAA)
1. Fact Sheet--Proposed subpart Ec Emission Standards for New
MWI's.
2. Fact Sheet--Proposed subpart Cc Emission Guidelines for Existing
MWI's.
3. This Federal Register notice (preamble).
4. Proposed subpart Ec Emission Standards.
5. Proposed subpart Cc Emission Guidelines.
Other technical documents, including the key documents listed under
the SUPPLEMENTARY INFORMATION section, are contained in Docket No. A-
91-61.
The following outline is provided to aid in locating information in
this notice (the preamble to the proposed standards and guidelines):
I. Introduction
A. Overview of this Preamble
B. New Source Performance Standards (NSPS)--General
C. NSPS Decision Scheme
D. Emission Guidelines--General Goals
E. Additional Requirements Under Section 129
II. Summary of the Standards and Guidelines
A. Source Category to be Regulated
B. Pollutants to be Regulated
C. Affected Facility and Designated Facility
D. Proposed Standards and Guidelines
E. Operator Training and Qualification Requirements
F. Siting Requirements--New MWI's
G. Inspection Requirements--Existing MWI's
H. Compliance and Performance Test Methods and Monitoring
Requirements
I. Reporting and Recordkeeping--New MWI's
J. Reporting and Recordkeeping--Existing MWI's
K. Compliance Times
L. Permit Requirements
III. Impacts of the Proposed Standards for New MWI's
A. Air Impacts
B. Water and Solid Waste Impacts
C. Energy Impacts
D. Control Cost Impacts
E. Economic Impacts
IV. Impacts of the Proposed Guidelines for Existing MWI's
A. Air Impacts
B. Water and Solid Waste Impacts
C. Energy Impacts
D. Control Cost Impacts
E. Economic Impacts
V. Rationale for the Proposed Standards and Guidelines
A. Background
B. Selection of Source Category
C. Modification of Existing MWI's
D. Selection of Pollutants
E. Selection of Affected and Designated Facilities
F. Selection of Format for the Proposed Standards and Emission
Guidelines
G. Selection of Classes, Types, and Sizes
H. Performance of Technology
I. MACT Floor and MACT for New MWI's
J. MACT Floor and MACT for Existing MWI's
K. Selection of Fugitive Fly Ash/Bottom Ash Standards and
Guidelines
L. Operator Training and Qualification Requirements
M. Siting Requirements--New MWI's
N. Inspection Requirements--Existing MWI's
O. Compliance and Performance Test Methods and Monitoring
Requirements
P. Reporting and Recordkeeping--New MWI's
Q. Reporting and Recordkeeping--Existing MWI's
R. Compliance Times
S. Permit Requirements
VI. Request for Comment
A. Procedure to Determine MACT
B. Alternatives to Onsite Incineration
C. Definition of Medical Waste
VII. Administrative Requirements
A. Public Hearing
B. Docket
C. Clean Air Act Procedural Requirements
D. Office of Management and Budget Reviews
E. Regulatory Flexibility Act Compliance
I. Introduction
A. Overview of This Preamble
The 1990 Clean Air Act Amendments reflect growing public concern
about the large volume of toxic air pollutants released from numerous
categories of emission sources. Title III of the Amendments
specifically enumerated 189 hazardous air pollutants and instructed EPA
to protect public health by reducing emissions of these pollutants from
the sources that release them. The EPA's standards are to be issued in
two phases. The first phase standards are designed to bring all sources
up to the level of emissions control achieved by those that are already
well-controlled, using pollution prevention measures as well as ``end-
of-pipe'' methods. The second phase standards, due approximately a
decade later, are to require further emission reductions in any case in
which the first phase measures were not by themselves sufficient to
fully protect the public health.
In this context, the 1990 Amendments singled out waste incineration
for special attention. Congress recognized both a high level of public
concern about the incineration of municipal, medical and other wastes,
and a number of special management concerns for these types of sources.
Consequently, section 129 of the Act directs EPA to apply the two-phase
control approach of Title III to various categories of waste
incinerators, including medical waste [[Page 10656]] incinerators.
Today's action proposes standards and guidelines for new and existing
MWI's under section 129.
Current methods of medical waste incineration cause the release of
a wide array of air pollutants, including several pollutants of
particular public health concern. In September of 1994, EPA released a
review draft of a report reassessing the health effects associated with
dioxin, which suggests that dioxin exposure can result in a number of
cancer and noncancer health effects in humans. In the report, MWI's are
identified as the largest known source of dioxin emissions, emitting
more than municipal waste combustors, hazardous waste incinerators, and
cement kilns. Because of this, the reduction of dioxin emissions from
all sources is one of the Administrator's highest air quality
protection priorities. Consequently, the development of MWI regulations
has received increased attention.
In addition to dioxin, MWI's also emit significant quantities of
heavy metals including lead, cadmium, and mercury. Once again, MWI's
have been identified as the largest known source of mercury emissions,
emitting more than municipal waste combustors and coal-fired electric
utility boilers. The MWI's also emit nitrogen oxides (a contributor to
ozone smog), particulate matter, sulfur dioxide, and other acid gases.
Several States, including New York, California, and Texas, have
adopted relatively stringent regulations in the past few years limiting
emissions from MWI's. The implementation of these regulations has
brought about very large reductions in MWI emissions and the associated
risk to public health in those States. It has also significantly
reshaped how medical waste is managed in those States. Many facilities
have responded to the State regulations by switching to other medical
waste treatment and disposal options to avoid the high cost of add-on
air pollution control equipment. The two most commonly chosen
alternatives have been off-site contract disposal in larger, commercial
incinerators dedicated to medical waste, and on-site treatment by other
means (e.g., steam autoclaving). Other alternatives include chemical
treatment and microwave irradiation. The availability of alternatives
to onsite incineration has mitigated the economic impacts that might
have been associated with the State regulations.
Today EPA proposes nationally applicable emission standards and
guidelines for MWI's that build on the experience of these leading
States. Like the State regulations, the standards and guidelines
proposed today are based on the use of add-on air pollution control
systems.
These standards and guidelines will implement the first phase
requirements of section 129, described above.
The commercial medical waste disposal industry has indicated that
sufficient commercial medical waste disposal capacity is available to
handle the amount of waste that would no longer be treated onsite. In
addition, as mentioned earlier, onsite alternatives are available for
facilities that choose to treat their medical waste onsite. In fact,
even in the absence of Federal regulations, most facilities that
generate medical waste do not operate onsite MWI's. This indicates that
there currently are viable alternatives to onsite incineration.
As described in detail below, section 129, like section 112, of the
Clean Air Act instructs the Agency to set performance standards that
challenge industry to meet or exceed the pollution control standards
established by better controlled similar facilities. In this way, the
overall state of environmental practice is raised for large segments of
industry, a basic level of health protection is provided to all
communities, situations in which uncertainty about total risk and
hazard result in no protection for the exposed public are avoided, and
yet the cost of pollution control to industry is constrained to levels
already absorbed by similar operations. Eight years later, in a second
phase, EPA must evaluate whether the residual public health risk
warrants additional control.
For new MWI's, the proposed emissions standards would reduce
nationwide emissions of dioxins/furans by 99 percent; PM, CO, HCl, Pb,
and Cd by greater than 95 percent; and Hg by 92 percent. In addition,
the standards would achieve an emission reduction of about 25 percent
for SO2 and NOx. Because wastewater, solid waste, and energy
requirements associated with implementation of the proposed standards
are not significant, adverse water, solid waste, or energy impacts are
not anticipated.
The nationwide annual costs associated with the proposed standards
for new MWI's will increase by approximately $74.5 million/yr from the
regulatory baseline cost of $63.3 million/yr. This results in an
increase in the cost of waste incineration per unit of waste treated of
approximately $177/Mg ($161/ton) compared to the regulatory baseline
cost of $150/Mg ($136/ton).
The results of the economic impacts analyses for new MWI's indicate
that no medical waste-generating industry would need to be
significantly reconstructed (e.g., through closures or consolidations)
as a result of the proposed standards. The market price increase
resulting from the standards is relatively small for each industry. The
corresponding decreases in output, employment, and revenue were also
low, never exceeding 0.05 percent.
With regard to existing MWI's, an estimated 3.4 million tons of
waste are produced annually by medical waste generators in the United
States. The EPA believes that approximately 3,700 MWI's are currently
burning waste generated at health care facilities. The proposed
guidelines for existing MWI's would reduce nationwide emissions of
dioxins/furans and Pb by 99 percent; PM, CO, and HCl by 98 percent; Cd
by 97 percent; and Hg by 94 percent. The guidelines would also achieve
an overall emission reduction of 37 percent for both SO2 and
NOx. Because wastewater, solid waste, and energy requirements
associated with implementation of the proposed guidelines are not
significant, adverse water, solid waste, or energy impacts are not
anticipated.
The nationwide annual costs associated with the proposed guidelines
for existing MWI's will increase by approximately $351 million/yr from
the regulatory baseline cost of $265 million/yr. This results in an
increase in the cost of waste incineration per unit of waste treated of
approximately $245/Mg ($222/ton) compared to the regulatory baseline
cost of $185/Mg ($168/ton).
The results of the economic impacts analyses for existing MWI's
indicate that no medical waste-generating industry would need to be
significantly restructured (e.g., through closures or consolidations)
as a result of the proposed emission guidelines. The market price
increase resulting from the emission guidelines is relatively small for
each industry. The corresponding decreases in output, employment, and
revenue were also low, never exceeding 1 percent.
Considering the benefits to be gained from the reduction of air
pollution from MWI's along with the availability of alternative
treatment methods and the clear Congressional intent, these proposed
standards and guidelines are considered reasonable.
This preamble will:
1. Summarize the important features of the proposed standards and
guidelines;
2. Describe the environmental, energy, and economic impacts of
these standards and guidelines; [[Page 10657]]
3. Present a rationale for each of the decisions made regarding the
proposed standards and guidelines;
4. Request public comment on specific issues; and
5. Discuss administrative requirements relevant to this action.
B. New Source Performance Standards--General
The proposed new source performance standards (NSPS, or
standard(s)) for MWI's would implement section 111(b) of the Act. The
NSPS are issued for categories of sources that cause, or contribute
significantly to, air pollution that may reasonably be anticipated to
endanger public health or welfare. They apply to new stationary sources
of emissions (i.e., sources whose construction or modification begins
after a standard is proposed). An NSPS requires these sources to
control emissions to the level achievable by the best system of
continuous emission reduction, considering costs and other impacts.
C. NSPS Decision Scheme
An NSPS is the end product of a series of decisions related to
certain key elements for the source category being considered for
regulation. The elements in this decision are generally the following:
1. Source category to be regulated--usually an emission source
category, but can be a process or group of processes within an
industry.
2. Affected facility--the pieces or groups of equipment that
comprise the sources to which the standards will apply.
3. Pollutants to be regulated--the particular substances emitted by
the affected facility that the standards control.
4. Best system of continuous emission reduction--the technology on
which the standards will be based, i.e., application of the best system
of continuous emission reduction that (taking into consideration the
cost of achieving such emission reduction and any nonair-quality health
and environmental impacts and energy requirements) the Administrator
determines has been adequately demonstrated (section 111(a)(1)).
5. Format for the standards--the form in which the standards are
expressed, i.e., as pollutant concentration emission limits, as a
percent reduction in emissions, or as equipment or work practice
standards.
6. Actual standards--generally, emission limits based on the level
of reduction that the best demonstrated technology (BDT) can achieve.
Only in unusual cases do standards require that a specific technology
be used. In general, the source owner or operator may select any method
for complying with the standards.
7. Other considerations--(in addition to emission limits) NSPS
usually include: standards for visible emissions, modification
provisions, monitoring requirements, performance test methods and
compliance procedures, and reporting and recordkeeping requirements.
D. Emission Guidelines--General Goals
The Act requires the promulgation of standards of performance under
section 111(b) for categories of new sources that may contribute to the
endangerment of public health or welfare. When standards of performance
are promulgated under section 111(b) for a designated pollutant, the
Act requires States under section 111(d) to submit plans that: (1)
establish emission standards for this designated pollutant from
existing sources and (2) provide for implementation and enforcement of
these emission standards. In most cases, this means that control under
section 111(d) is appropriate when the pollutant may cause or
contribute to endangerment of public health or welfare but is not known
to be ``hazardous'' within the meaning of section 112 and is not
controlled under sections 108 through 110 because, for example, it is
not emitted from ``numerous or diverse'' sources as required by section
108.
As specified in 40 CFR part 60.23, States are required to adopt and
submit to the Administrator a plan implementing the section 111(d)
guidelines within 1 year after the promulgation of the guidelines. The
Act further requires that the procedure for State submission of a plan
shall be similar to the procedure for submission of State
implementation plans (SIP's) under section 110. The Act also provides
that the EPA shall prescribe a plan according to procedures similar to
those in section 110(c) if a State fails to submit a ``satisfactory
plan.''
E. Additional Requirements Under Section 129
The Amendments of 1990 added section 129, which includes specific
requirements for solid waste combustion units. Section 129 requires the
EPA, under Sec. 111(b), to establish new source performance standards
(NSPS) for new MWI's and, under Sec. 111(d), to establish emission
guidelines for existing MWI's.
1. New Sources The NSPS must specify numerical emission limitations
for the following: Particulate matter (PM), opacity, sulfur dioxide
(SO2), hydrogen chloride (HCl), oxides of nitrogen (NOX),
carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg), and
dioxins/furans (CDD/CDF). Section 129 also includes requirements for
operator training as well as siting requirements for new MWI's.
Section 129 requires that emission standards reflect the maximum
degree of reduction in air emissions that the Administrator, taking
into consideration the cost of achieving such emission reduction, and
any nonair-quality health and environmental impacts and energy
requirements, determines is achievable. This requirement is referred to
as maximum achievable control technology (MACT). The degree of
reduction in emissions that is deemed achievable for new MWI's may not
be less stringent than the emissions control that is achieved in
practice by the best controlled similar unit. This requirement that the
standards must be no less stringent than certain levels of emission
control currently achieved is referred to as the ``MACT floor'' for new
MWI's.
For NSPS, the control technology used to achieve the standards is
not specified. Only the emission limits achievable by MACT are included
in the standards. Any control technology that can comply with these
emission limits may be used.
2. Existing Sources Notwithstanding the limitations of setting
guidelines for existing sources under section 111(d), section 129
directs EPA to issue guidelines for existing MWI's that specify
numerical emission limitations for the same pollutants listed above for
new MWI's. Section 129 also includes requirements for operator
training.
Section 129 provides that the State plan for existing MWI's be at
least as protective as the guidelines.
