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ENVIRON IMPACT ASSESS REV 1989;9:181-198 181

HUMAN HEALTH RISKS OF MUNICIPAL

SOLID WASTE INCINERATION

STEPHEN T. WASHBURN, JENNIFER BRAINARD,

AND ROBERT H. HARRIS

Recent estimates suggest that approximately 150-160 million tons of municipal

solid waste (MSW) are generated each year in the United States (O'Leary et al.
1988; USEPA 1987a, 1988a, 1989). The amount of MSW produced could ap-
proximately double to as much as 290 million tons by the year 2000 (USEPA
1987a). Based on 1980 U.S. Bureau of Census population projections (Johnson
1989), this amount would constitute approximately five pounds per day per
person. At the same time, the country's traditional means of disposal, land filling,
is becoming less and less feasible. Existing sites are closing, new sites are scarce,
and there is a widespread public perception that landfills represent unacceptable
risks to human health and the environment. Approximately 1200 of the country's
6000 MSW landfills are expected to close in the next five years (O'Leary et al.
1988). New York City has closed 14 of its 17 landfills in the past 20 years
(Inform Reports 1985). In response to the deepening MSW disposal crisis, the
USEPA has recommended a four-tiered integrated waste management strategy
involving source reduction, recycling, incineration, and land disposal (USEPA
1987a, 1988b, 1989).
Incineration of MSW offers several benefits, including a reduction in waste
volume by as much as 80% (USEPA 1987a) and an opportunity to convert heat
generated by the combustion process into electricity or steam. Despite these
advantages, however, concerns regarding the safety of MSW incinerators have
led to widespread and vocal opposition to the siting of these facilities. The
concerns have focused largely on the potentially toxic nature of stack emissions
from MSW incinerators. For example, in February 1985, the Swedish Environ-

The authors are affiliated with ENVIRON, Counsel in Health and Environmental Science, 210 Carnegie Center,
Suite 20t, Princeton, NJ 08540.

© 1989 Elsevier Science Publishing Co., Inc.

655 Avenue of the Americas, New York, NY 10010 0195-9255/89/$3.50
182 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

mental Protection Board declared a one-year moratorium on permitting new

MSW combustors in Sweden. This moratorium was established primarily as the
result of the potential health risks posed by stack emissions of polychlorodibenzo-
p-dioxins (PCDDs) and polychlorodibenzofurans (PCDFs) (Hershkowitz 1986).
In lieu of extending the moratorium beyond 1986, the Swedish government
established stringent guidelines to control MSW incinerator emissions (Repa
1986). Similarly, in January 1989, a bill was introduced in the New Jersey
legislature calling for a moratorium on new MSW incinerator permits, a com-
prehensive study of the potential impacts of statewide incinerator use, and an
analysis of potential waste management alternatives (Barr 1989).
The potential public health risks posed by ash residues from MSW incinerators
have also become a highly controversial issue. For over two years, a freighter
loaded with 14,000 tons of ash produced by an MSW incinerator in Philadelphia
traveled throughout the western hemisphere in search of a landfill for its cargo.
Landfills in the Bahamas, Puerto Rico, Antilles, the Dominican Republic, Ja-
maica, Panama, Honduras, Colombia, Guinea-Bissau, Cayman Islands, Haiti,
and Senegal rejected the ash, largely due to fears regarding its toxicity (Anderson
and Spear 1988).
The controversy surrounding MSW incineration is likely to intensify in light
of the anticipated growth of the industry. Approximately 111 MSW incinerators
with a total design capacity of 45,000 tons/day are currently operating in the
United States. The USEPA estimates that there will be at least 200 more MSW
combustors in the United States by the year 2000, representing roughly a four-
fold increase in total design capacity (USEPA 1987a). As more states and com-
munities begin to consider the option of incineration, more questions regarding
the potential risks of MSW incineration will be raised. In this article, a framework
for evaluating the public health risks posed by MSW incinerators is discussed.
This framework consists of three basic steps: (1) characterization of chemical
releases to the environment, (2) evaluation of pathways for human exposure to
these chemicals, and (3) estimation of potential human health effects.

