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Natural Events Policy

Natural Events Policy. WESTAR Planning Committee NEP Workgroup September 22, 2005. 1996 Policy. 1998 Implementation Memo. WESTAR Recommendations. EPA Staff Work Paper. Over-Arching Comments. WESTAR States Have Natural Events Experience – Use Us Natural Events ≠ Exceptional Events

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Natural Events Policy

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  1. Natural Events Policy WESTAR Planning Committee NEP Workgroup September 22, 2005

  2. 1996 Policy

  3. 1998 Implementation Memo

  4. WESTAR Recommendations

  5. EPA Staff Work Paper

  6. Over-Arching Comments • WESTAR States Have Natural Events Experience – Use Us • Natural Events ≠ Exceptional Events • Establish the Process For Defining “Appropriate Documentation” • SAFETEA-LU allows until March 2006 to Develop Proposed Rule • Requires Consultation with State Air Quality Agencies • New Rule Should Apply To All Forms Of PM NAAQS • Control Sources That Contribute Significantly To NAAQS Violations

  7. StaffWork Paper Cover Letter

  8. WESTAR Responses To EPA Questions • Documentation Levels • National Guidance Followed By Regional Collaboration • Annual Standard Data Flagging • Apply To Any And All Data Impacted By Natural Events • Timeframe For Documentation Submittal • Documentation Should Be Collected Immediately • Submitted To EPA Within 180 Days Following Quarter When States Make A Finding Of A Violation • Bright Line For What Constitutes A “High Wind” • Maintain Current Distinction Between “Natural” And “Exceptional” • “Unusual And Not Typical” Is Definition Of “Exceptional Event” • “Wind-generated Dust” Vs. “High Wind”

  9. WESTAR All Pm (2.5, 10, Coarse) Staff Paper Excludes PM10 Ozone Mentioned 1. What Pollutants?

  10. WESTAR Seismic/Volcano Wildfires Wind-generated Dust Impact Of Drought Staff Paper Seismic/Volcano Wildfires High Winds For Exceptional Events, Case-by-case 2. What Type Of Events?

  11. WESTAR Yes Staff Paper Yes 3. Annual NAAQS?

  12. WESTAR Within 90 Days Following End Of Quarter When Event Occurred Staff Paper Within 60 Days Following End Of Quarter When Event Occurred 5a. Flagging Data(Attainment Status)

  13. WESTAR Within 180 Days Following End Of Quarter When Violation Determined Staff Paper Within 60 Days Following End Of Quarter When Event Occurred 5b. Documentation Submittal(Attainment Status)

  14. WESTAR Immediately Following Event Staff Paper Within The 60-day Time Frame For Submittal To EPA 6. Documentation Collection (Attainment Status)

  15. WESTAR Any Time During SIP Development Staff Paper Not Allowed 6. Documentation For Events (Discovered During SIP Development)

  16. WESTAR National Guidance Regional Collaboration Technical Dispute Resolution Process Staff Paper “Compelling” “Clear and Causal Relationship” Administrative Dispute Resolution Process “Reasonable Documentation” Definition?

  17. WESTAR Public Education / Notification Minimize Public Exposure Controls for Sources Contributing Significantly Staff Paper Public Education / Notification Minimize Public Exposure Abate/Minimize contributing sources For High Wind Events, specifically requires BACM for any source disturbed by anthropogenic activities Natural Events Action Plan Should:

  18. WESTAR 18 Months Following End of Quarter when Violation of NAAQS Determined Staff Paper Within 18 Months of “NAAQS Violation” 10. Timeframe for NEAP Submittal

  19. WESTAR Collaborative Process between States and EPA Regions to Define Expectation Beforehand Staff Paper EPA “Concurrence” Not Defined 11. Natural Event and NEAP Processing

  20. Gerry Guay (AK) Bruce Friedl (AZ) Mark Lewandowski (AZ) Karen Magliano (CA) Rich Hackney (CA) Mark McMillan (CO) Ray Mohr (CO) Dan Redline (ID) Diane Riley (ID) Jean-Paul Huys (NV) Gail Cooke (NM) Andy Berger (NM) Brad Musick (NM) Brian Fineran (OR) Larry Calkins (OR) Dave McNeill (UT) Doug Schneider (WA) Tina Anderson (WY) Mike Stoll (WY) Workgroup Members

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