In 1997, the EPA issued new regulations controlling emissions from Hospital/Medical/Infectious Waste Incinerators (HMIWI). These regulations provide emission guidelines and operating requirements for both new and existing HMIWIs (40 CFR 60 subpart Ce for existing units, and 40 CFR 60 Subpart Ec for units constructed after June 20, 1996).
Other regulations that may apply to HMIWIs include the following:
- Operating permit provisions under Title V of the 1990 Clean Air Act (CAA) Amendments (40 CFR 70)
- New Source Performance Standards (40 CFR 60)
- Hazardous Air Pollutants program (40 CFR 63)
Operating permit provisions under Title V of the 1990 Clean Air Act (CAA) Amendments (40 CFR 70): 40 CFR 70 contains requirements for new operating permit provisions under Title V of the 1990 CAA Amendments. A Title V operating permit is required for new and existing facilities that:
- Are considered a "major stationary source"
- Emit or have a PTE (potential to emit) of 10 or more tons per year of any hazardous air pollutant (HAP) as defined under Section 112 of the CAA, or 25 tons per year of any combination of HAPs
- Emit or have a PTE of 100 tons per year of any air pollutant
- Is subject to a New Source Performance Standard or a National Emission Standard for Hazardous Air Pollutant (NESHAP)
- Is subject to the Acid Rain Provisions
- Is a facility that is required to have a preconstruction review permit according to the New Source Review Program
HMIWIs are specifically addressed under the New Source Performance Standards program and are required to apply for and obtain a Title V operating permit.
New Source Performance Standards (NSPS): The New Source Performance Standards (NSPS) contained in 40 CFR 60 address a variety of different types of new or modified stationary air emission sources. The emission guidelines for HMIWIs required by 40 CFR 60 Subpart Ce are described below.
Emission Limits - Under these regulations, HMIWIs must meet strict emission guidelines, based on their output:
- Small - less than or equal to 200 lbs/hr
- Medium - greater than 200 lbs/hr, to a maximum of 500 lbs/hr
- Large - greater than 500 lbs/hr
There are also optional, less restrictive emission guidelines for small HMIWIs located in rural areas that burn less than 2000 lbs per week.
The regulations list specific emission limits for certain pollutants within each category. These pollutants include:
- Particulate Matter
- Carbon Monoxide
- Dioxins/furans
- Hydrogen Chloride
- Sulfur Dioxide
- Nitrogen Oxides
- Lead
- Cadmium
- Mercury
Operator Training - The emission guidelines also outline specific training and qualification guidelines that HMIWI operators must meet, including passing a state-approved course or a course described in the guidelines. The course must encompass 24 hours of training on environmental concerns, combustion principles, incinerator operations, air-pollution control, air monitoring, inspection and maintenance, safe work procedure, ash-handling procedures, recordkeeping, and identifying and correcting malfunctions.
Waste Management Plan - Facilities operating HMIWIs must develop and implement a Waste Management Plan that outlines how the facility will implement waste minimization, waste separation, recycling and other waste management strategies.
Testing, Monitoring and Inspections - To ensure compliance with the emission guidelines, HMIWIs are required to undergo initial stack testing with regard to the parameters for emission limits and opacity. Annual testing is required for at least three years for particulate matter, carbon monoxide and hydrogen chloride. Small rural incinerators have somewhat less rigorous testing requirements.
Recordkeeping - HMIWIs also must monitor and record certain operating parameters identified in the operating permit, such as charge rate, secondary chamber temperature and others. Other records that must be kept include initial performance tests, training records, inspection records, maintenance records, waste management records and at least five years of continuous monitoring data.
New HMIWIs Constructed after 9/97 - The emission guidelines for new HMIWIs include stricter emission limits. They also require a siting study and analysis prior to construction and operation.
For the complete text of the regulations described above (40 CFR 60 Subparts Ce and Ec,), click here:
40 CFR 60