& EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-94-063a
July 1994
Air
Medical Waste Incinerators -
Background Information for
Proposed Standards and Guidelines:
Regulatory Impact Analysis
for New and Existing Facilities
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EPA-453/R-94-063a
Medical Waste Incinerators -
Background Information for Proposed Standards and Guidelines:
Regulatory Impact Analysis for New and Existing Facilities
July 1994
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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DISCLAIMER
This report is issued by the Emission Standards Division, Office
of Air Quality Planning and Standards, U. S. Environmental
Protection Agency. It presents technical data of interest to a
limited number of readers. Mention of trade names and commercial
products is not intended to constitute endorsement or
recommendation for use. Copies of this report are available free
of charge to Federal employees, current contractors and grantees,
and nonprofit organizations--as supplies permit--from the Library-
Services Office (MD-35), U. S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711 ([919] 541-2777} or,
for a nominal fee, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161
([703] 487-4650).
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EXECUTIVE SUMMARY
This report has been prepared .to comply with Executive Order
712866, which requires federal agencies,to assess costs and
benefits of each significant rule they propose or promulgate.
The proposed regulation of medical waste incinerators meets the
Order's definition of an economically significant rule. The
Agency has attempted to assess both the costs and benefits of the
proposed rule, as presented in this Regulatory Impact Analysis
(RIA) .
An estimated 3.4 million tons of medical waste are produced
annually by medical waste generators. These generators include
facilities such as hospitals, veterinary clinics, nursing homes,
dentists' offices, etc. Waste categorized as medical waste
include items such as needles and other sharp medical objects,
fabrics and garments, plastics, paper, waste chemicals, and
pathological waste. Generators of the above items either burn
the items in an on-site incinerator or ship the waste to either
other facilities that operate an incinerator or to a commercial
medical waste incinerator (MWI). Air emissions resulting from
the operation of MWIs include furans and dioxins (ODD/CDF),
hazardous air pollutants (HAPs) such as lead, cadmium, mercury
and hydrochloric aced and criteria pollutants such as sulfur_
dioxide, nitrogen oxide, particulate matter, and carbon dioxide.
This document examines the impact of imposing both the Emission
Guidelines (EG), aimed at controlling emissions from existing
MWIs, and the New Source Performance Standards (NSPS), aimed at
controlling emissions from new MWIs. The EG is expected to
affect an estimated 3,700 existing MWIs. [note: Although
approximately 5,000 MWIs are believed to exist nationwide, 1,300
of these MWIs exclusively burn pathological waste. These
pathological MWIs are excluded from this regulation. However,
some of the analyses presented in this document were completed
before the decision was made to exclude the pathological MWIs.
The exclusion of these pathological incinerators is not expected
to significantly affect the impact estimates because_the amount
of pathological medical waste generated as a proportion of total
medical waste is relatively small.]
The annualized control costs for controlling the existing MWIs is
estimated to be approximately $1.4 billion (1989 $). Using this
cost, the economic impact analysis estimates that the overall
impact on the prices of services generating medical waste (i.e.,
hospital services, nursing home care, etc.) is relatively small
(less than two percent price increase for any final product).
The lack of significant price impacts, despite the magnitude of
the annualized cost, may be due to one of two reasons. One
explanation for the low impacts may be that the costs are spread
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over a substantial amount of revenue . In general, medical waste
incineration is only a small cost of a typical facility's total
operating budget. A second reason for the small impacts may be
the possibility of substitution to lower cost alternatives as
opposed to onsite incineration (i.e., onsite autoclaving or
contract disposal). The combination of these two factors leads
to the conclusion that significant economic impacts should not
result from implementation of the proposed rules.
The annualized control costs for controlling new MWIs is
approximately $277 million (1989 $). The economic impact
analysis for new sources estimates that this cost increase will
result in relatively impacts on the prices of services generating
medical waste (less than 2% for any final product). Reasons for
the lack of significant price impacts for new sources are similar
to those for existing sources, as explained above.
The benefits of implementing the proposed regulations is expected
to result from reducing CDD/CDF, HAP, and criteria pollutant
emissions. The EG is expected to reduce annual HAP emissions by
approximately 40,000 Mg and annual CDD/CDF emissions by
approximately 285 Kg. The NSPS is expected to reduce annual HAP
emissions by approximately 10,000 Mg and annual CDD/CDF emissions
by approximately 22 Kg. Due to lack of data, the benefits of
reducing HAP emissions is only discussed in a qualitative manner.
These benefits are discussed in terms of reducing adverse human
health effects. In addition, the EG is expected to reduce annual
criteria pollutant emissions by approximately 24,000 Mg. The
NSPS is expected to reduce annual criteria pollutant emissions by
approximately 3,000 Mg. The benefits of reducing criteria
pollutant emissions are discussed in terms of reducing adverse
human health effects as well as adverse welfare effects. Where
possible, the benefits analysis has attempted to quantify the
benefits of reducing these emissions. For the EG, the analysis
estimates that quantified particulate matter benefits are
approximately $37.5 million/yr. (1989 $) In addition, the
analysis estimates that quantified particulate matter benefits
associated with the NSPS are approximately $5.4 million/yr. (1989
$)
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1.0 INTRODUCTION
1.1 Purpose %>
This report has been prepared to comply with Executive Order
12866, which requires federal agencies to assess costs and
benefits of each significant rule they propose or promulgate.
The proposed regulation of medical waste incinerators meets the
Order's definition of a significant rule. The Agency has
assessed both the costs and benefits of the proposed rule, as
presented in this Regulatory Impact Analysis (RIA).
1.2 Organization of the Report
The principal requirements of the Executive Order are that the
Agency perform an analysis comparing the benefits of the
regulation to the costs that the regulation imposes, that the
Agency analyze alternative approaches in the development of the
rule, and that the need for the regulation be identified.
Wherever possible, the costs and benefits of the rule are to be
expressed in monetary terms. To address the analytical
requirements of the Executive Order, this RIA is organized as
follows:
Chapter 2 presents an overview of the legislative, regulatory,
and policy background for the proposed regulations. This chapter
also provides an overview of the medical waste incineration
industry.
Chapter 3 briefly explains market failures that environmental
pollution control regulations are intended to correct. In
addition, this section discusses the environmental factors
necessitating the development of the proposed regulation.
Finally, the Agency's legal mandate for developing the regulation
is summarized.
Chapter 4 describes the regulatory requirements associated with
the Emission Guidelines as well as the requirements of the New
Source Performance Standards.
Chapter 5 presents a summary of the estimated annual costs of
compliance associated with the proposed regulations.
Chapter 6 describes the types of industries that generate medical
waste and therefore, will be affected by the proposed rules.
Chapter 7 presents a summary of the economic impacts associated
vwith the proposed rules.
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Chapter 8 discusses the health and environmental benefits
expected to result from implementation of the proposed
regulation. Relevant benefit categories are presented in a
qualitative discussion, and where possible, an attempt is made to
quantify these benefits.
Chapter 9 provides a partial comparison of the costs and benefits
of the proposed rules. A direct comparison of costs and benefits
is not possible since it was not possible to quantify most of the
benefit categories.
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2.0 BACKGROUND
2.1 Regulatory Background
Medical waste incinerators are subject to State and local
regulations that vary widely both in format and in scope. A
survey in April 1990 showed that in 38 states, regulations or
permit guidelines specific to MWIs were either in place or were
in the planning stages. The remainder of the States regulate
MWIs under general incinerator requirements, which typically are
less stringent than those specific to MWIs. The most common
State requirements for MWIs are limits for particulate matter
(PM) hydrogen chloride (HC1), and secondary chamber temperature
and residence time. Some States also regulate metals, dioxins
and furans (CDD/CDF), and carbon monoxide (CO). About half the
States with requirements specific to MWIs require operator
training or certification.
On November 1, 1988, the Medical Waste Tracking Act (MWTA) was
signed. The MWTA required the EPA to establish a 2-year _
demonstration program to track medical waste from its origin to_
its disposal. In early 1989, the EPA established this program in
40 CFR Part 259. The program was in effect from June 22, 1989,
to June 22, 1991 and applied to the states of New York, New
Jersey, Connecticut, and Rhode Island and to Puerto Rico. The
MWTA required the EPA to prepare a series of Reports to Congress
on medical waste and the demonstration program. Now that the
demonstration program has concluded, Congress will decide if_a
.medical waste tracking program should be implemented nationwide.
Section 129 of the CAA specifically addresses development of
standards for MWIs. Section 129 requires the EPA to establish an
NSPS for new MWIs and EG for existing MWIs that combust hospital
waste, medical waste, and infectious waste. The standards and
guidelines must specify numerical emissions limitations for the
following: PM, opacity, sulfur dioxide (S02) , HC1, nitrogen
oxides (NOX) , CO, lead (Pb) , cadmium (Cd) , mercury (Hg) , and
CDD/CDFs. Section 129 also includes requirements for operator
training and certification as well as siting requirements for new
MWIs. Section 129 directs that standards and guidelines are to
be promulgated no later than November 15, 1992.
The current air emissions standards development effort for MWIs
was initiated in 1989. The data gathering effort was designed to
take advantage of information gathered under the auspices of the
MWTA. Also, in 1989, an MWI operator training course and manual
were developed with recommendations on the proper operation of
MWIs.
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2.2 Medical Waste Industry Characteristics
The Solid Waste Disposal Act defines medical waste as "...any
solid waste which is generated in the diagnosis, treatment, or
immunization of human beings or animals, in research pertaining
thereto, or in production or testing of biologicals." In
addition, for the purpose of developing air emission standards
for MWIs, medical waste also includes: waste generated by health
care providers who provide medical services to individuals in
private homes when the waste is removed from the home and
transported to the provider's place of business for disposal; and
veterinary waste that is generated at a home or farm when the
waste is transported to the veterinarian's place of business.
An estimated 3.4 million tons of waste are produced annually by
medical waste generators in the United States. Table 2-1
presents the estimated number of facilities and the quantity of
waste generated annually by generator category. Hospitals are
the single largest generator of medical waste, producing over 70
percent of the annual total.
Approximately 5,000 MWIs are believed to exist. Table 2-2
presents the estimated number of MWIs and percent of the total
population by facility type. Over 60 percent of these MWIs are
found at hospitals. [note: This analysis was completed before a
decision was made to exclude pathological MWIs from the proposed
rules. An estimated 3,700 MWIs burning mixed medical waste are
currently covered under the proposed rules. The exclusion of
approximately 1,300 MWIs exclusively burning pathological waste
is not expected to significantly affect the impact estimates
because the amount of pathological waste burned at these
facilities is a relatively small proportion of the total amount
'of medical waste incinerated annually.]
Medical waste consists of the following types of materials:
1. Sharps (e.g., hypodermic and suture needles, scalpel
blades, syringes, pipettes, vials, other types of
broken or unbroken glassware, etc.);
2. Fabrics (e.g., gauze, garments, swabs, etc.);
3. Plastics (e.g., trash bags, sharps containers, IV bags,
tubes, specimen cups, etc.);
4. Paper (e.g., disposable gowns, sheets, etc.,
premoistened towels, paper towels, etc.);
5. Waste chemicals/drugs (e.g., lab chemicals, left-over
and out-of-date drugs, disinfectants,etc.);
6. Pathological waste (e.g., human and animal body parts
and tissue).
Most of these materials burn readily and, given the proper
conditions, will continue to burn once they are ignited. Metal
and glass sharps do not burn but also do not greatly impede
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Table 2-1. Estimated Number of U.S. Facilities and Quantity of
Waste Generated Annually by Generator Category
Generator Category
Hospitals
Physicians' Offices
Long-Term Care Facilities
(nursing homes)
Clinics (outpatient care)
Laboratories
(medical/research)
Dentists' Offices
Free-Standing Blood Banks
Veterinarians
Corrections
Fire and Rescue
Health Units in Industry
Funeral Homes
Police
No. of
Facilities
7,000
180,000
42,000
41,300
7,200
98,000
900
38,000
4,300
7,200
221,700
21,000
13,100
682,400
Annual Total
Waste Generated
(tons)
2,400,000
235,000
207,000
175,000
173,000
58,000
33,000
31,000
22,000
11,000
9,000
6,000
<1,000
3,361,000
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Table 2-2, Estimated U.S. MWI Population
Facility Type
Hospitals
Veterinary Facilities
Nursing Homes
Laboratories
Commercial Facilities
Other/Unidentified
Facilities
TOTAL
Population
Units
3,150
550
500
500
150
150
5,000
Percent of Total
63
11
10
10
3
3
100
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combustion of other materials,. Pathological waste has a very
high moisture content and will not support self-sustained
combustion but will burn if adequate heat is applied to drive off
the moisture.
Most MWIs burn a diverse mixture of medical waste, which my
include a small percentage of pathological waste (one
manufacturer specifies up to 5 percent). Larger amounts of
pathological waste require special operating conditions for
combustion; thus, some facilities maintain MWIs designed and
operated to burn pathological waste exclusively.
Because of differences in waste composition and the combustion
process, uncontrolled emissions from mixed medical waste
incinerators and pathological incinerators are very different.
Mixed medical waste typically contains more metals and chlorine
than does pathological waste, resulting in higher emissions of
metals and HC1 from mixed medical waste incinerators than from
pathological incinerators. Mixed medical waste incinerators also
have higher emission rates of PM, CO, and CDD/CDF than_do
pathological, incinerators. Because of the difference in the
nature of the waste burned, pathological MWIs and mixed medical
waste MWIs are considered two distinct subcategories for the
purpose of regulatory development.
2.3 Types of Medical Incinerator Design
The three different design types of MWIs are continuous units,
intermittent units, and batch units. In each of these systems,
sequential combustion operations typically are carried out in two
separate chambers, primary and secondary. In the primary
chamber, the waste is loaded.and ignited, the. volatile components
driven off, and the nonvolatile materials combusted to ash. The
volatile components, such as organics, that are released from the
primary chamber are combusted in the secondary chamber. New MWIs
are typically designed with 1-sec residence time secondary
chambers; older MWIs were designed with smaller, .25-sec
residence time secondary chambers.
All MWI capacities shown in this section are based on the
assumption that the heating values of mixed medical waste and
pathological waste are 8,500 British thermal units per pound -
(Btu/lb) and 1,000 Btu/lb, respectively.
While there are similarities in the three design types of MWIs,
as mentioned above, there are also key differences that make each
type unique. The primary difference between the three design
types of MWIs is the operating cycle. This difference causes a
variation in the way the waste is burned and in the pollutant
emission profile for each MWI design type. The method of
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charging the waste into the primary chamber and of removing ash
from the primary chamber dictates the MWI operating cycle.
Continuous units, which are the largest of the three types, have
mechanical ram feeders and continuous ash removal systems. These
features allow the unit to operate 24 hours per day for many days
at a time. Continuous MWIs achieve steady-state operation in the
beginning of their operating cycle and maintain this mode of
operation throughout the remainder of the cycle. Waste is_
charged and ah is removed simultaneously. During this period,
waste is burned at the same rate as it is charged into the unit
and pollutant emission rates and primary and secondary chamber
temperatures tend to be relatively constant.
Most intermittent MWIs also have mechanical ram feeders that
charge waste into the primary chamber at about 5 to 10 minute
intervals. However, there is no means for ash removal during the
burning cycle, the unit can only be operated for a limited number
of hours before the accumulation of ash in the primary chamber
becomes a problem. intermittent units, which are usually much
smaller than continuous units, typically operate on a daily burn
cycle. While these units tend to approach steady-state operation
during the middle of their operating cycle, waste is normally
being charged faster than it is being burned. Primary chamber
temperatures tend to climb throughout the operating cycle_until
waste is no longer charged into the unit. Because there is a
significant amount of unburned material in the primary chamber at
the end of the charging period, these units are designed with a
burndown/cooldown phase. Generally, pollutant emissions continue
throughout this phase, which can proceed for several hours beyond
charging.
The batch operating cycle consists of three phases- burn (low-
air) , burndown (high-air) , and cooldown. All of the waste to be
burned during a complete cycle is loaded into the primary chamber
before the unit begins operation. Once the unit is filled with
waste and the burning cycle begins, the charging door is not
opened again until the cycle is complete and the unit is cool.
This cycle normally takes 1 or 2 days depending on the size of
the unit and the amount of waste charged. During the burn phase,
temperatures in the primary chamber rise slowly because
combustion is occurring only on the surface of the waste pile and
because combustion air is restricted. When the burndown phase
begins, the temperatures climb more rapidly, more volatiles are
exposed to the flame front, and the combustion process quickens.
Batch MWIs tend to approach steady state operation at the end of
the burn phase, when the primary chamber temperature reaches the
design operating range. Pollutant emission rates also tend to
increase in the second half of the burn phase, then level off,
and continue steadily during the burndown and cooldown phases.
pollutant concentrations during burndown in batch MWIs are
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similar to concentrations during charging in continuous and
intermittent units.
Medical waste incinerators are divided into four subcategories
for the purpose of regulatory development. These subcategories
are based on the two waste types discussed in Section 3.2 (mixed
medical waste and pathological waste) and on the three_MWI design
types discussed in this section. Mixed medical waste is burned
in all 3 MWI design types resulting in 3 distinct subcategories:
continuous, intermittent, and batch MWIs. However, pathological
waste is burned almost exclusively in intermittent MWIs resulting
in one additional subcategory: pathological MWIs.
2.4 Model Combustors
Based on historic sales data, an estimated 700 new MWIs will be
installed over the next 5 years. The majority of these units
will burn mixed medical waste. Future MWIs are expected to be
comprised of 55 percent intermittent units, 25 percent batch
units, 20 percent continuous units, and less than 1 percent
pathological units. An estimated 5,000 existing MWIs will
potentially be subject to the EG. Based on information from
incinerator manufacturers, hospitals, and State surveys, the
existing population of MWIs is comprised of approximately 60
percent intermittent units, 2.6 percent pathological units, 7
percent continuous units, and 7 percent batch units.
The population distribution projected for new units differs _
substantially from the estimated distribution of existing units.
The distribution of new units is estimated based on known MWIs of
all ages. The projected increase in the percentage of continuous
MWIs burning mixed medical waste is primarily related to the
increasing number of commercial MWI facilities.
Seven different model combustors were selected to represent new
and existing MWI facilities: two continuous, three intermittent,
one batch, and one pathological unit. These model combustors
were selected to represent each common type of combustor design,
and typical sizes were selected within each combustor design
type Table 2-3 lists the model design capacity, the design
operating parameters, and the applicable industries for each
model combustor.
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3.0 NEED FOR THE REGULATION
The Executive Order requires that the'Agency identify_the need
for the regulation being proposed. The emission of air
pollutants poses a threat to human health and the environment.
Risks from these emissions include increases in cancer risk,
other adverse cancer risk, and degradation of the environment.
This section will discuss: (1) the reasons the marketplace does
not provide for adequate pollution control absent appropriate
incentives or standards; (2) the environmental factors that
indicate the need for additional pollution controls for this
source category; and (3) the legal requirements that dictate the
necessity for and timing of this regulation.
3.1 Market Failures
The need for emission limitations for this source category arises
from the failure of the marketplace to provide the optimal level
of pollution control desired by society. Corrections of such a
market failure may require federal regulation. Examples of
market failures are situations where externalities, natural_
monopolies, or inadequate information may exist. This section
addresses the category of externalities, the category of market
failure most relevant to the general case of environmental
pollution.
The concept of externalities partially explains the discrepancy
between the supply of pollution control provided by owners and
operators of pollution sources and the level of environmental
quality desired by the general population. The case_of
environmental pollution can be classified as a negative
externality because it is an unintended by-product of production
that creates undesirable effects on human health and the
environment.
In making production decisions, owners and operators will only
consider those costs and benefits that accrue to them personally,
i.e., internalized costs and benefits. However, the cost of
environmental pollution is not borne solely by the creators of
the pollution because all individuals in the polluted area must
share the social cost of exposure to the pollution, even if they
had no part in creating the' pollution. Therefore, although
owners and operators may be the creators of pollution, they do
not necessarily bear the costs of the pollution. Government
regulation is an attempt to internalize the costs of pollution.
If the people affected by a particular pollution source could
negotiate with the party responsible for that source, the parties
could negotiate among themselves to reach an economically
\
3-1
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efficient solution. The solution would be efficient because it
would involve trading of pollution and compensation among the
owner or operator and the people affected by the pollution.
Individual negotiation often does not occur in an unregulated
market, however, because of high transactions costs, even if
trade among the affected parties would be beneficial to all
parties involved. For the majority of environmental pollution
cases, the costs of identifying all the affected individuals and
negotiating and agreement among those individuals are
prohibitively high. Another problem preventing negotiations from
taking place is that our current market system does not clearly
define liability for the effects of pollution.
In the case of environmental quality, an additional problem is
the public nature of this "good." Environmental quality is a
public good because it is predominantly nonexcludable and
nonrival. Individuals who willingly pay for reduced pollution
cannot exclude others who have not paid from also enjoying the
benefits of a less polluted environment. Because many
environmental amenities are nonexcludable, individuals utilize
but do not assume ownership of these goods, and therefore, will
not invest adequate resources in their protection. The result is
that in the absence of government intervention, the free market
will not provide public goods, such as clean air, at the optimal
quantity and quality desired by the general public.
3.2 Environmental Factors
In the case of medical waste incineration, the result of the
market's failure to promote air pollution control is that
pollution of the nation's air is not controlled to the optimal
level. This operation of MWIs releases HAPs, dioxins and furans,
and criteria pollutants into the ambient air. Chapter 8
discusses in detail the air quality impacts of the proposed
regulation.
The EG are expected to decrease annual emissions of: air toxics
by approximately 40,000 Mg, dioxins and furans by approximately
285 Kg, and criteria pollutants by approximately 24,000 Mg .
Additionally, the NSPS are expected to decrease annual emissions
of: air toxics by approximately 10,000 Mg, dioxins and furans by
approximately 22 Kg, and criteria pollutants by approximately
3,000 Mg.
3.3 Legal Requirements
These Maximum Available Control Techonology (MACT) emission
standards and guidelines are proposed under the authority of
Section 129 of the Clean Air Act as amended in 1990.