Characterization of Chemical Releases to the Environment

Incinerator Stack Emissions
The identification of potentially hazardous chemicals in stack emissions is the
first step in assessing the potential public health risks posed by an MSW incin-
erator. Pollutants detected in the emissions can be evaluated with respect to
toxicity, persistence in the environment, and magnitude of release to determine
their potential to threaten human health. Care must be taken in weighing these
three characteristics. For example, 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-
TCDD), a chemical detected in MSW incinerator emissions, is usually present
in extremely small quantities, but is so toxic and environmentally persistent that
it is often the primary focus of concern.
HUMAN HEALTH RISKS OF MSW INCINERATION 183

Organic contaminants emitted from MSW incinerators may be either uncom-

busted residues of chemicals present in the feed, or compounds actually generated
during the combustion process. Although municipal solid waste is typically
considered "non-hazardous," it may actually contain many types of potentially
hazardous substances including cleaning agents, solvents, paints, oil and grease,
acids, bases, adhesives, pharmaceuticals, pesticides, herbicides, fertilizers, cos-
metics, alcohols, waxes, inks, and dyes (Puget Sound Council of Governments
1985). These and other substances that contain toxic organic chemicals are
frequently present in municipal waste streams received by MSW incinerators.
Since destruction of organics by incineration is never 100%, stack emissions
from MSW incinerators can contain uncombusted residues of these potentially
hazardous materials.
Organic compounds produced by the combustion process are known as prod-
ucts of incomplete combustion (PICs). These chemicals, which are often among
the most toxic pollutants present in stack emissions, are produced when partially
incinerated organic compounds rearrange or combine during combustion or in
the postcombustion zone of the incinerator. The most widely studied PICs are
PCDDs and PCDFs. Some forms of PCDD and PCDF are among the most highly
toxic compounds known to man, and have been found to bioaccumulate in
terrestrial animals (Firgerio 1978) and in fish (Stalling et al. 1983). Polynuclear
aromatic hydrocarbons (PAHs), such as benzo(a)pyrene (BaP), are also highly
toxic, highly persistent chemicals that can be formed during the incineration of
municipal solid waste (Environment Canada 1985; USEPA 1987d).
Stack emissions may also include toxic metals present in the MSW feed.
Metals such as cadmium, lead, and mercury are found in batteries, plastics, and
newsprint (USEPA 1987a). Other metals including silver, chromium, tin, and
zinc are frequently used in metallic surface coatings, galvanizing, and solders
(USEPA 1987a). Unlike organics, metals cannot be destroyed by incineration.
Some volatile metals, such as mercury, tend to volatilize during combustion,
and can be emitted as vapors from the incinerator stack. Bergstrom (1986), Vogg
et al. (1986), and Metzger and Braun (1987) indicate that over 80% of the
mercury in the MSW feed can be released as a vapor from the stack. Less volatile
metals, such as cadmium or chromium, are more likely to condense onto par-
ticulate matter in the postcombustion zone of an incinerator than to exist as
vapors (Klein et al. 1975; USEPA 1987b). Thus, stack emissions of the less
volatile metals are usually associated with particulates. In general, metal con-
centrations increase with particle size; as a result, the small, respirable-sized
particles tend to have the highest metal concentrations.
Some metals may exist in more than one form in incinerator stack emissions.
Distinguishing between these forms can be extremely important in assessing
public health risk. For example, hexavalent chromium is known to be a potent
human carcinogen, whereas trivalent chromium is not believed to cause cancer.
Recent stack testing data suggest that the majority of chromium emissions from
MSW incinerators are in the less toxic, trivalent form (see, for example, USEPA
184 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

