Date: June 19, 2009 

Subject: Revised Baseline Operating Costs for Existing HMIWI 

EPA Contract No. EP-D-06-118; Work Assignment No. 3-09; SPPD No. 02/30 

RTI Project No. 0210426.003.009 

From: Thomas Holloway 

To: Ketan Patel 

OAQPS/SPPD/NRCG (E143-03) 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

I. Background

The U.S. Environmental Protection Agency (EPA), under sections 111 and 129 of the 

Clean Air Act (CAA), is required to regulate emissions of nine pollutants from 

hospital/medical/infectious waste incinerators (HMIWI): 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). The regulation for the HMIWI 

category was promulgated on September 15, 1997 and subsequently remanded by the U.S. Court 

of Appeals for the D.C. Circuit on March 2, 1999. To respond to concerns raised by the Court 

regarding the methodology originally used to develop the 1997 regulation, EPA is re-developing 

the HMIWI regulation. In addition to developing compliance options to support that redevelopment, EPA is also exploring alternatives to compliance. The purpose of this memorandum 

is to show how the baseline operating costs for currently operating HMIWI compare to the 

primary alternative to compliance with the re-developed regulation, which is autoclaving and 

landfilling the waste. Note: The cost estimates presented in this memorandum are minor 

corrections of the estimates presented in a previous memorandum, prepared for the December 

2008 HMIWI re-proposal.1

II. Model Costs

This section presents the costs estimated for a series of model HMIWI for (1) the 

combustors currently being used to incinerate hospital/medical/infectious waste; (2) the emission 

controls currently being used to comply with the 1997 HMIWI regulation; (3) the monitoring, 

testing, recordkeeping, and reporting activities currently being used to demonstrate compliance 

with the 1997 regulation; and (4) the primary alternative to compliance with the re-developed 

regulation (i.e., autoclaving/landfilling). The model HMIWI include large, medium, small nonrural, and small rural units. Table 1 shows the basis for the development of the parameters for the 

model HMIWI (e.g., incinerator charge rate, stack gas flow rate, incinerator operating hours, and 

concentrations) were developed. Table 2 presents a summary of the model costs for combustors, 

emission controls, and the autoclave/landfill alternative. 
A. Combustors

Combustor costs are presented for each model size in Table 3 and were estimated based on 

algorithms provided in the Model Plant Description and Control Cost Report for HMIWI.

2

 The 

combustor capital costs from these algorithms were updated to 2007 dollars using the Chemical 

Engineering Plant Cost Index (CEPCI) and range from approximately $102,000 to $955,000. 

The combustor annual costs were estimated in units of dollars per year ($/yr) and $/flow. 

The $/flow costs were calculated by dividing the $/yr control cost estimate for each model HMIWI 

by the gas flow rate for that model. The $/flow costs were used to calculate unit-specific control 

costs for each HMIWI, as discussed in section III of this memorandum. The combustor annual 

costs were updated to 2007 dollars using current estimates for unit costs and labor rates and range 

from approximately $54,800/yr to $366,000/yr. Updated unit costs for electricity, natural gas, and 

dust disposal were obtained from online sources.3-5 A unit cost for water was obtained from the 

latest version of EPA’s Air Compliance Advisor.6 Current operating labor rates were estimated 

based on occupational employment statistics available online from the U.S. Bureau of Labor 

Statistics for several industries that use HMIWI, specifically the May 2007 mean hourly wage 

estimates for Stationary Engineers and Boiler Operators in the following sectors: General Medical 

and Surgical Hospitals; Waste Treatment and Disposal; Pharmaceutical and Medicine 

Manufacturing; and Colleges, Universities, and Professional Schools.7 To determine an average 

operating labor rate for all HMIWI, a weighted average was taken of the aforementioned mean 

hourly wage estimates using the fraction of HMIWI located in each of those sectors. 

B. Emission Controls

Emission control technologies that are currently being used to comply with the 1997 

HMIWI regulation include packed-bed scrubbers, venturi scrubbers, fabric filters, dry scrubbers, 

electrostatic precipitators (ESPs), carbon adsorbers, activated carbon injection (ACI), and selective 

noncatalytic reduction (SNCR). This section presents the model costs that were estimated for 

these control measures. 

As with the combustor costs, the emission control annual costs were estimated in units of 

$/yr and $/flow, with the $/flow costs used to calculate unit-specific control costs for each 

HMIWI, as discussed in section III. 

1. Packed-bed scrubbers. Packed-bed scrubbers are used to reduce emissions of acid 

gases such as HCl from both medium and large HMIWI and also provide limited control of PM, 

metals, and SO2 (if present at high enough concentrations). Model packed-bed scrubber costs are 

presented for the two model sizes in Table 4 and were estimated based on algorithms in the Model 

Plant Description and Control Cost Report for HMIWI and a memo update.2,8 The packed-bed 

scrubber capital costs from these algorithms were updated to 2007 dollars using the CEPCI and 

range from approximately $328,000 to $453,000 for the medium and large models. 

The packed-bed scrubber annual costs were updated to 2007 dollars using current 

estimates for unit costs and labor rates and range from approximately $65,700/yr to $104,000/yr 

(yr) for the medium and large models. The updated unit costs for electricity and caustic were 

2 
obtained from online sources.3,9 Unit costs for water and sewage disposal were obtained from the 

latest version of EPA’s Air Compliance Advisor.6

 Current operating labor rates were estimated 

based on the aforementioned occupational employment statistics available online from the U.S. 

Bureau of Labor Statistics.7 

2. Venturi scrubbers. Venturi and other types of wet scrubbers (e.g., rotary atomizers) 

are used to reduce emissions of PM (and associated particulate metals) from large, medium, and 

small HMIWI and also provide some control of acid gases such as HCl and SO2 (if present at high 

enough concentrations). For large HMIWI, these wet scrubbers are installed either alone (after the 

HMIWI) or after a dry scrubber/fabric filter, and the large model costs in this cost analysis are 

presented both ways. For the other model sizes, the wet scrubbers are installed alone. For the 

purposes of this cost analysis, venturi scrubbers were used to stand in for the other types of 

particulate wet scrubbers. Model venturi scrubber costs are presented for large, medium, and 

small HMIWI in Table 5 and were estimated based on algorithms in the Model Plant Description 

and Control Cost Report for HMIWI and a memo update.2,8 The venturi scrubber capital costs 

from these algorithms were updated to 2007 dollars using the CEPCI and range from 

approximately $344,000 to $625,000 for the three models. 

The venturi scrubber annual costs were updated to 2007 dollars using current estimates for 

unit costs and labor rates and range from approximately $78,400/yr to $192,000/yr for the three 

models. The updated unit costs for electricity and caustic were obtained from online sources.3,9 

Unit costs for water and sewage disposal were obtained from the latest version of EPA’s Air 

Compliance Advisor.6 Current operating labor rates were estimated based on the aforementioned 

occupational employment statistics available online from the U.S. Bureau of Labor Statistics.7

3. Fabric filters. Fabric filters are used to improve the PM (and associated particulate 

metals) emission control at two large HMIWI. Model fabric filter costs are presented for that 

model size in Table 6 and were estimated based on algorithms in the Model Plant Description and 

Control Cost Report for HMIWI.2

 The fabric filter capital costs from these algorithms were 

updated to 2007 dollars using the CEPCI and total approximately $1.02 million for the large 

model. 

The fabric filter annual costs were updated to 2007 dollars using current estimates for unit 

costs and labor rates and total approximately $268,000/yr for the large model. Updated unit costs 

for electricity, compressed air, and dust disposal were obtained from online sources.3,4,10 A unit 

cost for water was obtained from the latest version of EPA’s Air Compliance Advisor.6 Current 

operating labor rates were estimated based on the aforementioned occupational employment 

statistics available online from the U.S. Bureau of Labor Statistics.7

4. Dry scrubbers. Dry scrubbers are used in concert with fabric filters to reduce 

emissions of PM, as well as emissions of acid gases such as HCl. The predominant type of dry 

system used at HMIWI is a dry sorbent injection system followed by a fabric filter (DIFF). DIFF 

have been installed on both medium and large HMIWI. Model costs are presented for these two 

model sizes in Table 7 and were estimated based on algorithms in the Model Plant Description 

and Control Cost Report for HMIWI and a memo update.2,11 The DIFF capital costs from these 

3 
algorithms were updated to 2007 dollars using the CEPCI and range from approximately $1.07 

million to $1.36 million for the medium and large models. 

The DIFF annual costs were updated to 2007 dollars using current estimates for unit costs 

and labor rates and range from approximately $206,000/yr to $347,000/yr for the medium and 

large models. Updated unit costs for electricity, lime, compressed air, and dust disposal were 

obtained from online sources.3,4,10,12 A unit cost for water was obtained from the latest version of 

EPA’s Air Compliance Advisor.6 Current operating labor rates were estimated based on the 

aforementioned occupational employment statistics available online from the U.S. Bureau of 

Labor Statistics.7

5. Electrostatic precipitators. ESP’s are used in concert with wet scrubbers to reduce 

emissions of PM (and associated particulate metals) at two large HMIWI. A dry ESP has been 

installed at one HMIWI, and a wet ESP at the other. Dry and wet ESP costs are presented for 

large model HMIWI in Table 8 and were estimated based on algorithms in the OAQPS Control 

Cost Manual.

13 The ESP capital costs from these algorithms were updated to 2007 dollars using 

the CEPCI and Vatavuk Air Pollution Control Cost Index (VAPCCI) and equal approximately 

$1.07 million for the dry ESP and $607,000 for the wet ESP. 

The ESP annual costs were updated to 2007 dollars using current estimates for unit costs 

and labor rates and equal approximately $220,000/yr for the dry ESP and $158,000/yr for the wet 

ESP. Updated unit costs for electricity and dust disposal (for dry and wet ESPs) were obtained 

from online sources.3,4 Unit costs for water and sewage disposal (for wet ESPs) were obtained 

from the latest version of EPA’s Air Compliance Advisor.6

 Current operating labor rates were 

estimated based on the aforementioned occupational employment statistics available online from 

the U.S. Bureau of Labor Statistics.7

6. Carbon adsorbers. A carbon bed adsorber is used for Hg control at one large 

HMIWI (at East Carolina University). Carbon adsorber costs are presented for this specific 

HMIWI in Table 9 and were adapted from algorithms in the OAQPS Control Cost Manual.

14 For 

the purposes of this cost analysis, only the annual operating costs were estimated, which total 

approximately $6,800/yr for this specific HMIWI. (Because costs were estimated for a specific 

HMIWI, no $/flow estimates were developed.) In estimating the annual cost of the carbon for the 

carbon bed, the amount of carbon was assumed to be equivalent to that used in the ACI calculation 

in the section below. It was also assumed that the carbon is not regenerated (unlike more typical 

carbon adsorption units used to control organic emissions). Updated unit costs for virgin carbon 

and for spent carbon disposal were obtained from online sources.4,15-17 Current operating labor 

rates were estimated based on the occupational employment statistics available online from the 

U.S. Bureau of Labor Statistics.7

7. Activated carbon injection system. Injecting activated carbon before the fabric 

filter or other particulate control device is used to improve the removal efficiency of both Hg and 

CDD/CDF at medium and large HMIWI. Activated carbon injection costs are presented for these 

two model sizes in Table 11 and were estimated based on algorithms in the Model Plant 

Description and Control Cost Report for HMIWI.2

 Capital costs for the ACI system were updated 

4 
to 2007 dollars using the CEPCI and range from approximately $7,400 to $12,000 for the medium 

and large models. 

Annual costs for the ACI system were updated to 2007 dollars using current estimates for 

unit costs and labor rates and range from approximately $12,500/yr to $56,300/yr for the medium 

and large models. Updated unit costs for activated carbon and dust disposal were obtained from 

online sources.4,15-17 Current operating labor rates were estimated based on the occupational 

employment statistics available online from the U.S. Bureau of Labor Statistics.7

The factor of 0.00127 in the annual cost equation for dust disposal is based on an ACI rate 

capable of producing a carbon concentration of 338 milligrams per dry standard cubic meter 

(mg/dscm), which is expected to achieve reductions of 90 percent for Hg and 98 percent for 

CDD/CDF relative to inlet levels.2 

8. Selective noncatalytic reduction. SNCR systems are used for NOX emission 

control at two large HMIWI. NOX reductions of 45 percent or higher are estimated for HMIWI 

using SNCR systems.18 The costs for an SNCR system are presented for large model HMIWI in 

Table 10 and were estimated based on algorithms in the OAQPS Control Cost Manual.

19 The 

SNCR capital costs from these algorithms were updated to 2007 dollars using the CEPCI and total 

approximately $586,000 for the large model. 

The SNCR annual costs were updated to 2007 dollars using current estimates for unit costs 

and labor rates and total approximately $67,900/yr for the large model. The unit cost for a 

50 percent urea solution ($0.85/gallon [gal]) was also taken from the OAQPS Control Cost 

Manual.

19 Two other unit costs for urea were found online, but one cost (up to $0.46/gal) was 

based on delivery of dry urea (with the urea solution later mixed onsite), while the other cost 

($0.60/gal) was over 5 years old.20,21 To be conservative, the higher unit cost from the OAQPS 

Control Cost Manual was used. An updated unit cost for electricity was obtained from an online 

source.3 A unit cost for water was obtained from the latest version of EPA’s Air Compliance 

Advisor.6

 The average heating value of 8,500 British thermal units per pound (Btu/lb) of medical 

waste, used in the annual electricity cost equation, was obtained from the Process Description 

Report for HMIWI.22

The annual electricity cost for SNCR systems is also dependent on the NOX concentration 

at the inlet to the SNCR system, which was estimated to be 0.28 lb/million Btu (MM Btu), based 

on the average of the NOX concentration data for currently operating HMIWI. The NOX

concentration for each HMIWI was estimated (as shown in the following equation) using baseline 

emissions estimates developed in a separate memorandum:23

NOX concentration (lb/MM Btu) = NOX baseline emissions (lb/yr) / [operating hours per year (hr/yr) x incinerator 

charge rate (lb waste/hr) x heating value (8,500 Btu/lb waste)] x 106

 Btu/MM Btu 

C. Monitoring

1. Inspections. Under the 1997 HMIWI regulation, existing small rural HMIWI are 

required to conduct annual equipment inspections to compensate for the lack of annual emissions 

5 
testing at those sources. The inspections include the incinerator, control device (if any), and 

monitoring equipment. 

Information on equipment inspections was gathered for the 1997 regulation.24 Four 

companies (one incinerator dealer, one maintenance contractor, and two incinerator 

manufacturers) were contacted for information on the types of activities normally conducted 

during an equipment inspection; the companies provided inspection cost estimates ranging from 

$350 to $800.24 These costs were averaged and updated to 2007 dollars using the CEPCI to 

develop the inspection cost for small rural HMIWI ($900). (See Table 12.) 

2. Parameter monitors. Monitoring of operating parameters is used to indicate 

whether air pollution control equipment and practices are functioning properly to minimize air 

pollution. The 1997 HMIWI regulation includes parameter monitoring requirements for good 

combustion, wet scrubbers, dry scrubbers with fabric filters, and wet/dry scrubber combinations. 

Where applicable, the model costs associated with these parameter monitoring requirements are 

presented in Table 13. 

The monitoring costs presented in this memorandum include the costs to monitor the 

parameters, plus any ancillary equipment costs (e.g., computer, data logger/computer interface, 

logging and reporting software, and printer) and other costs. (Some of the other costs include 

planning, selecting the type of equipment, providing support facilities, installing and checking the 

equipment, conducting performance specification tests, preparing a quality assurance/quality 

control [QA/QC plan], and recordkeeping and reporting.) 

The 1997 regulation requires HMIWI to monitor the following parameters: 

● All HMIWI: monitor charge rate and secondary chamber temperature, to demonstrate 

good combustion practices 

● HMIWI equipped with wet scrubbers: monitor flue gas temperature, pressure drop 

across the wet scrubber (or the horsepower or amperage to the wet scrubber), scrubber 

liquor flow rate, and scrubber liquor pH 

● HMIWI equipped with DIFF: monitor fabric filter inlet temperature, and HCl sorbent 

(i.e., lime) flow rate 

● HMIWI equipped with ACI: monitor Hg and CDD/CDF sorbent (i.e., activated carbon) 

flow rate 

Consequently, the monitoring costs developed for the 1997 regulation included costs for 

the following:25

● All HMIWI: costs for weight scale and thermocouple wire 

● HMIWI equipped with wet scrubbers: costs for thermocouple wire, signal wire, 

pressure transducer, liquid flow transducers, and controller element and transmitter for 

pH meter 

● HMIWI equipped with DIFF: costs for thermocouple wire and labor to monitor and 

record lime flow 

● HMIWI equipped with ACI: labor costs to monitor and record activated carbon flow 

6 
The parameter monitoring costs estimated for the 1997 regulation were updated to 2007 

dollars using the CEPCI and latest labor rates and rounded to the nearest $100. Good combustion 

capital and annual monitoring costs were estimated to be $20,500 and $6,000/yr, respectively, for 

the small rural model. Wet scrubber capital monitoring costs were estimated at $27,400 for the 

small, medium, and large models; the annual monitoring costs were estimated to range from 

$7,700/yr to $11,000/yr for the small, medium, and large models. DIFF capital monitoring costs 

were estimated at $21,500 for the medium and large models; the annual monitoring costs were 

estimated to range from $8,300/yr to $14,900/yr for the medium and large models. FF capital 

monitoring costs were estimated the same as those for DIFF ($21,500), but the annual monitoring 

costs ($10,100/yr for the large model) do not include the cost to monitor HCl sorbent flow rate. 

Wet/dry scrubber combinations include a combination of the costs for wet scrubbers and DIFF. 

DIFF/WS capital and annual monitoring costs were estimated to be $27,500 and $16,000/yr, 

respectively, for the large model. For the purposes of this cost analysis, the capital monitoring 

costs for the large HMIWI equipped with DI-ESP/WS, WS/WESP, and HEPA/CA/WS were 

assumed to be identical to the capital monitoring cost for DIFF/WS, but the annual monitoring 

costs for WS/WESP and HEPA/CA/WS ($11,200/yr for the large model) would not include the 

cost to monitor HCl sorbent flow rate. ACI annual monitoring costs were estimated to range from 

$1,600/yr to $4,800/yr for the medium and large models; there are no capital costs associated with 

ACI systems. 

Two large HMIWI currently use SNCR systems and would be expected to monitor 

ammonia or urea injection rate. Costs to purchase and install an ammonia injection rate sensor 

with data acquisition system and data reduction were estimated by EPA in August 2008.26 These 

SNCR monitoring costs were adapted to the cost format in Table 11 and rounded to the nearest 

$100. The SNCR capital and annual monitoring costs for the large model were estimated to be 

$10,200 and $3,100/yr, respectively. 

D. Stack Testing

Under the 1997 HMIWI regulation, HMIWI are required to demonstrate ongoing 

compliance as follows: 

● Small rural HMIWI: Demonstrate ongoing compliance with the emission limit for 

opacity by conducting annual opacity stack tests. 

● All other HMIWI: Demonstrate ongoing compliance with the emission limits for HCl, 

CO, PM, and opacity by conducting annual stack tests for those pollutants. 