Section 129 also provides that emission guidelines for existing
MWI's reflect MACT, as described above. However, while the guidelines
for existing MWI's may be less stringent than the standards for new
MWI's, the guidelines may be no less stringent than the average
emission limitation achieved by the best performing 12 percent of units
in the category. This requirement that the guidelines must be no less
stringent than certain levels of emission control currently achieved is
referred to as the ``MACT floor'' for existing MWI's.
For emission guidelines (EG), the control technology used for
compliance is not specified. Only the emission limits achievable by
MACT are included in the guidelines. Any control
[[Page 10658]] technology that can comply with these emission limits
may be used.
Under section 129, States are required to submit to the
Administrator a plan implementing the emission guidelines within 1 year
after promulgation of the guidelines. Section 129 also requires that a
State plan shall provide that each unit subject to the guidelines shall
be in compliance with all requirements of the proposed guidelines
within 3 years after the State plan is approved by the Administrator
but in no case later that 5 years after promulgation of these
guidelines. The compliance schedule in today's proposed emission
guidelines would supersede and is more comprehensive than the
compliance schedule and timetable specified in section 129.
The proposal requires that a State plan shall provide that each
source subject to the guidelines shall be in compliance with all
requirements of the guidelines within 1 year after the State plan is
approved by the Administrator. The proposal allows two exceptions to
this compliance schedule: extensions for facilities planning to install
the necessary air pollution equipment and extensions under a petition
process for other reasons. State plans that include such provisions may
allow designated facilities up to 3 years after the State plan is
approved by the Administrator (but no more than 5 years after
promulgation of the guidelines) to achieve compliance. The only
exception to these compliance times involves the operator training and
qualification requirements and the maintenance inspection requirement.
The proposed emission guidelines require that a State plan provide that
each designated facility shall be in compliance with the operator
training and qualification requirements and the maintenance inspection
requirements within 1 year after the State plan is approved by the
Administrator.
Section 129 specifies that the EPA, in reviewing State plans for
any variation from the emission guidelines, must ensure that State
plans and their resulting MWI control requirements are at least as
protective as the EPA emission guidelines, including incorporation of
the compliance schedule requirements established by the guidelines.
II. Summary of the Standards and Guidelines
A. Source Category To Be Regulated
The proposed standards for new MWI's would limit emissions of air
pollutants from each MWI for which construction is commenced after
today's date, or for which modification is commenced after the
effective date of the standards. The effective date of the proposed
standards is specified in the Act as the date 6 months after
promulgation of the standards. The proposed guidelines for existing
MWI's would require States to develop emission standards limiting
emissions of air pollutants from each MWI for which construction was
commenced on or before today's date. Changes made to an existing MWI
solely for the purpose of complying with the emission guidelines would
not bring an existing MWI under the NSPS for new MWI's.
The proposed standards and guidelines would require facilities that
employ technologies such as pyrolysis/gasification in medical waste
destruction to meet the emission limits and all other requirements in
today's proposal. The pyrolysis/gasification industry does not object
to be covered under today's proposed MWI standards and guidelines and
believes that they can meet and exceed the proposed emission
limitations. However, the pyrolysis/gasification industry believes that
their process is unique enough to warrant a separate category for the
purpose of regulations. The agency is requesting comment on whether
these units should be regulated as MWI's or as a separate source
category. Also, comment is requested on the definitions of medical
waste incineration and medical waste pyrolysis/gasification that would
differentiate these two categories of waste destruction for the purpose
of regulation.
An MWI is defined as any device used to burn medical waste, with or
without other fuels or types of waste, including the heat recovery
device, if one is present. Medical waste is defined as any solid waste
that is generated in the diagnosis, treatment, or immunization of human
beings or animals, in research pertaining thereto, or in production or
testing of biologicals. Biologicals refer to preparations made from
living organisms and their products, including vaccines, cultures,
etc., intended for use in diagnosing, treating, or immunizing humans or
animals or in research pertaining thereto. Medical waste includes
materials such as sharps, fabrics, plastics, paper, waste chemicals/
drugs that are not RCRA hazardous waste, and pathological waste.
Medical waste does not include household waste, hazardous waste, or
human and animal remains not generated as medical waste.
Most MWI's burn a diverse mixture of medical waste (referred to in
this preamble as general medical waste), that may include some
pathological waste (human and animal body parts and/or tissue).
However, larger amounts of pathological waste require special operating
conditions for combustion. Thus, some facilities maintain MWI's
designed and operated to burn pathological waste exclusively.
The proposed standards and guidelines focus on regulating emissions
from general medical waste incinerators and include very minor
requirements for pathological MWI's. Under this proposal, pathological
MWI's would only be required to submit quarterly reports of the amount
and type of materials charged to the incinerator. Pathological MWI's
will be considered in future regulatory action under section 129 in the
source category of ``other solid waste incinerators.''
B. Pollutants To Be Regulated
Section 129 of the Act requires the EPA to establish numerical
emission limits for PM, opacity, CO, CDD/CDF, HCl, SO2, NOx,
Pb, Cd, and Hg. All pollutants to be regulated would be reported as
concentrations and are corrected to 7 percent oxygen. Particulate
matter and metals (Pb, Cd, and Hg) would be reported as milligrams per
dry standard cubic meter (mg/dscm). For Hg, the proposed standards and
guidelines would also establish an alternative percent reduction
requirement. Carbon monoxide, HCl, SO2, and NOx would be
reported as parts per million by volume (ppmv), dry basis. As an
alternative, the proposed standards and guidelines for HCl would also
establish a percent reduction requirement. Emissions of CDD/CDF would
be reported in units of total nanograms per dry standard cubic meter
(ng/dscm) or ng/dscm toxic equivalency (TEQ). Measurements of TEQ are
determined by first measuring the total concentration of CDD/CDF
congeners and adjusting the results to account for the varying toxicity
of each congener. Opacity is reported on a percentage basis. The
proposed standards and guidelines also establish fly ash/bottom ash
fugitive emission limitations, reported on a percentage basis.
C. Affected Facility and Designated Facility
The affected facility to which the proposed standards applies is
each individual MWI for which construction is commenced after today's
date or for which modification is commenced after the effective date of
these standards. The effective date of the proposed standards is
specified in the Act as the date 6 months after promulgation of the
standards. [[Page 10659]]
The designated facility to which the proposed emission guidelines
apply is each individual MWI for which construction is commenced on or
before today's date.
D. Proposed Standards and Guidelines
Table 1 lists the emission limitations under the proposed standards
and guidelines, Tables 2 and 3 list other requirements of the proposed
standards and guidelines, and Tables 4 and 5 list the compliance times
for the proposed standards and guidelines.
Table 1.--Summary of Proposed Emission Limits for New and Existing
Medical Waste Incinerators
------------------------------------------------------------------------
Pollutant Emissions limits
------------------------------------------------------------------------
Particulate matter................................ 30 mg/dscm (0.013 gr/
dscf) 12-hour
average.
Opacity........................................... 5 percent 6-minute
average.
Carbon monoxide................................... 50 ppmv 12-hour
average.
Dioxins/furans.................................... 80 ng/dscm total CDD/
CDF (35 gr/10\9\
dscf) or 1.9 ng/
dscm TEQ (0.83 gr/
10\9\ dscf) 12-hour
average.
Hydrogen chloride................................. 42 ppmv or 97%
reduction 9-hour
average.
Sulfur dioxide.................................... 45 ppmv 12-hour
average.
Nitrogen oxides................................... 210 ppmv 12-hour
average.
Lead.............................................. 0.10 mg/dscm (44 gr/
10\6\ dscf) 12-hour
average.
Cadmium........................................... 0.05 mg/dscm (22 gr/
10\9\ dscf) 12-hour
average.
Mercury........................................... 0.47 mg/dscm (210 gr/
10\6\ dscf) or 85%
reduction 12-hour
average.
------------------------------------------------------------------------
Note: Tables 1 through 5 depict the major provisions of the proposed
standards and guidelines and do not attempt to show all requirements.
The full text of Subparts Ec and Cc should be relied upon for a full
and comprehensive statement of the requirements of the proposed
standards and guidelines.
Table 2.--Summary of Additional Requirements Under the NSPS for New
Medical Waste Incinerators
------------------------------------------------------------------------
Additional Requirements
-------------------------------------------------------------------------
Operator Training and Qualification Requirements:
Complete MWI operator training course.
Qualify operators.
Develop a site-specific operating manual and update
annually.
Siting Requirements:
Prepare a siting analysis.
Conduct a public meeting at which comment is accepted on
the siting analysis.
Prepare responses to the comments and make them available
to the public.
Include in the initial notification to construct the
results of siting analysis and a letter from the State air
pollution control office approving the construction and operation
of the affected facility.
Compliance and Performance Testing Requirements:
Conduct an initial and annual performance test to determine
compliance with the emission limitations for all pollutants and to
establish operating parameters.
Facilities may conduct performance tests for CDD/CDF, PM,
Cd, Pb, and Hg every third year if the previous three MWI
performance tests demonstrate that the facility is in compliance
with the emission limits.
Continuously monitor emissions and measure and record operating
parameters.
Perform monthly fugitive testing.
Monitoring Requirements:
Install and maintain equipment to continuously monitor
emissions/operating parameters as appropriate.
Obtain monitoring data at all times during MWI operation.
Reporting and Recordkeeping Requirements:
Maintain for 5 years records of results from initial
performance test and all subsequent performance tests, operating
parameters, and any maintenance.
Maintain for the life of the incinerator records of siting
analysis and operator training and qualification.
Submit the results of the initial performance test and all
subsequent performance tests.
Submit, within 30 days following the end of the quarter of
occurrence, reports on emission rates or operating parameters that
have not been recorded or that exceeded applicable limits.
Provide notification of intent to construct, of planned
initial start-up date, and of planned waste type(s) to be
combusted.
------------------------------------------------------------------------
Note: Tables 1 and 2 depict the major provisions of the NSPS and do not
attempt to show all requirements. The regulatory text of Subpart Ec
should be relied upon for a full and comprehensive statement of the
requirements of the proposed NSPS.
Table 3.--Summary of Additional Requirements Under the EG for Existing
Medical Waste Incinerators
------------------------------------------------------------------------
Additional Requirements
-------------------------------------------------------------------------
Operator Training and Qualification Requirements:
Complete MWI operator training course.
Qualify operators.
Develop a site-specific operating manual and update
annually.
Inspection Requirements:
Provide for an annual equipment inspection by an MWI
service technician not employed by the owner or operator of the
affected facility until source demonstrates compliance with
emission limits.
Compliance and Performance Testing Requirements:
Conduct an initial and annual performance test to determine
compliance with the emission limitations for all pollutants and to
establish operating parameters.
[[Page 10660]]
Facilities may conduct performance tests for CDD/CDF, PM,
Cd, Pb, and Hg every third year if the previous three performance
tests demonstrate that the facility is in compliance with the
emission limits.
Continuously monitor emissions and measure and record
operating parameters.
Perform monthly fugitive testing.
Monitoring Requirements:
Install and maintain equipment to continuously monitor
emissions/operating parameters as appropriate.
Obtain monitoring data at all times during MWI operation.
Reporting and Recordkeeping Requirements:
Maintain for 5 years records of: results from initial
performance test and all subsequent performance tests, operating
parameters, annual inspections, and any maintenance.
Maintain for the life of the incinerator records of
operator training and qualification.
Submit the results of the initial performance test and all
subsequent performance tests.
Submit, within 30 days following the end of the quarter of
occurrence, reports on emission rates or operating parameters that
have not been recorded or which exceeded applicable limits.
------------------------------------------------------------------------
Note: Tables 1 and 3 depict the major provisions of the emission
guidelines (EG) and do not attempt to show all requirements. The
regulatory text of Subpart Cc should be relied upon for a full and
comprehensive statement of the requirements of the proposed
guidelines.
Table 4.--Compliance Times for New MWI's New Source Performance Standards
----------------------------------------------------------------------------------------------------------------
Requirement Compliance Time
----------------------------------------------------------------------------------------------------------------
Effective date.................................... 6 months after promulgation of NSPS.
Operator training and qualification requirements.. On effective date or upon initial start up, whichever is
later.
Initial compliance test........................... On effective date or within 180 days of initial start up,
whichever is later.
Performance test.................................. Within 12 months following initial compliance test and
annually thereafter.
CEMS and parameter monitoring..................... Continuously, upon completion of initial compliance test.
Recordkeeping..................................... Continuously, upon completion of initial compliance test.
Reporting......................................... Quarterly, upon completion of initial compliance test.
----------------------------------------------------------------------------------------------------------------
Table 5.--Compliance Times for Existing MWI's Emission Guidelines
----------------------------------------------------------------------------------------------------------------
Requirement Compliance Time
----------------------------------------------------------------------------------------------------------------
State Plan submittal.............................. Within 1 year after promulgation of EPA emission guidelines.
Effective date.................................... Within 1 year after EPA approval of State Plan.
Operator training and qualification requirements.. Within 1 year after EPA approval of State Plan.
Recordkeeping..................................... Continuously, upon completion of initial compliance test.
Initial compliance test........................... Within 1 year after EPA approval of State plan or up to 3
years after EPA approval of State plan if the source is
granted an extension.
Performance test.................................. Within 12 months following initial compliance test and
annually thereafter.
CEMS and parameter monitoring..................... Continuously, upon completion of initial compliance test.
Inspection requirements........................... Within 1 year after EPA approval of State Plan.
Reporting......................................... Quarterly, upon completion of initial compliance test.
----------------------------------------------------------------------------------------------------------------
A brief discussion of the emission limitations is presented below.
Further discussion of the additional requirements can be found in
sections II.E through II.L of this section.
1. Numerical Emission Limits
The numerical emission limits in this section are corrected to 7
percent O2.
Particulate Matter--The proposed emission limitation for PM for
both new and existing MWI's is 30 milligrams per dry standard cubic
meter (mg/dscm).
Opacity--The proposed emission limitation for stack opacity for
both new and existing MWI's is 5 percent (6-minute average).
Carbon Monoxide--The proposed emission limitation for CO for both
new and existing MWI's is 50 parts per million by volume (ppmv), dry
basis.
Dioxins/Furans--The proposed emission limitation for CDD/CDF for
both new and existing MWI's is 80 ng/dscm total CDD/CDF or 1.9 ng/dscm
TEQ. This limit would be measured as total tetra- through octa-
chlorinated dibenzo-p-dioxins and dibenzofurans as determined by
Reference Method 23 and converted to TEQ's using the toxic equivalency
factors (TEF's) shown in Table 6.
