							

Date:	  DATE \@ "MMMM d, yyyy"  March 24, 2011 

Subject:	Inventory of Hospital/Medical/Infectious Waste Incinerators
Potentially Covered by the Proposed Section 111(d)/129 Federal Plan

EPA Contract No. EP-D-07-019; Work Assignment No. 4-13



From:	Thomas Holloway

To:	Amy Hambrick

OAQPS/SPPD (E143-03)

U.S. Environmental Protection Agency

Research Triangle Park, NC  27711



Introduction

Under sections 111 and 129 of the Clean Air Act (CAA), U.S.
Environmental Protection Agency (EPA) is required to develop emissions
guidelines (EG) for existing hospital/medical/ infectious waste
incinerators (HMIWI) and new source performance standards (NSPS) for new
HMIWI.  The regulations are designed to limit emissions of nine
pollutants and opacity from these HMIWI.  The nine pollutants are
hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd),
mercury (Hg), particulate matter (PM), dioxins/furans (CDD/CDF),
nitrogen oxides (NOX), and sulfur dioxide (SO2).  Regulations for the
HMIWI category were promulgated on September 15, 1997.  The EG are
codified in 40 CFR part 60, subpart Ce, and the NSPS are codified in 40
CFR part 60, subpart Ec.  The HMIWI regulations were remanded by the
U.S. Court of Appeals for the D.C. Circuit (the Court) on March 2, 1999
for further explanation by EPA regarding the approach and methodology
that EPA used to develop the HMIWI regulations.  On October 6, 2009, the
EPA promulgated amended EG and NSPS for HMIWI to address the concerns
raised in the Court’s remand.

Unlike the subpart Ec NSPS, which apply directly to new sources, states
must develop a State Plan in order to compel existing sources to meet
the subpart Ce EG.  Together, subpart B and subpart Ce of part 60
specify the State Plan content and the general rules for adopting and
submitting these State Plans.  State Plans were developed previously to
implement the EG adopted on September 15, 1997.  Revised or new State
Plans to implement the amended EG adopted on October 6, 2009 were due to
EPA for review and approval on October 6, 2010.  The EG require EPA to
develop and implement a Federal Plan for each state that does not have
an approved revised or new State Plan in place within 2 years after
promulgation of the EG.  A Federal Plan to implement the September 15,
1997 EG was promulgated on August 15, 2000 and is codified in 40 CFR
part 62, subpart HHH.  Amendments to the Federal Plan are currently
being developed to implement the October 6, 2009 amendments to the EG.

For approval, one of the requirements of a State Plan is a source
inventory and an emissions inventory.  Likewise, the Federal Plan must
contain a source and emissions inventory for HMIWI not covered under a
State Plan.  The purpose of this memorandum is to present an updated
source and emissions inventory of the HMIWI industry for the proposed
amendments to the Federal Plan and to document the sources of the
database information.  The database fields are listed in Table 1 below,
along with descriptions of their respective information sources.  The
database is presented in Appendix A.  The acronyms and abbreviations
used in the database are presented in Appendix B.

Updates to 2010 Inventory

For the October 6, 2009 amendments to the EG, EPA estimated there were
57 HMIWI currently operating in the U.S.1  Based on recently obtained
inventory information, EPA has determined that three of those HMIWI have
shut down and now estimates there are 54 HMIWI currently operating.2-4 
The inventory of HMIWI was developed and updated as a result of contacts
with EPA Regions, States, and HMIWI facilities and review of existing
HMIWI inventories, title V permits, emissions test reports, and facility
websites.1-5

References

Memorandum from Thomas Holloway, RTI, to Project File.  July 6, 2009. 
Updated Hospital/Medical/Infectious Waste Incinerator (HMIWI) Inventory
Database.

Letter from James Bukowski, Johns Hopkins Institutions, to EPA Region
III.  January 28, 2010.

Zentner, Sonny.  May 5, 2008.  Analysis, Preliminary Determination and
Draft Permit for the Renewal of Operation Permit Number 7720545800-P10
for St. Joseph’s Hospital.  Wisconsin Department of Natural Resources.

Letter from Wilkes-Barre General Hospital to EPA Region III.  June 7,
2009.