3-2
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4.0 REGULATORY REQUIREMENTS
4.1 INTRODUCTION
In this chapter, the major industries in which medical waste is
generated are identified and characterized. For each industry,
such information as the number of facilities, the amount of waste
generated, and the number and distribution of MWIs, is presented.
Please refer to either the "Analysis of Economic Impacts for New
Sources" or the "Analysis of Economic Impacts for Existing
Sources" for sources of the estimates of the number of
facilities. Derivations of the estimates of the amount of waste
generated and the number of MWIs can be found in the "Industry
Profile Report for New and Existing Facilities."
[note: This analysis was completed before a decision was made to
exclude pathological MWIs from the proposed rules. Therefore,
total MWI population figures as well as the allocation of MWIs to
the appropriate medical waste generator industries the inclusion
of approximately 1,300 pathological incinerators. The exclusion
of the pathological MWIs is not expected to significantly affect
the impact estimates that are presented here because the amount
of pathological waste generated as a proportion of the total
medical waste generated is relatively small.]
4.2 WASTE GENERATED
For the major industries in which medical waste is generated, the
number of facilities and estimated total waste generated are
provided in Table 4-1. "Total" waste includes medical waste and
any other solid waste generated. Therefore, general refuse is
included. Total waste was calculated from the estimated amount
of infectious waste generated, assuming that infectious waste
comprises 15 percent of total waste. This is based on a national
survey indicating that a median of 15 percent of total waste at
hospitals is infectious. This relationship at hospitals is
assumed to apply to all other industries generating medical
waste.
The majority of medical waste is generated by industries involved
in the provision of health care. Table 4-1 shows,that among
medical waste generators, hospitals generate by far the most
total waste. Hospitals account for 2.4 million, or 71 percent,
of the estimated 3,361,000 tons of total waste generated annually
by medical waste generators. This comes to 348.7 tons per
hospital. The next-biggest waste generators are physicians|
offices, nursing homes, outpatient care facilities, and medical
and dental labs. On a per-facility basis, however, freestanding
'blood banks, at 151.4 tons per year, are second to hospitals.
4-1
-------
TABLE 4-1. TOTAL WASTE GENERATED, BY INDUSTRY
Total waste generated
(tons/yr)
Industry
Hospitals
Nursing homes
Veterinary facilities
Laboratories
Research
Other
Medical
Dental
Funeral homes
Physicians' offices
Dentists' offices and
clinics
Outpatient care
Physicians' clinics
Freestanding kidney
dialysis facilities
Otherb
Freestanding blood banks
Fire and rescue
operations
Correctional facilities
Otherd
TOTAL
Number of
facilities
6,882
17,525
21,496
3,826*
6,871
7,970
22,000
191,278
104,213
6,519
839
N/A
218°
29,840
4,288
258,700
>682,465
Industry- Average per
wide facility
2,400,000
198,000
31,000
55,500
117,500
6,000
235,000
58,000
175,000
33,000
11,000
22,000
19,000
3,361,000
348.7
11.3
1.4
<14.5
7.9
0.3
1.2
0.6
<23.8
151.4
0.4
5.1
0.1
•Commercial facilities only. Does not include captive research
labs.
bHome health care agencies, hospices, drug treatment centers,
et al.
C164 members of the American Association of Blood Banks, one
facility that is not a member, and 53 regional Red Cross
centers. ..,.'.
•"Includes health units in industry, residential care facilities,
and police departments.
N/A Not available.
4-2
-------
This results, though, from treating each member of the American
Association of Blood Banks and each regional Red Cross center as
only one facility.
All industries in Table 4-1 are included in the economic impact
.analysis (see Chapter 7) with the exception of the industries
represented by the two "other" groupings. The first, a subset of
outpatient care, includes such outpatient health care providers
as home health care agencies, hospices, and drug treatment
centers. On average, the "other" outpatient care facilities
generate less medical waste than physicians' clinics (i.e.,
ambulatory care centers — both general and surgical) and
freestanding kidney dialysis facilities. Therefore, it is
assumed that their economic impacts are conservatively
represented by the impacts calculated for physicians' clinics and
freestanding kidney dialysis facilities.
The second "other" grouping includes health units in industry,
residential care facilities, and police departments. Health
units in industry and police departments are excluded from the
economic impact analysis because they generate very little waste
(per facility, on average only 0.04 tons/year and 0.08 tons/year,
respectively) and therefore are likely to be minimally impacted
by the NSPS and Emission Guidelines. Although residential care
facilities — which are similar to, but offer less comprehensive
services than, nursing homes — generate on average 0.38 tons per
year of waste, they are excluded from the economic impact
analysis because their impacts are conservatively represented by
nursing homes, which generate more waste.
4.3 EXISTING MWI AND NEW MWI POPULATIONS
4.3.1 Existing MWIs
About 5,000 MWIs are believed to exist in the U.S. They are
operated primarily by hospitals, nursing homes, veterinary
facilities (including animal hospitals), research labs, and
commercial incineration facilities. Using primarily data from
state air programs and state hospital associations, the number of
existing MWIs in each of these industries was estimated by
extrapolating nationwide based on population. As represented by
the "projected nationwide population" in Table 4-2, it is
estimated that there are 3,150 existing MWIs at hospitals, 500 at
nursing homes, 550 at veterinary facilities, 500 at research
labs, and 150 at commercial incineration facilities. In
addition, 136 existing MWIs have been attributed to
other/unidentified industries. This category includes the few
outpatient clinics, blood banks, etc. that operate an MWI but are
not common enough to justify separate industry categories, as
well as MWIs that were identified in the state data but could not
be attributed to any industry.
4-3
-------
TABLE 4-2. DISTRIBUTION OF EXISTING MWIS
Industry
Hospitals
Nursing
homes
Veterinary
^=a r*n "1 -i +-T oa
LO.I— •-!- J. J- L* *L.CD
Research
labs
Model MWI*
Inter.
Cont.
Inter.
Path.
Inter.
Batch
Inter.
Path.
Inter.
Path.
TTlt"PT*
^44lv^i&- •
Inter.
Cont.
Inter.
Path.
Inter.
21,000
24,000
8,400
2,000
2,000
250
8,400
2,000
2,000
2,000
2, 000
21,000
24,000
8,400
2,000
2,000
Adjusted
capacity
per MWI Identified
(tons/yr)b population
1,176
977
470
172
115
27
470
172
115
172
115
1,176
977
470
172
115
50
57
219
158
513
115
2
14
37
86
10
6
4
21
50
46
Projected
nationwide
population
142
161
620
448
1,453
326
3,150
19
132
349
500
493
57
550
23
16
83
197
181
500
Commercial
incineration
facilities
Cont. 36,000
3,907
39
150
Other/
unidentified
TOTAL
Cont.
Inter.
Cont.
Inter.
Path.
Inter.
Batch
36,000
21,000
24,000
8,400
2,000
2,000
250
3,907
1,176
977
470
172
115
27
4
5
5
20
36
57
9
136
4,986
•Inter. = Intermittent, Cont. = Continuous, Path. =
Pathological.
•"Intermittent and Continuous MWIs: Ib/hr design capacity x
67% x charging hrs/day x operating days/yr x 1/2,000
tons/lb. Pathological MWI: Ib/hr design capacity x 100% x
charging hrs/day x operating days/yr x 1/2,000 tons/lb.
Batch MWI: Ib/batch design capacity x 67% x batches/yr x
1/2,000 tons/lb.
4-4
-------
In addition to the 4,986 existing MWIs represented in Table 4-2,
there are also some municipal waste combustors (MWCs) that co-
fire medical waste. Thirty-one such MWCs were identified but
there is no basis for extrapolating beyond these units. These
MWCs are not included in Table*'4-2 because medical waste
typically accounts for only a small portion of their total waste
stream. They are also not included in the economic impact
analysis because their impacts are likely to be conservatively
represented by commercial medical waste incineration facilities.
Table 4-2 also shows the distribution of existing MWIs as
represented by the seven model MWIs developed in Section 4.1 of
the "Model Plant Description and Cost Report." The model MWIs
are identified in Table 4-2 by type and Ib/day design capacity
(e.g., the Continuous 36,000 is a continuous-duty MWI with a
daily design capacity of 36,000 pounds).
The "identified population" distribution in Table 4-2 represents
MWIs that were specifically identified from information provided
by MWI manufacturers, information requests to hospitals and _
commercial incineration facilities, state surveys, and emissions
test reports. Identified MWIs were assigned to the most
representative model MWI. The nationwide distribution of MWIs
("projected nationwide population" in Table 4-2) was then derived
within each industry by using the same proportions as in the
identified population and by constraining the sum to equal the
industry total (e.g., 3,150 for hospitals).
4.3.2 New MWIs
The NSPS applies to new MWIs, defined to include newly built,
modified, and reconstructed units. The projected distribution of
new.MWI sales (newly built MWIs) in the five-year period
following adoption of the NSPS and EG is shown in Table 4-3. The
total, 702, as well as the distribution, are extrapolated from
the 1985-1989 sales of seven vendors believed to represent about
two-thirds of the MWI market.
The distribution is represented by the seven models developed for
new MWIs in Section 2.1 of the "Model Plant Description and Cost
Report." With the exception of the Continuous 36,000, the new
model MWIs are slightly different from their existing model MWI
counterparts. While all existing model MWIs except the _
Continuous 36,000 are specified to have a secondary chamber with
a minimum gas residence time of 1/4 second (1/4-second _
combustion), all new model MWIs have one-second combustion (the .
existing Continuous 36,000, like the new Continuous 36,000, has
one-second combustion).
Modified and reconstructed units are not reflected in Table 4-3.
However, reconstruction, which is defined to involve an
investment exceeding 50 percent of replacement cost, is not
4-5
-------
TABLE 4-3. DISTRIBUTION OF NEW MWI SALES, Fifth Year
Industry
Model MWIa
Adjusted
capacity per
MWI (tons/yr)b
Projected
nationwide
population
Hospitals
Inter.
Cont.
Inter.
Path.
Inter.
Batch
21,000
24,000
8,400
2,000
2,000
250
1,176
977
470
172
115
27
18
56
86
3
237
165
Nursing homes
Veterinary
facilities
Research labs
Inter.
Inter.
Path.
Inter.
Inter.
Cont.
Inter.
Path.
Inter.
8,400
2,000
2,000
2,000
21,000
24,000
8,400
2,000
2,000
Commercial
incineration
facilities
TOTAL
Cont. 36,000
470
115
172
115
1,176
977
470
172
115
3,907
565
1
11
18
1
5
6
2
4
8
1
21
36
77
702
•Inter. = Intermittent, Cont. = Continuous, Path. =
Pathological.
blntermittent and continuous MWIs: Ib/hr design capacity x
67% x charging hrs/day x operating days/yr x 1/2,000
tons/lb. Pathological MWI: Ib/hr design capacity x 100%
x charging hrs/day x operating days/yr x 1/2,000 tons/lb.
Batch MWI: Ib/batch design capacity x 67% x batches/yr x
1/2,000 tons/lb.
4-6
-------
considered to be practical in light of improvements in MWI
technology in recent years.
Because the projections in Table 4-3 are based on past MWI sales,
they do not reflect potential%ew medical waste'regulations (such
as the NSPS and Emission Guidelines). On the other hand, sales
in the period 1985-1989 may have already been influenced by the
trends toward stricter regulation of MWIs at the state and local
levels, stricter requirements for medical waste management
(hauling, packaging, treatment, transportation, disposal, etc.),
and more inclusive definitions of medical waste.
As indicated in Table 4-3, over three-quarters (565) of new MWI
sales are projected to be to hospitals. Commercial incineration
facilities follow with 77 units. Relatively few new units are
projected to be sold to nursing homes, veterinary facilities, and
research labs.
Although commercial incineration facilities account for only 11.0
percent (77 * 702) of all new MWI sales, they account for 64.7
percent of the adjusted capacity of new unit sales. This is
because MWIs at commercial incineration facilities are_much
larger on average than MWIs at other facilities. Hospitals
account for 31.9 percent of the adjusted capacity of new unit
sales. All other facilities account for only 3.4 percent.
The predominance of new capacity at commercial incineration
facilities reflects the trends toward stricter regulation of
medical waste incineration at the state and local levels and more
inclusive definitions of medical waste. Stricter MWI regulations
are increasing the per-ton cost advantage that offsite
(commercial) MWIs tend to have over onsite MWIs as a result of
the economies they achieve from being, as mentioned, larger on
average. Meanwhile, expanding definitions of medical waste are
increasing the ranks of facilities without onsite medical waste
management expertise that are searching for offsite treatment and
disposal solutions. As a result of these trends, the demand for
offsite incineration is expected to increase. This will result
in an increase in the number of commercial and regional
incineration facilities, with ownership either by a commercial
operator or a group of generators.
A new MWI sale can be a consequence of 1) replacing-an existing
MWI, 2) switching from an alternative medical waste treatment
method (e.g., offsite contract disposal) to onsite incineration,
or 3) industry growth. For the industries to which MWIs will be
sold in the next five years, the precise contribution_of each of
these factors is not known. In most of these industries, all
three factors may be at work. It is not believed, however, that
switching from an alternative treatment method to onsite
incineration will be prevalent. More restrictive requirements
for medical waste incineration at the state and local levels are
4-7
-------
increasing the cost of onsite incineration not only in comparison
to the cost of commercial incineration, but also in comparison to
the cost of other alternative treatment methods. Most new MWI
sales are expected to be replacement units. In contrast,_new
unit sales to commercial medical waste incineration facilities
will mainly reflect growth in the industry resulting from
increased demand for offsite contract treatment and disposal.
4.3.3 Relative Populations
For the major industries in which MWIs are operated, Table 4-4
compares the number of existing MWIs to the number of facilities,
and the number of new MWI sales to the number of existing MWIs.
A little less than half of all hospitals currently operate an
MWI. In all other industries in which medical waste is generated
(i.e., excluding commercial incineration facilities, which do not
generate medical waste), a much lower percentage of facilities
operate an MWI.
Survey responses from 15 commercial incineration facilities
indicated that on average they operate about two MWIs.
Consequently, as shown in Table 4-4, 75 commercial incineration
facilities are assumed to operate the estimated 150 existing MWIs
in the industry. MWI operators in all other industries typically
operate only one MWI.
The total number of new MWI sales, 702, represents 14.1 percent
of the total number of existing MWIs, 4,986. This does not
reflect 14.1 percent growth in the number of MWIs because many
new MWI sales will be replacement units. In relation to the
number of existing MWIs, commercial incineration facilities will
purchase the most new MWIs over the next five years (77/150 =
51.3%).
4.4 MWI OPERATORS VERSUS OFFS1TE GENERATORS
The NSPS and Emission Guidelines will directly impact facilities
that operate a new or existing MWI.- The regulations will also
indirectly impact facilities that generate medical waste and send
it offsite to be incinerated. This is because such, facilities
will likely pay higher fees for commercial incineration as a
result of the regulations. In the "Analysis of Economic Impacts
for New Sources" and "Analysis of Economic Impacts for Existing
Sources," facilities that generate medical waste but do not
incinerate it onsite are termed "offsite generators."
The economic impact analysis is conducted by comparing control
costs to financial and economic parameters of model facilities in
the regulated industries. In Table 4-5, model facilities that
are MWI operators are distinguished from model facilities that
4-8
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are offsite generators. A model facility is classified as an MWI
operator if it represents an industry category or subcategory in
which MWIs are commonly operated. For example, nursing homes
with 100+ employees commonly operate an MWI. A model facility is
classified as an offsite generator, on the other hand, if it
represents an industry category or subcategory in which MWIs are
not commonly operated. For example, nursing homes with fewer
than 100 employees do not commonly operate an MWI.
In the economic impact analysis, the impacts of MWI controls are
assessed for MWI operators, and the impacts of higher commercial
(offsite) incineration fees are assessed for offsite generators.
Designation as an MWI operator or offsite generator depended
mainly on total waste generated per facility and the number of
MWIs in the industry in relation to the number of facilities
represented by each model facility in the industry. For example,
of the 17,525 nursing homes in the U.S. (see Table 4-1), 5,059
have 100+ employees. This was considered a sufficiently large
number of facilities to fully account for the 500 existing MWIs
in the industry (see Table 4-2) . Moreover, estimated total waste
generated by nursing homes with 0-19 employees and 20-99
employees was not deemed sufficient, on average, to warrant
operating an MWI onsite. Therefore, nursing homes with 100+
employees were designated as MWI operators while nursing homes
with 10-19 and 20-99 employees were designated as offsite
generators.
Note in Table 4-5 that in addition to nursing homes, veterinary
facilities and commercial research labs are split: the larger
facilities are designated as MWI operators and the smaller
facilities are designated as offsite generators.
4.5 OTHER CHARACTERISTICS OF THE REGULATED INDUSTRIES
For the industries included in the economic impact analysis, two
scale parameters — revenue and employment — are shown in Table 4-
6. Hospitals average the most revenue per facility, $32.5
million, as well as the most employment, 575 (full-time-
equivalent) . At the other end of the spectrum, dentists' offices
and clinics average only $300,000 in revenue and 4.7 in
employment.
The regulated industries cover the gamut of organizational
structures: for-profit, not-for-profit, and public (government).
Some not-for-profit and public establishments do not generate
revenues; rather, they have a budget to pay for their expenses
(fire departments, for example). Not-for-profit organizations
often are underwritten by grants, donations, fund-raising
proceeds, etc., while public establishments are typically
4-10
-------
TABLE 4-5.
MODEL FACILITY CLASSIFICATION:
VS. OFFSITE GENERATORS
MWI OPERATORS
MWI operators"
Off site generators'1
Hospitals
300+ beds
100-299 beds
50-99 beds
0-49 beds
Nursing homes
100+ employees
Veterinary facilities
20+ employees
10-19 employees
Commercial research labs
100+ employees
20-99 employees
Commercial incineration
facilities
Nursing homes
20-99 employees
0-19 employees
Veterinary facilities
0-9 employees
Commercial research labs
0-19 employees
Medical labs
Dental labs
Physicians' offices
Dentists' offices and clinics
Outpatient care
Physicians' clinics
Freestanding kidney dialysis
facilities
Freestanding blood banks
Funeral homes
Fire and rescue operations
Correctional facilities
Industry categories and subcategories in which MWIs are
commonly operated. Therefore, the economic impacts of
controls for an onsite MWI are assessed.
blndustry categories and subcategories in which MWIs are
not commonly operated. Therefore, the economic impacts
of higher fees for commercial (offsite) incineration are
assessed.
4-11
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appropriated tax revenues. In these cases, revenue in Table 4-6
is instead the budget.
Two industries in Table 4-6 — fire and rescue operations and
correctional facilities — consist entirely of public
establishments. The number of fire and rescue operations,
29,840, represents the number of public fire departments in the
U.S. Public fire departments —which can be all-volunteer; fully
career; or part career, part volunteer — are operated in the U.S.
by county, municipal, township, and special-district governments.
Correctional facilities are operated by Federal, state, county,
and municipal governments.
To reflect the diversity of the regulated industries, various
model facilities were created for the economic impact analysis.
Hospitals, for example, are distinguished by
(1) ownership; Federal government vs. state government vs.
local government vs. not-for-profit vs. for-profit;
(2) location; urban vs. rural;
(3) function: psychiatric vs. tuberculosis and other
respiratory diseases vs. long-term other special and
general vs. short-term other special and general; and
(4) size; 0-49 beds vs. 50-99 beds vs. 100-299 beds vs.
300+ beds.
Tax-paying establishments are distinguished from tax-exempt
establishments for nursing homes, commercial research labs,
dentists' offices and clinics, physicians' clinics, and
freestanding kidney dialysis facilities. As evident in Table 4-
5, employment-size distinctions are made for nursing homes,
veterinary facilities, and commercial research labs.
Research laboratories can be either commercial or captive to a
larger organization such as a pharmaceutical company or a
research university. MWTs are operated by both types of research
labs. However, economic impacts are assessed only for commercial
research labs, which are independent and stand-alone. Captive
research labs that are integrated with other operations of a
larger organization will tend to be impacted less by the NSPS and
Emission Guidelines than independent, stand-alone labs because
there is more revenue to which a price increase recovering
control costs can be applied.. On the other hand, impacts
measured for commercial research labs should be representative of
impacts on captive research labs that are separate profit centers
(and therefore are effectively stand-alone).
4-13
-------
-------
5.0 Costs of Medical Waste Incineration
5.1 INTRODUCTION
Baseline costs and control costs for each model combustor are
presented in this chapter. For detailed derivations, please see
the model plant description and cost report.
Several issues pertaining to the costs should be noted. _First,
based on differences in operation, emissions, and economic
impacts, it was decided that pathological MWIs should be
considered in a separate rulemaking. The cost estimates t
presented in this chapter were completed under the assumption
that pathological MWIs would also be regulated under_the proposed
rules. Therefore, costs presented in this chapter will be
slightly higher than actual costs expected to be incurred by the
industries examined. Other discrepancies in cost estimates may
be attributable to rounding. These discrepancies in costs are_
not regarded as significant because the economic impact analysis
indicates that the impacts of the proposed rules are not
significant. Using the lower but slightly more accurate costs
would not affect this conclusion.
Second, control option 4 is not shown in this report because it
is identical to control Option 5 except that control option 5
includes more monitoring requirements.
5.2 PER-MWI COSTS
Per-MWI capital costs and total annualized costs are presented in
Tables 5-1 and 5-2, respectively. Total annualized cost is equal
to annual operating and maintenance (O&M) costs plus the
annualized capital cost. Capital costs are annualized using the
Capital Recovery Factor. A discount irate of 10 percent and a
useful life of 20 years are assumed.
Note in Tables 5-1 and 5-2 that baseline costs are identical
under the NSPS and Emission Guidelines for the 36,000 Ib/day
continuous model (Continuous 36,000) but not for the other model
MWIs This is because with the exception of the Continuous
36,000, which is specified to have a secondary chamber with a
minimum gas residence time of one second (one-second combustion),
all existing model MWIs are specified to have 1/4-second
combustion. In contrast, all new models are specified to have •
one-second combustion. This considers that older MWIs tend to
have smaller secondary chambers than newer units, and that with
the exception of large continuous units, the majority of existing
MWIs were installed before 1985.
