State Implementation Plan Element 

Adopted by the Commission 

40 CFR Part 51 Appendix V 2.1 ( d) 
Draft Revised PM10 Maintenance Plan for the 

Lamar Attainment/Maintenance Area 

Colorado Department 

of Public Health 

and Environment 

Revised PM10 Maintenance Plan Submittal: 

U.S. Environmental Protection Agency: submitted on -TBD 

Colorado Air Quality Control Commission, adopted on - 12120112 

PM10 Redesignation Request/Maintenance Plan Submittal: 

U.S. Environmental Protection Agency: approved on 10125105, effective on 11125105 

Colorado Air Quality Control Commission, adopted on 11115101 

PM10 State Implementation Plan Submittal 

U.S. Environmental Protection Agency: approved 06109194, effective 07111194 

Colorado Air Quality Control Commission, approved on 04115193 

Revisions Prepared By: 

Air Pollution Control Division 

Colorado Department of Public Health and Environment 

4300 Cherry Creek Drive South 

Denver, Colorado 80246 
[Blank Page] 
Table of Contents 

SECTION 1: INTRODUCTION ..................................................... 1 

A. BACKGROUND ..................................................................................... 2 

1. PM 10 National Ambient Air Quality Standard .......... ................. ......................... 2 

2. Health and Welfare Effects of PM10 ............ .......... .... ...... ...................... ....... .... 2 

~ Lamar Nonattainment Area Classification History ....... ... ................... ..... ........... 3 

4. Lamar Attainment/Maintenance Area Boundaries .. ........................ ................... 3 

B. ORGANIZATIONS INVOLVED IN PREPARING AND APPROVING 

PL.AN ........................................................................................................... ~ 

C. REQUIREMENTS FOR REDESIGNA TION AND MAINTENANCE ...... 5 

.1. Attainment of the Standard ................ ............................................ .. ............ .. .... 5 

2. State Implementation Plan (SIP) Approval ......... .... .. .................. ....................... 5 

~ Permanent and Enforceable Improvement in Air Quality ......... ..................... ..... 5 

4. Section 110 and Part D Requirements .. ...... ...................................................... 5 

~ Maintenance Plan .... .. .... .. .................. ....... ...... ......... ................ ................. ......... 5 

SECTION 2: PM10 ATTAINMENT HISTORY .............................. 6 

A. MONITORING HISTORY ....................................................................... 6 

B. PM10 MONITORING DA TA ................................................................... 6 

.1. Lamar Power Plant PM10 Monitor (08-099-0001) .................. .. ......... ... ............. 7 

2. Lamar Municipal Complex PM10 Monitor (08-099-0002) .................................. 8 

C. HIGH WIND EXCEPTIONAL EVENT DATA EXCLUSIONS ................. 9 

.1. Exceptional Events Rule and High Wind Guidance: .. ..... ........ ........... .............. .. 9 

2. Lamar Exceptional Events Analysis: ........ ............. .. ......... .. ....... ...................... . 12 

~ Historical Seasonal Fluctuations: ... ................................. ................................. 13 

D. DESIGN VALUE DETERMINATION ................................................... 16 

SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL .. 18 

A. 1993 SIP ELEMENT ............................................................................. 18 

B. PM10 REDESIGNATION REQUEST/MAINTENANCE PLAN ............ 18 

SECTION 4: PERMANENT AND ENFORCEABLE 

IMPROVEMENT IN AIR QUALITY ............................................. 19 

A. OVERVIEW .......................................................................................... 19 

B. CONTROL MEASURES ...................................................................... 20 

.1. Control of Emissions from Stationary Sources ... ..... .. ...................................... 20 

2. Federal Motor Vehicle Emission Control Program (FMVECP) ....................... .. 21 

~ Voluntary and State-Only Measures .. ........... .. .... .................. ........... .. ..... ......... 21 

4. State Implementation Plan Measures ........................................................... ... 21 

C. CLEAN AIR ACT SECTION 110 AND PART D REQUIREMENTS .... 22 

SECTION 5: MAINTENANCE PLAN ......................................... 23 

A. REQUIREMENTS ................................................................................. 23 
B. EMISSION INVENTORIES ................................................................... 23 

.1. 2010 Base Emission Inventory ...... .......... ........................................................ 24 

2. 2020 Interim Emission Inventory .. ... ... .. ........... ............ ..................................... 26 

~ 2025 Emission Inventory .. .......................................... ..................................... 26 

C. MAINTENANCE DEMONSTRATION .................................................. 28 

.1. Emission Inventory Roll-Forward Analysis ..... ............ .......... ............................ 28 

D. MAINTENANCE PLAN CONTROL MEASURES ................................ 30 

E. PM10 EMISSION BUDGET ................................................................. 30 

F. MONITORING NETWORK/VER/FICA TION OF CONTINUED 

ATTAINMENT ........................................................................................... 30 

G. CONTINGENCY PLAN ........................................................................ 31 

.1. Tracking ............... .. .......................................................................................... 31 

2. Trigger and Response ....................... ......................... ............................. .. ...... 31 

~ Potential Contingency Measures .. .. ........... ..... ............ ........ ... .. .. .......... .. .......... 32 

H. SUBSEQUENT MAINTENANCE PLAN REVISIONS ......................... 33 

APPENDIX A: Revised Natural Events Action Plan ................ 34 

APPENDIX B: High Wind Events .............................................. 68 

APPENDIX C: Blowing Dust Health Advisory Brochure ........ 95 
SECTION 1: INTRODUCTION 

This document is the second revision of the PM10 Maintenance Plan for the Lamar 

Attainment/Maintenance Area. The Environmental Protection Agency (EPA) first 

approved a particulate matter under 10 microns (PM10) redesignation request and 

maintenance plan for the Lamar area on October 25, 2005 (70 FR 61563), which 

became effective on November 25, 2005. The Lamar redesignation request and 

maintenance plan was adopted by the Colorado Air Quality Control Commission 

(AQCG) on November 15, 2001. 

This second maintenance plan was prepared to meet the provisions of section 175A(b) 

of the Clean Air Act and contains the same emission control strategies as the first 

maintenance plan that was adopted by the Commission in 2001. The 2012 revised 

plan includes updated the emissions inventories and projections using the latest EPAapproved tools. This plan establishes a new PM 10 motor vehicle emissions budget 

(MVEB) of 764 pounds per day in 2025. 

The City of Lamar, Powers County, and the State of Colorado request continuation of 

"attainment/maintenance" status for the Lamar PM10 nonattainment area. The Lamar 

area was originally designated as nonattainment for the daily PM10 National Ambient 

Air Quality Standard (NAAQS) since 1990, although the area is presently demonstrating 

attainment with the PM10 NAAQS. The Maintenance Plan section of this document 

has been updated and will demonstrate that the area will be able to maintain the 

NAAQS through the year 2025. The benefits of maintaining a redesignation to 

attainment status include: · 

1. Areas in attainment/maintenance lose the stigma associated with nonattainment 

of the NAAQS. 

2. Areas in attainment/maintenance do not become "serious" nonattainment areas 

even if a violation of the NAAQS occurs. This means that specific control 

measures can be applied to address a violation without going through a rigorous 

federal process, where serious areas must implement mandatory control 

measures and be subject to numerous administrative actiyities. 

