United States to UNEP Questionnaire for Paragraph 29 Study, Enclosure 4a April 2010. Revised May 2010 Waste Incineration Question #1 Question #2 What is the fraction and total amount of household waste incinerated? In 2008, Americans generated about 250 million tons of trash or 4.50 pounds per person per day. The U.S. EPA estimates residential waste (including waste from apartment houses) to be 55 to 65 percent of total municipal solid waste (MSW) generation (the balance is waste from commercial and institutional locations, such as schools, hospitals, and businesses). About 31.55 million tons of materials, or 12.7 percent, were combusted for energy recovery. The energy recovery statistic includes combustion of MSW in mass burn or refuse-derived fuel form, and combustion with energy recovery of source separated materials in MSW (e.g., wood pallets and tire-derived fuel). 1 What is the total number of household waste incinerators? In the United States (U.S.), there are 167 MSW incineration units larger than 250 tons per day (tpd) incineration capacity. These incineration units are referred to as large incineration units and represent more than 90% of municipal solid waste incineration capacity. Municipal solid waste incineration plants have multiple incineration units on site with 2 or 3 incineration units per plant being the most common. The 167 incineration units are located at 66 incineration plants. The average size of these incineration units is 535 tpd capacity and the average size of the incineration plants is 1,355 tpd. There are about 60 small municipal solid waste incineration units of less than 250 tpd capacity. Their average size is 120 tpd incineration capacity. 2 Table 1. Existing MSW Incinerators Large (>250 tpd) Small (<250 tpd) Plant Population 66 26 Avg. Plant Capacity (tpy) 1,355 275 Unit Population 167 60 Avg. Unit Capacity (tpd) 535 120 Question #3 What are the technical characteristics of the household waste incinerator plants? The 167 large incineration units described above are field erected units. These field erected units are composed of two different incinerator configurations. There are 133 incineration units of the water wall mass burn configuration and 34 incineration units of the waterwall refuse derived fuel (RDF) configuration. At the RDF configured units, the municipal solid waste is shredded before incineration. The 60 small incinerator units are generally of
two different configurations. Half are of the field erected water wall mass burn configuration and half are of a modular prefabricated configuration. With few exceptions, all incineration units generate steam that is sent to a steam turbine / electrical generator set for electric power production. The large and small MWCs in combination have approximately a 2,700 megawatt electric (MWe) nameplate generation capacity and generate about 22,000 gigawatthours electric power per year. 3 The exceptions are a few of the smaller incineration units that generate steam for industrial process use and do not generate electrical power. Question #4 What is the average mercury content in household waste? In the U.S., the mercury content of household waste has been significantly reduced in the last 20 years. In the 1990 period, the estimated mercury content of MSW was 664 megagrams (Mg) (709 tons), with concentrations ranging from 1 to 6 parts per million (ppm) by weight and a typical value being 4 ppm by weight. 4 In the 1990 period, combustion of MSW typically generated an uncontrolled mercury emission level of about 650 micrograms/dry standard cubic meters (ug/dscm) (@ 7% O 2 ). This has steadily been reduced, and by 1990 had been reduced to about180 ug/dscm, and by 2010 has been reduced to about 80 ug/dscm. Question #5 What are the mercury emissions from household waste incineration? The total mercury emissions from large and small MWC combined in 2005 were about 2.2 tonnes/year (2.4 tons/year). As shown in the spreadsheet, the total from large MWC was about 1.9 tonnes/year. These emissions represent the combined effect of mercury reduction in the MSW input stream (described above) and the application of post combustion Hg control by spray dryer based scrubbing systems (semi-dry scrubbers), enhanced with the use of activated carbon injection (ACI). Available data show that the use of ACI in combination with a spray-dryer scrubbing system results in 93% mercury control. The reduced mercury content of the MSW stream, in combination with the spray-dryer scrubbing system results in an average controlled mercury emission rate of about 14 ug/dscm (@ 7% O 2 ) as of 2000. 