Fundamentals of Successful Monitoring,Reporting, and Verification under a Cap-and-Trade Program

Abstract

The U.S. Environmental Protection Agency (EPA) developed and implemented the Acid Rain Program (ARP), and NO_x Budget Trading Programs (NBTP) using several fundamental monitoring, reporting, and verification (MRV) elements: (1) compliance assurance through incentives and automatic penalties; (2) strong quality assurance (QA); (3) collaborative approach with a petition process; (4) standardized electronic reporting; (5) compliance flexibility for low-emitting sources; (6) complete emissions data record required; (7) centralized administration; (8) level playing field; (9) publicly available data; (10) performance-based approach; and (11) reducing conflicts of interest. Each of these elements is discussed in the context of the authors’ experience under two U.S. cap-and-trade programs and their potential application to other capand-trade programs.

The U.S. Office of Management and Budget found that the Acid Rain Program has accounted for the largest quantified human health benefits of any federal regulatory program implemented in the last 10 yr, with annual benefits exceeding costs by >40 to 1. The authors believe that the elements described in this paper greatly contributed to this success. EPA has used the ARP fundamental elements as a model for other cap-and-trade programs, including the NBTP, which went into effect in 2003, and the recently published Clean Air Interstate Rule and Clean Air Mercury Rule. The authors believe that using these fundamental elements to develop and implement the MRV portion of their cap-and-trade programs has resulted in public confidence in the programs, highly accurate and complete emissions data, and a high compliance rate (>99% overall).     

Performance/Cost Estimates for Retrofitting Control Technologies

The U.S. EPA’s Air and Energy Engineering Research Laboratory is responsible for assessing control technology performance and costs under the National Acid Precipitation Assessment Program. A major part of this assessment involves developing site-specific estimates of the performance and costs of retrofitting SO₂ and NO_x control technologies for the top 200 SO₂- emitting (1980) coal-fired power plants in the 31-state eastern region. This effort includes detailed evaluation of a small number of plants (30 or less) representing a cross-section of the top 200 population. In cooperation with the states of Ohio and Kentucky (in conjunction with the U.S. EPA’s State Acid Rain Grant Program), efforts were undertaken to visit and conduct detailed evaluation of 12 coal-fired plants—five in Ohio, seven in Kentucky and the Tennessee Valley Authority System. A variety of commercial and advanced SO₂ and NO_x control technologies—including precombustion, combustion (in-furnace), and postcombustion (flue gas cleanup) technologies—were applied to each plant through conceptual designs. Retrofit factors (applied to the capital cost of a new pollution control system), cost “adders” (e.g., movement of existing equipment), and costs were developed for applying the control technologies to the boilers of each plant. Results of these and subsequent efforts will be valuable in evaluations of acid deposition control strategies by federal and state agencies and by electric utilities.     

Mercury Measurement and Its Control: What We Know,Have Learned,and Need to Further Investigate

ABSTRACT

Based on the available evidence of health effects, the U.S. Environmental Protection Agency (EPA) has been evaluating the need to regulate mercury releases to the environment. In response to the congressional mandates in The 1990 Clean Air Act Amendments (CAAA), the EPA has issued the Mercury Study Report and the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units Report. In spite of the enormous effort represented by these reports, as well as the efforts of both the U.S. Department of Energy (DOE) and the Electric Power Research Institute (EPRI), in conducting the field measurement programs that form the basis for these reports, a definitive answer on the need for mercury regulation has not been found. However, the EPA, as well as other regulatory agencies and health researchers, have suggested a "plausible link" between anthropogenic sources emitting mercury and the methylation, bioaccumulation in the food chain, and adverse health effects in humans and wildlife.     

EPA’s Clean Air Act Operating Permit Rules

Title V of the Clean Air Act requires tens of thousands of air pollution sources to obtain an operating permit incorporating all applicable requirements under the Act. EPA recently promulgated its controversial Title V regulations, which establish the minimum elements for state permit programs.