Annual stack test costs developed for each EPA test method for the 1997 regulation were 

updated to 2007 dollars using the CEPCI, adjusted as necessary to conform to the range of more 

recent, typical test costs, and rounded to the nearest $1,000 (except for the less expensive opacity 

test, which was rounded to the nearest $100).25,27,28 The updated and adjusted stack test costs are 

presented in Table 14 for all model HMIWI. Annual stack test costs were estimated at $12,000 for 

EPA Method 5 (PM); $2,500 for EPA Method 9 (opacity); and $7,000 each for EPA Methods 10 

(CO) and 26 (HCl). 

7 
E. Recordkeeping and Reporting Costs

The 1997 HMIWI regulation imposes the following recordkeeping and reporting burden on 

HMIWI: 

● Annual update of operating information—1 person-hour 

● Review of operating information with each operator (assume 2 operators)—16 personhours 

● Annual report of CMS operating parameters—32 person-hours 

● Annual report of no exceedances—8 person-hours per pollutant (1 pollutant small 

rural; 4 pollutants all other HMIWI) 

● Annual report of performance test results—8 person-hours (small rural); 40 personhours (all other HMIWI) 

● Records of startup, shutdown, and malfunction (weekly)—1.5 person-hours 

● Records of persons completing review of operating information (assume 2 operators)—

2 person-hours 

● Records of operating parameters (weekly)—0.5 person-hours (small rural); 1.5 personhours (all other HMIWI) 

● Records of CMS operation and maintenance (daily)—0.025 person-hours 

● Time to train personnel (EPA Methods 9 and 22)—40 person-hours 

Some of these burden items apply to all HMIWI, while others apply to only certain 

HMIWI (e.g., small rural units). The burden estimate for reporting CMS operating parameters (32 

person-hours) was determined by dividing the cost to certify CMS ($1,400/yr) by the composite 

hourly labor rate ($43.60/hr). The cost to certify CMS was based on an estimate for the 1997 

regulation.25 That cost estimate was updated to 2007 dollars using the CEPCI. The composite 

hourly labor rate was determined (as shown in the following bullets) based on occupational 

employment statistics available online from the U.S. Bureau of Labor Statistics, which were 

adjusted upwards by 60 percent to include overhead and profit.7

● Technical labor rate (natural resources, construction, and maintenance) = (total 

compensation of $23.47/hr) x (overhead and profit rate of 1.6) = $37.55/hr 

● Management labor rate (management, professional, and related) = (total compensation 

of $49.23/hr) x (overhead and profit rate of 1.6) = $78.76/hr 

● Clerical labor rate (sales and office) = (total compensation of $13.19/hr) x (overhead 

and profit rate of 1.6) = $21.10/hr 

● Composite hourly labor rate = (technical labor rate) + (0.05 x management labor rate) 

+ (0.1 x clerical labor rate) = $43.60/hr 

The management and clerical burden for each HMIWI were estimated at 5 and 10 percent 

of the technical burden, respectively. The recordkeeping and reporting costs for each HMIWI 

were estimated by multiplying the technical, management, and clerical burden estimates by their 

respective labor rates and summing the costs. The results are presented in Table 15. 

8 
F. Autoclave/Landfill Alternative to Compliance

The primary alternative to the compliance options is onsite autoclaving, followed by 

landfilling the waste. The costs for this alternative are presented for each model HMIWI in Table 

16 and were estimated using cost estimates provided by an autoclave vendor and an online 

source.29,30

Cost estimates from the vendor included capital costs for the sterilizer and compactor; 

operational costs for chamber liners, labor, capital expense, maintenance, steam, and electricity; 

and hauling costs; the vendor also provided costs for a biological indicators test (including test 

kit).29 Inspection costs and permit fees were obtained from an online source.30 Annual autoclave 

costs were calculated in units of $/lb by dividing the daily cost (in $/d) provided by the vendor by 

the daily charge rate (lb/d), also provided by the vendor. The other annual costs (biological 

indicators test, inspection costs, and permit fees) were calculated in units of $/lb by dividing the 

costs by the daily charge rate (lb/d) and annual operating days (d/yr) provided by the vendor. 

These costs were then added to the annual autoclave cost. 

The hauling costs from the vendor were revised to extract landfill costs. National average 

landfill tip fees from the 2005 Tip Fee Survey prepared by the National Solid Wastes Management 

Association (NSWMA) were then used to estimate model landfill costs.4 The total annual 

autoclave/landfill costs in Table 16 are presented in $/lb of waste and in $/yr. Calculation of the 

costs in $/yr assumes each model HMIWI operates at two-thirds of its capacity. The $/yr costs 

range from $9,100/yr to $205,000/yr. 

III. Nationwide Costs

The size category of the combustor (large, medium, small, small rural) and the types of 

emission controls currently employed at each HMIWI were used to determine the baseline 

operating costs. See Table 17 for the size category assigned to each HMIWI (consistent with the 

HMIWI size definitions in the 1997 regulation) and the list of emission controls currently 

employed at each HMIWI. The model costs associated with combustor operation and emission 

controls were assigned to the 57 HMIWI, based on which size category (large, medium, small 

non-rural, small rural) the HMIWI belonged. For example, large model costs for a combustor, 

DIFF, and ACI systems were applied to a large HMIWI using a DIFF and ACI system to comply 

with the 1997 regulation. Baseline combustor and emission control costs were applied on a unitspecific basis by using model $/flow values, which were multiplied by unit-specific flow rates to 

determine $/yr. Note: Indirect annual costs (e.g., capital recovery costs) for combustors and 

emission controls were not included in the assigned model costs; in a comparison of baseline 

operating costs to autoclave/landfill costs, the indirect annual costs for combustors and emission 

controls already in place would be incurred regardless of whether that equipment is still used. In 

addition to combustor and emission control costs, monitoring costs associated with DIFF and ACI 

systems were also applied. 

Table 17 shows the baseline combustor, emission control, and monitoring cost estimates 

applied to each HMIWI and presents nationwide totals. Baseline combustor costs were estimated 

to be approximately $16 million/yr (including $15 million/yr for the large units; $1.2 million/yr 

9 
for the medium units; $220,000/yr for the small units; and $92,000/yr for the small rural units). 

Baseline control costs were estimated to be approximately $11 million/yr (including $10 

million/yr for the large units; $710,000/yr for the medium units; and $65,000/yr for the small 

units). There are no control costs for the small rural units, which employ only good combustion. 

The baseline control costs presented in Table 17 include ACI costs for two HMIWI that were 

inadvertently omitted from the previous version of this memorandum.1 Baseline monitoring costs 

were estimated to be approximately $520,000/yr (including $420,000/yr for the large units; 

$84,000/yr for the medium units; $11,000/yr for the small units; and $8,400/yr for the small rural 

units). The baseline monitoring costs presented in Table 17 have been revised to remove one 

HMIWI’s CO CEMS costs, which were inadvertently included in the previous version of this 

memorandum.1 

Baseline stack testing costs were also assigned to individual HMIWI, based on their testing 

requirements under the 1997 regulation. For example, costs for PM, CO, HCl, and opacity tests 

were applied to all of the large, medium, and small HMIWI, which are required to test for those 

pollutants on an annual basis. The total cost for multiple stack tests such as these was adjusted by 

two-thirds to account for travel, accommodations, test methods/sampling trains, etc. that are 

common to the various stack tests.28 (Opacity tests are the exception since that test method cannot 

be combined with any others.) Because small rural HMIWI are only required to test for opacity 

on an annual basis, only the costs for opacity tests were applied to those units. Table 17 presents 

the baseline testing costs assigned to all 57 HMIWI (approximately $710,000/yr for the large 

units; $340,000/yr for the medium units; $40,000/yr for the small units; and $5,000/yr for the 

small rural units, for a nationwide total of $1.1 million/yr). 

Baseline recordkeeping and reporting costs were assigned based on which HMIWI would 

be required to conduct those activities under the 1997 regulation. For example, small rural 

HMIWI were assigned lower costs for submitting annual reports and keeping records of operating 

parameters compared to all other units because the requirements for small rural HMIWI under the 

1997 regulation are less stringent (fewer pollutants to test, fewer parameters to monitor). Table 17 

presents the baseline recordkeeping and reporting costs assigned to all 57 HMIWI (approximately 

$550,000/yr for the large units; $260,000/yr for the medium units; $30,000/yr for the small units; 

and $21,000/yr for the small rural units, for a nationwide total of $860,000/yr). The baseline 

recordkeeping and reporting costs presented in Table 17 have been revised to correct a mistake in 

the calculation of those costs for the two small rural HMIWI. 

Including the costs of emission controls, monitoring, testing, and recordkeeping/reporting, 

the total nationwide costs at baseline were estimated at approximately $30 million/yr (including 

$27 million/yr for the large units; $2.6 million/yr for the medium units; $370,000/yr for the small 

units; and $130,000/yr for the small rural units). 

Costs for the primary alternative to compliance (i.e., autoclaving and landfilling the waste) 

were also assigned to each HMIWI, so that the costs for this alternative could be compared to the 

total baseline operating costs for each HMIWI. Regional average landfill tip fees from NSWMA’s 

2005 Tip Fee Survey were used in estimating the nationwide autoclave/landfill costs.4

 For 

example, the regional average tip fee for the Mid-Atlantic region was used in estimating the 

autoclave/landfill costs for HMIWI in Maryland, Pennsylvania, and West Virginia. An 

10 
autoclave/landfill cost (in $/yr) was calculated for each HMIWI by taking the applicable model 

autoclave cost (in $/lb of waste) and regional average tip fee (in $/ton of waste), converting them 

into compatible units, and multiplying them by the annual operating hours and charge rate for the 

HMIWI (assuming each HMIWI operates at two-thirds of its capacity). See Table 18 for the 

autoclave/landfill costs estimated for each HMIWI and nationwide. 

As shown in Table 18, autoclave/landfill costs are approximately $11 million/yr (including 

$10 million/yr for large units; $540,000/yr for medium units; $40,000/yr for small units; and 

$18,000/yr for small rural units). The nationwide autoclave/landfill costs are estimated to be 36 

percent of the baseline operating costs for all HMIWI nationwide (37 percent for large, 21 percent 

for medium, 11 percent for small, and 14 percent for small rural units). It should be noted, 

however, that nearly 50 percent of HMIWI are known to practice waste heat recovery (see Table 

18), which may offset some of these HMIWI operating costs. Table 19 presents a summary of the 

nationwide baseline operating costs and autoclave/landfill costs. 

IV. References

1. Memorandum from Thomas Holloway, RTI, to Mary Johnson, EPA. October 24, 2008. 

Baseline Operating Costs for Existing HMIWI. 

2. U.S. Environmental Protection Agency. July 1994. Medical Waste Incinerators--

Background Information for Proposed Standards and Guidelines: Model Plant Description 

and Cost Report for New and Existing Facilities. Publication Number EPA-453/R-94-045a. 

(Docket item no. II-A-112)

3. Energy Information Administration. 2007. Average Retail Price of Electricity to Ultimate 

Customers by End-Use Sector. Industrial Sector, 2006. Web site: 

http://www.eia.doe.gov/cneaf/electricity/epa/epat7p4.html. Accessed July 8, 2008. 

4. Edward W. Repa. 2005. NSWMA’s 2005 Tip Fee Survey. NSWMA Research Bulletin 05-3. 

Web site: http://wastec.isproductions.net/webmodules/webarticles/articlefiles/478-

Tipping%20Fee%20Bulletin%202005.pdf. Accessed July 8, 2008. 

5. Energy Information Administration. 2007. Natural Gas Prices. Industrial Price, December 

2007. Web site: http://www.eia.doe.gov/oil_gas/natural_gas/info_glance/natural_gas.html. 

Accessed July 8, 2008. 

6. U.S. Environmental Protection Agency. 2003. Air Compliance Advisor (ACA) Air Pollution 

Control Technology Evaluation Model version 7.5. (Technology Transfer Network, Clean 

Air Technology Center.) Website: http://www.epa.gov/ttncatc1/products.html. Accessed 

July 8, 2008. 

7. Bureau of Labor Statistics. 2007. May 2007 National Industry-Specific Occupational 

Employment and Wage Estimates. Web site: http://www.bls.gov/oes/current/oessrci.htm. 

Accessed July 8, 2008. 

11 
8. Memorandum from Thomas Holloway, RTI, to MWI Project File. September 7, 1995. 

Approach Used to Estimate the Capital and Annual Costs for MWI Wet Scrubbers. (Docket 

item no. IV-B-30)

9. Purchasing Staff. 2007. Caustic Soda Price Hike Is On The Horizon. Web site: 

http://www.purchasing.com/article/CA6472577.html. Accessed July 8, 2008. 

10. Pollution Prevention (P2) Pays, NC Division of Pollution Prevention and Environmental 

Assistance. 2004. Determine the Cost of Compressed Air for Your Plant. Energy Tips – 

Compressed Air, Compressed Air Tip Sheet #1. August. Web site: 

http://www.p2pays.org/ref/40/39536.pdf. Accessed July 9, 2008. 

11. Memorandum from David Randall, RTI, to Rick Copland, EPA. January 29, 1996. Revised 

Costs for Dry Injection/Fabric Filter Controls for MWI’s. (Docket item no. IV-B-32) 

12. U.S. Geological Survey. 2008. Mineral Commodity Summaries 2008: Lime, 2007. Web site: 

http://minerals.usgs.gov/minerals/pubs/commodity/lime/mcs-2008-lime.pdf. Accessed July 

16, 2008. 

13. U.S. Environmental Protection Agency. September 1999. OAQPS Control Cost Manual. 

Section 6: Particulate Matter Controls. Chapter 3: Electrostatic Precipitators. Publication 

Number EPA/452/B-02-001.

14. U.S. Environmental Protection Agency. September 1999. OAQPS Control Cost Manual. 

Section 3: VOC Controls, Section 3.1: VOC Recapture Controls. Chapter 1: Carbon 

Adsorbers. Publication Number EPA/452/B-02-001 

15. The Innovation Group. 2003. Chemical Profiles: Activated Carbon. Current (2002) Price. 

Web site: http://www.the-innovation-group.com/ChemProfiles/Activated%20Carbon.htm. 

Accessed July 8, 2008. 

16. Norit Americas. 2006. 2007 Price Announcement. Web site: http://www.noritamericas.com/pressrelease1.html. Accessed July 15, 2008. 

17. Norit Americas. 2007. Norit Americas Announces 2008 Price Increase. Web site: 

http://www.norit-americas.com/pressrelease11.html. Accessed July 15, 2008. 

18. U.S. Environmental Protection Agency. November 1999. EPA Technical Bulletin: Nitrogen 

Oxides (NOX)--Why and How They Are Controlled. Clean Air Technology Center. 

Publication Number EPA/456/F-99-006R.

19. . U.S. Environmental Protection Agency. October 2000. OAQPS Control Cost Manual. 

Section 4.2: NOX Post-Combustion. Chapter 1: Selective Noncatalytic Reduction. 

Publication Number EPA/452/B-02-001. 

12 
13 

20. De-NOX Technologies, LLC. 2008. On-Site Urea Dissolving Systems. Web site: 

http://www.de-nox.com/bulk%20urea.htm. Accessed July 25, 2008.

21. EPRI. September 2002. Design and Cost Estimating Procedures for SCR and SNCR 

Retrofits on Gas- and Oil-Fired Boilers. 

22. U.S. Environmental Protection Agency. July 1994. Medical Waste Incinerators--

Background Information for Proposed Standards and Guidelines: Process Description 

Report for New and Existing Facilities. Publication Number EPA-453/R-94-043a. (Docket 

item no. II-A-110)

23. Memorandum from Thomas Holloway, RTI, to Ketan Patel, EPA. July 6, 2009. Revised 

Baseline Emissions and Emissions Reductions for Existing and New HMIWI. 

24. Memorandum from Thomas Holloway, RTI, to Rick Copland, EPA. August 31, 1992. 

Industry Comments on Maintenance/Inspection and Monitoring Programs for Medical Waste 

Incinerators. (Docket item no. II-B-88) 

25. Memorandum from Thomas Holloway, RTI, to Rick Copland, EPA. March 17, 1997. 

Revised Testing and Monitoring Options and Costs for Medical Waste Incinerators 

(MWI’s)—Methodology and Assumptions. (Docket item no. IV-B-66) 

26. Memorandum from Peter Westlin, EPA, to Mary Johnson, EPA. August 19, 2008. 

Monitoring approaches and associated costs for medical waste incinerator NOX emissions 

control (SNCR). 

27. E-mail from Jason Dewees, EPA, to Peter Westlin, EPA. August 20, 2008. “Monitoring 

Options for SNCR & Test Cost Questions.” 

28. E-mail from Jason Dewees, EPA, to Mary Johnson, EPA. August 20, 2008. “Re: Monitoring 

Options for SNCR & Test Cost Questions.” 

29. Contact report from Thomas Holloway, RTI, to project file. July 28, 2008. Summary of 

telephone conversation with Arthur McCoy, San-I-Pak, Inc. Autoclave Cost Estimates for 

Large, Medium, and Small Models. 

30. Association of Bay Area Governments. 2003. Bay Area Dioxins Project, Autoclaving Cost 

Worksheet, June 2003. Web site: 

http://dioxin.abag.ca.gov/pilot_projs/AutoclavingCostWorksheet.xls. Accessed July 21, 

2008.
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

1 1 Bristol-Myers Squibb Co. Wallingford CT L E FF Secondary chamber (1800F) and baghou5 5 Merck & Company, Inc. Rahway NJ L E DIFF Secondary chamber (1500F, 1 sec), partia

dry acid gas scrubber with dry lime injectiobaghouse

15 15--1 Curtis Bay Energy Unit 1 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and ba

with activated carbon injection

15 15--2 Curtis Bay Energy Unit 2 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and ba

with activated carbon injection

36 36--1 Merck & Company, Inc. Unit 2 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary/tertiary chamber (2000F, 2 sec

quench followed by sodium bicarbonate insystem with dry reaction chamber and pubaghouse

36 36--2 Merck & Company, Inc. Unit 5 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary chamber (1800F, 2.2 sec), wa

followed by sodium bicarbonate injection pulse-jet baghouse

40 40 Charleston Area Medical Center, General Hospital Charleston WV L E DIFF Secondary chamber (1800F, 2 sec), dry 

injection/baghouse scrubber system with carbon

42 42 Stericycle, Inc. Apopka FL L E DIFF Secondary chamber (1800, 1 sec), dry sc

system with quench chamber, passive aband carbon injection, and baghouse.

