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Department ofAir Quality & Environmental Management

500 S Grand Central Pky 1st FI . PO Box 555210 . Las Vegas NV 89155-5210(702) 455-5942 . Fax (702) 383-9994

Christine L. Robinson, Director. Alan Pinkerton, Deputy Director. Lewis Wallenmeyer, Assistant Director

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August 31,2005

Mr. Joseph PaisieMail Code: C504-02U.S. Environmental Protection AgencyResearch Triangle Park, NC 27711

Transmitted by E-mailAugust 31, 2005

Dear Mr. Paisie,

I am writing to transmit comments from the Clark County (Nevada) Department of AirQuality and Environmental Management on the August 11, 2005 draft staff work paperon the use of air quality data related to exceptional and natural events for particulatematter standards. We have provided comments under three general headings: (1)General Comments, (2) Responses to Questions - Joseph Paisie Cover Memorandum,(3) Comments On EPA OAQPS Staff Work Paper. Our comments are as follows:

General Comments:

The Clark County Department of Air Quality and Environmental Management (DAQEM)provides the following general comments:

1. The DAQEM requests withdrawal of the draft staff paper dated August 11,2005 and requests the EPA to adopt a new timeline for development andadoption of a revised natural events policy or natural events rulemakingprocess.a. The recommendations contained in the staff paper do not provide a

workable framework for addressing natural events.b. The staff paper presumesthat the PM1Q standardwill be revoked. We

believe this presumption is premature due to the controversy of theproposed replacement PM1o-2.5standard and the likelihood of legalchallenges. We note that even if EPA were to ultimately prevail inimplementing the proposed PM1Q-2.5standard in the face of suchchallenges, the current PM1Qstandard is likely to remain in place for anextended period of time.

c. The staff paper does not provide for flagging PM10and ozone data drivenby natural events. The EPA has assumed a nexus between handling datafrom natural/exceptional events and establishment of the NAAQS, and hasexcluded consideration of other pollutants on this basis. The Clean Air Act(CAA) does not appear to support this assumed nexus, which may besubject to legal challenge.

BOARD OF COUNTY COMMISSIONERSRORY REID, Chairman' MYRNA WilLIAMS, Vice Chair

TOM COLLINS' YVONNE ATKINSON GATES' CHIP MAXFIELD' lYNETTE BOGGS McDONALD' BRUCE L. WOODBURYTHOM REillY, County Manager

Mr. Joseph Paisie August 31, 2005 of 13

d. The EPA has not followed through with commitments made to the Western States Air Resources Council (WESTAR) by Lydia Wegman to work collaboratively with the WESTAR State Air Directors.

2. The DAQEM requests the EPA develop a new staff paper in consultation with the STAPPA/ALAPCO. a. State and local agencies have the largest body of expertise in dealing with

natural events. b. The EPA should devote particular attention to collaboratively developing

policy and requirements related to the eleven issues submitted by the WESTAR Natural Events Policy Work Group, last updated on April 21, 2005.

The DAQEM requests and strongly encourages the EPA to base all future natural events policies, rules, and requirements around the Guiding Principles outlined in the current policy as amended below:

(1) The Workgroup recommends that protection of public health remain the primary

concern.

(2) The Workgroup recommends that Footnote 3 in the policy referenced in Guiding Principle 2 be changed to reflect the terminology used in the Air Quality Index (AQI), including references to other particulate matter (PM) standards and averaging times, to reflect changes to PM standards since adoption of the NEP in 1996.

(3) The Workgroup recommends that Guiding Principle 5 be changed to state

“Emission controls should be applied to sources that contribute significantly to exceedances when those controls will result in fewer exceedances of the standard.” to remedy the implied equivalence of the terms exceedance and violation in the existing statement of this Guiding Principle.

Responses To Questions - Joseph Paisie Cover Memorandum A memorandum from Joseph Paisie accompanied the Staff Paper, indicating that agency input was particularly desired on four issues related to the treatment of data. The DAQEM’s comments on these issues are as follows:

1. The level of documentation that should be required to substantiate an exceptional or natural event claim.

Mr. Joseph Paisie August 31, 2005 of 13 Response: The level of documentation required should be sufficient to establish a clear and causal relationship between the measured exceedances and the natural event. The current Natural Events Policy recommends the following:

In circumstances where a State has reason to believe that natural events have caused measured exceedances of the NAAQS, the State is responsible for establishing a clear causal relationship between the measured exceedance and the natural event. Supporting documentation concerning the natural event could include filter analysis, meteorological data (e.g., wind speed and wind direction to support a source receptor relationship), modeling and receptor analysis, videos and/or photographs of the event and the resulting emissions, maps of the area showing sources of emissions and the area affected by the event, and news accounts of the event.

