DRAFT
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NOT
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or
CITE
Last
updated
8/
11/
05
Staff
Work
Paper
On
the
Use
of
Air
Quality
Data
Related
to
Exceptional
and
Natural
Events
for
the
Particulate
Matter
Standards
U.
S.
Environmental
Protection
Agency
Office
of
Air
and
Radiation
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
N.
C.
27711
DRAFT
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NOT
QUOTE
or
CITE
ii
Contents
Section
I
Introduction
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1
Section
II
What
are
the
goals
of
this
Policy?
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2
Section
III
Purpose
and
Management
of
Flagging
Data
in
the
Air
Quality
System
(
AQS)
Database
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5
Section
IV
Uses
of
flagged
data
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5
4.1
General
guidelines
on
the
use
of
flagged
data
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5
4.2
Use
of
Air
Quality
Data
for
National
Air
Ambient
Quality
Standards
(
NAAQS)
Compliance.
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6
4.3
State
Implementation
Plan
(
SIP)
Regulatory
Activities
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6
Section
V
Submittal
of
documentation
related
to
flagged
data
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7
5.1
Requirement
to
Provide
Appropriate
Documentation
of
Exceptional,
Natural,
or
International
Events
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7
Section
VI
Natural
Events
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9
6.1
The
natural
events
covered
by
this
policy
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9
6.2
Volcanic
and
seismic
activities
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9
6.3
Unwanted
or
wild
fires
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10
6.4
High
wind
events
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10
6.5
Response
to
NAAQS
violations
due
to
natural
events
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12
6.6
Development
of
the
Natural
Events
Action
Plan
(
NEAP)
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13
6.7
Does
the
NEAP
have
to
be
included
in
the
State
Implementation
Plan?
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14
6.8
When
must
a
State
develop
a
NEAP?
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14
6.9
How
does
the
NEAP
apply
to
areas
designated
as
DRAFT
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nonattainment
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15
6.10
Failure
to
develop
or
implement
a
NEAP
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15
6.11
Natural
event
emissions
transported
from
international
sources
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16
Section
VII
Exceptional
Events
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16
7.1
Criteria
for
identification
of
exceptional
events
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16
7.5
Chemical
Spills
and
Industrial
Accidents
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17
7.9
Infrequent
Large
Gatherings
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18
7.11
Clean
Up
After
A
Major
Disaster
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18
7.12
Development
Of
An
Exceptional
Event
Mitigation
Action
Plan
(
EEMAP)
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18
7.13
Response
to
NAAQS
Violations
Due
To
Exceptional
Events
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18
7.14
Failure
To
Develop
Or
Implement
and
EEMAP
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19
Section
VIII
Stagnation
and
Inversion
Events
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19
8.1
Stagnation/
Inversions
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19
DRAFT
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DO
NOT
QUOTE
or
CITE
1
For
the
purpose
of
this
document,
the
term
Particulate
Matter
refers
to
PM2.5
and
PM10­
2.5.
For
PM10,
issues
related
to
natural
events
will
continue
to
be
addressed
via
the
memorandum
from
Mary
D.
Nichols,
Assistant
Administrator
for
Air
and
Radiation
to
EPA
Regional
Offices
titled,
"
Areas
Affected
by
PM10
Natural
Events",
May
30,
1996.
For
PM10,
exceptional
events
will
also
continue
to
be
addressed
under
the
"
Guideline
on
the
Identification
and
Use
of
Air
Quality
Data
Affected
by
Exceptional
Events",
July
1986
until
the
standard
for
PM­
10
has
been
revoked.

2
Under
the
Tribal
Authority
Rule
(
TAR),
eligible
Tribes
may
develop
Tribal
Implementation
Plans
to
administer
Clean
Air
Act
(
CAA)
requirements
on
Tribal
lands.
The
CAA
recognizes
Tribal
governments
as
the
most
appropriate
parties
to
regulate
the
environment
on
Tribal
lands
and
grants
EPA
the
authority
to
approve
Tribal
programs.
The
EPA
has
developed
strategies
for
Federally
implementing
CAA
requirements
if
Tribes
do
not
adopt
TIP's.
In
cases
where
a
Tribal
air
quality
agency
has
implemented
an
air
quality
monitoring
network
which
is
impacted
by
emissions
from
exceptional,
natural,
or
International
events
the
policies
identified
in
this
guidance
document
may
be
used
to
discount
data
for
regulatory
purposes.
In
cases
where
a
Tribe
may
need
assistance
in
meeting
some
or
all
of
the
requirements
related
to
the
guidance
in
this
document
EPA
has
the
responsibility
to
assist
the
Tribal
government
in
meeting
the
requirements.
Section
1
Introduction
This
document
provides
guidance
on
identifying,
evaluating,
interpreting,
and
using
data
related
to
the
Particulate
Matter
(
PM­
2.5
and
PM10­
2.5)
standards
where
State,
local,
and
Tribal
air
control
agencies
are
requesting
that
the
data
be
treated
as
being
affected
by
exceptional
or
natural
events.
12
Certain
events
are
considered
to
be
exceptional
for
two
reasons:
(
1)
they
are
not
expected
to
recur
routinely
at
a
given
location,
or
(
2)
they
are
determined
to
be
uncontrollable
or
un­
preventable.
For
the
purpose
of
this
document,
the
definition
of
natural
events
are
defined
as
those
events
that
are
due
to
an
act
of
nature
which
also
contributes
to
emissions
that
either
cause
or
significantly
contribute
to
violations
of
the
Particulate
Matter
national
air
ambient
quality
standards
(
NAAQS).
The
natural
events
that
will
be
covered
under
this
document
are
high
wind
events,
volcanic
and
seismic
activities,
and
wild
fires.
Natural
events
that
are
international
in
origin,
but
are
determined
to
have
caused
or
significantly
contributed
to
violations
of
the
Particulate
Matter
NAAQS,
at
locations
within
the
United
States,
will
also
be
covered
under
this
document.
DRAFT
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DO
NOT
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or
CITE
2
3
Appendix
K
pertains
specifically
to
the
PM10
standard.
However,
it
contains
important
information
regarding
the
definition
of
exceptional
events.
Consequently,
the
provisions
of
appendices
K
and
N
should
be
considered
together
as
comprising
the
authority
and
basic
concepts
underlying
the
exceptional
and
natural
events
policies
discussed
in
this
document.
The
Environmental
Protection
Agency
(
EPA)
has
adopted
rules
governing
decisions
concerning
data
that
are
determined
to
be
affected
by
these
types
of
episodic
events
pursuant
to
40
CFR
Part
50,
Appendices
K,
I
and
N3.
Appendices
K
and
N
generally
set
forth
what
is
needed
to
determine
whether
the
PM10
and
PM2.5
standards
respectively
are
being
met,
based
on
three
consecutive,
complete
calendar
years
of
air
quality
data.
Appendix
I
sets
forth
what
is
needed
to
determine
whether
the
ozone
standards
are
being
met.
Appendices
K,
I,
and
N,
of
40
CFR
Part
50,
allow
EPA
to
apply
special
consideration
to
data
affected
by
exceptional
and
natural
events.
Several
guidance
documents
have
previously
been
issued
by
EPA
concerning
episodic
events
related
to
exceptional
and
natural
events.
This
document
supersedes
all
of
these
documents
as
they
relate
to
the
implementation
of
the
Particulate
Matter
standards
with
the
exception
of
the
PM­
10
standard.

While
all
valid
ambient
air
quality
data
should
be
submitted
to
EPA
via
the
Air
Quality
System
(
AQS)
database
for
use
in
making
regulatory
decisions,
Appendices
K,
I,
and
N
provide
that
in
some
cases
it
may
be
appropriate
for
the
Regional
Administrator
to
discount,
weight,
or
make
adjustments
to
the
data
that
has
been
appropriately
flagged
in
the
AQS
database
from
calculations
in
determining
whether
an
area
has
attained
the
standard
or
not.
These
decisions
are
to
be
made
on
a
case
by
case
basis
using
all
available
information
related
to
the
event
in
question,
and
should
be
made
available
to
the
public
for
review.
In
order
to
make
sure
that
decisions
concerning
the
discounting
of
data
for
regulatory
purposes
are
handled
in
a
consistent
manner,
affected
air
quality
agencies
are
encouraged
to
follow
the
guidance
in
this
document,
as
well
as
other
related
guidance
documents
in
making
decisions
concerning
how
to
handle
air
quality
data
determined
to
be
affected
by
exceptional
or
natural
events.

Section
2
What
are
the
goals
of
this
Policy?

This
policy
applies
to
the
Particulate
Matter
standards,
and
relates
to
measured
concentrations
determined
to
be
impacted
by
exceptional
or
natural
events.
The
policy
addresses
concentrations
of
Particulate
Matter
which
may
adversely
impact
public
health,
prevent
affected
areas
from
meeting
the
NAAQS,
or
cause
a
misinterpretation
of
the
data
related
to
whether
an
area
is
meeting
the
NAAQS.
The
goals
of
this
policy
are:
(
1)
to
identify
reasonable
actions
that
should
be
taken
to
address
the
air
quality
and
public
health
impacts
caused
by
these
types
of
events,
and
(
2)
to
avoid
imposing
unreasonable
planning
requirements
on
States
related
to
traditional
sources
of
Particulate
Matter
in
such
areas.