The new permit system is among the most important changes made by the 1990 Clean Air Act Amendments, and will significantly alter the way companies comply with air pollution requirements. Previously, the Act only required certain sources to obtain a new source review permit before constructing or modifying the facility (although many states established operating permit systems on their own). Now, all states must adopt operating permit programs consistent with the minimum federal requirements, and submit them to EPA by November 1993. Even though EPA has established minimum requirements, these programs are likely to vary widely from state to state.     

Federal Regulations for New Source Performance Standards

Section 111 of the Clean Air Act Amendments of 1970 authorizes the U.S. Environmental Protection Agency (EPA) to impose emission standards (NSPS) on those stationary sources that are determined to be significant contributors to air pollution and that consequently endanger the public health or welfare. In five years EPA promulgated 19 final and 1 proposed NSPS for stationary sources. Section 112 of the Act authorizes EPA to promulgate national emission standards for hazardous air pollutants (NESHAPS). EPA promulgated three final and 1 proposed regulation under Section 112. In addition, EPA promulgated NSPS for three "designated" pollutants from specific sources under Section Hid. EPA’s use of Section 111 and 112 authority provides for a quick response emission control program compared to the relatively slow process of establishing additional ambient air quality standards and having the states adopt implementation plans (Section 109). Three court cases, argued in the U.S. Court of Appeals for the District of Columbia, established basic guidelines for future promulgation of NSPS although certain legal actions are still pending. Proposed amendments to the Clean Air Act would further broaden and strengthen EPA’s direct regulatory authority.     

Air Quality: Status,Management and Direction

The Tenth Government Affairs Seminar conducted by the Air Pollution Control Association was held in Washington, D.C. on March 17–18, 1982. The APCA Government Affairs Committee of which John S. Lagarias is Chairman, sponsored this meeting. Dr. Jerry Pell was General Chairman of the Seminar Steering Committee which included in its membership: Gordon M. Rapier, Vice-chairman, William K. Bonta, Facilities Chairman, Barbara Bankoff, David Benforado, D. Kent Berry, Samuel Booras, William Chapman, Stanley Coloff, Philip T. Cummings, Roy S. Denham, Gerald P. Dodson, Daniel Dreyfus, Raymond W. Durante, Victor S. Engleman, Richard Grundy, W. G. Hamlin, Glenn Hanson, G. Steve Hart, Terrence Li Puma, Michael Lukey, John E. Maroney, William Megonnell, Curtis A. Moore, Russell Mosher, Joseph Mullan, Sidney R. Orem, Dennis G. Seipp, Martin L. Smith, Roger Strelow, Michael Tinkleman, Neal Troy.

This meeting served as a forum for discussion of the issues of: the Clean Air Act amendments, regulatory reform, international perspectives on acid rain, and new directions pursued by the U.S. Environmental Protection Agency.

Representative Henry A. Waxman, Chairman, Subcomittee on Health and the Environment, Committee on Energy and Commerce, U.S. House of Representatives, was the keynote speaker. The Honorable C. Boyden Gray, Counsel to the Vice President of the United States was the luncheon speaker on Wednesday. Daniel J. Goodwin, President, State and Territorial Air Pollution Program Administrators, was the luncheon speaker on Thursday.

Session 1. entitled “The Clean Air Act: Legislative Status,” was moderated by G. Steve Hart, President of APCA. Session 2. “Regulatory Reform,” was chaired by Richard N. Holwill, Vice President for Government Information, The Heritage Foundation. The Honorable A. Alan Hill, and Gordon Snow, from the President’s Council on Environmental Quality were co-moderators for Session 3. which was entitled, “Acid Rain: International Perspectives.” Session 4. “Critical Issues,” was moderated by Walter C. Barber, Jr., Director, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency.

Condensed versions of the remarks of the participants are presented here. A more extensive summary of the meeting which includes floor discussion is available in the Proceedings of the Tenth APCA Government Seminar which can be obtained from APCA headquarters.     

Mercury Measurement and Its Control: What We Know,Have Learned,and Need to Further Investigate

ABSTRACT

Based on the available evidence of health effects, the U.S. Environmental Protection Agency (EPA) has been evaluating the need to regulate mercury releases to the environment. In response to the congressional mandates in The 1990 Clean Air Act Amendments (CAAA), the EPA has issued the Mercury Study Report and the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units Report. In spite of the enormous effort represented by these reports, as well as the efforts of both the U.S. Department of Energy (DOE) and the Electric Power Research Institute (EPRI), in conducting the field measurement programs that form the basis for these reports, a definitive answer on the need for mercury regulation has not been found. However, the EPA, as well as other regulatory agencies and health researchers, have suggested a “plausible link” between anthropogenic sources emitting mercury and the methylation, bioaccumulation in the food chain, and adverse health effects in humans and wildlife.

Policy-makers have recognized that regulations must be based on good science and that a number of issues still remain. These issues can generally be grouped into four main categories: emissions inventory, control technology, fate of releases, and health effects. This paper will discuss recent, ongoing, and planned studies to address the remaining issues regarding the presence of mercury in the environment, with an emphasis on those studies that are directly related to the DOE/Federal Energy Technology Center’s (FETC) programmatic effort.     

The New Clean Air Act Operating Permit Program: EPA’s Proposed Regulations

The 1990 Clean Air Act Amendments added a new Title V to the Act which establishes an operating permit program for numerous sources of air pollution. Certain sources are currently required to obtain a construction or “new source review” permit; the 1990 Amendments will require many more sources to apply for a permit which will give them permission to operate. CAA Title V was modeled on the National Pollutant Discharge Elimination System (NPDES) permit provisions of the Clean Water Act, but there are important differences between the two statutes.

Although many states already have their own operating permit programs, by late 1993 every state must establish a program that meets the requirements of Title V and EPA’s implementing regulations. EPA recently proposed these regulations, and by the statutory deadline of November 15, 1991 hopes to issue final regulations establishing the minimum elements of state operating permit programs. These regulations will significantly affect implementation of air pollution measures for years to come because a Title V operating permit will have to assure compliance with all applicable CAA requirements. In addition, permitted sources will be required to pay fees to cover the costs of the permit program.     

Recent increases in nitrogen oxide (NOx) emissions from coal-fired electric generating units equipped with selective catalytic reduction

The most effective control technology available for the reduction of oxides of nitrogen (NO_x) from coal-fired boilers is selective catalytic reduction (SCR). Installation of SCR on coal-fired electric generating units (EGUs) has grown substantially since the onset of the U.S. Environmental Protection Agency’s (EPA) first cap and trade program for oxides of nitrogen in 1999, the Ozone Transport Commission (OTC) NO_x Budget Program. Installations have increased from 6 units present in 1998 in the states that encompass the current Cross-State Air Pollution Rule (CSAPR) ozone season program to 250 in 2014. In recent years, however, the degree of usage of installed SCR technology has been dropping significantly at individual plants. Average seasonal NO_x emission rates increased substantially during the Clean Air Interstate Rule (CAIR) program. These increases coincided with a collapse in the cost of CAIR allowances, which declined to less than the cost of the reagent required to operate installed SCR equipment, and was accompanied by a 77% decline in delivered natural gas prices from their peak in June of 2008 to April 2012, which in turn coincided with a 390% increase in shale gas production between 2008 and 2012. These years also witnessed a decline in national electric generation which, after peaking in 2007, declined through 2013 at an annualized rate of ?0.3%. Scaling back the use of installed SCR on coal-fired plants has resulted in the release of over 290,000 tons of avoidable NO_x during the past five ozone seasons in the states that participated in the CAIR program.