Table 6.--Toxic Equivalency Factors
------------------------------------------------------------------------
Toxic
CDD/CDF congener equivalency
factor
------------------------------------------------------------------------
2,3,7,8-tetrachlorinated dibenzo-p-dioxin.................. 1
1,2,3,7,8-pentachlorinated dibenzo-p-dioxin................ 0.5
1,2,3,4,7,8-hexachlorinated dibenzo-p-dioxin............... 0.1
1,2,3,7,8,9-hexachlorinated dibenzo-p-dioxin............... 0.1
1,2,3,6,7,8-hexachlorinated dibenzo-p-dioxin............... 0.1
1,2,3,4,6,7,8-heptachlorinated dibenzo-p-dioxin............ 0.01
octachlorinated dibenzo-p-dioxin........................... 0.001
[[Page 10661]]
2,3,7,8-tetrachlorinated dibenzofuran...................... 0.1
2,3,4,7,8-pentachlorinated dibenzofuran.................... 0.5
1,2,3,7,8-pentachlorinated dibenzofuran.................... 0.05
1,2,3,4,7,8-hexachlorinated dibenzofuran................... 0.1
1,2,3,6,7,8-hexachlorinated dibenzofuran................... 0.1
1,2,3,7,8,9-hexachlorinated dibenzofuran................... 0.1
2,3,4,6,7,8-hexachlorinated dibenzofuran................... 0.1
1,2,3,4,6,7,8-heptachlorinated dibenzofuran................ 0.01
1,2,3,4,7,8,9-heptachlorinated dibenzofuran................ 0.01
octachlorinated dibenzofuran............................... 0.001
------------------------------------------------------------------------
Hydrogen Chloride--The proposed emission limitation for HCl for
both new and existing MWI's is 42 ppmv, dry basis (or 97-percent
reduction).
Sulfur Dioxide--The proposed emission limitation for SO2 for
both new and existing MWI's is 45 ppmv, dry basis.
Nitrogen Oxides--The proposed emission limitation for NOX for
both new and existing MWI's is 210 ppmv, dry basis.
Lead--The proposed emission limitation for Pb for both new and
existing MWI's is 0.10 mg/dscm.
Cadmium--The proposed emission limitation for Cd for both new and
existing MWI's is 0.05 mg/dscm.
Mercury--The proposed emission limitation for Hg for both new and
existing MWI's is 0.47 mg/dscm (or 85-percent reduction).
2. Fly Ash/Bottom Ash Emissions
The proposed standards and guidelines would establish a limit of
zero percent opacity of fly ash or bottom ash from any fly ash or
bottom ash storage or handling area within the facility's property
boundary.
E. Operator Training and Qualification Requirements
The proposed standards and guidelines include operator training and
qualification requirements for each MWI operator. For new MWI's, these
requirements would become effective six months after promulgation of
the NSPS. For existing MWI's, these requirements would become effective
one year after approval of the State plan. An acceptable training
course would provide the operator with a minimum of: (1) 24 hours of
classroom instruction, (2) 4 hours of hands-on training, (3) an
examination developed and administered by the course instructor, and
(4) a handbook or other documentation covering the subjects presented
during the course. To be qualified, an operator must complete the
training course and have either a minimum level of experience or
satisfy comparable or more stringent criteria that are established by a
national professional organization. The proposed standards and
guidelines also would require that the owner or operator of the
facility develop and annually update a site-specific operating manual.
The manual would summarize State emissions regulations, operating
procedures, and reporting and recordkeeping requirements in accordance
with the proposed standards and guidelines.
F. Siting Requirements--New MWI's
Site selection criteria are being proposed for MWI's that commence
construction after the date of promulgation of this rule. The proposed
siting requirements would address the impact of the facility on ambient
air quality, visibility, soils, vegetation, and other factors that may
be relevant in determining that the benefits of the proposed facility
significantly outweigh the environmental and social costs imposed as a
result of its location and construction. A document presenting the
results of the analyses would be prepared and submitted to EPA, State,
and local officials and would be made available to the public.
Provisions for a public meeting and the preparation of a comment and
response document are also included in the proposed siting
requirements.
G. Inspection Requirements--Existing MWI's
The proposed emission guidelines include a requirement for an
initial equipment inspection of the designated facility. These
requirements would become effective 1 year after the EPA approval of
the State plan. The inspection must be performed by an MWI service
technician not employed by the owner or operator of the designated
facility. The proposed guidelines provide minimum requirements for
inspection of the designated facility. Following the initial inspection
and until compliance with the emission limitations has been
demonstrated, facilities are required to conduct annual inspections of
the MWI.
H. Compliance and Performance Test Methods and Monitoring Requirements
Testing and monitoring requirements are proposed to demonstrate
compliance with the emission limits. The proposed standards and
guidelines require that the owner or operator of the facility: (1)
conduct initial and annual performance tests to demonstrate compliance
with the emission limits and (2) demonstrate continuous compliance with
the emission limits following the initial performance test.
The initial and annual performance tests would be conducted using
the following EPA-approved methods:
1. Method 1 would be used to select the sampling site and number of
traverse points;
2. Method 3 or 3A would be used for gas composition analysis,
including measurement of oxygen;
3. Method 5 or Method 29 would be used to measure PM emissions;
4. A continuous emissions monitoring system (CEMS) would be used to
measure opacity;
5. A CEMS would be used to measure CO emissions;
6. Method 23 would be used to measure CDD/CDF emissions;
7. Method 26 would be used to measure HCl emissions;
8. Method 29 would be used to measure Pb, Cd, and Hg emissions; and
9. Method 9 would be used to measure opacity of fugitive emissions.
The proposed standards and guidelines include provisions for less
frequent testing if the facility consistently demonstrates compliance.
These provisions are described in detail in section V of this preamble.
Following the initial performance test, the owners or operators must
demonstrate continuous compliance with the limits by monitoring the
output of a CEMS, where a CEMS is required, and by monitoring site-
specific operating parameters where a CEMS is not required. Facilities
are required to:
1. Demonstrate continuous compliance with the CO emission limit
based on the output from the CO CEMS;
2. Demonstrate continuous compliance with the opacity emission
limit based on the output from the opacity CEMS; and
3. Demonstrate compliance with the fugitive emission limit by
conducting a performance test using Method 9 at least once per calendar
month when ash is removed from the incinerator and when ash is removed
from the air pollution control device (APCD).
In addition, facilities equipped with a dry scrubber followed by a
fabric filter are required to demonstrate compliance in the following
ways: [[Page 10662]]
1. Demonstrate compliance with the Hg emission limit by
continuously monitoring the Hg sorbent flow rate (typically activated
carbon) and continuously measuring the weight and time of each load of
waste charged to the incinerator. The minimum Hg sorbent flow rate, the
maximum charge weight, and the maximum hourly charge rate are to be
established during the initial performance test to determine compliance
with the Hg emission limit. Operation of the facility below the minimum
sorbent flow rate, or above the maximum charge weight or maximum hourly
charge rate would constitute a violation of the Hg emission limit.
2. Demonstrate compliance with the CDD/CDF emission limit by
continuously monitoring the CDD/CDF sorbent flow rate (typically
activated carbon) and the temperature measured at the inlet to the PM
control device. The minimum CDD/CDF sorbent flow rate and the maximum
PM control device inlet temperature are to be established during the
initial performance test to determine compliance with the CDD/CDF
emission limit. Operation of the facility below the minimum sorbent
flow rate or above the maximum PM control device inlet temperature
would constitute a violation of the CDD/CDF emission limit.
3. Demonstrate compliance with the HCl emission limit by
continuously monitoring the HCl sorbent flow rate (typically hydrated
lime) and continuously measuring the weight and time of each load of
waste charged to the incinerator. The minimum HCl sorbent flow rate,
the maximum charge weight, and the maximum hourly charge rate are to be
established during the initial performance test to demonstrate
compliance with the emission limit for HCl. Operation of the facility
below the minimum sorbent flow rate, or above the maximum charge weight
or maximum hourly charge rate would constitute a violation of the HCl
emission limit.
The proposed standards and guidelines require the owner or operator
of an MWI using a control device other than a dry scrubber followed by
a fabric filter to petition the Administrator for other site-specific
operating parameters to demonstrate continuous compliance with the
emission limits for CDD/CDF, Hg, HCl, and/or opacity. These parameters
would be established during the initial performance test for these
pollutants and would be continuously monitored to demonstrate
compliance with the emission limits. As discussed in section VI, the
EPA requests comment on appropriate parameters for wet scrubbers and
for other control systems that may be used to control emissions from
MWI's.
I. Reporting and Recordkeeping--New MWI's
The proposed standards would require owners of affected facilities
(i.e., new or modified MWI's) to submit notifications concerning
construction and initial startup of the affected facility. Owners and
operators are also required to maintain thorough records documenting
the results of the initial and annual performance tests, records
demonstrating continuous monitoring of site-specific operating
parameters, and CEMS output data and quality assurance determinations.
These records must be kept on file for at least 5 years.
Additional records must be kept on file for the life of the
affected facility. These records are required to document compliance
with the siting requirements and the operator training and
qualification requirements. The records to be maintained include all
documentation produced as a result of the siting requirements and
records of the names of the persons who have completed the operator
training requirements, the names of the persons who have been qualified
as MWI operators, and the names of the persons who have completed
review of the site-specific MWI operating manual. All records must also
include dates associated with operator training and qualification, and
dates associated with review of the operating manual.
Under the proposed standards, owners or operators of affected
facilities are required to submit the results of the initial
performance test and all subsequent performance tests. Also, reports on
emission rates or operating parameters that have not been obtained or
that exceed applicable limits must be submitted within 30 days after
the end of the quarter of occurrence. If no exceedances occur during a
quarter, the owner of the affected facility would be required to submit
a letter stating so. All reports submitted to comply with the
requirements of the proposed standards must be signed by the facilities
manager.
J. Reporting and Recordkeeping--Existing MWI's
The proposed emission guidelines would require owners of designated
facilities (i.e., existing MWI's) to maintain thorough records
documenting the results of the initial and annual performance tests,
records demonstrating continuous monitoring of site-specific operating
parameters, CEMS output data and quality assurance determinations, and
records of the initial and annual inspections. These records must be
kept on file for at least 5 years.
Additional records must be kept on file for the life of the
designated facility. These records are required to document compliance
with the operator training and qualification requirements and include
records of the names of the persons who have completed the operator
training requirements, the names of the persons who have been qualified
as MWI operators, and the names of the persons who have completed
review of the site-specific MWI operating manual. All records must also
include dates associated with operator training and qualification, and
dates associated with review of the operating manual.
Under the proposed emission guidelines owners or operators are
required to submit the results of the initial and annual maintenance
inspections and the results of the initial performance test and all
subsequent performance tests. Additionally, reports of data on emission
rates or operating parameters that have not been obtained or that
exceed applicable limits must be submitted within 30 days after the end
of the quarter of occurrence. If no exceedances occur during a quarter,
the owner of the designated facility would be required to submit a
letter stating so. All reports submitted to comply with the
requirements of the proposed emission guidelines must be signed by the
facilities manager.
K. Compliance Times
1. New MWI's
The effective date of the standards for new MWI's is the date 6
months after promulgation of the standards.
2. Existing MWI's
In accordance with the proposed guidelines, for approval, a State
plan must require that designated facilities comply with all
requirements of the guidelines within 1 year after EPA approval of the
State plan. The proposal allows two exceptions to this compliance
schedule. First, State plans may allow facilities that are planning to
install the necessary air pollution control equipment up to three years
after EPA approval of the State plan to comply, provided the State plan
specifies that the facility submit measurable and legally enforceable
incremental steps of progress that will be taken to comply with the
State plan. Second, State plans may include provisions for a petition
process through which designated facilities could
[[Page 10663]] request an extension for other reasons. The proposed
guidelines specify minimum requirements to be included in State plans
with such provisions. If an extension is granted, compliance must be
required within 3 years after EPA approval of the State plan.
Regardless of the status of the State plans, all designated
facilities must be in compliance within 5 years after promulgation of
the emission guidelines. The proposed emission guidelines require the
EPA to develop, implement, and enforce a plan for any State that has
not submitted an approvable plan within 2 years after promulgation of
the emission guidelines.
The proposed emission guidelines also require that, for approval, a
State plan provide that each designated facility must be in compliance
with the operator training and qualification requirements and the
inspection requirements within 1 year after EPA approval of the State
plan. No extension is available for training, qualification, or
inspection.
L. Permit Requirements
The proposed standards and guidelines include a requirement that
facilities operate pursuant to permits issued under the EPA-approved
State operating permit program. Permits would be required beginning 36
months after the date of promulgation of the standards and guidelines,
or on the effective date of an EPA-approved operating permit program in
the State in which the facility is located, whichever date is later.
The operating permit programs are developed under Title V of the Act
and the implementing regulations under 40 CFR part 70.
III. Impacts of the Proposed Standards for New MWI's
This section presents a description of the air, water, solid waste,
energy, control cost, and economic impacts of today's proposed
standards for new MWI's. All of the impacts presented are nationwide
impacts that are expected to result from the implementation of the NSPS
in the fifth year after adoption. As discussed below, it is expected
that as many as 80 percent of the projected number of new MWI's will
not be constructed to avoid the increased costs associated with
installation of control equipment. Therefore, impacts are presented
assuming 80 percent of projected new MWI's are not constructed, with
the waste being disposed of by other means (i.e., the ``switching
scenario'').
Based on historic sales to date, in the absence of regulation, an
estimated 700 new MWI's are expected to be installed over the next 5
years. However, onsite incineration is only one of several medical
waste treatment and disposal options. For some MWI's, the equipment
necessary to comply with the proposed regulations will make onsite
incineration more expensive than other waste treatment and disposal
options. Consequently, many facilities that would have chosen onsite
incineration are likely to consider less expensive methods of treatment
and disposal. The EPA expects that as many as 80 percent of the
projected number of new MWI's will not be constructed if the standards
are promulgated as proposed. This is referred to in this notice as the
``switching scenario'' because of the expectation that potential owners
of MWI's will switch to another method of waste treatment and disposal.
Recent experience at the State level confirms that switching to
lower cost alternatives is a likely impact of the implementation of MWI
regulations that require add-on air pollution control. For example,
recent regulations adopted by the State of New York require the use of
add-on acid gas scrubber systems. As a result, the State estimates that
as many as 90 percent of previously existing MWI's in New York have
ceased operation. New York's regulations are similar to the proposed
EPA standards in that they require the use of add-on air pollution
control systems or use of an alternative waste disposal approach. While
these State regulations have increased the cost of waste disposal, it
appears that the availability of alternatives to onsite incineration
has mitigated the economic impacts that might have been associated with
the State regulations.
One concern that has recently been raised related to switching away
from onsite incineration is the availability of alternatives to onsite
incineration. Two common alternatives are offsite contract disposal
(most commonly commercial medical waste incineration) and onsite
autoclaving (steam treatment). Other less common alternatives include
onsite chemical treatment and onsite microwave irradiation. The
commercial medical waste disposal industry believes that there
presently exists sufficient offsite capacity to treat the waste that
would no longer be treated onsite. In addition, autoclaves and other
onsite waste disposal options are available. In fact, even today in the
absence of Federal regulations, most facilities that generate medical
waste do not operate onsite MWI's. This indicates that there currently
are viable alternatives to onsite incineration.