This
document
provides
general
definitions
of
exceptional
and
natural
events
and
provides
DRAFT
­­
DO
NOT
QUOTE
or
CITE
3
4
Data
flagged
as
due
to
an
exceptional
or
natural
event
may
be
discounted
on
a
case
by
case
basis,
depending
on
a
concurrence
by
the
Regional
Office,
which
will
be
based
on
the
documentation
submitted
by
the
reporting
agency
to
substantiate
the
exceptional
or
natural
events
claim.
If
the
Regional
Office
provides
a
concurrence
on
the
event
flag
in
the
AQS
database
the
data
will
be
discounted
when
calculating
the
design
value
for
the
area.
The
data
may
also
be
discounted
for
the
design
value
calculation
for
an
area
in
conjunction
with
other
EPA
guidance,
such
as
the
"
Clean
Data
Policy",
or
the
"
Limited
Maintenance
Plan
Option",
where
applicable
for
a
pollutant.
guidance
concerning
what
actions
should
be
taken
in
the
event
that
data
at
an
air
quality
monitoring
site
are
determined
to
be
impacted
by
such
events.

General
guidance
will
be
provided
in
this
document
that
will
allow
State,
local,
and
Tribal
air
quality
agencies
to
flag
data
appropriately
in
the
AQS
database
that
is
determined
to
be
affected
by
emissions
from
one
or
more
of
the
events
addressed
in
this
document.
For
the
purpose
of
this
document
exceptional
and
natural
events
are
defined
as
follow:

1.
Exceptional
event:
An
event
that
is
not
expected
to
occur
routinely
at
a
given
location,
or
that
is
determined
not
to
be
reasonably
controllable
or
preventable,
but
is
determined
to
have
caused
or
significantly
contributed
to
an
exceedance
or
violation
of
the
NAAQS.

2.
Natural
event:
An
event
that
is
caused
by
an
act
of
nature
and
is
determined
to
have
caused
or
significantly
contributed
to
an
exceedance
or
violation
of
the
NAAQS.

The
policy
described
in
this
document
addresses
Particulate
Matter
NAAQS
exceedances
or
violations
that
have
been
caused
by
either
exceptional
or
natural
events
in
areas
that
are
designated
as
nonattainment,
attainment,
or
unclassifiable4.
This
policy
applies
at
the
time
that
the
State
makes
a
determination
that
a
Particulate
Matter
NAAQS
has
been
violated
due
to
one
or
more
of
the
aforementioned
types
of
events
and
addresses
the
question
of
what
should
be
done
to
protect
public
health.
The
policy
provides
that
EPA
will:
(
1)
exercise
its
discretion
under
section
107(
d)(
3)
to
not
redesignate
areas
as
nonattainment
or
reclassify
existing
nonattainment
areas
to
higher
classifications
where
one
of
these
types
of
events
has
significantly
impacted
a
monitoring
site
and
caused
an
exceedance
or
violation
of
a
NAAQS
provided
that
the
State
formally
commits
to
the
development
of
a
plan
to
address
public
health
impacts
related
to
the
event,
(
2)
where
exceptional
or
natural
events
are
concerned
EPA
agrees
to
use
its
discretion
not
to
redesignate
an
area
as
nonattainment,
or
reclassify
an
existing
nonattainment
area
by
discounting
the
data
from
regulatory
consideration
if
the
State
provides
adequate
and
compelling
documentation
to
substantiate
the
exceptional
or
natural
event
claim
by
applying
Appendix
N
related
to
the
Particulate
Matter
standards.
DRAFT
­­
DO
NOT
QUOTE
or
CITE
4
5
The
annual
PM­
2.5
standard
is
met
when
the
3
year
average
annual
mean
concentration
is
less
than
or
equal
to
15.0
ug/
m3.
The
24
hour
standard
for
PM­
2.5
is
met
when
the
3
year
average
of
the
98th
percentile
values
at
each
monitoring
site
is
less
than
or
equal
to
65
ug/
m3.
If
natural
events
cause
the
annual
standard
not
to
be
met,
only
one
Natural
Events
Action
Plan
(
NEAP)
will
be
required
for
the
area
to
cover
both
the
annual
and
the
24
hour
standard.
This
guidance
also
attempts
to
maintain
some
of
the
traditional
delineations
of
episodic
event
types,
such
as
chemical
spills
and
clean
up
activities
after
a
major
disaster,
yet
focuses
treatment
of
such
data
according
to
the
predictability
and
controllability
of
the
event
in
question.
For
instance,
for
an
event
that
can
reasonably
be
anticipated,
but
which
is
not
expected
to
recur
at
the
same
location,
the
State,
local,
or
Tribal
agency
will
be
expected
to
develop
a
plan
to
mitigate
the
risks
of
public
exposure
related
to
the
event.
For
an
event
that
can
not
reasonably
be
anticipated,
and
which
is
unlikely
to
recur
at
the
same
location
(
e.
g.,
A
major
disaster,
industrial
accidents,
or
chemical
spills
etc..),
the
guidance
requires
a
post­
event
action
plan
to
ensure
prompt
clean­
up
of
debris
related
to
the
event
and
calls
for
measures
to
be
taken
that
will
mitigate
the
impact
of
the
event
on
the
public.
For
events
that
may
recur,
yet
may
not
be
fully
controllable
(
e.
g.,
international
transport),
the
guidance
requires
that
reasonable
action
be
taken
to
address
local
sources
where
appropriate,
as
well
as
to
inform
the
public
and
mitigate
the
impact
of
such
events
on
public
health.

In
cases
where
a
State,
local,
or
Tribal
agency
has
taken
action
to
adopt
and
implement
plans
intended
to
address
exceptional
and
natural
events,
EPA
will
take
this
information
into
consideration
in
making
decisions
to
discount
data
affected
by
these
types
of
events.

The
guiding
principles
that
were
followed
in
the
development
of
this
policy
are
the
following:

1.
Protection
of
public
health
is
the
highest
priority
of
Federal,
State,
Tribal,
and
local
air
pollution
control
agencies.

2.
The
public
must
be
informed
whenever
the
air
quality
in
an
area
is
unhealthy.

3.
All
valid
ambient
air
quality
data
should
be
submitted
to
the
EPA
AQS
and
made
available
for
public
access.

4.
State,
local,
and
Tribal
air
quality
agencies
must
take
appropriate
and
reasonable
measures
to
safeguard
public
health
regardless
of
the
source
of
the
Particulate
Matter
emissions.

5.
Emission
controls
should
be
applied
to
sources
that
contribute
to
exceedances
or
violations
of
the
Particulate
Matter
NAAQS
when
the
controls
will
result
in
fewer
exceedances
or
violations
of
the
standards.
5
Section
3
DRAFT
­­
DO
NOT
QUOTE
or
CITE
5
Purpose
and
Management
of
Flagging
Data
in
the
AQS
Database
The
principal
purpose
of
the
data
flagging
system
in
the
AQS
database
is
to
identify
those
air
quality
measurements
that
are
influenced
by
either
exceptional
or
natural
events.
These
are
events
which,
if
unidentified,
could
lead
to
possible
misinterpretation
or
misuse
of
data.
If
a
particular
air
quality
measurement
is
influenced
by
an
exceptional
or
natural
event
it
is
important
that
those
who
may
review
and
ultimately
use
it
to
be
aware
of
this
influence
and
ensure
that
such
data
are
not
misinterpreted
or
misused.
Knowledge
and
understanding
of
what
the
data
represent
are
critical
in
the
overall
air
quality
planning
process.

Under
the
data
flagging
system
State,
local,
and
Tribal
air
pollution
control
agencies
are
responsible
for
identifying
and
documenting
data
that
is
believed
to
be
influenced
by
exceptional
or
natural
events.
These
agencies
are
also
expected
to
develop
the
appropriate
background
information
that
is
to
be
used
to
support
the
decision
to
flag
an
individual
piece
of
data.
These
agencies
are
also
expected
to
submit
the
information
documenting
the
event
to
the
appropriate
EPA
Regional
Office
for
concurrence
and
make
it
available
for
public
review.
Because
of
the
potential
implications
related
to
the
use
of
flagged
data,
the
agency
that
is
flagging
the
data
must
demonstrate
that
there
is
a
clear
causal
relationship
between
the
event
in
question
and
the
air
quality
data
that
is
being
flagged.
It
is
not
sufficient
to
merely
show
that
an
event
occurred.
The
reporting
agency
must
demonstrate
compellingly
that
the
event
occurred
and
that
it
caused
or
significantly
contributed
to
the
data
being
contested
at
the
monitoring
site
in
question.

