GREAT BASIN UNIFIED AIR POLLUTION CONTROL DISTRICT 

RULE 701 – AIR POLLUTION EPISODE PLAN FOR PARTICULATE MATTER 

ADOPTED MARCH 3, 2014 

ENCLOSURE 2 

GBUAPCD March 3, 2014 Staff Report (with attachments) 
Rule 701 – Air Pollution Episode Plan 

March 3, 2014 – Agenda Item No. 6 – Page 1 

GREAT BASIN UNIFIED AIR POLLUTION CONTROL DISTRICT

157 Short Street, Bishop, California 93514-3537 

Tel: 760-872-8211 Fax: 760-872-6109 

www.gbuapcd.org 

BOARD REPORT

Mtg. Date: March 3, 2014 

To: District Governing Board 

From: Phill Kiddoo, Senior Research and Systems Analyst 

Subject: Rule 701 – Air Pollution Episode Plan 

Summary 

Under United States Environmental Protections Agency (U.S. EPA) regulations, the specific 

requirements for emergency episode plans depend upon the priority classification of a given area. 

The priority classification system used in 40 CFR Part 51, subpart H, identifies areas that must 

submit emergency episode plans, and identifies specific content requirements for such plans. 

Measurements at District PM10 air quality monitoring sites from 1986 - 2013 have recorded 

numerous 24-hour maximum concentrations at several locations exceeding the US EPA Priority I 

Region area criteria of 325 μg/m3. Measurements at District PM10 air quality monitoring sites 

have also recorded episodes exceeding the U.S. EPA’s level of significant harm set at 600 μg/m3 

(averaged over 24 hours), that can pose a significant risk of harm to the health of the general 

public (40 CFR 51.151). 

For PM2.5, the U.S. EPA has not yet promulgated regulations that would provide the ambient 

levels to classify priority areas. Based on guidance recommended by the U.S. EPA on September 

25, 2009 (EPA’s 2009 I-SIP guidance) , the California Air Resources Board (CARB) has asked 

EPA to treat GBUAPCD as a Priority II for purposes of PM2.5 emergency episode regulation. 

(California Infrastructure SIP adopted January 23, 2014). Measurements at the District’s 

continuous PM2.5 monitor in Keeler have recorded concentrations in the Priority Level II range. 

The District’s Owens Lake Health Advisory Program has been successfully alerting the public at 

times when unhealthy levels of PM10 pollution occur since 1995. This existing health advisory 

program notifies residents of the appropriate actions to take in order to reduce exposure to the 

adverse health effects of these high concentration dust events. Similar to the Health Advisory 

Program, the District now seeks to further improve and refine our health alert system via Rule 

701 – Air Pollution Episode Plan. 

Theodore D. Schade

Air Pollution Control Officer
Rule 701 – Air Pollution Episode Plan 

March 3, 2014 – Agenda Item No. 6 – Page 2 

District Rule 701 – Air Pollution Episode Plan, expands pollutant episode criteria beyond PM10 

to include criteria levels for PM2.5. As an additional protective public health measure, wildfire 

smoke episode trigger levels for PM10 will be incorporated. Table 1 below summarizes all 

pollutant episode criteria. Rule 701 defines these criteria, provides public notification 

procedures, recommends precautionary actions, expands notifications throughout the entire 

District and details specific District requirements. 

Table 1. 

EPISODE CRITERIA

For the purpose of Rule 701, the following episode criteria shall apply:

Air Pollutant Averaging Time Stage 1 Health Advisory Stage 2 Health Advisory

PM10  ‐ Dust 1 Hour 400 μg/m3 800 μg/m3

PM2.5 ‐ Dust 1 Hour 150 μg/m3 300 μg/m3

PM10  ‐ Wildfire Smoke 1 Hour 100 μg/m3 200 μg/m3

Fiscal Impact 

None. 

Board Action 

Staff recommends that the Governing Board approve Rule 701 – Air Pollution Episode Plan. 

Attachments: 

Draft Rule 701 – Air Pollution Episode Plan 

Air Pollution Episode Plan for Particulate Matter - Supporting Technical Document 

Digital copies of these attachments are also available on the district website at: 

http://gbuapcd.org/boardmeetings/2014/20140303/Rule701/Rule701Draft.pdf 

http://gbuapcd.org/boardmeetings/2014/20140303/Rule701/Rule701TechnicalSupportingDocument.pdf 
GBUAPCD – Rule 701

Page 1 of 5

RULE 701. AIR POLLUTION EPISODE PLAN 

Adopted: / /14 

A. Description 

 

1. The Great Basin Unified Air Pollution Control District (GBUAPCD) Air Pollution 

Episode Plan is a system designed to alert the public of air contaminants that may be 

harmful to health and to protect that portion of the population at risk. It establishes 

advisory procedures when specified levels are reached. 