5,6 Table 2. Changes in mercury concentration in MWC exhaust Time Control Technique Typical Emission Rate Pre-1990 uncontrolled 650 ug/dscm @ 7% O2 1990 reduction in Hg input stream 180 ug/dscm @ 7% O2 2000 semi-dry scrubbers 80 ug/dscm @ 7% O2 2000 ACI + semi-dry scrubbers 14 ug/dscm @ 7% O2 Question #6 What is the fraction and total amount of industrial waste incinerated? The U.S. EPA does not have information on the fraction or total amount of industrial waste incinerated. 2
Question #7 Question #8 What is the total number of industrial waste incinerators? The U.S. EPA estimates that there are currently approximately 176 industrial waste incineration units, including incinerators, small remote incinerators, burn-off ovens, waste-burning cement kilns and energy recovery units. 7 What are the technical characteristics of the industrial waste incinerator plants? As noted under Question 19, the U.S. EPA recently proposed a new regulation for commercial and industrial solid waste incinerators. The current population of industrial waste incinerators that will be subject to this proposed regulation fall within five subcategories, which are described as follows: 8 Incinerators: Incinerators are used to dispose of solid waste materials and emissions are a function of the types of materials burned. Incinerators are designed without integral heat recovery (but may include waste heat recovery). While there are different designs, they all serve the same purpose; reduction in the volume of solid waste materials. They can be continuous or batch processes. Energy-recovery units: Energy recovery units are typically waste-fired boilers and process heaters that combust solid waste materials as a percentage of their fuel mixture and are designed to recover thermal energy in the form of steam or hot water. Energy recovery units are generally larger than incinerators. Energy recovery units typically fire a mixture of solid waste and other fuels, whereas incinerators burn predominantly solid waste, although sometimes a small amount of supplemental fuel is fired to maintain combustion temperature. Waste-burning cement kilns: Waste-burning cement kilns are fundamentally different than any other industrial waste incinerator. They are physically larger than most incinerators with a comparable heat input. The design and operation of kilns is also different than other types of units. For example, the design is typically a rotating cylindrical kiln with a fuel burner on one end and raw materials being fed in the other (cold) end. Fuel (particularly solids such as tires) may also in some cases be fed at the midpoint of the kiln. Some kilns also have a large preheater tower with a precalciner that is an additional firing point for both fossil and waste fuels. The temperature profile of the kiln is critical in order to produce a saleable product. Burn-off ovens: These units typically are very small (<1 MMBtu/hr), batchoperated, combustion units that are used to clean residual materials from various metal parts that are then reused in the process. The amount of waste combusted in these units is generally small (pounds per year in some cases) and the configuration of the stacks that serve these units precludes the use of some stack test methods for measuring emissions and could affect the ability to install certain control devices. Small, remote incinerators: These are batch-operated units that combust less than 1 ton of waste per day and are farther than 50 miles driving distance to the closest municipal solid waste (MSW) landfill. To the extent that these units are located in Alaska, a major difference in these types of units is the inability to operate a wet scrubber in the northern climates and the lack of availability of 3
