Transcript Introduction

Florida Department of
Environmental Protection
Hospital/Medical/Infectious
Waste Incinerators (HMIWI)
Tiffany Miesel & John Glunn
Florida DEP, Division of Air Resource Management
May 26, 2010
What happened at the Federal Level?
• September 15, 1997 – EPA promulgated final
NSPS and Emissions Guideline rules for HMIWI
• December 1, 2008 - EPA proposed an updated rule
which would tighten limits for HMIWI facilities
• October 6, 2009 – EPA promulgated final, updated
rules for new and existing HMIWI
• 40 CFR 60, Subpart Ec for new sources (NSPS)
• 40 CFR 60, Subpart Ce for existing sources (EG)
• State plans for implementing the Emissions
Guidelines must be submitted to EPA by October
6, 2010
May 26, 2010 | 2
What are the differences?
• New Source Performance Standards (NSPS)
• For new or modified facilities
• “For which construction is commenced after December 1,
2008; or for which modification is commenced after April
6, 2010”
• Emissions Guidelines (EG)
• For existing facilities
• “For which construction was commenced on or before
June 20, 1996, or for which modification was commenced
on or before March 16, 1998”
• “For which construction was commenced after June 20,
1996 but no later than December 1, 2008, or for which
modification is commenced after March 16, 1998 but no
later than April 6, 2010”
May 26, 2010 | 3
Emissions Guidelines for Large HMIWI
140
120
ng/dscm
Old (Table 1A)
New (Table 1B)
mg/dscm
ppmv
100
80
40
mg/dscm
ppmv
60
mg/dscm
ppmv
ppmv
mg/dscm
20
0
PM
CO
SO2
NOX
(x10)
HCl
D/F
Pb
(÷100)
Cd
(÷100)
Hg
(÷100)
May 26, 2010 | 4
What has been done at the state level?
• April 30, 2010 - DEP published notice of fast track,
adoption-by-reference of subparts Ce & Ec
• NSPS (Ec)
• Federal effective date: April 6, 2010
• State effective date: June 11, 2010
• Emissions Guidelines (Ce)
• State effective date for fast-track adoption of updated emissions
guidelines is April 1, 2012
• April 30, 2010 – DEP published notice of Secretarial
rule development to amend the fast-track adoption in
support of state plan development
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Why the need for a Secretarial Adoption?
• EPA requires the states to implement an
enforceable plan (state rules) to ensure
compliance with the emissions guidelines
• Changes proposed to the fast-track adoption are:
• To establish, with stakeholder input, Florida-specific
compliance dates and permit application deadlines
• To require additional metals testing
• To clarify the interaction between the requirements of
EG and the state rule for biological waste incinerators
• Also, DEP is proposing to remove obsolete
adoption by reference of Subpart HHHH (CAMR)
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Compliance and Performance Testing
• Large HMIWI are covered by the DEP testing
requirements in 62-296.401(4)(e)2. and 62-297.310,
in addition to the federal performance testing
requirements in 60.37e and 60.56c
• Large HMIWI subject to annual PM and HCl
testing under state rules will not be able to take
advantage of the NSPS ‘’skip testing” provisions
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Compliance and Performance Testing (cont’d)
• Mercury(Hg), cadmium(Cd) and lead(Pb) emissions
are input-driven and may vary under similar
control conditions
• Proposed language in 62-204.800(9)(g)7., F.A.C.
requires that a performance test for Hg, Cd, and Pb
be conducted whenever a PM test is done
• Proposed requirement doesn’t apply, for any of the
metals, if a facility operates a continuous monitor
for mercury
• Testing would be effective beginning April 1, 2012
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