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DEE-5: Air Pollution Control Enforcement Policy - Appendix V

Regulated Medical Waste Incineration - 6 NYCRR Subpart 219-3

I. Purpose

The purpose of the Enforcement Guidance Memorandum (EGM) is to establish the Department's enforcement strategy for addressing non-compliance with 6 NYCRR Subpart 219-3 which governs the allowable emissions from "regulated medical waste incineration facilities".(1) Subpart 219-3 applies to all facilities which incinerate regulated medical waste (RMW). Facilities incinerating 50 tons per day or more are also subject to 6 NYCRR Subpart 219-2. ECL Section 19-0306.7 requires regulated medical waste incineration facilities to employ best available control technologies (BACT). BACT for RMW incinerators burning less than 50 tons per day is set forth in Subpart 219-3.(2) The statutory deadline for compliance with this Subpart was April 1, 1989 for those RMW incinerators owned by health care facilities not licensed pursuant to Article 28 of the Public Health Law (PHL), (e.g. federal and state run institutions such as Veteran's Hospitals and NYS Office of mental Health Facilities) and RMW incinerators operated by health care facilities licensed pursuant to PHL §28 and permitted by DEC after September 1, 1987. RMW incinerators operated by health care facilities licensed pursuant to PHL Article 28 and permitted on or before September 1, 1987 are subject to a statutory deadline of January 1, 1992.

It is the duty of DEC as a regulatory and enforcement agency to ensure compliance with the ECL and associated regulations, and to utilize the penalties provided under Article 71 to deter and punish violations of the statute.

II. Background

It is estimated that some 400 facilities statewide may be subject to the requirements of Subpart 219-3. This regulation applies to an industry category which, for the most part, involves not-for-profit organizations. These organizations provide health and societal benefits to communities across the state.

The Legislature requires the application of BACT to ensure that hospitals and other health care facilities do not present unacceptable health risks to the communities they serve. This agency shall enforce the law in a manner consistent with the purposes served by the hospitals as well as the absolute requirement that compliance be achieved as soon as feasible. Compliance delays will be analyzed for the payment of appropriate penalties and the use of administrative and judicial injunctive relief.

Voluntary cessation of RMW incineration and the closure of Non-complying RMW incinerators will be the alternative chosen by many facility owners subject to Subpart 219-3. RMW incinerator owners choosing this alternative should close their incinerator according to the appropriate regulatory deadlines. DEC's enforcement responses to facility owner failure to close non-complying incineration are set forth in Section III of this EGM.

The Division of Air Resources (DAR) issued guidance concerning Implementation of Subpart 219-3 in 1989 and last revised that guidance on January 1, 1991 as 91-AIR-28.(3) That guidance established the basic approach that DEC Regional Air Pollution Control Engineers (RAPCES) should take towards reviewing applications for permits to construct; requirements for pre-construction dispersion modeling and health risk assessment; performance of post construction modeling and health risk assessment; and reviewing Certificates to Operate. That guidance should be referenced in determining a facility's compliance and in developing enforcement orders.(4)

Experience indicates there is often resistance in neighboring communities to permitting a new or upgraded incinerator. Controversy comes despite the fact that, in almost all cases, existing incinerator emissions will be significantly reduced through the implementation of Subpart 219-3. Hence, DEC expects that some facility owners may encounter delays and obstacles beyond their control as these owners attempt to comply with the regulation.

The health care industry is improving its record with the newly established RMW tracking systems under 6 NYCRR Part 364 and the federal rules of 40 CFR Parts 22 and 259. Likewise, there ultimately will be total compliance with the incinerator rules. Hence, the enforcement Strategy of DEC is to straightforwardly deal with delayed compliance by outlining our intended course of action and following through with consistent and fair enforcement.

III. Enforcement Strategy

  1. General Approach

    DEC shall issue Compliance Determination directives (CDD) (Attachment 1) to Subpart 219-3 RMW incinerator owners listed in DEC records. the RMW incinerator owner will be invited to respond to demonstrate Compliance, or answer the questionnaire provided within the CDD and provide a schedule leading to compliance where necessary. Additionally, the CDD will invite the RMW incinerator/owner that has committed to building new or renovated RMW incinerator Facilities to consent to an enforcement Order where such RMW incinerator owner's schedule of compliance extends beyond April 1, 1992 in the case of PHL Article 28 owners permitted on or before September 1, 1987. In the case of non PHL Article 28 owners and PHL Article 28 owners permitted after September 1, 1987 any non-compliance after January 1, 1992 should result in issuance of an Order.

