United States Office of Air Quality Emission Standards
Environmental Protection Planning and Standards Division
Agency Research Triangle Park, NC 27711
Prevention and Toxics
National Air Pollution
Control Techniques
Advisory Committee
Minutes of Meeting
November 19-21,1991
Volume 1 of 2
Printed on Recycled Paper
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National Air Pollution
Control Techniques
Advisory Committee
Minutes of Meeting
November 19-21,1991
U.S. Environmental Protection Agency
Office Of Air and Radiation
Office of Air Quality Planning and Standards
Emission Standards Division
Research Triangle Park, North Carolina 27711
CD,
UJ
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Two Volume Set: Volume 1 (Section I - X)
Volume 2 (Section I, XI - XVIII, and Appendix)
TABLE OF CONTENTS
PAGE
I. INTRODUCTION AND OPENING REMARKS
Bruce C. Jordan, Committee Chairman 1
Director, Emission Standards Division (BSD)
Office of Air Quality Planning and Standards, EPA
II. GENERAL PROVISIONS
A. EPA Presentation
Michele Dubow, ESD 5
B. Industry Presentation
Chemical Manufacturers Association 19
Danny Anderson
Vice President of Environmental Affairs
First Chemical Corporation
a. Supplemental Comments 22
C. Discussion 28
III. HAZARDOUS ORGANIC NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS (NESHAP)
A. EPA Presentation
Daphne McMurrer, ESD 33
B. Industry Presentation
Chemical Manufacturers Association 43
Thomas Robinson
Manager of Regulatory Affairs
Vulcan Chemicals Corporation
C. Discussion 48
IV- COKE OVEN NESHAP
A. EPA Presentation
Amanda Agnew, ESD 53
B. Discussion 66
V. DRY CLEANING NESHAP
A. EPA Presentation
Linda Herring, ESD 67
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PAGE
B. Industry Presentation
1. International Fabricare Institute *
William Fisher, Vice President
C. Discussion 83
VI. CHROMIUM ELECTROPLATING NESHAP
A. EPA Presentation
Lalit Banker, BSD 87
B. Discussion 99
VII. SECTION 112g
A. EPA Presentation
Tim Smith, BSD 105
B. Industry Presentations
1. Motor Vehicle Manufacturers Association . . 119
Richard Paul
Manager, Environmental Health
2. American Petroleum Institute 125
F. Dan Gealy
Director, Public Relations
Atlantic Richfield Company
3. Pharmaceutical Manufacturers Association . 131
Richard Vetter
Associate Counsel
Burroughs Wellcome
4. Chemical Manufacturers Association .... 140
Joe Woolbert
Principal Chemical Engineer
Texas Eastman Chemical Company
C. Discussion 145
VIII. SOURCE CATEGORY SCHEDULE FOR STANDARDS
A. EPA Presentation
David Svendsgaard and Chuck French, BSD .... 155
* Did not provide a copy of presentation for inclusion in the
minutes.
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PAGE
B. Industry Presentation
1. Institute of Chemical Waste Management . . . 181
Jonathan Kaiser
Manager, Resource Recovery and Combustion
Programs
National Solid Wastes Management Association
C. Discussion 190
D. Correspondence
1. Chemical Manufacturers Association .... 196
2. American Iron and Steel Institute 199
Bruce A. Steiner
Vice President, Environment and Energy
IX. INDUSTRIAL PROCESS COOLING TOWERS
A. EPA Presentation
Phil Mulrine, BSD 201
B. Industry Presentation
1. Superior Manufacturing Company 227
Chuck Sanderson, Engineer
C. Discussion 236
X. MEDICAL WASTE INCINERATORS
A. EPA Presentation
James Eddinger, ESD 241
B. Industry Presentations
1. Cremation Association of North America . . 279
a. Paul Rahill
b. Ed Laux
c. Harvey Lapin
2. Waste Combustion Equipment Institute . . . 332
Stephen Shuler
Chairman
3. American Hospital Association 340
Jim McLarney
Director, Division of Health Facilities
Management and Compliance
and
Lawrence G. Doucet
Doucet and Mainka, P.C.
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4. E.G. Wickberg Company 378
Henry H. Hadley
President
5. Calvert Environmental, Inc 386
Ronald G. Patterson
President
6. Konheim and Ketcham, Inc 397
Carolyn S. Konheim
President
C. Discussion 435
D. Correspondence
1. Wisconsin Department of Natural Resources . . 457
Donald F. Theiler
Director
Bureau of Air Management
2. Joy Energy Systems, Inc 459
Steve Shuler
Manager
Sales and Marketing
XI. OVERVIEW OF CONTROL TECHNIQUES GUIDELINES PROGRAM
A. EPA Presentations
1. General Overview
Susan R. Wyatt, ESD 468
2. Transfer Efficiency and Regulatory Guidance for
Spray Coating Operations
Dave Salman, ESD 477
B. Discussion 496
XII. PLASTIC PARTS COATING
A. EPA Presentation
Joanie McLean, Radian Corporation 500
B. Industry Presentations
1. National Paint and Coatings Association . . 521
Naomi Suss
PPG Industries, Inc.
IV
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PAGE
2. Motor Vehicle Manufacturers Association . . 539
Joe Lennon
Environmental Control Engineer
Ford Motor Company
3. Graco, Inc 553
Steve Kish
Market Development Manager
4. Mobay Corporation 562
John L. Williams
Director, Technical Marketing
C. Discussion 569
D. Correspondence
1. Navistar International Transportation
Corporation 577
Tim W. McDaniel
Environmental Manager
2. Electrostatic Consultants Company 579
Arvid C. Walberg
3. Vantage Products Corporation 608
Dale C. Jones
Finishing Department Manager
4. Motor Vehicle Manufacturers Association . . . 623
Eugene A. Praschan
Manager, Emissions and Control
XIII. OFFSET LITHOGRAPHY
A. EPA Presentation
Donna Jones, Radian Corporation 631
B. Industry Presentations
1. Rosos Research Laboratories 672
Agi Rosos
President
2. C.A. Enterprises, Ltd 676
Paul L. Martin
Vice President, Product Development
3. American Newspaper Publishers Association . . 680
Wilson Cunningham
Vice President, Technical Research
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PAGE
4. National Association of Printing Ink
Manufacturers 700
James E. Renson
Environmental Affairs Coordinator
5. Environmental Conservation Board 714
a. Gerald Bender
Vice President
Environment, Safety, and Materials
Engineering
R.R. Donnelley and Sons, Company
b. William Schaeffer
Consultant, Graphic Arts Technical Foundation
c. William Schneidereith, Jr.
President
Schneidereith and Sons, Inc.
C. Discussion 810
D. Correspondence
1. National Association of Printing Ink
Manufacturers 826
James H. Sutphin
Executive Director
XIV. OVERVIEW OF CONTROL TECHNIQUES GUIDELINES PROGRAM
(Repeat of presentations under Section XI.)
XV. WOOD FURNITURE COATING
A. EPA Presentation and Discussion
Mary Jo Caldwell, Midwest Research Institute . . 841
B. Industry Presentations and Discussions
1. Union Carbide 883
Thayer West
Marketing Manager, Unicarb System
2. Classic Systems, Inc 890
David Brookman
Technical Representative, Finishing Division
3. Graco, Inc 995
Steve Kish
Market Development Manager
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PAGE
4. Mobay Corporation 912
John L. Williams
Director, Technical Marketing
5. American Furniture Manufacturers Association. 921
Business and Institutional Furniture
Manufacturers Association
Kitchen Cabinet Manufacturers Association
National Paint and Coatings Association
a. Robert G. Mclnnes
Principal Air Quality Engineer
ENSR Consulting and Engineering
b. Mark Berkman
Senior Consultant
National Economic Research Associates
C. Correspondence
1. Thomasville Furniture Industries, Inc. . . . 963
Sherry Stookey
Supervisor
Environmental Compliance
XVI. AUTOBODY REFINISHING
A. EPA Presentation and Discussion
Darcy Campbell, Radian Corporation 965
B. Industry Presentation and Discussions
1. National Paint and Coatings Association . . . 997
Karl Schultz, Chairman, Automotive Refinishing
Coalition
2. BASF Corporation 1012
Bob Inglis
Director, Product Planning
3. Safety-Kleen 1023
John P- Kusz
Manager, Product Development
4. National Auto Dealers Association 1028
Douglas I. Greenhaus
Senior Attorney, Regulatory Affairs
5. PPG Industries, Inc 1037
R.T. Hilovsky
Manager, Regulatory Affairs
Automotive, Aircraft, and Fleet Finishes
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PAGE
6. The Sherwin-Williams Company 1045
Gregory Ocampo
Product Manager
C. Correspondence
1. Grace, Inc 1055
Steve Kish
Market Development Manager
2. Herkules Equipment Corporation 1060
Richard A. Robb
President
3. DuPont-Automotive Products 1065
Karl R. Schultz
Environmental Consultant
4. National Paint and Coatings Association, . 1074
Automotive Refinish Coalition
Jim Sell
Senior Counsel
XVII. BATCH PROCESSES
A. EPA Presentation
Randy McDonald, BSD 1115
B. Industry Presentations
1. On-Demand Environmental Systems, Inc. . . . 1148
Richard E. Hamilton
Vice President
2. Chemical Manufacturers Association .... 1155
Terri Ranganath
E.I. duPont de Nemours and Company
C. Discussion 1159
XVIII. VOLATILE ORGANIC LIQUID STORAGE
A. EPA Presentation
Mark Morris, BSD 1161
B. Industry Presentations
1. Conservatek Industries, Inc 1189
Rob Ferry
Vice President
vm.
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PAGE
2. Chemical Manufacturers Association .... 1199
Terri Ranganath
E.I. duPont de Nemours and Company
C. Discussion 1205
D. Correspondence
1. Petrex, Inc 1206
W. L. Wagner
President
2. Wisconsin Department of Natural Resources . 1212
Steven M. Jorgensen
Engineer, Bureau of Air Management
3. American Petroleum Institute 1222
James K. Walters
Director, Measurement Coordination
APPENDIX: RECORD OF ATTENDANCE 1239
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I. INTRODUCTION AND COMMENTS
Mr. Bruce C. Jordan, Chairperson
National Air Pollution Control Techniques
Advisory Committee
The National Air Pollution Control Techniques Advisory
Committee (NAPCTAC) of the U.S. Environmental Protectional Agency
(EPA) held a meeting on November 19-21, 1991, at the Sheraton Inn
University Center in Durham, North Carolina. Mr. Bruce Jordan
called the meeting to order at 9:00 a.m. Committee members in
attendance were:
Mr. Donald R. Arkell
Dr. Patrick R. Atkins
Mr. William J. Dennison
Mr. Ralph E. Rise
Ms. Vivian M. Mclntire
Mr. William O'Sullivan
Dr. John E. Pinkerton
Ms. Deborah A. Sheiman
Mr. Brian L. Taranto
Messrs. Paul H. Arbesman and Charles A. Collins were unable to
attend the meeting.
The agenda for the meeting was published in the Federal
Register on October 22, 1991.
Mr. Jordan opened the meeting by extending a welcome on
behalf of EPA and then introduced his colleagues at the speakers
table; the EPA and EPA contractor staffs on hand to answer
technical, economic, and regulatory questions; and the EPA staff
handling the administrative aspects of the meeting. He asked
that everyone sign the official register to provide a record of
their participation in the meeting (see Appendix). Mr. Jordan
noted that minutes of the proceeding would be available as soon
as possible after the date of the meeting.
Mr. Jordan briefly outlined the agenda and then introduced
the first of several speakers representing EPA and various
industries who addressed issues concerning air pollution to the
Committee.
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AGENDA
U. S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
Sheraton Inn University Center
Brightleaf Ballroom (Third Floor)
15-501 at Morreene Road
2800 Middleton Avenue
Durham, North Carolina 27705
(919) 383-8575
NOVEMBER 19, 20, AND 21, 1991
November 19 (Tuesday) - 9:00 a.m.
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
(NESHAP) PROJECTS STATUS REPORTS
(Title III of the Clean Air Act Amendments)
General Provisions
Hazardous Organic NESHAP (HON)
Coke Ovens
Dry Cleaning
Chromium Electroplating
SECTION 112g
Status Report on the Development of Guidance for New, Modified, and
Reconstructed Sources
(Title III of the Clean Air Act Amendments)
SOURCE CATEGORY SCHEDULE FOR STANDARDS
Status Report on the Development of a Prioritized Agenda for Source Category
Emission Standards Promulgation
(Title III of the Clean Air Act Amendments)
A LUNCH BREAK WILL BE TAKEN FROM 1:00-2:00 P.M. EACH DAY
11/19/91 2
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2
November 20 (Wednesday) - 9:00 a.m.
CONTINUATION OF NOVEMBER 19-AS REQUIRED
INDUSTRIAL PROCESS COOLING TOWERS
Status Report on the Development of the Proposed NESHAP
(Title III of the Clean Air Act Amendments)
MEDICAL WASTE INCINERATORS
Status Report on the Development of the Proposed Standards and Emission
Guidelines
(Section 111 and Title III of the Clean Air Act Amendments)
CONTROL TECHNIQUES GUIDELINES (CTG) PROGRAM
(Title I of the Clean Air Act Amendments)
Overview of Program
Plastic Parts Coating CTG Document
Offset Lithography CTG Document
November 21 (Thursday) - 9:00 a.m.
CONTINUATION OF NOVEMBER 20--AS REQUIRED
CONTROL TECHNIQUES GUIDELINES (CTG) PROGRAM
(Title I of the Clean Air Act Amendments)
Overview of Program
Wood Furniture Coating CTG Document
Autobody Refinishing CTG Document
Batch Processes CTG Document
Volatile Organic Liquid Storage CTG Document
A LUNCH BREAK WILL BE TAKEN FROM 1:00-2:00 P.M. EACH DAY
11/19/91 Q
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U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE
Chairperson and Designated Federal Official
Mr. Bruce C. Jordan
Director, Emission Standards Division (MD-13)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
(919) 541-5572
FTS: 629-5572
COMMITTEE MEMBERS
Mr. Paul H. Arbesman
Director, Pollution Control
Allied-Signal, Inc.
Columbia Road and Park Avenue
Morristown, New Jersey 07962
(201) 455-4286
Mr. Donald R. Arkell
Director
Lane Regional Air Pollution Authority
225 North 5th Street-Suite 501
Springfield, Oregon 97477
(503) 726-2514
Dr. Patrick R. Atkins
Director, Environmental Control
Aluminum Company of America
1501 Alcoa Building
Pittsburgh, Pennsylvania 15219
(412) 553-3805
Mr. Charles A. Collins
Administrator, Air Quality Division
Wyoming Department of Environmental Quality
122 West 25th Street
Cheyenne, Wyoming 82002
(307) 777-7391
Mr. William J. Dennison
Dennison and Associates
4 Cintilar
Irvine, California 92720
(714) 752-4150 or 51
Mr. Ralph E. Hise
President
Advanced Technologies Management, Inc.
2964 Falmouth Road
Cleveland, Ohio 44122
(216)751-5135 /
Ms. Vivian M. Mclntire
Environmental Affairs
Eastman Chemicals Company
Post Office Box 511
Kingsport, Tennessee 37662
(615) 229-3045
Mr. William O'Sullivan
Assistant Director
Air Quality Engineering and Technology
N.J. Department of Environmental
Protection
401 East State Street, CNO27
Trenton, New Jersey 08625
(609) 984-6721
Dr. John E. Pinkerton
Program Director, Air Quality
National Council of the Paper Industry
for Air and Stream Improvement, Inc.
260 Madison Avenue
New York, New York 10016
(212) 532-9047
Ms. Deborah A. Sheiman
Resource Specialist
Natural Resources Defense Council
1350 New York Avenue, N.W. Suite 300
Washington, D. C. 20005
(202) 783-7800
Mr. Brian L. Taranto
Senior Environmental Conservation
Associate
Exxon Chemical Americas
13501 Katy Freeway
Houston, Texas 77079
(713) 870-6117
November 19, 1991
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EPA PRESENTATION BY MICHELE DUBOW ON
GENERAL PROVISIONS FOR NESHAP FOR SOURCE CATEGORIES
NOVEMBER 19, 1991
I'm going to speak briefly on a project I've been working on
for the last year — developing general provisions for the MACT
standards that will be set under Section 112 of the recent Clean
Air Act Amendments. These MACT standards will be known formally
as National Emission Standards for Hazardous Air Pollutants for
Source Categories — or NESHAP for Source Categories — which
retains the NESHAP acronym — and they will be codified in 40 CFR
Part 63. The general provisions will be located in Subpart A of
Part 63.
Before going on, I'd like to review an outline of my
presentation. First, I'll explain the purpose of general
provisions for NESHAP for Source Categories. Then I'll explain
EPA's approach to developing the general provisions for Part 63.
Next, I'll review the content of existing general provisions in
40 CFR Parts 60 and 61 and the content of the new general
provisions for Part 63. The reason for reviewing the existing
general provisions in Parts 60 and 61 is that the content of the
proposed new general provisions is based on the existing
provisions, as well as the new statutory requirements in the
Clean Air Act. Finally, I'll inform you of the schedule for this
regulatory action.
The general provisions for Part 63 serve two major
functions: first, they codify procedures and criteria that will
be used to implement NESHAP for Source Categories — and second,
they eliminate the repetition of general information in MACT
standards. In other words, the general provisions organize and
present up-front in Part 63 information that is essential to the
implementation of standards for particular source categories or
subcategories that otherwise would have to be repeated over and
over in each standard when it is promulgated. In this regard,
the general provisions for Part 63 serve the same purpose as
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general provisions throughout EPA's regulations. In particular,
they are similar to the general provisions in 40 CFR Parts 60 and
61 which house new source performance standards and NESHAP
established under Section 112 of the Act before it was amended.
The general provisions for Part 63 serve additional
functions as well. Since new Section 112 includes a "savings
provision" that preserves the integrity of NESHAP in Part 61, the
general provisions in Part 63 will preserve Part 61 reguirements
for sources regulated under former Section 112. The new general
provisions include language that distinguishes existing NESHAP in
Part 61 from future NESHAP for Source Categories that will be
codified in Part 63.
The key element of our approach to developing new general
provisions for Part 63 has been to use the existing general
provisions in Parts 60 and 61 as much as possible. In doing
this, we've combined elements from Parts 60 and 61 to create a
template from which further development of the regulation could
take place. We believe this approach is reasonable since it
maintains consistency with EPA's previous policy and technical
decisions — and it takes advantage of the user communities'
familiarity with existing regulations for technology-based
standards.
Our next step was to change the existing general provisions
— for the purposes of Part 63 — to make them consistent with
new statutory reguirements under the recent Clean Air Act
Amendments — and also to correct past problems. An example of a
problem that we sought to correct is the lack of clarity in some
of the administrative procedures in the existing general
provisions.
Another important element of our approach was to coordinate
the new general provisions with reguirements under Titles 5 and 7
of the Amendments that will apply to the same source categories
and subcategories that will be regulated under Section 112.
As most of you already know, Title 5 introduces a new federal
operating permit program and Title 7 introduces reguirements for
"enhanced monitoring" and compliance certifications for major
sources.
The general provisions are also coordinated with other
regulatory activities under Title III that are not being
completed within this rulemaking. Examples are the hazardous air
pollutant list under Section 112(b), the source category list
under Section 112(c), and the petition processes being developed
to add and delete items from these lists.
Finally, we organized the new provisions to make them easier
to use, understanding that many people who are unfamiliar with
the existing general provisions will be using the new ones.
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This activity included grouping information more logically, and
adding numerous titles and subtitles throughout the regulation.
In order to understand the content of the new general
provisions for Part 63, it is helpful to review the content of
the existing general provisions in Parts 60 and 61. The
existing general provisions contain 3 general classes of
information — they deal with topics we've characterized as
"generic" — they include administrative material — and they
specify requirements to implement the technical and legal aspects
of the Act. "Generic" topics include such things as definitions,
units and abbreviations, addresses of EPA Regional Offices and
State air pollution control agencies, and technical materials
incorporated by reference. The administrative sections concern
actions EPA or delegated enforcement agencies need to take —
such as responding to requests for determinations, listing
pollutants and source categories, and making information
available to the public.
Finally, the heart of the existing general provisions are
those sections that spell out an owner or operator's compliance
responsibilities — these include compliance dates, requirements
for operation and maintenance, testing and monitoring,
recordkeeping, reports and notifications, and receiving approval
to make significant changes to a regulated source. These
sections also specify when waivers and exemptions may be granted.
Although the fundamental content from Parts 60 and 61 has
been carried over, the new general provisions for Part 63 have
been crafted to implement the new statutory requirements of
Section 112. This slide contains more information than I can
cover in detail, so I'll pause to highlight only the most
important points.
The new general provisions explain that Part 63 standards
are applicable to major and designated area sources that emit
hazardous air pollutants. They include definitions from the
statute — such as stationary source — and ones we've created to
implement the new air toxics program — including fugitive
emissions, malfunction, and equivalent emission limitation.
They include provisions governing the process of reviewing and
approving new construction and reconstruction projects after an
applicable MACT standard has been set. And they detail
compliance dates and requirements for new and existing sources.
This point is worth highlighting since the compliance provisions
in the amended Act are considerably more complicated than
comparable provisions in the old Act. I'll mention just three
examples.
First, unlike the former Act, where existing sources had 90
days to comply with an applicable NESHAP, existing sources under
new Section 112 may be given as much as 3 years to comply.
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Second, section 112 mandates that EPA set technology-based
standards early on and, if necessary, health-based, or residual
risk standards, down the road a number of years. Therefore, the
new general provisions include compliance dates for both types of
standards. And last, we've provided specific language indicating
compliance and reporting dates for new sources that begin
construction between proposal and promulgation of an applicable
standard.
Furthermore, the new general provisions include
administrative provisions governing case-by-case MACT
determinations, requests to use alternative means of compliance,
extensions of compliance, and other special circumstances. The
provisions dealing with case-by-case MACT determinations merely
explain the situations under which such a determination would
need to be made. Guidance describing how such determinations
should be made will be issued by our office separately.
Since other sections of the Act now contain requirements
that will apply to sources regulated under Section 112, and since
the statutory requirements of Section 112 are being covered under
various rulemakings, the new general provisions inform owners and
operators and enforcement personnel of these related requirements
and where they appear in the CFR. As I've indicated on the
overhead, Title 5 permit program requirements will appear in
Parts 70 and 71, Title 7 compliance certification requirements
will appear in Part 64, and other general regulatory language
relating directly to Section 112 will appear in Subparts B, C,
and D of Part 63.
With regard to Title 5 and 7 requirements that may be
similar to requirements in the general provisions, such as those
for reporting and compliance certifications, our goal has been to
reduce the administrative burden from possible duplicative or
conflicting requirements. The general provisions are drafted so
they defer to permit program and compliance certification
requirements when those requirements are at least as stringent as
the general provisions.
The existing general provisions in Parts 60 and 61 have been
improved considerably for use in implementing Part 63. Some of
the improvements are the result of suggestions we received during
the development of this regulation from industry representatives
and from State and local air pollution control officials. One
important change is that the new general provisions are organized
for the easy retrieval of information. We hope that this in
itself will promote compliance and enhance enforcement efforts.
We've also tried to promote compliance and enhance
enforcement by adding new provisions for quality assurance and
quality control — requiring a startup, shutdown, and malfunction
plan — clarifying administrative procedures and compliance
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requirements — and clarifying that operation and maintenance
requirements are independently enforceable.
The purpose of the quality assurance and quality control
provisions is to ensure the quality of data collected. These
provisions would be implemented in part through the development
of site-specific testing and monitoring plans that would be
worked out between an owner and operator and the enforcement
agency in advance of a required compliance test. If an owner or
operator wants to use an alternative means of compliance from one
specified in a standard, and if the enforcement agency approves
the use of that alternative, the source's site-specific test plan
would be the vehicle to work out such arrangements.
The purpose of the startup, shutdown, and malfunction plan
is to reduce confusion about a source's compliance
responsibilities during periods of startup, shutdown, and
malfunction of process and control technology equipment.
Although excess emissions during these periods may not be
considered violations of relevant standards, owners and operators
must exercise good air pollution control practices for minimizing
emissions at all times, including during these periods. The
startup, shutdown, and malfunction plan will help owners and
operators to plan appropriate operation and maintenance
procedures and corrective actions in advance — thereby
minimizing the potential for violating operation and maintenance
requirements. The plan is also designed to reduce the
recordkeeping burden on sources, since if owners or operators
follow the procedures specified in their startup, shutdown, and
malfunction plans, they would not have to keep additional records
of actions taken during these periods.
To reduce the reporting burden on regulated sources we've
made reporting requirements in the proposed general provisions
more flexible. The first new provision rewards good performers.
Sources that can demonstrate continual compliance with a relevant
MACT standard for at least one year would be eligible for a
reduction in the frequency of periodic reports, such as excess
emissions reports. Flexibility has also been added to allow
consistent reporting schedules for sources affected by multiple
MACT standards or multiple standards under Parts 60, 61, and 63.
Under this provision, sources could submit periodic reports for
all relevant standards on a common schedule. Finally, changes to
deadlines for other required submittals, such as applications,
would be allowed by mutual agreement between the owner and
operator and the enforcement agency.
I'd also like to mention, as part of this rulemaking, we'll
be amending Parts 60 and 61 to make their reporting requirements
consistent with the flexibility we've added to the reporting
requirements for Part 63.
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Our schedule for the general provisions proposed ruleraaking
is the following: we anticipate going to proposal sometime in
December of this year or January of 1992 — and we plan to
promulgate not later than November of 1992 so the general
provisions take effect at the same time or before the first MACT
standards are promulgated.
That concludes my presentation. I would be happy to answer
any questions you might have. If anyone is interested in
receiving a copy of the proposal when it comes out, please see me
afterwards and I'll send you a copy.
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GENERAL PROVISIONS
FOR NESHAP
FOR SOURCE CATEGORIES
40 CFR PART 63, SUBPART A
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL AIR POLLUTION CONTROL TECHNIQUES
ADVISORY COMMITTEE
NOVEMBER 19-21, 1991
11
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OVERVIEW
PURPOSE of general provisions
• APPROACH to developing general provisions
CONTENT of existing general provisions
CONTENT of new general provisions
• PROJECT STATUS
2
12
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PURPOSE OF GENERAL
PROVISIONS FOR PART 63
Codify procedures and criteria used to
implement NESHAP for Source Categories
Eliminate repetition of general information in
standards
Preserve Part 61 requirements for sources
regulated under former Section 112 of Clean
Air Act
Distinguish existing NESHAP in Part
61 from future NESHAP in Part 63
13
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APPROACH TO DEVELOPING
GENERAL PROVISIONS FOR PART 63
USE EXISTING GENERAL PROVISIONS AS
TEMPLATE
CHANGE EXISTING PROVISIONS
• As required by Clean Air Act Amendments
• To correct past problems
COORDINATE NEW PROVISIONS WITH
• Requirements under Titles V and VII of Clean
Air Act Amendments
• Other activities under Title III (Section 112)
ORGANIZE NEW PROVISIONS TO MAKE THEM
EASIER TO USE
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EXISTING GENERAL PROVISIONS
DEAL WITH "GENERIC" TOPICS SUCH AS
• Definitions
• Units and abbreviations
• Addresses of State and Regional agencies
• Incorporations by reference
INCLUDE ADMINISTRATIVE SECTIONS ON
• Applicability of standards
• Lists of pollutants and source categories
• State authority and delegations
• Availability of information to the public
IMPLEMENT TECHNICAL AND LEGAL
ASPECTS OF CLEAN AIR ACT SUCH AS
• Compliance dates
• Operation and maintenance requirements
• Testing and monitoring requirements
• Recordkeeping, reporting, and notification
requirements
• Changes to a source (modification and
reconstruction)
• Waivers and exemptions
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NEW GENERAL PROVISIONS
IMPLEMENT TECHNICAL AND LEGAL
ASPECTS OF NEW SECTION 112 SUCH AS
• Applicability to major and area sources emitting HAP
• Definitions
• Preconstruction review and approval
• Compliance dates and requirements for new and
existing sources
• Case-by-case MACT determinations
• Requests to use alternative means of compliance
• Extensions of compliance and special situations
TRIGGER AND CROSS-REFERENCE
RELATED REQUIREMENTS IN CLEAN AIR
ACT AMENDEMENTS SUCH AS
• Title V permit applications (Parts 70 and 71)
• Title VII "enhanced monitoring" and compliance
certifications (Part 64)
• Section 112(g) "modification" provisions (Subpart B)
• HAP list, source category list, petition processes
(Subpart C)
• Early reductions program (Subpart D)
13
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NEW GENERAL PROVISIONS
ARE ORGANIZED FOR EASY RETRIEVAL
OF INFORMATION
PROMOTE COMPLIANCE AND ENHANCE
ENFORCEMENT BY
• Including quality assurance and quality control
requirements
• Including startup, shutdown, and malfunction plan
• Clarifying administrative procedures and compliance
requirements
• Clarifying that operation and maintenance
requirements are independently enforceable
ADD FLEXIBILITY FOR REGULATED
INDUSTRIES BY ALLOWING
• Reduced frequency of periodic reporting
• Consistent reporting schedules
• Changes to deadlines for other required submittals
7
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PROJECT STATUS
PROPOSAL
Anticipated date: DECEMBER 1991
PROMULGATION
Not later than: NOVEMBER 1992
8
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CHEMICAL
MANUFACTURERS
ASSOCIATION
STATEMENT OF
DANNY ANDERSON
ON BEHALF OF
THE CHEMICAL MANUFACTURERS ASSOCIATION
BEFORE THE
NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE
ON
GENERAL PROVISIONS
NOVEMBER 19,1991
2501 M Street, NW 202-887-1100
Washington, D.C. 20037 Telex 89617 (CMA WSH)
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CHEMICAL MANUFACTURERS ASSOCIATION
TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE ON
GENERAL PROVISIONS
Good Morning, My name is Danny Anderson, Vice President of
Environmental Affairs of First Chemical. I am pleased to present this
testimony on the Part 63 General Provisions on behalf of the Chemical
Manufacturers Association (CMA). Collectively, the members of CMA make
up 90% of the productive capacity for basic industrial chemicals in the
United States. In my presentation today, I want to address a few
changes to the September draft we think will make the General
Provisions simpler to understand and easier to implement. My testimony
is based on a September draft of the Part 63 General Provisions.
Overall, CMA supports the direction taken in the development of
Part 63 General Provisions. The agency is making some real
improvements by simplifying the requirements, reducing duplicative
reporting, and increasing reporting flexibility. However, there are
still some details that need to be clarified.
I would like to touch on some of these crucial points.
First, EPA needs to clarify how and when a source is considered a
"major source" in the preamble and applicability section. Several
plants participating in the early reductions program may become area
sources for HAP's. As stated in the preamble: "The distinction between
major and area sources is significant because it determines how and
when a source comes under the regulatory umbrella of Part 63." Since
area sources will be regulated differently than major sources, the
general provisions must address the issue of how and when the major
source determination should be made.
Second, in Section 63.3, EPA needs to reconcile its use of the
term "modifications" with the statutory language in section 112(g).
The General Provisions must be "in sync" with the 112(g) guidance
presently under development. Specifically, nowhere in section 112(g)
does it state that a source must obtain written approval from the
permitting authority prior to acting. To remain competitive,
companies must be able to make modifications quickly. Every effort must
be made to insure that agency review of modifications are as short as
possible. Sources should be able to proceed with modifications at
their own risk without prolonged delays.
Third, when setting time periods for source response, EPA needs to
consider the lag time before a source receives the regulation, the
20
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amount of time it will take to identify requirements, and the time to
put together an appropriately detailed response. Some of the required
response times are just too short to be feasible. Two examples are the
Notification Requirements and the Performance Testing Requirement.
The Notification Requirements require a facility which started up
prior to the effective date of a regulation to file an initial
notification within 45 days. The notice requires fairly detailed
identification and quantification of HAPs and specific emission
points. A source starting up after the effective date has only 15 days
(including weekends) to file the same initial notice. This timeline is
just not realistic. EPA should give a source 60-90 days to provide
the necessary information.
Along the same lines, the Performance Testing Requirements have
similar reporting requirements. A source must complete a performance
test within 120 days of promulgation. The source must notify EPA at
least 75 days before the test, leaving a source only 45 days from the
effective date of promulgation to schedule a performance test and
develop a detailed QA/QC plan.
Again, these time frames are not realistic for the majority of
sources. A 30 day notice of performance testing should be sufficient,
likewise a 30 day response time on the QA/QC plan.
Fourth, some sections of the general provisions are more
appropriately included in individual standards. An example is the
sections that define operation cycles for Continuous Monitoring
Systems. Since operating parameters for monitors depend a great deal
on available technologies and the chemicals being monitored, this type
of technical information is best included in the individual standards.
Along the same lines, flares should not be addressed in section
63.11? They are the only control device mentioned and the information
is highly technical and unlike any other information included in the
General Provisions. Flare operations should be included within
specific standards that accept flares as a control device.
Finally, while EPA has made great strides in consolidating
recordkeeping and reporting requirements, recordkeeping and reporting
are still scattered throughout the general provisions. All
recordkeeping and reporting requirements should be summarized in
section 63.10 for clarity and completeness. Duplicate reporting to
both state and Federal agencies should be avoided, as should reports of
non- applicability. Where long term recordkeeping is necessary EPA
should explicitly allow modern methods of recordkeeping such as
magnetic media and microfilm.
CMA thanks NAPCTAC for the opportunity to present some of our
ideas and concerns regarding the Part 63 General Provisions, and will
detail our comments in our written testimony. We look forward to
constructive interaction with EPA as it moves forward in the rulemaking
process. At this point I'd be happy to answer any questions from the
committee.
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CHEMICAL
MANUFACTURERS
ASSOCIATION
WRITTEN TESTIMONY
ON BEHALF OF
THE CHEMICAL MANUFACTURERS ASSOCIATION
BEFORE THE
NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE
ON THE
PART 63 GENERAL PROVISIONS
NOVEMBER 19,1991
22.
2501 M Street, NW 202-887-1100
Washington, D.C. 20037 Telex 89617 (CMA WSH)
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CHEMICAL MANUFACTURERS ASSOCIATION
SUPPLEMENTAL COMMENTS ON
PART 63 GENERAL PROVISIONS
The Chemical Manufacturers Association (CMA) is pleased to present
supplemental written testimony on the General Provisions proposal. CMA
is a non-profit trade association whose members make up 90% of the
productive capacity for basic industrial chemicals in the United
States. CMA members will be significantly impacted by MACT rulemakings
generally, and, as a result, Part 63. We support efforts to make the
General Provisions simpler, clearer, and more flexible.
Overall, CMA supports the direction that the development of Part
63 General Provisions has taken. The agency is making some real
improvements by simplifying requirements, reducing duplicative
reporting, and increasing flexibility. Our oral testimony addressed a
number of general concerns. In addition, there are some details that
need to be addressed. The details are listed below and organized by
section, based on a September draft of Part 63 General Provisions.
Section 63.1
The statement of applicability in 63.1(a)(2) and in 63.l(b)(l)(ii)
should be limited to those sources that actually emit hazardous air
pollutants in quantities significant enough to make them subject to
regulation under Section 112. These regulations do not apply to all
sources that have the potential to emit a HAP, as stated in (b)(l)(ii),
or even to every source that does emit a HAP, as stated in (a)(2).
Section 63.2
Section 63.2 defines a compliance schedule to include "an
enforceable sequence of actions to maintain current compliance." It
should not be necessary for a source already in compliance to commit to
an "enforceable sequence of actions." If a source is in compliance with
the applicable requirements, EPA should not second guess that source's
practices. Any failure of the source to continue appropriate practices
will show up soon enough in the form of violations. The new
enforcement provisions carry penalties that will insure.
that no source will allow any violations that can be avoided.
Section 63.5
Section 63.5 seems to change the rules of the game as they apply
to newly constructed sources, reconstructed sources, and
modifications. Neither Section 112(i), which governs construction and
reconstruction, nor Section 112(g), which applies to modifications,
requires that approval be received before construction,
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CMA Supplemental Comments
Page 2
reconstruction, or modification occurs. The language in 63.5(b)(2)
should be changed by deleting both "written" and "in advance." Just
exactly how the approval process will work should be left to the permit
program rules.
Section 63.5(b)(6) is extremely confusing. It may be trying to
say that a source cannot avoid compliance with relevant standards by
making changes that do not meet the definition of reconstruction or
modification. If so, the sentence should be reworded to say that. If
not, the only meaning we can get from the sentence is that sources
subject to a standard remain subject to that standard even if there is
a physical or operational change. Surely the rules do not need to
include such an obvious conclusion.
Section 63.5(d)(l) is also confusing. It requires sources subject
to (b)(2) to submit preconstruction permit applications to the
Administrator. However, sources subject to (b)(2) are those already
subject to a state permit program but for which no relevant standard
yet exists. Preconstruction permit requirements for those sources,
including the time for submission of applications, should be addressed
in the permit rules. In any case, the permit application should go to
the permitting agency, not the Administrator.
Section 63.6
In section 63.6(f)(iii)(C)--the word "reduced" should most likely
be "produced."
Section 63.6(g)(l) provides the mechanism for sources that want to
use an alternative emission limitation (AEL). This process should not
be limited to only individual sources but should be extended to
categories or subcategories. If the AEL was acceptable for one source
in the category or subcategory, it should be deemed acceptable for all
other similar sources. This approach adds efficiency for both EPA and
industry.
Section 63.7 and 63.8
EPA needs to realize that it takes time to inform employees of new
requirements. When setting time periods for source response, EPA needs
to consider the lag time before a source receives the regulation, the
amount of time it will take to identify requirements, and the time to
put together an appropriately detailed response.
For new sources, Section 63.7(a) requires completion of a
performance test within 120 days of the effective date of applicable
standards. The source must notify EPA at least 75 days before the
test, leaving a source only 45 days to schedule a performance test and
develop a detailed QA/QC plan. This timeline is just not realistic. A
15 day notice period before testing would be more reasonable. If the
Agency raised questions or objections in that 15 day period, the clock
could be stopped while those differences were resolved. If the source
did not get a response from the Agency within 15 days, it should assume
4
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CMA Supplemental Comments
Page 3
that the plan is acceptable and be able to proceed with the test as
proposed.
Sections 63.7(g)(l) and (2) require the source to analyze results
of any performance test and report the determinations by registered
letter before the close of business on the 30th day following the
completion of the test. This time period is very short and may not
allow sufficient time to process laboratory samples and information,
given the large numbers of performance tests that will be required.
The required report should be due no sooner than 60 days after the test
or some time period measured from completion of the analysis.
As written, the Performance Testing and Monitoring Requirements in
Sections 63.7 and 63.8 will make it extremely difficult to understand
actual requirements. For example, in Section 63.8, far more detailed
cross references will be required to minimize the administrative burden
of searching between conflicting regulations and general provisions to
coordinate all requirements. Where there are too many alternatives, it
might be preferable not to address a particular issue in the General
Provisions.
Including a "Data Analysis, Recordkeeping and Reporting" section
under both the individual section such as 63.7(g) and 63.8(e)(5) as
well as a separate section of Recordkeeping and Reporting is confusing
to the regulated community. In some cases, notification or reporting
requirements are hidden within other provisions such as
63.9(f)(6)(iii). All recordkeeping requirements should be included at
one place.
The requirement in section 63.8(c)(4)(i) that all continuous
monitoring systems for measuring emissions other than opacity shall
complete a minimum of one cycle of operation for each successive
15-minute period is not appropriate for a General Provision. This
section should be eliminated and the frequency specified in the
particular NESHAP.
Section 63.9
Portions of the general reporting requirements are very similar in
content to the proposed notification requirements. It may be useful to
combine the overlapping requirements and then concentrate on
highlighting only the differences in notification and reporting
requirements.
There is no reason for a source to have to send notifications or
reports to both the state permitting agency and the Regional EPA office
as stated in 63.9(a)(4)(ii) and 63.10(a)(4)(ii). If the state has
permitting authority, only one notice or report to the state agency
should be required.
Sections 63.9(a)(6) and 63.10(a)(9) refer to situations where an
explicit postmark data is not given and state "the submittal period
specified shall measure the period between the date the submittal is
postmarked and the date it is due to the Administrator." This language
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CMA Supplemental Comments
Page 4
is unnecessarily legalistic and confusing. We assume that the
paragraph is trying to say that even when no specific postmark
requirement is included in an individual regulation, that the postmark
date will nevertheless govern the determination of whether the source
has submitted the information in a timely way. If this is the case,
the language should be modified accordingly.
A fair amount of detailed information must be provided with the
initial notification, including the identification and quantity of
hazardous air pollutant emissions and their specific emission points.
Additionally, the source must demonstrate whether it is a major source
and describe the existing or planned air pollution control equipment
for each emission point, including each control device for each HAP and
the estimated control efficiency.
For a facility which started up prior to the effective date for
the standard, initial notification must be filed within 45 days after
the effective date. However, a new or reconstructed source which has a
startup after the effective date of the standards shall notify EPA in
writing within 15 calendar days of startup. This notification shall
include all the information required for the facility which had a
startup prior to the effective date. A source should be given 45 days
to notify the agency that it is subject to the relevant standard and
another 60-90 days to provide the necessary data.
Section 63.9(c) implies that a source which cannot meet the
standard by the applicable compliance date may be granted an extension
when an extension request is submitted with the initial notification.
It is certainly not clear whether an extension will be automatically
granted and this needs clarification.
Section 63.10
There are some subsections, e.g., 63.10(b)(2)(iii)-(vii) which
appear to be duplicated by 63.10(c) relative to the calibration,
maintenance and performance of continuous monitoring systems. There is
need for review and clarification between these two subsections.
Section 63.10(e)(3)(iv) states that as soon as the continuous
monitoring system indicates that the source is not in compliance with
any emission limitation, the reporting frequency goes back to the time
frame otherwise specified in the regulations. No consideration is
given to the effect of possible malfunction in process or monitoring
equipment, even though such malfunctions are corrected. Reduced
frequency of reporting can be regained only after the collection of
data over a period of one year. This segment should be amended to take
into consideration malfunctions in monitoring systems or short term
emissions which are immediately corrected. These incidents should not
automatically place the source back into the more frequent report
category.
Section 63.10(e)(vii) says that if the total duration of excess
emissions or process or control system exceedances for the reporting
period is less that 1 percent of the total operating time and the
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CMA Supplemental Comments
Page 5
continuous monitoring system downtime is less than 5 percent of the
total operating time, only the summary reports need be submitted. This
same test could be applied to determine whether a source should be
kicked back into a more frequent reporting requirement.
All excess emissions and monitoring system performance reports and
their associated summary reports are to be submitted within 30 days of
the end of the reporting period. Section 63.10(e)(vi) requires a
separate report for each hazardous air pollutant monitored. Since most
of the information contained in the reports will be duplicated for each
pollutant, there is no need for a separate report for each pollutant.
Section 63.15
Section 63.15(a)(l) states that each permit application will be
available to the public. Section 503(e) of the CAAA recognized that
applicants may be required to submit certain information entitled to
protection under Section 114(c). The last sentence of 63.15(a)(l)
should be modified to read, "in addition, and consistent with
protections recognized in Section 503(e) of the Act, a copy..."
Conclusion
This concludes CMA's supplementary written testimony on Part 63
General Provisions. CMA thanks the NAPCTAC for the opportunity to
present some of our ideas and concerns. We look forward to
constructive interaction with EPA as it moves forward in the rulemaking
process.
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SUMMARY OF COMMENTS AND RESPONSES ON
GENERAL PROVISIONS FOR NESHAP FOR SOURCE CATEGORIES
NOVEMBER 19, 1991
Comments and Discussion Following EPA Presentation
Vivian Mclntire (Eastman Chemicals Company) complimented EPA
on consolidating and better organizing the general provisions.
As a point of clarification, Michele Dubow (EPA) added that
individual NESHAP in Part 63 will reference the general
provisions and that the general provisions are designed to lead
owners and operators through a determination of applicability of
a relevant NESHAP- Vivian asked if the general provisions can be
overridden by provisions in individual standards and by Title V
and Title VII reguirements. Michele responded that the general
provisions can be overridden by reguirements in individual
standards or in the source's Title V operating permit if those
reguirements are at least at stringent as the general provisions.
The permitting authority will look at all applicable reguirements
and choose the most stringent and incorporate those into the
permit.
Bill O'Sullivan (New Jersey Department of Environmental
Protection) asked Michele to expand on the guality
assurance/guality control (QA/QC) reguirements and the startup,
shutdown, and malfunction plan reguirement added to the general
provisions. He asked what the reguirements will look like and
how much detail is included for them in the rule. Michele
explained the general content of the QA/QC reguirements, their
level of detail, and that they reguire advance approval from the
enforcement agency. Michele also explained that the general
provisions specify the purpose of the startup, shutdown, and
malfunction plan reguirement, but the contents of the plan are
specified in much less detail than the QA/QC reguirements. Also,
although the startup, shutdown, and malfunction plan does not
need advance approval to be implemented, the enforcement agency
can reguire that the source make changes to it.
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Brian Taranto (Exxon Chemical Americas) asked about the
procedures in the general provisions for preconstruction review
and approval and how they relate to State preconstruction
permitting processes. His concern has to do with making sure
that federal and State rules do not contradict each other.
Michele responded that if the source must go through the same
process at the State level, and the State's requirements are at
least as stringent as the general provisions, then the general
provisions would be covered by the State's process and the source
would not have to go through the process twice. She added that
EPA's rules cannot be responsive to every State since State rules
differ from each other; the role of the general provisions is to
establish minimum federal requirements. The EPA's goal is to
create provisions that do not duplicate or conflict with State
requirements. The EPA envisions these processes being integrated
or melded by the permitting authority in each State pursuant to
the Title V permit program. Michele also explained that EPA
incorporated procedures for preconstruction review and approval
because various subsections of Section 112 of the amended Clean
Air Act (e.g., Section 112(i)) require such approval for sources
to begin construction. The procedures included for Part 63 are
similar to those included in the general provisions for Parts 60
and 61. Bruce Jordan (EPA) added that EPA's objective is to
catalog in one place all the requirements related to a source's
obligations regarding MACT standards.
John Pinkerton (National Council of the Paper Industry for
Air and Stream Improvement) asked if EPA is considering modifying
the general provisions to reflect experience about what does not
work. Doug Bell (EPA) responded that the existing general
provisions have been modified many times, that this is not a
problem for the future, and that EPA would carry out such
modifications by proposing and promulgating amendments to the
general provisions in the Federal Register. Michele added that
EPA is open to suggestions after proposal about what might not
work in the general provisions; the EPA will consider carefully
comments on how to make the provisions work better.
Pat Atkins (Aluminum Company of America) asked if
consideration is being given to providing a roadmap to explain
the requirements in the general provisions and how they fit
together. He said he thought such a roadmap would be an
important tool for eduction and training. Michele responded that
a contractor is now working on developing computer-based
flowcharts and timelines to assist EPA in making sure that the
deadlines and turnaround times specified in the general
provisions are reasonable. The EPA plans to use these computer-
based visual aids as educational and training tools. The
flowcharts and timelines should be available by the time the
regulation is promulgated; they will not be available in time for
the public comment period following proposal.
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Comments and Discussion Following Presentation by Danny Anderson
on Behalf of the Chemical Manufacturers Association
Vivian asked Danny Anderson (First Chemical Corporation) if
he would still object to including control device requirements
for flares in the general provisions if other control devices
besides flares were also included. Danny responded that he
believes the level of detail included for the control device
requirements is not appropriate for the general provisions and
such requirements should be included in individual standards.
John asked Danny if he thought 90 days after notification of
a performance test (i.e., a total of 120 days after the effective
date of a standard) was a realistic time period in which to plan
and conduct the test. Danny answered that it depends on the
amount of planning required (e.g., there is a big difference
between an incinerator and a dry cleaner); however, in general,
the longer the amount of time allowed, the better. He believes a
balance should be struck and enough flexibility should be allowed
that the details for performance tests can be worked out ahead of
time on a local level by the permitting agency and the source.
William Dennison (Dennison and Associates) commented that whether
90 days is adequate depends on the complexity of the source;
also, the tight timetable for completing a required performance
test reinforces Pat's earlier comment on the need for a good
roadmap to help sources attain compliance. If companies are
going to take the risk, they need to know rather well what they
are getting involved in.
Vivian emphasized that she foresees significant problems in
terms of overburdened resources as numerous affected sources
attempt to comply with initial MACT standards simultaneously.
She said there may need to be some special attention given at
that time (i.e., for the first group of standards) to prevent
such problems. Bill concurred with Vivian's concern about
overdrawing available testing resources. He also asked if the
120 day deadline for conducting a required performance test is
given in the statute or if EPA has discretion to change it. He
suggested keeping the 180 day deadline from the general
provisions in Part 60 since this period is more workable and it
would maintain consistency with current rules. Michele responded
that 120 days is not a statutory deadline; rather, it represents
a compromise between the performance test requirements in Parts
60 and 61. Between proposal and promulgation, EPA plans to
review the timing in the general provisions carefully and
consider alternative timing schemes.
Vivian commented that there needs to be a mechanism for
special exceptions or waivers where it is impossible to do the
testing within the first 6 months. In response to a question by
a committee member, she added that she sees this variance process
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being administered by States, since MACT standards will be
implemented by States.
Doug closed the session on the general provisions by stating
that EPA appreciates the comments given and that some of these
comments have already been addressed in the proposed rulemaking.
However, he cautioned people not to be surprised if they do not
see their concerns addressed in the proposal since the package is
at a stage where it is too late to make changes. Therefore, EPA
will treat the comments given at this NAPCTAC meeting as early
public comments.
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A: EPA PRESENTATION
Daphne McMurrer of the Standards Development Branch,
presenter, opened by reminding everyone that the Hazardous
Organic NESHAP (HON) is scheduled to be proposed in late February
or early March 1992, and promulgated in November 1992. It is
expected that 110 of the 189 hazardous air pollutants (HAP)
listed in the Clean Air Act Amendments (CAAA) of 1990 will be
regulated by the HON.
The HON will be applicable to all Synthetic Organic Chemical
Manufacturing Industry (SOCMI) processes which produce a HAP as a
product, by-product, co-product, intermediate, or use a HAP as a
reactant or raw material. Only major sources, as defined by the
CAAA, will be regulated. The EPA will be seeking comment on the
existence of SOCMI area sources and the applicability of the HON
to area sources in the proposed standard. The remainder, and
majority, of the presentation addressed the concept of emissions
averaging.
The averaging scheme for the HON is being developed to
address the complexity and diversity within the source category-
Because of this complexity and diversity, there can be a
significant cost incurred for individual sources using point-by-
point compliance. Emissions averaging is intended to provide
flexibility and allow equal or greater emission reductions at
lower costs. This concept differs from bubbling since no
emission caps will be set. The setting of emission caps under
previous bubbling policies did not account for decreases in
production or dismantling of equipment. As a result, when one or
more of these events occurred, the remaining emission points were
free to emit more than originally intended without exceeding the
emission cap. Emissions averaging will take into account changes
to the source and keep emissions from individual emission points
at the intended level.
1 s
J.J
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The scope of the HON emissions averaging will be determined
by the definition of "source." The current definition includes
all product process units regulated by the HON, in a contiguous
area, that are under common control. Emissions averaging will
not be allowed with any product process units which are not
regulated by the HON (outside the definition of source).
Emissions averaging may include emissions from eligible process
vents, storage tanks, wastewater streams, and transfer loading
racks. Emissions from equipment leaks will be excluded from
emissions averaging due to the uncertainty involved in
quantifying emissions, the inability to assign a known, nominal
emissions control efficiency rating, and because the equipment
leaks standard was developed through the regulatory negotiation
process and including it would nullify the agreement reached.
The form and compliance .plans being developed will indicate
what requirements are presented and described in the regulation.
Compliance requirements will include quarterly emissions limits
to allow more flexibility in administrating and enforcing
emissions averaging. Compliance requirements will also include
point-by-point commitments for the application of control devices
on emission points involved in an average. Mass emission
estimates will be required for all emission points included in
the averages. All compliance commitments will be part of the
Title V permits. Any change made by a source to the structure of
the emissions average will be reviewed by the State as part of
administering the Title V permits. Alternative operating
scenarios can be planned and included in the permit so that a
source has the flexibility to make changes without automatically
violating the emissions average.
For emissions averaging, under-controlling an emission point
will be regarded as a debit, while over-controlling an emission
point will be regarded as a credit. The three ways to obtain
credits are discussed below. First, credits may be generated by
controlling eligible emission points that are not required to
apply control. For example, credits would be given for
controlling a small storage tank that may be below the size
applicability criteria for the HON, and would not be required to
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apply emission controls. Second, credits can be generated by
using higher efficiency controls than required by the standard.
The higher efficiency must be achieved by using a different
control technology than that required by the regulation, and not
by using the same control technology at increased efficiency.
For example, the standard may require 98 percent control
efficiency on a process vent and if the source used a different
control technology which had an EPA nominal efficiency rating of
99 percent, it would receive credit for the 1 percent additional
control. The third way to generate credits is to use approved
pollution prevention methods. This can be used on points for
which control is or is not required. As with the above methods
to generate a credit, the emission reduction must be greater than
that required by the standard for the relevant emissions points.
Credits cannot be generated by production cutbacks or any
controls applied before promulgation of the standard, except
controls applied as part of the Early Reductions program and
pollution prevention measures taken since 1987. These allowances
are provided to encourage participation in the Early Reductions
program and reward innovative emission reductions made before the
standard is promulgated.
The final topic discussed was the use and value of a
discounting factor. A discounting factor reduces the value of
emission credits generated as part of an emissions average,
thereby ensuring greater emission reductions than would be
achieved using point-by-point compliance. It is judged by EPA
that the use of a discounting factor is fair and reasonable
because of cost savings achieved using emissions averaging. The
discounting factor chosen will reflect uncertainties in emissions
estimation procedures. The states feel that there is great
uncertainty for some of the emission estimation procedures
currently being used, and the discounting factor should
compensate for those uncertainties. The factor will only be
applied to the emission points generating credits to be used in
emissions averaging.
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HAZARDOUS ORGANIC NESHAP
(HON)
November 19,1991
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Structure of the HON
Applicability
- SOCMI
- "Major Sources"
Requirements for Vents, Tanks,
Transfer & Waste Water
- point by point compliance
- emissions averaging
Requirements for Equipment Leaks
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EMISSIONS AVERAGING
for the
HON
GOAL:
Equal or Greater Emissions
Reductions
at a Lower Cost
-------
SCOPE
Set by definition of "Source"
- SOCMI product process units
- regulated by HON
- in a contiguous area
- under common control
Equipment leaks excluded due
to uncertainty of emissions
-------
FORM & COMPLIANCE PLANS
Quarterly Emissions Limit
Compliance
- point by point committments
- emissions accounting for points in
averages
Title V Permits
-------
CREDITS
3 Ways to generate credits:
- controlling points without control requirements
- using higher efficiency controls than required
- pollution prevention
Cannot generate credits with:
- production cutbacks
- pre-existing controls, except
Early Reduction Controls
Pollution Prevention since 1987
-------
Discounting Factor
Only applied to points
generating credits
Used to reflect
- cost savings
- uncertainties in emissions estimates
-------
CHEMICAL
MANUFACTURERS
ASSOCIATION
STATEMENT OF
THOMAS ROBINSON
ON BEHALF OF
THE CHEMICAL MANUFACTURERS ASSOCIATION
BEFORE THE
NATIONAL AIR POLLUTION CONTROL TECHNIQUES
ADVISORY COMMITTEE
ON
EPA'S DEVELOPMENT OF NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
FOR HAZARDOUS ORGANICS
NOVEMBER 19, 1991
£..
•*•
2501 M Street, NW 202-887-1100
Washington, D.C. 20037 Telex 89617 (CMA WSH)
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CHEMICAL MANUFACTURERS ASSOCIATION
TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE ON
EPA'S DEVELOPMENT OF NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
FOR HAZARDOUS ORGANICS
Good morning. I'm Thomas Robinson. I'm Manager of Regulatory
Affairs at Vulcan Chemicals Corporation. I appreciate the opportunity
to testify today on behalf of the Chemical Manufacturers Association.
CMA is a non-profit trade association whose members make up more
than 90 percent of the productive capacity for basic industrial
chemicals in the United States.
In my presentation today, I will touch briefly on the HON issues
that are most important to members of CMA. As you might well imagine,
the impact of these regulations will be significant for CMA's member
companies.
One of the most important issues is emissions trading. It's a
cost-effective and efficient way to achieve the regulation's pollution
control objectives. At the same time, averaging will help our industry
stay competitive in an increasingly competitive world economy.
In our view, every effort should be made to make the averaging
program as straightforward as possible, as effective as possible, and
as simple to manage as possible—for both the regulators and the
regulated.
Point-by-point trading will keep administration of the program
simple. Having the flexibility to trade across emission types and
between process units will be key, in the long run, to achieving a
successful averaging program.
Based on our experience, trading should be allowed between all
units in a source category; between all units with the same MACT
standards; and between all source categories regulated on a single
promulgation date.As the scope of emissions trading expands, there are
more opportunities for environmental benefits.
Another important issue for a successful averaging program
involves credits. In our view, sources should receive credit for
emissions controls that are more stringent than MACT and for emissions
-------
controls that aren't covered by the standard--regardless of when the
controls were installed.
Not allowing credit for controls applied before an artificial
baseline date is counterproductive. It punishes companies which have
taken the initiative--voluntarily--to reduce emissions. It also
directly conflicts with other EPA programs, most notably the agency's
Industrial Toxics Program, also known as the "33/50" program.
Denying credit will simply delay the installation of non-required
control devices and technologies. The result of that will be a net
loss to the environment.
When measuring credits, a discounting factor is not necessary when
calculating credits for emissions averaging because EPA's control
efficiencies and the emissions averaging program conservatively
estimate actual emissions.
Another key element of the HON is de minimis cutoffs. We see them
as an integral part of the standard-setting procedure--in large measure
because they achieve the most environmental benefit per implementation
dollar. Put another way, de minimis cutoffs will return the most
environmental benefit for each dollar spent.
The de minimis concept is already embodied in individual state
regulations, existing NSPS standards, the federal concept of Total
Resource Effectiveness, and the recently negotiated regulation on
equipment leaks.
Without de minimis cutoffs MACT would apply to all emissions
points with little or no net positive effect on the environment.
Requiring the application of technology beyond the point of diminishing
benefits will be counter-productive.
A third key issue will be the definition of "source" and "major
source". EPA should define major source broadly, including contiguous
facilities in its definition.
A broad definition satisfies the fundamental purpose of the new
regulatory regime for air toxics, focusing on efficient application of
technology based standards. A broad definition of "source" will allow
the Agency to mandate controls for individual emission points. At the
same time, it will maximize the impact of these controls to reduce a
plant's overall emissions. This, of course, is the intent of the Act.
HON applicability is very important to our members. Sources need
a simple system to determine applicability clearly and conclusively.
If each process is regulated once under a single set of applicable
regulations, industry will be most effectively and efficiently
regulated under the Act.
The HON MACT is a source category based standard. Consequently,
applicability criteria must determine whether a source "resides within"
a source category regulated by the HON MACT. Units regulated by the HON
should not be subject to la_ter, possibly incompatible MACT standards.
-------
Once a source has been "assigned" to a source category, it will
know exactly which regulations it must follow, and when it must
comply. All hazardous emissions will be effectively regulated by the
standard covering that category. This approach will alleviate much of
industry's uncertainty, and ease EPA's administrative burden.
Without clearly defined applicability criteria, the limits of
the regulated population will continue to expand and it will become
more difficult to define. Potentially, the HON could expand to cover
all units that create trace amounts of a stated chemical, stretching
far beyond the synthetic organic chemical manufacturing industry and
becoming an administrative nightmare.
The last general HON issue I want to raise is timing and
compliance. If EPA promulgates a single HON encompassing all of SOCMI
at one time, it will be difficult, perhaps impossible, for industry to
meet required compliance deadlines. Equipment shortages, delayed
deliveries, overburdened agencies facing new levels of permit
applications, and a scarcity of internal resources are all formidable
obstacles to compliance.
Under this scenario, a source may find itself unable to comply due
to events beyond its control, such as delays in construction permits.
The Agency must provide for these possibilities in its compliance
timeline.
Furthermore, EPA should consider, in its development of lower
quantity threshold regulations, the impact such regulations will have
on the HON. The scope of the HON is already broad, covering over half
of the listed source categories. A significant lowering of lesser
quantity thresholds, and a subsequent increase in the number of sources
trying to comply within the next few years, will further increase the
burden on overloaded agencies. It will also increase the difficulty of
obtaining control equipment in a reasonable time frame.
EPA should consider the net environmental benefits of control
technologies when considering alternative technologies and setting MACT
standards. Increased NOx emissions and fuel consumption are both
by-products of familiar control technologies. In areas of
non-attainment, the maximum environmental improvement may be achieved
by using a marginally less efficient technology to achieve a balance
between toxics, NOx, SOx, and energy consumption.
I would like to spend my remaining time discussing a specific area
of the HON - secondary emissions from wastewater.
The HON includes industrial wastewater because volatile air toxics
from wastewater collection and treatment systems can be released to the
atmosphere. CMA supports the regulation of wastewater emissions.
However, there are ways to maximize overall controls and minimize
costs.
Not all HAP's can vaporize to the atmosphere. CMA encourages the
Agency to implement a tiered approach to controlling wastewater
-------
emissions based on physical chemistry. Only volatile Group 1 compounds
-those which have the correct physical properties to actually enter the
atmosphere - should be regulated. Non-volatile compounds which, by the
laws of physics and chemistry, cannot leave the wastewater matrix
should not be regulated.
A clear applicability procedure for wastewater, including de
minimis cutoffs, is also necessary. This insures that critical
secondary emissions are regulated and non-volatile ones are excluded.
CMA is concerned with the Agency's use of Reference Method 25D to
analyze emissions from wastewater. This analytical method should not
be used under the HON. It does not correctly identify the truly
volatile constituent of total organics present in the wastewater
matrix. Method 25D will result in the unnecessary and costly control
of many wastewater streams which have no significant hazardous
emissions.
CMA does not support steam stripping as the optimal control
technology for wastewater emissions. Steam stripping is inappropriate
for many HAP chemicals that are reactive with water, infinitively
soluble, or form azeotropes. Steam stripping is prone to operational
problems and it is difficult to dispose of the stripped residues.
Steam stripping is also incompatible with recently upgraded biological
treatment facilities required under Clean Water Act regulations.
Finally, the agency should exempt those systems which are closed
to atmosphere. To do this, the point of generation must be clearly
defined as the first air-water interface with the potential for organic
release to the atmosphere.
In conclusion, CMA thanks the NAPCTAC committee for this
opportunity to present some of our ideas and concerns regarding the
HON. We look forward to working with with EPA as it moves forward in
the rulemaking process. At this point I'll be pleased to answer any
questions from the committee.
-------
Discussion
Following the EPA presentation, Mr. Bruce Jordan, Director
of the Emission Standards Division, discussed the four goals of
the HON standard. The first goal was to provide flexibility to
industry to help minimize the costs of meeting the standard. The
second was to provide ease of implementation. Third was
certainty in enforceability. And fourth was to prevent
environmental damage.
Committee member Mr. Donald Arkell (Lane Regional Air
Pollution Authority) opened the question segment by asking how
new and existing emission points would be distinguished for the
purposes of emissions averaging. Ms. McMurrer replied that
Section 112(g) of the CAAA determines new emission points within
the boundaries of the existing source. She stated that new
emission points are not available for averaging, and would be
subject to the new source MACT. Existing points within a source
may only be averaged with other existing points. Mr. Arkell
asked if that meant new and existing sources could not be
averaged together. Mr. Jordan replied that was indeed correct.
Ms. McMurrer took this opportunity to reiterate the definition of
the terms emission point and source. An emission point is an
individual tank or process vent while a source (as defined in the
presentation) is the collection of SOCMI process units subject to
the HON in a contiguous area under common control.
Mr. Arkell noted that the emissions averaging accounting
process sounded difficult, specifically the calculation of
quarterly emission estimates. Dr. Jan Meyer, Standards
Development Branch, answered that while extra recordkeeping would
be required, the rule will give explicit instructions on how to
calculate emissions for the points included in emissions
averages. The data used to estimate emissions will be site-
specific. To comply with the rule, sources must also show the
parameters they use to demonstrate their proper use of control
technology.
-------
Committee member Mr. Brian Taranto (Exxon Chemical Americas)
asked what activities could generate emission credits,
specifically activities related to the application of early
reduction controls covered under Section 112(i) of the Act.
Ms. McMurrer replied that those sources that are part of the
Early Reductions program would be given credit for their
appligation of controls that are more stringent than the RON
standard. Mr. Taranto asked if other emission reduction
activities taken before promulgation would generate emission
credits. Ms. McMurrer replied that only activities under the
Early Reductions program and pollution prevention activities
since 1987 would generate credits.
At this time, Mr. Taranto asked whether emissions averaging
would be applicable to other MACT standards besides HON.
Mr. Jordan replied that emissions averaging is currently being
considered only for the HON and that the EPA would review its
applicability to other MACT standards on a case-by-case basis.
Mr. Jordan stated that emissions averaging will be studied
internally by the EPA and that comments will be collected and
considered between proposal and promulgation and, if warranted,
emissions averaging could be removed from the promulgated
standard.
Ms. Deborah Sheiman (Natural Resources Defense Council)
asked whether a quantitative analysis of the averaging scheme had
been done to determine the expected change in emissions.