Section
4
Uses
of
flagged
data
4.1
General
Guidelines
On
The
Use
Of
Flagged
Data
A
general
concern
on
the
part
of
States,
local,
and
Tribal
air
quality
agencies
is
the
potential
for
misuse
of
data
affected
by
exceptional
and
natural
events.
This
concern
has
prompted
EPA
to
develop
the
criteria
in
this
document
to
help
determine
what
actions
should
be
taken
if
air
quality
data
is
determined
to
be
significantly
affected
by
one
or
more
of
these
types
of
events.
This
document
requires
State,
local,
and
Tribal
air
quality
agencies,
as
well
as
EPA,
to
identify
and
explain
the
use,
or
the
non­
use,
of
data
determined
to
be
influenced
by
exceptional
or
natural
events
during
a
public
review
process.

In
general,
decisions
concerning
the
use
or
non­
use
of
flagged
data
will
be
made
on
a
case­
by­
case
basis,
and
the
public
must
be
informed
that
the
data
exist,
whether
the
data
are
used
in
regulatory
decisions
or
not.
The
main
concern
related
to
this
issue
lies
with
the
understanding
of
what
the
flagged
data
represent.
Four
steps
should
be
taken
in
order
to
decide
whether
questionable
data
should
be
flagged,
and
to
assist
potential
users
in
determining
how
the
data
should
be
used.
The
first
step
is
to
determine
whether
the
measured
value
at
the
monitoring
site
DRAFT
­­
DO
NOT
QUOTE
or
CITE
6
in
question
is
attributed
to
the
event
under
consideration.
The
second
step
is
to
determine
what
portion
of
the
measured
air
quality
level
is
attributable
to
the
event
in
question,
as
well
as
the
cumulative
effect
of
several
similar
exceptional
or
natural
events
that
create
significant
impacts
at
particular
monitoring
sites.
In
some
cases,
modeling
(
either
source
apportionment
or
dispersion)
or
other
procedures
may
be
used
to
determine
the
relative
contribution
of
the
event
in
question.
The
relative
contribution
of
the
event
provides
a
better
understanding
of
what
the
air
quality
level
of
the
day,
or
days
in
question,
actually
represent.

The
third
step
is
to
identify
the
area
that
has
been
influenced
by
the
event.
In
most
cases,
the
impact
will
be
limited.
Therefore,
if
the
data
are
being
considered
for
either
use
in
or
discounting
from
the
regulatory
process,
the
reporting
agency
is
required
to
identify
the
area
that
would
be
influenced
by
the
determination.

The
fourth
step
is
to
demonstrate
how
the
flagged
data
relates
to
previously
collected
data
at
the
monitoring
site
in
question.
This
is
required
in
order
to
provide
an
historical
perspective
related
to
the
concentration
levels
at
the
monitoring
site,
as
well
as
the
types
of
sources
that
normally
contribute
to
impacts
at
the
monitor.
This
step
is
extremely
critical
for
trends
analyses
and
for
determining
the
exceptional
nature,
recurrent
nature,
the
frequency
of
the
event
in
question,
as
well
as
for
preparation
of
reports
to
the
public
on
air
quality
levels
for
a
given
area.
If
flagged
data
are
used
or
discounted
in
preparing
summaries
of
air
quality
data,
the
public
should
be
made
aware
of
how
the
data
were
used.

4.2
Use
Of
Air
Quality
Data
For
NAAQS
Compliance
The
NAAQS
compliance
status
involves
the
use
of
air
quality
data
to
determine
whether
the
area
represented
by
the
data
is
meeting
or
exceeding
the
NAAQS
for
the
pollutant
being
monitored.
It
is
EPA's
policy,
and
a
regulatory
requirement,
to
submit
valid
data
(
i.
e.,
data
collected
in
accordance
with
40
CFR
Part
58)
to
the
AQS
database.
All
data,
flagged
or
unflagged,
should
be
available
to
the
public
for
comparison
to
the
NAAQS
to
determine
if
exceedances
have
occurred.
All
relevant
flagged
data
along
with
the
reasons
for
the
data
being
flagged,
and
a
demonstration
of
causality
between
the
event
in
question
and
the
flagged
data,
is
required
to
be
submitted
for
consideration
of
use/
non­
use
during
the
public
hearing
or
comment
period
called
for
under
sections
107,
110­
113,
119,
120,
122,
123,
126,
Part
C
or
Part
D
of
the
Clean
Air
Act
(
CAA).

4.3
State
Implementation
Plan
(
SIP)
Regulatory
Activities
The
use
of
flagged
air
quality
data
for
SIP
regulatory
activities
(
area
wide,
regional,
or
local
control
strategy
development,
SIP
design
values,
attainment/
non­
attainment
status,
enforcement
actions,
etc.)
shall
be
considered
on
a
case­
by­
case
basis
and
discussed
during
the
public
review
process.
The
discounting
of
the
flagged
data
for
regulatory
purposes
would
only
be
allowed
if
the
reporting
agency
determines
in
conjunction
with
a
public
review
that
the
flagged
data
are
inappropriate
for
such
use.
In
cases
where
the
implementation
of
control
measures
would
be
appropriate
and
meaningful,
the
State,
local,
or
Tribal
air
quality
agency
should
consult
DRAFT
­­
DO
NOT
QUOTE
or
CITE
7
6
A
State,
local,
or
Tribal
air
quality
agency
may
also
flag
data
determined
to
be
affected
by
exceptional
or
natural
events
that
is
below
the
standard
where
there
is
a
determination
that
the
data
may
later
have
an
impact
on
the
annual
standard
for
either
PM2.5
or
PM10­
2.5.
The
reporting
agency
must,
however,
provide
adequate
documentation
which
shows
that
the
event
occurred
and
that
the
event
either
caused
or
significantly
contributed
to
the
measured
value
under
consideration.
The
appropriate
Regional
Office
is
required
to
make
a
determination
that
the
documentation
provided
is
adequate
enough
to
substantiate
the
exceptional
or
natural
event
claim.
current
EPA
guidance
for
Particulate
Matter,
as
well
as
the
appropriate
EPA
Regional
Office,
to
determine
what
measures
would
be
appropriate
to
properly
control
the
sources
that
are
determined
to
contribute
to
the
exceptional
or
natural
event
in
question.

Section
5
Submittal
of
documentation
related
to
flagged
data
5.1
Requirement
to
Provide
Adequate
And
Compelling
Documentation
Of
Exceptional
Or
Natural
Events
In
circumstances
where
a
State,
local,
or
Tribal
air
quality
agency
has
reason
to
believe
that
an
exceptional
or
natural
event
has
caused
or
significantly
contributed
to
measured
exceedances
or
a
violation
of
the
Particulate
Matter
NAAQS,
the
State
is
responsible
for
establishing
a
clear
causal
relationship
between
the
measured
exceedance
or
violation
and
the
event
in
question6.
Supporting
documentation
concerning
the
event
should
include,
but
is
not
limited
to
some
of
the
following
types
of
information:
trajectory
analysis,
filter
analysis,
meteorological
data
(
e.
g.,
wind
speed
and
wind
direction
to
support
a
source
receptor
relationship),
modeling
and
source
receptor
analysis,
videos
and/
or
photographs
of
the
event
and
the
resulting
emissions,
satellite
images
of
the
event,
maps
of
the
area
showing
sources
of
emissions
and
the
area
affected
by
the
event,
as
well
as
news
accounts
of
the
event.

