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Exceptional Events and Region 9 AMTAC April 12 , 2011

Exceptional Events and Region 9 AMTAC April 12 , 2011. The Exceptional Events Rule & R9:. The Exceptional Events Rule (EER) is the only mechanism that allows S/L/Ts to exclude data* from regulatory decisions. R9 has > 45,000 exceptional event flags in AQS.

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Exceptional Events and Region 9 AMTAC April 12 , 2011

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  1. Exceptional Events and Region 9AMTACApril 12, 2011

  2. The Exceptional Events Rule & R9: • The Exceptional Events Rule (EER) is the only mechanism that allows S/L/Ts to exclude data* from regulatory decisions. • R9 has > 45,000 exceptional event flags in AQS. • We have acted on a few, but there are many, many more. • Prioritizing those that affect immediate regulatory actions. • Flags associated with: • Dry, dusty, windy areas (AZ, CA’s central valley) = PM2.5, PM10 flags • Summer wildfires (CA, NV) = O3, PM2.5, PM10flags • Volcanic activity (Hawaii) = SO2, PM2.5 flags • Fireworks = PM2.5 flags *Data that was collected in accordance with all applicable requirements.

  3. The Exceptional Events Rule & R9: • Currently takes many hours for S/Ls to produce, and for EPA to review and act on, one exceptional events package. • EPA R9 and S/L/Ts are looking to guidance (rule change) to promote transparent and efficient implementation of the EER. • National EER Workgroup has produced four products: • Overview memo • Q&A • Guidance on High Wind Dust Events • Website

  4. Guidance on High Wind Dust Events • Overview • R9/Workgroup product • Most applicable to dry, dusty areas in the West. • First comprehensive interpretation of the EER: • broad principles apply to all exceptional events; • many elements could be carried over to other event-specific guidance documents • Clarifies requirements, EER interpretation, provides step-by-step process for agencies to follow when developing packages, example analyses, package checklist, State/EPA submittal & review schedule.

  5. Guidance on High Wind Dust Events • Highlights • Addresses key litigation-risk issues: • Definition of event = wind + dust, not just the wind itself • Controls requirements and analyses • Provides streamlined process to satisfy “not reasonably controllable or preventable” criteria when wind speeds ≥ 25 mph* • Seeks progressive controls when events recur (e.g. optional High Wind Action Plan) • Provides general State/EPA submittal and review schedule *25 mph = minimum wind speed needed to entrain particles from stabilized surfaces in the western US.

  6. Stakeholder Involvement • Draft guidance is imminent; EPA will be soliciting stakeholder input • Janet McCabe will discuss at the April 25th WESTAR meeting • EPA will also invite comment through NACAA • Very interested in receiving informal feedback during this time • Near Term Draft Guidance for Stakeholder Review / Comment: • 1. Overview Memo from Gina McCarthy to Regional Offices • Identifies concepts to be addressed through guidance • Describes administrative process for demonstration submittal • 2. Frequently Asked Questions • 3. High Winds Guidance Document • 4. Website with example submissions at http://www.epa.gov/ttn/analysis/exevents.htm

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