INCREASING REGULATORS' CONFIDENCE IN POINT-NONPOINT POLLUTANT TRADING SCHEMES1

ABSTRACT: One of the principal stumbling blocks to regulatory agencies' adopting pollutant trading schemes is the complex of uncertainties surrounding any change in institutions. This is especially true if nonpoint pollution sources are to be involved along with point sources. Regulators are understandably reluctant to switch from tried-and-true point source permit systems, even if trading schemes can be shown (on paper, at least) to result in lower public expenditures. We propose a set of practical criteria for point-nonpoint pollutant trading systems that promise to increase regulators' confidence that the new system will be equally effective in controlling pollution and at the same time more likely to capture efficiencies in pollution reduction practices.     

Wetland ecological and compliance assessments in the San Francisco Bay Region, California, USA

The San Francisco Bay Region of the California Regional Water Quality Control Board (SFB CRWQCB) and the San Francisco District of the US Army Corps of Engineers (US ACOE) are looking for an expeditious means to determine whether regulated wetland projects produce ecologically valuable systems and remain in compliance with their permits (i.e. fulfill their legal requirements) until project completion. A study was therefore undertaken in which 20 compensatory wetland mitigation projects in the San Francisco Bay Region were reviewed and assessed for both permit compliance and habitat function, and this was done using a rapid assessment method adapted for this purpose. Thus, in addition to determining compliance and function, a further goal of this study was to test the efficacy of the assessment method, which, if useful, could be applied not only to mitigation projects, but also to restoration projects and natural wetland systems. Survey results suggest that most projects permitted 5 or more years ago are in compliance with their permit conditions and are realizing their intended habitat functions. The larger restoration sites or those situated between existing wetland sites tend to be more successful and offer more benefits to wildlife than the smaller isolated ones. These results are consistent with regulatory experience suggesting that economies of scale could be realized both with (1) large scale regional wetland restoration sites, through which efforts are combined to control invasive species and share costs, and (2) coordinated efforts by regulatory agencies to track project information and to monitor the increasing number and size of mitigation and restoration sites. In regard to the assessment methods, we find that their value lies in providing a consistent protocol for evaluations, but that the ultimate assessment will rely heavily on professional judgment, regulatory experience, and the garnering of pre-assessment information.     

中美燃煤火电厂空气污染物排放标准比较研究

本文对中美燃煤火电厂国家行业排放标准的内容设置、限值形式、监测、记录和报告规定,以及固定源排污许可证中如何执行排放标准进行了比较。相对于美国,中国燃煤火电厂国家行业排放标准文本内容过于简略,限值形式设置单一,主要采用全国统一的浓度限值而不是采用绩效限值;浓度限值的制定基于部分样本源而不是全部源的数据,很难体现行业的排放控制技术水平;达标判据不科学,也过于严格,小时均值的考核方式影响了火电厂的生产安排;排放标准中监测配套规定单薄,与环境监测的一般规定衔接性不佳,针对性差;记录和报告要求缺位,不能满足排污许可证管理的需求。建议参照美国行业排放标准的内容形式,排放限值采用绩效限值形式,并规定长平均周期的考核要求,将与之配套的监测、记录和报告要求纳入排放标准,以满足固定源排污许可证制度的需求。     

Maintaining quality focus with critical data

Total Quality Management measurement tools are often the very tools necessary to ensure compliance with the rapidly growing regulatory demand for data. At the same time, interest in the environment by average citizens, environmental groups, and regulatory agencies has put increasing pressure on environmental managers for “zero defects.” Violations and exceedances are actively pursued and are, at a minimum, made public to produce incentive for companies to comply. Even companies in compliance face pressure to further improve their performance. No business can afford the lost legal, operational, and public relations costs of noncompliance. There is no room for error. This article discusses the basic tools used at IBM Rochester to better manage and control some key environmental operations and shows how these basic control steps work in an actual wastewater treatment process at the facility.     