1988c). The fraction of chromium that is in the hexavalent form is likely influ-
enced by design and operation, however, and may therefore vary from one
incinerator to another.
Several compounds generally referred to as acid gases, including hydrogen
chloride (HC1), hydrogen fluoride (HF), sulfur dioxide (SO2), and nitrogen oxides
(NOx), are also emitted by MSW incinerators. Although acid gases are emitted
from MSW incinerators in relatively large quantities, they are not believed to
be carcinogenic, and are generally less toxic and less environmentally persistent
than PICs and metals. In some cases, however, acid gas emissions can lead to
an overall degradation of air quality and may pose risks to the environment. For
example, EPA modeling suggests that hydrogen chloride emissions from MSW
incinerators may have the potential to cause materials damage, primarily due to
corrosion of ferrous metals (USEPA 1987e). The use of appropriate air pollution
controls can minimize this problem, however.
Federal regulation of MSW incinerator emissions is currently limited to par-
ticulates, acid gases, and a relatively few metals and organics (40 CFR 50,
51.160, 52.21, 60.50). Increasing efforts on the part of state agencies to limit
incinerator emissions, however, provide evidence that concerns regarding the
potential health risks posed by incinerator emissions are increasing. For example,
facilities in several states--including California, Connecticut, Maine, Massa-
chusetts, Michigan, New Jersey, New York, Oregon, and Pennsylvania--are
required to meet either stack emission limits or ambient limits for PCDDs and
PCDFs (Stanislaus County Air Pollution Control District 1986; Connecticut DEP
1988; Maine DEP 1987; Massachusetts DEQE 1985; Michigan DNR 1987; New
Jersey DEP 1986; New York DEC 1984; Oregon DEQ 1983; and Pennsylvania
DER 1987). For the Stanislaus Waste-to-Energy Facility in California, for ex-
ample, testing for PCDDs and PCDFs is required every three months for the
first year, and yearly thereafter (SCAPCD 1986).

Solid Ash Residue

Solid residues produced by MSW incineration can be classified as either fly ash,
the fine particulate matter collected from the boilers and air pollution control
system, or bottom ash, which is collected from the combustion grates. Bottom
ash generally constitutes 70-90% of the total volume of solid residue produced
by MSW incinerators (USEPA 1988b). The first step in evaluating the inherent
hazard of the solid residues is to determine the identity and quantity of specific
chemicals in fly ash and bottom ash.
Metals have traditionally been the focus of concerns regarding the potentially
toxic nature of incinerator ash. Data suggest that concentrations of the most
hazardous metals (e.g., cadmium, and lead) are likely to be greater in the fly
ash than in the bottom ash (USEPA 1987b). Organic compounds such as PAHs,
phthalates, chlorobenzenes, chlorophenols, polychlorinated biphenyls (PCBs),
HUMAN HEALTH RISKS OF MSW INCINERATION 185

PCDDs, and PCDFs have also been detected in ash residue. With the exception
of the PCBs, PCDDs, and PCDFs, the levels of organics are generally higher
in the bottom ash than in the fly ash (USEPA 1987b).
The mobility of chemicals in ash must be evaluated to determine the inherent
hazard of incinerator residues. Several leaching tests are currently being em-
ployed to determine the mobility of chemicals in MSW incinerator ash. These
procedures include: (1) the Extraction Procedure (EP) toxicity test; (2) the Tox-
icity Characteristic Leaching Procedure (TCLP); (3) the Waste Extraction Test
(WET); and (4) the Monofill Waste Extraction Procedure (MWEP). In each of
these tests a sample of incinerator ash is subjected to an extraction fluid to
simulate potential leachate quality. This simulated leachate is then analyzed to
determine the concentrations of specific chemicals.
The various leaching procedures differ according to sample preparation, the
extraction fluid employed, the pH maintained in the extraction vessel, the ex-
traction time, and the scope of the chemical analysis. The EP toxicity test, which
involves the analysis of only metals and pesticides, is currently the method most
widely used by regulatory agencies in the United States. The TCLP and WET
tests are more recently developed procedures, and include the analysis of an
extended list of organic contaminants. The TCLP is being considered as a re-
placement for the EP test by the USEPA (51 FR 21618), while the WET test is
used exclusively by the State of California. The MWEP is designed to estimate
the concentration of contaminants in monofill leachate (i.e., leachate from land-
fills receiving only one type of waste) but currently has no regulatory significance
(USEPA 1987b, 1987c).
In the United States, it is standard practice for MSW incinerator ash to be
analyzed using the EP toxicity test to determine the leaching potential of metals.
If chemical concentrations in the leachate simulated by the EP toxicity test exceed
predetermined criteria based on Federal Drinking Water Standards, the ash is
classified as "EP toxic." Data collected to date indicate that the combined fly
ash and bottom ash residues from MSW incinerators often exceed the EP toxicity
test criteria for lead and/or cadmium (New York DEC 1987). When tested by
itself, fly ash almost always fails the EP toxicity test, exceeding the criteria for
at least one of these two metals (New York DEC 1987; Knudson 1986; USEPA
1988c). Thus, much of the ash currently produced by MSW incinerators would
be classified as "EP toxic," and may therefore be subject to more stringent
disposal requirements than nonhazardous waste in some states.
As defined in the Code of Federal Regulations, a solid waste displaying one
of several characteristics, including EP toxicity, is considered "hazardous" (40
CFR 261). Thus, it might seem logical to assume that MSW incinerator ash
exhibiting the characteristics of EP toxicity is hazardous, and should be managed
pursuant to existing hazardous waste regulations. A critical issue in the MSW
incinerator ash debate, however, is whether ash from facilities that recover energy
falls under the USEPA "household waste exclusion" (RCRA Section 30010);
186 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