3. Prevention of Significant Deterioration (PSD) permitting requirements replace 

New Source Review (NSR) permitting requirements for new and modified major 

stationary sources. These permitting requirements are important for large 

industrial facilities that are not currently located, nor likely to locate, in the Lamar 

area. 

This analysis is designed to document and ensure continuing attainment and 

maintenance of the NAAQS for PM10 in the Lamar area. This document is intended to 

comply with requirements of the federal Clean Air Act (CAA), and with relevant 

procedures and policies of the United States Environmental Protection Agency (EPA). 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 1 

August, 2012 
A. BACKGROUND 

1. PM 10 National Ambient Air Quality Standard 

In 1971 , the EPA set NAAQS for several air pollutants, including total suspended 

particulates (TSP), defined as particles with an aerodynamic diameter of less than 40 

microns. In 1987, the EPA changed the TSP standard to the PM10 NAAQS. The 

current PM10 NAAQS allow for a maximum 24-hour average of 150 ug/m3. The 24-

hour PM10 NAAQS may not be exceeded more than three times over any three year 

period. 

There are both primary and secondary air quality standards. The primary standards are 

set to protect human health, with a margin of safety to protect the more sensitive 

persons in the population, such as the very young, elderly and the ill. Secondary 

standards are set to protect property, materials, aesthetic values and general welfare. 

For PM10, the national primary and secondary standards are the same. The numerical 

levels of the standards are subject to change, based on new scientific evidence 

summarized in air quality criteria documents. In 2006, the EPA revoked the annual 

PM10 standard but maintained the 24-hour average of 150 ug/m3 (see 71 FR 61144) 

for both the primary and secondary NAQQS. 

In general, demonstrating attainment requires collecting representative air monitoring 

data and using approved measuring instruments and procedures, with adequate quality 

assurance and quality control. Air quality measurements in the Lamar area satisfy this 

requirement, as shown in Section 2 - "Table 1 - PM10 Monitoring Record". 

2. Health and Welfare Effects of PM10 

Particulate matter is the term given to tiny particles of solid or semi-solid material 

suspended in the atmosphere, and PM10 is inhalable particulate matter 10 micrometers 

in diameter and smaller. In the Lamar area, PM10 is created from re-entrained road 

dust, carbon black (from automobile and diesel engines) and soot (from fireplaces, 

woodstoves, and coal stoves), as well as transported blowing dust from outside the 

maintenance area. PM10 from these combustion sources contains a large percentage 

of elemental and organic carbon, which contributes to atmospheric haze and to health 

problems. 

Epidemiological studies and laboratory studies of humans and animals indicate that fine 

particles can be inhaled deeply into the respiratory system, resulting in aggravation of 

existing respiratory and heart diseases, damage to lung tissue, impairment of breathing 

and respiratory functions, alterations to the body's physical and immune system 

defenses, and even premature death. Many fine particles are also composed of 

compounds that are known or suspected human carcinogens. People most sensitive to 

particulate matter are the elderly, children, and those with chronic lung disease, 

cardiovascular disease, influenza, and asthma. 

The welfare effects of particulate air pollution are wide-spread. Because of the 

potential for extremely long-range transport of fine particles it is thought that no place 

on earth is free of particulate pollution generated by urban and rural sources. Chemical 

and photo-chemical reactions involving the particles may occur in the air, or once they 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Paqe2 

August, 2012 
have been deposited on environmental media or structures. Such soiling and acid 

deposition causes visibility degradation, climate changes, and damage to crops, natural 

vegetation, water bodies, and aquatic life. In addition, sculpture and architecture may 

be damaged or destroyed by particulate soiling and acid deposition--both of which have 

been detected in the most remote areas of the world. 

3. Lamar Nonattainment Area Classification History 

Because of observed problems with air particles, monitoring of total suspended 

particulates (TSP) began in 1975, and continued through 1987. In 1987, based on 

relatively high TSP levels, the Lamar area was designated as a "Group I" area for 

PM10. Lamar was then designated a "moderate" nonattainment area in 1990 pursuant 

to section 107(d)(4)(B) of the CAA. 

4. Lamar Attainment/Maintenance Area Boundaries 

The boundary for the Lamar PM10 attainment/maintenance area was officially adopted 

by the Colorado Air Quality Control Commission on June 20, 1991 that includes the 

Lamar city limits as they existed on August 1. 1991 . This boundary was determined to 

be the reasonable Lamar airshed by considering local topography, meteorology, and 

land use practices. 

A map illustrating the area boundary is shown in Figure 1. 

I 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Paqe3 

August, 2012 
Figure 1: Map of the Lamar Attainment/Maintenance Area 

Lamar PM-1 O Maintenance Area 

HH.00 

Legend 

Monitors 

e Lamar 2010 Point Sources 

- HIGHWAYS 

-- Local_Roads 

- MAJOR_ROADS 

~ RAIL_LIN ES 

CJ Prowers County 

EGE RD 

3:: 

---

~ ..----+-~ ~ ~ 

0 

:::0 

1 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area 

August, 2012 

I 

Paqe4 
B. ORGANIZATIONS INVOLVED IN PREPARING AND APPROVING 

PLAN 

Preparation of this revised maintenance plan was a cooperative effort of the City of 

Lamar, Powers County, and the Air Pollution Control Division (APCD) of the Colorado 

Department of Public Health and Environment. The document was approved by the 

Colorado Air Quality Control Commission (AQCC) on December 20, 2012. The EPA, 

through its regional office in Denver, provided policy advice and technical assistance, 

and is responsible for final approval of this revised maintenance plan. 

C. REQUIREMENTS FOR REDESIGNA TION AND MAINTENANCE 

Section 107(d)(3)(D) and (E) of the CAA defines the five required components of a 

redesignation request and maintenance plan. These components and their 

descriptions follow: 

1. Attainment of the Standard 

The State must show that the area is attaining the PM10 NAAQS. This demonstration 

must be based on monitoring data representative of the location of the expected 

maximum concentrations of PM10 in the nonattainment area. 

2. State Implementation Plan (SIP) Approval 

The State must demonstrate that it has a fully approved State Implementation Plan 

(SIP) Element for Lamar under Section 11 O(k) of the CAA. 

3. Permanent and Enforceable Improvement in Air Quality 

The State must demonstrate that the improvement in air quality leading to redesignation 

is due to permanent and federally enforceable emissions reductions. 

4. Section 110 and Part D Requirements 

The State must meet all requirements of Section 110 and Part D of the CAA. Section 

110 describes general requirements of SIPs, while Part D pertains to requirements 

applicable to nonattainment areas. 

5. Maintenance Plan 

The State must have a fully approved maintenance plan that meets the requirements of 

Section 175A of the CAA. This plan must provide for the maintenance of the NAAQS 

for at least 10 years following redesignation , and the plan must contain a contingency 

plan that describes potential control measures that could be implemented to ensure 

continued maintenance of the PM10 NAAQS. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page5 

August, 2012 
SECTION 2: PM10 ATTAINMENT HISTORY 

A. MONITORING HISTORY 

Monitoring for total suspended particulates (TSP) in Lamar began in August 1975 at the 

Lamar Power Plant and at the Lamar Municipal Complex. The historic TSP levels were 

the basis for Lamar being designated as a "Group I" area for the new PM10 standards, 

which were promulgated by the EPA in 1987. Group I locations were those areas 

estimated to have a greater than 95 percent probability of exceeding the new PM10 

standards. 

