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Treatment of Natural Events

Treatment of Natural Events. WESTAR Planning Committee & WESTAR NEP Workgroup March 28, 2006. Kudos to EPA!. EPA has listened Proposal has changed substantially. Proposed rule. Complex proposal Includes options Commenting will present difficulties Lay out principles. Compare.

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Treatment of Natural Events

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  1. Treatment of Natural Events WESTAR Planning Committee & WESTAR NEP Workgroup March 28, 2006

  2. Kudos to EPA! • EPA has listened • Proposal has changed substantially

  3. Proposed rule • Complex proposal • Includes options • Commenting will present difficulties • Lay out principles

  4. Compare • WESTAR Recommendationsapproved by WESTAR Council May 6, 2005 • Treatment of Data Influenced by Exceptional EventsEPAproposed rule: 71 FR 12592, March 10, 2006

  5. WESTAR All PM PM2.5 PM10 PM10-2.5 EPA PM Ozone 1. What pollutants?

  6. WESTAR Seismic/volcanoes Associated clean-up Wind-generated dust Impact of Drought EPA Volcanic/seismic Natural disasters/ associated clean-up High wind events Stratospheric ozone intrusion 2. What type of Natural Events?

  7. WESTAR Wildfires EPA Wildfires/wildland fire use fires Prescribed fires may qualify as Exceptional Events 2. [Continued]

  8. Role of Drought • SAFE-TEA-LU revises CAA Section 319 to exclude meteorologicaleventsinvolvingalackofprecipitation • Wind-generated dust natural event • Caused by winds • Drought may lower wind thresholds • EPA needs to • Clarify • Provide an example

  9. Role of Inversions • SAFETEA-LU revises CAA Section 319 to exclude meteorological eventsinvolvinginversions • A community may be impacted by inversion-related drainage smoke • EPA needs to • Clarify • Provide an example

  10. Fire • Issues raised about treatment of • Wildland fire use fires • Prescribed fires • Propose for further discussion and comment

  11. WESTAR Any and all data impacted by a natural event 24-hour, and Annual EPA Criteria Above the standard (an exceedance) Significantly beyond the normal fluctuating range of air quality No exceedance “but for” the event 3. What Data can be Flagged?

  12. Statistical Analyses WESTAR Principles • Statistical analyses may qualify an event as a natural event. • Statistical analyses may not exclude an event from consideration.

  13. WESTAR Yes EPA 2 of the 3 Options for Comment: Interim flag/ documentation up to 3 years following quarter of occurrence Flag/documentation no later than 6 months before a regulatory decision 4. Address the Annual Standard?

  14. WESTAR By the end of the quarter of event data submission to AQS EPA 3 Options for Comment: Flag at time of submission to AQS Interim flag at time of submission to AQS Flag no later than 6 months before a regulatory decision 5.a. Flagging Data

  15. WESTAR No later than 180 days after the end of the quarter a violationis discovered EPA 3 Options for Comment: 180 days following the quarter in which theeventoccurred Up to 3 years following the quarter in which theeventoccurred 5.b. Submittal of Documentation

  16. EPA no later than 6 months before a regulatory decision 5.b. [Continued]

  17. WESTAR Collect and retain data directly after an event EPA [No equivalent provision] 6. Collection of Documentation

  18. WESTAR No Limit on timeframe for flagging and documentation EPA Option for Comment: Flag/documentation no later than 6 months before a regulatory decision 7. Documentation during SIP Development

  19. WESTAR Discount exceedances Address new standards Qualify for limited maintenance plan Exclude data from attainment & maintenance demonstrations EPA Discount exceedances Purposes for Flagging Data

  20. WESTAR EPA-States collaborative process for national guidance Technical dispute resolution mechanism EPA Regional Offices-States regional criteria EPA No specified minimum level Examples of kinds of information Comment requested on whether guidance needed for national consistency No dispute resolution mechanism 8. Reasonable Documentation

  21. Documentation • The Natural Events Policy • No minimum level of documentation • Gave examples of kinds of information • Lessons • Examples can become requirements • Examples may not be applicable (high winds/transport) • Unintended consequences

  22. [Continued] • Documentation needs to be reasonable • Fires may affect multiple days • Proposed PM10-2.5 standard may result in more exceedances

  23. WESTAR Public education/ notification Minimize public exposure Controls for sources contributing significantly to unhealthy air EPA Options for Comment: Implement/ document public notification, education, appropriate & reasonable controls General mitigation plan as part of Section 110(a)(1) SIP 9. Natural Events Action Plans

  24. EPA Develop a mitigation plan following an event Do not require specific mitigation plan or measures 9. [Continued]

  25. Mitigation Plans • EPA proposing to require RACM • Taking comment on requiring BACM • EPA guidance on PM RACM? • Relation to a violation • Does an Exceptional Event that will not occur again need a mitigation plan?

  26. WESTAR 18 months following the end of quarter showing a violation EPA Options for Comment: With documentation for an event Within 3 years of NAAQS promulgation 18 months after the close of the quarter of the event 10. Action Plan Submittal

  27. EPA No requirement. Broad flexibility in response to an event 10. [Continued]

  28. WESTAR EPA-States collaborative process to define expectations EPA Documentation Up-front State-EPA Regional Office consultation 30-day EPA review Option for 30-day extension 11. Documentation/Plan Processing

  29. EPA Mitigation Plan Options for Comment: EPA oversight EPA review and concurrence EPA review and concurrence EPA provides broad flexibility 11. [Continued]

  30. SUMMARY • Kudos to EPA! • Issues for further consideration • “High Winds,” Drought and Inversions • Fire • Statistical Analyses • Purposes for Flagging Data • Documentation • Mitigation Plans

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