Memorandum from Thomas Holloway, RTI, to Mary Johnson, EPA.  July 6,
2009.  Revised Baseline Emissions and Emissions Reductions for Existing
and New HMIWI.Table 1.  Fields Included in HMIWI Source and Emissions
Inventory

  SEQ CHAPTER \h \r 1 Field name	Description	Information sources

No	Unique number assigned by RTI to each record.	Assigned by RTI for
each record.  Records sorted by EPA Region, State, city, facility name,
unit number, and pollutant.

Fac ID	Unique ID number assigned by RTI to identify a facility.	Assigned
by RTI for each facility.  Facilities sorted by EPA Region, State, city,
and facility name.

Unit ID	Unique ID number assigned by RTI to identify each unit at a
facility.	Assigned by RTI for each unit at a facility.  Units sorted by
EPA Region, State, city, facility name, and unit number.

Facility Name	The name of the facility.	Based on latest facility name
from permits, test reports, inventories, EPA’s Envirofacts website,
and facility websites.

Unit Number	The unit number of the incinerator, if the facility has more
than one incinerator.	Based on unit numbers from permits, test reports,
and inventories.

Previous Facility Name	The previous name of the facility.	Based on
previous facility names from permits, test reports, inventories, EPA’s
Envirofacts website, and facility websites.

Location Address	Physical location of the front door/main entrance of
the facility site.	Based on facility address information from permits,
test reports, inventories, EPA’s Envirofacts website, and facility
websites.  Included physical address and, if applicable, post office
box.

City	The name of the city.	Based on city name from permits, test
reports, inventories, and facility websites.

State	State abbreviation.	Based on State or territory name from permits,
test reports, and inventories.

Zip Code	The U.S. Postal Service zip code.	Based on zip code from
permits, test reports, inventories, and facility websites.

County	The name of the county.	Based on county name from permits, test
reports, inventories, and facility websites.

EPA Region	The EPA Region where the State or territory is located.	Based
on EPA Region assignments for States and territories from EPA website.

X Coordinate	Longitude measure in decimal degrees of the angular
distance on a meridian east or west of the prime meridian.  Negative (-)
data point for N. America.  Include (-) sign, e.g., -123.234561.	Most
based on the most accurate longitude data available from NEI (based on
horizontal accuracy measure).  Data for some units not available from
the NEI.  Obtained data for these units from EPA’s Envirofacts or from
RTI’s GIS group.

Y Coordinate	Latitude measure in decimal degrees of the angular distance
on a meridian north or south of the equator.  Positive (+) data point
for N. America.  Include (+) sign, e.g., +78.123456.	Most based on the
most accurate latitude data available from NEI (based on horizontal
accuracy measure).  Data for some units not available from the NEI. 
Obtained data for these units from EPA’s Envirofacts or from RTI’s
GIS group.

UTM Zone	Zone number in UTM coordinate system.	Determined using an
online program that converts latitude and longitude measures to UTM zone
numbers.

Plan Status (1997 HMIWI Rule)	Status of State/Federal Plans implementing
the 1997 HMIWI rule.	Taken from EPA’s State/Federal plan status
website for 1997 HMIWI rule.

Compliance Date (1997 HMIWI Rule)	Date of compliance with the
State/Federal plans implementing the 1997 HMIWI rule.	Based on
compliance dates in permits and inventories.

Facility Contact Name	The name of the facility contact.	Based on
facility contact name from permits, test reports, inventories, facility
websites, and facility contacts.

Facility Contact Phone	The phone number of the facility contact.	Based
on facility contact phone numbers from permits, test reports,
inventories, facility websites, and facility contacts.

SIC Primary	Standard Industrial Classification code.	Taken from NEI and
SIC code table.

NAICS Primary	North American Industry Classification System code.	Taken
from NEI and NAICS code table.

Site Description	Comments/description for this facility.	Based on
SIC/NAICS code assigned to the facility.

Size Category	The size category of the incinerator (i.e., large (L),
medium (M), small (S), or small rural (SR)).	Based on size information
from permits, test reports, and inventories.

New Existing	Whether the incinerator is new (N) or existing (E).	Based
on incinerator description from permits, test reports, and inventories.

Mode	The mode of operation of the incinerator (i.e., continuous (C),
inter-mittent (I), or batch (B)).	Based on operating information from
permits, test reports, and inventories.