Monitoring for PM10 began in 1985 at the Lamar Power Plant (100 N. 2nd Avenue) and 

an additional PM10 monitor was established at the Lamar Municipal Complex (104 E. 

Parmenter) in August 1986. 

B. PM10 MONITORING DAT A 

While PM10 is currently being monitored at both the Lamar Power Plant site and the 

Lamar Municipal Complex site, because of serious deficiencies associated with the 

siting of the power plant monitor the Division does not believe that data from this 

monitor should be used in assessing the Lamar area's ongoing compliance with the 

PM10 standard. The power plant monitor is located within a fenced area on Lamar 

Light and Power property where the public does not have access. Accordingly, the 

monitor is not technically located within ambient air for impacts from the coal-fired 

power plant, although the Division acknowledges that the monitor is fairly close to the 

fence line. Despite its proximity to the fence line, however, the siting of the monitor 

makes it ill-suited to assess the public's PM10 exposure. Specifically, the monitor is 

located on a building roof-top within a few meters of a taller power plant building wall, 

which creates rooftop turbulence and affects air flow patterns around the sample probe 

depending on wind direction (i.e., air flow is blocked by the taller wall for about half of 

the directions on the compass) and wind speed (i.e., the tall wall north of the monitors 

can create turbulence and other aerodynamic effects). Given this, the Division does not 

believe that it is appropriate to use data from this site to assess community-level 

exposure for the purposes of this maintenance plan. Indeed, even if the purpose of the 

monitor was to assess microscale exposure the aerodynamic downwash/cavity zone on 

the building rooftop would not meet current PSD monitor siting criteria. 

In addition to being poorly sited, the Lamar Power Plant site is a redundant monitor as 

the Lamar Municipal PM10 monitoring site is located 0.5 miles to the southeast. One 

PM10 monitoring station is adequate for a city the size of Lamar (population -7,800) 

with a relatively small attainment - maintenance area(< 4.3 square miles). 

Based on all these reasons, in 2011, the Division submitted a letter to EPA 1 requesting 

the removal of the Lamar Power Plant. After reassessing the relevant facts, the 

1 Letter to Adam Eisele, EPA Region VIII, Proposed removal of Lamar Power Plant PM10 SLAMS 

site/sampler AQS 10:08-099-0001, dated November 21, 2011 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area 

August, 2012 

Page6 
Division still concludes that removal of the monitor is the appropriate course of action. 

Moreover, in consideration of the identified Power Plant monitor site deficiencies, the 

Division believes it is inappropriate to use data from the Power Plant monitor to assess 

Lamar's ongoing compliance with the PM10 standard for the purpose of this 

maintenance plan update. Nevertheless, since EPA has not yet concurred on the 

Power Plant monitor removal request, the Division is including Power Plant monitor data 

for this maintenance demonstration in a parallel demonstration of continued 

maintenance of PM10 standard for the Lamar area using data from both monitors. 

1. Lamar Power Plant PM10 Monitor (08-099-0001) 

Table 1 lists the daily PM10 maximum, second maximum, third maximum, fourth 

maximum and estimated number of exceedances for the 11 year period from 2001 

through 2011 for the Power Plant monitoring site. 

Table 1: Lamar Power Plant - PM10 Monitoring Record 

1st 2nd 3rd 4th Yearly 3-yr Average 

Year Maximum Maximum Maximum Maximum Estimated 

(JJg/m3) (JJg/m3) (JJg/m3) (JJg/m3) Exceedances 

2001 152 133 111 108 1 

2002 246* 246* 196* 181* 0 

2003 132 120 113 99 0 

2004 80 79 75 74 0 

2005 203* 116 110 100 0 

2006 136 127 118 110 0 

2007 93 82 76 72 0 

2008 367* 227* 123 117 0 

2009 233** 174* 171** 138 2 

2010 136 131 97 92 0 

2011 192* 169* 113 108 0 

Note: Bolded numbers denote values over the 24-hour PM10 NAAQS of 150 ug/m3 

* Denotes data flagged as an Exceptional Event (EE) 

Estimated 

Exceedances 

0.33 

0.33 

0.33 

0 

0 

0 

0 

0 

0.67 

0.67 

0.67 

**Denotes data not flagged before EPA deadline, (Appendix B analysis sugge~ts EE) 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 7 

August, 2012 
Table 2 lists the Power Plant PM10 data completeness for the 11 year period. The data 

completeness over the last 10 years has been exceptional at the Power Plant site. 

Table 2: Lamar Power Plant- PM10 Data Completeness Record 

Year 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Overall 

(#samples collected I# scheduled samples)*100 = (%) 

2001 76/90 (84%) 69/91(76%) 91/92 (99%) 90/92 (98%) 326/365 (89%) 

2002 90190 ( 100%) 90/91(99%) 91/92 (99%) 90/92 (98%) 361/365 (99%) 

2003 88/90 (98%) 91/91(100%) 92/92 ( 100%) 92/92 ( 100%) 363/365 (99%) 

2004 91/91 (100%) 91/91(100%) 84/92 (91%) 92/92 ( 100%) 358/366 (98%) 

2005 89190 (99%) 90/91(99%) 92/92 ( 100%) 92/92 ( 100%) 363/365 (99%) 

2006 90190 ( 100%) 89/91(98%) 92/92 ( 100%) 90192 (98%) 361/365 (99%) 

2007 90190 ( 100%) 91/91(100%) 92/92 ( 100%) 90/92 (98%) 363/365 (99%) 

2008 91/91 (100%) 90/91 (99%) 92/92 ( 100%) 91/92 (99%) 364/366 (99%) 

2009 90190 ( 100%) 91 /91(100%) 92/92 ( 100%) 92/92 ( 100%) 365/365 ( 100%) 

2010 89190 (99%) 91/91(100%) 92/92 ( 100%) 91/92 (99%) 363/365 (99%) 

2011 90190 ( 100%) 91/91 (100%) 92/92 ( 100%) 92/92 ( 100%) 365/365 ( 100%) 

2. Lamar Municipal Complex PM10 Monitor (08-099-0002) 

Table 3 lists the daily PM10 maximum, second maximum, third maximum, fourth 

maximum and estimated exceedances for the 11 year period from 2001 through 2011 

for the Municipal Complex monitoring site. 

Table 3: Lamar Municipal Complex - PM10 Monitoring Record 

1st 2nd 3rd 4th Yearly 

Year Maximum Maximum Maximum Maximum Estimated 

(J,1g/m3) (JJg/m3) (JJg/m3) (JJg/m3) Exceedances 

2001 101 91 90 89 0 

2002 183* 162* 143 138 0 

2003 108 93 85 73 0 

2004 93 82 77 71 0 

2005 164* 108 95 93 0 

2006 116 88 80 76 0 

2007 58 55 51 49 0 

2008 123 118 90 86 0 

2009 176* 173* 144* 118 0 

2010 95 60 57 45 0 

2011 122 115 108 79 0 

Note: Bolded numbers denote values over the 24-hour PM10 NAAQS of 150 ug/m3 

* Denotes data flagged as an Exceptional Event (EE) 

3-yr Average 

Estimated 

Exceedances 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

** Denotes data not flagged before EPA deadline, (Appendix B analysis suggests EE) 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area PaqeB 

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Table 4 lists the Municipal Complex PM10 data completeness for the 11 year period. 