The
type
and
degree
of
documentation
provided
for
an
event
should
be
sufficient
to
demonstrate
compellingly
that
the
event
occurred,
and
that
it
impacted,
and
caused
or
significantly
contributed
to
the
measured
values
under
consideration
at
a
particular
monitoring
site.
The
State,
local,
or
Tribal
air
quality
agency
should
also
make
sure
that
the
documentation
related
to
the
event
in
question
is
made
available
for
public
review.
This
may
be
accomplished
in
a
number
of
ways
such
as
the
publishing
of
newspaper
announcements
related
to
the
event,
or
other
news
media,
periodic
reports
on
air
quality
in
the
area,
and
through
public
hearings.
This
would
allow
the
public
an
opportunity
to
comment
on
whether
the
causal
relationship
between
the
event
and
the
air
quality
measurement
is
compelling
and
whether
the
data
should
be
discounted
or
not.
Also,
open
hearings,
where
State,
local,
and
Tribal
regulatory
boards
can
review
the
documentation
are
useful
forums
to
notify
the
public
of
potentially­
important
policy
decisions
concerning
the
event.
DRAFT
­­
DO
NOT
QUOTE
or
CITE
8
7
In
cases
where
the
Regional
Office
has
requested
that
additional
information
be
provided
and
the
reporting
agency
does
not
provide
the
additional
documentation
related
to
the
event
within
the
time
period
identified
in
this
guidance,
the
Regional
Office
may
take
action
to
nonconcur
on
the
flag
in
the
AQS
database
and
inform
the
reporting
agency
that
a
decision
to
provide
a
nonconcurrence
on
the
data
has
been
made.
The
term
concurrence
means
that
the
Regional
Office
has
reviewed
the
documentation
submitted
by
the
reporting
agency
and
has
provided
an
indication
that
the
Regional
Office
agrees
that
the
data
under
consideration
should
be
provided
special
consideration
for
regulatory
purposes
due
to
influence
from
an
exceptional
or
natural
event.
Where
a
Regional
Office
has
provided
an
nonconcurrence,
this
means
that
the
Regional
Office
does
not
agree
with
the
State's
claim
that
the
data
has
been
influenced
by
an
exceptional
or
natural
event,
and
that
the
data
should
not
be
afforded
special
consideration
for
regulatory
purposes.
In
order
to
promote
consistency
related
to
the
implementation
of
the
policy,
in
cases
where
there
is
a
dispute
concerning
a
decision
to
concur
or
nonconcur
on
a
flag
in
the
AQS
database,
either
the
reporting
agency
or
the
Regional
Office
may
consult
the
appropriate
OAQPS
program
office
for
a
resolution
of
the
issue.
When
air
quality
data
affected
by
an
exceptional
or
natural
event
are
submitted
to
the
AQS
database,
the
State,
local,
or
Tribal
air
quality
agency
must
request
that
a
flag
be
placed
on
the
data
to
indicate
that
either
an
exceptional
or
natural
event
was
involved
and
that
the
data
should
be
provided
special
consideration.
Documentation
to
support
the
flagged
data
must
also
be
maintained
by
the
State.
A
copy
of
the
documentation
must
be
forwarded
to
the
appropriate
EPA
Regional
Office
no
later
than
60
days
following
the
end
of
the
quarter
in
which
the
event
occurred.
In
cases
where
the
reporting
agency
determines
that
additional
time
is
required
to
submit
the
supporting
documentation
related
to
the
event
in
question,
the
reporting
agency
must
contact
the
appropriate
Regional
Office
to
request
an
extension
of
the
reporting
period
up
to
an
additional
30
days.
The
documentation
submitted
by
the
State
must
also
be
made
available
on
the
AQS
website
by
the
appropriate
Regional
Office.
The
Regional
Office
is
then
responsible
for
providing
acknowledgment
to
the
State
related
to
the
receipt
of
the
documentation
and
confirm
that
the
data
was
concurred
or
non­
concurred
on
within
60
days
following
the
receipt
of
the
documentation
from
the
State.
The
Regional
Office
may
extend
the
period
for
providing
concurrence
on
the
flag
in
the
database
by
a
period
of
no
more
than
30
days,
if
there
is
a
determination
that
there
is
insufficient
documentation
to
make
a
decision
to
concur
or
nonconcur
on
the
flag
related
to
the
event.
The
Regional
Office
in
this
time
period
may
request
additional
information
from
the
State
to
further
substantiate
the
claim
related
to
the
event.
The
State
will
then
have
a
period
of
30
days
to
submit
the
additional
information
requested
by
the
Regional
Office.
Once
the
Regional
Office
receives
the
information
requested
from
the
State,
the
Regional
Office
will
then
have
30
days
to
provide
a
concurrence
or
nonconcurrence
on
the
data.
7
In
order
to
assure
that
prompt
action
is
taken
related
to
data
that
has
been
flagged
in
the
AQS
database,
it
is
important
that
the
time
periods
specified
be
adhered
to
by
both
the
reporting
agency
as
well
as
the
affected
Regional
Office.

Section
6
DRAFT
­­
DO
NOT
QUOTE
or
CITE
9
8
This
policy
can
also
be
applied
in
Tribal
territory
where
a
tribe
is
authorized
to
manage
its
air
quality
programs.
The
policy
also
applies
in
Tribal
areas
where
Tribes
do
not
have
authority
under
the
Tribal
Authority
Rule
(
TAR).

9
The
annual
PM2.5
standard
is
met
when
the
3­
year
average
of
the
spatially
averaged
annual
means
is
less
than
or
equal
to
15.0
:
g/
m3.
The
24­
hour
PM2.5
standard
is
met
when
the
3­
year
average
of
the
98th
percentile
values
at
each
monitoring
site
is
less
than
or
equal
to
65
:
g/
m3.
If
natural
events
cause
the
annual
NAAQS
to
not
be
met,
one
NEAP
for
the
area
will
cover
both
the
24­
hour
and
annual
NAAQS
for
PM.
Natural
Events
6.1
The
Natural
Events
Covered
By
This
Policy
8
This
policy
applies
to
data
affected
by
a
natural
event
at
a
Particulate
Matter
monitoring
site
where
it
has
been
determined
that
concentrations
due
to
the
event(
s)
have
caused
or
significantly
contributed
to
the
NAAQS
not
being
met
for
an
area.
9
The
policy
applies
to
three
specific
categories
of
natural
events
that
can
affect
air
quality,
as
well
as
the
attainment,
or
maintenance
of
the
Particulate
Matter
NAAQS.
The
events
covered
by
this
policy
are:
(
1)
volcanic
and
seismic
actives,
(
2)
high
wind
events,
and
(
3)
unwanted
or
wild
fires.
Exceedances
or
violations
of
the
Particulate
Matter
NAAQS
due
to
natural
events
that
are
international
in
origin
may
also
be
considered
under
this
policy
for
discounting
data
from
regulatory
consideration
if
the
reporting
agency
provides
compelling
documentation
which
sufficiently
demonstrates
that
the
event
caused
or
significantly
contributed
to
the
measured
concentrations
at
the
monitoring
site
in
question.

6.2
Volcanic
And
Seismic
Activities:

Ambient
concentrations
of
Particulate
Matter
for
which
volcanic
eruptions
or
seismic
activity
caused
or
significantly
contributed
to
high
levels
of
Particulate
Matter
in
an
affected
area
will
be
treated
as
natural
events.
While
not
occurring
frequently,
volcanic
and
seismic
activity
can
affect
air
quality
data
related
to
the
Particulate
Matter
NAAQS
for
an
extended
period
of
time
after
an
event.
Volcanic
eruptions
contribute
to
ambient
concentrations
in
two
ways:
(
1)
concentrations
due
to
primary
emissions
(
e.
g.,
ash),
and
(
2)
with
emissions
of
precursor
pollutants
(
e.
g.,
sulfur
dioxide)
that
contribute
to
the
secondary
formation
of
Particulate
Matter.
Seismic
activity
(
e.
g.,
earthquakes)
can
also
contribute
to
ambient
Particulate
Matter
concentrations
by
shaking
the
ground,
causing
structures
to
collapse
and
otherwise
raising
dust.

Emissions
attributed
to
anthropogenic
activities
that
re­
entrain
volcanic
ash
during
the
first
year
(
12
months)
following
an
event
will
be
treated
as
due
to
the
natural
event.
One
year
is
considered
an
adequate
amount
of
time
for
cleaning
ash
deposits
from
areas
where
anthropogenic
activities
(
e.
g.,
vehicle
traffic)
may
cause
re­
entrainment
and
possible
exceedances
of
the
Particulate
Matter
standards.
After
a
year,
however,
exceedances
or
violations
due
to
reentrainment
of
ash
deposits
will
not
be
provided
special
consideration
under
this
policy.
DRAFT
­­
DO
NOT
QUOTE
or
CITE10
10
The
EPA
recognizes
and
endorses
the
Federal
Wildland
Fire
Management
Policies
adopted
by
the
Departments
of
Interior
and
Agriculture.
These
policies
refer
to
all
fires
on
sparsely
populated
lands
managed
by
Federal
agencies
(
e.
g.,
national
parks,
national
forests,
grasslands,
etc.)
as
wildland
fires.
The
wildland
fires
term
includes
unwanted
fires
that
do
not
meet
a
prescription
(
wildfires),
management­
ignited
prescribed
fires,
and
naturally­
ignited
fires
that
meet
a
prescription
(
prescribed
natural
fire).
6.3
Unwanted
or
Wild
Fires:

Ambient
Particulate
Matter
concentrations
caused
by
smoke
from
wildland
fires
will
be
treated
as
due
to
natural
events
if
the
fires
are
determined
to
be
unwanted
fires,
not
designated
or
managed
as
prescribed
fires,
and
requiring
appropriate
suppression
action
by
a
wildland
manager.
10
For
the
purpose
of
this
document,
wildland
fire
natural
events
are
limited
to
unwanted
fires
that
do
not
meet
a
prescription
(
wildfires)
and,
therefore,
require
appropriate
suppression
actions.
Wildland
prescribed
fires,
the
burning
of
forest,
harvest
residues,
agricultural
burning,
and
fires
for
land
clearing
are
not
covered
by
this
policy.
Treatment
of
air
quality
data
affected
by
emissions
from
wildland
and
prescribed
fires
that
are
managed
to
achieve
resource
benefits
is
covered
under
EPA's
"
Interim
Air
Quality
Policy
on
Wildland
Prescribed
Fires,
issued
May
15,
1998".