40 CFR 261.4(b)(1)). While the statute and subsequent regulations indicate that
incinerators that recover energy and accept only household waste or nonhazardous
commercial/industrial waste are exempt from RCRA Subtitle C (USEPA 1988b),
it is not clear whether the USEPA will interpret this exclusion to include ash
generated from these incinerators. The household waste exclusion does not di-
rectly address incinerators that do not recover energy. Thus, ash from nonenergy
recovery incinerators appears to be subject to RCRA Subtitle C; i.e., this ash
would have to be tested to determine whether it is hazardous, and then managed
accordingly.
As previously discussed, the EP toxicity test includes the analysis of only a
limited number of organic compounds. Since the EP test is the most commonly
used procedure for evaluating MSW incinerator ash, data on other hazardous
organics, such as PCDD and PCDF, are scarce. As evidence that concerns
regarding the potential impacts of organics in ash residues are increasing, states
such as California, Maine, Massachusetts, and New Jersey require testing for
PCDDs and PCDFs in the leachate from MSW incinerator ash (CAC Title 22,
Division 4, Article 11; California DHS 1984, 1985, 1986; California DER 1986;
Maine DEP 1986a, 1986b; Massachusetts DEQE 1986, 1988; New Jersey DEP
1985, 1987). Incinerator ash from the Commerce Waste-to-Energy Facility in
California, for example, must be analyzed using the WET every month for the
first six months, and then annually thereafter (California DHS 1984).

Evaluation of Pathways for Human Exposure,

Identification of Critical Exposure Pathways
Human exposure to contaminants in stack emissions or ash residue can occur
through a variety of pathways. Some of these pathways are relatively direct; for
example, inhalation exposure to incinerator emissions involves only one envi-
ronmental medium, the air. Contaminants are emitted into the air, and then are
dispersed as they travel downwind to a point where they are directly inhaled.
Many potential pathways of exposure are far more complex than inhalation,
however, and involve several environmental media. These pathways are some-
times classified as "indirect." As shown in Figure 1, examples of indirect ex-
posure to incinerator air emissions include the ingestion of surface water, meat,
milk, and agricultural crops, the incidental ingestion of soil, and dermal contact
with soil. Although the most important potential exposure pathway for landfilled
incinerator ash is usually the ingestion of contaminated ground water, indirect
pathways such as the consumption of meat, milk and plants may also be appli-
cable in some cases (Figure 2).
The type of environment surrounding an incineration facility must be taken
into account when identifying potentially significant pathways of human exposure
to stack emissions. While direct inhalation is always a pathway of concern,
HUMAN HEALTH RISKS OF MSW INCINERATION 187

Human
Exposure
Pathways

Atmospheric Emissions

~ ~ e p ootno aSoil,iWater,
t and
i Vegetalion,~
o n ~.
--.-]
~**lt I

Contaminationof Contamination of
Contaminationof Fish CropsThcough LivestockTh0"ough L: ~::"J
ThroughDwectExposure RootUptake, Inhalation,and
to Water Direct Deposition, Ingestionof Soil,
and FotiarUptake Water, and
Vegetation

F I G U R E 1. Examples of potential human exposure to atmospheric emissions.