Table 4: Lamar Municipal Complex- PM10 Data Completeness Record 

Year 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Overall 

(#samples collected I# scheduled samples)*100 = (%) 

2001 74190 (82%) 64/91(70%) 83/92 (90%) 88/92 (96%) 309/365 (85%) 

2002 87190 (97%) 90/91(99%) 91/92 (99%) 85/92 (92%) 353/365 (97%) 

2003 69190 (77%) 91/91(100%) 91/92 (99%) 62/92 (67%) 313/365 (86%) 

2004 77/91 (85%) 83/91(91%) 88/92 (96%) 90/92 (98%) 338/366 (92%) 

2005 82/90 (91%) 78/91(86%) 73/92 (79%) 92/92 ( 100%) 325/365 (89%) 

2006 87190 (97%) 91/91(100%) 85/92 (92%) 92/92 ( 100%) 355/365 (97%) 

2007 87190 (97%) 88/91(97%) 90/92 (98%) 90192 (98%) 355/365 (97%) 

2008 89/91 (100%) 89/91 (98%) 91/92 (99%) 92/92 ( 100%) 361 /366 (99%) 

2009 90190 ( 100%) 89/91(98%) 92/92 ( 100%) 88/92 (96%) 359/365 (98%) 

2010 83/90 (92%) 78/91(86%) 82/92 (89%) 83/92 (90%) 326/365 (89%) 

2011 81/90 (90%) 88/91 (97%) 91/92 (99%) 89/92 (97%) 349/365 (96%) 

C. HIGH WIND EXCEPTIONAL EVENT DATA EXCLUSIONS 

1. Exceptional Events Rule and High Wind Guidance: 

In 2007, EPA promulgated the Exceptional Events Rule2 (EER) that replaced earlier 

EPA Natural Events Policy (NEP) guidance3

. Recently, EPA proposed supplemental 

draft High Wind Guidance4 (HWG) that recommends the criteria necessary for the 

exclusion of data influenced by high wind exceptional events. The purpose of excluding 

high wind data from the determination of an area's attainment status is associated with 

a state's inability to implement particulate matter control measures for sources that are 

not reasonably controllable or preventable (nRCP) because all reasonable best 

available control measures (BACM) are overwhelmed by high winds. 

The following is an excerpt from the draft HWG (see p.3) that pertains to the level of 

analysis necessary for demonstrating whether an event meets the nRCP criteria: 

The degree of event-specific information and data necessary for demonstrating 

"not reasonably controllable or preventable" will generally be less for sustained 

wind speeds at or above the high wind threshold and greater for speeds below 

that the threshold. The high wind threshold is the minimum threshold wind speed 

capable of overwhelming reasonable controls on anthropogenic sources (i.e. , 

significant emissions from controlled sources) or causing emissions from natural 

undisturbed areas. The EPA recommends that air agencies establish areaspecific high wind thresholds based on local or applicable conditions and 

2 Treatment of Data Influenced by Exceptional Events, see 72 FR 13560, March 2007 

3 EPA memorandum entitled "Areas Affected by PM-10 Natural Events" Mary D. Nichols, May 30, 1996 

4 Draft Guidance on the Preparation of Demonstrations in Support of Requests to Exclude Ambient Air 

Quality Data Affected by High Winds under the Exceptional Events Rule, EPA June 2012. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Paqe9 

August, 2012 
information. If an agency is unable to develop an area-specific high wind 

threshold, the EPA will accept a threshold of a sustained wind of 25 mph for areas 

in the West provided the agencies submit evidence of this as the level at which 

they expect stable surfaces (i.e., controlled anthropogenic and undisturbed natural 

surfaces) to be overwhelmed. In identifying a high wind threshold, the EPA does 

NOT intend to set a bright line as to what speed constitutes a high wind dust event 

or to categorically concur with all events with sustained winds above a given 

threshold. 

The draft high wind guidance suggests that in the absence of area specific information 

such as local soil studies, a minimum sustained wind speed threshold of 25 mph is 

sufficient to entrain particles from stable surfaces in the West provided the state 

submits evidence to support this assertion. The Division believes the following analysis 

provides convincing evidence that sustained winds above 25 mph do overwhelm all 

reasonable BACM controls for the Lamar area. Consequently, an event involving 

sustained wind speeds above the 25 mph threshold could be subject to a less rigorous 

analysis in the exceptional event demonstration. Sustained winds are generally 

calculated as wind speed averaged over a period of at least one minute and should be 

averaged over a time frame capable entraining or suspending particulate matter. 

Prior to the issuance of the proposed EPA HWG, the Division has consistently used 

hourly average winds or an estimate of an hourly average winds for determining the 

level of "sustained" winds in each exceptional event analysis. For example, most of the 

high wind exceptional event technical support documents prepared by the Division 

include the following language: 

"The 30 mph blowing dust threshold applies to hourly average winds. In most 

cases, these recorded speeds are not hourly average speeds but represent an 

instantaneous reading or several-minute average. If these spot observations 

show that speeds are above the 30 mph threshold for successive hours, then it 

can be reasonably assumed that hourly average winds are also above 30 mph. 

Similarly, the EPA draft guidance states: 

"6.3.2.2 Consideration of wind speed 

The demonstration should indicate what the expected high wind threshold is for 

the local area and whether the sustained wind speed exceeded this level (See 

Appendix A2 and A3 for information on developing a high wind threshold). The 

wind speed data do not necessarily have to be at the location of the exceedance, 

but they should represent the source area generating the emissions. Generally, 

the EPA will accept that high winds could be the cause of a high 24-hour 

average PM10 or PM2.5 concentration if there was at least one full hour in which 

the hourly average wind speed was above the area-specific high wind threshold. 

Potential issues arise when determining the hourly average wind speed if wind 

speeds are not recorded at specified intervals throughout each hour. While 

some sources of wind speed data use hourly averages, other data sources 

employ 1 - 5 minute ("short-period'? averages. When the available wind speed 

data consist of only the wind speed during a fixed short period of each hour (e.g., 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 10 

August, 2012 
the first or last five minutes of each hour) or the wind speed during the variable 

short period when wind speed was at its maximum during the hour, the EPA will 

generally accept that the hourly average wind speed was above the threshold if 

the reported short-period wind speed was above the threshold. Where wind 

speed is recorded at specified intervals throughout each hour, agencies should 

use all recorded data to calculate the hourly average wind speed. 5 EPA may, 

however, consider multiple occurrences of high wind measured at these shorter 

averaging times as part of the weight-of-evidence demonstration. At a minimum, 

demonstrations should include the maximum sustained wind speed for each hour 

of the event and also the number of periods above the high wind threshold. 

