The study concluded that the average fines were substantially higher in areas with the highest proportion of white people than in areas with the highest proportion of minority-group people (506% higher in RCRA actions and 306% higher in actions based on violations of multiple laws). The method used by the study for designating white and minority-group communities has been criticized, and later studies, including several undertaken by EPA, have contradicted its findings (Kuehn 1994). EPA recognizes a need for more data with regard to the racial impact of its enforcement activities (Kuehn 1994). Environmental justice issues are discussed further in Chapter 7.

CONCLUSIONS AND RECOMMENDATIONS

Conclusions
  • MACT-based regulations vary for incinerators of municipal waste, hazardous waste, and medical waste. There are three to five CO standards, depending on the size, type, and age of municipal solid-waste incinerator. But that is not the case for hazardous-waste incinerators or medical-waste incinerators, which by their nature are at least as diverse in feedstock and combustor design as municipal solid-waste combustors. Within the municipal-waste incinerator rules and medical-waste incinerator rules, several types of emissions (e.g., lead, NOx, and dioxins and furans) are lessstringently controlled for facilities of specified size (generally smaller) and ages (generally older).

  • Workers at incineration facilities tend to be subject to greater risk than other people from exposure to pollutants from normal incinerator operations and from accidents and upset conditions. Ensuring worker safety requires effective coordination of enforcement activities between EPA and OSHA.

  • Assessment of both regulatory compliance and the efficacy of regulatory oversight are important to ensure that existing standards are being met in all cases and to satisfy citizens' needs for information concerning incinerator safety.

Recommendations
  • In future regulatory decision-making, greater consideration should be given to emission levels achieved in actual performance of incinerators, including process upset conditions. EPA should routinely seek out and use the best and most appropriate data including foreign plant-emission data, and other sources, as well as domestic data, in proposing new standards. In addition, any combustion, emission-control, and continuous emission-monitoring, telemetering and bill boarding technologies and



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