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]
Submitted February 8, 2018 4:09 PM
Comment on
Regulatory amendments related to air emissions of sulphur dioxide and other items
ERO number
013-0903
Comment ID
460
Commenting on behalf of
Comment status