B. Purpose 

1. Define air pollution episode criteria. 

2. Provide for episode notification to the public. 

3. Recommend precautionary actions to be taken during episodes. 

4. Prevent or reduce the severity of episodes. 

C. GBUAPCD Requirements 

1. Measurements 

a. The APCO shall maintain strategic air monitoring stations throughout the District 

so that air quality can be monitored on a continuous basis and air pollution 

episodes can be measured and predicted. 

b. The APCO shall utilize other sources of information, including, but not limited 

to, the National Weather Service, Tribal Environmental Exchange Network 

and Incident Information System for episode notification and forecasting. 

2. Episode Notifications 

a. The APCO shall notify the United States Environmental Protection Agency 

(USEPA), California Air Resources Board (CARB), news media, schools, 

medical facilities, child day care facilities and the general public when an 

episode is declared. 

b. The APCO shall maintain on-line access to district wide air monitoring network 

measurements at http://gbuapcd.org/data. 

c. The APCO shall provide on-line subscription options for episode notifications 

at http://gbuapcd.org/healthadvisory. 

d. The APCO shall monitor air quality 24 (twenty four) hours a day, 7 (seven) 

days a week and will disseminate episode information to the parties identified 

in paragraph C.2.a and episode notification subscribers by the following 

methods within an hour of the first hourly reading in a day that exceeds the 

episode criteria specified in paragraph C.4: 

i. Phone text messaging 

ii. E-mail to the healthadvisory@gbuapcd.org listserv 

iii. Website http://gbuapcd.org/healthadvisory 

 
GBUAPCD – Rule 701

Page 2 of 5

3. Notification Content 

a. Stage level. 

b. Impacted geographic area(s) and communities. 

c. Pollutant for which the episode is declared, specified dust or wildfire smoke air 

contaminant and PM concentration. 

d. Associated health message. 

4. Episode Criteria (Attachment 1) 

a. A Stage 1 air pollution health advisory will be issued when hourly PM10 

particulate pollution levels exceed 400 micrograms per cubic meter (μg/m3) for 

dust and 100 μg/m3 for wildfire smoke or when hourly PM2.5 particulate 

pollution levels exceed 150 microgram per cubic meter (μg/m3). 

b. A Stage 2 air pollution health advisory will be issued when hourly particulate 

pollution levels exceed 800 μg/m3 for dust and 200 μg/m3 for wildfire smoke or 

when hourly PM2.5 particulate pollution levels exceed 300 microgram per 

cubic meter (μg/m3). 

5. Actions 

a. Stage 1 

A Stage 1 health advisory will recommend: 

i. Minimize outdoor activity. 

ii. Children, the elderly, and people with heart or lung problems refrain 

from strenuous outdoor activities in the impacted area. 

iii. Outdoor physical education classes, sports practices, and athletic 

competitions should be rescheduled or cancelled if practicable. 

b. Stage 2 

A Stage 2 health advisory will recommend: 

i. Eliminate outdoor activities in impacted area. 

ii. Remain indoors with doors and windows closed until the episode is 

terminated. 

iii. Avoid all activities that produce aerosols, dust, fumes and other irritants. 

6. Episode Termination 

a. An episode shall terminate when the concentration of the pollutant which 

causes the declaration of such episode has been verified to have fallen below 

the criteria level for the declaration of the episode and an analysis of 

meteorological and air quality data indicates that the pollutant concentration is 

expected to continue to decrease. 

7. Special Actions for Prescribed Burning 

 Where prescribed burning is defined in: 

 Rule 408 – Open Burning in Agricultural Operations or Disease or Prevention 

 Rule 409 – Range Improvement Burning 

 Rule 410 – Forest Management Burning 

Rule 411 – Wildland Vegetation Management Burning in Wildland and 

Wildland/Urban Interface Areas 

Rule 412 – Open Burning of Non-Industrial Wood Waste at City of County 

Disposal Sites 
GBUAPCD – Rule 701

Page 3 of 5

a. Upon the declaration of any predicted Stage 1 or Stage 2 episode, all coinciding 

scheduled prescribed burning, shall be prohibited. 

b. Upon the declaration of any Stage 1 or Stage 2 episode, all prescribed burning, 

if already ignited, shall be terminated. 

8. Interdistrict Coordination 

a. Upon request of an air pollution control officer in an adjoining air basin for 

action to abate Stage 1 or Stage 2 episodes occurring within that district, the 

APCO shall make a determination, and if the need for action is confirmed, 

direct the implementation of the actions required in this Rule for any 

significant source area identified within the District which contributes to the 

ongoing episode in the adjoining district. 

9. Abatement Actions 

a. The APCO shall investigate the nature of the problem and determine if 

abatement actions could be taken to reduce the pollution levels. 

b. The notification system will allow citizens to take actions to limit exposure. 

D. Definitions 

For the purpose of this rule, the following definitions apply: 

1. “Air Contaminant or Air Pollutant” - any discharge, release, or other propagation into 

the atmosphere and includes, but is not limited to, dust, smoke, particulate matter or any 

combination thereof. 

