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Environmental Progress - Fall 1999

New, Existing Hospital Waste Burning Impacted by Incineration Rules

Up to 98 incinerators could be affected by regulation changes

On Sept. 15, 1997, the U. S. Environmental Protection Agency (EPA) issued New Source Performance Standards (NSPS) and Emission Guide-lines (EG) to reduce air pollution emissions from hospital/medical/infectious waste incinerators (HMIWIs). The NSPS applies to new sources that were constructed after June 20, 1996, while the EG applies to existing sources that were constructed on or before June 20, 1996.

Unlike the NSPS, which can be directly implemented for new sources, states are required under the Clean Air Act to develop state plans to compel existing HMIWI sources to meet the emission guidelines.

The Illinois EPA developed a HMIWI regulation that was adopted as a final order by the Illinois Pollution Control Board on May 6, 1999, and approved by U.S. EPA on July 7, 1999, as the state's plan to control air emissions from existing HMIWI sources.

The HMIWI regulation applies to existing incinerator sources that primarily burn hospital and/or medical/infectious wastes. However, some sources will only be obligated to meet certain requirements of the rule.

HMIWIs that burn only pathological, low-level radioactive, or chemotherapeutic waste will be required to notify the Illinois EPA and fulfill certain record keeping and reporting requirements. Sources that burn 10 percent or less hospital waste or medical/infectious waste by weight, in conjunction with other fuels (on a calendar quarter basis), will only be required to notify the Illinois EPA of their status as a co-fired combustor, commit to this status as a condition in an Illinois EPA-issued permit and fulfill certain record keeping and reporting requirements. Finally, hospitals that send their hospital and medical/infectious waste off-site for incineration must conduct an assessment of their current waste management plans and submit annual waste management progress reports.

Some sources will be exempt from all requirements of the HMIWI regulation: pyrolysis units; incinerators that are already permitted as treatment, storage or disposal facilities under the federal Solid Waste Disposal Act; cement kilns; and municipal-waste combustors.

The Illinois EPA estimates that about 98 sources in Illinois potentially could be affected by the new regulations.

The HMIWI regulation sets emission limits for several air pollutants, and requires Clean Air Act Permitting Program permits, performance testing, establishment of site-specific operating parameters, continuous parameter monitoring, waste management plans, inspections, operator training and reporting and record keeping.

Generally, all HMWI owners and operators who plan to continue operating their incinerators will have to be in full compliance with all the requirements of the HMIWI regulation by September 15, 2000. This same deadline applies to owners and operators intending to shut down their incinerators. Owners and operators in this latter category must render their HMIWIs permanently inoperable to qualify for full compliance with the new rule.

Additional information can be obtained from Joe Uy, Air Quality Planning (217-524-4343) or Bonnie Sawyer, Division of Legal Counsel (217-782-5544). Additional information also can be obtained at the Illinois Pollution Control Board or U.S. EPA Web sites: