### Date: March 15, 2013

Subject: Inventory of Hospital/Medical/Infectious Waste Incinerator s Potentially Covered by

the Final Section 111(d)/129 Federal Plan

From: Amy Hambrick

OAQPS/SPPD ( E143

- 03 )
U.S. Envir onmental Protection Agency Research Triangle Park, NC 27711

To: HMIWI Federal Plan Docket

I. Introduction

Under sections 111 and 129 of the Clean Air Act (CAA), U.S. Environmental Protection Agency (EPA) is required to develop emissions guidelines (EG) for existing hospital/medical/ infectious waste incinerators (HMIWI) and new source performance standards (NSPS) for new

HMIWI. The regulations are designed to limit em issions of nine pollutants and opacity from these HMIWI. The nine pollutants are hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg), particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NO X 

### ), and sulfur dio xide (SO 2 

### ). Regulations for the HMIWI category were promulgated on September 15, 1997. The EG are codified in 40 CFR part 60, subpart Ce, and the NSPS are codified in 40 CFR part 60, subpart Ec. The HMIWI regulations were remanded by the U.S.
Court of A ppeals for the D.C. Circuit (the Court) on March 2, 1999 for further explanation by EPA regarding the approach and methodology that EPA used to develop the HMIWI regulations. On October 6, 2009, the EPA promulgated amended EG and NSPS for HMIWI to address the
concerns raised in the C ourt ’s remand

.

Unlike the subpart Ec NSPS, which apply directly to new sources, states must develop a State Plan in order to compel existing sources to meet the subpart Ce EG. Together, subpart B and subpart Ce of part 60 spe cify the State Plan content and the general rules for adopting and submitting these State Plans. State Plans were developed previously to implement the EG adopted on September 15, 1997 . R evised or new State Plans to implement the amended EG adopted on Oc tober 6, 2009 were due to EPA for review and approval on October 6, 2010. The EG require EPA to develop and implement a Federal Plan for each state that does not have an approved revised or new State Plan in place within 2 years after promulgation of the EG. A Federal Plan to implement the September 15, 1997 EG was promulgated on August 15, 2000 and is codified in 40 CFR part 62, subpart HHH . Amendments to the Federal Plan were proposed on April 23, 2012.

For approval, one of the requirements of a Stat e Plan is a source inventory and an emissions inventory. Likewise, the Federal Plan must contain a source and emissions inventory for HMIWI not covered under a State Plan. The purpose of this memorandum is to present an updated source and emissions inven tory of the HMIWI industry for the final amendments to the

### Federal Plan and to document the sources of the database information. The database fields are

listed in Table 1 below, along with descriptions of their respective information sources. The

databas e is presented in Appendix A. The acronyms and abbreviations used in the database are presented in Appendix B. Appendix C shows which units have shut down since 2010.

II. Updates to 2010 Inventory

For the October 6, 2009 amendments to the EG, EPA estimated there were 57 HMIWI currently operating in the U.S. 1 

### Based on recently obtained inventory information, EPA has

determined that 21 of those HMIWI have shut down and now estimates there are 33 HMIW I currently operating. 2

- 5 

### The inventory of HMIWI was developed and updated as a result of contacts with EPA Regions, States, and HMIWI facilities and review of existing HMIWI inventories, title V permits, emissions test reports, and facility websites. 1

- 6



### III. References

1. Memorandum from Thomas Holloway, RTI, to Project File. July 6, 2009

. Updated Hospital/Medical/Infectious Waste Incinerator (HMIWI) Inventory Database.

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

3. Zentner, Sonny. May 5, 2008. Analysis, Preliminary Determination and Draft Permit for the Renewal of Operation Permit Number 7720545800

- P10 for St. Joseph’s Hospital. Wisconsin Department of Natural Resources.

4. Letter from Wilkes

- Barre General Ho spital to EPA Region III. June 7, 2009.

5. Memorandum from Amy Hambrick, EPA, to HMIWI Federal Plan Docket

. March

15 , 2013. HMIWI Units Shut Down Since 2010

.

6. Memorandum from Thomas Holloway, RTI, to Mary Johnson, EPA. July 6

, 200 9

. Revised Baseline Emissions and Emissions Reductions for Existing and New HMIWI

.