Waste Heat Recovery Boiler	Whether the facility has a waste heat
recovery boiler to recover as steam the energy from the HMIWI	Based on
facility description from permits and test reports.

Commercial	Whether the facility is a commercial incineration facility
(Yes/No).	Based on incinerator description from permits, test reports,
and inventories.

Dun & Bradstreet Number	Dun & Bradstreet no. for the facility.	Based on
information from Dun & Bradstreet Million Dollar Directory, NEI, and
EPA’s Envirofacts website.

Parent Company	The name of the parent company of the facility.	Based on
information from permits, test reports, inventories, and facility
websites.

Parent Company Employment	Number of employees in the parent company.
Based on information from Dun & Bradstreet Million Dollar Directory,
Hoovers, Inc., and facility websites.

Parent Company Sales	Sales for the parent company ($million).	Based on
information from Dun & Bradstreet Million Dollar Directory, Hoovers,
Inc., and facility websites.

Year of Sales/Emp. Data	The year for which sales and employment data
were obtained for the parent company	Based on information from Dun &
Bradstreet Million Dollar Directory and Hoovers, Inc.

Size Standards	SBA size standards for the parent company (i.e., sales in
$million, or number of employees).	Based on SBA Table of Small Business
Size Standards Matched to NAICS Codes.

Small Business	Small business status based on SBA size standards
(Yes/No/ Borderline).	Determined based on comparison of SBA size
standards to employment and sales information for parent companies.

Facility Registry Identifier	The ID number assigned by the EPA Facility
Registry System.	Taken from NEI, permits, test reports, State
correspondence, and EPA’s Envirofacts website.

Other Facility Registry Identifiers	Other ID numbers assigned by the EPA
Facility Registry System.	Taken from NEI, permits, test reports, State
correspondence, and EPA’s Envirofacts website.

Emission Unit ID	Unique ID reported consistently over time by
State/local/tribal agency.	In most cases, based emission unit IDs on
permits, test reports, inventories, State correspondence, and NEI. 
Otherwise, assigned an emission unit ID of “1.”

Emission Unit Description	A text description of the Emission Unit.
Described emission units as “hospital/medical/infectious waste
incinerators.”  Also included information about the model of
incinerator, if available.

Emission Process ID	Unique ID reported consistently over time by
State/local/tribal agency.	In some cases, based emission process IDs on
permits, test reports, inventories, State correspondence, and NEI. 
Otherwise, assigned the same ID as the emission unit ID.

Emission Process Description	A text description of the Emission Process.
Described emission processes as “hospital/medical/infectious waste
incineration.”

Emission Release Pt ID	State/local/tribal ID for point/location where
emissions are released to ambient air.	In some cases, based emission
release point IDs on permits, test reports, inventories, State
correspondence, and NEI.  Otherwise, assigned the same ID as the
emission unit ID.

Emission Release Pt Description	A text description of the Emission
Release Point.	All but two facilities have one stack serving each
incinerator.  The remaining two facilities have one stack serving two
incinerators (although one of the facilities is not currently using the
second incinerator).  Provided text descriptions based on these
configurations.

SCC	EPA Source Category Code for Point Sources.	Taken from NIF SCC code
table.  Assigned SCC code of “50200501” to those
commercial/institutional HMIWI operating on a continuous or intermittent
basis (most units).  Assigned SCC code of “50200502” to the
commercial/institutional HMIWI operating on a batch basis (one unit). 
Assigned SCC code of “50200503” to those commercial/institutional
HMIWI which use a rotary kiln incinerator (three units).  Assigned SCC
code of “50100505” to locally-operated HMIWI (two units at one
facility).

Control System Description	Description of control equipment chain.	Most
control devices based on information from permits and test reports, but
one based on information from website.

Control System Abbr	Abbreviation of control equipment used (FF= fabric
filter, DIFF=dry injection fabric filter, WS=wet scrubber, CC=
combustion control, ESP= electrostatic precipitator, WESP=wet ESP, CA=
carbon adsorber).	Based on control system description.

Waste Types	Types of waste incinerated at the facility.	Based on waste
type information from test reports.

Design Capacity (lb/hr)	Numeric value of average operational capacity
(in lb/hr) for an emission unit	Based on design capacity information
from permits, test reports, and inventories.

