Critical Timelines for the SO2 Data Requirements Rule

We are now approaching the “home-stretch” of the SO₂ Data Requirements Rule (DRR).  State agencies were due to provide U.S. EPA with a list of the affected facilities where SO₂ air quality will be characterized on January 15, 2016.  The next critical milestone is on July 1, 2016 where facilities are required to identify which approach (ambient monitoring, air dispersion modeling, or the acceptance of an enforceable emissions limit less than 2,000 tons/yr) they elect to use to characterize SO₂ air quality surrounding their facility.  Check out our SO₂ DRR page for additional information on these approaches.  In addition, U.S. EPA is expecting either of the following documents be submitted for each facility by July 1, 2016:

1. An air dispersion modeling protocol if the facility elects to use the air dispersion modeling approach, or
2. An ambient monitoring plan that includes pertinent information about the proposed ambient monitor(s) if the facility elects to use the ambient monitoring approach.  This information would also be included in the agency’s annual monitoring network plan.

These July 1 deadlines are very misleading as they only indicate the dates that this information must be provided to U.S. EPA.  The truth is that each State agency, in States where the burden is being placed on facilities to prepare information, also needs time to review the facility’s dispersion modeling protocol or ambient monitoring plan.  Many States are requesting that dispersion modeling protocols and ambient monitoring plans be submitted by April 2016.  The reality is that the sooner the better for submittal so that you can start to work through questions or concerns from State agencies, well before any information needs to make its way to U.S. EPA.  Facilities need to start the dialogue with State agencies to make sure they provide all necessary information.  This is especially true if you elect to use the ambient monitoring approach.  We will have a subsequent blog post in the coming weeks to discuss the specifics of the ambient monitoring plan.

If you haven’t yet started your SO₂ DRR evaluation or if you have questions about upcoming deadlines, please contact Colin McCall at 678.460.0324 ext. 206 (cmccall@all4inc.com) or myself at 678.460.0324 ext. 204 (cdoyno@all4inc.com).