Subject: Secondary Environmental and Energy Impacts for New HMIWI

Clean Air Act (CAA), is required to regulate emissions of nine pollutants from hospital/medical/infectious waste incinerators (HMIWI): hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury (Hg), particulate matter (PM), dioxins/furans (CDD/CDF), nitrogen oxides (NOX), and sulfur dioxide (SO2). To respond to concerns raised by the U.S. Court of Appeals for the D.C. Circuit regarding the methodology originally used to develop the regulation, EPA is re-developing the HMIWI standards. The EPA has developed a series of maximum achievable control technology (MACT) floor and beyond-the-floor (BTF) options to support that re-development. These options are discussed further in separate memoranda.1,2 Emission control technologies and other control measures that can be used to comply with these options include wet scrubbers, fabric filters, dry scrubbers, selective noncatalytic reduction (SNCR), activated carbon injection (ACI), and various other control measures designed to obtain incremental emission reductions. The purpose of this memorandum is to determine the secondary environmental and energy impacts that would result from projected new sources using these various emission controls to comply, as well as using alternatives to compliance, specifically autoclaving and then landfilling the waste