Implications: To function as designed, a cap and trade program must maintain allowance costs that function as a disincentive for the release of the air pollutants that the program seeks to control. If the principle incentive for reducing NO_x emissions is the avoidance of allowance costs, emissions may be expected to increase if costs fall below a critical value, in the absence of additional state or federal limitations. As such, external factors as the cost of competing fuels and a low or negative growth of electric sales may also disincentivize the use of control technologies, the continuation of desirable emission rates will be best maintained by the implementation of performance standards that supplement and complement the emissions trading program.     

Emission projections for the U.S. Environmental Protection Agency Section 812 second prospective Clean Air Act cost/benefit analysis

Section 812 of the Clean Air Act Amendments (CAAA) of 1990 requires the U.S. Environmental Protection Agency (EPA) to perform periodic, comprehensive analyses of the total costs and total benefits of programs implemented pursuant to the CAAA. The first prospective analysis was completed in 1999. The second prospective analysis was initiated during 2005. The first step in the second prospective analysis was the development of base and projection year emission estimates that will be used to generate benefit estimates of CAAA programs. This paper describes the analysis, methods, and results of the recently completed emission projections. There are several unique features of this analysis. One is the use of consistent economic assumptions from the Department of Energy's Annual Energy Outlook 2005 (AEO 2005) projections as the basis for estimating 2010 and 2020 emissions for all sectors. Another is the analysis of the different emissions paths for both with and without CAAA scenarios. Other features of this analysis include being the first EPA analysis that uses the 2002 National Emission Inventory files as the basis for making 48-state emission projections, incorporating control factor files from the Regional Planning Organizations (RPOs) that had completed emission projections at the time the analysis was performed, and modeling the emission benefits of the expected adoption of measures to meet the 8-hr ozone National Ambient Air Quality Standards (NAAQS), the Clean Air Visibility Rule, and the PM2.5 NAAQS. This analysis shows that the 1990 CAAA have produced significant reductions in criteria pollutant emissions since 1990 and that these emission reductions are expected to continue through 2020. CAAA provisions have reduced volatile organic compound (VOC) emissions by approximately 7 million t/yr by 2000, and are estimated to produce associated VOC emission reductions of 16.7 million t by 2020. Total oxides of nitrogen (NO(x)) emission reductions attributable to the CAAA are 5, 12, and 17 million t in 2000, 2010, and 2020, respectively. Sulfur dioxide (SO2) emission benefits during the study period are dominated by electricity-generating unit (EGU) SO2 emission reductions. These EGU emission benefits go from 7.5 million t reduced in 2000 to 15 million t reduced in 2020.     

Overview of the U.S. Environmental Protection Agency's Hazardous Air Pollutant Early Reduction Program.

Under provision of the Clean Air Act Amendments of 1990 Title III, the EPA has proposed a regulation (Early Reduction Program) to allow a six-year compliance extension from Maximum Achievable Control Technology (MACT) standards for sources that voluntarily reduce emissions of Hazardous Air Pollutants (HAPs) by 90 percent or more (95 percent or more for particulates) from a base year of 1987 or later. The emission reduction must be made before the applicable MACT standard is proposed for the source category or be subject to an enforceable commitment to achieve the reduction by January 1, 1994 for sources subject to MACT standards prior to 1994. The primary purpose of this program is to encourage reduction of HAPs emissions sooner than otherwise required. Industry would be allowed additional time in evaluating emission reduction options and developing more cost-effective compliance strategies, although, under strict guidelines to ensure actual, significant and verifiable emission reductions occur.     