wastewater handling and treatment utilities. Question #9 What is the average mercury content in the industrial waste? The average mercury content in industrial waste is unknown. Question #10 What are the mercury emissions from industrial waste incinerated? The total mercury emissions for 2008 are estimated to be 490 kg/yr. 9 These emissions are anticipated to decrease in the upcoming years due to installation of controls and unit closures or cessation of waste burning in order to comply with the proposed emissions standards for commercial and industrial solid waste incineration units. A breakdown of the mercury emissions by subcategory is as follows: Burn-off oven 0.27 kg/yr Cement Kiln 323 kg/yr Energy recovery unit 93 kg/yr Incinerator 71 kg/yr Small, remote unit 0.45 kg/yr Question #11 What is the fraction and total amount of hazardous and medical waste incinerated? In the U.S., hazardous waste is defined specifically by the requirements of the Resource Conservation and Recovery Act and regulations developed under its authority. In general, hazardous waste is waste that is dangerous or potentially harmful to human health or the environment. Hazardous wastes can be liquids, solids, gases, or sludges. They can be discarded commercial products, like cleaning fluids or pesticides, or the by-products of industrial manufacturing processes. As noted under Question 19, hazardous waste is regulated differently from other industrial or medical waste that is not classified as hazardous. In 2005, approximately 40 x 10 6 tonnes (44 million tons) of hazardous waste were generated; more than 2.8 x 10 6 tonnes (3.1 millions tons) of hazardous waste or 7.2 percent was disposed of through combustion. This figure includes hazardous waste that is combusted in boilers and process heaters or used as fuel in kilns, as well as waste incinerated primarily for the purpose of waste destruction and treatment. 10 In 2003, the total quantity of hazardous waste treated by combustion was approximately was 3.0 x 10 6 tonnes (3.3 million tons). Of this total, approximately 41%, or 1.25 x 10 6 tonnes (1.37 million tons) of the hazardous waste treated was done so by incineration. 11 Hospital, Medical, and Infectious Waste (HMIW) In 1994, the total annual medical waste generated was 3.361 million tons; 15% of which was infectious. Medical waste was historically disposed of in a landfill or a sanitary sewer. In 2002, the total annual medical waste incinerated was 151,228 tons. 12 4
Question #12 What is the total number of hazardous and medical waste incinerators? In 2005, there were 107 units at which hazardous waste was incinerated. Of these, 15 units are commercial enterprises, meaning they accept waste from a variety of generators, and 92 are on-site incinerators, meaning that they burn hazardous waste generated at the facility. 13 There are 57 hospital/medical/infectious waste incinerators () currently operating in the U.S. Fourteen are commercial enterprises. Forty-three are captive, including 31 at hospitals, and the rest are related primarily to research. Six of the 57 are owned by the federal government. 14 Question #13 What is the technical characterization of the hazardous and medical waste incinerator plants? Hazardous waste incinerators are used to burn hazardous waste primarily for waste destruction/treatment purposes; however, some energy or material recovery can occur. When performed properly, incineration destroys the toxic organic constituents in hazardous waste and reduces the volume of the waste. Hazardous waste incinerator design types include rotary kilns, fluidized bed units, liquid injection units, and fixed hearth units. 15 The majority of commercial incinerators are rotary kilns, while the on-site incinerators consist of approximately equal number of rotary kilns and liquid injection units, with a few designed as fixed hearths and fluidized beds. A few hazardous waste incinerators also burn non-hazardous waste, including waste paper, animal bedding, and laboratory wastes. The majority of the (54 of the 57 units) are of a fixed grate (typically called fixed hearth) variety. Three of the units are rotary kilns. 16,17 All units have two combustion chambers. Twenty-seven of the incinerator units include waste heat recovery. The units range in capacity from about 50 pounds of waste per hour to up to about 8000 pounds per hour. Most the units are large, over 1,500 pounds per hour. Question #14 What is the average mercury content in the hazardous and medical waste? The average mercury content of hazardous waste is not available. Some incinerators burn hazardous waste containing little to no mercury, while other incineration units burn hazardous waste containing mercury. As a result, mercury stack emissions from incinerators vary widely. Although an average mercury content of the waste is not available, information regarding waste segregation practices at may be useful. Nine entities, 5