    The timeframe for the issuance of Compliance Determination directives is September 20 through September 30, 1991. Responses should be made due no more than 45 days from receipt. Based on the responses and non-responses, DEC will design a field inspection program that will commence on the first week in January of 1992. Facilities that do not respond should be subject to the highest inspection priority and follow-up enforcement. RMW incinerator owners that respond that they anticipate being in compliance on January 1, 1992 should be inspected after January 1, 1992 should be inspected after January 1, 1992 to assure the cessation of incineration of RMW or the operation of a complying RMW incinerator in accord with a Certificate to Operate.

    RMW incinerator owners regulated under PHL §28 and permitted on or before September 1, 1987, that respond to the CDD by projecting compliance after January 1, 1992 but before April 1, 1992 should be issued Notice of Compliance Determinations (NOCD) incorporating a Notice of violation (NOV). This latter group of facilities should be inspected to ascertain compliance on April 1, 1992.

    "Article 28" facilities permitted on or before September 1, 1987 that respond to the CDD by projecting Installation and permitting of a new or upgraded RMW incinerator after April 1, 1992 should be sent a NOV and a proposed Order on consent based on the facility owner's proposed compliance schedule and terms in accord with this EGM. "Article 28" facilities projecting noncompliance after April 1, 1992 and no plans or commitment to installation/upgrading of an RMW incinerator should be scheduled for administrative or judicial enforcement to Seek ordered cessation of RMW incineration by April 1, 1992.

    Facilities not regulated under PHL Article 28 and Article 28 facilities permitted after September 1, 1987 indicating non-compliance on January 1, 1992 should be issued a Notice of violation and sent a proposed consent order in accord with this EGM. The penalty schedule in the Consent Order must begin with sanctions for RMW incinerated on January 1, 1992 to the last day that RMW is burned at the non-complying facility.

    Whenever the inspection program verifies non-compliance and there is a non-response to the questionnaire; or whenever there is any failure to follow through with consent order negotiations, a notice of Hearing and a Motion for Summary Order pursuant to 6 NYCRR Section 622.10 should be issued. The Motion for a Summary Order should seek immediate cessation of non-complying incinerator operations and assessment of penalties in accord with the Civil Penalty Policy.

  2. Penalties

    DEC will use the approaches outlined in the Civil Penalty Policy as supplemented by the more specific guidance set forth here. That Civil Penalty Policy calls for calculation of economic benefit due to delayed compliance. The purpose of the calculation is to arrive At a sum that removes any "economic benefit" from delayed compliance.(5) A second analysis to Derive the gravity/punitive portion of the penalty is also Necessary. This latter sum takes account of the seriousness and Degree of harm posed by the violation. DEC enforcement staff should utilize the schedule of "Poundage Penalties" provided in this EGM for the total penalty figure for those RMW incinerator owners that are willing to: 1) sign a Consent Order to resolve violations, and 2) commit to a compliance schedule to construct a complying incinerator. For RMW owners that are electing to utilize non-incineration options, it shall be the approach of this agency to seek shut down of non-complying incinerators no later than April 1, 1992. Actions to seek closure of these facilities should proceed by use of motions for summary orders or applications for judicial injunctions.

    Where a RMW incinerator owner is violating other requirements of the ECL, these violations should be separately analyzed for penalty Liability according to the Civil Penalty Policy. Also, in adjudicated matters, the Civil Penalty Policy should be applied to Derive an appropriate penalty. Furthermore, DEC's enforcement policy should be clearly communicated to the RMW incinerator owners so that they can anticipate the penalty structure and quickly comply with the law.