This provides an appropriate level of documentation for the natural events and exceptional events rule. In practice, the DAQEM has found that this provides Clark County and the EPA regional office with sufficient yet flexible guidance to develop an appropriate level of documentation commensurate with the natural event in question. Concerns have been expressed over the lack of specificity by other air regulatory agencies when embarking on preparation of event “justification” or “validation” documentation. A separate guidance document can be developed following promulgation of the exceptional and natural events rule to provide additional specificity as required. The EPA should work collaboratively with the state and local agencies through STAPPA/ALAPCO in developing this guidance.

2. The flagging of data below the standard that may affect the annual average for an area. Should there be an air quality threshold for consideration of an exceptional event or natural event? Such as one or two standard deviations from the mean concentration reported at a particular monitoring site. If this type of approach is chosen, should it be used to set Significant Harm Levels for Emergency Episode Plans? Should Natural Event Action Plans and Exceptional Event Mitigation Action Plans be made a part of the Emergency Episode Plans?

Response: The DAQEM believes that state and local agencies should be allowed to flag data where elevated concentrations of pollutants can be tied to natural events. Issues such as criteria for elevated concentrations and linkage of the concentrations to the natural event should be detailed in a guidance document, the development of which should occur following promulgation of the exceptional and natural events rule. The EPA and state and local air regulatory agencies should develop the guidance document collaboratively.

Mr. Joseph Paisie August 31, 2005 of 13

3. The time frame for State, local, and Tribal air quality agencies to flag and

submit documentation to the Regional Office related to an exceptional or a natural event, and the time period that Regional Offices should take action in order to concur or non-concur on flagged data in the AQS database.

Response: The DAQEM advises that the minimum time period within which proper natural event documentation can be prepared is 180 days following the end of the quarter in which the event occurs. States that rely on filter-based sampling systems may require even more time. As detailed below, this time period may not be sufficient in every situation. We therefore request that the states have the option of requesting a 60-day extension to this time period from the regional office for cause. Details on what constitutes appropriate cause for an extension should be worked out in consultation with state and local agencies through STAPPA/ALAPCO. The air regulatory agency in the State of Nevada with the most experience in preparing natural event documentation for high winds is the Clark County DAQEM. Clark County has prepared documentation for a total of eight high wind events, beginning in 2002. The DAQEM completed, but did not submit, a ninth documentation package for which wind speeds were very close to the wind speed thresholds established for Clark County high wind events. The Clark County natural event program has been very successful. The EPA regional office has concurred with all documentation packages DAQEM submitted during this time period. Under the provisions of Clark County’s Natural Events Action Plan (NEAP), public notification and enhanced enforcement activities begin prior to any forecasted event. Where forecasted winds occur, department planning staff typically begin collection of information and development of documentation during the event. Clark County is fortunate in that the entire PM10 monitoring network uses continuous samplers. This allows the county to track concentrations during the day, and staff typically knows if an exceedance will occur prior to the end of the sampling period. Development of documentation continues following the event, but cannot be completed, until Quality Assurance/Quality Controlled (QA/QC) procedures are applied to the data. This typically takes 30 to 60 days and requires that the monitoring division conduct QA/QC procedures out of sequence, interrupting the division’s workflow. In addition, information on enforcement activities, such as the number of site inspections conducted before and during the event, the number of corrective action orders issued, and the number of notices of violations issued, does not become available until completion of the next monthly report.