including hospitals, pharmaceutical operations, universities, and commercial operations, were surveyed by the U.S. EPA. All of the survey respondents, except for the commercial company, practice onsite waste segregation to reduce the volume of waste being incinerated. The commercial company encourages waste segregation from its waste generator clients through a number of efforts, including a waste management plan, contract requirements and waste acceptance protocols, a dental waste management program, and educational programs and supporting posters. All of the respondents that practice onsite waste segregation separate batteries and fluorescent bulbs (i.e., mercury waste) from the waste stream. 18 Question #15 What are the mercury emissions from hazardous and medical waste incineration? The total mercury emissions for mercury in 2005 are estimated to be 315 kg/yr, as shown in the corresponding spreadsheet. Mercury emissions in 2009 would be lower still because a number of units that were operating in 2005 have since closed. The total mercury emissions are 309 kg/yr (from corresponding spreadsheet). These emission estimates reflect the period after the compliance date for rules finalized in 1997 (primarily 2002-2006). Both existing and new were required to reduce emissions. The 1997 rules included limits for hydrogen chloride (HCl), carbon monoxide (CO), lead (Pb), cadmium (Cd), mercury, particulate matter (PM), dioxins/furans, NOx, and SO 2. An estimated 98% of units closed or obtained exemptions, rather than applying controls. The remaining facilities reduced emissions by improving combustion and operational practices, and applying controls. 19 6
Question #16 What is the status for air pollution emission control? Percentage of plants/capacity with cyclones, ESP, bag filters, particle scrubbers, SO 2 scrubber, limestone injection, NO x reduction. Municipal Waste For MWC units in the United States, the suite of controls used to control emissions is generally the same at large and small units. The spray dryer scrubbing system is the primary control used at municipal waste incineration units. About 97 % of the incineration units use spray dryer based scrubbing systems. The air pollution control applications of the 167 incineration units are as follows: Air Pollution Control Number of MWC Units SD/FF/ACI/SNCR 94 SD/FF/ACI 5 SD/FF/SNCR 21 SD/FF 18 SD/ESP/ACI/SNCR 15 SD/ESP/ACI 4 SD/ESP/FF/ACI 2 SD/ESP/FF/ACI 0 SD/ESP 4 DSI/FF 2 DSI/GBF 2 Where: SD spray dryer FF fabric filter ACI activated carbon injection SNCR selective non catalytic reduction ESP electrostatic precipitator DSI dry sorbent injection GBF gravel bed filter Most hazardous waste incinerators have air pollution control equipment to capture particulate matter (and nonvolatile metals) and scrubbing equipment for the capture of acid gases. As can be determined from the emissions spreadsheet, approximately 84% of incinerators use scrubbers, which can include devices such as venturi scrubbers, packed bed scrubbers, and dry scrubbers. Approximately 20% of incinerators use fabric filters/baghouses, another 13% use ESPs or wet ESPs, and 5% use activated carbon injection or carbon beds. 7
Emission control technologies that are currently being used to comply with the 1997 regulation include wet packed-bed scrubbers, venturi scrubbers, fabric filters, dry scrubbers, electrostatic precipitators (ESPs), carbon adsorbers, activated carbon injection (ACI), and selective noncatalytic reduction (SNCR) (see breakdown in table below). 20 The most common control system in use for mercury is activated carbon injection (15 units). Air Pollution Control No. of Units CC 2 DI-ESP/WS/ACI 1 DIFF 6 DIFF/ACI 9 DIFF/ACI/SNCR 2 DIFF/VS 1 DIFF/VS/ACI 1 FF 1 HEPA/CA/WS 1 PB/WESP 1 VS 6 VS/PB 6 VS/PB/ACI 2 WS 18 Where: CC = combustion control only DI = dry sorbent injection ESP = electrostatic precipitator WS = wet scrubber FF = fabric filter ACI = activated carbon injection VS = venturi scrubber HEPA = high-efficiency particulate air filter CA = carbon adsorber WESP = wet ESP PB = packed-bed scrubber Industrial Waste Incinerators (all subcategories under Q 8) Emission control technologies currently being employed by industrial incinerators vary widely. While some types of industrial incinerators are currently subject to emissions regulations, there are some types that are not currently subject, but will be subject to regulations currently being proposed. Based on the current emissions information for the baseline emissions 8
