erators on metropolitan or regional scales are largely unknown, it is uncertain whether implementation of MACT standards for incinerators will substantially reduce the actual risks posed by persistent environmental pollutants at those scales.

Based on estimates of incinerator emissions, environmental transport and fate, potential total exposure, and relative toxicity of the individual substances inferred from studies not involving incineration, the committee concludes

  • Compliance with MACT regulations is expected to reduce substantially local population exposures, especially for particulate matter, lead, mercury and other metals, acidic gases, and acidic aerosols.

  • Substantial concerns about regional dioxin and furan exposures and moderate concerns about regional exposures to metals are not expected to be relieved by MACT regulations, because the regulations may not adequately reduce risks attributable to cumulative emissions on a regional basis.

  • Substantial concerns about workers' exposures to particulate matter, lead, mercury, and dioxins and furans are not expected to be relieved by MACT compliance, because those regulations were not designed to affect workers' exposures.

Recommendations
  • Technologies used in other countries for combustion, emission control, continuous emission monitoring, and public dissemination of information, as well as optimum operating practices, should be actively studied and considered for adoption in the United States.

  • All regulated medical-waste incinerators and municipal solid-waste combustors should have uniform limits for each pollutant, irrespective of plant size, design, age, or feedstock, as is the case for hazardous-waste combustors. The same technology for air-pollution control is applicable to small and large facilities. 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), dissemination technologies, and computer programs that automatically analyze, summarize, and report CEM data. In addition to the CEMs already required in municipal solid waste incinerator rules, requirement of CEMs for hydrochloric acid and particulate-matter should be considered on such incinerators. Also, as soon as a mercury monitor that measures 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



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