Ms. McMurrer answered that emissions are expected to be egual to
those without averaging, or less using a discounting factor. The
actual decrease depends on the discounting factor chosen.
Ms. Sheiman then stated that the emission levels from which the
sources are starting do not necessarily reflect MACT. Mr. Jordan
reiterated the EPA's position that emissions averaging will
achieve the same amount or greater emission reductions than would
be achieved otherwise. Ms. McMurrer stated that credits can only
be generated by controlling emissions above the levels set by the
technical requirements. Mr. Jordan expounded on Ms. McMurrer's
statement by saying that, for example, every process vent may not
be controlled by the HON and this would provide a source
opportunities to achieve emission credits.
-------
Mr. Ralph Hise (Advanced Technologies Management, Inc.)
questioned whether the use of more stringent controls (i.e.,
innovative technologies) for credits would change the
determination of MACT. Dr. Jan Meyer and Mr. Jordan both
emphasized that MACT must be universally applicable and that
there may be individual cases where a more stringent control
technology can be applied that would not be widely applicable to
other similar emission points.
Ms. Vivian Mclntire (Eastman Chemicals Company) discussed
the subject of quarterly emission limits, specifically as they
related to compliance. She asked the attendees to suppose there
were two vents involved in an emissions average. One vent was in
compliance while the other vent was not. She questioned whether,
as a result, you would be out of compliance for the entire
quarter. Ms. McMurrer responded that yes, you would be out of
compliance for the entire quarter. She explained that a quarter
consists of a three-month rolling average. Ms. Mclntire then
asked what happens if you are out of compliance and whether the
states will be given the authority to decide compliance status.
Ms. McMurrer replied that enforcement action for an emissions
averaging non-compliance would be similar to enforcement actions
taken in the absence of emissions averaging and that states are
given authority to determine compliance since they establish the
permits.
Mr. William Dennison (Dennison and Associates) asked whether
the discounting factor of 20 percent is workable and whether or
not it incorporates any safety factor. Ms. McMurrer replied that
the proposed rule seeks comment on the need and value of the
discounting factor. She stated that EPA welcomed feedback on
this topic.
Next, Mr. Dennison stated that the standard did not seem to
allow a reduction in production to generate credits.
Ms. McMurrer replied that the production changes resulting in
different emissions are allowed. However, if any emission points
associated with the equipment experiencing changes in production
levels were involved in an emissions average, any unanticipated
debits would need to be balanced with additional credits. Ms.
-------
McMurrer further stated that Mr. Dennison was correct in saying
that production reductions could not be credited.
Dr. John Pinkerton (National Council of the Paper Industry
for Air and Stream Improvement, Inc.) asked how wastewater air
emissions fit into the emissions averaging concept. Dr. Meyer
replied that emissions from HON wastewater are distinguishable
from other wastewater because they are estimated at and
controlled from the point of generation. Dr. Pinkerton went on
to state that if he understood correctly, credits could not be
received for controlling wastewater emissions from non-SOCMI
processes. Ms. McMurrer stated that this was correct.
Committee member Mr. William O'Sullivan (N. J. Department of
Environmental Protection) commented that, as a representative of
state agencies, he was opposed to emissions averaging, especially
for new sources or new emission points. Mr. O'Sullivan then
provided EPA with three recommendations. The first
recommendation was to include enforceable short-term emission
limits with point-by-point commitments. Second, Mr. O'Sullivan
disagreed with the assignment of nominal control efficiency
values. He noted the wide variations in performance and
recommended that different efficiencies be assigned for different
levels of control for a control technology- Third,
Mr. O'Sullivan stated that under the Early Reductions program,
credits can be generated through process shutdowns. Mr.
O'Sullivan felt that shutdown credits should not be allowed
within the emissions averaging program.
Next, Ms. Sheiman asked how pollution prevention is being
defined. Ms. McMurrer answered that the definition from the
Pollution Prevention Act of 1990 was being used. Dr. Meyer added
that since pollution prevention was being incorporated into the
HON, the rule would give the definition as well. Ms. Sheiman
added that she felt that pollution prevention could be used as a
loophole.
For the final question, committee member Dr. Patrick Atkins
(Aluminum Company of America) asked why the Industrial Toxics
Program (ITP) was not included as an activity for generating
-------
emission credits. Mr. Jordan replied that many of the activities
taken under this program are pollution prevention measures and,
therefore, would be creditable under the HON. Those actions that
are part of the ITP, but are not pollution prevention, are not
creditable because the ITP is voluntary, and thus not enforceable
like the Early Reductions program.
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PROJECT STATUS REPORT: NESHAP FOR COKE OVEN EMISSIONS
A. EPA PRESENTATION
Ms. Amanda Agnew
Standards Development Branch
Emissions Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
(SLIDE #1) The purpose of this presentation is to brief the
committee on the status of the NESHAP for emissions from coke
ovens. (SLIDE #2) This summary of the status will examine the
general requirements of the Clean Air Act Amendments for coke
ovens, the emission limits specified in the Act, and a review of
the next steps to be taken in the development of a standard.
(SLIDE #3) The Act requires that EPA promulgate standards by
December 31, 1992, for maximum achievable control technology (MACT)
for existing coke batteries, lowest achievable emission rate (LAER)
for existing coke batteries, and MACT for new coke batteries. The
MACT standards for new batteries will apply only to new
construction ("greenfield" plants) and to expansions in coke
capacity. The MACT standards for new batteries will not apply to
existing batteries that are rebuilt unless there is an accompanying
increase in capacity. The EPA must also promulgate work practice
standards that the industry must comply with by November 15, 1993.
The Act also requires that EPA and DOE conduct a joint study of
cokemaking technology from October 1991 to September 1997; however,
this study has not yet been funded.
(SLIDE #4) The structure of the Act's requirements for coke
ovens provides two potential tracks for compliance. Special
provisions are given for those coke plant operators that wish to
qualify for an extension of the residual risk standard until 2020.
The "extension" track will require compliance with (1) specific
limits in the Act by November 1993, (2) LAER limits by January
1998, (3) revised LAER limits by January 2010, and
(4) the residual risk standard by January 2020. The second track
is designed for those owners or operators who are not seeking an
extension of the residual risk standard. On this compliance track,
MACT limits promulgated by EPA must be met by December 1995 and the
residual risk standard must be met by December 2003. Batteries
that are constructed after the proposal date must meet the MACT
standard for new batteries.
-------
(SLIDE 15) The Act specifies the least stringent emission
limits that can be applied to coke ovens. For batteries that are
on the extension track to defer the risk standard until 2020, the
limits that must be met by November 1993 are 8 percent leaking
doors (PLD), 1 percent leaking lids (PLL), 5 percent leaking
offtakes (5 PLO), and 16 seconds of emissions per charge
(s/charge). The MACT limits for batteries that are not on the
extension track cannot be less stringent than those just
described, and these limits must be met by December 1995. The
Act requires that the MACT limits be based on the average
emission limitation achieved by the best performing 12 percent of
all coke batteries for existing sources and the best performing
similar source for new sources.
(SLIDE #6) The Act also specifies the least stringent
limits that can be promulgated for LAER. Those limits are 3 PLD
(for doors less than 6 meters in height), 5 PLD (for doors 6
meters or more in height), 1 PLL, 4 PLOf and 16 s/charge. The
Act allows EPA to consider the exclusion of 2 leaking doors on
the last oven charged. The EPA can develop LAER limits more
stringent than those given in the Act based on the most stringent
limitation achieved in practice. The MACT standard for new
batteries shall not be less stringent than the LAER limits, and
the EPA must evaluate the use of sodium silicate and nonrecovery
cokemaking for new batteries.
(SLIDE #7) In addition to the emission limits, a work
practice rule is required by the Act. The EPA is coordinating
with the American Iron and Steel Institute (AISI) and the
American Coke and Coal Chemicals Institute (ACCCI) to identify
and establish general work practices. The approach under
consideration is to require each plant to develop a written set
of specific work practices that is tailored to their operation.
The work practices must be reviewed and approved by EPA. The
specific work practices are expected to include worker training,
worker certification, and specific operating and maintenance
procedures.
(SLIDE t8) As required by the Act, EPA is continuing its
evaluation of nonrecovery cokemaking. This process is promising
because of the potential to reduce the environmental impacts of
by-product cokemaking. The ovens are operated under a negative
pressure; consequently, emissions do not leak from the doors on
the ovens. There are no lids or offtakes on nonrecovery ovens,
which eliminates these two sources of emissions. The organic
compounds removed from the coal during the coking process are
burned with a high efficiency, which significantly reduces
emissions of air toxics. The nonrecovery process does not have a
by-product recovery plant, which eliminates another source of air
pollution as well as a source of hazardous waste and wastewater.
The nonrecovery process requires only one-third to one-
fourth of the labor required to operate by-product batteries.
For the most economical operation, waste heat from the
r 7
-------
nonrecovery process can be recovered to produce steam or
electricity; however, gas cleaning, heat recovery, and
cogeneration of electricity have not been demonstrated. The
nonrecovery batteries require more land than by-product
batteries, primarily because of their horizontal design instead
of the vertical design of by-product ovens.
(SLIDE #9) Several meetings have been held with
representatives from industry, State agencies, environmental
groups, and the steelworkers union to discuss the development of
the coke oven regulations. A major issue raised by the industry
relates to the interpretation of data and the adequacy of data
that might be used to support limits more stringent than those
given in the Act. The industry is also concerned about the
variability in test results, which they believe may be due to
observer error when the visible emission test method is used.
The use of different averaging times to enforce the standard
(e.g., an average of 3 daily observations or a monthly average)
has also been discussed. The environmental groups have been
interested in the potential environmental advantages of
nonrecovery ovens.
(SLIDE #10) The standard will be developed and proposed by
February 1992. Promulgation is scheduled for December 1992.
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EPA - NAPCTAC
COKE OVEN NESHAP
STATUS REPORT
NOVEMBER 1991
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OVERVIEW OF STATUS REPORT
I. CLEAN AIR ACT REQUIREMENTS
II. CLEAN AIR ACT SPECIFICATIONS
NEXT STEPS
-------
CLEAN AIR ACT REQUIREMENTS
I. EPA MUST PROMULGATE THESE STANDARDS BY 12/31/92:
• MACT for existing sources
• LAER for existing sources
• MACT for new sources
II. EPA MUST PROMULGATE WORK PRACTICE STANDARDS WITH INDUSTRY
COMPLIANCE BY 11/15/93
JOINT DOE/EPA STUDY OF COKE OVEN TECHNOLOGY: 10/91 • 09/97
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CLEAN AIR ACT REQUIREMENTS
(cont'd)
IV. INDUSTRY HAS A CHOICE OF TWO TRACKS OF COMPLIANCE:
A. Those ovens who elect to qualify for an extension of the residual risk standards
must:
Comply with default limits by 11/15/93
Comply with LAER limits by 01 /01 /98
Comply with revised LAER limits by 01 /01 /10
Comply with residual risk standard by 01/01/20
B. Those ovens who do not elect for the deferral of residual risk must:
Comply with existing source MACT limits by 12/31/95
Comply with residual risk standard by 12/31/03
C. Ovens commencing construction after proposal date must meet new source
MACT
-------
CLEAN AIR ACT SPECIFICATIONS
DEFAULT LIMITS TO BE MET IN 11/15/93:
6 percent leaking doors (PLD)
1 percent leaking lids (PLL)
5 percent leaking offtakes (PLO)
16 seconds per charge (s/charge)
MACT FOR EXISTING SOURCES LIMITS-AVERAGE ACHIEVED BY THE BEST
PERFORMING 12% OF SOURCES. AT A MINIMUM THESE LIMITS WILL NOT
EXCEED:
8 PLD
1 PLL
5 PLO
16 s/charge
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CLEAN AIR ACT SPECIFICATIONS
(cont'd)
LAER FOR EXISTING SOURCES LIMITS - THE MOST STRINGENT EMISSION
LIMITATION ACHIEVED IN PRACTICE. THESE LIMITS SHALL BE NO LESS
STRINGENT THAN:
3 PLD (short)
5 PLD (tall)
1 PLL
4PLO
16 s/charge
with an exclusion for emissions during the period after the closing of self-sealing
doors.
MACT FOR NEW SOURCES LIMITS - THESE LIMITS SHALL BE NO LESS
STRINGENT THAN THE LAER LIMITS. WHEN ESTABLISHING THESE LIMITS, THE
USE OF SODIUM SILICATE AND THE THOMPSON NONRECOVERY OVEN MUST
BE EVALUATED
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DEVELOPMENT OF WORK PRACTICE RULE
1. Coordinating with AISI to establish general work practices.
2. Require each plant to develop a written set of specific work practices.
3. Must be reviewed and approved by EPA.
4. Work practices will include items such as worker training/certification
and specific O & M procedures.
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NONRECOVERY OVEN
• Operates under negative pressure: no door leaks
• Significant reduction in air toxics emissions
• Environmental benefits from the elimination of the by-product
plant
• Requires one-third to one-fourth the labor of a conventional
oven
• Heat can be recovered to generate electricity-however, this
process has not yet been demonstrated
• Requires more land than by-product ovens
8
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ISSUES
• DATA INTERPRETATION
• METHOD 109 (or 303)
• AVERAGING TIMES
• NONRECOVERY OVENS
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u> i
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B. DISCUSSION
Following the EPA presentation, there were only two
questions from committee members. The first question dealt with
the industry's reaction to nonrecovery cokemaking. The EPA
replied that the coke industry was concerned about the cost of
new nonrecovery batteries, the effect on the economics of their
industry, and the uncertainties associated with the nonrecovery
process. However, several iron and steel companies are
investigating the process and some are considering replacing
their by-product batteries. The second question asked what
health risks were associated with the nonrecovery process. The
EPA explained that information was still being gathered to
evaluate emissions and potential risks from nonrecovery
batteries. An extensive stack test has just been completed, and
the final results should be ready in a few weeks. Other tests
may be conducted in the future.
CD
-------
DRY CLEANING NESHAP
STATUS REPORT
November 1991
-------
PURPOSE
Background
Recommended NESHAP
- MACT for Major Sources
- GACT for Area Sources
-------
ID
BACKGROUND
Large Source of Emissions
Due to Number of Facilities
Dry Cleaners Generally
Located in Populated Areas
Court Order Requires
Administrator to Sign Proposed
Rule by November 15,1991
-------
BACKGROUND
continued
Pollutant of Concern --
Perchloroethylene (PCE)
Almost all Facilities
are Small Businesses
-------
BACKGROUND
continued
Sector
Coin-operated
Commercial
Industrial
Total Number
Dry Cleaning
Machines
3,000
31,500
130
National Annual
Baseline Emissions
(tons/yr)
950
86,800
4,550
TOTAL
34,630
92,300
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CONTROL TECHNIQUES
ro
Two Types of Dry Cleaning Machines
- Dry-to-Dry
- Transfer
Two Sources of Emissions with Each
- Vents
- Fugitives
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CONTROL TECHNIQUES
continued
Effectiveness
Control Technology Dry-to-Dry Transfer
Vents
- Carbon Adsorber 95% 95%
- Refrigerated Condenser 95% 85%
Fugitives
- Pollution prevention Not Quantified
(good work practices)
- Use Dry-to-Dry instead of Transfer Up to 50%
MACT Floor
- Over 50% of existing machines achieve 95% control using
either a carbon adsorber or refrigerated condenser - except
coin-operated self-service machines, which have no control
-------
NESHAP DEVELOPMENT
UNDER CLEAN AIR ACT
98% of Dry Cleaners are
Area Sources
CAA Allows Us to Regulate
Area Sources Under GACT
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M ACT vs. G ACT
MACT APPROACH
May regulate both major and area
sources under MACT
GACT APPROACH
May regulate only area sources
under GACT, when appropriate
Dry cleaning source category was
Congress' example of a GACT
approach for area sources
CJl
Establish emission limits at least as
stringent as floor for new (best
controlled similar source) and
existing sources (best existing 12%)
Considers costs and economic
impacts above stringency floor
No floor required, but must
demonstrate that area sources
cause an adverse threat to health
or the environment
Considers costs, economic impacts
and technical capabilities of plant
owners or operators to operate and
maintain emission control systems
Requires residual risk review analysis
Residual risk analysis is not required
for area sources under GACT
-------
REGULATORY
ALTERNATIVES
Area Sources (< 10 tons)
Regulatory
Alternative
ia
II a
"|b
Major
Sources
(> 10 tons)
95%
95%
95%
Dry-to-Dry and
New Transfers
95%
(RC or CA)
95%
(RC or CA)
95%
(RC or CA)
Existing
Uncontrolled
Transfers
85%
(RC)
95%
(CA)
95%
(CA)
Existing RC
Controlled
Transfers
85%
(RC)
85%
(RC)
95%
(CA)
a Represents the MACT floor for Major Sources and GACT for Area Sources
Represents the MACT floor for both Major and Area Sources
-------
BASIS FOR SELECTION OF
ALTERNATIVE II UNDER
GACT FOR AREA SOURCES
Average Cost Effectiveness is Reasonable
($1,060 per ton HAP removed)
Existing RC-Controlled Transfer
Machines would Not have to Retrofit
at a Cost-Effectiveness of $15,200
No Significant Difference in Emission
Reduction (compared to RA
-------
OD
RECOMMENDED NESHAP
MACT for Major Sources (10 TRY or greater);
GACT for Area Sources (less than 10 TRY)
Set an Equipment Standard for Vented
Emissions (carbon adsorber, refrigerated
condenser, or equivalent)
- Major Sources
95% control for new and existing
-------
RECOMMENDED NESHAP
continued
- Area Sources
95% control for new
95% control for existing uncontrolled
g 85% control for existing transfer-controlled
- Operation and Manintenance Requirements
for Control Equipment
- Exemption
Dry-to-dry machine consuming less than
220 gal/yr
Transfer machine consuming less than
300 gal/yr
-------
RECOMMENDED NESHAP
continued
• Pollution Prevention for
Fugitive Emissions
- Weekly leak inspection (valves, hose connections, etc.)
« - Good housekeeping practices (drain cartridge
0 filters, store PCE and PCE-containing waste in tightly sealed,
nonreactive containers)
• Compliance
- New Sources
Upon start-up
- Existing Sources
18 months for large sources
36 months for small sources
-------
RECOMMENDED NESHAP
continued
• Recordkeeping
- Documentation of PCE consumption
- Weekly PCE liquid and vapor leak inspections
- Periods of desorption if CA is used
• Reporting
- Initial notification (required from controlled and
uncontrolled facilities)
- Initial compliance report
- Initial report of PCE consumption to verify exemption
-------
NEXT STEPS
• Publish proposed standard NOV 1991
in Federal Register
s • Hold Public Hearing JAN 1992
• End of 60-day public JAN 1992
comment period
• Administrator signs NOV 1992
final standard
-------
DISCUSSION
Following the EPA presentation, Mr. Bruce Jordan, EPA/ESD,
opened the floor to questions and comments from the NAPCTAC
members. Both EPA staff members and contractor personnel were
available to discuss any issues of concern. One industry
representative then made a short speech. The questions and
comments posed during the discussions are summarized below.
Ms. Vivian Mclntire, a committee member, inquired about
initial notification requirements. She asked if there is some
process available to make all of the small commercial businesses
aware that they have to make this type of notification.
Ms. Linda Herring, EPA/SDB, responded that a communication
strategy is being developed to spread the word about the
standard. Ms. Herring added that the trade associations are
aware of the notification requirement and they will be informing
their members.
Ms. Mclntire also asked whether, for purposes of this
standard, the de minimis levels are the 220 and 300 gallon per
year cutoffs. Mr. Jordan responded that, yes, these are the
proposed levels.
Mr. Ralph Hise, a committee member, asked how these levels
were picked. Ms. Herring responded that these levels were
selected based on economic considerations.
Mr. Donald Arkell, a committee member, asked where the
coin-operated machines fall. Ms. Herring responded that all of
these machines fall beneath the exempted level.
-------
Mr. William O'Sullivan, a committee member, asked whether
the residual risk/residual emissions from controlled machines had
been compared to the residual risk/residual emissions from
exempted machines. Mr. Jordan responded that, in some cases,
emissions from machines controlled to the level of the standard
might be higher than the emissions from exempted machines.
Mr. Jordan noted that many of the exempted machines already have
controls and that machines above the exemption level represent
more than 90 percent of the emissions.
Mr. O'Sullivan further commented that although EPA may not
be requested to look at residual risk, the Agency should look at
it anyway. Mr. Jordan responded that EPA did take a look at the
residual risk and that it is in the range of 1 x 10~6.
Mr. O'Sullivan then asked whether there was some way to
ensure that the EPA looks at residual risk, some automatic
trigger. Mr. Doug Bell, EPA/SDB, responded that considering
residual risk is optional for area sources.
Ms. Deborah Sheiman, a committee member, commented that at
the last NAPCTAC meeting there was some discussion about a new
German machine with a built-in control device that achieved
greater control. She inquired as to whether that machine was
considered further. Ms. Herring responded that EPA did consider
that technology; however, the manufacturer has not adequately
demonstrated what efficiency it can achieve. Ms. Herring added
that if the machine is used more in the future and data become
available, it could be an option for control.
A member of the audience asked how EPA would ensure that
annual reporting of PCE consumption is being made by the smallest
sources. He asked whether there is some type of registration
scheme available that States could use. Mr. Jordan responded
that this was a legitimate question and that maybe Mr. Bill
Fisher of the International Fabricare Institute could respond to
it since he was scheduled to. speak at the meeting.
-------
Mr. Pat Atkins, a committee member, asked whether the
recovered solvent is usable. Mr. Dave Beck, EPA/CPB, responded
that any solvent recovered from either a refrigerated condenser
or a carbon adsorber is put back through the process.
Mr. Fisher added that there is 100 percent PCE recovery from all
control devices.
Another member from the audience, a representative from
Safety Kleen, questioned whether some percentage (something like
50 to 60 percent) of the recovered PCE from still bottoms taken
offsite is added back into the calculation of solvent use. He
noted that if the percentage of PCE recovered from still bottoms
is not accounted for, it would make emissions estimates high.
Mr. Fisher commented that the numbers used in the technical
analysis are valid. He stated that the numbers reflect PCE
consumption, which accounts for the reuse of recovered solvent.
Another member of the audience, Mr. Max Batavia from
South Carolina, asked how the 18-month compliance time for major
sources and the 36-month compliance time for area sources will
mesh with Title V timing for State permit programs. Ms. Herring
responded that until the States have approved permit programs
under Title V, EPA will be responsible for permits.
Mr. O'Sullivan added that, concerning cost effectiveness, it
should be noted that $1,000 per ton is cheap for removing a
carcinogen from the air, but citing $15,000 per ton as expensive
for air toxics is giving the wrong impression. He said that this
cost is still relatively inexpensive. Mr. Bill Seitz,
Neighborhood Cleaners Association, stated that because PCE has
not yet been established as a carcinogen it should not be
referred to as such.
Mr. Fisher began his talk by noting that Mr. Seitz,
representing the Neighborhood Cleaners Association, concurred
with his position. Mr. Fisher observed that other branches of
the Agency had input into the standard after it was initially
-------
drafted by BSD, such as removing 1,1,1-TCA and wanting a cut-off
level that is 2.5 times higher than the one proposed. He stated
that he did not support these specific changes. Mr. Fisher then
stated that overall he did agree with the standards as proposed,
except for one problem: the timetable. He wanted to see the
standard finalized sooner, in the spring.
Following Mr. Fisher's brief remarks, Mr. Atkins asked if it
would be possible for dry cleaners to comply with requirements
without the standard. Mr. Fisher responded by saying that the
standards would be helpful.
-------
Status Briefing
Chromium Electroplating and Anodizing NESHAP
A. EPA PRESENTATION
Mr. Laiit Banker
Emission Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Summary
Mr. Lalit Banker provided a status update on developments in
the regulatory process for the chromium electroplating and
anodizing national emission standards for hazardous air
pollutants (NESHAP) since the last presentation to the Committee
in January 1991. The attached charts provide an outline of this
presentation.
Mr. Banker began the presentation by introducing the project
team and acknowledging their contributions. After a brief
summary of the operations involved in this source category, he
described the regulatory alternatives developed for decorative
chromium plating, chromic acid anodizing, and hard chromium
plating operations.
Two regulatory alternatives were considered for decorative
chromium plating operations. One alternative was based on the
use of chemical fume suppressants, and the other alternative was
based on the trivalent chromium plating process. Only one
regulatory alternative, based on the use of chemical fume
suppressants, was considered for chromium anodizing operations.
Other add-on control technologies were not considered for these
operations because other technologies are less effective in
reducing chromium emissions and more costly to use.
Both the trivalent chromium plating process and chemical
fume suppressants are pollution prevention technigues because
they reduce pollution at the source by inhibiting misting at the
surface of the plating solution. Both technologies achieve
similar emission reductions; however, the trivalent chromium
plating process is considered to be the better control technique
because it eliminates the use of hexavalent chromium plating
solutions (therefore eliminating hexavalent chromium emissions).
37
-------
Mr. Banker then presented nationwide impacts for these
regulatory alternatives for existing sources. No significant
economic impact is expected. Chemical fume suppressants
represent the maximum achievable control technology (MACT) floor
for existing decorative chromium electroplating and anodizing
operations, and the trivalent chromium plating process represents
MACT for new decorative chromium sources because this process is
the most effective technique evaluated for reducing hexavalent
chromium emissions.
Mr. Banker outlined the current staff recommendation to
subcategorize decorative chromium electroplating operations into
large and small operations based on production capacity- He
justified this subcategorization with the following findings:
(1) hexavalent chromium is a potent carcinogen; (2) chromium is a
significant contributor to urban air toxics; (3) there are high
residual risks from hexavalent chromium; and (4) large sources
are the most significant contributors of emissions from this
source category. Based on this subcategorization, the current
staff recommendations are to apply MACT to large sources and
generally available control technology (GACT) to small sources.
Therefore, the recommended standard for existing decorative
chromium plating operations would be currently based on the use
of chemical fume suppressants, which represent both MACT and GACT
for existing sources. The recommended standard for new
decorative chromium plating operations would be based on the
trivalent chromium process for new large operations and the use
of chemical fume suppressants for small operations.
In the case of chromium anodizing operations, where the
majority of the sources are area sources, the current staff
recommendation is to base the standard on chemical fume
suppressants for all operations.
The next discussion involved the five regulatory
alternatives evaluated for hard chromium electroplating
operations. Three control technologies formed the basis for the
alternatives: (1) a composite mesh pad system, (2) packed-bed
scrubbers, which are currently used by 40 percent of the
industry, and (3) chevron-blade mist eliminators.
Regulatory Alternative III is the MACT floor for existing
sources. Two alternatives above the floor and two below the
floor were evaluated. The two alternatives below the floor were
evaluated for GACT considerations.
Nationwide impacts were presented for all five regulatory
alternatives for existing facilities. The nationwide impacts
show that no significant economic burden is projected for any
regulatory alternative; a small business closure rate of less
than 5 percent would be expected for the most stringent
alternative. Because a large percentage of operations currently
-------
use packed-bed scrubbers, packed-bed scrubbers represent the MACT
floor.
As with decorative chromium plating operations, the hard
chromium plating source category was also subcategorized into
small and large sources based on production capacity, and the
current staff recommendation is to apply MACT to large sources
and GACT to small sources. Therefore, the proposed standards for
existing hard chromium plating operations would be based on
packed-bed scrubbers which represent MACT and GACT for existing
sources. The proposed standard for new sources would be based on
the use of composite mesh pad systems at large operations and
packed-bed scrubbers for small operations.
Mr. Banker ended the presentation by providing a current
project schedule. Proposal is planned to occur in April 1992,
and promulgation is planned for April 1993.
89
-------
STATUS
BRIEFING
CHROMIUM ELECTROPLATING
AND ANODIZING NESHAP
Briefing For
NATIONAL AIR POLLUTION CONTROL TECHNIQUES
ADVISORY COMMITTEE
NOVEMBER 19, 1991
COORDINATED BY
Lai it Banker
Project Team: Phil Mulrine, Tim Watkins, Nancy Pate
-------
REGULATORY ALTERNATIVES
(New and existing)
DECORATIVE Subcategory
Fume Suppressant (99%)
or
Trivalent Chromium (99%)
ANODIZING Subcategory
Fume Suppressant (99%)
-------
DECORATIVE AND ANODIZING
NATIONWIDE IMPACTS
(Based on existing)
DECORATIVE
•Control technology Trivalent
Chromium
•Is technology
demonstrated?
•% Of industry
using technology
•Emission t
reduction*, Mg/yr
•Economic impacts
•Capital costs, $
•Annualized
costs*, $
•Cost effectiveness,
$/Mg
yes
-No closures
-Pollution
Prevention
Fume
Suppressant
yes
80
10
-No closures
-Annual costs for
small plant $1,000
240,000
20,000
ANODIZING
Fume
Suppressant
yes
30
-No closures
-Annual costs
for small
plant $1,600
No cost
No cost
*- Emission reduction and annualized costs are beyond baseline.
"-There will be cost of control for uncontrolled facilities; however, the facilities with
add-on controls may derive cost savings since they do not have to operate the control
device in conjunction with the fume suppressants. Thereby, on a nationwide basis we
estimate no cost as a result of fume suppressants as control.
***-No estimates are provided because this technology Is applied to new sources.
-------
SUMMARY OF
RECOMMENDATIONS
NEW
EXISTING
DECORATIVE
Large
(MACT)
Trivalent
chromium
Fume
Suppressant
Small
(GACT)
Fume
Suppressant
Fume
Suppressant
ANODIZING
All sources
(GACT)
Fume
Suppressant
Fume
Suppressant
-------
REGULATORY ALTERNATIVES
(New and existing sources)
Hard Chrome Electroplating
Model Plant Sizes
Regulatory
Alternatives
i
ii
III (FLOOR)
IV
V
Large Medium Small
**
<] — Emerging Technology — •[>
(99.9%)
•^ Emerging [-»> Packed-bed
Technology Scrubber
(99.9%) (99%)
-3— Packed-bed Scrubber--^
(99%)
•^ — Packed-bed — [>- Chevron-blade
Scrubber Mist Eliminator
(99%) (95%)
-Chevron-blade Mist Eliminator-
(95%)
* Model plant sizes relate to the number of tanks/ampere-hours used. They do not relate
to small businesses.
** Emerging Technology—Advanced mesh-pad mist eliminator
94
-------
HARD CHROME ELECTROPLATING
NATIONWIDE IMPACTS
(Based on existing)
•Control technology
•Is technology
demonstrated?
•% Of industry
using technology
•Emission
reduction, Mg/yr**
•Annuajized
costs *, $
•Incremental cost
effectiveness, $/Mg
•End product price
increase
•Small business
closures
RANI
PBS
yes
40
140.8
RAN
ET/PBS
likely
143.7
RAI
ET
likely
144.2
11
million
1.7
million
22
million
3.5
million
31
million
21
million
* -PBS--Packed-bed scrubber
-ET—Emerging technology
"-Emission reduction and annuallzed costs are beyond baseline
35
-------
HARD CHROME ELECTROPLATING
NATIONWIDE IMPACTS
(Based on existing)
•Control technology
•Is technology
demonstrated?
•% Of industry
using technology
•Emission
reduction, Mg/yr**
•Annualized
costs, $
•Incremental Cost
effectiveness, $/Mg
•End product price
increase
•Small business
closures
RAIII
PBS
yes
40
140.8
RAIV
PBS/CBME
yes
40/30
139.0
RA V
CBME
yes
30
127.2
11
million
1.7
million
8
million
290,000
5
million
40,000
* --PBS-Packed-bed scrubber
--CBME-Chevron-blade mist eliminator
"--Emission reduction and annuallzed costs are beyond baseline
> if»
iO
-------
SUMMARY OF
RECOMMENDATIONS
Hard Chrome Electroplating
NEW EXISTING
Large Emerging Packed-bed
(MAGI) technology* scrubber
Small Packed-bed Packed-bed
(GACT) scrubber scrubber
'Emerging technology, if demonstrated after source tests. If this technology is
not demonstrated then packed-bed scrubber will be applied to new sources.
97
-------
PROJECT SCHEDULE
Proposal 04/92
Promulgation 04/93
-------
B. DISCUSSION
Following the EPA presentation, Mr. Bruce Jordan, BSD/EPA,
opened'the floor to questions and comments from the NAPCTAC
members and other interested parties.
Dr. John Pinkerton (National Council of the Paper Industry
for Air and Stream Improvement, Inc.) raised the first question.
Dr. Pinkerton asked if the hard chromium electroplating industry
was comfortable with a MACT standard for new sources based on
emerging technology given that test data are limited. Mr. Al
Vervaert (Emission Standards Division) replied that a decision to
base a new source standard on this technology would be based on
the available test data and that some new information was being
obtained from discussions with vendors at the current NAPCTAC
meeting. He elaborated that industry would be given the
opportunity to comment on the validity of this decision and that
the National Association of Metal Finishers (NAMF) has had no
concerns with the decision. Dr. Pinkerton asked how many
operations were currently using the emerging technology.
Mr. Vervaert replied that a small number of facilities are
currently using this technology. Ms. Robin Barker (Midwest
Research Institute) stated that approximately 50 operations out
of the total 5,000 industry sources were known to be using this
technology.
Ms. Vivian Mclntire (Eastman Chemicals Company) wanted to
know why fume suppressants, which have a 99 percent emission
reduction efficiency, were not considered as an option for hard
chromium electroplating operations. Mr. Vervaert explained that
there are problems for hard chrome platers with the two types of
fume suppressants considered. Wetting agents affect the quality
of plating by enhancing pitting problems, and foam blankets are
an explosion hazard because they trap the hydrogen gas generated
during the plating process. He stated that these problems were
more pronounced in hard chromium electroplating than decorative
chromium plating operations. Ms. Mclntire asked whether fume
suppressants could be considered MACT for existing sources if
they could be used. Mr. Vervaert replied that as long as the
emission limit was met, owners/operators could achieve the
standard in any manner they deemed appropriate for their
operation.
Mr. William O'Sullivan (New Jersey Department of
Environmental Protection) was concerned about how inspectors were
to determine that fume suppressants were being used; were they
easily observed or was there some standard testing method?
Mr. Lalit Banker (Emission Standards Division) replied that the
-------
regulation would specify the surface tension to be measured and
recorded, and that the frequency of measurement would provide
insurance that the wetting agents were being maintained properly
in the tank. Mr. 0'Sullivan asked if a device is available that
inspectors could use to measure surface tension. Mr. Vervaert
replied that the necessary instrument, a stalagmometer, would
probably be available onsite because owners/operators would
probably be required to take measurements at least daily.
Mr. O'Sullivan further asked why the emerging technology
costs are three times the costs of a packed-bed scrubber. He was
concerned about the high cost of what he thought was essentially
another scrubber. Ms. Barker replied that the costs are not
three times higher and that these costs reflect incremental
differences between the regulatory alternatives. The
technologies are not that different nor the costs that
exorbitant. The annualized costs are only 20 to 30 percent
higher than those of packed-bed scrubbers.
Mr. O'Sullivan asked a final question concerning the
annualized costs for the hard chromium electroplating regulatory
alternatives, which he felt were fairly high. Ms. Barker
explained that these costs are beyond baseline. A large
percentage of hard chromium electroplating operations
(40 percent) are already using packed-bed scrubbers at baseline
so the incremental costs for this technology are lower than those
for the emerging technology. However, the annualized costs for
the emerging technology reflect replacement and retrofit costs,
which results in higher incremental differences nationwide.
Mr. Banker added that, on a model plant basis, the capital costs
would range from $37,000 to install packed-bed scrubbers to
$58,000 for the emerging technology. The annualized costs would
range from $16,000 (packed-bed scrubber) to $17,000 (emerging
technology).
Mr. Ralph Hise (Advanced Technologies Management, Inc.)
raised a concern about the trivalent chromium plating process.
He asked whether the actual level of chromium emissions to the
environment changed with the use of this process, or was the type
of chromium emitted the significant factor. Mr. Banker replied
that the type of chromium emitted was different, and a
demonstration test was conducted recently to quantify the
emissions from the process. Mr. Vervaert added that the test is
expected to show that there are no chromium emissions, but
results are not yet available.
Ms. Deborah Sheiman (Natural Resources Defense Council)
asked why the trivalent chromium plating process was recommended
for new large decorative chromium electroplaters but not for
small decorative electroplaters. Mr. Banker answered that the
large sources had a higher residual risk, and the trivalent
chromium plating process represents the highest level of control
1QO
-------
for these large sources. Ms. Sheiman clarified her question by
asking if new small sources could use the trivalent chromium
plating process. Mr. Banker pointed out that the residual risks
were not as high for small sources and that fume suppressants can
achieve similar emission reductions with lower capital costs for
small sources. Mr. Doug Bell (Emission Standards Division) added
that the trivalent chromium process is considered MACT and new
small sources will only have to comply with GACT (fume
suppressants) because they are area sources. Ms. Sheiman
responded that the Agency also has the option to set MACT for
area sources.
Mr. Bruce Jordan (Emission Standards Division) asked if the
trivalent chromium process can be applied to small sources.
Mr. Banker replied that the technology could be applied to small
sources, but the costs are considered to be high for small
sources compared to the costs associated with using fume
suppressants. Mr. Vervaert ended the discussion by stating that
trivalent chromium is used by all sizes of decorative chromium
electroplaters. However, the Agency is setting MACT for the
larger sources and exercising its discretion to set GACT for
smaller sources.
Mr. Arkell asked about the basis for the source size cut-
off. Mr. Vervaert replied that it would be based on ampere-hours
per year (production rate). Mr. Banker added that the production
rate cutoff values are still to be determined. Ms. Sheiman made
a final comment that because hexavalent chromium is an extremely
potent carcinogen, if the source test at the trivalent chromium
plating facility shows there are no chromium emissions from this
process, then the trivalent chromium process should be the option
chosen for new sources, regardless of size.
Mr. William Dennison (Dennison and Associates) said he was
familiar with previous problems encountered with the trivalent
chromium process (e.g., darker finishes than hexavalent
chromium). He asked if any additional work had been done on
assessing the durability of trivalent chromium for hard chromium
electroplating applications. Mr. Vervaert answered that the
limiting factor is the thickness of plate that the trivalent
chromium process can achieve. He said a lot of research and
development is taking place on this issue. Mr. Dennison also
added that the flexibility of the standard covered the other
types of fume suppressants (i.e., ping-pong balls). Mr. Vervaert
reemphasized that the standard would be based on a concentration
limit, not a specific technology-
Dr. Pinkerton asked if the economic impacts for fume
suppressants addressed monitoring costs for the device. Both
Mr. Vervaert and Ms. Barker said they did not; however,
Ms. Barker said that these monitoring costs would be calculated
and provided in the supporting statement for the standard.
101
-------
Ms. Barker also said the device used to measure surface tension
was relatively inexpensive, less than $200. She briefly
summarized the monitoring requirements—the analysis should take
15 to 20 minutes, and monitoring might be done one or two times
per day or shift. Mr. Vervaert added that many owners/operators
were already using similar methods and that there should be no
additional burden on plant personnel.
Ms. Mclntire added a recommendation regarding the
flexibility of the standard. Because owners/operators have a
choice of control options to achieve the standard, she said
States should have the flexibility of considering these
alternatives in the permit. She requested that the States make
these determinations instead of having an involved process with
the EPA. Mr. Banker replied that guidelines for the States would
be provided in an enabling document.
Mr. O'Sullivan recommended that emission reductions and
residual emissions be given in future presentations so that it
would be easier for the audience to understand the regulatory
alternatives. He also recommended that the emerging technology,
once it is fully demonstrated, be considered for new small
sources of hard chromium electroplaters because the cost
difference between the emerging technology and packed-bed
scrubbers is not significant. Mr. Banker answered that the
incremental cost effectiveness between the two technologies,
based on existing sources, is too high to justify selection of
the more costly technology; therefore, packed-bed scrubbers are
recommended by the project staff as the basis of the standard.
Mr. Jordan added that cost effectiveness must be used in
conjunction with other factors in selecting control technologies
as the basis for the standards. Mr. Jordan said decisions cannot
be made based on cost-effectiveness alone.
The last question from the Committee was raised by
Dr. Patrick Atkins (Aluminum Company of America). He asked if
the emission limit was based on hexavalent, trivalent, or total
chromium. Mr. Vervaert replied that the limit was based on the
measurement technique used. For most of the data, the
colorimetric method was used for hexavalent chromium. However,
because of the low loading with the emerging technology, there
may be a detection sensitivity that requires an alternate method
analyzing total chromium. The test data from hard chromium
electroplating operations comparing the two methods show total
chromium is 10 to 20 percent higher than hexavalent chromium. It
is not certain if this is an artifact of the different
sensitivities of analytical methods or is an actual fact.
Mr. Jordan then opened the floor for questions from the
audience. Mr. Bob Wooten (North Carolina Department of
Environmental Management) asked if there were any organics in the
fume suppressants that might be "cooked off" to become volatile
102
-------
organic compounds or ozone precursors and affect ambient
attainment. Mr. Vervaert replied that the wetting agents were
fluorinated hydrocarbons, which are fairly stable. He was not
sure of the activation function in foam blankets. Ms. Barker
added that these fume suppressant formulations were proprietary;
however, due to their low bath concentrations, she expected there
would be a minimal potential for releases. She referred the
question to Mr. Dennis Masarik (M&T Harshaw), who represents a
major vendor of fume suppressants.
Mr. Masarik stated that temporary fume suppressants do
decompose in the plating bath. However, permanent fume
suppressants are lost through dragout from the plating tank. In
response to previous questions asked, he added that trivalent
chromium plating processes are now second and third generation,
so differences in the appearance of the two chromium plates is
not a problem. Also, surface tension monitoring kits for his
company's fume suppressants are provided, and their costs are
part of the fume suppressant cost. Finally, industry is working
very hard to develop a functional trivalent chromium as a
substitute for hard chromium operations currently using
hexavalent chromium.
Mr. Steve Spardel (Otto-York) asked the next question. His
company manufactures mesh pad technologies. He was concerned if
an owner/operator had several sources, would the owner/operator
have to meet the standard for the whole facility or for
individual stacks. Mr. Vervaert replied that the owner/operator
would have to make sure that existing or new individual tanks or
a combination of tanks venting to a common control device met
existing or new source standards. Ms. Barker simplified the
answer by stating that each emission source has to meet the
applicable standard at the discharge point.
Mr. Haile Mariam (EPA's-Office of Solid Waste) asked if
other plating alloys had been evaluated as substitutes for
chromium. Mr. Vervaert replied that he knew of no alternatives
for chromium in hard chromium engineering applications.
Mr. Vervaert stated that decorative chromium plating is performed
mainly because of consumers' taste for decorative finishes and
that some potential could exist for nickel plating as a
substitute if consumer preferences changed. Ms. Barker said the
only alternative considered for hard chromium plating was
electroless nickel, but it involved such a narrow range of
application it was not considered viable. Mr. Masarik added that
some alternatives industry is considering include ceramics, zinc,
copper, nickel, and other composites. However, no widespread
substitute has been found that yields the desired properties
achieved by hard chromium plating.
Finally, Ms. Lenora Geary (General Motors [GM]) asked if the
emerging technology could be scaled up to achieve the same
103
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control efficiency at very large operations. Mr. Vervaert asked
if GM had hard chromium electroplating tanks; he thought GM
mainly had decorative chromium operations. Ms. Geary responded
that GM does perform both hard and decorative chromium plating
operations. Mr. Vervaert said EPA was considering representative
facilities and did not anticipate any problems scaling up.
104
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Section 112(g)
Presentation to NAPCTAC
CJl
Tim Smith
EPA/OAQPS/PAB
November 19,1991
-------
Purpose
1. Introduce 112(g) requirements
2. Outline major regulatory issues
3. Outline latest EPA thinking on how to address
these issues
4. Discuss schedule for proposed rule
-------
NEW
New and Recon-
structed Sources
NEW SOURCE MACT
REQUIRED
AFTER TITLE V
EFFECTIVE DATE?
No
Yes
MAJOR SOURCE?
>10/25TPYORLQC
No
Yes
NEW OR
112 (G)
DOES
NOT
APPLY
EXISTING
EXISTING?
"MODIFICATION"
(EXISTING
SOURCE
MACT
APPLIES)
No
No
Phys Change or
Change in Meth of op?
i
Actu
Emission 1
,
Yes
al
icreases'
Yes
Exceed De Minimis
Levels?
Yes
Have emission
increases been
offset?
No
No
No
V
Not a
"modifi-
cation"
subject
to
112(9)
es
SCHEMATIC OF 112 (G) PROCESS
-------
Time
Case-by-case Case-by-case
MA C T w'th Stron9 clues
GO
Effective
Date
of Title V
(93 or 94)
Demonstrate
Continuing
Compliance compliance
Early
MACT
Proposal
MACT MACT
Promulgation Compliance
Types of 112(g) Effects
-------
112(g) Issues
Regulatory Issues
- Source Definition
- De Minimis Values
- Offsets
- Interface with Title V
Hazard Ranking Issues
-------
Source Definition
Need to address:
- Changes to existing equipment
- Addition of new equipment
-------
Source Definition
Existing Equipment Changes
Congressional intent is clear
- Historically: modification = new source standard
- 112(g): modification = existing source standard
- Wanted flexibility; eliminate unnecessary delays
Proposed approach:
- Change to existing process unit = modification
- Keep exclusions: changes in hours/rates (within
allowable), changes in raw materials (unless more
hazardous)
- Actual emissions: tons/yr basis
-------
Source Definition
Addition of New Equipment
ro
Congressional intent less clear
- New plantsite (greenfield): new source MACT
- New equipment at existing plant: ???
EPA reading: DOUBT that Congress intended all
new equipment at existing plants to be
"modifications"
Equity issue
-------
CO
Equity issue
1. Large new production unit at existing plant
Existing Production
80
tons/yr
60
tons/yr
Proposed
New Plant
100
tons/yr
Plant boundary
2. Small new greenfield plant
10
tons/yr
-------
Source Definition
Addition of New Equipment
Proposed approach
- New production unit: treat as new source
- New emission unit at existing production area: under
discussion
-------
H->
C/l
Proposed approaches:
- Offsets federally enforceable prior to the physical
change
- Allow alternative types of offset demonstrations
- Simplified: future decrease from one (or a few) units
- More complex: all contemporaneous increases/decreases
"More hazardous" means reduction of:
(1) More (1.1 to 1,1.3 to 1) of an equally hazardous pollutant OR
(2) At least 1:1 from more hazardous pollutant
-------
De Minimis Levels
Proposed approach:
- Each HAP is assigned a de minimis emission rate
- Calculate emission rate from health benchmark based
upon a model plant reflecting a reasonable worst-case
dispersion scenario
- Basis:
- Carcinogen: cone @ 10-6
- Chronic noncancer: RfC
- Acute noncancer: interim benchmark
- If none of above exist: default assumption
-------
Interface with Title V
Proposed approaches
- Section 112(g) modification is "Title I" modification,
Cannot operate without revised Title V permit.
- Title V permit can establish federally enforceable
emission baseline.
- New production unit: preconstruction review
-------
Schedule
EPA workgroup closure: January
OMB review: March-April
Proposal: early May
-------
Motor Vehicle Manufacturers Association
presentation to
National Air Pollution Control
Techniques Advisory Committee
on
Implementation of Section 112(g)
November 19, 1991
119
-------
- MODIFICATIONS
Title IE Air Toxics Clean Air Act Amendments.
Designed to limit emission increases of major sources prior
to MACT promulgation.
Designed to allow sources to make necessary and/or routine
changes.
Designed to benefit environment through required emissions
offsetting.
120
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IMPORTANT DEFINITIONAL TERMS
Definition of Source
112(a)(l) "stationary source or group of stationary
sources within a contiguous area and under common
control".
Exclusions
Important to make minor and/or routine changes in
operations.
De Minimis
Should be set at practicable levels.
Baseline
MVMA recommends verifiable monthly HAP
emissions.
121
-------
HAZARD RANKING
112(g)(l)(b): Requires "identification, to the extent
practicable, of the relative hazard to human health resulting
from emissions..."
Hazard is a function of both toxicity and dose.
Carcinogens and Non-carcinogens need to be ranked
together.
122
-------
OFFSETTING PROCEDURES
112(g)(l)(a): Increase in actual emissions... shall not be
considered a modification, if such increase... will be offset
by an equal or greater decrease in the quantity of emissions
of another HAP (or HAPs)... which is deemed more
hazardous...
Offsetting should allow for evaluation of the relative hazard
of the mixture of stream of HAPs.
Offsetting calculations should include both the potency
ranking and quantity of emissions.
A case-by-case option for offsetting calculations must be
allowed.
123
-------
CASE-BY-CASE DETERMINATIONS
112(g)(2)(a): requires case-by-case assessment for changes
in operations defined as modifications.
Modifications should be triggered only for significant
changes.
-------
ORAL STATEMENT OF
F. DAN GEALY
ATLANTIC RICHFIELD COMPANY (ARCO)
CHAIRMAN OF THE
AIR TOXICS TASK FORCE
FOR THE
AMERICAN PETROLEUM INSTITUTE
BEFORE THE
NATIONAL AIR POLLUTION CONTROL TECHNIQUES
ADVISORY COMMITTEE
NOVEMBER 19, 1991
125
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GOOD MORNING (AFTERNOON) . MY NAME IS DAN GEALY AND I AM
REPRESENTING THE AMERICAN PETROLEUM INSTITUTE. I AM PLEASED FOR
THE OPPORTUNITY TO PRESENT API'S VIEWS ON THE MODIFICATION
PROVISIONS IN SECTION 112(g) OF THE CLEAN AIR ACT AMENDMENTS.
ALTHOUGH WE HAVE A NUMBER OF CONCERNS WITH IMPLEMENTING SECTION
112(g) ON MODIFICATIONS, I WILL ADDRESS FOUR MAJOR CONCERNS:
O DEFINITION OF SOURCE;
O MODIFICATION EXCLUSIONS;
O PROVISIONS FOR EMISSION OFFSETS; AND
O DE MINIMIS CONSIDERATIONS FOR MODIFICATIONS.
DEFINITION OF SOURCE
API INTERPRETS THE DEFINITION OF SOURCE UNDER SECTION 112(g) TO BE
THE ENTIRE CONTIGUOUS FACILITY. SUCH A DEFINITION IS CONSISTENT
WITH SECTION 112(a)(1), AND IS NECESSARY FOR THE MODIFICATION
SECTION TO PROVIDE THE ABILITY TO OBTAIN OFFSETS FROM WITHIN THE
ENTIRE FACILITY.
IN TERMS OF THE REQUIREMENTS FOR EMISSION REDUCTIONS, API BELIEVES
THAT THESE REQUIREMENTS SHOULD NOT EXTEND BEYOND THE ACTUAL
EQUIPMENT TO BE MODIFIED. THIS INTERPRETATION IS CONSISTENT WITH
PRIOR EPA POLICIES IN ADDRESSING NEW SOURCE REVIEW. WHILE THIS
COMMENT MAY APPEAR TO STATE THE OBVIOUS, WE BELIEVE THAT IT IS
126
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IMPORTANT TO CLARIFY THIS POINT.
MODIFICATION EXCLUSIONS
API BELIEVES THAT SECTION 112(g) SHOULD ALSO BE CONSISTENT WITH NEW
SOURCE PERFORMANCE STANDARDS AND PREVENTION OF SIGNIFICANT
DETERIORATION PROGRAMS REGARDING EXCLUSIONS OF CERTAIN OPERATIONS.
THESE EXCLUSIONS INCLUDE:
0 CHANGES IN OPERATING RATES OF PROCESSES OR EQUIPMENT;
0 INCREASE IN OPERATING HOURS NOT PREVIOUSLY RESTRICTED;
0 CHANGES IN RAW MATERIAL USE OR OF FUEL USE ALREADY
ACCOMMODATED IN THE OPERATIONS;
O ROUTINE MAINTENANCE; AND
0 INCREASES IN PRODUCTION RATES THAT ARE ACCOMPLISHED WITHOUT A
CAPITAL EXPENDITURE ON THE STATIONARY SOURCE.
SUCH EXCLUSIONS ARE NECESSARY TO AVOID EXCESSIVE MODIFICATION
REQUIREMENTS FOR ACTIVITIES THAT ARE ASSOCIATED WITH THE NORMAL
VARIABILITY OF DAILY OPERATIONS OF AN INDUSTRIAL FACILITY.
FURTHER, GIVEN THE LARGE SCALE CHANGES LIKELY IN MANY FACILITIES AS
A RESULT OF THE CLEAN AIR ACT AMENDMENTS, API BELIEVES THAT
EXEMPTIONS SHOULD BE PROVIDED UNDER SECTION 112(g) FOR ANY PHYSICAL
CHANGE OR CHANGE IN OPERATION RESULTING FROM REQUIREMENTS MANDATED
BY THE CLEAN AIR ACT. WE ARE ESPECIALLY CONCERNED ABOUT THE
EXTENSIVE REFINERY CONSTRUCTION AND MODIFICATIONS MANDATED UNDER
127
-------
TITLE II OF THE AMENDMENTS THAT REQUIRE THE INDUSTRY TO PRODUCE
REFORMULATED GASOLINES TO REDUCE MOTOR VEHICLE EMISSIONS. THIS
MANDATED CONSTRUCTION/MODIFICATION PROGRAM WILL OCCUR OVER THE NEXT
THREE YEARS TO MEET THE TITLE II DEADLINES.
THESE SYSTEM CHANGES, AS REQUIRED BY LAW, SHOULD NOT BE PENALIZED
UNDER SECTION 112(g), PARTICULARLY BEFORE MACT REQUIREMENTS ARE
CHARACTERIZED. EPA SHOULD STRIVE TO ELIMINATE THE POTENTIAL FOR
REGULATORY TRAPS IN THE MODIFICATION PROGRAM THAT COULD RESULT FROM
MEETING THE DEMANDS OF OTHER SECTIONS OF THE CLEAN AIR ACT.
PROVISIONS FOR EMISSION OFFSETS
API SUPPORTS THE CONCEPT THAT OFFSETS CAN BE OBTAINED, FOR PURPOSES
OF MEETING REQUIREMENTS UNDER SECTION 112(g), FROM ANYWHERE WITHIN
A CONTIGUOUS FACILITY. WE ALSO BELIEVE THAT A 5 YEAR BANKING
PERIOD FOR OFFSETS IS GENERALLY ADEQUATE. API STRONGLY URGES THAT
OFFSET CREDIT BE PROVIDED FOR SHUTTING DOWN OPERATIONS OR EQUIPMENT
WITHIN A CONTIGUOUS FACILITY. SHUTDOWNS ARE A LEGITIMATE, AND
OFTEN THE MOST COST-EFFECTIVE, MEANS OF REDUCING EMISSIONS,
PARTICULARLY WHEN ASSOCIATED WITH REPLACEMENT BY MORE EFFICIENT
PROCESS OPERATIONS.
API IS CONCERNED THAT PROVISIONS FOR OFFSET CREDITS COULD BE MADE
TOO RESTRICTIVE BY LIMITING THE WAY POLLUTANTS ARE TRADED. THE
128
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CLEAN AIR SCIENCE ADVISORY BOARD IS CURRENTLY ADDRESSING HAZARDOUS
AIR POLLUTANT RANKING AND WEIGHTING ISSUES. NEVERTHELESS, API
URGES NAPCTAC TO RECOMMEND THAT EPA ADOPT A POLICY PROVIDING FOR
OFFSETS BASED ON A TOXICITY WEIGHTED RANKING OF TOTAL EMISSIONS
RATHER THAN RESTRICTING OFFSETS TO A POLLUTANT-BY-POLLUTANT BASIS.
OFFSETS BASED A TOXICITY WEIGHTED QUANTITY OF EMISSIONS WOULD
PROVIDE FOR A MUCH MORE WORKABLE PROGRAM. MANY OPERATIONS IN THE
PETROLEUM INDUSTRY INCLUDE THE HANDLING AND PROCESSING OF PETROLEUM
STREAMS CONTAINING A COMPLEX COMBINATION OF HYDROCARBON
CONSTITUENTS.
OFFSETTING ON A POLLUTANT-BY-POLLUTANT BASES WOULD CREATE AN
ACCOUNTING SYSTEM THAT WOULD BE DIFFICULT TO CONSTRUCT, MUCH LESS
MONITOR AND TRACK, GIVEN NORMAL VARIABILITY IN FEEDSTOCKS AND
OPERATIONS. USE OF A TOXICITY WEIGHTED QUANTITY BASED OFFSET
SYSTEM UNDER SECTION 112(g) WOULD PROVIDE THE FLEXIBILITY NEEDED TO
FOR A WORKABLE OFFSET PROGRAM. MORE IMPORTANT, THIS TYPE OF SYSTEM
WOULD MEET THE GOALS OF THE ACT.
DE MINIMIS CONSIDERATIONS FOR MODIFICATIONS
DE MINIMIS LEVELS FOR EXCLUDING A CHANGE FROM THE DEFINITION OF
MODIFICATION MUST BE RECONCILED WITH DE MINIMIS THRESHOLD LEVELS
ABOVE WHICH THERE IS A REQUIREMENT TO INSTALL MACT OR TO OBTAIN
OFFSETS. WE ARE CONCERNED THAT UNLESS DE MINIMIS MACT THRESHOLDS
-------
ARE MAINTAINED, MODIFICATION PROVISIONS COULD BE APPLIED TO MORE
UNITS AND EQUIPMENT THAN CALLED FOR UNDER THE MACT REQUIREMENTS OF
SECTION 112(d). SUCH AN OUTCOME WOULD BE CONTRARY TO THE INTENT OF
THE CAAA.
FIRST, API RECOMMENDS THAT SECTION 112(g) PROVISIONS PRESERVE
WHATEVER DE MINIMIS THRESHOLDS ARE ESTABLISHED AS PART OF THE MACT
RULES. SECOND, API RECOMMENDS THAT, PRIOR TO DEVELOPMENT OF MACT
RULES FOR THE SOURCE CATEGORIES, A DEFAULT DE MINIMIS HAP THRESHOLD
BE ESTABLISHED OF 5 PERCENT. THIS 5 PERCENT FIGURE IS BASED ON THE
NEGOTIATED RULE FOR SOCMI FUGITIVE EQUIPMENT LEAKS. AFTER MACT
RULES ARE DEVELOPED FOR RELEVANT SOURCE CATEGORIES, A REVISED DE
MINIMIS HAP THRESHOLD (IF, IN FACT, REVISED) WOULD APPLY TO ALL
SUBSEQUENT MODIFICATIONS.
IN CONCLUSION, API STRESSES THE IMPORTANCE OF PROVIDING A WORKABLE
AND FLEXIBLE PROGRAM FOR IMPLEMENTING SECTION 112(g) OF THE CLEAN
AIR ACT AMENDMENTS. THE RECOMMENDATIONS I HAVE MADE ON BEHALF OF
API WOULD PROVIDE FOR SUCH A PROGRAM WHILE FULFILLING THE GOAL OF
ENVIRONMENTAL PROTECTION DURING THE MODIFICATION OF INDUSTRIAL
FACILITIES.
NOVEMBER 19, 1991
130
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TESTIMONY OF THE
PHARMACEUTICAL MANUFACTURERS ASSOCIATION
BEFORE THE NATIONAL AIR POLLUTION CONTROL TECHNIQUES
ADVISORY COMMITTEE
CONCERNING SECTION 112(g) OF THE CLEAN AIR ACT
NOVEMBER 19, 1991
-------
Good afternoon, my name is Richard Vetter. I am
Associate Counsel for Burroughs Wellcome Co. with primary
responsibility for environmental matters. I am here today to
speak on behalf of the Pharmaceutical Manufacturers
Association ("PMA").
The PMA is a non-profit trade association representing
about one hundred manufacturers of pharmaceutical and
biological products. PMA member companies discover, develop,
manufacture and market most of the prescription drugs used in
the United States and about half of the world's supply of
prescription drugs. Each of PMA's member companies
manufacture a number of different products. Both the
particular product being manufactured and the quantity of that
product being manufactured vary over time. The type of
product being manufactured at any given time is dictated by
the current and near term need for that particular product.
The quantity being produced also depends on the current and
near term need for that product. The need for a particular
product can change rapidly. EPA has acknowledged this unique
aspect of the pharmaceutical industry in its draft control
techniques guidelines for the control of volatile organic
compound emissions from batch processes (the "Draft Batch
Process CTG") stating: "[F]luctuations in market demand often
drive production schedules, more so than in any other
industry."
While we strive to predict in advance what the need for a
particular product will be, it is difficult to accurately
determine very far in advance what a particular facility's
manufacturing schedule will be. In addition to the
uncertainty involved in predicting the demand for a particular
product, PMA member companies constantly strive to bring new
products to the market. Each such new product places
additional and/or different demands on a company's
manufacturing operations. The time that it takes to obtain
approval for the production and marketing of a new product
from the United States Food and Drug Administration (the
"FDA") is substantial, often as long as ten years. Due to the
cost of developing the new drug and the obvious need for that
drug, once approval has been obtained, it is essential that
the manufacture of that drug commence with a minimum of delay.
In order to effectively respond to the changing need for
their products and to maintain the necessary quality of those
products, most PMA member companies produce their products in
batches employing multipurpose equipment. This type of
-1-
1 -^
JL • j t-*
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operation also readily facilitates the rapid production of a
new drug once FDA approval has been obtained. In batch
operations, a particular quantity of an intermediate, active
substance or final drug product is produced at a given time.
Once the designated quantity has been produced, the equipment
which was employed is thoroughly cleaned and then used to
manufacture a different intermediate, active substance or
final drug product. The second process may employ basically
the same chemicals, a combination of chemicals used in the
previous process and new chemicals or entirely new chemicals.
The wide variation in the particular equipment being used and
the raw materials employed in the various processes lend a
number of unique characteristics to the pharmaceutical
industry. As EPA describes it in the Draft Batch Process CTG:
"Since the characteristics of emission streams emanating from
such equipment vary according to the product, the devices used
to control such streams must either be easily detached and
moved or be capable of controlling streams that vary widely in
solvent content, temperature and pressure."
It is essential to the continued viability of the United
States pharmaceutical industry that it be able to make changes
in its operations, whether to respond to changes in the
market, to manufacture a new product or to implement a change
in operations designed to achieve environmental benefits,
without unnecessary delay. EPA again clearly recognizes this
unique aspect of the pharmaceutical industry in the Draft
Batch Process CTG stating: "Such variation in emission stream
characteristics also presents some difficulty to agencies
responsible for issuing permits, since the actual emission
levels of point sources such as reactor kettle condensers and
the like will in some cases exceed the maximum permitted
yearly emission rates because a different product is
manufactured in the equipment. In most other industries,
plant personnel would apply for a permit modification.
However, the variability of equipment use and the short
production runs characteristic of this industry make the
application procedure and permit modification waiting period
unrealistic."
While the variability in emission stream characteristics
resulting from rapid equipment and product changes makes it
difficult to accurately anticipate changes in emissions, the
pharmaceutical industry can accurately demonstrate compliance
with permit conditions. The FDA requires pharmaceutical
manufacturers to keep accurate, detailed records of all
aspects of the production process. Through the use of
appropriate engineering calculations, these detailed records
can be used to determine the emissions from each batch
process. This procedure is not appropriate for determining
the rate and composition of emissions at a particular point in
time; however, it is reliable in determining the amount and
composition of emissions for the process as a whole.
I1 "> Q
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We believe that Congress clearly intended to provide the
degree of flexibility necessary to the competitive posture of
the U.S. pharmaceutical industry- Section 101 of the Clean
Air Act espouses two primary goals to be achieved through the
protection and enhancement of the Nation's air resources: 1)
promotion of the public health and welfare; and 2) promotion
of the productive capacity of the nation. Far too often, this
second goal of promoting the productive capacity of the nation
does not appear to be given appropriate consideration in
developing the various programs intended to implement the
requirements of the Clean Air Act. Congress addressed this
specific issue in the Clean Air Act Amendments of 1990 by
adding Section 502(b)(10). Section 502(b)(10) specifically
prescribes that operating permits provide for a significant
amount of operational flexibility as long as the changes do
not constitute a modification and do not exceed the emissions
allowable under the permit.
Section 112 (g) of the Clean Air Act was intended to act
as a transitional rule pending the determination and
imposition of maximum achievable control technology ("MACT").
It was not intended to obviate operational flexibility. PMA
member companies are very concerned that the Section 112(g)
program could, in fact, substantially and unjustifiably
restrict the operational flexibility which the U.S.
pharmaceutical industry needs to continue to compete in a
global market.
The EPA staff has previously stated its position
regarding certain key issues under section 112(g) and have
requested input on a number of other key issues. I would like
to take this opportunity to address those issues.
Definition of Major Source
The first issue is what constitutes a "major source" for
purposes of evaluating the effect of offsets. We believe that
"major source" should be construed as encompassing the entire
facility for purposes of evaluating offsets. This would most
effectively facilitate offsetting, thereby minimizing the
impact of environmentally inconsequential changes on a
facility's operations. From a practical standpoint, as long
as increased emissions are actually offset by decreased
emissions, it does not matter where at the facility the
reduction takes place. The final result is that there has
been no net increase in emissions.
Once it is determined that a greater than de minimis
increase in emissions of hazardous air pollutants ("HAPs")
has occurred, which cannot be offset, only the emission unit
which is the subject of the modification should be the subject
of the Section 112(g)(2) determination. Requiring a broader
determination would discourage companies from making changes
which could improve the effectiveness and quality of their
-------
operations. It would also place an enormous burden on the
agency responsible for making the determination. Limiting the
evaluation to the particular emission unit involved will
minimize the regulatory burden on both the regulated community
and the regulators. This treatment is also consistent with
the historical limitation on the application of control
requirements imposed under the new source performance
standards ("NSPS") program due to modifications.
