1. WESTAR Planning Committee NEP Workgroup September 22, 2005
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. Staff Work 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”

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

11. 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

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

13. 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

14. 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

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

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

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

18. 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

19. 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”

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

21. 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)