**Q. What does "unclassifiable" mean with regard to the AQCR's?
A. From http://gsa.gov/pbs/pt/call-in/update/spr97/spr97_4.htm
The Clean Air Act (CAA) recognizes that increases in air pollution results in danger to public health and welfare. To protect and enhance the quality of the Nation's air resources, the CAA authorizes the Environmental Protection Agency (EPA) to promulgate six National Ambient Air Quality Standards (NAAQS) which regulates carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and particulate matter. The CAA seeks to reduce or eliminate the creation of pollutant at their source, and designates this responsibility to state and local governments. States are directed to develop implementation plans to achieve NAAQS. Geographic areas are officially designated by the EPA as being in attainment or nonattainment for pollutants in relation to their compliance with NAAQS. Geographic regions established for air quality planning purposes are designated as Air Quality Control Regions (AQCR). Pollutant concentration levels are measured at designated monitoring stations within the AQCR. An area is designated as unclassifiable when insufficient monitoring data exists.
That is, it is neither in attainment or "non-attainment".

* Q Where do vehicle emissions fit into the legislation?
A. In EPA parlance, vehicle emissions are “mobile sources.” They are not regulated under the clean air act directly (for the most part) but the common pollutants from them are in the “priority pollutants” that must be controlled in each Air Quality Management zone. I say for the most part, because there are new vehicle emission standards for manufactures and I believe those are under the CAA as well. Mobile sources are seldom Hazardous and Toxic Waste issues, so I don't teach much about them.

*Q. How are air quality control regions defined? Is it based on the number of people in an area, the level of pollution, etc.?
A.They were “logical” airsheds – regions that seem to share air, based on currents, seasons, etc.

*Q. Aregion can be labeled as Attainment, Non-attainment and Unclassifiable. Under what circumstances would a region be labeled Unclassifiable. To me it's like going to court; You can plead guilty, not guilty or no contest. Is Unclassifiable like saying “no contest” thereby detouring an admission of guilt. Or is that term simply used when an area hasn't been truly monitored?


* Q. Why is in the CAA for the other chemicals than the almost 200 on the laundry list a threshold of 10 tons of discharge per year defined before a permit is required? Is the reason lack of data?
A. Just a threshold below which is not worth regulating. But 10 tons is not much. I burn 2000 gal of fuel a year, which weighs about 12000 pounds or 6 tons. Say the fuel is CH2 with a MW of 14 to that I add 3 oxygens with a MW of 48 to get CO2 +H2O, so my stack gas weighs 26 tons.

* Q. The EPA has lobbyists who are inclined either towards industry or towards certain environmental groups. So every regulation that EPA produces is influenced by the biased attitude of its members. Is it politics taking over science?
A. Regulations are not science, nor are laws. They are rules or conventions of society that keep us from killing each other. Laws then seek consensus, not truth. See:
http://www.faculty.uaf.edu/ffrap/ENVE_652/Module12/12A_RegulatoryTox/12A_RegulatoryTox.htm

* Q. My question is: The Bush administration has seriously rolled back regulations
for the Clean Air and Water Acts. I am a little curious about how the
regulators are handling the cuts. I read an article about how some regulators
aren't even issueing tickets or fines because they know the higher ups won't
follow through.
A. Here you may be reading something that is politically biased. The federal regulators, rank and file, have a strong "whistle-blowing" statute to protect them. If they could show a political boss directed them to violate the law, the worker could scream to the press and get befits from screaming. Just as regulations must be "promulgated" via the Administrative Procedures Act, likewise, they must go through the same steps to "role back" or modify the regulations in any way. Congress (and the state legislatures) sometimes strip an agency of budget so they can no longer enforce a law, but this is deliberate action by the congress. Having said that, for sections of both the CWA and the CAA, there are sections that require "Best Available Control Technology" and such that might have a variable definition. For example, BACT allows consideration of economics. One regulator might believe that any technology, up to and almost including what would bankrupt an industry, is "economical," while another regulator might feel that any technology that did not allow the industry to make at least 15% return on their invested capital is not economically achievable. Take your pick. There is ample room for political criticism.