The
"
Interim
Air
Quality
Policy
on
Wildland
and
Prescribed
Fires"
was
developed
to
address
the
impacts
of
air
pollutant
emissions
related
to
fires
which
are
managed
for
resource
benefits
where
the
State,
local,
or
Tribal
air
quality
agency
has
taken
action
to
mitigate
the
impact
of
the
fires
on
public
health
and
welfare
as
it
relates
to
impacts
on
the
Particulate
Matter
NAAQS.
The
policy
provides
that
EPA
will
allow
State,
local,
and
Tribal
air
quality
agencies
flexibility
related
to
their
approach
to
regulating
fires
managed
for
resource
benefits
if
the
agencies
certify
that
they
have
adopted
and
are
implementing
a
certified
Smoke
Management
Plan
(
SMP)
as
required
under
the
policy.
If
a
State,
local,
or
Tribal
air
quality
agency
does
not
certify
that
a
basic
SMP
is
being
implemented,
as
required
under
the
policy,
no
special
consideration
will
be
granted
by
EPA
related
to
exceedances
or
violations
attributed
to
fires
managed
for
resource
benefits.

6.4
High
Wind
Events:

High
wind
events
that
affect
ambient
Particulate
Matter
concentrations
due
to
dust
raised
by
unusually
high
winds
will
be
treated
as
due
to
natural
events
under
the
following
conditions:
(
1)
the
dust
originated
from
nonanthropogenic
sources,
or
(
2)
the
dust
originated
from
land
that
was
disturbed
by
anthropogenic
activities
where
the
State,
local,
or
Tribal
air
quality
agency
has
implemented
what
is
determined
to
be
Best
Available
Control
Measures
(
BACM)
for
the
affected
DRAFT
­­
DO
NOT
QUOTE
or
CITE11
11
In
cases
where
a
State,
local,
or
Tribal
agency
has
adopted
and
implemented
BACM
level
controls
on
anthropogenic
sources
determined
to
be
affected
by
a
high
wind
event,
and
the
event
has
over
powered
the
controls
to
cause
or
significantly
contribute
to
an
exceedence
or
violation
of
the
Particulate
Matter
standard,
EPA
will
apply
this
policy
to
discount
the
data
from
regulatory
consideration.
However,
the
State,
local,
or
Tribal
air
quality
agency
must
document
that
the
controls
were
in
place
and
being
implemented,
and
being
complied
with,
at
the
time
that
the
event
in
question
occurred.
In
making
a
determination
concerning
what
is
considered
to
be
BACM
for
a
particular
anthropogenic
source,
the
State,
local,
or
Tribal
air
quality
agency
should
consult
current
EPA
guidance,
as
well
as
the
affected
Regional
Office.
In
some
cases
the
BACM
level
control
for
a
particular
source
may
be
identified
as
Reasonable
Available
Control
Measures
(
RACM).
sources
consistent
with
current
EPA
guidance.
11
The
conditions
that
create
fugitive
dust
emissions
from
high
wind
events
vary
from
area
to
area
with
soil
type,
precipitation,
and
wind
speeds.
Therefore,
the
reporting
agency
must
determine
the
unusually
high
wind
conditions
that
act
to
overcome
BACM
for
the
affected
anthropogenic
sources
in
each
region
or
subregion
of
the
State.
The
reporting
agency
is
encouraged
to
consult
the
appropriate
Regional
Office
in
making
this
determination.
The
reporting
air
quality
agency
should
also
provide
supporting
documentation
which
shows
that
the
average
wind
speeds
experienced
on
the
day
or
days
that
the
measured
values
in
question
were
recorded
were
unusual
and
untypical
for
the
area
during
the
period
under
consideration.
A
presumptive
high
wind
speed
is
not
established
under
this
policy,
as
was
identified
in
the
Guideline
on
the
Identification
and
Use
of
Air
Quality
Data
Affected
by
Exceptional
Events,
(
Exceptional
Events
Guideline,
EPA­
450/
4­
86­
007,
July
1986).
States
should
provide
appropriate
documentation
to
show
that
the
high
winds
experienced
at
the
monitoring
site
in
question
were
indeed
unusual
for
the
affected
area.

The
BACM
must
be
implemented
at
contributing
anthropogenic
dust
sources
in
order
for
Particulate
Matter
NAAQS
exceedances
to
be
provided
special
consideration
as
due
to
natural
events
under
this
policy.
Therefore,
BACM
level
controls
must
be
implemented
for
anthropogenic
dust
sources
contributing
to
NAAQS
exceedances
or
violations
in
attainment,
unclassifiable,
and
nonattainment
areas.
The
EPA
will
use
its
flexibility
not
to
redesignate
areas
as
nonattainment
where
anthropogenic
sources
have
contributed
to
an
exceedance
or
violation
of
the
Particulate
Matter
NAAQS
where
a
natural
event
was
involved,
if
the
reporting
State,
local,
or
Tribal
air
quality
agency
formally
commits
to
implement
BACM
at
the
contributing
anthropogenic
sources.

In
attainment
and
unclassifiable
areas,
the
BACM
level
controls
must
be
implemented
for
all
contributing
anthropogenic
sources
related
to
a
high
wind
event
within
3
years
of
the
first
NAAQS
violation.
The
EPA
will
also
exercise
its
authority
not
to
reclassify
an
existing
nonattainment
area
to
a
higher
classification
if
the
State,
local,
or
Tribal
agency
commits
to
implement
BACM
level
controls
within
3
years
of
the
first
NAAQS
violation.
In
these
areas,
BACM
level
controls,
however,
should
be
implemented
as
expeditiously
as
practicable
for
all
DRAFT
­­
DO
NOT
QUOTE
or
CITE12
contributing
sources
related
to
the
event
in
question.
The
conditions
that
create
high
wind
events
vary
form
area
to
area
with
soil
type,
precipitation
and
the
speed
of
wind
gusts.
Therefore,
as
stated
previously,
the
State
must
determine
the
unusually
high
wind
conditions
that
will
overcome
BACM
for
anthropogenic
sources
in
each
region
or
subregion
of
the
State.

The
State
must
also
provide
compelling
documentation
to
the
appropriate
Regional
Office
concerning
the
flagged
event.
This
documentation
must
demonstrate
that
the
event
occurred
and
that
the
event
caused
or
significantly
contributed
to
the
exceedance
or
violation
measured
at
the
affected
monitoring
site.

6.5
Response
To
NAAQS
Violations
Due
To
Natural
Events.

If
an
area
fails
to
meet
a
NAAQS
because
one
or
more
Particulate
Matter
values
has
been
affected
by
a
natural
event,
the
State
is
required
to
develop
a
NEAP
to
address
future
events
within
18
months
of
the
NAAQS
violation.
A
NEAP
should:

1.
Establish
public
notification
and
education
programs.
Such
programs
may
be
designed
to
educate
the
public
about
the
short­
term
and
long­
term
harmful
effects
that
high
concentrations
of
Particulate
Matter
may
have
on
public
health
and
inform
the
public
that:
(
a)
certain
types
of
natural
events
affect
the
air
quality
of
the
area
periodically,
(
b)
a
natural
event
is
imminent,
and
(
c)
specific
actions
are
being
taken
to
minimize
the
public
health
impacts
of
the
events.

2.
Minimize
public
exposure
to
high
concentrations
of
Particulate
Matter
due
to
future
natural
events.
Programs
to
minimize
public
exposure
should:
(
a)
identify
the
people
most
at
risk,
(
b)
notify
the
at­
risk
population
that
a
natural
event
is
imminent
or
currently
taking
place,
(
c)
suggest
actions
to
be
taken
by
the
public
to
minimize
their
exposure
to
high
concentrations
of
Particulate
Matter,
and
(
d)
suggest
precautions
that
should
be
taken
if
exposure
cannot
be
avoided.

3.
Abate
or
minimize
appropriate
contributing
controllable
sources.
Programs
to
minimize
Particulate
Matter
emissions
may
include
the
following:

(
a)
volcanic
and
seismic
activities
­
cleaning
ash
and
dust
deposits
from
areas
where
it
would
be
re­
entrained
into
the
air
by
anthropogenic
activities;

(
b)
unwanted
or
wild
fires
­
prohibition
of
other
burning
activities
during
wild
fire
events
and
steps
to
minimize
fuel
loadings
in
areas
vulnerable
to
fire.
Appropriate
suppression
actions,
as
determined
by
the
wildland
manager,
should
consider
the
air
DRAFT
­­
DO
NOT
QUOTE
or
CITE13
12
The
FMP
will
integrate
fire,
as
a
natural
ecological
process,
into
land
and
resource
management
plans
and
will
form
the
basis
for
management
actions
taken
on
wildland
fires.
The
FMP
must
include
prescriptions
for
any
use
of
fire
to
meet
land
and
resource
management
objectives.
The
EPA
anticipates
that
FMPs
will
achieve
an
acceptable
balance
between
forest
health
and
public
health
concerns.
Public
health
concerns
caused
by
the
potential
effects
of
smoke
on
air
quality
from
wildland
fires
will
be
addressed
in
FMP
through
SMP
and
other
measures.
The
SMPs
attempt
to
minimize
smoke
impacts
by
monitoring
fire
behavior,
meteorology
and
air
quality
during
the
fire
and
by
publicly
announcing
forecasts
of
likely
smoke
conditions
in
communities
impacted
by
ongoing
fires.
Since
the
FMP
will
treat
fire
as
a
natural
ecological
process,
the
impact
of
wildland
fires
on
air
quality
and
regional
haze
is
expected
to
increase
in
the
future.
Therefore,
EPA
will
encourage
Federal
land
management
agencies
to
support
air
quality
monitoring
near
fires,
to
assess
air
and
haze
impacts,
and
to
develop
a
fire
information
data
base
and
regional­
scale
smoke
management
plans.
quality
impacts
caused
by
the
fires.
The
Federal
Wildland
Fire
Management
Policies
require
that
fire
management
plans
(
FMP)
be
developed
for
all
Federal
lands
with
burnable
vegetation.
12
A
goal
of
an
FMP
is
to
prevent
NAAQS
violations
caused
by
wildland
fires.

