WESTAR Planning Committee NEP Workgroup September 22, 2005 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 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

Staff Work Paper Cover Letter

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”

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

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

3. Annual NAAQS? WESTAR Yes Staff Paper Yes

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

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

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

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

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

Natural Events Action Plan Should: 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 WESTAR Public Education / Notification Minimize Public Exposure Controls for Sources Contributing Significantly

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

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

Workgroup Members Gerry Guay (AK) Gail Cooke (NM) 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)