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CAB000362 E ID 7 4 4 0 5 5
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Minimize Uncertainty
Option 1
Option 2
Minimize Model Uncertainty
EPA recognizes model uncertainty, especially in short timeframes but doesn't specify over-prediction.
Scholarly paper purports air dispersion models conservative by over 2X - only one reference and still doesn't offer alternative
Substitute Monitoring Data for Modeling
Most likely less conservative than modeling
Where and when to sample are critical issues
Edge Moor sampling program was $50-60,000 based on 5 sampling events (locations) measuring 24-hr average concentrations at 5 locations.
Best approach - Conduct modeling using EPA model (AERMOD scheduled to be approved) compare results with ISC
Assume 1 to 2 months; cost of new
t*3 meteorological data and modeling time (< $5000)
04/ 10/03
GAB000363
EID744056