51 51 Lakeland Regional Medical Center Lakeland FL L E DIFF Secondary chamber (1800F, 1 sec), lime 

system, and baghouse

60 60--1 BMWNC, Inc. Unit 1 Matthews NC L E DIFF Secondary chamber (1641F), dry scrubbe

and activated carbon injection, and bagho

84 84 Mayo Clinic, Waste Management Facility Rochester MN L E DIFF Secondary chamber (1800F, 1 sec) and b

with lime and carbon injection

j

87 87 MedCentral Health System, Mansfield Hospital Mansfield OH L E DIFF Secondary chamber (1800F, 2 sec) and b

with lime and carbon injection system

109 109 Healthcare Environmental Services Inc. Fargo ND L E DIFF Secondary chamber (1800F) and dry 

scrubber/baghouse system with lime and injection

120 120--1 Waste Management Resource Recovery and Recycling 

Center

Unit 1 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin 

injection, urea injection, and activated carinjection

120 120--2 Waste Management Resource Recovery and Recycling 

Center

Unit 2 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin 

injection, urea injection, and activated carinjection

29 29 Hamot Medical Center Erie PA L E DIFF/WS Secondary chamber (2000F, 2 sec), lime 

system, powdered activated carbon injectbaghouse, and vertical upflow two-stage mmicroventuri scrubber system

55 55 St. Joseph's Hospital Tampa FL L E DIFF/WS Secondary chamber (1800F, 1 sec), lime 

baghouse, and venturi scrubber

110 110 Stericycle, Inc. North Salt Lake UT L E DI-ESP/WS Secondary chamber (1834F), carbon injec

system, ESP, dry scrubber, and wet scrub

125 125 East Carolina University, Health Sciences Campus, 

HSC Utility Plant

Greenville NC L N HEPA/CA/

WS

Secondary chamber (1985F), rotary atomscrubber (with NaOH scrubbing medium), bed adsorber, HEPA filtering system, and recovery system

20 20--1 Fort Detrick Unit 5 Fort Detrick MD L E WS Secondary chamber and rotary atomizing 

scrubber

20 20--2 Fort Detrick Unit 6 Fort Detrick MD L E WS Secondary chamber and rotary atomizing 

scrubber

43 43 Boca Raton Community Hospital Boca Raton FL L E WS Secondary chamber (1800F, 1 sec) and ro

atomizing wet scrubber system with caustinjection

44 44 Bethesda Memorial Hospital Boynton Beach FL L E WS Secondary chamber (1800F, 2 sec) and ro

atomizing scrubber with mist eliminator
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

46 46 Holy Cross Hospital Fort Lauderdale FL L E WS Secondary chamber (1800F, 1 sec) and v

scrubber with packed bed absorption unit dilute NaOH

48 48 Memorial Regional Hospital Hollywood FL L E WS/WESP Secondary chamber (1800F, 1 sec), pack

gas scrubber, and wet ESP

54 54 Bayfront Medical Center St. Petersburg FL L E WS Secondary chamber (1800F, 1 sec) and fl

force/condensation collision scrubber sysdilute NaOH

59 59--1 Stericycle, Inc. Unit 1 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid 

quench system, wet scrubber system conpacked bed absorber and venturi scrubbedemister.

59 59--2 Stericycle, Inc. Unit 2 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid 

quench system, wet scrubber system conpacked bed absorber and venturi scrubbedemister.

65 65--1 Stericycle, Inc. Unit 1 Clinton IL L E WS Secondary chamber (1800F), venturi scru

condensing absorber

65 65--2 Stericycle, Inc. Unit 2 Clinton IL L E WS Secondary chamber (1800F), venturi scru

condensing absorber

71 71 Loyola University Medical Center Maywood IL L E WS Two secondary chambers (1600F), twin ro

atomizer scrubber using 50% caustic solutwo demister pads

77 77 Parkview Hospital Fort Wayne IN L E WS Secondary chamber and wet scrubber 94 94 Stericycle, Inc. Warren OH L E WS Secondary chamber (1800F, 2 sec), wet s98 98--1 University of Texas Medical Branch Galveston TX L E WS Secondary chamber, packed tower, and v

scrubber with activated carbon injection

106 106 Steric 106 106 Stericycle, Inc. Kansas Cit Inc. Kansas City KS L E WS Secondar KS L E WS Secondary chamber chamber (1800F, 2 sec), wet s

wet s

130 130 Department of Veterans Affairs Medical Center Miami FL L E WS Secondary chamber (1800F, 1 sec), ventu

scrubber, and packed tower absorber

Avge L 

Avge L, dry

Avge L, wet

38 38 Wilkes-Barre General Hospital Wilkes-Barre PA M N DIFF Secondary/tertiary chambers (1800F, 2.85 

dry scrubber/baghouse with lime and activcarbon injection

63 63 St. Jude Children's Research Hospital Memphis TN M E DIFF Secondary chamber (1528F) and baghou

sodium bicarbonate and carbon injection

95 95 St. Joseph's Hospital Marshfield WI M E DIFF Secondary chamber (1800F), quench tow

baghouse with lime/carbon injection

13 13 University of Maryland at Baltimore, Environmental 

Health and Safety Facility

Baltimore MD M E WS Secondary chamber (1832F) and venturi 

scrubber with packed-bed scrubber

16 16 Johns Hopkins Medical Institute, Department of Health, 

Safety, and Environment

Baltimore MD M E WS Secondary chamber (1800F) and venturi w

scrubber followed by saturation chamber eliminator

18 18 Franklin Square Hospital Center Baltimore MD M E WS Secondary chamber (1800F) and venturi 

followed by quench chamber and mist elim

21 21 Washington County Hospital Hagerstown MD M E WS Secondary chamber and venturi caustic s25 25 Holy Spirit Hospital Camp Hill PA M E WS Secondary chamber (1800F) and venturi s

with prequench and NaOH injection

30 30 Riddle Memorial Hospital Media PA M E WS Secondary chamber (1800F, 2 sec), caus

tower scrubber, and high pressure venturactivated carbon injection

34 34 Pennsylvania State University, Animal Diagnostic Lab 

Incinerator

State College PA M E WS Secondary chamber (1900F) and rotary a

wet scrubber with demister

41 41 Thomas Memorial Hospital South Charleston WV M E WS Secondary chamber (1800F) and venturi 

tower wet scrubber with caustic injection

47 47 Malcolm Randall Veterans Affairs Medical Center Gainesville FL M E WS Secondary chamber (1800F, 1 sec) and w

scrubber with caustic soda injection

81 81 South Bend Medical Foundation South Bend IN M E WS Secondary chamber and wet scrubber 
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

82 82 Good Samaritan Hospital Vincennes IN M E WS Secondary chamber and multi-chamber s

scrubber

88 88 Medina General Hospital Medina OH M E WS Secondary chamber (1800F, 1 sec) and w

scrubber

108 108--1 Rocky Mountain Laboratories, National Institute of 

Allergy and Infectious Diseases

Unit 1 Hamilton MT M E WS Secondary chamber and wet scrubber 

111 111 Wyoming Medical Center Casper WY M E WS Secondary chamber and wet scrubber 

Avge M 

Avge M, dry

Avge M, wet

86 86 Fairfield Medical Center Lancaster OH S E WS Secondary chamber (1800F, 1 sec) and w

scrubber

129 129 Centers for Disease Control and Prevention--Clifton, 

Building 18

Unit 3 Atlanta GA S N WS Secondary chamber (1800F, 1.68 sec) an

atomizing wet scrubber

Avge S 

115 115 Kona Community Hospital Kealakekua HI SR E CC Secondary chamber (1900F, 2 sec), no A116 116 Yukon-Kuskokwim Delta Regional Hospital Bethel AK SR E CC Secondary chamber, no APCD 

Avge SR 

Notes:

1. Assumed values are highlighted in yellow.2. For dry APCD, 95% HCl control assumed based on average % HCl control (96.59%) for several of the HMIWI in database equipped with dry APCD, and99% PM control assumed based on % Pb and Cd control (99.6% and 99.2%) for a recently shutdown HMIWI (Northwest Hospital Center) equipped with a dry APCD.

3. For wet APCD, 99% HCl control assumed based on % HCl control (99.29%) for an HMIWI in database equipped with a wet APCD, and

85% PM control assumed based on % Pb and Cd control (87.2% and 88.4%) for a recently shutdown HMIWI (Northwest Hospital Center) equipped with a dry APCD.
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number

1 1 Bristol-Myers Squibb Co.5 5 Merck & Company, Inc.

15 15--1 Curtis Bay Energy Unit 115 15--2 Curtis Bay Energy Unit 236 36--1 Merck & Company, Inc. Unit 236 36--2 Merck & Company, Inc. Unit 540 40 Charleston Area Medical Center, General Hospital42 42 Stericycle, Inc.51 51 Lakeland Regional Medical Center60 60--1 BMWNC, Inc. Unit 184 84 Mayo Clinic, Waste Management Facility

Stack gas 

temperature 

(°F)

Operating 

hours (hr/yr)

HCl 

(ppmvd)

HCl % 

reduction

HCl unc. 

(ppmvd) PM (gr/dscf)

PM % 

reduction

PM unc. 

(gr/dscf) 

217 2,072 65.7 0.00180 99.00% 0.180 246 4,321 0.780 0.00330 99.00% 0.330 296 8,736 85.2 93.19% 1,251 0.00823 99.00% 0.823 303 8,736 76.9 92.27% 994 0.00407 99.00% 0.407 358 865 4.22 0.00156 99.00% 0.156 304 5,753 3.75 0.00255 99.00% 0.255 312 1,248 26.6 0.00106 99.00% 0.106 327 7,951 27.1 0.00203 99.00% 0.203 212 6,247 2.68 0.00254 99.00% 0.254 343 7,456 38.8 96.24% 1,031 0.00504 99.00% 0.504 294 6,240 15.2 96.93% 497 0.0137 99.00% 1.367 

87 87 MedCentral Health System, Mansfield Hospital

109 109 Healthcare Environmental Services Inc.120 120--1 Waste Management Resource Recovery and Recycling 

Center

Unit 1

120 120--2 Waste Management Resource Recovery and Recycling 

Center

Unit 2

29 29 Hamot Medical Center55 55 St. Joseph's Hospital

110 110 Stericycle, Inc.125 125 East Carolina University, Health Sciences Campus, 

HSC Utility Plant

20 20--1 Fort Detrick Unit 520 20--2 Fort Detrick Unit 643 43 Boca Raton Community Hospital44 44 Bethesda Memorial Hospital

260 3,120 24.8 0.00357 99.00% 0.357 302 1,872 72.5 0.00611 99.00% 0.611 296 7,896 11.0 98.76% 888 0.00702 99.00% 0.702 291 7,896 5.30 99.11% 594 0.00947 99.00% 0.947 122 2,080 16.6 0.00174 99.00% 0.174 400 8,008 12.5 0.00111 99.00% 0.111 126 7,309 3.93 0.00449 99.00% 0.449 125 625 1.58 99.996% 43,053 0.00323 99.00% 0.323 

87 1,300 0.190 0.00721 85.00% 0.048 92 1,300 0.353 0.00775 85.00% 0.052 91 8,736 0.986 0.0104 85.00% 0.069 

106 3,024 0.608 0.00960 85.00% 0.064 
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number

46 46 Holy Cross Hospital48 48 Memorial Regional Hospital54 54 Bayfront Medical Center59 59--1 Stericycle, Inc. Unit 159 59--2 Stericycle, Inc. Unit 265 65--1 Stericycle, Inc. Unit 165 65--2 Stericycle, Inc. Unit 271 71 Loyola University Medical Center77 77 Parkview Hospital94 94 Stericycle, Inc.98 98--1 University of Texas Medical Branch

106 106 Stericycle, Inc.

Stack gas 

temperature 

(°F)

Operating 

hours (hr/yr)

HCl 

(ppmvd)

HCl % 

reduction

HCl unc. 

(ppmvd) PM (gr/dscf)

PM % 

reduction

PM unc. 

(gr/dscf) 

124 2,964 1.18 0.0103 85.00% 0.069 143 4,992 1.02 0.00973 85.00% 0.065 133 3,352 0.947 0.00543 85.00% 0.036 135 8,400 4.24 0.00714 85.00% 0.048 138 8,400 3.88 0.0102 85.00% 0.068 143 7,665 1.12 0.00921 85.00% 0.061 141 7,558 1.43 0.00878 85.00% 0.059 156 4,800 2.22 0.0105 85.00% 0.070 114 8,395 2.68 99.29% 380 0.0109 85.00% 0.073 138 7,904 0.661 0.00617 85.00% 0.041 111 5,328 2.12 0.0147 85.00% 0.098 

106 106 Stericycle, Inc. 152 8,760 0.567 0.00828 85.00% 0.055 

130 130 Department of Veterans Affairs Medical Center

38 38 Wilkes-Barre General Hospital63 63 St. Jude Children's Research Hospital95 95 St. Joseph's Hospital13 13 University of Maryland at Baltimore, Environmental 

Health and Safety Facility

16 16 Johns Hopkins Medical Institute, Department of Health, 

Safety, and Environment

18 18 Franklin Square Hospital Center21 21 Washington County Hospital25 25 Holy Spirit Hospital30 30 Riddle Memorial Hospital34 34 Pennsylvania State University, Animal Diagnostic Lab 

Incinerator

41 41 Thomas Memorial Hospital47 47 Malcolm Randall Veterans Affairs Medical Center81 81 South Bend Medical Foundation

152 8,760 0.567 0.00828 85.00% 0.055 155 4,160 8.32 99.00% 832 0.0111 85.00% 0.074 154 5,997 3.82 98.76% 888 0.007 0.108 291 24.83 96.59% 0.004127 1.12 99.15% 0.010274 4,472 8.95 95.00% 179 0.00399 99.00% 0.399 276 1,050 27.5 95.00% 551 0.00505 99.00% 0.505 223 1,404 5.27 95.00% 105 0.00294 99.00% 0.294 189 1,440 0.708 99.00% 71 0.0126 85.00% 0.084 179 1,350 1.39 99.00% 139 0.0294 85.00% 0.196 

54 5,408 1.48 99.00% 148 0.0256 85.00% 0.170 

112 2,496 6.26 99.00% 626 0.0197 85.00% 0.131 

99 3,944 0.736 99.00% 74 0.0164 85.00% 0.110 

239 2,920 2.10 99.00% 210 0.0124 85.00% 0.083 175 1,022 1.27 99.00% 127 0.0239 85.00% 0.159 146 2,080 2.62 99.00% 262 0.0261 85.00% 0.174 115 1,664 4.69 99.00% 469 0.0173 85.00% 0.115 121 2,028 12.3 99.00% 1,230 0.01159 85.00% 0.077 
Table 1. Basis for Model HMIWI Parameters

FACID UNITID Facility name

Unit 

number

82 82 Good Samaritan Hospital88 88 Medina General Hospital

108 108--1 Rocky Mountain Laboratories, National Institute of 

Allergy and Infectious Diseases

Unit 1

111 111 Wyoming Medical Center

86 86 Fairfield Medical Center

129 129 Centers for Disease Control and Prevention--Clifton, 

Building 18

Unit 3

115 115 Kona Community Hospital116 116 Yukon-Kuskokwim Delta Regional Hospital

Notes:

1. Assumed values are highlighted in yellow.2. For dry APCD, 95% HCl control assumed based on average % HCl control (96.5999% PM control assumed based on % Pb and Cd control (99.6% and 99.2%) for a re3. For wet APCD, 99% HCl control assumed based on % HCl control (99.29%) for a85% PM control assumed based on % Pb and Cd control (87.2% and 88.4%) for a re

Stack gas 

temperature 

(°F)

Operating 

hours (hr/yr)

HCl 

(ppmvd)

HCl % 

reduction

HCl unc. 

(ppmvd) PM (gr/dscf)

PM % 

reduction

PM unc. 

(gr/dscf) 

128 2,574 1.58 99.00% 158 0.0137 85.00% 0.091 100 3,016 3.29 99.00% 329 0.0267 85.00% 0.178 112 1,248 0.455 99.00% 46 0.0216 85.00% 0.144 130 989 1.17 99.00% 117 0.00336 85.00% 0.022 130 2,028 2.10 158 0.016 0.144 258 8.95 0.004136 5.48 0.018

97 5,018 1.03 99.00% 103 0.0137 85.00% 0.091 

163 2,920 1.30 99.00% 130 0.00760 85.00% 0.051 130 3,969 1.16 116 0.011 0.071 

1,787 1,430 135 135 0.0128 0.0128 

1,457 1,560 298 298 0.0162 0.0162 

1,622 1,495 216 216 0.015 0.015 
Table 2. Summary of Model HMIWI Combustor and Control Costs

Control option Pollutants controlled Large Medium SmaA. Total Capital Investment, $

1. Combustor PM, CO, CDD/CDF $954,948 $212,177 $1022. Packed-bed scrubber HCl, SO2 $452,658 $327,726 

3. Venturi scrubber HCl, Pb, Cd, Hg, PM, CDD/CDF, SO2 $625,073 $625,073 $4244. Fabric filter Pb, Cd, Hg, PM, CDD/CDF $1,017,892 -- 5. Dry injection fabric filter HCl, Pb, Cd, Hg, PM, CDD/CDF, SO2 $1,363,508 $1,074,716 

6. Electrostatic precipitator (dry) Pb, Cd, Hg, PM, CDD/CDF $1,067,363 -- 7. Electrostatic precipitator (wet) Pb, Cd, Hg, PM, CDD/CDF $607,438 -- 8. Selective noncatalytic reduction NOX $585,709 -- 

9. Activated carbon injection system Hg, CDD/CDF $11,989 $7,425 

B. Annual Costs, $/yr

1. Combustor PM, CO, CDD/CDF $366,304 $88,751 $1182. Packed-bed scrubber HCl, SO2 $104,101 $65,687 3. Venturi scrubber HCl, Pb, Cd, Hg, PM, CDD/CDF, SO2 $192,484 $159,654 $834. Fabric filter Pb, Cd, Hg, PM, CDD/CDF $267,793 -- 5. Dry injection fabric filter HCl, Pb, Cd, Hg, PM, CDD/CDF, SO2 $347,053 $206,105 

6. Electrostatic precipitator (dry) Pb, Cd, Hg, PM, CDD/CDF $220,178 -- 7. Electrostatic precipitator (wet) Pb, Cd, Hg, PM, CDD/CDF $157,544 -- 8. Carbon adsorber Hg, CDD/CDF $6,754 -- 9. Selective noncatalytic reduction NOX $67,918 -- 

10. Activated carbon injection system Hg, CDD/CDF $56,313 $12,522 11. Autoclave/landfill Alternative to compliance $205,273 $27,758 $19

Note:

1. Annual costs for carbon adsorber do not include indirect annual costs (e.g., capital recovery costs).2. National average landfill tip fees used to estimate model autoclave/landfill cost.
Table 3. Combustor Model Costs

Parameters/Costs Equation Large Medium Small Small ruralA. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 500 100 125

2. Annual operating hours, hr/yr (H) 6,000 2,000 4,000 1,500 a. Preheat = 0.5 hr/d x H/24 125 42 83 31 b. Burning = H - (preheat + burndown + cooldown) 5,375 1,625 3,250 1,219 c. Burndown = 2 hr/d x H/24 500 167 333 125 d. Cooldown = 2 hr/d x H/24 (for medium/small) 0 167 333 1253. Exhaust gas flow rate, dscfm (Q) 4,000 1,800 900 6005. Operating labor rate, $/hr (LR) $24 $24 $24 $246. Electricity cost, $/kWh (EC) $0.06 $0.06 $0.06 $0.067. Natural gas cost, $/1,000 ft3 (NGC) $7.97 $7.97 $7.97 $7.97