Maintaining high-volume, low-pressure surface-coating regulatory compliance using the U.s. Environmental Protection Agency's data quality objectives process

To effectively reduce the environmental compliance costs associated with meeting specific requirements under the Aerospace Manufacturing and Rework Facility's National Emission Standard for Hazardous Air Pollutants rule, the U.S. Environmental Protection Agency's (EPA) Data Quality Objective (DQO) process has been proposed as a suitable framework for developing a scientifically defensible surface compliance monitoring program. By estimating the variability associated with the air cap pressure of high- volume, low-pressure (HVLP) surface-coating spray equipment, the number of monitoring samples necessary for an affected facility to claim compliance with a desired statistical confidence level was established. Using data taken from the pilot test facility, the DQO process indicated that the mean of at least 21 HVLP air cap pressure samples taken over the compliance period must be < or = 10 pounds per square inch (psig) gauge for the facility to claim regulatory compliance with 99.99% statistical confidence. Fewer compliance samples could be taken, but that decision would lead to a commensurate reduction in the compliance confidence level. Implementation of the DQO-based compliance sampling plan eliminates the need for an affected facility to sample all regulated HVLP surface-coating processes while still maintaining a high level of compliance assurance.     

Status of the DOE/GEESI In-Duct Scrubbing Pilot Study

The recent promulgation of stack height regulations and possible changes in the National Ambient Air Quality Standards for sulfur dioxide and the associated dispersion model methodologies, could require older power plants to develop new compliance strategies and upgrade emission control systems. In such situations, an inexpensive, moderate removal efficiency flue gas desulfurization technology could maintain the cost effectiveness of these plants. Such a technology was selected by the Department of Energy for demonstration in its Acid Rain Precursor Control Technology Initiative. The process applies the rotary atomizer techniques developed for lime slurry dry flue gas desulfurization spray absorbers, and utilizes existing ductwork and particulate collectors. This induct scrubbing technology is anticipated to result in a dry desulfurization process of moderate removal efficiency. The critical elements for successful application are (i) adequate mixing for efficient reactant contact, (ii) sufficient residence time to produce a non-wetting product, and (iii) appropriate ductwork cross sectional areas to prevent deposition of reaction products before drying. The ductwork in many older power plants, previously modified to meet 1970 Clean Air Act requirements for particulate control, usually meets these criteria. A pilot study of the process is now in design-construct phase. Testing will start in 1987 and determine conditions under which the technology would be a cost effective approach to meeting emission reduction design criteria     

Maintaining High-Volume,Low-Pressure Surface-Coating Regulatory Compliance Using the U.S. Environmental Protection Agency’s Data Quality Objectives Process

Abstract

To effectively reduce the environmental compliance costs associated with meeting specific requirements under the Aerospace Manufacturing and Rework Facility’s National Emission Standard for Hazardous Air Pollutants rule, the U.S. Environmental Protection Agency’s (EPA) Data Quality Objective (DQO) process has been proposed as a suitable framework for developing a scientifically defensible surface compliance monitoring program. By estimating the variability associated with the air cap pressure of high-volume, low-pressure (HVLP) surface-coating spray equipment, the number of monitoring samples necessary for an affected facility to claim compliance with a desired statistical confidence level was established. Using data taken from the pilot test facility, the DQO process indicated that the mean of at least 21 HVLP air cap pressure samples taken over the compliance period must be ≤10 pounds per square inch (psig) gauge for the facility to claim regulatory compliance with 99.99% statistical confidence. Fewer compliance samples could be taken, but that decision would lead to a commensurate reduction in the compliance confidence level. Implementation of the DQO-based compliance sampling plan eliminates the need for an affected facility to sample all regulated HVLP surface-coating processes while still maintaining a high level of compliance assurance.     