2. “Air Pollution Control Officer” (APCO) - the person appointed to the position of Air 

Pollution Control Officer of GBUAPCD pursuant to the provisions of California Health 

& Safety Code §40750, and his or her designee. 

3. “Child Day Care Facility”- a State licensed child day care, pre-school, or after-school 

program. 

4. “Great Basin Unified Air Pollution Control District” (GBUAPCD)- California regional 

government agency that works to protect the people and the environment of Alpine, 

Mono and Inyo Counties from the harmful effects of air pollution. 

5. “Episodes” – exceedances of hourly PM levels set by the District for issuing air quality 

advisories to protect public health prior to 24-hour exceedances of the National Ambient Air 

Quality Standard and Level of Significant Harm. The applicable Episode criteria, for 

this rule, are presented in Attachment 1. 

6. “Impacted Area and Communities”- geographic location or place of human occupation 

or permanent dwelling within or downwind of known or forecasted pollution impact 

boundaries. 

7. “Medical Facility”- any location at which medicine is practiced regularly ranging from 
GBUAPCD – Rule 701

Page 4 of 5

small clinics and doctor's offices to urgent care centers and hospitals.

8. “News Media” - the written press, television, radio, and other mass media of 

communication such as on-line computer information services. 

9. “PM10 and PM2.5”- Particulate matter of less than 10 and 2.5 microns in aerodynamic 

diameter, respectively, which are regulated under federal and state law to protect public 

health. PM10 and PM2.5 are easily inhaled into the deepest parts of the lung and can 

cause adverse health consequences, particularly for children, the elderly, and people 

with respiratory conditions. 

 

10. “Prescribed Burning”- the intentional use of fire to reduce wildfire hazards, clear 

downed trees, control plant diseases, improve rangeland and wildlife habitats, and 

restore natural ecosystems. 

11. “School”- means public and private educational institutions for children ranging from 

grades Kindergarten through high school. 

12. “Strenuous Outdoor Activity”- Vigorous outdoor exercise lasting short durations at 

high intensity or long durations at moderate intensity. 

 
GBUAPCD – Rule 701

Page 5 of 5

ATTACHMENT 1

EPISODE CRITERIA

For the purpose of Rule 701, the following episode criteria shall apply:

Air Pollutant Averaging Time Stage 1 Health Advisory Stage 2 Health Advisory

PM10  ‐ Dust 1 Hour 400 μg/m3 800 μg/m3

PM2.5 ‐ Dust 1 Hour 150 μg/m3 300 μg/m3

PM10  ‐ Wildfire Smoke 1 Hour 100 μg/m3 200 μg/m3
Air Quality Episode Plan for

Particulate Matter

Great Basin Unified Air Pollution

Control District Rule 701

Supporting Technical Document 

Prepared by:

Phill Kiddoo

Great Basin Unified Air Pollution Control District

March 3, 2014

Great Basin Unified Air Pollution Control District 

157 Short Street, Bishop, California 93514-3537 

Tel: (760) 872-8211, Fax: (760) 872-6109 

E-mail: info@gbuapcd.org
March 3, 2014

Air Pollution Episode Plan for Particulate Matter

Great Basin Unified Air Pollution Control District Rule 701

Supporting Technical Document

TABLE OF CONTENTS

            Page

1 Introduction                   1

2 Geographic and Air Quality Setting               3

2.1 Geographic Setting, Weather and Climate

2.2 Major Sources of Air Pollution

2.3 District Air Quality Monitoring Network

   

3 Health Advisory Program Background           7

3.1 Particulate Matter Health Impacts

3.2 Owens Lake Health Advisories

4 Windblown Particulate Matter             10

4.1 Wind, PM10 and PM2.5

4.2 Particulate Matter Size Comparisons

5 Air Pollution Episode Criteria               15

6 Air Quality Improvements               23

7 References

LIST OF APPENDICIES

Appendix A Daily PM10 at Owens Lake Communities in Health Advisory Program Area, 1995 – 2013

Appendix B Health Advisory PM10 Threshold Exceedances at Owens Lake Community Monitors

Appendix C Keeler Daily PM2.5, Daily PM10, and Max Hourly Wind Speed Data

Appendix D Keeler Hourly PM10 and PM2.5 Data, 2009 – 2013

Appendix E Keeler Daily Average and Daily Max Hourly Data for PM10 and PM2.5

Appendix F Mammoth Lakes Wildfire Season (June – September) PM10 Data
Figures                           Page

Figure 2.1   Owens Lake, Mono Lake and National Annual Max Daily PM10 2000 – 2012 5