5-1
-------
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Control costs in Tables 5-1 and 5-2 are incremental to the
baseline. For example, the total capital cost for a new
Continuous 36,000 under Control Option 2 (two-second combustion)
is the baseline cost, $649,779, plus the control cost, $70,207,
or $719,986. There are no control costs for new MWIs under
Control Option 1 (one-second combustion) because they are
controlled at this level in the baseline (recall that new model
MWIs are all specified to have one-second combustion).
5.3 PER-FACILITY COSTS
In order to estimate economic impacts on facilities that operate
an MWI, it is necessary to link the per-MWI control costs in
Tables 5-1 and 5-2 to the model facilities that were judged to
represent MWI operators (see Table 4-5 in Chapter 4). The
assignment scheme for accomplishing this is demonstrated in Table
5-3.
The assignment scheme reflects that, in general, larger MWIs are
expected to be located at larger facilities. In addition, total
waste generated by the model facility in relation to MWI capacity
is considered. For example, hospitals with 300+ beds generate
sufficient waste, on average, to warrant operating a Continuous
24,000 or Intermittent 21,000 onsite. Hospitals with 300+ beds
could also operate the much smaller Batch 250. However, the
Batch 250 is not assigned to such hospitals because its economic
impacts will be conservatively represented by the Continuous
24,000 and Intermittent 21,000, which are more costly to control.
On the other hand, hospitals with 0-49, 50-99, and 100-299 beds
do not generate sufficient waste, on average, to warrant
operating a Continuous 24,000 or Intermittent 21,000. Instead,
hospitals with 0-49 beds are assigned the smallest model MWI, the
Batch 250; hospitals with 50-99 beds are assigned the two next-
largest MWIs, the Intermittent 2,000 and Pathological 2,000; and
hospitals with 100-299 beds are assigned the next-largest MWI,
the Intermittent 8,400.
Survey responses from 15 commercial incineration facilities
indicated that on average they operate about two MWIs.
Therefore, commercial incineration facilities are stipulated to
each operate two of the Continuous 36,000s assigned'to them in
Table 5-3. In all other industries, typically only one MWI is
operated per facility (though there are exceptions).
Consequently, the assigned MWIs are operated on a one-to-one
basis. For those model facilities assigned more than one MWI in-
Table 5-3 (e.g., hospitals with 50-99 beds, which are assigned
the Intermittent 2,000 and Pathological 2,000), separate economic
impacts are measured for each MWI.
One implication of linking model MWIs to model facilities on a
one-to-one basis is that the per-MWI costs in Tables 5-1 and 5-2
5-4
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can be construed as per-facility. For commercial incineration
facilities, on the other hand, the per-facility costs are twice
the costs of the Continuous 36,000 in Tables 5-1 and 5-2.
5.4 NATIONWIDE COSTS
Nationwide total annualized costs are presented in Table 5-4 for
the NSPS and in Table 5-5 for the Emission Guidelines. Two
distributions are provided: by model MWI and by industry. The
costs by model MWI are derived by multiplying per-MWI total
annualized costs in Table 5-2 by the number of MWIs nationwide,
provided in the first column of Tables 5-4 and 5-5. The costs by
industry are derived by summing for each model MWI the product of
the total number of MWIs in the industry (see Chapter 4, Tables
4-2 and 4-3) and per-MWI total annualized costs in Table 5-2.
The control costs in Tables 5-4 and 5-5 are calculated assuming
that all MWIs are controlled at the same level. For example, the
nationwide total annualized control cost under Control Option 2
of the NSPS, $12,109,000, assumes that all new MWIs are subject
to Control Option 2.
The nationwide total annualized baseline cost is approximately
$63.6 million for new MWIs and approximately $335.0 million for
existing MWIs. The nationwide total annualized control cost
ranges up to $215.3 million under the NSPS and $1,415.6 million
under the Emission Guidelines if all MWIs are subject to Control
Option 5 (DI/FF with carbon) and continuous emissions monitoring.
5.5 PER-TON COSTS
Per-ton total annualized costs are presented in Table 5-6. The
costs for the model MWIs are calculated by dividing per-MWI total
annualized costs in Table 5-2 by adjusted capacity per MWI,
listed in the first column of Table 5-6. The calculations
therefore assume full utilization of adjusted capacity. If less
than full adjusted capacity is used, the per-ton cost would be
higher. The costs for the MWI subcategories (e.g., "total
continuous") are calculated by dividing nationwide total
annualized costs in Tables 5-4 and 5-5 by nationwide adjusted
capacity, which is equal to the sum, for each model MWI in the
subcategory, of the product of the number of MWIs
nationwide (Tables 5-4 and 5-5) and adjusted capacity per MWI.
In Table 5-2 it was seen that larger MWIs tend to have higher
total annualized baseline costs, as well as higher total
annualized control costs. Table 5-6 demonstrates, in contrast,
that on a per-ton basis, the baseline cost and control costs
decrease as the size of the MWI increases (i.e., as adjusted
capacity increases). This reflects economies of scale.
5-6
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5.6 Costs of the Regulations
Costs for the proposed regulations are summarized in Tables 5-7
and 5-8. Table 5-7 shows per-MWI control costs. The NSPS and EG
control costs reflect dry injection/fabric filter with carbon
requirements for all new and existing MWIs. The costs can be
confirmed by cross-referencing Tables 5-1 and 5-2. For example,
the MACT capital costs for the Continuous 36,000 in Table 5-7 is
$795,286. Referring to Table 5-1, it is seen that this is the
cost under Control Option 5.
The per-MWI total annualized control costs in Table 5-7 are
multiplied by the number of MWIs nationwide (Tables 5-4 and 5-5)
to yield nationwide total annualized costs for the NSPS and EG
requirements in Table 5-8. Under the NSPS, the nationwide total
annualized control cost is approximately $213.9 million. Under
the EG, the nationwide total annualized control cost is
approximately $1.133 billion.
5.7 COMMERCIAL INCINERATION COSTS
The NSPS and Emission Guidelines will increase costs not only for
establishments that operate an MWI, but also for establishments
that generate medical waste and send it offsite to be
incinerated. Such establishments can be expected to pay more for
commercial (offsite) incineration as a result of the NSPS and
Emission Guidelines. The impacts of the NSPS and Emission
Guidelines on the cost of commercial incineration are estimated
in Tables 5-9 and 5-10.
• Nationwide total annualized commercial incineration control costs
(i.e., total annualized control costs attributable to MWI
capacity used for commercial incineration) are estimated in Table
5-9.- This is- accomplished by recognizing that, by definition,
100_percent of the adjusted MWI capacity of commercial
incineration facilities is used for commercial incineration, and
by assuming that 10 percent of adjusted MWI capacity at
hospitals, nursing homes, veterinary facilities, and research
labs is used for commercial incineration. (Ten percent may be
high. This would have the advantage, however, of yielding
conservative economic impacts for offsite generators.) These
factors are multiplied by industry-wide MWI capacity to yield
industry-wide commercial incineration capacity, and by industry-
wide total annualized control costs in Tables 5-4 and 5-5 to
yield industry-wide total annualized commercial incineration
control costs (i.e., industry-wide total annualized control costs
that are attributable to MWI capacity used for commercial
incineration.)
As indicated in Table 5-9, it is estimated that 702,865 tons per
year of existing MWI capacity is used for commercial
5-10
-------
TABLE 5-7 PER-MWI CONTROL COSTS (INCREMENTAL TO THE
BASELINE) FOR CONTROL OPTION 5 (1989 DOLLARS)
Model MWI
Capital Cost
Control Option
5°
Total Annualized
Cost
Control Option 5C
Cont.
Inter.
Cont.
Inter.
Path.
Inter.
Batch
Cont.
Inter.
Cont.
Inter.
Path.
Inter.
36,000
21,000
24,000
8,400
2,000
2,000
250
36,000
21,000
24,000
8,400
2,000
2,000
250
972,374
972,374
852,681
756,649
660,098
646,418
1,078,373
1/078,373
930,317
811,588
692,340
675,470
453,781
247,958
338,001
315,518
273,354
267,718
484,083
-, 424,513
354,482
327,214
279,893
273,948
•Annual O&M costs plus the annualized capital cost. _ Capital
costs are annualized at 10 percent over a useful life of 20
bContf.% Continuous, Inter. = Intermittent, Path. = Pathological,
-------
TABLE 5-8. NATIONWIDE TOTAL ANNUALIZED CONTROL COSTS (INCREMENTAL
TO THE BASELINE) FOR THE REGULATORY ALTERNATIVES ($103, 1989)*
NSPS
EG
Control Option 5
Control Option 5
By model MWIb:
Cont. 36,000
Cont. 24,000
Total cont .
Inter. 21,000
Inter. 8,400
Inter. 2,000
Total inter.
Path. 2,000
Batch 250
TOTAL6
34,941
20,280
55,221
8,009
29,974
76,539
114,522
44,174
213,917
74,549
64,516
139,065
72,592
242,793
586,936
902,321
91,773
1,133,159
'Annual O&M costs plus the annualized capital cost. Capital costs
are annualized at 10 percent over a useful life of 20 years.
bCont. = Continuous, Inter. = Intermittent, Path. = Pathological.
"Under the NSPS and EG, Control Option 5 reflects DI/DD w/carbon for
all new and existing MWIs.
5-12
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incineration, and that over the next five years, new MWIs^will
account for 317,270 tons per year of commercial incineration
capacity. For the NSPS, the nationwide total annualized
commercial incineration control cost ranges up to $53.0 million
($167/ton) if all new MWIs are subject to Control Option 5. For
the Emission Guidelines, the range is up to $210.5 million_
($300/ton) if all existing MWIs are subject to Control Option 5.
Note that under every control option, the average per-ton costs
of commercial incineration in Table 5-9 are lower than the per-
ton costs of all model MWIs in Table 5-6 except the Continuous
36,000. This reflects that, on average, commercial MWIs are
larger and more efficient than onsite MWIs.
Next, in Table 5-10, it is recognized that the cost of commercial
incineration will be impacted by both the NSPS and Emission
Guidelines. The increase in the average per-ton total annualized
cost of commercial incineration is calculated as a weighted
average, by commercial incineration capacity, of the per-ton
control costs for new and existing MWIs in Table 5-9. Since
':total commercial incineration capacity is 31*^270 tons per year
for new MWIs and 702,865 tons per year for existing MWIs, the
weights assigned to new MWIs and-existing MWIs are 31.1 .percent
and 68.9 percent, respectively.
Consider Control Option 5 under the NSPS (i.e., all new MWIs are
subject to Control Option DI/FF with carbon). In the case of the
baseline for existing MWIs, the weighted-average increase in the
.•total annualized cost of commercial incineration is (68.9% x 0) +
(31.1% x $167/ton) = $52/ton. If, at the other extreme, all
existing MWIs are subject to Control Option 5, the weighted-
average increase in the,total annualized cost of commercial
'incineration is (68.9% x $300/ton) + (31.1% x $167/ton) =
$259/ton.
Table 5-10 presumes that the stringency of the NSPS is greater
than or equal to that of the Emission Guidelines. For this
reason, some combinations of a control option under the NSPS and
a control option under the Emission Guidelines are not addressed
in the table. If the NSPS and Emission Guidelines are of equal
stringency, the incremental total annualized cost .of commercial
incineration is, as shown in Table 5-10, $9/ton under Control
Option 1, $25/ton under Control Option 2, $86/ton under Control
Option 3, and $259/ton under Control Option 5.
5-15
-------
6.0 Medical Waste Treatment and Disposal
6.1 INTRODUCTION
Incineration, either onsite or offsite, is the predominant
treatment method for medical waste. However, there are both
onsite and offsite alternatives. According to a 1989 report by
the Rational Solid Waste Management Association, while 60 percent
of infectious waste at hospitals is incinerated onsite, 20
percent is steam-sterilized (autoclaved) onsite and 20 percent is
treated offsite.1
In Section 6.2 of this chapter, recent trends in the U.S. medical
waste treatment and disposal market are discussed. In
Section 6.3, alternatives to onsite incineration—the most
common of which are offsite incineration and onsite autoclaving —
are identified. Estimated per-ton total annualized costs of
onsite incineration, offsite incineration, and onsite autoclaving
— before and after the NSPS and Emission Guidelines — are
compared in Section 6.4. These costs are then used in
Section 6.5 to calculate the costs of substituting from onsite
incineration to offsite incineration and onsite autoclaving.
6.2 RECENT TRENDS
Medical waste has been the object in recent years of a great deal
of regulatory activity, prompted in large part by growing public
concern over proper treatment and disposal, which was galvanized
by the wash-up-of medical waste on East Coast beaches in the
summer of 1988. As a result of the regulatory activity, there
have been some pronounced trends in the medical waste treatment
and disposal market. The most significant of these trends
include:
• The quantity of medical waste generated has increased.
• Restrictions on general medical waste management
(handling, transportation, treatment, disposal, etc.)
at the state and local levels have increased.
• Restrictions on MWIs at the state and local levels have
increased.
• More regional MWIs — either privately owned and/or
operated, or cooperatively owned and/or operated by a
group of generators — have been put into operation.
• Medical waste regulations have become more uneven from
region to region and there is more uncertainty in the
regulatory climate.
• The demand for alternative (to incineration) medical
waste treatment methods has increased, and new
6-1
-------
technologies have been developed and put into
operation.
The first five of these trends are discussed in this section.
The sixth trend is discussed "in Section 6.3.
The quantity of medical waste generated has increased in recent
years because the use of disposable items has increased and
because new regulations have tended to define medical waste more
inclusively. In addition, some waste haulers and landfill
operators are refusing to accept waste from medical waste
generators even if it is not infectious under applicable
regulations or guidelines. This may require the waste to be
treated and handled as infectious.
As a result of the increase in medical waste generated, the
overall demand for medical waste treatment — both onsite and
offsite — has increased.
Growth in the quantify of medical waste generated has perhaps
been mitigated' somewhat" by more-" careful waste1 segregation
practices, which have been encouraged by increases in treatment
.and disposal costs resulting from the.new restrictions on MWIs
and medical waste management in general.
Restrictions on general medical waste management have increased
in recent years as many states and localities have instituted new
regulations and extended guidelines to regulation status. As a
result, the cost of medical waste treatment — both onsite and
offsite — has increased. Those regulations that have targeted
the transportation and disposal of medical waste (e.g., tracking
requirements) have increased the relative attractiveness of
"onsite treatment methods, particularly•onsite incineration, which
reduces transportation and disposal requirements by significantly
reducing volume and weight. On the other hand, regulations aimed
-at MWIs have favored noriincineration treatment methods, as well
as offsite incineration because offsite/ commercial MWIs are
larger and therefore more efficient (i.e., have lower per-ton
costs), on average, than onsite MWIs.
The choice of a medical waste treatment method depends ultimately
on the particular circumstances of the generator and the host
community.2 Such factors as 1) the nature and quantity of the
waste generated, 2) the cost, 3) liability risk, 4) regulatory
requirements, 5) the availability of permitted landfill space
(after treatment, solid medical waste, including incinerated
medical waste, is generally disposed of in a landfill), and 6)
local air quality conditions, must be considered. While onsite
treatment affords the generator more control over the ultimate
disposal of medical waste (thereby reducing liability_exposure)
. and can lower transportation and disposal costs, offsite
6-2
-------
treatment may be preferred if the generator has limited space for
treatment equipment or, more importantly, does not want to devote
resources to an operation that is outside its line of business.
No doubt in part due to the unevenness of regulations, there has
been no clear trend, towards onsite or offsite medical waste
treatment. With respect to incineration, for example, the U.S.
Congress, Office of Technology Assessment (OTA) concludes that
"it is not clear whether there is a trend for more off-site or
continued on-site incineration."3
As with medical waste management in general, MWIs have been
subject to increasing restrictions in recent years. Most
significantly, many states and localities have tightened
emissions standards for MWIs and/or made it more difficult to get
a permit for, and site, an MWI.
Emissions regulations have caused the cost of operating an MWI to
increase. This has encouraged the use of nonincineration
treatment technologies. .It has also encouraged generators to use
larger onsite MWIs and to send their medical waste offsite to be
incinerated by commercial MWIs, which are larger on average than
onsite MWIs. Due to economies of scale, large MWIs tend to have
lower per-ton impacts from regulations than small MWIs.
Indeed, MWIs have been increasing in size. Further, new regional
MWIs have been sited. Most regional MWIs are commercial (i.e.,
privately owned and/or operated), but some are cooperatively
owned and/or operated by a group of generators. Commercial
incineration has grown not only in response to regulations that
have disproportionately impacted small onsite MWIs, but also in
response to the expanding quantity of medical waste being
generated.
The average cost.of commercial incineration is estimated to be
$600 per ton. This can vary substantially according to
regional/local market conditions, however. For example, it can
depend on the hauling distance from the generator to the MWI.
Although large generators may be able to achieve a volume
discount, commercial incineration may be most appropriate for
small generators who do not have the expertise or resources to
treat medical waste onsite.
MWI capacity in some areas of the country — such as the
Northeast, Illinois, and Texas — is tight.4 This is particularly
likely to be the case if state emissions requirements have led to
the closure of existing MWIs or if siting/permitting difficulties
have limited the construction of new MWI capacity. Permitting an
'MWI can take over two years.5 On the other hand, the Southeast,
lower Midwest (centered in and around Oklahoma), and Ohio River
Valley, for example, appear to have excess MWI capacity.6 OTA
6-3
-------
concludes that temporary shortfalls of MWI capacity can be
averted if the "adoption of new regulations is coordinated with
careful planning and expedient permitting."7
Despite these restrictions, MWls still have some advantages over
other treatment methods. Incineration significantly reduces the
volume and weight of medical waste (by up to 95%). This can
reduce transportation and landfill-disposal costs. Also,_
incineration ensures the total destruction and sterilization of
medical waste. Because the medical waste can therefore be
identified as treated and disinfected, it may be more acceptable
to some waste haulers and landfill operators. OTA concludes that
incineration is "likely to remain, at least for the next decade,
the cornerstone of (medical waste) management methods. OTA
notes, however, that incineration will continue to be effectively
supplemented by alternative medical waste treatment methods.
As a result of all the regulatory activity at the state and local
levels, the regulatory climate has become more variable and
uncertain. While some states and localities have encouraged
incineration-(often-"indirectly-by not approving alternative
technologies), others have gone so far as to establish MWI
moratoria. Moreover, some regulations have favored small MWIs,
while others have favored larger units. Currently there are no
Federal standards for MWIs. A "leveling of the playing field,
which would be the effect of Federal regulations such as the NSPS
and Emission Guidelines, would tend to benefit large MWIs because
they have economies of scale.
6.3 ALTERNATIVES TO ONSITE INCINERATION
Landfilling of medical waste without prior treatment is becoming
less and less common. Most states require prior treatment.
Moreover, where landfills have discretion, they are becoming more
•likely to require prior treatment. Consequently, if not
incinerated onsite, medical waste generally requires alternative
treatment.
One alternative, as discussed in Section 6.2, is offsite
incineration by a commercial or regional MWI. Another
alternative is co-incineration with municipal solid waste. At
least 31 municipal waste combustors (MWCs) are known to co-fire
medical waste.9 However, of these 31 units, only one accepts an
average of 50 percent medical waste. The rest accept no more
than 5 percent medical waste. Co-firing medical waste with
municipal solid waste has had limited application due, for
example, to 1) public concern over "importing" medical waste from
other areas, 2) employee concern over exposure to medical waste
in the workplace, and 3) mechanical considerations, such as
^potentially rupturing red bags in the handling system.1
6-4
-------
There are_also nonincineration alternatives to onsite
incineration of medical waste. The commercial viability and use
of nonincineration alternatives have increased in recent years
for a number of reasons, including: l) the quantity of medical
waste generated has increased, 2) concern over MWI emissions has
increased, with consequent regulatory action and increased costs
for MWIs, 3) MWIs have become more difficult to permit and site,
and 4) new technologies have been developed and brought to
market.
By far the most common nonincineration medical waste treatment
method is autoclaving (steam sterilization). Autoclaving is
already a common onsite "treatment method and is growing as an
offsite treatment method. Although there are believed to be
fewer than 24 commercial autoclaving facilities in the U.S., one
waste management company reports that it is currently siting more
autoclaves than incinerators.11-12
Autoclaving is usually combined with shredding or grinding, which
can- reduce-the volume of the waste by up to 80 percent. The
shredding or grinding can be done after autoclaving to render the
waste unrecognizable, or before autoclaving to both render the
waste unrecognizable and improve the efficiency of the
disinfection process. If medical waste is shipped offsite to be
autoclaved, onsite shredding or grinding may first be necessary
if recognizability is a factor to the transporter.
By reducing volume, shredding or grinding can reduce disposal
costs (for example, fewer trips to the landfill are required).
Shredding or grinding does not reduce weight, however. In fact,
autoclaving can increase the weight of medical waste because
water is added in the process.
Autoclaving is -not an appropriate treatment for some components
of the medical*waste stream, particularly pathological waste.
About 10 percent of all medical waste cannot be autoclaved.13
Supplementary treatment such as incineration may therefore be
needed for a small portion of the medical waste stream. Another
limitation of autoclaving is that some waste haulers and
landfills are not willing to accept autoclaved waste because it
cannot be identified as noninfectious without being tested.
However, "informal discussions" with a number of hospital
officials across the country indicated to OTA that "few refusals
(of autoclaved medical waste) occur if a hospital works closely
with landfill operators to explain their waste procedures."14
The remaining nonincineration medical waste treatment
alternatives are all relatively new applications and have not yet
gained widespread use in the U.S. These alternatives include
chemical disinfection, microwave sterilization, thermal
inactivation (dry heat sterilization), irradiation, and
6-5
-------
radiofrequency sterilization. Some of these methods may_be more
appropriate for either onsite or offsite treatment, but in
'•. general they can be used for both. Like autoclaving, these
alternatives are generally combined with shredding or grinding to
•render the medical waste unrecognizable, to reduce the volume (by
:'up to 80%), and, if performed prior to treatment, to make the
disinfection process more efficient. Again, like autoclaving,
weight is not reduced by these methods, and in fact may increase
if water is added in the process.
