Date: April 6, 2012

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

the Proposed Section 111(d)/129 Federal Plan

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

From: Thomas Holloway

To: Amy Hambrick

OAQPS/SPPD (E143-03)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

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 emissions of nine pollutants and opacity from these 

HMIWI. The nine pollutants are hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), 

cadmium (Cd), mercury (Hg), particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen 

oxides (NOX), and sulfur dioxide (SO2). Regulations for the HMIWI category were promulgated 

on September 15, 1997. The EG are codified in 40 CFR part 60, subpart Ce, and the NSPS are 

codified in 40 CFR part 60, subpart Ec. The HMIWI regulations were remanded by the U.S. 

Court of Appeals for the D.C. Circuit (the Court) on March 2, 1999 for further explanation by

EPA regarding the approach and methodology that EPA used to develop the HMIWI regulations. 

On October 6, 2009, the EPA promulgated amended EG and NSPS for HMIWI to address the 

concerns raised in the Court’s remand.

Unlike the subpart Ec NSPS, which apply directly to new sources, states must develop a 

State Plan in order to compel existing sources to meet the subpart Ce EG. Together, subpart B and 

subpart Ce of part 60 specify the State Plan content and the general rules for adopting and 

submitting these State Plans. State Plans were developed previously to implement the EG adopted 

on September 15, 1997. Revised or new State Plans to implement the amended EG adopted on 

October 6, 2009 were due to EPA for review and approval on October 6, 2010. The EG require 

EPA to develop and implement a Federal Plan for each state that does not have an approved 

revised or new State Plan in place within 2 years after promulgation of the EG. A Federal Plan to 

implement the September 15, 1997 EG was promulgated on August 15, 2000 and is codified in 40 

CFR part 62, subpart HHH. Amendments to the Federal Plan are currently being developed to 

implement the October 6, 2009 amendments to the EG.
2

For approval, one of the requirements of a State Plan is a source inventory and an 

emissions inventory. Likewise, the Federal Plan must contain a source and emissions inventory

for HMIWI not covered under a State Plan. The purpose of this memorandum is to present an 

updated source and emissions inventory of the HMIWI industry for the proposed amendments to 

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

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

database is presented in Appendix A. The acronyms and abbreviations used in the database are 

presented in Appendix B.

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 three of those HMIWI have shut down and now estimates there are 54 HMIWI 

currently operating.2-4 The inventory of HMIWI was developed and updated as a result of 

contacts with EPA Regions, States, and HMIWI facilities and review of existing HMIWI

inventories, title V permits, emissions test reports, and facility websites.1-5

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 Hospital to EPA Region III. June 7, 2009.

5. Memorandum from Thomas Holloway, RTI, to Mary Johnson, EPA. July 6, 2009. 

Revised Baseline Emissions and Emissions Reductions for Existing and New HMIWI.
3

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 States and 

territories from EPA website.

X Coordinate Longitude measure in 

decimal degrees of the 

angular distance on a 

meridian east or west of 

the prime meridian. 

Negative (-) data point for 

N. America. Include (-) 

sign, e.g., -123.234561.

Most based on the most accurate longitude data available 

from NEI (based on horizontal accuracy measure). Data 

for some units not available from the NEI. Obtained 

data for these units from EPA’s Envirofacts or from 

RTI’s GIS group.
4

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., 

+78.123456.

Most based on the most accurate latitude data available 

from NEI (based on horizontal accuracy measure). Data 

for some units not available from the NEI. Obtained 

data for these units from EPA’s Envirofacts or from 

RTI’s GIS group.

UTM Zone Zone number in UTM 

coordinate system.

Determined using an online program that converts 

latitude and longitude measures to UTM zone numbers.

Plan Status (1997 HMIWI 

Rule)

Status of State/Federal 

Plans implementing the 

1997 HMIWI rule.

Taken from EPA’s State/Federal plan status website for 

1997 HMIWI rule.

Compliance Date (1997 

HMIWI Rule)

Date of compliance with 

the State/Federal plans 

implementing the 1997 

HMIWI rule.

Based on compliance dates in permits and inventories.

Facility Contact Name The name of the facility 

contact.

Based on facility contact name from permits, test reports, 

inventories, facility websites, and facility contacts.

Facility Contact Phone The phone number of the 

facility contact.

Based on facility contact phone numbers from permits, 

test reports, inventories, facility websites, and facility 

contacts.

SIC Primary Standard Industrial 

Classification code.

Taken from NEI and SIC code table.