Definition of New Source
A second issue of primary concern to PMA members is the
type of activities which can convert an "existing source" into
a "new source." It is essential that the section 112(g)
program recognize that the emission of a new or different HAP
from a particular emission source does not automatically
convert the source into a "new source" within the purview of
Section 112(a)(4). Such treatment is lacking in either
statutory or policy support. Where emissions of a particular
HAP or HAPs have either been addressed in an alternative
operating scenario or are not prohibited by a facility's
operating permit, there is no basis for asserting that the
emissions act to convert the "existing source" into a "new
source." Further, since section 112(a)(4) defines a "new
source" in terms of construction or reconstruction, the mere
emission of a new HAP without any requisite reconstruction
cannot convert an "existing source" into a "new source" for
purposes of Section 112(g).
The exact type of emissions coming from a particular
piece of multipurpose equipment employed in pharmaceutical
manufacturing operations is subject to significant variation.
Treating the emission of a new or different HAP from a
particular piece of equipment as converting an "existing
source" into a "new source" would effectively cripple the
operational flexibility which is essential to the
pharmaceutical industry.
Physical and Operational Changes
A third area of concern is the question of what
constitutes "[a] physical change in, or change in the method
of operation of, a major source." The EPA staff previously
indicated a willingness to adopt all of the exemptions
historically recognized under Title I. PMA strongly
encourages EPA to in fact adopt all of those exemptions.
While PMA believes all of these exemptions are important
and should be adopted, there are clearly some which are of the
greatest importance to the pharmaceutical industry. An
exclusion for the use of alternative raw materials is
important to the pharmaceutical industry. A key component in
our continuing efforts to improve our processes so as to
further improve efficacy, minimize environmental impacts and
•i! ~> r-
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increase product yield is the use of alternative raw
materials. Any change in raw materials is subject to FDA
preapproval, a long, arduous and often uncertain process.
Subjecting such changes to further delay due to review under
section 112(g) is neither appropriate nor required by the
Clean Air Act.
PMA also encourages EPA to adopt a new exemption for
pollution controls. Delaying the application of pollution
control equipment pending an evaluation under section 112(g)
is contrary to the Clean Air Act Amendments of 1990's goal of
reducing HAP emission. Major sources of HAPs will be required
to install various pollution controls under both Title I and
section 112. In addition, a source which chooses to
participate in the Early Reduction Program will most likely
also have to install significant new pollution controls. The
installation of these required or necessary controls should
not trigger modification requirements under section 112(g).
De Minimis Level
A fourth issue of concern for PMA members is the
designation of the baseline for evaluating whether a change
will result in a greater than de minimis increase in
emissions. PMA strongly encourages EPA to designate allowable
or permitted levels as the baseline for purposes of the
Section 112(g) analysis. If a particular level of emissions
has already been evaluated for permitting purposes, there is
no reason it should be subject to the Section 112(g)
requirements. Section 112(g) should not be interpreted so as
to inhibit operational flexibility or to impose substantial
new requirements on a facility unless the particular
circumstances dictate that result.
There are additional practical reasons for dealing with
the baseline issue in this manner, particularly with regard to
the pharmaceutical industry- The intermittent, multipurpose
nature of batch processing makes the determination of
plant-wide short-term (e.g., hourly) actual emissions
impossible. In recognition of this fact, many sources
determine hourly emissions under the NSPS program using a
baseline which is dependent on "potential" emissions.
Calculating actual yearly emissions is also very difficult
and, more important, may not be "representative" of a
facility's emissions because a particular product may not be
produced or may be produced at a substantially higher or lower
level during a given year. PMA wishes to stress that a
facility's allowable or permitted emissions will necessarily
be substantially less than its potential emissions since
"potential," by definition, assumes that all equipment will be
run at its maximum capacity twenty-four hours per day, seven
days per week, fifty-two weeks per year.
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A related issue of concern to PMA members is what
constitutes a de minimis change. Unless sound science dictates
otherwise, EPA should adopt the major source threshold levels
established in section 112 as the trigger for determining that
there has been "a greater than de minimis increase" in
emissions. This approach is straight-forward and easily
administered by the Agency or the permitting authority. It
also recognizes existing precedent under the Prevention of
Significant Deterioration ("PSD") Program.
Emission Offsets
A fifth issue of concern for PMA is emission offsets. EPA
should consider reductions made under other programs, such as
33/50, BACT and LAER, to be available for use as offsets under
Section 112(g). There is no requirement that offsets be
"contemporaneous." In fact, Section 112(g)(l)(A) states that
the source must show that the increase in emissions "has been
offset," indicating that banking is allowed.
Without the ability to bank credits, sources will be
forced to delay reduction projects until they "need" the
credits. This will negatively affect such programs as the
33/50 program and the Early Reduction Program. This is
currently a consideration for many companies weighing their
participation in any type of early reductions effort.
It is also important that EPA recognize the concept of
internal offsetting. Because we frequently change production,
we may increase the emissions of a HAP from one part of the
facility, but decrease it elsewhere. Because no net emissions
increase has occurred, the de minimis level has not been
exceeded, therefore, the increase has been offset. This
position is inherent in a facility-wide definition of "major
source."
Hazard Ranking
PMA is also concerned with hazard ranking issues. Again,
because of the frequent changes indicative of our industry, we
must have the ability to trade among chemicals. We recognize,
however, that the limited amount of data available on most of
the 190 HAPs will make an individualized ranking difficult. We
recommend that EPA use a "binning" approach, but provide for
trading among the HAPs in a particular bin.
Determination that MACT Will Be Met
A final issue under section 112(g) of major concern to PMA
members is the question of the timing for the determination
that "the maximum achievable control technology emission
limitation . . . for existing sources will be met" where a
major source has undergone a modification. The resolution of
this issue will have a substantial impact on operating
i. "1 7
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flexibility. In preliminary discussions with EPA technical
personnel and in the EPA's draft preamble entitled "General
Provisions for National Emission Standards of Hazardous Air
Pollutants for Source Categories," which will be discussed at
some future point in this meeting, the Agency has stated that
section 112(g)(2) requires preconstruction review. This is
simply not the case. Section 112(g)(2) only requires that a
determination be made by EPA or the permitting authority and
not that the change be subject to "preconstruction review," as
the term is used under Title I. A preconstruction review
requirement would substantially delay the implementation of
desirable changes, thus significantly hampering a company's
competitiveness. This delay cannot be justified by the
statutory language.
Section 112(g)(2) prohibits a modification after the
effective date of a permit program unless a determination is
made that MACT will be met. There is no time-frame specified
within which MACT must be met by the source, no requirement
that the determination be made prior to implementation of the
change and no deadline for when the required determination must
be made. Congress did not intend for the delays inherent in
the preconstruction review process under Title I to be imposed
on sources undergoing modifications under Section 112. As
Senator Lautenberg stated during the debate on the Conference
Report: "[T]he Congress did not want to see modification
requirements impose delays on batch processing operations or
delays for manufacturers who want to change or improve
manufacturing processes or who want to initiate the manufacture
of new products. The competitive posture of the country cannot
afford such delays. And equally important, we can satisfy our
environmental objectives without such pre-approval delays."
(Emphasis added). Congress' intent to avoid such delays is
further evidenced by the provision in Section 112(g)(3)
directing the Administrator (or the State) to establish
reasonable procedures for assuring that the requirements
applying to modifications are reflected in the permit.
Imposing a preconstruction review requirement would utterly
frustrate this attempt to minimize any delays arising from the
Section 112(g) modification process.
General Provisions for National Emission Standards for
Hazardous Air Pollutants for Source Categories
Before closing, I would like to make a few brief comments
regarding the draft document entitled: "General Provisions for
National Emission Standards for Hazardous Air Pollutants for
Source Categories." PMA is greatly concerned that Agency
positions set out in this document will have a substantial
impact on the development of future programs, including section
112(g). As I have previously stated, EPA has taken the
position in this document that preconstruction review is
required for a section 112(g) modification. Specifically, it
requires that the source obtain advance written approval from
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the permitting authority prior to acting. This result is not
required by the language in section 112(g) and is contrary to
Congressional intent. EPA has also established extremely short
and, therefore, infeasible reporting times for significant
undertakings such as the Notification Requirements and the
Performance Testing Requirements.
Conclusion
In conclusion, I want to thank the members of NAPCTAC for
their time and attention. I also want to congratulate
responsible EPA personnel for their fine work in the
development of the numerous programs mandated by the Clean Air
Act Amendments of 1990. Finally, I want to express PMA's
gratitude to EPA for allowing us to participate in a meaningful
way in the development of these programs. We hope that EPA
will continue to engage in this type of dialogue in the future
and look forward to being a participant.
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CHEMICAL
MANUFACTURERS
ASSOCIATION
STATEMENT OF
JOE WOOLBERT
ON BEHALF OF
THE CHEMICAL MANUFACTURERS ASSOCIATION
BEFORE THE
NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE
ON
SECTION 112(G) MODIFICATIONS
NOVEMBER 19, 1991
T
2501 M Street, NW 202-887-1100
Washington, D.C. 20037 Telex 89617 (CMA WSH)
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CHEMICAL MANUFACTURERS ASSOCIATION
TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE ON
SECTION 112(g) MODIFICATONS
Good morning. My name is Joe Woolbert, Principal Chemical
Engineer, Texas Eastman Chemical Company. I am pleased to
present testimony on behalf of the Chemical Manufacturers
Association (CMA) on the modifications provisions of section
112(g) of the Clean Air Act. Collectively, the members of CMA
make up 90 per cent of the productive capacity for basic
industrial chemicals in the United States. In my presentation
today, I will make general observations about the modifications
program and address a few particular issues CMA feels are
critical to its success.
Our industry is large and diverse. One fundamental
reality of how our industry functions is that we are constantly
changing to improve and adapt our processes in a competitive
market. Sometimes our changes are minor tweaks in the system.
Other times, we must undergo substantial alterations to meet
the product demands of our customers. Simply put, chemical
manufacturing is a very dynamic industry.
Congress recognized this basic fact when it created section
112(g). The goals of this provision are to allow manufacturers
flexibility in a changing business environment and to ensure
that emission increases will be controlled. To meet these
goals, the modifications program must only look to those
changes which create a significant emissions increase. A
regulatory program that scrutinizes every small change at a
facility will lead to immense resource drains for both
government and industry without much environmental benefit.
Almost every day, some type of change occurs at a chemical
plant. We are continually maintaining and improving our
equipment. Operating hours and production rates vary. We
often switch alternative fuels or feedstocks. Equipment is
changed to implement pollution control projects. CMA believes
that these types of changes should be excluded from the
definition of "physical change or change in method of
operation" under 112(g). just as they are excluded under the
rules for New Source Performance Standards.
In addition, CMA believes that changes that fall within a
facility's operating permit terms should not be a part of the
112(g) definition of "physical change or change in method of
operation". Since all operating scenarios allowed under a
permit will be scrutinized by the permitting authority, there
is no need for a 112(g) determination. EPA should not allow
141
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J. Woolbert Testimony
Section 112(g) Modifications
Page 2
section 112(g) requirements to threaten the integrity of the
operating permit program.
When a change does trigger a 112(g) modification, the
112(g) review should apply only to the modified portion of the
source. This approach is consistent with existing New Source
Performance Standards. Subjecting the entire facility to a
MACT determination every time a modification occurs would place
an impossible burden on regulators and sources to scrutinize
emissions that eventually will be covered by MACT anyway. The
scope of the 112(g) MACT requirements must be limited to the
modified unit if the program is to work.
Besides providing for certain exclusions and limiting the
scope of coverage, we believe a workable modification rule
should resolve several timing questions. First, a source must
be allowed to move ahead with a change upon submitting an
offset showing or a compliance plan for the modification.
Often, sources cannot make competitive changes if they wait
until the regulatory authority responds. We believe the
statute does not require sources to delay projects until the
completion of a potentially long review period. In fact,
112(g) does not say "until" - instead it uses the word
"unless". A source should be able to move forward at its own
risk after making the required submittal to the proper
authority.
Second, section 112(g)(2)(A) requires the Administrator to
determine that MACT for existing sources "will be met." How
long does a modified unit have to comply with existing source
MACT? CMA believes the best answer is to require modified
sources to comply within the same time frame as existing
sources. Section 112(i)(3)(A) allows up to 3 years for
existing sources to comply with MACT. It is consistent with
the statute to apply the same time frame to 112(g)
modifications.
If there is no applicable MACT standard established at the
time of modification, 112(g) requires a source to meet
case-by-case MACT. What happens to a source that installs
case-by-case MACT only later to find that the promulgated MACT
is different? Again, CMA believes that the best answer is
found in the statutory provisions for existing sources.
Section 112(j)(6) provides up to 8 years for a source subject
to case-by-case MACT to comply with a subsequent standard.
Sources that install case-by-case MACT under 112(g) should also
have up to 8 years to meet subsequent standards.
The statute exempts a source from case-by-case MACT
requirements if the emission increase is offset by a sufficient
decrease elsewhere in the source. CMA urges EPA to adopt rules
that encourage the use of offsets to maintain or reduce
-2-142
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J. Woolbert Testimony
Section 112(g) Modifications
Page 3
emission levels. There is a clear environmental benefit to
maintaining no net increase in emissions as opposed to merely
controlling new emissions without corresponding decreases.
Sources cannot offset emission increases if there are no
other emission points within the source to reduce. Therefore,
CMA believes a broad interpretation of the term "major source"
is necessary if offsets are going to be a realistic option. A
narrow construction of "major source" would severely limit
available offsets within a facility and make the offset
provisions of the statute potentially meaningless. CMA is
convinced that defining a major source as the entire contiguous
facility under common control and ownership is necessary for
the success of the offset program.
The rules for offsets should not discourage companies from
pursuing emission reductions earlier than otherwise required.
Many of our companies are implementing voluntary emission
reductions through programs such as EPA's 33/50 project.
Disallowing past reductions as offsets would create a great
disincentive for companies to voluntarily reduce emssions
early. CMA strongly believes that past reductions should be
creditable as offsets under 112(g).
We feel that the statute clearly allows past reductions as
offsets. Section 112(g) refers to offsets in the past tense,
requiring that an offset "has been" made. It is simply
illogical to require the emission reduction to occur
simultaneously with the emission increase. There must be some
time period between the increase and the offsetting reduction.
The real question concerning banked offsets is not whether
they are allowable, but what is a reasonable and workable time
period between the reduction and increase? We believe that a
five year period, beginning with five years before approval of
a permit program, is both fair and workable.
The ranking of HAPs used in the offset procedure is
another area of concern to us. While the hazard ranking should
provide reasonable assurance that offsets do not increase
potential hazards, the ranking scheme should not be so
complicated and rigid as to make offsets impossible. CMA
supports a ranking system that considers both the quantity and
physical properties of chemicals, but is simple enough to allow
offsetting between mixed streams as well as individual
substances
Finally, CMA would like to emphasize that the procedures
for complying with 112(g) should be simple and expedient.
Sources should be able to move forward after submitting the
proper showing to the regulatory authority without prolonged
procedural delay. We believe that the modification program can
T f 1
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J. Woolbert Testimony
Section 112(g) Modifications
Page 4
work, but only if companies do not become mired in the
government approval process.
CMA thanks the NAPCTAC for the opportunity to present some
of our ideas and concerns regarding 112(g) modifications. We
look forward to constructive interaction with EPA as it moves
forward in the rulemaking process. At this point I'd be happy
to answer any questions from the committee.
-4- 1
144
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C. Discussion-SECTION 112 g
Bruce Jordan introduced the EPA staff responsible for
implementing the Section 112(g) "Modifications" requirements.
Tim Smith of the EPA presented a summary of 112(g) requirements.
This presentation also outlined the EPA's current thinking on
several of the more important 112(g) issues. The following is a
summary of the discussion following Mr. Smith's presentation.
Mr. William O'Sullivan commented on the use of a tons/year
basis for emission calculations and asked if the EPA had given
any consideration of a pounds/hour basis for some chemicals. The
EPA staff agreed that pounds/hour is more appropriate for some
chemicals, but that there is a currently unfilled need for
pounds/hour concentration benchmarks. Mr. O'Sullivan stated his
support for a source definition that treated new equipment as new
sources.
Mr. William Dennison complemented the EPA staff on the
public outreach, as evidenced by the comment letters distributed
to committee members. Mr. Dennison supported a source definition
that would treat new equipment as a new source. Mr. Dennison
expressed concerns that the 10 tons/year major source definition
is a guideline; some situations require controls at less than 10
tons/year. Additionally, for large facilities, consideration is
needed in offsetting that near-term effects for one person may be
very different than for another person. Finally, Mr. Dennison
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asked whether Section 112(g) offsets would have to be "surplus"
to those in the early reductions program.
Dr. John Pinkerton asked for clarification of the suggested
approach to de minimis levels. The EPA staff indicated a desire
to give more toxic pollutants a greater probability for review.
For this, health benchmarks would be used to establish a de
minimis value for each of the pollutants.
Mr. Donald Arkell asked for clarification on the issue of
"banked" offsets. The EPA discussed the various views on this
topic. A STAPPA/ALAPCO resolution indicated a desire for a
decrease at the same time as the increase, but industry
commenters have stated that this would be a disincentive for
pollution prevention projects.
Mr. Brian Taranto requested clarification of the EPA's
statement that a "contemporaneous" offset demonstration is more
complex. Tim Smith stated that the contemporaneous offset
method would require all increases and decreases to be accounted
for. Mr. Smith discussed his view that a contemporaneous period
implies that at some time period, toxic air pollutant emissions
are at "OK" levels. Given that Congress felt that these
emissions are not "OK" as evidenced by Title III of the Act, it
might make more sense to require an overall emission reduction if
a contemporaneous period was allowed.
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Mr. O'Sullivan recommended that de minimis be determined on
a process unit basis, based upon a desire not to sum up emissions
from multiple changes. Mr. Smith indicated that this might
suggest somewhat lower de minimis values.
Mr. Taranto stated that it would be ironic to disallow
credits for early reductions in the past, while allowing them if
they occurred at the same time as the increase.
Ms. Vivian Mclntire recommended that these requirements
should be coordinated with Title V. The EPA agreed. Dr. Patrick
Atkins stated that if permits could establish the basis for
offsets, then the EPA should make sure that those involved with
permit programs understand this.
Mr. Dennison expressed concerns with the terms allowable and
potential emissions. For some equipment, capacity is well-
defined (e.g., boilers) but for others (e.g., spray booths) they
are not so well defined.
Mr. Taranto asked how the 112(g) guidance would treat
changes that are allowable in the permit. Mr. Smith stated that
the concept of building enforceable scenarios in the permit is
sound in concept, but that exactly how to do this is under
discussion within the EPA.
Mr. O'Sullivan recommended that de minimis values for
noncancer effects should be based upon a fraction of the
reference concentration, not the reference concentration itself.
Some of the reference conferences are only 10 percent of the no-
effect level. Ms. Karen Blanchard of the EPA indicated that
this was the case only when very good data existed; more
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typically, uncertainty factors for reference concentrations are
around 1000, and some are as high as 10,000.
Mr. Jordan then introduced Mr. Richard Paul of the Motor
Vehicle Manufacturers Association (MVMA). A summary of the
questions and comments on this presentation are as follows.
Mr. Taranto asked for a clarification of how the MVMA views
the source definition. Mr. Paul indicated a desire for the
broadest possible definition to promote offsets.
Mr. O'Sullivan questioned the MVMA recommendation for a
case-by-case option for offsets. Mr. Sullivan expressed concerns
that if air quality modeling was involved, this would slow down
the process, not speed it up. Mr. Paul agreed that it would not
speed up the process but stressed that it would be at the owner
or operator's option. Mr. O'Sullivan preferred the use of
hourly averaging times rather than the monthly averaging time
suggested by the MVMA.
Mr. O'Sullivan asked whether the EPA needed to rank
carcinogens and noncarcinogens together. The EPA staff stated
that the Act's requirements do not prohibit carcinogen decreases
as offsets for noncarcinogen increases; hence, a combined ranking
is required.
Mr. Dennison stated that upcoming changes that are expected
could be written into the permit. Mr. Dennison stated that case-
by-case de minimis determinations could have a potential for
lengthy reviews.
Dr. Atkins stated that hazard is a function of toxicity and
dose. He asked Mr. Paul if the MVMA supported air quality
-------
modeling for each offset. Mr. Paul clarified that this was not
the case; it is just an option.
Dr. Pinkerton asked whether the MVMA had any thoughts on
calculating actual emissions, and asked whether the MVMA
envisioned testing. Mr. Paul commented that this raised a lot of
tough issues. Analytical methods are not available for all
hazardous air pollutants, and it can be tough to analyze complex
streams. Mr. Arkell stated that the monthly baseline suggested
by the MVMA would be a loophole because the highest monthly
emissions may not be representative and companies might increase
emissions to increase the baseline. Mr. Paul mentioned that
baseline could not exceed allowable emissions.
Mr. Jordan then introduced the next presenter, Mr. Dan Gealy
of ARCO representing American Petroleum Institute (ARCO).
Mr. Gealy provided the committee with a copy of his prepared oral
statement. Comments and questions on Mr. Gealy's statement are
as follows.
Dr. Pinkerton asked whether there was a fundamental conflict
between the emission averaging in the hazardous organic NESHAP
and the offsets in Section 112(g). Mr. Jordan clarified that he
did not believe there was a conflict; MACT would be required for
the points covered by the HON.
Ms. Mclntire asked for a clarification of API's suggestion
regarding a 5 percent exemption. Mr. Gealy clarified API's point
that some regulations covering streams with mixtures often only
consider those greater than a given percentage in the stream.
For example, leak regulations have exempted those less than
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5 percent, and that a default assumption of 5 percent might be
workable for now. Mr. Smith expressed support for the notion of
exemptions if a MACT standard had been promulgated but expressed
concerns with a general default.
Mr. Dennison noted that it is desirable to have exclusions
consistent with new source review in addition to PSD and NSPS.
Mr. Dennison asked Mr. Gealy if API felt that a change in raw
materials should be excluded if it led to a more toxic raw
material being used. Mr. Gealy stated that they would have more
concerns in this regard than the MVMA. A change in crude oil
supplies, which is a fungible commodity, would make this more
possible. Mr. Dennison suggested that different crude oil
supplies should be accommodated by the permit.
Mr. O'Sullivan stated that a 5-year period for credits
appeared reasonable, but that shutdowns should only be credited
if it involved the replacement with another unit that is more
efficient.
Mr. Robert Kellam of the EPA asked whether reformulation
would tend to decrease or increase HAP emissions. Mr. Gealy
emphasized a desire on the part of the industry to guess right on
MACT as they carry out the reformulation effort. The API does
not want to retrofit with MACT later. As a result, emissions
should decrease.
Mr. Jordan then introduced Mr. Richard Vetter, Burroughs
Wellcome, representing the Pharmaceutical Manufacturing
Association (PMA). Unlike the other speakers, Mr. Vetter did not
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submit a prepared statement. Mr. Vetter's presentation is
summarized as follows.
Mr. Vetter emphasized that the pharmaceutical industry needs
to handle frequent changes in response to market needs. Plants
typically produce batch quantities in operations that are not
dedicated to one particular chemical.
Mr. Vetter stated the PMA's view that Congress did not want
modifications to be subject to a lengthy review, nor did Congress
want to restrict operational flexibility. In keeping with this
view, the PMA has a number of recommendations. First, major
source should refer to the entire facility, but MACT should be
limited to the equipment being modified. Second, new source
requirements should recognize that an equipment change should not
lead to that equipment being treated as a new source. Third,
"physical change" should keep the historical exclusions. The EPA
should add an exclusion for "pollution control projects."
Fourth, the PMA suggests an allowable emissions baseline; for
pharmaceutical plants, an actual emissions baseline is difficult.
Fifth, reductions from the EPA's voluntary "33/50" program, and
from LAER, etc. should be creditable as offsets, and the phrase
"has been offset" means that the EPA should allow for banked
credits. Sixth, the major source thresholds are sufficient as
de minimis levels. Seventh, the hazard ranking should allow
trades within a "bin." Finally, Mr. Vetter expressed the PMA's
view that the statutory language that requires that MACT "will be
met" does not require preconstruction review; Congress did not
intend for this delay.
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Mr. Vetter also outlined the PMA's view that the general
provisions (discussed earlier in the NAPCTAC proceedings) sets
out procedures for 112(g) reviews that the PMA feels are not
required by the Act.
Ms. Mclntire asked for clarification regarding "binning."
Mr. Smith discussed the EPA's "floating bin" concept which is to
avoid problems near the boundaries of fixed bins. (For example,
under fixed bins, 2 and 9 would be the same, but 9 and 11 could
be treated differently).
Mr. O'Sullivan stated that much of the flexibility requested
by the PMA could be built into the permits, and that baseline
should be allowable emissions. Mr. O'Sullivan stated that he
felt that de minimis values should be considerably less than the
major source thresholds.
Mr. Kellam introduced the final presenter, Mr. Joe Woolbert,
Texas Eastman Company, speaking on behalf of the Chemical
Manufacturers Association (CMA). Mr. Woolbert submitted copies
of his statement to the committee. The following is a summary of
the discussion following the presentation,
Ms. Deborah Sheiman questioned whether industries have a
right to continue emissions at historical rates. Ms. Sheiman
characterized the intent of the law to have major changes be
controlled by MACT; emission reductions prior to the increase
should not be allowed.
Mr. 0'Sullivan asked Mr. Woolbert whether the CMA suggests
that modifications proceed at their own risk without prior
review. Mr. Woolbert confirmed that this is the CMA's
-------
recommendation. Owners would be able to proceed as long as they
sent in a description of the project. If a substantial error is
made, there would be a risk of noncompliance.
Mr. O'Sullivan disagreed with the recommendation for no
preconstruction review, and that modifications should undergo the
Title V permit review process.
Mr. Dennison requested clarification on how the CMA would
view a system of "banked" emission reductions. Would this
involve a formal banking system. Mr. Woolbert stated that the
CMA viewed this more as an accounting system similar to the PSD
program than a formal banking system.
Mr. Dennison requested clarification as to whether credits
for the early reductions program under Clean Air Act Section
112(i)(5) would be creditable as Section 112(g) offsets.
Mr. Woolbert stated that the CMA thought they should be.
Ms. Blanchard mentioned that the CMA had apparently taken a
different position at the July "roundtable" meeting. The CMA
agreed to provide clarification on their position to the EPA.
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OVERVIEW OF THE SOURCE CATEGORY
SCHEDULE FOR STANDARDS PROJECT
1.0 INTRODUCTION
This paper provides an overview of the Source Category
Schedule for Standards project. Topics discussed in this
paper include the statutory basis for the project, the
relationship of this project to the Source Category List
project reviewed at the last National Air Pollution Control
Technology Advisory Committee (NAPCTAC) meeting, the
methodology of the Source Category Ranking System (SCRS), the
decision criteria used in assigning the source categories to
completion-year bins, and a review of the project schedule.
This paper is intended to provide a brief overview of the
project.
Section 112(e) of the Clean Air Act (CAA) requires the
development of a schedule for the promulgation of emission
standards for each source category and subcategory (hereafter
referred to as categories) listed under the Source Category
List project, which will result in the regulation of all
listed categories within 10 years of the effective date of the
CAA amendments of 1990. The CAA requires the U. S.
Environmental Protection Agency (EPA) to promulgate
regulations for 40 source categories, in addition to coke
ovens, within 2 years; 25 percent of all listed categories
within 4 years; 50 percent of all listed categories within
7 years; and to complete the regulatory process for all listed
categories within 10 years.
The emission standards promulgation schedule, which will
establish the dates for the promulgation of emission standards
for each listed source category, is required to be published
by November 15, 1992. Section 112(e)(3) explicitly states
.A ", J
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that the prioritization of the emission standards promulgation
schedule is not considered an Agency rulemaking and is,
therefore, not subject to judicial review. However, failure
to promulgate any standard pursuant to this schedule shall be
subject to judicial review as indicated in Section 112(e)(3).
Finally, Section 112(j) requires additional actions in
the event the Administrator fails to meet the promulgated
schedule for establishing regulations for any listed source
category- The owner or operator of any major source in a
category for which emissions standards are delayed by more
than 18 months from the scheduled date for promulgation of
standards, but not prior to the effective date of a State
permit program, must submit a Title V permit application that
specifies emissions reductions that are determined to be
equivalent to the level of control that would have been
required by the Federal emission standards. The requirement
to set a case-by-case emission limit has been referred to as
the "maximum achievable control technology (MACT) hammer".
The CAA also establishes specific requirements or
timeframes for the regulation of certain specified source
categories independent of the schedule developed under this
project.
In the past, national emission standards for hazardous
air pollutants (NESHAP) were prioritized and developed on a
pollutant-by-pollutant basis, resulting in many source
categories being assessed several times for different
pollutants. Each assessment might then lead to the
development of an independent regulation. The focus of the
Emission Standards Division's (ESD's) program changed in 1989,
however, to the assessment of source categories based on
combined hazardous air pollutant (HAP) emissions and risks.
The source category approach was introduced at the June 1989
NAPCTAC meeting. The CAA amendments of 1990 also focus on the
overall health effects from a source category, and require EPA
to prioritize its regulatory efforts based, in part, on
relative risks among the listed source categories. The
following sections will discussr the development of the list of
': IT e 2
j. . O
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source categories to be prioritized, the methodology used in
assessing their relative risk ranking, and the decision
criteria used in assigning the listed categories to
completion-year bins.
2.0 RELATIONSHIP TO THE SOURCE CATEGORY LIST PROJECT
In order to fulfill the statutory requirements, EPA first
needed to develop a list of source categories warranting
regulatory development. That effort is being conducted under
the Source Category List project, which was discussed at the
January 1991 NAPCTAC meeting.
The SCRS is being utilized, along with other references,
by the source category list project to assess emissions
potential. A draft list of over 700 categories and
subcategories emitting any of the 189 HAP's listed in
Section 112(b)(3) of the CAA was developed and published for
public comment on June 21, 1991 (56 FR 28548). The public
comments on the draft list have been reviewed by EPA, and the
list is currently being revised.
Currently, EPA anticipates publishing a Federal Register
notice containing the source category list in late
December 1991. The draft and final versions of the schedule
for standards will address all source categories on the
published list. Additionally, data and information gleaned
from the public comments submitted to the source category list
docket are being evaluated for incorporation in this project
as well.
3.0 SOURCE CATEGORY RANKING SYSTEM METHODOLOGY
To assist in its effort to meet the statutory
requirements for establishing the schedule for standards, EPA
developed the SCRS. The SCRS combines emission estimates,
human exposure estimates, and health effects data to rank
source categories based on all pollutants emitted from each
source category. The result is a scale of relative measure by
which a source category is ranked in relation to all other
listed source categories, based on its associated exposure and
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health effects. The methodology used in the SCRS is only
briefly discussed below. A more detailed explanation is
provided in the document "Methodology for the Source Category
Ranking System."
A diagram showing the general methodology used in the
SCRS is shown in Figure 1. For each HAP emitted by a source
category, the SCRS develops an exposure score and a health
effects score. Together these scores produce a combined score
for each HAP; the combined scores are then summed to produce
an overall source category score. The source categories are
then ranked according to their source category scores.
The exposure score for each source category in the SCRS
is a function of the estimated concentrations of pollutants
emitted from the category and an estimation of the population
exposed to those pollutants.
Emission estimates are an integral part of the exposure
score calculations. Emissions data are processed through
simplified atmospheric dispersion algorithms to develop
estimates of ambient pollutant concentrations for source
categories. The resultant ambient concentrations are then
multiplied by appropriate population data to obtain the
exposure score.
For each source category, the emissions estimation
technique depends on whether the source category is comprised
of point sources or area sources. Point source emissions are
generated by estimating emissions from individual plants,
assigning plants to source categories, and summing emissions
for each source category. For area sources, emissions are
estimated for the source category in aggregate. The term
'area source1 as used in the SCRS refers only to how emissions
are estimated for modeling purposes but does not have the same
meaning as the term 'area source' as defined in the CAA. Each
estimation approach as described below addresses particular
types of area sources as explained at the end of this section.
Four general approaches are used to develop emission
estimates: the BSD approach, the National Emissions Data
System (NEDS) approach, literature searches of existing EPA
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Estimate Emission* by
Sourc* Category
U.S. Census Data
Develop Hearth
Effect Scores
Air Quality
Model Algorithms
Develop Exposure
Scores
Develop Combined
Scores
Develop Source
Category Scores
Rank Source
Categories
Figure 1. Schematic Diagram of the
Source Category Ranking System Methodology
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studies, and the Toxic Release Inventory System (TRIS)
approach. A hierarchy was established in order to apply the
most appropriate technique for each source category. The BSD
approach is first used for certain source categories involving
the manufacture and use of organic chemicals. Next, the NEDS
approach is applied. Then, a review of existing EPA studies
is done, including, but not limited to: source assessments of
pollutants, locating and estimating documents, and data
developed in support of previous Section 111 and Section 112
regulatory decisions- Finally.- the TRIS approach is used for
source categories not covered by the other approaches. The
four approaches are briefly explained in the following
paragraphs.
The ESD emissions estimate approach is used for source
categories for which published organic chemical production and
consumption data were available. Where the data involved
HAP's, facilities are identified within the applicable source
category and point source emissions are estimated. If a list
of facilities is not available, the source category is treated
as an area source because without a facility list, the Agency
is unable to assign emissions to a specific geographic
location. For point sources, emission estimates are produced
by multiplying a series of emission factors by the chemical
production/consumption rate at individual facilities. The
primary sources of production and consumption data for the ESD
approach are Stanford Research Institute's Directory of
Chemical Producers. Mannville's Chemical Production Synopsis.
and the Chemical Marketing Reporter.
The NEDS approach is used to develop emission estimates
for additional source categories. The NEDS is an EPA data
base of reported emissions from each state for sources
emitting more than 90 megagrams per year (Mg/yr) (100 tons per
year [tpy]) of any criteria pollutant (U. S. EPA, 1988). A
list of the approximately 4,000 defined Source Classification
Codes (SCC's), along with descriptions, can be found in
Criteria Pollutant Emission Factors for the 1985 NAPAP
Emissions Inventory (U. S. EPA, 1987b).
,.80 6
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The first step in estimating emissions using the NEDS
approach is to identify all SCO's emitting one or more of the
listed HAP's and then to assemble source categories based on
SCC descriptions. National Acid Precipitation Assessment
Program (NAPAP) pollutant speciation profiles are then applied
to particulate matter (PM) and volatile organic compound (VOC)
emissions data available in NEDS. In the NEDS approach, the
selected speciation ratios are applied to total VOC and PM
emissions in order to estimate emissions of listed HAP's for
each NEDS-identified source category.
Another approach being used consists of a review of
existing EPA studies in order to collect existing emissions
data for listed sources categories. Included in this review
were source assessment reports, locating and estimating
documents, and data developed in support of previous
Section 111 and 112 regulatory activities. The information
collected through this approach provides emissions data that
is either specific to a source category as it appears on the
list or contributes to a broader source category-
The TRIS approach is limited to emission estimates for
HAP production categories not previously addressed by the ESD
and NEDS approaches. The TRIS data base contains emissions
data reported by individual industrial facilities as required
by the Superfund Amendments and Reauthorization Act (SARA)
Section 313. The most recent (1987) TRIS data base contains
data for facilities using as little as 5 Mg/yr (5 tpy) of any
single chemical covered under SARA Section 313.
The four approaches yield an emissions data base which is
combined with population data to produce an exposure score.
After establishing the emission data base, simplified
dispersion algorithms are developed to estimate the potential
ground-level concentration from fugitive and point source
emissions for individual plants. Source categories for which
plant lists could not be generated are handled as area sources
with a separate simplified dispersion algorithm. These
dispersion algorithms provide a concentration factor that when
-------
multiplied by the pollutant emission rate yields an
approximate pollutant concentration.
The SCRS calculates four exposure scores for each source
category: short-term maximum, short-term aggregate, long-term
maximum, and long-term aggregate, in order to match emissions
data to the different types of health effects data.
Population data for both point and area sources from the 1980
U. S. Census Bureau are used in calculating long-term and
short-term exposures. By multiplying the appropriate
population data by the estimates of short-term and long-term
pollutant concentrations, the four exposure scores are
calculated for each pollutant within a source category.
Four general types of health effects, or endpoints, are
evaluated for each hazardous air pollutant in each source
category: carcinogenicity, reproductive toxicity, acute
lethality, and other toxicity- Health effects scores are
developed for each potential health effect for each pollutant
and then aggregated using assigned weights into a long-term
and short-term health effects score. The long-term health
effects score represents those effects associated with
carcinogenicity, and nonlethal health effects. The short-term
health effects score represents those effects associated with
acute lethality and reproductive toxicity.
Health effects and exposure data are combined by the SCRS
to produce a single combined score for each pollutant. The
scores for each pollutant in a source category are then summed
to produce a source category score. The final source category
scores in the SCRS do not represent a quantitative risk
assessment and are not intended to estimate absolute risks to
a population. The source category scores provide a relative
measure of public health risks considering a variety of
potential acute and chronic effects, providing a reasonable
method for ranking the source categories. Once the source
category scores are determined, the categories are then ranked
by a simple sorting of the scores.
Although EPA uses the SCRS as a tool in the consideration
of the exposure and health effects potential of the candidate
O^ 8
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source categories, as is generally the case, it is an
imperfect tool. For example, in most cases, emissions for a
given source category are determined through only one of the
four approaches and the input data is of varying quality.
Perhaps the greatest concern arises over the unavoidable
reality that substantially more emission data are available
for some source categories than others, regardless of their
true relative emission or risk potentials. After the ranking
is completed, EPA will review the data upon which each source
category's ranking is based, in order to consider the
qualitative value of the source category scores.
Therefore, the SCRS is not the sole determining factor in
establishing the schedule for promulgating standards, but
contributes to the EPA's consideration of the exposure and
health effects criteria in setting the schedule. The third
criterion, efficiency of grouping, is discussed in the next
section.
4.0 BINNING DECISION ELEMENTS
As set forth in Section 112(e)(2) of the CAA, three
criteria are being considered for prioritizing the emission
standards promulgation schedule. The first two criteria,
emissions exposure and health effects, are incorporated into
the SCRS. The third criterion, efficiency of grouping, is
based upon the similarity and availability of demonstrated
control technologies; the similarity of pollutants, emission
points or processes; the availability of data to document
emissions and processes; and the status of current regulatory
efforts.
For the 2- and 4-year bins, the status of current
regulatory efforts has the greatest influence. A certain
amount of technical work and information is necessary to
finalize any standard in these shorter timeframes. The 2-year
bin, therefore, is comprised of the NESHAP for coke ovens, dry
cleaners, and the hazardous organic NESHAP, or RON, which
includes nearly 400 subcategories.
J 9
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The draft, preliminary 4-year bin is made up of active
regulatory efforts, as shown in Figure 2. Additionally, there
are other projects not currently active which may be included
within this bin (i.e., hospital sterilizers, aerospace,
printing and publishing, and marine coatings). Pulp and paper
is the only active project not included in either the 2- or
4-year bin, and is currently scheduled for promulgation in the
fifth year.
For the 7- and 10-year bins, EPA is reviewing the
remaining ranked source categories to see where they could
reasonably be combined, both with active projects in the 2-
and 4-year bins, and within the later bins themselves.
5.0 PROJECT SCHEDULE
Because of the CAA mandate that the published schedule
include all source categories on the final source category
list, this project is inextricably tied to the source category
list project. The BSD will revise the final ranking after the
list is finalized, incorporating data drawn from public
comments on the draft list, and incorporating any additions or
deletions to the list. The EPA intends to publish a draft
schedule shortly after the final list is published, and plans
to finalize the schedule after considering public comments.
Publication of the final schedule is currently planned to meet
the statutory date of November 15, 1992.
10
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4 years
completion of 25%
of Listed Categories
7 years - Completion of
50% of Listed Categories
10 years - Completion of
All of Listed Categories
Hazardous Organic NESHAP (production of ~40O chemicals)
Dry Cleaners '
Coke Ovens (charging, topside & door leaks)
Chromium Anodizing *
Hard Chromium Electroplating *
Decorative Chromium Electroplating *
Ethylene Oxide Sterilization*
Gasoline Marketing (Stage 1)*
Magnetic Tapes (Surface Coating)
Polymers & Resins I
Polymers & Resins II
Wood Furniture (Surface Coating)
Degreaslng Operations
Petroleum Refineries
Asbestos (revisions)
Solid Waste Treatment, Storage &
Disposal Facilities
Industrial Cooling Towers *
Large Aircraft (Surface Coating)
Printing/Publishing (Surface Coating)
Shipbuilding and Repair
(Surface Coatings)
Hospital Sterilizers *
Secondary Lead Smelting
•
Includes area sources
Figure 2. Bin Assignments for the Emissions Standards Development Schedule
DRAFT
-------
Source Category Schedule
for Standards
Presentation to
NAPCTAC
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division
November 19,1991
-------
PRESENTATION OUTLINE
Clean Air Act Requirements
Technical Basis for Source Category
Ranking
Criteria for Prioritizing Schedule of
Standards Promulgation
Draft Schedule
-------
CLEAN AIR ACT REQUIREMENTS
f-0
I m
loooooooooaoooa
Publish a list of Source Categories
within 12 months of enactment of CAA
Amendments of 1990.
Prioritize listed Source Categories
considering health impacts, exposure,
and efficiency of grouping.
Publish Final Schedule for Standards
for listed categories within 24 months
of enactment of CAA Amendments
of 1990.
-------
Co
<^3
STATUS OF THE
SOURCE CATEGORY LIST
Preliminary draft list of source categories
was published June 21,1991.
Revisions to preliminary draft list
based on Agency review of data
and public comments in progress.
Scheduled for publication in December
-------
40
'Categories^
plus Coke Ovens
25%
of Listed Categories'
2 Year Bin
4 Year Bin
50%
of Listed Categories
7 Year Bin
All Listed Categories
10 Year Bin
REQUIREMENTS FOR EMISSION STANDARDS DEVELOPMENT
SCHEDULE
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CAA CRITERIA FOR PRIORITIZING
EMISSION STANDARDS PROMULGATION
Adverse effects on public
health & the environment
Quantity and location
of category emissions
Efficiency of grouping categories
according to pollutants, processes
or technologies
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SOURCE CATEGORY RANKING SYSTEM (SCRS)
Assists in the development of the schedule
for standards.
Incorporates first two criteria (health effects
and exposure).
Generates a relative ranking of Source
Categories based on health effects and
exposure estimates.
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SOURCE CATEGORY RANKING SYSTEM (SCRS)
Emission
Estimates
Concentration
Estimates
Population
Data
Health Effects
Scores
Exposure
Scores
Combined
Scores
Sum for all Pollutants
in a Source Category
DEVELOPMENT OF A COMBINED SCORE FOR A SOURCE CATEGORY
-------
HEALTH EFFECTS SCORES
Four general health endpoints included.
• Carcinogenicity • Acute lethality
* Reproductive and * Other toxicity
developmental toxicity
Health effects scores are potency - based.
Short-term and Long-term health effects
score developed for each Source Category.
-------
EMISSIONS DATA INPUTS
National Emissions Data System
Production/Consumption Data
SOCMI Data developed under HON Project
• Other EPA Sources
-------
SCRS USE AND
RELEVANCE TO SCHEDULE
Useful "tool" that assists the scheduling
process.
Limitations due to varied data quality and
modeling assumptions.
Not to be used for developing emission
standards.
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"EFFICIENCY OF GROUPING"
CRITERION
Considers similarities in:
• Pollutants
• Processes
Examples:
• HON
Emission Points
Control Strategies
Polymers and Resins I & II
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CHARACTERIZATION OF
DRAFT SCHEDULE
2-Year Current standards under development,
CAA and court-mandated promulgation
schedules.
4-Year Active EPA projects and high priority
source categories from SCRS.
7- & Determined by application of SCRS,
10-Year efficiency of grouping criterion, and level
of technical knowledge evaluations.
-------
4 years
completion of 25%
of Listed Categories
7 years - Completion of
50% of Listed Categories
10 years - Completion of
All of Listed Categories
Hazardous Organic NESHAP (production of ~40O chemicals)
Dry Cleaners
Coke Ovens (charging, topside & door leaks)
Chromium Anodizing *
Hard Chromium Electroplating *
Decorative Chromium Electroplating *
Ethylene Oxide Sterilization*
Gasoline Marketing (Stage 1)*
Magnetic Tapes (Surface Coating)
Polymers & Resins I
Polymers & Resins II
Wood Furniture (Surface Coating)
Degreaslng Operations
Petroleum Refineries
Asbestos (revisions)
Solid Waste Treatment, Storage &
Disposal Facilities
Industrial Cooling Towers *
Large Aircraft (Surface Coating)
Printing/Publishing (Surface Coating)
Shipbuilding and Repair
(Surface Coatings)
Hospital Sterilizers *
Secondary Lead Smelting
Includes area sources
DRAFT BIN ASSIGNMENTS FOR THE EMISSIONS STANDARDS DEVELOPMENT SCHEDULE
PRELIMINARY/DRAFT
-------
7-YEAR DRAFT BIN
ASSIGNMENTS
ACETAL RESINS PRODUCTION
ACRYLIC FIBERS/MODACRYLIC FIBERS PRODUCTION
AEROSOLS PRODUCTION
ASPHALT CONCRETE MANUFACTURING
ASPHALT PROCESSING
AUTO AND LIGHT DUTY TRUCK (SURFACE COATING)
BENZYLTRIMETHYLAMMONIUMCHLORIDE PRODUCTION
CADMIUM REFINING
CARBOXYMETHYLCELLULOSE PRODUCTION
CELLOPHANE PRODUCTION
CHELATING AGENTS PRODUCTION
CHLORONEB PRODUCTION
CHROMIUM REFRACTORIES PRODUCTION
CLAY PRODUCTS MANUFACTURING
COKE OVENS (PUSHING. QUENCHING, BATTERY STACKS)
ENGINE TEST FACILITIES
FERROALLOYS PRODUCTION
FLEXIBLE POLYURETHANE FOAM PRODUCTION
FORMALDEHYDE RESINS PRODUCTION
HYDROCHLORIC ACID PRODUCTION
HYDROGEN FLOURIDE PRODUCTION
INTEGRATED IRON & STEEL MANUFACTURING
INTERNAL COMBUSTION ENGINES
IRON FOUNDRIES
MINERAL WOOL PRODUCTION
MUNICIPAL LANDFILLS
NON-STAINLESS STEEL MANUFACTURING • EAF OPERATION
NYLON FIBERS PRODUCTION
NYLON PLASTICS PRODUCTION
OIL AND GAS PRODUCTION
PAPER AND OTHER WEBS (SURFACE COATING)
PHARMACEUTICALS PRODUCTION
PHENOLIC RESINS PRODUCTION
PHOSPHATE FERTILIZERS PRODUCTION
PHOTOGRAPHIC CHEMICALS PRODUCTION
POLYESTER RESINS PRODUCTION
POLYETHER POLYOLS PRODUCTION
POLYMETHYL METHACRYLATE RESINS PRODUCTION
POLYVINYL ACETATE EMULSIONS PRODUCTION
POLYVINYL ALCOHOL PRODUCTION
POLYVINYL BUTYRAL PRODUCTION
PORTLAND CEMENT MANUFACTURING
PRIMARY COPPER SMELTING
PRIMARY LEAD SMELTING
PROCESS HEATERS
PULP & PAPER PRODUCTION
RAYON PRODUCTION
REINFORCED PLASTIC COMPOSITES PRODUCTION
RUBBER CHEMICALS PRODUCTION
R-11 (BUTADIENE - FURFUHAL-COTRIMER)
PRODUCTION
SEMICONDUCTORS MANUFACTURING
SEWAGE SLUDGE INCINERATION
STAINLESS STEEL MANUFACTURING • EAF
OPERATION
STEEL FOUNDRIES
STEEL PICKLING - HCUHF PROCESS
TURBINES
WOOL FIBERGLASS MANUFACTURING
ZINC SMELTING
-------
llCWM
Institute
of Chemical
Waste Management
Statement Before the EPA
National Air Pollution Control Techniques
Advisory Committee
November 19, 1991
We appreciate the opportunity to come before the National Air
Pollution Control Techniques Advisory Committee and to offer ICWM's
comments on the listing and prioritization of source category
standards. ICWM — the Institute of Chemical Waste Management — is a
component of the National Solid Wastes Management Association and is
comprised of firms which commercially treat, recycle, and dispose of
hazardous wastes. Several of our members operate hazardous waste
incineration facilities regulated under Subtitle C of the Resource
Conservation and Recovery Act (RCRA).
In July 1991, NSWMA submitted comments in response to EPA's
"Preliminary Draft List of Categories and Subcategories Under Section
112 of the Clean Air Act". In those comments, we urged that
"Hazardous Waste Incineration" should be removed from the preliminary
draft list based on the comprehensive regulation of air emissions from
these facilities under RCRA and the importance of avoiding
inconsistent or contradictory requirements. We continue to believe
that this type of incineration facility should be subject to RCRA
controls.
On April 27, 1990, EPA proposed amendments to the current
hazardous waste incinerator standards found at 40 C.F.R. Part 264.
Hazardous waste incinerators have been strictly regulated under these
RCRA standards for several years, complying with elaborate permitting
and "test burn" requirements to demonstrate that the unit can safely
process the hardest-to-burn "principal organic hazardous constituents"
(POHCs), can maintain 99.99% "destruction and removal efficiency"
(DRE), and can provide HCL and particulate emission controls. In
addition to these current standards, EPA indicated that "the proposed
[RCRA] rule would add emission standards for products of incomplete
combustion (i.e., carbon monoxide and hydrocarbon limits), metals, and
hydrogen chloride and chlorine gas." 55 Fed. Reg. 17,862 (Apr- 27,
1990); see also 56 Fed. Reg. 7,134, 7,137 (Feb. 21, 1991). In
addition, EPA proposed to revise the definition of POHCs used to
demonstrate DRE. "The revised definition would allow the Director on
a case-by-case basis to approve as POHCs compounds that are neither
constituents in the hazardous waste nor organic." Id. The Agency
made clear that the proposed air emission standards for hazardous
waste incinerators were derived solely from EPA's RCRA authority. 55
Fed. Reg. at 17,863.
An institute ; £
of the National ~ *~ "*"
Solid Wastes
Management Association
-------
While the proposed 1990 revisions to the hazardous waste
incinerator regulations have not yet been finalized, EPA policy
requires that all new incinerator permits or major modifications to
existing hazardous waste incinerator permits incorporate the proposed
standards. The Agency has used RCRA's "omnibus provision" — which
states that permit writers may augment existing standards to ensure
protection of health and the environment -- to increase RCRA
protections during the pendency the proposed regulatory revisions.
Section 112(n)(7) of the 1990 Clean Air Act Amendments
specifically addresses RCRA-regulated facilities by providing that in
the case of any category of sources whose air emissions are regulated
under Subtitle C of RCRA, EPA must take such regulations into account
in establishing regulations under the amended Section 112 authority,
and to the extent practicable and consistent with Section 112, assure
that the RCRA and Clean Air Act regulations are consistent. In
proposing standards for the burning of hazardous waste in boilers and
industrial furnaces, 56 Fed. Reg. 7,134 (Feb. 21, 1991), EPA
recognized the limitations imposed upon it by Congress pursuant to
Section 112(n)(7):
It is premature for the Agency to attempt to provide a
definitive opinion on the relationship of these provisions
[Section 112] to today's [RCRA] rule. Sources covered by
the present rule may not ultimately be required to be
further regulated under amended Section 112. In this
regard, amended Section 112(n)(7) provides that if sources'
air emissions are regulated under Subtitle C, "the
Administrator shall take into account any regulations of
such emissions ... and shall, to the maximum extent
practicable and consistent with the provisions of this
section ensure that the requirements of such subtitle and
this section are consistent." Thus, at a minimum, Congress
was concerned about the potential for duplicative regulation
and urged the Agency to guard against it. Since the Agency
regards today's [RCRA] rules as protective (based on present
knowledge), it may be possible to avoid further air
emissions regulation.
Id. at 7,137.
The Agency has engaged in a lengthy and complex process to
develop stringent regulations for hazardous waste incinerators and to
establish generally consistent air emission standards for both
hazardous waste incinerators and boilers and industrial furnaces
burning or processing hazardous waste. It would be extraordinarily
confusing and would generate few if any additional environmental
benefits to now subject incinerators and newly-regulated boilers and
industrial furnaces to potentially overlapping, duplicative, or even
conflicting Clean Air Act requirements.
-------
A copy of our July 19th letter covering the listing and
prioritization of both municipal solid waste landfills and hazardous
waste incinerators is attached.
Given Congress' insistence that EPA to take steps to ensure that
RCRA and Clean Air Act regulations are consistent, we believe that EPA
should continue to pursue the regulation of air emissions from
hazardous waste incinerators under RCRA and, accordingly, remove the
category from the proposed draft Section 112 list.
DM/rr
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NBI111JA
National Solid Wastes Management Association
Via Hand Delivery
July 19, 1991
U.S. Environmental Protection Agency
Air Docket (LE-131 )
Attn: Docket No. A-90-49
401 M Street, S.W., Room M-1500
Waterside Mall
Washington, D.C. 20460
Re: Preliminary Draft List of Categories and Subcategories Under
Section 112 of the Clean Air Act; Notice of Availability of
Preliminary Draft List of Categories and Subcategories and
Request for Information, 56 Fed. Reg. 28,548 (June 21, 1991)
Dear Sir/Madam:
The National Sol id Wastes Management Association (NSWMA) is pleased
to respond to the Agency's preliminary draft listing of categories
and Subcategories pursuant to Section 112(c) of the Clean Air Act
Amendments of 1990 ("Act"). NSWMA is a trade group representing
more than 2,500 private waste service companies in the U.S. and
Canada. Our members include transporters of solid and hazardous
waste, operators of solid and hazardous waste treatment and
disposal facilities, waste recyclers, manufacturers and
distributors of waste management equipment, and firms providing
legal, financial and consulting services to the waste management
industry.
The Proper Scope of Section 112 Regulation Under the Act
Section 112 of the Act envisions the creation of technology-based
emission standards, set forth on an industrial category basis, for
major sources of listed hazardous air pollutants. Section
112(c)(1) requires the EPA to publish, within one (1) year of
enactment, a listing that includes categories of major sources of
"hazardous air pollutants". The Act does not, however, divest EPA
of its substantial discretion to choose among different emission
control provisions of the Act, i.e., to utilize Section 111 rather
than 112. Congress did not mandate that the Agency regulate under
.8-1
1730 Rhode Island Ave.. NW Suite 1000 Washington. DC 20036 (202) 659-4613
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U.S. Environmental Protection Agency
July 19, 1991
Page 2
Section 112 every source of a pollutant listed as hazardous.
Instead, it intended that EPA would evaluate all possible control
authorities and select-through the process of listing categories
the section best suited to the regulation of a given source.
Section H2(c)(1) provides that:
Not later than twelve (12) months after the date of
enactment of the Clean Air Act Amendments of 1990, the
Administrator shall publish, and shall from time to time,
but no less often than every eight (8) years, revise, if
appropriate, in response to public comment or new
information, a list of all categories and subcategories
of major sources and area sources (listed under paragraph
(3)) of the air pollutants listed pursuant to subsection
(b). To the extent practicable, the categories and
subcategories listed under this subsection shall be
consistent with the list of source categories established
pursuant to Section 111 and part C. Nothing in the
preceding sentence limits the Administrator's authority
to establish subcategories under this section, as
appropriate.
In addition, the Act expressly preserves EPA's authority to
exercise discretion in its Section 112 listing decisions by
deferring to previously established Section 111 requirements.
Section 112(d)(7) states that:
No emission standard or other requirement promulgated
under this section shall be interpreted, construed or
applied to diminish or replace the requirements of a more
stringent emission limitation or other applicable
requirements established pursuant to Section 111, part
C or D, or other authority of this Act or a standard
issued under State authority.
In sum, Congress did not mandate that EPA rely entirely upon any
one section of the legislation. The Agency has, however,
improperly included the category of "municipal landfills" within
the industry group "waste treatment and disposal", despite the
clear directive of Section 112(d)(7) and the Agency's prior
determination that the air emissions from municipal landfills
should be regulated exclusively pursuant to Section 111.
Similarly, the category of "hazardous waste incineration" should
be removed from the draft list in light of the Agency's prior
actions to regulate air emissions pursuant to the Resource
Conservation and Recovery Act (RCRA) .
("1 r"
0 \
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U.S. Environmental Protection Agency
July 19, 1991
Page 3
"Municipal Landfills" Should Not be Listed Within the Industry
Group "Waste Treatment and Disposal"
On May 30, 1991, EPA proposed standards of performance for new
municipal solid waste landfills under Section 111(b) of the Act and
emission guidelines for existing landfills under Section 111(d).
In the preamble to the proposal, EPA announced that it viewed the
"complex air emission mixture from landfills to constitute a single
designated pollutant." 56 Fed. Reg. 22,468, 22,475 (May 30, 1991).
The Agency noted that:
The EPA has determined that this mixture, MSW landfill
emissions, will be designated and regulated under
sections 11 Kb) and 111(d) of the CAA. Section m
standards can address a broad range of sources of
pollutants "...which may reasonably be expected to
endanger public health or welfare." Municipal solid
waste landfill emissions are designated on the basis of
both the health and welfare impacts described in the
previous section. Although different effects may result
from different individual constituents of the landfill
gas, the constituents are emitted together and the same
control technologies will control all the constituents
of MSW landfill emissions. Therefore, control of these
constituents can be achieved through regulation of "MSW
landfill emissions." Furthermore, MSW landfill emissions
may contain 100 or more individual compounds. Although
it would be theoretically possible to measure all the
components, such a task would be extremely burdensome.
expensive and impractical. The standards and guidelines
EPA is proposing provide a high level control of total
MSW landfill emissions, and avoid the administrative
burden and expense of measuring all components of MSW
landfill emissions by using NMOC Tnonmethane organic
compounds] concentration as a surrogate measure.
Id. (emphasis added).
In determining that the air emissions from municipal landfills
should be regulated solely under Section 111 of the Act, EPA stated
that it had considered in depth which statutory approach to
utilize. It explained its choice of Section 111 regulation over
Section 112 controls:
After considering what statutory approach to use in
regulating MSW landfill emissions, EPA announced the
decision to regulate these emissions under Section 111
of the CAA in the Federal Register on August 30, 1988
PI if
t (.•
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U.S. Environmental Protection Agency
July 19, 1991
Page 4
(53 FR 33314). When this decision was made, EPA was
cognizant that Section 112 of the CAA (which can be used
to develop NESHAP) could have been used. However, given
the uncertainty and difficulty in setting standards under
Section 112, EPA decided to proceed with standards
development under Section 111. Now that EPA is proposing
standards to regulate MSW landfills, EPA has found no
reason to change that initial decision to regulate these
emissions under Section 111 of the CAA.
Id. at 24,474.
Given the Agency's prior (and quite recent) finding that the
regulation of municipal landfills under Section 111 would conform
to congressional intent, promote a more effective system of
control, and produce cost-effective standards, no justification
exists for the proposed inclusion of "municipal landfills" within
the Section 112 category list.
In proposing emission controls pursuant to Section 111, the Agency
correctly noted that landfill gas and non-methane organic compound
emissions could practicably be regulated only through the
collection and combustion of landfill gas. Id. at 24,474, 24,475.
Implicit in the choice of a Section 111 strategy was EPA's
determination that the environmental and health risks of individual
non-methane organic compounds could not adequately be quantified.
Id. at 24,471, 24,474. The Agency, accordingly, reasoned that
because "the complex mixture [of emissions] cannot be characterized
quantitatively in terms of single pollutants...", id. at 24,475,
the extraction, combustion and monitoring of landfill gas would
clearly satisfy "best demonstrated technology' requirements set
forth in sections m(a)(1)(b) and (a)(1)(c) of the Act. No
additional environmental, health or administrative benefit can be
obtained by efforts to promote technology-based Section 112 MACT
standards for municipal solid waste landfills. Indeed, it is
highly unlikely that true technology-based controls could be
created, given that "the exact composition of MSW landfill
emissions can vary significantly from landfill to landfill and over
t i me." Id.
The Category "Hazardous Waste Incineration" Should be Removed from
the Preliminary Draft List in Light of the Agency's Determination
that Air Emissions from Incinerators Should be Regulated Pursuant
to RCRA
The EPA proposed, on April 27, 1990, amendments to existing
hazardous waste incinerator standards found at 4-0 C.F.R. Part 264.
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U.S. Environmental Protection Agency
July 19, 1991
Page 5
EPA has noted that "the proposed [RCRA] rule would add emission
standards for products of incomplete combustion (i.e., carbon
monoxide and hydrocarbon limits), metals, and hydrogen chloride and
chlorine gas." 55 Fed. Reg. 17,862 (Apr. 27, 1990); see also 56
Fed. Reg. 7,134, 7,137 (Feb. 21, 1991). In addition, "EPA proposed
to revise the definition of principal organic hazardous
constituents (POHCs) used to demonstrate destruction and removal
efficiency (ORE). The revised definition would allow the Director
on a case-by-case basis to approve as POHCs compounds that are
neither constituents in the hazardous waste nor organic." id. The
Agency made clear that the proposed air emission standards for
hazardous waste incinerators were derived solely from EPA's RCRA
authority. 55 Fed. Reg. at 17,863.
Section 112(n)(7) of the 1990 Clean Air Act Amendments specifically
addresses RCRA-regulated facilities by providing that in the case
of any category of sources whose air emissions are regulated under
Subtitle C of RCRA, EPA must take such regulations into account in
establishing regulations under the amended Section 112 authority,
and to the extent practicable and consistent with Section 112,
assure that the RCRA and Clean Air Act regulations are consistent.
In proposing standards for the burning of hazardous waste in
boilers and industrial furnaces, 56 Fed. Reg. 7,134 (Feb. 21,
1991), EPA recognized the limitations imposed upon it by Congress
pursuant to Section 112(n)(7):
It is premature for the Agency to attempt to provide a
definitive opinion on the relationship of these
provisions [Section 112] to today's [RCRA] rule. Sources
covered by the present rule may not ultimately be
required to be further regulated under amended Section
112. In this regard, amended Section I12(n)(7) provides
that if sources' air emissions are regulated under
Subtitle C, "the Administrator shall take into account
any regulations of such emissions... and shall, to the
maximum extent practicable and consistent with the
provisions of this section ensure that the requirements
of such subtitle and this section are consistent." Thus,
at a minimum, Congress was concerned about the potential
for duplicative regulation and urged the Agency to guard
against it. Since the Agency regards today's [RCRA]
rules as protective (based on present knowledge), it may
be possible to avoid further air emissions regulation.
Id. at 7,137.
Given Congress' insistence that EPA to take steps to ensure that
RCRA and Clean Air Act regulations are consistent, we believe that
p a.
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U.S. Environmental Protection Agency
July 19, 1991
Page 6
EPA should continue to pursue the regulation of air emissions from
hazardous waste incinerators under RCRA and, accordingly, remove
the category from the proposed draft Section 112 list.
Municipal Waste Combustors. Medical Waste Incinerators and
Commercial and Industrial Solid Waste Incinerators are
Appropriately Addressed Pursuant to Section 129 of the Act
NSWMA agrees with the Agency's position that solid waste
incinerators should not be included on the draft list of categories
in light of Congress' unequivocal determination that these sources
should be regulated exclusively under Section 129 of the Act:
Municipal waste combustors, medical waste incinerators
as well as commercial and industrial waste incinerators
are specifically addressed under the authority of section
129. The categories included on the list developed under
section 112(c) are subject to regulation under section
112. Solid waste incineration categories subject to
regulation under section 129 should not be listed under
section 112(c). Municipal waste combustion, medical
waste incinerators and general industrial solid waste
incineration were omitted from today's preliminary draft
list because these categories are specifically addressed
under section 129.
56 Fed. Reg. at 28,551 .
Congress did not intend that EPA promulgate emission limitations
and other requirements for solid waste incineration units pursuant
to Section 112.
Respectfully submitted,
H. Turner, Esq.
Association Counsel
National Sol id Wastes Management
Association (NSWMA)
1730 Rhode Island Avenue, N.W.
Suite 1000
Washington, D.C. 20036
(202) 659-4613
JHT:amp
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DISCUSSION
Following the BSD presentation, Mr. William 0'Sullivan asked
when the ranking produced by the source category ranking system
(SCRS) would be available. The EPA staff indicated that February
1992 was the likely date it would be available in the docket.
Ms. Deborah Sheiman expressed concern that slippage in
several previously scheduled projects appeared to have occurred.
She reported that many groups were waiting for standards for
sources that had been in the pipeline for some time, such as pulp
and paper, publicly owned treatment works (POTW's), and hazardous
wastewater treatment. She further asked why EPA is not
scheduling 40 source categories for completion by November of
1992.
Mr. Bruce Jordan, Director of the Emission Standards
Division, responded that EPA considered the congressional intent
behind the 40 source category mandate to be equivalent to the
current HON project. Ms. Sheiman then requested that the
definition of HON be stated for the record. Mr. Jordan asserted
that HON must be defined as one category in order to allow
emissions averaging, but that EPA's legal staff is confident that
it can defend the position that the HON, even defined as one
source category, would meet the congressional mandate of
40 source categories because of clear congressional intent.