8. Burner capacities, Btu/hr a. Primary chamber (PC) = (129.1 x C) + 170,273 363,923 234,823 183,183 186,411 b. Secondary chamber (SC) = (1,290 x C) + 297,036 2,232,036 942,036 426,036 458,2869. Burner utilization rate, % a. PC burner-preheat 100% 100% 100% 100% b. PC burner-burning 100% 100% 100% 100% c. PC burner-burndown 0% 0% 0% 0% d. SC burner-preheat 50% 50% 50% 50% e. SC burner-burning 75% 75% 75% 75% f. SC burner-burndown 90% 90% 90% 90%10. Burner utilization, Btu/yr a. PC burner-preheat = PC burner capacity x PC burner utilization 

rate x preheat hr/yr

45,490,375 9,784,292 15,265,250 5,825,328

 b. PC burner-burning = PC burner capacity x PC burner utilization 1,956,086,125 381,587,375 595,344,750 227,187,797

rate x burning hr/yr

 c. PC burner-burndown = PC burner capacity x PC burner utilization 

rate x burndown hr/yr

0 0 00

 d. SC burner-preheat = SC burner capacity x SC burner utilization 

rate x preheat hr/yr

139,502,250 19,625,750 17,751,500 7,160,719

 e. SC burner-burning = SC burner capacity x SC burner utilization 

rate x burning hr/yr

8,997,895,125 1,148,106,375 1,038,462,750 418,902,047

 f. SC burner-burndown = SC burner capacity x SC burner utilization 

rate x burndown hr/yr

1,004,416,200 141,305,400 127,810,800 51,557,175

11. Heating value (natural gas), Btu/ft3 (HV) 1,020 1,020 1,020 1,020

12. Ash disposal cost, $/ton (ADC) $34.29 $34.29 $34.29 $34.2913. Water cost, $/1,000 gal (WC) $0.20 $0.20 $0.20 $0.2014. Cost index a. 2007 525.4 525.4 525.4 525.4 b. 1989 357.5 357.5 357.5 357.515. Refractory thickness, in. (RT) 4.5 4.5 4.5 4.516. Insulation thickness, in. (IT) 2 2 2217. PC volume, ft3 (PCV) = (0.304 x C) + 26.05 482 178 56 64

18. PC internal diameter, ft (PCD) = (4 x PCV / (π x 1.5))1/3 7.42 5.33 3.63 3.79

19. PC internal length, ft (PCL) = PCL/PCD ratio (1.5) x PCD 11.14 7.99 5.45 5.6820. PC refractory volume, ft3 = PCL x π/4 x ((RT x 2/12 x PCD)2 - PCD2) + 

π/2 x PCD2 x RT/12

134.78 70.38 33.49 36.32 

21. PC insulation volume, ft3 = PCL x (π/4 x (((((RT+ IT) x 2)/12) + PCD)2 - 

((RT x 2/12) + PCD)2)) + 2 x π/4 x (PCD + 

RT/12)2 x (IT/12)

64.56 34.63 17.18 18.54 

22. SC volume, ft3 (SCV) = Q/0.9 x (SC temp + 460)/528 x (resid time) 

x (1 min/60 sec)

317.06 142.68 71.34 47.56 

23. SC internal diameter, ft (SCD) = (SCV x 2/π)1/3 ,( ) 5.87 4.50 3.57 3.12 (SCV x 2/π)
Table 3. Combustor Model Costs

Parameters/Costs Equation Large Medium Small Small rural

24. SC internal length, ft (SCL) = SCL/SCD ratio (2) x SCD 11.73 8.99 7.14 6.23 25. SC refractory volume, ft3 =SCL x (π/4 x ((RT x 2/12 + SCD)2- SCD2)) + 

π/2 x SCD2 x RT/12

106.53 63.48 40.64 31.36 

26. SC insulation volume, ft3 = SCL x (π/4 x (((((RT+ IT) x 2)/12) + SCD)2 - 

((RT x 2/12) + SCD)2)) + 2 x π/4 x (SCD + 

RT/12)2 x (IT/12)

51.86 31.68 20.82 16.36 

27. Unit refractory cost, $/ft3 = $127/ft3 x (525.4/357.5) $187 $187 $187 $187

28. Unit insulation cost, $/ft3 = $43/ft3 x (525.4/357.5) $63 $63 $63 $63

29. Capital recovery factors (CRF) = [i x (1 + i)a] / [(1 + i)a - 1], where i = interest 

rate, a = equipment life

 a. Refractory CRF, 8-yr life, 7% interest 0.16747 0.16747 0.16747 0.16747 b. Equipment CRF, 20-yr life, 7% interest 0.09439 0.09439 0.09439 0.09439

B. Total Capital Investment, $

1. Purchased equipment cost (PEC) a. Large model = (174.2 x C + 177,740) x (525.4/357.5) $645,235 b. Medium/small models = 5,817 x C0.4537 x (525.4/357.5) $143,363 $69,074 $76,433

2. Installation cost (IC) = 0.48 x PEC $309,713 $68,814 $33,155 $36,6883. Total cost = PEC + IC $954,948 $212,177 $102,229 $113,121

C. Direct Annual Costs, $/yr

1. Operating labor = ((0.5 x burning hr/yr) + (1 hr/d ash removal 

x H/24 hr/d [for medium/small])) x LR

$64,500 $21,500 $43,000 $16,125

2. Supervisory labor = 0.15 x (operating labor) $9,675 $3,225 $6,450 $2,419

3 Mit lb 3. Maintenance labor = (0.5 hr/8-hr shift) x H x (LR x 1.1) $9,900 $3,300 $6,600 $2,475 (0 5 h /8 h hift) H (LR 1 1) $9 900 $3 300 $6 600 $2 475

4. Maintenance materials = 0.02 x TCI $12,905 $2,867 $1,381 $1,5295. Electricity = (0.746 kW/hp) x hp x H x EC $8,250 $618 $494 $2036. Auxiliary fuel = burner utilization / HV x NGC $94,885 $13,287 $14,023 $5,5537. Ash disposal = 0.09 x C x (1 ton / 2,000 lb) x (burning 

hr/yr) x ADC

$12,441 $1,254 $501 $235

8. Water = (water consumption (1 gpm)) x (60 min/hr) 

x (burning hr/yr) x WC

$71 $12 $24 $9

9. Refractory replacement a. PC refractory = CRF x [PC refractory volume (ft3) x unit 

refractory cost ($/ft3) + PC insulation volume 

(ft3) x unit insulation cost (ft3)]

$4,896 $2,566 $1,229 $1,332

 b. SC refractory = CRF x [SC refractory volume (ft3) x unit 

refractory cost ($/ft3) + SC insulation volume 

(ft3) x unit insulation cost (ft3)]

$3,879 $2,320 $1,491 $1,153

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $58,188 $18,535 $34,459 $13,5282. Property taxes, insurance, and administration = 0.04 x TCI $25,809 $5,735 $2,763 $3,0573. Capital recovery = CRF x TCI $60,906 $13,532 $6,520 $7,215

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual 

Costs

$366,304 $88,751 $118,935 $54,832

2. ($/yr) / dscfm = ($/yr) / Q $91.58 $49.31 $132.15 $91.39
Table 3. Combustor Model Costs

Parameters/Costs Equation Large Medium Small Small ruralNotes:Costs assume continuous operation for large model, intermittent operation for medium and small models.Large model: hp = (0.0130 x C) + 10.42Medium/small models: hp = (0.0101 x C) + 1.677Sources:1. Cost equation: Model Plant Description and Cost Report (II-A-112).2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific Occupational Employment and WageEstimates.3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.4. Natural gas cost: Energy Information Administration. Natural Gas Prices: December 2007.5. Ash disposal cost: NSWMA’s 2005 Tip Fee Survey.6. Water cost: Air Compliance Advisor, version 7.5.
Table 4. Packed Bed Scrubber Model Costs

Parameters/Costs Equation Large Medium

A. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 500

2. Temperature out of FF into quench, F (T1) 300 300

3. Temperature out of PB to ID fan, F (T2) 130 130

4. Annual operating hours, hr/yr (H) 6,000 2,000

5. Exhaust gas flow rate, dscfm (Qd) 4,000 1,800

6. Assumed moisture content in gas entering 

quench, % (M) 

10 10

7. Exhaust gas flow rate, scfm (Qw) = (Qd) / (1- M/100) 4,444 2,000

8. Water added in quench, scfm (Qh) = ((7.010 x (T1 - 77) - 6.958 x (T2 - 77)) x 0.9 

+ (8.154 x (T1 - 77) - 8.064 x (T2 - 77)) x 0.1) 

x (lb-mole/385 scf) x Qw / (1,160 Btu/lb) / (18 

lb/lb-mole) x (0.7302 ft3

-atm/lb-mol-R) x 528 

R / 1 atm

259 116

9. Actual flow out of PB, acfm (Qa) = (Qw + Qh) x (460 + T2)/(528) 5,256 2,365

10. HCl concentration, ppmvd (HCl) 25 9

11. Operating labor rate, $/hr (LR) $24 $24

12. Electricity cost, $/kWh (EC) $0.06 $0.06

13. Caustic cost, $/ton (CC) $357 $357

14. Sewage disposal cost, $/1,000 gal (SDC) $3.80 $3.80

15. Water cost, $/1,000 gal (WC) $0.20 $0.20

16. Assumed pressure drop through control 

system, inches of water (ΔP)

15 15

17. Surface area-to-volume ratio for 1" dia. 

Ceramic Raschig rings, ft2

/ft3 (SAV)

58 58

18. Minimum packing wetting rate, ft2

/hr (WR) 1 1

19 W t d it lb/ft3 19. Water density, lb/ft (Wd) 62 4 62 4 3 (Wd) 62.4 62.4

20. Water circulation flow rate, lb/hr-ft2 (Gs) = SAV x Wd x WR 4,705 4,705

21. Estimated column cross-sectional area from 

separate analysis, ft2 (A)

19.2 8.6

22. Water circulation rate, gpm (GPM) = Gs x A x (1 hr/60 min) x (1 gal/8.33 lb) 181 81

23. Water head, ft of water (Head) 60 60

24. Wastewater (blowdown) flow, gpm (B) = (HCl/1000000) x (Qd) x (lb-mole/385 ft3

) x 

(1 lb-mole NaCl/1 lb-mole HCl) x (58.2 lb 

NaCl/lb-mole NaCl) x (1 lb wastewater/0.1 lb 

NaCl) x (1 gal/8.33 lb)

0.018 0.003

25. Capital recovery factor, 15-yr equipment life, 

7% interest (CRF)

= [i x (1 + i)a

] / [(1 + i)a - 1], where i = interest 

rate, a = equipment life

0.10979 0.10979

26. Chemical Engineering plant cost index

 a. 2007 525.4 525.4

 b. 1989 357.5 357.5

B. Total Capital Investment, $ = (27.6 x Qd + 109,603) x (525.4/357.5) x 

(1.4 retrofit factor)

$452,658 $327,726

C. Direct Annual Costs, $/yr

1. Operating labor = (if Qa < 20,000, then 0, otherwise 0.5 

hr/shift) x H x LR

$0 $0

2. Supervisory labor = 0.15 x (operating labor) $0 $0

3. Maintenance labor = (0.5 hr/8-hr shift) x H x (LR x 1.1) $9,900 $3,300

4. Maintenance materials = 0.02 x TCI $9,053 $6,555

5. Electricity = (0.000181 x Qa x ΔP x H x EC) + 

(0.000289 x GPM x Head x H x EC)

$5,172 $775

6. Caustic = HCl x (3.117E-9) x Q x H x CC $667 $36

7. Sewage disposal = B x (gal/8.33 lb) x (60 min/hr) x H x SDC $25 $1
Table 4. Packed Bed Scrubber Model Costs

Parameters/Costs Equation Large Medium

8. Makeup water = (B + Qh x (lbmole/385 scf) x (18 lb/lbmole) 

x (gal/8.33 lb)) x (60 min/hr) x H x WC

$106 $16

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $11,372 $5,913

2. Property taxes, insurance, and administration = 0.04 x TCI $18,106 $13,109

3. Capital recovery = CRF x TCI $49,699 $35,983

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual 

Costs

$104,101 $65,687

2. ($/yr) / dscfm = ($/yr) / Q $26.03 $36.49

Sources:

1. Cost equations: Model Plant Description and Cost Report (II-A-112); and Wet Scrubber Cost Memorandum (IV-B-30).

2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific

 Occupational Employment and Wage Estimates.

3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.

4. Caustic cost: Purchasing.com. Caustic soda price hike is on the horizon. August 29, 2007.

5. Sewage disposal cost, water cost: Air Compliance Advisor, version 7.5.
Table 5. Venturi Scrubber Model Costs

Parameters/Costs Equation

Large 

(after 

HMIWI)

Large-

(after 

DIFF) Medium Small

A. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 1,500 500 1002. Annual operating hours, hr/yr (H) 6,000 6,000 2,000 4,0003. Exhaust gas flow rate, dscfm (Q) 4,000 4,000 1,800 9004. HCl concentration, ppmvd (HCl) 890 20 160 1205. Operating labor rate, $/hr (LR) $24 $24 $24 $246. Electricity cost, $/kWh (EC) $0.06 $0.06 $0.06 $0.067. Caustic cost, $/ton (CC) $357 $357 $357 $357

8. Sewage disposal cost, $/1,000 gal (SDC) $3.80 $3.80 $3.80 $3.809. Water cost, $/1,000 gal (WC) $0.20 $0.20 $0.20 $0.2010. Capital recovery factor, 20-yr equipment life, 7% interest (CRF)

= [i x (1 + i)a] / [(1 + i)a - 1], where i = interest 

rate, a = equipment life

0.10979 0.09439 0.09439 0.09439

17. Cost index a. 2007 525.4 525.4 525.4 525.4 b. 1995 381.1 381.1 381.1 381.1

B. Total Capital Investment, $ = (145.7 x C + 234,848) x (525.4/381.1) $625,073 $625,073 $424,205 $343,858C. Direct Annual Costs, $/yr

1. Operating labor = (0.4 hr/8-hr shift) x H x LR $7,200 $7,200 $2,400 $4,8002. Supervisory labor = 0.15 x (operating labor) $1,080 $1,080 $360 $7203. Maintenance labor = (0.3 hr/8-hr shift) x H x (LR x 1.1) $5,940 $5,940 $1,980 $3,960

4 Maintenance materials 4. Maintenance materials = 0 02 x TCI = 0.02 x TCI $12 501 $12,501 $12 501 $12,501 $8 484 , $6 877 ,5. Electricity = (0.746 kW/hp) x fan hp (0.02316 x Q + 

4.554) x H x EC

$26,798 $26,798 $4,250 $4,669

6. Caustic = (HCl) x (3.117E-9) x Q x H x CC $23,737 $533 $640 $4807. Sewage disposal = [blowdown rate (0.000747 x Q), gpm] x (60 

min/hr) x H x SDC

$4,088 $4,088 $613 $613

8. Makeup water = [makeup water flow rate (0.00512 x Q), 

gpm] x (60 min/hr) x H x WC

$1,475 $1,475 $221 $221

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $16,033 $16,033 $7,934 $9,8142. Property taxes, insurance, and administration = 0.04 x TCI $25,003 $25,003 $16,968 $13,7543. Capital recovery = CRF x TCI $68,630 $59,002 $40,042 $32,458

E. Total Annual Cost, $/yr

1. $/yr = Direct Annual Costs + Indirect Annual 

Costs

$192,484 $159,654 $83,893 $78,366

2. ($/yr) / dscfm = ($/yr) / Q $48.12 $39.91 $46.61 $87.07

Sources:

1. Cost equations: Model Plant Description and Cost Report (II-A-112); and Wet Scrubber Cost Memorandum (IV-B-30).2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific Occupational Employment and WagEstimates.3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.4. Caustic cost: Purchasing.com. Caustic soda price hike is on the horizon. August 29, 2007.5. Sewage disposal cost, water cost: Air Compliance Advisor, version 7.5.
Table 6. Fabric Filter Model Costs

Parameters/Costs Equation Large

A. Parameters

1. Incinerator capacity, lb/hr (C) 1,500

2. Annual operating hours, hr/yr (H) 6,000

3. Exhaust gas flow rate, dscfm (Q) 4,000

4. PM concentration, gr/dscf (PM) 0.10

5. Water vapor in gas from incinerator (10% 

by weight)

 a. lb/min = Q / (385 ft3

/lb-mol) x (29 lb/lb-mol) x moisture content (0.10) 30.1

 b. scfm = (lb/min) / (18 lb/lb-mol) x (385 ft3

/lb-mol) 644

6. Enthalpy change in quench (1800°F to 

300°F)

 a. Dry gas from incinerator, Btu/lb air = [7.010 x (300°F - 77°F) - 7.554 x (1800°F - 77°F)] / (29 lb/lb-mol) 395

 b. Water vapor from incinerator, Btu/lb 

water vapor

= [8.154 x (300°F - 77°F) - 9.215 x (1800°F - 77°F)] / (18 lb/lb-mol) 781

 c. Total gas stream, Btu/yr = [(Btu/lb air) x Q / (385 ft3/lb-mol) x (29 lb/lb-mol) x (60 min/hr) x H] + 

[(Btu/lb water vapor) x Q x (0.00753 lb water vapor/ft3) x (60 min/hr) x 

H]

5.13E+10

 d. Cooling water

 i. Heat of vaporization at 77°F, Btu/lb 1,050

 ii. Sensible heat for vapor, Btu/lb 85

 iii. Total, Btu/lb water 1,135

7. Cooling water evaporated, lb/yr

 a. lb/yr = [enthalpy change (total gas stream, Btu/yr)] / [enthalpy change 

(cooling water, Btu/lb)]

4.52E+07

 b. scfm = [cooling water evaporated (lb/yr)] / (18 lb/lb-mol) x (385 ft3/lb-mol) / 

(H * 60 min/hr)

2,686

8. Actual gas flow into fabric filter, acfm (AQ) = [Q + (wat g () [ ( p g )( p er vapor in gas from incinerator, scfm) + (water vapor 10,551

added in quench, i.e., cooling water evaporated, scfm)] x [(300°F + 

460°F)/528°R]

9. Operating labor rate, $/hr (LR) $24

10. Electricity cost, $/kWh (EC) $0.06

11. Water cost, $/1,000 gal (WC) $0.20

12. Compressed air cost, $/1,000 ft3 (CAC) $0.24

13. Dust disposal cost, $/ton (DDC) $34.29

14. Capital recovery factors = [i x (1 + i)a

] / [(1 + i)a - 1], where i = interest rate, a = equipment life

 a. Bag CRF, 2-yr life, 7% interest 0.55309

 b. Cage CRF, 4-yr life, 7% interest 0.29523

 c. Equipment CRF, 20-yr life, 7% interest 0.09439

15. Cost index

 a. 2007 525.4

 b. 1989 357.5

B. Total Capital Investment, $ = (47.0 x Q + 306,720) x (1.4 retrofit cost factor) x (525.4/357.5) $1,017,892

C. Direct Annual Operating Costs, $/yr

1. Electricity = (0.746 kW/hp) x hp (0.0072 x Q + 3.20) x H x EC $8,823

3. Evaporative cooler water = (0.1007 x Q + 23.1506) gal/min x (60 min/hr) x H x WC $30,668

4. Operating labor = (1 hr/shift) x (1 shift/8 hr) x H x LR $18,000

5. Supervisory labor = 0.15 x (operating labor) $2,700

6. Maintenance labor = (0.5 hr/shift) x (1 shift/8 hr) x H x (LR x 1.1) $9,900

7. Maintenance materials = 0.02 x TCI $20,358

8. Compressed air = AQ x (2 ft3 air/1,000 ft3 filtered) x (60 min/hr) x H x CAC $1,823

9. Dust disposal = (PM gr/dscf x Q x 60 min/hr x 1 lb/7,000 gr) x (1 ton/2,000 lb) x H x 

DDC

$353

10. Bag replacement

 a. Bag cost = AQ x ($2.5/ft2

) x (525.4/317.4) x (1.08 taxes and freight ratio)/(3.5 

ft/min G/C ratio)

$13,473

ft/min G/C ratio)
Table 6. Fabric Filter Model Costs

Parameters/Costs Equation Large

 b. Bag replacement labor cost = AQ x (0.15 hr/bag)/(18 ft2 bag area)/(3.5 ft/min G/C ratio) x LR $603

 c. Bag replacement cost = Bag CRF x [(total bag cost) + (bag replacement labor cost)] $7,785

11. Cage replacement

 a. Number of bags = AQ/(3.5 ft/min G/C ratio)/(18 ft2 bag area) $167

 b. Cage replacement labor cost = bag replacement labor cost $603

 c. Cage replacement cost = Cage CRF x [single-cage cost (4.941+ 0.163 x 18 ft2

 bag area) x 

(number of bags) x (525.4/317.4) + (cage replacement labor cost)]

$823

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $30,575

2. Property taxes, insurance, and 

administration

= 0.04 x TCI $40,716

3. Capital recovery = Equipment CRF x (TCI - bag replacement cost - cage replacement 

cost)

$95,269

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual Costs $267,793

2. ($/yr) / dscfm = ($/yr) / Q $66.95

Sources:

1. Cost equations: Model Plant Description and Cost Report (II-A-112); and Dry Injection Fabric Filter Cost Memorandum (IV-B-32).