(2008) 21, approximately 16% of incinerators use scrubbers, which can include devices such as venturi scrubbers, packed bed scrubbers, and dry scrubbers. Approximately 30% of incinerators use fabric filters/baghouses, another 21% use ESPs or wet ESPs, and 13% use selective non-catalytic reduction. Question #17 Question #18 What are the current (2005 or more recent) emissions of SO 2, NO x, particles, and mercury from the sector? Large Municipal Waste Combustors Hazardous Waste Incinerators Industrial Incinerators 22 Year 2005 2002-2006 2005 2008 Particles 378 41 100 3,960 (tonnes/yr) SO 2 3593 57 Not 9,620 (tonnes/yr) available NO x 41,566 491 Not 104,700 (tonnes/yr) available Mercury 1,925 309 315 490 (kg/yr) See accompanying spreadsheets for details. What are the expected changes in incineration between now and 2020 and 2050? Municipal Waste In the United States, the future use of incineration units for MSW management will depend on various policies. On its own, the MWC industry will slowly increase capacity over time. However, a greenhouse gas (GHG) reduction policy might possibly result in an increase in the construction of new incineration plants depending on how such a policy might affect landfills, as incineration generated less GHG emissions than land filling. Currently, the majority of MSW in the United States is land filled. As part of its analyses supporting the new regulations issued in 2005, EPA projected that a number of commercial and on-site hazardous waste combustors would close in the future. 23 EPA has no information to suggest that new hazardous waste incineration capacity will be established in the future, rather EPA anticipates that any new incinerator construction would be built with the purpose of replacing existing incineration capacity (e.g., facility modernization). MACT standards require control, monitoring, testing, recordkeeping, and reporting costs. EPA expects that some on-site captive (located at 9
hospitals, pharmaceutical firms, and universities) will choose to shut down rather than comply with the revised MACT standards and either take advantage of alternative treatment methods (such as autoclaving) or contract with commercial waste treatment companies to manage their waste. Other captive will seek to segregate their waste more effectively to reduce the quantity of waste they incinerate. Faced with higher prices, the customers of commercial will similarly reduce the quantity of waste they send for incineration. Federally owned are likely to have reasons to operate unrelated to market forces. 24 Commercial and Industrial Solid Waste Incineration The U.S. EPA is not anticipating new incineration units to be built. Three of the proposed CISWI subcategories have potential alternatives to incineration that could be more economical than complying with the proposed CISWI standards. The incinerator and small, remote incinerator subcategories could cease to burn solid waste and instead divert this waste to a landfill for disposal. Likewise, burn-off ovens could be replaced with abrasive blasting or process modifications which would not necessitate the use of a burn-off oven. Question # 19 Are there plans for increased air pollution control based on national legislation or international conventions? Please specify plans if possible with information on which pollutant will be controlled and by which technologies. Air emissions from the incineration of solid waste are regulated under the Clean Air Act section 129. Currently there are regulations that limit emissions from the categories described in the response to this questionnaire: MWC (both large and small),, and commercial and industrial solid waste incinerators. Emissions from both existing and new units are limited under this authority. Mercury is one of several pollutants covered. The others are particulate matter (total and fine), SO 2, hydrogen chloride (HCl), NOx, CO, lead, and dioxins and furans. Due to litigation and to requirements under section 129 to review emission standards periodically, there are new rulemakings recently published or ongoing. For, the U.S. EPA finalized a new regulation in 2009. To achieve the mercury limits, increased use of ACI is anticipated. 