The EPA notes that The National Climate Center has started archiving the 2-

minute winds for every 2-minute period of each hour for all ASOS stations in the 

country. Almost all sites have data since March 2005, with most archiving data 

since 2000. The EPA has further developed a preprocessor to AERMOD, called 

AERMINUTE, that takes short-period wind speed observations and calculates an 

hourly average wind that can be fed into AERMET, the AERMOD meteorological 

processor. The AERMINUTE output is user friendly. AERMET can also accept, 

process, and calculate hourly average wind speeds from sub-hourly data with a 

resolution equal or greater than 5-minutes from sources other than AERMINUTE. 

The EPA will consider shorter-term "snapshots" of wind data such as National 

Weather Service hourly summaries as part of the weight-of-evidence 

demonstration." 

The word "sustained does refer to a one or two-minute average in other meteorological 

contexts. In more recent exceptional event demonstrations, the Division has been 

addressing the threshold issue with the following language: 

EPA ~ May 2, 2011 draft Guidance on the Preparation of Demonstrations in 

Support of Requests to Exclude Ambient Air Quality Data Affected by High 

Winds under the Exceptional Events Rule states -Empirical evidence shows 

that a sustained wind speed of 25 mph is typically the minimum wind speed 

needed to entrain particles from many stable surfaces (i.e., undisturbed/natural 

surfaces with a crust or disturbed surfaces that have been restabilized) in the 

western U.S. where rainfall is seasonal (see Appendix A), and thus is a useful 

threshold for setting differential expectations for the detail to be included in a 

demonstration that dust from a wind event was not reasonably controllable or 

preventable.I/ In Eastern Colorado it has also been shown that wind speeds of 

30 mph or greater and gusts of 40 mph or greater can cause blowing dust (see 

references for the Natural Events· Action Plan for High Wind Events - Lamar, 

Colorado and the Technical Support Document for the January 19, 2009 Lamar 

Exceptional Event and Attachment A - Grand Junction, Colorado, Blowing Dust 

5 While the National Weather Service defines a "sustained wind" as the wind speed determined by 

averaging observed values over a two-minute period, the EPA believes that it would take a longer period 

of high wind speeds to raise enough dust to significantly influence measured 24-hour average values of 

PM10 or PM2.5 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 11 

August, 2012 
Climatology). Sustained winds of 25 mph and wind gusts of 40 mph will be used 

for blowing dust thresholds in this report." 

2. Lamar Exceptional Events Analysis: 

The Lamar area experiences high wind events that typically occur over the period 

November through May when regional weather patterns create strong pressure 

gradients which can cause strong winds and significant blowing dust across the plains 

of eastern Colorado, western Kansas and western Nebraska and the arid regions of the 

Four Corners states. 

As indicated in the PM10 monitoring data, a number of exceedances of the 24-hour 

PM10 standard have been recorded that appear to be associated with regional highwind events. Table 5 identifies the all exceedances of the 24-hour PM10 NAAQS for 

both the Power Plant and Municipal Complex monitors over the past 11 years and the 

current status of these events. 

Table 5: Lamar Area PM10 Exceedances (2001-2011) 

Monitor Site 24-hr 

Event PM10 Data Flag Filing Status/EPA Review Date Value 

[μg/m3] 

04/11/01 Power Plant 152 none Event not flaaaed 

02/09/02 Power Plant 246 High Wind EPA Concurrence on Flag 

03/07/02 Power Plant 246 High Wind EPA Concurrence on Flag 

05/21/02 Power Plant 196 High Wind EPA Concurrence on Flag 

05/21/02 Municipal 183 High Wind EPA Concurrence on Flag 

06120102 Power Plant 181 High Wind EPA Concurrence on Flag 

06120102 Municipal 162 High Wind EPA Concurrence on Flag 

04/05/05 Power Plant 203 High Wind EPA Concurrence on Flag 

04/05/05 Municipal 164 High Wind EPA Concurrence on Flag 

05102108 Power Plant 367 High Wind EE demo submitted to EPA 

05/22/08 Power Plant 227 High Wind EE demo submitted to EPA 

01/19/09 Power Plant 174 ·High Wind EE demo submitted to EPA 

01/19/09 Municipal 173 High Wind EE demo submitted to EPA 

02106109 Power Plant 233 none Event not flaaaed 

03/05/09 Municipal 176 High Wind Flaaaed - Not submitted 

03/26/09 Power Plant 171 none Event not flaaaed 

04/03/11 Power Plant 169 High Wind Prelim Analysis in Plan 

11/05/11 Power Plant 192 High Wind Prelim Analysis in Plan 

2008 Events 

There were two exceedances of the standard in 2008 that were clearly associated with 

high wind events. The Division submitted the technical analysis for these events to 

EPA The following links provide access to the documents: 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 12 

August, 2012 
http://www.colorado.gov/airquality/documentsffSD Lamar Event Update 050208.pdf 

http://www.colorado.gov/airquality/documentsffSD Lamar Event 052208.pdf 

2009 Events 

There were five exceedances of the standard in 2009 that were clearly associated with 

high wind events. The Division submitted the technical analysis for the two January 

19th events to EPA. The following link provides access to the document. · 

http://www.colorado.gov/airquality/documentsffSD Blowing Dust Event 011909.pdf 

The Lamar Power Plant PM 10 monitor recorded two high-wind exceedances of the 24-

hour PM10 standard , 233 μg/m3 on February 5th and 171 μg/m3 on March 26th that 

were not flagged by the Division because of a data tracking oversight. Unfortunately, 

the data flagging requirements prescribed in the EPA regulations (Treatment of Air 

Quality Monitoring Data Influenced by Exceptional Events), under 40 CFR §50.14(c)(iii), 

do not provide any flexibility for missing a data flag event. Based on wind speed data 

from the Lamar Municipal Airport for the two unflagged exceedances in 2009 (see 

Appendix B), it appears that the February 5th event had predominantly westerly winds 

ranging 29-38 miles per hour (mph) over a 6-hour period with peak gusts over 49 mph, 

while the March 26th event had predominantly north easterly winds ranging 28-33 mph 

over a 4-hour period wit.h peak gusts over 40 mph. Consequently, based on the draft 

EPA guidance, both events appear to have sustained wind speeds that are over the 

suggested 25 to 30 mph thresholds and gusts over 40 mph, thus had these events 

been flagged , it is very likely that these data points would have been excluded. 

The Municipal Complex PM10 monitor recorded a 176 μg/m3 on March 5th that was 

flagged by the Division as a high wind event; however, the Division did not submit a 

technical analysis before the regulatory deadline because of resource limitations. 

Based on wind speed data from the Lamar Municipal Airport for this flagged but not 

submitted to EPA exceedance (see Appendix B), it appears that the March 5th event 

had predominantly westerly winds ranging 26.5 - 39 miles per hour (mph) bver a 10-

hour period with peak gusts over 50 mph. Consequently, this event appears to have 

sustained wind speeds that are over the thresholds, thus had this event been flagged, it 

is very likely that this value would have been excluded. 

, 

2011 Events 

The Division has performed a preliminary analysis (see Appendix B) of the two events 

that occurred in 2011 , which clearly indicates high wind contributed to the PM10 

exceedances. A complete analysis of the 2011 high wind events at the Power Plant 

monitoring site are not due to EPA until the November 1, 2014. 