Mr. Joseph Paisie August 31, 2005 of 13 In practical terms, it is not possible to complete the draft documentation for an event in less than 60 days. Following completion of the draft documentation, an additional 60 days are required to comply with statutory public comment periods and public meetings, and preparation of responses to comments where required. Additional time is required for state approval and transmittal to the EPA regional office. In those rare occasions where episodes occur at only one to two monitoring sites, it may be possible to complete the draft documentation package a little sooner. Where a regional dust storm results in exceedances across the entire monitoring network of 17 particulate samplers, completion of the draft documentation will require more than 60 days to complete. The Clark County NEAP requires a formal public review process of the draft documentation after completion. This public review process is consistent with that outlined in the staff paper and will require a minimum of 60 days to complete. Following completion of the public hearing process, staff must prepare written responses to public comments and incorporate these into the documentation. In some instances, public comments may identify the need for additional documentation. The package must then be reviewed by DAQEM management and transmitted to the NDEP for review, approval, and transmitted to the EPA regional office. For states that rely on filter-based samplers, this process is much more difficult. Typically, a state will not even know if an exceedance has occurred until 90 days after the event. The DAQEM may be required to deal with natural events measured by filter-based samplers under the more stringent PM2.5 and the recommended PM10-2.5 standards. In these situations, we believe that it will be very difficult for the DAQEM to comply with a 180-day requirement. Provision for granting a 60-day extension to the 180-day time period is therefore warranted. With the mandated public comment procedures, time required for completion of laboratory analysis of filter samples, and time required for analyzing an event and preparing documentation, it would not be possible to consistently complete the requirements in a shorter time period.

4. Should there be a bright line test associated with high wind events, or should we continue to make decisions concerning these types of events by requiring States to submit documentation to show that high wind events should be considered as unusual and not typical for an area.

Response: The DAQEM believes that wind speed thresholds must be set by one of two criteria: (1) Was the wind speed sufficient to overwhelm natural sources? (2) Was the wind speed sufficient to overwhelm Best Available Control Measures (BACM) on anthropogenic sources? The local conditions that will determine what the actual wind speed threshold will be for a given area include soil types and precipitation. The wind thresholds for a given area can be determined experimentally by wind tunnel testing or other types of science-based field studies. Empirical data should establish the “bright line” for a region’s wind speed thresholds.

Mr. Joseph Paisie August 31, 2005 of 13 Characterizations such as “unusual” or “not typical” should not be a factor in this assessment. It must be accepted that some regions are more prone to high winds than other regions, in the same way some other regions are more prone to seismic or volcanic activity. We are aware that several air regulatory agencies have proposed to flag data based on wind speeds that do not meet either of the above criteria. We are not persuaded of the merits of such request. Comments On EPA OAQPS Staff Work Paper The DAQEM provides the following comments on the EPA OAQPS Staff Work Paper on Air Quality Data Related to Exceptional Events and Natural Events for the Particulate Matter Standards, dated August 11, 2005, referred to herein as staff paper. Comment 1: Section 1 of the Staff Paper indicates that the rulemaking will only address PM and PM .

2.5

10-2.5 The DAQEM strongly believe that the rulemaking should include PM10 and Ozone. It is our understanding that the OAQPS is developing the Exceptional and Natural Events Rule as a companion rule to the upcoming revisions to the NAAQS. We believe that this approach is without legal merit and does not provide a rational means for addressing exceptional events or natural events. The exceptional events and natural events regulation must be considered separately from the new NAAQS. The CAA Section 188, “Classifications and Attainment Dates,” subpart (f) “Waivers for Certain Areas,” does not have a nexus to establishment of the NAAQS under CAA Section 109. EPA approval of the State of Nevada PM10 State Implementation Plan (SIP) for Clark County is currently under litigation. The same litigants have questioned the legal validity of the current PM10 Natural Events Policy (NEP), arguing that by determining attainment and nonattainment status on the basis of a policy, the EPA is exceeding its legal authority under the CAA. The DAQEM is very concerned that by not including PM10 in the “Exceptional and Natural Events Rule,” findings of attainment that rely on data flagged under a policy may be more vulnerable to legal challenge in the future. The DAQEM also believes very strongly that ozone should be included in the “Exceptional and Natural Events Rule.” Clark County recently experienced the most severe ozone exceedances that have occurred in this region over the past 20 years. The events in question occurred during an intensive study period in the Clark County ozone and precursor study. The study data demonstrate very clearly that the source of the elevated ozone levels was wildfires.