    Where appropriate, consent orders should include a provision calling for payment of poundage penalties according to one of the following applicable schedules:

    Per Pound of RMW Plus Non-RMW Incinerated at Non-Complying RMW incinerators
    Period of Compliance Schedule All Non PHL Article 28 Facilities and any Article 28 facilities Permitted After 9/1/87 Any PHL Article 28 Facilities Permitted on or before 9/1/87
    Nominal Schedule Penalty Adjusted Schedule
    1/1/92 - 3/31/92 $0.07 $~~~ $~~~
    4/1/92 - 6/30/92 $0.10 $0.07 $0.04
    7/1/92 - 9/30/92 $0.15 $0.10 $0.07
    10/1/92 - 12/31/92 $0.20 $0.15 $0.12
    1/1/93 - 3/31/93 $0.30 $0.20 $0.17
    4/1/93 - 12/31/93 $0.35 $0.30 $0.27
    1/1/94 and after $0.35 + $0.05 per month after 1/1/94 $0.30 + $0.05 per month after 1/1/94 $0.27 + $0.05 per month after 1/1/94

    All orders should include interim operating conditions which make it a term of the Order that existing incinerator facilities shall be operated in a manner that causes the least possible emission impact. Also, the order must require strict compliance with last issued Certificate to Operate. A schedule of stipulated penalties for non-compliance with interim operating conditions should be included in the Order on Consent at the discretion of the regional Air Pollution Control Engineer.

    All consent orders shall contain a provision for a minimum of $25,000 in stipulated penalties, if the respondent fails to pay poundage penalties within the time frame required by the consent order. This stipulated penalty shall be in addition to the poundage penalties due. In addition, all consent orders shall contain A separate and distinct provision specifying at least $25,000.00, per emission point for violation of any provision of the order other than paying the poundage penalties in a timely fashion.

    Matters taken to enforcement hearing prosecution should include Consideration of why additional penalties should not be paid in accord with the Civil Penalty Policy.

  3. Compliance Schedules for Construction/Upgrading of Complying Incinerators

    Orders on Consent are often termed "bridges" from non-compliance to compliance. Schedules shall be as short as practically possible. Delays beyond the timeframes specified in the Compliance Schedule themselves should result in the payment of meaningful stipulated penalties over and above those provided by operation of the poundage penalties schedule.

    In developing the Compliance Schedule for an Order, Department Staff may take account of delays attributable to protracted state government review and delay attributed to public controversy which may accompany the permitting process and public hearings. Hospitals are also regulated by the New York State Department of Health (DOH). In particular, hospitals seeking to upgrade or construct new complying incinerators or otherwise undertaking capital expenditure in excess of $300,000 must receive a certificate of Need (CON) from DOH. DOH review involves technical And fiscal considerations. In establishing compliance schedules, DEC should provide for DOH review time frames to the extent that Such reviews do not run concurrently with other events subject to the compliance schedule.

    Nonetheless, the approach taken through this guidance is that the protracted operation of a facility's non-complying Incinerator provides to the hospital an undeserved economic benefit due to the fact that the hospital saves operating and maintenance Costs and is able to postpone capital expenditure for incineration and control equipment required to meet the new emission limits.

    In accord with the Order on Consent Policy and as a matter of practical implementation, DEC should exercise its enforcement discretion to except from enforcement action all Article 28 facilities permitted on or before September 1, 1987 which come into actual compliance with the statutory and regulatory emission Limitations by April 1, 1992 where such progress is shown in the response to the Compliance Determination Directive and DEC's permit review.

  4. Compliance Schedule Elements

    All Orders on Consent shall have, as appropriate, the following minimum compliance schedule events:

    1. Milestone dates for payment of stipulated penalties for delayed compliance. (The intervals for payment of stipulated penalties generally should not exceed 60 days);
    2. Date for submission of complete application for a permit to construct;
    3. Date for submission of a protocol for air quality impact analysis and performance of the health risk assessments, if necessary;
    4. Date for submission of the Certificate of Need (CON) application to the Department of Health;
    5. Commencement of construction;
    6. Stack test;
    7. Submittal of stack test results and health risk assessment based on stack test results; and
    8. Final compliance through the issuance of a Certificate to operate and payment of any remaining stipulated penalties.
  5. Penalty Adjustments

    Where a RMW incinerator owner regulated under PHL §28 and permitted on or before September 1, 1987, has expended A substantial portion of the capital funds necessary for the installation of complying equipment and where this commitment is specified in a written contract for the construction and installation of the equipment and where the equipment manufacturer warrants the performance of that equipment to meet the requirements of New York State regulations, the operator may seek to have the stipulated penalties for delayed compliance calculated according to the "Adjusted Penalty Schedule" rather than the "Nominal Penalty Schedule".

