(RCRA) consider combustion and other operations, including the handling of wastes coming into the facility and leaving it. RCRA inspections accordingly will cover personnel training, waste storage, and ash disposal.

A principal goal of an inspection is to determine whether a facility is operating in conformity with the applicable permits or certificates. Logs, strip charts, and data from continuous emission-monitoring systems (CEMS) are important sources of data regarding emissions and cases in which they exceed limits. Data from strip charts and CEMS are particularly reliable because they appear not to be subject to alteration or fraud. CEMS do not exist for all important toxicants though EPA does not require use of all CEMS that are commercially available. The operating conditions set during trial burns are used as surrogate measures of some emissions of substances for which CEMS are not required or for which continuous-monitoring technology has not yet been developed and validated. If the surrogate measures are within compliance ranges, it is assumed that the unmeasured substances are also within compliance ranges. Modems connected to CEMS make it possible for regulators to obtain contemporaneous data on a facility 's operations. Such an approach would allow regulators to quickly know about process upsets or bypassing of emission control devices due to emergencies or equipment malfunctions. In Pennsylvania, data from CEMS sent directly and contemporaneously to regulators are used to produce computer-generated records of conditions that exceed limits and the resulting fines that are assessed against a facility, although extenuating circumstances might be the basis for a reduction in fines (Francine Carlini, Air Quality Inspector, Pennsylvania EPA, pers. commun., Nov. 1995). Continuous emission monitoring need not necessarily foreclose the exercise of regulatory discretion. For example, data revealing limit violations that do not appear to be caused by identifiable engineering problems or by technical conditions that can be fixed might not trigger enforcement action (James Topsale, U.S. EPA Region III, pers. commun., Oct. 31, 1995).

Although continuous emission and process monitoring will be required for some pollutants on some incinerators as a result of the CAA, a municipal-waste incinerator will be allowed to exclude data from 25% of its daily operating time and from 10% of the calendar days per quarter when the plant is operating. Furthermore, the proposed standards and guidelines do not indicate which data may or may not be excluded. Separate from the allowable exclusions mentioned above, emissions during startup, shutdown, and upsets are specifically excluded from consideration with respect to compliance. These data exclusions seem to confirm citizen complaints that they do not have access to a full picture of the safety of incinerators.

The timing and frequency of inspections are matters of some criticism by environmentalists. Some jurisdictions conduct inspections without advance notice to the operator; others do not. Environmental activists are concerned that advance notice of an inspection allows an operator to clean up a facility, remove



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