AHA's comments and recommendations to the U.S. EPA's draft medical waste incinerator regulations

The following summarizes specific recommendations with respect to the requested regulatory changes discussed above: 1. Either defer publishing the proposed regulations or exclude the emission limits from the proposed regulations until they have been properly established based upon the specific requirements of Sections 111 and 129. 2. Establish the the emission limits on the basis of proper technical analyses, using all necessary data and information which are readily available, and after consulting with state APC agencies as required under Section 111(f)(3). 3. Establish emission limits and requirements for new facilities based upon actual "systems" and according to size classifications. 4. Establish emission limits and requirements for existing facilities using the full range of available data to establish MACT levels according to size classifications. Exclude LAER facilities in the MACT analysis as required under Section 129. 5. Properly account for technical achievability and applicability in setting limits for the various size categories. 6. Properly account for cost and risk implications in establishing emission limits as required under Sections 111 and 129. It is important to highlight that when specific emission values are identified from test data or elsewhere for the in establishing emission limits for new and existing MWIs, it is critical that a proper factor be applied to them as necessary to reflect standard deviations and statistical variables. A recommended methodology for this is included in the U.S. EPA document entitled, Combustion Emissions Technical Resource Document (CETRED), draft, EPA530-4-94-0114, May 1994, Chapter 5, "Determinations of Technically Achievable Emissions." Finally, it is recommended that the U.S. EPA reassess the technical feasibilities and cost implications of various other key issues which have been raised. Such reassessments could be done during the period that emission limits are reassessed and revised.