2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific

Occupational Employment and Wage Estimates.

3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.

4. Water cost: Air Compliance Advisor, version 7.5.

5. Compressed air cost: P2Pays.org. Energy Tips – Compressed Air. Compressed Air Tip Sheet #1. August 2004.

6. Dust disposal cost: NSWMA’s 2005 Tip Fee Survey
Table 7. Dry Injection Fabric Filter Model Costs

Parameters/Costs Equation Large A. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 

2. Annual operating hours, hr/yr (H) 6,000 3. Exhaust gas flow rate, dscfm (Q) 4,000 4. HCl concentration, ppmvd (HCl) 890 5. PM concentration, gr/dscf (PM) 0.10 6. Water vapor in gas from incinerator (10% by weight) a. lb/min = Q / (385 ft3

/lb-mol) x (29 lb/lb-mol) x moisture content (0.10) 30.1 

 b. scfm = (lb/min) / (18 lb/lb-mol) x (385 ft3

/lb-mol) 644 

7. Enthalpy change in quench (1800°F to 300°F) a. Dry gas from incinerator, Btu/lb air = [7.010 x (300°F - 77°F) - 7.554 x (1800°F - 77°F)] / (29 lb/lb-mol) 395  b. Water vapor from incinerator, Btu/lb water vapor

= [8.154 x (300°F - 77°F) - 9.215 x (1800°F - 77°F)] / (18 lb/lb-mol) 781 

 c. Total gas stream, Btu/yr = [(Btu/lb air) x Q / (385 ft3/lb-mol) x (29 lb/lb-mol) x (60 min/hr) x H] + 

[(Btu/lb water vapor) x Q x (0.00753 lb water vapor/ft3) x (60 min/hr) x H]

5.13E+10 

 d. Cooling water i. Heat of vaporization at 77°F, Btu/lb 1,050 

ii Sensible heat for vapor Btu/lb ii. Sensible heat for vapor, Btu/lb 85 

 iii. Total, Btu/lb water 1,135 8. Cooling water evaporated, lb/yr a. lb/yr = [enthalpy change (total gas stream, Btu/yr)] / [enthalpy change (cooling 

water, Btu/lb)]

4.52E+07 

 b. scfm = [cooling water evaporated (lb/yr)] / (18 lb/lb-mol) x (385 ft3/lb-mol) / (H * 

60 min/hr)

2,686 

9. Actual gas flow into fabric filter, acfm (AQ) = [Q + (water vapor in gas from incinerator, scfm) + (water vapor added in 

quench, i.e., cooling water evaporated, scfm)] x [(300°F + 460°F)/528°R]

10,551 

10. Operating labor rate, $/hr (LR) $24 11. Electricity cost, $/kWh (EC) $0.06 12. Lime cost, $/ton (LC) $95 13. Water cost, $/1,000 gal (WC) $0.20 14. Compressed air cost, $/1,000 ft3 (CAC) $0.24 

15. Dust disposal cost, $/ton (DDC) $34.29 16. Capital recovery factors (CRF) = [i x (1 + i)

a

] / [(1 + i)a - 1], where i = interest rate, a = equipment life

 a. Bag CRF, 2-yr life, 7% interest 0.55309  b. Cage CRF, 4-yr life, 7% interest 0.29523  c. Equipment CRF, 20-yr life, 7% interest 0.09439 17. Cost index a. 2007 525.4  b. 1989 357.5 

B. Total Ca B. Total Capital Investment = Investment (63.8 x Q + 407 x

Q 407,498) x(1.4 retrofit cost factor retrofit cost factor) x(525.4/357.5) 525.4/357.5) $1,363,508 1,363,508 
Table 7. Dry Injection Fabric Filter Model Costs

Parameters/Costs Equation Large C. Direct Annual Operating Costs, $/yr

1. Electricity = (0.746 kW/hp) x hp (0.0079 x Q + 3.51) x H x EC $9,681 2. Makeup lime = (2.4E-7 lb/dscf x HCl x Q) x (1 ton/2,000 lb) x (60 min/hr) x H x LC $14,610 3. Evaporative cooler water = (0.1007 x Q + 23.1506) gal/min x (60 min/hr) x H x WC $30,668 4. Operating labor = (1 hr/shift) x (1 shift/8 hr) x H x LR $18,000 

5. Supervisory labor = 0.15 x (operating labor) $2,700 6. Maintenance labor = (0.5 hr/shift) x (1 shift/8 hr) x H x (LR x 1.1) $9,900 

7. Maintenance materials = 0.02 x TCI $27,270 8. Compressed air = AQ x (2 ft3 air/1,000 ft3 filtered) x (60 min/hr) x H x CAC $1,823 

9. Dust disposal = [(PM gr/dscf x Q x 60 min/hr x 1 lb/7,000 gr) + (HCl x Q x 60 min/hr x 

2.86E-7 lb/dscf)] x (1 ton/2,000 lb) x H x DDC

$6,637 

10. Bag replacement a. Bag cost = AQ x ($2.5/ft2) x (525.4/317.4) x (1.08 taxes and freight ratio)/(3.5 ft/min 

G/C ratio)

$13,473 

 b. Bag replacement labor cost = AQ x (0.15 hr/bag)/(18 ft2 bag area)/(3.5 ft/min G/C ratio) x LR $603 

 c. Bag replacement cost = Bag CRF x [(total bag cost) + (bag replacement labor cost)] $7,785 11. Cage replacement a. Number of bags = AQ/(3.5 ft/min G/C ratio)/(18 ft2 bag area) 167 

 b. Cage replacement labor cost = bag replacement labor cost $603  c. Cage replacement cost = Cage CRF x [single-cage cost (4.941+ 0.163 x 18 ft2 bag area) x 

(number of bags) x (525 4/317 4) + (cage replacement labor cost)]

$823 

(number of bags) x (525.4/317.4) + (cage replacement labor cost)]

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $34,722 2. Property taxes, insurance, and administration

= 0.04 x TCI $54,540 

3. Capital recovery = Equipment CRF x (TCI - bag replacement cost - cage replacement cost) $127,893 

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual Costs $347,053 

2. ($/yr) / dscfm = ($/yr) / Q $86.76 

Sources:

1. Cost equations: Model Plant Description and Cost Report (II-A-112); and Dry Injection Fabric Filter Cost Memorandum (IV-B-32).2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific Occupational Emp

3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.4. Lime cost: U.S. Geological Survey. Mineral Commodity Summaries 2008. Hydrated Lime Average Value, 2007.5. Water cost: Air Compliance Advisor, version 7.5.6. Compressed air cost: P2Pays.org. Energy Tips – Compressed Air. Compressed Air Tip Sheet #1. August 2004.7. Dust disposal cost: NSWMA’s 2005 Tip Fee Survey.
Table 8. ESP Model Costs

Dry ESP Wet ESP

Large Large

Parameters/Costs Notes (before WS) (after WS)A. Input Parameters

1. Inlet stream flow rate, dscfm 4,000 4,0002. Inlet stream moisture content, % 10 103. Inlet stream temperature, °F 300 1304. Water added in quench before wet scrubber, scfm N/A 2595. Inlet stream flowrate, acfm 6,397 5,2566. Particulate type fly ash fly ash7. ESP type ('flat plate' =1; 'plate wire' = 2) 2 28. ESP 'options' included? ('yes'=1; 'no'=0) 1 19. Inlet particulate loading, gr/dscf 10.0 10.010. Particulate mass median diameter, microns 15 1511. Most penetrating particle size, microns 2 212. Particle rapping puff size, microns 5 513. Particulate resistivity, ohm-cm No severe back corona if <2.0E+11 2.0E+07 2.0E+0714. Overall PM collection efficiency, fraction 0.990 0.99015. PM migration velocity, cm/s From Table 6.2 9.4 9.416. Sneakage factor From page 6-30 0.07 0.0517. Rapping reentrainment factor From page 6-31 0.124 0.00018. Gas free space permittivity, F/m 8.8E-12 8.8E-1219. ESP pressure drop, in. w.c. From Table 6.6 0.38 0.3820. Material of construction (see list below) 1 1

B. Design Parameters

1 O ll i 1. Overall penetration 0 010. 0.010 2. Specific collection area #1, ft2/1000 acfm 248.9 248.9

3. Gas viscosity, kg/m-s 2.3E-05 2.0E-054. Electric field at sparking, V/m 3.1E+05 4.7E+055. Average electric field, V/m Need to multiply by 0.7 if back corona is severe 1.8E+05 2.7E+056. Loss factor 0.185 0.0507. Number of collecting sections in ESP 3 28. Average section penetration 0.2154 0.10009. Section collection penetration If this value is negative, n must be increased 0.0370 0.052610. Particle size change factor (D), micron Equal to average section penetration 0.2154 0.100011. Particle size change factor (MMDrp), micron 2.577 0.00012. Section parameters table:

Dry ESP Wet ESP

Section # MMDi SCAi MMDi SCAi

1 15 17.57 15 5.802 7.877 33.46 8.913 9.763 5.517 47.78 0.000 0.004 0.000 0.00 0.000 0.005 0.000 0.00 0.000 0.006 0.000 0.00 0.000 0.00

13. Specific collection area #2, s/m 98.81 15.5714. ESCA #2, ft2/1,000 acfm 501.96 79.07

15. Total collector plate area, ft2 (use max of SCA #1 and #2) Equipment cost correlation valid for >10,000 ft2 3,211 1,308

C. Cost Inputs

1. Operating factor, hr/yr 6,000 6,0002. Operating labor rate, $/hr 24 243. Operating labor factor, hr/shift 0.5 0.5
Table 8. ESP Model Costs

Dry ESP Wet ESP

Large Large

Parameters/Costs Notes (before WS) (after WS)

4. Operating labor factor lookup table:

Plate Area, ft2 Factor, hr/shift

0 0.5

10,000 1.0

100,000 1.5

1,000,000 2.0

5. Electricity price, $/kWh $0.06 $0.066. Dust disposal, $/ton (assumed transportation cost included) $34.29 $34.297. Water use in wet ESP, gal/min-kacfm 5.008. Water cost, $/1,000 gal $0.209. Wastewater treatment, $/1,000 gal $3.8010. Annual interest rate, fraction) 0.07 0.0711. Control system life, yrs 20 2012. Capital recovery factor 0.0944 0.094413. Taxes, insurance & admin. Factor 0.04 0.0414. Cost index a. VAPCCI, fourth quarter 1998 107.7 107.7 b. CE plant cost index, Oct 1998 391.5 391.5 c. CE plant cost index, 2007 525.4 525.4

D. Total Capital Investment, $

1. Equipment costs a. Basic ESP $97,576 $55,531 b. ESP 'standard options' p $43,909 $24,989 ,

 c. Auxiliaries (ductwork, etc.) $0 $0 d. Total (base) $141,485 $80,520 e. Total (escalated) $288,439 $164,1512. Purchased equipment cost $340,358 $193,6983. Retrofit factor 1.4 1.44. Total $1,067,363 $607,438

E. Direct Annual Costs, $/yr

1. Operating labor $9,000 $9,000

2. Supervisory labor $1,350 $1,3503. ESP coordinator labor $3,000 $3,000

4. Maintenance labor $7,920 $7,9205. Maintenance materials $3,404 $1,9376. Electricity (only for ESP, not fan) $2,303 $9387. Water $0 $1,8928. Dust disposal (only PM from incinerator, not carbon) $34,952 $09. Wastewater disposal $0 $35,948

F. Indirect Annual Costs, $/yr

1. Overhead $14,804 $13,924

2. Taxes, insurance, administrative $42,695 $24,2983 Capital recovery $100,752 $57,338

G. Total Annual Cost

1. $/yr $220,178 $157,544

2. ($/yr) / dscfm $55.04 $39.39

Note:
Table 8. ESP Model Costs

Dry ESP Wet ESP

Large Large

Parameters/Costs Notes (before WS) (after WS)

Material of construction, enter one: carbon steel--'1'; 316 stainless steel--'1.3'; Carpenter 20 (CB-3)--'1.9'; Monel-400--'2.3'; Nickel-200--'3.2'; titanium--'4.5'.Source:OAQPS Control Cost Manual.
Table 9. Carbon Adsorber Model Operating Costs

Parameters/Costs Equation ECU

A. Parameters

1. Incinerator capacity, lb/hr (C) 1,000

2. Annual operating hours, hr/yr (H) 625

3. Exhaust gas flow rate, dscfm (Q) 3,124

4. Mercury concentration (after control), 

mg/dscm

0.00164

5. Mercury control efficiency (assumed), % 90

6. Mercury concentration (calculated 

uncontrolled), mg/dscm (U)

0.0164

7. Mercury emissions (uncontrolled), mg/yr = U x Q x (1 m3

/35.3145 ft3) x (60 min/hr) x H 54,404

8. Carbon consumption, lb/yr(AC) = (338 mg/dscm) x Q x (1 m3

/35.3145 ft3) x (1 

kg/1,000 g) x (l lb/453.593 kg) x (60 min/hr) x 

H

2,472

9. Operating labor rate, $/hr (LR) $24

10. Carbon cost, $/lb (ACC) $1.38

11. Spent carbon landfill disposal cost, $/ton 

(DDC)

$34.29

B. Direct Annual Costs, $/yr

1. Operating labor = (if Q < 10,000, then 0, otherwise 0.5 

hr/shift) x H x LR

$0

2. Supervisory labor = 0.15 x (operating labor) $0

3. Maintenance labor = (0.5 hr/8-hr shift) x H x (LR x 1.1) $1,031

4. Maintenance materials = maintenance labor $1,031

5. Carbon = (AC) x (ACC) $3,411

6 C b di l 6. Carbon disposal = (AC) x (DCC) x (1 ton/2,000 lb) $42 (AC) (DCC) (1 t /2 000 lb) $42

C. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $1,238

D. Total Annual Operating Cost, $/yr = Direct Annual Costs + Indirect Annual 

Costs

$6,754

Note:

Assumed that the amount of carbon needed in a carbon bed would be equivalent to that used in ACI calculation.

Also assumed the carbon is not regenerated.

Sources:

1. Mercury concentration after control: East Carolina University Test Report-January 2000.

2. Carbon consumption, mercury concentration (338 mg/dscm): Model Plant Description and Cost Report.

3. Cost equations: OAQPS Control Cost Manual.
Table 10. Selective Noncatalytic Reduction Model Costs

Parameters/Costs Equation LargeA. Parameters

1. Incinerator capacity, lb/hr (C) 1,500

2. Annual operating hours, hr/yr (H) 6,0003. Exhaust gas flow rate, dscfm (Q) 4,0004. NOX, lb/MMBtu 0.28

5. Heating value, Btu/lb (HV) 8,5006. Urea solution cost, $/gal (U) $0.857. Electricity cost, $/kWh (EC) $0.068. Water cost, $/1,000 gal (WC) $0.209. Capital recovery factor, 20-yr equipment life, 7% interest (CRF)

= [i x (1 + i)a] / [(1 + i)a - 1], where i = interest rate, a = 

equipment life

0.09439

10. Cost index a. 2007 525.4 b. 1998 390.6

B. Total Capital Investment, $ (TCI)

1. Total Direct Capital Cost (DC) = [$950/(MMBtu/hr)] x [(C x HV) / 106] x [(2,375 MMBtu/hr / 

(C x HV)]0.577 x (0.66 + 0.85 x 45% NOX removal efficiency) 

x (1.2 retrofit factor) x (525.4/390.6)

$416,033

2. Indirect Installation Costs (IC) = 0.2 x DC $83,207

3. Other Capital Costs (OC) = [0.173 x (DC + IC)] + (119.3 gal x U) $86,4704. Total = DC + IC + OC $585,709

C. Direct Annual Costs, $/yr

1. Maintenance = 0.015 x TCI $8,7862. Reagent = (0.36 gal/hr) x H x U $1,8363. Electricity = kW [0.47 x NOX x (C x HV) / 106] / 9.5 x H x EC $65

4. Water = 1.62 gal/hr x H x WC $1,944

D. Indirect Annual Costs, $/yr

1. Capital recovery = CRF x TCI $55,287

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual Costs $67,9182. ($/yr) / dscfm = ($/yr) / Q $16.98

Sources:

1. Cost equations, urea solution cost: OAQPS Control Cost Manual. Section 4.2: NOX Post-Combustion, Chapter 1: Selective Noncatalytic R

2. Heating value: Process Description Report (II-A-110).3. Electricity cost: Energy Information Administration. Average Retail Price of Electricity: 2006.4. Water cost: Air Compliance Advisor, version 7.5.5. NOX removal efficiency: Clean Air Technology Center. EPA Technical Bulletin: Nitrogen Oxides (NOX)--Why and How They Are Controlled

November 1999.
Table 11. Activated Carbon Injection Model Costs

Parameters/Costs Equation Large MediumA. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 5002. Annual operating hours, hr/yr (H) 6,000 2,0003. Exhaust gas flow rate, dscfm (Q) 4,000 1,8004. Operating labor rate, $/hr (LR) $24 $245. Activated carbon cost, $/lb (ACC) $1.38 $1.386. Dust disposal cost, $/ton (DDC) $34.29 $34.297. Capital recovery factor, 20-yr equipment life, 7% interest (CRF)

= [i x (1 + i)a] / [(1 + i)a - 1], where i = interest rate, 

a = equipment life

0.09439 0.09439

8. Cost index a. 2007 525.4 525.4 b. 1990 361.3 361.3

B. Total Capital Investment, $ = 4,500 x (Q/1,976)0.6 x (1.2 retrofit factor) x 

(525.4/361.3)

$11,989 $7,425

C. Direct Annual Costs, $/yr

1. Operating labor = (0.25 hr/8-hr shift) x H x LR $4,500 $1,5002. Supervisory labor = 0.15 x (operating labor) $675 $2253. Maintenance = 0.2 x TCI $2,398 $1,485

4 Activated carbon 4. Activated carbon = 0 00127 = 0.00127 x Q x H x ACC x

Q

x

H

x ACC $42 062 $42,062 $6 309 ,

5. Dust disposal = 0.00127 x Q x (1 ton/2,000 lb) x H x DDC $523 $78

D. Indirect Annual Costs, $/yr

1. Overhead = 0.6 x (labor + maintenance materials) $4,544 $1,9262. Property taxes, insurance, and administration

= 0.04 x TCI $480 $297

3. Capital recovery = CRF x TCI $1,132 $701

E. Total Annual Cost

1. $/yr = Direct Annual Costs + Indirect Annual Costs $56,313 $12,5222. ($/yr) / dscfm = ($/yr) / Q $14.08 $6.96

Note:

Factor of 1.27 x 10-3 for activated carbon is based on injecting carbon at a rate to achieve a carbon concentration of 338

mg/dscm (achieving reductions of 90% for Hg, 98% for CDD/CDF).Sources:

1. Cost equations: Model Plant Description and Cost Report (II-A-112).2. Operating labor rate: Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific OccupationalEmployment and Wage Estimates.3. Activated carbon cost: The Innovation Group. Chemical Profiles: Carbon, Activated. 2002. Assumed 20% price increase based on onlineinformation from Norit, an activated carbon vendor.4. Dust disposal cost: NSWMA’s 2005 Tip Fee Survey.
Table 12. Maintenance and Inspection Costs

Parameters Equation Values

A. Parameters

1. Cost index

 a. 2007 525.4

 d. 1992 358.2

B. Maintenance/Inspection Cost, $/yr (rounded)

1. Company A = $500 x (525.4/358.2) $700

2. Company B = $350 x (525.4/358.2) $500

3. Company C = $800 x (525.4/358.2) $1,200

4. Company D = $750 x (525.4/358.2) $1,100

5. Average = ∑ (Companies A-D) / 4 $900

Note:

Maintenance/inspection costs have been rounded to the nearest $100 to be

consistent with level of rounding in original costs.