Risk aversion and compliance in markets for pollution control

This paper examines the effects of risk aversion on compliance choices in markets for pollution control. A firm's decision to be compliant or not is independent of its manager's risk preference. However, non-compliant firms with risk-averse managers will have lower violations than otherwise identical firms with risk-neutral managers. The violations of non-compliant firms with risk-averse managers are independent of differences in their profit functions and their initial allocations of permits if and only if their managers' utility functions exhibit constant absolute risk aversion. However, firm-level characteristics do impact violation choices when managers have coefficients of absolute risk aversion that are increasing or decreasing in profit levels. Finally, in the equilibrium of a market for emissions rights with widespread non-compliance, risk aversion is associated with higher permit prices, better environmental quality, and lower aggregate violations.     

THE INFLUENCE OF CLIMATE VARIATION ON THE ESTIMATION OF LOW FLOWS USED TO PROTECT WATER QUALITY: A NATIONWIDE ASSESSMENT1

ABSTRACT: Historical flow records are used to estimate the regulatory low flows that serve a key function in setting discharge permit limits through the National Pollutant Discharge Elimination System, which provides a nationwide mechanism for protecting water quality. Use of historical records creates an implicit connection between water quality protection and climate variability. The longer the record, the more likely the low flow estimate will be based on a broad set of climate conditions, and thus provides adequate water quality protection in the future. Unfortunately, a long record often is not available at a specific location. This analysis examines the connection between climate variability and the variability of biologically based and hydrologically based low flow estimates at 176 sites from the Hydro‐Climatic Data Network, a collection of stream gages identified by the USGS as relatively free of anthropogenic influences. Results show that a record of 10 to 20 years is necessary for satisfactory estimates of regulatory low flows. Although it is possible to estimate a biologically based low flow from a record of less than 10 years, these estimates are highly uncertain and incorporate a bias that undermines water quality protection.     

固定源排污许可合规制度研究

固定源合规制度是确保固定源企业将排污许可证中载明的要求得以实施的具体措施和规定,也是将排污许可制度打造为固定源环境管理核心制度的重要环节。本文基于美国固定源合规监管经验和当前国内排污许可实施基础,构建了固定源排污许可合规管理制度。所构建的制度基于整体性治理理论,以固定源企业需提交的排污许可合规报告为主要合规监管环节,将政府部门对于固定源企业的合规监管分为以合规报告为主的书面核查和企业现场核查两个环节,并在整个合规监管过程中贯彻数据管理,设计了企业合规报告、政府核查报告、核查类型及任务、核查评估方法、合规信息公开及违规处罚方式等关键内容,以节省对于固定源企业污染排放合规监管过程的环境执法资源和提升监管效率。     

Chemical industry wastewater treatment

Treatment of chemical industrial wastewater from building and construction chemicals factory and plastic shoes manufacturing factory was investigated. The two factories discharge their wastewater into the public sewerage network. The results showed the wastewater discharged from the building and construction chemicals factory was highly contaminated with organic compounds. The average values of chemical oxygen demand (COD) and biochemical oxygen demand (BOD) were 2912 and 150 mgO₂/l. Phenol concentration up to 0.3 mg/l was detected. Chemical treatment using lime aided with ferric chloride proved to be effective and produced an effluent characteristics in compliance with Egyptian permissible limits. With respect to the other factory, industrial wastewater was mixed with domestic wastewater in order to lower the organic load. The COD, BOD values after mixing reached 5239 and 2615 mgO₂/l. The average concentration of phenol was 0.5 mg/l. Biological treatment using activated sludge or rotating biological contactor (RBC) proved to be an effective treatment system in terms of producing an effluent characteristic within the permissible limits set by the law. Therefore, the characteristics of chemical industrial wastewater determine which treatment system to utilize. Based on laboratory results engineering design of each treatment system was developed and cost estimate prepared.     

