ENV-14-41 Dealing with the SO2 NAAQS Data Requirements Rule: Challenges and Options

Description:

The purpose of this paper is to provide industrial sources information about certain concerns with the proposal, as well as an overview of strategic planning dealing with the rule’s implementation: what is involved in modeling or monitoring approaches. For modeling approaches, advanced techniques involve specific AERMOD modeling options (e.g., the “low wind” options) and possible use of site-specific meteorological data. A successful modeling outcome, if guided by strategic selection of modeling input, can avoid a costly monitoring program. However, in some cases, monitoring may provide more realistic results than monitoring. For a monitoring program, the key issues are “how many monitors” and “where to place the monitor(s)”. Since the operation of monitors is expensive, up-front planning in this regard is critical to success.