over 35 Mg/day adhere to good combustion practices, which include the following requirements:

  • The incinerator load level and the flue-gas temperature at the particulatematter control-device inlet must be measured and not exceed the levels demonstrated during the most-recent dioxin or furan performance test. EPA did not propose any specific flue-gas temperature requirement for either new or existing plants. Each incinerator is to establish a sitespecific maximal flue-gas temperature based on the maximal 4-hr block average temperature measured during the most-recent dioxin and furan compliance test. The incinerator must then be operated in such a way that the flue-gas temperature does not exceed that maximum by more than 17 °C (31°F).

  • The chief facility operator and shift supervisor must obtain provisional and then full operator certification from ASME, and a provisionally certified control-room operator may “stand in” for the chief facility operator or shift supervisor for an unspecified period.

  • All chief facility operators, shift supervisors, and control-room operators are required to complete an EPA or municipal solid-waste incinerator operator-training course. However, uniform course curricula or criteria are not specified in the law.

The rule requires control of flue-gas temperature and load level at the inlet of the particulate-matter control device. Flue-gas temperature at the inlet to the particulate-matter control device, activated-carbon and alkaline-reagent sorbent injection rates, waste-feed rates, and other characteristics are considered surrogates for continuous monitoring of mercury, HCl, and dioxins or furans; and EPA mandates measurement and monitoring of these pollutants under the standards and guidelines.

The CAA amendments of 1990 are being implemented to require the updating of antiquated technologies with more-modern control devices that are not, in the view of EPA, too expensive for both new and large old incinerators. For control of dioxins and furans and mercury, which are the types of the municipal solid-waste incinerator emissions that are most toxic and difficult to remove, and control of acid gases, such as SO2, NOx, and HCl, the MACT floors in both the NSPS and the guidelines for large plants are based on use of activated-carbon injection, spray-dryer absorbers with alkaline-reagent injection, fabric-filter particle-control devices, and selective noncatalytic reduction for NOx control.

Because of concerns about the bioaccumulation of mercury in the environment, EPA considers the incremental costs associated with adding activatedcarbon injection to control mercury emission reasonable for new and existing small plants, and it therefore requires the same mercury-emission standards for all municipal solid-waste incinerators—new and old, large and small. EPA con-



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