Environmental Engineering FOURTH EDITION

420 ENVIRONMENTALENGINEEFUNG

these sources of sulfur dioxide and nitrogen oxides. The 1990 regulations require SO2
emissions to be reduced by 9 million tons from the 1980 nationwide emission level,
and NO2 emissions to be reduced by 2 million tons from the 1980 levels.
Reductions are to be achieved at 111 key fossil fuel facilities in 21 states
encompassing the Ohio River Valley, New England and the northeast seaboard, the
Appalachian states, and the North Central states. The Clean Air Act (Section 404)
issues a regulated facility “allowances” for sulfur dioxide emissions. These allowances
may be freely used by the facility, transferred by sale to other polluters, or held for
future use. Allowances for the 111 facilities are based on historical operation data for
the calendar years 1985 through 1987. An annual auction of these transferable dis-
charge permits will be held, with anyone, including national and local environmental
organizations, able to bid.

Carbon Dioxide and Climate Change

Although the United States did not sign the Kyoto Accords, by which most of the
developed nations agreed to curtail C02 emissions, the United States recognizes the
need to limit such emissions and reduce atmospheric C02. No law or regulation has yet
been proposed. The signers of the Kyoto Accords have no regulations in place either
as of this writing.

PROBLEMS OF IMPLEMENTATION

Both regulatory agencies and the sources of pollution have encountered difficulties in

the implementation of air pollution abatement measures. Because most major stationary

sources of air pollution now have installed abatement equipment in response to fed-

eral pollution control requirements, regulatory agencies must develop programs that

promote continuing compliance. However, the track records of the agencies indicate

that current programs are not always effective.

Haws in design and construction of control equipment contribute to significant

noncompliance. Problems include the use of improper materials in constructing con-

trols, undersizing of controls, inadequate instrumentation of the control equipment, and

inaccessibility of control components for proper operation and maintenance. Design

flaws such as these cast doubt on how effectively the air pollution control agencies

evaluate the permit applications for these sources. Additionally, many permit review-

ers working in government lack the necessary practical experience to fully evaluate

proposed controls and tend to rely too heavily on the inadequate technical manuals

available to them.

A source permit, as it is typically designed within the regulatory framework, could

ensure that an emitter plans to install necessary control equipment. It could also require

the emitter to perform record-keeping functions that facilitate proper operation and

maintenance. However, agencies do not always use the permit program to accomplish

these objectives. For example, in some states, a majority of the sources fail to keep