### Date: April 6, 2012

Subject: Inventory

of Hospital/Medical/Infectious Waste Incinerator s Potentiall y Covered b y 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. Envir onmental 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 HM IW I. The nine pollutants are h ydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury

(Hg), particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NO X 

### ), and sulfur dioxide (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 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 HMIWIregulations. 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 specify the State Plan content and the general rules fo r adopting and submitting these State Plans. State Plans were developed previousl y to implement the EG adopted on September 15, 1997 . R evised or new State Plans to implement the amended EG adopted on October 6, 2009 were due to EPA for review and approva l 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 y ears after promulgation of the EG. A Federal Plan to implement the September 15, 1 997 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, 20 09 amendments to the EG.

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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 HMIWInot covered under a State Plan. The purpose of this memorandum is to present an updated source and emissions inventory of the HMIWIindustry

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 data base is presented in Appendix A. The acron yms 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 currentl y operating in the U.S. 1 

### Based on recentl y obtained inventory information, EPA has determined that three of those HMIWIhave shut down and now estimates there are 54 HM IW I currentl y operating. 2

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

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

. Updated Hospital/Medical/I

nfectious W

aste Incinerator (HMIWI) Inventory Database. 2. Letter from James Bukowski, Johns Hopkins Institutions, to EPA Region III. January 28, 2010. 3. Zentner, Sonn y. May 5, 2008. Analysis, Preliminary Determination and Draft Permit for the Renewal of O peration 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 , 200 9

. 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 Inform**  **ation sources** No Unique number assigned by RTI to e ach 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 EP A 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 T he name of the facility. Based on latest facility name from permits, test reports, inventories, EPA’s Envirofacts w ebsite, and facility websites. Unit Num

ber The unit number of the

incinerator, if the facility has more than one incinerator. Based on unit num bers 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 offic e 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 som e units not available from the NEI. Obtained data for th ese units from EPA’s Envirofacts or from RTI’s GIS group.

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**Field name Description**  **Inform ation 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 som e 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 UTM coordinate system. Determine d 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 im plementing the 1997 HMIWI rule

. Taken from EPA’s State/Federal plan status website for 1997 HMIWI ru le

. Com pliance Date (1997 HMIWI Rule) Date of compliance with the State/Federal plans im plementing the 1997 HMIWI rule

. Based on compliance dates in permits and inventories.

Facility Contact Name The name of the facility contact. Based on facility contac t 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 Prim ary Standard Industrial Classification code. Taken from NEI and SIC code table.
NAICS Prim ary North American Industry Classification System code. Taken from NEI and NAICS code table.

Site Description Comments/description f or 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 sm all rural (SR))

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

N ew 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 o perating information from permits, test reports, and inventories.

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

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**Field name Description**  **Inform ation 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 & Br adstreet Million Dollar Directory, NEI , and EPA’s Envirofacts website. Parent Company The name of the parent com pany of the facility. Based on information from permits, t est reports, inventories, and facility websites

. Parent Company Em ployment Number of employ ees 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 com pany ($million). Based on information from Dun & Bradstreet Million D ollar 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 St andards SBA size standards for the parent company (i.e., sales in $million, or number of em ploy ees). Based on SBA Table of Small Business Size Standards Matched to NAICS Codes.

Sm all Business Sm all business status based on SBA size standards (Yes/No/ Bord erline)

. Determined based on comparison of SBA size standards to em ployment and sales information for parent com panies. Facility Registry Identifier The ID number assigned by the EPA Facility Registry System. Taken from NEI, permits, test reports, State c orrespondence, and EPA’s Envirofacts website. Other Facility Registry Identifiers Other ID num bers 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 U nit. Described emission units as “hospital/medical/infectious wa ste 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 P t ID State/local/tribal ID for point/location where emissions are released to In some cases, based emission release point ID s on permits, test reports, inventories, State correspondence, and NEI. Otherwise, assigned the same ID as the

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**Field name Description**  **Inform ation sources** 
am bient air. emission unit ID. Emission Release Pt Description A text description of the Emission Release Point. All but two facilities have one stack servi ng 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 C ode 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 HM IWI 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). 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 and test reports, but one ba sed on information from website

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

Waste Types Ty pes of waste incinerated at the facility. Based on wa ste 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 re garding 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 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 e mission unit if different from design capacity. Based on maximum charge rate informati on from permits, test reports, inventories , and facility contacts

. S everal 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.

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**Field name Description**  **Inform ation sources**  Max Charge Rate Notes Notes regarding calcu lation 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.
Ann ual Throughput fo r 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 us ed to calculate estimated annual throughput
Winter Throughput PCT The percentage a process operates during the winter months. Whole number betw een 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 betw een 0 and 100. Taken from NEI and EPA’s Envirofacts website. Otherwise assumed “25 percent” for each season.

Summer Throughput PCT The percentage a proces s operates during the summer months. Whole number betw een 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 numbe r betw een 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 fe w 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.

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**Field name Description**  **Inform ation sources**  Ann ual Avg Days Per Week Average number of days per w eek 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 No tes Notes regarding calculation of annual average days per w eek

. Documented inputs used to calculate annual average days per w eek.
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 Note s Notes regarding calculation of annual average hours per y ear. 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. Ba sed on stack diam eter data from test reports. Stack diam eter 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 sta ck 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 diam eter, or data for exit gas flow rate and exit gas velocity. Exit Gas Tem

perature (deg F) The temperature of an exit gas stream (degree s Fahrenheit). 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 test

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**Field name Description**  **Inform ation sources**  (dscfm) standard cubic feet per minute. reports.
HCl U nit Average Concentration (ppmvd) Numeri c 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 averag e 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/dsc m) 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 Average Concentration (mg/dscm) Numeric value of average Hg concentration (in mg/dscm) for an emission unit Ba sed 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 U nit Avera ge 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.

NO X Unit Average 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 Unit Average 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 emiss ions (in lb/yr) for an emission unit Based on emissions and parameter data from test reports and annual operating hours.

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**Field name Description**  **Inform ation 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 Bas ed 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 operating 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.

### App **endix A**  **HMIWI Source and Emissions Inventory** 

### Appendix **B**

**Acronyms and Abbreviations Used in HMIWI Source and Emissions**  **Inventory**