A second concern regrading a shift away from onsite incineration is
the increased transportation and handling of untreated medical waste.
However, the Department of Transportation (DOT) has promulgated
regulations (49 CFR parts 171, 172, and 173) that address the safe
transportation and handling of medical waste. The DOT regulations
include provisions for packaging and labeling of medical waste. Also,
the Occupational Safety and Health Administration (OSHA) promulgated
regulations on December 5, 1991 (29 CFR part 1910) that address
occupational exposure to bloodborne pathogens. Using a combination of
engineering and work practice controls, personal protective clothing
and equipment, training, medical follow-up of exposure incidents,
vaccinations (where appropriate) and other provisions, the OSHA
regulations minimize or eliminate health risk as a result of
occupational exposure to bloodborne pathogens. The Agency believes
these DOT and OSHA regulations will provide sufficient protection from
potential increases in exposure to these wastes.
A. Air Impacts
As discussed earlier, impacts are presented assuming the more
likely ``switching scenario.'' Baseline emissions and emissions under
the proposed NSPS based on the switching scenario are presented in
Tables 7a and 7b.
Table 7a.--Baseline Emissions Compared With Emissions After NSPS (With
Switching)
[Metric Units]
------------------------------------------------------------------------
After
Pollutant Units Baseline NSPS with
switching
------------------------------------------------------------------------
PM................................... Mg/yr..... 1,670 81.7
CO................................... Mg/yr..... 1,630 61.7
CDD/CDF.............................. kg/yr..... 21.7 0.032
HCl.................................. Mg/yr..... 10,000 230
SO2.................................. Mg/yr..... 192 144
NOX.................................. Mg/yr..... 1,240 944
Pb................................... Mg/yr..... 19.2 0.29
Cd................................... Mg/yr..... 1.38 0.042
Hg................................... Mg/yr..... 14.5 1.10
------------------------------------------------------------------------
[[Page 10664]]
Table 7b.--Baseline Emissions Compared With Emissions After NSPS (With
Switching)
[English Units]
------------------------------------------------------------------------
After NSPS
Pollutant Units Baseline with
switching
------------------------------------------------------------------------
PM................................ Tons/yr..... 1,850 90.0
CO................................ Tons/yr..... 1,790 68.0
CDD/CDF........................... Lb/yr....... 47.9 0.070
HCl............................... Tons/yr..... 11,100 254
SO2............................... Tons/yr..... 212 159
NOX............................... Tons/yr..... 1,370 1,040
Pb................................ Tons/yr..... 21.2 0.32
Cd................................ Tons/yr..... 1.52 0.046
Hg................................ Tons/yr..... 16.0 1.21
------------------------------------------------------------------------
The proposed standards would reduce nationwide emissions of PM by
1,590 megagrams per year (Mg/yr) (1,750 tons per year (tons/yr)) from
estimated emission levels under the typical existing control or the
``regulatory baseline'' of 1,670 Mg/yr (1,850 tons/yr). This reduction
represents a decrease of about 95 percent from baseline PM emission
levels in the absence of the proposed standards.
Nationwide emissions of CO would be reduced by 1,570 Mg/yr (1,730
tons/yr) from estimated emission levels under the regulatory baseline
of 1,630 Mg/yr (1,790 tons/yr). This reduction equates to an overall
control level of about 96 percent for CO emissions.
As a result of today's proposal, nationwide emissions of CDD/CDF
would be reduced by 21.70 kilograms per year (kg/yr) (47.8 pounds per
year (lb/yr)) from estimated emission levels under the regulatory
baseline of 21.73 kg/yr (47.9 lb/yr). The CDD/CDF emissions would be
reduced by over 99 percent from the regulatory baseline.
The proposed standards would reduce nationwide emissions of HCl by
9,820 Mg/yr (10,800 tons/yr) from estimated emission levels under the
regulatory baseline of 10,000 Mg/yr (11,100 tons/yr). This reduction
represents a decrease of about 98 percent in HCl emissions.
Nationwide emissions of SO2 and NOX would be reduced by
48.1 Mg/yr (53.0 tons/yr) and 300 Mg/yr (331 tons/yr), respectively,
from estimated emission levels under the regulatory baseline of 192 Mg/
yr (212 tons/yr) for SO2 and 1,240 Mg/yr (1,370 tons/yr) for
NOX. These reductions equate to an overall emissions decrease of
about 25 percent for SO2 and about 24 percent for NOX.
As a result of today's proposal, the nationwide emissions of Pb,
Cd, and Hg would be reduced by 18.9 Mg/yr (20.9 tons/yr), 1.34 Mg/yr
(1.47 tons/yr), and 13.4 Mg/yr (14.8 tons/yr), respectively, from
estimated emission levels under the regulatory baseline of 19.2 Mg/yr
(21.2 tons/yr) for Pb, 1.38 Mg/yr (1.52 tons/yr) for Cd, and 14.5 Mg/yr
(16.0 tons/yr) for Hg. These reductions equate to overall control
levels of about 98 percent for Pb, 97 percent for Cd, and 92 percent
for Hg.
B. Water and Solid Waste Impacts
Under the proposed NSPS, no significant water pollution impacts are
projected because the emission control technologies on which the
emission limits are based do not produce a wastewater stream. However,
to the extent that wet scrubber systems could be used to comply with
the proposed emission limitations, water pollution impacts could be
more significant. As discussed in section VI of this preamble, the
Agency solicits information regarding water pollution impacts
associated with the use of wet scrubber systems.
With regard to solid waste impacts, about 421,000 Mg (464,000 tons)
of medical waste are projected to be burned annually in new MWI's in
the fifth year after adoption of the NSPS in the absence of Federal
regulations (i.e., at the regulatory baseline). This quantity of waste
burned would result in about 42,100 Mg/yr (46,400 tons/yr) of solid
waste (bottom ash) disposed of in landfills. The addition of acid gas
control using dry lime injection, and CDD/CDF and Hg control using
activated carbon injection, would increase the quantity of solid waste
for final disposal by adding baghouse ash to the amount of bottom ash
already generated under the regulatory baseline. In addition, switching
to onsite alternatives to incineration will result in an increase in
solid waste for final disposal because the nonincineration treatment
methods do not reduce the volume of waste as much as incineration.
Under the switching scenario, the amount of solid waste ultimately
sent to landfills would increase by about 135,000 Mg/yr (149,000 tons/
yr). This includes the increase in ash from the air pollution control
devices (APCD's) and the increase in waste that is treated and
landfilled without being incinerated. Compared to municipal waste,
which is disposed in landfills at an annual rate of over 91 million Mg/
yr (100 million tons/yr), the increase in solid waste from the
implementation of the MWI standards is insignificant. Therefore, no
adverse solid waste impacts are anticipated under the proposed
standards.
C. Energy Impacts
The emission control technologies upon which the emission limits
are based would require additional energy consumption for all new
MWI's. Under the switching scenario, it is not clear whether energy
consumption will increase, decrease, or remain the same. Alternatives
to incineration require energy to operate. However, information is not
available to estimate whether alternatives use more or less energy than
MWI's. It is expected that the increase in energy consumption resulting
from the switching scenario will be less than the increase under the
no-switching scenario.
The estimates of energy impacts assuming all new MWI's are
constructed and install air pollution control (no-switching scenario)
include additional auxiliary fuel (natural gas) for combustion controls
and additional electrical energy for operation of the add-on control
devices. In the fifth year after adoption, the proposed standards would
increase total national usage of natural gas by about 25 million cubic
meters per year (MMm3/yr) (895 million cubic feet per year
(106 ft3/yr)) compared to fuel consumption determined from
the regulatory baseline. Total national usage of electrical energy
would increase by about 41,400 megawatt hours per year (MW-hr/yr) (141
billion British thermal units per year (109 Btu/yr)) of
electricity compared to electrical energy consumption determined from
the regulatory baseline.
D. Control Cost Impacts
The control cost impacts on individual facilities will vary
depending on the cost of compliance with the regulation; the cost of
alternative treatment and disposal methods; and other factors such as
proximity to an offsite contract disposal facility, liability issues
related to the transportation and final disposal of the waste, and
State and local medical waste treatment and disposal requirements. In
general, facilities requiring a smaller waste treatment capacity will
have a greater incentive to use a less expensive treatment and disposal
option because their onsite incineration cost (per ton of waste burned)
will be higher. Facilities with larger amounts of waste to be treated
may have some cost advantages if they use lower cost alternatives, but
these advantages are not as significant due to economies of scale.
Under the switching scenario, the nationwide annual costs
associated with the NSPS will increase by about 74.5 million/yr (from a
baseline cost of 63.3 [[Page 10665]] million/yr). The nationwide
annualized cost of waste disposal per unit of medical waste treated
would increase by $177/Mg ($161/ton) from the estimated nationwide
annualized cost of $150/Mg ($136/ton) under the regulatory baseline.
E. Economic Impacts
The goal of the economic impact analysis was to estimate the market
response to the NSPS and to determine whether there would be adverse
impacts associated with the proposed standards. The proposed standards
would affect five major industry sectors (hospitals, nursing homes,
veterinary facilities, commercial research laboratories, and commercial
medical waste incineration facilities) within which some facilities
operate an onsite MWI. In addition, the proposed standards would affect
a number of other industry sectors in which facilities do not typically
operate an onsite MWI (e.g., blood banks). The economic impact analysis
for new MWI's examined each of these sectors as a whole to determine
industrywide impacts.
To assess the industrywide impacts of control costs, the market
price increase resulting from the proposed standards was estimated for
each regulated industry. The market price increases, presented in Table
8, may be thought of as an average price increase across each industry
required to recover control costs within each industry. Table 8
reflects the more likely switching scenario. For example, under the
switching scenario, the hospital industry would have to raise prices by
an average of about 0.03 percent (over current revenues of about $224
billion/yr) to cover the increased cost of waste disposal. This table
shows that the price increase is relatively small for each industry.
This result is mainly due to the projection that most facilities do not
(or will not, within the next 5 years after adoption of the standards)
operate an onsite incinerator.
Table 8.--Market Price Increases in the Major Industry Sectors Under the
NSPS--Switching Scenario
------------------------------------------------------------------------
Price
Industry increase,
percent
------------------------------------------------------------------------
Hospitals................................................... 0.03
Nursing Homes............................................... 0.01
Veterinary Facilities....................................... 0.01
Commercial Research Laboratories............................ 0.03
Physicians' Offices......................................... 0
Dentists' Offices........................................... 0
Freestanding Bloodbanks..................................... 0.02
Commercial Medical Waste Incineration Facilities............ aN/A
------------------------------------------------------------------------
aIndustrywide impacts were not calculated for commercial medical waste
incineration facilities because estimates of the change in demand for
commercial medical waste incineration were not available. However,
this industry is expected to be able to recoup all control cost
increases through price increases.
Output, employment, and revenue impacts were also estimated. As a
result of the low market price increases and/or relatively inelastic
demand, the corresponding decreases in output, employment, and revenue
were also low, never exceeding 0.05 percent under the more likely
switching scenario. This result implies that no medical waste-
generating industry would need to be significantly reconstructed (e.g.,
through closures or consolidations) as a result of the proposed
standards.
IV. Impacts of the Proposed Guidelines for Existing MWI's
This section presents a description of the air, water, solid waste,
energy, control cost, and economic impacts of today's proposed
guidelines. All impacts are nationwide impacts that are expected to
result from the implementation of the emission guidelines. As discussed
below, it is expected that as many as 80 percent of existing facilities
currently using onsite incineration will switch to an alternative
method of treatment and disposal to avoid the increased cost of
installing air pollution control equipment. Therefore, impacts are
presented assuming 80 percent of existing facilities using onsite MWI's
will switch to a lower cost alternative treatment and disposal methods
(i.e., the ``switching scenario'').
Onsite incineration is only one of several medical waste treatment
and disposal options, and for some MWI's, the cost of the equipment
necessary to comply with the proposed emission guidelines will make
onsite incineration more expensive than other treatment and disposal
options. Consequently, many facilities that currently operate onsite
MWI's are likely to switch to a less expensive method of treatment and
disposal. The EPA expects that as many as 80 percent of the existing
facilities currently using onsite MWI's will switch to a lower cost
alternative method of treatment and disposal if the guidelines are
promulgated as proposed. This is referred to in this notice as the
``switching scenario'' because of the expectation that owners of MWI's
will switch to another method of waste treatment and disposal.
Recent experience at the State level confirms that switching to
lower cost alternatives is a likely impact of the implementation of MWI
regulations that require add-on air pollution control. For example,
recent regulations adopted by the State of New York require the use of
add-on acid gas scrubber systems. As a result, the State estimates that
as many as 90 percent of previously existing MWI's in New York have
ceased operation. New York's regulations are similar to the proposed
EPA guidelines in that they require the use of add-on air pollution
control systems or use of an alternative waste disposal approach. While
these State regulations have increased the cost of waste disposal, it
appears that the availability of alternatives to onsite incineration
has mitigated the economic impacts that might have been associated with
the State regulations.
One concern that has recently been raised related to switching away
from onsite incineration is the availability of alternatives to onsite
incineration. Two common alternatives are offsite contract disposal
(most commonly commercial medical waste incineration) and onsite
autoclaving (steam treatment). Other less common alternatives include
onsite chemical treatment and onsite microwave irradiation. The
commercial medical waste disposal industry believes that there
presently exists sufficient offsite capacity to treat the waste that
would no longer be treated onsite. In addition, autoclaves and other
onsite waste disposal options are available. In fact, even today in the
absence of Federal regulation, most facilities that generate medical
waste do not operate onsite MWI's. This indicates that there currently
are viable alternatives to onsite incineration.
A second concern regarding a shift away from onsite incineration is
the increased transportation and handling of untreated medical waste.
However, the Department of Transportation (DOT) has promulgated
regulations (49 CFR parts 171, 172, and 173) that address the safe
transportation and handling of medical waste. The DOT regulations
include provisions for packaging and labeling of medical waste. Also,
the Occupational Safety and Health Administration (OSHA) has
promulgated regulations on December 5, 1991 (29 CFR part 1910) that
address occupational exposure to bloodborne [[Page 10666]] pathogens.
Using a combination of engineering and work practice controls, personal
protective clothing and equipment, training, medical follow-up of
exposure incidents, vaccinations (where appropriate) and other
provisions, the OSHA regulations minimize or eliminate health risk as a
result of occupational exposure to bloodborne pathogens. The EPA
believes these DOT and OSHA regulations will provide sufficient
protection from potential increases in exposure to those wastes.