Analysis of primary fine particle national ambient air quality standard metrics

In accordance with the Clean Air Act, the U.S. Environmental Protection Agency (EPA) is currently reviewing its National Ambient Air Quality Standards for particulate matter, which are required to provide an adequate margin of safety to populations, including susceptible subgroups. Based on the latest scientific, health, and technical information about particle pollution, EPA staff recommends establishing more protective health-based fine particle standards. Since the last standards review, epidemiologic studies have continued to find associations between short-term and long-term exposure to particulate matter and cardiopulmonary morbidity and mortality at current pollution levels. This study analyzed the spatial and temporal variability of fine particulate (PM2.5) monitoring data for the Northeast and the continental United States to assess the protectiveness of various levels, forms, and combinations of 24-hr and annual health-based standards currently recommended by EPA staff and the Clean Air Scientific Advisory Committee. Recommended standards have the potential for modest or substantial increases in protection in the Northeast, ranging from an additional 13-83% of the population of the region who are living in areas not likely to meet new standards and thereby benefiting from compliance with more protective air pollution controls. Within recommended standard ranges, an optimal 24-hr (98th percentile)/annual standard suite occurs at 30/12 microg/m3, providing short- and long-term health protection for a substantial percentage of both Northeast (84%) and U.S. (78%) populations. In addition, the Northeast region will not benefit as widely as the nation as a whole if less stringent standards are selected. Should the 24-hr (98th percentile) standard be set at 35 microg/m3, Northeast and U.S. populations will receive 16-48% and 7-17% less protection than a 30 microg/m3 standard, respectively, depending on the level of the annual standard. A 30/12 microg/m3 standard suite also provides nearly equivalent 24-hr and annual control of PM2.5 distributions across the United States, thereby ensuring a more uniform and consistent level of protection than unmatched or "controlling" and "backstop" standards. This could occur even within EPA staff's recommended range of standard suites, where 22-43% of the monitors in the country could meet a controlling standard but fail to meet the combined backstop standard, resulting in inconsistent short- and long-term protection across the country. An equivalent standards combination of 30/12 microg/m3 would minimize the wide variation of protectiveness of 24-hr and annual PM2.5 concentrations. Furthermore, given recent associations of subdaily exposures and acute adverse health effects, in the absence of a subdaily averaging metric, a stringent 24-hr standard will more effectively control maximum hourly and multihourly peak concentrations than a weaker standard.     

Summary of the 1991 EPRI/EPA/DOE SO2 Control Symposium

The 1991 SO₂ Control Symposium was held December 3-6, 1991, in Washington, D.C. The symposium, jointly sponsored by the Electric Power Research Institute (EPRI), the U.S. Environmental Protection Agency (EPA), and the U.S. Department of Energy (DOE), focused attention on recent improvements in conventional sulfur dioxide (SO₂) control technologies, emerging processes, and strategies for complying with the Clean Air Act Amendments of 1990. Its purpose was to provide a forum for the exchange of technical and regulatory information on SO₂ control technology. Over 800 representatives of 20 countries from government, academia, flue gas desulfurization (FGD) process suppliers, equipment manufacturers, engineering firms, and utilities attended. In all, 50 U.S. utilities and 10 utilities in other countries were represented. In 11 technical sessions, a diverse group of speakers presented 111 technical papers on development, operation, and commercialization of wet and dry FGD, Clean Coal Technologies, and combined sulfur dioxide/nitrogen oxides (SO₂/NO_x processes.     

Impact of three interactive Texas state regulatory programs to decrease ambient air toxic levels

The Federal Clean Air Act (FCAA) framework envisions a federal-state partnership whereby the development of regulations may be at the federal level or state level with federal oversight. The U.S. Environmental Protection Agency (EPA) establishes National Ambient Air Quality Standards to describe “safe” ambient levels of criteria pollutants. For air toxics, the EPA establishes control technology standards for the 187 listed hazardous air pollutants (HAPs) but does not establish ambient standards for HAPs or other air toxics. Thus, states must ensure that ambient concentrations are not at harmful levels. The Texas Clean Air Act authorizes the Texas Commission on Environmental Quality (TCEQ), the Texas state environmental agency, to control air pollution and protect public health and welfare. The TCEQ employs three interactive programs to ensure that concentrations of air toxics do not exceed levels of potential health concern (LOCs): air permitting, ambient air monitoring, and the Air Pollutant Watch List (APWL). Comprehensive air permit reviews involve the application of best available control technology for new and modified equipment and ensure that permits protect public health and welfare. Protectiveness may be demonstrated by a number of means, including a demonstration that the predicted ground-level concentrations for the permitted emissions, evaluated on a case-by-case and chemical-by-chemical basis, do not cause or contribute to a LOC. The TCEQ's ambient air monitoring program is extensive and provides data to help assess the potential for adverse effects from all operational equipment in an area. If air toxics are persistently monitored at a LOC, an APWL area is established. The purpose of the APWL is to reduce ambient air toxic concentrations below LOCs by focusing TCEQ resources and heightening awareness. This paper will discuss examples of decreases in air toxic levels in Houston and Corpus Christi, Texas, resulting from the interactive nature of these programs.