Source: ENVIRON, Counsel in Health and Environmental Science

I Exposure
I Pathways
I
I

I
Crops& I
Landfill ~,..stock ',I~"l
I
"'.';.:" ;3""".~'.": ~ Ash Residue"£:2;-;"T;'*'2~:""
Water Well
Well
'l-"f--
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GroundWater I
.4

F I G U R E 2. Examples of potential human exposure to chemicals in ash residue.

Source." ENVIRON: Counsel in Health and Environmental Science
188 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

ingestion of milk or beef may not be important if a facility is sited in a non-

agricultural area. The relative importance of indirect pathways, when applicable,
is currently a matter of considerable debate. For example, some researchers have
suggested that exposures to 2,3,7,8-TCDD can be about 200 times greater through
ingestion of cow's milk than through direct inhalation (Connett and Webster
1986). Others believe that, for properly designed incinerators, there is little
difference between the 2,3,7,8-TCDD exposures received via inhalation and via
ingestion of cow's milk (Miller et al. 1987). Furthermore, additional indirect
pathways of exposure, such as the ingestion of mother's milk by infants, may
prove to be critical as more information becomes available. Smith (1987) suggests
that an infant breast-fed for one year would receive about 10% of the cumulative
dose per unit body weight received by an adult exposed through other pathways
for a full 50 years.

Estimation of Chemical Concentration in the Environment

Several approaches can be used to estimate chemical concentrations in environ-
mental media that are important for the exposure pathways of concern. Ideally,
the background level of critical pollutants would be measured in all relevant
media prior to the operation of an MSW incinerator, and again periodically after
the facility begins combustion. In this way, the relative contribution of the
incinerator could be measured directly to assess the incremental health risks
posed by facility operations.
Ambient measurements have been used on occasion to evaluate the significance
of MSW incinerator emissions. For example, in 1986, soil samples in the area
surrounding an MSW incinerator near Florence, Italy were collected and analyzed
for PCDD and PCDF. The levels of PCDD and PCDF detected were judged by
local health authorities to be sufficiently high to force the shutdown of the
incinerator, and to prohibit the consumption of locally grown produce (Berlin-
cioni and di Domenico 1987).
In many situations, however, it is not feasible to measure directly the impact
of incinerator operations through sampling and analysis of environmental media.
For example, the predictive assessment of potential health risks is often required
during the MSW incinerator siting process, when it is clearly not possible to
measure environmental concentrations resulting from facility emissions. Fur-
thermore, for certain chemicals, such as for 2,3,7,8-TCDD, concentrations of
concern in some media may be below normal detection limits. It may also be
difficult to identify the source of contamination in nonpristine areas. Thus, it is
often necessary to use mathematical models to predict potential concentrations
of chemicals in the environment, and to evaluate the extent of potential human
exposure.
The uncertainty involved in modeling chemical concentrations in the envi-
ronment can be significant, especially when evaluating indirect pathways. When
HUMAN HEALTH RISKS OF MSW INCINERATION 189

assessing the risks posed by direct inhalation, it is necessary to predict chemical

concentrations only in air. These concentrations can he estimated with relative
accuracy using EPA-approved air dispersion models such as the Industrial Source
Complex (ISC) model, information on facility design and operation, and data
on local meteorology and topography. On the other hand, evaluation of exposure
via ingestion of cow's milk, for example, requires not only the estimation of
chemical concentrations in air, but various additional data as well, including:

• The rate of contaminant deposition from air onto the soil and onto sources
of feed and water for livestock;
• The depth of contaminant mixing in soil;
• The persistence of contaminants in soil, vegetation, and water;
• The extent of contaminant uptake by vegetation from soil and air;
• The amount of potentially contaminated soil, fodder, and water ingested by
a cow in the vicinity of the facility; and
• The extent to which contaminants ingested by a cow accumulate in cow's
milk.