Most of these alternatives are as effective as incineration and
autoclaving in rendering medical waste noninfectious.1 Thermal
inactivation, however, is not considered as efficient as
autoclaving.16 With the possible exception of chemical
disinfection, these alternatives, like autoclaving, cannot be,
used to treat pathological waste (the suitability of chemical
disinfection for pathological waste is said by OTA to be not
clear") " Hence, as with autoclaving, supplementary treatment
such as incineration may be needed for a small portion of the
medical waste stream.
'• - , • --"
6.4 COMPARATIVE COSTS
Tables 6-1 and 6-2 compare the estimated per-ton total annualized
costs of onsite incineration and its two most common _
alternatives, onsite autoclaving and offsite incineration. Table
6-1 shows costs before and after the NSPS, and Table 6-2 shows
costs before and after the Emission Guidelines.
Baseline costs of onsite incineration in Tables 6-1 and 6-2, as
represented by six of the seven model MWIs.(the Continuous 36,000
'• is excluded because it is modeled as a commercial MWI, not an
onsite MWI), are from Table 5-6. in Chapter 5. The costs of
•onsite incineration under the, control options ,are derived from
the incremental control costs in Table 5-6. --As explained in
Section 5.5, these per-ton costs assume full utilization of
adjusted capacity. If less than full adjusted capacity is used,
the per-ton cost would be higher.
The costs of onsite autoclaving in Tables 6-1 and 6-2 are for
autoclave systems with the same capacities as the model MWIs.
The cost of shredding is included. Again, full capacity_
utilization is assumed; less than full capacity utilization would
result in a higher per-ton cost. Note that the cost of
autoclaving is not affected by the NSPS or Emission Guidelines
(i e under the control options, cost does not differ from the
baseline). This assumption disregards the increase in cost that
could come if the demand for autoclave systems were to increase
' as a result of the regulations.
6-6
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In contrast, the costs of offsite incineration, which follow from
Table 5-10 in Chapter 5, increase as the control options become
more stringent. For offsite incineration costs in Table 6-1,_the
low end of the range is based on no controls (i.e., the baseline)
for existing MWIs under the Emission Guidelines, and the high end
is based on the same control stringency for existing MWIs under
the Emission Guidelines as for new MWIs under the NSPS. In Table
6-2, the low end is based on the same control stringency for new
MWIs under the NSPS as for existing MWIs under the Emission
Guidelines, and the high end is based on the maximum control
stringency, Control Option 5, for new MWIs under the NSPS. This
presumes that the stringency of the NSPS will be greater than or
equal to that of the Emission Guidelines. While the cost of
offsite incineration does vary by control option, it is shown in
Tables 6-1 and '6-2 to not vary by capacity. This assumes,
perhaps simplistically, that volume discounts are not achieved.
Tables 6-1 and 6-2 show that in the baseline, the cost of onsite
incineration is generally lower than the cost of onsite
autoclaving. The exception for both new MWIs (Table 6-1) and
existing MWIs (Table 6-2) is the Continuous 24,000, which costs
more than an autoclave system of the same capacity.
Offsite incineration, in the baseline, is more expensive on
average than the Intermittent 2,000 and all larger models, but
less expensive on average than the smaller Batch 250. Similarly,
offsite incineration is less expensive in the baseline than an
autoclave system of the same capacity as the Batch 250, but more
expensive than larger autoclave systems.
With controls, the cost of onsite incineration relative to both
• onsite autoclaving and offsite incineration becomes less
favorable. For onsite autoclaving, this is because it is
unaffected by the NSPS and Emission Guidelines. For offsite
••incineration,.this is because compared to onsite MWIs, commercial
MWIs are larger on average and therefore have lower per-ton
impacts from the NSPS and Emission Guidelines.
In Table 6-1, while all but one new MWI, the Continuous 24,000,
are less expensive than onsite autoclaving under Control Options
1 and 2 (as in the baseline), no new MWIs (excluding the
Pathological 2,000, for which autoclaving is not a suitable
substitute) are less expensive under Control Options 3 and 5. In
Table 6-2, all existing MWIs other than the Continuous 24,000 are
less expensive than onsite autoclaving under Control Option 1 (as
in the baseline) , all but two existing MWIs (the Continuous
24,000 and Intermittent 21,000) are less expensive under Control
Option 2, and no existing MWIs (again, excluding the Pathological
C2,000) are less expensive under Control Options 3 and 5.
Meanwhile, while offsite incineration continues, as in the
baseline, to be less expensive than both a new and existing Batch
6-9
-------
250 under all control options, it also becomes less expensive
than both the new and existing Pathological 2,000 under Control
- Option 5, and both the new and existing Intermittent 2,000 under
^Control Options 3 and 5. The larger model MWIs — the
. Intermittent 21,000, Continuous 24,000, and Intermittent 8,400—
- remain less expensive than offsite incineration under all control
options.
Estimated capital costs of newly built MWIs (i.e., new MWIs, but
not ones that are modified or reconstructed) and new autoclave
systems are compared in Table 6-3. Offsite incineration is not
included because it has the advantage of requiring no capital
investment. The capital costs of the newly built MWIs are in the
baseline, i.e., before the NSPS. For capital control costs of
the NSPS (and of the Emission Guidelines), see Table 6-1 in
Chapter 5. Table 6-3 highlights that with the exception of the
Pathological 2,000, for which autoclaving is not a suitable
substitute, the capital cost of a newly built MWI exceeds the
capital cost of a new autoclave system of the same capacity,
across the board.
6.5 SUBSTITUTION COSTS
In addition to complying with the NSPS or Emission Guidelines by
installing controls, MWI operators have the option of switching
to an alternative medical waste treatment method. Comparative
costs of 'onsite incineration, onsite autoclaving, and offsite
incineration were presented in Section 6.4. Incremental per-ton
total annualized costs of switching from onsite incineration in
the baseline to onsite autoclaving and offsite incineration,
based on the comparative per-ton total annualized costs in Tables
6-1 and 6-2, are presented in Table 6-4. The-costs of switching
to offsite incineration assume that new MWIs under the NSPS and
existing MWIs under the Emission Guidelines are similarly
controlled (the high end of the ranges in Table 6-1 and the low
end of the ranges in Table 6-2).
For the two cases in Tables 6-1 and 6-2 in which onsite
incineration is more expensive than an alternative in the
baseline — the Continuous 24,000 versus onsite autoclaving, and
the Batch 250 versus offsite incineration — Table 6-4 shows that
the incremental cost of substitution is negative.. In all other
cases, the incremental cost of substitution is positive because
onsite autoclaving and offsite incineration are more expensive
than onsite incineration in the baseline. The incremental cost •
of switching to offsite incineration increases as the control
options become more stringent, reflecting that the cost of
commercial incineration is impacted by the NSPS and Emission
Guidelines. In contrast, the incremental cost of switching to
onsite autoclaving, which is assumed to be unaffected by the
.regulations, is independent of the control level.
6-10
-------
TABLE 6-3. COMPARATIVE CAPITAL COSTS OF NEWLY BUILT
MWIS AND NEW AUTOCLAVE SYSTEMS (1989 DOLLARS)
Newly built MWI
Adjusted Baseline Cost of a new
capacity" Unitb cost autoclave system0
1,176 tons/year Inter. 21,000 237,659
977 tons/year Cont. 24,000 520,871
470 tons /year Inter. 8,400 156,822
172 tons/year Path. 2,000 96,345
115 tons/year Inter. 2,000 95,266
27 tons/year Batch 250 71,669
173,376
136,509
107,015
N.A.
77,521
66,406
'Intermittent and continuous MWIs: Ib/hr design capacity x
67% x charging hrs/day x operating days/yr x 1/2,000 tons/
Ib. Pathological MWI: Ib/hr design capacity x 100% x
charging hrs/day x operating days/yr x 1/2,000 tons/lb.
Batch MWI: Ib/batch design capacity x 67% x batches/yr x
1/2,000 tons/lb.
blnter. « Intermittent, Cont. = Continuous, Path. =
Pathological.
Includes the cost of a shredder.
N.A. Not applicable (because autoclaving cannot be used to
treat pathological waste, and therefore is not a suitable
substitute for the Pathological 2,000).
6-11
-------
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The per-ton substitution costs in Table 6-4 can be compared to
the per-ton control costs in Chapter 5, Table 5-6 to see which
costs more: controls or substitution?
Multiplying the'per-ton costs in Table 6-4 by tons treated per
year, represented by the adjusted capacities of the model MWIs
(see, for example, Tables 6-1 and 6-2), yields incremental per-
MWI total annualized costs of substitution in Table 6-5. These
are the incremental annual costs that facilities substituting for
one of the model MWIs could be expected to incur. For both
onsite incineration and onsite autoclaving, full utilization of
adjusted capacity is assumed. As a result, the incremental total
annualized costs of switching to both onsite autoclaving and
offsite incineration are conservative, i.e., may be overstated.
The incremental total annualized cost of onsite autoclaving is
conservative because the number of tons treated per year may be
overstated (no doubt, many MWIs and autoclave systems are not
operated at full capacity). The incremental total annualized
cost of offsite incineration is conservative not only because the
number of tons treated per year may be overstated, but also
because the per-ton cost of onsite incineration in the baseline
would be understated if full capacity is not utilized. This
would lead to an overstatement of the per-ton cost differential
between offsite incineration and onsite incineration in the
baseline.
6-13
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7.0 Economic Impacts
'7.1 INTRODUCTION
The ma-ior aims of the economic impact analysis were to determine
1) thS average industry-wide price increase necessary to recover
control cSS? 2) theltarket response to the industry-wide price
incase - specifically, impacts on output, employment revenue,
and market structure; 3) the extent to which individual
establishments can recover control costs by increasing prices; 4)
the availability of capital to finance the investment in
controls; 5) the exten? of economic hardship if control costs
cannot be fully recovered or if capital is not readily available;
and 6) the extent to which the impacts of control costs can be
and will be, avoided by switching to an alternative medical waste
treatment and disposal method.
[note: This analysis was completed before a decision was made to
exclude pathological MWIs from the proposed rules Annualized
costs used as an input to estimate economic: impacts were also
•calculated before this decision was made. Consequently, the
economic impact estimates presented in. this: chapter are expected
to be slightly greater than actual economic impacts expected to
t£ incurred by the industries examined. This discrepancy is not
expected to significantly affect the conclusion of the analysis -
that the economic impacts of the proposed rules are not
significant.]
in Section 7.2 of this chapter, the general methodology of the
economic impact analysis is presented. In Section 7.3, the
'findings of the analysis are summarized. The maDor conclusions
of tiS analysis are presented in Section 7.4.' Impacts on small
entities are discussed in Section 7.5.
For more-detailed discussion and analysis of economic impacts,
please refer to the "Analysis of Economic Impacts for_New
Sources" and the "Analysis of Economic Impacts for Existing
Sources."
7.2 METHODOLOGY
7.2.1 Model Facility Approach
The economic impact analysis was conducted by comparing control
costs and incremental substitution costs to economic a*d
costs an ncre
financial parameters of the regulated industries. As discussed
in lectionl 4.4 and 4.5 of Chapter 4, model facilities were
created for this purpose. The major parameters assigned to the
•model facilities include annual revenue, annual before-tax net
7-1
-------
income, employment, and total liabilities (assets minus net
worth). (Revenue and employment were presented in Chapter 4,
Table 4-6.) The .-parameters are averages per facility; hence, the
model facilities represent average or typical establishments.
The model facility data can be used directly to estimate per-
facility economic impacts or can be aggregated to estimate
industry-wide economic impacts.
7.2.2 Industry-wide and Per-facility Analyses
Indeed, two separate economic impact analyses were conducted:
industry-wide and per-facility. The general methodologies of the
industry-wide and per-facility analyses, and how they are linked,
can be understood with the aid of the flow chart in Figure 7-1.
The figure applies specifically to facilities with an onsite MWI
(MWI operators).
7.2.2.1 Industry-wide Analysis.
The linchpin for the industry-wide analysis was calculating the
"market price increase." This represents the average industry-
wide price increase necessary to recover control costs. It is
calculated as the ratio of the industry-wide total annualized
control cost (see Chapter 5, Tables 5-4 and 5-5) to industry-wide
revenue.
Because most, if not all, of the regulated industries are
fragmented, actual price increases will vary from market segment
to market segment according to such factors as 1) the number of
facilities, 2) the number of facilities operating an MWI, 3) the
distribution of MWI types, and 4) market structure and pricing
mechanisms. Ideally, the average price increase in each market
segment would be measured. However, it is not possible to define
and characterize literally hundreds of regional and local market
'segments. ^Therefore, the market price increase, which is an
average price increase across all market segments, was used to
represent the average price increase in each individual market
segment.
Based on the market price increase, the percent change in
industry-wide output was then estimated. The change in output is
inversely related to the market price increase depending on the
price plasticity of demand, which measures the percent change in
quantity demanded (which in market equilibrium is equal to
output) along the demand curve in response to a percent change in
price. The more inelastic demand is, the greater is the ability
to increase price without an attendant decline in output.
Relatively elastic demand, on the other hand, restricts the
•ability to increase price without losing output.
The majority of medical waste is generated by industries involved
in the provision of health care. In general, the demand for
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health care is considered to be relatively inelastic. There are
several reasons for this. First, other than abstinence, there is
7, no substitute for health care. Secondly, good health is a
•virtual necessity. As a result of these factors, consumers are
.'relatively captive to providers (e.g., physicians) and often are
. given little choice in medical decisions. Another factor is that
health care providers tend to compete more on quality than price.
Finally, and perhaps most importantly, patients are 'to a great
extent insulated from changes in the price of health care because
medical bills are commonly paid by third parties such as
government programs (e.g., Medicare, Medicaid) and private
insurers. In 1987, third parties paid for 72 percent of the cost
of health care in the U.S.1"
There are some offsetting factors. For one, co-payments and
deductibles on insurance plans still constitute a significant
share of consumers' budgets. Further, health care providers have
been meeting increased resistance to price increases_from third-
party payers. Finally, abstaining from health care is apparently
an option, as 37 million Americans are presently without health
insurance.2 '~'
Demand elasticity was qualitatively assessed for each regulated
industry. Most of the regulated industries were judged to face
relatively inelastic demand. The assessments ranged from
"slightly elastic" demand for research laboratories and medical
laboratories, to "highly inelastic" demand for hospitals,
physicians' offices, physicians' clinics, freestanding kidney
dialysis facilities, freestanding blood banks, funeral homes,
fire and rescue operations, and correctional facilities.
-The next step in the industry-wide analysis.was to estimate the
' change in industry-wide employment.- • This was done assuming a
fixed labor-output ratio. As a result, the percent change in
employment is equal-to the percent change in output. The change
in employment can then be calculated as the percent change in
employment multiplied by baseline employment:
The final step in the industry-wide analysis was to estimate the
change in industry-wide revenue. The percent change in revenue
is equal to the sum of the market price increase and the percent
change in output, plus their cross-product. The change in
revenue, in turn, is equal to the percent change in revenue
multiplied by baseline revenue. Revenue will increase in
response to a price increase if demand is relatively inelastic
and decrease if demand is relatively elastic (it does not change
if the elasticity is "unitary").
7.2.2.2 Per-facility Analysis.
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In the per-facility analysis, impacts were measured for both MWI
operators and offsite generators (defined in Chapter 4, Section
4.4). The impacts of control costs were assessed for MWI
operators and the impacts of higher commercial incineration fees
were assessed for offsite generators.
Capital and total annualized control costs for MWI operators were
established in Chapter 5, Section 5.3. Unlike MWI operators,
offsite generators have no capital control costs. Higher fees
for commercial incineration imply incremental annual costs,
however. Incremental annual costs of offsite (commercial)
incineration were calculated for offsite generators by
multiplying average per-ton total annualized control costs for
commercial incineration (see Chapter 5, Table 5-10) by estimated
total waste generated annually per facility. For the per-ton
control costs, it was assumed that the NSPS and Emission
Guidelines are of equal stringency. This results in costs of
$9/ton under Control Option 1, $25/ton under Control Option 2,
$86/ton under Control Option 3, and.$259/ton under Control Option
5. Total waste generated annually per facility was estimated by
disaggregating industry-wide total waste generated (see Chapter
4, Table 4-1) by employment. This uses employment as a scale
factor, and assumes a constant ratio of waste generated to
employment. Also, by using total waste generated annually in the
calculation, it is assumed, conservatively, that 100 percent of
waste generated., is sent offsite to be incinerated.
The per-facility analysis was triggered by calculating the
"facility price increase," which is the price increase necessary
for an individual facility to recover control costs. For MWI
operators, the facility price increase is calculated as the ratio
of total annualized control cost to revenue. For offsite
operators, it is calculated as the ratio of the incremental
annual cost of offsite incineration to revenue.
As demonstrated in Figure 7-1, the facility price increase was
then compared to the market price increase (in this way, the
industry-wide and per-facility analyses are linked). If the
facility price increase was less than one percentage point higher
then the market price increase, it was judged to be achievable
(market structure was also considered in this assessment). This
is based on the premise that facilities are constrained to set
prices that are not far out of line with the average industry-
wide price.
As Figure 7-1 demonstrates for MWI operators, if the facility
price increase is achievable, onsite incineration can be
continued. This does not rule out substitution from occurring,
however. Recall from Chapter 6, Tables 6-1 and 6-2 that relative
to the costs of onsite autoclaving and offsite incineration, the
cost of onsite incineration increases under the NSPS and Emission
Guidelines, especially as the control options become more
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fSI
.1*1
in
i
t-
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stringent. As a result, onsite autoclaving and/or offsite
incineration are less expensive than onsite incineration in some
cases. It may therefore be cost-saving to substitute (though, as
discussed in Chapter -6, cost is not the only consideration in
choosing a.medical waste treatment and disposal method).
For facilities that may not be able to achieve the facility price
increase, two questions were then asked: 1) will absorbing the
portion of control costs that cannot be recovered with a price
increase result in an unsustainable decline in earnings?, and 2)
will capital generally be available to finance the investment in
controls?
The impact on earnings of absorbing control costs was gauged by
the ratio of total annualized control cost (or the incremental
annual cost of offsite incineration for offsite generators) to
before-tax net income. This measures the percent decrease in
before-tax net income if control costs are fully absorbed (i.e.,
if no price increase is achieved). In the short run, the
theoretical closure point is when variable costs exceed revenues.
Because some costs are fixed, net income would have to decline by
more than 100 percent for this closure threshold to be reached.
In the long run, on the other hand, firms are free to redeploy
assets to investments that yield higher rates of return.
Consequently, the closure point in the long run is when the rate
of return on capital falls below the opportunity cost of capital
(i.e., the rate of,,return on the best alternative use of
capital). To account for the' greater vulnerability to closure in
the long run, a 10 percent decrease in before-tax net income
resulting from full absorption of control costs was used as the
criterion for a significant, or unsustainable, impact.
The availability of capital to MWI operators (offsite generators
have no capital control costs) was gauged by 1) the ratio of the
capital control .cost to before-tax net income and 2) the ratio of
the capital control cost to total liabilities. The first
measurement gives an indication of the ability to finance the
investment from internal cash flow (before-tax net income is used
as a proxy for cash flow). A value exceeding 100 percent was
taken to indicate that debt may have to be issued (normally for
an investment in pollution controls, it is assumed-that equity
will not be issued because the investment does not add to
productive capacity). The second measurement indicates the
impact on capital structure in the event debt is issued. A value
exceeding 20 percent was taken to indicate that debt capital may
not be readily available. This considers that creditors are
reluctant to lend to firms with a high degree of financial
leverage (i.e., high ratio of debt to net worth) because there is
^a high risk that debt cannot be repaid. An exception was made,
"however, if the facility price increase is achievable. Because
total annualized control cost includes the annualized cost of
capital, comprising depreciation and interest, achieving, the
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facility price increase implies that additional cash flow will be
generated to service new debt. In theory, the capital markets
should recognize this and make financing available, regardless of
the impact of the new debt on total liabilities.
;:If, in the event that the facility price increase is not
achievable,- neither the impact on net income of full;cost
absorption nor the availability of capital is prohibitive, MWI
operators (Figure 7-1) can continue onsite incineration, though,
again, substitution may take place, depending in part on which is
lower-cost. If either is prohibitive, however,_onsite
incineration will have to be terminated. In this event,
substitution will be necessary in order to avoid closure — or at
least to avoid the termination of operations that result in, or
are dependent on, the generation of medical waste.
In Chapter 6, it was seen that with some restrictions, applying
mainly to pathological waste, substitution for onsite
incineration of medical waste is feasible. The feasibility of
substitution is further suggested by the fact, as indicated in
Chapter 4, Table 4-4, that over half of all hospitals and an even
greater majority of nursing homes, veterinary facilities, and
research labs currently do not operate an MWI. Although the
impacts of control costs can be avoided by substituting, there
are also incremental costs associated with substituting. These
costs were presented in Chapter 6, Tables 6-4 and 6-5.
To determine the impacts of substitution, per-facility
incremental total annualized costs of substitution were assessed
in the same way that per-facility total annualized control costs
were. First, the price increases necessary to recover the _
incremental costs of switching to onsite autoclaving and offsite
-incineration were measured. -These were calculated as the ratio
.of the incremental total annualized cost of substitution to
revenue. A price increase exceeding one percent was considered
potentially unachievable. Secondly, if the price increase was
potentially unachievable, the impact on net income of full
absorption of incremental substitution costs was measured, ^his
was calculated as the ratio of the incremental total annualized
cost of substitution to before-tax net income. A decrease in
before-tax net income exceeding 10 percent was considered
significant in the long run.