Design Capacity Notes	Notes regarding calculation of design capacity.
Documented inputs used to calculate design capacity.

Design Capacity Batch (lb/batch)	Numeric value of average operational
capacity (in lb/batch) for a batch emission unit.	Based on batch design
capacity information from test reports.

Max Charge Rate (lb/hr)	Numeric value of maximum charge rate (in lb/hr)
for an emission unit if different from design capacity.	Based on maximum
charge rate information from permits, test reports, inventories, and
facility contacts.  Several facilities chose to have their permits
revised to reduce their allowable HMIWI charge rates below design
capacity in order to qualify for a smaller HMIWI size category with less
stringent emission limits.

Max Charge Rate Notes	Notes regarding calculation of maximum charge
rate.	Documented inputs used to calculate maximum charge rate.

Avg Throughput (lb/hr)	Average numeric value of throughput over entire
emission test.	Based on average of test throughput data from test
reports.

Annual Throughput for 2002 (tpy)	Numeric value of 2002 annual throughput
(in tpy)	Most based on 2002 annual throughput values from facilities,
EPA Regions, and States.  Data not available for several units, so
annual throughput values were calculated using hourly throughputs from
stack test and annual operating hours from facilities.

Annual Throughput for 2002 Notes	Notes regarding calculation of 2002
annual throughput.	Documented inputs used to calculate annual
throughput.

Est. Annual Throughput	Numeric value of estimated annual throughput (in
tpy)	Calculated based on maximum charge rate and annual operating hours,
assuming the unit operates at 2/3 capacity.

Est. Annual Throughput Notes	Notes regarding calculation of estimated
annual throughput (in tpy)	Documented method used to calculate estimated
annual throughput

Winter Throughput PCT	The percentage a process operates during the
winter months.  Whole number between 0 and 100.	Taken from NEI and
EPA’s Envirofacts website.  Otherwise assumed “25 percent” for
each season.

Spring Throughput PCT	The percentage a process operates during the
spring months.  Whole number between 0 and 100.	Taken from NEI and
EPA’s Envirofacts website.  Otherwise assumed “25 percent” for
each season.

Summer Throughput PCT	The percentage a process operates during the
summer months.  Whole number between 0 and 100.	Taken from NEI and
EPA’s Envirofacts website.  Otherwise assumed “25 percent” for
each season.

Fall Throughput PCT	The percentage a process operates during the fall
months.  Whole number between 0 and 100.	Taken from NEI and EPA’s
Envirofacts website.  Otherwise assumed “25 percent” for each
season.

Annual Avg Hours Per Day	Average number of hours per day an emission
process is active within year.	Most based on data from facilities, EPA
Regions, and States, with a few based on data from NEI and one based on
data from a permit.

Annual Avg Hours Per Day Notes	Notes regarding calculation of annual
average hours per day.	Documented inputs used to calculate annual
average hours per day.

Annual Avg Days Per Week	Average number of days per week an emission
process is active within year.	Most based on data from facilities, EPA
Regions, and States, with four based on data from NEI and two based on
data from a permit.

Annual Avg Days Per Week Notes	Notes regarding calculation of annual
average days per week.	Documented inputs used to calculate annual
average days per week.

Annual Avg Weeks Per Year	Average number of weeks per year an emission
process is active.	Most based on data from facilities, EPA Regions, and
States, with four based on data from NEI and two based on data from a
permit.

Annual Avg Weeks Per Year Notes	Notes regarding calculation of annual
average weeks per year.	Documented inputs used to calculate annual
average weeks per year.

Annual Avg Hours Per Year	Average number of hours per year an emission
process is active.	Most based on data from facilities, EPA Regions, and
States, with four based on data from NEI and two based on data from a
permit.

Annual Avg Hours Per Year Notes	Notes regarding calculation of annual
average hours per year.	Documented inputs used to calculate annual
average hours per year

Stack Height (ft)	The height (in feet) of a stack.	Most based on stack
height data from test reports.  Several based on stack height data from
permits, EPA’s Envirofacts website, and NEI.

Stack Diameter (ft)	The diameter (in feet) of a circular stack.	Based on
stack diameter data from test reports.  Stack diameter values also could
be calculated based on data for stack area, or data for exit gas flow
rate and exit gas velocity.