Clearly, far more data and assumptions are necessary to predict chemical
concentrations in cow's milk than in air. As a direct result of these additional
assumptions, there is considerably more uncertainty associated with the predic-
tion of chemical concentrations in cow's milk than in the prediction of corre-
sponding concentrations in air.
In general, relatively little work has been conducted to predict ground water
concentrations for contaminants present in landfilled MSW incinerator ash. In-
stead, the hazards posed by ash in landfills have been judged solely on the basis
of leaching tests, such as the EP toxicity test. As concerns regarding ash disposal
increase, however, it is likely that a more concerted effort will be made to predict
chemical concentrations that could be present in ground water as a result of
MSW ash disposal.

Estimation of Potential Human Health Effects

Estimation of Human Dose
To assess the potential human health effects associated with incinerator opera-
tions, it is first necessary to estimate the level of exposure to the chemicals in
the environment. Estimating the magnitude of the human dose based on con-
taminant concentrations in the environment may require the application of several
assumptions with regard to (1) body weight, (2) respiration rate, (3) rate of
consumption of food and water, (4) rate of incidental soil ingestion, and (5)
extent of dermal absorption. Examples of the generic assumptions utilized in
190 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

TABLE 1. Generic Assumptions Used in Estimating Human Dose for the Average
Adult a
Body weight 70 kg (USEPA 1986a)
Breathing weight 20 m3/d (USEPA 1986a)
Water consumption 2 1/d (USEPA 1986a)
Beef consumption 72 g/d (USDA 1983
Pork consumption 28 g/d (USDA 1983
Poultry consumption 30 g/d (USDA 1983
Fish consumption (total) b 20 g/d (USDA 1984
(estuarine and freshwater) c 6.5 g/d (USEPA 1980
Egg consumption 36 g/d (USDA 1983
Milk consumption 218 g/d (USDA 1983
Vegetable consumption 250 g/d (USDA 1983
Incidental soil
ingestion 0.02 g/d (USEPA 1986c)
aAll values correspond to an average adult male.
bValue corresponds to average consumption of marine, estuarine, and freshwater fish and shellfish.
CValue corresponds to average consumption of estuarine and freshwater fish and shellfish.

estimating the average dose for adults are outlined in Table 1; corresponding
assumptions can also be made to examine exposures of children.
In many cases, assumptions that tend to overestimate the average level of
exposure are used to evaluate the potential risk. For example, it is typical to
assume that exposures occur continuously during the entire life of the facility,
or, in some cases, a projected 70-year life span of the potentially exposed
individual. This approach, while tending to overestimate the average public
health risk in many cases, minimizes the possibility that risks are underestimated
for highly exposed individuals.

Carcinogenic Health Effects

Chemicals which induce the formation of tumors (either benign or malignant)
are generally known as carcinogens, although the term carcinogen literally means
"cancer-causing" substance. The process of carcinogenesis is typically thought
to involve a number of stages including initiation and promotion. Different
chemicals appear to affect different stages of the carcinogenic process. Complete
carcinogens are those substances capable of both initiation and promotion:
Benzo(a)pyrene (BaP) is an example of a complete carcinogen. Chemicals ca-
pable of initiating cancer by altering the genetic material of a cell are referred
to as initiators, while substances that increase the incidence of tumors only when
exposure occurs after initiation are called promoters. Numerous carcinogens,
including BaP, 2,3,7,8-TCDD, hexavalent chromium, and cadmium, have been
detected in MSW stack emissions and ash residue. It is generally thought that
HUMAN HEALTH RISKS OF MSW INCINERATION 191