Mr. Joseph Paisie August 31, 2005 of 13 Comment 2: Section I, footnote 1, presumes the revocation of the PM10 standard. The DAQEM strongly believes this presumption is premature due to the controversy of the proposed replacement PM10-2.5 standard and the likelihood of legal challenges. Even if EPA were to ultimately prevail in implementing the proposed PM10-2.5 standard in the face of such challenges, the current PM10 standard is likely to remain in place for many years beyond EPA’s initial promulgation of the new standard. It is therefore critical that the new rule address this pollutant. Comment 3: Section II, paragraph 5, sets forth the following:

This guidance also attempts to maintain some of the traditional delineations of episodic event types, such as chemical spills and clean up activities after a major disaster, yet focuses treatment of such data according to the predictability and controllability of the event in question. For instance, for an event that can reasonably be anticipated, but which is not expected to recur at the same location, the State, local, or Tribal agency will be expected to develop a plan to mitigate the risks of public exposure related to the event. For an event that can not reasonably be anticipated, and which is unlikely to recur at the same location (e.g., A major disaster, industrial accidents, or chemical spills etc.), the guidance requires a post-event action plan to ensure prompt clean-up of debris related to the event and calls for measures to be taken that will mitigate the impact of the event on the public.

The DAQEM notes that key words and phrases in this section, including “uncontrollable, “not expected to recur at the same location,” and “cannot reasonably by anticipated,” illustrate the inappropriateness of requiring air quality plans to address such events. The states already have plans for dealing with such events that fall outside the purview of the CAA. Emergency events are news worthy and the media makes a concerted effort to inform the public of any unhealthy conditions occurring as a result of the event, including unhealthy air quality. A generic non-specific or an event-specific air quality plan for alerting the public is unnecessary to ensure that critical information on air quality conditions reaches the public in these situations. Because such events constitute a disruption to the community, affected agencies are forced to mitigate the impacts of such events on the public quickly. Requiring states and local agencies to use resources to develop mitigation plans for uncontrollable sources that cannot reasonably be anticipated seems an unreasonable and inefficient use of state and local agency resources.

Mr. Joseph Paisie August 31, 2005 of 13 Homeland Security considerations may in some instances prevent air regulatory agencies from sharing emergency response information with the public, preventing an agency from moving forward with the public process set forth in the staff paper for mitigation plan development. Moreover, air regulatory agency staff, including EPA staff, may not have the authorization or security clearances required to review some elements of these plans. The DAQEM therefore requests that this Exceptional Event Mitigation Action Plan (EEMAP) requirement be removed from further consideration in the rule development process. Comment 4: Section 4.1, paragraph 2, discusses determination of how the measured data is affected by a natural event. The DAQEM notes that unless a natural event occurs during a major air pollutant field measurement study for the area of concern, then modeling of the natural event will generally not be feasible. Where the event occurs during a major air pollutant field measurement study, it may not be feasible to complete required laboratory analysis and complete the modeling within the 180-days recommended by the DAQEM for submittal of natural events documentation. Comment 5: Section 4.1, paragraph 3, states in part that in most cases, the area impacted by a natural event will be limited. Natural events often affect large areas, and may affect multistate or even multinational boundaries. Some types of natural events, such as volcanoes, will almost always affect large areas. It is likewise rare for high winds to affect only a small area. Wildfires may affect rural areas with small populations or multistate areas with very large populations. The DAQEM believes that EPA should step back and begin a collaborative effort with state and local agencies to develop appropriate requirements for handling data affected by these natural events. Comment 6: Section 5.1, paragraph 3, discusses time frame for submitting documentation. States that documentation must be submitted to EPA no later than 60 days following the end of the quarter in which the natural event occurred. Also provides for 30 days to submit additional information requested by the regional office. Provides the EPA region 60-days to review the submitted documentation.