    Also, where a respondent has made timely application for Requisite approvals to DEC and DOH and where public hearings and state government review periods result in compliance schedule delays more than 8 weeks beyond those established by the respondents and DEC in settlement of the consent order terms, Respondents may be afforded an opportunity to keep the "per pound" stipulated penalty rate from escalating to the next higher penalty rate on account of such delay greater than 8 weeks. A modification provision to this effect may be contained in the Consent Orders.

  6. Inter-Divisional Coordination

    The Central Office DAR's Bureau of Source Control will have primary responsibility for tracking DEC's compliance effort. RAPCE's and Regional Attorneys will be primarily responsible for negotiation of acceptable Consent Orders and prosecuting recalcitrant sources. Throughout the process though, other Divisions will become involved in the effort. In particular, the Division of Hazardous Substance Regulation (DHSR) should be kept apprised of health care facilities plans for handling RMW. DHSR should follow up to ensure Compliance with 6 NYCRR Part 364 requirements for the transport, packaging and storage of RMW. Likewise, the Division of Solid Waste is preparing regulations [6 NYCRR Subparts 360-10 (revised) and 360-17 (new)] which will specify requirements for treatment and handling of Off-site generated RMW. The Division of Solid Waste should stay apprised of the Air enforcement efforts as well.

    The Office of Hearings should expedite the hearings in these matters and the Division of Environmental Enforcement should continue to provide primary compliance counseling on the conduct of this enforcement program.

IV. Conclusion

The medical waste incinerator compliance program involves A sizable effort by this agency and the permitting and enforcement workload will have to be integrated with existing demands.

This EGM is designed to encourage swift compliance with 6 NYCRR subpart 219-3. Compliance schedules and orders negotiated under this EGM will address the abilities and needs of the hospitals and health care facilities involved but at the same time have a definite path toward compliance.

This Enforcement Guidance Memorandum is effective immediately.

DATED: Albany, New York

September 30, 1991

Thomas C. Jorling

Commissioner of Environmental Conservation




In the Matter of a Compliance
Determination Pursuant to Title 6 COMPLIANCE
of the Official Compilation of DETERMINATION
Rules and Regulations of the State DIRECTIVE (CDD)
of New York, Part 202 and
Subpart 219-3 (6 NYCRR Part 202 &
subpart 219-3) and Article 19 of the
Environmental Conservation Law (ECL) by:

A Regulated Medical Waste (RMW) Incinerator Owner.


The Administrator
3~, NY 4~


  1. The RMW Incinerator owner named above operates an incinerator subject to the best available control technology requirements set forth at ECL §19-0306 and 6 NYCRR Subpart 219-3;
  2. The Commissioner of Environmental Conservation (Commissioner) may require testing to ascertain compliance under Environmental Conservation Law (ECL) Sections 3-0301, 19-0301 and 19-0303, and 6 NYCRR Part 202;
  3. Failure to submit the required information on time is deemed sufficient reason for the Commissioner to suspend or deny your certificate to Operate and will result in further enforcement action;
  4. ECL Section 19-0306.8 requires that each person who operates a regulated medical waste (RMW) incinerator, report to the Commissioner on the volume and sources of regulated medical waste that is incinerated on-site; and,
  5. The Commissioner of Environmental Conservation has issued an Enforcement Guidance Memorandum dated September, 1991. Said guidance document outlines the DEC's program for enforcement and compliance with respect to facilities subject to 6 NYCRR subpart 219-3. You may obtain a copy of this document by writing to:

    Compliance Counsel for Air Resources
    New York State Department of Environmental Conservation
    Division of Environmental Enforcement
    625 Broadway
    Albany, New York 12233-5500.


I. The above named RMW Incinerator owner submit a protocol, test procedure and results for the noted incinerator as follows:

  1. Submit approvable protocol and test procedure for the identified incinerator to test for all the contaminants identified in 6 NYCRR Subpart 219-3 and also in DEC Division of Air Resources guidance Memorandum 91-AIR-28, dated January 1, 1991. [This document is exactly the same, verbatim, as 90-AIR-28A, dated April 17, 1990.] The protocol and test procedure shall be submitted to the Department within 45 days of receipt of this CDD;
  2. Test and measure emissions form the incinerator between January 1, 1992 and January 31, 1992; and,
  3. Submit results of testing within 60 days of actual Testing.


