The updating of SO2…

ERO number

013-0903

Comment ID

460

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Individual

Comment status

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Comment

The updating of SO2 standards is welcome and overdue. In particular the development of the 10 min spike AAQC standard is important to take into account acute effects on vulnerable populations. While I recognize the difficulty in translating this AAQC into an enforceable POI regulatory standard, it is vital that (as seems to be proposed) the standard require that models for calculating 1 hour POI concentration incorporate TOC (flaring etc), and that the 1 hour POI standard itself be low enough to prevent transient exceedence of the 10 min AAQC.
A further concern is how effective the new standard will be in practice given the 7-8x higher URT., and the apparent lack of consideration of multiple sources of SO2 that might affect actual concentrations at the POI (at least in the regulation itself, if not in the ECAs of specific emitters).
For these reasons it is important that the amendments be at least no weaker than those proposed.

[Original Comment ID: 211473]