optimum operating practices used in foreign plants should be actively studied and considered for adoption in the United States. In order to give appropriate consideration to combustor and air-pollution control technology and operating techniques used in foreign countries, EPA should develop methods for characterizing the uncertainty of relevant information.

  • All regulated medical-waste incinerators and municipal solid-waste incinerators should have uniform limits for each pollutant, irrespective of plant size, design, age, or feedstock, as is the case for hazardous-waste incinerators. The same technology for air-pollution control is applicable to small and large facilities. Although there may be other legitimate reasons for doing so, allowing less-stringent limitations for some designs or sizes is inconsistent with the principle of minimizing risks of health effects.

  • Government agencies should encourage research, development, and demonstration of continuous emission monitors (CEMs), telemetering, bill boarding, and computer programs that automatically analyze, summarize, and report CEM data for all types of incineration facilities. In addition to the CEMs already required in the municipal solid-waste incinerator rules, requirement of HCl and particulate-matter CEMs should be considered on all municipal solid-waste incinerators. Also, as soon as a mercury monitor that measures both ionic and metallic forms of mercury emissions has been proven reliable, EPA should consider its use for domestic incinerators. The same approach should be used for other monitors, including those for other heavy metals and the dioxins and furans. EPA should also explore the utility of telemetering and bill boarding of CEM data to regulatory authorities and the public. Providing such data and data summaries on the Internet should be considered.

  • In monitoring for compliance, or other purposes, data generated during the intervals in which a facility is in startup, shutdown, and upset conditions should be included in the hourly emissions data recorded and published. It is during those times that the highest emissions are expected to occur, and omitting them systematically from monitoring data records does not allow for a full characterization of the actual emissions from an incineration facility.

  • Because operators need to be trained to handle new technologies and follow new requirements, periodic renewal of operator certification for all types of waste incineration should require retesting on new technologies, practices, and regulations. Both provisional and onsite certification should apply to all control room operators, because they can stand in for certified individuals for indeterminate periods of time.

  • Government agencies and incineration equipment manufacturers should continue to undertake research to determine how to optimize incineration facility performance for different types of incinerators and how to prevent and mitigate upsets. Detailed guidance should be provided based on



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