EPA Region 10

Review of Exceptional Event Request

2013 Klamath Falls, Oregon

24-hour PM2.5 NAAQS

Dates Analyzed: July 30, 2013 and August 5, 2013

Background

On March 22, 2007, the EPA adopted a final rule, Treatment of Data Influenced by Exceptional Events

(Exceptional Events Rule at 72 FR 13560), to govern the review and handling of certain air quality

monitoring data for which the normal planning and regulatory processes are not appropriate. Under the

Exceptional Events Rule, the EPA may exclude data from use in determinations of National Ambient

Air Quality Standard exceedances and violations if a state demonstrates that an "exceptional event"

caused the exceedances. Before the EPA can exclude data from these regulatory determinations, the

state must flag the data in the EPA's Air Quality System database and, after notice and opportunity for

public comment, submit a demonstration to justify the exclusion. After considering the weight of

evidence provided in the demonstration, the EPA decides whether or not to concur with each flag.

ODEQ's Request

The Oregon Department of Environmental Quality requested concurrence on flagged 24-hour PM2.5 data

on two days for the Peterson School monitor (Klamath Falls, Klamath County Oregon, AQS site 41-

035-0004 FOCI); herein this will be referred to as "the monitor." The recorded 24-hour PM2.5 levels for

the monitor ranged from 74.8 ,LLg/m3 to 79.8 ug/m3 for the data values for which the ODEQ is requesting

the EPA's concurrence as exceptional events. Table 1 lists all of the values at the monitor for which the

ODEQ has requested evaluation and concurrence.

Table 1. Dates and Values Flagged by ODEQ

Klamath Falls Monitored Values

Date PM25 concentration (μg/m3 )

AQS site 41-035-0004 POCI

7/30/2013 79.8

8/5/2013 74.8

PM2 , 5 levels from submitted days led to exceedance of the 35μg/m 3 24-hour PM2.5 NAAQS and

violation of the 2012-2014 design value for the 24-hour PM2 .5 NAAQS. Documentation provided by the

ODEQ demonstrates that there were multiple wildfires occurring in Oregon and California in the

summer of 2013, notably the Douglas Complex fire in Oregon.

The ODEQ flagged the monitored values as wildfire exceptional events before the statutory deadline of

July 1, 2014. The agency made the documentation available for public comment for 30 days starting on

October 1, 2014 and received no comments. The ODEQ submitted the exceptional event demonstration

package to.the EPA Region 10 on November 12, 2014, for two dates at the site. The ODEQ is requesting

concurrence from the EPA on both of these days.

1
The EPA's Exceptional Event Evaluation

The EPA evaluated whether the documentation provided by the ODEQ for the flagged values at the

monitor demonstrates that the requirements of the Exceptional Events Rule were met. The EPA has

determined that both values would be used in a regulatory determination and the EPA has, therefore,

evaluated both of the days and values listed in Table 2 with respect to the Exceptional Event Rule

requirements.

The matrix below summarizes the requirements of the Exceptional Events Rule and describes how the

ODEQ met each requirement. All references to page numbers, tables, and figures relate to the ODEQ's

November 12, 2014 submittal.

Procedural Requirements: EPA's Evaluation of Flagged Exceedances:

• The data are flagged

and include an initial

event description in

the EPA's AQS

database. 40 CFR

50.14(c)(2)(i) and (iii)

The ODEQ flagged and described the summer 2013 elevated

PM2.5 values as wildfire exceptional events in the EPA's AQS

database prior to the July 1, 2014 deadline.

• The public had an

opportunity to review

and comment on the

demonstration

justifying data

exclusion. 40 CFR

50.14(c)(3)(i) and (v)

The ODEQ provided a 30-day public comment period on the

documentation for the multi-day claimed exceptional event.

The public comment period occurred between October 1, 2014

and November 1, 2014 for the demonstration. The ODEQ

received no comments during the public comment period.

• The demonstration

justifying data

exclusion was

submitted timely to

the EPA. 40 CFR

50.14(c)(3)(i)

The EPA received demonstration documentation from the

ODEQ on November 12, 2014 before the deadline of not later

than three years following the end of the calendar quarter in

which the flagged concentration was recorded (in this case,

September 30, 2016).

Technical Criteria:

• The event satisfies Conceptual Model

the criteria in 40 The ODEQ developed a conceptual model that shows how

CFR 50.1(j) (i.e., wildfires in Oregon and California, especially the Douglas

affects air quality, is Complex fire in Oregon, affected air quality in the Klamath

not reasonably Falls area during the summer of 2013. In 2013, a number of

controllable or fires burned approximately 350,786 acres in southwestern

preventable, is an Oregon. In neighboring California, wildfires burned

event caused by 577,675 acres (p 10 and Table 3). In August 2013, weather

human activity that conditions in Oregon were hot and dry, typical of the summer

is unlikely to recur at periods (Figures 2, 3, 6). The combination of hot and dry

2
a particular location

or a natural event,

and is determined by

EPA to be an

exceptional event).