-------
In response to Ms. Sheiman's question about wastewater, Ms.
Susan Wyatt, Chief of the Chemicals and Petroleum Branch (CPB),
reported that wastewater is being regulated through the various
rulemakings underway for source categories associated with
wastewater, such as the HON. Ms. Wyatt further noted that the
CAA mandates that emissions from POTW's be regulated within five
years, although that was not reflected in the presentation. In
the case of the pulp and paper project, the schedule was affected
by the need to work with the Office of Water, because of the
likelihood that technologies effective for air impacts may also
be effective for water impacts.
Ms. Sheiman then asked if the current schedule would
accomplish the twenty-five percent mandate for the four-year
standards, and was assured by Mr. Jordan that the schedule would
meet the mandates for all four time periods. Mr. David
Svendsgaard, also of CPB, added that the two polymers and resins
projects actually count for about twenty source categories.
Mr. Donald Arkell asked if EPA intended to double-dip with
the HON (that is, regulate a polymer and resin source once under
the HON and then again under the polymer and resin rule). Mr.
Bob Rosensteel of CPB reported that we would indeed have two
rules. However, even though it is likely to have HON source(s)
and polymer and resin source(s) located at the same site, the HON
would regulate the production of SOCMI chemicals and the polymers
and resins rule would regulate the resin product.
Mr. Brian Taranto commented that since the CAA amendments
refer to source categories or subcategories, if the HON is
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comprised of about 400 subcategories, EPA doesn't have to worry
at all. Mr. Jordan replied that if the HON equaled 400
categories and fulfilled the 2-, 4-, and 7-year requirements, EPA
still has a monumental task ahead in order to regulate the
remaining categories by the year 2000. Thus, EPA has to get
started now, and stay busy until the year 2000, to meet all of
the Section 112(e) requirements.
Mr. Taranto then noted that it appeared as if the efficiency
of grouping primarily considered regulatory efficiency, and asked
if feasibility of compliance had been considered. Mr. Rosensteel
replied that feasibility of compliance had not been a CAA
criteria, though it could be considered in the actual rulemaking
for a source category. Mr. Taranto asserted that although it
might be convenient to co-regulate many similar source
categories, all the source categories regulated together would
have to respond within 3 years. He noted that this would result
in much business activity, even if the CAA amendments did not
consider that result. Mr. Rosensteel responded that the HON
would be the primary regulation to have this impact.
Ms. Sheiman then proposed that the regulation of
pharmaceutical production should be so similar to the HON, why
would EPA need to wait until the 7-year bin to address
pharmaceutical production? Ms. Wyatt replied that EPA needed
time to evaluate the impacts on the pharmaceutical production
source category since it is a very diverse and complex industry.
Mr. William Dennison commented that for all the considerable
input into the SCRS, the feedback to EPA from its use will slow
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down the process even more. Mr. Tim Mohin, Chief of the Program
Implementation and Review Section of the Pollutant Assessment
Branch (PAB), emphasized that the SCRS was intended to be a tool,
or first step, in the prioritization process. Mr. Ralph Hise
asked if there had been clear divisions in the source category
ranking to establish the cut-off for adjacent bins. Mr. Jordan
responded that binning had not been an easy process. Mr. Mohin
noted that due to the previous risk-basis for developing NESHAP,
the on-going projects had been undertaken due to high risk, which
was borne out by the SCRS.
Mr. John Pinkerton reported that he feared that challenges
would keep EPA from completing the job. Mr. Jordan asserted that
BSD is looking at how the rulemaking process can be changed to
improve its success. He added that EPA will need a lot of input
from industry to help it do a good job. Mr. Mohin noted that the
CAA amendments are very prescriptive and were supposed to make
the process easier, with smoother technical processing.
Mr. Jordan clarified that even if a scheduled source category is
sub-categorized, every resultant sub-category needs to be
completed within the same bin.
Ms. Vivian Mclntyre asked if adjustments in the list can be
made prior to finalizing the schedule. Mr. Mohin recited the CAA
amendments, "you shall develop the schedule from the initial
list."
Ms. Sheiman asked about the treatment of certain source
categories, such as smelters and electric utilities, having only
a few people who are highly exposed. Mr. Jim Crowder, Chief of
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the Industrials Studies Branch, noted that the SCRS did take this
into account and generally these source categories, such as
Primary Lead and Primary Copper, were tentatively assigned to the
7-year bin.
Mr. Patrick Atkins asked what the schedule and list would
look like. Mr. Jordan replied that the list, showing the actual
source categories is planned for release in December. The source
category regulatory schedule, which will detail when regulations
will be promulgated for each of these source categories, is
planned to be published for comment in February 1992. He
concluded the discussion by noting that BSD staff has monumental
hurdles to overcome, but that MACT standards cannot be acted upon
until the initial list and preliminary schedule are published.
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DISCUSSION
Following Mr. Kaiser's remarks, Mr. William 0'Sullivan asked
what the ICWM would propose as a final particulate standard.
Mr. Kaiser reported that he was only a spokesperson for ICWM, and
reflected that the EPA has established RCRA as the proper vehicle
for control.
Mr. Paul Atkins noted that EPA doesn't need to cherry-pick
among regulations to get to the most stringent regulation.
Mr. William Dennison, however, commented that different laws
force EPA to look at different concerns. He asked Mr. Kaiser if
an integrated process would satisfy the association, while
allowing EPA to fulfill its various mandates. Mr. Kaiser again
noted that he was speaking only as a spokesperson, and was not
prepared to address any issues outside the scope of his
presentation.
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CHEMICAL
MANUFACTURERS
ASSOCIATION
WRITTEN COMMENTS OF THE
CHEMICAL MANUFACTURERS ASSOCIATION
BEFORE THE
NATIONAL AIR POLLUTION CONTROL
TECHNIQUES ADVISORY COMMITTEE
ON THE
SOURCE CATEGORY SCHEDULE
NOVEMBER 19-21, 1991
2501 M Street, NW 202-887-1100
Washington, D.C. 20037 Telex 89617 (CMA WSH)
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CHEMICAL MANUFACTURERS ASSOCIATION
COMMENTS ON EPA'S
SOURCE CATEGORY SCHEDULE
The Chemical Manufacturers Association (CMA) welcomes the
opportunity to comment on the materials developed by the Environmental
Protection Agency (EPA) for the November 19-21, 1991, meeting of the
National Air Pollution Control Techniques Advisory Committee
(NAPCTAC). CMA is a nonprofit trade association whose member companies
represent more than 90% of the productive capacity for basic industrial
chemicals in the United States. Our comments will address EPA's
schedule for regulating source categories and how this schedule may
affect the chemical industry.
We will not be addressing the MACT standard in these comments, and
for good reason. We support a clearly defined technology-based control
standard. We endorsed that kind of control standard during the Clean
Air legislative debate, and we think EPA is well on its way towards
developing MACT standards for our industry. Our specific thoughts on
EPA's proposal for MACT standards are included in our comments
addressing that proposal.
CMA believes that controls ought to be placed on emissions of
listed air toxics. Responsible Care® commits each of CMA's 185
member companies to strive for continuous improvement in operations
that affect health, safety and the environment. And we are putting our
commitment into practice by implementing our Pollution Prevention
Code. It calls on companies to make continuous reductions in waste
generation and releases to the environment.
Promulgating a single MACT standard for the entire SOCMI industry
might at first, appear to be a speedy and effective implementation plan
for our industry. We must caution, however, that recent experience
shows that EPA, the States and the regulated community will have their
hands full getting the thousands of SOCMI facilities into compliance
with new control standards all at once.
We are concerned that if all regulated facilities must comply with
the standard at the same time they will overwhelm the regulated
community's ability to design safe and effective control systems and
equipment. In addition, the market's ability to supply needed
pollution control equipment and services will be overwhelmed and costs
will skyrocket. State agencies will be flooded with permit
applications. Companies will face long delays for construction permits
and other government approvals. The effect would be regulatory
gridlock.
One way to address these problems would be to stagger promulgation
dates for MACT for the SOCMI industry. The Agency's charge under the
Clean Air Act is to promulgate MACT for 40 source categories or
subcategories by November, 1992. Through a series of promulgation
dates, the Agency can still meet this statutory requirement and reduce
-------
the likelihood of creating gridlock and widespread unintended
noncompliance.
Another way would be to address compliance deadlines. Compliance
deadlines cannot be compressed into unrealistic or unachievable time
frames. Delays and logjams in the permit process are a reality that we
should all accept. The Agency can acknowledge this, for example, by
including provisions in the compliance timeline that takes into account
events that are beyond the control of a regulated source.
When EPA promulgates new MACT standards beginning in November
1992, facilities will install controls that will require physical or
operational changes. Those changes will trigger federal and state
pre-construction review and permitting requirements. We anticipate
that EPA will establish a 3-year compliance period for the new MACT
standards. Will permitting programs be able to cope with the resulting
flood of permit applications in a timely manner? We believe that many
permits will face extensive delays. The statute does not contemplate
that sources may be trapped into involuntary noncompliance as a result
of the actions of other entities, such as permitting authorities, over
whom they have no control.
It is very important for EPA to define compliance requirements in
a way that protects sources from being involuntarily in noncompliance
due to delays beyond their control. EPA can do this by defining what
it means to be in "compliance." For instance, for those sources that
must obtain permits for the mandated controls, a source would be in
compliance once a complete permit application is approved by the
permitting authority. That filing should be sufficiently in advance of
the compliance deadline to allow for a reasonable period of review by
the permitting authority plus the time required for construction.
The purpose of this approach is not to allow sources to avoid
meeting the compliance deadline by waiting until the last minute to
submit their permit applications or by submitting incomplete
applications. To the contrary, it would require sources to take all
steps necessary to ensure that they will meet the substantive
requirements of the standard by the compliance deadline if the
permitting authorities complete their review in a timely manner.
Regulating all of SOCMI under a single MACT standard is an
ambitious, and potentially dangerous, undertaking for EPA. Unless a
carefully planned and flexible approach is taken, the effort is likely
to collapse under its own weight. The risk of failure is high due to
equipment shortages, permit delays and other factors beyond everyone's
control. If it is accomplished successfully -- and we believe it can
be if EPA accepts these recommendations -- the standard can help all of
us to meet the requirements of the Clean Air Act.
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American Iron and Steel Institute
1101 17TH STREET, N.W., SUITE 1300 WASHINGTON, D.C. 20036-4700
Phone(202)452-7100 November 22, 1991
Fix (202) 463-6573
Mr. Bruce C. Jordan
Director
Emissions Standards Division (MD-13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Dear Bruce:
At the NAPCTAC meeting of November 19, 1991, a presentation was
made on EPA's efforts to establish a source category list and schedule
for development of regulations for hazardous air pollutants. The
American Iron and Steel Institute (AISI) has some concerns with the
direction of that program and wish to submit the following comments
for the record of the NAPCTAC meeting.
When the preliminary source category list was published on
June 21, 1991, AISI submitted comments to suggest that a single
category for iron and steel manufacturing was too broad. We note that
electric furnace steelmaking has now been divided into two categories
(stainless and non-stainless), with both separated from the iron and
steel manufacturing category. However, we continue to believe that
the iron and steel manufacturing category is too broad and should be
separated into iron sintering, iron blast furnaces, and basic oxygen
steelmaking, as noted in our comments on the June 21 proposal.
In addition, we are concerned with the clustering of so many
categories related to iron and steel in the 7-year grouping. We
recognize that the 7-year "bin" includes categories that could have
regulations promulgated anytime within a three-year period (five to
seven years), but the history of regulatory deadlines tells us that
most will come toward the end of that period. Indeed, as you
indicated at the NAPCTAC meeting, the Agency will be hard-pressed to
stay on schedule, given the work load mandated by the Congress and the
resource limitations of the Agency.
Moreover, even if the regulations are promulgated gradually over
the three-year period, the number of categories applicable to the iron
and steel industry would impose an incredible burden on the industry
over that short span. For example, in the 7-year bin are the
following categories that would be directly applicable to the industry:
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Coke Ovens (Pushing, Quenching, Battery Stacks)
Integrated Iron & Steel Manufacturing
Non-Stainless EAF Steel Manufacturing
Stainless EAF Steel Manufacturing
Steel Pickling
Process Heaters
Steel Foundries
Iron Foundries
Of course, I do not need to remind you that during this same time
frame (1995-1997) the industry will already be exposed to huge
expenditures and resource-intensive projects to comply with coke oven
emission control requirements, regulations which will be promulgated
in the first batch of standards by the end of 1992.
In addition to those regulations that will impact our member
companies directly, the 7-year bin also includes the following
categories that will impact key industry suppliers:
Chromium Refractories Production
Clay Products Manufacturing
Ferroalloys Production
Hydrochloric Acid Production
Hydrogen Fluoride Production
Internal Combustion Engines
Primary Lead Smelting
Zinc Smelting
The impact on these industries will indirectly affect the iron
and steel industry and will compound the cost impacts and potential
disruption over the very short three-year period.
Among the criteria used by EPA to establish the groupings of
source categories was the "efficiency of grouping", which I
interpreted to mean regulatory efficiency for the Agency. In taking
that approach, it is apparent that the Agency has created considerable
inefficiency for industries and has imposed an unconscionable burden
on industries to do everything at once.
AISI strongly recommends that EPA reconsider the source category
groupings that have been proposed and requests that some of the
categories pertaining to the iron and steel industry be moved into the
10-year bin. A further breakdown of the category titled Integrated
Iron & Steel Manufacturing might provide the potential to do this.
AISI would be pleased to meet with you and your staff to discuss the
criteria used to establish the groupings to help set priorities that
would allow some categories to be reassigned to the 10-year bin.
Very truly yours,
Bruce A. Steiner
Vice President
Environment & Energy
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INDUSTRIAL PROCESS
COOLING TOWERS
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Mr. Philip Mulrine of the Industrial Studies Branch briefed
the committee on the status of the NESHAP development for
chromium emissions from industrial process cooling towers
(IPCT's). The presentation slides are provided in Attachment 1.
Mr. Mulrine began by stating the objectives of the
presentation. Background information was then provided on the
use of chromium in IPCT's, cooling tower operation and emissions,
and the rationale for controlling chromium emissions from IPCT's.
Mr. Mulrine identified two general cooling tower types (comfort
cooling towers [CCT's] and IPCT's) and explained how cooling
towers operate. He also briefly discussed the CCT rule, which
was promulgated under the Toxic Substances Control Act (TSCA) and
which eliminated the use of chromium compounds in CCT systems.
This was followed by a description of typical cooling water
treatment programs, which include corrosion inhibitors, such as
chromate, and other additives for controlling corrosion, scaling,
fouling, and microbial growth in IPCT systems. The factors that
affect emissions from cooling towers were also described.
Mr. Mulrine then identified the industries that use
chromium-based water treatment programs and provided estimates of
the number of cooling towers using chromium for corrosion
control. Nationwide hexavalent chromium emissions were also
presented. He then described the two measures used to control
chromium emissions from IPCT's—high-efficiency drift eliminators
and nonchromate-based water treatment programs—and the extent to
202
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which each of these controls is used in IPCT systems. He also
pointed out that because using nonchromates completely eliminates
chromium emissions and is in practice in 90 percent of IPCT's
nationwide this control measure would qualify as the maximum
achievable control technology (MACT) for new and existing sources
under Title III of the Clean Air Act as amended November 1990
(CAAA). In addition, the nonchromate option constitutes a
pollution prevention measure because it eliminates the use of
chromium at the source.
Mr. Mulrine then discussed the implications of a nonchromate
standard for IPCT's. He began by describing the process of
converting from a chromate-based to a nonchromate-based water
treatment program. He then summarized the findings of EPA's
investigation into the feasibility of banning chromate use in
IPCT systems and the possible impediments to nonchromate use.
The results of the investigation were that nonchromate-based
programs have been demonstrated to perform as well as chromate-
based programs under all conditions investigated and in all sizes
of IPCT systems. The cost impacts of a nonchromate standard were
then discussed. Mr. Mulrine summarized the presentation by
stating that nonchromate-based water treatment programs currently
are used in 90 percent of IPCT's nationwide, there appears to be
no impediment to operating the remaining IPCT's on nonchromate-
based programs, and the resulting costs and economic impacts
would be minimal.
203
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PRESENTATION OBJECTIVES
DESCRIBE INDUSTRIAL PROCESS COOLING TOWERS
(IPCT'S) AND THEIR FUNCTION
SUMMARIZE THE USE OF CHROMIUM FOR CORROSION
CONTROL IN IPCT'S
DESCRIBE TECHNIQUES USED TO CONTROL
CHROMIUM EMISSIONS FROM IPCT'S
PRESENT THE RESULTS OF OUR ASSESSMENT OF THE
FEASIBILITY OF BANNING CHROMIUM USE IN IPCT'S
204
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BACKGROUND
CHROMIUM (IN THE FORM OF CR + 6) IS USED FOR
CORROSION CONTROL IN COOLING TOWER SYSTEMS
COOLING TOWER SYSTEMS USING CHROMIUM WATER
TREATMENT PROGRAMS EMIT CR + 6
HEXAVALENT CHROMIUM (CR + 6) IS A VERY POTENT
HUMAN CARCINOGEN
CHROMIUM COMPOUNDS ARE LISTED AS HAP'S
UNDER SECTION 112
205
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TYPES OF COOLING TOWERS
COMFORT COOLING TOWERS (CCT'S) ARE USED IN
HEATING, VENTILATION, AND AIR CONDITIONING
(HVAC) SYSTEMS ONLY
INDUSTRIAL PROCESS COOLING TOWERS (IPCT'S) ARE
USED TO REMOVE HEAT PRODUCED FROM
MANUFACTURING, INDUSTRIAL, AND CHEMICAL
PROCESSES
2
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EXISTING FEDERAL REGULATIONS
CCT RULE PROMULGATED FEBRUARY 1990
BANNED CHROMIUM USE IN ALL CCT'S
RULE PROMULGATED UNDER THE TOXIC SUBSTANCES
CONTROL ACT (TSCA)
207
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REASONS FOR TSCA RULEMAKING
GREATLY SIMPLIFIED ENFORCEMENT
LARGE NUMBER (250,000) OF POTENTIAL USERS
RELATIVELY SMALL NUMBER (100) OF
DISTRIBUTORS
POINT OF REGULATION IS DISTRIBUTOR
BANNED DISTRIBUTION OF CHEMICALS IN
COMMERCE
IN CONTRAST, UNDER CAA THE POINT OF
REGULATION WOULD BE THE USER
EOB
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EMISSIONS
\H//
AIR INLET
MAKEUP
CROSSFLOW
COOLING
TOWER
COLO WATER BASIN
HOT WATER RETURN
r —
SLOWDOWN
HEAT EXCHANGERS
PROCESS
INDUSTRIAL PROCESS COOLING SYSTEM
209
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FAN STACK
DISTRIBUTION DECK
FILL
•COLD WATER BASIN
COOLING TOWER COMPONENTS
210
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WATER TREATMENT PROGRAMS
CORROSION INHIBITOR TO CONTROL CORROSION
GENERAL
LOCALIZED (PITTING)
DISPERSANTS TO CONTROL SCALING AND FOULING
BIOCIDE TO CONTROL MICROBIAL GROWTH
ACID/CAUSTIC FOR PH CONTROL
211
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CHROMIUM WATER
TREATMENT PROGRAMS
CHROMATE (CR04'2) IS THE ACTIVE INGREDIENT IN
CHROMIUM-BASE?) PROGRAMS
TYPICAL CHROMATE CONCENTRATIONS RANGE FROM
10 TO 25 PPM
KEY ADVANTAGES
VERY EFFECTIVE CORROSION INHIBITOR
DOES NOT REQUIRE TIGHT CONTROLS OF
CHEMICAL FEED OR COOLING WATER QUALITY
cio
21
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COOLING TOWER EMISSIONS
EMISSIONS CONSIST OF SMALL WATER DROPLETS
REFERRED TO AS "DRIFT-
DRIFT CONTAINS ALL CONSTITUENTS OF
RECIRCULATING WATER, INCLUDING CHROMIUM,
OTHER METALS AND MINERALS
FACTORS AFFECTING EMISSIONS
AIR FLOW RATE THROUGH FILL SECTION
WATER RECIRCULATION RATE
TYPE OF FILL MATERIAL
TYPE OF DRIFT ELIMINATOR
CONCENTRATION OF RECIRCULATING WATER
IMPURITIES
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CHROMATE USE IN INDUSTRY
INDUSTRIES THAT USE CHROMATE WATER
TREATMENT PROGRAMS
PETROLEUM REFINERIES
CHEMICAL MANUFACTURING PLANTS
PRIMARY METALS PRODUCERS
OTHERS (TEXTILE, TOBACCO, TIRE AND RUBBER,
GLASS)
NATIONWIDE THESE INDUSTRIES OPERATE ABOUT
8000 IPCT'S AT 2800 SOURCES
CHROMATE IS USED IN APPROXIMATELY 800, OR 10%
OF THE IPCT'S
REMAINING 90% USE NONCHROMATES
214
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ANNUAL HEXAVALENT CHROMIUM EMISSIONS
BY INDUSTRY SECTOR
ro
Primary metals (14.8%)-\
Other (0.9%)
Chemical manufacturing (45.4%)
Petroleum refining (38.9%)
Total Annual Emissions: 23 Mg (25 tons)
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CONTROL MEASURES
ADD-ON CONTROL
HIGH EFFICIENCY DRIFT ELIMINATORS (HEDE'S)
PROCESS CHANGE
NONCHROMATE WATER TREATMENT PROGRAMS
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HEDE'S
MORE COMPLEX THAN STANDARD EFFICIENCY DRIFT
ELIMINATORS
ESTIMATED TO ACHIEVE 70% REDUCTION IN DRIFT
OVER STANDARD EFFICIENCY DRIFT ELIMINATORS
USED ON ONLY ABOUT 5% OF ALL IPCT'S
CAPITAL COST: $8,700 - $51,000
OT 7
u x «
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NONCHROMATE WATER TREATMENT
ULTIMATE POLLUTION PREVENTION ALTERNATIVE
TOTALLY ELIMINATES CHROMIUM
PHOSPHATES, MOLYBDATES, ZINC, AND ORGANICS
ARE USED INSTEAD OF CHROMIUM
NONE ARE HAZARDOUS AIR POLLUTANTS
ACHIEVES RESULTS COMPARABLE TO CHROMATE
PROGRAMS
REQUIRES CAREFUL CONTROL OF CHEMICAL FEED
AND WATER QUALITY PARAMETERS
USED IN 90% OF IPCT'S IN THE 8 INDUSTRY
CATEGORIES
WOULD QUALIFY AS MACT FLOOR FOR NEW AND
EXISTING IPCT'S UNDER TITLE III DEFINITION
21B
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MOTIVATIONS FOR CONVERTING
TO NONCHROMATE
INCREASED PUBLIC AWARENESS OF THE TOXICITY OF
HEXAVALENT CHROMIUM
VENDORS ARE ENCOURAGING THE CONVERSION TO
NONCHROMATE PROGRAMS
AVAILABILITY OF NONCHROMATE PROGRAMS
HAS INCREASED
PERFORMANCE OF NONCHROMATE PROGRAMS
HAS IMPROVED TO EQUAL CHROMATE
CHROMIUM WATER TREATMENT PROGRAMS BANNED
IN CALIFORNIA IN 1990
COMPANIES ARE ANTICIPATING FEDERAL
REGULATIONS BANNING CHROMIUM WATER
TREATMENT
r-
- 7
I
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CONVERSION TO NONCHROMATE
INSTALL COOLING WATER CONTROL SYSTEM
INSTRUMENTATION
TIMER FOR CHEMICAL FEED
PH FOR ACID/CAUSTIC
CONDUCTIVITY FOR SLOWDOWN
AUTOMATIC CONTROLLERS FOR CHEMICAL FEED,
SLOWDOWN AND MAKEUP
PLANT SHUTDOWN IS NOT NECESSARY
CAPITAL COST: $4,300 - $144,000
220
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IMPEDIMENTS TO NONCHROMATE USE
COOLING TOWER SIZE
ADVERSE CORROSION EFFECTS
POOR MAKEUP WATER QUALITY
HIGH TEMPERATURE PROCESSES
£21
£j u A
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INFORMATION COLLECTION
ACTIVITIES
SURVEY OF 140 FACILITIES WITH IPCT'S
SURVEY OF WATER TREATMENT VENDORS
(>50% OF MARKET)
SITE VISITS TO 4 REFINERIES (21 IPCT SYSTEMS)
SURVEY RESPONSES FROM 18 CHEMICAL
MANUFACTURERS (41 IPCT SYSTEMS)
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FINDINGS
NONCHROMATES WIDELY USED IN ALL SIZES OF
IPCT'S
CORROSION RATES NOT ADVERSELY AFFECTED
NONCHROMATES USED EXTENSIVELY IN PLANTS
LOCATED IN AREAS WHERE WATER QUALITY IS
GENERALLY POOR
NONCHROMATES USED EXTENSIVELY IN PLANTS
THAT OPERATE HIGH TEMPERATURE HEAT
EXCHANGERS
n
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COST IMPACTS
RECIRCULATION EMISSIONS ANNUALIZED COST ($) COST EFFECTIVENESS
RATE, gal/min (Ib/yr) CHROMATE NONCHROMATE ($/!b)
CO
to
^
1,000
15,000
105,000
10
120
1,250
1,000
27,000
188,000
6,000
51,000
332,000
500
200
100
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INCREMENTAL COST IMPACTS
FOR CHROMATE USERS
NATIONWIDE INCREMENTAL COSTS
HEDE RETROFIT OPTION $11 MILLION
NONCHROM ATE OPTION $14 MILLION
CURRENT COSTS FOR
CHROMATE USERS
$ 1 5.5 MILLION
TOTAL REVENUE FOR
CHROMATE USERS
APPROX. $64 BILLION
ESTIMATED PRICE INCREASE
REQUIRED TO RECOVER
CONTROL COSTS
< .03%
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SUMMARY
THERE APPEARS TO BE NO IMPEDIMENT TO
NONCHROMATE USE
90% OF IPCT'S USE NONCHROMATE TREATMENT
PROGRAMS
COST AND ECONOMIC IMPACTS ARE MINIMAL
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Good Morning, I'm Chuck Sanderson, a project engineer
and have been involved in water treatment for over 30
years.
My experience has been chemical and non-chemical water
treatment plus, of course, sodium ion exchange, de-ion-
ization, reverse osmosis, filtration, etc.
The purpose of my presentation is to introduce a new
technology that is not mentioned in the Information
Document for Industrial Process Cooling Towers dated
September 1991.
Water is by far the most widely used heat transfer
medium, because of its plentiful supply and favorable
thermodynamic properties. One problem with using water
is that it often contains other chemical species which
are not well suited for heat-transfer applications.
Specifically, certain dissolved species, generally
measured through hardness, may precipitate out of
solution onto the heat transfer surface in the form of
"scale". Scaling adds a resistance to heat transfer,
and thus has a detrimental impact on thermal perform-
ance. There are several methods used to overcome this
problem, and one of these alternatives, the magnetic
treatment of water is the topic of this review.
I am not endorsing or promoting any particular product,
however, this technology is being used successfully
throughout the United States and 37 foreign countries
that I am aware of.
It is far from a cure-all, however, when a properly
designed system is correctly installed on a cooling
tower, or any water-using equipment within its limita-
tions, hard water scale and corrosion can be controlled
as effectively as any other method presently being used
in the industry.
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The new technology being utilized today, especially in
cooling towers, is a combination of several pieces of
equipment of old and proven technology of the past.
Shown here is a system that was developed in 1988 and
is now being used in several states, but nowhere more
than in the state of Michigan. The Department of
Natural Resources in Lansing, Michigan is enforcing the
"wetland restrictions" and has been instrumental in
creating the need for a non-chemical discharge from the
cooling towers that do not have the luxury of city
sewers.
As you can see, the water is pulled from the basin of
the tower (or perhaps a remote sump) by the pump,
through the first sight glass and then forced
through a hydro-cyclone (or sometimes referred to as a
centrifugal separator) at high velocity and then
through a sight glass, a magnetic water conditioner and
back into the far end of the sump.
This system is controlled by a mini computer that
automatically purges the solids from the bottom of the
separator and down the drain. There is no toxic waste
as the purge water contains nothing more than what was
introduced with the fresh water make-up and perhaps
some air pollutants that the water may have picked up
in the tower. Basically, the bleed water is nothing
more than a concentration of calcium and magnesium mixed
with the purge water.
At the request of a user of this original system, on
one of their cooling towers a second piece of
equipment was designed as an add-on to eliminate all
bleed.
228
-------
This system was then designed and installed on one of
the 4 cooling towers being used for industrial process
with the other 3 continuing the use of softened water,
plus the various chemicals needed to control scale,
corrosion and algae.
The vendors of both treatment systems (chemical and
non-chemical) were put on notice that at the end of a
6-month period, only one would remain and would treat
all 4 towers.
To make sure each method of treatment was equal,
hydro-cyclones and sock filters were installed on all 4
cooling tower recirculating lines. The water softeners
were left in-line with the 3 chemically treated towers,
while the water softener was by-passed on the non-
chemical treated cooling tower.
Each vendor had total freedom to adjust the system to
provide the best results. The difference between the 2
systems were:
Chemical System Non-chemical System
Chemicals No chemicals
Soft water make-up Hard water make-up
Constant bleed No bleed
Due to an unscheduled down-time of the plant, the
systems were opened after only 5 months of operations.
The difference found in the cooling towers were:
Chemically Treated Non-Chemical Treatment
Normal scale accumulation No new scale formation,
substantially cleaner
than at time of instal-
lation
Considerable algae Much less algae than 5
months previous with
only traces in dead
water area
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-------
The case histories of this new technology, used for the
treatment of the water used in the industrial process
cooling towers is quite impressive.
The water that would normally be purged down the drain
from the bottom of the hydro-cyclone on the first
system, is directed to the pump on the second system
through a second magnetic water conditioner, then
through 2 smaller separators at extremely high velocity
which separates as much of the good water as possible.
It then goes to a holding recirculating tank and con-
tinues to pass back through the second system for
ultra-fine separation.
The purged water from the bottom of the dual separators
is forced, under pressure, through a .5 micron sock (or
bag) filter. The filtered water then joins the
continuing recirculated water which eventually over-
flows into a second tank and from there is pumped back
into the cooling tower.
The sock filter is sized according to the water quality
and the tonage of the tower, to enable it to hold at
least a 30 day accumulation of the calcium magnesium
siudge.
The socks are pulled, hung to dry and the residue is
then safely disposed of without any restrictions.
No bleed is required and the only water loss, other
than evaporation, drift or leaks, is the moisture con-
tained in the sock when it is pulled to dry.
As I stated in the beginning, nothing "man-made" is
ever 100%, however, there are very strong indications
in the field that support the evidence that a combina-
tion of standard equipment, coupled with the proper
magnetic fields, will produce desirable water treatment
results.
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-------
There are many factors to consider, such as the flux
density, gauss, velocity, reversing alternating
polarity, L over D pole separation and perhaps the most
important is the velocity of the water breaking the
lines of force perpendicular to the flow.
This new technology has proven to be a viable
alternative to the chemical water treatment and can be
used as a "preventative measure" instead of a "cure" to
combat our present-day pollution problems caused by
cooling tower's drift and bleed.
I realize that time is very limited, but if there are
any questions, I will try to answer them in the
allotted time.
Thank you.
£31
-------
ro
CO
ro
25 MICRO,
FILTER
AUTOMAT 1C PURGI
VALVE FOR FILTER
FRAME
WATER
CONDITIONER
OUTLET-TO
OPPOSITE END OF
COOLINGTCWER
MANUAL SYSTEI
DRAIN VALVE
SKID
PI ATFORM
HYDRO-CYCLONE
SEE-THRU
HOUSING
COMPUTERIZED
TIMER CONTROL
FILTER
DRAIN VALVE
CONCENTRATION
COLLECTOR
AUTOMATIC PURGE
VALVE FOR
HYDRO-CYCLONE
INLET--
FROM SUMP
PUMP
-------
ACV-5K
( O
CO
FROM COOLING
SYSTEM
TO COOLING
SYSTEM
MAKE-UP
WATER
CLOSED
CIRCUIT
COILS
u
CT-200APD
-------
-------
SEPCRATOR
, • rj
SEPERATOR3
SOCK FILTER
FILTERS
*EUERCENCY OVERFLOW-
TO DRAIN
PUMP
WATER
CONDITIONERS
VOTE: THIS 3YSTEU 13 DESIGNS) TO RECYCLE WATER BLEED THAT "WOULD
NORMALLY BE DISCHARGED INTO THE SEWERS. IP SUMP PUliH FAILURE KA3
TO OCCUR, HATER WOULD OVERFLOW INTO THE DRAIN TO AVOID FLOODING,
HOWEVER. THIS IS GOOD QUALITY WATER AND DOES NOT CONTAIN ANY POLLUTANTS.
SOLENOID
VALVE
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DISCUSSION
Following the presentation by Mr. Mulrine, Mr. Bruce Jordan
opened the floor to questions and comments by the NAPCTAC
members. Dr. John Pinkerton began the discussion by asking if
the nationwide cost impacts for the nonchromate option were based
only on the IPCT's in which chromium is currently used. Mr. Al
Vervaert of the Industrial Studies Branch responded that the cost
impacts were based only on the IPCT's currently using chromate-
based water treatment programs. Dr. Pinkerton asked if anyone
had expressed concern about the use of phosphate and zinc as
chromium substitutes because these two compounds are usually
regulated in wastewater discharge permits and in certain parts of
the country the discharge of these compounds may be limited. Mr.
Vervaert replied that phosphate and zinc discharges have not been
an issue.
Dr. Patrick Atkins asked if the issue of phosphate and zinc
discharges had been investigated because zinc, in particular, can
be difficult to remove from wastewater. Mr. Vervaert responded
that this matter had not been investigated extensively, but in
many cases, the wastewater discharged from cooling towers is
treated onsite, and, thus, the impacts would be "inhouse"
impacts. In addition, when facilities convert IPCT's from a
chromate to a nonchromate program, owners or operators can select
from a number of alternative programs, including phosphate-based,
zinc-based, molybdate-based, and others. Mr. Richard Marinshaw
of Midwest Research Institute commented that there were cases in
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which plants were forced to use alternative water treatment
programs in order to comply with zinc discharge limits. He
pointed out that in addition to some of the nonchromate-based
programs, chromate-based water treatment programs also use zinc.
He also noted that there are nonchromate-based programs, such as
molybdate-based and all-organic programs, that contain neither
zinc nor phosphate.
Dr. Atkins also remarked that it was misleading to compare
control cost to the total revenues of the affected industries and
conclude that the economic impacts are minimal because the IPCT
standard would be one of several standards with which the
affected facilities must comply and the combined impact of all of
these standards would not be insignificant. Mr. Vervaert agreed
that an IPCT standard would be one of several that would affect
these industries. However, by comparing control cost to total
revenues, EPA was trying to demonstrate that the $14 million cost
of the nonchromate measure may appear to be high, but it is a
very small percentage of the affected industries' total revenues.
Dr. Atkins then remarked that it might be more demonstrative to
compare the control costs and revenues of a single plant rather
than of all affected industries combined.
Ms. Deborah Sheiman asked for the timetable for the IPCT
standard. Mr. Vervaert responded that the IPCT standard is
included in the group of MACT standards to be promulgated within
4 years of enactment of the CAAA. Mr. Mulrine responded that
proposal for the standard currently is scheduled for July 1992.
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Mr. Marinshaw added that promulgation is scheduled for July 1993.
Ms. Sheiman also asked if compliance could be achieved more
quickly if the standard were promulgated under TSCA as was the
CCT rule. Mr. Vervaert responded that EPA currently is
discussing the merits of rulemaking under TSCA versus rulemaking
under the CAAA, but a final decision has not yet been made. The
NAPCTAC presentation was based on the assumption that the IPCT
standard would be promulgated under the CAAA, but EPA has the
option of proceeding under either of these two regulatory
authorities.
Dr. Atkins asked if vendors would be targeted for
enforcement if the rule were to be promulgated under TSCA. Mr.
Vervaert replied that if the rule were promulgated under TSCA,
enforcement would be through vendors as is the case for the CCT
rule. He made the distinction, however, that unlike CCT's, which
are not located at permitted facilities, IPCT's are all located
at facilities that will be permitted under Title V of the CAAA.
In addition, because the number of IPCT's is much smaller than
the number of CCT's, enforcement of the IPCT owners and operators
would be much more manageable than enforcement of CCT owners and
operators would have been. However, the merits of proceeding
under both regulatory authorities would be thoroughly discussed
before a final decision is made.
Mr. Brian Taranto asked if EPA's investigations indicated an
increase in leaks in heat exchangers due to corrosion following
conversion from chromates to nonchromates. Mr. Vervaert
-------
responded that the performance of nonchromate-based water
treatment programs was thoroughly investigated and the data
indicated that there were no adverse effects on the performance
of systems in which nonchromate programs were used.
Following the response to Mr. Taranto's question, Mr. Jordan
opened the floor to questions from the audience. Mr. Bob Ajax of
Ajax and Associates asked if the compliance schedule following
promulgation of the IPCT standard had been set. Mr. Vervaert
replied that the IPCT standard is included among the group of
standards that must be promulgated within 4 years of enactment of
the CAAA and following promulgation, plants will have up to 3
years to comply. However, a compliance schedule has not yet been
set for the standard.
Mr. Jordan next introduced Mr. Chuck Sanderson of Superior
Manufacturing. Mr. Sanderson made a presentation on the use of a
magnetic water conditioner as an alternative to chemical-based
water treatment programs for corrosion control in cooling tower
systems. The text of Mr. Sanderson's presentation is provided as
Attachment 2.
Mr. Jordan then invited the committee to comment or ask
questions about the presentation. However, there was no
discussion of Mr. Sanderson's presentation.
Finally, Ms. Angela Hill of EPA Region IV asked for an
explanation of the derivation of cost effectiveness as mentioned
•7 ~ O
-------
in Mr. Mulrine's presentation. Mr. Mulrine responded that cost
effectiveness is the ratio of control cost to emission reduction
achieved by a particular control measure and is expressed in
units of dollars per unit weight of pollutant removed by the
control measure. There was no further discussion.
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STATUS OF EPA REGULATORY PROGRAM FOR
MEDICAL WASTE INCINERATORS
A. EPA PRESENTATION
Mr. James Eddinger
Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Slide 1. The status of the EPA regulatory development program
for air emissions from medical waste incinerators will be
presented.
Slide 2. Today, I will briefly present background information on
the regulatory program, the industry profile, and the pollutants
being investigated for standards. The presentation will
summarizes our data gathering and technical analyses. Included
will be a discussion of available control techniques, the EPA
test program, the model plant analyses, and the cost of control.
Also presented will be preliminary impacts associated with the
regulatory alternatives reflecting maximum achievable control
technology for both new and existing medical waste incinerators.
Also addressed will be operator training and certification and
the program schedule.
Slide 3. The regulatory program includes the development of
maximum achievable control technology standards for new medical
waste incinerators, and the development of emission guidelines
for existing medical waste incinerators. The program also
include the development of a model State program for the training
and certification of medical waste incinerators operators.
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2
Slide 4. Section 129 of the Clean air Act requires EPA to
develop standards for new medical waste incinerators under both
Sections 129 and 111. The standards will be numerical emissions
standards, but may also include equipment or work practice type
requirements. The standards will be based on the maximum
achievable control technology or MACT. Section 129 states that
the standards for new medical waste incinerators must not be less
stringent than the emissions control achieved in practice by the
best-controlled similar unit. Under Section 129, the EPA may
distinguish among classes, types, and sizes of medical waste
incinerators in developing standards for new units.
Slide 5. Section 129 also requires EPA to develop emission
guidelines for existing medical waste incinerators under Sections
129 and lll(d) of the Clean Air Act. These emission guidelines
may be equal to or less stringent than the MACT standards for new
units, but must not be less stringent than the average emissions
control achieved by the best controlled 12% of units in the
category. States are required to submit a plan to implement and
enforce the guidelines within 1 year after the guidelines are
promulgated. All existing medical waste incinerators are
required to be in compliance within 3 year after the State plan
is approved by EPA but not later than 5 years after the
guidelines are promulgated.
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3
Slide 6. This is a schematic of a typical medical waste
incinerator. It is a multi-chamber design where the medical
waste is charged into the primary chamber either manually or
mechanically by a ram feeder. The waste is burned under
controlled air conditions usually under starved air conditions.
The combustion of the off-gases or volatiles from the waste
combustion is completed in the secondary chamber where additional
air is added to achieve overall excess air conditions.
Additional fuel is added if necessary to achieve higher secondary
chamber temperatures. The exhaust from the secondary chamber
goes to a waste heat boiler for energy recovery, to an air
pollution control device, or directly out the stack.
Slide 7. There are several design or operating types of medical
waste incinerators. The major types are continuous, intermittent
or batch units. Continuous units are capable of operating 24
hours a day because they are designed with continuous ash
removal. Intermittent units typically have an operating cycle of
24 hours or less. These units are charged with waste over a 10
to 14 hour period. The unit must be shut down to remove the ash
that has built up over the day. In batch type units, the
incinerator is charged with a single load of waste, the waste is
combusted and the unit is shutdown to remove the ash.
There are several types of medical waste. Red bag waste is
defined as the infectious portion of medical waste. It is
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4
estimated that 15% of hospital waste is red bag type waste. Red
bag waste tends to have a high plastic content, about 30%.
General medical waste is a combination of red bag waste and
general housekeeping waste. Pathological waste is human and
animal remains and tissues. In our development program, we are
investigating all these incinerators and waste types.
Slide 8. We estimate that there are about 7000 existing medical
waste incinerators in operation. Half of these are located on-
site at hospitals. There are about 150 commercial or regional
medical waste incinerators in operation. The remainder of
medical waste incinerators are located at facilities like:
research laboratories, veterinary facilities, nursing homes, and
crematories.
The average size of a on-site unit is about 300 LB/hr
compared to 1200 Ib/hr for an average size commercial type unit.
The largest on-site medical waste incinerator is about 2500 Ib/hr
or 30 tons per day (tpd). The largest commercial/regional unit
is 8000 Ib/hr or 100 tpd.
We estimate that about 125 new on-site hospital medical
waste incinerators and 15 new commercial units will be built each
year.
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5
We also estimate that over 4 million tons of general medical
waste is incinerated per year. About 700,000 tons of this total
is red bag type waste.
Slide 9. Medical waste incinerators have the potential to emit a
range of pollutants. Section 129 of the Clean Air Act reguires
the EPA to set limits for particulate matter and opacity; the
acid gases: hydrogen chloride and sulfur dioxide; the metals:
lead, cadmium, and mercury; carbon monoxide; nitrogen oxide and
for dioxins and furans. We are investigating these pollutants as
well as additional metals and organics, and also the pathogen
destruction achieved by medical waste incinerators.
Slide 10. The control techniques being investigated are
combustion controls, add-on control devices, and combinations of
combustion controls and add-on controls. Combustion controls
generally refers to the secondary chamber temperature, the
secondary chamber residence time, and the waste charging
procedures. The add-on controls being investigated are wet
scrubbers, fabric filter followed by a packed bed systems, dry
injection/fabric filter systems, and spray dryer / fabric filter
system.
Slide 11. A key activity in this regulatory development has been
an extensive testing program. The purpose of the EPA test
program was to define baseline emission levels, the performance
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6
of combustion controls, the performance of the various add-on
controls, and the performance of the combinations of combustion
controls and add-on controls.
Slide 12. This slide list the MWI's tested in the EPA test
program. Seven medical waste incinerators were selected for
testing. To date, 6 of the 7 have been tested. The 7th unit is
being tested this week. The 7 units selected cover the range of
incinerator types, combustion controls, and add-on controls
existing in the industry- We have tested, or are testing, batch,
intermittent, and continuous units; controlled air and rotary
kiln type incinerators; units firing 100% general, red bag, or
pathological waste. The units range in size from 250 to 1200
Ib/hr. The units have secondary chamber residence times ranging
from 0.15 to 2 seconds. The units range in age from newer units
with 1 to 2 second residence time to units that are about 10
years old having less than 1 second residence times. To date, we
have tested a dry injection/fabric filter system, a venturi/
packed bed system, a fabric filter/packed bed system, and 3
medical waste incinerators with no add-on controls. We are
currently testing a rotary type unit with a spray dryer/fabric
filter system. In addition, 1 of the units (Facility A) was
retested with carbon injection, in addition to the lime
injection, to determine the effect of carbon injection on
controlling mercury and dioxin emissions. The carbon content of
the fly ash is felt to be important in controlling emissions of
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7
dioxins and mercury. Not all the results of this retest are yet
available.
Slide 13. Presented here are the preliminary performance levels
that reflect the typical performance of the control techniques
tested during the EPA test program. All values are corrected to
7% oxygen. Baseline here is for newer units and is define as a
unit having no add-on control device and having a secondary
chamber with 1 second residence time operating at 1700F.
Combustion controls is defined as a secondary chamber with 2
second residence time and operating at a minimum temperature of
1800F. As can be seen, combustion controls have no effect on
metals or acid gases emissions. Combustion controls by
themselves are capable of reducing baseline emissions of dioxins
and CO by 90% to 95%. Venturi/packed bed systems can reduced PM
and metal emissions by 50%, achieves little control of mercury
emissions, can reduced HCL by 95% and can reduce dioxins
emissions by an additional 70% over that achieve by combustion
control alone. Dry injection / fabric filter system can achieve
the greatest reduction in PM emissions, down to 0.01 grain per
dry standard cubic feet (gr/dscf), and can reduce metal emissions
by 99%. It can also achieve 95% control of HC1 emissions. In
terms of mercury and dioxins emissions, these performance levels
for the dry injection system reflect the levels achievable with
the addition of carbon injection to the normal lime injection
system. When the unit was tested with lime injection only, the
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8
system achieved no control of mercury or dioxin emissions. As. I
said before, carbon content of the fly ash is felt to be
important in the control of dioxins and mercury emissions. With
carbon injection, we achieved greater than 80% control of mercury
emissions. We do not yet have the dioxins results from our
carbon injection tests to verify the dioxin level indicated here.
This level for dioxins is assumed achievable with carbon
injection based on test results on municipal waste units and
medical waste incinerators in Europe.
Slide 14. This slide shows the effect of the secondary chamber
residence time and temperature on dioxin emissions. What is
plotted here is dioxins emissions results, out of the
incinerator, versus secondary chamber residence time for 3 units
having different gas residence times but operating at similar
secondary chamber temperatures. The solid line shows the effect
of residence time on dioxin emissions at a secondary chamber
temperature of 1650F. The dotted line shows the effect at 1850F.
As can be seen, in both cases dioxin emissions decreases as
residence time increase for a given temperature. For example, at
1850F, dioxin emissions decreased from about 7000 nanograms per
dry standard cubic meter (ng/dscm) at 0.35 second residence time
to 2400 ng/dscm at 1 second, and down to 450 ng/dscm at close to
2 second gas residence time. The effectiveness of gas residence
time is greater at lower temperatures. The effect of secondary
chamber temperature can also be seen here. At a residence time
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9
of 1 second, dioxins emissions decreased from about 5000 ng/dscm
at a secondary chamber temperature of about 1650F to 2400 ng/dscm
when the unit was operated at 185OF in the secondary chamber.
The effectiveness of increased secondary chamber temperatures
decreases at higher gas residence times. These trends are also
the same for PM and CO emissions.
Slide 15. One objective of the test program was to develop a
test method for determining pathogen destruction. In our test
program, we did not sample for actual pathogens, but a known
guantity of a heat resistent indicator spore was spiked/added to
the waste as a surrogate in determining pathogen destruction.
Both the stack gas and incinerator ash were sampled for these
indicator spores. Based on the number of spores detected in the
stack and the ash, the overall spore destruction efficiency
achieved was greater than 99% for all the units tested with
generally greater than 99.99% destruction efficiency being
achieved. If you look at just the stack results, all units were
99.99% efficient in controlling the spores out the stack.
Slide 16. The model plant analysis included the selection of 8
different model combustors to represent the typical types and
sizes of new and existing medical waste incinerators. For the
purpose of the analysis, the 8 model combustors were grouped into
3 size categories. These being: small, medium, and large. Small
being units about 200 Ib/hr and less in capacity- Large units
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10
being about 1000 Ib/hr and greater. Three control options were
selected for analysis. The first is good combustion control
which includes proper design, operation, and maintenance of the
incinerator to minimize emissions. Good combustion control is
define as including a minimum secondary chamber temperature of
1800F and a secondary chamber residence time of 2 seconds. For
the analysis, this control option is labelled as GOOD emission
control. The second control option is wet scrubbing in
combination with good combustion control. The venturi/packed bed
system was selected to represent this control option since it is
the typical wet scrubbing system used in the industry. This
control option is referred to as BETTER emission control. The
third control option is dry injection/fabric filter system in
combination with good combustion control. This control option is
referred to as BEST emission control and also includes fabric
filter/packed bed and spray dryer/fabric filter systems.
Combining the 8 model combustors and the 3 control options result
in 24 model plants. These model plants have been analyzed in
terms of emission reductions, costs of control, environmental
impact, economic impacts and over various regulatory
alternatives.
Slide 17. As stated before, Section 129 of the CAA requires that
standards for new medical waste incinerators must not be less
stringent than the level of emission control achieved in practice
by the best controlled similar unit. This is referred to as
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11
MACT. MACT for new medical waste incinerators firing mixed
medical waste appears to be equal to the BEST emission control
for all size categories. The basis for this is that BEST emission
control is installed on an medical waste incinerator in all size
categories. For example, there is a small batch unit installed
with a fabric filter / packed bed system which is included in our
definition of BEST emission control. The national total annual
cost of applying MACT to new units is estimated at about $94
million or would increase the average cost of operation by $204
per ton of waste burned.
As for pathological or crematories type incinerators, no
decision has been reached on what appears to be MACT for these
units.
Slide 18. The national emission impacts of apply MACT to new
units are presented here. Again, baseline is a unit with no add-
on controls and having a secondary chamber with 1 second
residence and operating at 1700F. Emission reductions range from
50 Ib/year for dioxins emissions to about 10,000 tons/year for
HC1 emissions or from 50% control for SO2 emissions to 99.5%
reduction for dioxin emissions.
Slide 19. For existing units, Section 129 requires that the
emission guidelines must not be less stringent than the level of
emission control achieved in practice by the best controlled 12%
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12
of existing units. This is referred to as the MACT floor. To
determine the MACT floor, Section 129 allows for grouping similar
units into subcategories. The MACT floor for existing medical
waste incinerators burning mixed medical waste appears to be BEST
emission control for large units and baseline emission control
for small and medium units. Baseline control for existing small
and medium units is define as no add-on control and a secondary
chamber with a quarter second residence time operating at 1700F.
The basis for the MACT floor is that more than 12% of existing
large units operate BEST emission control systems. The national
costs of control of applying the MACT floor to existing units is
estimated at $117 million of would increase the average cost by
$73 per ton of waste burned. Various regulatory alternatives are
being investigated that are more stringent than the MACT floor.
For example, to apply BEST emission control to all existing
medical waste incinerators, the total annual cost would be $528
million or an increase of $327 per ton of waste burned.
As for existing pathological or crematories type
incinerators, no decision has been reached on what appears to be
the MACT floor for these units.
Slide 20. The national emission impacts of applying the MACT
floor to existing units are shown here. Emissions reductions
would range from about 200 Ib/year of dioxin emissions to 21,000
-------
13
tons per year of HC1 emissions or about 50% reduction over
baseline emission levels for all pollutants.
If BEST emission control was applied to all existing units,
the emission reductions would be double that achieved by the MACT
floor.
Slide 21. The goal of the economic impact analysis is to
determine the industry-wide and per-facility impacts associated
with the regulation. For existing medical waste incinerators,
the impact analysis indicated that on an industry-wide basis the
impacts are not substantial due to insignificant price increases.
This is partly because, in terms of the hospital industry, half
of the existing hospital do not have incinerators and therefore
would not be impacted. On a per facility basis, there would be
some significant impacts under BETTER or BEST emission control,
generally for the smaller units. The impacts can be avoided by
switching to alternatives disposal methods( such as autoclaving
or off-site contract disposal). Also many facilities may
substitute to minimize costs with small medical waste incinerator
facility the most likely to switch. In summary, the overall
economic impacts are generally not significant due to the
availability and cost effectiveness of substitutes, such as
contract disposal or autoclaving. However, crematories can not
substitute, but should be able to increase price to recover costs
under the GOOD control option.
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14
Slide 22. Section 129 requires the EPA to develop and promote a
model State Program for the training and certification of
operators of medical waste incinerators. This would apply to
both new and existing units. In 1989, the EPA developed a basic
operator training course and materials. It was intended as
general guidance on the proper operation and maintenance to
minimize emissions. The training materials were forwarded to the
States in May 1989 for their use. We are currently working with
the ASME in their development of a certification program and
requirements for operators of medical waste incinerators. We are
also currently updating and revising the EPA-developed training
materials to incorporate both new information and the necessary
information that will be required by the ASME certification
requirements.
Slide 23. Finally, the schedule we are working under for this
program calls for completing the test program in December 1991.
The EPA internal review would occur January 1992 to September
1992. Proposal of the MACT standard for new units and the
emission guidelines for existing medical waste incinerators would
be in January 1993. Promulgation of the final standards and
guidelines would be in May 1994.
-------
STATUS OF EPA REGULATORY PROGRAM
FOR
MEDICAL WASTE INCINERATORS
November 20, 1991
-------
INTRODUCTION
BACKGROUND
Regulatory program
Industry profile
Pollutants
DATA GATHERING AND TECHNICAL ANALYSES
Control techniques
MWI test program
Model plant analyses
Control costs
PRELIMINARY MACT AND PRELIMINARY IMPACTS
OTHER SUBJECTS
Operator training and certification
Schedule
-------
REGULATORY PROGRAM
Maximum Achievable Control Technology
(MACT) Standards for New MWI's
Emission Guidelines for Existing MWI's
Develop and promote a model State program for
training and certification of MWI operators
-------
MACT -- NEW SOURCES
• Sections 129 and 111 of Clean Air Act
• Emission Standards
• Based on Maximum Achievable Control
Technology (MACT)
• Not Less Stringent Than Best Controlled Similar Unit
• May Distinguish Among Classes, Types, and Sizes
of MWI's
-------
EMISSIONS GUIDELINES
Sections 129 and 111 (d) of Clean Air Act
Apply to Existing Sources
May Be Equal To or Less Stringent Than MACT for
New Sources
Not Less Stringent Than Average Emissions
Achieved by Best Performing 12% in Category
States Required to Submit Plans to EPA Within 1
Year After Promulgation
All Units in Compliance 3 Years After State Plan
Approved but Not Later Than 5 Years After EPA
Promulgation
-------
BACKGROUND INFORMATION
Blower
Burner
Ram Feeder
Waste Feed
To Stack
To APCD
To Boiler
Secondary Chamber
Blower
Air
Fuel
— Burner
Primary Chamber
Medical Waste Incinerator
-------
BACKGROUND INFORMATION
MWI DESIGN TYPES
Continuous -- Operate 24 Hours/Day
— Continuous Ash Removal
Intermittent -- Charge Waste 10 to 14 Hours/Day
— Shutdown to Remove Ash
Batch -- 1 Waste Charge Per Day
— Shutdown to Remove Ash
WASTE TYPES
Red Bag - "Infectious waste" or Regulated Medical Waste
- High Plastics Content
General -- Red Bag + General Housekeeping Waste
Pathological -- Human and Animal Remains and Tissues
-------
INDUSTRY PROFILE
Estimated 7,000 Existing MWI's
-- Half on-site at hospitals
- 150 commercial/regional units
— Remainder located at: laboratories
veterinary facilities
nursing homes
crematories
SIZE: Average = 300 Ib/hr for on-site
= 1,200 Ib/hr for commercial
Largest = 2,500 Ib/hr for on-site
= 8,000 Ib/hr for commercial
Estimated 125 New On-Site MWI's and 15 New
Commercial MWI's Per Year
Estimated Over 4 Million Tons of Medical Waste
Incinerated Per Year
-------
MWI EMISSIONS
Particulate Matter
Acid Gases
-- Hydrogen chloride *
Metals
-- Lead *
-- Cadmium
Carbon Monoxide
Nitrogen Oxides *
Organics
-- Dioxins / Furans *
Pathogens
— Sulfur dioxide
-- Mercury
Section 129 Requires Standards for these Pollutants
-------
CONTROL TECHNIQUES
Combustion Controls
— Secondary chamber temperature
•• Secondary chamber residence time
-- Waste charging procedures
Add-On Controls
-- Wet Scrubber
— Fabric filter / packed bed
-- Dry injection / fabric filter
-- Spray dryer / fabric filter
Combinations of combustion controls and add-on
controls
-------
TEST PROGRAM
TO DEFINE:
Baseline Emission Levels
Performance of Combustion Controls
Performance of Add-On Controls
Performance of Combustion Controls
+ Add-On Controls
-------
TEST PROGRAM
FACILITY
A
B
J
K
S
W
M*
A**
DUTY
CYCLE
Intermittent
Continuous
Batch
Intermittent
Intermittent
Intermittent
Continuous
(Rotary)
Intermittent
WASTE
TYPE
General/
Red Bag
General
Red Bag
General
Pathological
General
General
General
DESIGN
CAPACITY
(Ib/hr)
680
1200
750
(Ib/batch)
320
250
320
1000
680
SECONDARY
CHAMBER
RESIDENCE
TIME (SEC).
1.75
2
2
0.35
0.15
1
2
1.75
APCD
Lime Injection/
Fabric Filter
Venturi/
Packed Bed
Fabric Filter/
Packed Bed
None
None
None
Spray Dryer/
Fabric Filter
Lime Injection/
Fabric Filter
= Not yet tested
= Facility retested with carbon injection
-------
PRELIMINARY PERFORMANCE LEVELS
POLLUTANT
PM (gr/dscf)
Lead
Cadmium
Mercury
HCI
SO2
Dioxins/Furans
(ng/dscm)
CO (ppm)
BASELINE
0.016
4100
ug/dscm
300
ug/dscm
3100
ug/dscm
1460 PPM
15 PPM
4500
300
COMBUSTION
CONTROLS
0.10
0%
0%
0%
0%
0%
440
15
VS / PB *
0.05
50%
40%
15%
95%
50%
130
15
Dl / FF *
0.01
99%
99%
80%
95%
50%
-100
15
Includes Combustion Control
-------
14
EFFECTS OF RESIDENCE TIME AND TEMPERATURE
ON DIOXIN EMISSIONS
C\|
O
o
CO
CO
c
4 —
X
o
40000
30000 r
20000 r
10000 ~-
0
Sec, Temp, - 1 650F
- Sec, Temp, = 1850F
0,35
1,75
Residence Time (sec,)
-------
INDICATOR SPORE RESULTS
FACILITY
NUMBER OF INDICATOR
SPORES
STACK
ASH
SPORE
DESTRUCTION
B
K
W
ND
2.2E + 04
LIE + 05
> 4.2E + 06
ND
<3.1E + 08
ND
NT
> 3.3E + 07
ND
< 1.2E + 06
< 9.3 E + 09
> 99.9999
< 99.9999
< 99.998
< 99.9999
> 99.9999
>99.4
ND: Not detected
NT: Not tested
-------
MODEL PLANT ANALYSES
8 MODEL COMBUSTORS
3 SIZE CATEGORIES
3 CONTROL OPTIONS
-- Good Combustion Control (GOOD)
— Minimum 1800F at 2 sec. residence time
-- VS / PB + GCC (BETTER)
-- Dl / FF + GCC (BEST)
24 MODEL PLANTS
ANALYSES PERFORMED
— Emission Reductions
— Cost of Control
— Environmental Impacts
-- Economic Impacts
-- Regulatory Alternatives
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MACT
(New — Mixed Medical Waste)
• Authority -- Section 129: MACT Not Less Stringent
Than That Achieved by Best Controlled Similar Unit
• MACT = BEST CONTROL (i.e. Dl / FF + GCC)
• For All Size Categories
• Basis: BEST Control Installed on All Size Categories
-- FF / PB Installed on Small Batch MWI
• National Costs of Control
- Total Annual Cost = $94 Million
-- Average Increased = $204/Ton of Waste Burned
-------
NATIONAL EMISSION REDUCTIONS
(New MWI's - Mixed Medical Waste)
POLLUTANT
CDD/CDF
CO
HCL
SO2
PM
LEAD
CADMIUM
MERCURY
BASELINE
(tpy)
0.024
1,700
10,500
200
1,740
20
1.4
15
MACT
Emission Reduction
(tpy)
0.023
1,600
9,900
100
1,600
19.8
1.39
12
% Reduction
99.5
95
95
50
94
99
99
60
-------
MACT FLOOR
(Existing MWI's -- Mixed Medical Waste)
• AUTHORITY -- Section 129: MACT Not Less Stringent Than
Average Emissions Achieved By Best Performing
12% in Category
• MACT FLOOR = BEST CONTROL FOR LARGE UNITS
= BASELINE FOR SMALL & MEDIUM UNITS
• Basis: Over 12% of Large Units Have BEST Control
• National Costs of Control
-- Total Annual Cost = $117 Million
-- Average Increased = $73/Ton Waste Burned
• To Apply BEST Control Across All Sizes
- Total Annual Costs = $528 Million
-- Increased Cost - $327/Ton Waste
-------
NATIONAL EMISSION REDUCTIONS
(Existing MWI's - Mixed Medical Waste)
Pollutant
CDD/CDF
CO
HCL
SO2
PM
Lead
Cadmium
Mercury
Baseline
(TPY)
0.3
13,300
42,000
800
1 1 ,400
80
6
60
MACT FLOOR
Emission
(tpy)
0.11
5,600
21,000
200
5,000
41
3
24
Reductions
(%)
39
42
50
26
44
51
52
42
BEST CONTROL
Emission
(tpy)
0.29
13,000
40,000
400
1 1 ,000
78
5.5
57
Reductions
(%)
99.8
97
95
50
96
99
99
80
-------
ECONOMIC IMPACT ANALYSIS
GOAL
- Determine Industry-Wide and Per-Facility Impacts
RESULTS - EXISTING MWIs
- Industry-Wide Impacts
- Impacts not substantial due to insignificant price increases
- Per-Facility Impacts
- Some significant impacts under BETTER and BEST Control Options
- Impacts can be avoided by substitution
- Many facilities may substitute to minimize costs
- Small MWIs most likely to switch
-------
ECONOMIC IMPACT ANALYSIS
SUMMARY
- Impacts not significant due to availability and
cost effectiveness of substitutes
- Crematories can not substitute, but can
increase prices to recover costs under GOOD
control options
-------
OPERATOR TRAINING AND CERTIFICATION
Authority -- Section 129 Requires EPA to Develop and
Promote a Model State Program
New and Existing MWI's
Developed Basic Course and Materials (1989)
- General Guidance on Proper Operation and Maintenance to
Minimize Air Emissions
Forward to States - May 1989
ASME Certification Program
Currently Updating Training Materials to Incorporate
New Information and Necessary Information Required
by ASME Certification Requirements
-------
FUTURE MILESTONES
Test Program Completed - December 1991
Internal EPA Review - Jan. 1992 - Sept. 1992
Proposal - January 1993
Promulgation - May 1994
-------
CREMATION ASSOCIATION
OF NORTH AMERICA
MEMORANDUM TO
NATIONAL AIR POLLUTION
TECHNIQUES ADVISORY COMMITTEE
SUBMITTED ON NOVEMBER 19, 1991
-------
'OHN SCOTT HOFF, R C.
IL, IA, NE, CA, Wl & DC
HARVEY I. LAPIN, P.C.
IL, FL & Wl
STEVEN L. SLAW, P. C., IL & IN
JAMES T. LAFFEY, P. C., IL
MICHAEL D. SIMMONS, IL.
BRANDT R. MADSEN, IL & Ml
TAMARA L.WARN, IL.
LAW OFFICES OF
LAPIN, HOFF, SLAW & LAFFEY
A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS
278O HARRIS BANK BUILDING
115 SOUTH LA SALLE STREET
CHICAGO, ILLINOIS eOGO3
(312) 346-Bill
FAX (312) 853-3924
November 18, 1991
OF COUNSEL
SHALE P. LAPPING, P.C., ,L,MI
JAMES C.SPANGLER
II & Wl
ERWIN H. GREENBERG
IL & Wl
ROBERT T. HOFF
IA & RES. IN D.C.
WASHINGTON OFFICE
I7OO KENYON, N.W.
WASHINGTON, D.C. 2OOIO
TELEPHONE
(2O2) 26S-8699
National Air Pollution Techniques
Advisory Committee
c/o United States Environmental Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
Dear Chairperson Jordan and Committee Members:
This memorandum is being submitted concurrently with the oral
presentation to be made to the Committee on November 19, 20, and 21 at
the Sheraton Inn University Center, Durham, North Carolina on the topic of
Medical Waste Incinerators. Our firm is the General Counsel to the
Cremation Association of North America ("CANA") and this memorandum is
being submitted on their behalf.
CANA is an international trade association which represents the
cremation industry. Its has 654 members consisting of 546 crematory
owners and operators and 108 associate members consisting of those who
for various reasons have an interest in the cremation area and 82 supplier
members. Some of CANA's members own and operate more than one
facility, so that CANA's membership encompasses more Crematory
Chambers than 546.