25 For commercial and industrial waste, the U.S. EPA proposed for public review a revised standard on April 29, 2010. To achieve the mercury limits, the use of activated carbon injection is expected for all units requiring better control. The proposed rule and other information can be found at http://www.epa.gov/airquality/combustion/ Two other solid waste combustion categories have not been included in the response to this questionnaire. The category known as Other Solid Waste Incinerators, which rules have been developed, is made up of smaller units or other units that are not covered by the other categories. Regulations have been 10
developed for OSWI. Regulations are being developed for units that incinerate sewage sludge; they are expected to be final in December 2010. Hazardous waste incinerators are regulated under the Clean Air Act section 112. They are part of a larger category of hazardous waste combustors, which also include units that burn or process hazardous waste primarily for energy recovery, such as cement kilns, lightweight aggregate kilns, and industrial boilers or process heaters. The regulations limit mercury emissions, along with other hazardous air pollutants, from both existing and new units. In 2009, U.S.EPA committed to re-examining all hazardous air pollutant standards, including for mercury, for hazardous waste incinerators. At this time, there is no specified date by which this re-examination would be completed Question #20 Are there plans for modernization of sector until 2020 or 2050? MWC The principal area of potential modernization is in the use of MSW as a feed stock for synthetic fuel production. The expansion of such technology might potentially reduce the growth in capacity of conventional incineration units. The U.S. EPA has no knowledge of modernization of the sector, other than what was described under Question 18. The standards are expected to be fully implemented by 2014 and bring about increased incineration costs. As these incineration costs increase, the use of some technologies in the sector may increase. Specifically, some sources will likely take advantage of alternative treatment methods, such as autoclaving, or use a waste heat recovery boiler to recover as steam some of the energy generated by the incinerator. Industrial Waste Incinerators The U.S. EPA is not aware of any plans for modernization of this sector. Question #21 What are the projected emissions of mercury and air pollutants 2020 and 2050? Municipal Waste For MSW, projected emissions would probably be similar to current emissions. However, if significantly more new plants were built, emission may increase. If a significant number of synthetic fuel plants using MSW as feed stock were built that incorporated high efficiency controls, emissions may be lower. The US. EPA does not have projections specific to 2020 or 2050 for emissions from HMWI. Emissions of mercury and other air pollutants are expected to decline (as a result of additional shutdowns or the installation of additional emission controls) due to the more stringent regulations finalized in 11
2009. If all existing units were to install additional emission controls to comply with the 2009 regulations, anticipated national reductions would be: particulate matter 1,438 kg/yr; SO 2 33,430 kg/yr; NO x 66,224 kg/yr; mercury 274 kg/yr. 26 The U.S. EPA does not have 2020 or 2050 projections for other waste categories. Question #22 Please provide information on any case studies where mercury emissions have been monitored. Municipal Waste Extensive performance testing has been done at MWC. These data are summarized in a U.S. EPA document Performance Test Data for Large Municipal Waste Combustor (MWC) at MACT Compliance, June 18, 2002. It is publically available in EPA s Air Docket A-98-45, Item VIII-B-4. Hazardous waste incinerators are required to conduct periodic performance testing (every 5 years) to demonstrate compliance with the emission standards for hazardous air pollutants and establish operating parameter limits to maintain compliance with those standards. Either EPA or the State where the incinerator is located maintains the results of the