### Table 1. Fields Included in HMIWI Source and Emissions Inventory

Field name Description Information sources

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

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

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

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

websites.

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

.

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

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

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

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

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

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

.

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

.

X Coordinate Longitude measure in decimal degrees of the angular distance on a
meridian east or west of the prime meridian. Negative (

- ) data point for N. America. Include (

- ) sign, e .g.,

- 123.2345 61

. Most based on the most accurate longitude data available from NEI (based on horizontal accuracy measure). Data
for some units not available from the NEI. Obtained
data for th ese units from EPA’ s Envirofacts or from RTI’s GIS group.Field name Description Information sources

Y Coordinate Latitude measure in decimal degrees of the angular distance on a
meridian north or south of the equator. Positive (+) data point for N. America. Include (+) sign, e .g., +78.12345 6

. Most based on the most accurate latitude data available from NEI (based on horizontal accuracy measure). Data
for some units not available fr om the NEI. Obtained
data for these units from EPA’s Envirofacts or from RTI’s GIS group.

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

Plan Status (1997 HMIWI Rule) Stat us of State /Federal
Plan s implementing the
1997 HMIWI rule

. Taken from EPA’s State/Federal plan st atus website for
1997 HMIWI rule

.

Compliance Date (1997 HMIWI Rule) Date of compliance with the State/Federal plans implementing the 1997
HMIWI rule

. Based on compliance dates in permits and inventories.

Facility Contact Name The name of the facility

contact. Based on facility contact name from permits, test reports, inventories, facility websites, and facility contacts.

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

contacts.

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

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

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

Size Category The size category of the
incinerator (i.e., large (L), medium (M), small (S), or small rural (SR))

. Based on size information from permits, test reports, and
inventories.

New Existing Whether the incinerator is

new (N) or existing (E)

. Based on incinerator description from permits, test reports, and inventories.

Mode The mode of operation of
the incinerator (i.e., continuous (C), inter

mittent (I), or batch (B))

. Based on operating information from permits, test reports, and inventories.

Waste Heat Recovery
Boiler Whether the facility has a waste heat recovery boiler
to recover as steam the energy from the HMIWI Based on facility descri ption from permits and test
reports.Field name Description Information sources

Commercial Whether the facility is a
commercial incineration facility (Yes/No)

. Based on incinerator description from permits, test reports, and inventories.

Dun & Bradstreet Number Dun & Bradstreet no. for
the facili ty. Based on information from Dun & Bradstreet Million Dollar Directory, NEI

, and EPA’s Envirofacts website.

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

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

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

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

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

Small Business Small business status
based on SBA size
standards (Yes/No/ Borderline)

. Determined based on comparison of SBA size standards to employment and sales information for parent companies.

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

Other Facility Registry
Identifiers Other ID numbers assigned by the EPA Facility Registry System. Taken from NEI, permits, test reports, State

correspo ndence, and EPA’s Envirofacts website.

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

Emission Unit Description A text description of the
Emission U

nit. Described emission units as “hospital/medical/infectious

waste incinerators.” Also included information about the model of incinerator, if available.

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

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

Emission Release P t ID State/local/tribal ID for point/location where
emissions are released to In some cases, based emission release point IDs on permits, test reports, inventories, State correspondence, and NEI. Otherwise, assigned the same ID as theField name Description Information sources

ambient air. emission uni t ID.

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

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

- operated HMIWI (two units at one facility).

Control System Description Description of control equipment chain. Most control devices based on information from p ermits

an d test reports, but one ba sed on information from
website

.
Control System Abbr Abbreviation of control equipment used (FF= fabric filter, DIFF=dry injection fabric filter, WS=wet scrubber, CC= combustion control, ESP= electrostatic precipitator,

WESP=wet ESP, CA= carbon adsorber). Based on control system description.

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

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

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

Design Capacity Batch (lb/batch) Numeric value of average operational capacity (in lb/batch) for a batch

e mission u nit. Based on batch design capacity information from test
reports.

Max Charge Rate (lb/hr) Numeric value of maximum charge rate (in lb/hr) for an e mission u nit

if different from design capacity. Based on maximum charge rate informati on from permits, test reports, inventories , and facility contacts

. Several facilities chose to have their permits revised to reduce their allowable HMIWI charge rates below design

capa city in order to qualify for a smaller HMIWI size category with less stringent emission limits.Field name Description Information sources

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

rate.

