Air Emissions

This page provides information on equipment and materials for which health care facilities may be required to obtain air quality permits.

See Practice Greenhealth’s Clean Air Act page for additional information on the federal law that authorizes the EPA to impose air quality permit requirements.

Sources of air emissions at health care facilities

• boilers
• medical waste incinerators
• air conditioning and refrigeration units
• crematoria
• asbestos
• paint booths
• ethylene oxide sterilization units
• emergency generators
• anesthesia
• laboratory chemicals
• laboratory fume hoods

Permits that may be required under the Federal Clean Air Act

Title I: Some large pieces of equipment may be subject to New Source Performance Standards under the Clean Air Act. Information on NSPS requirements for certain specific pieces of equipment can be found on Practice Greenhealth pages dealing with

• boilers
• incinerators

Many types of emission involving Hazardous Air Pollutants are also regulated under Title I. Specific cases are discussed in more detail in the next section.

Title V: This section of the CAA requires that all “major sources” (and certain minor sources) obtain an overall operating permit. A health care facility that qualifies as a major source would be required to have a Title V permit, and may be required to submit a permit application that includes information about emissions, control devices, and the general process at the facility. Permits may limit pollutant emissions and impose monitoring, record-keeping, and reporting requirements.

Monitoring requirements for many facilities with Title V permits are specified in the Compliance Assurance Monitoring regulations. For facilities that meet emissions requirements on their permits by using pollution control equipment, CAM may require that the facilities monitor the control equipment to assure that it is operated and maintained as prescribed in their permits.

The EPA website provides an index page on Title V operating permits

NESHAPs that may apply to health care facilities

Industrial, Commercial and Institutional Boilers and Process Heaters

This NESHAP may apply at hospitals that are major hazardous air pollutant emitters under the CAA. A major emitter is defined as emitting at least:

• 10 tons/year of a single HAP, or
• 25 tons/year of a combination of HAPs

Note: Only health care facilities that are part of a large entity such as a prison, university or military base are likely to be major sources under the CAA. The EPA provides additional information about rules pertaining to boilers.

More information on the boiler NESHAP can be found on the Practice Greenhealth Boilers page.

Medical Waste Incinerators

• Subpart Ec applies to HMIWI that were constructed after June 20, 1996.
• Subpart Ce contains emissions guidelines that apply to HMIWI that were constructed before June 20, 1996.)

Under the CAA, EPA regulates air emissions from hospital medical/infectious waste incinerators (HMIWI). When burned, medical waste may emit air pollutants, including:

• acid gases, such as
  • hydrochloric acid (HCl)
  • dioxins
  • furans
• metals, such as
  • lead (Pb)
  • cadmium (Cd)
  • mercury (Hg)

EPA has developed emission standards that apply both to incinerators used by hospitals and health care facilities as well as to those used by commercial waste treatment and disposal companies to treat medical waste.

The emission guidelines are intended to meet the requirements of the federal CAA. States can establish their own standards, but they must be at least as protective as the federal standards. These standards will result in reductions in the air emissions of concern from HMIWI.

The EPA provides an index page with links to detailed information on the HMIWI rule.

Generators (Stationary Reciprocating Internal Combustion Engines)

(40 CFR 63 subpart ZZZZ)

Stationary reciprocating internal combustion engines (usually gas or diesel generators) at healthcare facilities are probably subject to this standard if:

• they are part of a facility that is major source for HAP (i.e. that has the potential to emit at least:
  • 10 tons/year of a single HAP, or
  • 25 tons/year of a combination of HAPs
• they are over 500 horsepower, and
• they were built after December 19, 2002

Note: Only health care facilities that are part of a large entity such as a prison, university or military base are likely to be major sources under the CAA. The full set of applicability criteria for various cases is somewhat elaborate. The EPA provides an applicability flowchart covering a range of situations.

Asbestos

(40 CFR 61 Subpart M)

A health care facility that performs demolition and renovation operations will be subject to the CAA NESHAP for asbestos. Here is a brief summary of requirements; please refer to the additional resources listed below for more details:

• A written notice of intention to demolish or renovate must be submitted to EPA at least 10 working days prior to the start of construction.
• No asbestos is to be stripped, removed, or otherwise handled or disturbed unless at least one authorized representative trained in NESHAP asbestos regulations is present.
• Asbestos must be removed prior to demolition or renovation and proper precautions must be made such as wetting down the material to keep it intact.

Additional resources for asbestos:

• The Asbestos Informer gives a concise explanation of the risks posed by asbestos and applicable regulations.
• EPA Region 4 (southeastern states) provides an index page with links to many asbestos-related resources.

• EPA Region 10 (northwestern states) also provides an index page with asbestos-related resources.

• EPA Asbestos Ombudsman:
  • Hours of Service: 8:30 a.m. – 5:00 p.m. (EST) M – F
  • Telephone: 800-368-5888 (available 24 hours a day)

• Managing Asbestos in Place: A Building Owner’s Guide to Operations and Maintenance Programs (“Green Book”, available in paper copies only) can be ordered through the Ombudsman.

Ethylene oxide (EtO)

Healthcare facilities should be aware that a future area source rule covering hospital sterilizers using EtO could apply to them.)

Some healthcare facilities use ethylene oxide as a sterilant for certain types of healthcare supplies and devices. In some cases, manufacturers recommended this practice to ensure the sterility of a product.

EPA is considering a number of new standards under its Urban Air Toxics Strategy that would apply to “area sources” (facilities that emit less than those that would be considered “major sources”). Most healthcare facilities would be considered to be area sources under this definition. Hospital sterilizers are one of 55 area source categories that may be subject to NESHAP regulations as a part of this strategy. See the EPA’s Area Source Standards for more information.

Refrigerants

(CAA Section 608)

The purpose of Section 608 of the CAA is to maximize the recovery and recycling of refrigerants during the servicing and disposal of stationary air conditioning and refrigeration equipment. Requirements covered under this section include:

• prohibition of venting
• service requirements
• equipment certification
• leak repair
• proper disposal
• recordkeeping

EPA Region 2 provides an information page on the Refrigerant Recycling Rule that includes compliance and technical information for facility managers and contractors.

EPA Region 6 provides an information page with links to documentation of recent rules related to leak repair requirements and refrigerant venting, and to technical information.