Optimizing Liquid Effluent Monitoring at a Large Nuclear Complex

Effluent monitoring typically requires a large number of analytes and samples during the initial or startup phase of a facility. Once a baseline is established, the analyte list and sampling frequency may be reduced. Although there is a large body of literature relevant to the initial design, few, if any, published papers exist on updating established effluent monitoring programs. This paper statistically evaluates four years of baseline data to optimize the liquid effluent monitoring efficiency of a centralized waste treatment and disposal facility at a large defense nuclear complex. Specific objectives were to: (1) assess temporal variability in analyte concentrations, (2) determine operational factors contributing to waste stream variability, (3) assess the probability of exceeding permit limits, and (4) streamline the sampling and analysis regime. Results indicated that the probability of exceeding permit limits was one in a million under normal facility operating conditions, sampling frequency could be reduced, and several analytes could be eliminated. Furthermore, indicators such as gross alpha and gross beta measurements could be used in lieu of more expensive specific isotopic analyses (radium, cesium-137, and strontium-90) for routine monitoring. Study results were used by the state regulatory agency to modify monitoring requirements for a new discharge permit, resulting in an annual cost savings of US $223,000. This case study demonstrates that statistical evaluation of effluent contaminant variability coupled with process knowledge can help plant managers and regulators streamline analyte lists and sampling frequencies based on detection history and environmental risk.     

Forest law compliance and enforcement: the case of on-farm timber extraction in Ghana

The paper investigates law compliance in case of on-farm timber extraction in Ghana. It empirically investigates compliance with rules that (i) require timber operators to obtain prior and informed consent from the farmers, (ii) require timber operators to pay appropriate and timely compensation for crop damage caused by timber extraction and (iii) ban chainsaw lumbering. The study documents a low level of compliance in all three domains. Subsequently, the paper discusses the underlying causes for the observed low compliance. The low compliance level is attributed to a legislation, and enforcement, that provides huge financial incentives for non-compliance for both farmers and timber operators, and in the latter case both with and without legal permits. At the same time the regulation is perceived to violate their moral values. The paper underlines the interests of the political elite as decisive in shaping the current regulation and the way it is implemented on the ground. It asserts that eliciting compliance requires consideration of both the instrumental and normative perspectives; else it becomes illusive. The study thus challenges the typical response of governments in developing countries, who, supported by donor agencies, attempt to elicit compliance through enhanced law enforcement efforts. The results presented on the Ghana case suggest that such an approach is unlikely to elicit compliance.     

Practicalities of participation in urban IWRM: Perspectives of wastewater management in two cities in Sri Lanka and Bangladesh

As the demand for water in cities increases, the quantity of wastewater being produced is growing at a phenomenal rate. If resources are to be managed effectively, a new paradigm is required for urban wastewater management. This paper reviews the initial findings of a participatory action planning process for managing wastewater for agricultural use. It finds that such processes need considerable facilitation, capacity building and knowledge sharing, but that if a plan can be devised that meets the needs of the stakeholders, even if some compromise is required, then certain stakeholders are likely to take responsibility for specific aspects. This may not meet the entire integrated water resources management (IWRM) vision of the plan but provided the plan is developed in such a way that incremental implementation will be beneficial then this will produce some success and may stimulate further cooperation.     

The Role of Ownership in Environmental Performance: Evidence from Coalbed Methane Development

One way coalbed methane production differs from traditional oil and gas extraction is in the large quantities of produced water. This water must be disposed of for production to occur. Surface discharge has proven to be a low-cost alternative; regulations are in place to protect surface water quality. This paper investigates the effects of alternative ownership regimes on regulatory compliance. A unique dataset linking coalbed methane wells in Wyoming to water disposal permit violations is used to explore differences in environmental performance across severed and unified minerals. Empirical analysis of these data suggest that ownership does impact environmental compliance behavior. Most violations occur on split estate. Federal split estate wells have more severe violations, though not necessarily more of them. Federal unified wells performed best, with fewer and less serious violations. Wells on private land have more, though not necessarily more severe, violations. These results suggest some room for policy proposals accounting for alternative ownership regimes.     