there is a cancer risk associated with any level of exposure to a carcinogen, i.e.,
that there is no threshold of exposure below which the probability of developing
cancer is zero. As a result, it is necessary to estimate the risk associated with
all finite exposure levels.
The cancer potency factor, which is an upper 95% confidence limit on the
probability of developing cancer per unit intake, is usually used to convert
measured (or predicted) chemical intakes directly into estimates of the probability
of developing cancer (USEPA 1986a). For the purpose of assessing overall cancer
risk from exposure to a mixture of carcinogens, the cancer probabilities calculated
for individual chemicals in the mixture are usually considered additive. In as-
suming overall additivity, it is also assumed that no synergism or antagonism
exists between chemicals and that carcinogenic risks from different exposure
routes are additive (USEPA 1986a).
It should be noted that some scientists and regulatory bodies believe that the
no-threshold model is not appropriate for all carcinogens. For example, the
Ontario Ministry of the Environment (OMOE) supports the use of a threshold
model for evaluating the carcinogenic risk of 2,3,7,8-TCDD, asserting that a
virtually safe level of exposure can be determined, and that risks below this
level are essentially zero (OMOE 1985). The process of cancer initiation is
believed to be associated with the induction of mutation, or a heritable change
in the structure or sequence of the DNA, and is believed to be a no-threshold
phenomenon. However, the results of experimental studies suggest that 2,3,7,8-
TCDD does not appear capable of inducing mutations or initiating cancer, but
instead acts as a cancer promoter. OMOE and others believe that promotion can
be modeled as a threshold phenomenon.
Using a no-threshold model, the USEPA has estimated that the maximum
individual cancer risk posed by inhalation exposure to existing MSW incinerator
emissions is approximately 1 in 1000 to 1 in 1,000,000 (USEPA 1987e). In
other words, the maximally exposed individual was predicted by the USEPA to
have a chance of approximately 1 in 1000 to 1 in 1,000,000 of developing cancer
as a result of exposure to MSW incinerator emissions. The USEPA results
indicate that exposure to emissions from "nonheat recovery" mass-burn facilities
poses the highest cancer risk for existing MSW incinerators. Assuming improve-
ments in incinerator technology and air pollution control, the USEPA believes
the high end of this range (i.e., 1 in 1000) will decrease to below 1 in 10,000
for new facilities. For both existing and projected emissions, the USEPA data
also suggest that the highest cancer risk posed by MSW incineration is associated
with exposure to TCDD and TCDF.
It is important to note that the high end of the estimated range for existing
conditions exceeds the 1 in 10,000 risk benchmark often considered by the
USEPA to be unacceptable (USEPA 1986b), even though these estimates reflect
risks posed only by direct inhalation. As previously noted, other exposure path-
192 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

ways may be more important than direct inhalation when assessing potential
human health risks. However, the USEPA's estimates of cancer risk associated
with MSW incinerator emissions have been questioned by some scientists. Jones
and Walsh (1988), for example, criticize the USEPA, citing "inappropriate" use
of dioxin emission data and dioxin analysis recovery information.

Noncarcinogenic Health Effects

Chronic noncarcinogenic health effects appear to have a threshold dose below
which the effect will not occur. Such noncarcinogenic effects include liver dys-
function, central nervous system disorders, and adverse reproductive effects.
The chronic exposure threshold for noncarcinogens is usually expressed in terms
of a Reference Dose (RfD) or an Acceptable Daily Intake (ADI). The ratio of
the actual (or predicted) dose to the ADI or RfD is commonly known as the
Hazard Index (HI): If the HI value is less than 1.0, then the safe threshold is
not exceeded, and adverse effects are not expected as a result of the chemical
exposure.
Exposures to MSW incinerator emissions may involve a complex mixture
of noncarcinogens. The cumulative effect of exposures to such mixtures is often
initially assessed by assuming that the chronic noncarcinogenic effects can be
considered additive (USEPA 1986b). In other words, the individual HI values
for all chemicals to which exposure occurs are added to provide a cumulative
HI. If the cumulative HI is less than 1.0, noncarcinogenic effects would not
be expected from exposure to the mixture. In instances where the assumption
of overall additivity suggests that the general population may be at risk, the
USEPA recommends considering the noncarcinogenic risk of each adverse ef-
fect separately (USEPA 1986a). Further refinement may be possible by more
closely examining the individual mechanisms of action for the chemicals in
the mixture to determine how best to assess the cumulative effect. While this
latter approach may be the most scientifically sound, it is often not feasible
given the paucity of data regarding the mechanisms of toxicity for many con-
taminants. In addition, such a detailed evaluation may not be required if sig-
nificant health risks are not predicted assuming overall additivity.
The USEPA has indicated that ingestion exposures to deposited lead and
mercury emissions from MSW incinerators may in some circumstances con-
tribute appreciably to total environmental exposures to these chemicals (USEPA
1987e). However, most assessments that have been conducted to date indicate
that the noncarcinogenic risks posed by MSW incineration are not likely to be
significant (see, for example, HDR Techserv 1987; Weston 1987). Thus, most
of the concerns regarding MSW incinerator emissions have focused on poten-
tial cancer risks rather than on the possibility of other types of adverse health
effects.
HUMAN HEALTH RISKS OF MSW INCINERATION 193