CANA is considered to be the spokesman for the Cremation industry
and is presently participating in that role in the Review of the Funeral
Practices Trade Regulation Rule by the Federal Trade Commission. CANA
is the primary source of statistical information on the number of
cremations by location and has been assembling and publishing that
information on an annual basis since the early 1900's. A copy of the
current annual report and a forecast analysis of cremations up to the year
2010 is attached hereto for your information.
The purpose of CANA's participation in these proceedings is to
280
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provide information to the Committee and to present recommendations for
the treatment of Crematories in the upcoming regulations to be issued by
the EPA in July of 1992 and to respond to the initial recommendations of
the EPA as presented in the seven Draft Reports on the subject of Medical
Waste Incinerators issued on September 30, 1991 ("Draft Reports"). Mr.
Edward Laux, Chairperson of the CANA Environmental Subcommittee and
Immediate Past President of CANA, Paul Rahill of Industrial Equipment
and Engineering Company, technical advisor to the Subcommittee and
Harvey I. Lapin, General Counsel to CANA, will be making the oral
presentation at the Committee Hearings and will be available to respond
to questions. Prior to covering the background of the Cremation Industry,
CANA feels it would be helpful to summarize the information and
recommendations about the Cremation Industry contained in the Draft
Reports.
EPA DRAFT REPORTS REVIEW
CANA has reviewed the Draft Reports issued by the various members
of the EPA staff and in this section of this Memorandum is summarizing
what it believes is the EPA's proposal on Crematory Chambers, which are
referred to as batch pathological units by the EPA Staff. This section of
the Memorandum covers both EPA's factual basis for Crematories and
EPA's Conclusions and Recommendations. The following EPA findings and
recommendations made in the Draft Reports apply to Crematory Chambers:
1. The proposed EPA definition of "medical waste" includes "human
remains."
2. Crematories are classed with Funeral Homes and the annual medical
waste generated for both is estimated to be 138,000 tons. It would
appear that most of that tonnage relates to Funeral Homes rather than
Crematories.
3. It is estimated that there are 1200 Cremation Retorts in
Crematories/Funeral Homes. The EPA reports refer to all incinerators
covered in the Draft Reports as Medical Waste Incinerators ("MWI").
4. It is believed by the EPA that Crematories/Funeral Homes are the
second largest category of MWI's by number that exist.
5. The primary waste incinerated by Crematories/Funeral Homes is
Pathological Waste (e.g., human and animal remains, body parts and
tissues). Pathological wastes have a very high moisture content and will
281
CANA-EPA 2 November 17, 1991
-------
not support self-sustained combustion but will burn if adequate heat is
applied to drive off the moisture.
6. Crematories/Funeral Homes use batch feed units which are the
smallest MWI's in terms of waste burning capacity and are generally in the
range of 250 to 500 Ib/d capacity.
7 Because of the difference 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 pathological waste,
resulting in higher emissions of metals and HCI from mixed medical
incinerators than pathological incinerators and because of these
differences, pathological and mixed medical incinerators are considered
two distinct subcateqories for the purpose of regulatory development.
8. It is estimated that 200 new pathological MWI's with 98% being of the
batch type will be installed over the next 5 years. This estimate is based
on the growth in the use of cremation for the final disposition of human
remains.
9 The existing population of pathological units totals about 2450 and is
comprised of approximately 50 percent batch and 50 percent intermittent-
duty units. Two of the eight model combustors selected to represent new
and existing MWI facilities are pathological units consisting of one batch
and one intermittent-duty models.
10. According to the EPA reports, there are basically two approaches to
controlling emissions from MWI's: good combustion control and emission
control using add-on air pollution controls. Based on these approaches
combustion and emission control has been divided in to the category's of
Good, Better and Best. Good combustion control includes the proper design
construction, operation and maintenance of an MWI to destroy or prevent
the formation of certain types of emissions before their release to the
atmosphere. Good combustion control includes a minimum secondary
chamber temperature of 1800 degrees F and a minimum secondary chamber
residence time of 2 seconds. Add-on air pollution controls consist of
various types of scrubbing equipment to control emissions. Better
emission control results from addition of wet scrubbing systems to good
combustion control systems. Best emission controls consist of good
combustion control with new technology consisting of either a fabric
filter alone or with a upstream activated carbon injection followed by a
packed-bed absorber or a dry sorbent and activated carbon injection
system followed by a fabric filter. The EPA, as of the issuance of the
Draft Reports has not determined the best systems for the Best category.
282
CANA-EPA 3 November 17, 1991
-------
11. The EPA has proposed that three regulatory alternatives for existing
pathological waste incinerators (Crematory Chambers) consisting of
requiring compliance with Good, Better and Best emissions controls. Table
5-6 in the September 30, 1991 draft of Medical Waste Incinerators-
Background Paper for New and Existing Facilities, indicates that the
capital cost for a batch pathological unit to add Good Control Options
would be $18,900, to add Better Control Options would be $156,900 and to
add Best Control Options, $462,900. The estimated annual cost for a batch
pathological unit for Good Control Options would be $4030, for Better
Control Options would be $32,830 and for Best Control Options $93,030.
Regulatory requirement for new units has not been proposed at this point.
It would appear that the improvement in emissions for MWI's burning
Pathological Waste would be insignificant under the Good requirement, a
little better under the Better and possibly significant under the Best
Requirement. (See Tables 5-5 in the Background Paper for New and
Existing Facilities, page 20)
12. The EPA, based on partial information published by CANA and believed
to have been submitted by another source, has determined that there are
954 crematory businesses of which 400 are stand-alones and 554 are
combined with funeral homes. It has determined from information
provided to it by the National Funeral Directors Association ("NFDA"),that
the average revenue of crematory businesses based on an average of 348
Cremations a year is $500 per cremation. The EPA also determined the
average crematory has 5.3 employees, with an annual revenue of $174,000,
a before tax profit margin of 11.4%, an after tax profit margin of 8%,
before tax income of $19, 886, after tax income of $13,920, assets of
$135,372 and a net worth of $73,507 (p. 27 and Table 4B at p. 14, Medical
Waste Incinerators-Background Information for Proposed Standards and
Guidelines: Analysis of Economic Impacts for Existing Sources).
("Economic Report")
13. The EPA recognizes that if the cost of making these changes for other
MWI's was too high they could switch their disposal methods to less
costly off site MWI's. The EPA determined, however, that Crematories,
which handle human remains, have no alternative to on site incineration
and the only other means of disposal is burial, which means there will be
no Cremation at all. It is stated in the Economic Report that: "A key aim
of the economic impacts analysis is to determine the ability of the
regulated establishments to pass along control costs to their customers
by increasing prices. The extent to which this is possible without an
attendant decline in output depends greatly on price elasticity of demand."
CANA-EPA '' ^4 November 17, 1991
-------
(Economic Report, page 36) The EPA then determined that the price
elasticity of demand for Crematories is highly inelastic because there is
no lower cost substitute and death disposal is an absolute necessity.
(Economic Report, page 40, table 7) It was also determined that
Crematories do not generate medical waste that is incinerated offsite and
therefore have no share of the commercial incineration cost pool.
(Economic Report, page 48) It was estimated that in order to achieve
Good Cost Controls it would be necessary for Crematories to increase
their prices by 6.571% but this be readily achievable because: "Due to the
huge cost advantage of a cremation over a funeral (approximately $500
versus $3,000), respectively), Crematories face very little competition.
Consequently, the 6.6 percent market price increase under Control Option
1 is considered achievable." (Economic Report, page 52) Table 11 of the
Economic Report deals with Impacts of the Market Price Increase on
Industry Wide Output and Crematories, based on the EPA figure, would
have the biggest impact to which the EPA responded: "In the case of the
maximum elasticity under Control Option 1, output at Crematories would
decline by 2.078 percent. This is not likely to involve a reorganization of
the U.S. Crematory industry, though. This is because like many of the
other regulated industries, the U.S. crematory industry is highly
fragmented. (Economic Report, page 56) The EPA state further:
"Crematories should be able to achieve the maximum price increase under
Control Option 1 because, as discussed in Section 3.4.3, the industry is
insulated from competition. In addition all Crematories operate an MWI
(by definition), so there is not competition within the industry from
offsite generators. The maximum price increase for Crematories under
Control Option 1 (6.97%) is slightly higher that the market price increase
(6.57%) because no commercial incineration cost sharing is assumed.
(Economic Report, page 67)
14. The EPA then determined in Table 15B that Crematories would
experience a 60.95% decrease in net income if there was no price
increase, but commented that this was no problem because they will be
able to readily achieve the maximum price increase. (Economic Report,
pages 69 and 70) The EPA then analysis capital costs to determine
whether it would be necessary for an entity to finance the cost for the
new controls and in their analysis indicated that if the ratio of capital
costs to total liabilities exceeds 20% external financing would be
difficult to obtain. They found that the ratio for Crematories was 96.90
percent, but nevertheless they concluded this was not problem because
Crematories could make the maximum price jncreases, thus generating
284
CANA-EPA 5 November 17, 1991
-------
additional cash flow to pay for the cost of debt. It was stated that the
capital markets should recognize this and permit an almost doubling of
the average Crematories total liabilities. (Economic Report, pages 78 and
79)
15. Finally in the Economic Report, the EPA complies with the Regulatory
Flexibility Act of 1980 and considers whether the emission guidelines
will have a significant effect on a substantial number of small entities.
It analyzed the criteria and stated that four criteria would apply to
determine if the EPA Guidelines would have a significant impact on a
small entity. (Economic Report, page 90) These Criteria were as follows:
(a) Annual compliance costs increase total costs of production by more
than 5%.
(b) Compliance costs (annualized, presumably) as a percent of sales are at
least 10 percent higher than for larger entities.
(c) Capital costs of compliance represent a significant portion of capital
available.
(d) The requirements of the regulation are likely to result in closures.
While applying the criteria to the various types of MWI's the EPA
recognized that Criteria (a) and (c) were problems for Crematories, but
because of Crematories ability to increase prices none of the Criteria
would be a problem and as a result there were no significant impact on a
substantial number of small entities. (Economic Report, page 92)
The remainder of this memorandum will cover the following topics:
1. Cremation Industry Information, Practices and Procedures, and
2. CANA's Recommendations
Cremation Industry Information, Practices and Procedures
The Cremation Industry is very small and most of the businesses are
family owned and operated. According to CANA's records there are only
954 crematory businesses in operation in the United States. The first
Crematory in the United States was constructed in Pennsylvania in the
late 1800's and in the early part of the 1900's the practice of cremation
increased at a very slow but steady rate. In recent years cremation has
increased, particularly on the west coast. There are various reasons for
2J|5
CANA-EPA **£u November 18, 1991
-------
this increase, including of course low cost and because it is perceived by
consumers to be cleaner and less harmful to the environment. Another
major factor has been the recent interest in the whole subject of funerals
and cost generated from the FTC proceedings on the Funeral Practices
Trade Regulation Rule over the last 15 years.
Cremation services in the cremation industry means the services
performed in actually cremating the body in the retort. Funeral Homes, on
the other hand, often refer to cremation services as the total of all
funeral services required in connection with a cremation of the body
including the picking up of the body, preparing it for a service and related
areas. A Funeral Home will usually have several options for those who
select cremation. One is to have a traditional funeral service, using a
casket with viewing and a service and then instead of going to the
cemetery the casket and body will be taken to the crematory for
cremation. Another is to have a direct cremation where all the Funeral
Home does is pick up the body, prepare it on a minimum basis, place it in a
cremation container and deliver the container to the crematory. There are
variations of these two methods, such as having the cremation first and
then having a memorial service or some religions require that the service
be at the crematory and the mourners participate in starting the
cremation equipment. In this memorandum cremation services means only
that service performed by a crematory in actually cremating the body.
Traditionally in the cremation industry most Crematories are providing
cremation services as an outside service company to funeral homes and
sometimes cemeteries, who have been contacted by consumers for these
services or the other services related thereto. Crematories as a result
only receive a small part of the proceeds which may be involved in a full
cremation service contracted for with a funeral home.
Attached hereto is a copy of the relevant portions from a survey
prepared by CANA's outside management company Smith Bucklin and
Associates in 1988 for submission to the Federal Trade Commission in
connection with the review of the Funeral Practices Trade Regulations
Rule which illustrates the nature of the industry. This Survey will be
referred to as the FTC Survey in the remainder of this memorandum.
The FTC Survey illustrates the following facts:
1. 34.7% of the Crematories are located in the West, 22.8% in the South,
25.5% in the Mid West and 13.4% in the Northeast. (FTC Survey, table 2)
33.1% of the Crematories are located on the premises of or operated in
conjunction with a funeral home, 32% are located on the premises of or
operated in conjunction with a cemetery or columbarium, and 16.4% are
CANA-EPA 7 November 17, 1991
-------
located in or operated in conjunction with a combination funeral home
cemetery operation and 9.9% are free standing. (FTC Survey, table 3)
2. 64.5% of the Crematories do not deal directly with the public and
34.4% do deal directly with the public. (FTC Survey, table 4)
3. In 1987, 5.6% of the Crematories performed 50 or less cremations,
11.3% performed 51 to 100 cremations, 37.6% performed 101 to 250
cremations, 23.9% performed 251 to 500 cremations, 13.2% performed
501 to 1000 cremations and 6.5% performed over 1000 cremations. (FTC
Survey, table 6)
4. 9.9% of the Crematories have no competition, 40.6% have 1-2
competitors, 34.1% have 3-5 competitors and the remaining 15.4% have
from 6 to over 20 competitors. (FTC Survey, table 7)
5. 43.3% of the Crematories receive 100% of their cremation business
from funeral directors, 13.1% receive 75% to 99% from funeral directors,
7.8% receive 51 to 75% of their cremation business from funeral
directors, 5.6% receive 26 to 50% of their cremation business from
funeral directors, 14.2% receive 1 to 25% of their cremation business
from funeral directors and 15.9% receive none of their cremation business
from funeral directors. (FTC Survey, table 8)
6. 7.8% of the Crematories in 1987 did not cremate any traditional
caskets along with the body, 77.4% of the Crematories in 1987 only had
caskets to cremate along with the body in 25% of the cremations handled,
10.0% of the Crematories in 1987 only had caskets to cremate along with
the body in 26% to 50% of the cremations handled, 3.3% of the Crematories
in 1987 only had caskets to cremate along with the body in 51% to 75% of
the cremations handled, 3.3% of the Crematories in 1987 only had caskets
to cremate along with the body in 51% to 75% of the cremations
handled,1.1% of the Crematories in 1987 only had caskets to cremate
along with the body in 76% to 99% of the cremations handled and .3% of
the Crematories in 1987 only had caskets to cremate along with the body
in 100% of the cremations handled. (FTC Survey, table 12) In all other
cases the crematory either used the majority of the time an alternative
container, usually a corrigated cardboard container or in some instances
no container. (FTC Survey, tables 13 and 14)
A great deal of the information that is contained in the Draft
Reports on MWI's issued on September 30, 1991 is incomplete or
inaccurate. Attached hereto is a copy of a Survey of CANA Members
recently taken on a confidential basis by the statistical department of
Smith, Bucklin, Inc., CANA's outside management company and referred to
287
CANA-EPA 8 November 17, 1991
-------
as the Telephone Survey. The Telephone Survey illustrates the following
additional information about the Cremation Industry:
1. The average price charged for cremation services is $150 in most
areas of the country, not the $500 figure on which EPA based its economic
projections.
2. Most Crematory Chambers do less than 400 cremations per year. See
item 3 above under the FTC Survey, which reflects that about 55% of the
Crematories do less than 250 cremation services per year.
3. 88.7% of the Crematories responding to the survey performed
cremations for others in funeral service.
4. 56.4% of the Crematories only had one Cremation Chamber.
5. 49.7% of the Crematories owned Cremation Chambers which were 11
years or older and 33.8% of the Crematories owned Cremation Chambers in
the 6 to 11 year age range.
6. 95.1% of the Crematories only cremated human remains in their
Cremation Chambers.
7. 43.6% of the Crematories did not have the room for increasing the
size of the Cremation Chamber in their present facilities.
8. Most of the Crematories do not have an additional emission control
equipment installed on their Cremation Chambers.
9. The cost for improving the environmental emissions is beyond the
economic capability of most Crematory Operators.
CANA's Recommendations
1. Medical waste should be defined in the Regulations consistent with the
statutory definition and should not include human remains cremated by
Crematories;
2. Crematory Chambers (Batch Pathological Combustors ) should be
excluded from all requirements because the improvement in emissions is
not worth the cost; and
3. Crematory Chambers (Batch Pathological Combustors ) should be
excluded from all requirements because the economic analysis by the EPA
is in error and the new requirements will have a Significant economic
impact on a substantial number of small entities.
288
CANA-EPA 9 November 17, 1991
-------
Discussion
Definition of Medical Waste.
Ch. 4902 USCA §6903(40) added as part of the Medical
Tracking Act of 1988 defines the term "medical waste" as follows:
11 Except as otherwise provided in this paragraph, the
term 'medical waste' means any solid waste which is
generated in the diagnosis, treatment or immunization of
human beings or animals, in research pertaining thereto, or
the production or testing of biologicals. Such term does not
include any hazardous waste identified or listed under
subchapter III of this chapter or any household waste as
defined in regulations under subchapter III of this chapter."
Waste
Consistent with that definition the EPA issued Regulations under
this provision as follows:
40 CFR s 259.30 Definition of regulated medical waste.
"(a) A regulated medical waste is any solid waste, defined in s 259.10(a)
of this part, generated in the diagnosis, treatment, (e.g., provision of
medical services), or immunization of human beings or animals, in
research pertaining thereto, or in the production or testing of biologicals,
that is not excluded or exempted under paragraph (b) of this section,
* * * *
(b)(1) Exclusions.
(i) Hazardous waste identified or listed under the regulations in Part
261 of this chapter is not regulated medical waste.
(ii) Household waste, as defined in s 261.4(b)(1) of this Chapter, is not
regulated medical waste.
(iii) Ash from incineration of regulated medical waste is not regulated
medical waste once the incineration process has been completed.
(iv) Residues from treatment and destruction processes are no longer
regulated medical waste once the waste has been both treated and
destroyed.
(v) Human corpses, remains, and anatomical parts that are intended for
interment or cremation are not regulated medical waste." (Emphasis
CANA-EPA
283
10
November 17, 1991
-------
supplied)
The definition proposed by the EPA in the Draft Reports is much
broader and includes human remains. CANA believes that this proposed
definition is broader than provided for in the statutory definition of
"medical waste." CANA agrees with the definition in the medical waste
tracking regulations that Human (corpses) remains are not medical waste
and accordingly there should be an exclusion in the proposed regulation
definition of medical waste similar to the one under the Medical Tracking
Act.
There is a famous quote by William E. Gladstone, a famous Prime
Minister of England which CANA believes is appropriate to this matter.
He said:
"Show me the manner in which a nation or community cares for
its dead, and I will measure with mathematical exactness the
tender mercies of its people, their respect for the laws of the
land and their loyalty to high ideals."
One wonders what Gladestone would think about the American People or
for that matter what the American people will think, when the Federal
Government issues a Regulation that classifies human remains as medical
waste.
Crematory Chambers (Batch Pathological Combustors) should be
excluded from all requirements because the improvement in
emissions is not worth the cost.
The statistical information contained in the various reports dealing
with the proposed regulations indicates that the total tons of cremated
human remains processed by Crematories in their retorts is so small as
compared with other types of incinerators listed that Crematories should
be considered diminimis and not be covered. This is consistent with the
regulations under the Medical Tracking Act, which exempted from the
tracking and reporting requirements entities which process less than 50
pounds per month. Even the EPA recognized that most Crematories only
cremated human remains and in fact CANA members cannot maintain their
membership if they cremate anything other that human remains and the
container in which the remains are encased. This policy was reaffirmed in
a statement issued by the CANA Board of Directors at the 1991 Annual
230
CANA-EPA 11 November 17, 1991
-------
Meeting in August.
The average weight of a cremated body is 124 pounds and the
average number cremated in each Crematory Chamber is about 250 per
year or about 31,000 pounds per unit. If 1200 units cremate this amount
the total is 37,200,000 pounds or 18,600 tons per year. The 138,000 tons
used in the EPA Draft Reports is a combination of Funeral Homes and
Crematories and clearly most of that tonnage relates to Funeral Homes.
Accordingly Crematories should be at the low end of Table 3-1 for the
estimated quantity of medical waste generated contained in the Draft
Report titled "Background Paper for New and Existing Facilities".
Further, even the improvement in emissions as a result of the
program suggested by the EPA of adding the various controls is not that
significant. Finally the capital cost and annual maintenance costs
estimated by the EPA are probably low. Mr. Rahill, the technical advisor
for CANA will present information and give testimony about studies they
have made in several states adding lesser controls than suggested under
Control Option 1 and the estimated cost would be in the area of $25,000 to
$35,000 for each unit. Requiring Crematories to meet the new standards
with present equipment will probably result in more wear and tear on the
equipment and more expensive repairs will be require. As example, most
Crematory Chambers, presently in operation, will have extensive repair
costs for stacks and bricks as a result of the higher temperature
requirement under the proposed standards. The cost to accomplish these
goals, however, is quite significant and CANA believes that it will not be
worth the cost and its members may elect to cease their operations.
Accordingly, Crematory Chambers should be excluded from the Proposed
Regulations.
The Cremation industry is economically incapable of
complying with the proposed changes for control of emissions.
The EPA proposal is based on some significant errors about the
Cremation industry and for that reason most of the crematory businesses
in the industry will be economically unable to meet the costs involved in
complying with the new requirements. These errors are as follows:
1. The average price charged for cremation services is $150 in most areas
of the country, not the $500 figure on which EPA based its economic
projections.
2. Cremation is the technical heating process by heat and evaporation that
231
CANA-EPA 12 November 17, 1991
-------
reduces human remains to bone fragments. Cremation is a step in the
final disposition of the remains of a human being. Once a body is cremated
there is still the question of what to do with the cremated remains.
Usually they are placed in a cremation urn and stored in a niche at
cemetery or in a church. The revenue for these items goes to other
entities and many Funeral Homes sell the urn to the family. There are
alternatives to cremation, such as ground burial, entombment in a
mausoleum, and entombment in a lawn crypt. Even though the cost of the
cremation service is fairly low the other costs, such as for the urn, niche
and cremation container can bring the cost to where it is comparable to
the other alternatives. There also are some religions which prohibit or
are not in favor of cremation, so there are other market limitations which
cause consumers to select the other alternatives.
3. There is active competition in the cremation industry, both as between
crematory businesses themselves and between crematory businesses and
the other organizations in the cemetery industry which provide the
alternatives to cremation.
4. The price elasticity of demand for Crematories is not highly inelastic
because there are many alternatives. Death disposal is an absolute
necessity, but not by Cremation. Cremation is often discouraged by the
Funeral Home Industry because the Funeral Director cannot usually sell a
casket when there is a cremation and often there will be no traditional
funeral service with viewing and a service in the funeral home. If the
cost of cremation was to go up to cover additional costs, it would just
give another reason for not selecting cremation as an alternative.
5. It is believed by CANA that the estimated costs for equipment changes
and annual expenses made by the EPA are too low. CANA's technical
experts have indicated that based on other projects for upgrades less than
proposed the estimated costs were in the $25,000 to $35,000.
Accordingly, it is CANA's belief that the EPA has failed to show the
proposed changes are economically feasible as required by the Regulatory
Flexibility Act of 1980 as the emission guidelines will have a significant
effect on a substantial number of small entities because the:
(a) Annual compliance costs will increase total costs of production by
more than 5%.
(b) Compliance costs (annualized, presumably) as a percent of sales are at
least 10 percent higher than for larger entities.
(c) Capital costs of compliance represent a sjgnificant portion of capital
2S2
CANA-EPA 13 November 17, 1991
-------
available.
(d) The requirements of the regulation are likely to result in closures.
CONCLUSION
For the Reasons stated in the Memorandum and the supporting
Documentation, CANA recommends that Crematory Chambers should be
excluded from the proposed EPA Regulations.
Respectfully Submitted on Behalf of
Cremation Association of North
America
By: Lapin, Hoff, Slaw & Laffey
apm
General Counsel
223
CANA-EPA 14 November 17, 1991
-------
LIST OF EXHIBITS
1 1990 ANNUAL CREMATION STATISTICS AND
FORECAST TO THE YEAR 2010
2. FTC CANA SURVEY, PREPARED IN 1988
3. 1991 CANA TELEPHONE SURVEY
224
CANA-EPA -15 November 17, 1991
-------
1988,1989,1990 NORTH AMERICAN
CREMATION STATISTICS
The submitted figures of each crematory have been kept confidential and added to its geographical area.
UNITED STATES
NEW ENGLAND
Conn., Me., Mass.,
N.H., R.I., Vt.
MIDDLE ATLANTIC
N.J., N.Y., Penn.
E. NO. CENTRAL
III., Ind., Mich.,
Ohio, Wise.
W. NO. CENTRAL
Iowa, Kans., Minn.,
Mo., Neb., No. Dak.,
So. Dak.
SO. ATLANTIC
Del., D.C., Fla., Ga.,
Md., N.C., S.C.,
Va., W. Va.
E. SO. CENTRAL
Ala., Ky., Miss.,Tenn.
W. SO. CENTRAL
Ark., La., Okla.,Tex.
MOUNTAIN
Ariz., Colo., Ida.,
Mont., Nev., N. Mex.,
Utah, Wy.
PACIFIC
Ala., Cal., Haw.,
Ore., Wash.
TOTAL U.S.
CANADA
EASTERN CANADA
N.B., Nfld., N.S.,
Ont., P.E.I., Que
WESTERN CANADA
Alta., B.C., Man.,
N.W.T.Sask.. YT.
TOTAL CANADA
TOT. NO. AMERICA
01
W
•2 '
o
H
<
5
IU
1C
o
43
99
171
71
207
24
61
102
238
1016
63
43
110
1126
1988
Estimated ~'o Change
Deaths Cremations J'o Cremations
(Jool Total) (%ol Total) to Deaths
121,658 18,591 +1.37
(5.61) (5.60) 15.28
373,443 47,997 +6.18
(17.21) (14.45) 12.85
374,467 44,077 +4.46
(17.26) (13.27) 11.77
167,896 14,505 +8.63
(7.74) (4.37) 8.64
390,957 58,498 +1.82
(18.02) (17.91) 14.96
149,298 3,567 +1.86
(6.88) (1.07) 2.39
217,606 13,148 +.61
(10.03) (3.96) 6.04
96,664 25,410 +.73
(4.46) (7.65) 26.29
277,784 106,390 +1.29
(12.80) (32.03) 38.30
2,169,773 332,183 +2.73
Cremations to deaths 15.31%
133,900 34,985 +7.53
(71.76) (60.77) 26.13
52,700 22,583 +5.86
(28.24) (39.23) 42.85
186,600 57,568 +6.87
Cremations to deaths 30.85%
2,356,373 389,751 +3.32
Cremations to deaths 16.54%
1989
Estimated °/o Change
Deaths Cremations % Cremations
('.ot Total) (%ot Total) to Deaths
117,320 18,718 +.68
(5.45) (5.31) 15.95
363,176 48,976 +2.00
(16.86) (13.90) 13.48
368,631 45,618 +3.38
(17.11) (12.95) 12.37
164,478 15,129 +4.12
(7.64) (4.29) 9.20
395,197 65,110 +10.16
(18.35) (18.48) 16.48
143,249 4,284 +16.74
(6.65) (1.22) 3.00
215,141 13,582 +3.20
(9.99) (3.85) 6.31
96,645 29,552 +14.02
(4.49) (8.39) 30.58
290,059 111,401 +4.50
(13.47) (31.61) 38.41
2,153,896 352,370 +5.73
Cremations to deaths 16.36%
Not avail. 35,908 +2.57
(59.76)
Not avail. 24,179 +6.60
(40.24)
Not avail. 60,087 +4.19
Not avail. 412,457 +5.51
1990
Estimated % Change
Deaths Cremations % Cremations
(°'o of Total) (% of Total) to Deaths
116,363 19,843 +6.01
(5.38) (5.39) 17.05
359,499 50,526 +3.16
(16.63) (13.73) 14.05
370,039 47,243 +3.56
(17.12) (12.84) 12.77
164,888 15,910 +5.16
(7.63) (4.32) 9.56
396,873 69,810 +7.22
(18.36) (18.97) 17.59
148,739 4,492 +4.86
(6.88) (1.22) 3.02
219,619 14,352 +5.67
(10.16) (3.90) 6.53
98,964 30,447 +3.03
(4.58) (8.27) 30.76
287,016 115,352 +3.55
(13.28) (31.35) 40.19
2,162,000 367,975 +4.43
Cremations to deaths 17.02%
Not avail. 37,701 +4.99
(60.04)
Not avail. 25,096 +3.79
(39.96)
Not avail. 62,797 +4.51
Not avail. 430,772 +4.44
Compiled by the Cremation Association of North America, 401 North Michigan Avenue, Chicago, Illinois 60611, 312/644-6610
-------
CREMATION ASSOCIATION OF NORTH AMERICA
1991 PROJECTIONS TO THE YEAR 2010
ro
Jg PRESENTED AT THE 73rd ANNUAL CONVENTION
WESTIN HARBOUR CASTLE HOTEL
TORONTO, ONTARIO CANADA
AUGUST 14-18, 1991
Prepared by:
Smith, Bucklin & Associates, Inc.
Market Research & Statistics Division
(C) Copyright CANA, 1991
Printed in U.S.A.
-------
Map of the U.S. and Canada, showing CANA Regional Divisions
to
NORTH
CENTRAL
WEST
SOUTH
CENTRAL
JOUTH
^ATLANTIC
-------
PERCENT OF CREMATIONS TO DEATHS
NORTH AMERICA
U.S.
New England
Mid Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
CANADA
Eastern Canada
Western Canada
^vv_>j. \~>m-i
1990
18.29
17.02
17.05
14.05
12.77
9.56
17.59
3.02
6.53
30.76
40.19
32.53
27.24
45.94
1991
18.78
17.47
17.54
14.60
13.63
9.83
17.72
3.02
6.78
31.19
40.34
33.35
27.92
47.53
— rrvv/JE/v^iE.i-'
2000
24.02
22.33
23.16
19.27
19.10
13.97
21.97
4.13
9.17
38.55
45.88
42.99
37.26
57.74
2010
28.94
26.87
28.77
24.17
24.96
18.25
25.55
5.21
11.27
44.47
50.42
52.05
46.09
67.17
Printed in U.S.A.
-------
U.S. vs. CANADA
Percent of Cremations to Deaths
1975 to 2010
ro
en
IB
52.05%
0% - i i i i i
1975 1980 1985 1990 1991 1995 2000 2010
l\\, Year
(C)CANA 1991
-------
NUMBER OF CREMATIONS
CO
NORTH AMERICA
U.S.
New England
Mid Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
CANADA
Eastern Canada
Western Canada
(
ACTUAL
1990
430.8
368.0
19.8
50.5
47.2
15.9
69.8
4.5
14.4
30.4
115.4
62.8
37.7
25.1
thousands)
1991
451.0
385.1
21.0
53.9
50.5
16.4
71.8
4.5
15.2
31.6
120.2
65.9
39.9
26.0
PROTFrTFD - .
2000
628.4
536.1
29.0
73.3
72.2
24.2
102.4
6.7
22.8
45.8
159.7
92.3
57.6
34.7
2010
825.6
703.9
37.8
94.9
96.5
32.9
136.4
9.2
31.1
61.5
203.6
121.7
77.3
44.4
Printed in U.S.A.
-------
NUMBER OF DEATHS
CO
(thousands)
NORTH AMERICA
U.S.
New England
Mid Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
CANADA
Eastern Canada
Western Canada
ACTTJAT
x«.\— ' J. ^-/^»_L/
1990
2,355.0
2,162.0
116.4
359.5
370.0
164.9
396.9
148.7
219.6
99.0
287.0
193.0
138.4
54.6
1991
2,401.5
2,203.9
119.7
369.3
370.4
166.8
405.1
149.2
224.9
101.3
298.0
197.6
142.9
54.7
PROTPrTFD
2000
2,6153
2,400.6
125.2
380.4
378.0
173.2
466.1
162.2
248.6
118.8
348.1
214.7
154.6
60.1
2010
2,853.1
2,6193
131.4
392.6
386.6
180.3
533.9
176.5
275.9
138.3
403.8
233.8
167.7
66.1
Printed in U.S.A.
-------
NUMBER OF CREMATORIES
NORTH AMERICA
U.S.
New England
Mid Atlantic
East North Central
C ' ">
cr-5 West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
CANADA
Eastern Canada
Western Canada
./XV^ JL V ' r~* • •
1990
1,126.0
1,016.0
43.0
99.0
171.0
71.0
207.0
24.0
61.0
102.0
238.0
110.0
63.0
43.0
1991
1,186.7
1,066.6
43.9
102.8
188.0
73.5
209.3
25.6
67.5
103.4
252.6
120.1
73.9
46.2
I IN.VAI dV_ 1 l^U
2000
1,560.9
1,399.0
58.0
129.4
250.7
100.1
282.2
35.7
98.3
144.1
300.5
161.9
100.8
61.1
2010
1,976.5
1,768.1
73.6
158.9
320.2
129.7
363.2
47.0
132.4
189.3
353.8
208.4
130.6
77.8
Printed in U.S.A.
-------
CASES PER CREMATORY
NORTH AMERICA
U.S.
New England
Mid Atlantic
East North Central
West North Central
co South Atlantic
East South Central
West South Central
Mountain
Pacific
CANADA
Eastern Canada
Western Canada
-rtA^l \JS\ls
1990
382.6
362.2
460.5
510.1
276.0
223.9
337.2
187.5
236.1
298.0
484.9
570.9
598.4
583.7
1991
380.0
361.1
478.4
524.3
268.6
223.1
343.0
175.8
225.2
305.6
475.9
548.7
539.9
562.8
— r t\^jj EX, i C*LJ
2000
402.6
383.2
500.0
566.5
288.0
241.8
362.9
187.7
231.9
317.8
531.4
570.1
571.4
567.9
2010
417.7
398.1
513.6
597.2
301.4
253.7
375.6
195.7
234.9
324.9
575.5
584.0
591.9
570.7
Printed in U.S.A.
-------
Year
2000
2010
United States Figures
Cremations to Deaths
Increase from 1990 (in thousands)
D«ajth«
Cremations
457.3
i i i i
100 200 300 400
Additional Deaths & Cremations
500
600
Year Deaths Cremations
1990 (Actual) 2,162,000 368,000 17.02%
2000 (Projected) 2,400,600 536,100 22.33%
2010 (Projected) 2,619,300 703,900 26.87%
-------
Year
2000
2010
United States Figures
Cremations to Burials
Increase from 1990 (in thousands)
Burials
B3 Cremation*
335.9
i i i i i i
50 100 150 200 250 300
Additional Burials & Cremations
350 400
Year
1990
2000
2010
Burials
1,794,000
1,864,500
1,915,400
Cremations
368,000
536,100
703,900
Increase in
Cremations
0
168,100
335,900
Increase in
Burials
0
70,500
121,400
-------
Year
2000
2010
Canadian Figures
Cremations to Deaths
Increase from 1990 (in thousands)
Deaths
Cremations
10 20 30 40 50
Additional Deaths & Cremations
58.9
i
60
70
Year
1990 (Actual)
2000 (Projected)
2010 (Projected)
Deaths Cremations
193,000 62,800 32.53%
214,700 92,300 42.99%
233,800 121,700 52.05%
-------
Year
2000 -
2010 -
-40
Canada Figures
Cremations to Burials
Change from 1990 (in thousands)
-7.8
-18.11
M Burial*
ESS Cremations
58.9
i i i
-20 0 20 40 60
Change in Burials & Cremations
80
Year
1990
2000
2010
Burials
130,200
122,400
112,100
Cremations
62,800
92,300
121,700
Increase in
Cremations
29,500
58,900
Decrease in
Burials
0
(7,800)
(18,100)
-------
Five Key Trends
Affecting Cremation 1990 - 2010
1. Society is becoming middle aged
2. Educational level is rising
3. The earnings gap is widening
4. Origins of immigrants are changing
5. Regional differences are diminishing
-------
READING THE INFORMATION
The following terms are used throughout the Cremation Projections to 2000. Use
this page as a guide to help understand the data tables within the report.
ACTUAL: 1990 information is presented as actual reported figures for the
calendar year of 1990.
PROJECTED: Deaths, cremations, and crematory figures have been estimated for
the years of 1991, 95, 2000, and 2010.
CREMATION TO
DEATH RATE; The actual or estimated number of cremations for the region are
divided by the actual or estimated number of deaths reported for the
region. All figures are rounded to the nearest 10th or 1 percent.
FOR EXAMPLE:
Number of Deaths = 100
Number of Cremations = 25
Cremation to Death rate = 25.0%
OR
For each 100 deaths reported in the given year, 25 will result in
cremation.
CASES PER
CREMATORY: The actual or estimated number of cremations for the region are
divided by the actual or estimated number of crematories reported
for the region. All figures are rounded the nearest 10th of 1
percent
FOR EXAMPLE:
Number of Crematories = 10
Number of Cremations = 4000
Cases per Crematory = 400
OR
Each crematory within the region will perform an average of 400
cremations per year.
METHODOLOGY: A statistical modeling package is used that allows the following
variables to be utilized: year, number of crematories, number of
deaths, number of cremations, cases per crematory, cremations to
deaths, regions of Canada and the U.S.
All of the variables consist of actual historical data with which the
computer program looks for linear relationships. These patterns
allow us to formulate our projections.
-------
CANA
CREMATORY SURVEY
1988
DATA TABLES
EXCERPTS
-------
I.ANA IVtta CREMAT SURVEY
2. IS YOUR CREMATORY:
1. REGION
2. TYPE OF CREMATORY
3.DIRECT ARRANG
ANALYZED RESPONDENTS
A) LOCATED UK PREMISES OF
Oft OPER IN COJUNCT W/HOME
B) LOC ON PREM OR OPER IN
CONJUNCT U/MEM CEH COLUMS
C) OPER IN CONJUNCT W/NFP
MEM OR CREMATION SOCIETY
0) FREE SfArtD NOT IN CONJ
U/HOME MLMCK OR NFP SOC.
BOTH A AND B
OTHER MULTIPLE RESPONSE
NO RESPONSE
MEAN
STANDARD DEVIATION
STANDARD ERROR OF HtAH
TOTAL
NORTH
EAST
372 \ 50
100.0
123
33.1
119
32.0
37
9.9
61
16.4
13.4
10
20.0
23
46.0
7
14.0
-
•
30 / 10
8.1 1 20.0
2 /
0.5
-
2.67 2.88
1.75 1.78
0.09 0.25
MID
UEST
95
25.5
27
28.4
39
41.1
17
17.9
6
6.3
5
5.3
1
1.1
2.45
1.50
0.15
A)LOCAT B)LOCAT OOP IN D)FREE
ON PREM ON PREM CONJ U/ STAND
OF FUNE OF FUNE NFP MEM FAC.NOT
HOME OR HOME OR OR CREM IN CONJ
IN CONJ IN CONJ SOCTY U/HOME/ OTHER
UITH U/MEMOR MEM/NFP BOTH MULT I PL
SOUTH
85
22.8
43
50.6
14
16.5
9
10.6
14
16.5
5
5.9
.
-
2.44
1.78
0.19
UEST PROP.
129 123 119
34.7 33.1 32.0
39 123
30.2 100.0
38 - 119
29.5 - 100.0
3
2.3
41
31.8
8
6.2
. .
•
2.95 1.00 2.00
1.83
0.16
A) i B) RESPONS YES
37 61 30 128
9.9 16.4 8.1 34.4
60
46.9
31
24.2
37 - - 2
- 100.0 - - 1.6
61 • 28
• 100.0 - 21.9
30 7
- 100.0 5.5
• • • • >
.
4.00 5.00 6.00 2.44
1.78
0.16
NO
240
64.5
62
25.8
88
36.7
34
14.2
33
13.8
23
9.6
.
•
2.82
1.71
0.11
Smith BucUin & Associates Inc.
TABLE 3
-------
CANA 198S CREKATORr SURVtr
3. DO MEMBERS OF THE GENERAL PUBLIC ARRANGE FOR CREMATIONS DIRECTLY WITH YOUR CREMATORY?
7A) X OF CREHTS. FROM PROVIDER U/NO CONTRACT 7B) X OF CREHTS. IN 87 FROM PROVIDER U/CONTRACT
SC = = =
TOTAL
OX
1-
2SX
26-
SOX
51-
75X
76-
99X
100X
OX
1-
2SX
26-
50%
51-
75X
76-
99%
100X
ANALYZED RESPONDENTS
YES
NO RESPONSE
MEAN
STANDARD DEVIATION
STANDARD ERROR OF MEAN
372
100.0
240
64.5
71
19.1
26
36.6
43
60.6
2
2.8
1.58
0.55
0.07
51
13.7
29
56.9
21
41.2
1
2.0
1.39
0.53
0.07
20
5.4
12
60.0
8
40.0
1.40
0.49
0.11
28
7.5
13
46.4
15
53.6
1.54
0.50
0.09
47
12.6
25
53.2
22
46.8
1.47
0.50
0.07
155
41.7
23
14.8
131
84.5
1
0.6
1.84
0.38
0.03
250
67.2
89
35.6
159
63.6
2
0.8
1.63
0.50
0.03
26
7.0
13
50.0
13
50.0
1.50
0.50
0.10
19
5.1
5
26.3
14
73.7
1.74
0.44
0.10
9
2.4
4
44.4
5
55.6
1.56
0.50
0.17
30
8.1
8
26.7
20
66.7
2
6.7
1.60
0.61
0.11
38
10.2
9
23.7
29
76.3
1.76
0.43
0.07
Sun th Buck L i n & Ass.cc \ates 1 nc .
TABLE
-------
CANA 198S CREMA' SURVEY
5. HOW MANY CREMATIONS DID YOU PERFORM IN 1987?
1. REGION
2. TYPE OF CREMATORY
3.DIRECT ARRANG
ANALYZtD RESPONDENTS
0 • 50
51 • 100
101 • 250
251 • 500
501 • 1000
OVER 1000
NO RESPONSE
MEAN *
STANDARD DEVIATION
STANDARD ERROR OF MEAN
TOTAL
NORTH
EAST
1 — 1Z2_- 50
100.0
21
5.6
/ A2
11.3
140
37.6
89
23.9
49
13.2
24
13.4
4
8.0
3
6.0
17
34.0
9
18.0
11
22.0
/ 5
6.5 / 10.0
7 / 1
^ 1.9/ 2.0
3.61 4.49
3.67 4.29
0.19 0.61
HID
WEST
95
25.5
6
6.3
13
13.7
46
48.4
18
18.9
7
7.4
2
2.1
3
3.2
2.54
2.58
0.26
A)LOCAT B)LOCAT OOP IN D)FREE
ON PREH ON PREH CONJ U/ STAND
OF FUNE OF FUNE MFP MEM FAC.NOT
HOME OR HOME OR OR CREH IN CONJ
IN CONJ IN CONJ SOCTY W/HOME/ OTHER
WITH U/MEMOR MEM/NFP BOTH MULT I PL
SOUTH WEST
85
22.8
9
10.6
16
18.8
36
42.4
10
11.8
7
8.2
6
7.1
1
1.2
3.03
3.80
0.41
129
34.7
2
1.6
8
6.2
40
31.0
46
35.7
21
16.3
11
8.5
1
0.8
4.43
3.84
0.34
123
33.1
9
7.3
22
17.9
52
42.3
31
25.2
7
5.7
2
1.6
.
•
2.51
2.35
0.21
PROP.
119
32.0
7
5.9
8
6.7
42
35.3
27
22.7
24
20.2
7
5.9
4
3.4
3.93
3.67
0.34
A) & B) RESPONS
37
9.9
1
2.7
3
8.1
14
37.8
9
24.3
4
10.8
5
13.5
1
2.7
4.48
4.59
0.75
61
16.4
2
3.3
7
11.5
21
34.4
16
26.2
7
11.5
8
13.1
.
•
4.51
4.52
0.58
30
8.1
2
6.7
2
6.7
11
36.7
6
20.0
7
23.3
2
6.7
.
•
4.21
3.79
0.69
YES
128
34.4
12
9.4
19
14.8
45
35.2
27
21.1
16
12.5
7
5.5
2
1.6
3.30
3.55
0.31
NO
240
64.5
9
3.8
23
9.6
94
39.2
61
25.4
33
13. B
17
7.1
3
1.3
3.81
3.74
0.24
* MEAN IS DEFINED IN HUNDRETHS (00)
tXAMKLE: 3.61 = 361
to
Smi th buck I in & Associates Inc.
TABLE 6
-------
CAMA 1986 CREM
Y SURVEY
6. HOW MANY OTHER CREMATIONS CO YOU BELIEVE ARE IN DIRECT COMPETITION WITH YOU?
1. REGION
2. TYPE OF CREMATORY
3.DIRECT ARRAHG
ANALYZED RESPONDENTS
0
1 - 2
3 - 5
6 - 10
11-20
OVER 20
NO RESPONSE
MEAN
STAMMRD DEVIATION
SIANDARO EKrtOX OF MEAN
TOTAL
NORTH
EAST
372 \ 50
100.0 13.4
37 \ 1
9.9 2.0
151 18
40.6 36.0
127 25
34.1 50.0
33 6
8.9 12.0
9
2.4
6 /
1.6 /
9 /
2.4 /
3.93 3.57
4.53 2.02
0.25 0.29
HID
WEST
95
25.5
10
10.5
41
43.2
29
30.5
8
8.4
3
3.2
1
1.1
3
3.2
3.74
4.20
0.46
SOUTH
85
22.6
12
14.1
38
44.7
26
30.6
5
5.9
.
-
1
1.2
3
3.5
3.16
3.68
0.43
WEST
129
34.7
14
10.9
48
37.2
43
33.3
14
10.9
5
3.9
4
3.1
1
0.8
4.81
5.77
0.54
A)LOCAT
OH PREM
OF FUME
HOME OR
IM CONJ
WITH
123
33.1
17
13.8
54
43.9
39
31.7
10
8.1
1
0.8
.
•
2
1.6
3.14
2.34
0.23
B) LOG AT OOP IN
ON PREH CONJ W/
OF FUNE NFP MEK
HOME OR OR CREH
IN CONJ SOCTY
W/HEHOR
PROP.
119
32.0
8
6.7
52
43.7
38
31.9
11
9.2
6
5.0
2
1.7
2
1.7
4.24
4.91
0.47
D)FREE
STAND
F AC. NOT
IN CONJ
U/HOHE/
HEH/NFP
37
9.9
3
8.1
11
29.7
17
45.9
4
10.8
.
•
.
•
2
5.4
3.43
2.13
0.36
BOTH
A) 4 B)
61
16.4
8
13.1
22
36.1
19
31.1
6
9.8
2
3.3
4
6.6
.
•
5.81
7.56
1.04
OTHER
MULTIPL
RESPONS
30
8.1
1
3.3
12
40.0
14
46.7
2
6.7
.
•
.
•
1
3.3
3.10
1.85
0.34
YES
128
34.4
13
10.2
49
38.3
42
32.8
11
8.6
6
4.7
2
1.6
5
3.9
4.20
4.85
0.45
NO
240
64.5
24
10.0
102
42.5
85
35.4
20
8.3
3
1.3
4
1.7
2
0.8
3.79
4.35
0.30
I -,
i x.h Buck Ii n & Associates I nc.
TABLE 7
-------
CANA 19&a CREnATORY SURVEY
7.
-------
CANA 19od CREMATORY SURVEY
8. IN WHAT PERCENTAGE OF THE CREMATIONS THAT YOU PERFORMED IN 1987 WERE THE FOLLOWING USED: TRADITIONAL CASKET
7A) X OF CREHTS. FROM PROVIDER W/NO CONTRACT 78) X OF CREMTS. IN 87 FROM PROVIDER U/CONTRACT
ANALYZED RESPONDENTS
OX
1 - 25X
26 • SOX
51 - 75%
76 - 99X
100X
MEAN
STANDARD DEVIATION
STANDARD ERROR OF MEAN
TOTAL
o:
r™\
1 100.0 \
28 \
7.8 \
278 \
77.4 I
/
36
10.0
12
3.3 ,
'' /
\ ''I /
Yj'-y
16.78
14.97
0.79
1-
( 25X
68 49
18.9 13.6
15 6
22.1 12.2
53 36
7.9 73.5
6
12.2
1
2.0
.
-
.
-
?.74 15.05
5.18 11.84
3.63 1.69
26-
5 OX
18
5.0
1
5.6
16
88.9
1
5.6
.
-
.
-
.
-
13.19
6.55
1.54
51-
75X
28
7.8
1
3.6
25
89.3
1
3.6
1
3.6
.
-
.
•
14.73
10.59
2.00
76-
99X
47
13.1
1
2.1
37
78.7
8
17.0
1
2.1
.
•
.
•
17.55
11.72
1.71
100X
149
41.5
4
2.7
111
74.5
20
13.4
9
6.0
4
2.7
1
0.7
21.14
19.15
1.57
OX
242
67.4
19
7.9
175
72.3
31
12.8
12
5.0
4
1.7
1
0.4
18.80
17.35
1.12
1-
25X
25
7.0
2
8.0
20
80.0
3
12.0
.
•
.
-
m
•
14.50
9.14
1.83
26-
SOX
18
5.0
—
-
17
94.4
1
5.6
.
•
.
•
»
-
13.89
5.73
1.35
51-
75X
8
2.2
f
•
7
87.5
1
12.5
.
-
.
•
_
-
15.63
8.27
2.92
76-
99X
29
8.1
3
10.3
26
89.7
.
-
„
-
.
-
_
•
11.21
3.81
0.71
100X
37
10.3
4
10.8
33
89.2
.
•
.
•
.
•
f
•
11.15
3.88
0.64
p.'.'
Smith Bucklin & Associates Inc.
TABLE 12
-------
CANA 1983 CREM. Y SURVEY
8. IN WHAT PERCENTAGE OF THE CREMATIONS THAT YOU PERFORMED IN 1987 WERE THE FOLLOWING USED: ALTERNATIVE CONTAINER
7A) X OF CREHTS. FROM PROVIDER W/NO CONTRACT 7B) X OF CREHTS. IN 87 FROM PROVIDER U/CONTRACT
TOTAL
OX
ANALYZED RESPONDENTS / 359\ 68
/100.0 1 18.9
/ I
OX 7 \ 5
1.9 1 7.4
1 - 25X 27 I 2
7.5 I 2.9
26 - 50% 24
6.7
51 - 75X 48 3
13.4 4.4
76 - 99% 230 48
64.1 70.6
100X 23 10
6.4 I 14.7
MEAN W^f— '79.60
STANDARD DEVIATION ^5.65 26.77
STANDARD ERROR OF MEAN 1.35 3.25
1-
25X
49
13.6
.
3
6.1
2
4.1
7
14.3
31
63.3
6
12.2
78.83
21.90
3.13
26-
50X
18
5.0
.
1
5.6
2
11.1
2
11.1
12
66.7
1
5.6
75.69
23.00
5.42
51-
75X
28
7.8
-
2
7.1
3
10.7
1
3.6
21
75.0
1
3.6
76.34
23.94
4.52
76-
99X
47
13.1
-
6
12.8
2
4.3
8
17.0
30
63.8
1
2.1
71.81
26.23
3.83
100X
149
41.5
2
1.3
13
8.7
15
10.1
27
18.1
88
59.1
4
2.7
70.55
25.99
2.13
OX
242
67.4
5
2.1
19
7.9
20
8.3
40
16.5
142
58.7
16
6.6
72.37
26.29
1.69
1-
25X
25
7.0
.
2
8.0
2
8.0
3
12.0
16
64.0
2
8.0
75.50
24.36
4.87
26-
50X
18
5.0
-
1
5.6
2
11.1
2
11.1
13
72.2
.
75.00
22.44
5.29
51-
75X
8
2.2
-
1
12.5
-
3
37.5
4
50.0
•
68.75
24.21
8.56
76-
99X
29
8.1
.
3
10.3
.
.
23
79.3
3
10.3
81.03
23.59
4.38
100X
37
10.3
2
5.4
1
2.7
-
-
32
86.5
2
5.4
81.42
23.18
3.81
Smith Bucklin & Associates Inc.
TABLE 13
-------
CANA 1983 CREMATORY SURVEY
8. IN WHAT PERCENTAGE OF THE CREMATIONS THAT YOU PERFORMED IN 1987 UERE THE FOLLOWING USED: NO CONTAINER
1. REGION 2. TYPE OF CREMATORY
3.DIRECT ARRANG
TOTAL
NORTH
EAST
ANALYZED RESPONDENTS "/ 359\ 48
/100.0 \ 13.4
OX / 308
/ 85.8
1 - 25X / 17
/ 4'7
26 -SOX / 6
/ 1>?
39
81.3
.
-
5
10.4
51 • 7iX / 9/1
1 2.5 / 2.1
76 - 99% 15 /
2
4.2/ 4.2
100X 41
1./I 2.1
MEAN 7.S6 10.94
STANDARD DEVIATION 22.A3 25.21
STANDARD ERROR OF MEAN 1/18 3.64
MID
WEST
91
25.3
81
89.0
7
7.7
1
1.1
1
1.1
1
1.1
.
•
3.02
12.06
1.26
SOUTH
82
22.8
63
76.8
5
6.1
.
-
4
4.9
8
9.8
2
2.4
14.79
31.18
3.44
WEST
126
35.1
116
92.1
4
3.2
.
•
1
0.8
4
3.2
1
0.8
4.47
18.40
1.64
A)LOCAT
ON PREM
OF FUNE
HOME OR
IN CONJ
WITH
119
33.1
98
82.4
5
4.2
2
1.7
3
2.5
10
8.4
1
0.8
10.93
27.14
2.49
B)LOCAT OOP IN
ON PREM CONJ W/
OF FUNE NFP MEM
HOME OR OR CREH
IN CONJ SOCTY
W/MEHOR
PROP.
114
31.8
101
88.6
6
5.3
3
2.6
3
2.6
1
0.9
.
•
4.06
14.10
1.32
D)FREE
STAND
FAC.NOT
IN CONJ
W/HOME/
MEM/NFP
37
10.3
29
78.4
2
5.4
.
•
2
5.4
1
2.7
3
B.1
14.53
32.04
5.27
BOTH
A) & B)
58
16.2
52
89.7
3
5.2
.
•
.
•
3
5.2
.
•
5.17
19.43
2.55
OTHER
MULT I PL
RESPONS
29
8.1
27
93.1
.
•
1
3.4
1
3.4
.
•
.
•
3.45
13.09
2.43
YES
125
34.8
107
85.6
7
5.6
.
•
3
2.4
6
4.8
2
1.6
8.00
23.79
2.13
NO
230
64.1
198
86.1
9
3.9
6
2.6
6
2.6
9
3.9
2
0.9
7.39
21.83
1.44
Smith Bucklin S. Associates Inc.
TABLE 14
-------
CREMATION SURVEY
1991
Prepared by
Smith, Bucklin & Associates, Inc.
Market Research & Statistics Division
November, 1991
-------
METHODOLOGY
Telephone interviewing was chosen as the best method given the time
constraints and the fact that the sample needed to be as close
to the actual proportion of members in each region. Names were selected
from each state and province to get a representative sample as close as
possible to the actual proportion of members in those areas.
A sample of 266 surveys were completed out of the 546 CANA members that
conduct cremations. For the purpose of this survey, cremations are defined
as a direct cremation of the human body without traditional funeral services.
The tabulated results are considered to be very representative of the total
CANA membership with an error rate of ± 4.3 percentage points at a
95 percent confidence level. In other words, if a total census of CANA
members were conducted, 95 out of 100 times the results would be within ± 4.3
percentage points of the total results presented here.
Telephone interviewing and statistical tabulation was conducted by an
independent third party Smith, Bucklin & Associates (SBA) Market Research
& Statistics Division. SBA conducts market research for over 80 national and
international trade associations, professional societies and technology
organizations. All data is held in the strictest confidence. Under no
circumstances does any CANA member or staff personnel have access to the
individual company data.
Make-up of CANA Membership:
Total Percent
Crematory only 42 5.7%
Crematory and
Funeral Services 184 25.0%
Crematory and
Cemetery 203 27.6%
Crematory, Cemetery
and Funeral Services 117 15.9%
Do not have a
Crematory 108
Suppliers 82
TOTAL 736
(TT
-------
Ql. What is your current charge for an adult cremation (cremation only)?
Total = 258
Low = $75
High = $395
Mean = $159
Median = $150
Q2. Do you perform cremations for others in the funeral service?
Total Percent
Yes 236 88.7%
No 28 10.5%
No Answer 2 0.8%
TOTAL 266 100.0%
-------
Q4. How many retorts do you have?
Total
Percent
1
2
3 or more
No Answer
TOTAL
150
79
35
2
266
56.4%
29.7%
13.2%
0.8%
100.0%
Mean
1.56 retort
Q5. Age of each retort?
(Multiple response allowed)
5 or less years
6-10 years
11-15 years
16-30 years
31 or more years
No Answer
TOTAL
Mean
Total
Percent
77
90
52
58
21
20
318
28.9%
33.8%
19.5%
21.8%
7.9%
7.5%
13.2 years
- r,
^ 6-,
-------
Q6. What was the cost of your retort?
Total
Percent
$30,000 or less
$31,000 45,000
$46,000 - 60,000
$61,000 or more
No Answer
TOTAL
Mean
Median
92
52
15
7
1QQ
266
34.6%
19.5%
5.6%
2.6%
37.6%
100.0%
$33,710
$26,760
Low Value = $10,000 High Value = $100,000
-------
Q7. What brand/type of equipment do you use?
(Multiple response allowed)
Number of
Responses
IEE 92
All Manufacturing 90
Crawford 14
Jones 12
American 10
Industrial 8
Nortek 4
Therm Tech 4
Foster 3
B&L 2
G&S 2
Jarvis 2
Mouse Bolser 2
Smith 2
Alphred Post 1
Basic 1
California Crematory 1
Caser 1
Commercial Burner 1
David Evans 1
Delong 1
Downers Grove/Larson 1
Eclipse Parts 1
Evan 1
FC 1
Firebrick 1
G&L 1
Hepburn 1
Interteck 1
Intex 1
ITT 1
James Krapp 1
Kellogg Man 1
Knapps 1
Kosser 1
Krentz 1
Larsen 1
Power Pack II 1
P&NT Manufacturing. 1
Ray Co. 1
Rototherm 1
Treats 1
Williams 1
TOTAL 276
-------
Q8. Do you cremate/incinerate items other than human remains and their
casket/container in each retort?
Total Percent
Yes 13 4.9%
No 253 95.1%
TOTAL 266 100.0%
Q8. If yes, list items:
(Multiple response allowed)
Total
Animals 3
Medical Waste 3
Pathological
Waste 5
Other 3
TOTAL 14
Other:
• Fetuses from hospitals. (2)
• Biological cremations.
• Just limbs.
-------
Q9. Do you have room for increasing the size of your retort in your present
facility?
Total Percent
Yes 149 56.0%
No 116 43.6%
No Answer 1 0.4%
TOTAL 266 100.0%
-------
Q10. Do you have added pollution controls on each unit?
Wet Scrubbers
Total
Percent
Yes
No
No Answer
TOTAL
42
197
27
266
15.8%
74.1%
10.1%
100.0%
Dry Scrubbers
Yes
No
No Answer
TOTAL
Total
18
195
53
266
Percent
6.8%
73.3%
100.0%
-------
Q10. Do you have added pollution controls on each unit?
Bag House
Total
Percent
Yes
No
No Answer
TOTAL
17
196
53
266
6.4%
73.7%
19.9%
100.0%
Other
Total
Percent
Yes
No
No Answer
TOTAL
33
228
5
266
12.4%
85.7%
1.9%
100.0%
Other:
Updated the after burner. (9 responses)
Added temperature controls. (5 responses)
State of Florida is enacting legislation of its own. (2 responses)
Incinamites - tertiary burning system.
Hawaii state standards.
Brought standards up on equipment, but did not add controls.
Temperature probes, fuel cut-off, monitors on stack.
Old retort was just re-done.
Updated controls last year.
Have air quality controls.
Monitored very closely by the state of California.
Stack control added five years after installation.
Second burn chambers.
Temperature requirements, opacity monitors, velocity count at end of stack. Strict
Philadelphia standards.
Natural gas.
Added a gas control system.
8
-------
Q10. Continued.
Other - answered no to question.
Just what was on originally. (11 responses)
Standard on equipment. (2 responses)
Has been inspected by pollution control (government). (2 responses)
Equipment has a pollution device built into it.
Stacks for smoke and heat control.
Refractory line stack.
When installed, unit has controls.
Monitored by GVRD.
Furnished controls on equipment.
No pollution; state-of-the-art.
We are going to new equipment and new site due to pollution controls.
-------
Qll. How many cremations per year, per retort?
Less than 100
100 200
201 - 400
401 - 600
601 or more
No Answer
TOTAL
Mean
Median
Total
408 retorts
243 retorts
Percent
11
75
86
36
49
9
266
4.1%
28.2%
32.2%
13.5%
18.4%
3.4%
100.0%
10
-------
CREMATION INDUSTRY IMPACT
Batch
Pathological
Baseline
Control
Option 1
Control
Option 2
Control
Option 3
PM
GRDSCF
.027
.017
.015
.005
CO
PPMDV
50
2
2
2
% REDUCED
FROM
BASELINE
38%
44%
81%
EQUIPMENT
COSTS
50,000
68,900
206,900
512,900
EQUIPMENT
COST
INCREASE
38%
413%
1,024%
INDUSTRY
UPGRADE COSTS
(MILLIONS) *
23 (30) **
188
555
* Industry upgrade costs based on 1,200 existing cremation units.
** Recent quotes for upgrading to 1,800° F. 1 second retention indicate $25,000
estimated cost.
— Under Control Option 1 we will reduce annual PM output by 10 tons for an
industry cost of $23 to $30 million.
— Under Control Option 2 we will reduce annual PM output by 11.5 tons for an
industry cost of $188 million.
— Under Control Option 3 we will reduce annual PM output by 21 tons for an
industry cost of $555 million.
.il
-------
I
WCEI
Waste Combustion
Equipment
Institute
Waste Combustion Equipment Institute
Testimony Before The
National Air Pollution Control Techniques Advisory Committee
Research Triangle Park, North Carolina
November 20, 1991
By
Stephen E. Shuler, Chairman
Waste Combustion Equipment Institute
1730 Rhode Island Avenue, N.W., Suite 1000
Washington, B.C. 20036
Manager, Sales and Marketing
Joy Energy Systems, Inc.
11900 Westhall Drive
Charlotte, NC 28241-0647
]A
An Institute
of the National
Solid Wastes
Management Association
> o.
O <-;
1730 Rhode Island Avenue, NW, Suite 1000
Washington, DC 20036
(202) 659-4613 FAX (202) 775-5917
Printed on Recycled Paper
-------
Introduction
My name is Stephen Shuler, Chairman of the Waste Combustion
Equipment Institute (WCEI). WCEI is an institute of the National
Solid Wastes Management Association (NSWMA), a trade association
with over 2,500 members of the private waste services industry-
WCEI represents companies that develop waste combustion
technologies for various specialty waste combustion applications.
These applications inclu.de municipal systems less than 250 tons
per day, and systems used for hospital, commercial, and hazardous
industrial waste destruction.
Medical Waste Combustor Standards
WCEI appreciates the opportunity to be here today to provide
comments relating to EPA's development of maximum achievable
control technology (MACT) standards for medical waste
incinerators (MWI's). My discussion will focus on EPA's draft
documents relating to the standards development program. The
primary areas I will cover are:
1) Permit and compliance protocols for non-MWI management
options;
2) Recommended technical corrections to the draft
documents;
3) Recommended changes to EPA's model plants; and
4) Short fall areas in EPA's background documentation.
Let me begin by emphasizing that proper regulation of MWI's,
along with all other medical waste management options, is
essential for the protection of public health and the
environment. We all need to be fully confident in the methods
used to manage our nation's medical wastes.
Toward this end, EPA's efforts to establish MACT standards
for new and existing MWI sources are to be applauded. In support
of this approach, though, it is important to recognize that such
standards must be flexible enough to accommodate the needs for
medical waste management in various types of applications and
geographic areas of the United States. Such standards must also
accurately reflect the latest advancements in MWI technology.
More specific to the point, there are numerous clarifications,
corrections, and questions pertaining to the draft documents I
would like to discuss at this time.
Regulating Non-MWI Management Options
Alternative medical waste management options such as steam
sterilization, chemical disinfection, and microwave sterilization
are not currently regulated for air emissions and discharges to
the sewer at present. What tests have been conducted by EPA to
-------
determine the varieties and volumes of criteria toxic pollutants
in either the exhaust or blow-down of these systems? WCEI
believes that such an investigation may result in the need for
add-on equipment which would enable these systems to better
control pollutants and likely result in more protection of human
health-and the environment. At a minimum, these non-MWI options
should be subject to comparable permitting and compliance
protocols.
MWI Process Technical Clarifications
The Process Description/Baseline Emissions Report notes on
page 5 that the typical operating temperature range for primary
chambers is 750° to 1800°F. WCEI feels that, with the exception
of cold-loaded batch systems, the minimum range should be 1200°
to 1400°F, particularly for modern systems. Page 6 of the report
notes that the typical operating temperature range for the
secondary chamber is 1600° to 2000°F. All modern MWI systems are
capable of operating at a minimum 1800°F and can reach 2200°F
when processing large percentages of high BTU/lb. waste materials
like plastics.