Figure 2.2   District Air Quality Monitoring Network (Map)         6

Figure 3.1   Continuous Community Monitors at Owens Lake (Map)       8

Figure 4.1   Keeler Windblown PM10, 1993 – 2013           11

Figure 4.2   Keeler Windblown PM2.5, 2009 – 2013           12

Figure 4.3   Keeler Hourly Particulate Matter Comparisons         13

Figure 4.4   Keeler Daily Particulate Matter Comparisons         14

Figure 5.1 Significant Harm Events for PM10           17

Figure 5.2   Keeler PM10 Episode Criteria Analysis           19

Figure 5.3   Keeler PM2.5 Episode Criteria Analysis             20

Figure 5.4   Mammoth Lake Wildfire Season PM10 June 1992 – October 2013    21

Tables                   Page

Table 1 CARB Classification of Regions for PM2.5 Emergency Episode Plans     2

Table 2 Owens Lake Community Health Advisory Event Level Summary 1995 – 2013    9

Table 3 Current US EPA Air Quality Index for PM2.5 and  PM10         15

Table 4  US EPA’s 2009 I‐SIP guidance for PM2.5 emergency episode plans     16

Table 5  Great Basin Unified Air Pollution Control District Episode Criteria    22
1

Introduction

This technical supporting document for District Rule 701, Air Pollution Episode Plan for

Particulate Matter (PM), has been prepared by the Great Basin Unified Air Pollution Control

District (GBUAPCD) in response to address the Clean Air Act (CAA) emergency episode plan

requirement (CAA sections 110(a)(2)(G) and 303).

Authority to Halt Pollutant Emissions

Under CAA Section 110(a)(2)(G), states are to provide for authority comparable to that in CAA

Section 303, which gives U.S. EPA legal authority to halt the emission of air pollutants causing or

contributing to injury of the public or welfare. U.S. EPA is further authorized to either bring a

lawsuit in federal court or, if such civil action cannot assure prompt protection of public health or

welfare, to issue such orders as may be necessary to protect public health, welfare, or the

environment.

The authority granted to the U.S. EPA Administrator is vested in ARB and the districts under

H&SC Section 42400, et seq. These sections of California law apply to a range of emissions

violations and impose penalties that are equivalent to or exceed federal penalties for

comparable violations. These penalties include the imposition of fines and/or imprisonment (CA

Infrastructure SIP, January 23, 2014).

Under United States Environmental Protections Agency (U.S. EPA) regulations, the specific

requirements for emergency episode plans depend upon the priority classification of a given

area.  The priority classification system used in 40 CFR Part 51, subpart H, identifies areas that

must submit emergency episode plans, and identifies specific content requirements for such

plans.  

Particulate Matter less than 10 microns in aerodynamic diameter (PM10):

For PM10, Priority I Regions means any area with greater ambient concentrations than

the 95 μg/m3 annual geometric mean; 325 μg/m3 24‐hour maximum (40 CFR 51.150).

Although not classified as a Priority I Region, measurements at District air quality

monitoring sites for PM10 from 1986 ‐ 2013 have recorded numerous 24‐hour

maximum concentrations exceeding the Priority I Region area criteria of 325 μg/m3 24‐

hour maximum.  

Beginning in 1995, the District implemented the Owens Lake Health Advisory Program

due to frequent violations in the Owens Valley planning area caused by windblown dust

from Owens Lake. This program was officially adopted in the 1998 Owens Valley PM10

Planning Area Demonstration of Attainment State Implementation Plan (OVPM10 SIP)

(GBUAPCD, 1998). This program was continued as part of the 2003 OVPM10 SIP

(GBUAPCD, 2003) and continues to operate as part of the 2008 OVPM10SIP (GBUAPCD,

2008). Due to the success of this health advisory program, it is now being further refined

and expanded throughout the District as incorporated into Rule 701 – Air Pollution

Episode Plan.

Page 1
Fine Particulate Matter less than 2.5 microns in aerodynamic diameter (PM2.5):

For PM2.5, the U.S. EPA has not yet promulgated regulations that would provide the

ambient levels to classify priority areas. Based on guidance recommended by the U.S.

EPA on September 25, 2009 (EPA’s 2009 I‐SIP guidance)1, the California Air Resources

Board (CARB) has asked EPA to treat GBUAPCD as a Priority II for purposes of PM2.5

emergency episode regulation. (California Infrastructure SIP adopted January 23, 2014).

Table 1.  Recommended classification of regions for PM2.5 emergency episode plans,

per EPA’s 2009 I‐SIP guidance.

Priority PM2.5 24‐hr Concentrations (μg/m3)

Priority Level III < 140.5

Priority Level II 140.5 – 210.4

Priority Level I and IA > 210.4

On December 1, 2011 a PM2.5 concentration in the Priority Level II range of 208 μg/m3

was recorded at the Keeler monitoring station in the Owens Lake area.  Dust storm

events, like the one at Keeler, are caused by windblown dust from the anthropogenically

dried Owens Lake bed and are unique to the Owens and Mono Lakes areas in the

District.  Additional protective public health precautions for PM2.5 will be incorporated

into Rule 701 and implemented as part of the Air Pollution Episode Plan.  These

procedures will remain in effect until dust control measures are fully implemented at

Owens Lake and PM2.5 levels no longer violate the National Ambient Air Quality

Standard (NAAQS).