7.2.3 Analysis of Impacts on Taxpayers
There are three primary ways in which the NSPS and Emission
Guidelines will impact taxpayers. First, taxpayers^! 11
indirectly subsidize tax-exempt debt issued by public and some
not-for-profit institutions to finance the investments in
pollution controls. This is because tax-exempt debt results in a
tax-revenue shortfall for the government that must ultimately be
>made up for by other taxes. Measuring this impact was beyond the
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scope of the analysis. Secondly, taxpayers will underwrite the
costs to government programs that pay for health care. In the
long run, it can be expected that, on average, about 35 percent
of the price increases achieved by health care providers will be
passed on to taxpayers (in the form of higher taxes). This is
because government programs pay for about 35 percent of health
care in the U.S. -(in 1987, Medicare 16.2%, Medicaid 9.9%, other
government programs 8.9%).3 Thirdly, taxpayers will pay for the
costs to public establishments. Medical waste generators that
are exclusively government-owned include fire departments and
correctional facilities. Many hospitals are also public. In
addition, it is possible that some tax-exempt nursing homes,
commercial research laboratories, outpatient clinics, and
dentists' clinics are government-owned.
The last of these three impacts was gauged by calculating the
annual per-capita impact of full absorption of control costs for
three of the above categories of public establishments: public
hospitals, fire departments, and correctional facilities.
Impacts were calculated by dividing per-facility total annualized
control costs by the average populations of the types of
government units,in the U.S. that have jurisdiction over
hospitals, fire departments, and correctional facilities. Six
types of government units operate hospitals: Federal, state,
county, municipal, township, and special-district. Fire
departments are operated by county, municipal, township, and
special-district governments. Correctional facilities are
operated by Federal, state, county, and municipal governments.
Total annualized control costs for hospitals followed from
assigning the Intermittent 8,400 to Federal and local (including
,,, county, municipal, township, and special-district) hospitals
because they average 100-299 beds (296 and 113, respectively),
and from assigning the Intermittent 21,000 to state hospitals
because they average 300+ beds (387). Fire departments and
correctional facilities are offsite generators. Therefore,
incremental annual costs of offsite incineration were used.
Total population was used as a substitute for the total number of
taxpayers, which is not known for the different types of
government units. Since not all residents are taxpayers, per-
capita impacts underestimate impacts per taxpayer.
7.3 FINDINGS
7.3.1 Industry-wide Impacts
For all control options under both the NSPS and Emission
^Guidelines, the market price increase is less than one percent in
all_but two of the industries that generate medical waste. This
is in large part due to the predominance in every industry of
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facilities that do not operate an MWI. The two exceptions are
•' veterinary facilities and commercial research labs under Control
Option 5.
•Owing to a small market price increase and/or relatively
inelastic demand, all impacts on industry-wide output,
employment, and revenue in industries generating medical waste
are likewise minor. Output impacts in all but two industries,
for example, are less than one percent. Under the most stringent
control scenario — Control Option 5 — output declines by less
than 0.1 percent in the majority of industries, including
hospitals.
Although it is sizable, the market price increase was not
calculated for the commercial incineration industry. This is
because it is expected to be achievable as a result of the
increase in the demand for alternatives to onsite incineration,
including offsite incineration, that will be brought about by the
NSPS and Emission Guidelines. It is expected that the demand for
offsite incineration will increase to offset the negative impact
on output of control---costs. • Already, •commercial incineration
capacity is tight in the face of growing demand (see Chapter 6).
The NSPS and Emission Guidelines will?.--give impetus to this demand
growth by increasing the relative cost of onsite incineration.
Given these forces, a contraction in industry output, or in the
rate of growth in industry output, is unlikely. One implication
of no adverse impact on output is that prices can be raised to
fully recover control costs. This is because profitability must
be undiminished (implying full recovery of control costs) in
order for regulated facilities to have the incentive to maintain
their level of, or rate of growth in, output.
> 7.3 '.2 ' Per-facility Impacts'
7.3.2.1 MWI Operators^
MWI operators in the following cases may not be able to recover
control costs with a price increase because the facility price
increase exceeds the market price increase by more than one
percentage point (the assigned model MWIs are in parentheses):
— Hospitals with fewer than 50 beds under Control Options
3 and 5 of both the NSPS and Emission Guidelines (Batch
250)
This analysis was completed before a decision was made to
exclude pathological MWIs from the proposed rules. Therefore, any
• impacts noted for pathological MWIs are no longer relevant for the
- -proposed rules.
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— Hospitals with 50-99 beds under Control Option 5 of
both the NSPS and Emission Guidelines (Pathological
2,000, Intermittent 2,000)
— A limited number of hospitals with 100+ beds (including
tuberculosis hospitals, of which there are only four
nationwide) under Control Option 5 of both the NSPS and
Emission Guidelines (Intermittent 8,400)
— Nursing homes with 100+ employees under Control Options
3 and 5 of both the NSPS and Emission Guidelines
(Intermittent 8,400; for the Emission Guidelines only,
Pathological 2,000; Intermittent 2,000)
— Veterinary facilities with 10-19 employees under
Control Options 2, 3, and 5 of the NSPS, and Control
Options 1, 2, 3, and 5 of the Emission Guidelines
(Pathological 2,000, Intermittent 2,000)
— Veterinary facilities with 20+ employees under Control
Options 3 and 5 of both the NSPS and Emission
Guidelines (Pathological 2,000, Intermittent 2,000)
— Tax-paying commercial research labs with 20-99
'-""employees under Control Options 3 and 5 of both the
NSPS and Emission Guidelines (Pathological 2,000,
Intermittent 2,000)-
— Tax-exempt commercial research labs (average number of
employees equals 148) under Control Option 5 of the
NSPS and Emission Guidelines (Intermittent 8,400)
Note that no cases involve the three largest model MWIs, the
Continuous 36,000, Intermittent 21,000, and Continuous 24,000.
With respect to the Continuous 36,000, this is because it is
modeled as a commercial MWI and, as explained earlier, commercial
incineration facilities are expected to be able to recover
control costs. With respect to the Intermittent 21,000 and
Continuous 24,000, this is because they offer economies of scale
to facilities generating a sufficient amount of medical waste.
The following types of MWI operators, in turn, may have to
terminate onsite incineration because control costs may be
prohibitive, i.e., the impact on earnings of full-cost absorption
may be unsustainable and/or capital to finance the investment in
controls may not be readily available (assigned model MWIs in
parentheses):
— Hospitals with fewer than 50 beds under Control Options
3 and 5 of both the NSPS and Emission Guidelines (Batch
250)
— Hospitals with 50-99 beds under Control Option 5 of
both the NSPS and Emission Guidelines (Pathological
2,000, Intermittent 2,000)
— A limited number of hospitals with 100+ beds (including
tuberculosis hospitals, of which there are only four
nationwide) under Control Option 5 of both the NSPS and
Emission Guidelines (Intermittent 8,400)
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— Nursing homes with 100+ employees under Control Options
3 and 5 of both the NSPS and Emission Guidelines
(Intermittent 8,400; for the Emission Guidelines only.
Pathological 2,000; Intermittent 2,000)
— Veterinary facilities with 10-19 employees under
Control Options 3 and 5 of both the NSPS and Emission
Guidelines (Pathological 2,000, Intermittent 2,000)
— Veterinary facilities with 20+ employees under Control
Option 5 of both the NSPS and Emission Guidelines
(Pathological 2,000, Intermittent 2,000)
— Tax-paying commercial research labs with 20-99
employees under Control Options 3 and 5 of both the
NSPS and Emission Guidelines (Pathological 2,000,
Intermittent 2,000)
— Tax-exempt commercial research labs (average number of
employees equals 148) under Control Option 5 of the
NSPS and the Emission Guidelines (Intermittent 8,400)
If onsite incineration must be terminated, it.will be necessary
to substitute in order to avoid shutting down ?operations that
result in, or are dependent on, the generation of medical waste.
For most of the cases in which-substitution may be necessary; :
there is at least one medical waste treatment alternative (onsite
autoclaving or offsite incineration) with incremental costs that
could be recovered with a price increase under one percent. This
includes all cases of hospitals.
There are no capital costs associated with switching to offsite
incineration. Onsite autoclaving, on the other hand, does have
capital costs. Estimated capital costs of new autoclave systems
and newly built MWIs were compared in Chapter 6, Table 6-3. The
capital costs of new autoclave systems are lower across-the-
board. Since it is implicit in the projection of new MWI sales
that capital costs can be financed, it follows that the capital
costs of new autoclave systems that are substituted for a newly
built MWI can also be financed. Comparing Table 6-3 with Table
5-1 in Chapter 5, it is seen that the capital costs of new
autoclave systems are comparable to capital control costs under
Control Option 2 of the Emission Guidelines. Since it was
concluded that capital costs under Control Option 2 of the
Emission Guidelines can be financed, it follows that the capital
costs of new autoclave systems that are substituted for an
existing MWI can also be financed.
In the following three cases, however, the price increase
necessary to recover incremental substitution costs may not be
achievable because it exceeds one percent, and earnings would be
significantly impacted (i.e., would decline by more than 10%) if
incremental substitution costs were fully absorbed:
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— Nursing homes with 100+ employees that operate the
Pathological 2,000 under Control Options 3 and 5 of the
Emission Guidelines only
— Veterinary facilities with 10-19 employees that operate
the Pathological 2,000 under Control Options 3 and 5 of
both the NSPS and Emission Guidelines
— Tax-paying commercial research labs with 20-99
employees that operate the Pathological 2,000 under
Control Options 3, and 5 of both the NSPS and Emission
Guidelines
Note that all three cases involve the Pathological 2,000.
However, since the analysis has been completed, a decision has
been made to exclude pathological MWIs from the proposed rules.
7.3.2.2 Offsite Generators.
For the model facilities classified as offsite generators in
Chapter-^, -.Table--4'-5, all. facility price increases are less than
0.7 percent. They are.therefore considered achievable. As a
result, there are no adverse impacts on earnings. Capital
availability is not an issue because offsite generators do not
have capital control costs.
Since MWI operators and offsite generators coexist in all
industries that generate medical waste, the model facilities
classified as MWI operators in Chapter 4, Table 4-5 also
represent some offsite generators. Economic impacts could not be
calculated for these offsite generators because comparative scale
parameters (e.g., revenue) for MWI operators and offsite
generators are not known. For example, it is likely that among
nursing homes with 100+ employees (classified as MWI operators),
MWI operators are larger on average than offsite generators. How
much larger-is not known.
However, it can be said that, on average, offsite generators will
be impacted less by the NSPS and Emission Guidelines than MWI
operators of comparable size. This is because commercial MWIs
are larger than average and therefore have comparatively low
control costs per ton. Further, offsite generators are no doubt
less dependent on offsite incineration, on average, than MWI
operators are dependent on onsite incineration. An offsite
generator with no dependence on offsite incineration, for
example, will not be directly impacted by the NSPS and Emission.
Guidelines (there may be indirect impacts if the demand for, and
as a result the price of, alternative medical waste treatment
methods increases).
In some situations, an offsite generator could experience similar
impacts to an MWI operator of comparable size. The offsite
generator would have to be as dependent on offsite incineration
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as the MWI operator is dependent on onsite incineration (normally
100%), and would have to rely on incineration by a commercial MWI
that is comparable in size and efficiency to the MWI used by the
onsite operator. In addition, the commercial MWI operator would
fhave to fully pass along the pro rata share of control costs 'to
the offsite generator (because medical waste treatment and
disposal capacity is at a premium, this is expected to occur).
7.3.3 Impacts on Taxpayers
Annual per-capita impacts of control costs for Federal and state
hospitals are insignificant, ranging up to only eight cents for
state hospitals under Control Option 5 of the NSPS, and nine
cents for state hospitals under Control Option 5 of the Emission
Guidelines. Per-capita impacts for local hospitals are higher,
ranging up to $101.16 under Control Option 5 of the NSPS, and
$104.91 under Control Option 5 of the Emission Guidelines. These
impacts are accounted for by township hospitals. Among
government units operating hospitals, townships have the lowest
average population, 3,119. It is likely to be rare, however, for
a facility operating'ari MWI to be under the jurisdiction of a
government unit with a population of only several thousand.
Therefore, per-capita impacts, for hospitals — or any other,type
of facility, for that matter — operating an MWI are not
considered to be significant, in general. In any case, if any
impacts are significant, they can be avoided by substituting.
Per-capita impacts for fire departments and correctional
facilities are negligible. At the most they are only eight
cents.
7.4 CONCLUSIONS , .. .
•Because industry-wide output impacts are small, the NSPS and
Emission Guidelines are not expected to significantly affect
market structure or competition in any regulated industry. No
industry should require significant restructuring such as through
closures or consolidations.
Substitution will be a major impact of the NSPS and Emission
Guidelines not only because it will be necessary in some cases in
order to avoid prohibitive impacts of the control costs, but also
because it can be cost-saving (though,'as discussed, cost is not
the only consideration in choosing a medical waste treatment and
disposal method). In Chapter 6, Tables 6-1 and 6-2, it was seen
that relative to the costs of onsite autoclaving and offsite
incineration, the cost of onsite incineration increases under the
NSPS and Emission Guidelines. As the control options increase in
stringency, there is a cost-saving alternative to more and more
MWIs. The likelihood of substitution is greatly influenced by
the control stringencies of the control options.
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There are few cases of a cost-saving alternative under the
Emission Guidelines. Because it is more stringent, the NSPS^will
result in a greater incidence of substitution than the Emission
Guidelines. Furthermore, there is likely to be a greater
incidence of substitution for small MWIs than for large MWIs.
This is because small MWIs have comparatively high per-ton cost
impacts from the NSPS and Emission Guidelines. As a result,
under the more stringent control options, cost savings from
substituting tend to be greater for small MWIs than for large
MWIs (see Chapter 6, Tables 6-1 and 6-2). Again, this applies
particularly to the NSPS because it is more stringent.
For new MWIs, substitution means that planned investments will be
foregone in favor of other medical waste treatment and disposal
methods. Onsite autoclaving and offsite (commercial)
incineration, and perhaps other alternatives such as offsite
(commercial) autoclaving, should benefit by experiencing
accelerated demand growth. For most of the model MWIs, onsite
autoclaving is a lower-cost alternative than offsite
incineration. r"-'-This suggests that onsite autoclaving may be the
more common substitute. Offsite incineration is a. lower-cost
alternative to the Batch 250, however. This suggests that
offsite incineration may be the more cost-effective alternative
for small facilities generating insufficient medical waste to
achieve low per-ton costs operating an autoclave system. Because
it requires no capital investment, offsite incineration may also
be more appropriate for facilities with limited capital (e.g.,
small facilities). Offsite incineration may also be necessary if
landfills or waste haulers are unwilling to accept autoclaved
waste. Finally, autoclaving cannot be used to treat some types
of medical waste, particularly pathological waste (as a result,
autoclaving is not a substitute for the Pathological 2,000).
Therefore, offsite incineration may be needed for supplementary
treatment. •
To the extent that substitution takes place, sales of onsite MWIs
will be adversely affected (sales of commercial MWIs are not
expected to be similarly affected because the demand for offsite
incineration will increase as a result of the NSPS and Emission
Guidelines). From Table 4-3 in Chapter 4, it can be calculated
that commercial incineration facilities account for 64.7 percent
of the capacity of projected new unit sales over the next five
years. Hospitals account for most of the remaining capacity —
31.9 percent. This implies — assuming a strong correlation
between the capacity and sale price of MWIs — that, as a result
of the NSPS, up to approximately one-third of the market for new
MWIs in the next five years could face competition from
alternative medical waste treatment methods. Actual erosion of
.the market will depend greatly on the extent of substitution by
"hospitals.
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This leaves open the possibility that some MWI vendors will go
out of business. Vendors with a high degree of concentration in
onsite, noncommercial MWIs would be most vulnerable. On the
other hand, vendors of autoclave systems and other alternative
medical waste treatment systems should benefit from the NSPS and
Emission Guidelines.
Because the NSPS is more stringent than the Emission Guidelines,
some MWI operators may be prompted to postpone replacing existing
.MWIs with new MWIs. This could adversely affect sales of both
commercial and noncommercial MWIs. Ultimately, existing MWIs
have to be replaced, but replacement may not occur until after
the market for new MWIs has been disrupted. It is not known
whether some MWI vendors might, as a result, go out of business.
7.5 IMPACTS ON SMALL ENTITIES
In accordance with the Regulatory Flexibility Act of 1980, it is
necessary to determine if the NSPS and Emission Guidelines will
have a "significant economic impact on a substantial number of
small entities." Small entities affected by the regulations
include small businesses, small not-for-profit organizations, and
small government jurisdictions.
The Small Business Administration (SBA) standard for a "small"
business is 500 employees or fewer for SIC 8731, Commercial
Physical and Biological Research (research labs), and annual
sales of $3.5 million or less for all other industries affected
by the NSPS and Emission Guidelines. The EPA "Guidelines for
Implementing the Regulatory Flexibility Act" (February 9, 1982)
suggest that not-for-profit organizations are "small" if they are
not-dominant in their field.4 " Government' jurisdictions are '
"small" if they have a population of 50,000 or less.
According to the EPA "Guidelines," the criterion for a
"substantial number" is 20 percent or more of all small entities
impacted by a regulation.
The impacts of control costs may be significant for some small
government jurisdictions. However, in general, significant
impacts can be avoided by substituting. Moreover,-the number of
• government jurisdictions that are significantly impacted should
not be "substantial." Not only will small government units with
jurisdiction over one or more MWI operators not typically be
significantly impacted, but the majority of small government
units probably have jurisdiction only over offsite generators,
rwhich in general are not significantly impacted.
-.Many small businesses and small not-for-profit organizations will
be impacted by the NSPS and Emission Guidelines. In fact,
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according to the SBA criteria, all regulated industries except
hospitals consist predominantly of small entities. Some of these
facilities may be significantly impacted by the NSPS and Emission
Guidelines. However, in general, significant impacts can be
avoided by substituting. In any case, the number of facilities
that are significantly impacted should not be "substantial."
This is in part because the great majority of small entities
generating medical waste do not operate an MWI.
Because they are not medical waste generators, commercial
incineration facilities cannot substitute, per se« However, due
to an increase in the demand for offsite incineration that will
result from the NSPS and Emission Guidelines, they are expected
to be able to fully recover control costs by increasing prices.
The NSPS and Emission Guidelines will also probably not have
differential impacts favoring large facilities. On the one hand,
due to economies of scale, relative impacts will be less for
large facilities that operate an MWI than for small facilities
that.operate an-MWI. On the other hand, offsite generators —
especially to the extent that they do not send their medical
waste offsite to be incinerated — will be impacted less, on
average, than MWI operators. Since MWIs tend to be operated by
large facilities, this results in differential impacts favoring
small facilities. Net differential impacts will depend on the
comparative strengths of these two countervailing tendencies.
Since the majority of facilities in all industries* in which
medical waste is generated are offsite generators, net
differential impacts will probably favor small facilities.
Because they do not generate medical waste, commercial
incineration facilities are an exception. However, although
relative impacts will most likely be greater for small commercial
incineration facilities than for. large ones, facilities of all
sizes are expected to be able to pass along control costs to
customers.
7-16
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8.0 BENEFITS ANALYSIS
The Agency has attempted to identify the potential environmental
benefits expected to result from implementation of the proposed
regulation. This chapter provides the following discussion: (1)
a qualitative description of health and environmental benefit
categories associated with implementation of the proposed
regulation and (2) a quantitative assessment of the benefit
categories previously described that can be readily monetized.
8.1 Qualitative Description of Benefits
This section qualitatively discusses the potential health and
welfare benefits associated with air emission reductions
resulting from implementation of the proposed regulations. The
proposed regulations are expected to reduce emissions of a wide
range of hazardous air pollutants as well as emissions of
criteria pollutants. The discussion will focUjS on .adverse health
effects resulting from exposure to the above pollutants as well
as welfare effects, such as effects on crops and other plant
life, resulting from exposure to ozone.
8.1.1 Hazardous Air Pollutants
Exposure to HAPs can cause a variety of adverse health effects.
Some hazardous air pollutants to be affected by the proposed
rules are classified as probable human carcinogens and therefore,
are .suspected of containing cancer-causing agents. These
-.hazardous air pollutants-have-not, been proven as,.human
carcinogens but are nevertheless, linked with causing adverse
health effects such as lesions or abnormal cell growth (which may
eventually -lead to cancer). The benefits of reducing emissions
of these non-carcinogenic HAPs is that adverse health effects
resulting from exposure to these pollutants will be decreased.
Several other pollutants are not classifiable as to their
carcinogenicity but there are documented health effects
associated with exposure to these pollutants. This section
describes some of these health effects.
Health Benefits of Reducing Hazardous Air Pollutant Emissions
According to baseline emission estimates, this source category of
medical waste incinerators currently emits approximately 41,000
.Mg of cadmium, hydrochloric acid, lead, and mercury annually.
The Emission Guidelines are expected to reduce these HAP
emissions by approximately 40,100 Mg annually. The Background
.Information Document provides a detailed explanation of the
8-1
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methods used to calculate pollutant emissions and emission
reductions.
The major pathways for human exposure to environmental
contaminants are through inhalation, ingestion, or dermal
contact. Airborne contaminants may be toxic to the sites of
immediate exposure, such as skin, eyes, and linings of the
respiratory tract. Toxicants may also cause a spectrum of
systemic effects following absorption and distribution to various
target sites such as liver, kidneys, and the central nervous
system.
Exposure to contaminants in the air can be acute, chronic, or
subchronic, Acute exposure refers to a very short-term (i.e.,
less than or equal to 24 hours), usually single-dose, exposure to
a contaminant. Health effects often associated with acute
exposure include: central nervous system effects such as
headaches, drowsiness, anesthesia, tremors, and convulsions;
skin, eye, and respiratory tract irritation; nausea; and
olfactory "effects- 'such as awareness of unpleasant or disagreeable
odors. Many of these effects are reversible and disappear with
cessation of exposure. Acute exposure to very high
concentrations or to low levels of highly toxic substances can,
however, cause serious and irreversible tissue damage, and even
death. A delayed toxic response may also occur following acute
exposure.
Chronic exposures are those that occur for long periods of time
(many months to several years). Subchronic exposure falls
between acute and chronic exposure, and usually involves exposure
for a period of weeks or months. Generally, the health effects
of greatest concern following intermittent or continuous long-
term exposures are those that cause either irreversible damage
and serious impairment to the normal functioning of the
individual,' such"'as cancer and organ dysfunction, or death.