NAICS Primary North American Industry 

Classification System 

code.

Taken from NEI and NAICS code table.

Site Description Comments/description for 

this facility.

Based on SIC/NAICS code assigned to the facility.

Size Category The size category of the 

incinerator (i.e., large (L), 

medium (M), small (S), or 

small rural (SR)).

Based on size information from permits, test reports, and 

inventories.

New Existing Whether the incinerator is 

new (N) or existing (E).

Based on incinerator description from permits, test 

reports, and inventories.

Mode The mode of operation of 

the incinerator (i.e., 

continuous (C), intermittent (I), or batch (B)).

Based on operating information from permits, test 

reports, and inventories.

Waste Heat Recovery 

Boiler

Whether the facility has a 

waste heat recovery boiler 

to recover as steam the 

energy from the HMIWI

Based on facility description from permits and test 

reports.
5

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 facility.

Based on information from Dun & Bradstreet Million 

Dollar Directory, NEI, and EPA’s Envirofacts website.

Parent Company The name of the parent 

company of the facility.

Based on information from permits, test reports, 

inventories, and facility websites.

Parent Company 

Employment

Number of employees in 

the parent company.

Based on information from Dun & Bradstreet Million 

Dollar Directory, Hoovers, Inc., and facility websites.

Parent Company Sales Sales for the parent 

company ($million).

Based on information from Dun & Bradstreet Million 

Dollar Directory, Hoovers, Inc., and facility websites.

Year of Sales/Emp. Data The year for which sales 

and employment data 

were obtained for the 

parent company

Based on information from Dun & Bradstreet Million 

Dollar Directory and Hoovers, Inc.

Size Standards SBA size standards for the 

parent company (i.e., sales 

in $million, or number of 

employees).

Based on SBA Table of Small Business Size Standards 

Matched to NAICS Codes.

Small Business Small business status 

based on SBA size 

standards (Yes/No/ 

Borderline).

Determined based on comparison of SBA size standards 

to employment and sales information for parent 

companies.

Facility Registry Identifier The ID number assigned 

by the EPA Facility 

Registry System.

Taken from NEI, permits, test reports, State 

correspondence, and EPA’s Envirofacts website.

Other Facility Registry 

Identifiers

Other ID numbers 

assigned by the EPA 

Facility Registry System.

Taken from NEI, permits, test reports, State 

correspondence, and EPA’s Envirofacts website.

Emission Unit ID Unique ID reported 

consistently over time by 

State/local/tribal agency.

In most cases, based emission unit IDs on permits, test 

reports, inventories, State correspondence, and NEI. 

Otherwise, assigned an emission unit ID of “1.”

Emission Unit Description A text description of the

Emission Unit.

Described emission units as “hospital/medical/infectious 

waste incinerators.” Also included information about the 

model of incinerator, if available.

Emission Process ID Unique ID reported 

consistently over time by

State/local/tribal agency.

In some cases, based emission process IDs on permits, 

test reports, inventories, State correspondence, and NEI. 

Otherwise, assigned the same ID as the emission unit ID.

Emission Process

Description

A text description of the 

Emission Process.

Described emission processes as 

“hospital/medical/infectious waste incineration.”

Emission Release Pt ID State/local/tribal ID for 

point/location where 

emissions are released to 

In some cases, based emission release point IDs on 

permits, test reports, inventories, State correspondence, 

and NEI. Otherwise, assigned the same ID as the 
6

Field name Description Information sources

ambient air. emission unit ID.

Emission Release Pt

Description

A text description of the 

Emission Release Point.

All but two facilities have one stack serving each 

incinerator. The remaining two facilities have one stack 

serving two incinerators (although one of the facilities is 

not currently using the second incinerator). Provided 

text descriptions based on these configurations.

SCC EPA Source Category 

Code for Point Sources.

Taken from NIF SCC code table. Assigned SCC code of 

“50200501” to those commercial/institutional HMIWI 

operating on a continuous or intermittent basis (most 

units). Assigned SCC code of “50200502” to the 

commercial/institutional HMIWI operating on a batch 

basis (one unit). Assigned SCC code of “50200503” to 

those commercial/institutional HMIWI which use a 

rotary kiln incinerator (three units). Assigned SCC code 

of “50100505” to locally-operated HMIWI (two units at 

one facility).

Control System

Description

Description of control 

equipment chain.

Most control devices based on information from permits 

and test reports, but one based on information from 

website.