(
c)
High
winds
­
application
of
the
BACM
level
of
controls
to
any
source
of
soil
that
has
been
disturbed
by
anthropogenic
activities.
Application
of
BACM
level
of
control
measures
for
an
anthropogenic
source
requires
an
analysis
of
the
technological
and
economic
feasibility
of
individual
control
measures
on
a
case­
by­
case
basis.
The
NEAP
should
include
analyses
of
these
types
of
controls
for
contributing
sources.
Controls
must
be
implemented
for
anthropogenic
dust
sources
contributing
to
NAAQS
exceedances
in
attainment
and
unclassifiable
areas
and
in
nonattainment
areas.
In
unclassifiable,
attainment,
and
nonattainment
areas,
control
measures
must
be
implemented
for
those
contributing
sources
for
which
it
has
been
defined
within
3
years
of
the
first
NAAQS
violation
which
is
attributed
to
high
wind
events.
In
any
case,
the
State,
local,
or
Tribal
agency
should
implement
BACM
as
expeditiously
as
practicable
in
order
to
provide
prompt
protection
of
public
health.
The
control
measures
which
may
be
implemented
related
to
windblown
dust
include,
but
are
not
limited
to
the
application
of
chemical
dust
suppressants
to
unpaved
roads,
parking
lots
and
open
areas;
dust
suppression
at
construction
sites;
use
of
conservation
farming
practices
on
agricultural
lands;
tree
rows
and
other
physical
wind
breaks;
restricting
or
prohibiting
recreational
off­
road
vehicle
activities;
and
use
of
surface
coverings.
If
control
measures
are
not
defined
for
the
anthropogenic
sources
in
question,
step
4
listed
below
is
required.
DRAFT
­­
DO
NOT
QUOTE
or
CITE14
If
control
measures
are
not
yet
required
for
some
dust
sources,
the
State,
local,
or
Tribal
agency
is
required
to
reach
agreements
with
the
appropriate
stakeholders
to
minimize
future
emissions
from
such
sources
using
BACM
level
control
measures
and
include
the
agreements
in
the
NEAP.
Control
measures
must
be
implemented
for
those
contributing
sources
for
which
it
has
been
defined
within18
months
after
the
due
date
for
the
NEAP.

4.
Identify,
study
and
implement
practical
mitigating
measures
as
necessary.
The
EPA
believes
that
good
control
measures
have
been
defined
for
most
anthropogenic
sources
of
dust,
and
that
those
measures
should
be
implemented
on
the
above
schedule.
However,
the
NEAP
may
also
include
commitments
to
conduct
pilot
tests
of
new
emission
reduction
techniques.
For
example,
it
may
be
desirable
to
test
the
feasibility
and
effectiveness
of
new
strategies
for
minimizing
sources
of
windblown
dust
through
pilot
programs.
The
plan
must
include
a
timely
schedule
for
conducting
such
studies
and
implementing
the
best
measures
that
are
technologically
and
economically
feasible.
The
State
should
also
consult
the
most
current
guidance
developed
by
EPA
related
to
the
BACM
for
the
affected
source.

5.
The
State
must
periodically
re­
evaluate:
(
a)
the
conditions
causing
a
Particulate
Matter
NAAQS
to
not
be
met
in
the
area,
(
b)
the
status
of
implementation
of
the
NEAP,
and
(
c)
the
adequacy
of
the
actions
being
implemented.
The
State
should
re­
evaluate
the
NEAP
for
an
area
every
3­
5
years
at
a
minimum
and
make
appropriate
revisions
to
the
plan
in
consultation
with
the
appropriate
Regional
Office.

6.6
Development
Of
The
NEAP
The
State,
local,
or
Tribal
agency
should
develop
a
NEAP
in
conjunction
with
the
affected
stakeholders
in
the
area.
When
the
State,
local,
or
Tribal
air
quality
agency
develops
a
NEAP
related
to
wildland
fires,
the
plan
should
include
input
from
Federal,
State,
local,
Tribal,
and
private
land
managers
in
areas
vulnerable
to
fire.
Also,
agencies
responsible
for
suppressing
fires
and
the
citizens
in
the
affected
area
should
be
involved
in
developing
the
plan.
Development
of
a
NEAP
for
high
wind
events
should
include
input
from
Federal,
State,
local,
Tribal,
and
private
managers
of
open
desert
lands,
rangelands,
agricultural
lands,
the
construction
industry,
and
organizations
promoting
the
use
of
recreational
off­
road
vehicles
and
other
stakeholders
who
may
be
affected
by
development
of
the
NEAP.
Development
of
a
NEAP
for
volcanic
and
seismic
activities
should
include,
but
is
not
limited
to,
input
from
geophysicists
and
public
works
officials
who
will
be
responsible
for
removal
and
disposal
of
ash
deposits.
The
plan
should
include
documented
agreements
among
the
stakeholders
delineating
planned
actions,
the
implementation
schedule,
and
the
parties
responsible
for
carrying
out
those
actions.
DRAFT
­­
DO
NOT
QUOTE
or
CITE15
13
In
cases
where
an
area
is
required
to
implement
BACM
for
a
serious
or
higher
classified
area,
the
State
is
required
to
adopt
these
measures
and
submit
them
as
a
part
of
the
SIP
for
the
serious
(
or
higher
classified)
area.
In
cases
where
a
State
makes
a
request
to
have
an
are
redesignated
to
attainment,
the
State
must
meet
the
requirements
of
section
107(
d)(
3)(
E).
This
would
include
the
submittal
of
a
maintenance
plan
as
required
pursuant
to
section
175A,
and
the
State
must
ensure
that
all
anthropogenic
control
measures
required
to
address
the
impacts
related
to
natural
events,
identified
as
a
part
of
the
NEAP,
are
approved
as
a
part
of
the
maintenance
plan.
Other
portions
are
the
NEAP
will
not
be
required
to
be
submitted
for
approval
as
a
part
of
the
maintenance
plan.
6.7
Does
The
NEAP
Have
To
Be
Included
In
The
State's
Implementation
Plan?

The
State,
local,
or
Tribal
agency
is
not
required
to
submit
the
NEAP
as
a
revision
to
the
SIP
for
the
area.
However,
if
any
rules
that
are
currently
a
part
of
the
SIP
are
revised
as
part
of
the
NEAP,
those
rules
must
be
submitted
to
EPA
as
a
revision
to
the
SIP13.
The
State,
local,
or
Tribal
air
quality
agency
should
make
the
NEAP
available
for
public
review
and
comment.
Preliminary
and
final
plans
should
be
submitted
to
EPA
for
review
and
concurrence,
along
with
the
documentation
of
stakeholder
and
public
participation
in
the
NEAP
development
process,
and
public
comments
on
the
NEAP
and
the
response
of
the
State,
local,
Tribal
air
quality
agency.
The
concurrence
process
related
to
the
Regional
Office
review
of
the
NEAP
is
to
assist
the
State,
local,
or
Tribal
air
quality
agency
in
identifying,
adopting,
and
implementing
appropriate
control
measures
related
to
the
contributing
anthropogenic
sources
related
to
the
event
in
question.
The
EPA
does
not
intend
to
publish
notices
to
approve
or
disapprove
NEAPs.
However,
the
State,
local,
or
Tribal
air
quality
agency
may
make
a
decision
to
submit
the
NEAP,
or
the
control
measures
under
the
NEAP,
to
EPA
to
make
them
federally
enforceable.
Again,
EPA
does
not
require
that
the
NEAP
be
made
federally
enforceable,
but
does
require
that
the
appropriate
Regional
Office
provide
a
concurrence
on
the
NEAP
in
order
for
the
flagged
data
to
be
discounted
from
regulatory
consideration.

6.8
When
Must
A
State
Develop
A
NEAP?

A
NEAP
must
be
developed
when
natural
events
cause
a
Particulate
Matter
NAAQS
not
to
be
met.
However,
since
natural
events
can
significantly
increase
concentrations
of
Particulate
Matter
in
an
area
for
a
few
hours,
or
several
days
at
a
time,
the
State
should
consider
implementing
many
of
the
elements
of
a
NEAP
in
advance
of
an
event
(
e.
g.,
public
notification,
education,
and
episode
response
programs)
to
respond
to
future
natural
events
and
to
mitigate
the
impact
on
the
public.