The risk associated with exposure to a toxic agent is a function
of many factors, including the physical and chemical
characteristics of the substance, the nature of the toxic
response, and'the dose required to produce the effect, the
susceptibility of the exposed individual, and the exposure
situation. In many situations, individuals may be concurrently
or sequentially exposed to a mixture of compounds, which may
influence the risk by changing the nature and magnitude of the
toxic response.
Of the four HAPs identified, two pollutants - cadmium and lead,
are classified as a probable human carcinogens. Current baseline
emissions of cadmium are estimated to be 5.62 Mg/yr. Acute human
inhalation exposure to high levels of cadmium in humans may cause
adverse effects on the lung, such as bronchial and pulmonary
irritation. A single exposure to high levels of cadmium can
8-2
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result in long-lasting impairment of lung function. Chronic
-human exposure to cadmium in air may affect the lung, with
effects such as bronchitis and emphysema, the kidney, and the
nasal passages. Chronic oral exposure to cadmium in animals and
humans results in effects on the kidney, bone, immune system,
blood, and nervous system. The Emission Guidelines are expected
to reduce these cadmium emissions from existing sources by 5.40
Mg/yr. In addition, the NSPS is projected to reduce cadmium
emissions from new sources by approximately 1.32 Mg/yr.
MWI operations are estimated to emit approximately 77.53 Mg of
lead annually. Acute exposure to lead .has been shown to cause_
adverse effects such as gastrointestinal symptoms, such as colic,
brain and kidney damage, and even death. Chronic exposure to
lead can affect the blood, such as anemia, and the nervous
system, such as neurological symptoms and slowed nerve conduction
in peripheral nerves. Occupational exposure to high levels of
lead has been associated with a severe depression of sperm count
and decreased function of the prostate and/or seminal vesicles in
male workers and a high likelihood of spontaneous abortion in
pregnant women. Prenatal exposure to lead produces toxic effects
on the human fetus, including increased risk of preterm delivery,
low birth weight, and reduced mental activity. The Emission
Guidelines are expected to reduce lead emissions from existing
MWIs by 75.98 Mg annually. In addition, the NSPS is projected to
reduce lead emissions from new sources by 18.82 Mg annually.
The remaining two HAPs are not classifiable as to their human
carcinogenicity due to lack of sufficient scientific data.
However, adverse effects resulting from exposure to these
pollutants may give rise to toxic endpoints other than cancer and
gene mutations. Results.from human and/or animal studies provide
information on the types of adverse health effects associated
with exposure to these pollutants.
Baseline hydrochloric -acid emissions from existing MWIs are
estimated to be approximately 41,197 Mg annually. In humans,
acute inhalation exposure to HcL may cause coughing, hoarseness,
inflammation and ulceration of the respiratory tract, chest pain,
and pulmonary edema. Acute oral exposure may cause corrosion of
the mucous membranes, esophagus, and stomach, with nausea,
vomiting, and diarrhea reported. HC1 is corrosive-to the eyes,
skin, and mucous membranes. Chronic occupational exposure to
hydrochloric acid has been reported to cause gastritis, chronic
bronchitis, dermatitis, and photosensitization in workers.
Prolonged exposure to low concentrations may also cause dental
discoloration and erosion. The Emission Guidelines are expected
to reduce HC1 emissions from existing sources by approximately
39,961 Mg/yr. The NSPS are projected to reduce an additional
9,746 Mg of HC1 annually.
8-3
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Current annual emissions of mercury are estimated to be
approximately 58.57 Mg. Acute inhalation exposure to high levels
of elemental mercury in humans results in central nervous system
effects, such as hallucinations, delirium, and suicidal
tendencies. Gastrointestinal effects and respiratory effects,
such as chest pains, dyspnea, cough, pulmonary function
impairment, and interstitial pneumonitis have also been noted
from inhalation exposure to elemental mercury. Symptoms noted
after acute oral exposure to inorganic mercury compounds include
a metallic taste in the mouth, nausea, vomiting, and severe
abdominal pain. The acute lethal dose for most inorganic mercury
compounds, for an adult, is 1 to 4 grams. The central nervous
system is the major target organ for elemental mercury toxicity
in humans. Effects noted include erethism (increased
excitability), irritability, excessive shyness, insomnia, severe
salivation, gingivitis, and tremors. Chronic exposure to
elemental mercury also affects the kidney. The EG are expected
to reduce Hg emissions by approximately 52.57 Mg annually. The
NSPS are projected to reduce Hg emissions by approximately 13.05
;Mg annually." - •*•-:•• - -
Reduction in emissions of the above pollutants is expected to
reduce cancer risk as well as the occurrence of adverse health .
effects such as those described above. However, due to data
deficiencies, further quantification of the benefits associated
with these emission reductions is not possible. Table 8-1
presents a summary of the HAP emission reductions.
Since lack of data prevents the above benefit categories from
being monetized, it is expected that this omission will lead to
an underestimation of the health benefits associated with the
proposed regulations. The Agency cannot confidently characterize
the magnitude of the underestimation.
$
8.1.2 Dioxins
The proposed rules are expected to reduce emissions of 2,3,7,8-
chlorinated dibenzodioxins (CDD) and 2,3,7,8-chlorinated
dibenzofurans (CDF), isomers of dioxins. Baseline emission
estimates of CDD/CDF are estimated to be approximately 285 Kg
annually. Although 2,3,7,8-tetrachlordibenzo-p-dioxin (TCDD) is
listed as a HAP, its isomers are not. However, the health
effects described below are believed to result from exposure to
any of the three compounds - TCDD, CDD, or CDF. Table 8-2
provides a summary of the dioxin emission reductions. The
following discussion provides a brief description of the adverse
health effects associated with exposure to dioxins.
In humans, the most prevalent effect from exposure to CDD/CDF is
chloracne, a dermatological condition that is a direct result of
8-4
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Table 8-1
HAP Emission Reductions
Pollutant
Cd
HC1
Hg
Pb
EG (Mg/yr)
5.4
1,235.92
52.71
75 . 98
NSPS (Mg/yr)
1.32
9,746.23
13.05
18.83
Table 8.2
Dioxin Emission Reductions
Pollutant
CDD/CDF
EG (Kg/yr)
284.73
NSPS (Kg/yr)
.21.68
8-5
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exposure. The condition can be short-lived but has also been
known to persist in some patients for as long as 40 years.
There is evidence in some animal studies that dioxins cause
adverse reproductive and developmental effects. The fact that a
wide variety of developmental events, across several different
species can be affected, lends more support to the possibility
that similar effects could occur (possibly with different
severity levels) in humans.
Another health effect linked to dioxin exposure is a change in
hormone levels. Exposure to dioxins can cause some hormone
levels to decrease. The significance of these effects has not
been determined but this research has formed the basis for the
emerging concern for "environmental hormones." An association
between reproductive system and dioxin exposure has been seen in
monkeys but there are no studies showing a link in humans.
The EG is expected to reduce CDD/CDF emissions from existing
..-sources ^by^approximately 285 Kg/yr. The NSPS is expected to
reduce CDD/CDF emissions from new sources by approximately 21
Kg/yr.
Reductions in emissions of CDD/CDF is expected to reduce the
possibility of adverse health effects such as those described
above from occurring. However, lack of data prevents further
quantification of the benefits associated with these emission
reductions. Once again, the total monetized benefits estimates
are expected to be underestimated due to the omission of this
benefit category from total estimates.
8.1.3 Criteria Pollutants
.'.Particulate .matter (PM) and carbon monoxide (CO) are classified
as criteria pollutants by the EPA. Baseline emissions caused by
medical waste incineration are estimated to be approximately
11,300 Mg/yr. Baseline emissions of CO are estimated to be
approximately 13,100 Mg/yr.
The presence of PM emissions has been linked with not only
causing adverse health effects, such as exacerbating asthmatic
conditions, but also adverse welfare effects, such as materials
damage and household soiling. The EG is expected to reduce
baseline PM emissions to be approximately 10,800 Mg annually. In
addition, the NSPS is expected to reduce PM emissions from new
sources by approximately 1,600 Mg annually.
In the health category, health effects associated with PM
exposure include mortality as well as various types of acute and
chronic morbidity. Potential morbidity effects include increases
in respiratory distress, aggravation of existing respiratory and
8-6
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cardiovascular disease, impairment of the body's defense
mechanisms, damage to lung tissues, and carcinogenesis.
In addition, welfare effects such as soiling, visibility effects,
and acidic deposition effects on materials and
aquatic/terrestrial life are possible. For example, increases in
PM emissions may result in increased soiling of households,
requiring more frequent cleaning. Controlling PM emissions is
expected to reduce the adverse health and welfare effects
associated with these emissions.
The methodology used to value PM emission reductions is the
application of a benefit/Mg value established by the Agency in
1985 for the development of New Source Performance Standards. A
policy-based benchmark value of $3,457 (1989 $) was established
as an incremental cost-effectiveness, cut-off for the development
of NSPSs. The establishment of this value suggests that the same
value can be used to value PM emission reductions.
Applying the above value to the PM emission reductions, a total
benefit value of approximately $37.5 million-c-an be attributed to
the EG while a total benefit value of approximately $5.4 million
can be attributed to the NSPS.
The approach used in this analysis to monetize the benefits of
reduced PM emissions attempts to estimate the average benefit of
reducing a Megagram of PM emissions. The estimates represent
average values and do not reflect differences in the benefits of
achieving the first unit of emission reduction versus the
benefits of achieving the last unit of emission reduction. The
benefit estimates also ignore the impact of the value of each
unit in emission reduction or the geographic placement of the
emission 'reduction.
In addition, the proposed rules are expected to reduce emissions
of CO. The EG is expected to reduce baseline CO emissions by
approximately 12,800 Mg/yr. The NSPS is expected to reduce CO
emissions from new sources by approximately 1,500 Mg/yr. Lack of
data prevent further quantification of the benefits associated
with these emission reductions.
Table 8-3 presents a summary of the criteria pollutant emission
reductions as well as the monetized value of the PM emission
reductions.
8-7
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Table 8-3
Criteria Pollutant Emission Reductions and Benefits
(1989 $)
Pollutant
PM
CO
Emission Guidelines
Emission
Reduction
(Mg/yr)
10,843.85
12,797.31
Benefits
(million
$/yr)
37.490
NSPS
Emission
Reduction
(Mg/yr)
1,565.1
1,545.8
Benefit
(million
$/yr)
5.411
8-8
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9.0 BENEFIT/COST ANALYSIS
This chapter presents a comparison of the costs, emission
reductions, and partial benefits associated with the proposed
NSPS and EG.
Nationwide total cost estimates for both the NSPS and EG
represent costs of control option 5 (DI/FF with carbon) for
continuous, intermittent, and batch MWIs. Note that the costs_
presented in this chapter do not include the costs of controlling
pathological MWIs because pathological MWIs will not be regulated
under the proposed rules. Likewise, the emission reduction
estimates presented in this chapter reflect the same scenario.
Table 9-1 presents the total costs, emission reductions, and
quantified PM benefit estimates for the proposed regulations.
The NSPS total cost and emission reduction data represent the
impacts of new MWIs. The EG total cost and emission reduction
data represent the impacts of controlling existing MWIs.
As shown in Table 9-1, the total annual cost of implementing the
proposed NSPS is approximately $277 million. The regulation is
expected to reduce annual HAP emissions by almost 10,000 Mg,
annual criteria pollutant emissions by approximately 3,000 Mg,
and annual emissions of dioxins and furans by approximately 22
Kg. The quantified PM health and welfare benefits associated
with the NSPS is estimated at approximately $5.4 million
annually.
The total annual cost of imposing the proposed EG on existing
MWIs is approximately $1.4 billion. Implementation of the EG is
expected to achieve a total HAP emission reduction of
approximately 40,000 Mg/yr, a total criteria pollutant emission
reduction of approximately 24,000 Mg/yr, and a total CDD/CDF
emission reduction of approximately 285 Kg/yr. The quantified PM
health and welfare benefits expected to result from
implementation of the proposed EG is estimated to equal
approximately $37.5 million annually.
Due to data paucities, a direct comparison of the costs to the
total benefits of the proposed rules is not possible. Therefore,
gaps in the data do not allow a conclusion to be reached
regarding the efficiency of the proposed rules.
9-1
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TABLE 9-1
Costs, Emission Reductions, and Quantified. Benefits
(1989 $)
Total Annual Cost
($/yr)
Total HAP* Emission
Reduction (Mg/yr)
Total Criteria
Pollutant2 Emission
Reduction (Mg/yr)
Total CDD/CDF
Emission Reduction
(Kg/yr)
Quantified PM " ' "
Benefits
($ Million/yr)
NSPS
$277.3 million
9,779
3,111
22
$5.4
EG
$1.4 billion .
40,096
23,641
284
$37.5
1 Includes Pb, Cd, HC1, and Hg impacts.
•"Includes PM and CO impacts.
9-2
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-94-063a
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Medical Waste Incinerators - Background Information for
Proposed Standards and Guidelines: Regulatory Impact
Analysis for New and Existing Facilities
5. REPORT DATE
July 1994
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards Division (Mail Drop 13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D1-0143
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Published in conjunction with proposed air emission standards and guidelines for
medical waste incinerators
16. ABSTRACT
The Regulatory Impact Analysis attempted to compare the costs to the benefits expected to result from
the implementation of standards and guidelines. The cost and economic impact discussion is a summary
of information from the "Analysis of Economic Impacts" Reports (EPA-453/R-94-047a and EPA-453/R-
94-048a). A qualitative discussion of relevant benefit categories such as reduced adverse health and
welfare effects is presented. Due to lack of data regarding the benefits associated with reducing specific
pollutants, only a few benefit categories were quantified. Therefore, a direct comparison of costs to
benefits was not possible. This report is one in a series of reports used as background information in
developing air emission standards and guidelines for new and existing medical waste incinerators.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Pollution Control
Standards of Performance
Emission Guidelines
Medical Waste Incinerators
Air Pollution Control
Solid Waste
Medical Waste
Incineration
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
84
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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MRI
MIDWEST RESEARCH INSTJTU
Suite:
401 Harrison Oaks Boulev
Cary. North Carolina 27513-2-
. Telephone (919) 677-0:
FAX(919)677-CK
A-91-61
: me 009
Date: January 30, 1995 .
Subject: Regulatory Impacts of the Proposed New Source
Performance Standard (NSPS) and Emission Guidelines
(EG) for Medical Waste Incinerators (MWI's)
EPA Contract No. 68-D1-0115; Work Assignment NO. 75
ESD Project No. 90/17; MRI Project No. 6502-75
From: Brian Strong
Suzanne Shoraka-Blair
To: Rick Copland, EPA
ESD/SDB/RDS (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
I. Introduction
The purpose of this memorandum is to present cost impacts
and energy and environmental impacts of baseline, maximum
achievable control technology (MACT) flo'or, and MACT levels of
control for the proposed NSPS and EG for MWI's. Section II
presents the regulatory background, Section III presents a
summary of the methodology used to perform the regulatory
analysis, Section IV .presents the results of the regulatory
analysis for new and existing MWI's and Section V presents the
references.
II. Background
The proposed NSPS would implement Sections lll(b) and 129
of the Clean Air Act (Act) as amended in 1990 and the proposed EG
would implement Sections lll(d) and 129 of the Act. The intent
of Section 129 and the proposed NSPS and EG is to require new and
existing MWI's to control emissions of air pollutants to levels
that reflect the degree of emission reduction based on MACT,
considering costs, nonair quality health, and environmental and
energy impacts.
Section 129 of the Act states that the Administrator may
distinguish among classes, types, and sizes of units within a
category in establishing the standards. After reviewing the
population of MWI's, it was determined that, for the purpose of
regulatory development and of determining .MACT, the MWI
population should be divided into three subcategories:
(1) continuous MWI's, (2) intermittent MWI's, and (3) batch
MWI's. While there are similarities in the three design types of
MWI's, there are also key differences that make each type unique.
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The primary differences between the three design types of MWI's
are the method of charging waste to and removing ash from the
primary chamber. These differences cause variations in the way
the waste is burned and in the pollutant emission profile for
each MWI design type. The basic differences are discussed
briefly in the following paragraphs. . *
Continuous units, which are the largest of the three types,
have mechanical ram feeders and continuous ash removal systems.
These features allow the unit to operate 24 hours per day for
many days at a time.' Continuous MWI's achieve steady-state
operation in the beginning of their operating cycle and maintain
this mode of operation throughout the remainder.of the cycle.
Waste is charged and ash is removed simultaneously. During this
period, waste is burned at the same rate as it is charged into
the unit and pollutant emission rates and primary and secondary
chamber temperatures tend to be relatively constant.
Most intermittent MWI's also have mechanical ram feeders
that charge waste into the primary chamber at about 5- to
10-minute intervals. However, because there is no means for ash
removal_during t> • burning cycle, the unit can only be operated
for a limited nu.r...ar of hours before the accumulation of ash in
the primary chamber becomes a problem. Intermittent units, which
are usually much smaller than continuous units, typically operate
on a daily burn cycle. While these units tend to approach
steady-state operation during the middle of their operating
cycle, waste is normally being charged faster than it is being
burned. Primary chamber temperatures tend to climb throughout
the operating cycle until waste is no longer charged into the
unit. Because there is a significant accumulation of unburned
material in the primary chamber at the end of the charging
period, these units are designed with a burndown/cooldown phase.
Generally, pollutant emissions continue throughout this phase,
which can proceed for several hours beyond charging.
The batch operating cycle consists of three phases--burn
(low-air), burndown (high-air) , and cooldown. All of the waste
to be burned during a complete burn cycle is loaded into the
primary chamber before the unit begins operation. Once the unit
is filled with waste and the burning cycle begins, the charging
door is not opened again until the cycle is complete and the unit
is cool. This cycle normally takes 1 or 2 days depending on the
size of the unit and the amount of waste charged. During the
burn phase, temperatures in the primary chamber rise slowly
because combustion is occurring only on the surface of the waste
Pi *£ because combustion air is restricted. When the bumdown
phase begins, the temperatures climb more rapidly, more volatiles
are exposed to the flame front, and the combustion process
quickens. Batch MWI's tend to approach steady state operation at
the end of the burn phase, when the primary chamber temperature
reaches the design operating rang Pollutant emission rates
also £end to increase in the second half of the burn phase, then
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level off, and continue steadily.during the burndown and cooldown
phases. Pollutant concentrations'during burndown in batch MWI's
are similar to concentrations during charging in continuous and
intermittent units.
To evaluate impacts, the baseline level of control and the
MACT floor need to be determined. For new and existing MWI's the
regulatory baseline reflects the level of emissions in the
absence of Federal regulations. The MACT floor for new MWI's is
defined as the level of emission control achieved by the best
controlled similar unit, and the MACT floor for existing MWI's is
defined as the average emissions limitation achieved by the best
performing 12 percent of units. The regulatory baseline, MACT
floor and MACT levels for each subcategory (continuous,
intermittent and batch MWI's) are defined below and presented in
Tables l and 2.
Continuous MWI's are typically found at; commercial waste
disposal facilities, large hospitals, and large research
laboratories. At the regulatory baseline, the typical new and
existing continuous MWI includes a secondary combustion chamber
with a 1-sec gas residence time at a temperature of 1700°F and no
add-on air pollution control system. The MACT floor for new
continuous MWI's is a DI/FF system with carbon injection. The
MACT floor for existing continuous MWI's is based on the emission
levels that are achievable with a DI/FF system without carbon
injection.1'2 For both new and existing continuous MWI's, the
level of emission control achieved by a DI/FF system with carbon
injection is considered MACT.
Intermittent MWI's are typically found at hospitals,
nursing homes, veterinaries, and research laboratories. At the
regulatory baseline, the typical new intermittent MWI includes a
secondary combustion chamber with a 1-sec gas residence time at a
temperature of 1700°F and no add-on air pollution control system,
the typical existing intermittent MWI includes a secondary
combustion chamber with a 0.25-sec gas residence time at a
temperature of 1700°F and no add-on air pollution control system.
The MACT floor for new intermittent MWI's is based on the
emission levels that are achievable with a DI/FF system with
carbon injection. The MACT floor for existing intermittent MWI's
is based on the emission levels that are a DI/FF system without
carbon injection.1'2 For both new and existing intermittent
MWI's, the level of emission control achieved by a DI/FF system
with carbon injection is considered MACT.
Batch MWI's are typically found at small hospitals. At the
regulatory baseline, the typical new batch MWI includes a
secondary combustion chamber with a 1-sec gas residence time at a
temperature of 1700°F and no add-on air pollution control system
At the regulatory baseline, the typical existing batch MWI
includes a secondary combustion chamber with a 0.25-sec gas
residence time at a temperature of 1700°F and no add-on air
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batch iS?.S °* Astern. 1< 2 The MACT "oor for new and existing
55£?»^K/Sp OTSiStS °f the emission l^els that are achievable
SiatinS £? Sy5^? wijhout carbon injection. For both new and
existing_batch MWI's the level of control achieved by a DI/FF
system with carbon injection is considered MACT.
111• Methodology of Regulatory Analysis
This section presents the methodology used to develop the
cost_and energy and environmental impacts, discussed in
°Sf IXITA S2d IP"B' respectively.- Nationwide emissions and
were also developed for a scenario that assumes that in
£he stringency of the proposed-regulations, some new and
^^3 may de.Cide t0 use an Alternative to onsite
to dispose of their waste. The methodologies used
«.?S^imate these impacts are discussed in Section III-C. The
toTevaluate the economic impacts are discussed
In sorne cases/ this section also includes
MWI types- The ^sults of the
A. Costs
„„„,.,. T^1?? 3 and,f Present the total annual costs for each
control option applied to the six model combustors . 3 • * These
inKL??? Plotted "in Figures 1 and 2 for the new continuous and
intermittent model combustors, and Figures 3 and 4 for the
existing continuous and intermittent model combustors
ThS followin9 observations can be drawn from these
,,««- 1; For a Siven model combustor, the annual costs for all
wet systems are generally within the same range.