Stack Dimensions (ft x ft)	The dimensions (in feet x feet) of a
non-circular stack.	One unit has rectangular, not circular, stack. 
Therefore, stack diameter is not relevant for this units.  Provided
stack dimensions in units of feet x feet.

Stack Area (ft2)	The area (in square feet) of a stack.	Based on stack
area data from test reports.  Stack area values also could be calculated
based on data for stack diameter, or data for exit gas flow rate and
exit gas velocity.

Exit Gas Temperature (deg F)	The temperature of an exit gas stream
(degrees Fahrenheit).	Based on average stack temperatures from test
reports.

Exit Gas Velocity (ft/s)	The velocity of an exit gas stream (feet per
second).	Based on average exit gas velocities from test reports.  Exit
gas velocities also could be calculated based on data for exit gas flow
rate and stack diameter.

Exit Gas Flow Rate (acfm)	Numeric value of stack gas flow rate in actual
cubic feet per minute.	Based on average actual gas flow rates from test
reports.

Exit Gas Flow Rate Std (dscfm)	Numeric value of stack gas flow rate in
dry standard cubic feet per minute.	Based on average standard gas flow
rates from test reports.

HCl Unit Average Concentration (ppmvd)	Numeric value of average HCl
concentration (in ppmvd) for an emission unit	Based on average HCl
concentration data from test reports.

CO Unit Average Concentration (ppmvd)	Numeric value of average CO
concentration (in ppmvd) for an emission unit	Based on average CO
concentration data from test reports.

Pb Unit Average Concentration (mg/dscm)	Numeric value of average Pb
concentration (in mg/dscm) for an emission unit	Based on average Pb
concentration data from test reports.

Cd Unit Average Concentration (mg/dscm)	Numeric value of average Cd
concentration (in mg/dscm) for an emission unit	Based on average Cd
concentration data from test reports.

Hg Unit Average Concentration (mg/dscm)	Numeric value of average Hg
concentration (in mg/dscm) for an emission unit	Based on average Hg
concentration data from test reports.

PM Unit Average Concentration (gr/dscf)	Numeric value of average PM
concentration (in gr/dscf) for an emission unit	Based on average PM
concentration data from test reports.

Total CDD/CDF Unit Average Concentration (ng/dscm)	Numeric value of
average CDD/CDF concentration (in ng/dscm) for an emission unit	Based on
average CDD/CDF concentration data from test reports.

CDD/CDF TEQ Unit Average Concentration (ng/dscm)	Numeric value of
average TEQ concentration (in ng/dscm) for an emission unit	Based on
average TEQ concentration data from test reports.

NOX Unit Average Concentration (ppmvd)	Numeric value of average NOX
concentration (in ppmvd) for an emission unit	Based on average NOX
concentration data from test reports.

SO2 Unit Average Concentration (ppmvd)	Numeric value of average SO2
concentration (in ppmvd) for an emission unit	Based on average SO2
concentration data from test reports.

HCl Annual Emissions (lb/yr)	Numeric value of annual HCl emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

CO Annual Emissions (lb/yr)	Numeric value of annual CO emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

Pb Annual Emissions (lb/yr)	Numeric value of annual Pb emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

Cd Annual Emissions (lb/yr)	Numeric value of annual Cd emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

Hg Annual Emissions (lb/yr)	Numeric value of annual Hg emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

PM Annual Emissions (lb/yr)	Numeric value of annual PM emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

Total CDD/CDF Annual Emissions (g/yr)	Numeric value of annual CDD/CDF
emissions (in g/yr) for an emission unit	Based on emissions and
parameter data from test reports and annual operating hours.

CDD/CDF TEQ Annual Emissions (g/yr)	Numeric value of annual TEQ
emissions (in g/yr) for an emission unit	Based on emissions and
parameter data from test reports and annual operating hours.

NOX Annual Emissions (lb/yr)	Numeric value of annual NOX emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.

SO2 Annual Emissions (lb/yr)	Numeric value of annual SO2 emissions (in
lb/yr) for an emission unit	Based on emissions and parameter data from
test reports and annual operating hours.



 Appendix A

HMIWI Source and Emissions Inventory

Appendix B

Acronyms and Abbreviations Used in HMIWI Source and Emissions Inventory

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