Summary and Discussion

MSW incineration has become a highly controversial and emotional issue in the
United States. Its proponents argue that it can be a safe, economical, and effective
means of alleviating the MSW disposal crisis facing this country. Detractors
claim that it poses unacceptable risks to human health and the environment, and
reduces the opportunities for recycling and waste minimization. The USEPA
currently plans to rely heavily on MSW incineration. Over 310 facilities with a
total capacity exceeding 200,000 tons/day are predicted to be operating in the
United States by the year 2000 (USEPA 1987a). A shift away from MSW
incineration, for whatever reason, would force the United States to place a greater
reliance on other waste management methods such as source reduction, recycling,
and landfilling, and to reevaluate its long-term waste management strategy. While
the USEPA has already ranked source reduction and recycling above incineration
in its waste management hierarchy, the ability of these methods to address the
waste disposal crisis in the short-term is not clear.
The most critical factor in evaluating the acceptability of MSW incineration
is clearly public health risk. Both incinerator stack emissions and incinerator ash
have been shown to be contaminated by a variety of toxic chemicals, including
metals such as lead and chromium, and organics such as 2,3,7,8-TCDD. The
simple presence of these metals in stack emissions and ash does not imply that
MSW incinerators are unsafe, however. To assess objectively the public health
risks posed by incineration, the expected level of exposure to the chemicals of
greatest concern must first be estimated. Once the magnitude of the exposure is
known, the probability that a given adverse health effect will occur can be
predicted.
An objective evaluation of the risks posed by MSW incineration, however,
requires a great deal of data to estimate exposures and to evaluate chemical
toxicity. The reliability of a risk assessment is clearly dependent upon the avail-
ability and quality of these data. Unfortunately, although data have improved
over the past decade, considerable uncertainties still exist. Sources of uncertainty
include:

• The lack of long-term emissions data for MSW incinerators. Most available
data are from test burns conducted during the first few weeks of facility
operation. Little, if any, data have been collected to evaluate long-term
emissions or releases that occur during accidents or process upsets.
• The lack of ambient monitoring data for MSW incinerators. Such data could
be used to validate fate and transport models currently being used to predict
chemical concentrations in the environment.
• Limited toxicity data for some of the chemicals of greatest concern. For
example, many assessments suggest that the greatest potential cancer risks
194 S.T. WASHBURN, J. BRAINARD, AND R.H. HARRIS

posed by MSW incinerators result from exposures to PCDD and PCDF. At

the current time, however, the only data available regarding the carcinogenic
potency of these chemicals are derived from high-dose laboratory animal
experiments. These data must be extrapolated to examine low-dose, human
cancer risk.

Other sources of uncertainty also exist. These uncertainties must be acknowl-

edged and carefully considered in interpreting the results of any MSW incinerator
risk assessment.
A recognition of the risks posed by MSW incineration have already begun to
impact the design and operation of proposed facilities. For example, the current
trend toward dry scrubber/baghouse pollution control systems stems largely from
efforts to control stack emissions of PCDD and PCDF. Other advances in design
and operation, including improved methods for regulating combustion condi-
tions, and processing MSW feed prior to incineration, are also being made to
reduce public health risks. Furthermore, the USEPA has established an objective
of reducing the risks of MSW incineration by upgrading incinerator performance
standards and risk management regulations (USEPA 1989). Along with these
types of advances in incinerator technology and regulatory guidance, however,
there is also a need to refine our understanding of the risks posed by MSW
incineration, and to develop more sophisticated methods for their estimation.

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