II. As an alternative to, and instead of, the submission of the protocol and stack test results described in paragraph I, above, the RMW incinerator owner must submit a fully completed and certified Compliance Determination Questionnaire describing said owner's incinerator operation and compliance plan with respect to 6 NYCRR Subpart 219-3 and containing specific answers to the questions propounded therein within 45 days of receipt of this compliance Determination Directive. A blank Compliance determination Questionnaire is attached to this CDD as "Attachment 1."

III. Send submissions pursuant to this Compliance Determination directive to:

New York State Department of Environmental Conservation
Division of Air Resources
Bureau of Source Control
625 Broadway
Albany, New York 12233-3254

If you have any questions regarding the CDD or Questionnaire please call Major Source Review Section staff in the Bureau of source Control at (518) 457-2044.

IV. All submissions, statements, and answers required should be Certified by an authorized officer of the RMW incinerator owner corporation.

DATED: Albany, New York

September 30, 1991


BY: ________________________________________

Thomas Allen, P.E.
Director, Division of Air Resources


1. Compliance Determination Questionnaire

2. Compliance Schedule Work Sheet

cc: Commissioner of Health
DEC Compliance Counsel for Air Resources
DEC Regional Air pollution Control Engineer


Attachment 1


Name of Hospital: ______________________________

Street Address: __________________________

City: ______________________________

County: ______________________________

Zip Code: ______________________________

DEC Location Facility ID#: ______________________________

Incinerator #: ______________________________

Contact Person: ______________________________

Telephone Number: ______________________________


  1. Pounds of RMW incinerated per week at the facility?

    ______________________________ pounds per week
  2. Off-Site Sources of RMW?

    1. ______________________________
    2. ______________________________
    3. ______________________________
    4. ______________________________
  3. If there are more than four sources of RMW please list and attach separately.
  4. Pounds of non-RMW incinerated per week at the facility?

    ______________________________ pounds per week

    Please attach a copy of the 1990 DEC Form 47-15-23 (11/89) 10f, "On-site Medical Waste Incineration Report" submitted for this facility.


  1. Will this incinerator be operated on or after January 1,1992?

    YES [ ] / NO [ ]

    If Yes, go to Section 2b.

    If no, please explain below when shutdown will occur and proposal for handling the RMW and non-RMW that is being generated, then go to Section 5 of this questionnaire.

  2. Will this incinerator be in compliance with 6 NYCRR Subpart 219-3 prior to January 1, 1992?

    YES [ ] / NO [ ]

    If Yes, go to Section 3.

    If No, go to Section 4.


These questions are for owners of incinerators who plan to be in compliance with 6 NYCRR Part 201 and Subpart 219-3 prior to January 1, 1992. Compliance will be demonstrated by obtaining a Certificate to Operate subsequent to submittal of an acceptable stack test report.

  1. When will your acceptable stack test protocol be submitted?


  2. When will the stack test be performed?


  3. When will the results be submitted to DEC?



These questions are for owners of incinerators who plan to be in compliance with 6 NYCRR Part 201 and Subpart 219-3 on or after January 1, 1992. Compliance will be demonstrated by obtaining a certificate to Operate subsequent to submittal of an acceptable stack test report.

  1. Has a DEC air Permit to Construct application for a modification or new facility been submitted?

    YES [ ] / NO [ ]

    If Yes, give date of submittal.


    If No, when will the application be submitted?


  2. Has an air Permit to Construct been issued by DEC?

    YES [ ] / NO [ ]

    If Yes, give date of issuance.



  1. Is the source owner licensed under New York Public Health Law Article 28?

    YES [ ] / NO [ ]

    If Yes, DOH's Operating Certificate number:


    If No, go to Section 5c.

  2. Was DEC's initial Permit to Construct issued prior to September 1, 1987.

    YES [ ] / NO [ ]

  3. Is the facility exempt from licensing under PHL Article 28?

    YES [ ] / NO [ ]

    If exempt, please state below the basis for such exemption.





  1. Does the source owner wish to be considered for a Voluntary Order on Consent Program?

    YES [ ] / NO [ ]

  2. If yes, please fill in the attached compliance schedule worksheet and provide the name, address and telephone number of your attorney. Upon receipt of the compliance schedule worksheet and your answers to the above posed questions, DEC compliance staff will review the submittals and respond to your designated Counsel with a proposed Order on Consent and/or other communications in accord with DEC enforcement policy.