40 CFR

50.14(c)(3)(iii)(A)

conditions made the area more susceptible to wildfires (Figure

12). The ODEQ demonstrated that elevated emissions at the

monitor were due to direct impact from the Douglas Complex

wildfire smoke plume. Other nearby wildfires were also

generating emissions (Figure 17).

Affected Air Quality

As evidence that the event affected air quality, the ODEQ

documented that the event exceeded historical fluctuations and

that there was a clear causal relationship between the event and

the exceedances at the monitor. As discussed above, in 2013,

wildfires burned 350,786 acres in Oregon (Table 3), and

multiple wildfires burned in the summer of 2013 in areas

impacting the monitor. As shown on Table 1, elevated values

ofPM2 , 5 occurred in late July and early August 2013.

The historical fluctuations criterion is discussed in further

detail later in this analysis. The clear causal relationship

criterion (also discussed later in further detail) also supports

the conclusion that the event affected air quality by describing

conceptually how the emissions generated by the wildfires

reached the monitor, and by analyzing each affected day using

HYSPLIT air mass back trajectories, hourly PM2 , 5 levels,

observed meteorological data, MODIS imagery, and text. The

Appendices provide supporting information in the form of

daily data analyses, newspaper articles and distributed ODEQ

air quality alerts.

Natural Event and not Reasonably Controllable or

Preventable

In 2013, wildfires burned 350,786 million acres in Oregon. In

late July and August 2013 weather conditions in Oregon were

hot and dry, typical of the summer periods (Figures 2, 3, 6).

The combination of hot and dry conditions made the area more

susceptible to wildfires (Figure 13).

While there were multiple wildfires in Oregon and surrounding

states in the summer of 2013, Klamath Falls was primarily

affected by the Douglas Complex fire in Douglas County.

This fire complex was located 100 miles to the northwest of

Klamath Falls. The Douglas Complex fire ignited by lightning

on July 27, 2013, burned 48,679 acres, cost an estimated $55

million to control, and was controlled over a month later on

September 3, 2013. Table 11 identifies that 2,652 people were

part of the response effort. It was managed using the Oregon

Department of Forestry management strategy (page 18) and

was physically controlled by Oregon Department of Forests

3
and the Douglas Forest Protective Association under full

suppression control methods (page 20).

The ODEQ discussed that, based on interviews with multiple

state and local officials, there were no unusual anthropogenic

sources of emissions during this period. Typically

anthropogenic emissions are low in August. No prescribed

burning or slash burning occurs during July and August

because conditions are highly susceptible to loss of control of

fires. (Table 2 in the executive summary, page 21, Section 7.3

on page 49).

Based on the submitted information, the EPA concludes that

the wildfires that occurred in and around southwest Oregon in

late July and early August 2013 were natural events that

affected air quality at the monitor and that they were not

reasonably controllable or preventable due to their size despite

the significant resources committed to suppression of these

fires.

• There is a clear

causal relationship

between the

exceedance and the

claimed exceptional

event. 40 CFR

50.14(c)(3)(iii)(B)

Overview

The ODEQ established the clear causal relationship by

describing how the elevated emissions in Klamath Falls came

primarily from the Douglas Complex fire in Oregon located

100 miles to the northwest of Klamath Falls. The ODEQ also

identified multiple other fires in the surrounding area during

the summer of 2013.

The ODEQ documented the direct connection between the

fires and the monitor using MODIS satellite images, HYSPLIT

back trajectories, and wind/temperature data.

Figure 41 shows a graph including wind speed, emissions

levels, and wind directions. It shows that the winds were

coining from the northwest (the direction of the Douglas

Complex and Big Windy Complex fires) during times of

elevated emissions levels at the monitor and at speeds

sufficient to transport the emissions from the fires to the

monitor. HYSPLIT modeling further supports this by showing

the trajectory of the plumes from the Douglas and Big Windy

Complex fires moving towards Klamath Falls on the high

emissions days (Figures 43, 44, 45, 46, 47). Satellite imagery,

Figure 40, show the plume from the Douglas Complex fire, as

well as from the Big Windy Complex fire and fires in northern

California, heading eastward toward nearby Klamath Falls.

Wind roses in Figures 48 and 49 also support that winds were

coining from the northwest during the days of the high

4
emissions levels and from the area where the fires were

burning.