Q. Fugitive emissions are an area that is interesting to me, possibly from a commercial point of view. It looks like there is going to be increasing pressure to control them, and you can't do that unless you know what they are and where they are coming from. Toward that end, I am interested in field portable gc and gc/ms instrumentation. FIDs, PIDs and OVAs tell you something, but generally you have to have some prior knowledge of what you are dealing with to be confident that is what you are measuring, and they are semi-quantitative. Do you know anyone with some practical experience with field portable gcs?
A. Not at a practical, as opposed to research, level. I see them advertised, but am not aware of their field use. Remember though, that for the GC you still need to have a good idea what you are looking for. You need to calibrate them with appropriate test chemicals. gc/ms is one or two levels more complex..

Q. Some pollutants are rare in some regions so they are not tested for?
A. I tried to find an example but did not. One definition, which does not add much new is: unclassifiable area is one in which the area's compliance with primary or secondary NAAQS cannot be determined with current information. I don't know more offhand.

Q.. In Fairbanks we have a relatively expensive air quality inspection process for our vehicles to try to reduce carbon monoxide emissions. How bad is our air quality relatively speaking? If I recall correctly if we exceed the standard more than twice a year we are in violation. How was that standard arrived at? We spend millions to reduce CO to two times a winter then breathe forest fire smoke all summer long. Where is the balance or reasoning?
A. (Shhh. I agree with you completely. There is no human health related reason for all that expense.)

Q.Along the same lines, the air in India doesn't just stay in India. With changes in weather, that air is bound to move around and possibly contaminate another region. Just looking at the United States for instance: If the air in Chicago, Illinois is really bad and the air in South Bend, Indiana is really good; How does weather affect the quality of the air from one region to another. Couldn't the bad air in Chicago move into the South Bend region and vise versa? The air could be measured as good one day and bad the next. Has this ever been a problem as far as you know?
A. Dust from the Sahara has been traced to particulates in the US, and smoke from forest fires in Russia had polluted the air in Alaska as if we did not have our own fire, and the Scandinavian countries accuse the US of acid rain. Sure it's a problem.

Q. In my experience it seems that in the last couple of years the question of indoor air quality has just become a major concern for some of the projects I am working on. Up until recently it seems that there was not a lot of pressure from ADEC project managers to look at the topic. Is there a reason for this increased interest by the ADEC in the indoor air quality in Alaska or in Fairbanks at least?
A. They had an “incident” in the ADEC building a few years ago.

Q. Also in some states the clean air act prohibits smoking indoors. Are these primarily ‘state' clean air acts? Federal CAA does not address smoking. As it's quite clear you can still smoke in some designated areas in Alaska. The airport in Anchorage now has only outside smoking. This is an interesting topic, is it covered in the clean air act, or how is it regulated at the federal levels?
A. Yes, state and local laws.

Q. Dog and the disputes over emissions there and I wondered what part of the Clean Air Act it came under. The only thing I remember is industry was saying it was exorbitantly costly to attain levels that EPA/DEC? wanted and that existing (or modifications to existing?) equipment was "good enough". That is, the cost of just a little less emissions was costly in the order of millions.
A. I'm not up on that one. But, it may be "permit condition" rather than a CAA violation. They required permits to build the road across public lands and many other permits from the state and federal government.

Q. Not a question in 12, 13, 14 but a semi-question/comment for 13D Oil Issues. This topic has fascinated me somewhat. I continually see "abandoned drums" in village while traveling for inspections of solid waste sites (dumps, landfills). They are perceived as "not my job" as they are not sitting at the dumpsite but "in town somewhere". Since they typically aren't spilling (or in very few instances they are but the quantities are small), spill response doesn't get involved. I am learning that "at most" it is possible a "pollution prevention" issue and I've been working with our P2 office on some "eventual, some time in the future" solutions to getting these drums transported somewhere. Finally, it is known (but often whispered) that some contractors in villages will simply "burn" the products in these drums rather than abandoning them, and the products are typically used oil. So a few other possible "oil issues" may include Clean Air Act (?) with regard to toxic smoke release and issues related to transporting drums out of remote rural areas when you don't have a "responsible party".
A. I was with the Corps of Engineers, a very RP, that moved about a quarter of a million drums from the Nome area. Almost all were empty. For any government action, there has to be some motivation. Although they will deny it, even at the public prosecutor's office, they routinely drop prosecution of crimes because the crime is small and it is simply too much money and resources to follow up. Police the same.