3. Historical Seasonal Fluctuations: 

Additionally, the preamble of the Exceptional Event Rule (EER) states "For extremely 

high concentrations relative to historical values (e.g., concentrations greater than the 

95th percentile), a lesser amount of documentation or evidence may be required to 

demonstrate that the event affected air quality." See 72 FR 13569. Accordingly, those 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 13 

August, 2012 
values that are extremely high relative to historical norms may be subject to a less 

rigorous technical analysis because of the obvious rarity of such events. 

Figure 2 provides a historical seasonal evaluation of daily PM10 fluctuations over the 5-

year period (2007-2011) involving 1,820 daily PM10 concentrations recorded at the 

Power Plant PM10 monitor. 

Figure 2: Lamar Power Plant (08-099-0001) - Historical Seasonal Fluctuations 

Lamar Power Plant Historical Seasonal Fluctuations 

in PMlO Data 2007-2011 

%7-Submitttd 0 05/02/08 

~ 250 +---- H3-NoFlae --+----------l--------+---------+-

"00 0 02/06/09 27 Submitttd 

...:. \::.,) 05/22/ 08 

0 

.... 192.naec•d 200 ~ • 11/05/11 D.. 171-NoFlac 169-Flacctd :; 0 03/26/ (}9 • • 04/03/11 0 

~ 174-5umitttd 

~ 150 01/ 19/ 09 

• 

• • • 

• • 100 . • •• . • • • •• •• ... • • 

The daily Power Plant values over the 24-hour PM 10 NAAQS are circled in red and are 

associated with seasonal high wind events that exceed the ggth percentile (quarterly 

basis) which suggest exceptional events requiring less rigorous demonstrations. The 

red horizontal lines denote the 951

h percentile (1 ,820*(1-.95)/4 =23rd high) for the four 

quarters. As indicated in the above figure, high PM10 values appear to correspond with 

the seasons when Lamar experiences high wind events (e.g. late fall through late 

spring). 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 14 

August, 2012 
Figure 3 provides a historical seasonal evaluation of daily PM 10 fluctuations over the 5-

year period (2007-2011) involving 1,750 daily PM10 concentrations recorded at the 

Municipal Complex Plant PM 10 monitor. 

Figure 3: Municipal Complex (08-099-0002)- Historical Seasonal Fluctuations 

m 

-! 

.. 

..:. 

0 

.... 

~ 100 

Q. 

:; 

0 

.r. 

it 

173-Sumittod 

01/19/09 

0 

Lamar Municipal Complex Historical Seasonal Fluctuations 

in PMlO Data 2007-2011 

0 . 176-Flauod 

No Submittal 

03/05/09 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

The daily Municipal Complex values over the 24-hour PM10 NAAQS are circled in red 

and are associated with seasonal high wind events that exceed the 99th percentile 

(quarterly basis) which suggest exceptional events. The red horizontal lines denote the 

95th percentile (1 ,750*(1-.05)/4 =22nd high) for the four quarters. 

The above 144 μg/m3 PM10 concentration (recorded in 2009) was flagged as a high 

wind event but is included in the design value determination because the value is below 

the level of the 24-hour PM10 NAAQS. The above 176 μg/m3 PM10 concentration 

(recorded in 2009) was flagged as a high wind exceptional event, but the Division could 

not complete the technical analysis before the March 30, 2012 submittal deadline, thus 

this exceedance is included in the design value calculation. 

In conclusion, all Lamar PM10 exceedances are clearly rare events that are well above 

the 95th percentile and occur in the three seasons associated with high wind events. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 15 

August, 2012 
D. DESIGN VALUE DETERMINATION 

The "design value (DV)" is the critical air quality value from which the maintenance plan 

is based. The design value, and the conditions that occurring on the day which it was 

measured, are utilized to develop emission inventories and serve as a baseline for 

modeling ambient concentrations into the future. The selection of this design value 

utilized EPA's table look-up method from EPA's "RM10 SIP Development Guideline" 

document. According to the guidance, the design concentration at the Power Plant site 

is the fourth high PM10 concentration based on number of daily monitoring values 

(1,093) over the 3-year period (2009 - 2011 ). However, the design concentration at the 

Municipal Complex site is the third high based on a lower number of daily monitoring 

values (1,034) over the same 3-year period. 

Table 6 provides the status of all exceedances of the PM10 NAAQS, since 2001, to 

ensure the correct values are used in determining the DV for both the Power Plant and 

Municipal Complex monitoring sites. 

Table 6: Lamar Area PM10 Exceedances (2001-2011) 

Event PM10 EPA Review/Filing Treatment of Data in 

Monitor Site Value Data Flag DV calculation (2009- Date [μg/m3] Status 2011) 

04/11/01 Power Plant 152 none Event not flagged Not considered in D V 

02/09/02 Power Plant 246 High Wind EPA Concurrence Not considered in D V 

03107102 Power Plant 246 High Wind EPA Concurrence Not considered in D V 

05/21/02 Power Plant 196 High Wind EPA Concurrence Not considered in DV 

05/21/02 Municipal 183 High Wind EPA Concurrence Not considered in D V 

06/20/02 Power Plant 181 High Wind EPA Concurrence Not considered in D V 

06/20/02 Municipal 162 High Wind EPA Concurrence Not considered in D V 

04105105 Power Plant 203 High Wind EPA Concurrence Not considered in D V 

04105105 Municipal 164 High Wind EPA Concurrence Not considered in D V 

05/02/08 Power Plant 367 High Wind Under EPA Not considered in D V 

Consideration 

05/22/08 Power Plant 227 High Wind Under EPA Not considered in D V 

Consideration 

01/19/09 Power Plant 174 High Wind Under EPA Excluded from DV 

Consideration , Under EPA 01/19/09 Municipal 173 High Wind Consideration Excluded from DV 

02/06/09 Power Plant 233 none Event not flagged Included in DV 

03105109 Municipal 176 High Wind Flagged - Not Included in DV 

submitted 

03/26/09 Power Plant 171 none Event not flagged Included in DV 

04/03/11 Power Plant 169 High Wind Prelim Analysis Excluded from DV 

11/05/11 Power Plant 192 High Wind Prelim Analysis Excluded from DV 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 16 

August, 2012 
The "controlling" design concentration, or design value for an area with two monitors is 

the higher of the two values. 

From the above table, the Division assumes that EPA will concur on four high-wind 

exceptional events thereby allowing exclusion of these data values from the 

determination of the design value. Three other exceedances of PM10 standard are 

included in the design value calculation even though these events appear to be 

exceptional and are associated with high winds. Table 7 provides the determination of 

the design value for both the Power Plant monitor and the Municipal Complex monitor. 