6.9
How
Does
The
NEAP
Apply
To
Areas
Designated
As
Nonattainment?

The
State
may
request
that
a
nonattainment
area
for
the
Particulate
Matter
NAAQS
not
be
reclassified
to
a
higher
classification,
when
appropriate,
if
it
can
be
demonstrated
that
the
area
would
have
attained
the
affected
standard
by
the
statutory
attainment
date
but
for
emissions
DRAFT
­­
DO
NOT
QUOTE
or
CITE16
caused
by
a
natural
event.
Similarly,
the
State
may
request
redesignation
of
nonattainment
areas
to
attainment
if
it
can
be
demonstrated
that
the
area
would
have
met
the
affected
NAAQS
for
the
affected
pollutant
"
but
for"
the
emissions
caused
a
natural
event.

Approval
of
the
above
requests
will
be
made
by
EPA
on
a
case­
by­
case
basis
as
determined
by
the
adequacy
of
the
information
submitted
by
the
State
to
substantiate
its
claim.
At
a
minimum,
the
State
must
have
adopted
a
NEAP
for
the
area
which
demonstrates
that,
"
but
for"
the
emissions
from
the
natural
event
in
question
the
area
would
have
met
the
NAAQS.
In
order
for
the
area
to
be
redesignated
to
attainment
the
State
must
also
have
adopted
a
SIP
for
the
area
and
submitted
a
redesignation
request
along
with
a
maintenance
plan
pursuant
to
section
175A
of
the
Act.
In
each
case,
all
of
the
requirements
must
be
met
related
to
redesignation
of
an
area
from
nonattainment
to
attainment
under
section
107(
d)(
3)(
E)
of
the
CAA.

In
order
for
a
Regional
Office
to
approve
the
redesignation
request
of
a
State
related
to
an
area
affected
by
a
natural
event
the
State
must
agree
to
keep
the
NEAP
in
place
following
the
redesignation
of
the
area
to
attainment.
As
stated
previously,
a
review
of
the
NEAP
should
be
performed
by
the
State
and
the
Regional
Office
at
least
once
every
3­
5
years
to
determine
whether
the
NEAP
is
still
adequate,
or
whether
there
is
a
need
for
changes
to
the
provisions
of
the
NEAP
in
order
to
make
it
more
effective.
If
it
can
be
demonstrated
by
the
State,
local,
or
Tribal
agency
that
conditions
which
warranted
the
implementation
of
the
NEAP
no
longer
exist
after
the
first
5­
year
period,
the
State,
local,
or
Tribal
air
quality
agency
may
submit
a
request
to
the
affected
Regional
Office
to
discontinue
the
implementation
of
the
NEAP
for
the
area.
The
Regional
Office
should
provide
an
approval
or
disapproval
of
the
request
based
upon
information
submitted
by
the
State,
local,
or
Tribal
air
quality
agency.
The
approval
or
non­
approval
of
the
State,
local,
or
Tribal
air
quality
agency's
request
to
discontinue
the
NEAP
is
to
be
made
available
for
public
review
by
the
affected
Regional
Office.

6.10
Failure
To
Develop
Or
Implement
A
NEAP.

If
the
State
fails
to
submit
an
adequate
NEAP
that
includes
the
components
described
in
this
policy
for
an
area
that
does
not
meet
a
Particulate
Matter
NAAQS,
EPA
may
exercise
its
discretion
to
notify
the
Governor
of
the
State
that
the
area
should
be
designated,
or
redesignated
as
the
case
may
be,
as
nonattainment.
The
EPA's
action,
in
such
instances,
would
be
authorized
under
section
107
of
the
Act
based
on
the
conclusion
that
the
health
of
citizens
affected
by
natural
events
is
not
being
protected
by
the
State.
The
EPA
may
also
exercise
its
discretion
to
call
for
a
SIP
revision,
also
known
as
a
SIP
call,
to
address
the
issues
related
to
the
impacts
from
the
natural
events
in
the
area.

In
cases
where
an
area
has
been
designated,
or
redesignated,
as
nonattainment,
or
EPA
has
called
for
a
SIP
revision,
the
State
will
be
required
to
adopt
a
federally­
enforceable
control
strategy
related
to
sources
of
Particulate
Matter
emissions
in
the
affected
area.
Most
likely,
the
SIP
revision
or
control
strategy
will
include
many
of
the
same
mitigative
measures
that
could
have
been
included
in
a
NEAP
for
the
area
DRAFT
­­
DO
NOT
QUOTE
or
CITE17
6.11
Data
Affected
By
Natural
Events
Due
To
Transport
From
International
Sources
The
States
with
air
quality
monitoring
sites
that
have
been
impacted
by
emissions
from
natural
events,
due
to
transport
from
international
origins,
may
flag
the
data
related
to
these
events
for
discounting
from
regulatory
consideration
if
adequate
and
compelling
documentation
is
provided
to
substantiate
the
claim.
The
documentation
must
show
that
there
is
a
clear
causal
relationship
between
the
exceedances
or
violations
measured
at
the
air
quality
monitoring
site
in
question,
and
the
documentation
must
substantiate
that
the
emissions
were
due
to
emissions
from
sources
of
international
origin.
An
example
of
the
types
of
natural
events
attributed
to
international
transport
which
may
be
considered
under
this
policy
are
the
following:
(
1)
fires
occurring
outside
of
the
borders
of
the
United
States,
such
as
forest
fires
initiated
in
Mexico,
Central
America,
and
Canada,
or
natural
events
such
as
African
dust,
Asian
dust,
or
glacial
dust.
Other
types
of
events
may
be
considered
on
a
case
by
case
basis.

As
stated
previously,
in
order
for
the
data
to
be
considered
for
exclusion
for
regulatory
purposes,
the
reporting
air
quality
agency
must
flag
the
data
in
the
AQS
database
and
submit
adequate
and
compelling
documentation
which
shows
that
the
event
occurred
and
that
there
is
a
clear
causal
relationship
between
the
event
in
question
and
the
exceedance
or
violation
that
was
measured
at
the
affected
monitoring
site.
Decisions
concerning
the
concurrence
or
nonconcurrence
of
data
in
the
AQS
database
related
to
emissions
from
natural
events
transported
for
international
origins
will
be
made
by
the
appropriate
Regional
Office,
along
with
consultation
from
OAQPS,
within
the
time
periods
provided
in
this
policy
for
flagging
the
data
and
submittal
of
documentation.
(
See
section
5
above
concerning
flagging
of
data
and
submittal
of
documentation.)
EPA
will
be
disinclined
to
grant
concurrence
on
flagged
data
unless
it
is
determined
that
sufficient
documentation
has
been
submitted
related
to
the
event
in
question,
within
the
time
periods
provided
in
this
policy.

Section
7
Exceptional
Events
7.1
Criteria
For
Identification
Of
Exceptional
Events
As
stated
previously,
for
the
purpose
of
this
document,
certain
events
are
considered
to
be
exceptional
for
two
reasons:
(
1)
they
are
not
expected
to
recur
routinely
at
a
given
location,
or
(
2)
they
are
determined
not
to
be
reasonably
controllable
or
unpreventable.
The
criteria
chosen
for
identifying
"
exceptional
events"
in
this
document
was
designed
to
be
expansive
enough
to
encompass
most
good
faith
claims
by
State,
local,
and
Tribal
air
quality
agencies
related
to
when
data
should
be
considered
for
special
treatment.
The
flagging
of
data
in
the
AQS
database
is
the
process
that
a
State,
local,
or
Tribal
air
quality
agency
uses
to
indicate
that
it
believes
that
data
has
been
influenced
by
an
exceptional
event,
and
will
later
provide
documentation
that
substantiates
a
claim
that
the
data
should
be
discounted
for
regulatory
purposes.
DRAFT
­­
DO
NOT
QUOTE
or
CITE18
As
stated
previously,
in
order
for
data
to
be
discounted
by
EPA
from
regulatory
consideration,
a
State
must
provide
the
appropriate
documentation
to
show
that
there
is
a
clear
causal
relationship
between
the
exceptional
event
and
the
exceedance
or
violation
measured
at
the
monitoring
site
in
question.
Below
are
several
examples
of
exceptional
events
covered
by
this
document.
The
EPA
will
consider
other
types
of
events
on
a
case
by
case
basis
and
will
provide
concurrence
related
to
these
events
if
appropriate
documentation
is
provided
to
demonstrate
that
the
event
occurred
and
that
it
caused
or
significantly
contributed
to
an
exceedance
or
violation
at
a
monitoring
site.
The
EPA
will
exercise
its
discretion
to
deny
claims
related
to
data
submitted
by
a
State,
local,
or
Tribal
air
quality
agency
if
it
determines
through
a
review
of
the
history
of
the
monitoring
site,
or
the
affected
area,
that
the
event
occurs
routinely
at
the
location
in
question,
or
is
an
event
that
does
not
meet
the
criteria
of
being
"
not
being
reasonably
controllable"
or
"
unpreventable".
Examples
of
events
that
will
be
covered
under
this
policy
include
such
events
as:
(
2)
chemical
spills,
(
3)
Industrial
accidents,
(
4)
Clean
ups
after
major
disasters,
and
(
5)
Infrequent
Large
Gatherings.