Bureau of Source Control
New York State Department of Environmental Conservation
Division of Air Resources
625 Broadway
Albany, New York 12233-3254


All submissions, statements, and answers required should be Certified as follows by an authorized officer of the RMW incinerator owner.


I hereby affirm under penalty of perjury that I am _______________ (title) of _______________ (entity); that I am authorized by that entity to respond to this CDD Questionnaire; that this response was prepared by me or under my supervision and Direction; and that information provided in this Questionnaire is true to the best of my knowledge and belief. I am aware that any false statement made herein is punishable as a Class A misdemeanor pursuant to Section 210.45 of the Penal Law.





[NYSDEC CDD Questionnaire: 9/91]


New York State Department of Environmental Conservation

Regulated Medical Waste Incinerator Compliance Schedule worksheet for Owners Responding to a Compliance Determination Directive Issued with Respect to Incinerators Subject to 6 NYCRR subpart 219-3

Incinerator Owners Responding to the CDD Questionnaire Section 6 in the affirmative must submit this sheet as part of their Response. Proposed dates for incorporation into a consent order should reflect the incinerator owner's best judgement of dates that it will be able to meet. DEC has issued an Enforcement Guidance Memorandum which describes the consequences of operating an incinerator in violation of 6 NYCRR Subpart 219-3. Certain penalties may apply to the operation of the incinerator. This compliance Schedule Work Sheet will be reviewed by DEC staff and a Proposed settlement will be offered to those incinerator owners that meet the requirements set forth in the Enforcement Guidance Memorandum for a rapid program to come into full compliance with emission limitations. Use a separate worksheet for each incinerator.


Incinerator Owners should supply proposed dates for incorporation into an Order on Consent, as appropriate:

1. Date for submission of a complete application for a Permit to construct and acceptable protocol for air quality impact analysis: _______________.
(Allow four weeks for DEC approval protocol.)

2a. Date for submission of acceptable air quality impact analysis: _______________

2b. Date for submission of acceptable health risk assessment (if Necessary): _______________ (Allow at least ten weeks for DEC review and issuance of Permit to construct.)

3. Date for submission of the Certificate of Need (CON) application to Department of Health: _______________

4. Date for commencement of construction: _______________

5. Date for stack testing: _______________

6. Date for submittal of stack test results: _______________

7. Date for submission of revised health risk assessment (if Necessary): _______________

DEC will project a final compliance date, which is the issuance of a Certificate to Operate. Also, DEC will propose consent order milestone dates for payment of stipulated penalties for delayed compliance.

Name and Address of the Owner's Attorney:


Telephone Number: ____________________

Name and Title of Person Completing This Work Sheet:


Telephone Number: ______________________________

Facility Name for Which This Work Sheet is Submitted: ______________________________

INCINERATOR #: ______________________________

DATE: ____________________

[NYSDEC-9/91-CDD Attachment 2]


1. ECL §19-0306.1(c) defines "Regulated Medical Waste incineration Facility" as an incinerator which is operated or Utilized for the disposal or treatment of regulated medical waste (RMW), as defined in Title 15 of Article 27 of the ECL and which may utilize high temperature thermal destruction technologies, including combustion for recovery of thermal value.

2. DEC has announced its staff determination that the Carbon Monoxide standard should be revised from 150 ppm to 100 ppm In order to reflect BACT. Rulemaking efforts are expected to be completed by late 1991.

3. This document is exactly the same (verbatim) as 90-AIR-28A dated April 17, 1990.

4. Facilities incinerating radioactive materials may also be subject to review/permitting under 6 NYCRR Part 380.

5. DEC has data showing that costs for RMW incineration vary from 7 cents to 50 cents per pound of waste. The estimated annualized cost of existing non-complying Incinerators is approximately 15 cents per pound. The estimated cost for new incinerator systems with control systems meeting subpart 219-3 is approximately 20 to 30 cents per pound. Based on this data and DEC's enforcement discretion, the penalty structure established herein shall be utilized in Consent Orders leading to expeditious compliance. Costs for off-site shipment and handling of RMW range from 30 to 80 cents per pound of RMW for large generators. The Poundage Penalty Chart provided in Section III is not applicable to those who choose non-incinerator alternatives to compliance.

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