August
30,
2005
Mr.
Larry
Wallace
USEPA
Mail
Code
(
C504­
02)
Research
Triangle
Park,
North
Carolina
27711
Dear
Mr.
Wallace:

Listed
below
are
the
Oklahoma
Department
of
Environmental
Quality's
comments
on
the
"
Staff
Work
Paper
on
the
Use
of
Air
Quality
Data
Related
to
Exceptional
and
Natural
Events
for
the
Particulate
Matter
Standards"
and
recommendations
for
modifications
to
the
proposed
language
for
the
rule.

1.
Ozone
­
The
State
and
Territorial
Air
Pollution
Program
Administrators
and
the
Association
of
Local
Air
Pollution
Control
Officials
(
STAPPA/
ALAPCO)
briefing
on
July
27,
2005
included
a
discussion
of
the
pollutants
to
be
included
in
the
rule
and
specified
that
ozone
is
to
be
included.
The
staff
work
paper
needs
to
be
clear
that
the
rule
will
apply
not
only
to
particulate
matter
(
PM),
but
also
to
ozone.

2.
Public
Hearings
­
States
should
hold
public
hearings
if
there
is
sufficient
public
input
but
a
hearing
should
not
be
mandated
for
all
Exceptional
Event/
Natural
Event
(
EE/
NE)
requests.
If
a
hearing
must
be
held
within
the
60­
day
request
timeline,
an
extension
may
be
necessary.
Many
states
have
requirements
that
they
must
give
a
30­
day
notice
of
any
public
hearing,
which
makes
holding
the
hearing
within
the
60­
day
request
timeline
almost
impossible.

3.
Website
Tracking
­
EPA
should
develop
a
website
that
contains
all
the
information
for
EE/
NEs,
all
requests
and
concurrences,
and
provides
examples
for
states
to
quickly
determine
what
is
expected.
We
also
suggest
that
this
website
provide
resources
such
as
links
to
relevant
websites
and
documents.
This
would
expedite
the
process
of
searching
for
sources
of
data
when
working
under
a
tight
deadline.

4.
Request
Deadline
­
The
60­
day
EE/
NE
request
deadline
should
be
extended.
The
Oklahoma
Department
of
Environmental
Quality
as
well
as
many
other
agencies
and
tribes
contract
with
outside
labs
to
perform
the
PM2.5
filter
analysis.
This
process
often
requires
50
to
70
days,
or
longer,
to
receive
the
data
from
the
lab.
Even
adding
a
30­
day
extension
request
would
make
the
timeframe
very
tight.
To
make
a
PM2.5
EE/
NE
request
feasible,
we
suggest
increasing
the
deadline
to
90
days.
Mr.
Larry
Wallace
August
30,
2005
Page
2
5.
Modeling
Time
Frame
­
Listed
on
pages
6
and
7
of
the
staff
work
paper
is
the
idea
that
modeling
is
one
of
the
means
that
we
are
allowed
to
use
as
the
basis
of
our
request.
If
a
state
wishes
to
use
modeling
of
an
event,
additional
time
will
be
necessary
to
complete
the
modeling.
There
may
need
to
be
an
additional
mechanism
set
up
for
the
state
and
region
to
agree
to
additional
time
required
to
perform
modeling.

6.
Tribal
Monitors
­
There
are
many
monitors
located
on
tribal
lands
that
must
be
shown
the
same
consideration
as
those
located
on
state
and
federal
land.
However,
many
tribes
may
lack
the
resources
to
make
an
EE/
NE
request
or
to
develop
an
EEMAP.
Will
the
Region
or
the
State
take
this
responsibility
for
them,
or
will
they
be
provided
with
some
form
of
assistance?

7.
Inversions
and
Stagnation
Events
­
While
routine
or
even
yearly
meteorological
events
should
not
be
discounted,
there
should
be
some
mechanism
for
addressing
truly
exceptional
inversions
or
stagnation
events.
Under
this
current
version,
none
of
this
would
qualify
as
exceptional.
We
believe
that
inversions
and/
or
stagnation
events
should
qualify
under
the
policy
if
states
can
convincingly
prove
that
the
event
occurs
with
less
than
a
specified
frequency
that
is
indicative
of
a
rare
or
abnormal
occurrence.

8.
PM2.5
Standard
­
Compared
to
the
form
of
the
ozone
standard,
which
averages
the
4th
highest
values
over
3
years,
the
form
of
the
PM2.5
24­
hour
standard,
which
averages
values
at
the
98th
percentile
over
3
years,
is
not
very
forgiving.
Many
of
the
PM2.5
sites
run
every
6
days,
having
65
to
66
sample
days
a
year
with
100%
data
capture.
If
the
sample
number
were
reduced
as
a
result
of
all
the
sample
collection/
data
problems
normally
encountered
in
a
year,
the
average
sample
number
would
range
from
55
to
60
days.
The
98th
percentile,
for
any
site
yielding
less
than
50
samples
per
year,
is
the
highest
value.
For
sites
yielding
less
than
100
samples
per
year,
the
98th
percentile
is
the
2nd
highest
value.
For
the
year
2004,
Oklahoma
had
19
sites,
one
of
which
had
less
than
50
samples
and
9
other
sites
that
had
less
than
100
samples.
Therefore,
for
most
of
our
sites
the
2nd
highest
value
each
year
is
critical
and
even
a
small
impact
from
an
event
that
lasts
more
than
5
days
has
the
potential
to
force
the
site
into
non­
attainment.
Given
the
sensitivity
of
the
form
of
the
PM2.5
standard
to
EE/
NEs,
and
the
probability
that
the
standard
will
be
changed
to
a
much
tighter
value
when
the
review
of
the
standard
has
been
completed,
it
is
critical
that
the
guidance
not
be
over
complicated
and
or
burdensome
for
either
EPA
or
the
States
and
Tribes.
Many
events
that
were
ignored
in
the
past
will
now
threaten
the
attainment
status
of
an
area
and
must
be
worked
as
an
EE/
NE.

We
appreciate
the
opportunity
for
input.
Should
you
have
any
questions
or
need
additional
information,
please
feel
free
to
contact
Scott
Thomas
at
405­
702­
4100.

Sincerely,

Eddie
Terrill,
Director
Air
Quality
Division
ET:
nlm:
hlb