performance testing. The emissions spreadsheets are based on earlier performance testing conducted in the 1980s or 1990s. The U.S. EPA has no information on any mercury emissions monitoring case studies conducted at facilities, but mercury continuous emission monitoring systems (CEMS) and integrated sorbent trap mercury monitoring (continuous sampling with periodic sample analysis) were included as monitoring options in the regulation finalized in 2009. The original 1997 regulation required monitoring of mercury sorbent (activated carbon) flow rate to demonstrate ongoing compliance with the mercury emission limit and mercury emission tests to demonstrate initial compliance with the mercury emission limit. The 2009 regulation included additional mercury emission testing for to demonstrate compliance with the revised mercury emission limits, unless the shows (using applicable results from previously conducted tests) that it is already in compliance. 27 The details and results of the tests to demonstrate initial compliance with the original 1997 rule have been compiled by the U.S. EPA, and are available in the docket for the rulemaking as entry EPA-HQ-2006-0534-0318 at http://www.regulations.gov. Industrial Waste Incinerators In support of developing the proposed regulations for commercial and industrial solid waste incineration units, the U.S. EPA required performance 12
Question #23 testing on industrial waste incineration units in 2009. The results of these tests have been utilized in developing the emission limits being proposed in 2010, as well as the development of the baseline emission estimates. 28,29 The details and results of the tests have been compiled by the U.S. EPA and are available in the docket for the rulemaking as entry EPA-HQ-OAR-2003-0119 at http://www.regulations.gov. Please provide any available information on investment and running costs for emission control of mercury. Muncipal Waste For ACI on a typical large MWC unit of 730 Mg waste/day, estimated costs in 1987 U.S. dollars are $150,000 capital and $91,000/yr annual operating costs. These costs do not include the spray dryer/fabric filter system, which would add an additional $12 x 10 6 capital cost and $3.6 x 10 6 annual cost, if they were not already applied for controlling pollutants other than mercury. 30 Capital costs for the ACI system applied to an unit range from approximately $3,800 to $12,000. Annual costs for the ACI system range from approximately $5,400/yr to $56,300/yr. Both capital and annual costs are in 2007 U.S. dollars. Additional information on the origin of the costs can be found in the referenced memorandum on cost estimates for the rulemaking. 31 Industrial Waste Incinerators Estimated capital costs for the activated carbon injection system (ACI) applied to a commercial or industrial solid waste incineration unit range from approximately $5,600 to $156,000. Annual costs for the ACI system range from approximately $2,900/yr to $3.2 million/yr. Both capital and annual costs are in 2008 U.S. dollars. Additional information on the origin of the costs can be found in the referenced memorandum on cost estimates for the commercial and industrial solid waste incineration rulemaking. 32 Question #24 Please provide information on any case studies where mercury emissions have been monitored. Repeat of question 22 1 Municipal Solid Waste Generation, Recycling, and Disposal in the United States: Facts and Figures for 2008 http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw2008rpt.pdf and Municipal Solid Waste Generation, Recycling, and Disposal in the United States Detailed Tables and Figures for 2008 http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw2008data.pdf 2 National Inventory of Small Municipal Waste Combustion (MWC) Units at MACT Compliance (Year 2005)" November 1, 2006; Jason Huckaby, Eastern Research Group,Inc to Walt Stevenson, U.S. Environmental Protection Agency. 3 Waste-to-Energy Research and Technology Council. "ABC of Sustainable Waste Management (SWM)" ; 2009 4 US EPA. Mercury Study Report to Congress Volume II: An Inventory of Anthropogenic Mercury Emissions in the United States (PDF). December 1997. <http://www.epa.gov/mercury/report.htm> 13