Control System Abbr Abbreviation of control 

equipment used (FF= 

fabric filter, DIFF=dry 

injection fabric filter, 

WS=wet scrubber, CC= 

combustion control, ESP= 

electrostatic precipitator, 

WESP=wet ESP, CA= 

carbon adsorber).

Based on control system description.

Waste Types Types of waste 

incinerated at the facility.

Based on waste type information from test reports.

Design Capacity (lb/hr) Numeric value of average 

operational capacity (in 

lb/hr) for an emission unit

Based on design capacity information from permits, test 

reports, and inventories.

Design Capacity Notes Notes regarding 

calculation of design 

capacity.

Documented inputs used to calculate design capacity.

Design Capacity Batch 

(lb/batch)

Numeric value of average 

operational capacity (in 

lb/batch) for a batch 

emission unit.

Based on batch design capacity information from test 

reports.

Max Charge Rate (lb/hr) Numeric value of 

maximum charge rate (in 

lb/hr) for an emission unit 

if different from design 

capacity.

Based on maximum charge rate information from 

permits, test reports, inventories, and facility contacts. 

Several facilities chose to have their permits revised to 

reduce their allowable HMIWI charge rates below design 

capacity in order to qualify for a smaller HMIWI size 

category with less stringent emission limits.
7

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.

Annual Throughput for 

2002 (tpy)

Numeric value of 2002 

annual throughput (in tpy)

Most based on 2002 annual throughput values from 

facilities, EPA Regions, and States. Data not available 

for several units, so annual throughput values were 

calculated using hourly throughputs from stack test and 

annual operating hours from facilities.

Annual Throughput for 

2002 Notes

Notes regarding 

calculation of 2002 annual 

throughput.

Documented inputs used to calculate annual throughput.

Est. Annual Throughput Numeric value of 

estimated annual 

throughput (in tpy)

Calculated based on maximum charge rate and annual 

operating hours, assuming the unit operates at 2/3 

capacity.

Est. Annual Throughput 

Notes

Notes regarding 

calculation of estimated 

annual throughput (in tpy)

Documented method used to calculate estimated annual 

throughput

Winter Throughput PCT The percentage a process 

operates during the winter 

months. Whole number 

between 0 and 100.

Taken from NEI and EPA’s Envirofacts website. 

Otherwise assumed “25 percent” for each season.

Spring Throughput PCT The percentage a process 

operates during the spring 

months. Whole number 

between 0 and 100.

Taken from NEI and EPA’s Envirofacts website. 

Otherwise assumed “25 percent” for each season.

Summer Throughput PCT The percentage a process 

operates during the 

summer months. Whole 

number between 0 and 

100.

Taken from NEI and EPA’s Envirofacts website. 

Otherwise assumed “25 percent” for each season.

Fall Throughput PCT The percentage a process 

operates during the fall 

months. Whole number 

between 0 and 100.

Taken from NEI and EPA’s Envirofacts website. 

Otherwise assumed “25 percent” for each season.

Annual Avg Hours Per

Day

Average number of hours 

per day an emission 

process is active within 

year.

Most based on data from facilities, EPA Regions, and 

States, with a few based on data from NEI and one based 

on data from a permit.

Annual Avg Hours Per

Day Notes

Notes regarding 

calculation of annual 

average hours per day.

Documented inputs used to calculate annual average 

hours per day.
8

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 calculate annual average 

days per week.

Annual Avg Weeks Per

Year

Average number of weeks 

per year an emission 

process is active.

Most based on data from facilities, EPA Regions, and 

States, with four based on data from NEI and two based 

on data from a permit.

Annual Avg Weeks Per

Year Notes

Notes regarding 

calculation of annual 

average weeks per year.

Documented inputs used to calculate annual average 

weeks per year.

Annual Avg Hours Per

Year

Average number of hours 

per year an emission 

process is active.

Most based on data from facilities, EPA Regions, and 

States, with four based on data from NEI and two based 

on data from a permit.

Annual Avg Hours Per

Year Notes

Notes regarding 

calculation of annual 

average hours per year.

Documented inputs used to calculate annual average 

hours per year

Stack Height (ft) The height (in feet) of a 

stack.

Most based on stack height data from test reports. 

Several based on stack height data from permits, EPA’s 

Envirofacts website, and NEI.

Stack Diameter (ft) The diameter (in feet) of a 

circular stack.

Based on stack diameter data from test reports. Stack 

diameter values also could be calculated based on data 

for stack area, or data for exit gas flow rate and exit gas 

velocity.

Stack Dimensions (ft x ft) The dimensions (in feet x 

feet) of a non-circular

stack.

