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An HMIWI, when combusting waste, creates bottom ash in its primary chamber.(302) In batch and intermittent HMIWIs, this bottom ash is removed periodically, and in continuous HMIWIs, it is removed continuously.(303) Ash is also captured from the exhaust gas stream by fabric filters, and this fly ash also must be removed periodically.(304) Fugitive emissions can be created when removing ash as part of the removal and disposal process.(305) After the date on which the initial performance test is completed or is required to be completed, no HMIWI is allowed to discharge from an ash conveying system visible emissions of combustion ash into the atmosphere in excess of five percent of the observation period.
In addition to monitoring the operating parameters, an owner or operator of an affected unit is required to maintain and operate a device or method for measuring the use of the bypass stack, including date, time, and duration.(354) Owners or operators using technology other than that identified as the basis of EPA's regulations must maintain and operate whatever equipment is required in order to monitor the site-specific operating parameters.(355) Finally, an owner or operator must obtain monitoring data whenever the HMIWI is operating except when the monitoring equipment malfunctions or is being repaired or calibrated.(356)
Emissions Limits Pollutant HMIWI size Small Medium Large Particulate 115 (0.05) 69 (0.03) 34 (0.015) matter Carbon 40 40 40 monoxide Dioxins/ 125 (55) or 125 (55) or 125 (55) or furans 2.3 (1.0) 2.3 (1.0) 2.3 (1.0) Hydrogen 100 or 93% 100 or 93% 100 or 93%.
Once again, for a state plan dealing with existing HMIWIs to be approved, it must contain requirements set forth in subpart Ec, which includes the monitoring requirements found in section 60.57c.(426) A state plan must contain additional requirements for small rural HMIWIs, including the operation and maintenance of a device that will record and measure the secondary chamber temperature, the operation and maintenance of a device that will automatically measure and record the date, time, and weight of each charge fed to the HMIWI, and the acquisition of monitoring data for all periods the HMIWI is operating, except when the monitoring equipment is malfunctioning.(427)
If the new standards had not been promulgated, EPA estimates that eighty-five new small HMIWIs, ninety new medium HMIWIs, sixty new large HMIWIs, and ten new commercial HMIWIs would have been installed in the five years following the September 1997 promulgation of the HMIWI Final Rule, for a total of 245 new HMIWIs.(441) Based upon these assumptions regarding new HMIWIs, EPA estimates for :scenario A that an annual expenditure of $36.2 million will be required for the control measures necessary to meet the new standards.(442) However, EPA also concluded that this estimate is "unrealistic and grossly overstates the national costs associated with the standards."(443)
EPA estimates that in the fifth year following implementation of the NSPS, HMIWI particulate matter emissions will be reduced by eight-five to ninety-two percent, carbon monoxide by zero to fifty-two percent, CDD/CDF by seventy-four to eight-seven percent, and HCl by ninety-five to ninety-eight percent.
Industries that generate hospital waste or medical/infectious waste, such as hospitals, nursing homes, veterinary facilities, commercial research laboratories, and commercial medical waste incinerators, are expected to see slight price increases of up to 0.16%.(453) Output and employment impacts are expected to range from zero to 0.21%.(454) Revenues are expected to change as well, ranging from an increase of 0.05% to a decrease of 0.05%.(455) Most facilities will be able to switch disposal methods more inexpensively than to install a new HMIWI.
Due to the HMIWI guidelines, industries that generate hospital waste or medical/infectious waste are expected to see average price increases of up to 0.14%.(466) Output and employment impacts are expected to range from zero to 0.18%.(467) Revenues are expected to change as well, ranging from an increase of 0.05% to a decrease of 0.04%.(468)
The final HMIWI rule should result in significant reductions in the emission of many harmful pollutants.
While the major immediate challenge is to implement the new HMIWI Final Rule, the rule itself is being challenged.
However, in the Final Rule, EPA changed the terminology to hospital/medical/infectious waste incinerators, or HMIWI. Compare Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Medical Waste Incinerators [1995 Proposed Rule], 60 Fed.
10, 1999) <http://www.epa.gov/epaoswer/non-hw/muncpl/ msw96.htm>; HMIWI Final Rule, 62 Fed.
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