Mr. Joseph Paisie August 31, 2005 of 13 The DAQEM advises that the minimum time period within which proper natural event documentation can be prepared is 180 days following the end of the quarter in which the event occurs. The time frames required for QA/QC assessments, laboratory assessments, field reporting, data acquisition from outside sources, and legal notice requirements for public review of documents do not allow for a shorter time period. States that rely on filter-based sampling systems may require even more time. As detailed below, our 180-day recommendation may not be sufficient in every situation. We therefore request that states have the option of requesting a 60-day extension to this time period from the regional office for cause. Details on what constitutes appropriate cause for an extension should be worked out in consultation with state and local agencies through STAPPA/ALAPCO. The air regulatory agency in the State of Nevada with the most experience in preparing natural event documentation for high winds is the Clark County DAQEM. Clark County has prepared documentation for a total of eight high wind events, beginning in 2002. The DAQEM completed, but did not submit, a ninth documentation package, in which wind speeds were very close to the wind speed thresholds established for Clark County high wind events. The Clark County natural event program has been very successful; the EPA regional office has concurred with all documentation packages DAQEM submitted during this time period. Under the provisions of Clark County’s Natural Events Action Plan (NEAP), public notification and enhanced enforcement activities begin prior to any forecasted event. Where forecasted winds occur, department planning staff typically begins collection and development of documentation during the event. Clark County is fortunate in that the entire PM10 monitoring network uses continuous samplers. This allows the County to track concentrations during the day and staff typically knows if an exceedance will occur prior to the end of the sampling period. Following the event, development of documentation continues, but cannot be completed until QA/QC procedures are applied to the data. This typically takes 30 to 60 days and requires that the monitoring division conduct QA/QC procedures out of sequence, interrupting the division’s workflow. In addition, information on enforcement activities, such as the number of site inspections conducted before and during the event, the number of corrective action orders issued, and the number of notices of violations issued does not become available until completion of the next monthly report. In practical terms, it is not possible to complete the draft documentation for an event in less than 60 days. Following completion of the draft documentation, an additional 60 days are required to comply with statutory public comment periods and public meetings, and preparation of responses to comments where required. Additional time is required for state approval and transmittal to the EPA regional office.

Mr. Joseph Paisie August 31, 2005 of 13 In those rare occasions where episodes occur at only one to two monitoring sites, it may be possible to complete the draft documentation package a little sooner. Where a regional dust storm results in exceedances across the entire monitoring network of 17 particulate samplers, completion of the draft documentation will require more than 60 days. The Clark County NEAP requires a formal public review process of the draft documentation after completion. This public review process is consistent with that outlined in the staff paper and will require a minimum of 60 days to complete. Following completion of the public hearing process, staff must prepare written responses to public comments and incorporate these into the documentation. In some instances, public comments may identify the need for additional documentation. The package must then be reviewed by DAQEM management and transmitted to the NDEP for review, approval, and transmittal to the EPA regional office. For states that rely on filter-based samplers, this process is much more difficult. Typically, a state will not even know if an exceedance has occurred until 90 days after the event. The DAQEM may be required to deal with natural events measured by filter-based samplers under the more stringent PM2.5 and the recommended PM10-2.5 standards. In these situations, we believe that it will be very difficult for the DAQEM to comply with a 180-day requirement. Provision for granting a 60-day extension to the 180-day time period is therefore warranted. With the mandated public comment procedures, time required for completion of laboratory analysis of filter samples, and time required for analyzing an event and preparing documentation, it would not be possible to consistently complete the requirements in a shorter time period. Comment 7: Section 6.3, paragraph 3, EPA proposes to retain the “Interim Air Quality Policy on Wildland Prescribed Fires, issued May 15, 1998”. The DAQEM notes that the interim policy is now eight years old. We believe that prescribed fires should be addressed under the same policy or rule as wildfires, and strongly recommend that EPA step back and work collaboratively with state and local agencies to integrate prescribed fires into the new rule. EPA’s failure to embrace prescribed fires under the proposed rule could make the approved smoke management plans vulnerable to legal challenge, and may result in conflicting requirements and confusion among regulatory agencies and the public.