Wildfire Smoke:

As observed and measured in the Town of Mammoth Lakes from the Aspen Fire and in

the District towns of Markleeville and Bear Valley from the Rim Fire during the summer

months of 2013, smoke impacts from wildfire events can be high enough to surpass

federal air pollution standards. As an additional protective public health measure,

wildfire smoke episode trigger levels for PM10 will be incorporated into Rule 701 and

implemented as part of Rule 701 – Air Pollution Episode Plan.

   

                                                            

1 Memorandum from William T. Harnett, Director, Air Quality Policy Division, OAQPS, to Regional Air Division

Directors, Regions I through X, “Guidance on SIP Elements Required Under Section 110(a)(1) and (2) for the 2006

Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS).” (September 25, 2009)

Page 2
2

Geographic and Air Quality Setting

2.1 Geographic Setting, Weather and Climate

The GBUAPCD encompasses Alpine, Inyo and Mono counties. Measuring approximately 320

miles along its eastern boundary and approximately 135 miles across its southern boundary,

the District covers a total area of 14,102 mi2. Mainly composed of desert, forest and alpine

ecosystems, the low District average population density of 2.6/mi2 enjoys four distinct climatic

seasons. All three counties are bounded by the Sierra crest to the west and the expansive Great

Basin Ecosystem to the east. In the northern end of the District, Alpine and Mono counties are

situated in mixed coniferous forests while in the southern end; Inyo County is situated in an

expansive desert. Because the District is situated in the rain shadow of the Sierra Nevada from

Pacific storms from the west, annual rainfall decreases to the east.

Temperatures in the District range from artic like freezing conditions in the high mountains

during the winter, to scorching world record high temperatures during the summer months in

Death Valley. All areas experience large diurnal swings in temperature between the daily highs

and lower temperatures at night. Wind events are severe and generally associated with the

passage of low pressure systems during winter and spring months. The leading edges of these

low‐pressure systems are usually cold fronts that initially produce winds from the south as the

colder air mass approaches, under‐running and displacing the warmer air in its path. As the

leading edge of the front passes, the wind direction shifts, often resulting in converging winds

from the south along the east side of the Owens Valley and from the north along the west side.

Cold winds from the north typically follow the passage of the low‐pressure system as high

pressure begins to build back over the area.

2.2 Major Sources of Air Pollution

In Inyo County, the southern Owens Valley has been designated by the state and the U.S. EPA

as nonattainment for the state and federal 24‐hour average PM10, standards. The Owens Lake

bed is considered anthropogenic (human caused) source of PM10 and PM2.5 because the City

of Los Angeles’ aqueduct diverts water sources that historically supplied the lake. Windblown

dust from the dry lakebed of Owens Lake is the dominant cause of NAAQS violations for PM10

and PM2.5 in the OVPM10 non‐attainment area.  

In Mono County, the PM‐10 nonattainment problem in the Mono Basin is caused by windblown

dust from the exposed lakebed of Mono Lake. Exposure of the lakebed was primarily caused by

the diversion of water from the Mono Basin by the City of Los Angeles from 1941 through 1989.  

In Alpine County, there are no major sources of air pollution for nonattainment designation.

The greatest threat to poor air quality conditions are infrequent wildfire smoke impacts.

Page 3
In the data available on the US EPA’s Air Data website (http://www.epa.gov/airdata), Owens

Lake and Mono Lake have produced the highest PM10 readings in the nation in all but two of

the past thirteen years. As shown graphically in Figure 2.1, PM10 concentrations from Owens

Lake and Mono Lake have consistently dwarfed values reported from the rest of the nation

since 2000.  

2.3 District Air Quality Monitoring Network

The District operates a multitude of air quality monitoring stations throughout Alpine, Mono

and Inyo Counties. These monitoring stations are displayed in Figure 2.2. Three Owens Lake

monitoring stations depicted, North Beach, Mill Site, and Dirty Socks, are temporarily shut

down since December 2011 due to lease cancelations. The District is working to bring these

monitors back on‐line. In addition to these fixed monitoring sites depicted in Figure 2.2, the

District operates two portable PM10 TEOM monitors that can be deployed in any warranted

location and two additional special purpose monitors located below the Owens Lake shoreline

of 3,600 feet above mean sea level, for specific purposes related to the District’s Owens Lake

Dust ID program.

   

Page 4
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Health Advisory Program Background

3.1 Particulate Matter Health Impacts

PM2.5 and PM10, which indicates particulate matter less than 2.5 and 10 microns in average

aerodynamic diameter, respectively, are extremely small. Because of their small size, the

particles can easily penetrate into the lungs. Breathing these airborne particulates can cause a

variety of health problems. In addition to aggravating existing symptoms associated with

respiratory allergies, it can increase the number and severity of asthma and bronchitis attacks.

It can cause breathing difficulties in people with heart or lung disease, and it can increase the

risk for, or complicate, existing respiratory infections. Children, the elderly and people with

existing heart and lung problems are especially sensitive to elevated levels of PM10. Even

healthy people can be adversely affected by dust at extremely high concentrations. The U.S.