A. Air Impacts
As discussed earlier, impacts are presented assuming the more
likely ``switching scenario.'' Baseline emissions and emissions under
the proposed EG based on the switching scenario are presented in Tables
9a and 9b.
Table 9a.--Baseline Emissions Compared With Emissions After
Implementation of the Emission Guidelines (With Switching)
[Metric Units]
------------------------------------------------------------------------
After EG
Pollutant Units Baseline with
switching
------------------------------------------------------------------------
PM.................................. Mg/yr..... 11,300 272
CO.................................. Mg/yr..... 13,100 207
CDD/CDF............................. kg/yr..... 285 0.11
HC1................................. Mg/yr..... 41,200 777
SO2................................. Mg/yr..... 766 479
Nox................................. Mg/yr..... 5,040 3,160
Pb.................................. Mg/yr..... 77.5 0.97
Cd.................................. Mg/yr..... 5.62 0.14
Hg.................................. Mg/yr..... 58.6 3.67
------------------------------------------------------------------------
Table 9b.--Baseline Emissions Compared With Emissions After
Implementation of the Emission Guidelines (With Switching)
[English Units]
------------------------------------------------------------------------
After EG
Pollutant Units Baseline with
switching
------------------------------------------------------------------------
PM................................ Tons/yr..... 12,400 300
CO................................ Tons/yr..... 14,500 228
CDD/CDF........................... Lb/yr....... 628 0.23
HC1............................... Tons/yr..... 45,400 857
SO2............................... Tons/yr..... 844 528
NOx............................... Tons/yr..... 5,560 3,490
Pb................................ Tons/yr..... 85.5 1.07
Cd................................ Tons/yr..... 6.20 0.16
Hg................................ Tons/yr..... 64.6 4.05
------------------------------------------------------------------------
The proposed guidelines would reduce nationwide emissions of PM by
11,000 megagrams per year (Mg/yr) (12,100 tons per year (tons/yr)) from
the estimated emission levels under the typical existing control or the
``regulatory baseline'' of 11,300 Mg/yr (12,400 tons/yr). This
reduction represents an overall decrease of about 98 percent of
baseline PM emission levels in the absence of the proposed emission
guidelines.
Nationwide emissions of CO would be reduced by 12,900 Mg/yr (14,200
tons/yr) from the estimated emission levels under the regulatory
baseline of 13,100 Mg/yr (14,500 tons/yr). This reduction represents an
overall control level of about 98 percent for CO emissions.
The proposed guidelines would reduce nationwide emissions of
dioxins/furans by 284.8 kilograms per year (kg/yr) (627.9 pounds per
year (lb/yr)) from the estimated emission levels under the regulatory
baseline of 284.9 kg/yr (628.1 lb/yr). Dioxin/furan emissions would be
reduced by over 99 percent from the regulatory baseline.
Nationwide emissions of HCl would be reduced by 40,400 Mg/yr
(44,600 tons/yr) from the estimated emission levels under the
regulatory baseline of 41,200 Mg/yr (45,400 tons/yr). This reduction
represents a decrease of about 98 percent in HCl emissions from the
regulatory baseline.
Nationwide emissions of SO2 and NOX would be reduced by
287 Mg/yr (316 tons/yr) and 1,880 Mg/yr (2,070 tons/yr), respectively,
from the estimated emission levels under the regulatory baseline of 766
Mg/yr (844 tons/yr) for SO2 and 5,040 Mg/yr (5,560 tons/yr) for
NOX. These reductions equate to an overall emissions decrease of
about 37 percent for both SO2 and NOX.
As a result of today's proposal, nationwide emissions of Pb, Cd,
and Hg would be reduced by 76.6 Mg/yr (84.4 tons/yr), 5.48 Mg/yr (6.04
tons/yr), and 54.9 Mg/yr (60.5 tons/yr), respectively, from the
estimated emission levels under the regulatory baseline of 77.5 Mg/yr
(85.5 tons/yr) for Pb, 5.62 Mg/yr (6.20 tons/yr) for Cd, and 58.6 Mg/yr
(64.6 tons/yr) for Hg. These reductions equate to overall control
levels of about 99 percent for Pb, 97 percent for Cd, and 94 percent
for Hg.
B. Water and Solid Waste Impacts
Under the proposed guidelines, no significant water pollution
impacts are projected because the emission control technologies upon
which the emission limits are based do not produce a wastewater stream.
However, to the extent that wet scrubber systems could be used to
comply with the proposed emission limitations, water pollution impacts
could be more significant. As discussed in section VI of this notice,
the Agency solicits information regarding water pollution impacts
associated with the use of wet scrubber systems.
With regard to solid waste impacts, about 1.43 million Mg (1.58
million tons) of medical waste are burned annually in existing MWI's
producing about 143,000 Mg/yr (158,000 tons/yr) of solid waste (bottom
ash) disposed of in landfills. The addition of acid gas control using
dry lime injection, and CDD/CDF and Hg control using activated carbon
injection, would increase the quantity of solid waste for final
disposal by adding baghouse ash to the amount of bottom ash already
generated under the regulatory baseline. In addition, switching to
onsite alternatives to incineration would result in an increase in
solid waste for final disposal because the nonincineration treatment
methods do not reduce the volume of waste as much as incineration.
Under the switching scenario, the amount of solid waste ultimately
sent to landfills would increase by about 631,000 Mg/yr (696,000 tons/
yr). This quantity includes the increase in ash from the APCD's and the
increase in waste that is treated and landfilled without being
incinerated. Compared to municipal waste, which is disposed in
landfills at a rate of over 91 million Mg/yr (100 million tons/yr), the
increase in solid waste from the implementation of the MWI emissions
guidelines is insignificant. Therefore, no adverse solid waste impacts
are anticipated under the proposed guidelines.
C. Energy Impacts
The emission control technologies upon which the emission limits
are based would require additional energy consumption for all existing
MWI's. Under the switching scenario, it is not clear whether energy
consumption will increase, decrease, or remain the same. Alternatives
to incineration require energy to operate. However, information is not
available to estimate whether alternatives use more or less energy than
MWI's. It is expected that the increase in energy consumption resulting
from the switching scenario will be less than the increase under the
no-switching scenario.
The estimates of energy impacts assuming all existing MWI's install
air pollution control (no-switching scenario) include additional
auxiliary fuel for combustion controls and additional electrical energy
for operation of the add-on control devices. The proposed guidelines
would increase total national usage of natural gas for combustion
controls by about 100 million cubic meters per year (MMm3/
[[Page 10667]] yr) (3,490 million cubic feet per year (106
ft3/yr)) compared to fuel consumption determined from the
regulatory baseline. Total national usage of electrical energy for the
operation of add-on control devices would increase by about 175,000
megawatt hours per year (MW-hr/yr) (599 billion British thermal units
per year (109 Btu/yr)) of electricity compared to energy
consumption determined from the regulatory baseline.
D. Control Cost Impacts
The control cost impacts on individual facilities will vary
depending on the cost of compliance with the guidelines; the cost of
alternative treatment and disposal methods; and other factors such as
proximity to an offsite contract disposal facility, liability issues
related to the transportation and final disposal of the waste, and
State and local medical waste treatment and disposal requirements. In
general, facilities requiring a smaller waste treatment capacity will
have a greater incentive to use a less expensive treatment and disposal
option because their onsite incineration cost (per ton of waste burned)
will be higher. Facilities with larger amounts of waste to be treated
may have some cost advantages if they use a lower cost alternative, but
these advantages are not as significant due to economies of scale.
Under the switching scenario, the nationwide annual costs
associated with the proposed emission guidelines will increase by about
$351 million/yr. The nationwide annual cost of waste disposal per unit
of medical waste treated would increase by $245/Mg ($222/ton) to a
total cost of $430/Mg ($390/ton) from the estimated nationwide
annualized cost of $185/Mg ($168/ton) under the regulatory baseline.
E. Economic Impacts
The goal of the economic impact analysis was to estimate the market
response to the emission guidelines and determine whether there would
be adverse impacts associated with the proposed guidelines. The
proposed guidelines would affect five major industry sectors
(hospitals, nursing homes, veterinary facilities, commercial research
laboratories, and commercial medical waste incineration facilities)
within which some facilities operate an onsite MWI. In addition, the
proposed guidelines would affect a number of other industry sectors in
which facilities do not typically operate an onsite MWI (e.g.,
bloodbanks). The economic impact analysis for existing MWI's examined
each of these sectors as a whole to determine industry wide impacts.
To assess the industrywide impacts of control costs, the market
price increase resulting from the proposed guidelines was estimated for
each regulated industry. The market price increases, presented in Table
10, may be thought of as an average price increase across each industry
required to recover control costs within each industry. Table 10
reflects the more likely switching scenario. For example, under the
switching scenario, the hospital industry would have to raise prices by
an average of about 0.1 percent (over current revenues of about $224
billion/year) to cover the increased cost of waste disposal. This table
shows that the price increase is relatively small for each industry.
This result is mainly due to the fact that the majority of the
facilities in each industry sector do not operate an onsite
incinerator.
Table 10.--Market Price Increased in the Major Industry Sectors Under
the Emission Guidelines--Switching Scenario
------------------------------------------------------------------------
Price
Industry increase,
percent
------------------------------------------------------------------------
Hospitals................................................... 0.1
Nursing Homes............................................... 0.1
Veterinary Facilities....................................... 0.6
Commercial Research Laboratories............................ 0.4
Physicians' Offices......................................... 0
Dentists' Offices........................................... 0
Freestanding Bloodbanks..................................... 0.1
Commercial Medical Waste Incineration Facilities............ \9\N/A
------------------------------------------------------------------------
\9\Industrywide impacts were not calculated for commercial medical waste
incineration facilities because estimates of the change in demand for
commercial medical waste incineration were not available. However,
this industry is expected to be able to recoup all control cost
increases through price increases.
Output, employment, and revenue impacts were also estimated. As a
result of the low market price increases and/or relatively inelastic
demand, the corresponding decreases in output, employment, and revenue
were also low, never exceeding 1 percent under the more likely
switching scenario. This result implies that no medical waste-
generating industry would need to be significantly restructured (e.g.,
through closures or consolidations) as a result of the proposed
emission guidelines.
V. Rationale for the Proposed Standards and Guidelines
A. Background
An estimated 3.4 million tons of waste are produced annually by
medical waste generators in the United States. Hospitals are the single
largest generator of medical waste, producing over 70 percent of the
annual total. Approximately 5,000 MWI's are believed to exist
nationwide (3,700 burning general medical waste and 1,300 burning
pathological waste). Over 60 percent of these MWI's are found at
hospitals. Medical waste incinerators are also found at commercial
medical waste disposal facilities, research laboratories, nursing
homes, and veterinary facilities. Based on historic sales data, an
estimated 700 new MWI's will be installed over the next 5 years.
Medical waste incinerators are subject to State and local
regulations that vary widely both in format and scope. A survey in
April 1990 showed that in 38 States, regulations or permit guidelines
specific to MWI's were either in place or were in the planning stages.
The remainder of the States regulate MWI's under general incinerator
requirements, which typically are less stringent that those specific to
MWI's. The most common State requirements for MWI's are limits for PM,
HCl, and secondary chamber temperature and residence time. Some States
also regulate metals, CDD/CDF, and CO. About one third of the States
require operator training.
On November 1, 1988, the Medical Waste Tracking Act (MWTA) was
signed by Congress. The MWTA required EPA to establish a 2-year
demonstration program to track medical waste from its origin to its
disposal. In early 1989, EPA established this program in 40 CFR 259.
The program was in effect from June 22, 1989, to June 22, 1991, and
applied to the States of New York, New Jersey, Connecticut, and Rhode
Island, and to Puerto Rico. The MWTA required EPA to prepare a series
of Reports to Congress on medical waste and the demonstration program.
Now that the demonstration program has concluded, Congress will decide
if a medical waste tracking program should be implemented nationwide.
The current air emissions standards development effort for MWI's
was initiated in 1989. The data-gathering effort was designed to take
advantage of information gathered under the auspices of the MWTA. Also,
in 1989, an MWI operator training course and manual were developed with
recommendations on the proper operation and maintenance of MWI's.
The Amendments of 1990 added section 129 to the Act. Section 129
specifically addresses development of standards for MWI's. Section 129
requires EPA to establish an NSPS for new MWI's and emission guidelines
for existing MWI's that combust hospital [[Page 10668]] waste, medical
waste, and infectious waste. The standards and guidelines must specify
numerical emission limitations for the following: PM, opacity,
SO2, HCl, NOX, CO, Pb, Cd, Hg, and CDD/CDF. Section 129 also
includes requirements for operator training as well as siting
requirements for new MWI's.
The standards and guidelines must reflect MACT ``* * * the maximum
degree of reduction in emissions of air pollutants * * * that the
Administrator, taking into consideration the cost of achieving such
emission reduction, any nonair quality health and environmental impacts
and energy requirements, determines is achievable * * *'' Section 129
states that ``The degree of reduction in emissions that is deemed
achievable for new units in a category shall not be less stringent than
the emissions control that is achieved in practice by the best-
controlled similar unit * * *'' Also section 129 requires that
``Emissions standards for existing units in a category may be less
stringent than standards for new units in the same category but shall
not be less stringent than the average emissions limitation achieved by
the best performing 12 percent of units in the category * * *'' The
standards and guidelines must be no less stringent than these levels of
emission control currently achieved. These levels are referred to as
the MACT floor.
B. Selection of Source Category
Section 129 of the Act directs the EPA to issue standards and
guidelines pursuant to section 111 for solid waste incineration units
combusting hospital waste, medical waste, and infectious waste (i.e.,
MWI's). An MWI is defined as any device that burns medical waste, with
or without other types of waste (e.g., municipal solid waste [MSW]) and
with or without heat recovery.
Medical waste is defined pursuant to the Solid Waste Disposal Act
as codified in 40 CFR 259 subpart B as any solid waste that is
generated in the diagnosis, treatment, or immunization of human beings
or animals, in research pertaining thereto, or in the production or
testing of biologicals. Medical waste consists of, but is not limited
to, the following types of materials:
1. Sharps (e.g., hypodermic and suture needles, scalpel blades,
syringes, pipettes, vials, other types of broken or unbroken glassware,
etc.);
2. Fabrics (e.g., gauze, garments, bandages, swabs, etc.);
3. Plastics (e.g., trash bags, sharps containers, IV bags, tubes,
specimen cups, etc.);
4. Paper (e.g., disposable gowns, sheets, etc.; premoistened
towels; paper towels; etc.);
5. Waste chemicals/drugs that are not RCRA hazardous waste (e.g.,
lab chemicals, leftover and out-of-date drugs, disinfectants, etc.);
and
6. Pathological waste (e.g., human and animal body parts and
tissue).