One unit has rectangular, not circular, stack. Therefore, 

stack diameter is not relevant for this units. Provided 

stack dimensions in units of feet x feet.

Stack Area (ft2) The area (in square feet)

of a stack.

Based on stack area data from test reports. Stack area 

values also could be calculated based on data for stack 

diameter, or data for exit gas flow rate and exit gas 

velocity.

Exit Gas Temperature

(deg F)

The temperature of an exit 

gas stream (degrees

Fahrenheit).

Based on average stack temperatures from test reports.

Exit Gas Velocity (ft/s) The velocity of an exit gas 

stream (feet per second).

Based on average exit gas velocities from test reports. 

Exit gas velocities also could be calculated based on data 

for exit gas flow rate and stack diameter.

Exit Gas Flow Rate

(acfm)

Numeric value of stack 

gas flow rate in actual 

cubic feet per minute.

Based on average actual gas flow rates from test reports.

Exit Gas Flow Rate Std Numeric value of stack 

gas flow rate in dry

Based on average standard gas flow rates from test 
9

Field name Description Information sources

(dscfm) standard cubic feet per 

minute.

reports.

HCl Unit Average 

Concentration (ppmvd)

Numeric value of average 

HCl concentration (in 

ppmvd) for an emission 

unit

Based on average HCl concentration data from test 

reports.

CO Unit Average 

Concentration (ppmvd)

Numeric value of average 

CO concentration (in 

ppmvd) for an emission 

unit

Based on average CO concentration data from test 

reports.

Pb Unit Average 

Concentration (mg/dscm)

Numeric value of average 

Pb concentration (in 

mg/dscm) for an emission 

unit

Based on average Pb concentration data from test 

reports.

Cd Unit Average 

Concentration (mg/dscm)

Numeric value of average 

Cd concentration (in 

mg/dscm) for an emission 

unit

Based on average Cd concentration data from test 

reports.

Hg Unit Average 

Concentration (mg/dscm)

Numeric value of average 

Hg concentration (in 

mg/dscm) for an emission 

unit

Based on average Hg concentration data from test 

reports.

PM Unit Average 

Concentration (gr/dscf)

Numeric value of average 

PM concentration (in 

gr/dscf) for an emission 

unit

Based on average PM concentration data from test 

reports.

Total CDD/CDF Unit 

Average Concentration

(ng/dscm)

Numeric value of average 

CDD/CDF concentration 

(in ng/dscm) for an 

emission unit

Based on average CDD/CDF concentration data from 

test reports.

CDD/CDF TEQ Unit 

Average Concentration

(ng/dscm)

Numeric value of average 

TEQ concentration (in 

ng/dscm) for an emission 

unit

Based on average TEQ concentration data from test 

reports.

NOX Unit Average 

Concentration (ppmvd)

Numeric value of average 

NOX concentration (in 

ppmvd) for an emission 

unit

Based on average NOX concentration data from test 

reports.

SO2 Unit Average 

Concentration (ppmvd)

Numeric value of average 

SO2 concentration (in 

ppmvd) for an emission 

unit

Based on average SO2 concentration data from test 

reports.

HCl Annual Emissions 

(lb/yr)

Numeric value of annual 

HCl emissions (in lb/yr) 

for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.
10

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 Emissions 

(lb/yr)

Numeric value of annual 

Pb emissions (in lb/yr) for 

an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

Cd Annual Emissions

(lb/yr)

Numeric value of annual 

Cd emissions (in lb/yr) for 

an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

Hg Annual Emissions

(lb/yr)

Numeric value of annual 

Hg emissions (in lb/yr) for 

an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

PM Annual Emissions

(lb/yr)

Numeric value of annual 

PM emissions (in lb/yr) 

for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

Total CDD/CDF Annual 

Emissions (g/yr)

Numeric value of annual 

CDD/CDF emissions (in 

g/yr) for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

CDD/CDF TEQ Annual 

Emissions (g/yr)

Numeric value of annual 

TEQ emissions (in g/yr) 

for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

NOX Annual Emissions

(lb/yr)

Numeric value of annual 

NOX emissions (in lb/yr) 

for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.

SO2 Annual Emissions

(lb/yr)

Numeric value of annual 

SO2 emissions (in lb/yr) 

for an emission unit

Based on emissions and parameter data from test reports 

and annual operating hours.
Appendix A

HMIWI Source and Emissions Inventory
Appendix B

Acronyms and Abbreviations Used in HMIWI Source and Emissions Inventory