Conclusion

Based on the suite of evidence provided, including MODIS

imagery, HYSPLIT back trajectories, surface wind speed and

wind direction data, pressure gradients, and no evidence of

unusual sources of anthropogenic PM2.5 (as discussed in the

Not Reasonably Controllable or Preventable section of this

analysis), the EPA concludes that there is a clear causal

connection between the Peterson School monitor values in

Klamath Falls, Oregon for the days listed in Table 2 of this

analysis and the multiple wildfires, primarily the Douglas

Complex fire with contribution from the Big Windy Complex

fire and fires in Northern California, that occurred in Oregon

and surrounding states during the summer of 2013.

• The event is

associated with

measured

concentrations in

excess of normal

historical

fluctuations

including

background. 40 CFR

50.14 (c)(3)(iii)(C)

When reviewing summertime PM 2.5 values from 2000-2011 at

the monitor, there were 27 days over the standard, all of which

ODEQ attributed to wildfires (Table 5).

The average PM? s concentrations during the summertime

period between 2000-2011 is 8. I ug/m 3 . If the above mentioned

exceedances attributed to wildfires are removed from the

dataset, the average lowers to 6.8μg/m3 (page 23). The data

shows that with or without wildfires the summertime average

is generally very low.

The ODEQ compared the PM2 .5 concentrations on the days it is

claiming as exceptional events to summer concentrations

during low wildfire years. For the low wildfire years, the 99th

percentile high concentration was 17.4 p.g/m3 . The requested

days' concentrations were well over this 99th percentile high

concentration and demonstrated that they exceeded historical

fluctuations. Table 6 in the submittal also identifies that 90

percent of summer days fall below 12 μ.g/m' further supporting

lower summer concentrations.

Based on the presented data, the EPA concludes that the values

listed in Table 2 are in excess of normal historical fluctuations,

including background.

• There would have

been no exceedances

"but for" the event.

40 CFR

50.] 4(c)(3)(iii)(D)

To show there would have been no exceedances "but for" the

event, the ODEQ demonstrated through historical fluctuations

that the average summertime PM- . s values for the 2000-2011

period were relatively low at 8.1 μg/rn 3 , and at the lower

6.8μg/m3 level with suspected wildfire data removed (page

22). It then showed a clear causal relationship between the

5
wildfires and the elevated PM2 .5 values at the monitor through

the analysis in the clear causal relationship section. The ODEQ

also showed that there were no other significant sources of

PM2,5 that would have contributed at the time or in the quantity

needed to result in the elevated values that were recorded at the

monitor during this time period.

ODEQ compared the requested days' concentration to seven

recent years of summer concentrations during low wildfire

years. For those seven years, the 99 th percentile high

concentration was 17.4 μg/m3 . The requested days'

concentrations of 79.8 1_tg/m3 and 74.8 pg/m3 were well over

this 99th percentile high concentration and demonstrated that

they exceeded historical fluctuations.

The ODEQ discusses that there were no unusual anthropogenic

sources of emissions during this period.

Given this, the EPA concludes that but for the wildfires in and

around Oregon in the summer of 2013, there would have been

no exceedances of the 24-hour PM2.5 NAAQS at the monitor in

Klamath Falls, Oregon.

• Mitigation, 40 CFR

51.930

As described in the not reasonably controllable or preventable

section above, a significant amount of financial and human

resources were invested in containment of the multiple fires in

and around Oregon in 2013.

Additionally, multiple agencies and organizations in Oregon

utilized a wildfire response protocol to organize state response

efforts and responsibilities (Section 8.2.1). This includes

management and use of the Oregon Smoke Biog.

The ODEQ also maintains an air quality index website to

communicate ongoing air quality levels and issues health

advisories through the web and via email during prolonged

(72+ hours) unhealthy air quality periods. Appendix A

includes news releases on unhealthy air quality levels for the

2013 events. The ODEQ took mitigation actions to protect

health from elevated particulate matter levels related to these

exceptional events.

6
Conclusion

Based on the documentation submitted by the ODEQ on November 12, 2014, the EPA concurs with the

exceptional events flags for these two days listed in Table 2, which have been flagged by the ODEQ in

AQS as exceptional events.

Table 2. Dates and Values Concurred on by EPA

Klamath Falls Monitored Values

Date PM2 .5 concentration (μg/m3 ) -

AQS site 41-035-0004 POC1

7/30/2013 79.8

8/5/2013 74.8

The information and analyses presented in the ODEQ's exceptional event demonstration package

provided a weight of evidence sufficient for the EPA's concurrence on the flagged data from the monitor

on the dates listed in Table 2 above and as described in this document. Accordingly, we are placing a

concurrence indicator in the EPA's AQS database for these dates at this monitor.

Note that the EPA's decisions on exceptional event exclusions are not considered final agency action

until they are acted upon as part of a final regulatory action subject to public notice and comment. Such

actions would include, for example, decisions to exclude the affected data from use in an approval of a

non-attaimnent plan, maintenance plan or other regulatory decision.

7