=„* r,J*t™ F°r a Sfiven model combustor, the annual costs for DI/FF
and FF/PB systems with and without carbon are within the same
range. These costs are higher than costs for the wet systems.
\-^?ur a 5iyen model combustor, the annual costs for SD/FF
£ *-£ wjthout carbon are within the same range and are
than those for all other systems.
h^t-oH ^Laimuai costs for each control option as applied to the
batch model combustor follow these same relationships.
B- Energy and Environmental Impacts
The energy and environmental impacts analysis is an
evaluation of air pollution, water pollution, solid wlste
f«Se»^i0n; and ener^y consumption associated with the MACT floor
asd^=?LSKr:Lngent contro1 levels. Wastewater impacts are
estimated because some of the control systems evaluated generate
-------
these effluents. However, none of the control systems at_the
MACT floor or MACT control levels, lead to any wastewater impacts.
Solid waste impacts include estimates of bottom ash and baghouse
ash. Energy requirements include estimates of additional
auxiliary fuel for combustion controls and additional electrical
energy for operation of the add-on control devices. The specific
impacts by model plant, subcategory, and nationwide are presented
in Sections IV-A and IV-B.
In addition to these impacts, estimates of annual ambient
pollutant concentrations from selected new-and existing model
combustors were also developed. These results were compared to
threshold concentration levels beyond which adverse health .
'effects or welfare effects may occur. The results of the
analysis indicate that:
l. None of the modeled maximum pollutant concentrations
exceed 15 percent of the established thresholds;
2. Maximum concentrations for all scenarios occur between
downwind distances of 20 and 100 meters for urban settings and
between downwind distances of 100 and 1,000 meters for rural
settings; and • - . -
3. The modeled maximum concentrations for each particular
scenario are greater for urban settings than they are for rural
sett-ings because in urban settings surrounding buildings impair
the dispersion of effluents.
C. Impacts of Alternative Disposal Methods
Onsite incineration is only one of several medical waste
treatment and disposal options. For some MWI's, the cost of the
equipment necessary to comply with the proposed NSES and EG will
make onsite incineration more expensive than other treatment and
disposal options. Consequently, many new facilities that would
have chosen onsite incineration may decide to use a less
expensive method of treatment and disposal, resulting in
substantially lower national annual costs. Also, many existing
facilities that currently operate an MWT may choose to switch to .
a less expensive waste disposal option. In general, facilities
with smaller waste treatment capacities will have a greater-
incentive to use less expensive treatment and disposal options
because their onsite incineration cost (per ton of waste burned)
will be higher. Facilities with larger amounts of waste to be
treated may have some cost advantages if they use lower cost
alternatives, but these advantages are not as significant due to
economies of scale. The fact that the majority of facilities in
each of the regulated industries do not operate onsite
incinerators indicates that there currently are viable
alternatives to onsite incineration. Two common alternatives are
offsite contract disposal (most commonly commercial incineration.
and onsite autoclaving.
-------
the Cost^f^omDfiaSci^^J^1 facHities wil1 ™*y depending on
facilities
•
The costs
new un.e3?Sd?gtSit:cSS;r.?aiBe assumPtions w«^ made as for
an
meet the proposed NS PS S PP ? c°ntrol equipment necessary to
-------
D. Economic Impacts •£-.
To evaluate the economic impacts of the proposed NSPS and
guidelines five major industry sectors were examined (hospitals,
nursing homes, veterinary facilities, commercial research
laboratories, and commercial medical waste incineration
facilities). The economic impact analysis for new and existing
MWI's examined each of these sectors as a whole to determine'
industrywide impacts. To assess the industrywide impacts of
control costs, the market price, increase resulting from the
proposed standards and guidelines was estimated for each
regulated industry. The market price increase may be thought of •
as an average price increase across each industry required to
recover control costs within each industry.
IV. Results' nf the Regulatory Analysis
This section presents the results of the regulatory
analyses for new and existing MWI's. Section IV-A presents
impacts by model plant; Section IV-B presents impacts by
subcategory and total nationwide impacts; Section IV-C presents
impacts of using alternative disposal methods Section IV-D
presents the economic impacts and Section IV-E presents the solid
waste impacts.
A. Impacts by Model Plant
A total of six new and six existing model combustors have
been developed to represent the MWI population. Table 7
summarizes the industries that typically use MWI's represented by
each model.3 As shown in Table 7, most of the model combustors
are generic, in that they may represent MWI's in more than one
industry. The models span the range of design capacities and
options offered by MWI manufacturers. A new or existing MWI in
any industry will be adequately represented by at least one of
the six models.
The regulatory impacts associated with the MACT floor and
MACT levels of control are presented in Tables 8 through 12 for
each new model combustor and in Tables 14 through 19 for each
existing model combustor.
B. Nationwide Impacts bv Subcatecrorv and Total Nationwide
Impacts
Nationwide regulatory baseline, MACT floor, and MACT
emissions and costs for new and existing MWI's are presented in
Tables 20 through 25 for each of the three subcategories. These
nationwide impacts were determined by multiplying the pollutant
levels and costs for each model plant by the estimated nationwide
MWI population for each model plant. The results of the
emissions and cost for each subcategory were then added to
determine the nationwide emissions and cost by subcategory.
-------
and s
NSPS and emissions gi
Also included in thlse
baghouse ash generated
mpacts of the
ln Tables 26 and 27-
"lount °f
have
expensive method of treatmen =n-
many existing MWl's mirchoose to 2i??°Jal-
°
that
a less
At the same time'
incineration. However,
from onsite
use of autoclaves
D-
emissions associated with the
S tn
and guideline!
a
and
NSPS
cost of the
this
«
,-h nationwide annualized
2:
f?Und in Tabls
hospitals th
(0.35*0.08 s 0.03)
the remaining market e
under the NSPS and for JSSh
guidelines, The market price
under the switching -
lncre*se of 0.03
Wa\U?ed to determine
each industry sector
°r Under the
-------
E. Solid Wasi-g Impacts
Solid waste impacts were estimated for new and existing
MWI's in two ways: (1) assuming all facilities would comply with
the proposed NSPS and guidelines and (2) assuming the "switching
scenario" (Tables 34 and 35). In the absence of Federal
?egSlat?ons (i.e., at the regulatory baseline) 421,192megagrams
(Mq) (464,284 tons) of medical waste are projected to be burned
annually in new MWI's in the fifth year after adoption of the
NsSP About 1.43 million Mg (1.58 million tons) of medical
waste'are burned annually in existing MWI',s in the absence of
regulation*. This quantity of waste burned would result in about
42 100 Mg/yr (46,400 tons/yr) and 143,000 Mg/yr
(158 000 tons/yr) , for 'new and existing MWI's' respectively, of
solid waste (bottom ash) disposed of in landfills. The amount of
bottom ash was determined by assuming that incineration reduces
the total amount of solid waste treated by 90 percent.
Under the no-switching scenario, the addition of acid gas
control using dry lime injection, and CDD/CDF and Hg control
Ssing activated carbon injection, would increase the quantity of
soiid waste for final disposal by 34,504 Mg/yr (38,034 tons/yr)
and 141 195 Mg/yr (155,641 tons/yr) for new^and existing MWI's
SsDectively*Under the no-switching scenario, the amount of
S3d wa^euitimately sent to landfills would be about 76,623
Mg/yr (84,462 tons/yr) and 284,488 Mg/yr (313,594 tons/yr), for
new and existing MWI's respectively.
The total amount of solid waste generated under the
switching scenario is a sum of (1) the bottom ash_and baghouse
ash for facilities that choose to continue to incinerate, and (2)
the amount of waste that is treated using an onsite autoclave
then landfilled. The amount of bottom ash generated was
estimated as 10 percent of the amount of waste that would
continue to be incinerated. Under the switching scenario the
amount of waste that would continue to be incinerated is the
portion of the total waste stream that is not assumed to be
treated using an onsite autoclave and landfilled. For example,
Table 35 shows that under the switching scenario, of the 1.58
million tons/yr of medical waste currently estimated to be burned
in existing MWI's, 489,000 tons/yr will be treated using an
onsite autoclave and landfilled. Therefore, it is estimated that
1.09 million tons/yr would continue to be incinerated. The
amount of bottom ash then is estimated at 109,000 tons/yr (10
percent of the amount incinerated.) Similarly, the total amount
• of baghouse ash generated was estimated based on generation rates
for individual model combustors for which the assumption was that
the model would continue to use incineration (i.e., not switch to
onsite autoclaving.)5 Under the switching scenario, the amount
of solid waste ultimately sent to landfills would be about
135,189 Mg/yr (149,020 tons/yr) and 284,488 Mg/yr _
(313 594 tons/yr) for new and existing MWI's respectively. This
quantity includes the increase in ash from the air pollution
-------
10
or over 91 million Mg/vr fioo mill-ion <-™«/„,-•* *.t._ :_ uaj- face
-------
11
$650-r
$600
24
26
28 30 32
MWI Capacity, Ib/day
(Thousands)
34
36
Figure 1. Annual control costs for new continuous MWl's,
$600
$550
o
8
1
O
8
10 12 14 16
MWI Capacity, ib/day
(Thousands)
18 20 22
Figure 2. Annual control costs for new intermittent MWI's
-------
12
$700
$650
' $600
$550- •
^ $500
^ ^ $450
| "g $400
1 | $350
| £ $300
I *-* $250
^ $200
$150
$100
$50
$0
24
26
28 30~ 32
MWI Capacity, Ib/day
(Thousands)
34
36
Figure 3. Annual control costs for existing continuous MWI's
$600
$0
8 10 12 14 16
MWI Capacity. Ib/day
(Thousands)
T
18
20 22
Figure 4. Annual control costs for existing intermittent MWl's.
-------
13
TABLE 1. CONTROL TECHNOLOGY BASIS FOR REGULATORY BASELINE, MACT
FLOOR, AND MACT FOR NEW MWI'S1'2
MWI subcategory
Continuous
Intermittent
Batch
Regulatory baseline
l-sec combustion
1-sec combustion
l-sec combustion
MACT floor
DI/FF with carbon
injection
DI/FF with carbon
injection
DI/FF without carbon
injection
MACT
DI/FF with carbon
injection
DI/FF with carbon
injection
DI/FF with carbon
injection
TABLE 2. CONTROL TECHNOLOGY BASIS FOR REGULATORY BASELINE, MACT
FLOOR, AND MACT FOR NEW MWI's1'
MWI subcategory
Continuous
Intermittent
Batch
Regulatory baseline
l-sec combustion
0.25 -sec combustion
0.25 -sec combustion
MACT floor
DI/FF without carbon
injection
DI/FF without carbon
injection
DI/FF without carbon
injection
MACT
DI/FF with carbon
injection
DI/FF with carbon
injection
DI/FF with carbon
injection
-------
14
-------
15
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-------
17
TABLE 7. SUMMARY OF MODEL COMBUSTORS3
Combustor type
Continuous
Intermittent
Batch
Model design
capacity
1,000 Ib/hr
1,500 Ib/hr
200 Ib/hr
600 Ib/hr
1,500 Ib/hr
200 Ib/hr
Applicable
industries
H^ L
C&
H, N, L, Vs
H, N, L, V
H, N, L, V
H, N, L, V
aCodes represent hospitals, nursing homes, laboratories, and
veterinaries.
bCode represents commercial facilities.
TABLE 8 . ANNUAL ENVIRONMENTAL IMPACTS AND COSTS FOR EACH
NEW CONTINUOUS 1,500 Ib/hr MWI-i''4'y
Impact
Primarv emissions:
PM
CO
ODD /CDF
HC1
SO2
NO.,
PbX
Cd
Hg
Costs:
Total annual costtt
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr {tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
11.46 (12.63)
10.93 (12.05)
1.5E-04 (1.6E-04)
69.25 (76.33)
1.25 (1.38)
8.38 (9.24)
0.13 (0.14)
9.1E-02 (l.OE-02)
0.10 (0.11)
293,704
649,779
MACT floor/MACT
DI/FF with carbon
0.72 (0.79)
0.54 (0.60)
2.7E-07 (3.0E-07)
3.47 (3.82)
1.25 (1.38)
8.38 (9.24)
2.5E-03 (2.8E-03)
3.7E-04 (4.1E-04)
l.OE-02 (1.1E-02)
747,485
972,374
alncludes annual cost of baseline.
-------
18
TABLE 9.
ANNUAL ENVIRONMENTAL IMPACTS AND CC
NEW CONTINUOUS 1,000 Ib/hr MWI^/4,
!OSTS FOR EACH
Primary emissions.
PM~~~
CO
CDD/CDF
HC1
SO,
NO..
Pbx
Cd
Hg
COStS:
Total annual cos'ta
Capital cost
Includes annual cost of baseline.
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
M3/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
3.51 (3.87)
3.35 (3.69)
4.4E-05 (4.8E-05)
21.20 (23.37)
0.38, (0.42)
2.57. (2.83)
3.9E-02 (4.3E-02)
2.9E-03 (3.2E-03)
3.0E-02 (3.3E-02)
169,095
520,871
3)
!)
!)
•!)
MACT floor/MACT
DI/FF with carbon
0.22 (0.24)
0.16 (0.18)
8.4E-08 (9.3E-08)
1.06 (1.17)
0.38 (0.42)
2.57 (2.83)
7.9E-04 (8.7E-04)
1.2E-04 (1.3E-04)
3.0E-03 (3.3E-03)
507,096
852,681
TABLE 10.
ANNUAL ENVIRONMENTAL IMPACTS AND COS
NEW INTERMITTENT 1,500 Ib/hr MWI
FOR EACH
PM
CO
CDD/CDF
HC1
SO2
NOV
Pbx
Cd
He
• ~
Costs:
Total annual costa
Capital cost
Mg/yr
Mg/yr
Mg/yr
Mg/yr
Mg/yr
Mg/yr
Mg/yr
Mg/yr
(tons/yr)
(tons/yr)
(tons/yr)
(tons/yr)
(tons/yr)
(tons/yr)
(tons/yr)
{tons/yr)
(tons/yr)
6.22 (6.86)
5.93 (6.54)
7.6E-05 (8.4E-05)
37.58 (41.43)
0.68 (0.75)
4.55 (5.01)
7.0E-02 (7.7E-02)
5.1E-03 (5.6E-03)
5.3E-02 (5.8E-02)
Includes annual cost of baseline.
MACT floor/MACT
DI/FF with
0
0
1.5E
1
0
4
1.4E
2.0E
.39
.30
-07
.88
.68
.55
-03
-04
5.3E-03
519
972
(0.
(0.
(1.
(2.
(0.
(5.
(1.
(2.
(5.
carbon
43)
33)
6E-
07)
75)
01)
5E-
2E-
8E-
07)
03)
04)
03)
,532
,374
-------
19
TABLE 11. ANNUAL ENVIRONMENTAL IMPACTS AND COSTS FOR EACH
TTOW TNTERMITTENT 600 lb/hr MWI-3'*'*
'
Primarv emissions :
PM
CO
CDD/CDF
HC1
SO,
NO,,
Pb
Cd
Hg
Costs :
Total annual cost*
Capital cost
"
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)'
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr { tons/yr)
$/yr
$
_______ -— s-=
Baseline
2.49 (2.74)
2.38 (2.62)
31E-05 (3.4E-05)
15.03 (16.57)
0.27 (0.30)
1.82 (2.01)
2.8E-02 (3.1E-02)
2.0E-03 (2.2E-03)
2.1E-02 (2.3E-02)
83,437
156,822
MACT floor/MACT
DI/FF with carbon
0.15 (0.17)
0.12 (0.13)
6.0E-08 (6.6E-08)
0.75 (0.83)
0.27 (0.30)
1.82 (2.01)
5.5E-04 (6.1E-04)
8.2E-05 (9.0E-05)
2.1E-03 (2.3E-03)
398,955
756,649
J======= '
alncludes annual cost of baseline.
TABLE 12
ANNUAL ENVIRONMENTAL IMPACTS AND COSTS FOR EACH
NEW INTERMITTENT 200 lb/hr MWIJ'*'y
•
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
S02
NOX
Pb
Cd
Hg
Costs:
Total annual costa
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
J=s=s======
sss^ — — — — —— —
Baseline
0.71 (0.78)
0.67 (0.74)
8.7E-06 (9.6E-06)
4.27 (4.71)
7.7E-02 (8.5E-02)
0.52(0.57)
7.9E-03 (8.7E-03)
5.8E-04 (6.4E-04)
6.0E-03 (6.6E-03)
52,626
95,266
=========
MACT floor/MACT
DI/FF with carbon
4.4E-02 (4.9E-02)
3.4E-02 (3.7E-02)
1.7E-08 (1.9E-08)
0.22 (0.24)
7.7E-02 (8.5E-02)
0.52 (0.57)
1.5E-04 (1.7E-04)
2.4E-05 (2.6E-05)
6.0E-04 (6.6E-04)
325,980
660,098
===== "
alncludes annual cost of baseline.
-------
20
TABLE 13.
=r
Impact
————
Primary emissions:
PM
CO
CDD/CDF
HC1
SO2
NO,,
Costgi
Total annual cost3
Capital cost
ANNUAL ENVIRONMENTAL IMPACTS AND COSTS FOR EACH
NEW BATCH MWI3/4/9
alncludes annual cost of baseline.
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
L '
Baseline
0.14(0.15)
0.32 (0.35)
8.7E-06 (9.6E-06)
0.41 (0.45)
7.3E-02 (8.0E-02)
0.22 (0.24)
4.4E-03 (4.8E-03)
1.6E-04 (1.8E-04)
3.1E-03(3.4E-03)
33,595
71,669
MACT floor
DI/FF without carbon
3.1E-02(3.4E-02)
1.5E-02 (1.7E-02)
•8.5E-07 (9.4E-07)
2.1E-02(2.3E-02)
7.35E-02 (8.0E-02)
0.22 (0.24)
8.7E-05 (9.6E-05)
6.5E-06 (7.2E-06)
3.1E-03 (3.4E-03)
296,840
644,647
MACT
DI/FF with carbon
3.1E-02 (3.4E-02)
1.5E-O2 (1.7E-02)
1.7E-08 (1.9E-08)
2.1E-02(2.3E-02)
7.35E-02 (8.0E-02)
0.22 (0.24)
8.7E-05 (9.6E-05)
6.5E-06 (7.2E-06)
3.1E-03 (3.4EO4)
301,313
646,418
TABLE 14. ANNUAL ENVIRONMENTAL IMPACTS AND COST*
EXISTING CONTINUOUS mnn iffgJ^SWs
FOR EACH
Impact
"•"•^™*ni
imarj
PM
CO
CDD/CDF
HC1
SO,
Pb
Cd
Hg
Costs:
Total annual cost*
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
11.46(12.63)
10.93 (12.05)
1.5E-04 (1.6E-04)
69.25 (76.33)
1.25(1.38)
8.38 (9.24)
0.13(0.14)
9.1E-02(1.0E-02)
0.10(0.11)
293,704
alncludes annual cost of baseline.
4)
2)
==
— • •saaa^^ssssaa-g—
MACT floor
DI/FF without carbon
0.72 (0.79)
0.54 (0.60)
1.4E-05 (1.5E-05)
3.47 (3.82)
1.25 (1.38)
8.38 (9.24)
2.5E-03 (2.8E-03)
3.7E-04(4.1E-04)
0.10(0.11)
734,841
1,071,139
=f===========>==m===n=— ,
MACT
DI/FF with ctrboo
0.72(0.79)
0.54 (0 60)
2.7E-07C30E-07,
3.47 (3.82)
1.25(1.31)
8.38(924)
2.5E-03 (2.8E-03)
3.7E-04(4 1E-04)
1.0E-02(1.IEO2)
777.78''
1,078.373
-------
21
TABLE 15. ANNUAL ENVIRONMENTAL,. IMPACTS AND COST£
EXISTING CONTINUOUS 1,000 lb/hr MWI3'4'-
FOR EACH
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
so2
NOX
Pb
Cd
Hg
Costs:
Total annual costa
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
6.58 (7.25)
7.81 (8.61)
1.7E-04 (1.9E-04)
21.20 (23.37)
0.38 (0.42)
2.57 (2.83)
3.9E-02 (4.3E-02)
2.9E-03 (3.2E-03)
3.0E-02 (3.3E-02)
161,074
MACT floor
DI/FF without carbon
0.22 (0.24)
0.16(0.18)
4.2E-06 (4.6E-06)
1.06 (1.17)
0.38(0.42)
2.57 (2.83)
7.9E-04 (8.7E-04)
1.2E-04 (1.3E-04)
3.0E-02 (3.3E-02)
500,235
924,645
MACT
DI/FF with carbon
0.22 (0.24)
0.16(0.18)
8.4E-08 (9.3E-08)
1.06 (1.17)
0.38 (0.42)
2.57 (2.83)
7.9E-04 (8.7E-04)
1.2E-04 (1.3E-04)
3.0E-03 (3.3E-03)
515,556
930,317
alncludes annual cost of baseline.
TABLE 16. ANNUAL ENVIRONMENTAL IMPACTS AND COSTS FOR EACH
EXISTING INTERMITTENT 1,500 lb/hr MWI3'4'9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
S02
NOX
Pb
Cd
Hg
Costs:
Total annual costa
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
11.66(12.85)
13.84 (15.26)
3.1E-04(3.4E-04)
37.58 (41.43)
0.68 (0.75)
4.55 (5.01)
7.0E-02 (7.7E-02)
5.1E-03(5.6E-03)
5.3E-02 (5.8E-02)
108,407
MACT floor
DI/FF without carbon
0.39(0.43)
0.30 (0.33)
7.4E-06 (8.2E-06)
1.88(2.07)
0.68 (0.75)
4.55 (5.01)
1.4E-03 (1.5E-03)
2.0E-04 (2.2E-04)
5.3E-02 (5.8E-O2)
508,094
1,071,139
MACT
DI/FF with carbon
0.39(0.43)
0.30 (0.33)
1.5E-07 (1.6E-07)
1.88 (2.07)
0.68 (0.75)
4.55(5.01)
1.4E-03 (1.5E-03)
2.0E-04 (2.2E-04)
5.3E-03 (5.8E-03)
532,920
1,078,373
alncludes annual cost of baseline.