Table 7: PM10 Design Value Determination for 3-Year Period (2009- 2011) 

Lamar Power Plant [08-099-0001] Lamar Municipal Complex [08-099-0002) 

PM10 PM10 

Rank Concentration Date Rank Concentration Date 

[μg/m3] [μg/m3] 

1 SI 233 February 6, 2009 1s1 176 March 5, 2009 

2na 171 March 26, 2009 2na 144 February 17, 2009 

3ra 138 March 5, 2009 3ra 122 November 5, 2011 

4tn 136 April 13, 2010 

As discussed above, the siting deficiencies associated with the Lamar Power Plant 

monitor should preclude the use of that data to assess Lamar's ongoing compliance 

with the PM10 NAAQS. Accordingly, the revised maintenance plan PM10 design value, 

based on the Lamar Municipal Complex data is 122 μglm3. Alternatively, even if the 

Lamar Power Plant data were included in the analysis, the revised maintenance plan 

PM10 design value would be 136 μglm3. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 17 

August, 2012 
SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL 

The following presents a brief sumrnary of the development and the approval of the 

Lamar PM10 nonattainment SIP Element. 

A. 1993 SIP ELEMENT 

A Lamar SIP Element was adopted by the AQCC in April 1993 and became effective 

April 1993. The Lamar SIP Element was approved by the EPA on June 9, 1994 (59 FR 

14015). The Plan did not include mandatory control measures as they were not 

needed to demonstrate attainment. 

B. PM10 REDESIGNATION REQUEST/MAINTENANCE PLAN 

The Lamar PM10 Redesignation Request/Maintenance Plan was adopted by the 

Commission on November 15, 2001. The U.S. Environmental Protection Agency 

approved the plan on October 25, 2005 which became effective on November 25, 2005. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 18 

August, 2012 
SECTION 4: PERMANENT AND ENFORCEABLE 

IMPROVEMENT IN AIR QUALITY 

The State must demonstrate, based on Section 107(d)(3)(E) of the CAA, that the 

improvement in air quality leading to attainment of the NAAQS and the redesignation 

request is based on permanent and enforceable measures, and that the reductions are 

not the result of temporary reductions in emissions or unusually favorable meteorology. 

For the Lamar area, non-attainment was largely the result of blowing dust due to high 

wind events. As these are naturally occurring and uncontrollable, no mandatory 

controls have been required for the Lamar area. The area was able to demonstrate 

attainment in the 1993 State Implementation Plan without additional control measures. 

A. OVERVIEW 

Lamar was designated a non-attainment area in 1990 due to high TSP values and high 

PM 10 concentrations. 

Over the last ten years, the area has experienced a decline in growth and population, 

although it is not clear whether the decline has had any influence on monitored PM 10 

concentrations. The Colorado State Demographer's Office reports that between 2000 

and 2010, the population of Lamar declined by a -1.3% annual rate and the population 

of Prowers County declined by a -1.4% annual rate. Similarly, economic conditions in 

Prowers County declined by a -0.5% annual rate. 

A review of the Colorado Department of Transportation's (COOT) information for the 

Lamar area indicates average daily traffic is projected to annually increase at a rate of 

about 1.4%. Despite growth in traffic, attainment of the PM10 NAAQS continues to be 

demonstrated, and relatively few concentrations above 100 ug/m3 are measured. High 

wind events have resulted in occasional exceedances of the PM 10 NAAQS, but these 

natural events are excluded from determination of non-attainment/attainment. 

Local economic conditions might be a contributing factor in maintaining lower ambient 

PM levels in the Lamar attainment/maintenance area because Prowers County tax 

. revenue has experienced a slight decline of about 3.6% over the past eight years. 

Generally, it is assumed that growth in population and sales tax revenue are indicators 

of increased activities that could cause increased PM10 emissions and the potential for 

elevated PM 10 concentrations. 

Aside from infrequent high wind events, favorable meteorology seems to be an unlikely 

reason for the typically low PM10 concentrations in the Lamar area. Since 2007, there 

have been nine exceedances of the 24-hour PM NAAQS but all appear to be 

associated with high wind events. Generally, the eastern plains of Colorado experience 

variable high wind meteorological conditions over the fall to spring period but there is 

little evidence, aside from the extreme drought in the area in 2002, to suggest that 

meteorological conditions experienced over the more recent years are anything but 

typical" (although it is difficult to make definitive conclusions based on short-term 

meteorological records). Consequently, the APCD concludes that the good air quality 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 19 

August, 2012 
in the Lamar area is due the implementation of emission reduction control measures, 

except for high wind events where BACM controls are overwhelmed. 

B. CONTROL MEASURES 

The following describes the control measures that have been implemented in the Lamar 

area: 

1. Control of Emissions from Stationary Sources 

Although there are few stationary sources located in the Lamar attainment/maintenance 

area, the State's comprehensive permit rules will limit emissions from any new source 

that may, in the future, locate in the area. These rules include: 1) Regulation No. 1, 

"Emission Control Regulation for Particulates, Smoke, Carbon Monoxide and Sulfur 

Oxides;" 2) Regulation No. 3, "Air Pollution Emission Notices, Construction Permits and 

Fees, Operating Permits, and Including the Prevention of Significant Deterioration;" 3) 

Regulation No. 4, "New Woodstoves and Woodburning Appliance Use During High 

Pollution Days;" 4) Regulation No. 6, "Standards of Performance for New Stationary 

Sources;" and 5) the "Common Provisions" regulation . 

Regulation No. 1 applies to fugitive dust, fuel burning equipment, incinerators, and 

certain manufacturing processes as potential sources of PM10. Regulation No. 1 

Section 111.D requires new or existing sources of fugitive particulate emissions to employ 

such control measures and operating procedures necessary to minimize fugitive 

particulate emissions including a 20% opacity limitation, a prohibition on off-property 

transport of visible emissions and no emission of fugitive particulates that create a 

nuisance. Each subject source is required to obtain an emission permit under 

Regulation No. 3 must submit to the Division a fugitive particulate emission control plan 

that specifies all available practical methods which are technologically feasible and 

reasonable to prevent and control fugitive particulate emissions. Examples of subject 

sources include unpaved roadways with vehicle traffic over 200 vehicles per day 

(attainment areas); construction activities; storage and handling of materials; mining 

activities; haul roads/trucks, tailings piles and ponds; demolition activities and blasting 

activities; sandblasting operations and livestock confinement operations. 

The Common Provisions, and Parts A and B of Regulation No. 3, are already included 

in the approved State-wide SIP. Regulation No. 3 requires all sources with uncontrolled 

actual PM10 emissions equal to or exceeding five (5) tons per year to obtain a permit. 

Regulation No. 6 implements the federal standards of performance for new stationary 

sources (NSPS), which includes incorporation of Standards of Performance for 

Nonmetallic Mineral Processing Plants (40 CFR Part 60, Subpart 000). NSPS 000 

applies to fixed or portable sand and gravel operations that exceed defined production 

levels. The maintenance plan makes no changes to these regulations. This reference 

to Regulation No. 6 shall not be construed to mean that this regulation is included in the 

SIP. 

As indicated above, emissions from new or modified major stationary sources 

emissions of PM10 are controlled under Regulation No. 3's nonattainment area new 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 20 

August, 2012 
source review (NSR) permitting requirements. The NSR provisions require all new and 

modified major stationary sources in non-attainment areas to apply emission control 

equipment that achieves the "lowest achievable emission rate" (LAER) and to obtain 

emission offsets from other stationary sources of PM10. 