On page 19 of the report EPA notes that an intermittent-
duty, controlled-air unit typically has an operating cycle of 24
hours or less. With specific regard to loading and combustion
time (i.e., not including cool-down time), intermittent duty
systems are typically designed for a maximum 16 hour duty cycle.
In addition, waste feed is not intended to have intervals of
several hours. Six to 15 minute intervals are more appropriate
for hot-loaded system, while 24 hour intervals are characteristic
of cold-loaded systems. Also, preheat of any incinerator should
be no less than 45 to 60 minutes, not 15 to 60 minutes. This is
necessary to ensure that refractory damage will not occur.
On page 26 it is noted that incinerators that burn only
pathological wastes are excess air systems. Some pathological
incineration designed for animal carcass destruction do not
utilize an excess air primary chamber. These are typically
designed to operate without underfire combustion air and use the
fossil fuel burners to drive off moisture, followed by combustion
of the remaining combustible materials.
On page 30 mention is made of mechanical loaders (feeders).
As a point of clarification, mechanical loaders are typically
used on modern combustion systems having thermal capacities
ranging from less than 850,000 BTU/hr- and larger. Based on the
assumption that medical waste averages 8500 BTU/lb. heat of
combustion, combustors equipped with feeders typically range in
size from less than 100 Ib./hr- and larger.
-------
With regard to auger waste feed systems discussed on page
30, it is questionable whether this device should be used to
process infectious wastes. First, the auger hopper is an open
top design and allows aerosols to discharge into the atmosphere
as wastes are processed prior to and through the screw feeder
section. Second, in the event of mechanical failure or jamming,
infectious waste would have to be removed manually thus exposing
the operator to such material at the risk of contamination.
On page 39 it is stated that combustion air can be added to
a tertiary chamber. WCEI assumes this to mean that at the point
this air is added, the calculation for retention time is measured
following the introduction of this additional combustion air-
Recommended Model Plant Changes
On page 17 of the Model Plant Description and Cost Report
EPA notes that a 1-second residence time has been assumed as
baseline for all models because it is a conservative estimate for
determining cost impacts. WCEI recognizes that this has been
done to account for the operating performance of older units, but
feel that good logical evaluations should be based upon new
technology. For example most manufacturers now offer 2 second
secondary chamber residence times and the model plant evaluations
should therefore be based on this criteria. WCEI does recommend
an exception to this rule for pathological units.
With regard to MWI capital costs, those reflected in Table
19 on page 135 are understated. Attachment 1 to my statement
reflects WCEI Member Facility Combustion Unit and APC Equipment
Costs. These costs, which were submitted previously to EPA, are
more accurate.
Document Shortfalls
During the period when data were being collected for the
Background Paper for New and Existing Facilities, a number of
changes occurred in the industry- WCEI urges EPA to consider
these important developments and incorporate them into its MACT
standards for MWI's.
For example, incinerator technology has changed
dramatically. Combustion efficiencies, controls, interlocks, and
safeties have all been incorporated into modern systems. Test
sites selected by the EPA do not properly reflect these and other
technological advances made by the industry. Consequently, WCEI
believes that the data presented in the draft documents are
skewed toward older units which are not capable of achieving
modern combustion efficiency standards. Attachment 2 to my
written statement is a list of facilities WCEI feels are more
reflective of modern systems. WCEI urges EPA to conduct testing
at these plants.
-------
A second problem relates to an inability by state regulatory
agencies to agree on a uniform operating standard for MWI
systems., including requirements for air pollution control (APC)
and continuous emissions monitoring systems. WCEI has seen the
performance requirements change from an opacity standard to
incremental steps defining more stringency in particulate
control, from 0.2 G/DSCF (corrected to 7% O2) to requirements of
0.015 G/DSCF (also corrected to 7% O2). The problem is that
before APC vendors can design, manufacture, and install systems
with a specified operating range in one state, the operating
standard changes in another. The earlier version then is tested
and used as the database to determine the validity of a specific
technology.
The California Air Resources Board (GARB) tests performed on
Stanford University's MWI system provides a good example. This
installation uses a wet variable venturi scrubber designed for
the removal of HC1 only. However, CARB tested the system for
dioxins and furans, metals and other elements for which the
system was not designed to manage and subsequently determined
that wet scrubber technology was not appropriate in California.
WCEI feels the data presented in EPA's draft documents
demonstrate the same flawed logic as seen in the CARB report.
EPA's database is incomplete. The data do not adequately
represent recent technological developments made by the MWI
industry- A case in point is provided by the wet scrubber system
tested by EPA as a part of its standards development program.
When this system was installed the particulate emission standard
was approximately eight times the current level being targeted by
EPA. Unfortunately, EPA interprets this to mean that the
equipment can only achieve eight times the proposed standard,
without looking at developments which have taken place beyond
this one installation. Development and installation of scrubber
technology has not been allowed to the point where an appropriate
assessment can be made as to which technology truly represents
MACT.
-------
Summary
In summary, I would like to recap WCEI'a primary
recommendations to EPA:
* Establish baseline standards (design and operational) on
current state-of-the-art technology, not older technology as
summarized in the background documents.
* Recognize the potential for emissions which can be damaging
to human health and the environment from alternative
technologies. Establish a comparable set of regulations for
design and operational criteria for these technologies.
* Correct inaccuracies in the background documents relating to
retention, operating temperatures, feed rates, warm-up
times. Recognize that animal carcass combustors are not
excess air design systems and should be exempt from
retention requirements.
* Investigate the applicability of augers as a viable feed
method for regulated medical waste. Are these devices
capable of minimizing human health risk and protecting the
environment?
* Retention calculation for a tertiary chamber addition should
specify at what point combustion air can be introduced.
* Model plant calculations should be based on costs of modern
MWI combustion/boiler/APC/CEMS, not older installations
using out-of-compliance designs. WCEI submitted cost data
to EPA in October 1990 representative of modern systems. We
recommend its use to reflect the real cost of modern plants.
Thank you for the opportunity to express WCEI's positions.
I look forward to working productively with the EPA on developing
the MWI rules. Working together will provide the best
opportunity to establish regulations that are reasonable and
effective.
:?
-------
C©
(i)
(2)
(3)
(4)
ATTACHMENT 1
WCEI MEMBER FACILITY COM3USTOR UNIT & ARC EQUIPMENT COSTS
Capacity (PPH)
1 00-299 (1)
300-199 (1)
500-999 (1)
1.000-1.499(1)
1,500-1,999(1)
2,000-2.500(1)
Capactty (PPH)
100-299 (1)
300-499 (1)
500-999 (1)
1,000-1,499(1)
1 ,500-1 ,999<1)
2,000-2500(1)
1-2 Shift Duty
50.000-100,000
85,000-270,000
230,000-360.000
300. Or -425.000
375,000-500,000
485,000-540,000
Start-up Costs (2)
37^00- 75,000 (3)
63,750-202^00 (3)
124,000-190.000 (4)
144,000-216.000 (4)
166.000-244,000(4)
206,000-310,000 (4)
CO*IBUSTOfl UMT W/ BOILER COSTS
1-2 Shift
303,000^77.000
402.000-564.000
492, 000-655 .000
624,000-712.000
Continuous
388.000-592,000 i
462.000-680,000
532.000-765.000
655,000-947,000
Wet w/o Bo4ler
100,000-170.000
150.000-275,000
245.000-380,000
335,000^70,000
420.000-650.000
W»t w/Bofler
—
115.000-220,000 •
195,000-260,000
220.000-295,000
250,000-335.000
Dry w/o Bolter
145.000-290.000
275,000-385.000
360.000-425,000
445,000-510.000
525.000-600.000
Dry »/ Batter
—
200.000-310.000
285.000-375,000
355,000-480.000
425.000-510,000
Units 300 PPh and greater are assumed to have an automate loader; Units 500 PPH and greater are assumed to have a scrubb«
Includes Freight, Installation. Start-up. Operator Training and Comptance Testing Supervision
75% of base combustor price (1-2 shift dirty)
40% of base combustor price (continuous duty)
CBt Compooem
CO
CEII Coat
40.000-«5.000
CO, 25,000-70,000
o,
Opacity
HO
Method 5 Testing
Dbxins. Heavy Metals
CO. etc. Testing
EIS
Dispersion Analysis
Remitting
15.000-25.000
25.000-45,000
100.000-160.000
5,000-7.000
75,000-150,000
50,000-125.000
10,000-25,000
2.000-50.000
CaWntton
7,500-15.000
7^00-15.000
7.500- 1 5,000
2^00-8.000
15.000-25.000
EPA OrtMcsUon
12.000-20,000
8,000-15.000
5,000-10,000
5,000-10,000
15,000-25,000
-------
ATTACHMENT 2
Waste Combustion Equipment Institute
Recommended MWI Sites For EPA Testing
(November 1991)
Company/Site
1. National Medical Waste
a. Pearland, TX
b. Nashville, TN
2. Waste Management, Inc.
a. Apopka, FL
3. Thermal Reduction
a. Haw River, NC
Equipment Scope
(1) Joy Energy Model 2500TES
w/Andersen 2000 wet scrubber
(1) Joy Energy Model 2500TES
w/Andersen 2000 wet scrubber
(1) Joy Energy Model 2500TESI
w/United McGill dry scrubber
(2) Joy Energy Model 2500TES w/Sly
wet scrubbers
4. Hamot Medical Center
a. Erie, PA
5. Grouse Irving
a. Syracuse, NY
6. Grandview Hospital
a. Sellersville, PA
(1) Cleaver-Brooks Model 128072
w/energy recovery and Beco
Engineering dry/wet scrubber
(1) Cleaver-Brooks Model 78031
w/B.G. Wickberg dry/wet scrubber
(1) Cleaver-Brooks Model 78031
w/Andersen 2000 wet scrubber
-------
COMMENTS TO
"MEDICAL WASTE INCINERATORS - BACKGROUND
INFORMATION FOR PROPOSED STANDARDS
AND GUIDELINES"
(Draft - Documents dated September 30, 1991)
as issued by the
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office Of Air Quality Standards And Planning
Research Triangle Park, North Carolina
Prepared and submitted on behalf of the
American Hospital Association
Chicago, Illinois
By
Lawrence G. Doucet, P.E., D.E.E.
November 20, 1991
• »j
DOUCET & MAINKA, P.C. 1200 BROWN STREET PEEKSKILL, NY 10566 ™X(914™
-------
COMMENTS TO: Medical Waste Incinerators Background Information for
Proposed Standards and Guidelines
Draft Documents dated September 30, 1991
SUBMITTED BY: Lawrence G. Doucet, P.E., D.E.E.
DOUCET & MAINKA, P.C.
1200 Brown Street
Peekskill, New York 10566
on behalf of the
AMERICAN HOSPITAL ASSOCIATION
Chicago, Illinois
DATE: November 20, 1991
I. INTRODUCTION
The U.S. Environmental Protection Agency (U.S.EPA) has issued Draft Documents
(dated September 30, 1991) as part of their regulatory program to develop Maximum
Achievable Control Technology (MACT) standards for emissions from medical waste
incinerators in accordance with Section 129 of the Clean Air Act. This set of
documents includes the following titles:
1. Industry Profile Report for New and Existing Facilities
2. Process Description/Baseline Emissions Report for New and Existing Facilities
3. Model Plant Description and Cost Report for New and Existing Facilities
4. Control Technology Performance Report for New and Existing Facilities
5. Environmental Impacts Report for New and Existing Facilities
6. Analysis of Economic Impacts for Existing Sources
1. Background Paper for New and Existing Facilities
It is understood that these documents are intended to serve as the basis of support for
proposed federal regulations for new and existing medical waste incinerators.
- 1 -
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
The purpose of this document is to present our review comments and
recommendations of each of the seven (7) documents listed above. These comments
have been prepared and are being submitted on behalf of the American Hospital
Association (AHA).
Our background, qualifications and experience in medical waste incineration make us
exceptionally well qualified to review these documents and offer our comments.
Doucet & Mainka is an independent consulting firm specializing in medical, solid and
hazardous waste management, treatment, disposal and incineration. We have worked
on waste management and medical waste incineration projects for more than 250
hospitals, universities, research facilities and similar institutions in more than 35
states. We have worked as consultants and have provided advisory assistance to ten
state hospital associations, the Office of Technology Assessment of the U.S. Congress
and the AHA on medical waste management and incineration issues. We wrote a
Medical Waste Incinerator Operator Handbook and a four-day training program for
presentation to all 50 states as needed for compliance with present and pending state
and federal regulations. This program is presently being given to all incinerator
operators in the State of Washington under a contract with the Washington
Department of Ecology.
I have been involved with medical and solid waste incineration projects for more than
twenty years. I am a registered professional engineer in eleven states, a Diplomat of
the American Academy of Environmental Engineers and Chairman of NFPA-82
Committee, Incinerators and Waste Handling Systems. I have worked for the
U.S.EPA as a consultant and advisor on numerous projects involving regulatory
impact analysis and other related assignments concerning solid and hazardous waste
regulatory development. I also presented a series of workshops entitled Medical and
Institutional Waste Incineration for the U.S.EPA Center for Environmental Research
Information.
The following sections include general and specific review comments to the seven (7)
Medical Waste Incinerators Background Documents.
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
H. GENERAL COMMENTS
In general, the overall approach used in compiling the background information and
establishing a methodology and modeling procedure for evaluating technical,
economical and environmental impacts is very commendable. This was obviously a
very difficult assignment, particularly in light of the large data gaps, technical
complexities, wide variations in medical waste incinerator applications and designs,
and the inherent difficulties in consolidating meaningful and useful data from different
vendors and facilities. With the exception of some of the comments presented herein,
it appears that the general framework presented in the documents is very useful for
supporting regulatory decisions in development of the proposed regulations.
Based upon our extensive experience and numerous projects involving medical waste
incineration and related impact analyses, we basically agree and endorse the bottom
line conclusion that the environmental impacts of medical waste incineration are
negligible and well below threshold levels. As summarized in the Background Paper
document, "the environmental impacts for the pollutants of concern have shown to be
less than 15% of welfare health effect levels" without add-on emission controls. We
have performed similar, independent analyses and have come to the same conclusion,
with exception to site-specific conditions, particularly in urban and high-rise areas.
Specific comments to each of the background documents are included in Section III of
this submission. The following are general comments pertaining to all of the
documents:
1. Inconsistencies
There are inconsistencies in terminologies and various details between the
different documents. For example, terms such as medical waste, infectious
waste and red bag waste are used in different fashions and interchangeably in
different documents.
2. Medical Waste
There appear to be inconsistencies and general inaccuracies in the various
discussions and definitions pertaining to medical waste. In addition, medical
waste composition and the differences between medical and potentially
infectious waste appear to be incorrect in several documents.
-3-
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
The introduction of the Industry Profile Report appears to leave an impression
that there are undue health hazards associated with medical/infectious waste
disposal. Such references should either be deleted or clarified to show that
such health hazards are far more perceptual than realistic.
3. "Pathological Incinerator"
Throughout all of the documents, it is assumed that a "pathological
incinerator" is a type or category of incinerator. This is an incorrect
assumption. Any incinerator that burns pathological waste could be
categorized as a pathological incinerator. Conversely, pathological waste can
be burned in any of the more conventional medical waste incinerators (i.e.,
multiple-chamber, controlled-air or rotary kiln) given proper design conditions.
4. Pathogens
In several of the documents there appear to be unnecessary, undue stress on
"pathogens" and "pathogen destruction" as related to medical waste and
medical waste combustion. Medical and scientific data clearly show that
pathogens (and all other microorganisms) are destroyed almost instantaneously
at temperatures that even poorly designed incinerators are operated at. A
Thermal Death Time Curve is included to illustrate this point in Section III.
All references that the "goal" of good combustion includes pathogen
destruction should be deleted.
5. Alternative Technologies and Options
The documents which discuss alternative medical waste treatment technologies
is incomplete, outdated and contains several major inaccuracies. This seems to
have lead to various unrealistic projections and conclusions as to the viabilities
of potential alternatives and options for medical waste generators.
6. Incinerator Capacity and Sizing Categories
The various documents appear to indicate unrealistic capacity ranges for
various incinerator types. For example, 50 Ib/hr is repeatedly shown as a
viable capacity for intermittent-duty operations. This is not a possible mode of
operation for a system this small. In addition, other references are made to
unrealistic medical waste incinerator capacities of "5000 Ib/hr" and "6590 Ib/hr."
4 -
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
It further appears that the categories of incinerator sizes, i.e., small, medium
and large, have been established on the basis of daily rather than hourly
capacities. Tiering of incinerator size should be based on hourly capacity, as
is done by all states which regulate medical waste incinerators under a tiering
system. It appears that the selection of sizing categories based on daily
capacity may have lead to erroneous conclusions as to what is the MACT floor
level for large capacity systems. It is recommended that such categories be
redefined on the basis of hourly capacity.
7. Incomplete Data
It appears that data are not complete in various documents, particularly as
needed for establishing economic analysis and baseline emission levels.
Specifics of apparently incomplete data are identified in Section III comments.
8. Technical Inaccuracies and Inconsistencies
There are various technical items throughout the documents relating to
incineration systems and air pollution control technologies which appear
inaccurate or incomplete. Specifics have been noted and identified in Section
III comments.
9. Projections
Several documents include projected future scenarios or trends with respect to
incinerator installations and the selection of various treatment and disposal
options by medical waste generators. Unfortunately, these projections do not
account for actual events which have been occurring over the last several
years, and they also do not account for various other key factors such as
public opposition to incinerators and state regulatory restrictions which have,
in effect, eliminated medical waste incineration as a viable technology for
many hospitals.
10. Incinerator Retrofitting
The document sections relating to the difficulties and costs of upgrading and/or
retrofitting medical waste incinerators appear to be generally incomplete and
inaccurate. For example, stated assumptions that upgrading will be equally as
difficult and costly as adding a new installation are not supported by real data.
-5
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
11. Emission Removal Efficiencies
Several of the documents appear to have inaccurate assumptions with respect
to pollutant removal efficiencies, particularly for TCDD and HC1.
12. Assumptions for "GOOD Combustion Control"
The assumption that "a minimum secondary chamber residence time of 2
seconds" is the criteria for GOOD Combustion Control is improper and
unjustified. Two seconds is basically an arbitrary value. Data do not support
that two seconds provides any better performance than one second or less. In
fact, the vast majority of state environmental agencies have established a one
second residence time as being the regulatory requirement. Many incinerator
manufacturers can provide superior performance with one second residence
time because of their system design features which provide excellent
turbulence. It is strongly recommended that a residence time of one second be
selected as the basis of GOOD Combustion Control.
Another assumption which appears to be unjustified is that secondary chamber
temperature should be not less than 1800°F. Test data clearly have shown that
well designed and properly operated medical waste incinerators can have
secondary chamber temperatures in the range of 1600°F to 2000°F without
significant differences in CO and trace organic (CDD/CDF) emissions. It is,
therefore, also strongly recommended that 1600°F be used as the criteria for
GOOD Combustion Control rather than 1800°F.
13. Recommended Regulatory Alternative
The Background Paper document concludes that Regulatory Alternative in is
the best or recommended option. We do not believe that this conclusion is
valid, particularly for large size facilities. As discussed above, the large size
facilities have apparently been categorized on the basis of daily, rather than
hourly, capacity. This appears to have lead to an erroneous determination of
the MACT floor for these. We believe that the best alternative should be one
that is not presented in the documents, namely, BASELINE for small systems,
BASELINE for medium systems and BETTER for large systems (instead of
BEST). BEST is an excessive Control Option for even large medical waste
incinerators, as it exceeds BACT. There are very few systems with this
degree of control and appreciable operating experience. Limited data have
-6-
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
shown that a wet venturi scrubber with packed tower, as defined under the
BETTER Control Option, can achieve the same levels of acid gas and metals
control as a dry injection scrubber.
14. Partial Benefit Analyses
The cost to benefit ratio documented in the Background Paper is shown to
range between 130 to 1 for Control Option 1, to 617 to 1 for Control Option
3. This is such a tremendously wide ratio that it leads us to question as to
how this will be used in selecting or determining regulatory levels under
MACT.
-7-
DOUCET & MAINKA, P.C.
Consulting Engineers
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III. SPECIFIC COMMENTS
The following include specific comments to each of the seven
Medical Waste Incinerators Background Documents
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.0 COMMENTS TO DOCUMENT TITLED INDUSTRY PROFILE REPORT FOR
NEW AND EXISTING FACILITIES
1.1 Page 1, Second Paragraph
It should be noted that although "improper disposal can lead to public exposure to
(potentially) infectious organisms," there appears to be no documentation or evidence
that any such improper disposal has led to the spread of infection in the general public
or created any undue public health hazards.
1.2 Page 3, Table 1
Column 3 denotes "Annual infectious waste generated, tons" this should be changed
to "regulated medical" waste or "potentially infectious waste" or "medical waste".
"Infectious waste" is an improper term since only a tiny fraction of medical waste is
infectious or even potentially infectious.
1.3 Page 5, First Paragraph, Last Sentence
It is unclear as to why the "nonmedical portion of the waste stream is assumed to be
small." Depending on definitions, for many healthcare facilities the nonmedical
portion of the waste stream is larger than the medical waste stream. On a weight
basis, dietary waste from hospitals may be the largest fraction.
1.4 Page 5, Last Paragraph
The discussion of incinerating "pathological waste" is very confusing. "Human and
pathological remains and tissue" are defined as pathological waste. Therefore, what
does it mean that incinerator emissions from these would be "substantially similar" to
those from pathological waste incineration?
1.5 Page 6, First Paragraph
The statement that "all materials that make the medical waste stream unique from
other solid waste in terms of air pollutant emissions" appears to be incorrect or
confusing. Medical waste stream components are identical to those from the general
solid waste stream. Only the percentages of the component may vary and a small
fraction may be contaminated with blood or body fluids. Some studies have shown
that residential waste may have even higher pathogenic contamination than most
hospital waste streams.
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.6 Page 8, first Paragraph
The first sentence describing medical waste materials generated by hospitals is
incorrect. Medical waste is a heterogenous mixture of components such as paper,
plastics, cloth, etc. It may also contain a small fraction of pathological waste.
Laboratory and pharmaceutical chemicals are not, by definition, medical waste,
although most medical facilities generate such materials. By definition, medical waste
also does not contain low-level radioactive waste even though it is generated at some
medical facilities.
1.7 Page 8, Second Paragraph
The percentage of the waste stream that may be classified as potentially infectious
also depends to a large extent on parameters other than those listed. For example,
state regulations have substantially more of an impact than the listed federal
regulations and guidelines. Also, a facility's waste management policies and
protocols may dictate that a large percentage of its waste be managed and disposed of
as "potentially infectious."
1.8 Page 10, Second Paragraph
This is a confusing paragraph. Most definitions state that medical waste is the total
waste generated from medical and healthcare facilities. Therefore, under such a
definition, "total waste stream" is the same as "medical waste stream." Also,
references should be made to the percentage of medical waste that is "potentially
infectious or considered potentially infectious" "not infectious". Finally, on what
basis can it be assumed that the "total waste generated by other facilities is the same
as that of hospitals"?
1.9 Page 13, Second Paragraph - "Incineration"
It is incorrect to state that modern incineration systems are operated at high
temperatures (between 1100 and 2000°F) "to kill infectious agents." Infectious agents
can be killed at much lower temperatures.
1 2
DOUCET&MAINKA,P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.10 Page 13, Third Paragraph - "Steam Sterilization"
Steam sterilization is an inappropriate term for autoclaves. Steam autoclaves do not
routinely demonstrate sterilization when treating medical waste.
1.11 Page 13, Last Paragraph - "Thermal Inactivation"
This is not a viable, widely used or commercially available treatment technology for
medical waste.
1.12 Page 14, Third Paragraph - "Gas Sterilization"
Gas sterilization is not a viable medical waste treatment technology at this time.
Also, it would fall under the category of a chemical disinfection system.
1.13 Page 14, Last Paragraph - "Irradiation Sterilization"
This discussion should also include electron beam radiation which is currently being
developed. The radio frequency "irradiation treatment" referred to is basically a
thermal treatment method similar to microwaves. Ultraviolet radiation is not viable
for treating medical waste.
1.14 Page 15, Third Paragraph - "Microwave Sterilization"
This should be categorized as a thermal treatment process since the microwaves are
used to heat water to 205 °F in order to provide thermal inactivation of microbes for
disinfection. It does not provide sterilization.
1.15 Page 15, Last Paragraph - "Radiofrequency Sterilization"
The Stericycle commercial facility is located in West Memphis, Arkansas, not
"Schaumburg, Illinois." Furthermore, data is not available to demonstrate that this
technology provides sterilization.
1.16 Page 16, First Paragraph, Second to the Last Sentence
Incineration is not considered to be in the same category as grinding and shredding.
It is also not considered a physical destruction process but a combustion process.
1-3
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.17 Page 18, First Paragraph
What is the basis for assuming that "the infectious waste component of the total waste
generated at other facilities is the same as that of hospitals"? Data does not appear to
support this.
1.18 Page 24, Third Paragraph
There is no possible way that "up to 10% of medical waste can be radioactive." For
virtually all medical waste generators, radioactive waste percentages are likely to be
one or two orders of magnitude less than this.
1.19 Page 26, Third Paragraph - "Trends"
It is believed that current data do not support the statement, "the quantity of waste
generated at hospitals has been rising in recent years." The referenced document is
more than ten years old.
1.19 Page 32, Table 9
The table showing percentages of facilities using specified off-site treatment methods
appears confusing because the total percentages are greater than 100% in several
columns.
1.20 Page 60, Table 11
It appears that the "average years" was determined on the basis of an average of the
"range" of years for different incinerator units for most, if not all, of the facilities. If
so, this is an inappropriate basis for assuming the averages.
1.21 Page 65, Second Paragraph (and others)
There are extensive discussions in this and the other documents as to the affect that
"pathological incinerators" are a type of incinerator comparable to controlled air,
rotary kiln and multiple-chamber incinerators. This is not true. Any incinerator can
be a pathological waste incinerator if it burns pathological waste. Pathological
incinerators are not categories or types of incinerators.
1 -4
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.22 Page 65, Third Paragraph
It seems incredible that it was not possible to "locate an excess-air incinerator."
There are countless multiple-chamber, excess-air type incinerators in operation at
hospitals throughout the country.
1.23 Page 66, Table 13
As noted above in Item 1.21, "pathological" is not a type of incinerator or combustor
but is a type of waste. A controlled air incinerator would be a pathological
incinerator if it were designed to burn pathological waste.
1.24 Page 69, Second Paragraph
The first sentence does not appear to be correct. Although some hospitals may accept
small quantities of medical waste for disposal in their incineration systems, it is not
believed to be a "common" practice because of potential liabilities that hospitals can
incur and because of state and local regulations and restrictions.
1.25 Page 70, Top Paragraph
It is recommended that better classification be provided between "operating hours"
and waste loading hours. Some incinerators may be "operated" for many hours per
day (per week) but with actual waste loading taking place for only a fraction of the
total operating time. Does "operation" mean time that the equipment is running (from
pre-heat through shutdown) or the time that the system is actually loaded with waste?
1.26 Page 77, Second Paragraph - "Trends"
The scenario or projections described in this section do not take into account realities
and actual trends that have taken place over the last several years. There have not
been an increasing number of large on-site incinerators constructed because of public
opposition, siting difficulties and alternative technologies which seem to be drawing
great interest. Also, few if any, consortia of hospitals have been successful in siting
regional incineration facilities for their membership/participants as either a means of
taking care of their own waste or having a commercial operation as a revenue
generator.
1 -5
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATION BACKGROUND DOCUMENTS (9/30/91)
1.27 Page 79, Fourth Paragraph
The indicated projected sales do not appear realistic in view of increased public
opposition, costs and regulatory restrictions for incinerators. It is also questionable
that the projection and sales data provided by the MWI vendors is realistic,
considering that two of the largest and oldest major vendors (Consumat and Joy) are
reportedly on the market for sale due to declining sales of their equipment.
"Pathological units, again, are not a category of an incinerator." "50 Ib/hr" is not a
realistic or viable capacity for a medical waste incinerator.
1.28 Page 82, Last Paragraph
It does not appear to be a correct statement that "reconstruction of existing units . . .
is impractical in light of improvements and incinerator technology." Economic
factors and regulatory benefits often make incinerator reconstruction/upgrading and
retrofitting to be a preferred option as compared to replacement for many hospitals.
1 -6
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
2.0 COMMENTS TO DOCUMENT TITLED PROCESS DESCRIPTION/BASELINE
EMISSIONS REPORT FOR NEW AND EXISTING FACILITIES
2.1 Page 3, Second Paragraph, Last Sentence
"Pathogen destruction" is not a characteristic of "acceptable ash." Rarely are
pathogens detected in the ash from medical waste incinerators. More appropriate
characterization includes metals.
2.2 Page 3, Last Paragraph
It is not correct to state that the "goal of the (combustion) process is to achieve ...
destruction of pathogens in the waste." Pathogens will be destroyed at much lower
temperatures than even the most poorly operated incinerators. Pathogens will
inherently be destroyed by good combustion processes, and therefore "pathogen
destruction" is not a "goal" of combustion.
2.3 Page 9, Top Paragraph
As with other discussions throughout this document, "medical waste" is erroneously
assumed to be identical or synonymous to "infectious" waste. Also, this paragraph
indicates that "carefulness" is the key to segregation and minimization, but waste
management protocols and their administration are far more important parameters.
2.4 Page 12, Second Paragraph
This paragraph does not appear to be correct. There is no particular reason why the
degree of segregation of medical waste is likely to be greater when the waste is to be
shipped off-site for treatment. In many cases, the degree of segregation for facilities
shipping waste off-site is much less in order to minimize burdens, potential problems
and costs associated with increased rigid segregation. Furthermore, there is no reason
why the "characteristics" of the waste shipped off-site should be typically different
from those medical wastes treated on-site.
2- 1
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
2.5 Page 14, Table 3
As discussed, "pathological" is not a type of incinerator.
Many rotary kiln incinerators are operated on an intermittent basis when burning
medical waste.
Virtually all rotary kiln incinerators are designed to operate with excess-air levels in
the primary chamber. Rarely, if ever, are they operated under substoichiometric
conditions.
2.6 Page 15, 3rd Paragraph, Last Sentence
This is not a true statement. Waste/ash is moved in smaller units via the charging
ram of the loader.
2.7 Page 15, Last Paragraph
All incinerators are "capable of treating both infectious and non-infectious wastes."
There are no differences in the basic waste characteristics of these two categories.
2.8 Page 16, Top Paragraph
As discussed above, there is no such thing as a "pathological system." Any
incinerator that burns pathological waste can appropriately be termed a pathological
incinerator.
2.9 Page 17, Table 4
It does not seem possible that an intermittent-duty incinerator can have a capacity of
as low as 50 Ib/hr. The lower range of this mode of operation is typically about
200 300 Ib/hr. In addition, we do not believe there are any controlled air
incinerators with a design capacity anywhere near "6,590 Ib/hr" particularly for
burning medical waste.
2.10 Page 18, Figure 2
Primary and secondary combustion air are not shown on the diagram.
2-2
DOUCET & MAINKA, P.C.
f Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
2.11 Page 19, Second Paragraph
Intermittent-duty incinerators do not have "an operating cycle of 24 hours" or less.
They are always less than 24 hours.
2.12 Page 21, Figure 3
What is the difference between this and Figure 2? Also, primary and secondary air
are not shown.
2.13 Page 22, Figure 4
An automatic ash removal system is not shown. Also primary and secondary air are
not shown.
2.14 Page 23, Second Paragraph
As discussed, rotary kilns are not operated under substoichiometric conditions,
particularly when burning medical wastes. This combustion mode was tried several
years ago and failed. Virtually all rotary kilns are operated under excess-air
conditions.
2.15 Page 26, Second Paragraph - "Pathological Systems"
Again, there is no such category as a "pathological incinerator".
2.16 Page 27, Second Paragraph - "Retort Hearth System"
This discussion relates to a type of multiple-chamber incinerator. On-line type
multiple-chamber incinerators are also used for burning pathological waste.
2.17 Page 31, Figure 8
Provide proper reference and credit for figure. This was prepared by Lawrence G.
Doucet for the NFPA Fire Protection Handbook, 16th Edition, Section 12/Chapter 14,
pp. 12- 116.
2 3
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
2.18 Page 33, Last Paragraph
Mechanical grate stokers are not appropriate for medical waste incineration because of
leakage and spillage of unburned materials through the grates.
2.19 Page 34, Figure 9
The schematic is incorrect in that an automatic ash removal system is needed for an
incinerator with a transfer ram.
2.20 Page 46, Third Paragraph - "Fugitive Emissions"
Because of typical high temperature operating conditions, "pathogens" are not usually
considered a type of fugitive emissions from medical waste incinerators. Also
"poorly ventilated areas" do not typically contribute to fugitive emissions. Moreover,
mechanical loading systems do not compact the waste with such force as to cause
aerosolization problems.
2.21 Page 49, Last Paragraph
It is an incorrect statement that secondary chamber retention time is a key criteria for
pathogen destruction. At even moderate operating temperatures, say as little as
1400°F to 1600°F, microorganisms are destroyed almost instantaneously.
2.22 Page 53, First Paragraph - "Uncontrolled Emissions"
It is not clear that uncontrolled (and controlled) emissions data reported and used in
this and the other documents incorporate all of the available data, including the latest
CARB test reports and the U.S.EPA "Hospital Waste Combustion Study of December
1988" data. It appears that it does not since only seven facilities are shown in
subsequent tables and documents.
2-4
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
3.0 COMMENTS TO DOCUMENT TITLED MODEL PLANT DESCRIPTION AND
COST REPORT FOR NEW AND EXISTING FACILITIES
3.1 Page 4, Third Paragraph - "Design"
As discussed, "pathological" is not a medical waste incinerator "design." Any
incinerator that burns pathological waste is a pathological waste incinerator.
"Red bag" is used as a synonym for "infectious waste;" however, this term has not
been previously discussed or defined.
It is improper to assume that both "red bag and general waste" have an average
heating value of 8500 Btu/lb. First of all, it is not likely that both wastes have the
same heating value because segregated "red bag waste" tends to have higher plastic
percentages. Also, many studies have shown that general hospital waste has heating
values closer to 7000 - 7500 Btu/lb.
It is improper to assume that all pathological waste has a heating value of only 1000
Btu/lb. Pathological waste often has heating values substantially greater than 1000
Btu/lb. This also contradicts the data shown in the document entitled, "Process
Description/Baseline" Table 2B, Page 8, which shows pathological animals with
heating values as high as 6400 Btu/lb and human remains as high as 3600 Btu/lb.
3.2 Page 4, Last Paragraph
Intermittent-duty operating cycles, by definition, are not as long as 24 hours per day.
3.3 Page 5, Top Paragraph
The statement that "although no units are known to operate with an auger feeder ..."
does not appear to have meaning and does not appear to be correct.
3.4 Page 6, Top Paragraph
Rotary kiln incinerators may also be designed for intermittent operations, as many have.
3- 1
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
3.5 Page 6, Last Paragraph
A 50 Ib/hr capacity is not realistic for an intermittent incineration operation.
3.6 Page 7, Second Paragraph
Hospitals do not use (and have not used) 5000 Ib/hr incinerators. Also, it is doubtful
that controlled air incinerators of this capacity are standardly available.
3.7 Page 8, Middle Paragraph
We believe that there are no operational rotary kiln incinerators with 350 Ib/hr
capacities burning medical waste at hospitals.
3.8 Page 10, Middle Paragraph
See comments to Item 3.1, above, with respect to heating values.
3.9 Page 11, Top Paragraph
See comments to Item 3.1, above, with respect to heating values.
3.10 Page 12, Next to the Last Paragraph
Almost all waste heat boilers at medical waste incinerator facilities are designed for
low pressure steam recovery - 15 psig saturated. A 110 psig steam pressure is not
typical.
3.11 Page 16, Second Paragraph
The indicated excess air levels are not correct for most medical waste incinerators.
Most operate with 200% excess air, not "200% theoretical air." 100% excess air (or
200% theoretical air) is too low - temperatures and emissions would likely be excessive.
3.12 Page 17, Second Paragraph
Virtually no existing older units have secondary chamber retention times of "0 seconds."
3-2
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
3.13 Page 18, Last Paragraph
Clarification should be provided with respect to definition of operating hours
compared to loading hours. For example, the "10 to 12 hours per day operations"
referred to may be either times of loading or times when equipment is running both
with and without loading.
3.14 Page 25, Second Paragraph
It is inappropriate to assume that "a minimum secondary chamber residence time of 2
seconds" is a criteria for "GOOD combustion control." Two seconds is an arbitrary
number and does not take into account parameters such as turbulence and
temperature. Some manufacturers have retention times of much shorter, one second
or less, and achieve superior performance with their secondary chamber designs as
compared to other manufacturers' systems having much longer retention times.
Simply put, data does not support two seconds as being better than one second in
terms of combustion performance, but the costs and other impacts are substantial.
One second minimum should be selected as the basis for "GOOD emission controls."
3.15 Page 30, Third Paragraph - "Process and Control Costs"
Major cost items which do not appear factored into this (and other economic sections)
include costs for performance, compliance and emission testing; permitting and risk
assessment analyses; and engineering and design fees.
3.16 Page 48, Fifth Paragraph - "Ash Disposal"
Costs for ash sampling and analysis should also be accounted for.
3.17 Page 50, Fourth Paragraph - "Capital Recovery"
Medical waste incineration systems do not typically have a 20 year life expectancy.
We believe a 15 year life is a better and more realistic value.
3 -3
DOUCET & MAINKA, P.C.
T Consulting Engineers
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REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
3.18 Page 50, Next to the Last Paragraph - "Operating Labor"
Incinerator operating labor costs should not be calculated at a fraction of their time
because most systems require a full time operator and supervisory attention. The full
operating labor costs must be accounted for. Also, a $12.00 per hour operator wage
rate appears low considering that overhead and benefits must also be accounted for.
Requirements for trained and certified operators are also driving up costs.
3.19 Page 52, Top Paragraph - "Total Annual Costs"
Annual costs for such items as retesting, recertification, operator training updates and
environmental agency compliance are major and should be accounted for. Also, costs
for times when incinerators are down and waste needs to be disposed by off-site
contractors (at high cost) are major and should be added.
3.20 Page 55, Third Paragraph - "Operating Labor"
See comments to Item 3.18, above.
3.21 Page 61, Third Paragraph - "Operating Labor"
See comments to Item 3.18, above.
3.22 Page 68, Top Paragraph
Many controlled air incinerators installed more than 5 years ago have retention times
greater than 0.25 seconds. This is an exceptionally low value to assume.
3.23 Page 68, Third Paragraph
It is wrong to assume that a "gas retention time of 0.25 seconds is appropriate for
retorts because they are old." This type of multiple-chamber incinerator inherently
has retention times of greater than one second because of its box-like configuration.
3.24 Page 69, Second Paragraph
It is improper to assume "down time costs are negligible to APCD retrofits because
most existing medical waste incinerators are outdoors." First of all, we believe it is
not true that most hospitals have medical waste incinerators located outdoors.
3-4
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
Secondly, there will be down times associated with making mechanical and electrical
connections during the refrofit work which are not "negligible."
3.25 Page 70, Third Paragraph
An "average disposal cost of 30C/lb" for commercial facilities appears very low.
What is the source for this? We believe the average unit costs are much higher,
particularly when also considering packaging and manifesting costs.
3.26 Page 71, First Paragraph
It is improper to assume that the cost for retrofitting an existing incinerator with an
APCD is the same as for installing an APCD at a new facility. Retrofitting costs are
almost always much higher.
3.27 Page 72, First Paragraph
It is improper to assume additional building and related general construction costs
would be the same for existing and new units. Retrofitting costs are substantially
higher when an APCD is located outside, particularly for hospitals which typically use
wet scrubbers, since a building enclosure is needed (for weather protection) which
should be accounted for.
3.28 Page 74, Third Paragraph - "Annual Costs"
Off-site disposal costs must be incurred during periods when incinerators are down
for repairs and during retrofitting work. These may be substantial and should be
included.
3.29 Page 78, Third Paragraph
It does not appear that all available emissions data have been accounted for in
establishing baseline and controlled emission limits data and criteria.
3.30 Page 80, Last Paragraph
Again, two seconds is an arbitrary retention time, and it is not particularly indicative
of or necessary for "GOOD emission control." One second would be more
appropriate.
3-5
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
3.31 Page 81, Second Paragraph
It is a false statement that "CDD/CDF are not effected by add-on controls."
Substantial data show that lower APCD temperatures achieve higher removal
efficiencies for these pollutants (for reference see attached Figures 1 and 2).
3.32 Page 81, Third Paragraph
It is a misleading statement that "no test data indicates what emission limit can be
achieved by a 50-in. w.c. (as compared to 30-in. w.c.)." It is well documented that
higher venturi pressure drops provide higher removal efficiencies.
3.33 Pages 83-89 - "Purchase Equipment Costs" Curves
The data in these appear very questionable. For example, the cost for a 1000 Ib/hr
controlled air incinerator is only about $130,000 (Page 83), but the cost for a
1000 Ib/hr rotary kiln incinerator is about $1.6 million (page 86). There is simply
not a ten-fold differential in costs for these units.
3.34 Page 107 - "Primary Chamber Volumes" Curve
The basis for this curve is not clear. There are standard engineering criteria used for
determining optimum primary chamber volumes.
3-6
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
FIGURE 1
Effect of Pollution Control Device
Temperature on Hospital Incinerator
Emissions
•o
•
m
E
E
C
en
o
c
C
_0
"co
o
UJ
c
ra
DIOXINS AND FURANS
Stack Temperature °F
450
373
W7
1IJ f
10000
10OO -
100 •
f i- SETTER HOSPITAL
{
!
I
"V
\
\
v
\
s
— -*q
4TOTAJ.DOXU
QTOTALRJFVJ
2.3.7.3 Isorr
•
\
\
— f
^
\
\
,PC •
^
n
iir
STM.
K
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^
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]
VfS
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1
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-v-i —
xl
s
k S
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\
^
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|
»V
\
X
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\
\
\
\
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I
-HOi
\1
*=CR
•JfTA
•
L' .
1.0 1.1 I.J 1.3 1.4 1.1 t.« 1.
1/AbsoIute Temperature x 1000 (1/*R)
1000
100
10
E
ra
CT
O
c/l
C
E
UJ
X
O
Data Source - correlated from California Air Board reports, 1987 and 1988
3 7
DOUCET & MAINKA, RC.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
FIGURE 2
Effect of Pollution Control Device
Temperature on Hospital Incinerator
Emissions
tow
X
u_
CO '00
o
VI
c
E
LU TO
5
OJ
CO
o
HEAVY METALS
Stack Temperature °F
450 373
SUTTER HOSPITAL
304
I
207 U3 f
CEDARS HOSPfTAL
•Irort •
i CtdtrJum
• S TAHFOPO H3SPITM.
t.O l.t 1.2 1.3 1.4 1.5 1.« 1.7
1/AbsoIute Temperature x 1000 (1/°R )
Data Source - correlated from California Air Board reports, 1987 and 1988
3 8
DOUCET & MAINKA, RC.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
4.0 COMMENTS TO DOCUMENT TITLED CONTROL TECHNOLOGY
PERFORMANCE REPORT FOR NEW AND EXISTING FACILITIES
4.1 Page 3, First Paragraph
As discussed, the "goal" of the combustion process does not encompass "destruction
of pathogens."
4.2 Page 3, Third Paragraph
As discussed, by definition, laboratory and pharmaceutical chemicals are not medical
waste, although they are generated from most medical facilities.
4.3 Page 5, Sixth Paragraph, Item 5
This is a misleading statement. Pathogens are destroyed almost instantaneously in
incinerators and are not, in effect, partitioned between ash and exhaust gas.
4.4 Page 10, Second Paragraph
Again, this is a misleading discussion. The high temperatures and turbulent
conditions described are important for good combustion but do not necessarily relate
to pathogen destruction. Pathogens will be almost instantaneously destroyed at much
lower temperatures and retention times.
4.5 Page 12, First Paragraph, Last Sentence
Again, misleading. The water vapor from the combustion process will not
significantly affect pathogen destruction in incinerators.
4.6 Page 14, Next to the Last Paragraph
See comments to Item 4.4, above.
4.7 Page 16, Last Paragraph
See comments to Item 4.4, above.
4 1
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
4.8 Page 20, First Paragraph
This is an incorrect statement and a poor reference. Numerous scientific studies
clearly show that pathogens are destroyed almost instantaneously at even moderate to
low incineration temperatures. For example, a typical Thermal Death Time Curve is
shown on page 4-3. The reference documents by Barbeito, et al, are old and based
upon non-scientific sampling and testing conditions.
4.9 Page 22, First Paragraph
Again, a secondary chamber temperature of 1700°F to 2200°F is not needed to
"promote effective destruction of pathogens."
4.10 Page 28, Third Paragraph
The need and numbers of transfer rams and hearths are not a function of incinerator
modernization but incinerator size. Simply, larger systems require more hearths and
rams.
4.11 Page 29, First Sentence
We believe data is available to support that pulse hearth systems provide excellent ash
quality. I am sure that the manufacturer would make such data available, if
requested.
4.12 Page 46, Third Paragraph, Last Sentence
Scrubber liquid pH is typically maintained at greater than 7.0, not less.
4.13 Page 104, Table 2B
The indicated data for a dry lime injection system appears to require explanation. For
example, TCDD outlet concentrations are higher than inlet concentrations. How can
this be?
4.14 Page 119, Second Paragraph
Bacillus stearothermophilus spores are used for testing pathogen destruction efficiency
not because they protect exposures to lab personnel, but because they are very heat
resistant and their destruction indicates that other less heat resistant microorganisms
are destroyed.
DOUCET & MAINKA, P.C.
4 2 Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
TYPICAL THERMAL DEATH TIME CURVE
100
«•
3 10
c
•~
^
^
1
o 1.0
E
*
t—
— ^
^ —
\^
K
*\
x
1 — i
X
. = 1
•
•
x^
s
uu-
D<
Si
\
9 !
J 1
( t ru
r vi v
^X
cti
ral
^•^
on .
"X^
\^
X
240 250 260 270
Temperature — °F.
280
Thermal Death Time Curve with survival and destruction times
plotted against temperature of moist heat. z = 20°F(11.2°F).
The curve passes through 9 minutes at 250°F.
B. stearothermophilus at 100,000 population of dried spores.
Ref: Principles and Methods of Sterilization in Health Sciences, John J. Perkins,
M.S., LL.D., F.R.S.H., Second Edition.
DOUCET & MAINKA, RC.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
5.0 COMMENTS TO DOCUMENT TITLED ENVIRONMENTAL IMPACTS
REPORT FOR NEW AND EXISTING FACILITIES
5.1 Page 2, Second Paragraph
The definition of baseline emission levels is confusing. Baseline is stated to "reflect
the level of emissions in the absence of any federal regulations for medical waste
incinerators." The fact is there are no existing federal regulations for medical waste
incinerators. Therefore, why wouldn't all the data reported in all of the available
studies and test reports (including all of the CARB reports and the Hospital Waste
Combustion Study) be used as the baseline? Virtually any medical waste incinerator
that operates today with objectional emissions or continual smoking because of poor
combustion would be literally forced to shut down due to regulations and public
opposition. Therefore, by and large, baseline data for all existing facilities are valid.
5.2 Page 3, Last Paragraph
It is not clear why Control Option 2 was determined to need a particulate emission
limit of 0.015 gr/dscf. Why wasn't a level of, say, 0.03 gr/dscf selected? We
believe that 0.03 gr/dscf is more indicative of BACT for small and medium capacity
medical waste incinerators. Furthermore, we believe that 0.015 gr/dscf exceeds
BACT for such systems and data suggests that it is not routinely achievable without
costly and very specialized wet scrubber system designs.
5.3 Page 4, Fourth Paragraph
Data appear to clearly support the statement that lower flue gas temperatures provide
higher removal efficiencies for CDD and CDF. Since wet scrubbers provide lower
temperatures than dry scrubbers, shouldn't CDD and CDF removal efficiencies be
higher for Control Option 2?
5.4 Page 4, Next to the Last Paragraph
Wet scrubbers typically provide HC1 removal efficiencies of 99%. Therefore,
Control Option 2, with wet scrubbers, should be assumed to have higher HC1 removal
than dry scrubbers under Option 3.
5 1
DOUCET & MAINKA, P.C.
, Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
5.5 Page 6, Third Paragraph
It does not appear practical or beneficial to consider ambient impacts at a distance as
great as 20 kilometers from the stack due to the large volume of data needed for such
an analysis.
5.6 Page 6, Fifth Paragraph
Although it is understandably difficult to assume "average" meteorological conditions,
it is questionable whether average data between Pittsburgh and San Bernardino are
truly representative of extreme scenarios, and it appears unclear as to how these were
used to determine "average" conditions. Also, are these representative of conditions
in urban and metropolitan areas such as New York City?
5.7 Page 7, Third Paragraph - "Secondary Emissions"
For comparative purposes and completeness, it is recommended that emissions from
transport vehicles engaged in off-site transport and disposal of waste and ash be
included.
5.8 Page 15, Last Paragraph - "Energy Impacts"
It is improper to assume that "additional auxiliary fuel is used to maintain the
secondary chamber temperature at 1800°F." For all but pathological waste, such
temperature can usually be maintained with excess air reductions and with no
additional fuel.
5.9 Page 16, Third Paragraph
It appears to be an erroneous statement that the "additional fuel usage over baseline is
the same for ... both mixed medical and pathological waste." There are substantial
differences in auxiliary fuel requirements between these two waste types.
5.10 Page 27, Table 4 (and all other related references)
Some of the indicated baseline emission limits do not appear to be realistic. For
example, 300 ppmv of CO is an exceptionally high level. Most existing medical
waste incinerators achieve emission limits well below this level. In addition, the
indicated 1460 ppmv of HC1 seems very high. Available data seems to indicate that
5 2
DOUCET & MAINKA, P.C.
•y Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
900 ppmv is the highest level, and much data indicate that most HC1 levels are
substantially less than this.
5.11 Page 34, Table 10 - "Model Plant Parameters"
This table summarizes stack and building parameters used for stack modeling and
health risk assessments. However, this appears to show that Good Engineering
Practice (GEP) stack height was not taken into account. It appears particularly
troublesome that the stack heights for Model Plants C.I and C.2 are less than their
associated building heights.
5 3
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
6.0 COMMENTS TO DOCUMENT TITLED ANALYSIS OF ECONOMIC IMPACTS
FOR EXISTING SOURCES
6.1 Page 2, Last Paragraph
We believe it is an incorrect statement that "off-site contract disposal is generally less
expensive than operating a small medical waste incinerator." We have undertaken
numerous economic evaluations of such comparisons and, in the vast majority of
cases, on-site incineration is substantially more cost-effective than off-site contract
disposal. Payback periods for on-site facilities are, in most cases, less than five
years.
6.2 Pages 3 and 4
The discussions of "substitution alternatives" does not appear to be based on reality or
current trends. For example, many, if not most, hospitals do not have the alternatives
readily available to them to find substitutions to on-site incineration or other more
cost effective on-site and off-site disposal options. There appears to be a scarcity of
off-site incineration (disposal) capacity and availability. Many hospitals are unable to
obtain competitive prices for contract disposal services and are often unable to assure
that they are sending their waste to a reliable off-site disposal contractor. It is not
correct to assume, for example, as stated on page 4, that hospitals will have an option
to switch from a small to a large commercial incinerator. It is not foreseeable that
this option will ever be available to any significant extent. Other factors and impacts
which work against the posed theory of "substitution alternatives" include public
opposition to both on-site and off-site incineration; uncertainties in the status,
developments and acceptabilities of alternative technologies; and regulatory
restrictions dealing with incineration and alternative technologies. It seems that
economic factors and their respective "elasticities" currently have minimal impact in
connection with the selection of an on-site or off-site treatment and disposal
alternative for most facilities.
6.3 Page 6, Last Paragraph
The category identified as "other/unidentified facilities" is significant and should be
further described or explained.
It is recommended that more explanation and source data be provided as to the 31
facilities indicated to be co-firing medical waste. Does this include MSW incineration
6 1
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
facilities? If so, this is not an insignificant number. The plant at Hampton, South
Carolina, for example, is permitted to process between 30 and 100 TPD of medical
waste.
6.4 Page 29, First Paragraph
This particular discussion on autoclaves appears to be over simplistic. Autoclaves do
not provide sterilization and are not generally "considered a good substitute for
incineration." Many medical waste components such as sharps, pathological waste,
chemotherapy waste and bulk fluids cannot be autoclaved and must be disposed of by
alternative means at high costs. There are also regulatory and disposal problems
associated with autoclave system operations.
6.5 Pages 30-32, Tables 5a-5c
It is recommended that these economic tables be revised to account for the cost items
which do not appear to be included, per comments presented in other documents
specifically 3.15 through 3.21, 3.25 through 3.27, and 3.33.
6.6 Page 33, First Paragraph
Statements in this paragraph concerning cost comparisons do not appear to be correct
based on numerous studies we have conducted. It is also very difficult to determine
how all of the indicated cost values were derived.
6.7 Page 34, Table 6 - "Comparative Capital Costs"
Autoclave system costs appear to be very low, particularly if shredders are included.
Are breakouts of these costs available?
6.8 Page 35, Last Paragraph
The indicated statement does not appear logical and realistic based upon actual cost
studies which we have conducted at numerous facilities. On a life-cycle cost basis,
off-site contract disposal costs are substantially greater than on-site treatment for most
facilities.
6 2
DOUCET & MAINKA, P.C.
Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
6.9 Page 36, First Paragraph
To assume that "profit-maximizing behavior is sufficient motivation for a medical
waste incinerator operation to switch to an alternative treatment method" does not
appear to be correct. Firstly, medical waste disposal is not typically a "profit" center
for most medical waste generators. Secondly, economics are seldom the primary
motivation for a facility to switch to an alternative waste treatment method. Other
motivations which are of equal, if not greater, importance include technical viabilities,
regulatory uncertainties, socio-political factors, potential liabilities and local disposal
restrictions.
6 3
DOUCET & MAINKA, P.C.
r Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
7.0 COMMENTS TO DOCUMENT TITLED BACKGROUND PAPER FOR NEW
AND EXISTING FACILITIES
7.1 Total Document
of the comments discussed in the previous six documents also apply to this
document, particularly since this it intended to be a general summary document. The
following comments are additional to those previously stated.
7.2 Page 8, Fourth Paragraph
Contrary to the indicated statement, many intermittent-duty units have automatic ash
removal systems and are not required to cool prior to manual ash cleanup. Also,
many intermittent-duty units are not fixed-hearth designs.
73 Page 25, Last Paragraph
A particularly important conclusion is that "none of the modeled minimum paniculate
concentrations exceed 15% of established thresholds." On this basis, it would appear
that Control Option 1 (Good Combustion Control) is more than adequate to provide
environmental protection. We fully endorse this conclusion.
7A Page 32, Second Paragraph
See comments to Item 7.3, above.
7.5 Page 34, Table 7-8 - "Partial Benefits Analysis"
This table indicates that the cost to benefit ratio is about 130 to 1 for Control Option
1, about 270 to 1 for Control Option 2, and about 617 to 1 for Control Option 3. On
this basis, it appears that the costs greatly outweigh the benefits of any of the Control
Options.
7.6 Page 36, First Paragraph
Again, there are no federal regulations applicable to medical waste incinerators.
7 1
DOUCET & MAINKA, P.C.
' Consulting Engineers
-------
REVIEW COMMENTS TO DRAFT U.S.EPA
MEDICAL WASTE INCINERATOR BACKGROUND DOCUMENTS (9/30/91)
7.7 Page 40 - "Subcategorization by MWI Size"
It appears that size categories for MWI's were selected on the basis of daily rather
than hourly burning capacity. This is not a proper tiering methodology because
incinerators are rated in terms of hourly capacity. All states with such categories
rank large, medium and small units in terms of Ib/hr limits or ranges.
7.8 Page 46, Second Paragraph
It appears that some degree of manipulation and extrapolation may have been done in
order to derive at the determination that Regulatory Alternative III is the best option
in accordance with MACT. We believe that this conclusion could be revised without
much difficulty if the percentage of large capacity units were revised by simply
expanding the definition of "large" size. We believe that the size categorization of
MWI is based on Ib/day (or ton/day) incinerated, rather than Ib/hr, and has
erroneously led to a conclusion that "BEST" is the MACT floor for "large" units.
For example, if large units were defined to include those greater than 1000 Ib/hr, it is
likely that "BETTER" would be the MACT floor. Furthermore, the BETTER
Control Option (for large systems) would be representative of BACT for medical
waste incineration facilities. Very few dry injection scrubbers have been in operation
for any appreciable time to demonstrate their viability for medical waste incinerator
applications. Also, many modern wet scrubber systems can achieve the same
compliance levels as dry scrubber systems. It is recommended that the best
Regulatory Alternative should be BASELINE for small systems, BASELINE for
medium systems and BETTER for large systems. It is also questionable as to why
this Alternative is not listed on Table 9-1 (pp 45), as it seems viable and appropriate.
7 2
DOUCET & MAINKA, RC.
Consulting Engineers
-------
Blower and Dust Collector Systems tor
Pollution Control and Heat Conservation
B G Wickberg Company, Inc., 33 Newport Ave., North Quincy, MA 02171
(617) 328-9200
WICKBERG
B. G. WICKBERG CO., INC.
NORTH QUINCY, MA
Thank you for inviting me to join with your group today. I welcome
the opportunity to share with you some data from recent testing
that we have done. This data is the result of both pre-tests and
compliance tests, and is in no way intended to be all inclusive.
In the interests of time I have selected test groupings which
illustrate a point and which have brought to me some interesting
and significant information. I hope it will do the same for
others.
Of particular interest in these test results are certain
implications with respect to:
1. Which tests are meaningful, and an interpretation?
2. What do we learn about, the performance of the equipment?
3. Is there a basis for the public's fears?
I invite you to review these results and draw you own conclusions.
-------
PARTICULATE DATA
mg weight as collected
location
I-H
I2-H
C-C
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
run 1
2
4.4
39.2
175
1850
2
0
12.5
35
132
1875
2
0.73
3
1.5
128
1800
1.35
run 2
0.2
2.6
22.5
175
1850
2
.0009
8.2
23.4
140
1850
2
0.93
3.6
1.9
127
1800
1.35
run 3
0.3
37.3
8.1
126
1850
2
0
23.4
17
125
1900
2
0.82
3.4
2.2
117
1850
1.35
379
-------
PARTICULATE DATA
mg weight as collected
Location
E-C
J-H
H-C
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
FILTER
PROBE RINSE
IMPINGER
STACK TEMP
SEC TEMP
RETENTION
un 1
0
6.6
26.1
124
1900
2
1.3
26.6
105
1875
1
0.4
7.6
0.3
166
1930
2
run 2
0
4.6
25.6
126
1950
2
3.4
37.6
110
1875
1
3.7
7.4
0 . 4
158
1900
2
run 3
0.5
5.8
27.1
127
1950
2
2
34.8
122
1875
1
0
28.6
0
150
1925
2
330
-------
HCI DATA
ppm basis, corrected
Location
I-H INLET
OUTLET
E-H
INLET
OUTLET
C-C INLET
OUTLET
run 1
9.6
0.6
94
126
0.4
99.7
653
0.26
99. 9
run 2
157
0.7
99.5
1003
0.6
99.9
87
0.13
99.8
run 3
600
1.25
99.8
182
18.9
89.6
173
0 . 38
99.8
381
-------
M ETALS - Selected
MERCURY H-C
C-C
CADMIUM H-C
C-C
LEAD H-C
C-C
uf/dscf corrected concentration
3.4 scrubber failed
0.02
0.04
0.55
0 .24
0.62
one run ND
two runs ND
332
-------
B.C. WICKBERG CO. INC.
NORTH QUINCY, MA
R £. D .PROGRAM FOR MEDICAL WASTE INCINERATORS
PHASE 1: STARTED 1988, TO DEMONSTRATE THAT NEW EMISSION
CONTROL LEVELS OF .015 AND 97.5% COULD BE MET
3 SYSTEMS INVOLVED, COMPLETED
PHASE 2: STARTED 1989 TO DEMONSTRATE THAT
a. process was repeatable
b. process was BACT
c. process still successful with impingers
PHASE 3: STARTED 1990 SET UP TO
a. get an installed base
b. design necessary peripherals
PHASE 4: STARTED 1991 SET UP TO RESOLVE PROBLEM OF
INCONSISTENCIES BETWEEN DIFFERENT MAKES OF
INCINERATORS
333
-------
TROUBLESOME AREAS
1. POOR TEST LAB FEEDBACK
2. IMPINGER ORGANICS - WHY, WHERE, WHO, WHICH STATES
REQUIRED?
3. MERCURY - WHERE WANTED - SOLID, LIQUID, AIR - HOW?
4. WHAT DO WE DO WITH THE MATERIAL WE COLLECT?
5. LACK OF TRAINED OPERATORS
6. THE NIMBY PROBLEM
334
-------
PARTICULATE EMISSIONS
CD
VI
CD
cn
CD
CO
cn
cn
co
cn
CO
o-i
cn
B.6.VICK3ERG Co.
-------
Testimony before the
National Air Pollution Control Techniques Advisory Committee
Research Triangle Park, North Carolina
November 20, 1991
By: Ronald G. Patterson, Ph.D. President
CALVERT ENVIRONMENTAL, INC.
Medical Waste Incinerator Standards
My name is Ronald Patterson, President of CALVERT Environmental, Inc.
CALVERT Environmental, started out over 20 years ago as Air Pollution Technology.
During the 1970's and early 1980's Air Pollution Technology completed a number of
research and development contracts for EPA's Industrial and Engineering Research Labs.
These research contracts were focused on developing new technologies to solve air
pollution control problems. Today, CALVERT manufactures air pollution control systems
for controlling emissions from both hazardous waste incinerators and medical waste
incinerators.
We appreciate the opportunity to be here today to provide comments related to
EPA's development of the maximum achievable control technology (MACT) standards
for medical waste incinerators (MWI's). My discussion will focus on EPA's draft
documents relating to the development of NSPS standards for Medical Waste
Incinerators. The primary focus will be the emission standards that will be set for Medical
Waste Incinerator's.
336
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Incineration is widely accepted in medical waste management because it can
accomplish safe conversion of medical waste, permanently reducing large volumes of
waste material by 80 to 90%. The resulting ash can be safely landfilled. Moreover,
incineration can often provide an optimum, permanent solution to medical waste
management with minimum long term ecological effects.
As the medical wastes are incinerated, acid gases, such as HCI & SO^, heavy
metals, such as admium, chromium, lead and mercury and other combustion by-
products, such as dioxins and furans may be omitted along with the ash particles. Some
of these compounds are toxic and carcinogenic even at low exposure levels and must be
removed from the gas stream prior to discharge into the atmosphere.
The September 30,1991 draft report on "Medical Waste Incinerators - Background
Paper For New And Existing Facilities", goes a long way towards delineating the NSPS
for these facilities. The report, however, falls short in its evaluation of control technologies
that can meet proposed standards. Further the report tends to jump over its main
objective, which is setting new source performance standards, to establishing the
preferred control technology.
The Draft Report summarizes the work completed to date by EPA towards
developing an NSPS for MWI's and Emission guidelines for existing MWI's that combust
hospital waste, medical waste, and infectious waste. The report states that:
The standards and guidelines must specify numerical
emissions limitations for the following: PM, opacity,
sulfur dioxide (SO2), HCI, oxides of nitrogen (NOX),
CO, lead (Pb), cadmium (Cd), mercury (Hg), and
387
-------
CDD/CDF's Standards for new MWI's must not be less
stringent than the emissions control achieved in
practice by the best controlled similar unit.
In Section 4.3 on Best Emission Control Technology, the report states that:
BEST emission control combines GCC with either an
FF/PB system or a DI/FF system to capture pollutants
as they leave the incinerator.
It is one thing to specify the numerical emissions as required by Section 129 of
Title III of the Clean Air Act as amended in 1990. However it is severely limiting to owners
and operators of MWI's to specify the control technology acceptable for meeting those
emission requirements. Doing so severely limits the choices and most likely will not allow
the least cost solution to provide the intended result.
One of the problems in determining the maximum achievable control technology
is that state requirements for medical waste incinerators varies widely. This is shown
in Table 6 of the Draft Report on "Process Description/Baseline Emissions Report For
New And Existing Facilities". This report shows that the particulate standards can vary
all the way from as high as 0.2 gr/dscf corrected to 7% oxygen to 0.015 gr/dscf also
corrected to 7% oxygen. Since then more stringent regulations have just recently come
into place there are not many sites where the gas cleaning equipment is designed to meet
the lower limit of 0.015 gr/dscf. In particular we know of no sites where a wet scrubber
is installed for this lower limit, however, units are presently being designed for installation.
-------
Most of the installed data base on wet scrubbing systems are for either codes were
only controlled HCI were required or a very minimal code requirements in terms of
particulate. There are a number of systems around which are currently meeting an
emission limit of 0.03 gr/dscf, corrected to 7% oxygen.
Further, as lower emission limits are demonstrated, the removal efficiency for heavy
metal emissions will increase. Temperatures in the range of 1400° -1800° F are employed
for medical waste incineration. At these temperature, heavy metals and heavy metal
compounds become volatile and undergo thermal conversion. Some of the metals will
be oxidized while others will react with chlorides and become metal chlorides. As the flue
gas cools, the volatile compounds condense on surfaces. Because fine particles offer a
relatively large surface when compared to course particles metals are enriched on fine
particles. Therefore, if an air pollution control system that has high fine particle removal
efficiency, it's heavy metal removal efficiency will also be high.
