MEMORANDUM
SUBJECT:
Treatment
of
Data
Influenced
By
Exceptional
and
Natural
Events
FROM:
The
Connecticut
Department
of
Environmental
Protection
Bureau
of
Air
Management
Michael
Geigert,
Air
Pollution
Control
Engineer
August
31,
2005
TO:
Larry
Wallace
(
EPA)

Thank
you
for
the
opportunity
to
comment
on
the
"
Staff
Work
Paper
on
the
Use
of
Air
Quality
Data
Related
to
Exceptional
and
Natural
Events
for
the
Particulate
Matter
Standards"
(
Updated
August
11,
2005,
US
EPA
OAR,
OAQPS).
As
you
already
know,
the
different
parts
of
the
Country
will
have
differing
needs
with
regard
to
the
flagging
of
such
data.
Within
recent
memory,
Connecticut,
as
well
as
several
other
nearby
States
had
successfully
flagged
the
PM2.5
data
during
a
2002
wildfire
event
in
Quebec,
Canada.
The
guidance
in
place
at
the
time
(
The
1996
PM10
Natural
Events
Policy)
worked
well,
and
this
current
draft
guidance
appears
to
be
a
natural
extension
of
that
policy.

Unlike
some
of
the
western
States,
Connecticut
is
not
likely
to
be
as
frequently
impacted
by
socalled
natural
or
exceptional
events.
Although
Connecticut
may
occasionally
be
impacted
by
regional
wildfires,
the
case
of
the
Quebec
wildfires
was
indeed
exceptional:
smoke
from
numerous
fires
in
the
Quebec
wilderness
was
driven
due
south
by
an
unusually
strong
high
pressure
in
July,
and
even
affected
States
as
far
south
as
Virginia.
We
feel
that
your
draft
guidance
adequately
addresses
this
type
of
situation,
especially
section
6.11,
which
addresses
transport
from
international
sources.

Another
area
of
concern
for
Connecticut
would
be
the
flagging
of
emissions
caused
by
fireworks
or
other
celebratory
events.
This
was
addressed
in
section
7.3
(
Infrequent
Large
Gatherings),
but
should
be
further
elaborated
with
regards
to
the
fireworks.
We
have
definitely
noticed
elevated
PM2.5
levels
during
some
Fourth
of
July
fireworks
displays,
but
none
have
exceeded
the
current
24­
hour
PM2.5
standard.
With
the
expectance
of
the
24­
hour
PM2.5
standards
being
revised
downward,
there
is
a
possibility
that
an
exceedance
may
occur
during
certain
conditions.
As
currently
written
into
this
section,
prior
to
an
event:
"
all
reasonable
available
control
measures
must
be
used
and
documented."
More
specific
guidance
for
this
type
of
event
would
be
helpful
as
Connecticut
has
not
regulated
emissions
from
these
events
in
the
past.

Another
section
of
concern
for
Connecticut
is
Section
5.1:
The
guidance
proposes
that
air
quality
agencies
submit
detailed,
compelling
documentation
to
justify
the
flagging
in
AQS
of
high
concentration
PM
samples
that
are
linked
to
exceptional
or
natural
events
within
60
days
of
the
end
of
the
calendar
quarter
in
which
the
event
occurred.
In
accordance
with
40CFR
section
58.35,
the
agency
deadline
for
submittal
of
validated
data
to
AQS
is
90
days
after
the
end
of
a
calendar
quarter.
For
the
PM
manual
methods,
analytical
laboratory
sample
turnaround
times,
manual
entering
of
field
and
laboratory
data
sheets
into
computer
databases
and
the
required
review
and
validation
process
would
likely
preclude
an
agency's
evaluation
of
the
ambient
sample
data
significantly
earlier
than
the
90­
day
deadline.
If
the
proposed
guidance
were
accepted,
data
inaccessibility
in
the
60
days
following
the
quarter
could
also
cause
an
agency
to
miss
the
deadline
for
filing
for
an
extension,
depending
on
whether
there
was
prior
awareness
of
probable
high
concentrations
or
the
potential
for
a
cause
and
effect
relationship
between
a
natural
event
and
ambient
concentration
data.

In
addition
to
data
access
issues,
an
adequate
time
allowance
must
be
made
for
the
agency
to
perform
studies
(
data
analyses,
modeling),
complete
the
technical
document,
and
secure
management
approval.
Given
the
potential
time
needed
for
reviewing
the
data
and
submitting
the
request,
the
State
recommends
that
agency
requests
for
exceptional
or
natural
event
flags
and
submission
of
supporting
documentation
be
required
no
less
than
90
days
following
the
end
of
the
quarter
in
which
the
event
occurred,
and
that
the
agency
may
submit
a
request
for
a
30
day
extension
for
the
exceptional/
natural
event
submission
within
the
90
days
following
the
end
of
the
quarter.

The
other
issues
that
you
requested
comment
on:
The
level
of
documentation
that
should
be
required
to
substantiate
an
exceptional
or
natural
event
claim
and
the
flagging
of
data
below
the
standard
that
may
affect
the
annual
average
for
an
area
are
difficult
to
quantify
and
should
be
negotiated
on
a
case
by
case
basis.
Regarding
whether
should
there
be
a
bright
line
test
associated
with
high
wind
events,
Connecticut
is
rarely
impacted
by
high
wind
events
that
would
raise
PM2.5
levels
and
so
has
no
comment
on
this.

Best
Regards,

Michael
Geigert
Cc:
Amy
Royden­
Bloom