EPA has set an episode level of 600 μg/m3 (averaged over 24 hours) as the level that can pose a

significant risk of harm to the health of the general public (40 CFR 51.151).

3.2 Owens Lake Health Advisories

The Owens Lake Health Advisory Program carried out in the Owens Valley Planning Area since

1995 has been successfully alerting the public at times when unhealthy levels of particulate

pollution occur.  This existing health advisory program notifies residents of the appropriate

actions to take in order to reduce exposure to the adverse health effects of these high

concentration dust events. Table 2 summarizes the number of days each year when District

Tapered Element Oscillating Microbalance (TEOM) continuous PM10 samplers (EPA Manual

Reference Method: EQPM‐1090‐079) in the communities of Keeler, Lone Pine and Olancha

exceeded the initial advisory threshold of 400μg/m3 for PM10. Locations of these community

monitors at Owens Lake are mapped in Figure 3.1. Additional details of all daily PM10 averages

and maximum hourly values for every day during this nineteen (19) year period can be found in

Appendix A.  Details for days where only health advisory alert conditions are exceeded can be

found in Appendix B.

Page 7
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Page 9
4

Windblown Particulate Matter  

4.1 Wind, PM10 and PM2.5

Meteorology along with water diversion landscape alteration, explain the nature of the

windblown PM10 and PM2.5 problems within the Owens Valley and Mono Basin PM10

Planning Areas. Due to the combination of high wind events and substantially large areas of

source material exposure to these sheering winds, lofting of particulate into the air downwind

of sources in these Planning Areas can be extreme.  Gusty winds occur every month of the year,

but it is the passage of large turbulent storm systems in the fall and spring where sustained

winds create the highest measured concentrations of PM10 and PM2.5.

The longest running continuous PM10 monitor in the District is located in the town of Keeler.

Monitoring began at this location along the shoreline of Owens Lake on an hourly basis in

March of 1993. In September of 2009 a continuous PM2.5 monitor was added at this site to

collect additional particulate data on an hourly basis.  Measurements of maximum hourly

average wind speeds for every day and the corresponding daily average PM concentrations for

both particulate monitors can be found in Appendix C. Graphical representation of these data

are shown for PM10 (7,227 days) in Figure 4.1 and for PM2.5 (1,465 days) in Figure 4.2. In these

plots, the relationship is clear: as wind speeds increase, particulate concentrations are elevated.

On December 1, 2011 when the hourly average wind speeds measured over 45 miles per hour

particulate concentrations were at their highest. PM 10 and 2.5 TEOM levels reached 2,994

μg/m3 and 208 μg/m3 respectively with only 20 valid hours due to an extended power outage,

while the District’s filter based 24‐hour partisol monitor measured 13,380 μg/m3. This

exemplifies the strong association between high wind events and elevated PM10 and PM2.5

levels in the Owens Lake area.

4.2 Particulate Matter Size Comparisons

When collocated PM10 and PM2.5 data from the District monitoring site in Keeler began in

2009, comparison of hourly and daily concentrations of these particulates became possible.  

With the accessibility to track both particulate sizes in time and space, it’s now possible to

determine that PM10 and PM2.5 exhibit corresponding concentrations.  Hourly comparisons of

PM10 and PM2.5 concentrations are plotted in Figure 4.3. Daily comparisons of PM10 and

PM2.5 concentrations are plotted in Figure 4.4. Keeler hourly PM10 and PM2.5 input data for

these comparisons is available in Appendix D. The usefulness of these comparisons is relevant

particularly for determining air quality episode thresholds for PM2.5 where the data of record

isn’t as extensive for PM2.5 as it is for PM10, whose episode thresholds are tried and true.

   

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0

500

1000150020002500300035004000

0 5 10 15 

PM10 Daily Average (μg/m3)

Daily Max Hourly Average Wind Speed (m/s)

Keeler PM10 vs. Wind Speed

March 1993 ‐ December 2013

Figure 4.1.

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50

100150200

0 5 10 15 

PM2.5 Daily Average (μg/m3)

Daily Max Hourly Average Wind Speed (m/s)

Keeler PM2.5 vs. Wind Speed

September 2009 ‐ December 2013

Figure 4.2.

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PM10 (μg/m3/hr)

PM2.5 (μg/m3/hr)

Keeler Hourly PM10 vs. PM2.5

September 2009 ‐ December 2013

Figure 4.3. 

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1

10

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1 10 100 

PM10 (μg/m3/day)

PM2.5 (μg/m3/day)

Keeler Daily PM10 vs. PM2.5

September 2009 ‐ December 2013

Figure 4.4.