5 U.S. EPA. Performance Test Data for Large Municipal Waste Combustors (MWC) at MACT Compliance. June 18, 2002. EPA Air Docket A-98-45, Item VIII-B-4. 6 U.S. EPA. Standards of Performance for New Stationary Sources: Muncipal Waste Combustors, Proposed Rule. Federal Register Vol. 59, No. 181, page 48198. September 20, 1994. 7 U.S. EPA. Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration Units, Proposed Rule. April 2010. 8 Eastern Research Group, Inc. to U.S. EPA, memorandum. CISWI Test Data Database. April 20, 2010. 9 Eastern Research Group, Inc. to U.S. EPA, memorandum. Baseline Emissions and Emissions Reductions Estimates for Existing CISWI Units. April 22, 2010. 10 2005 National Biennial RCRA Report, December 2006, EPA530-R-06-006 <http://www.epa.gov/waste/hazard/tsd/td/combustion.htm> 11 U.S. EPA. Addendum to the Assessment of the Potential Costs, Benefits & Other Impacts of the Hazardous Waste Combustion MACT Final Rule Standards. September 2005. Docket item EPA-HQ-OAR-2004-0022-0463. Exhibit 3. 12 RTI International; Prepared for U.S. EPA. Economic Impacts of Revised MACT Standards for Hospital/Medical/Infectious Waste Incinerators. July 2009. Docket item EPA-HQ-OAR-2006-0534-0376 13 U.S. EPA. 70 Federal Register Vol. 70, page 59530 (October 12, 2005). Also, US EPA. Assessment of the Potential Costs, Benefits & Other Impacts of the Combustion MACT Final Rule Standards. September 2005. Chapter 2, Exhibit 2-3. Docket items EPA-HQ-OAR-2004-0022-0464 and EPA-HQ-OAR-2004-0022-0466. 14 RTI International; Prepared for US EPA. Economic Impacts of Revised MACT Standards for Hospital/Medical/Infectious Waste Incinerators. July 2009. Docket item EPA-HQ-OAR-2006-0534-0376 15 US EPA. Wastes - - Treatment & Disposal Website <http://www.epa.gov/waste/hazard/tsd/td/combustion.htm> 16 RTI International for U.S. EPA. Updated Hospital/Medical/Infectious Waste Incinerator () Inventory Database. 7/6/09 Docket item EPA-HQ-OAR-2006-0534-0389. 17 U.S. EPA. process description report. Legacy docket no A-91-61, item II-A-110. 18 RTI International to U.S. EPA, memorandum. Summary of Industry s to Waste Segregation Information Collection Request 10/24/08 EPA-HQ-OAR-2006-0534-0316 19 Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Hospital/ Medical/Infectious Waste Incinerators; Proposed Rule. Federal Register Vol. 73, No. 231, December 1, 2008. 20 RTI International to U.S. EPA, memorandum Revised Baseline Operating Costs for Existing. 6/19/09 EPA-HQ-OAR-2006-0534-0381 21 Eastern Research Group, Inc. to U.S. EPA, memorandum. Baseline Emissions and Emissions Reductions Estimates for Existing CISWI Units. April 22, 2010. 22 Eastern Research Group, Inc. to U.S. EPA, memorandum. Baseline Emissions and Emissions Reductions Estimates for Existing CISWI Units. April 22, 2010. 23 U.S EPA. Addendum to the Assessment of the Potential Costs, Benefits & Other Impacts of the Hazardous Waste Combustion MACT Final Rule Standards. September 2005. Docket item EPA-HQ-OAR-2004-0022-0463. Exhibit 9. 24 RTI International; Prepared for US EPA. Economic Impacts of Revised MACT Standards for Hospital/Medical/Infectious Waste Incinerators. July 2009. Docket item EPA-HQ-OAR-2006-0534-0376 25 Standards of Performance for New Stationary Sources and Emissions Guidelines for Existing Sources: Hospital/ Medical/Infectious Waste Incinerators; Final Rule. Federal Register Vol. 74, No. 192. October 6, 2009. 26 Standards of Performance for New Stationary Sources and Emissions Guidelines for Existing Sources: Hospital/ Medical/Infectious Waste Incinerators; Final Rule. Federal Register Vol. 74, No. 192. October 6, 2009. 27 Standards of Performance for New Stationary Sources and Emissions Guidelines for Existing Sources: Hospital/ Medical/Infectious Waste Incinerators; Final Rule. Federal Register Vol. 74, No. 192. October 6, 2009. 28 Eastern Research Group, Inc. to U.S. EPA, memorandum. CISWI Test Data Database. April 20, 2010. 29 Eastern Research Group, Inc. to U.S. EPA, memorandum. Baseline Emissions and Emissions Reductions Estimates for Existing CISWI Units. April 22, 2010. 30 U.S. EPA. Standards of Performance for New Stationary Sources: Muncipal Waste Combustors, Proposed Rule. Federal Register Vol. 59, No. 181, page 48209. September 20, 1994. 31 RTI International to U.S. EPA, memorandum Revised Compliance Costs and Economic Inputs for Existing. 7/6/09 EPA-HQ-OAR-2006-0534-0384 14
32 Eastern Research Group, Inc. to U.S. EPA, memorandum. Compliance Cost Analyses for CISWI Units. April 22, 2010. 15