The
guidance
concerning
exceptional
events
in
this
document
provides
general
definitions
and
examples
for
these
types
of
events
and
provides
general
criteria
related
to
the
flagging
of
the
events
in
the
AQS
database.
The
definitions
and
examples
identified
as
exceptional
events
in
this
document
should
only
be
considered
as
a
guide
in
making
decisions
related
to
exceptional
events
and
should
not
replace
reasonable
judgement
on
the
part
of
the
affected
Regional
Office,
State,
local,
or
Tribal
air
quality
agency
defining
and
identifying
exceptional
events
for
the
purpose
of
flagging
data..

In
cases
where
it
is
foreseeable
that
human
activity
related
to
a
specific
exceptional
event
may
have
potential
impact
on
the
public,
the
affected
State,
local,
or
Tribal
air
quality
agency
will
be
expected
to
have
implemented
appropriate
pre­
emptive
control
measures
to
mitigate
the
impact
of
the
activity
on
the
public.
In
cases
where
the
State,
local,
or
Tribal
air
quality
agency
has
taken
action
to
develop
and
implement
a
control
plan
to
mitigate
the
impact
of
these
types
of
events,
or
an
Exceptional
Event
Mitigation
Action
Plan
(
EEMAP),
EPA
will
take
this
information
into
consideration
in
making
its
decisions
concerning
the
concurrence
related
to
these
types
of
data
flags
in
the
AQS
database.
With
these
limitations
in
mind
the
following
are
some
general
definitions
related
to
exceptional
events
covered
by
this
guidance
document.

7.2
Chemical
Spills
And
Industrial
Accidents
Emissions
that
result
from
accidents
such
as
fire
explosions,
power
outages,
train
derailments,
vehicular
accidents,
or
combinations
of
these
may
be
flagged
as
an
exceptional
event.
The
spill
or
accident
must,
of
course,
not
be
a
routine
occurrence.
Any
of
these
situations
that
do
occur
routinely
should
be
critically
evaluated
and
stopped.
Data
from
States
that
can
be
unequivocally
related
to
a
non­
routine
accident
or
spill
may
be
flagged.
DRAFT
­­
DO
NOT
QUOTE
or
CITE19
7.3
Infrequent
Large
Gatherings
An
infrequent
large
gathering
is
a
gathering
of
more
than
10,000
people
(
5000
cars)
at
any
one
time
and
at
a
single
location.
Unusual
traffic
congestion
must
be
associated
with
the
event.
A
large
gathering
in
and
of
itself
without
the
associated
traffic
congestion
would
not
qualify
as
an
unusual
event
for
the
purpose
of
flagging.
The
event
would
also
be
expected
to
occur
less
than
once
per
year,
and
the
event
should
be
limited
to
sites
classified
as
micro­
or
middle­
scale
with
respect
to
the
gathering.
The
EPA
will
also
consider
the
discounting
of
data
related
to
celebratory
events
in
which
emissions
from
fireworks
either
cause
or
significantly
contributes
to
exceedances
or
violations
of
the
NAAQS.
These
events
may
only
be
discounted
where
it
has
been
determined
by
the
affected
Regional
Office
that
they
events
are
not
routine
in
terms
of
occurrence
(
i.
e.,
they
only
occur
once
per
year)
and
precautions
have
been
taken
by
the
appropriate
air
quality
agency
to
mitigate
the
influence
of
the
event
on
public
health.
Prior
to
the
types
of
event
described
in
this
section,
all
reasonable
available
control
measures
must
be
used,
and
documented,
before
the
data
can
be
flagged
for
exclusion
from
regulatory
consideration
related
to
the
site.

7.4
Clean
Up
Activities
After
A
Major
Disaster
For
the
purpose
of
flagging,
major
disasters
are
to
be
considered
as
serious
public
misfortunes
for
which
State
and
Federal
relief
has
been
granted.
Particulate
Matter
data
affected
by,
and
collected
during,
or
for
a
reasonable
period
after,
the
clean
up
activities
following
a
major
disaster
may
be
flagged
in
order
for
the
event
to
be
excluded
from
regulatory
consideration.

7.5
Development
Of
An
Exceptional
Event
Mitigation
Action
Plan
(
EEMAP)

The
State,
local,
or
Tribal
agency
should
develop
an
EEMAP
in
conjunction
with
the
affected
stakeholders
in
the
area.
When
the
State,
local,
or
Tribal
agency
develops
an
EEMAP
related
to
an
exceptional
event
the
plan
should
include
input
from
affected
stakeholders
related
to
the
event.
The
plan
should
include
documented
agreements
among
the
stakeholders
delineating
planned
actions,
the
implementation
schedule,
and
the
parties
responsible
for
carrying
out
those
actions.

7.6
Response
To
NAAQS
Violations
Due
To
Exceptional
Events.

If
an
area
fails
to
meet
a
NAAQS
because
one
or
more
Particulate
Matter
values
has
been
affected
by
an
exceptional
event,
the
State
is
required
to
develop
an
EEMAP
to
address
future
events
within
18
months
of
the
NAAQS
violation.
A
EEMAP
should:

1.
Establish
public
notification
and
education
programs.
Such
programs
may
be
designed
to
educate
the
public
about
the
short­
term
and
long­
term
harmful
effects
that
high
concentrations
of
Particulate
Matter
may
have
on
public
health
and
inform
the
public
DRAFT
­­
DO
NOT
QUOTE
or
CITE20
that:
(
a)
certain
types
of
exceptional
events
affect
the
air
quality
of
the
area
periodically,
(
b)
an
exceptional
event
is
imminent,
and
(
c)
specific
actions
are
being
taken
to
minimize
the
public
health
impacts
of
the
event.

2.
Minimize
public
exposure
to
high
concentrations
of
Particulate
Matter
due
to
future
exceptional
events.
Programs
to
minimize
public
exposure
should:
(
a)
identify
the
people
most
at
risk,
(
b)
notify
the
at­
risk
population
that
an
exceptional
event
is
imminent
or
currently
taking
place,
(
c)
suggest
actions
to
be
taken
by
the
public
to
minimize
their
exposure
to
high
concentrations
of
Particulate
Matter,
and
(
d)
suggest
precautions
that
should
be
taken
if
exposure
cannot
be
avoided.

3.
Abate
or
minimize
appropriate
contributing
controllable
sources.

7.7
Failure
To
Develop
Or
Implement
An
EEMAP.

If
the
State
fails
to
submit
an
adequate
EEMAP
that
includes
the
components
described
in
this
policy
for
an
area
that
does
not
meet
a
Particulate
Matter
NAAQS,
EPA
may
exercise
its
discretion
to
notify
the
Governor
of
the
State
that
the
area
should
be
designated,
or
redesignated
as
the
case
may
be,
as
nonattainment.
The
EPA's
action,
in
such
instances,
would
be
authorized
under
section
107
of
the
Act
based
on
the
conclusion
that
the
health
of
citizens
affected
by
natural
events
is
not
being
protected
by
the
State.
The
EPA
may
also
exercise
its
discretion
to
call
for
a
SIP
revision,
or
SIP
call,
to
address
the
issues
related
to
the
impacts
from
the
natural
events
in
the
area.

Section
8
Stagnation
and
Inversion
Events
8.1
Stagnation/
Inversions
Stagnation
and
inversions
are
frequent
climatological
occurrences
that
must
be
considered
in
evaluating
whether
a
control
program
is
adequate
to
attain
and
maintain
the
NAAQS.
An
inversion
is
said
to
occur
at
a
point,
or
through
a
layer,
where
temperature
increases
with
increasing
height.
Surface­
based
inversions
are
those
that
extend
vertically
from
the
surface
to
some
altitude
aloft.
Studies
have
found
that
surface­
based
inversions
generally
occur
about
32
percent
of
the
time.
They
are
usually
short­
lived
and
disperse
shortly
after
sunrise.
Because
inversions
are
expected
to
occur
frequently
and
are
part
of
weather
patterns,
they
are
not
considered
exceptional
events
for
the
purpose
of
flagging
data
for
exclusion.
DRAFT
­­
DO
NOT
QUOTE
or
CITE21
Stagnation
episodes
are
periods
of
four
or
more
days
with
surface
wind
speeds
of
generally
4
m/
sec
or
less
and
no
precipitation
or
frontal
passage.
In
some
parts
of
the
country
stagnation
conditions
usually
persist
for
an
extended
period
of
time,
and
they
can
affect
an
entire
air
basin;
therefore,
they
are
not
generally
considered
exceptional
for
the
purpose
of
flagging
data
for
exclusion.
