The advent of the short term NAAQS has prompted us to reassess the level of conservatism commonly used in dispersion modeling analyses. An area of conservatism in NAAQS demonstrations relates to the combining of predicted (modeled) concentrations from AERMOD with observed (monitored) concentrations. Normally, some of the highest monitored observations are combined with AERMOD results yielding a very conservative total concentration. For example, in the case of the 1-hour NO2 NAAQS, the chances of the 98th percentile monitored concentration occurring at the same time as the meteorology to generate the 98th percentile ambient concentration is extremely low. Therefore, assuming that both of these happen at the same time is overly conservative.
This presentation includes justification for the use of a reasonable background concentration to combine with the AERMOD predicted concentration. The use of this method, if accepted by regulatory agencies, can help facilities demonstrate compliance in dispersion modeling analyses by assuming a more reasonable background concentration while, at the same time being protective of the NAAQS.