The heavy metal removal efficiency of a gas cleaning system also depends on the
flue gas temperature at the particle collection zone. Figure 1 shows the vapor pressure
for a number of metal compounds. As can be seen, several of these compounds are
volatile and their collection efficiencies will be low if the flue gas is not cooled sufficiently
in the collection zone.
Mercury is especially difficult to collect because of its high vapor pressure. Figure
2 shows published mercury removal efficiencies as a function of temperature. The
removal efficiency is clearly temperature dependant and it increases as the gas
temperature is decreased. Wet scrubbers in general have shown higher mercury removal
efficiencies than baghouses because of the lower operating temperature.
389
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Higher removal efficiencies of dioxins and furans is another advantage of wet
scrubber systems. Figure 3 shows the vapor pressure for several dioxin compounds.
As can be seen from this figure the vapor pressure for dioxin compounds decreases by
2 orders of magnitude from the operating temperature range of most baghouse to the
operating range of wet scrubbers.
Wet scrubbing technology is further improved by adding a condenser/absorber
upstream of the wet scrubber to sub-cool the gas prior to scrubbing. The operating
temperatures for the condenser/absorbers may further reduce the vapor pressure by
another 1 1 /2 orders of magnitude. This means that far more of the dioxins will condense
out so that they can be collected by the scrubber.
Tests conducted by the California Air Resources Board on the wet scrubber
system at Stanford University Environmental Safety Facility Incinerator show removal of
total dioxins and furans in the range of 95 to greater than 99%. These removal
efficiencies were demonstrated on a wet scrubber system designed primarily for HCI acid
gas removal which did not have a condenser absorber.
The Draft Report on "Controlled Technology Performance for New and Existing
Facilities For Medical Waste Incinerators" has eight tables showing test data on fabric
filters and one Venturi packed bed scrubbing system. The tables containing information
on fabric filters all show approximately the same amount or a greater amount of total
dioxins or furans leaving the bag house as entering the bag house. Table Number 8 for
the Venturi packed bed scrubbing system shows an overall removal efficiency for total
dioxins and furans of 72%.
3
-------
It is time that we start looking around at what is being done on similar sources in
the U.S. as well as Europe and Japan. One finds it is possible to meet the proposed U.S.
standards as well as the more stringent European standard with systems other than fabric
filters. Both Wet scrubbing systems and Wet Electrostatic Participator have been shown
to meet the standards that are implied in these draft reports.
The following table shows the emissions limits for new MWI's inplied by the Draft
Report. This table also presents removal efficiencies that have been obtained with wet
systems on hazardous waste incinerators in the U.S.
POLLUTANT
CDD/CDF
HCI
SO,
PM
Pb
Cd
Hg
REGULATORY1
EFFICIENCY, %
95
95
50
81
99
99
80
WET SCRUBBER2
EFFICIENCY
OBTAINED ON HWI, %
95
99.9
98
99
99
99
98
Regulator Efficiency for Control Device
Efficiencies Based on Trial Bum Data
SI
-------
These efficiency levels, which meet or exceed the proposed standards, may be
obtained at cost levels substantially below that of DI/FF, as shown below. Both the
capital and annual costs for the wet scrubbing option are in the range of 50 to 70% of the
DI/FF.
PARAMETERS/MODEL COMB.1
1. COMBUSTION PARAMETERS1
Capacity, Ib/hr
Gas Flow Rate, dscfm
2. CAPITAL COSTS
Combustor1
Combustion Control1
APCD Capital Costs
DIFF-11
F/C3
3. ANNUAL COSTS
Combustor2
Combustion Control2
APCD Capital Costs
DIFF-12
F/C2
5
500
1,582
392,000
29,900
508,000
250,000
284,000
12,800
148,000
82,100
6A
1,000
3,165
521,000
47,100
609,000
330,000
204,000
16,000
150,000
87,600
7A
1,500
4,747
650,000
64,300
710,000
400,000
366,000
33,300
222,000
152,500
Medical Waste Incinerators - Background Information for Proposed Standards and Guidlines:
Model Plant Description and Cost Report for New and Existing Facilities. Prepared for U.S. EPA
Office of Air Quality Planning and Standards. September 30, 1991. p. 139.
Reference No. 1. p. 180.
CALVERT Flux Force/Condensation Air Pollution Control System. Costs Determined in
Accordance with Ref. No. 1.
332
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Summary
We recommend that EPA establish a minimum performance standard for medical
waste incinerator emissions. This means the specifications of numerical emissions as
required 'by Section 129 of Title III of the Clean Air Act as amended in 1990. This does
not mean the specification of limited control technology. Setting a numerical emissions
standards opens up the choices available to operators of medical waste incinerators and
will allow them to select the least cost solution to provide the intended result.
Thank you for the opportunity to comment on the Draft Report and we look forward
to working productively with the EPA in developing the New Source Performance
Standards for Medical Waste Incinerators. We would be pleased to assist by providing
additional data or helping the EPA find additional suitable test sites.
333
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mg/m3
AsCI
10
10
SeO,
1 OO
212
Cd
Zn
PbCL
Pb
PbO
30O
572
5OO
932
7OO
1292
900
1652
TEMPERATURE
FIGURE 1. VAPOR PRESSURE OF SEVERAL HEAVY METAL SPECIES
c
F
-------
The Relationship of Temperature and Control Device
On The Removal of Mercury
CO
V3
CJ1
>-
o
o
<
o
O
100
90
80
70
60
50
40
30
20
10
QUEBEC CITY
0,0
QUEBEC CITY
NYBORG
SYSAV MALNO
NYBORGgi|
BAMBERG —— ZURIC
QAVESTA QUEBEC CITY
50
122
VOGG
WURZBURG
QUEBEC CITY
BRUNNER
• VOGG
4-
100 150
212 302
TEMPERATURE
200
392
250
482
°C
T
FIGURE 2. MERCURY REMOVAL EFFICIENCY
-------
CD
1O
-3 I
IO--T
io--h
s
in
CO
£
ol
o
CL.
CO
10
-6-L
10
5O
30O
Temperature. K
350
4OO
oo
OCDD
1. 2, 3, A - TCDD
1OO
3OO
150 2OO 250
Temperature. °F
1 atm - 1.01 x 10s Pa
FIGURE 3. VAPOR PRESSURE OF OCTA- AND TETRACHLORODIBENZO-(P) DIOXINS
35O
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KONHEIM &KETCHAM
175 Pacific Street, Brooklyn, New York 11201 ® (718) 330 0550 (201) 623 8832
COMMENTS OF CAROLYN S. KONHEIM
on
PROPOSED STANDARDS AND EMISSION GUIDELINES
for
MEDICAL WASTE INCINERATORS
I am Carolyn S. Konheim, president of Konheim & Ketcham,
Inc., of Brooklyn, New York, a consulting firm that prepares
environmental impact assessments and permit applications of a
broad array of projects, including 11 medical waste
incinerators. With Waste Management Technologies, Inc., of
Houston, Texas, we have also prepared major segments of New
York City's Medical Waste Management Plan. I have been an
environmental regulator in New York City and State for many
years, and am active in a number of environmental
organizations. These comments reflect my own positions and
not those of any clients.
Good Combustion Conditions - At this workshop, OQAPS
project managers have indicated that they are open to a
variety of methods of achieving GCC, not limited to a
specification of two seconds retention time to achieve what
may be a numerical standard for organics, primarily CDD/CDF.
In this investigation, I suggest that you explore as a method
of achieving GCC, the advisability of abandoning the starved
air mode of operating a dual chamber incinerator. This is
advocated by Dr. Alex Green and his colleagues at the Clean
Combustion Technology Laboratory of the University of Florida
in Gainesville. The starved air mode of operation was
designed to reduce turbulence in the primary chamber as a
method of reducing particulate emissions for incinerators
without emissions controls. Since all facilities are now
required to install some degree of back end controls, the
premise of the starved air mode may no longer be relevant.
With the focus of control now on dioxins, formed at least
partially as products of incomplete combustion, it may be
preferable to minimize the formation of PICs in the primary
chamber, and lessen the potential that some may slip through
the secondary chamber. Dr. Green finds the optimum mode of
his pilot pt is 1700°F in the primary chamber.1'2 More test
data are needed on full scale application of this principal.
However, given the cost and delay of testing for dioxins
under different operating conditions, it would be helpful for
those designing test protocols to receive guidance from USEPA
as to the promise of this approach.
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KONHEIM &KETCHAM
You have heard a number of objections to the imposition
of a retention time beyond one second as being unnecessary in
improving combustion efficiency- It should be noted that if
an increase in retention time were mandated, it would
virtually rule out that any existing incinerator could be
economically feasible to upgrade. This was the conclusion of
our analysis as part of the New York City Medical Waste
Management Study. The only alternative means to achieve
greater retention time is by downrating the incinerator, a
step which is generally feasible for an on-site hospital
facility in combination with waste reduction strategies.
Continuous Emissions Monitors - The draft MACT is silent
on a requirement for CEMS for key pollutants. Some states,
e.g. New York, are requiring these for medical waste
incinerators. CEMS would be helpful to the operator, the
regulators, and the public in indicating whether optimum
conditions are being maintained over the life of the
facility. The definition of optimum conditions is expected
to vary somewhat from one pt to another. At the very least,
the operating conditions that prevailed during performance
tests should be fully documented so that corresponding
indicators that can be measured on a continuous basis can be
established and the operator can be held to operating within
those parameters.
Testing of More Representative Facilities - You have
heard numerous objections to the scanty database for this
project and its potential unrepresentativeness of the best
operating facilities, the statutory basis of MACT. Many such
facilities are now coming on-line and will be tested by state
regulatory agencies. USEPA could participate in overseeing
those tests to assure uniformity and obtain a large body of
data at very little incremental cost.
Risk Based Standards - Although MACT is, by definition,
a technology-driven standard, it will have to pass review of
the Office of Management and Budget, which has historically
required a demonstration of the benefits based on risk
assessment. There are several features in the air quality
analysis to date that would make risk assessment invalid for
most applications.
The primary problem is that the modeling in the draft
document has assumed two features that produce higher ground
level concentrations than in most actual installations that
would receive permits by any state today: stack heights of
12.2 meters, 40 feet; and building heights of 6 meters, 20
feet. This relationship is a violation of USEPA guidelines
for a stack of Good Engineering Practices height, resulting
'.< C
-------
KONHEIM &KETCHAM
in a downwash of the plume, and high ground level
concentrations. While a non-GEP stack height may be
characteristic of many hospital installations, such buildings
are surely taller than the 20 feet assumed in your modeling.
Typically in urban areas, they are many times higher,
resulting in lower ground level concentrations, except during
periods when the plume may be caught in the cavity. Neither
are these heights representative of most regional facilities,
which are generally 30 feet high with a 75 foot stack,
eliminating downwash effects. Thus, actual ground level
concentrations are likely to be lower than reported in the
draft documents.
A second deficiency is the absence of isomer-specific
data on CDD/CDF which is necessary to compute a toxic
equivalence. The availability of such data would be
important to those of us who would like to expand the
database for use in air quality analyses and health risk
assessments for regulatory purposes. It is more important to
publish the isomer breakdown for uncontrolled, or inlet,
levels, so that one could apply the expected control
efficiency for the proposed equipment.
A third deficiency is the absence of particulate size
distribution data for the various control equipment. These
data, in the range shown in Table 1, are critical to
performing deposition modeling, the results of which drive
most risk assessments. All manufacturers should be urged to
develop these data for their own equipment.
Finally, site-specific air quality impacts due to MACT
are far more relevant than the national emission reductions
estimated in the report. These are based on numerous
uncertainties, such as the number of future facilities, and
don't reflect the fact that the major effects of these
relatively small installations are highly localized. If an
analysis of prototypical facilities were done, one may see a
need for a difference in the application of MACT. Avoiding
acute effects may predominate in the hospital setting, where
a plume can enter air intakes of rooms in which patients are
especially sensitive to short term pulmonary irritants, such
as would be the case with cardiac and asthmatic patients or
premature infants. This might dictate use of technologies
that achieve the highest removal efficiencies of hydrogen
chloride and sulfur dioxide in on-site hospital facilities.
On the other hand, regional facilities located in less
sensitive industrial areas might not cause problems from
exposure to short term peaks of respiratory irritants.
However they could affect an adjacent residential area, which
includes those who could be exposed for a lifetime. Thus, it
•'• 9
^f v> O"
-------
TABLE 1 NYC acute care facility medical waste composition
total waste stream components.
STREAM
Illllll
liiliBli5
IliiliiBS
$
!
$
l
mill
IBili
^Iliiiiil 1
fflSliil! \
COMPONEMT
IV BAGS
SHARPS
SHARPS CONTAINERS
SOLUTION CONTAINER
RMW PLASTIC BAGS
ANIMAL BEDDING
APPARATUS
DISPOSABLE LINENS
PATIENT FOOD SERVIC
PACKAGING
PAPER
PAPER TOWELS
OTHER
TOTAL RMW
DISPOSABLE LINENS
PAPER TOWELS
OFFICE PAPER
COMPUTER PAPER
NRMW PLASTIC BAGS
BATTERIES
ANIMAL BEDDING
PATIENT FOOD SERVIC
MIXED PAPER
KITCHEN
PACKAGING
CORRUGATED
NEWS/MAG
APPARATUS
OTHER
TOTAL NRMW
WEHGNT56
OFSTfcEAM
8.9
8.3
1.8
8.5
4.4
1.2
10.5
12.4
10.4
5.4
4.8
2.9
20.6
100.0
10.7
4.2
5.8
1.3
3.8
0.1
0.3
10.7
7.1
15.0
5.2
10.1
6.0
4.3
15.4
100.0
WEIGHT
(L0$/PAY>
17,781
16,526
3,588
16,923
8,776
2,502
21,021
24,828
20,821
10,859
9,526
5,751
41,310
200,213
72,556
28,548
39,496
9,105
25,993
381
1,793
72,449
48,249
101,876
34,967
68,412
40,374
29,166
104,342
677,708
TOTAL RMW & NRMW 877,921
WglOHT%
OF TOTAL
2.0
1.9
0.4
1.9
1.0
0.3
2.4
2.8
2.4
1.2
1.1
0.7
4.7
22.8
8.3
3.3
4.5
1.0
3.0
0.0
0.2
8.3
5.5
11.6
4.0
7.8
4.6
3.3
11.9
77.2
100.0
SUMMARY
RMW
NRMW
PATHO
RMW CONTAINERS
SUMMARY TOTAL
200,213
677,707
4,250
23,691
905,861
22.1%
74.8%
0.5%
2.6%
100.0%
-------
KONHEIM &KETCHAM
may be more important that regional facilities are equipped
with controls that best minimize pollutants that could cause
long term effects, even if they are somewhat less effective
for acid gases.
Alternative Technologies - The draft documents treat all
alternative technologies as being readily available
substitutes for incineration, without mentioning any of their
environmental and health care considerations. Factors such
as cost, throughput and reliability in terms of downtime have
led several hospitals in the New York area to abandon the
only state-approved alternative, autoclaving. (New York
State Department of Health has an extensive testing program
for alternate technologies, but none has yet been accepted.
Since most involve some type of shredding to meet the
criterion of unrecognizability of the waste, a major
stumbling block is how to associate the spore indicators with
the treated waste.)
Autoclaving is also objected to by some hospital
personnel because of the odors nearly always present after
"pressure cooking" the waste. Odors are usually a good
indicator of volatized organic pollutants. And, indeed, data
published in the New York City Medical Waste Management Study
(excerpts included as Attachment A) reveal the presence of
many known carcinogens. The California Air Resources Board
and the New York State Department of Environmental
Conservation are currently conducting test programs of
autoclave emissions. These may prove to be inconsequential,
especially after use of a control device, such as a
condenser. However, at present, the efficiency of such
equipment is not known. Nor is it known whether the controls
capture fugitive emissions from the autoclaved waste after
discharge from the vessel. If such a condenser is used, it
is not known whether discharges to the wastewater lines are
acceptable. Since other new technologies, such as
microwaving, are also thermal methods that raise the
temperature of the waste, the same concerns should apply,
although even less is known about these. In the interest of
public health and the environment, these issues should be
addressed by EPA. Mitigation of such effects, if needed,
would also add to the relative cost of such technologies, and
change much of the economic analysis in the report.
Since USEPA has been sensitive to the issue of pathogen
kill in incinerators, this concern should extend to other
technologies as well. Thermal treatment at relatively low
temperatures may be adequate for pathogen kill on homogenous
wastes that have impervious surfaces; but uniform penetration
of destruction temperatures cannot be assured given the
4C1
-------
KONHEIM &KETCHAM
varying densities of mixed medical wastes, e.g. balled up
diapers, closed containers. For example, HIV is destroyed by
exposure to 100°F for 20 minutes; however, it may be
difficult to assure maintenance of 100°F for a full 20
minutes throughout mixed waste, which is typically autoclaved
for 30 minutes.
Another environmental consideration is that treated
waste still must either be incinerated or landfilled.
Increasingly, landfills are prohibiting medical waste. No
hospital waste of any kind may be accepted at New York City's
landfill. (This is prudent since a finding of waste sorts in
the New York City's Medical Waste Management Study is that
half the regulated medical i.e., infectious waste was found
in the non-regulated general hospital waste stream.) Ohio
landfills are demanding strict identification of medical
waste generators to assure that the recognizable medical
waste has indeed been treated. The next predictable step is
restriction altogether. This would bring us back to
incineration of autoclaved waste.
In addition, the energy and emission consideration of
transport of wastes over long distances should be considered
in any national overview of the effects of the proposed
regulations.
Pollution Prevention - Since pollution prevention is a
USEPA policy, this project should explore the steps that can
be taken to reduce emissions by changes in the waste stream.
Removing batteries from the waste stream should be effective
in reducing mercury and cadmium based on USEPA's studies of
the sources of these pollutants in the municipal waste
stream. The fact that you found no lower inlet values of
mercury at a facility that was re-tested after it began a
battery recycling program is insufficient reason to discount
this control approach. As noted, the program may not yet
have been fully effective, or the levels may have reflected a
spike in the waste.
Another method is to reduce the chlorine content of the
waste by removing the sources--polyvinyl chloride-containing
plastics and gloves—which accounts for 77% of the chlorine
in hospital waste3 (see Table 2) . The New York City Medical
Waste Management Plan proposes to capture these sources
through segregation in patient rooms of plastic medical
apparatus. These wastes, which have been found to comprises
85% of regulated medical waste, are the type of impervious
materials for which on-site autoclaving or shredding and
bleach systems (when approved) would be more suitable, and
cause less emissions, than treating very heterogenous
-------
TABLE 2 Chlorine content of New York City acute care facilities medical waste.
COMPONENT
SEGREGATED PLASTICS
IV BAGS
GLOVES (IN RMW)
GLOVES (IN NRMW)
SHARPS
SHARPS CONTAINERS
SOLUTION CONTAINERS
APPARATUS (IN RMW)
APPARATUS (IN NRMW)
SUBTOTAL
NOT SEGREGATED
=LAST1C BAGS (IN RMW)
PLASTIC BAGS (IN NRMW)
OTHER (IN RMW)
OTHER (IN NRMW)
BATTERIES
SUBTOTAL
CELLULOSIC
DISP. LINENS
PAPER
CORRUGATED
PAPER TOWELS
PACKAGING
SUBTOTAL
ORGANICS
ANIMAL BEDDING
KITCHEN/FOOD SERVICE
SUBTOTAL
TOTAL
% Cl CONTENT
WEIGHT
LBS/DAY(1)
17,781
3,980
13,476
16,526
3,588
16,923
21,021
29,166
122,461
8,776
25,993
37,330
90,866
381
163,346
97,384
146,750
68,412
34,299
45,826
392,671
4,295
195,146
199,441
877919
1.22
PLASTIC
LBS/DAY(2)
5,868
3,980
13,476
12,395
3,588
11,338
6,247
17,500
8,776
25,993
21,632
51,216
0
29,215
0
0
0
6,874
215
29,272
: ' • ::' ':::;: ' ;::::-: ::':' : ::-:::'::
PVC
LBS/DAY(3)
5,868
1,990
6,738
*
0
0
*
*
0
0
*
*
0
0
0
0
0
0
0
0
• ; : : • ; •:•:•;•:';• ; •:•:•:•:•:-: : : : ; • '.
3ELLULOSE
LBS/DAY
650
0
0
65
650
650
1,192
5,833
0
0
11,980
30,259
0
63,300
146,750
68,412
13,720
38,952
2,148
48,787
INORGANIC
LBS/DAY
1,500
0
0
2,000
350
150
3,584
4,375
0
0
2,066
5,217
381
0
0
0
0
0
0
31,223
ORGANIC
LBS/DAY
0
0
0
0
0
0
0
0
0
0
1,652
4,174
0
0
0
0
0
0
1,074
62,447
\:\:'- :'•:'.: ••.::'':i:-.':-:'-:'i:- :•:•:':
CHLORINE
LBS/DAY(4)
3,135
1,078
3,651
103
31
93
56
159
8,306
0
0
211
505
0
716
405
396
185
37
160
1,183
10
535
545
10750
NOTES:
1. Includes free water.
2. Excludes free water.
3. Items marked (*) may contain small amounts of PVC.
4. The chlorine content of PVC is 53.8%; the chlorine content of other plastics is 0.8%; the chlorine content of
the plastic fraction of sharps containers, solution containers and plastic bags is assumed ato; the chlorine content
of cellutosic waste is 0.27%; the chlorine content of inorganic waste is 0.08%; and the chlorine content of organic waste is 0.23%.
-------
KONHEIM &KETCHAM
materials. Since PVC does not readily burn, removal of these
materials from the waste to be incinerated may improve
combustion. It will lessen lime demand and thereby reduce
the emission control residue, which may be more costly to
landfill as a result of a recent appellate court decision to
treat incineration ash as a hazardous waste.
Finally, pollutant prevention begins by reducing the
quantity of wastes. The New York City Medical Waste
Management Plan includes numerous cost-effective management
strategies that reduce by 47% a prototypical hospital's
overall waste stream. The executive summary of the plan is
provided as Attachment B.
References:
1. Green, A., et al., "Phenomenological Models of
Chlorinated Hydrocarbons," Chemosphere 22; 1-2, 1991.
2. Green, A. et al., "Medical Waste Incinerators With a
Toxic Prevention Protocol," presented at the 84th Annual
Meeting of the Air & Waste Management Association,
Vancouver, BC, June, 1991.
3. Jordan, J. W., et al., "Segregation Of Specific
Regulated Medical Waste Items Can Be The Centerpiece Of
Medical Waste Reduction And Cleaner Incineration,"
presented at the 84th Annual Meeting of the Air & Waste
Management Association, Vancouver, BC, 1991.
i:\cskmemos\medwaste.epa
-------
ATTACHMENT A
THE NEW YORK CITY
MEDICAL WASTE MANAGEMENT STUDY
TASK 3 REPORT
EVALUATION OF MEDICAL WASTE
MANAGEMENT AND TREATMENT OPTIONS
PREPARED BY
WASTED-TECH
WASTE ENERGY TECHNOLOGIES
HOUSTON, TX - NEW YORK, NEW YORK
AND
KONHEIM & KETCHAM
BROOKLYN, NEW YORK
MARCH 25, 1991
EXCERPTS ON AUTOCLAVES
if £
O-
-------
Autoclaving Process Considerations
Autoclaving is reported to be the method of choice of the
National Research Council and USEPA for treating waste
cultures, stocks of infectious agents, associated
biologicals, and contaminated labware. It can also be used
for other categories of RMW, but is generally considered
undesirable for pathological wastes, since it does not render
them unrecognizable, or for other wastes which do not permit
adequate steam penetration, such as bulky diapers or body
fluid containers. (4)
It is considered "of critical importance" that certain
wastes, due to their hazardous or pathological nature, not
be autoclaved. For example, autoclaving hazardous materials
such as antineoplastic agents, radioisotopes, solvents or
other toxic wastes could lead to chemicals being volatilized
by the steam and could result in possible worker exposure
between process cycles(5). Such substances are contained in
medical waste, based on observations in this study.
Hazardous chemicals enter the waste stream as a consequence
of the common use of disposable underpads to .clean up spills
of drugs, disinfectants, and other chemicals, as well as the
daily use throughout a facility of products containing
hazardous compounds. Anti-neoplastic drug spills are
generally absorbed using a spill clean-up kit that is
discarded in RMW containers. Disposable diapers, bed pans,
and drainage canisters contain low-level radioactive
compounds and chemotherapeutic agents excreted by patients
who have undergone diagnostic or treatment procedures
requiring their use.
Although it is proposed that operating room and laboratory
wastes not be autoclaved, these wastes are common elements in
both NRMW and RMW, as presently collected in hospitals.
Wastes that contain oil or greases that repel water and do
not allow direct contact with the steam are not appropriate
for autoclaving. Wastes with low heat capacity or
conductivity can take longer to reach sterilization
temperatures. Containers that have air pockets which allow
air to mix with the steam so that it is no longer saturated
can interfere with the heat transfer mechanism (6) .
"Apparatus" of this type were found to constitute 7.6 percent
of RMW.
Steel trays or bins that aid in transferring heat are
recommended over plastics that can impede heat transfer(6)
for the autoclaving of cultures and laboratory apparatus.
Plastics, however, are abundant in the waste itself, and
constitute 23% of the total waste stream. Small loads and
-------
limitations on the diameter of the autoclave are also a
method of improving contact of the steam and heat. These
recommendations may not be relevant to the autoclaving of
Medical Waste, since they principally address the
sterilization of laboratory and OR equipment.
There is disagreement on the effect of waste containers on
the process. According to some: "Waste containers are the
most common impediment to direct steam contact. The waste
container must allow steam penetration or entry- Some
plastic bags that have been sold as ' autoclavable' have been
shown to be poor at allowing steam penetration. Similarly,
a tightly closed bag or a needle box that has been sealed
protects waste handlers but allows little opportunity for
steam to enter. The thermal instability of some plastics,
like petri dishes, can encapsulate some infectious agents and
prevent steam penetration."(6) Double bagging, (found to be
the general practice, in this study) especially with
polypropylene bags, nearly always impedes steam penetration.
However, the developer who pioneered commercial autoclaves
maintains that direct steam contact is not necessary.
According to him, steam serves only to transfer heat, which
is sufficient to disinfect enclosed materials (2) . Another
expert on commercial autoclaves explains that the purpose of
using autoclavable bags in small facilities is to prevent
melted plastic bags sticking to the walls of the vessel or
clogging drains. In a larger plant where standard red bags
are placed in steel bins, it is said to be desirable to have
the plastic bags melt away(7).
Recommended procedures to increase the likelihood of exposing
all the waste to sterilizing conditions include insuring more
effective creation of a vacuum before charging wastes,
lengthening the exposure time at 250o F. from 30 to 60 or
even 90 minutes, increasing the exposure temperature to 270o
F., punching openings in bags, opening bottle caps and
stoppers, and adding some water to bags(6). Some of these
procedures are obviously inappropriate for infectious RMW.
Proper training of operators is viewed as most critical to
ensure that standard procedures are followed. Regular
testing of the effectiveness of the destruction of the heat-
resistant spores of Bacillus stearothermophilus must be
conducted to verify the short-term evidence of chemical
indicators. Spore cultures must be put in places where it
may be difficult for the steam to reach (6) . A procedure
employed by BFI is to insert a rod containing spores into the
interior of bags or sharps containers "about" once a week.
After unloading the waste, the spores are cultured and
incubated for "about" a week. The results are said ensure
that the time/temperature profile and other operating
practices are effective(4).
-------
Wastes from pathology and microbiology laboratories in New
York City hospitals is generally autoclaved in on-site
autoclaves and disposed of in the RMW stream. These
facilities are usually adjacent to the laboratory areas and
their operation is monitored by the appropriate departments.
There is some basis for estimating emissions from thermal
processes. Although thermal processes are non-combustion
processes, emissions do occur. These emissions result from
the escape of volatile organic compounds which may either be
contained in the waste or are the product of organic
reactions taking place in the autoclave or other thermal
treatment during the operating cycle.
Medical waste contains heterogeneous materials with a
complex chemical composition. A review of the HHC Office of
Occupational and Environmental Health Services inventory of
products used in health care facilities includes over 1,300
products. The majority of these products contain hazardous
ingredients as defined by OSHA in the Hazardous Communication
Standard g-1910.1200. Since pressurized steam is a well
established method of volatizing organic compounds, it is
expected that such compounds will be emitted in the
autoclaving or other thermal process. In addition, the
heating of plastics and other materials in an autoclave or
other thermal process breaks down complex chemical molecules
into numerous shorter molecular chain compounds. Many
organic reactions are accelerated at elevated temperatures.
Therefore, the very wide variety of organic species which may
be emitted could not be estimated, as the quantity and
composition of the hazardous chemicals contained in the
waste, and their possible reaction products would be
unpredictable.
A partial list showing the types of hazardous ingredients
found in products, provided in Table 3.4-1 illustrates the
variety of hazardous chemicals used within the hospital
setting. While laboratory waste and radioactive waste are
segregated and disposed of by a licensed hauler, many
hazardous products used in cleaning, maintenance, or patient
care are routinely disposed of in a hospital's RMW an
NRMW streams. This has been observed in the Medical Waste
study by noting the difference between the number of products
used and those removed by a hazardous waste hauler. The
segregation of waste types varies substantially from hospital
to hospital. A characterization of waste must be done at
each hospital, from representative samples, to determine the
degree of segregation which occurs in actual practice.
-------
NYC MEDICAL WASTE MANAGEMENT STUDY
TABLE 3.4.1-1
EXAMPLES OF HAZARDOUS INGREDIENTS
FOUND IN PRODUCTS USED IN HOSPITALS
1,1,1 - TRICHLOROETHANE
ACETONE
CYCLOHEXANOL
ETHYLENE OXIDE
FORMALDEHYDE
GLUTARADEHYDE 2.4%
HYDROCHLORIC ACID 17.2%
ISOBUTANT
ISOPROPYL ALCOHOL
METHYL ETHYL KETONE
MONOETHANOLAMINE
NAPH TA
PETROLEUM DISTILLATES
PHOSPHORIC ACID
POTASSIUM HYDROXIDE
PROPYLENE GLYCOL
SODIUM HYDROXIDE
SODIUM HYDROSULFITE
TETRAHYDROFURAN
TOLUENE
TRICHLOROTRIFLUOROETHANE
Prepared by: HHC Office of Occupational &
Environmental Health Services
i:\hhc\task3\tables\sect3-4\tab1
-------
Autoclaving is not recommended for wastes that contain
solvents, anti-neoplastic agents, radioisotopes and other
toxic materials. Substantial amounts of these materials
undoubtedly enter the waste stream, as indicated above. It
is expected that the same restrictions would apply to other
thermal treatment processes when they come into greater
currency-
Emissions of autoclaving are beginning to be characterized,
although the data are extremely limited. The California Air
Resources Board has just begun efforts to characterize
autoclave emissions, but no tests have yet been conducted.
Presumably tests of other thermal processes will be required
by regulators before granting approval of their use. One
test was conducted for BFI of a stack at a 1500 Ib/hr
regional autoclave which vents the steam at the end of the
autoclave process. This single test series, consisting of
three samples drawn over a period of about 10 minutes each,
were rich in hydrocarbons, most of which were unknown.
However, 18 specific organic compounds of high, moderate and
low toxicity, as well as lead and chromium, were identified.
Although no tests were conducted for dioxins, furans, a
related compound, were detected in one test. The test
facility is not equipped with any method to condense the
venting steam. The emissions measured in the three tests are
shown in Table 3.4-2. If the plant were equipped with a
condenser, and if the nature of the emissions were known, a
control efficiency could be demonstrated. Some tests of the
control efficiency of a condenser at a San Diego autoclave
have been conducted, but the results are not yet available.
One level of control assumed in the air quality analysis for
this study was 90% of the autoclave emissions. Air quality
impacts were also estimated assuming a 99% control
efficiency. For a conservative estimate of emissions, the
first step prescribed by NYSDEC (Air Guide #1) is to divide
stack gas concentration by 100. This has been done in Table
3.4-3. Average values at both the 90% and 99% control levels
were compared to NYS Ambient Guideline Concentration (AGCs).
The controlled levels for 1,2-Dichloroethane, toluene and
lead exceed the AGCs by about two orders of magnitude. Thus,
the next step prescribed by DEC was taken.
Emission factors were developed based on the exit gas
velocity and the cross-sectional area of the stack. In
Table 3.4-4, the hourly emission rates for a 240 TPD facility
were reduced by both 90% and 99% to reflect control
efficiencies. Using the Air Guide algorithm to estimate an
annual cavity calculation, the results were compared to the
AGCs. All resulting annual average concentrations are well
below the AGCs at both removal efficiencies. It must be
noted, however, that the majority of the emissions consists
• T 0
Jb. -t- W
-------
NYC MEDICAL WASTE MANAGEMENT STUDY
TABLE 3.4.1-2
EMISSION FACTORS FOR AUTOCLAVE
BASED ON ONE TEST SERIES
Contaminant
Trichlorofluoromethane
Melhylane Chloride
Acetone
Carbon Olsulllde
Chloroform
1 ,2-Dichloroethane
Dutanone
1,1,1-Trichloroethane
Vinyl Acetate
cis-1 ,3-Dichloropropene
Trichloroethene
trans-1 ,3-Dichloropropene
Tetrachloroethene
Toluene
Ethylbenzene
Styrene
o-Xylene
m-p-Xylene
Lead
Total Hydrocarbons
RUN-1 I
{tia/to$ i
1.29E+05
7.50E+02
ND
2.72E+Q4
8.00E+01
1.70E+02
1.43E+03
1.26E+03
2.00E+01
3.40E+02
1.50E+02
9.00E+01
2.40E+02
7.69E+03
2.96E+03
1.01E+04
ND
8.35E+03
9.50E+01
2.62E+05
RUN 2 \
toMi3)....l
ND
9.11E+03
ND
1.30E+02
2.70E+03
2.32E+03
2.20E+03
1.00E+02
3.70E+02
1.30E+02
3.65E+03
3.00E+01
ND
4.76E+03
ND
ND
ND
4.00E+01
1.47E+02
2.62E+05
ftBrt*
.utfmto \
9.14E+03
6.73E+03
1.27E+04
1.19E+05
5.62E+03
4.92E*03
2.27E+03
3.94E+03
6.70E+02
4.106+02
3.67E+03
1.10E+02
5.00E+01
4.82E+03
1.20E+02
1.13E+03
4.76E+03
7.30E+02
5.00E+01
1.44E+05
iiUMiiilf
iliiilli!
mwwm
4.60E+04
S.53E+03
4.22E+03
4.87E+04
2.80E+03
2.47E+03
1.97E+03
1.77E+03
3.53E+02
2.93E+02
2.49E+03
7.67E+01
9.67E+01
5.76E+03
1.03E+03
3.74E+03
1.59E+03
3.04E+03
9.73E+01
2.23E+05
I HI I! IK!
H &HlidiJi!i!
II "Wfllil!1
1.S8E-02
1.90E-03
1.45E-03
1.67E-02
9.62E-04
8.48E-04
6.75E-04
6.07E-04
1.21E-04
1.01E-04
8.S5E-04
2.63E-05
3.32E-05
1.98E-03
3.53E-04
1.29E-03
5.4SE-04
1.04E-03
3.34E-05
7.65E-02
iBi-KJao^lid:
iHiMi
ll!li[!jlSiKiJiii!!
iiiiliiaifi^li
1.58E-01
1.90E-02
1.45E-02
1.67E-01
9.62E-03
8.48E-03
6.75E-03
6.07E-03
1.21E-03
1.01E-03
8.55E-03
2.63E-04
3.32E-04
1.98E-02
3.53E-03
1.29E-02
5.45E-03
1.04E-02
3.34E-04
7.65E-01
i:\hhc\task3\tables\sect3-4\tab2.wk1
9/5/90
-------
TABLE 3.4.1-3
AIR QUALITY SCREENING IMPACTS COMPARED TO
AMBIENT GUIDELINE CONCENTRATIONS BASED ON
ONE AUTOCLAVE TEST SERIES
&).WWft1»tt
Trichlorolluoromethane
Methylene Chloride
Acetone
Carbon Bisulfide
Chloroform
1,2-Dichloroethane
Butanone
1,1,1-Trichloroethane
Vinyl Acetate
cis-1 ,3-Dlchloropropene
Trichloroethene
trans- 1 ,3-Dichloropropene
Tetrachloroethene
Toluene
Ethylbenzene
Styrene
o-Xylene
m-p-Xylene
Lead
Total Hydrocarbons
JS&
1.29E+05
7.50E+02
ND
2.72E+04
8.00E+01
1.70E+02
1.43E+03
1.26E+03
2.00E+01
3.40E+02
1.50E+02
9.00E+01
2.40E+02
7.69E+03
2.96E+03
1.01E+04
ND
8.35E+03
9.50E+01
2.62E+05
W"**
ND
9.11E+03
ND
1.30E+02
2.70E+03
2.32E+03
2.20E*03
1.00E*02
3.70E+02
1.30E+02
3.65E+03
3.00E*01
ND
4.76E*03
ND
ND
ND
4.00E+01
1.47E+02
2.62E*05
*»«"
9.14E-.03
6.73E+03
1.27E+04
1.19E+05
5.62E+03
4.92E+03
2.27E*03
3.94E+03
6.70B-02
4.10E+02
3.67E+03
1.10E+02
5.00E+01
4.82E»03
1.20E+02
1.13E+03
4.76E*03
7.30E*02
5.00E+01
1.44E+05
, ;
AveraflQ: •
4.60E+04
5.53E+03
4.22E+03
4.87E+04
. Z80E+03
2.47E+03
1.97E+03
1.77E+03
3.53E+02
2.93E+02
2.49E+03
7.67E+01
9.67E+01
5.76E+03
1.03E+03
3.74E+03
1.59E*03
3.04E+03
9.73E*01
2.23E*05
IMW
' SflMlS
4.60E+03
5.53E+02
4.22E+02
4.87E+03
2.80E+02
2.47E+02
1.97E+02
1.77E+02
3.53E+01
2.93E+01
2.49E+02
7.67E+00
9.67E+00
5.76E+02
1.03E+02
3.74E+02
1.59E+02
3.04E+Q2
9.73E*00
2.23E*04
' I
teitiL
4.60E+02
5.53E+01
4.22E+01
4.87E+02
2.80E+01
2.47E+01
1.97E+01
1.77E+01
3.53E+00
2.93E+00
2.49E+01
7.67E-01
9.67E-01
5.76E+01
1.03E+01
3.74E+01
1.59E+01
3.04E+01
9.73E-01
2.23E+03
«^Art*rw«
•QQ|Q0|»f^
p(X^t^^H^*Wf^
lOflftflyV
NA
1.17E+03
3.56E+04
1.00E+02
1.67E*02
2.00E-01
NA
3.80E+04
NA
NA
NA
NA
NA
1.30E-01
1.45E+03
7.16E+02
1.45E+03
1.45E+03
1.50E*00
1.60E+02*
' lormer 3 hour National Ambient Air Quality Standard
I:\hhc\task3\tables\sect3-4\tab3.wkl
9/17/90
-------
NYC MEDICAL WASTE MANAGEMENT STUDY
TABLE 3.4.1-4
COMPARISON OF SCREENING CONCENTRATIONS OF ORGANIC POLLUTANTS
AND LEAD FROM AN AUTOCLAVE TO AMBIENT AIR GUIDELINES
Contaminant
Trichlorofluoromethane
Methytene Chloride
Acetone
Carbon Disulfide
Chloroform
1,2-Dlchloroethane
Butanone
1,1,1-Trlchloroethane
Vinyl Acetate
els- 1 ,3-Dlchloropropene
Trichloroethene
trans- 1 ,3-Dlchloropropene
Tetrachloroethene
Toluene
Ethylbenzene
Styrene
o-Xylene
m-p-Xylene
Lead
Total Hydrocarbons
Uncomroited
240 tW>
flMw)
1.58E-01
1.90E-02
1.45E-02
1.67E-01
9.62E-03
8.48E-03
6.75E-03
6.07E-03
1.21 E-03
1.01 E-03
8.55E-03
2.63E-04
3.32E-04
1.98E-02
3.53E-03
1.29E-02
5.45E-03
1.04E-02
3.34E-04
7.65E-01
Erai&stons
flbvttt)
1.58E-02
1.90E-03
1.45E-03
1.67E-02
9.62E-04
8.48E-04
6.75E-04
6.07E-04
1.21E-04
1.01E-04
8.55E-04
2.63E-05
3.32E-05
1.98E-03
3.53E-04
1.29E-03
5.45E-04
1.04E-03
3.34E-05
7.65E-02
•' ! ::::i:::::::i:i ::i: ': '•
: : ::•:•:;::: ::;: •:
\ i! JljflwihiJ!; ii
1.58E-03
1.90E-04
1.4SE-04
1.67E-03
9.6I2E-05
8.43E-05
6.75E-05
6.07E-05
1.2 IE-OS
1.0 IE-OS
8.55E-05
2.63E-06
3.32E-06
1.98E-04
3.53E-OS
1.29E-04
5.45E-05
1.04E-04
3.34E-06
7.65E-03
iiji;S#«hloai!* Hi
iHrfftHI
i;iii;iiiii(Utdnwii:iiii Hi
1.66E-01
2.00E-02
1.53E-02
1.76E-01
1.01E-02
8.94E-03
7. 11 E-03
6.40E-03
1.28E-03
1.06E-03
9.01 E-03
2.77E-04
3.50E-04
2.09E-02
3.72E-03
1.36E-02
5.74E-03
1.10E-02
3.52E-04
8.06E-01
jjiiiji§$jg$i$J3j::ijj
iiliiliiiiiiiwi^iiiiiiii
1.66E-02
2.00E-03
1.53E-03
1.76E-02
1.01 E-03
8.94E-04
7.11E-04
6.40E-04
1.28E-04
1.06E-04
9.01 E-04
2.77E-05
3.50E-OS
2.09E-03
3.72E-04
1.36E-03
5.74E-04
1.10E-03
3.52E-05
8.06E-02
$jtittgjiiri$$r$
liiffllllS
£n;ii(iR !/$&); iji
NA
1.17E*03
3.56E*04
1.00E+02
1.67E+02
2.00E-01
NA
3.80E+04
NA
NA
NA
NA
NA
1.30E-01
1.45E+03
7.16E+02
1.45E+03
1.45E>03
1.50E+00
NA
CA?
1 Concentration - 47420 ' (emission rate in Ib/hr) / (height in leet * width in feet)
Reference: Air Guide 1 , 9/89
i:\hhc\iask3\tabagc.wki
-------
of unknown compounds and thus no determination can be made of
the significance of these pollutants.
Whether it is appropriate or not to calculate an annual
average for pollutants that may have an acute effect remains
to be examined by regulators. In those cases where no AGCs
have been established, NYSDEC's practice is to require a
literature search to enable an evaluation of the significance
of the concentrations. Since autoclaves and other thermal
processes have never been subjected to the regulatory
scrutiny of other potential sources of emissions, the
procedures for doing so are not defined.
The test program undertaken by BFI at its San Diego
autoclave facility has included other potential compounds,
such as formaldehyde, iodine compounds, and quartenary
ammonium compounds. While the new test results will be
illuminating, they cannot be definitive because the range of
compounds that could be released will be as great as those in
the waste. This concern is substantiated by the high level
of unknown hydrocarbons noted in BFI's test data.
The available data for total hydrocarbons in Table 3.4-2
indicates that the quantity of total hydrocarbons in
emissions from thermally treated Medical Waste may be
significant. One way to determine whether or not they pose a
concern would be to inventory the very large number of
chemicals that are used in hospitals and select a few that
are both likely to be present and have a high vapor pressure.
These could then be used as "markers" of the condensation
efficiency for the unpredictable array of substances that may
appear in any given waste load.
Further analysis also needs to examine the potential for
fugitive emissions from the system. For example, when the
autoclave or other thermal process vessel is evacuated,
residual volatile gases may be emitted. If the disinfection
is followed by a mechanical process, grinding the heated
waste creates a second potential opportunity for volatizing
chemicals, which can escape as fugitive emissions.
In sum, thermal treatment processes generate emissions from
the vessel, and fugitive emissions as well. The degree to
which these emissions must be controlled to meet air quality
standards cannot be determined until their nature becomes
known. However, thermal treatment is not appropriate for many
categories of waste that are pervasive in the medical waste
stream because of their emissions consequences.
.4
-------
1. Office of Technology Assessment, Congress of the United
States, "Finding the Rx for Managing Medical Wastes: OTA
Special Report on Medical Waste Treatment Methods" June
4, 1990, Draft for Discussion.
2. Bingham, W. Browning-Ferris Industries, Medical Wastes
Systems, personal communication, C.S. Konheim, 4-17-90.
3. Spurgin, R.A. Medical Waste Treatment Technologies, OTA
Contract Number N3-2045.0, March 16, 1990.
4. Honahan, K., BFI, personal communication, C.S. Konheim,
5-11-90.
5. Office of Technology Assessment, Congress of the United
States, "Finding the Rx for Managing Medical Wastes: OTA
Special Report on Medical Waste Treatment Methods" June
4, 1990, Draft for Discussion.
6. Reinhardt, P. and J. G. Gordan, Infectious and Medical
Waste Management, Lewis Publishers, Inc. 1990.
7. Spurgin, R., Spurgin Associates, personal communication,
C.S. Konheim, July 21, 1990.
8. Emil, D., Sani-Pak Pacific, Inc., correspondence to J.A.
McGrane, August 6, 1990.
9. Mafrici, NYSDEC, personal communication, C.S. Konheim,
April, 1990.
10. Bingham, W., personal communication, C.S. Konheim, 7-13-
90.
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ATTACHMENT B
THE NEW YORK CITY
MEDICAL WASTE MANAGEMENT STUDY
TASK 4
FINAL REPORT:
THE NEW YORK CITY
MEDICAL WASTE MANAGEMENT PLAN
EXECUTIVE SUMMARY
PREPARED BY
WASTE-TECH
WASTE ENERGY TECHNOLOGIES
HOUSTON, TX - NEW YORK, NEW YORK
FOR
THE CITY OF NEW YORK
NEW YORK CITY HEALTH AND HOSPITALS CORPORATION
JUNE 24, 1991
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
I. PURPOSE AND REGULATORY MANDATE
This document presents a summary of the Task 4 Report of the New York City Medical Waste Management Study. The
Task 4 Report is the concluding report prepared for that study and presents the New York City Medical Waste
Management Plan and recommendations for implementation. Previous report! have presented the basic data and
information necessary for the development of the Plan and the recommendations and conclusions.
The purpose of the study has been to develop a planning document for use by the City in the preparation of a
Generic Environmental Impact Statement (GEIS) for a Comprehensive Solid Waste Management Plan, in compliance
with the New York State Solid Waste Management Act of 1988 (Chapter 70 of the Laws of 1988.
The Act imposes a hierarchy of
1) waste prevention,
2) recycling,
3) incineration of wastes that cannot be prevented or recycled, and
4) landfill of the resulting ash and other wastes that cannot be prevented, recycled or incinerated.
The Act encourages all "planning units' within the State of New York to prepare comprehensive solid waste
management plans for all waste generated within each unit. For the purposes of meeting this planning
requirement:
The City of New York has been designated a planning unit.
The solid wastes that must be addressed include Medical Waste.
New York City Health and Hospitals Corporation (HHC) was assigned the responsibility of overseeing
the development of the medical waste segment of the City's plan.
The Medical Waste study was undertaken, to develop that segment for integration with the City's
comprehensive plan.
Because of the unique concerns surrounding Medical Waste, other federal, state, and local laws have been
enacted that affect the options available to the City for its management. These laws, and the underlying
concerns that prompted them, were considered during the evaluation of available options and the development of
recommendations. Research, literature reviews and on-site surveys and sorting of statistically representative
waste from various categories of generators were conducted to develop the basic data that would allow an
evaluation of the options available to the City for compliance with the Act and other applicable regulations.
H. BACKGROUND ISSUES
All wane generated by health care providers is Medical Waste. Current regulations distinguish between
Regulated Medical Waste (RMW or "red bag" waste), which is subject to certain segregation, packaging, labeling.
manifest, and treatment requirements, and Non Regulated Medical Waste (NRMW or "clear bag" waste). Medical
Waste comprises only about 4% of the City's total solid waste stream. Three important issues distinguish this
small but highly visible portion of the City's massive solid waste stream.
Page 1
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
Worker Safety i»u« first brought public attention to Medical Waste in 1984, with the reported puncture of a
sanitation worker by a needle suspected of being contaminated with the AIDS virus, and led to the passage of
strict Medical Waste regulations in New York City. Since 1989, approximately 50 needlestick injuries uave been
reported by sanitation workers.
Although i| is extremely difficult to determine the exact source of these needle* (Le., corner trash cans or
trash bags from sidewalk collection), no needlestick injuries resulting from the handling of waste from health
care facilities have been reported by DOS workers in the last two years. There have been no known incidents of
HBV or HIV infection resulting from the needlestkks.
Other workers, including housekeeping and other health care workers are punctured with used needles every year.
Most such injuries are not associated with waste handling. Other important worker safety issues arc identified
in the report.
Public Safety issues aroused broad public concerns about Medical Waste in the summer of 1989 as a result of the
beach wash-ups of needle* and other medical device*. Once again, fear of AIDS played an important role, and
strict Federal regulations swiftly led to the imposition of manifest and tracking requirements for wastes that
had the appearance of possible blood contamination. The items that washed ashore were later shown not to be of
hospital origin, but probably originated with drug users, households, or laboratories.
Snifaliny Cost issues have dominated the attention of Medical Waste generators affected by the passage of the
Federal Medical Waste Tracking Act in 1989. The Act resulted in an increase of approximately 300% in the
volume of waste handled by the emerging Medical Waste transportation and disposal industry. In New York City,
over $50,000,000 per year was spent in 1990 for disposal services, up from a negligible amount before 1985.
Other issues include:
The perception by some that hospitals are profligate waste generators who have little incentive to
alter their practices without mandated bans on the use of certain disposables and the imposition of
reduction and recycling quotas.
The local opposition to any kind of waste treatment or disposal facility and the organized opposition
to the expansion of health care facilities in areas of the City that see themselves as overburdened
with institutional facilities.
Concerns about the environmental propriety of certain waste management and treatment technologies,
the practicality of waste source reduction and recycling programs in health care facilities and the
ability of New York City and her Agencies to implement a flexible plan that relies on incentives and
disincentives to promote its goals within a competitive market
HI. MAJOR FINDINGS AND CONCLUSIONS
The major findings and conclusions of this study address the Medical Waste management issues discussed above
and have influenced the recommendations presented in the final report. Those findings are discussed fully in
ihc final report and are summarized below.
Page 2
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
1. Medical Wnte Doe* Not Pose • Significant Public Health RUk.
Although fear of infection or contagion from Medical Waste resulted in rigorous Federal, State, and Local Laws
regulating its disposal, no public health threat attributable to Medical Waste from health care facilities hat
been substantiated in the literature review and other research conducted during the course of this study.
2. Medical Waste Doe» PWKS • Workplace Hazard.
Waste handling workers are exposed to some risks, as are all workers. The risk to those workers results
primarily from puncture injuries incurred during manual waste handling. The syringes and other waterborne
debris of medical appearance that led to the current regulatory climate were largely generated by households
and illegal drug users. Thus, the risk of injury for DOS waste handlers is unlikely to be affected by even the
most draconian Medical Waste regulations.
Exposure to drugs and hazardous chemicals contained in the waste during its btndling or treatment by non-
incineraiion processes may also result in some worker risks. Some equipment used for recycling or treatment of
waste may expose workers to risk of injury, hearing damage due to excessive noise, or other hazards.
3. Medical Waste Constitutes <•% of New York City's Solid Waste.
New York City generates approximately 20,000 TQ&I per day (TPD) of solid waste. Of this amount, 788 TPD, or
about 4% of all solid waste is Medical Waste. Figure 1, below illustrates the total Medical Waste component
of (he City's solid waste stream, and the amounts currently handled as RMW or NRMW. Please note that the
amount shown as RMW includes all waste incinerated on-site, some of which is NRMW from patient-care areas.
NYC WASTE GENERATION
IN TONS PER DAY
NYC SOLID WASTE MEDICAL WASTE
nc. i IWTI-TSCM. tt»i
Page 3
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
4. Moat Medical Waste I* Generated by Acute Care Fadlitle* (ACFs).
Although ACFs account for only 39% of the total number of certified bedi in New York City, they generate 66% of
all Medical Waste and 87% of all Regulated Medical Waste (RMW).
Figure 2, below, illustrates the quantities of Medical Waste for each major generator group established in this
study. The waste generated by Municipal SOGs appears as a small shaded segment in the illustration and is not
labeled
MEDICAL WASTE
GENERATOR CATEGORIES
OTHER ACFi
4348
OTHER SQC»
59.4
HHC LTC»
13.5
OTHER LTC«
1020
788 TONS/DAY
nc i »»m-TtcH
5. There Is a Sharp Difference In the Characteristic! of the Medical Waste Stream Among Generator Groups.
The data show a significant difference in composition between ACFs and LTCs. The composition of ACF and LTC
waste is affected by the differences in services provided, which results in differences in the percentages of
major components. Figure 3 illustrates some of the major components of the ACF and LTC waste streams.
The "PMA" category denotes "Plastic Medical Apparatus". (I.V. bags and tubing, Sharps, Solution Containers,
and Apparatus, as defined in Task 3 of this study.)
The "Added" category denotes the materials used to package RMW, including Sharps Containers, RMW liners, and
RMW shipping containers.
The "Linens' category includes disposable OH. drapes, pants, shirts, isolation gowns, underpads, diapers, etc
Page 4
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
The Taper category denotes til paper products, including Newspaper and Magazine*, Packaging, Office Paper,
Paper Towels, Computer Print Out paper, and Mixed Paper. Corrugated constitutes over 7% of the waste stream.
Two waste components. Kitchen (and other food waste) and Corrugated, are the major waste categories that affect
quantity and composition. These two component categories account for one-third of the total New York City
Medical Waste stream. For some individual generators, these percentages are much higher.
The "Patho- category includes Pathological Waste and Animal Bedding.
MAJOR COMPONENT QUANTITIES
FOR NYC ACFs AND LTCs
360
Thouitad* of Pound! ptr 0*y
300 -
160 -
100 -
MIA
ADDED UKOn FOOD PAFtt OOMO. M1MO
Excludes Amounts Incinerated On -Site
•I ACT ESS LTC
OTStS
nc.3 turn TICK,
6. There la • Great Variability la the Waste Stream Composition Among Individual Generators Within Each
Group.
Substantial differences were also found to exist in the composition of the waste stream among individual
generators. Although the variability in composition among generators is substantial, the average composition
is a valid way to estimate the impacts of waste management options genetically.
Due to (his variability the application of the average waste generation and composition used in this study
would not be valid for individual generators.
7. The Current Medical Waste Regulations Have Resulted in an Ineffective Waste Segregation System.
Approximately 130 TPD of New York City Medical Waste is currently shipped for out-of-state disposal as RMW,
including corrugated shipping containers. Only about 25% of that amount, however is actually defined as RMW by
any regulation.
Page 5
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TI IE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
Over 95% of the waste actually defined as RMW and shipped fgr out-of-*tale disposal consists of I.V. hags and
lubing, sharps, and medical or laboratory apparatus containing body fluids. Pathological wastes constitute
about 2% of RMW and blood-soaked items about 1%. Other laboratory waste and miscellaneous RMW items contribute
a small amount.
Figure 4, below, illustrates the ineffectiveness of the current Medical Waste regulations in achieving adequate
waslc segregation.
RMW COMPOSITION
As Shipped for Export
ENTRAINED
143.151
NED
83,93fl
SHARPS
17.266
eiooor
1.710
PATHO
4.260
SHIP BOXES
38,849
APPARATUS
Z 1.886
As-Shipped RMW
Defined RMW
4 »ASTE-UCJI. HOI
"Entrained" waste is not defined as RMW, but is entrained in the RMW stream in the generation and collection
process.
"Ship Boxes" are the single-use corrugated cartons used by most haulers for handling RMW.
"Bloody" includes any item tinged or soaked with blood.
8. The Current Medlcnl Wn.ite Regulations llnve Resulted In Increased Waste Generation.
As determined in this study, approximately 15,000,000 pounds per year of single-use packaging materials are
required ax a result of the implementation of current regulations. This added waste included 5,200,000 pounds
of red plastic bags and red plastic sharps containers, and 8,979,000 pounds of corrugated boxes. The packaging
of RMW resulting from the implementation of Medical Waste Tracking Act and local regulation* is now one of the
major components of (his waste stream.
Page 6
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
Figure 5, below, illustrates the contribution of packaging rewriting from the current Medical Waste regulation*
to the New York City Medical Waste stream and its composition.
SINGLE-USE RMW PACKAGING
RESULTING FROM CURRENT REGULATIONS
44 M
AS-SHIPPED RMW REQUIRED PACKAGING
rta t tAjtt-TtcM. IMI
9. The Current Regulations Have Resulted In an Increase In the Amount of Waste That Mutt be Handled M RMW.
Before the enactment of the MWTA, it is estimated that only about 5% of all hospital waste was bandied as Ted
bag", or infectious, waste. At present, the amount is about 17% (20% including the shipping boxes). Thus, the
current regulations have contributed significantly to increases in both the total amount of Medical Waste and
the total RMW.
10. New York City Currently Relies on Export For 50% of Alt Medical Waite DUpotal.
Figure 6, below, illustrates the current treatment of Medical Waste generated in New York City. The current
waste management system relies on out-of-state export for 100% of the RMW and 30% of the NRMW. The total
amount of exported waste, over 400 TPD constitutes more than 50% of the total Medical Waste stream.
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
WASTE TREATMENT AND DISPOSAL
CURRENT SYSTEM (1990)
DOS INCIN
300
ONSITE INCIN
70.9
EXPORT
130.Z
SQG EXPORT
614
NRMW EXPORT
235.5
TOTAL MEDICAL WASTE: 788 TPD
no I WAITZ-TtCH. IMI
The 51.4 TPD of NRMW generated by SQGs it repotted to be largely collected by private carters for out-of-city
disposal, although some may be collected along with residential waste u MSW, since many of these generators
are located in residential buildings, thus, most of the NRMW from SQGs is not treated as Medical Waste. Of the
70.9 TPD incinerated on site, it could not be determined how much was RMW, thus all waste incinerated on-site
was assumed to be RMW. However, RMW, and some NRMW from patient care areas are incinerated on-site, as well
as some pathological waste. RMW export includes the pathological waste that is not incinerated on-site and the
shipping containers.
The relative amount of NRMW incinerated by DOS and that which is exported by private carters vary depending on
suspension of service and other factors. The NRMW generated by professional health care providers classified
as SQGs is generally collected as commercial waste and exported to out-of-state landfills, although some may be
collected as MSW by DOS and laodfilled in New York City. Household generator's waste is collected as
residential waste by DOS.
Please note that, although some corrugated and office paper were recycled in 1990, the amounts involved were
small and could not be verified. The 1990 waste stream quantities and composition determined in this study do
not include any recycling streams.
Page 8
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
Ultimately, all waste that is not recycled is either landfilled or incinerated, with the resulting ash also
landfilled.
Hgurc 7, below, illustrates the current ultimate disposal, or landfilled amounts, and the source of the ash
that is landfilled. Approximately 287 TPD of Medical Waste is landfilled out-of-state, mostly NRMW, as we!/ as
75TPDofash.
The ash from hospital incinerators and DOS is landfilled at Fresh Kills. The remaining ash is generated and
tamifill&i ouc-of-scaCc by commercial RMW incinerators.
LANDFILLED AMOUNTS
CURRENT NYC MEDICAL WASTE
MOfRTALI I0.«
DOI 4«
LANDFILL STREAM
ICTNZU tt.s
ASH SOURCES
nc i •Avrt-nof. it«i
11. Cost-Effcctive Waste Management Options Can Reduce Indnentioa and Landfill Requirements by Up To 47%.
This study has found that the implementation of practical cost-effective Management Techniques and on-iite
grinding and disinfection (thermal or chemical) could significantly reduce the amount of waste thai must be
exported, incinerated or landfilled.
Figure 8, below, illustrates that the cost-effective prevention, recycling, segregation, and hospital-based
non-incineration treatment options evaluated in this study can reduce the total Medical Waste incineration and
landfill requirement by up to 47%.
Page 9
,. 5
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
REDUCING THE REQUIREMENTS
FOR INCINERATION AND LANDFILL
KDUCI
CURRENT: 788 TPD POTENTIAL REDUCTION
nc a wtan not. stti
12. Upgraded Existing Facilities May Provide Sufficient Capacity For a Reduced Medical Watte Stream.
As illustrated in figure 8, above, 421TPO of Medical Waste would remain even after implementation of all
prevention, recycling, composting, and on-site non-incineration treatment and grinding of Plastic Medical
Apparatus. Of that amount, approximately 43 TPD would be RMW. All the remaining watte must either be
landfilled or incinerated. Incineration would require landfilling of the ash residue. Non-incineration
treatment would require landfilling of the treated waitc.
The current waste management system does not provide sufficient capacity to avoid dependance on out-of-itate
resources and does not comply with the intent of the New York State Solid Waste Management Act. However, an
analysis of waste quantities and treatment capacity indicates that sufficient waste treatment capacity may be
available in New York City to accommodate the demands of the Medical Waste stream after the implementation of
cost-effective Management Techniques. Section IV of (hit Executive Summary illustrates how the upgraded
current capacity may be effectively utilized.
13. All Treatment Processes Generate Emissions that Must Be Controlled: Effective Control of Incinerator
Emissions Has Been demonstrated.
Landfilling treated or untreated solid waste results hi emissions. AD treatment technologies, including non-
inancration technologies, generate emissions which must be characterized and controlled if they pose
unacceptable risks to workers or the public. At the time of this study, the emissions from non-incineration
technologies have not been characterized sufficiently to establish associated risks or control technology
requirements.
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
The generic evaluation of option* conducted in Task 3 identified the environmental impact* of incineration,
with tandfiUing of the ash residue, to be substantially lower than those of landfuTing solid waste. All of
the incineration options, with landfilling of the ash residue, evaluated result in negligible or minimal risk.
Thus, although all waste treatment and disposal technologies generate emissions and result in risks, mitigation
measures can control those risks. However, not all risks associated with Medical Waste results from emhsiom,
as has been discussed previously ia this report All risks must be considered equally and addressed in order
to comply with the goals of this study.
14. The Health Impacts of Emissions Are Affected by Site-Specific Factors.
The health rink impact of incinerator emissions is affected by the physical features of buildings and other
structures housing or surrounding incineration facilities. All incinerators must be evaluated using site-
specific data during the permitting process. The impacts of incinerator emissions from any facility may be
mitigated by several measures, including facility downsizing, operator training, and fuel preparation.
The health risk from incineration facilities which comply with New York State regulatory criteria are estimated
to be negligible or acceptable for all the options investigated, although the larger oa-site options may, in
some cases, be an exception. Out-of-ctate commercial incinerators, which may be uncontrolled or located in
food-producing are**, may carry much higher risks than in an urban setting. Hospitals, especially those
undergoing renovation, that are in locations where there are no high-rise buildings within about 80 feet, are
acceptable candidates for on-site incinerators and core facilities. All en-site, post-recycling incineration
options evaluated are consistent with all regulatory and statutory requirements.
15. Mart Pathological Waste Is Currently Exported aa RMW.
An estimated 6 tons of waste are burned each day in the 44 operating pathological incinerators. Of this
amount, 3.7 TPD is incinerated in 40 non-HHC hospitals and the remainder in non-HHC LTC facilities, veterinary
and research facilities. Less than 90 pounds per day is burned in any HHC institution. Thus, most hospitals
are shipping their pathological waste out-of-state as RMW.
16. There ia Inadequate Data to Evaluate the Impacts of Pathologic*! Incinerator Emissions.
Although pathological wastes represent a small pan of the existing Medical Waste stream in New York City,
these wastes are not amenable to reduction through management strategies or treatment by non-incineration
technologies. Incineration will be necessary, either outside or within the city.
Until stack measurements are published by USEPA and other regulatory agencies, there are insufficient data to
determine if utilization of the existing 44 incinerators would result in acceptable air quality and health
impacts. Very limited data indicate they may not be causing adverse effects. However, the proximity of many
of these uncontrolled incinerators to sensitive receptors suggests that a preferable course of action may be to
build a regional pathological incinerator.
17. Non-Incineration Technologies May Be Effective in Reducing Incineration Capacity Requirements.
Chemical or thermal disinfection accompanied by shredding and grinding is an accepted method of treatment and
destruction in some Mates, and a increasing in acceptance and experience nationally. Although no alternative
technology in me is suitable for all RMW components or considered a replacement for incineration, some can be
Page 11
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
integrated with incineration to provide a comprehensive disposal alternative. Alternative technologic* may be
used to treat RMW and render k unrecognizable, or decrease the quantity of waste requiring incineration.
Thermal disinfection has been found in this study to be most effective when applied to waste that is segregated
to exclude waste such as closed containers and disposable linens. Chemical processes have been found to be
most effective when applied to relative hard plastic apparatus (PMA).
18. Tbc/e Arc inadequate Regulatory Standards for Noo-Indaenitloo Technologic*.
The emissions from autoclaves and other non-incineration technologies have generally not been characterized.