Environmental cost accounting: The bottom line for environmental quality management

Recent years have seen the environment emerge as one of the most pressing issues facing American business. Eventually, environmental costs will affect the bottom line of every American company. A recent study in the National Law Journal estimates that cleanup of the nation's known hazardous wastes sites will cost $752 billion over thirty years under current environmental policies. Environmental legislation and regulations impose annual compliance costs estimated by the Environmental Protection Agency at more than $30 billion. In the near future, environmental expenses for cleanup, regulatory compliance, and management are anticipated to grow to between 2.5 and 3 percent of GNP. Corporations that wish to be competitive must successfully manage these costs while maintaining or improving their role as responsible corporate citizens. Implementing a comprehensive system for identifying and managing environmental costs requires a multidisciplinary team effort. Environmental costs impact product selection, design and pricing, capital budgeting, and future strategic direction. In order to make informed and meaningful managerial decisions on environmental programs, real cost data are vital. An environmental management systems (EMS) requires information to set goals and then monitor progress towards those goals over time. This article will discuss the current cost accounting systems (CASs) available to support the myriad goals of environmental management systems. In addition, the article will outline a framework for plotting the location of your current EMS on a matrix of regulatory and information requirements and evaluating whether your corporation's CAS is adequate to support the goals and objectives set by your environmental management program. By anticipating future regulatory and information requirements, flexible systems can be developed to adapt to new and more stringent regulations and more complex information requirements.     

WATER QUALITY CONCERNS AND REGULATORY CONTROLS FOR NONSTORM WATER DISCHARGES TO STORM DRAINS1

ABSTRACT: Nonstorm water discharges to municipal separate storm sewer systems (MS4s) are notable for spatial and temporal variability in volume, pollutant type, pollutant concentration, and activity of origin. The objective of this paper was to determine whether current technical knowledge and existing U.S. policy support an improved regulatory approach. The proposed policy would use type of discharge as a regulatory basis, merging the concepts of allowability of de minimis discharges and type-based statewide consistent rules. Specific research objectives were to comprehensively identify discharge types, characterize their prevalence in California, analyze relevant local and regional regulatory guidelines, and systematically evaluate opinions of experts about potential water quality impacts. Results demonstrate nonstorm water discharges were widespread in at least one sector, industrial facilities subject to a state permit; one discharge for every four facilities was reported in 1995, even though the permit explicitly prohibits such discharges. Clear consensus exists for minimal water quality concern for some discharge types when considering both municipal guidelines and experts’ opinions. In particular, condensate from a wide range of equipment and discharges from fire fighting equipment testing were found to be of low concern. Discharge types with consensus high concern were largely limited to discharges prohibited under other regulations, such as wastewater and hazardous waste management controls. Some discharge types where no consensus was identified, such as landscape irrigation, nevertheless generated concern for water quality impacts and appear to be relatively widespread. Available information supports technical feasibility of the proposed policy because at least some discharge types show strong consensus for de minimis impacts among regulatory guidelines and opinions of technical experts.     

IMPLEMENTATION OF ACUTE CRITERIA FOR CONSERVATIVE SUBSTANCES1

ABSTRACT: Acute criteria are assigned to the fish and wildlife propagation beneficial use in Oklahoma's water quality standards. Dye studies are analyzed to show that these criteria can be implemented through acute regulatory mixing zones. Acute regulatory mixing zones may be defined as areas in receiving streams where acute numerical criteria may be exceeded without causing acute toxicity. Acute regulatory mixing zones are used to obtain acute waste load allocations. If effluent loading does not exceed acute waste load allocation, acute criteria exceedance is confined to the acute regulatory mixing zone and there is no acute toxicity in the receiving stream. Waste load allocations for acute and chronic criteria are compared to determine which is appropriate to develop permit limits for the dye studies.     

Air Regulation Requirements in the Marcellus and Utica Shale Region: Management Approaches and Case Study

Evolving air emissions regulation presents a serious compliance challenge for all oil and gas operators in the United States of America. In Appalachia, a legacy producing region, the rapid development of the Marcellus and Utica shales has led to a rapid expansion of operations across the states of Pennsylvania, West Virginia, and Ohio. Driven by this unprecedented development, increased public pressure, and lawsuits, new regulatory programs are being developed at both the state and federal levels. This article discusses the evolving air regulations impacting operators in the region and how operators can implement an air emissions management system to help them stay compliant.     