Medical waste does not include any hazardous waste identified or
listed under 40 CFR 261, or any household waste as defined in 40 CFR
261.4(b)(1). On the other hand, mixtures of medical waste with
hazardous waste or household waste would be considered medical waste
for the purposes of these proposed standards and guidelines. The
definition of household waste includes waste generated at single and
multiple residences. Nursing homes or retirement homes with a health
care facility could be considered multiple residences. For the purpose
of the proposed standards and guidelines, the definition of medical
waste includes waste materials that meet the definition of medical
waste and are generated by retirement homes/nursing homes.
Medical waste also does not include human and animal remains that
are not generated as medical waste. A device that burns solely human or
animal remains (and the caskets or containers carrying the remains, or
the bedding included with the animal remains) for the purpose of
cremation is not an MWI and, therefore, is not subject to the
requirements of the standards and guidelines. For example, a facility
that burns the remains of animals that have been euthanized at animal
shelters and animal hospitals is not an MWI because the remains are not
considered medical waste. On the other hand, a facility that burns
human and/or animal remains that are generated as medical waste or a
facility that burns general medical waste in addition to human and/or
animal remains is an MWI and is subject to the standards and
guidelines. For example, a facility that burns the remains of research
laboratory rats is an MWI because the remains are considered medical
waste (they are generated in research pertaining to the diagnosis,
treatment, or immunization of human beings or animals or in the
production or testing of biologicals).
The range of waste types included in this definition is broader
than that defined in the now expired Medical Waste Tracking Act (40 CFR
part 259) as Regulated Medical Waste. Regulated Medical Waste consisted
of seven categories of medical waste based on potential for infection
or aesthetic concerns. The definition of medical waste in this proposal
classifies medical waste more broadly based on materials' composition.
Consequently, the estimated amount of waste generated by medical waste
generators (3.4 million tons/yr) and the estimated amount of waste
burned in medical waste incinerators (1.8 million tons/yr) is greater
than the Medical Waste Tracking Act estimated amount of Regulated
Medical Waste generated (922,000 tons/yr). It has been suggested that
EPA's definition of medical waste in this proposal is inappropriate.
The EPA specifically requests comment on the definition of medical
waste as applied to the regulation of medical waste incinerators.
Most MWI's burn a diverse mixture of medical waste (referred to in
this preamble as general medical waste), which may include some
pathological waste (human and animal body parts and/or tissue). Most of
the materials that make up the general medical waste stream burn
readily, and given the proper conditions, will continue to burn once
they are ignited. Metal and glass sharps do not burn but also do not
greatly impede combustion of other materials. Pathological waste has a
very high moisture content and will not support self-sustained
combustion but will burn if adequate heat is applied to drive off
excess moisture. As a result, larger amounts of pathological waste
require special operating conditions for combustion. Thus, some
facilities maintain MWI's designed and operated to burn pathological
waste exclusively.
Because of differences in waste composition and the combustion
process, uncontrolled emissions from pathological MWI's contain
significantly lower levels of the pollutants of concern for this source
category than uncontrolled emissions from general medical waste
incinerators. General medical waste typically contains more metals and
chlorine than does pathological waste, resulting in higher emissions of
metals and HCl from general medical waste incinerators than from
pathological incinerators. For example, typical uncontrolled Hg
emissions are about 3.1 mg/dscm for general medical waste incinerators
and about 0.05 mg/dscm for pathological MWI's. Overall pollutant
emissions from pathological MWI's represent less than 3 percent of the
uncontrolled nationwide emissions from MWI's burning general medical
waste.
Additionally, onsite alternatives to incineration are available for
the treatment of general medical waste, while most of these
technologies are not applicable to the treatment of purely pathological
waste. As a result, pathological MWI's are more likely to
[[Page 10669]] face adverse economic impacts associated with
installation of pollution control equipment, while general medical
waste incinerators could use available alternatives to incineration.
For these reasons, the proposed standards and guidelines focus on
regulating emissions from general medical waste incinerators and
include very minor requirements for pathological MWI's. Under the
proposed standards and guidelines, pathological MWI's would only be
required to submit quarterly reports of the amount and type of
materials charged to the incinerator.
Finally, in addition to developing standards and guidelines for
medical waste incinerators, section 129 of the Act directs the EPA to
develop standards and guidelines for municipal waste incinerators,
commercial or industrial waste incinerators, and other categories of
solid waste incinerators. The Agency intends to consider pathological
incinerators (along with crematory incinerators) when evaluating the
category of other solid waste incinerators for regulation.
C. Modification of Existing MWI's
Previously, the terms ``modification'' and ``reconstruction'' were
defined under sections 60.14 and 60.15 of subpart A of part 60. Section
129 of the Act has specified a new definition of ``modified'' that
combines and revises the previous definitions of ``modification'' and
``reconstruction.'' Specifically, ``modified'' refers to:
(1) modifications for which the
* * * cumulative costs of the modifications, over the life of the
unit, exceed 50 per centum of the original cost of the construction and
installation of the unit (not including the cost of any land purchased
in connection with such construction or installation) updated to
current costs * * *
or (2) modification involving
* * * a physical change in or change in the method of operation of
the unit which increases the amount of any air pollutant emitted by the
unit for which standards have been established under [section 129] or
sections 111 * * *.
A special provision has been included in the proposed NSPS and
emission guidelines to address certain modifications to existing
facilities. This provision states that if an existing MWI is modified
for the purpose of meeting the requirements of the proposed guidelines
for existing MWI's or State regulations developed to implement these
guidelines, then the MWI would not be considered a ``modified'' MWI and
would not be subject to the NSPS (40 CFR part 60, subpart Ec).
On the other hand, if the existing facility is modified in ways not
required to meet the emission guidelines, then the facility could be
considered a ``modified'' MWI and could become subject to the NSPS. For
example, if an existing pathological MWI, which was not originally
designed to accommodate general medical waste, begins burning general
medical waste, then that MWI may be considered a modified MWI and, as a
result, will be subject to the NSPS.
D. Selection of Pollutants
Section 129 of the Act requires that the standards and guidelines
promulgated under sections 111 and 129 and applicable to all solid
waste incineration units shall specify numerical emission limitations
for the following substances or mixtures: PM (total and fine), opacity,
SO2, HCl, NOX, CO, Pb, Cd, Hg, and CDD/CDF. For this reason,
the MWI standards and guidelines specify numerical emission limits for
these pollutants.
E. Selection of Affected and Designated Facilities
As required by section 129 of the Act, the affected facility to
which the proposed new source performance standards apply is each
individual MWI for which construction is commenced after today's date
or for which modification is commenced after the effective date of
these standards. The designated facility to which the proposed emission
guidelines apply is each existing MWI for which construction commenced
on or before today's date. A facility that burns both municipal waste
and medical waste could be subject to both the municipal waste
combustor standards and guidelines and the medical waste incinerator
standards and guidelines.
F. Selection of Format for the Proposed Standards and Emission
Guidelines
The format selected for the proposed standards and guidelines is a
combination of emission limitations and percent reductions to ensure
control of emissions. The specific format of the proposed standards and
guidelines and the reasons for selection are discussed below.
As required by section 129 of the Act, the proposed standards and
guidelines would establish numerical emission limitations for PM, CO,
CDD/CDF, HCl, SO2, NOX, Pb, Cd, and Hg. For the purpose of
regulating PM and metals (Pb, Cd, and Hg) the format selected is a
numerical concentration limit in units of mg/dscm corrected to 7
percent oxygen. For the purpose of regulating Hg an alternative percent
reduction is also proposed. The numerical Hg emission limit reflects
the emission level that can be achieved based on a fabric filter (FF)
system with activated carbon injection. Emissions of Hg can be highly
variable and depend on the Hg input level. In cases where Hg levels are
temporarily elevated due to variability in the waste feed, the
numerical emission limit may not be consistently achievable. However,
the control device is capable of achieving 85 percent reduction of
elevated Hg levels.
Under the proposed standards and guidelines, CDD/CDF emissions are
measured in units of total ng/dscm or ng/dscm toxic equivalency (TEQ).
To arrive at the TEQ, measured emissions of each tetra- through octa-
CDD and CDF congener are multiplied by the corresponding toxic
equivalency factor (TEF) specified in the standards and guidelines (see
Table 6). The products are then added to obtain the total concentration
of CDD/CDF emitted in terms of TEQ.
For CO, SO2, NOX, and HCl, the proposed standards and
guidelines are volume concentrations corrected to 7 percent oxygen. For
HCl, an alternative percent reduction is also proposed. A percent
reduction is generally appropriate for acid gases emissions from MWI's.
However, in cases where inlet levels are very low and the specified
percent reduction would result in concentrations below the specified
volume concentration (42 ppmv, which is a 97 percent reduction from
typical uncontrolled emissions), these percent reductions may not be
achievable. Therefore, the proposed HCl emission limits would require
either a 97 percent reduction or a 42 ppmv HCl outlet concentration,
which is based on reduction from typical uncontrolled emission levels,
whichever is less stringent. An alternative percent reduction is not
proposed for emissions of SO2 because at the low inlet levels
associated with medical waste, EPA emission test data shows that acid
gases controls are not effective in reducing SO2 emissions and as
a result, SO2 limits are based on uncontrolled emissions.
Under the proposed standards and guidelines, emission limits for Hg
and HCl include stack concentrations as well as percent reductions. The
EPA is requesting comments on the appropriateness of including a
percent reduction along with a stack concentration limit in the
standards and guidelines for these two pollutants.
G. Selection of Classes, Types, and Sizes
Section 129 states that the Administrator may distinguish among
[[Page 10670]] classes, types, and sizes of units within a category in
establishing the standards and guidelines. In other words, EPA may
subcategorize the MWI source category in establishing standards and
guidelines. After reviewing the population of MWI's, the EPA believes
that, for the purpose of regulatory development and of determining
MACT, the MWI population should be divided into three subcategories:
(1) continuous MWI's, (2) intermittent MWI's, and (3) batch MWI's.
These three subcategories are based on differences in the design of the
MWI's as discussed in the following paragraphs.
In each of the design systems, sequential combustion operations
typically are carried out in two separate chambers: primary and
secondary. In the primary chamber, the waste is loaded and ignited, the
volatile organic components driven off, and the nonvolatile materials
combusted to ash. The volatile organic components released from the
primary chamber are combusted in the secondary chamber. Newer MWI's are
typically designed with 1-second (1-sec) residence time secondary
chambers; older MWI's were designed with smaller, 0.25-second (0.25
sec) residence time secondary chambers.
While there are similarities in the three design types of MWI's,
there are also key design differences that make each type unique. The
primary differences between the three design types of MWI's are the
methods of charging waste to and removing ash from the primary chamber.
These differences cause variations in the way the waste is burned and
in the pollutant emission profile for each MWI design type.
Continuous units, which are the largest of the three types, have
mechanical ram feeders and continuous ash removal systems. These
features allow the unit to operate 24 hours per day for many days at a
time. Continuous MWI's achieve steady-state operation in the beginning
of their operating cycle and maintain this mode of operation throughout
the remainder of the cycle. Waste is charged and ash is removed
simultaneously (i.e., on a continuous basis). During operation, waste
is burned at the same rate as it is charged into the unit, and
pollutant emission rates and primary and secondary chamber temperatures
tend to be relatively constant.
Most intermittent MWI's also have mechanical ram feeders that
charge waste into the primary chamber at about 5- to 10-minute
intervals. However, because there is no means for ash removal during
the burning phase of the operating cycle, the unit can only be operated
for a limited number of hours before the accumulation of ash in the
primary chamber requires the unit to be shut down for ash removal.
Intermittent units, which are usually much smaller than continuous
units, typically operate on a daily burn cycle of 10 to 14 hours. While
these units tend to approach steady-state operation during the middle
of their operating cycle, waste is normally being charged faster than
it is being burned. Primary chamber temperatures tend to climb
throughout the operating cycle until waste is no longer charged into
the unit. Because there is a significant accumulation of unburned
material in the primary chamber at the end of the charging period,
these units are designed with a burndown/cooldown phase. Generally,
pollutant emissions continue through this phase, which can continue for
several hours after charging has ceased.
The batch operating cycle consists of three phases: low-air, high-
air, and cooldown. All of the waste to be burned during a complete
cycle is loaded into the primary chamber before the unit begins
operation. Once the unit is filled with waste and the burning cycle
begins, the charging door is not opened again until the cycle is
complete and the unit is cool. This cycle normally takes 1 or 2 days,
depending on the size of the unit and the amount of waste charged.
During the low-air phase, temperatures in the primary chamber rise
slowly because combustion is occurring only on the surface of the waste
pile and because combustion air is restricted. When the high-air phase
begins, the temperatures climb more rapidly, more volatiles are exposed
to the flame front, and the combustion process quickens. Batch MWI's
tend to approach steady-state operation at the end of the low-air
phase, when the primary chamber temperature reaches the design
operating range. Pollutant emission rates also tend to increase in the
second half of the low-air phase, then level off, and continue steadily
during the high-air and cooldown phases. Pollutant concentrations
during the high-air phase of batch MWI's are similar to concentrations
during the charging period for continuous and intermittent units.
The differences in typical hours of operation, discussed above,
affect the potential for total emissions (on a mass basis) from each
MWI type. Continuous MWI's, which can accommodate waste charging for an
unrestricted length of time, will have the greatest potential emissions
because waste burning and subsequent emissions can occur continuously.
Intermittent MWI's, designed to accept waste charges at periodic
intervals for between 8 and 14 hours, will be limited in potential
emissions by periods of shutdown required to remove ash from the
incinerator. The hours of operation, limited by the time required to
remove ash, result in less potential emissions from intermittent MWI's
than from continuous MWI's. Batch MWI's are designed to burn only one
load of waste at a time. The operating cycle normally takes 1 or 2
days, depending on the size of the unit and the amount of waste
charged. Potential emissions from batch MWI's are lower than continuous
and intermittent MWI's because of the significant difference in the
total amount of waste burned over a given period of time.
Typical uncontrolled emission levels for each of the three
subcategories are presented in Tables 11a and 11b. Table 11a shows
uncontrolled emissions from new MWI's, while Table 11b shows
uncontrolled emissions from existing MWI's. These emission levels
reflect concentrations when the MWI is operating at steady-state
conditions, which include the high-air phase for the batch MWI and the
charging period for continuous and intermittent MWI's. As noted
elsewhere, the EPA specifically solicits comment on the determination
to distinguish between continuous, intermittent, and batch units.