Source:

Maintenance/Inspection Programs Memorandum (II-B-88).
Table 13. Parameter Monitoring Costs

Large 

Parameters/Costs Equation DIFF FF WS

DIFF/WS, 

DI-ESP/WS

HEPA/CA/WS, 

WS/WESP SNCR ACI DIFF 

A. Parameters

1. Recording charge weight and hourly rate, min/hr

= (10 sec/load) x (1 min/60 sec) x (8 loads/hr) 1.3 1.3 1.3 1.3 1.3 1.3 1.3 

2. Recording lime/carbon flow, min/4-hr period

5 5 5 5 5 5 5 5 

3. Annual operating hours, hr/yr (H) 6,000 6,000 6,000 6,000 6,000 6,000 6,000 2,000 4. Cost index a. 2007 525.4 525.4 525.4 525.4 525.4 525.4 525.4 525.4  b. 1997 386.5 386.5 386.5 386.5 386.5 386.5 386.5 386.5  c. 1993 359.2 359.2 359.2 359.2 359.2 359.2 359.2 359.2  d. 1992 358.2 358.2 358.2 358.2 358.2 358.2 358.2 358.2 5. Operating labor wage rate, $/hr (LR) $24.00 $24.00 $24.00 $24.00 $24.00 $24.00 $24.00 $24.00 6. Capital recovery factor, 20-yr equipment life, 7% interest (CRF)

= [i x (1 + i)a] / [(1 + i)a - 1], where i = interest 

rate, a = equipment life

0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 0.09439 

B. Total Capital Investment, $ (TCI)

1. Planning = $500 x (525.4/386.5) $700 $700 $700 $700 $700 $700 $700 2. Select type of equipment = $300 x (525.4/386.5) $400 $400 $400 $400 $400 $400 $400 3. Provide support facilities = $1,000 x (525.4/386.5) $1,400 $1,400 $1,400 $1,400 $1,400 $1,400 $1,400 4. Purchased equipment cost (PEC) a. Scale/parameter monitors = $10,400 x (525.4/359.2) (good comb.) $15,400 $15,400 $20,800 $20,900 $20,900 $4,900 $15,400 

= $10,500 x (525.4/359.2) (DIFF, FF)= $14,200 x (525.4/359.2) (WS)= $14,300 x (525.4/359.2) (DIFF/WS, etc.)

 b. Taxes and freight = 0.08 x scale/monitor cost $1,200 $1,200 $1,700 $1,700 $1,700 $400 $1,200 5. Install and check equipment = $150 x (525.4/359.2) ( q p ( ) (g )ood comb.) $1,000 $1,000 $1,000 $1,000 $1,000 $1,000 $1,000 

= $650 x (525.4/359.2) (everything else)

6. Perf. spec. tests (certif.) = $500 x (525.4/386.5) $700 $700 $700 $700 $700 $700 $700 7. Prepare QA/QC plan = $500 x (525.4/386.5) $700 $700 $700 $700 $700 $700 $700 8. Total capital cost = Planning + selecting equipment + support 

facilities + PEC + installation + perf. spec. tests + QA/QC plan

$21,500 $21,500 $27,400 $27,500 $27,500 $10,200 $21,500 

C. Annual Costs, $/yr

1. Operating labor a. Recording charge weight and hourly rate

= (Recording charge weight and hourly rate) x (1 hr/60 min) x H x LR

$3,200 $3,200 $3,200 $3,200 $3,200 $1,100 

 b. Recording lime or carbon flow measurements

= (Recording flow/4-hr period) x (1 hr/60 min) x H x LR

$3,000 $3,000 $3,000 $1,000 

2. Maintenance materials = 0.02 x TCI $400 $400 $500 $600 $600 $200 $400 3. Recordkeeping and reporting = $1,000 x (525.4/386.5) $1,400 $1,400 $1,400 $1,400 $1,400 $1,400 $1,400 4. Overhead = 0.6 x (labor + maintenance materials) $4,000 $2,200 $2,200 $4,100 $2,300 $100 $1,800 $1,500 5. Property taxes, insurance, and administration

= 0.04 x TCI $900 $900 $1,100 $1,100 $1,100 $400 $900 

6. Capital recovery = CRF x TCI $2,000 $2,000 $2,600 $2,600 $2,600 $1,000 $2,000 7. Total annual cost =SUM(C29:C34) $14,900 $10,100 $11,000 $16,000 $11,200 $3,100 $4,800 $8,300 

Note:

1. Monitoring costs have been rounded to the nearest $100 to be consistent with level of rounding in original costs.2. Monitoring for DI-ESP/WS similar to DIFF/WS, so used same costs.3. Monitoring for WS/WESP and HEPA/CA/WS similar to FF/WS, so used same costs.

Sources:

1. Testing and Monitoring Options and Costs Memo (IV-B-66).2. E-mail and attachment from Peter Westlin, EPA, to Mary Johnson, EPA. August 19, 2008. Monitoring Options for SNCR on Medical Waste Incinerators.

3. E-mail from Dan Bivins, EPA, to Mary Johnson, EPA. September 27, 2006. Cost of CO CEMS.
Table 14. Stack Testing Costs

Parameters Values

A. Testing Costs, $

1. Method 5 (PM) = $8,000 x (525.4/358.2) $12,000

2. Method 9 (opacity) = $1,000 x (525.4/358.2) + $1,500 $2,500

3. Method 10 (CO) = $4,000 x (525.4/358.2) + $1,000 $7,000

4. Method 26 (HCl) = $5,000 x (525.4/358.2) $7,000

Note:

1. Testing costs have been rounded to the nearest $1,000 (except for opacity) to be

consistent with level of rounding in original costs; costs also adjusted based on

additional information from EPA.

2. Multiple test costs adjusted by 2/3 in nationwide cost estimates to account for travel,

accomodations, etc. common to all tests.

Sources:

1. Memorandum from R. Segall, EPA/EMB, to R. Copland, EPA/SDB. October 14, 1992.

Medical Waste Incinerator Study: Emission Measurement and Continuous Monitoring.

(II-B-89)

2. E-mail from Jason Dewees, EPA, to Mary Johnson, EPA. August 20, 2008.

Monitoring Options for SNCR & Test Cost Questions.
Table 15. Recordkeeping and Reporting Costs

(A) (B) (C) (D) (E

Burden item

Personhours per 

occurrence

Number of 

occurrences 

per year

Technical 

person-hours 

per year (C = A 

x B)

Management 

person-hours per 

year (D = C x 0.05)

Cler

pers

hours 

year (E 

0.1

A. Applications N/A B. Surveys and Studies N/A C. Reporting Requirements

1. Read instructions N/A 2. Required activities a. Annual update of operating information 20 1 20 1  b. Review of operating information with each operator 8 2 16 1 3. Write report a. Annual report i. CMS emissions/operating parameters 32 1 32 2  ii. Report of no exceedances --Small rural HMIWI 8 1 8 0  --All other HMIWI 32 1 32 2  iii. Results of performance tests conducted during the year --Small rural HMIWI 8 1 8 0  --All other HMIWI 40 1 40 2 

D. Recordkeeping Requirements

1. Read instructions N/A 2. Plan activities N/A 3. Implement activities N/A 4. Develop record system N/A 5. Time to enter information a. Records of startup, shutdown, or malfunction 1.5 52 78 4  b. Records of persons completing review of operating information 2 2 4 0  c. Records of annual and any subsequent compliance tests Incl. in 3C d. Records of process and control device operating parameters i. Small rural HMIWI 0.5 52 26 1  ii. All other HMIWI 1.5 52 78 4  e. Records of CMS operation and maintenance 0.025 365 9 0 6. Time to train personnel 40 1 40 2 7. Time for audits N/A 

E. Total Labor Burden and Cost 20 Notes:1. Estimate that 57 HMIWI are operating, including 2 small rural units and 55 other units (large, medium, small non-rural).2. Industry costs are based on the following hourly rates: technical at $37.55, management at $78.76, and clerical at $21.10 (see table below). The compo+ (0.05 x $78.76/hr) + (0.1 x $21.10/hr) = $43.60/hr. Labor rates were increased by 60% to account for overhead.3. Inspection cost already accounted for under monitoring costs.4. Assume 20 hours to update the operating information each year.5. Assume 8 hours to review the operating information with each operator.
Table 15. Recordkeeping and Reporting Costs

(A) (B) (C) (D) (E

Burden item

Personhours per 

occurrence

Number of 

occurrences 

per year

Technical 

person-hours 

per year (C = A 

x B)

Management 

person-hours per 

year (D = C x 0.05)

Cler

pers

hours 

year (E 

0.1

6. Review of operating information assumes 2 operators per facility. Also assume there is no operator turnover at the affected facilities.7. Person-hours per occurrence for annual report of CMS operating parameters are based on the reporting and recordkeeping costs for CMS ($1,400) divid($43.60/hr).8. Assume 8 person-hours per report per pollutant to report no excess emissions. For small rural HMIWI, testing and monitoring focus on stack opacity. Foand monitoring focus primarily on three pollutants (PM, CO, and HCl) and stack opacity.9. Assume all respondents in compliance and report no exceedances.10. For small rural HMIWI, assume 8 hours to review report of annual stack opacity compliance test. For the remaining HMIWI, assume 40 hours to review and stack opacity compliance tests.11. These records are kept on a weekly basis.12. Assume 2 operators per facility and no operator turnover at the affected facilities, but no facilities will need to complete initial operator training requirem13. For small rural HMIWI, assume 0.5 hours per week to record process and control device operating parameters and to record any exceedances of these HMIWI, assume 1.5 hours per week to record operating parameters and parameter exceedances.14. Person-hours per occurrence for CMS operation and maintenance (O&M) are based on the O&M cost for CMS divided by the composite hourly labor radetermined for each existing HMIWI, and then averaged.15. Time to train personnel based on the time per year to train one person to perform the Method 9 and Method 22 tests. The labor requirements to train th8 hours per day for 5 days per year.16. The average recurrent burden and cost in the first 3 years after promulgation for the sources with recurrent burden are equal to the person-hours added management, and clerical and the sum of the cost column.Sources:1. Bureau of Labor Statistics, Occupational Employment Statistics, May 2007 National Industry-Specific Occupational Employment and Wage Estimates.2. Testing and Monitoring Options and Costs Memo (IV-B-66).Labor Rates:Parameter

General

Medical & 

Surgical 

Hospitals

Waste 

Treatment & 

Disposal

Colleges, 

Universities, & 

Professional 

Schools

Pharmaceutical & 

Medicine 

Manufacturing Tot

A. % of industry (excluding U.S. military/gov. research facilities) 58.49% 26.42% 7.55% 7.55% 10B. Labor Rates

1. Technical - Stationary Engineers & Boiler Operators $23.80 $23.31 $22.01 $22.94 $2. Management - Engineering Managers $45.95 $55.00 $47.07 $56.56 $3. Clerical - Office Clerks, General $13.16 $12.75 $12.53 $15.63 $4. Composite labor rate 
Table 16. Autoclave/Landfill Model Costs

Parameters/Costs Equation Large Medium 

A. Parameters

1. Incinerator capacity, lb/hr (C) 1,500 500 2. Annual operating hours, hr/yr (H) 6,000 2,000 3. Landfill tip fee (national average), $/ton $34.29 $34.29 

B. Total Capital Investment $1,000,000 $450,000 C. Annual Costs, $/lb

1. Autoclave $0.02 $0.02 2. Biological indicators test = [($7/test kit) x (12 tests/yr) + (0.5 hr/test) x (12 

tests/yr) x ($20/hr)]/ (312 d/yr) / (50,000 lb waste/d)

$0.000013 $0.000013 

3. Inspections = 2 hr/inspection x 1 inspection/yr x ($20/hr) / (312 d/yr) 

/ (50,000 lb waste/d)

$0.000003 $0.000003 

4. Permit fee = ($500/yr) / (312 hr/yr) / (50,000 lb waste/d) $0.00003 $0.00003 6. Total a. Without landfill tip fee = Autoclave + biological indicators test + inspections + 

permit fee

$0.02 $0.02 

 b. With landfill tip fee = Autoclave + biological indicators test + inspections + 

permit fee + (landfill tip fee/2 000 lb/ton)

$0.03 $0.04 

permit fee + (landfill tip fee/2,000 lb/ton)

D. Annual Costs (with landfill tip fee), $/yr = Total annual cost x (C x 0.67) x H $205,273 $27,758 Notes:1. Annual autoclave costs include operational costs (chamber liners, labor, capital expense, maintenance, steam, electricity) and hauliHauling costs from vendor were revised to extract landfill costs, which will be applied to each HMIWI on a regional basis in estimating nNational average landfill tip fees used to estimate model costs.2. The vendor's labor rate and operating time were used in costing the biological indicators test, inspections, and permit fee in order to with the approach used in the vendor's autoclave costs.Sources:1. Autoclave costs and biological indicators test (test kit): San-I-Pak, July 2008.2. Biological indicators test (labor), inspections, and permit fee: Bay Area Dioxins Project, June 2003.
Table 17. Nationwide Baseline Annual Operating Costs for Existing Sources

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

1 1 Bristol-Myers Squibb Co. Wallingford CT L E FF Secondary chamber (1800F) and baghouse 5 5 Merck & Company, Inc. Rahway NJ L E DIFF Secondary chamber (1500F, 1 sec), partial quench

scrubber with dry lime injection, and baghouse

15 15--1 Curtis Bay Energy Unit 1 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and baghouse w

carbon injection

15 15--2 Curtis Bay Energy Unit 2 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and baghouse w

carbon injection

20 20--1 Fort Detrick Unit 5 Fort Detrick MD L E WS Secondary chamber and rotary atomizing wet scrub20 20--2 Fort Detrick Unit 6 Fort Detrick MD L E WS Secondary chamber and rotary atomizing wet scrub29 29 Hamot Medical Center Erie PA L E DIFF/WS Secondary chamber (2000F, 2 sec), lime injection s

powdered activated carbon injection system, baghovertical upflow two-stage multi-microventuri scrubbe

36 36--1 Merck & Company, Inc. Unit 2 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary/tertiary chamber (2000F, 2 sec), water q

followed by sodium bicarbonate injection system wichamber and pulse-jet baghouse

36 36--2 Merck & Company, Inc. Unit 5 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary chamber (1800F, 2.2 sec), water quenc

sodium bicarbonate injection system and pulse-jet b

40 40 Charleston Area Medical Center, General 

Hospital

Charleston WV L E DIFF Secondary chamber (1800F, 2 sec), dry injection/ba

scrubber system with activated carbon

42 42 Stericycle, Inc. Apopka FL L E DIFF Secondary chamber (1800, 1 sec), dry scrubbing sy

quench chamber, passive absorber, lime and carboand baghouse.

43 43 Boca Raton Community Hospital Boca Raton FL L E WS Secondary chamber (1800F, 1 sec) and rotary atom

scrubber system with caustic soda injection

44 44 Bethesda Memorial Hospital Boynton Beach FL L E WS Secondary chamber (1800F, 2 sec) and rotary atom

with mist eliminator

46 46 Holy Cross Hospital Fort Lauderdale FL L E WS Secondary chamber (1800F, 1 sec) and venturi scr

packed bed absorption unit using dilute NaOH

48 48 Memorial Regional Hospital Hollywood FL L E WS/WESP Secondary chamber (1800F, 1 sec), packed column 

scrubber, and wet ESP

51 51 Lakeland Regional Medical Center Lakeland FL L E DIFF Secondary chamber (1800F, 1 sec), lime injection s

baghouse

54 54 Bayfront Medical Center St. Petersburg FL L E WS Secondary chamber (1800F, 1 sec) and flux force/c

collision scrubber system using dilute NaOH

55 55 St. Joseph's Hospital Tampa FL L E DIFF/WS Secondary chamber (1800F, 1 sec), lime injection, 

venturi scrubber

59 59--1 Stericycle, Inc. Unit 1 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid gas quen

wet scrubber system consisting of a packed bed abventuri scrubber, and demister.

59 59--2 Stericycle, Inc. Unit 2 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid gas quen

wet scrubber system consisting of a packed bed abventuri scrubber, and demister.