蒸汽排放降噪式污水回收装置研究及应用

注汽锅炉是稠油油田热注作业生产使用的主要设备,当需要停止注汽或需要维修时,需将炉内的高温高压蒸汽进行排空,才能保证安全作业;而高压蒸汽直接进行排空时,会产生120 dB(A)以上的强烈的噪声污染,针对此问题曙光油田研制了"蒸汽排放降噪式污水回收装置"。文章介绍了其降噪及污水回收原理,对其现场应用情况进行了说明。实际应用效果表明,该装置可以达到降噪、节水、减排多重作用。     

Where Did the Agricultural Nonpoint Source Trades Go? Lessons from Virginia Water Quality Trading Programs

Governmental agencies, nongovernmental organizations, and agricultural organizations promote water quality trading programs as an innovative policy to engage agricultural producers in conservation activities. Cost analyses suggest regulated sources can reduce compliance costs by purchasing agricultural nonpoint source credits. Yet, such “point‐nonpoint” trades are rare. This article assesses the demand for agricultural nonpoint sources in well‐developed nutrient trading programs in Virginia for industrial and municipal wastewater treatment plants, municipal stormwater programs, and land developers. Evidence suggests nutrient trading programs in Virginia will not stimulate investments in pollutant reduction practices on working agricultural lands. The lack of demand for agricultural nonpoint source credits can be attributed to a substantial degree to the design features and incentives present in multiple overlapping regulatory programs. The legal setting that dampens regulated source demand for nonpoint source credits in Virginia is broadly representative of conditions found elsewhere in the United States.     

Fuzzy-based wastewater quality indices for pollution classification: a case study in the United Arab Emirates

This paper presents a fuzzy logic-based tool for assessing the pollution concentration of effluents generated by various industrial and commercial activities. The study proposes a fuzzy overall pollution compliance index (FOPCI) (range 0–100) to classify the wastewater discharged from various types of properties present in Ajman, United Arab Emirates. The work mainly focused on three types of pollution that can occur at the inlets of the wastewater treatment plant of Ajman, due to discharge of industrial and commercial effluents, namely pH pollution, salt pollution, and organic pollution. The proposed FOPCI integrates six characteristics, namely pH, Cl^?, SO₄ ^2?, conductivity, chemical oxygen demand (COD), and fats, oils, and greases (FOG) values into a readily understandable scale. The FOPCI is developed by using the Fuzzy Inference System Toolbox available in MATLAB in two steps, in which during the first step, three sub-indices, namely fuzzy pH compliance index, fuzzy salt compliance index, and fuzzy organic compliance index are developed. It is then processed in the second stage to develop the FOPCI. Fuzzy rules are used to classify effluents quality into six categories based on the concentration of pollutant in the effluent, namely “Excellent Quality”, “Good Quality”, “Acceptable Quality”, “Moderately Polluting”, “Highly Polluting”, and “Extremely Polluting”. This linguistic classification using fuzzy logic will be helpful as a decision support system to provide an outline for the prioritization of plans for wastewater management based on the values of the indices developed.     

SURFACE WATER WITHDRAWAL ALLOCATION AND TRADING SYSTEMS FOR TRADITIONALLY RIPARLAN AREAS1

ABSTRACT: There is a growing need for water regulations in states traditionally managed by the riparian doctrine. Several states have passed water laws to control withdrawals from streams. Few, if any, however, have set up consistent and defensible methods for allocating water to users. This paper explores several methods for such allocations, examining each in detail and offering numerical examples that compare each on the basis of economic efficiency and effectiveness for maintaining critical stream‐flow standards. This work is part of a study to assess the vulnerability of Midwestern streams to climate change and, especially, surface supplied irrigation spawned by such climate change. The results suggest that it is possible to implement regulations that at once (1) are consistent with the riparian doctrine; (2) control the hydrological and ecological impacts of off stream withdrawals effectively; and (3) preserve the primary economic functions of those withdrawals, including minimizing economic risk. The results further suggest that trading of water permits improves the latter two objectives, but only if both the regulatory system and permit are well‐designed. On the other hand, in the absence of regulations, or under poorly designed regulations, streamflows, and therefore aquatic ecosystems, could be quite vulnerable.