-------
22
TABLE 17. ANNUAL ENVIRONMENTAL IMPACTS AND COST?
EXISTING INTERMITTENT 600 Ib/hr MWI?'
FOR EACH
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
so2
NOV
Pb
Cd
Hg
Costs;
Total annual costa
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr- (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
4.66(5.14)
5.33(6.10)
1.3E-04 (1.4E-04)
15.03 (16.57)
0.27 (0.30)
1.82 (2.01)
2.8E-02(3.1E-02)
2.0E-03 (2.2E-03)
2.1E-02(2.3E-02)
77,806
MACT floor
DI/FF without carbon
0.15(0.17)
0.12(0.13)
3.0E-06 (3.3Ii-06)
: 0.75(0.83)
• 0.27 (0.30)
1.82 (2.01)
5.5E-04(6.1E-04)
8.2E-05 (9.0E-05)
2.1E-02(2.3E-02)
392,997
807,413
MACT
DI/FF with carbon
0.15'(0.17)
0.12(0.13)
6.0E-08 (6.6E-08)
0.75 (0.83)
0.27 (0.30)
1.85 (2.01)
5.5E-04 (6. 1E-04)
8.2E-05 (9.0E-05)
2.1E-03 (2.3E-03)
405,020
811,588
alncludes annual cost of baseline.
TABLE 18. ANNUAL ENVIRONMENTAL IMPACTS AND fOS.T£
EXISTING INTERMITTENT 200 Ib/hr
FOR EACH
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
so2
NO_
__, *
Pb
Cd
Hg
Costs;
Total annual cost3
Capita] cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
1.32 (1.46)
1.57 (1.73)
3.5E-05 (3.9E-05)
4.27 (4.71)
7.7E-02 (8.5E-02)
0.52 (0.57)
7.9E-03 (8.7E-03)
5.8E-04 (6.4E-04)
6.0E-03 (6.6E-03)
49,410
—
MACT floor
DI/FF without carbon
4.4E-02 (4.9E02)
3.4E-02 (3.7E-02)
8.5E-07 (9.4E-07)
0.22 (0.24)
7.7E-02 (8.5E-02)
0.52 (0.57)
1.5E-04 (1.7E-04)
2.4E-05 (2.6E-05)
6.0E-03 (6.6E-03)
323,931
690,181
MACT
DI/FF with carbon
4.4E-02 (4.9E-02)
3.4E-02 (3.7E-02)
1.7E-08 (1.9E-08)
0.22 (0.24)
7.7E-02 (8.5E-02)
0.52 (0.57)
1.5E-04 (1.7E-04)
2.4E-05 (2.6E-05)
6.0E-04 (6.6E-04)
329,303
692,340
"Includes annual cost of baseline.
-------
23
TABLE 19. ANNUAL ENVIRONMENTAL IMPACTS*AND COSTS FOR EACH
EXISTING BATCH 200 lb/hr MWIJ'4'9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
SO2
NOX
Pb
Cd
Hg
Costs:
Total annual cost0
Capital cost
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$
Baseline
0.25 (0.28)
0.73 (0.81)
3.5E-05 (3.9E-05)
0.41 (0.45)
7.3E-02 (8.0E-02)
0.22 (0.24)
4.4E-03 (4.8E-03)
1.6E-04 (1.8E-04)
3.1E-03 (3.4E-03)
30,700
MACT floor
DI/FF without carbon
3.1E-02(3.4E-02)
1.5E-02 (1.7E-02)
8.5E-07 (9.4E-07)
2.1E-02(2.3E-02)
7.3E-02 (8.0E-02)
0.22 (0.24)
8.7E-05 (9.6E-05)
6.5E-06 (7.2E-06)
3.1E-03(3.4E-03)
300,175
673,699
MACT
DI/FF with carbon
3.1E-02(3.4E-02)
1.5E-02 (1.7E-02)
1.7E-08 (1.9E-08)
2.1E-02(2.3E-02)
7.3E-02 (8.0E-02)
0.22 (0.24)
8.7E-05 (9.6E-05)
6.5E-06 (7.2E-06)
3.1E-04(3.4E-04)
304,648
675,470
alncludes annual cost of baseline.
TABLE 20. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS AND
COSTS FOR NEW CONTINUOUS MWI's3'4'9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
SO2
NO,
Pb
Cd
Hg
Costs:
Total annual cost3
Cost per ton of waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
1,093 (1,205)
1,042(1,149)
1.343E-02(1.480E-2)
6.604E-02 (7,280)
119.2(131.4)
799.1 (880.9)
12.24 (13.49)
0.8953(0.9869)
9.25 (10.20)
32,760,908
100 (91)
MACT floor/MACT
DI/FF with carbon
68.29 (75.28)
52.13(57.46)
2.626E-05 (2.895E-05)
198.1 (218.4)
119.2 (131.4)
799.1 (880.9)
0.2446 (0.2698)
3.5816 (3.948E-02)
0.925 (1.020)
87,982,105
270 (245)
alncludes annual cost of baseline.
-------
24
TABLE 21. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS AND
COSTS FOR NEW INTERMITTENT MWI's3'4'9
Impact
Primarv emissions:
PM
CO
CDD/CDF
HC1
SO2
NO..
Pb
Cd
Hg
Costs:
Total annual cost3
Cost per ton of waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
558.53 (615.67)
532.85 (587.37)
6.8647E-03 (7.567E-03)
3,376 .(3,721)
60.94(67.18)
408.5 (450.3)
6.254 (6.894)
0.4577 (0.5045)
4.729 (5.213)
25,043,855
276(250)
MACT floor/MACT
DI/FF with carbon
34 (38)
26 (29)
1.342E-05 (1.480E-05)
101.2(111.6)
60.94(67.18)
408.5 (450.3)
0.1251 (0.1379)
1.830E-02 (2.018E^)2)
0.4729 (0.5213)
139,565,765
1,533 (1,391)
alncludes annual cost of baseline.
TABLE 22. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR NEW BATCH MWI's3'4'9
Impact
PrimarY emissions?
PM
CO
CDD/CDF
HC1
SO2
N0_.
Pb
Cd
Hg
Costs:
Total annual cost*
Cost per ton
waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
22.19 (24.46)
52.28 (57.63)
1.435E-03 (1.582E-03)
68.05 (75.01)
11.96(13.18)
36.50 (40.23)
7.1840E-01 (7.919E-01)
2.694E-03 (2.970E-02)
0.5164 (0.5692)
5,543,175
1,371 (1,244)
MACT floor
DI/FF without carbon
5.137(5.6(53)
2,614(2.831)
1.403E-04(1.547E-04)
2.041 (2.Z'50)
11.96(13.18)
36.50 (40.23)
1.437E-02 (1.584E-02)
1.078E-02(1.188E-02)
0.5164 (0.5692)
48,978,600
12,347 (10,994)
MACT
DI/FF with carbon
5.137(5.663)
2.614 (2.881)
2.806E-06 (3.093E-06)
2.041 (2.250)
11.96(13.18)
36.50 (40.23)
1.457E-02(1.584E-02)
1.078E-03(1.188E-03)
0.0516 (0.0569)
49,716,645
12,534(11,160)
"Includes annual cost of baseline.
-------
25
TABLE 23. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR EXISTING CONTINUOUS MWI's3'4'
Impact
Primary emissions*
PM
CO
CDD/CDF
HC1
SO2
NOX
Pb
Cd
Hg
Costs:
Total annual cost*
Cost per ton
of waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
2,962(3,265)
3,104 (3,422)
5.360E-02 (5.908E-02)
14,523 (16,009)
262.2 (289.0)
1,757(1,937)
26.91 (29.66)
1.969 (2.170)
20.35 (22.43)
74,545, 884
106(96)
MACT floor
DI/FF without carbon
150.2 (165.6)
114.7 (126.4)
2.888E-03 (3.183E-03)
435.7 (480.3)
262.1 (289.0)
1,757 (1,937)
0.5381 (0.5932)
0.0787 (0.0868)
20.35 (22.43)
204,208,284
289 (262)
MACT
DI/FF with carbon
150.2 (165.6)
114.7(126.4)
5.775E-05 (6.366E-05)
435.7 (480.3)
262.1 (289.0)
1,757(1,937)
0.5381 (0.5932)
0.0787 (0.0868)
2.035 (2.243)
213,610,390
302 (274)
alncludes annual cost of baseline.
TABLE 24. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR EXISTING.INTERMITTENT MWI's3'4'9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
S02
N0_
Pb
Cd
Hg
Costs:
Total annual costa
Cost per ton of
waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
8,233 (9,075)
9,774 (10,774)
2.144E-01 (2.419E-01)
26,536 (29,251)
479.1 (528.1)
3,21.1 (3,540)
49.17 (54.20)
3.598 (3.966)
37.18 (40.98)
179,882,419
250 (227)
MACT floor
DI/FF without carbon
274.4 (302.5)
209.5 (230.9)
5.276E-03 (5.816E-03)
797 (878)
479.1 (528.1)
3,211 (3,540)
0.9833 (1.084)
0.1439 (0.1586)
37.18 (40.98)
1,057,771,155
1,474 (1,337)
MACT
DI/FF with carbon
274.4 (302.5)
209.5 (230.9)
1.055E-04(1.163E-04)
797 (878)
479.1 (528.1)
3,211 (3,540)
0.9833(1.0*4)
0.1439(0.1586)
3.718 (4.09S)
1,082,202.551
1,508 (14««)
alncludes annual cost of baseline.
-------
26
TABLE 25. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR EXISTING BATCH
Impact
Primaiy emissions-
PM
CO
CDD/CDF
HC1
SO,
NO.
Pb
Cd
Hg
Costs;
Total annual cost*
Cost per ton
of waste
Units
Mg/yr (tons/yr)
Mg/yr '(tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
84.49 (93.13)
247.7 (273.0)
1.185E-02(1.306E-02)
' 138.2(152.3)
24.28 (26.76)
74.10 (81.68)
1.458 (1.608)
5.469E-02 (6.029E-02)
1.049 (1.156)
10,284,500
1,253 (1,137)
MACT floor
DI/FF without carbon
10.43 (11.50)
5.307 (5.850)
2.849E-04 (3.140E-04)
. 4.145(4.569)
24.28(26.76)
.' 74.10(81.68)
2.917E-02 (3.215E-02)
2.188E-03 (2.412E-03)
1.049(1.156)
100,558,625
12,255(11,118)
MACT
DI/FF with carbon
10.43 (11.50)
5.307 (5.850)
5.697E-06 (6.280E-06)
41.145(4.569)
24.28 (26.76)
74.10(81.68)
2.917E-02 (3.215E-02)
2.188E-03 (2.412E-03)
0.1049(0.1156)
102,057,080
12,437(11,283)
"Includes annual cost of baseline.
TABLE 26. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR NEW MWI's3'4'9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
SO2
N0_
Pb
Cd
Hg
Costs:
Total annual cost8
Cost per ton of
waste
Ash:
Bottom ash
Baghouse ash
Eoerev requirements:
Fuel usage (natural
gas)
Electricity usage
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
106 m3/yr
(106 ftS/yr)
109 Btu/yr
(Mwh/yr)
Baseline
1,673.44(1,844.66)
1,627.63(1,794.17)
2.173E-02(2.396E-02)
10,047.66(11,075.71)
192.13(211.79)
1,244.10(1,371.39)
19.21 (21.17)
1.38 (1.52)
14.50 (15.98)
63,347,938
150 (136)
42,119(46,428)
62 (2,187)
82 (24,096)
MACT floor
108.34(119.43)
81.38 (89.71)
1.800E-04 (1.985E-04)
301.43 (332.27)
192.13 (211.79)
1,244.10(1,371.39)
0.38 (0.423)
0.06 (0.061)
1.91 (2.11)
276,526,470
687 (596)
42,119(46,428)
34,351 (37,866)
87 (3,082)
224 (65,499)
MACT
DI/FF with carbon
108.34(119.43)
81.38(89.71)
4.250E-05 (4.685E-05)
301.43 (332.27)
192.13(211-79)
1,244.10(1,371.39)
0.384 (0.423)
0.055 (0.061)
1.45(1.60)
277,264,515
658 (597)
42,119(46,428)
34,503 (38,034)
87 (3,082)
224 (65,499)
alncludes annual cost of baseline.
-------
27
TABLE 27. TOTAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR EXISTING
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
so2
N0_
Pb
Cd
Hg
Costs:
Total annual cost*
Cost per ton of
waste
Ash:
Bottom ash
Baghouse ash
Enerev reauirements:
Fuel usage (natural
gas)
Electricity usage
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
106 m3/yr
(106 ft-Vyr)
109Btu/yr
(Mwh/yr)
Baseline
11,278.88 (12,423.90)
13,126.69 (14,469.77)
0.2849 (0.3141)
41,197.36 (45,412.55)
765.57 (843.90)
5,042,255 (5,558.49)
77.53 (85.47)
5.62 (6.20)
58.57 (64.56)
264,712,803
162 (147)
143,292 (157,593)
261 (9,219)
305 (89,199)
MACT floor
DI/FF without carbon
435.04 (479.55)
329.38 (363.08)
8.450E-03 (9.315E-03)
1,235.92 (1,362.38)
765.57 (843.90)
5,042.55 (5,558.49)
1.55 (1.71)
0.22 (0.25)
58.57 (64.56)
1,362,538.064
833 (755)
143,292 (157,593)
128,296 (141,423)
360 (12,707)
903 (264,612)
MACT
DI/FF with carbon
435.04 (479.55)
329.38 (363.08)
1.68E-04(1.85E-04)
1,235.92(1,362.38)
765.57 (843.90)
5,042.55 (5,558.49)
1.55 (1.71)
0.22 (0.25)
5.86 (6.46)
*
1,397,870,021
854 (775)
143,292 (157,593)
141,194 (155,641)
360 (12,707)
903 (264,612)
alncludes annual cost of baseline.
TABLE 28. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS
AND COSTS FOR NEW MWI's USING ALTERNATIVE DISPOSAL METHODSa3"5'9
Impact
Primary emissions*
PM
CO
CDD/CDF
HC1
SO2
NOX
Pb
Cd
Hg
Costs;
Total annual costb
Cost per ton of waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
1,166.59 (1,285.96)
1,112.98(1,226.85)
1.434E-02 (1-581E-02)
7,050.51 (7,771.90)
127.29 (140.31)
853.16(940.45)
13.06 (14.40)
0.96 (1.05)
9.88 (10.89)
63,347,938
150 (136)
MACT
DI/FF with carbon
81.66 (90.02)
61.67 (67.98)
3.18E-05(3.51E-05)
230.61 (254.21)
144.06 (158.80)
943.74 (1,040.30)
0.29 (0.32)
0.042 (0.046)
1.10 (1.21)
137,823,917
417 (378)
aModel 1 installs DI/FF; Models 2 and 3 split evenly between switching to autoclaving and installing DI/FF.
Models 4, 5, and 6 evenly split between switching to autoclaving and switching to offsite disposal.
"Includes annual cost of baseline.
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28
TABLE 29. TOTAL ANNUAL NATIONWIDE ENVIRONMENTAL IMPACTS AND
COSTS FOR EXISTING MWI's USING ALTERNATIVE
DISPOSAL METHODS3"3'4'^9
Impact
Primary emissions:
PM
CO
CDD/CDF
HC1
so2
NOX
Pb
Cd
Hg
Costs:
Total annual costb
Cost per ton of waste
Units
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
Mg/yr (tons/yr)
$/yr
$/Mg ($/ton)
Baseline
5,084.81 (5,605.07))
5,625.44 (6,201.02)
0.1101(0.,12147)
21,366.24 (23,552.37)
385.75 (425.22)
2,585.47 (2,850.00)
39.59 (43.64)
2.90(3.19)
29.93 (33.00)
264,712,803
162 (147)
MACT
DI/FF with carbon
272.46 (300.34)
206.63 (227.77)
1.06E-04(1.16E-04)
777.35 (856.89)
478.71 (527.69)
3,164.20(3,487.95)
0.97 (1.07)
0.14(0.16)
3.67 (4.05)
615,575,114
703 (638)
aModcl 1 installs DI/FF; Models 2 and 3 split evenly between switching to autoclaving and installing DI/FF.
Models 5 and 6 evenly split between switching to autoclaving and switching to offsite disposal.
"Includes annual cost of baseline.
TABLE 30. MARKET PRICE INCREASES IN THE MAJOR INDUSTRY
SECTORS UNDER THE NSPS--NO SWITCHING7
Industry-
Hospitals
Nursing Homes
Veterinary Facilities'
Commercial Research Laboratories
Physicians' Offices
Dentists' Offices
Freestanding Bloodbanks
Commercial Medical Waste Incineration Facilities
Price
increase,
percent
0.08
0.03
0.03
0.09
0
0
0.06
N/Aa
Industrywide impacts were not calculated for commercial medical
waste incineration facilities because estimates of the change in
demand for commercial medical waste incineration were not
available. However, this industry is expected to be able to
recoup all control cost increases through price increases.
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29
TABLE 31. MARKET PRICE INCREASES IN THE MAJOR INDUSTRY
SECTORS UNDER THE EMISSION GUIDELINES--NO SWITCHING0
Industry
Hospitals
Nursing Homes
Veterinary Facilities
Commercial Research Laboratories
Physicians' Offices
Dentists' Offices
Freestanding Bloodbanks . '
Commercial Medical Waste Incineration Facilities
Price
increase,
percent
0.4
0.4'
1.9
1.2
0
0
0.3
N/Aa
Industrywide impacts were not calculated for commercial medical
waste incineration facilities because estimates of the change
in demand for commercial medical waste incineration were not
available. However, this industry is expected to be able to
recoup all control cost increases through price increases.
TABLE 32. MARKET PRICE INCREASES IN THE MAJOR INDUSTRY
SECTORS UNDER THE NSPS--SWITCHING SCENARIO
Industry
Hospitals
Nursing Homes
Veterinary Facilities
Commercial Research Laboratories
Physicians' Offices
Dentists' Offices
Freestanding Bloodbanks
Commercial Medical Waste Incineration Facilities
Price
increase,
percent
0.03
0.01
0.01
0.03
0
0
0.02
N/Aa
Industrywide impacts were not calculated for commercial medical
waste incineration facilities because estimates of the change in
demand for commercial medical waste incineration were not
available. However, this industry is expected to be able to
recoup all control cost increases through price increases.
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30
TABLE 33. MARKET PRICE INCREASES IN THE MAJOR INDUSTRY
SECTORS UNDER THE EMISSION GUIDELINES--
SWITCHING SCENARIO8
Industry-
Hospitals
Nursing Homes
Veterinary Facilities
Commercial Research Laboratories
Physicians' Offices
Dentists' Offices
Freestanding Bloodbanks
Commercial Medical Waste Incineration
Facilities
Price
increase,
percent
0.1
0.1
0.6
0.4
0
0
0.1
N/Aa
Industrywide impacts were not calculated for commercial medical
" incineration< facilities because estimates of ?he change in
°r
< c
cSmmercial medical waste incineration were not
reco a Con?™?r' *?*? industry is expected to be able to
recoup all control cost increases through price increases
TABLE 34. SOLID
=====r=======:=
Baseline
Switching
No -switching
WASTE IMPACTS
======
Amount of
waste
treated and
landfilled
• o
74,138
(81,723)
0
FOR NEW MWI
==============
Amount of
bottom ash
42,119
(46,428)
34,705
(38,256)
42 , 119
(46,428)
's [Mg/yr (tons/yr/ ] 9
Amount
of
flyash
0
26,346
(29,041)
34,504
(38,034)
Total
amount of
solid
waste
42.113
(46, 428)
135. 189
(149, C2:
76,623
(84,462
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31
TABLE 35. SOLID WASTE IMPACTS FOR EXISTING MWI's
[Mg/yr (tons/yr)]9
Baseline
Switching
No -switching
Amount of
waste
treated and
landfilled
0
443,546
(488,925)
0
Amount of
bottom
ash
143,293
(157,953)
98,938
(109,060)
143,293
(157,953)
Amount of
flyash
0
' 88,772
:(97,854)
141,195
(155,641)
Total
amount of
solid waste
143,293
(157,953)
631,256
(695,839)'
284,488
(313,594)
V.
1.
2.
3.
4.
5.
6.
7.
REFERENCES .
Memorandum from D. Randall, MRI, to R. Copland, EPA/SDB.
May 16, 1994. Determination of the Maximum Achievable
Control Technology (MACT) Floor for New Medical Waste
Incinerators.
Memorandum from S. Shoraka-Blair and B; Strong, MRI, to
R. Copland, EPA/SDB. June 15, 1994. Determination of the
Maximum Achievable Control Technology (MACT) Floor for
Existing Medical Waste Incinerators.
U. S. Environmental Protection Agency. Medical Waste
Incinerators--Background Information for Proposed Standards
and Guidelines: Model Plant Description and Cost Report for
New and Existing Facilities. No. EPA-453/R-94-045a.
July 1994.
Memorandum from T. Holloway and S. Shoraka-Blair, MRI, to
Rick Copland, EPA, March 30, 1994. Testing and Monitoring
Options and Costs for Medical Waste Incinerators.
U. S. Environmental Protection Agency. Medical Waste
Incinerators--Background Information for Proposed Standards
and Guidelines: Analysis of Economic Impacts for New
Sources. No. EPA-453/R-94-047a. July 1994.
U. S.. Environmental Protection Agency. Medical Waste
Incinerators--Background Information for Proposed Standards
and Guidelines: Analysis of Economic Impacts for Existing
Sources. No. EPA-453/R-94-048a. July 1994.
Medical Waste Incinerators--Background Information for
Proposed Standards and Guidelines: Analysis of Economic
Impacts for New Sources, EPA-453/R-94-047a, July 1994.
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32
9. U. S. Environmental Protection Agency. Medical Waste
Incinerators--Background Information for Proposed
anrt nil-i rtai •! T-i^<-.. T?^..J ~._.__.—_i__ i -r , _ j^ »»««—**
ironmental Impacts Report for .,^« «,
No. EPA-453/R-94-046a. July 1994.
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