I spent a little more than two days at work this week putting together a spreadsheet of hazardous air pollutant emission estimates for Camp Dodge. I already knew the results but I needed to put together the documentation in a readily available form.
Without getting too tedious about it, air pollution in the United States is regulated from two lists of pollutants, the “priority pollutants”—particulates, lead, volatile organic compounds, oxides of nitrogen and sulfur, and carbon monoxide, and “Hazardous Air Pollutants”, or HAPs. There is a list of 187 HAPs. The list was developed in 1990 and has been minimally modified since then.
So my task was to estimate how much of each of those chemicals the different regulated sources emit. How much formaldehyde does a generator emit? How much xylene goes into the air when you paint? Are we a “major source” or are we an “area source”? (We are an area source—the lowest regulatory category).
The list of HAPs includes some pesticides. The herbicide 2,4-D and the banned insecticide chlordane are on the list, along with a few others. The industrial sources that are regulated by air pollution laws do not emit those chemicals unless they manufacture them.
Pesticides are generally not treated as air pollution. There are a host of other pesticide chemicals that are every bit as toxic as the few on the list, and every bit as likely to be present in the air. The community that is regulated by air toxics rules is not the community that applies pesticides.
Pesticides regulations generally target the applicator, and ensure that he or she is adequately trained to apply the pesticide safely. There are attempts to control spray drift and to a lesser extent vapor drift. However, when chemical based agriculture is conducted on a landscape scale the air pollution part of the equation is largely ignored.
Air pollution inventories and dispersion models need to be developed for the application of pesticides. In order to do that, you first need to know how much was applied, and where it was applied.