San
Joaquin
Valley
Air
Pollution
Control
District
Comments
on
Exceptional
and
Natural
Events
Rulemaking
Briefing
for
STAPPA/
ALAPCO,
July
27,
2005
All
comments
are
based
on
the
"
Exceptional
and
Natural
Events
Rulemaking"
slide
presentation
given
by
Larry
Wallace
of
EPA
on
the
STAPPA/
ALAPCO
conference
call
on
July
27,
2005.

1.
Time
line
options:
Revising
the
time
line
from
180
days
to
60
or
90
days
would
present
a
hardship
to
the
local
agencies.
The
time
line
is
best
left
at
180
days,
as
in
the
current
Natural
Events
Policy.

After
an
air
monitor
sample
is
collected
and
shipped
to
a
laboratory
for
weighing,
EPA
guidelines
state
that
the
data
must
be
submitted
to
AQS
(
Air
Quality
System)
within
30
days
of
the
end
of
the
calendar
quarter.
The
data
does
not
become
official
until
90
days
after
submittal
to
AQS.
A
60
or
90
day
documentation
requirement
is
not
enough
time
to
allow
for
this
or
the
many
other
potentially
time­
consuming
phases
of
documentation
preparation:
filter
speciation,
meteorological
data
collection
and
analysis,
review
of
relevant
EPA
policy,
review
of
regional
agency
plans
and
BACM,
staff
coordination,
writing
and
assembly
of
the
natural
event
documentation,
internal
agency
review,
and
public
comment.
This
is
not
an
issue
of
agency
size;
in
spite
of
staff
size,
many
agencies
do
not
have
enough
people
to
do
what
they
need
to
do
as
is
without
adding
a
natural
or
exceptional
event
to
the
workload.
Natural
and
exceptional
events
are
by
their
very
nature
unexpected,
so
there
must
be
enough
time
for
assigned
staff
to
work
on
documentation
as
they
continue
their
normal
tasks.

EPA's
concern
over
the
"
loss
of
data"
(
slide
11)
cannot
outweigh
the
resources
necessary
for
natural
event
documentation
and
mitigation
plan
preparation.
Data
collection
is
likely
one
of
the
earlier
tasks
that
an
agency
will
complete
in
this
process,
so
losing
data
because
of
a
lag
between
the
event
and
the
completion
of
documentation
is
unlikely.
Even
if
an
agency
does
not
have
portions
of
useful
data,
there
are
almost
always
other
sources
of
data
that
can
be
used.
In
fact,
third­
party
data
can
greatly
contribute
to
a
more
complete
understanding
of
the
event,
but
an
agency
needs
time
to
identify
and
incorporate
relevant
external
data.

With
regard
to
addressing
data
quickly
to
take
"
appropriate
action
to
protect
public
health,"
the
data
flagging
itself
is
not
as
critical
to
public
health
as
is
the
mitigation
plan.
It
is
advantageous
to
allow
an
agency
time
to
develop
a
thorough
understanding
of
the
event
and
to
develop
effective
programs
that
will
address
the
complicated
and
varying
characteristics
of
natural
and
exceptional
events.
Flagging
of
data
for
design
value
purposes
can
result
in
fewer
controls
on
emissions,
so
it
is
important
that
the
process
not
be
unduly
rushed.
Simply
expediting
the
data
flagging
process
will
not
expedite
the
protection
of
the
public.

I
n
addition,
automatic
EPA
concurrence
at
the
close
of
the
review
period
is
crucial
if
an
agency
is
to
meet
mitigation
plan
commitments.
An
agency
would
not
dedicate
resources
to
a
mitigation
plan
until
it
is
certain
that
it
is
required
(
that
is,
not
before
the
data
flag
is
approved),
but
mitigation
plans
need
to
be
submitted
within
a
specified
time
frame.

Therefore,
an
agency
should
have
180
days
from
the
date
of
the
exceedance
to
submit
documentation,
and
there
must
be
automatic
concurrence
from
EPA
at
the
close
of
their
review
period.

2.
Existing
mitigation
plans
If
the
policy
for
mitigation
plans
changes,
how
will
the
new
policy
apply
to
NEAPs
in
progress
or
already
adopted?
For
areas
that
already
have
NEAPs
in
place
or
in
progress
for
data
that
has
already
been
flagged,
it
would
be
best
for
any
mitigation
plan
changes
required
by
the
new
policy
to
occur
at
the
5­
year
revision.