60 60--1 BMWNC, Inc. Unit 1 Matthews NC L E DIFF Secondary chamber (1641F), dry scrubber with lime 

carbon injection, and baghouse

65 65--1 Stericycle, Inc. Unit 1 Clinton IL L E WS Secondary chamber (1800F), venturi scrubber, and 

absorber

65 65--2 Stericycle, Inc. Unit 2 Clinton IL L E WS Secondary chamber (1800F), venturi scrubber, and 

absorber

71 71 Loyola University Medical Center Maywood IL L E WS Two secondary chambers (1600F), twin rotary atom

using 50% caustic solution, and two demister pads

77 77 Parkview Hospital Fort Wayne IN L E WS Secondary chamber and wet scrubber 84 84 Mayo Clinic, Waste Management Facility Rochester MN L E DIFF Secondary chamber (1800F, 1 sec) and baghouse 

carbon injection

87 87 MedCentral Health System, Mansfield Hospital Mansfield OH L E DIFF Secondary chamber (1800F, 2 sec) and baghouse 

carbon injection system

94 94 Steric 94 Stericycle,Inc. Warren OH L E WS Secondar Inc. Warren OH L E WS Secondary chamber chamber (1800F,2 sec),wet scrubbe wet scrubber 
Table 17. Nationwide Baseline Annual Operating Costs for Existing Sources

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

98 98--1 University of Texas Medical Branch Galveston TX L E WS Secondary chamber, packed tower, and venturi scr

activated carbon injection

106 106 Stericycle, Inc. Kansas City KS L E WS Secondary chamber (1800F, 2 sec), wet scrubber 109 109 Healthcare Environmental Services Inc. Fargo ND L E DIFF Secondary chamber (1800F) and dry scrubber/bagh

with lime and carbon injection

110 110 Stericycle, Inc. North Salt Lake UT L E DI-ESP/WS Secondary chamber (1834F), carbon injection syste

scrubber, and wet gas absorber

120 120--1 Waste Management Resource Recovery and 

Recycling Center

Unit 1 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin lime inje

injection, and activated carbon injection

120 120--2 Waste Management Resource Recovery and 

Recycling Center

Unit 2 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin lime inje

injection, and activated carbon injection

125 125 East Carolina University, Health Sciences 

Campus, HSC Utility Plant

Greenville NC L N HEPA/CA/

WS

Secondary chamber (1985F), rotary atomizing wet sNaOH scrubbing medium), carbon bed adsorber, H

system, and heat recovery system

130 130 Department of Veterans Affairs Medical Center Miami FL L E WS Secondary chamber (1800F, 1 sec), venturi scrubb

tower absorber

13 13 University of Maryland at Baltimore, 

Environmental Health and Safety Facility

Baltimore MD M E WS Secondary chamber (1832F) and venturi caustic sc

packed-bed scrubber

16 16 Johns Hopkins Medical Institute, Department of 

Health, Safety, and Environment

Baltimore MD M E WS Secondary chamber (1800F) and venturi wet scrub

saturation chamber and mist eliminator

18 18 Franklin Square Hospital Center Baltimore MD M E WS Secondary chamber (1800F) and venturi scrubber f

quench chamber and mist eliminator

21 21 Washington County Hospital Hagerstown MD M E WS Secondary chamber and venturi caustic scrubber 25 25 Holy Spirit Hospital Camp Hill PA M E WS Secondary chamber (1800F) and venturi scrubber w

and NaOH injection

j

30 30 Riddle Memorial Hospital Media PA M E WS Secondary chamber (1800F, 2 sec), caustic packed 

scrubber, and high pressure venturi, with activated injection

34 34 Pennsylvania State University, Animal 

Diagnostic Lab Incinerator

State College PA M E WS Secondary chamber (1900F) and rotary atomizing w

with demister

38 38 Wilkes-Barre General Hospital Wilkes-Barre PA M N DIFF Secondary/tertiary chambers (1800F, 2.85 sec) and 

scrubber/baghouse with lime and activated carbon 

41 41 Thomas Memorial Hospital South Charleston WV M E WS Secondary chamber (1800F) and venturi packed to

scrubber with caustic injection

47 47 Malcolm Randall Veterans Affairs Medical 

Center

Gainesville FL M E WS Secondary chamber (1800F, 1 sec) and wet scrubb

soda injection

63 63 St. Jude Children's Research Hospital Memphis TN M E DIFF Secondary chamber (1528F) and baghouse with so

bicarbonate and carbon injection

81 81 South Bend Medical Foundation South Bend IN M E WS Secondary chamber and wet scrubber 82 82 Good Samaritan Hospital Vincennes IN M E WS Secondary chamber and multi-chamber spray scrub88 88 Medina General Hospital Medina OH M E WS Secondary chamber (1800F, 1 sec) and wet scrubb95 95 St. Joseph's Hospital Marshfield WI M E DIFF Secondary chamber (1800F), quench tower, and ba

lime/carbon injection

108 108--1 Rocky Mountain Laboratories, National Institute 

of Allergy and Infectious Diseases

Unit 1 Hamilton MT M E WS Secondary chamber and wet scrubber 

111 111 Wyoming Medical Center Casper WY M E WS Secondary chamber and wet scrubber 

86 86 Fairfield Medical Center Lancaster OH S E WS Secondary chamber (1800F, 1 sec) and wet scrubb

129 129 Centers for Disease Control and Prevention--

Clifton, Building 18

Unit 3 Atlanta GA S N WS Secondary chamber (1800F, 1.68 sec) and rotary a

scrubber

115 115 Kona Community Hospital Kealakekua HI SR E CC Secondary chamber (1900F, 2 sec), no APCD 116 116 Yukon-Kuskokwim Delta Regional Hospital Bethel AK SR E CC Secondary chamber, no APCD 

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide
Table 17. Nationwide Baseline Annual Operating Costs for Existing Sources

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD description

Note:Included CO CEMS cost for one unit. CO CEMS annual cost =$26,300 ($25,000 x 525.4/499.6). Source is e-mail from Dan Bivins,EPA, to Mary Johnson, EPA. September 27, 2006.
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

1 1 Bristol-Myers Squibb Co.5 5 Merck & Company, Inc.

15 15--1 Curtis Bay Energy Unit 115 15--2 Curtis Bay Energy Unit 220 20--1 Fort Detrick Unit 520 20--2 Fort Detrick Unit 629 29 Hamot Medical Center36 36--1 Merck & Company, Inc. Unit 236 36--2 Merck & Company, Inc. Unit 540 40 Charleston Area Medical Center, General 

Hospital

42 42 Stericycle, Inc.43 43 Boca Raton Community Hospital

Baseline annual control costs

Stack gas 

temperature 

(°F)

Operating 

hours 

(hr/yr)

Estimated 

annual 

throughput 

(tpy)

Baseline 

annual 

incinerator 

operation 

cost DIFF FF ACI

Venturi 

scrubber

Packed-

scrubb

217 2,072 694 $115,222 $60,438246 4,321 1,157 $513,461 $329,586296 8,736 20,729 $1,936,035 $1,242,723 $378,784303 8,736 20,729 $2,137,348 $1,371,945 $418,171

87 1,300 436 $169,431 $59,90492 1,300 436 $161,338 $57,043

122 2,080 739 $258,679 $166,044 $50,610 $69,991358 865 580 $365,920 $234,881304 5,753 5,868 $567,529 $364,292312 1,248 418 $302,185 $193,970 $59,122327 7,951 5,061 $489,813 $314,407 $95,832

91 8,736 2,136 $145,213 $51,342

44 44 Bethesda Memorial Hospital46 46 Holy Cross Hospital48 48 Memorial Regional Hospital51 51 Lakeland Regional Medical Center54 54 Bayfront Medical Center55 55 St. Joseph's Hospital59 59--1 Stericycle, Inc. Unit 159 59--2 Stericycle, Inc. Unit 260 60--1 BMWNC, Inc. Unit 165 65--1 Stericycle, Inc. Unit 165 65--2 Stericycle, Inc. Unit 271 71 Loyola University Medical Center77 77 Parkview Hospital84 84 Mayo Clinic, Waste Management Facility87 87 MedCentral Health System, Mansfield Hospital94 94 Stericycle, Inc.

106 3,024 1,013 $317,121 $112,122124 2,964 1,291 $236,134 $83,488 $30

143 4,992 3,010 $319,272 $41

212 6,247 1,570 $232,273 $149,094133 3,352 1,684 $202,532 $71,608400 8,008 4,024 $233,951 $150,171 $63,300135 8,400 5,378 $279,697 $98,890 $36138 8,400 5,378 $273,796 $96,804 $35

343 7,456 3,747 $472,707 $303,426 $92,485143 7,665 3,852 $230,975 $81,664 $29141 7,558 3,798 $218,409 $77,221 $28

156 4,800 2,653 $246,484 $87,147

114 8,395 3,375 $193,349 $68,361

294 6,240 4,181 $455,427 $292,335 $89,104260 3,120 627 $164,322 $105,477 $32,149

94 94 Stericycle, Inc. 138 7,904 3,707 $191,286 $67,631
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

98 98--1 University of Texas Medical Branch

106 106 Stericycle, Inc.109 109 Healthcare Environmental Services Inc.110 110 Stericycle, Inc.120 120--1 Waste Management Resource Recovery and 

Recycling Center

Unit 1

120 120--2 Waste Management Resource Recovery and 

Recycling Center

Unit 2

125 125 East Carolina University, Health Sciences 

Campus, HSC Utility Plant

130 130 Department of Veterans Affairs Medical Center

13 13 University of Maryland at Baltimore, 

Environmental Health and Safety Facility

16 16 Johns Hopkins Medical Institute, Department of 

Health, Safety, and Environment

18 18 Franklin Square Hospital Center21 21 Washington County Hospital25 25 Holy Spirit Hospital

Baseline annual control costs

Stack gas 

temperature 

(°F)

Operating 

hours 

(hr/yr)

Estimated 

annual 

throughput 

(tpy)

Baseline 

annual 

incinerator 

operation 

cost DIFF FF ACI

Venturi 

scrubber

Packed-

scrubb

111 5,328 2,677 $316,938 $62,009 $112,057 $41

152 8,760 4,402 $250,939 $88,722302 1,872 1,057 $313,003 $200,914 $61,239126 7,309 4,738 $439,730 $86,033 $57

296 7,896 11,022 $701,128 $450,048 $137,175 291 7,896 11,022 $631,040 $405,059 $123,463 125 625 209 $218,351 $114,532 $59,079 155 4,160 1,394 $448,880 $158,707 $58

189 1,440 241 $76,114 $29,448 $18179 1,350 145 $72,942 $28,221

54 5,408 906 $115,785 $44,796

112 2,496 418 $70,780 $27,384

99 3,944 661 $65,716 $25,425

30 30 Riddle Memorial Hospital34 34 Pennsylvania State University, Animal 

Diagnostic Lab Incinerator

38 38 Wilkes-Barre General Hospital41 41 Thomas Memorial Hospital47 47 Malcolm Randall Veterans Affairs Medical 

Center

63 63 St. Jude Children's Research Hospital81 81 South Bend Medical Foundation82 82 Good Samaritan Hospital88 88 Medina General Hospital95 95 St. Joseph's Hospital

108 108--1 Rocky Mountain Laboratories, National Institute 

of Allergy and Infectious Diseases

Unit 1

111 111 Wyoming Medical Center

86 86 Fairfield Medical Center

129 129 Centers for Disease Control and Prevention--

Clifton, Building 18

Unit 3

115 115 Kona Community Hospital116 116 Yukon-Kuskokwim Delta Regional Hospital

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide

239 2,920 489 $66,763 $11,072 $25,830 $15

175 1,022 171 $81,723 $31,618

274 4,472 599 $79,640 $78,761 $13,208146 2,080 327 $58,916 $22,794 $14115 1,664 276 $63,500 $24,568276 1,050 176 $90,060 $89,066 $14,936121 2,028 319 $89,733 $34,717128 2,574 431 $52,190 $20,192100 3,016 303 $44,524 $17,226223 1,404 235 $63,076 $62,380 $10,461112 1,248 209 $69,105 $26,736130 989 133 $58,088 $22,474

97 5,018 160 $133,457 $39,135

163 2,920 117 $87,093 $25,539

1,787 1,430 96 $50,7691,457 1,560 26 $41,482

$14,749,915 $6,274,369 $174,970 $1,686,175 $1,565,079 $358

$1,218,657 $230,206 $0 $49,678 $381,430 $48

$220,549 $0 $0 $0 $64,674 

$92,251 $0 $0 $0 $0 

$16,166,150 $6,504,576 $114,532 $1,735,853 $2,011,183 $406
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

Note:Included CO CEMS cost for one unit. CO CEMS annual cost =$26,300 ($25,000 x 525.4/499.6). Source is e-mail from Dan Bivins,EPA, to Mary Johnson, EPA. September 27, 2006.

Baseline annual control costs

Stack gas 

temperature 

(°F)

Operating 

hours 

(hr/yr)

Estimated 

annual 

throughput 

(tpy)

Baseline 

annual 

incinerator 

operation 

cost DIFF FF ACI

Venturi 

scrubber

Packed-

scrubb
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

1 1 Bristol-Myers Squibb Co.5 5 Merck & Company, Inc.

15 15--1 Curtis Bay Energy Unit 115 15--2 Curtis Bay Energy Unit 220 20--1 Fort Detrick Unit 520 20--2 Fort Detrick Unit 629 29 Hamot Medical Center36 36--1 Merck & Company, Inc. Unit 236 36--2 Merck & Company, Inc. Unit 540 40 Charleston Area Medical Center, General 

Hospital

42 42 Stericycle, Inc.43 43 Boca Raton Community Hospital

Baseline annual monitoring costs

Total 

baseline 

control cost

Maintenance/ 

inspection

Good 

combustion 

monitoring

DIFF 

monitoring

FF 

monitoring

ACI 

monitoring

WS 

monitoring

DIFF/WS 

monitoring

DI

m

$60,438 $7,200

$329,586 $12,000

$1,621,507 $12,000 $4,800$1,790,115 $12,000 $4,800

$59,904 $7,300$57,043 $7,300

$286,645 $4,800 $12,300$234,881 $12,000$364,292 $12,000$253,092 $12,000 $4,800$410,238 $12,000 $4,800

$51,342 $7,300

44 44 Bethesda Memorial Hospital46 46 Holy Cross Hospital48 48 Memorial Regional Hospital51 51 Lakeland Regional Medical Center54 54 Bayfront Medical Center55 55 St. Joseph's Hospital59 59--1 Stericycle, Inc. Unit 159 59--2 Stericycle, Inc. Unit 260 60--1 BMWNC, Inc. Unit 165 65--1 Stericycle, Inc. Unit 165 65--2 Stericycle, Inc. Unit 271 71 Loyola University Medical Center77 77 Parkview Hospital84 84 Mayo Clinic, Waste Management Facility87 87 MedCentral Health System, Mansfield Hospital94 94 Stericycle, Inc.

$112,122 $7,300$114,141 $7,300$128,129 $149,094 $12,000

$71,608 $7,300

$213,471 $12,300$135,199 $7,300$132,346 $7,300$395,911 $12,000 $4,800$111,648 $7,300$105,574 $7,300

$87,147 $7,300$68,361 $7,300

$381,439 $12,000 $4,800$137,626 $12,000 $4,800

94 94 Stericycle, Inc. $67,631 $7,300
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

98 98--1 University of Texas Medical Branch

106 106 Stericycle, Inc.109 109 Healthcare Environmental Services Inc.110 110 Stericycle, Inc.120 120--1 Waste Management Resource Recovery and 

Recycling Center

Unit 1

120 120--2 Waste Management Resource Recovery and 

Recycling Center

Unit 2

125 125 East Carolina University, Health Sciences 

Campus, HSC Utility Plant

130 130 Department of Veterans Affairs Medical Center

13 13 University of Maryland at Baltimore, 

Environmental Health and Safety Facility

16 16 Johns Hopkins Medical Institute, Department of 

Health, Safety, and Environment

18 18 Franklin Square Hospital Center21 21 Washington County Hospital25 25 Holy Spirit Hospital

Baseline annual monitoring costs

Total 

baseline 

control cost

Maintenance/ 

inspection

Good 

combustion 

monitoring

DIFF 

monitoring

FF 

monitoring

ACI 

monitoring

WS 

monitoring

DIFF/WS 

monitoring

DI

m

$215,209 $4,800 $7,300

$88,722 $7,300

$262,152 $12,000 $4,800$263,799 $4,800 $618,898 $12,000 $4,800 $557,030 $12,000 $4,800 $180,365 $3,440 $7,300 $216,978 $7,300

$47,627 $4,000$28,221 $4,000$44,796 $4,000$27,384 $4,000$25,425 $4,000

30 30 Riddle Memorial Hospital34 34 Pennsylvania State University, Animal 

Diagnostic Lab Incinerator

38 38 Wilkes-Barre General Hospital41 41 Thomas Memorial Hospital47 47 Malcolm Randall Veterans Affairs Medical 

Center

63 63 St. Jude Children's Research Hospital81 81 South Bend Medical Foundation82 82 Good Samaritan Hospital88 88 Medina General Hospital95 95 St. Joseph's Hospital

108 108--1 Rocky Mountain Laboratories, National Institute 

of Allergy and Infectious Diseases

Unit 1

111 111 Wyoming Medical Center

86 86 Fairfield Medical Center

129 129 Centers for Disease Control and Prevention--

Clifton, Building 18

Unit 3

115 115 Kona Community Hospital116 116 Yukon-Kuskokwim Delta Regional Hospital

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide

$52,848 $1,600 $4,000$31,618 $4,000$91,969 $7,300 $1,600$36,866 $4,000$24,568 $4,000

$104,002 $7,300 $1,600

$34,717 $4,000$20,192 $4,000$17,226 $4,000$72,841 $7,300 $1,600$26,736 $4,000$22,474 $4,000$39,135 $5,600$25,539 $5,600

$0 $900 $3,300$0 $900 $3,300

$10,333,682 $0 $0 $168,000 $10,640 $62,400 $124,100 $24,600 

$709,510 $0 $0 $21,900 $0 $6,400 $56,000 $0 

$64,674 $0 $0 $0 $0 $0 $11,200 $0 

$0 $1,800 $6,600 $0 $0 $0 $0 $0 

$11,047,427 $1,800 $6,600 $189,900 $3,440 $68,800 $191,300 $24,600 
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

Note:Included CO CEMS cost for one unit. CO CEMS annual cost =$26,300 ($25,000 x 525.4/499.6). Source is e-mail from Dan Bivins,EPA, to Mary Johnson, EPA. September 27, 2006.

Baseline annual monitoring costs

Total 

baseline 

control cost

Maintenance/ 

inspection

Good 

combustion 

monitoring

DIFF 

monitoring

FF 

monitoring

ACI 

monitoring

WS 

monitoring

DIFF/WS 

monitoring

DI

m
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

1 1 Bristol-Myers Squibb Co.5 5 Merck & Company, Inc.

15 15--1 Curtis Bay Energy Unit 115 15--2 Curtis Bay Energy Unit 220 20--1 Fort Detrick Unit 520 20--2 Fort Detrick Unit 629 29 Hamot Medical Center36 36--1 Merck & Company, Inc. Unit 236 36--2 Merck & Company, Inc. Unit 540 40 Charleston Area Medical Center, General 

Hospital

42 42 Stericycle, Inc.43 43 Boca Raton Community Hospital

Baseline annual testing costs (annual tests) Baseline annual recordkeeping and reportin

Total 

monitoring 

cost

Annual 

PM 

testing

Annual 

CO 

testing

Annual 

HCl 

testing

Annual 

opacity 

testing

Total 

annual 

testing 

cost

Operating 

information

Compliance 

report Records

Train

perso

$7,200 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$12,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$17,100 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$12,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$12,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

44 44 Bethesda Memorial Hospital46 46 Holy Cross Hospital48 48 Memorial Regional Hospital51 51 Lakeland Regional Medical Center54 54 Bayfront Medical Center55 55 St. Joseph's Hospital59 59--1 Stericycle, Inc. Unit 159 59--2 Stericycle, Inc. Unit 260 60--1 BMWNC, Inc. Unit 165 65--1 Stericycle, Inc. Unit 165 65--2 Stericycle, Inc. Unit 271 71 Loyola University Medical Center77 77 Parkview Hospital84 84 Mayo Clinic, Waste Management Facility87 87 MedCentral Health System, Mansfield Hospital94 94 Stericycle, Inc.

