does not necessarily represent the position of the Puget Sound Air Pollution Control Agency.108(e) of the Clean Air Act. Diffusion modeling need not be dropped under such a program, but should be continued for informational and advisory purposes. The legal test for approval of a source would be that it met the requirements of the code of practices, not that it would meet all air quality standards. This would eliminate an open invitation in most present indirect source regulations for either the proponents or opponents of projects to litigate modeling studies.
ConclusionsIndirect Source Regulations present problems to the reviewing authority. The effectiveness of these regulations is reduced since the authority lacks control over tailpipe emissions and its sole means of control is provided through diffusion modeling of alternative source configurations. The modeling process lacks sufficient reliability to be the only criterion for approval since it is subject to inherent modeling error and to error involved in estimating future worst case, short term traffic, and atmospheric conditions. This problem, and the problems of equity posed by ISR, lead to enforcement problems which further reduce effectiveness.Enforceability of indirect source regulations might be improved by requiring new indirect sources to conform to a code of practices of measures which would reduce air pollutant concentrations, rather than to require that they model so as not to predict standard violations. This would prevent litigation based on modeling studies and thereby improve enforcement, as well as tie the ISR process to Section 108(e) planning.
Human populations are exposed to environmental carcinogens in both indoor and outdoor atmospheres. Recent studies indicate that pollutant concentrations are generally higher in indoor atmospheres than in outdoor. Environmental pollutants that occur in indoor air from a variety of sources include radon, asbestos, organic and inorganic compounds, and certain particles (e.g., tobacco smoke). Some of the gases or vapors are adsorbed on suspended particulate matter, whereas others exist entirely in the gas phase or are distributed between the latter and a particle‐bound state. Because of differences in chemical and physical properties, each class of carcinogens generally requires different sampling and analytical methods. In addition, a single indoor environment may contain a wide variety of air pollutants from different sources. Unfortunately, no single best approach currently exists for the quantitative determination of such complex mixtures and, for practical reasons, only the more toxic or the more abundant pollutants are usually measured. This paper summarizes the currently available monitoring methods for selected environmental pollutants found in indoor atmospheres. In addition, some possible sources for those pollutants are identified.
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