3.
Clarifying
"
routine"
The
new
policy
needs
to
be
very
clear
on
what
is
meant
by
"
routine."
Slide
4
defines
exceptional
events
as
those
events
that
are
not
expected
to
occur
"
routinely"
at
a
given
location.
Are
cyclical,
seasonal
wind
events
or
emissions
events
such
as
harvesting
considered
exceptional,
or
routine?
There
needs
to
be
clear
boundaries
on
what
can
be
presented
as
non­
routine.

4.
Fireworks
Slide
9
mentions
fireworks
emissions,
but
there
is
no
other
mention
of
fireworks
in
the
presentation.
Would
PM2.5
violations
after
yearly,
4th
of
July
fireworks
be
considered
"
routine?"
More
details
on
how
fireworks
could
be
handled
would
be
of
interest.

4.
Special
Events
Policy
Slide
5
on
EPA
policies
does
not
mention
the
September
1994
policy,
"
Guidelines
on
the
Identification
and
Handling
of
Ambient
Air
Quality
Data
Affected
by
Special
Events
or
Special
Conditions."
Is
this
policy
still
in
effect?
Might
it
be
included
in
the
revised
Natural
and
Exceptional
Events
Policy?
Might
the
5­
year
Recurrence
Test
(
Section
2.3)
be
revised?
Since
this
policy
also
covers
data
from
unusual
circumstances,
it
should
be
included
in
the
revised
Natural
and
Exceptional
Events
Policy.

5.
BAM
and
FRM
data
EPA's
guidance
should
present
EPA's
viewpoint
on
real­
time
BAM
(
beta
attenuation
monitor)
data
and
how
it
is
to
be
used
with
official
filter
based
FRM
(
federal
reference
method)
data.
What
if
the
BAM
data
is
higher
than
the
FRM
data?
Which
is
most
important
in
terms
of
the
data
flagging
process?
Any
data
that
can
be
used
in
an
area's
attainment
calculations
should
be
subject
to
flagging
policies,
so
both
BAM
and
FRM
data
should
qualify.

6.
High
winds
For
"
high
winds,"
will
the
more
rigid
definition
from
the
Exceptional
Events
Policy
or
the
more
flexible
definition
from
the
Natural
Events
Policy
be
used?
Deposition
from
high
wind
source
regions
needs
to
be
addressed
as
well.
The
San
Joaquin
Valley
(
SJV)
has
had
high
wind
events
in
its
northern
portion
that
affected
low
wind
regions
further
south
in
the
SJV.
The
Natural
Events
Policy
definition
of
high
winds
is
preferable
as
it
allows
for
the
variability
among
regions
and
events.

7.
Wildland
fires
The
definition
of
a
wildland
fire
also
needs
clarification.
Is
an
arson
wildfire
considered
an
exceptional
event?
If
a
catastrophic
but
routine
wildland
fire
occurs
and
an
exceedance
is
captured
on
a
monitor,
should
that
data
be
flagged?
What
about
wildland
fire
use
(
WFUs)?
If
a
naturally
ignited
wildland
fire
occurs
during
a
major
stagnation
event
and
lasts
several
days,
is
there
a
limitation
on
the
number
of
consecutive
days
that
can
be
flagged?
Clearly
defined
classes
of
wildland
fire
data
flags
would
allow
various
types
of
events
to
be
flagged
while
ensuring
that
those
viewing
or
using
the
data
have
as
much
information
as
possible
regarding
the
nature
of
the
event.

8.
Data
affecting
attainment
of
the
annual
standard
Currently,
data
flags
are
either
accepted
or
rejected,
and
the
flags
denote
the
event
causing
the
exceedance
("
A"
for
high
winds,
"
E"
for
wildfires,
etc).
Perhaps
an
additional
type
of
flag
can
be
introduced
for
events
producing
readings
that
are
high
enough
to
affect
annual
attainment
status
even
if
there
was
not
a
24­
hour
violation.
Since
data
from
these
types
of
events
do
not
represent
the
same
type
of
threat
to
public
health
as
does
a
24­
hour
violation
and
areas
with
these
types
of
exceedances
most
likely
have
SIPs
in
place,
a
full
mitigation
plan
may
not
be
needed
for
these
types
of
flags
provided
that
the
same
documentation
process
is
utilized.