Table 11a.--Typical Uncontrolled Emissions From New MWI's
------------------------------------------------------------------------
Pollutant Continuous Intermittent Batch
------------------------------------------------------------------------
PM, mg/dscm................... 300 300 300
CO, ppmv...................... 300 300 300
CDD/CDF, ng/dscm.............. 6,600 6,600 6,600
HCI, ppmv..................... 1,400 1,400 1,400
SO2, ppmv..................... 16 16 16
NOX, ppmv..................... 140 140 140
[[Page 10671]]
Pb, mg/dscm................... 4.2 4.2 4.2
Cd, mg/dscm................... 0.29 0.29 0.29
Hg, mg/dscm................... 3.1 3.1 3.1
------------------------------------------------------------------------
Table 11b.--Typical Uncontrolled Emissions From Existing MWI's
----------------------------------------------------------------------------------------------------------------
Continuous Continuous
Pollutant (0.25-sec) (1-sec) Intermittent Batch
----------------------------------------------------------------------------------------------------------------
PM, mg/dscm............................................. 570 300 570 570
CO, ppmv................................................ 690 300 690 690
CDD/CDF, ng/dscm........................................ 25,000 6,600 25,000 25,000
HCI, ppmv............................................... 1,400 1,400 1,400 1,400
SO2, ppmv............................................... 16 16 16 16
NOX, ppmv............................................... 140 140 140 140
Pb, mg/dscm............................................. 4.2 4.2 4.2 4.2
Cd, mg/dscm............................................. 0.29 0.29 0.29 0.29
Hg, mg/dscm............................................. 3.1 3.1 3.1 3.1
----------------------------------------------------------------------------------------------------------------
One specific approach which EPA is considering and on which EPA
requests comment is that of further subcategorizing batch and
intermittent MWI's by size or capacity to burn medical waste. Some have
suggested, for example, that EPA examine alternatives, such as
subcategorizing these categories into incinerators with capacities of
50 pounds per hour or less, 100 pounds per hour or less, 200 pounds per
hour or less, etc. A number of States have already established
subcategories based on size which exempt the smallest incinerators or
impose less stringent requirements on such incinerators. Current State
regulations, therefore, may provide a basis for further subcategorizing
the categories of batch and intermittent MWI's.
To fully consider subcategorization by size within the batch and
intermittent categories, however, a mechanism must be available to
accurately and consistently determine the capacity of an MWI. Only if
such a mechanism exists, will enforcement personnel, as well as owners
and operators of MWI's, be assured that MWI's are subject to a
consistent set of requirements.
The EPA believes this may be a serious problem. It appears there is
no common or widely used mechanism or ``standard'' within the MWI
industry for sizing or determining the capacity of an incinerator to
burn medical waste. As a result, it seems that one vendor's 50 pound
per hour capacity incinerator can be another vendor's 100 pound per
hour capacity incinerator. It also appears the same vendor may sell one
customer a 50 pound per hour capacity MWI and then sell another
customer the same incinerator as a 100 pound per hour MWI. The EPA
believes that a manufacturer's or vendor's ``nameplate capacity'' is
not an accurate and reliable means for determining the size or capacity
of an MWI.
The EPA recognizes that the composition of medical waste changes
across generators, over time, and in response to changes in waste
handling or recycling practices in a way that may affect the amount of
medical waste a specific incinerator is able to burn. For the purposes
of enforcing regulations that may vary by size or capacity, a common
mechanism or ``standard'' to measure or determine the capacity of MWI's
is necessary.
Consequently, EPA specifically requests comments on a mechanism or
``standard'' for accurately and consistently determining the capacity
of MWI's in the enforcement of whatever regulation might be adopted.
For example, the comments might outline the mechanisms or approaches
used by States to ensure all MWI's of the same capacity are subject to
the same requirements. Or, the comments may offer alternative measures
of capacity that serve as a better basis for identifying small
intermittent and/or small batch MWI's. Finally, the manufacturers may
choose to develop a voluntary approach providing a consistent measure
of rated capacity.
H. Performance of Technology
Medical waste incinerator emissions are mixtures of pollutants
including acid gases (HCl and SO2), NOX, CO, PM, CDD/CDF, and
metals (Pb, Cd, and Hg). There are basically two approaches to
controlling these emissions: combustion control and add-on air
pollution control. These approaches will be discussed in sections 1.
and 2. below.
The first approach, combustion control, can be broken down into
three levels that are based on the flue gas residence time in the
secondary chamber. These three levels are 0.25-sec combustion, 1-sec
combustion, and 2-sec combustion.
The second approach can be further broken down into various add-on
control systems, including wet systems, fabric filter systems without
activated carbon injection, and fabric filter systems with activated
carbon injection. The control of NOX will also be discussed under
add-on control systems.
One additional area that has been suggested for consideration is
waste segregation. This topic will be discussed in paragraph 3. of this
section.
1. Combustion Control
Combustion control includes the proper design, construction,
operation, and maintenance of an MWI to destroy or prevent the
formation of air pollutants prior to their release to the atmosphere.
Test data indicate that as secondary chamber residence time and
temperature increase, emissions decrease. Combustion control is most
effective in reducing CDD/CDF, PM, and CO emissions.
The 0.25-sec combustion level includes a minimum secondary chamber
temperature of 927 deg.C (1700 deg.F) and a 0.25-sec secondary
chamber residence time. These combustion conditions are typical of
older MWI's.
The 1-sec combustion level includes a minimum secondary chamber
temperature of 927 deg.C (1700 deg.F) and residence time of 1-sec.
These combustion conditions are typical of newer MWI's. Compared to
0.25-sec combustion, 1-sec combustion will achieve substantial
reductions in CDD/CDF and CO emissions, and will [[Page 10672]] provide
some control of PM, but will not reduce emissions of acid gases (HCl
and SO2), NOX, or metals (Pb, Cd, and Hg).
The 2-sec combustion level includes a minimum secondary chamber
temperature of 1800 deg.F and residence time of 2-sec. These combustion
conditions will provide additional control of CDD/CDF, CO, and PM, but
will not reduce emissions of acid gases (HCl and SO2), NOX,
or metals (Pb, Cd, and Hg). The 2-sec combustion conditions are
considered to be the best level of combustion control that is applied
to MWI's.
2. Add-On Control
Add-on control refers to various add-on air pollution control
systems used in addition to 2-sec combustion to capture pollutants as
they leave the incinerator. Add-on controls include wet systems, fabric
filter systems without activated carbon injection, and fabric filter
systems with activated carbon injection. Because Pb and Cd are
associated with PM in the flue gas and are removed by PM control
devices, these three pollutants are considered as a group when
evaluating MACT. Similarly, SO2 and HCl are considered together
because generally, they are both reduced using acid gas controls.
a. Wet systems. Wet systems include scrubbing systems such as a
venturi scrubber (VS) or a venturi scrubber followed by a packed-bed
absorber (VS/PB). Compared to combustion control, wet systems achieve
substantial reductions in HCl emissions, provide some control of Pb and
Cd, and further reduce PM and CDD/CDF emissions, but do not add to the
control of NOX, CO, or Hg. However, at the low SO2 levels
associated with MWI's, wet systems are not, in EPA's experience,
effective in reducing SO2 emissions. As discussed in section VI,
EPA requests comment on the performance and costs of wet scrubber
systems.
b. Fabric filter systems without carbon injection. Fabric filter
systems include a fabric filter followed by a packed bed absorber (FF/
PB), dry sorbent injection followed by a fabric filter (DI/FF), or a
spray dryer followed by a fabric filter (SD/FF). The SD/FF and the DI/
FF systems have the same performance based on EPA MWI test data. The
fabric filter alone was not examined because wet systems achieve
greater overall emission reduction at a lower cost.
Compared to wet systems, fabric filter systems generally provide
additional control of PM, Pb, and Cd, but do not add to the control of
acid gases, NOX, CO, or Hg. The performance of the three fabric
filter systems in reducing CDD/CDF emissions varies significantly.
Compared to combustion control, the DI/FF and SD/FF systems provide no
additional control of CDD/CDF, while formation of CDD/CDF is a
potential problem with the FF/PB system.
Formation of CDD/CDF occurs when there is intimate contact between
a gas stream containing CDD/CDF precursors and fly ash, which acts as a
catalyst for CDD/CDF formation. The optimum temperature window for fly
ash catalyzed CDD/CDF formation is between 300 deg. and 600 deg.F. The
formation of CDD/CDF is minimized when using combustion control or wet
systems because these options provide: (1) rapid cooling of the gas
stream through the temperature window; and/or (2) quick dispersion (or
removal in the case of wet systems) of CDD/CDF precursors and fly ash.
In DI/FF and SD/FF systems, the presence of an acid gas sorbent (lime,
for example) also limits the formation of CDD/CDF. The fabric filter in
a FF/PB system, on the other hand, can provide those conditions
conducive to CDD/CDF formation. In fact, test data have shown CDD/CDF
formation in the FF/PB system.
c. Fabric filter systems with carbon injection. Data from a DI/FF
system and a SD/FF system show that the injection of activated carbon
upstream of the fabric filter results in significant reductions in CDD/
CDF and Hg emissions, compared to wet systems and FF systems without
carbon. Because no data are available from a FF/PB system with carbon
injection, and because CDD/CDF formation occurred in a FF/PB system, it
is not known exactly what CDD/CDF emission reductions can be achieved
with this system. However, it is expected that the injection of carbon
will improve the performance of a FF/PB system in reducing CDD/CDF
emissions.
d. Nitrogen oxides control. During combustion, NOX is formed
through oxidation of fuel-bound nitrogen (N2) contained in the
medical waste and oxidation of atmospheric N2 (from the combustion
air). Selective noncatalytic reduction (SNCR) add-on technology has
been used to control NOX emissions from municipal waste combustors
(MWC's) by reducing NOX to N2 without the use of catalysts.
Techniques include Thermal DeNOXTM, which injects ammonia
into the combustor as a reducing agent; the NOXOUTTM process,
which injects urea with chemical additives; and a two-stage urea/
methanol injection process. Maximum emissions reduction occurs when the
reducing agents are injected into a gas stream within a narrow
temperature range and the gas is maintained in that range for a
sufficient length of time.
A discussion of SNCR NOX control was presented in the recent
proposal preamble for the MWC NSPS (59 FR 181 page 48228). The use of
SNCR at MWC's results in NOX emission reductions of about 45
percent.
There are some concerns about the applicability of SNCR to MWI's.
The SNCR technology has never been applied to MWI's, and several
factors may complicate the use of SNCR and may reduce its performance
level. The periodic charging of waste may cause corresponding
temperature fluctuations, and the varying moisture and nonhomogeneous
nature of the waste burned. When the temperature rises above the
required injection temperature window, the reducing agent is oxidized
to NOX, and NOX emissions can increase. In the event of low
temperatures, unreacted ammonia (NH3) emissions can occur.
Furthermore, uncertainties exist regarding the injection pattern
necessary to achieve adequate mixing and residence time in the
operating temperature window and in the design and engineering work
necessary to develop equipment that could be used in applications with
much smaller gas flow rates than those for MWC's. Consequently, SNCR is
not considered a demonstrated control technology for MWI's.
Although SNCR is not considered a demonstrated control technology
for MWI's, the EPA specifically solicits comments on the technical
feasibility of applying NOX control to MWI's. Specifically, the
EPA solicits information on the performance, including control device
inlet and outlet emissions data, costs, applicability, and operating
experience associated with specific NOX control technologies for
MWI's.
3. Waste segregation. One area that has been suggested for
consideration is waste segregation. It has been suggested that removal
of batteries would reduce Hg emissions and that removal of chlorinated
plastics would result in reductions in HCl and CDD/CDF. The EPA data
indicate that these emissions vary from facility to facility which
could be a result of differences in the amount of Hg and chlorine found
in the waste stream. The types of materials that are sent to the
incinerator will vary from facility to facility depending on facility
operating practices, which are defined by purchasing decisions, waste
handling procedures, and other practices that affect the types of
materials incinerated. The EPA has no data on the effect of waste
handling practices on emissions [[Page 10673]] of various pollutants
and is requesting comments on the extent to which operating practices
could influence emissions. To evaluate the effectiveness of waste
segregation programs, the EPA is specifically soliciting detailed
descriptions of the programs and results of performance tests conducted
to demonstrate pollutant emission levels from the MWI prior to
implementation of the program and subsequent to implementation of the
program. This information is critical to a thorough evaluation of the
effectiveness of the program. In addition, the EPA solicits comments on
how such a program could be incorporated into the MWI regulations.
Whenever information is submitted relative to Hg emissions, the EPA
requests that, if available, Hg emissions data be broken out by various
species emitted (for example mercury chloride or elemental mercury).
I. MACT Floor and MACT for New MWI's
Section 129 of the Clean Air Act requires that emission standards
reflect MACT. According to section 129, the degree of reduction in
emissions that is deemed achievable for new MWI's may not be less
stringent than the emissions control that is achieved in practice by
the best controlled similar unit. As a result, the emission limits
selected to reflect MACT for new MWI's must, at a minimum, be as
stringent as the emission levels achieved by the best controlled
similar unit. This minimum performance level is known as the MACT
floor. Beyond the MACT floor, in determining what performance level
should be adopted in the standards as MACT, the Administrator is to
consider the costs, any nonair-quality health and environmental impacts
and energy requirements associated with such emission limits.
The basis for MACT determinations are presented for each
subcategory in paragraphs I1, I2, and I3 of this section. The EPA
solicits comments on whether test data are available from MWI's that
are achieving better control than the systems used as the basis for the
MACT determinations. If submitting Hg data, EPA specifically requests
that, if available, Hg emission data be broken down by various species
emitted (for example, mercury chloride and elemental mercury).
While the paragraphs that follow focus on specific control
technologies in determining the MACT floor and MACT for new MWI's, the
standards do not require the use of any specific technology. The
Agency's assessment of the performance of specific technologies is used
to develop emission limitations, which appear in the regulation. Any
control technology that can comply with the emission limitations may be
used.
1. MACT Floor and MACT for New Continuous MWI's
As discussed in section VI, the discussion that follows is based in
part on limited test data on wet scrubber systems. The EPA requests
comment on the performance and costs of wet scrubber systems.
The MACT floor for continuous MWI's consists of the emission levels
that are achievable with DI/FF with carbon injection. The MACT floor is
based on these emission levels because DI/FF with carbon injection
achieves the lowest emission levels for all pollutants, and it is used
to control emissions from at least one existing continuous MWI. While
the lowest emission levels for most of the pollutants are achieved by
several different control technologies (including DI/FF with carbon
injection), the lowest Hg and CDD/CDF emission levels for continuous
MWI's are achieved only with DI/FF with carbon injection.
Because the MACT floor is the most effective level of control for
continuous units, there are no alternatives beyond the MACT floor to
consider. The level of emission control achieved by a DI/FF system with
carbon injection is considered MACT for continuous MWI's.