Implications: Texas recognized through the collection of ambient monitoring data that additional measures beyond federal regulations must be taken to ensure that public health is protected. Texas integrates comprehensive air permitting, extensive ambient air monitoring, and the Air Pollutant Watch List (APWL) to protect the public from hazardous air toxics. Texas issues air permits that are protective of public health and also assesses ambient air to verify that concentrations remain below levels of concern in heavily industrialized areas. Texas developed the APWL to improve air quality in those areas where monitoring indicates a potential concern. This paper illustrates how Texas engaged its three interactive programs to successfully address elevated air toxic levels in Houston and Corpus Christi.     

Precipitation in light extinction reconstruction

The U.S. Environmental Protection Agency (EPA) published the Regional Haze Rule (RHR) in 1999. The RHR default goal is to reduce haze linearly to natural background in 2064 from the baseline period of 2000-2004. The EPA default method for estimating natural and baseline visibility uses the Interagency Monitoring of Protected Visual Environments (IMPROVE) formula. The IMPROVE formula predicts the light extinction coefficient from aerosol chemical concentrations measured by the IMPROVE network. The IMPROVE light scattering coefficient formula using data from 1994-2002 underestimated the measured light scattering coefficient by 700 Mm(-1), on average, on days with precipitation. Also, precipitation occurred as often on the clearest as haziest days. This led to estimating the light extinction coefficient of precipitation, averaged over all days, as the light scattering coefficient on days with precipitation (700 Mm(-1)) multiplied by the percent of precipitation days in a year. This estimate added to the IMPROVE formula light extinction estimate gives a real world estimate of visibility for the 20% clearest, 20% haziest, and all days. For example, in 1993, the EPAs Report to Congress projected visibility in Class I areas would improve by 3 deciviews by 2010 across the haziest portions of the eastern United States because of the 1990 Clean Air Act Amendments. Omitted was the light extinction coefficient of precipitation. Adding in the estimated light extinction coefficient of precipitation, the estimated visibility improvement declines to <1 deciview.     

Making Cleanup Decisions at Hazardous Waste Sites: The Clean Sites Approach

This paper provides a summary of the results of an 18-month study conducted by Clean Sites, Inc. of Alexandria, Virginia. The study was designed to take a critical look at the way remedies are selected for abandoned hazardous waste sites that are cleaned up under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) and to develop recommendations for improving that process. The recommendations were released in an October 1990 report entitled “Improving Remedy Selection: An Explicit and Interactive Process for the Superfund Program.” Through a cooperative agreement with the U.S. Environmental Protection Agency, Clean Sites is working to test these recommendations. At two actual Superfund sites, Clean Sites will assist EPA in performing the remedy selection in accordance with the process Clean Sites has developed.     

Revised Air Quality Surveillance Requirements for State Implementation Plans

The National Ambient Air Quality Monitoring Program is carried out by state and local air pollution control agencies in support of their State Implementation Plans (SIP’s). The current EPA regulations which specify the characteristics of these state monitoring programs are undergoing change as a result of a comprehensive review by an independent work group. These revised regulations, which are described in the paper, are intended to improve the quality, timeliness, and usability of the data generated by the states for all data users. In addition, the revised regulations seek to bring about; (a) national consistency in monitoring site locations through standardized siting procedures; (b) improved network operations by means of a minimum quality assurance program; (c) reduced network inflexibility through an annual network review process; and (d) reduced data reporting through changed data reporting procedures.