Georgia
Department
of
Natural
Resources
Environmental
Protection
Division,
Air
Protection
Branch
4244
International
Parkway,
Suite
120,
Atlanta,
Georgia
30354
404/
363­
7000
Noel
Holcomb,
Commissioner
Carol
A.
Couch,
Ph.
D.
Director
Comments:
Staff
Work
Paper
on
the
Use
of
Air
Quality
Data
Related
to
Exceptional
and
Natural
Events
for
the
Particulate
Matter
Standards.

Section
5
Submittal
of
documentation
related
to
flagged
data.

The
staff
paper
states
that
the
documentation
supplied
to
EPA
must
be
sufficient
to
demonstrate
compelling
reasons
for
EPA
to
concur
with
the
Exceptional
or
Natural
Event
flag.
In
addition,
the
paper
provided
a
list
of
suggested
types
of
analyses
to
be
included
in
the
documentation
(
trajectory
analysis,
filter
analysis,
meteorological
data,
modeling,
source
receptor
analysis,
videos
of
the
event,
satellite
images,
maps
of
the
area
showing
sources
of
emissions
and
the
area
affected
by
the
event,
as
well
as
news
accounts
of
the
event).
However,
when
similar
sets
of
documentation
are
provided
to
different
Regional
Administrators,
different
outcomes
occur.
Therefore,
instead
of
a
laundry
list
of
items
to
be
included
in
the
justification,
EPA
should
come
to
a
consensus
and
identify
the
key
issues
involved
in
making
a
concurrence
judgment.
For
each
key
issue
a
list
of
possible
analyses
useful
for
providing
the
supporting
evidence
to
sufficiently
address
that
issue
should
be
provided.
The
EPA
document
should
indicate
why
the
particular
analysis
is
relevant
for
it
to
make
the
judgment
for
concurrence.
In
addition,
each
item
should
identify
the
expected
outcome
that
is
deemed
consistent
with
the
concurrence
flag.
If,
for
some
reason,
it
is
not
possible
to
supply
one
of
the
suggested
evidentiary
analyses
(
ex.
satellite
imagery
not
available
due
to
cloud
cover)
then
state/
local/
tribal
agency
must
supply
documentation
of
the
reason.
The
State,
Local,
and
Tribal
entities
should
be
allowed
to
perform
the
set
of
analyses
that
is
most
appropriate
based
on
the
available
databases
for
the
key
issues
being
addressed.
Analysis
results
for
each
of
the
key
issues
should
be
considered
and
used
to
make
a
determination
on
how
the
preponderance
of
information
from
each
set
of
results
is
consistent
with
the
flagging.

In
addition
to
the
data
analysis
discussion,
documentation
including
a
description
of
the
data
used
to
support
each
analysis
such
as
identification
of
air
quality
models,
statistical
models,
or
analytical
techniques
used;
outcome
of
each
analysis
and
whether
it
is
consistent
with
the
flagging
hypothesis,
assessment
of
the
credibility
of
each
type
of
analysis
used,
and
a
narrative
describing
the
rational
used
to
conclude
that
the
weight
of
evidence
supports
a
conclusion
that
the
data
should
be
flagged
must
be
included.

As
with
other
analyses
required
for
EPA
(
eg.
Mid
Course
Review),
it
takes
time
to
perform
the
required
analyses
to
address
the
various
key
issues.
The
staff
paper
suggests
that
the
flagging
package
is
to
be
submitted
within
60
days
of
the
end
of
the
quarter.
There
are
several
problems
associated
with
this
deadline;
the
data
from
routine
laboratory
analyses
for
the
speciation
sites
are
conducted
at
an
EPA
funded
contract
laboratory.
The
data
is
not
available
for
use
in
data
analysis
for
approximately
90
days
after
the
sampling
event,
making
the
60­
day
requirement
for
documentation
submittal
unreasonable.
In
addition,
the
State/
Local/
Tribal
agencies
must
rely
on
alternative
non­
EPA
networks
(
IMPROVE,
research
networks)
for
chemical
data
due
to
the
limited
number
of
EPA
speciation
sites
nationwide.
However,
data
form
these
sources
are
not
commonly
available
for
one
or
more
years
after
the
sampling
event
making
it
impossible
to
meet
the
deadline
for
submittal.
Finally,
the
60­
day
requirement
will
not
allow
sufficient
time
to
develop
supporting
non­
routine
chemical
analysis
such
levoglucosan
analysis.

Section
5
also
suggests
that
solicitation
of
stakeholder
feedback
should
be
included
in
the
flagging
process.
However,
the
60­
day
deadline
makes
it
unrealistic
for
completing
the
public
comment
process.
The
public
comment
process
is
a
minimum
of
45
days
including
posting
the
notice
to
the
media,
collecting
comments
for
30
days
and
then
supplying
a
reply.

Footnote
7,
Indicates
that
the
Regional
Office
may
consult
the
appropriate
OAQPS
program
office
for
a
resolution
of
disagreements
between
State,
Local,
and
Tribal
entities.
It
is
suggested
that
instead
of
EPA
resolving
the
dispute
between
EPA
and
the
reporting
agencies
over
flagging,
that
the
dispute
resolution
should
be
handled
by
a
consortium
of
representatives
from
the
Regional
office,
the
appropriate
OAQPS
program
office
and
representatives
from
the
regional
state,
local,
tribal
agencies.

The
comments
found
above
for
section
5
are
also
applicable
to
section
6.11
and
section
7.