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,500 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$12,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$12,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

94 94 Stericycle, Inc. $7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

98 98--1 University of Texas Medical Branch

106 106 Stericycle, Inc.109 109 Healthcare Environmental Services Inc.110 110 Stericycle, Inc.120 120--1 Waste Management Resource Recovery and 

Recycling Center

Unit 1

120 120--2 Waste Management Resource Recovery and 

Recycling Center

Unit 2

125 125 East Carolina University, Health Sciences 

Campus, HSC Utility Plant

130 130 Department of Veterans Affairs Medical Center

13 13 University of Maryland at Baltimore, 

Environmental Health and Safety Facility

16 16 Johns Hopkins Medical Institute, Department of 

Health, Safety, and Environment

18 18 Franklin Square Hospital Center21 21 Washington County Hospital25 25 Holy Spirit Hospital

Baseline annual testing costs (annual tests) Baseline annual recordkeeping and reportin

Total 

monitoring 

cost

Annual 

PM 

testing

Annual 

CO 

testing

Annual 

HCl 

testing

Annual 

opacity 

testing

Total 

annual 

testing 

cost

Operating 

information

Compliance 

report Records

Train

perso

$12,100 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$16,800 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$17,100 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$18,500 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$18,500 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$18,240 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$7,300 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

30 30 Riddle Memorial Hospital34 34 Pennsylvania State University, Animal 

Diagnostic Lab Incinerator

38 38 Wilkes-Barre General Hospital41 41 Thomas Memorial Hospital47 47 Malcolm Randall Veterans Affairs Medical 

Center

63 63 St. Jude Children's Research Hospital81 81 South Bend Medical Foundation82 82 Good Samaritan Hospital88 88 Medina General Hospital95 95 St. Joseph's Hospital

108 108--1 Rocky Mountain Laboratories, National Institute 

of Allergy and Infectious Diseases

Unit 1

111 111 Wyoming Medical Center

86 86 Fairfield Medical Center

129 129 Centers for Disease Control and Prevention--

Clifton, Building 18

Unit 3

115 115 Kona Community Hospital116 116 Yukon-Kuskokwim Delta Regional Hospital

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide

$5,600 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $

$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$8,900 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$8,900 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$8,900 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,000 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$5,600 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$5,600 $12,000 $7,000 $7,000 $2,500 $19,833 $1,570 $4,535 $7,374 $$4,200 $0 $0 $0 $2,500 $2,500 $1,570 $2,093 $5,107 $

$4,200 $0 $0 $0 $2,500 $2,500 $1,570 $2,093 $5,107 $

$420,440 $432,000 $252,000 $252,000 $90,000 $714,000 $56,507 $163,244 $265,468 $6

$84,300 $204,000 $119,000 $119,000 $42,500 $337,167 $26,684 $77,087 $125,360 $2$11,200 $24,000 $14,000 $14,000 $5,000 $39,667 $3,139 $9,069 $14,748 $

$8,400 $0 $0 $0 $5,000 $5,000 $3,139 $4,186 $10,214 $

$517,140 $648,000 $378,000 $378,000 $140,000 $1,076,000 $89,470 $253,586 $415,789 $9
Table 17. Nationwide Baseline Annual Operating C

FACID UNITID Facility name

Unit 

number

Note:Included CO CEMS cost for one unit. CO CEMS annual cost =$26,300 ($25,000 x 525.4/499.6). Source is e-mail from Dan Bivins,EPA, to Mary Johnson, EPA. September 27, 2006.

Baseline annual testing costs (annual tests) Baseline annual recordkeeping and reportin

Total 

monitoring 

cost

Annual 

PM 

testing

Annual 

CO 

testing

Annual 

HCl 

testing

Annual 

opacity 

testing

Total 

annual 

testing 

cost

Operating 

information

Compliance 

report Records

Train

perso
Table 18. Nationwide Autoclave/Landfill Annual Costs for Existing Sources

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD descr

1 1 Bristol-Myers Squibb Co. Wallingford CT L E FF Secondary chamber (1800F) and baghou5 5 Merck & Company, Inc. Rahway NJ L E DIFF Secondary chamber (1500F, 1 sec), partia

with dry lime injection, and baghouse

15 15--1 Curtis Bay Energy Unit 1 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and ba

injection

15 15--2 Curtis Bay Energy Unit 2 Baltimore MD L E DIFF Secondary chamber, dry scrubber, and ba

injection

20 20--1 Fort Detrick Unit 5 Fort Detrick MD L E WS Secondary chamber and rotary atomizing 20 20--2 Fort Detrick Unit 6 Fort Detrick MD L E WS Secondary chamber and rotary atomizing 29 29 Hamot Medical Center Erie PA L E DIFF/WS Secondary chamber (2000F, 2 sec), lime 

activated carbon injection system, baghoumulti-microventuri scrubber system

36 36--1 Merck & Company, Inc. Unit 2 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary/tertiary chamber (2000F, 2 sec

sodium bicarbonate injection system with jet baghouse

36 36--2 Merck & Company, Inc. Unit 5 West Point (Upper 

Gwynedd Township)

PA L E DIFF Secondary chamber (1800F, 2.2 sec), wa

bicarbonate injection system and pulse-je

40 40 Charleston Area Medical Center, General Hospital Charleston WV L E DIFF Secondary chamber (1800F, 2 sec), dry in

system with activated carbon

42 42 Stericycle, Inc. Apopka FL L E DIFF Secondary chamber (1800, 1 sec), dry sc

chamber, passive absorber, lime and carb

43 43 Boca Raton Community Hospital Boca Raton FL L E WS Secondary chamber (1800F, 1 sec) and r

system with caustic soda injection

44 44 Bethesda Memorial Hospital Boynton Beach FL L E WS Secondary chamber (1800F, 2 sec) and r

eliminator

46 46 Holy Cross Hospital Fort Lauderdale FL L E WS Secondary chamber (1800F, 1 sec) and v

absorption unit using dilute NaOH

48 48 Memorial Regional Hospital Hollywood FL L E WS/WESP Secondary chamber (1800F, 1 sec), pack

ESP

51 51 Lakeland Regional Medical Center Lakeland FL L E DIFF Secondary chamber (1800F, 1 sec), lime 54 54 Bayfront Medical Center St. Petersburg FL L E WS Secondary chamber (1800F, 1 sec) and fl

scrubber system using dilute NaOH

55 55 St. Joseph's Hospital Tampa FL L E DIFF/WS Secondary chamber (1800F, 1 sec), lime 

scrubber

59 59--1 Stericycle, Inc. Unit 1 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid 

system consisting of a packed bed absorbdemister.

59 59--2 Stericycle, Inc. Unit 2 Haw River NC L E WS Secondary chamber (1800F, 1 sec), rapid 

system consisting of a packed bed absorbdemister.

60 60--1 BMWNC, Inc. Unit 1 Matthews NC L E DIFF Secondary chamber (1641F), dry scrubbe

injection, and baghouse

65 65--1 Stericycle, Inc. Unit 1 Clinton IL L E WS Secondary chamber (1800F), venturi scru65 65--2 Stericycle, Inc. Unit 2 Clinton IL L E WS Secondary chamber (1800F), venturi scru71 71 Loyola University Medical Center Maywood IL L E WS Two secondary chambers (1600F), twin ro

caustic solution, and two demister pads

77 77 Parkview Hospital Fort Wayne IN L E WS Secondary chamber and wet scrubber 84 84 Mayo Clinic, Waste Management Facility Rochester MN L E DIFF Secondary chamber (1800F, 1 sec) and b

injection

87 87 MedCentral Health System, Mansfield Hospital Mansfield OH L E DIFF Secondary chamber (1800F, 2 sec) and b

injection system

94 94 Stericycle, Inc. Warren OH L E WS Secondary chamber (1800F, 2 sec), wet s98 98--1 University of Texas Medical Branch Galveston TX L E WS Secondary chamber, packed tower, and v

carbon injection

106 106 Steric 106 106 Stericycle,Inc. Kansas Cit Inc. Kansas City KS L E WS Secondar KS L E WS Secondary chamber chamber (1800F,2 sec),wet s

wet s
Table 18. Nationwide Autoclave/Landfill Annual Costs for Existing Sources

FACID UNITID Facility name

Unit 

number City State Category

New/ 

existing APCD code APCD descr

109 109 Healthcare Environmental Services Inc. Fargo ND L E DIFF Secondary chamber (1800F) and dry scru

and carbon injection

110 110 Stericycle, Inc. North Salt Lake UT L E DI-ESP/WS Secondary chamber (1834F), carbon injec

and wet gas absorber

120 120--1 Waste Management Resource Recovery and Recycling 

Center

Unit 1 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin 

activated carbon injection

120 120--2 Waste Management Resource Recovery and Recycling 

Center

Unit 2 Anahuac TX L N DIFF Secondary chamber, baghouse with virgin 

activated carbon injection

125 125 East Carolina University, Health Sciences Campus, 

HSC Utility Plant

Greenville NC L N HEPA/CA/

WS

Secondary chamber (1985F), rotary atomscrubbing medium), carbon bed adsorber

recovery system

130 130 Department of Veterans Affairs Medical Center Miami FL L E WS Secondary chamber (1800F, 1 sec), ventu

absorber

13 13 University of Maryland at Baltimore, Environmental 

Health and Safety Facility

Baltimore MD M E WS Secondary chamber (1832F) and venturi 

scrubber

16 16 Johns Hopkins Medical Institute, Department of Health, 

Safety, and Environment

Baltimore MD M E WS Secondary chamber (1800F) and venturi w

saturation chamber and mist eliminator

18 18 Franklin Square Hospital Center Baltimore MD M E WS Secondary chamber (1800F) and venturi 

chamber and mist eliminator

21 21 Washington County Hospital Hagerstown MD M E WS Secondary chamber and venturi caustic s25 25 Holy Spirit Hospital Camp Hill PA M E WS Secondary chamber (1800F) and venturi s

NaOH injection

30 30 Riddle Memorial Hospital Media PA M E WS Secondary chamber (1800F, 2 sec), caus

high pressure venturi, with activated carbo

34 34 Pennsylvania State University, Animal Diagnostic Lab 

Incinerator

State College PA M E WS Secondary chamber (1900F) and rotary a

demister

38 38 Wilkes-Barre General Hospital Wilkes-Barre PA M N DIFF Secondary/tertiary chambers (1800F, 2.85 

with lime and activated carbon injection

41 41 Thomas Memorial Hospital South Charleston WV M E WS Secondary chamber (1800F) and venturi 

caustic injection

47 47 Malcolm Randall Veterans Affairs Medical Center Gainesville FL M E WS Secondary chamber (1800F, 1 sec) and w

injection

63 63 St. Jude Children's Research Hospital Memphis TN M E DIFF Secondary chamber (1528F) and baghou

carbon injection

81 81 South Bend Medical Foundation South Bend IN M E WS Secondary chamber and wet scrubber 82 82 Good Samaritan Hospital Vincennes IN M E WS Secondary chamber and multi-chamber s88 88 Medina General Hospital Medina OH M E WS Secondary chamber (1800F, 1 sec) and w95 95 St. Joseph's Hospital Marshfield WI M E DIFF Secondary chamber (1800F), quench tow

injection

108 108--1 Rocky Mountain Laboratories, National Institute of 

Allergy and Infectious Diseases

Unit 1 Hamilton MT M E WS Secondary chamber and wet scrubber 

111 111 Wyoming Medical Center Casper WY M E WS Secondary chamber and wet scrubber 

86 86 Fairfield Medical Center Lancaster OH S E WS Secondary chamber (1800F, 1 sec) and w

129 129 Centers for Disease Control and Prevention--Clifton, 

Building 18

Unit 3 Atlanta GA S N WS Secondary chamber (1800F, 1.68 sec) an

115 115 Kona Community Hospital Kealakekua HI SR E CC Secondary chamber (1900F, 2 sec), no A116 116 Yukon-Kuskokwim Delta Regional Hospital Bethel AK SR E CC Secondary chamber, no APCD 

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide
Table 18. Nationwide Autoclave/Landfill Annual Costs 

FACID UNITID Facility name

Unit 

number

1 1 Bristol-Myers Squibb Co.5 5 Merck & Company, Inc.

15 15--1 Curtis Bay Energy Unit 115 15--2 Curtis Bay Energy Unit 220 20--1 Fort Detrick Unit 520 20--2 Fort Detrick Unit 629 29 Hamot Medical Center36 36--1 Merck & Company, Inc. Unit 236 36--2 Merck & Company, Inc. Unit 540 40 Charleston Area Medical Center, General Hospital42 42 Stericycle, Inc.43 43 Boca Raton Community Hospital44 44 Bethesda Memorial Hospital

Autoclave/landfill annual cost

Stack gas 

flow rate 

(dscfm)

Stack gas 

temperature 

(°F)

Operating 

hours (hr/yr)

Estimated 

annual 

throughput 

(tpy)

Waste heat 

recovery 

boiler

Autoclave 

($/lb)

Landfill tip 

fee region

Land

($

1,648 217 2,072 694 Yes $0.02 Northeast $7,346 246 4,321 1,157 $0.02 Mid-Atlantic $

27,698 296 8,736 20,729 Yes $0.02 Mid-Atlantic $30,578 303 8,736 20,729 Yes $0.02 Mid-Atlantic $

2,424 87 1,300 436 Yes $0.02 Mid-Atlantic $2,308 92 1,300 436 Yes $0.02 Mid-Atlantic $3,701 122 2,080 739 Yes $0.02 Mid-Atlantic $5,235 358 865 580 $0.02 Mid-Atlantic $8,119 304 5,753 5,868 $0.02 Mid-Atlantic $4,323 312 1,248 418 Yes $0.02 Mid-Atlantic $7,008 327 7,951 5,061 $0.02 South $2,078 91 8,736 2,136 Yes $0.02 South $4,537 106 3,024 1,013 Yes $0.02 South $

46 46 Holy Cross Hospital48 48 Memorial Regional Hospital51 51 Lakeland Regional Medical Center54 54 Bayfront Medical Center55 55 St. Joseph's Hospital59 59--1 Stericycle, Inc. Unit 159 59--2 Stericycle, Inc. Unit 260 60--1 BMWNC, Inc. Unit 165 65--1 Stericycle, Inc. Unit 165 65--2 Stericycle, Inc. Unit 271 71 Loyola University Medical Center77 77 Parkview Hospital84 84 Mayo Clinic, Waste Management Facility87 87 MedCentral Health System, Mansfield Hospital94 94 Stericycle, Inc.98 98--1 University of Texas Medical Branch

106 106 Stericycle, Inc.

3,378 124 2,964 1,291 Yes $0.02 South $4,568 143 4,992 3,010 Yes $0.02 South $3,323 212 6,247 1,570 Yes $0.02 South $2,898 133 3,352 1,684 Yes $0.02 South $3,347 400 8,008 4,024 Yes $0.02 South $4,002 135 8,400 5,378 $0.02 South $3,917 138 8,400 5,378 $0.02 South $6,763 343 7,456 3,747 $0.02 South $3,304 143 7,665 3,852 $0.02 Midwest $3,125 141 7,558 3,798 $0.02 Midwest $3,526 156 4,800 2,653 Yes $0.02 Midwest $2,766 114 8,395 3,375 Yes $0.02 Midwest $6,516 294 6,240 4,181 Yes $0.02 Midwest $2,351 260 3,120 627 $0.02 Midwest $2,737 138 7,904 3,707 $0.02 Midwest $4,534 111 5,328 2,677 $0.02 South Central $

106 106 Stericycle, Inc. 3,590 152 8 590 152 8,760 4,402 $0.02 West Central .02 West Central $
Table 18. Nationwide Autoclave/Landfill Annual Costs 

FACID UNITID Facility name

Unit 

number

109 109 Healthcare Environmental Services Inc.110 110 Stericycle, Inc.120 120--1 Waste Management Resource Recovery and Recycling 

Center

Unit 1

120 120--2 Waste Management Resource Recovery and Recycling 

Center

Unit 2

125 125 East Carolina University, Health Sciences Campus, 

HSC Utility Plant

130 130 Department of Veterans Affairs Medical Center

13 13 University of Maryland at Baltimore, Environmental 

Health and Safety Facility

16 16 Johns Hopkins Medical Institute, Department of Health, 

Safety, and Environment

18 18 Franklin Square Hospital Center21 21 Washington County Hospital25 25 Holy Spirit Hospital30 30 Riddle Memorial Hospital34 34 Pennsylvania State University, Animal Diagnostic Lab 

Incinerator

Autoclave/landfill annual cost

Stack gas 

flow rate 

(dscfm)

Stack gas 

temperature 

(°F)

Operating 

hours (hr/yr)

Estimated 

annual 

throughput 

(tpy)

Waste heat 

recovery 

boiler

Autoclave 

($/lb)

Landfill tip 

fee region

Land

($

4,478 302 1,872 1,057 Yes $0.02 West Central $6,291 126 7,309 4,738 Yes $0.02 West Central $

10,031 296 7,896 11,022 $0.02 South Central $

9,028 291 7,896 11,022 $0.02 South Central $3,124 125 625 209 Yes $0.02 South $6,422 155 4,160 1,394 Yes $0.02 South $1,972 189 1,440 241 $0.02 Mid-Atlantic $1,890 179 1,350 145 $0.02 Mid-Atlantic $2,999 54 5,408 906 Yes $0.02 Mid-Atlantic $1,834 112 2,496 418 Yes $0.02 Mid-Atlantic $1,702 99 3,944 661 $0.02 Mid-Atlantic $1,730 239 2,920 489 Yes $0.02 Mid-Atlantic $2,117 175 1,022 171 $0.02 Mid-Atlantic $

38 38 Wilkes-Barre General Hospital41 41 Thomas Memorial Hospital47 47 Malcolm Randall Veterans Affairs Medical Center63 63 St. Jude Children's Research Hospital81 81 South Bend Medical Foundation82 82 Good Samaritan Hospital88 88 Medina General Hospital95 95 St. Joseph's Hospital

108 108--1 Rocky Mountain Laboratories, National Institute of 

Allergy and Infectious Diseases

Unit 1

111 111 Wyoming Medical Center

86 86 Fairfield Medical Center

129 129 Centers for Disease Control and Prevention--Clifton, 

Building 18

Unit 3

115 115 Kona Community Hospital116 116 Yukon-Kuskokwim Delta Regional Hospital

Total largeTotal mediumTotal smallTotal small ruralTotal nationwide

2,063 274 4,472 599 Yes $0.02 Mid-Atlantic $1,526 146 2,080 327 $0.02 Mid-Atlantic $1,645 115 1,664 276 Yes $0.02 South $2,333 276 1,050 176 $0.02 South $2,325 121 2,028 319 $0.02 Midwest $1,352 128 2,574 431 $0.02 Midwest $1,153 100 3,016 303 $0.02 Midwest $1,634 223 1,404 235 Yes $0.02 Midwest $1,790 112 1,248 209 $0.02 West Central $1,505 130 989 133 $0.02 West Central $1,095 97 5,018 160 $0.06 Midwest $

715 163 2,920 117 $0.06 South $684 1,787 1,430 96 $0.06 West $559 1,457 1,560 26 $0.06 West $
Table 19. Summary of Nationwide Baseline Annual Operating Costs and

Autoclave/Landfill Annual Costs for Existing Sources

Baseline annual operating costs

Parameters Combustor Control Monitoring Testing

Recordkeeping 

and reporting Total

A

utoclave/

landfill annual 

cost

Large $14,749,915 $10,333,682 $420,440 $714,000 $548,005 $26,766,041 $10,035,221Medium $1,218,657 $709,510 $84,300 $337,167 $258,780 $2,608,413 $543,819Small $220,549 $64,674 $11,200 $39,667 $30,445 $366,535 $40,033Small rural $92,251 $0 $8,400 $5,000 $21,027 $126,678 $18,163Total $16,166,150 $11,047,427 $517,140 $1,076,000 $858,257 $29,649,752 $10,637,237Note: The autoclave/landfill costs are presented for comparison to baseline operating costs for existing HMIWI.