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5

Air Pollution Episode Criteria

For the District, when setting episode criteria for both PM10 and PM2.5, particulate

concentrations need to, first and foremost, be at levels that provide for adequately protection

of public health. In determining episode criteria for PM10, the District considered EPA’s Air

Quality Index (AQI) for PM10 and PM2.5 at 40 CFR part 58, Appendix G; EPA’s emergency

episode plan regulations at 40 CFR part 51, subpart H for PM10; and EPA’s 2009 I‐SIP guidance

for PM2.5.  The Air Quality Indices (AQI) for PM10 and PM2.5 are presented in Table 3 below.

   

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Based on EPA’s 2009 I‐SIP guidance, the recommended interim significant harm and action

levels for PM2.5 emergency episode plans can be found in Table 4.  

Both PM10 and PM2.5 AQI criteria have valid breakpoints for 24‐hour particulate

concentrations however, elevated PM events within the District are typically short in duration,

yet drastic and extreme in regards to pollution exposure levels. Because of these unique

circumstances in the GBUAPD, the need for hourly monitoring breakpoints is pertinent to

achieving adequate public health protection goals. In Figure 5.1, days of significant harm (40

CFR Part 51.151) for PM10 as measured at District air quality monitors mapped in Figure 2.2,

are shown as red circles, whereas non‐significant harm days following these events are plotted

as green triangles.  Here, the striking difference between days of significant harm and the

drastically lower concentrations of PM10 following these events can be observed. As of

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1998

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2007

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2008

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2009

2010

Daily Average PM10 (μg/m3)

Significant Harm Events for PM10

1994 ‐ 2013 Significant Harm Day PM10 Concentration

Day After PM10 Concentration

Significant Harm Level for PM10 = 600 μg/m3

Figure 5.1.

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December 31, 2013, no significant harm days for PM2.5 have been measured. Consequently, by

using 24‐hour concentrations for setting episode criteria in the District, the greatest impact to

public health has already occurred prior to any issuance of air pollution advisories.  In light of

these realities, hourly air quality episode criteria have greater applicability for the District and

superior public health protection benefit.

In Figure 5.2, maximum hourly PM10 concentrations at the District’s longest operating

continuous PM10 monitor in Keeler are compared to the daily average PM10 concentrations for

all days from the period beginning in March 1993 through the end of December 2013.

Measurements for Keeler max hourly and daily average PM10 can be found in Appendix E. One

crosshair intersection shows that the 1‐hour PM10 threshold of 400 μg/m3 captured all

instances where the federal 24‐hour PM10 NAAQS was exceeded. Similarly, another crosshair

intersection shows that the 1‐hour PM10 threshold of 800 μg/m3 captured all instances where

the 24‐hour PM10 levels exceeded the federal 24‐hour PM10 AQI for Hazardous 1/warning

level of 425 μg/m3, as used in the SIP‐approved emergency episode plans of other Districts

such as South Coast AQMD and San Joaquin Valley APCD. The combination of using a 1‐hour

averaging period to monitor high‐wind dust events, the 1‐hour thresholds selected, and the

coverage of comparable federal 24‐hour PM10 events means that Great Basin’s rule is, in

effect, slightly more protective than the federal requirements. Another public health benefit to

these hourly thresholds are that they allow the District to progressively notify the public and

take action before federal 24‐hour PM10 significant harm levels are reached.

In Figure 5.3, maximum hourly PM2.5 concentrations at the District’s only operating continuous

PM2.5 monitor, also in Keeler, are compared to the daily average PM2.5 concentrations for all

days from the period beginning in September 1999 through the end of December 2013.

Measurements for Keeler max hourly and daily average PM2.5 can be found in Appendix E. Like

PM10 in the previous figure, here with PM2.5, one crosshair intersection shows that the 1‐hour

PM2.5 threshold of 150 μg/m3 captured all instances where the federal 24‐hour PM2.5 NAAQS

was exceeded. The other crosshair intersection shows that the 1‐hour PM2.5 threshold of 300

μg/m3 captured all instances where the 24‐hour PM2.5 levels exceeded the federal 24‐hour

PM2.5 AQI for Hazardous 1/warning level of 250.5 μg/m3 and all instances of 210.5μg/m3

recommended by EPA’s 9/25/2009 guidance. Again, this time with regards to PM2.5, the

District’s episode criteria are set at more protective levels than the federal requirements. Most

importantly, from a public health standpoint, an air advisory will immediately follow the first

hour of an upscale pollution event.