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

A nn ual Throughput for 2002 (tpy) Numeric value of 2002 annual throughput (in tpy) Most based on 2002 annual throughput values from

f acilities, EPA Regions, and States. Data not available for several units, so annual throughput values were calculated using hourly throughputs from stack test and annual operating hours from facilities.

Annual Throughput for

2002 Notes Notes regarding

ca lculation of 2002 annual throughput. Documented inputs used to calculate annual throughput.

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

Est. Annual Throughput

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

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

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

Summer Throughput PCT The percentage a process operates during the
summer months. Whole
number between 0 and

100. Taken from NEI and EPA’s Envirofacts web site. Otherwise assumed “25 percent” for each season.

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

Annual Avg Hours Per Day Average number of hours per day an emission process is active within

year. Most based on data from facilities, EPA Regions, and States, with a few based on data from NEI and one based on data from a permit.

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

Annual Avg Days Per
Week Average number of days per week an emission process is active within

year. Most based on data from facilities, EPA Regions, and States, with four based on data from NEI and two based on data from a permit.

Annual Avg Days Per
Week Notes Notes regarding
calculation of annual

average days per week

. Documented inputs used to calcul ate annual average days per week.

Annual Avg Weeks Per

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

Annual Avg Weeks Per

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

Annual Avg Hours Per

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

Annual Avg Hours Per

Year Notes Notes regarding
calculation of annual

average hours per year. Documented inputs used to calc ulate annual average hours per year

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

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

Stack Dimensions (ft x ft) The dimensions (in feet x feet) of a non

- circular
stack. One unit ha s rectangular, not circular, stack. Therefore,
stack diameter is not relevant for th i s unit s . Provided
stack dimensions in units of feet x feet.

Stack Area (ft 2 ) The area (in square feet)
of a stack

. Based on stack area data from test reports. Stack area
values also could be calculated based on data for stack diameter, or data for exit gas flow rate and exit gas velocity.

Exit Gas Temperature (deg F) The temperature of an exit gas stream (degree s Fa hrenheit). B ased on average stack temperatures from test reports.

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

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

Exit Gas Flow Rate Std Numeric value of stack gas flow rate in dry B ased on average standard gas flow rates from testField name Description Information sources

(dscfm) standard cubic feet per
minute. reports.

HCl U nit A verage Concentration (ppmvd) Numeric value of average HCl concentration (in ppmvd) for an emission
unit Based on average HCl concentration data from test
reports.

CO U nit A verage Concentration (ppmvd) Numeric value of average CO concentration (in ppmvd) for an emission
unit Based on average CO concentration data from test
reports.

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

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

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

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

Total CDD/CDF U

nit

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

CDD/CDF TEQ U

nit
A verage Concentration (ng/dscm) Numeric value of average TEQ concentration (in ng/dscm) for an emission
unit Based on average TEQ concentrat ion data from test
reports.

NO X U nit A verage Concentration (ppmvd) Numeric value of average

NO X concentration (in ppmvd) for an emission
unit Based on average NO X concentration data from test
reports.

SO 2 U nit A verage Concentration (ppmvd) Numeric value of average

SO 2 concentration (in ppmvd) for an emission
unit Based on average SO 2 concentration data from test
reports.

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

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

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

Cd Annual Emissions (lb/yr) Numeric value of annual Cd emissions (in lb/yr) for

an emission unit Based on emissions and parameter data from test reports and annual operating hours.

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

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

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

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

NO X Annual Emissions (lb/yr) Numeric value of annual

NO X emissions (in lb/yr)
for an emission unit Based on emissions and parameter data from test reports and annual opera ting hours.

SO 2 Annual Emissions (lb/yr) Numeric value of annual

SO 2 emissions (in lb/yr)
for an emission unit Based on emissions and parameter data from test reports and annual operating hours.

### Appendix A

HMIWI Source and Emissions Inventory

### Appendix B

Acronyms and Abbreviations Used in HMIWI Source and Emissions Inventory

### Appendix C
HMIWI That Have Shut Down Since 2010