As discussed earlier, NOX control has not been demonstrated on
MWI's and acid gas controls are not effective in reducing SO2
emissions from MWI's. Therefore, MACT reflects no control of NOX
and SO2. However, because the Act requires EPA to set numerical
emission limits for NOX and SO2, the limits are proposed at
210 ppmv for NOX and 45 ppmv for SO2, the highest
uncontrolled NOX and SO2 emission rates measured during the
EPA test program. The EPA specifically solicits comments on the
emission limits of 45 ppmv set for SO2 and 210 ppmv set for
NOX and whether these levels accurately reflect uncontrolled
emissions of NOX and SO2 at MWI's.
2. MACT Floor and MACT for New Intermittent MWI's
As discussed in section VI, the discussion that follows is based in
part on limited test data on wet scrubber systems. The EPA requests
comment on the performance and costs of wet scrubber systems.
The MACT floor for intermittent MWI's is based on the emission
levels that are achievable with a combination of two control
technologies. The VS/PB and DI/FF without carbon injection technologies
are each used to control emissions from at least one intermittent MWI.
The MACT floor is based on both of these technologies because VS/PB
achieves the lowest CDD/CDF emissions, but DI/FF without carbon
injection achieves the lowest PM, Pb, and Cd emissions. The MACT floor
emission levels for the other pollutants can be achieved with either
technology. Therefore, one way to achieve all of the MACT floor
emission levels for intermittent MWI's would be to use a combination of
both VS/PB and DI/FF without carbon injection.
Another approach, which is less complex and less costly than the
above combination of controls, could also be used to achieve the MACT
floor emission levels. As noted in the discussion of the MACT floor for
continuous MWI's, the CDD/CDF emission levels achievable with the DI/FF
with carbon injection are even lower than those achievable with the VS/
PB system. Even though this technology is not known to be used with
existing intermittent MWI's, it could achieve better performance for a
much lower cost than the combination of controls described above, and
therefore the MACT floor for new intermittent MWI's is based on these
emission levels.
Because the MACT floor is the most effective level of control for
intermittent units, there are no alternatives beyond the MACT floor to
consider. The level of emission control achieved by a DI/FF system with
carbon injection is considered MACT for intermittent MWI's.
As discussed earlier, NOX control has not been demonstrated on
MWI's and acid gas controls are not effective in reducing SO2
emissions from MWI's. Therefore, MACT reflects no control of NOX
and SO2. However, because the Act requires EPA to set numerical
emission limits for NOX and SO2, the limits are proposed at
210 ppmv for NOX and 45 ppmv for SO2, the highest
uncontrolled NOX and SO2 emission rates measured during the
EPA test program. The EPA specifically solicits comments on the
emission limits of 45 ppmv set for SO2 and 210 ppmv set for
NOX and whether these levels accurately reflect uncontrolled
emissions of NOX and SO2 at MWI's.
3. MACT Floor and MACT for New Batch MWI's
As discussed in section VI, the discussion that follows is based in
part on limited test data on wet scrubber systems. The EPA requests
comment on the performance and costs of wet scrubber systems.
[[Page 10674]]
Like the MACT floor for intermittent MWI's, the MACT floor for new
batch MWI's consists of the emission levels that are achieved with a
combination of two control technologies. The 2-sec combustion control
is used to control emissions from many existing batch MWI's, and FF/PB
is used to control emissions from at least one batch MWI; no other add-
on control technologies have been identified on batch units. The FF/PB
achieves lower PM, Pb, Cd, and HCl emissions than 2-sec combustion
control, but because CDD/CDF formation can occur in a FF/PB system, 2-
sec combustion control alone achieves lower CDD/CDF emissions.
Equivalent emission levels for other pollutants are achieved with both
technologies. The MACT floor for all pollutants can be achieved with
the use of another technology: DI/FF without carbon injection. Except
for CDD/CDF, this technology achieves the same emission levels as FF/
PB, and the CDD/CDF emissions are the same as those for 2-sec
combustion control alone. Therefore, the MACT floor for new batch MWI's
consists of the emission levels that are achievable with DI/FF without
carbon injection.
Unlike continuous and intermittent MWI's, there is a level of
control more effective than the MACT floor for batch MWI's. This level
of control is achieved by adding carbon to the DI/FF system. The result
is further reduction in CDD/CDF emissions along with significant Hg
control. The incremental national annual cost of this option is about
$740,000, or about $170/ton of waste burned nationwide. The national
annual costs increase by only about 3 percent. Therefore, the level of
control achieved by the DI/FF system with carbon injection is
considered MACT for batch MWI's.
As discussed earlier, NOX control has not been demonstrated on
MWI's and acid gas controls are not effective in reducing SO2
emissions from MWI's. Therefore, MACT reflects no control of NOX
and SO2. However, because the Act requires EPA to set numerical
emission limits for NOX and SO2, the limits are proposed at
210 ppmv for NOX and 45 ppmv for SO2, the highest
uncontrolled NOX and SO2 emission rates measured during the
EPA test program. The EPA specifically solicits comments on the
emission limits of 45 ppmv set for SO2 and 210 ppmv set for
NOX and whether these levels accurately reflect uncontrolled
emissions of NOX and SO2 at MWI's.
J. MACT Floor and MACT for Existing MWI's
1. MACT Floor for Existing MWI's
Section 129 of the Act requires that emission guidelines reflect
MACT. According to section 129, the degree of reduction in emissions
that is deemed achievable for existing MWI's must not be less stringent
than the average emission limitation achieved by the best performing 12
percent of units in the category. In setting MACT standards, the EPA
must establish the MACT floor for a source category because the Act
specifies that each standard must be at least as stringent as the floor
for the relevant source category. For the MWI source category, the EPA
did not have sufficient emissions data to determine the MACT floor.
Data was only available from 7 MWI facilities (8 emissions tests), to
represent 3,700 existing MWI's. As a result, the EPA examined air
quality permits and State regulations to determine the emission
limitations achieved by the best-performing 12 percent of units in each
subcategory.
Emission limitations were determined for the estimated total MWI
population by examining air quality permits where available and by
assuming that the estimated population of MWI's for which permits were
not available are subject to emission limitations specified by State
regulations. It was assumed that all MWI's are either achieving their
permit limits or are achieving their State regulatory emission limits.
For each subcategory, the emission limitations for each pollutant
were ranked from most stringent to least stringent and the MACT floors
for each pollutant were determined by averaging the emission
limitations of the top 12 percent of units in that subcategory. In some
cases, the number of MWI's subject to specific emission limitations did
not comprise 12 percent of the population in a subcategory. Where this
occurred, numerical emission limits were established for the MACT floor
by including uncontrolled emission values for the additional number of
MWI's necessary to make up 12 percent of the existing population.
The MACT floors define the minimum level of emissions control.
Beyond these levels, in determining what performance levels should be
adopted in the guidelines as MACT, the Administrator is to consider the
costs, any nonair-quality health and environmental impacts, and energy
requirements associated with such emission limits.
An estimated 338 continuous, 3,018 intermittent, and 336 batch
MWI's exist nationwide. For each of these subcategories, the MACT floor
emission levels for each pollutant are calculated as the averages of
the emission limitations reported by the top 12 percent of units in
that subcategory. The top 12 percent of units in each subcategory is
represented by the 41 continuous, 363 intermittent, and 41 batch MWI's
with the most stringent permit or state regulation limitations. The
MACT floor emission levels for each pollutant in each subcategory are
presented in Table 12.
Table 12.--MACT Floor Emission Levels for Existing MWI's
------------------------------------------------------------------------
MWI type
Pollutant -------------------------------------
Continuous Intermittent Batch
------------------------------------------------------------------------
PM, mg/dscm....................... 46 69 69
CO, ppmv.......................... 76 90 91
CDD/CDF, ng/dscm.................. 1,619 12,906 14,606
HC1, ppmv......................... 43 115 911
SO2, ppmv......................... 284 414 1,166
NOX, ppmv......................... 257 216 220
Pb, mg/dscm....................... 8.7 11.8 23.1
Cd, mg/dscm....................... 0.56 1.8 3.4
Hg, mg/dscm....................... 4.0 15.6 18.5
------------------------------------------------------------------------
[[Page 10675]]
As noted above, EPA is also considering further subcategorizing
batch and intermittent MWI's by size or capacity to burn medical waste.
Specifically, some have suggested EPA consider alternatives, such as
subcategorizing these categories into incinerators with capacities of
50 pounds per hour or less, 100 pounds per hour or less, 200 pounds per
hour or less, etc. A number of States have regulations which exempt the
smallest medical waste incinerators or impose less stringent
requirements on such incinerators.
Subcategorization of the batch and intermittent MWI categories
could find that the MACT floor for small intermittent and/or small
batch incinerators is less stringent than the MACT floor for larger
incinerators in these categories. The MACT floor for small intermittent
and/or small batch MWI's within these categories, for example, could be
much less stringent than the MACT floor of 69 mg/dscm identified above
for both batch and intermittent incinerators.
2. MACT for Existing Continuous MWI's
As discussed in section VI, the discussion that follows is based on
limited test data on wet scrubber systems. The EPA requests comment on
the performance and costs of wet scrubber systems. Also, while the
paragraphs that follow focus on specific control technologies in
determining MACT for existing continuous MWI's, the guidelines do not
require the use of any specific technology. The Agency's assessment of
the performance of specific technologies is used to develop emission
limitations, which appear in the guidelines. Any control technology
that can comply with the emission limitations may be used.
a. MACT for PM, Pb, and Cd. Uncontrolled PM emissions typically are
570 mg/dscm for MWI's with 0.25-sec combustion and 300 mg/dscm for
MWI's with 1-sec combustion. The MACT floor for PM is 46 mg/dscm. A
fabric filter system is necessary to meet the MACT floor level. The FF
system is capable of achieving PM emission levels of as low as 30 mg/
dscm.
Typical uncontrolled Pb and Cd emission are 4.2 mg/dscm and 0.29
mg/dscm, respectively. The MACT floors for Pb and Cd are 8.65 mg/dscm
and 0.56 mg/dscm, respectively. Although no control is necessary to
achieve the MACT floor levels for Pb and Cd, the fabric filter system
that would be needed to meet the MACT floor emission level for PM,
would reduce Pb and Cd emissions to 0.10 mg/dscm and 0.05 mg/dscm,
respectively. Because this system is already necessary to meet the MACT
floor level for PM, there is no cost associated with reducing emissions
of Pb and Cd from the uncontrolled MACT floor levels to the level of
control achieved by the FF system. Additional control beyond the FF
system has not been demonstrated for any of these pollutants. As a
result, the proposed MACT for PM, Pb, and Cd for continuous MWI's are
the levels achievable with the FF system: 30 mg/dscm for PM, 0.10 mg/
dscm for Pb, and 0.05 mg/dscm for Cd.
b. MACT for Carbon Monoxide. Typical uncontrolled emissions of CO
at continuous MWI's are 690 ppmv for units with 0.25-sec combustion and
300 ppmv for units with 1-sec combustion. As discussed earlier, the
MACT floor for CO is 76 ppmv. Two-second combustion control is
necessary to meet the MACT floor level for CO and is capable of
achieving CO levels as low as 50 ppmv at no additional cost. Further
reduction of CO emissions has not been demonstrated. Therefore, the
proposed MACT for CO is 50 ppmv, the level achievable by 2-sec
combustion.
c. MACT for Dioxins and Furans. Typical uncontrolled emissions of
dioxins and furans (CDD/CDF) are 25,000 ng/dscm for MWI's with 0.25-sec
combustion and 6,600 ng/dscm for MWI's with 1-sec combustion. The MACT
floor for CDD/CDF is 1,619 ng/dscm. Two-second combustion control is
necessary to meet the MACT floor level for CDD/CDF and is capable of
achieving CDD/CDF levels of 1,500 ng/dscm, at no additional cost.
As discussed earlier, an FF system is needed to achieve the MACT
floor for PM. Control of CDD/CDF beyond the level of emissions
achievable with 2-sec combustion control can be attained either by
adding a wet system or by injecting activated carbon into the FF
system. Although the wet system is capable of reducing CDD/CDF
emissions, the less expensive approach would be to inject carbon into
the FF system because the FF system is already needed to meet the MACT
floor level for PM. By injecting carbon into the FF system, CDD/CDF
emissions could be reduced to about 80 ng/dscm and Hg emissions could
substantially be reduced. The nationwide incremental annual cost of
carbon injection is about $9.4 million/yr, or about $12/ton of waste
burned in continuous MWI's. This incremental cost represents an
increase of only about 5.8 percent over the cost of the FF system
without carbon injection. As a result, MACT for CDD/CDF is the level of
control achievable with an FF system with carbon injection, 80 ng/dscm
total CDD/CDF, or 1.9 ng/dscm TEQ. To arrive at the TEQ, measured
emissions of each tetra- through octa- CDD and CDF congener are
multiplied by the corresponding toxic equivalency factor (TEF)
specified in Sec. 60.36c of the proposed emission guidelines. The
products are then added to obtain the concentration of CDD/CDF emitted
in terms of TEQ.
d. MACT for Mercury. Typical uncontrolled Hg emissions are 3.1 mg/
dscm. The MACT floor for Hg is 4.04 mg/dscm. No control of Hg is
necessary to meet the MACT floor emission level.
The only control system capable of consistently reducing Hg
emissions is the FF system with carbon injection, which can achieve
emissions of 0.47 mg/dscm Hg or 85 percent reduction from uncontrolled
emissions. The FF system without carbon injection is necessary to meet
the MACT floor for PM and the injection of carbon is necessary to meet
the proposed MACT emission level for CDD/CDF. As mentioned above in the
discussion on CDD/CDF, the nationwide incremental annual cost of
injecting carbon is about $9.4 million/yr, or about $12/ton of waste
burned. This additional cost represents an increase of only about 5.8
percent over the cost of the FF system without carbon injection.
Therefore, the proposed MACT for Hg is 0.47 mg/dscm or 85 percent
reduction.
e. MACT for acid gases (HCl and SO2). Typical uncontrolled
emissions of HCl and SO2 from continuous MWI's are 1,400 ppmv for
HCl and 16 ppmv for SO2. In general, acid gases controls are
capable of reducing emissions of both HCl and SO2. However, in
EPA's experience, acid gases controls are not effective in reducing
emissions of SO2 from MWI's because of the low SO2 inlet
levels associated with the incineration of medical waste. The emissions
of HCl from MWI's, on the other hand, are reduced by acid gas controls.
As discussed earlier, the MACT floor for HCl is 43 ppmv. A reduction of
97 percent from uncontrolled levels is necessary to achieve the MACT
floor for HCl. Wet systems and FF systems are each capable of reducing
HCl emissions to 42 ppmv or by 97 percent from uncontrolled levels.
Therefore, MACT for HCl is 42 ppmv or 97 percent reduction.
Typical uncontrolled emissions of SO2 are 16 ppmv, but can
range as high as 45 ppmv. The MACT floor for SO2 is 2
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