In addition to windblown dust episode criteria for PM10 and PM2.5 the District will implement

hourly stage 1 and stage 2 episode criteria for wildfire smoke. Since the District only operates

one continuous PM2.5 monitor in Keeler, Inyo County and wildfire impacts are more common

and severe in Mono and Alpine Counties, the District will use PM10 as a surrogate for PM2.5

concentrations. Wildfire smoke impacts from the Aspen and Rim fires in the summer of 2013

reinforced the urgency of having adequate criteria levels and air advisory procedures in place

during these occurrences (http://airblog.gbuapcd.org).  Although infrequent, wildfire smoke

impacts have been measured at the District’s PM10 monitoring site in the Town of Mammoth

Lakes at levels exceeding the NAAQS, Figure 5.4. Measurements for daily PM10 at the District’s

Mammoth Lakes monitoring site during wildfire season, June – September, for the 22 year

period (1992 – 2013), can be found in Appendix F. Episode criteria for smoke will not apply to

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1

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1 10 100 1000 10000 

PM10 Daily Average (μg/m3/day)

Max Hourly PM10 (μg/m3/hr)

Keeler PM10

March 1993 ‐ December 2013

400 μg/m3

PM10

Stage 1

Episode Criteria

800 μg/m3

PM10

Stage 2

Episode Criteria

150 μg/m3

PM10 NAAQS

600 μg/m3

40 CFR 51.151 Significant Harm Level

Figure 5.2.

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PM2.5 Daily Average (μg/m3/day)

Max Hourly PM2.5 (μg/m3/hr)

Keeler PM2.5

September 2009 ‐ December 2013

350.5 μg/m3

PM2.5 NAAQS

150 μg/m3

PM2.5

Stage 1

Episode Criteria

35 μg/m3

US EPA PM2.5 Significant Harm Level Under Consideration

Figure 5.3.

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Daily Average PM10 (μg/m3)

Mammoth Lakes Wildfire Season PM10

June 1992 ‐ October 2013

Monitor

Down

1992 Rainbow Fire

Monitor Down

Figure 5.4.

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PM readings in Mammoth Lakes during the winter.  Mammoth Lakes calls voluntary and

mandatory no burn days for residential wood burning pursuant to District Rule 431 and Town of

Mammoth Lakes Municipal Code 8.20.  The burn day calls are intended to prevent daily average

PM10 levels from exceeding 130 μg/m3 and are based on forecasted conditions that affect

dispersion and emission levels.  Therefore, burn day calls are made before hourly PM readings

reach emergency episode levels.

A summary of all episode criteria are presented in Table 5 below.

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Air Quality Improvements

The District has comprehensive programs in place to investigate and control the major sources

of windblown dust. The most robust of these being the Dust Identification (Dust ID) program at

Owens Lake. Currently as part of the 2008 OVPM10 SIP, the success of this program for

determining source areas needing dust controls in conjunction with subsequent dust control

mitigation projects that are implemented by the City of Los Angeles Department of Water and

Power, continue. At Owens Lake, 45 mi2 of Best Available Control Measures (BACM) are almost

complete and annual tons of potential PM10 emissions have been reduced by 90% (GBUAPCD,

2011).  The District has determined that an additional 2.86 square miles in 2011 and 0.76

square miles in 2012 of supplemental control requirements are needed to attain the PM10

NAAQS. However, these and prior year controls have not been fully implemented. If fully

implemented over the next several years, additional emission reductions are expected,

resulting in further air quality improvements.  

At Mono Lake a similar, but not as extensive Dust ID program, is in place. The solution to

controlling windblown dust from exposed areas at Mono Lake is to raise the lake level to 6,391

feet above mean sea level. At this lake level, most of the shoreline areas that are causing

windblown dust will be submerged. In 1994, the State Water Resources Control Board (SWRCB)

approved Decision 1631, which limited the diversion of water from the Mono Basin until the

lake reaches 6,391 feet when measured on April 1st of any calendar year. Mono Lake was at

6,382.2 feet above mean sea level in April 2013, still 8.8 feet below the target level.

In addition to the Dust ID programs adopted for air quality improvements at major sources of

air pollution in the District, other District rules provide for further pollution source controls and

regulatory enforcement.  These rules include; Rule 401 – Fugitive Dust, Rule 402 – Nuisance and

District Rule 502 – Conservation Management Practices. The District has adopted these rules to

control dust emissions from sources in an effort to attain and maintain the federal and state

standards for PM‐10.  

   

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REFERENCES

GBUAPCD, 1998. Great Basin Unified Air Pollution Control District, Owens Valley PM10

Planning Area Demonstration of Attainment State Implementation Plan, GBUAPCD,

Bishop, California, November 16, 1998.

GBUAPCD, 2003. Great Basin Unified Air Pollution Control District, Owens Valley PM10

Planning Area Demonstration of Attainment State Implementation Plan ‐ 2003 Revision,

GBUAPCD, Bishop, California, November 13, 2003.

GBUAPCD, 2008. Great Basin Unified Air Pollution Control District, Owens Valley PM10

Planning Area Demonstration of Attainment State Implementation Plan ‐ 2008 Revision,

GBUAPCD, Bishop, California, January 28, 2008.

GBUAPCD, 2011. Great Basin Unified Air Pollution Control District, Revised Final 2011

Supplemental Control Requirements Determination (2006‐2010), GBUAPCD, Bishop,

California, November 18, 2011.

GBUAPCD, 2012. Great Basin Unified Air Pollution Control District, Final 2012

Supplemental Control Requirements Determination (2010‐2011), GBUAPCD, Bishop,

California, November 16, 2012.

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