1. 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

2. 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

3. 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

4. Emissions Guidelines for Large HMIWI May 26, 2010 | 4

5. 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 May 26, 2010 | 5

6. 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) May 26, 2010 | 6

7. 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 May 26, 2010 | 7

8. 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 May 26, 2010 | 8