Mr. Joseph Paisie August 31, 2005 of 13 Comment 8: Section 6.4 High Wind Events. The staff paper indicates that in situations where dust originated from land that was disturbed by anthropogenic activities and where the responsible air quality agency has implemented BACM for the affected sources, the state must document that the controls were in place, being implemented, and being complied with at the time the event in question occurred. The DAQEM concurs with and endorses this requirement, but requests additional clarification on what constitutes implementation and compliance. During the public review of the Clark County NEAP and natural event documentation, an advocacy group noted that a notice of violation had been issued on the day of the national event. The advocacy group argued that clearly BACM had not been implemented because Clark County’s own enforcement record showed that BACM had not been fully applied to the source in question. Clark County responded that it is widely recognized and accepted that it is impossible to achieve 100 percent compliance with a regulation. The EPA uses the term “rule effectiveness” to describe the rate of compliance with a rule. When calculating the emission reductions achieved by a rule, the EPA uses a default “rule effectiveness” value of 80 percent unless an agency can justify using a higher percentage. Clark County believes that under the NEP, the EPA did not intend that an agency achieve 100 percent rule effectiveness in order to implement a NEAP. Rather, the NEP requires the effective implementation of BACM. Clark County accepted the EPA’s 80 percent default rule effectiveness value for development of PM10 SIP emissions inventories and attainment demonstration, but strives to achieve 100 percent control during high wind conditions. In order to achieve the highest possible compliance rate under adverse wind conditions, Clark County issues advisory notices to permit holders before the event and inspects 100 percent of all permitted sources. Although the issuance of some corrective action orders and notices of violation in the hours leading up to and during a natural event show that 100 percent compliance is not achieved, the small numbers of violations issued demonstrate that Clark County’s compliance program achieves a rule effectiveness rate that exceeds the EPA default assumptions for demonstrating attainment of the standard. The DAQEM request that the EPA define “effective implementation of BACM” as achieving the rule effectiveness rate utilized in the applicable SIP or achieving 80 percent rule effectiveness for applicable BACM. This will provide an appropriate link between the exceptional events and natural events regulation and CAA Section 110 SIP planning and attainment demonstration requirements.

Mr. Joseph Paisie August 31, 2005 of 13 Comment 9: Section 7 and 7.1 Exceptional Events. The DAQEM notes that key words and phrases in this section, including “uncontrollable, “not expected to recur at the same location,” and “cannot reasonably by anticipated,” illustrate the inappropriateness of requiring air quality plans to address such events. The states already have plans for dealing with such events that fall outside the purview of the CAA. Emergency events are news worthy and the media makes a concerted effort to inform the public of any unhealthy conditions occurring as a result of the event, including unhealthy air quality. A generic non-specific or an event-specific air quality plan for alerting the public is unnecessary to ensure that critical information on air quality conditions reaches the public in these situations. Because such events constitute a disruption to the community, affected agencies are forced to mitigate the impacts of such events on the public quickly. Requiring states and local agencies to use resources to develop mitigation plans for uncontrollable sources that cannot reasonably be anticipated seems an unreasonable and inefficient use of state and local agency resources. Homeland Security considerations may in some instances prevent air regulatory agencies from sharing emergency response information with the public, preventing an agency from moving forward with the public process set forth in the staff paper for mitigation plan development. Moreover, air regulatory agency staff, including EPA staff, may not have the authorization or security clearances required to review some elements of these plans. The DAQEM therefore requests that this Exceptional Event Mitigation Action Plan (EEMAP) requirement be removed from further consideration in the rule development process. Comment 10: Section 7.4, cleanup after a major disaster. Defines a major disasters as a serious public misfortune for which State and Federal relief has been granted. The DAQEM believes this section needs to be expanded to include smaller disasters or public misfortunes that occur in close proximity to a monitoring site. The DAQEM strongly encourage the EPA to work collaboratively with state and local agencies in defining these parameters.

Mr. Joseph PaisieAugust 31, 2005 of 13

Comment 11:

Section 7.5, development of an Exceptional Event Mitigation Action Plan (EEMAP)

The DAQEM again requests that this requirement be stricken from further consideration.As noted in Comments 3 and 9, such plans fall outside of the purview of the CM, arenot needed to protect the public health, provide no public benefit, and in some caseswould require use of classified information related to Homeland Security that cannot bereleased to the public under federal law.

The DAQEM will look forward to working with your agency in development of anexceptional events and natural rule that protects the public health while providingappropriate standards for handling data for regulatory purposes. Please contact DennisRansel or John Koswan of my staff. Mr. Ransel can be reached at (702) 455-1660. Mr.Koswan can be reached at (702) 455-1647.

Sincerely,

(~/?~Christine Robinson, Director

RUcs

cc: Lydia Wegman, U.S. EPALarry Wallace, U.S. EPAEric Ginsburg, U.S. EPAAmy Royden Bloom, STAPPAIALAPCONancy Kruger, STAPPAIALAPCOJennifer Carr, NDEP/BAQPAmy Zimpfer, U.S. EPA

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