Thermal and chemical processes may vaporize or aerosolize many organic compounds, some hazardous, known to
exist in Medical Waste. The absence of air emissions permit requirements for non-incineration technologies has
not necessitated the characterization of emissions resulting from the operation of Medical Waste autoclaves,
grinder/sterilizers, or other alternative technologies. The almost complete lack of data on emissions from
these technologies makes the quantitative evaluation of air quality impacts impossible.
19. Low-Level Radioactive Waste Can Be Detected, If Present in Medical Waste, by Passive Radiation Monitoring.
During the course of this study. Low Level Radioactive (LLRW) waste was found in isolated instances in both RMW
and NRMW shipments to out* of-ttate disposal facilities. Hospitals that generate LLRW in the course of the
treatment or diagnosis of patients have generally instituted rigorous detection programs.
20. The Current Medical Waste Management System Cost for New York City is $150,000,000 per Year.
1990 WASTE MANAGEMENT COST
FOR MAJOR GENERATOR GROUPS
150 Million Dollars
no, 9 WA»IT TTCM,
Page 12
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
In 1990, the total cost of Medical Waste management, operation* and disposal to the health care system of the
City of New York, both municipal and non-municipal, was $150,000,000. The total cost of waste management
operations for the generator groups identified in this study is illustrated in Figure 9, above.
Figure 10, below, illustrates the major cost components of the current New York City Medical Waste management
system, as established in this study.
COST COMPONENTS
Of Present Management System
NT*
ton BUP
won
of Total Cost
% of Labor Cost
HO. 1C IAVTC-TIQ1. lt*l
RMW disposal cost is approximately $0.42 per pound, while NRMW disposal by NYDOS is $0.028 per pound. The
average price charged by private carters to hospitals for NRMW is $40/cubk yard, or about SO. 13 per pound.
This rate is about three times that charged to commercial waste generator*. Waste collection tervice to
hospitals is not regulated by the Department of Consumer Affairs.
21. Continued Reliance on Export and Landfllllng of Treated or Untreated RMW Is Inappropriate.
The amount of Medical Waste exported and landfilled out of the City would increase under some current
proposals. This direction would be in opposition to the State's solid waste management hierarchy, which gives
landfills the lowest priority. It would also be in opposition to state law, the intent of which is to develop
self-sufficient solid waste districts. Other states faced with the same problem are expected to succeed in
developing legislative restrictions to the importation of waste to protect the rapidly diminishing landfill
capacity. At the current rate of use, New York State's landfill capacity, outside New York City, will be
exhausted in 1998. Because of this and other factors, the most critical landfill issue facing New York City's
Medical Waste generators is the potential restriction of exports.
Technologies such as autoclaving, microwaving, irradiation, or chemical treatment were not found to reduce the
quantity of waste requiring ultimate disposal through combined incineration and landfilling.
Page 13
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
22. Some Landfill UK* Are Appropriate and Will Arwayi Be Required,
In spite of public resistance to accepting New York City waste of any kind at out-of-state landfill*, tome
landfilling of treated RMW and NRMW will continue for the next 3-10 yeari. Landfill* will continue to be the
ultimate repository of the residue from all treatment processes. If all Medical Waste were to be incinerated,
about 245 TPD of ash would require landfill disposal.
23. Single-Solution Waste Management Plan Model* Arc Inappropriate for tht Development of the New York City
Medical Waste Management Flan.
Private sector proposals for treatment facilities have focused on single-solution approaches such as large
incineration and autoclaving facilities. The only currently available option for dispoul of RMW continues to
be export to out-of-state facilities. Single-solution options do not offer to create more market-sensitive
pricing mechanisms that could ultimately lower the extraordinary burden currently borne by heakh care
institutions. Single-solution options have consistently been widely opposed by the public, and thus may be
expected to face lengthy permitting and siting processes. The public ha* so far remained unconvinced that
either City government or the private sector can effectively protect public heakh through reliance on single-
solution waste management models.
24. Mandated Waste Prevention and Recycling Qnotaa Art Inappropriate for Inclusion In the New York City
Medical Waste Management Plan.
Mandated waste reduction and recycling quotas would require the establishment of a baseline waste generation
rate against which to measure progress towards a mandated quota. Because of the significant variance in waste
composition and generation among Medical Waste generators, the Use of average per-bed city wide generation
rates or composition to establish mandated reduction quotas would result in grossly unfair targets which would
be unattainable by many individual generators. Therefore uniform mandated targets could not be implemented,
and would not achieve the levels of waste reduction and recycling projected in this study.
25. Mandated Implementation of Waste Management Technique* and Treatment and Disposal Option* are
Inappropriate for Inclusion In the New York City Medical Waste Management Plan.
Health care facilities have widely different patient populations, with a large variety of health care and
infection control requirements. These varying requirements result in a variety of activities that generate
very different types of wastes. Tha different average composition reported in this study for the waste
generated by major groups masks the even sharper differences in waste composition among individual generators,
and the infection control and health care practices that cause these differences.
Mandated waste prevention programs (i.e., mandated use of reusable diapers) would impose uniform waste
management requirements that would fail to address the important differences in infection control (i.e., the
population of patients with communicable diseases) and health care requirements (Len the population of adult
incontinent patients) among individual facilities.
Mandated segregation and treatment requirement! (i.e., segregation of PMA) would impose uniform requirements
that address wastes that may be an insignificant portion of the waste from certain individual facilities (i.c.
u residential facility).
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
26. An Integrated Waate Management Approach it Appropriate for the New York City Medical Waite Management
Plan.
The New York State Solid Waste Act of 1988 mandates the development of integrated solid waste management plans
that include source reduction, recycling, incineration in waste-to-energy facilities, and landfill of residues.
Although the state hierarchy of waste management strategies places source reduction at the top, no practical
source reduction steps have been taken. Recycling, the second tier of the integrated hierarchy, has been
mandated for institutional waste generators in New York City.
The individual waste management options identified and evaluated in this study do not represent comparable and
alternative approaches to Medical Waste management. Some options are applicable to specific waste components
of the waste stream, while other options are intended to provide treatment and disposal capacity for the waste
stream as a whole.
Thus, any Medical Waste Management Plan must integrate a variety of options in order to meet the requirements
of the New York City Medical Waste stream.
IV. PRINCIPAL RECOMMENDATIONS
Reduce the Quimtky and Hazards of the Medical Waste Stream Thrnuyh Cost-Effective Options.
The study concludes that the City of New York can encourage the development of a Medical Waste management
system that complies with the State Act by encouraging the implementation of cost-effective waste prevention,
segregation, recycling, and on-jite non-incineration treatment options. Such cost-effective options would
reduce the current Medical Waste stream by up to 47%. Another 47% may be incinerated without a significant
public health risk in new or upgraded regional and on-site facilities that meet current standards. The
remaining 6%, all of it from physicians and dentists offices and other small generators, would be collected as
commercial or residential waste, a* it is at the present time.
The segregation treatment and grinding of Plastic Medical Apparatus (PMA), sharps and vinyl gloves was found in
this study to offer the greatest potential among the identified options to reduce the quantity and possible
hazards of the RMW stream. Over 95% of the waste actually classified as RMW by current regulations consists of
PMA. However, under the present system, only 25% of the waste shipped as RMW is actually defined as such.
Thus, the City of New York could promote the rectification of a major portion of the RMW stream by
encouraging on-site disinfection and grinding of PMA. The hazards associated with the post-collection handling
and incineration of the remaining RMW may also be reduced by this approach. By treating and destroying sharps
on-sitc, the risk of needle punctures by waste handling workers would be reduced. The removal of PMA from the
portion of the waste stream requiring incineration would remove the largest identified source of chlorine in
hospital waste, thus reducing chlorine emissions. The centerpiece of the approach recommended in this study is
the development of site-specific waste management plans that target specific components of each generator's
unique waste stream for reduction, segregation, and possible on-site treatment. The development of such plans
would be required for each individual generator as a part of a Waste Generator Permit System.
Page 15 ,
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
Based on the average characteristics of the New York City Medical Waste stream, the implementation of cost
effective waste management plam would reduce the total Medical Waste stream as follows:
11% reduction through cost-effective waste prevention programs.
12% reduction by segregating and recycling corrugated boxes and office paper.
17% reduction by collecting all food service and kitchen waste separately for composting by DOS.
2% reduction by draining containers of sterile solutions and non-toxic fluids to the sewer through
on-iite treatment and grinding.
5% reduction by recycling ground plastics resulting from the on-site treatment of I.V. bags, tubing,
and other Plastic Medical Apparatus (PMA) with thermal or chemical disinfection techniques.
Effectively \ M]JM ftlC A^^le Treatment Capacity.
The study concludes that the current incineration capacity would be sufficient to meet the present requirements
of New York City, provided that it is upgraded to meet current standards and that it is effectively utilized.
The future requirements are not expected to exceed current levels.
The study found that, in 1990,788 TPD of Medical Waste was disposed of as follows:
130 TPD is exported as RMW for incineration.
300 TPD is incinerated as NRMW by DOS.
236 TPD is exported as NRMW to out-of-state landfills.
51 TPD is collected as Municipal Solid Waste (MSW) from SOGs and landfilled, mostly out-of-state.
71 TPD is incinerated on-site. Since 1990 some of these incinerators have discontinued operations.
The study has shown that about 75% of the waste exported as RMW is not defined as such, but results from
inadequate segregation or overzealous interpretation of current regulations. The data indicate, and a pilot
program conducted by HHC confirms, that the segregation of Plastic Medical Apparatus (PMA) and on-site treatment
through thermal or chemical disinfection and grinding could result in the elimination of most entrained waste, as
well as mo&t single-use RMW shipping boxes and disposable sharps containers. Other cost-effective waste
prevention options identified in this study could further reduce the waste stream.
The 536 TPD of NRMW that is incinerated by DOS or exported to out-of-ttate landfills includes 98 TPD of
recyclable corrugated and office paper and 131 TPD of compostable food service and kitchen waste, components that
do not require incineration.
Thus, the implementation of site-specific waste management plans that incorporate these steps, or achieve similar
results through other approaches, would reduce the capacity required for the incineration of that portion of the
waste stream that cannot be prevented or recycled from the current 788 TPD to 421 TPD, a 47% reduction.
Page 16
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
The reduction of the Medical Waste stream and the required treatment capacity would be achieved as follows:
84 TPD would be eliminated by using reusable container! and implementing other prevention programs.
136 TPD would be segregated for recycling.
131 TPD would be segregated for composting.
16 TPD of sterile solution* and non-tone fluids would be drained to the sewer.
This study has found that the health risk and other adverse impacts of i«i»MilKi*g treated or untreated Medical
Waste are far greater than for incineration. Therefore, this study recommends incineration for that portion of
the Medical Waste stream that couid not be prevented or recycled and must thus be incinerated or tandfillcd.
Of the remaining 421 TPD, the NRMW from SQGs could continue to be collected and disposed of as MSW, and thus
would not require treatment as Medical Waste. The new or upgraded existing capacity could be effectively
utilized for the other 370 TPD of Medical Waste that would continue to require incineration, as follows:
300 TPD would be incinerated as NRMW by DOS in upgraded facilities.
18 TPD would be incinerated in low-risk hospital-based facilities.
44 TPD would be incinerated in a tow-risk regional RMW facility.
8 TPD would be incinerated in a low-risk regional pathological facility.
The net amount of Medical Waste iandfiUed, including ash would decrease from 362 TPD to 106 TPD, as follows:
The amount of ash Iandfilled would decrease from 75 TPD to 55 TPD.
The amount of NRMW Iandfilled would decrease from 236 TPD to 0 TPD.
The amount of RMW exported for incineration would decrease from 130 TPD to 0 TPD.
Institute Reyulatorv Systems to Encourage Waste Reduction
The study recommends measures that the City can implement to achieve the waste reduction and disposal system
outlined above. These include:
Establishment of a Waste Generator Permit System with filing feet and other requirements based on the
generator's current waste quantities. The system would replace and augment current filing
requirements and would require each generator to develop a rite-specific plan stating reduction goals
and approaches.
Development of threshold standards for certain recyclable and regulated components in waste disposed
into the DOS system or handled by private carters.
Assurances to holders of valid Waste Generator Permits that DOS collection service would not be
suspended arbitrarily for exceeding threshold limits, coupled with a pass-through to the generator of
any coats incurred by DOS to dispose of such waste through private carters.
Discontinuance of service to non-permitted generators. Permits would require annual renewal, and
could be denied to generators who do not comply with their own plans or who are frequent threshold
violators.
Page 17
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THE NEW YORK CITY MEDICAL WASTE MANAGEMENT STUDY
EXECUTIVE SUMMARY OF THE FINAL REPORT
The above recommendations would act in concert to strongly encourage compliance with the City's reduction,
recycling, and waste segregation goals, while allowing each generator the necessary flexibility in achieving
thote goals. That flexibility is critical, because the study has found that the kinds of waste management
techniques that lead to significant reductions in waste generation vary widely among generators.
Control Waste Composition at the Point of Dignoad to Achieve Comnli/mce with the Gtft CrQali,
Although the City is responsible for meeting the State mandate, it is individual generators that must actually
implement effective waste reduction, recycling and ultimate disposal programs. For that reason, the study
evaluated a variety of options for experience, feasibility, public health and worker safety, and environmental
and economic impacts. The evaluation of those options was conducted geaericaUy, as is appropriate for a GEIS.
The study concludes that each generator must evaluate any option on a site-specific basis, since the impact of
any option is subject to a large number of factors unique to each institution. The generic evaluation of
options, however, may serve to educate generators as to the wide range of available options and their impacts.
The *tudy thus provides a "menu* of options that have been found, genericaUy, to achieve the planned goals on
a city-wide basis.
Because of the well-documented variability among generators, tome facilities may achieve their reduction goals
through the intensive implementation of just a few options, while others may opt for a broader-based approach.
The implementation approach would clearly be within each generator's control
The establishment of realistic threshold levels for waste components at the point of disposal, however, would
assure compliance with the City's waste reduction goal*, since, in order to meet the thresholds, each generator
must implement effective waste prevention or segregation programs.
Do Not Mandate Specific Wflfte Reduction Quota^.
A seemingly simpler approach, the adoption of nundated goals and product bans, has been recommended by tome.
It is important to understand that, after extensive investigation, the study found that such mandated programs
cannot result in the achievement of the projected reduction goals.
The establishment of a baseline against which to measure compliance with mandated goals presents a formidable
obstacle to the consideration of such programs as realistic alternatives to the recommended strategy. Such
factors as the constantly varying mix of reusable and disposable items by some hospitals in response to
changing health care needs (i.e., the number of patients in isolation), the constant fluctuation in patient
census (number of occupied beds), the ratio of Intensive Care Unit 0CU) beds to other beds, and a multitude of
other variables would require consideration. In the absence of a verifiable baseline for each generator,
efforts to require compliance with mandated reductions would be fruitless. Arguments for adjusting a baseline
can assume Byzantine proportions if all pertinent, interactive factors are to be considered.
Therefore, the implementation strategy recommended in this report establishes a system that encourages the
development of coat-effective, site-specific waste management plans by individual generators and insures
compliance with the City's mandated reduction quotas by establishing threshold levels that specify the maximum
allowable content of recydables in the waste at the point of disposal Therefore, in order to achieve the
thresholds, individual generators would have to determine the composition of their waste and develop systems to
effectively reduce their most prevalent components. The recommended strategy would achieve the desired
reductions without imposing unrealistic burdens on health care providers.
Page 18
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C. DISCUSSION
Following the EPA presentation, Mr. William O'Sullivan
inquired about the relationship between dioxin emissions and
secondary chamber residence time and temperature. He questioned
if there actually is much difference in emissions with a
residence time greater than 1 second (sec) considering the
limited number of data points used as the basis for this
determination. Mr. James Eddinger of EPA responded that the
number of data points is few; based on the units tested, however,
there was a reduction in dioxin emission between 1 sec and 2 sec
from approximately 2500 ng/dscm to approximately 500 ng/dscm.
One of these units with a 1.75-sec residence time was tested over
a range of temperatures (1600°F to 2000°F). In this case, the
difference in temperature had no effect in dioxin emissions. He
suggested that perhaps there is a tradeoff with residence time
and temperature.
Mr. O'Sullivan asked if, looking at capital costs for
existing facilities, there are alternatives to replacing the
secondary chamber with a larger one by perhaps increasing
turbulence in the existing secondary chamber. Mr. Eddinger
responded that turbulence is a difficult factor to measure. The
EPA has not decided how to define the regulations or if there
will be a requirement for residence time. The standard might be
a numeric limit that each facility can meet in its own way.
Mr. O'Sullivan commented that the carbon injection for mercury
(Hg) control looked very promising. He asked if EPA has, in
addition, considered waste separation programs as an option for
reducing Hg. Mr. Eddinger responded that Hg emissions varied
considerably among the medical waste incinerators (MWI's) tested.
The facility tested with carbon injection had the highest levels
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of Hg. This facility had recently implemented a battery recycle
program but was not sure how effective it was. There was no
significant change in Hg emissions between the first test without
the recycle program and the second test with recycle. The
facility is not sure why the Hg levels are so high.
Mr. Ralph Hise inquired about nitrogen oxide (NOX)
emissions. Typically, NOX emissions increase with higher
temperatures. Mr. Hise asked why EPA had not reported any NOX
emissions data. Mr. Eddinger responded that based on test data,
there is no significant difference in NOX emissions in the MWI
secondary chamber operating temperature range (1600°F to 2000°F) .
Generally, NOX emissions are approximately 120 parts per million
(ppm) corrected to 7 percent oxygen (O2). Mr. Eddinger added
that there is no difference in NOX emissions between the
different types of MWI's. Mr. Hise added that NOX is a factor in
areas where MWI's are located. Mr. Eddinger explained that EPA
is required to set a standard for NOX and that EPA has
investigated various NOX control technologies such as non-
catalytic reduction systems.
Ms. Vivian Mclntire noted that EPA has tested or is planning
to test 7 out of 7,000 MWI's. She asked if this is a
representative sample of the 7,000 existing units. Mr. James
Crowder explained that certainly the different types of
combustors have been represented by the 7 over a range of waste
and temperatures. Ms. Mclntire also asked if the increased cost
per ton of waste ($327/ton) reported are in addition to normal
operating costs. Mr. Eddinger said that was correct. These
costs are over and above the facility's normal operating costs.
The $327/ton is an average cost increase per ton for all three
sizes of MWI's. The large units will have a lower cost increase,
and the smaller units will have a higher cost increase.
Ms. Mclntire added that one method of substitution referred to in
the EPA reports was offsite contract disposal. However, the
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additional costs over baseline affecting the larger incinerators
will indirectly affect the smaller units because larger
facilities will pass these costs on to their customers.
Mr. Eddinger responded that the additional cost for a large
facility is much lower than that for a small facility. The
background documents present the additional costs for each size
of facility. Mr. Tim Watkins of EPA added that EPA's cost
estimates for contract disposal include these additional costs
for large commercial facilities. Mr. Patrick Atkins asked what
is the current cost for contract disposal. Mr. Watkins estimated
this cost at $600/ton, and EPA has estimated an increase in this
cost under each control option.
Ms. Deborah Sheiman asked whether EPA has any data on the
percent of small and medium existing MWI's that have the BEST
level of control or what the top 12 percent have. Mr. Eddinger
responded that very few existing MWI's have add-on controls.
Approximately 200 facilities with controls have been located, and
the majority of these are in the large size category. EPA has
identified approximately 12 percent with the BEST control. There
are very few small and medium controlled units. Ms. Sheiman
expressed concern that EPA might tend to regulate the existing
smaller units less stringently. If communities have difficulties
siting new units with the more stringent regulations, they will
be forced to rely on the existing poorly controlled MWI's. She
added that this is a factor EPA should consider in developing the
regulations. Mr. Richard Copland replied that EPA will look at
the maximum available control technology (MACT) floor and cannot
be any less stringent than that. Mr. Eddinger added that EPA is
analyzing options that are more stringent than the MACT floor.
Ms. Sheiman added that she feels EPA should look at the politics
involved.
Mr. Brian Toranto indicated that EPA had generally defined
three waste types—general, pathological, and red bag waste—and
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at least two different feed cycles. He asked if, with regard to
MACT floor, EPA is considering differentiating within each MWI
size category based on waste type and feed cycle. Mr. Eddinger
responded that EPA has looked at that. There is no significant
difference between red bag waste and general waste. However,
there is a difference between these wastes and pathological
waste. Therefore, pathological waste has been subcategorized.
There is no significant difference in emissions between a
continuous feed unit and an intermittent duty unit. There is
some difference in emissions from batch units. However, this
difference is not sufficient to justify a separate category.
Mr. O'Sullivan had the following comments and
recommendations for regulating MWI's:
1. States have been regulating MWI's for the past 5 years
with much less data than EPA has. The EPA data base is a fairly
good one for decision making;
2. The EPA should be as stringent for small MWI's as for
large MWI's;
3. Because of tremendous public opposition to MWI's, EPA
should tend to be more stringent rather than less stringent; and
4. The EPA should look at requirements for stack heights.
Mr. William Dennison added that operator training is
important and asked if it will be part of the MACT requirements.
Mr. Eddinger responded that, through the test program, EPA has
investigated varying the feed and operating parameters. These
parameters did have an effect on emissions. Mr. Dennison added
that different charging mechanisms also have an impact on
emissions and asked if they would be included in the MACT
requirements for both new and existing MWI's. Mr. Eddinger
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replied that EPA is investigating this issue to determine what
type of monitoring or work practice requirements should be
developed. He added that the regulations might require some type
of automatic loading system on new units. Mr. Dennison asked if
EPA is investigating any alternative types of combustion for new
units other than dual chamber, starved air. He asked if there is
perhaps a better combustion process than BEST. Mr. Eddinger
responded that in terms of this project, the only alternative to
a typical controlled air unit that EPA has looked at is the
rotary kiln combustor. The EPA is currently testing this type of
unit. Mr. Dennison asked if conceivably MACT could go to a
different process—not just the add-on but the up-front as far as
the original generation of the pollutants. Mr. Eddinger
responded that basically EPA will require a set of emission
standards based on tests. Mr. Copland added that if the rotary
kiln is better in terms of emissions, the standard might be based
on that; however, a facility would not be required to have a
certain type of combustion process.
Mr. John Pinkerton commented that the baseline calculations
seem to be different between the reports and the presentation and
asked how they were calculated. Mr. Eddinger responded that the
presentation is the most accurate. He explained that there are
two different baselines, one for new units based on a 1-sec
residence time and one for existing units based on a 1/4 sec
residence time. The numbers were calculated as the average of
the test data for each type of unit. Mr. Pinkerton asked why
particulate matter (PM) emissions for new units are reduced by
good combustion control (GCC) from 0.16 to 0.1 grains per dry
standard cubic foot (gr/dscf) but lead and cadmium emissions are
not reduced at all. Mr. Eddinger responded that the reduction in
PM is due to the organic soot that is combusted in the system,
not the metals. Mr. Pinkerton wanted to know if dioxins and
furans are expressed in toxic equivalents. Mr. Eddinger replied
that the numbers presented are total dioxins and furans, tetra
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through octa isomers. Mr. Pinkerton added that this breakdown
would be important for health impacts because information on
total dioxins does not reveal very much. Mr. Crowder responded
that for any risk assessments the dioxins and furans will be
broken down.
Mr. Pinkerton asked if EPA has looked at radionucleid
emissions from MWI's burning radioactive waste. Mr. Eddinger
responded that these emissions are regulated elsewhere. Mr.
Pinkerton added that radionucleids and polycyclic organic matter
are on the list of 189 hazardous air pollutants. Mr. Eddinger
added that none of the hospitals tested indicated that they burn
radioactive waste. Mr. Pinkerton asked if there is a plan to
restrict burning this waste in MWI's. Mr. Crowder replied that
EPA is not required to regulate pollutants from the list of 189
for MWI's. Mr. Bruce Jordan, Director of BSD, said that MWI's
are not on the list, they are only regulated under Section 129 of
the Clean Air Act Amendments. Radionucleid emissions are
regulated elsewhere.
Mr. Pinkerton asked what the current thinking is about
compliance emission testing for these MWI's, considering how
expensive the testing will be (especially dioxin/furan testing).
Mr. Eddinger responded that the current thinking is that initial
compliance testing will be required on new units. He added that
EPA is currently investigating the costs.
Mr. Donald Arkell asked about the spore count on Facility J.
This facility has a lower spore destruction than any of the
others, yet it has good combustion (2 sec residence time at
1800°F). Mr. Eddinger replied that EPA has not been able to
explain this anomaly. It may be due to the way the data are
analyzed and recorded. He added that there was a trend towards
higher spore counts detected in the stacks on units with lower
residence times for facilities B, K and S. Facility J does not
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follow this trend. This facility is a batch unit. High spore
counts in the ash can be expected but not in the stack.
Mr. Copland added that heat-resistant spores were used for the
pathogen testing. Bacteria and infectious agents would destruct
much easier than the spores used in the tests. Mr. Arkell
expressed concern that the public's biggest fear is pathogens.
He was very surprised that pathogens were not completely
destroyed. Mr. Eddinger replied that the Office of Solid Waste
(OSW) is investigating pathogen destruction for all medical waste
treatment techniques and will compare incineration with other
treatment techniques.
Mr. Dennison asked why EPA reported that crematories do not
have the option of substitution. Mr. Eddinger replied that by
substitution EPA is referring to a different means of waste
treatment and disposal. Crematories have no substitute because
incineration is their business.
Mr. Atkins asked if EPA is required to look at the cost,
risk, and health impacts of transporting the waste when a small
facility substitutes offsite disposal for onsite disposal.
Mr. Eddinger responded that EPA is not required to look at health
impacts in any part of this regulation. The cost impacts have
been included. Mr. Watkins added that the $600/ton includes the
transportation costs. Mr. Atkins confirmed that the
transportation cost is included in the baseline cost ($600) but
not in the additional ($327) cost.
Mr. Jordan proposed that the committee think about the
problem of developing a data base through testing for such a
large source category (7,000 facilities), considering the costs.
Mr. Toranto asked if facilities will be required to do
performance testing. Mr. Jordan responded that EPA is thinking
that they will be required to do so, but the costs are great.
Ms. Mclntire asked if EPA is currently including cost estimates
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8
for testing/monitoring/maintenance costs. Mr. Eddinger responded
that EPA is in the process of determining low-cost ways of
monitoring (will not be as good as continuous emission monitors
[OEM's]) once the initial test is passed to indicate that the
equipment is operating as it was during the performance test.
Ms. Mclntire suggested that all these costs be considered in
developing the standard.
Mr. O'Sullivan commented that C>2 and carbon monoxide (CO)
monitoring is used in New Jersey for operational reasons, and CO
is used as a surrogate to dioxins. New Jersey went to the public
with this practice and as a result of comments added dioxin
testing at startup and every fifth year. New Jersey found that
indeed dioxin varies with combustion practices and there is good
technical reason for requiring dioxin testing.
1. Discussion following the Cremation Association of North
America (CANA) presentation
Following the presentation by CANA, Ms. Mclntire asked what
emissions EPA is concerned about from crematories. Mr. Eddinger
responded that through the test program EPA has tested 100
percent pathological waste. The overall emissions from this
waste are lower than those from mixed medical waste, but dioxins
and some metals are emitted at the facility EPA tested.
Pathological waste incinerators emit all pollutants of concern
listed under Section 129. Mr. Paul Rahill commented that CANA is
not aware of any testing done on crematories that considered
dioxins, usually the pollutants of concern are PM and CO.
Mr. Eddinger added that the type of waste fed into the system
tested by EPA was not human remains or tissue but consisted of
animal carcasses. Mr. Copland indicated that the wastes are
expected to have, for the most part, the same composition as
human remains. The EPA has subcategorized pathological waste
from mixed medical waste. Mr. Harvey Lapin added that most of
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CANA's members do not cremate animal waste and are not
technically allowed to do so. He suggested that maybe EPA could
further subcategorize pathological waste into animal remains and
human remains. Mr. Copland responded that if EPA can show a
difference in emissions between incinerating human remains and
animal remains then this could be an option. Mr. Eddinger added
that one of the reasons crematories were initially considered is
the possibility that some crematories might be incinerating
medical waste as well and EPA would want to cover these
facilities in the regulation. Also, if EPA is looking at
pathological waste, then why not consider crematories if the
emissions are the same. Ms. Mclntire agreed with this, if the
emissions are the same. The presentation, she said, mentioned
only CO and PM. Mr. Eddinger said that EPA has tried to locate
test reports from crematories and is aware of testing done by the
California Air Resources Board (CARB). Mr. Edward Laux added
that these tests are complete and the results are due out "any
day", and that EPA is on the distribution list.
Mr. Pinkerton asked what type of fuel is typically used in
these units. Mr. Rahill responded that typically natural gas is
used. Mr. Pinkerton also asked if any of the existing
crematories had any type of control device. Mr. Rahill responded
that most cremators have secondary chambers. In some parts of
the country, wet scrubbers that are nothing but a spray chamber
are required. Mr. Pinkerton asked what CANA expects in terms of
new crematories in the next 5 years. Mr. Rahill responded that
this is a controversial issue but that growth is definitely
expected.
Mr. Dennison stated that he believes that crematories are a
simple batch-type unit. Basically, once the unit is turned on,
it controls itself. Mr. Rahill explained that the body is loaded
into the incinerator inside a box or casket, and the unit is
preheated automatically and controlled with temperature controls.
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10
The cycle lasts approximately 2 hours. Mr. Dennison asked if
most crematories are automated batch systems. Mr. Rahill said
yes. Mr. Dennison asked if CANA would enter into a program to
help EPA characterize emissions from crematories. Mr. Rahill
replied that this has been done in Sacramento County, but the
results are not yet available.
Mr. Arkell asked if CANA could technically describe the
types of add-ons available for crematories. Mr. Rahill responded
that typically there are no add-ons on crematories. The add-ons
available are the same as those for other incinerators: wet
scrubbers, baghouses, etc. Mr. Arkell asked if anything can be
done to the secondary chamber to stretch out the residence time.
Mr. Rahill responded that the residence time on newer units is in
excess of 1 sec and for older units is approximately 1/2 sec to 1
sec. On most installed equipment, because of the nature of the
buildings they are installed in, retrofit to the secondary
chamber is most unlikely. Mr. Hise asked if it is difficult to
raise the temperature to 1800°F. Mr. Rahill responded that it
would be difficult for these units. He added that increasing the
temperature from 1600 to 1800°F could require additional burner
equipment.
Mr. O'Sullivan asked CANA to comment on other materials that
might be included in human remains such as the container, medical
devices, and tooth fillings. He asked if these materials are
controlled by some type of good waste management practices at
crematories. Mr. Lapin responded that through a survey of its
members, CANA found that most members (approximately 85 percent)
do not burn caskets. Almost every crematory prohibits medical
devices and requires that they be removed prior to cremation
because they can damage the incinerator if they explode.
Pacemakers are prohibited for the same reason. Mr. Laux added
that this does not include nuclear-powered pacemakers, which are
very rare these days. These devices are required by the Nuclear
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11
Regulatory Commission (NRC) to be returned to the source. He
also added that by regulation in many States, all devices that
have a nickel/cadmium battery or are somehow mechanically
assisted must be removed from the body by the funeral director,
who signs a certification to that fact prior to transportation to
the crematory. Mr. Laux believes that this was a problem at one
time (15 to 20 years ago) but is no longer a problem.
Mr. O'Sullivan asked about Hg in tooth fillings. Mr. Laux
replied that a survey in Europe indicated that the American
Dental Association stated that it has not used Hg-based fillings
in this country for 25 years or more. He added that if this is a
problem, it is very insignificant.
Mr. O'Sullivan asked if CANA has recommended any good
management practice alternatives, such not burning caskets, to
control the emissions from incinerators. Mr. Laux replied that
it would be impossible to discourage caskets. He added that CANA
has been working with casket manufacturers to develop an
environmentally safe casket to be used in cremations. Mr. Lapin
added that CANA also offers an annual training course for
crematory operators, and part of the program deals with this
area.
Mr. Atkins asked if CANA would support the Sacramento County
test data. Mr. Laux said he could not respond on behalf of the
Association but that in his opinion the criteria used in the
California tests are somewhat confusing. Sacramento County
started out in one direction, then reversed when a story of an
alleged reduced threat of dioxins in the United States was
published that caused them to go back and retest. He is not sure
of the outcome of these tests. He added, though, that the
industry has cooperated with the California district doing the
test.
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Mr. Jordan asked if there was a difference in costs in
regulating new MWI's versus existing MWI's. He asked if EPA
decides to regulate new units, understanding that the economic
impacts on existing units are severe, what impacts would this
have on the industry? Mr. Rahill responded that the new units
would not be able to compete with the cheaper existing units (at
approximately 30 percent lower operating costs), therefore
limiting growth.
Mr. Pinkerton asked what the lifetime of a cremator was.
Mr. Rahill said approximately 20 years, though some existing
facilities are over 40 years old.
Mr. Bruce Varner of EPA Region V asked if the Agency has
looked at testing for Hg from tooth fillings. He added that
removing them prior to cremation would be very expensive.
Mr. Eddinger responded that EPA has not tested a crematory and
therefore is not aware of a problem with Hg emissions from these
facilities.
2. Discussion following the Waste Combustion Equipment
Institute (WCEI) presentation
Following the presentation by Mr. Stephen Shuler of the
WCEI, Mr. Dennison asked if Mr. Shuler, with respect to his
comments on the California facility with a wet scrubber system,
believes wet scrubbers exist that can meet the limits determined
by EPA to be the BEST [using the dry injection/fabric filter
(DI/FF)]. Mr. Shuler said he could not respond on behalf of WCEI
but would give his opinion. He said that the facility tested in
California by CARB is a Joy Energy Systems incinerator with a
Ducon venturi scrubber (VS). The VS was designed for
hydrochloric acid (HC1) removal only with no intentions of
removing particulates, metals, and dioxins. One vendor has been
able to demonstrate achieving 0.015 gr/dscf for particulates. It
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13
has been tested for dioxins, heavy metals, etc., and he would not
go so far as to say that this facility has demonstrated the- BEST
capability there. Mr. Shuler stated that his main point is that
EPA's data base is not representative of recent technological
developments in the MWI industry; there is virtually no data
base. Mr. Dennison asked if the standard was developed as a
numerical standard, would Mr. Shuler feel that EPA should
eliminate the presumption that wet scrubbers cannot meet the
standard, or does he feel that newer wet scrubbers can achieve
better limits? Mr. Shuler responded that there is no MWI
facility currently operating with a spray dryer/fabric filter
(SD/FF) system. The EPA data base is deficient for that
particular type of system, so the analogies that have been drawn
were based on large municipal waste incinerators with SD/FF
systems. Medical waste incinerators have different combustion
characteristics and have much more variation in terms of
excursion of the volume of gas, actual cubic feet per minute
(acfm). Therefore, they are much more difficult to control.
Mr. Shuler added that there are several DI/FF systems, but again
these units have only been in operation for the past 2 to 3 years
and the data base for these systems is also shallow. The
regulations on the State level have within the last 2 years only
begun to address emissions in establishing specific target or
allowable thresholds for criteria pollutants. Only very recently
has there been any focus on heavy metals, as far as the
controlled thresholds associated with those applies. Also, there
has been no legitimate testing on dioxins or on beginning to
establish an allowable threshold. Mr. Shuler said he would
recommend that rather than trying to define the technology
(unproven and untested), EPA should develop a numerical standard
based on good technical and scientific evaluation for the
appropriate protection of human health and the environment.
Mr. Dennison added that the law requires that existing facilities
be regulated as stringently as the best 12 percent and that new
units be controlled as stringently as the best single unit. He
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also asked if the WCEI is willing to work with EPA to add to the
existing data base. Mr. Shuler responded that the WCEI would
absolutely work with the EPA to increase/develop its data base.
The WCEI attempted to do so and has been very supportive of EPA's
efforts all along. He added that there has been an unfortunate
lack of funds for the test program to properly select those best
performing 12 percent. This has not been accomplished and
neither has the single best performing MWI been tested.
Therefore, the limits have been based on an inaccurate and
incomplete data base. There is a real fear that in today's
marketplace, grass roots and special interest groups will acquire
these documents (based on an inaccurate data base reflecting
other than state-of-the-art equipment) and use them to negate the
permitting and operation of MWI's. It has been fairly well
proven that incineration is the most appropriate solution to the
medical waste disposal problem. Mr. Shuler concluded that
several problems are associated with the inappropriate selection
of test sites and the documentation of the operational
capabilities of these sites.
Mr. Pinkerton asked if he understood correctly that WCEI is
willing to support a test program. Mr. Shuler responded that it
would but not financially- Mr. Pinkerton asked what level of
testing Mr. Shuler would recommend in order to establish the
reliability of the technology through the tests. Mr. Shuler
responded that a statistical sampling of one, and that one not
being representative of the best in the industry, is certainly an
erroneous statistic. Mr. Pinkerton asked what data base EPA
should shoot for. Mr. Shuler recommended that EPA should try to
identify the best performing 12 percent (he does not think that
has been established). Of the 7,000 existing units, those sites
that were tested certainly do not represent the best performing
12 percent in the marketplace. Also, the best performing single
unit has not been identified nor tested.
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Mr. Dennison asked if industry has cooperated with EPA in
determining the best performing 12 percent. Mr. Shuler responded
that Attachment 2 is a suggestion of additional sites. The WCEI
put this list together because it feels that those specific sites
represent the best efforts of the incinerator and air pollution
control device (APCD) vendors.
Mr. Arkell commented that Attachment 2 is a list of only
large incinerators, and if industry really wanted to help develop
the proper data base, it would need to include smaller units as
well. Mr. Shuler responded that the WCEI list can be expanded to
include smaller facilities; WCEI certainly can and will work with
EPA to develop a list of smaller facilities.
Mr. Jordan asked Mr. Gil Wood for a rough estimate of the
cost of six tests (Attachment 2 is a list of six). Mr. Wood
responded that the cost depends on the pollutants being tested
for and how many process conditions are varied and can range
anywhere from $100,000 up to $500,000 per test. Ms. Carolyn
Konheim of the audience asked if EPA could increase the data base
by including results from State-supervised testing programs such
as Mr. O'Sullivan had earlier described. Mr. Eddinger responded
that the data reported is from the EPA test program. The EPA is
collecting and evaluating test reports from States and
considering the results. Dioxin data is usually lacking from
many of these test reports. Mr. O'Sullivan added that even
though New Jersey is requiring testing for new facilities, most
of the testing, with a few exceptions, has not been done.
Mr. Taranto wanted to clarify a point. He stated that,
based on the EPA reports, the MACT for existing large facilities
is BEST control with a note that more than 12 percent of the
facilities have BEST control. He added that, based on
Mr. Shuler's comments, there was only one facility with BEST
control and it has not been tested. Mr. Eddinger replied that it
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16
depends on the definition of BEST. The EPA's definition includes
DI/FF, SD/FF and fabric filter/packed bed (FF/PB). The EPA has
been able to identify 12 percent with one of these systems.
However, only one facility exists with a SD/FF system.
3. Discussion following the American Hospital Association (AHA)
Presentation
Following the presentation by the AHA, Mr. John Pinkerton
asked if EPA had seen these comments and asked what EPA's
reaction was to GCC at 1 sec versus 2 sec residence times. Mr.
Eddinger responded that EPA would not disagree that the same
emission limits can be achieved with 1 sec as with 2 sec. The
EPA's basis for 2 sec is that generally the facilities tested
with GCC were at 2 sec. The standard may not necessarily require
a specific residence time.
Mr. Larry Doucet added that more than 80 percent of State
regulations are at 1 sec. Mr. Pinkerton asked about the
temperature requirement. Mr. Doucet responded that most states
regulated at 1800°F use 1600°F. When 1600°F is set as a minimum,
incinerators do not operate at the minimum temperature because
they will shut down. They always operate at 200°F higher. If
EPA requires 1800°F and incinerators use 2000°F, some data shows
that there is an increased formation of dioxins with higher
temperatures; in effect this might be creating more dioxins. Mr.
Pinkerton asked how AHA feels about the data base and if more
hospital incinerators should be tested. Mr. Doucet replied that
he recognizes the time and cost constraints and believes that
other tests that have been done by other sources should be
included. Mr. Doucet does not believe a conclusion should be
made at this point. The data is not enough to resolve what
alternative is the best, and the economics are not as complete as
they should be. The conclusion of BEST based on X number of dry
scrubbers is not valid. Just because there are 12 percent for
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17
the past 6 months or year does not mean these facilities will be
there in a few years. It has been shown that facilities have had
a hard time with dry scrubbers because of corrosion problems.
Also, wet scrubbers today are being designed to meet the same
stringent levels as dry scrubbers. He objects to saying that a
dry scrubber can be applied to a small system, particularly to a
hospital, because of the size and the cost to install these
systems at small hospitals in the municipal sector (in most cases
these systems will need to be installed on the facilities' roof).
He believes that building costs were not included in the cost
estimates and should be. The EPA reports assume that all
incinerators are located outside, which is not the case.
Mr. O'Sullivan asked about comments on page 4 that EPA is
placing unnecessary emphasis on pathogen destruction. The AHA
believes that pathogens should be destroyed in incinerators, yet
EPA has data on pathogen destruction that shows incomplete
destruction. He asked how this can be resolved. Mr. Doucet
responded that pathogens should be destroyed at 240°F. It is
chemically impossible for these micro-organisms to survive such
high temperatures. What is being captured could be contamination
or ambient air, or micro-organisms that exist everywhere.
Mr. O'Sullivan asked if EPA could comment on that. Mr. Crowder
replied that the pathogens used were very heat-resistant spores.
Mr. Doucet added that the spores used (bacillus
stearothermophilus) are heat resistant up to about 250°F for a
very short time. He added that even looking at the pathogens in
the ash bed, the temperature there is at least 700°F for about 4
to 12 hours. Autoclaves destroy pathogens in 90 minutes at
250°F. Mr. Doucet added that pathogen destruction is not the
goal of good combustion. Pathogen destruction comes with the
operating temperatures and retention times. The focus of good
combustion is to get as complete a destruction as possible with
the hydrocarbons.
;i
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18
4. Discussion Following the B. G. Wickberg Presentation
Following the presentation, Mr. O'Sullivan asked what type
of facility and control device Facility C-C was. Mr. Hadley
responded that C-C was a commercial facility of 400 Ib/hr
capacity with an FF/PB. Mr. O'Sullivan commented that on the HCl
data one test had a low inlet with 94 percent removal
efficiency, which presents a problem with efficiency standards.
He asked if Mr. Hadley had a recommendation for setting a ppm
standard. Mr. Hadley responded that most of these facilities are
in Massachusetts and have two standards:
97.5 percent removal efficiency or 40 ppm.
Mr. Hise asked what Mr. Hadley recommends as a standard for
PM10. Mr. Hadley responded that he would recommend approximately
.01 gr/dscf. One facility (C-C) demonstrated 0.0004 gr/dscf, but
he has not been able to achieve that since. He recommends that
maybe EPA should show a progression of lower emission
requirements and push the industry a little. Mr. Hise asked if
Mr. Hadley had an alternative recommendation for dioxins and
furans rather than setting a standard for them. Mr. Hadley
responded that he is working on this and is not happy with it
yet. He has only tested three units for dioxins, and there is
some feeling that dioxins and furans are particularly collected
on very small particles, in which case the more particles that
are collected, the better the dioxin removal efficiencies will
be. Mr. Wood asked if EPA has this data. Mr. Hadley said he
will submit this data to EPA.
Mr. Steve Lanier of EER Corporation commented that the data
from the particular APCD on the batch system shows a very
substantial creation of dioxin across the control device and
asked if he would comment on the balance between control of
certain particulates, good HCl and metals control, and a creation
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19
of dioxins across the device. Mr. Hadley responded that he does
not know the answer to the question. The facility in question is
a very interesting unit. Mr. Hadley did not receive the data for
that facility, so he could not respond to the question. Ms.
Carolyn Konheim asked if operating with excess air has been
considered as opposed to starved air and if EPA's test program
has measured any particle size distribution, because this data is
lacking, which drives health risk assessments. Mr. Eddinger
responded that particle sizing has been done. The EPA has a
breakdown that is generally 85 percent PM10. Ms. Konheim added
that PM10 is too big a break. She is asking about submicron
levels. Mr. Eddinger responded that PM could have been broken
down further, but the reports show at least PM10, since
Section 129 requires the EPA to set standards for PM 10
emissions. Mr. Wood responded that EPA's test program has broken
PM down but not to the submicron levels. The data that EPA does
have are being published in a draft chapter of AP-42, but these
data are not yet available.
Mr. Wood wanted to clarify that Mr. Hadley agrees that the
emission limits are fine and could be tighter. Regardless of how
much more data EPA collects, Mr. Hadley thinks that it would
suggest that EPA could go even tighter, not that EPA does not
have enough data already. Mr. Hadley agreed. Mr. Atkins added
that he understands that it is Mr Hadley's and the previous
speaker's beliefs that the standard will specify a certain type
of equipment. Mr. Hadley agreed that this is implied in the
reports. Mr. Jordan asked if that is EPA's plan. Mr. Eddinger
responded that under Section 129 EPA is required to set emission
standards. He added that EPA is intending to do so and the
standard will primarily be a performance standard.
5. Discussion Following the Calvert Environmental Presentation
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20
Following the presentation, Mr. Pinkerton asked what the
pressure drop was for these venturi scrubbers. Mr. Patterson
responded that the pressure drop for hazardous waste incinerators
(HWI's) is 25 in. w.c. to 55 in w.c. and the VS with gas cooling
used on MWI's is predicted to be in the same range. One of the
advantages of gas cooling is that the water can be condensed on
the submicron particulate and drawn into a larger size
particulate and, therefore, can be removed in a wet device with a
much lower pressure drop.
Mr. O'Sullivan asked what inlet concentration the 99 percent
removal efficiency for PM was based on. Mr. Patterson responded
that the inlet concentrations are approximately 3 to 5 gr/dscf
with more than 50 percent in the submicron range. Typically.- the
range of inlet concentrations for most hospital waste
incinerators is . 1 to .4 gr/dscf with 50 to 70 percent in the
submicron range. Mr. O'Sullivan commented that the condensation
of Hg is dependent on inlet concentration and asked if the
incinerators with high removal efficiencies are typically HWI's
with higher concentrations of Hg. Mr. Patterson responded that
most of them are HWI's but they had a range of Hg contents in the
inlets. Mr. Patterson agreed that removal efficiency depends on
inlet concentrations; higher efficiencies are due to higher inlet
loadings. Mr. O'Sullivan asked if Mr. Patterson could supply EPA
with the inlet concentration data if it is available.
Mr. Patterson said he could do so.
Mr. Atkins asked if the cost estimates reported by
Mr. Patterson include waste water treatment costs. Mr. Patterson
responded that these costs are not included but are estimated to
be in the range from $10,000 to $15,000 using zero water
discharge.
Mr. Arkell asked if there have been any comparisons of
ground level concentration profiles between a wet scrubber system
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21
and a dry scrubber system. Mr. Patterson said that he was not
aware of any such tests. Mr. Arkell added that even with higher
removal efficiencies, there is still liable to be a tremendous
difference in ground level concentrations of wet systems versus
dry systems and that one of the bases of the permits issued
might be the ambient air concentrations.
After the lunch break, Dr. Konheim gave her presentation.
Citing the work of Dr. Alex Green at the University of Florida,
she recommended that MWI's operate in the excess-air mode rather
than the starved-air mode as a way of producing fewer products of
incomplete combustion. She further recommended the use of
continuous emission monitoring as a means of giving ongoing
readings of how a facility's operating conditions relate to its
emissions and ensuring the public of the medical waste facility's
compliance with performance levels achieved in the performance
test. Performance tests themselves are inadequate because they
rarely document operating conditions under which the tests were
taken. The documentation of the conditions should be required.
Dr. Konheim reiterated the need to broaden the data base and
suggested EPA could either sponsor or at least participate in
testing facilities that are just coming on-line. She also
emphasized the need for risk-based standards in dealing with the
White House and State permitting agencies, with the introduction
of isomer-specific data for dioxins, for example, in the revised
report. Dr. Konheim reiterated the need for particle size
distributions down to 0.1 microns for use in dispersion modeling
to determine the effect on pathways such as agriculture and fish
for health risk assessments.
Dr. Konheim stated that the national reductions of
cumulative emissions achieved as a result of the standards were
unrealistic. They were based on uncertain projections on the
number of facilities implementing the control measures, and the
effects of the facilities are also extremely localized.
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Dr. Konheim also questioned the assumptions used in the modeling
in the report, particularly the values for stack heights and
building heights for medical waste facilities. As a result, she
found the ground level concentrations determined by the models to
be unrealistic and unrepresentative of most situations. She
further emphasized the importance of site-specific factors, such
as location near a hospital or an industrial area, in determining
the health effects of a particular facility, as well as the acute
respiratory effects of pollutants such as HC1, hydrogen chloride
with sulfur dioxide, NOX, and PM emitted from the facility- As a
result, acute pollutants in or near hospitals may require
stricter standards than those in or near industrial areas.
Dr. Konheim discussed the findings of the New York City
medical waste study on the effectiveness of removing plastic
components from medical waste in reducing both the chlorine
content of the waste stream being burned and the lime demand. In
such a program, the plastic components could be clearly
designated and treated onsite using an autoclave. Dr. Konheim
stated that thermal processes such as autoclaving do volatilize
the organics in the waste, and that there are fugitive emissions
from the treated waste, which could be captured in condensers in
the new facilities. The additional cost of this control should
be examined. Dr. Konheim also discussed the problem of the
acceptance of treated medical waste at landfills, as well as its
pervasive odor, a possible indicator of other emissions of
concern. She concluded her presentation by emphasizing the
importance of alternative treatment methods in protecting the
health of patients, workers, and the general public.
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WISCONSIN
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
101 So"* Webstef **"**
DEFT. OF NATURAL RESOURCES I BcK 7921
Madison, Wisconsin 53707
Carroll D. Besadny TELEPHONE 60&266-2621
Secretary TELEFAX 60&567-0560
TOO 60&267-6897
November 14, 1991 IN REPLY REFER TO: 4530
Bruce Jordan
Director, Emission Standards Division (MD-13)
Office of air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
SUBJECT: Review of Medical Waste Incinerator Background Information for
Proposed Standards and Guidelines
Dear Mr. Jordan:
Thank you for the opportunity to comment on the draft "Medical Waste
Incinerator Background Information for Proposed Standards and Guidelines."
The documents were reviewed by my staff and the following comments were made.
COMMENT 1: Human Crematoriums
Crematoriums which are not burning medical or municipal waste should be
considered in a source category separate from medical waste incinerators.
The constituents in the medical waste stream and the crematorium "waste"
stream differ greatly, and therefore medical waste incinerators and
crematoriums should be regulated differently. For example, the
constituents in the bodies fed to a crematorium are primarily water,
carbon and oxygen. The wastes fed to a medical waste incinerator contain
heavy metals, chlorine, and other substances that may contribute to
hazardous pollutant emissions. The destruction of pathogens in a
crematorium may be an environmental concern. However, the temperature in
the crematorium's chamber should be sufficient to destroy any pathogens
present.
COMMENT 2: Definition of Incinerator Capacity
EPA has established that the capacity of a medical waste incinerator has
to be determined based on firing a "design" medical waste with a specific
heat content of 8500 BTU/lb. Many owners and operators of medical waste
incinerators have argued that a heat content of 9,000 10,000 BTU/lb is
more realistic of the medical waste they burn. If this could be
demonstrated to be true, EPA should allow flexibility when defining
capacity.
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If you have any questions on the above comments, please feel free to call
Molly Oswald at (608)267-0568 or Paul Yeung at (608)266-0672.
Sincerely,
--yj^o ~K$-
DonalWf. Theiler, Director
Bureau of Air Management
cc: William 0'Sullivan EPA
Dale Ziege AM/10
Dean Packard AM/10
Jon Heinrich AM/10
Pat Kirsop AM/10
a:\rn isc\nsps.epa
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JOY ENERGY SYSTEMS INC p ° Box 410647
A T -T ^ , -;JOICIVIli' IINI^- Charlotte. NC 28241-0647
A Joy Technologies Company P^ne- ,704J ssy-eooo
Fax: (704) 587-8030
November 25, 1991
Mr. Bruce Jordan
Director, Emission Standards Division (MD-131)
Office of Air Quality Planning & Standards
US EPA
Research Triangle Park, NC 27711
Subject: MACT Standards Background Documents for
Emissions from MWI's - New & Existing Sources
Dear Mr. Jordan:
On behalf of Joy Energy Systems, Inc., I submit the attached comments to the following listed
background documents as prepared by the US EPA:
1. Industry Profile Report for New and Existing Facilities,
2. Process Description/Baseline Emissions Report for New and Existing Facilities,
3. Model Plant Description and Cost Report for New and Existing Facilities,
4. Control Technology Performance Report for New and Existing Facilities,
5. Environmental Impacts Report for New and Existing Facilities,
6. Analysis of Economic Impacts for Existing Sources, and
7. Background Paper for New and Existing Facilities.
As evidenced by my testimony at the NAPCTAC hearings on November 20, 1991, the industry
has some grave concerns about the validity, applicability, and accuracy of the background
documents. Furthermore, JES has major concerns about modern state-of-the-art systems having
not been tested. Without this reference data to reflect the results of industry's development efforts
and relative efficiencies achievable, the public will continue to believe that incineration is a
continuing source of health risk and destructive to our environment. Obviously, this is not true
with modem systems.
We request that you will kindly consider our comments. Furthermore, if JES can provide
assistance to your staff in any way, we will be most pleased to assist.
Respectfully,
Steve Shuler
Manager - Sales & Marketing
SS/cmc
Enclosures
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I - Ref.: "Industry Profile Report for New and Existing Facilities"
Table 5. Page 11
* Chemical retardants are not included which affect combustion efficiencies and ash
quality.
4.1.2 Steam Sterilization
* Autoclave systems have emissions in the form of aerosols and liguid blow-down
to the sewer. What tests have been conducted to determine the varieties and
volumes of criteria toxic pollutants in either the exhaust or blow-down of these
systems? Should these processes not require permitting and compliance protocols
equal to an incineration system?
4.1.4 Chemical Disinfection
* See comments as 4.1.2, above.
4.1.7 Microwave Sterilization
* Aerosols released during the shredding process are theoretically captured by a
filtration system. Have any tests been performed to measure the variety and
volumes of criteria toxic pollutants released to atmosphere down-range of the
filter? Likewise, have these systems been measured in vicinity of the shredder
hopper for the same aerosol bome emissions?
II- Ref.: "Process Description/Baseline Emissions Report for New and Existing Facilities"
2.0, Page 2
* Typical operating temperatures of the incinerator primary chamber are 750°F-
1800T.
* We feel this range should be 1200°F-14QQ°F and is especially true for modern
systems.
2.0, Page 6
* Typical operating temperatures of the incinerator secondary chamber are 1600°F-
2000°F.
* All modern systems are capable of operating at minimum 1800°F and can reach
2200°F when processing large percentages of high BTU/lb. waste materials.
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3.2. Page 10
* Based on what we have seen, infectious waste is not usually double bagged.
Table 3. Page 14
* Pathological, for animal carcass destruction, units are not designed to operate with
excess air in the primary chamber.
4.0. Page 15
* See comment as Table 3, Page 14, above.
Figure 2. Page 18
* The schematic should include underfire and secondary chamber combustion air and
their respective controls since the incineration technology is "Controlled Air
Incineration".
4.1. Page 19
* An intermittent duty design is typically a maximum 16 hr. duty cycle, not 24 hrs.
or less.
* Feed charges are not intended to have intervals of several hours. Instead, 6-15
minute intervals are more appropriate.
* Preheat of any incinerator typically should be no less than 45-60 minutes.
Otherwise, refractory damage will occur.
Figure 3. Page 21
* Same comment as Figure 2, Page 18, above.
Figure 4. Page 22
* Same comment as Figure 2, Page 18, above.
4.2, Page 23
* Some batch fed unit designs have the inability to prevent surge flow at initial start-
up.
Figure 5. Page 25
* Same comment as Figure 2, Page 18, above.
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Figure 6. Page 25
* Same comment as Figure 2, Page 18, above.
4.4. Page 26
* Pathological incineration design for animal carcass destruction does not utilize an
excess air primary chamber. It is typically designed to operate without underfire
combustion air and utilizes the fossil fuel burners to drive off moisture followed
by combustion of the remaining combustible materials.
4.6.1. Page 30
* Mechanical loaders (feeders) are typically used on modern incineration systems
having thermal capacities of 2 x 106 BTU/hr. and larger. Based on the assumption
that medical waste averages 8500 BTU/lb. heat of combustion, the incinerator sizes
equipped with feeders range from 235 lb./hr. and larger.
* Although the few rotary kiln incineration systems in use today utilize auger
feeders, it is questionable that this device should be used to process infectious
waste. Two issues should be addressed One, the auger hopper is an open top
design and allows aerosols to discharge into the atmosphere as a result of ripping,
shredding, and compressing the infectious waste materials prior to and through the
screw feeder section. These aerosols could entrain pathogens putting the operator
at risk. Two, in the event of a mechanical failure, or jamming, waste would have
to be manually removed from the hopper and screw feeder. Thus, exposing the
operator/maintenance person to infectious materials and the risk of contamination.
Figure 9, Page 34
* Same comments as Figure 2, Page 18, above.
4.5.2.3, Page 35
* Animal carcass incineration systems (pathological) are not designed to operate the
primary chamber in an excess air mode.
* Typical modern systems are designed such that the primary chamber burner
temperature controller set point is in the range of 1200°F-1400°F, so that if the
chamber temperature falls below the setpoint, the burner ignites.
4.6.3, Page 39
* It has been stated in the text that combustion air can be added to a tertiary
chamber. We assume that the point where this air is added, the calculation for
retention time is measured followine the introduction of this additional combustion
air.
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5.2.2. Page 48
* Overfeeding is controllable by use of a modern PLC based systems control protocol
which include the necessary interlocks and safety features to disallow the operator
to overcharge the incinerator. Many vendors offer this option today, some only
offer this system control version.
* Fugitive emissions are especially prevalent when an auger feed mechanism is
applied to infectious medical waste which provides the opportunity for aerosol
airborne microorganisms.
5.2.3, Pages 50 and 51
* Modern incineration system design incorporate burners of adequate BTU/hr. thermal
capacity to both attain operating setpoint temperatures in both chambers without
the requirement to burn waste and maintain the setpoint operating temperatures
when inadequate heat is generated from the combustion of waste materials.
in - "Model Plant Description and Cost Report for New and Existing Facilities"
2.1.1.2.2, Page 5
* Intermittent operated incinerators should not be charged at intervals of several
hours. Intervals of 6-15 minutes are more suitable for units of this design level.
2.1.4.5. Page 17
* Although the data was extracted from old and new model designs, good logical
evaluations should be based upon new technology, i.e., most manufacturers offer
2 second secondary chamber resident times today. Should the evaluation not be
based on this criteria?
2.1.4.6. Page 17
* Modern systems incorporate temperature controls whereas the operating setpoint
temperature is maintained during normal operation and through the burn-down
phase. Typically, these are 1200DF-1400°F for the primary chamber and minimum
setpoint of 1800°F for the secondary chamber.
Table 19, Page 135
* The tabulated capital costs are understated. Refer to the attached WCEI Member
Facility Combustion Unit and APC Equipment Costs which were previously
submitted.
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Table 23, Pages 139 and 140
* Same note as Table 19, Page 135, above.
General Comment
* Incineration systems are expressed as being sized to accommodate a specified
throughput based on pounds of waste per hour of operation. In reality, modern
incineration systems are designed to accommodate a specified thermal heat release
capacity as measured on an hourly basis. Combustion controls (thermocouples,
temperature controller, modulated combustion air, and burners) and system
operating control protocols (PLC based CPU or relay logic- • controls) are
incorporated to accommodate maintaining setpoint operating temperatures by
controlling the feed rate which matches the thermal design capacity.
Waste materials, as stated in the text, range from zero heat of combustion to in
excess of 20,000 BTU/lb. This broad range of thermal heat release in the waste
requires controls to accommodate controlling the rate of volatization, heat release,
and burn out of these waste materials. Modern systems from most vendors provide
control protocols to accommodate the range of wastes. Thus, controlling the feed
rate to match operating parameters. Therefore, incineration systems should be
expressed as thermal heat release devices, not pound per hour processors.
IV - "Control Technology Performance Report for New and Existing Facilities"
* No comment comments are expected from the APC vendor membership.
V - "Environmental Impacts Report for New and Existing Facilities"
* No comment comments are expected from the APC vendor membership.
VI - "Analysis of Economic Impacts for Existing Sources"
3.1. Tables 5A, 5B. 5C
* Autoclaves are not currently regulated for air emissions and discharges to the
sewer. Should these systems be completely assessed for airborne emissions in
the form of aerosols, which may contain microorganisms, and subsequent liquid
discharge to the sewer. Then, add-on equipment may be required which will cause
the capital cost of installing and operating these systems to be unattractive as
compared to incineration.
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Vin -"Background Paper for New and Existing Facilities"
General Comment
While the data summarized in this report was being gathered, a number of changes have
occurred in the industry. Some of these follow:
* Individual state regulations have begun to require scrubbing systems.
* Few installed MWI's have scrubbers. Therefore, few sites exist which can be
tested.
.* •
* Incinerator technology has changed dramatically during this period. Combustion
efficiencies, controls, interlocks, and safeties have been incorporated to attain best
incineration practices by the industry. Sites selected by the US EPA do not
properly reflect the technological advances made by the industry. Therefore, we
believe the data baseline is skewed towards system from a prior design generation
which are not capable of achieving the same combustion efficiencies of modern
systems.
* State regulatory agencies cannot agree on a single specified operating standard for
MWI systems, including the APC and CEM standard. We have seen the
performance requirements change from an opacity standard, which at best equates
to a calibrated eyeball, to incremental steps defining more stringency in paniculate
control from .2 G/DSCF corrected to 7% O2 to the more common requirements
encountered today of .015 G/DSCF, also corrected to 7% O2.
The problem is that before APC vendors could design, manufacture, and install
systems with a specified operating range (i.e., .03 G/DSCF, corrected), the
operating standard changed elsewhere. The earlier version gets testing and is used
as the database to determine the applicability or non-applicability of a specific
technology. We reference the CARB tests performed on Stanford University's
incineration system. This specific installation utilizes a wet variable venturi
scrubber intended to removal HC1 only. However, it was tested for CDD/CDF,
Metals, etc. and subsequently wet scrubbers were determined not to be an
appropriate technology in California.
We view the data represented in these reports to have been drawn from some of
the same logic as the CARB report referenced above. The database from which
these conclusions originate have two major flaws. One, the data does not
adequately represent developments of the incineration vendor's technological
advancements. Two, scrubber technology has not been allowed to be developed
and installed to make an appropriate assessment of which technology truly
represents MACT.
r'
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SS/cmc
Therefore, we recommend establishing a minimum performance standard based on
a scientific assessment required to provide appropriate protection for the
environment and human health. This will hopefully provide a baseline for the
individual states which will enable them to establish a common performance
standard rather than the diverse mixture of standards encountered today.
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WCEI MEMBER FACILITY COMBUSTOR UNIT & ARC EQUIPMENT COSTS
Capacity (PPH)
100-299 (1)
300-499 (1)
500-999 (1)
1,000-1,499(1)
1,500-1,999(1)
2,000-2,500(1)
1
COMBUSTOR UNIT ONLY COSTS
1-2 Shift Duty
50,000-100,000
85,000-270,000
230,000-360,000
300.U00-425,000
375,000-500,000
485,000-540,000
Continuous
—
—
310,000-475,000
360,000-540,000
415,000-610,000
515,000-775,000
COMBUSTOR UNIT W/ BOILER COSTS
1-2 Shift
308,000-477,000
402,000-564,000
492,000-655,000
624,000-712,000
Continuous
388,000-592,000
462,000-680,000
532,000-765,000
655,000-947,000
— — — — ^— — — — — — — — — — •
SCRUBBER COSTS
Wot w/o Boiler
100,000-170,000
150,000-275,000
245,000-380,000
335,000-470,000
420,000-650,000
Wet w/ Boiler
—
115,000-220,000
195,000-260,000
220,000-295,000
250,000-335,000
Dry w/o Boiler
145,000-290,000
275,000-385,000
360.000-425,000
445.000-510,000
525,000-600,000
Dry w/ Boiler
200,000-310,000
285,000-375,000
355,000-480,000
425,000-510,000
CEM Component
CO
CEM Cost
40,000-85,000
CO, ! 25,000-70,000
o,
Opacity
HCI
Method 5 Testing
Dtoxins, Heavy Metals
CO, etc. Testing
EIS
Dispersion Analysis
Permitting
15,000-25,000
25,000-45,000
100,000-160,000
5,000-7,000
75,000-150,000
50,000-125,000
10,000-25,000
2,000-50,000
Calibration
7,500-15,000
7,500-15,000
7,500-15,000
2,500-8,000
15,000-25,000
—
—
—
—
—
EPA Certification
12,000-20,000
8,000-15,000
5,000-10,000
5.000-10,000
15,000-25,000
—
—
—
—
(1) Units 300 PPh and greater are assumed to have an automatic loader; Units 500 PPH and greater are assumed to have a scrubber
(2) Includes Freight, Installation, Start-up, Operator Training and Compliance Testing Supervision
(3) 75% of base combustor price (1-2 shift duty)
(4) 40% of base combustor price (continuous duty)
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