From: Thomas Holloway

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). The regulation for the HMIWI category was promulgated on September 15, 1997 and subsequently remanded by the U.S. Court of Appeals for the D.C. Circuit on March 2, 1999. To respond to concerns raised by the Court regarding the methodology originally used to develop the 1997 regulation, EPA is re-developing the HMIWI regulation. In addition to developing compliance options to support that re-development, EPA is also exploring alternatives to compliance. The purpose of this memorandum is to show how the baseline operating costs for projected new HMIWI compare to the primary alternative to compliance with the re-developed regulation, which is autoclaving and landfilling the waste. II. Model Costs This section presents the costs estimated for a series of model new HMIWI for (1) the combustors expected to be used to incinerate hospital/medical/infectious waste; (2) the emission controls the new HMIWI are expected to use to comply with the 1997 HMIWI regulation; (3) the monitoring, testing, recordkeeping, and reporting activities the new HMIWI are expected to conduct to demonstrate compliance with the 1997 regulation; and (4) the primary alternative to compliance with the re-developed regulation (i.e., autoclaving/landfilling). The model new HMIWI include large, medium, and small units, patterned after HMIWI that have been installed over the last 10 years (Waste Management Resource Recovery and Recycling Center in Anahuac