The EPA approval of the original PM10 Maintenance Plan, effective on 11/25/05, 

reinstates the prevention of significant deterioration (PSD) permitting requirements in 

the Lamar Attainment/Maintenance area. The federal PSD requirements apply to new 

or modified major stationary sources which must utilize "best available control 

technology" (BACT). This requirement will help to ensure that PM10 emissions in the 

Lamar Attainment/Maintenance area will continue to be minimized in the future. 

2. Federal Motor Vehicle Emission Control Program (FMVECP) 

The FMVECP has reduced PM10 emissions through a continuing process of requiring 

diesel engine manufacturers to produce new vehicles that meet tighter and tighter 

emission standards. As older, higher emitting diesel vehicles are replaced with newer 

vehicles through fleet turnover; tailpipe PM10 emissions in the Lamar area will be 

further reduced . 

3. Voluntary and State-Only Measures 

In addition to the measures discussed above, there are other activities that result in the 

reduction of PM10 emissions. Some notable examples include: 

• The City of Lamar has historically cleaned their streets in town throughout the 

winter and spring using street sweepers. The frequency of this voluntary effort is 

determined by weather. 

• The City of Lamar and areas immediately surrounding require that new 

development have paved streets. 

These strategies are considered to be voluntary local initiatives and State-only 

requirements, and are intended to reduce PM10 emissions. These strategies are not 

intended to be federally enforceable. 

4. State Implementation Plan Measures 

• Any owner or operator responsible for the construction or maintenance of any 

existing or new unpaved roadway which has vehicle traffic exceeding 200 

vehicles per day in the attainment/maintenance area and surrounding areas 

must stabilize the roadway in order to minimize fugitive dust emissions6

. These 

statewide requirements are defined in detail in the AQCC's Regulation No. 1. 

6 See Regulation No. 1, 111.D.2.a.(i). Particulate matter requirements are specified in section Ill of 

Regulation Number 1 which was approved into the Colorado State Implementation Plan on 04/17/1997, 

[62 FR 18716]. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 21 

August, 2012 
C. CLEAN AIR ACT SECTION 110 AND PART D REQUIREMENTS 

For the purposes of redesignation, all of the requirements of CAA Section 110 and Part 

D applicable to the area must first be met. The requirements of Section 110 and Part D 

applicable to the Lamar area are already included in the SIP for Colorado and have 

already been approved by EPA. In particular, see EPA's final approval actions for the 

Lamar SIP Element (Federal Register, Vol. 59, No. 110, June 9, 1994). 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 22 

August, 2012 
SECTION 5: MAINTENANCE PLAN 

A. REQUIREMENTS 

Section 107(d)(3)(E) of the CAA provides that for an area to be redesignated to an 

attainment classification, EPA must fully approve a maintenance plan which meets the 

requirements of CAA Section 175A. The maintenance plan will constitute a SIP 

revision and must provide for maintenance of the relevant NAAQS in the area for at 

least ten years after redesignation. Since the requirement is for ten years after 

redesignation , some lead time for the EPA approval process (up to 18 months per CAA 

Section 107(d)(3)(D)) should be considered in establishing the maintenance year, which 

the State determines to be 2021 . An additional requirement (Section 175A(b)) is the 

submittal of a SIP revision eight years after the original redesignation 

request/maintenance plan is approved that provides for maintenance of the NAAQS for 

an additional ten years following the first ten-year period. The State of Colorado has 

satisfied this commitment by submitting this revised maintenance plan as required by 

the CAA and EPA requirements. 

Section 175A further states that the plan shall contain such additional control measures 

as necessary to ensure maintenance. All current nonattainment area control measures 

shall remain in place, except for the most stringent NSR stationary source permitting 

requirements (see Section 4.B.3.). The maintenance plan shall contain a contingency 

plan to ensure the prompt correction of any unforeseen violation of the PM 10 NAAQS. 

Failure to maintain the NAAQS and triggering of the contingency plan will not 

necessitate a revision of the SIP Element, unless required by the EPA Administrator, as 

stated in CAA Section 175A(d). 

The provisions that are addressed in this maintenance plan include emission 

inventories (for a base year and a future year), a maintenance demonstration, an 

emission budget, an approved monitoring network, verification of continued attainment, 

and a contingency plan. 

B. EMISSION INVENTORIES 

The below emission inventories include the 2010 base year, 2020 interim year and the 

2025 maintenance year. These inventories reflect the base and projected conditions in 

the Lamar Attainment/Maintenance Area, and account for the emission control 

measures that have been adopted as part of the original redesignation request and the 

previous 10-year maintenance plan. Unlike the previous Lamar plans where the 

emission inventories were based on a grid system of the attainment/maintenance area 

and an average winter-time day, the updated emission inventories, for 2010, 2020 and 

2025, are based on average daily winter/spring emissions. Consequently there are 

significant differences between the emission inventories in the previous plan and this 

updated PM10 Maintenance Plan. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 23 

August, 2012 
1. 2010 Base Emission Inventory 

The 2010 base emission inventory for the Lamar Attainment/Maintenance Area is 

presented below. This updated emission inventory incorporates the most current 

estimates for the following sixteen (16) source categories: 

• Point Sources (Actual Emissions used in 2010) 

• Helicopters 

• Construction 

• Fuel Combustion 

• Railroads 

• Structure Fires 

• Wood-burning 

• Paved Road Dust 

• Unpaved Road Dust 

• Non-Road Commercial Equipment 

• Non-Road Construction and Mining Equipment 

• Non-Road Industrial Equipment 

• Non-Road Lawn and Garden Equipment (Com) 

• Non-Road Lawn and Garden Equipment (Res) 

• Non-Road Railroad Equipment 

• Highway Vehicles 

The mobile source inventories (unpaved road dust, paved road dust, and highway 

vehicles) have been updated to reflect the following: 

• Latest traffic (VMT) estimates from the Colorado Department of Transportation 

(COOT) 

• Revised emission factors and methods for determining paved road emissions 

• Road paving of unpaved roads that has occurred in the area 

• Vehicle exhaust emissions based on most up-to-date fleet mix using the EPA 

MOVES model (version 201 Oa) 

All emission estimates were prepared by using EPA-approved methods and assigned to 

the area comprising the Attainment/Maintenance area. 

The Lamar Attainment/Maintenance Area is the urbanized portion of the City of Lamar 

that existed in 1992. No commercial agriculture activities are practiced in the Lamar 

Attainment/Maintenance Area. 

Table 8 presents the 2010 PM10 emission estimates for each source category pounds 

per winter/spring average day and tons per year. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 24 

August, 2012 
Table 8: 2010 PM10 Emission Inventory - Lamar Attainment/Maintenance Area 

Source Category 2010 PM10 2010 PM10 

[lbs/day] [tons/yr] 

Point Sources (2010 Actual Emissions) 186.3 34.0 

Helicopters 0.1 0.0 

Construction 257.7 47.0 

Fuel Combustion 0.6 0.1 

Railroads 1.0 0.2 

Structure Fires 0.5 0.1 

Wood-burning 116.6 21 .3 

Paved Road Dust 194.7 35.5 

Unpaved Road Dust 229 41 .8 

Non-Road Commercial Equipment 2 0.4 

Non-Road Construction & Mining Equipment 75.8 13.8 

Non-Road Industrial Equipment 1.7 0.3 

Non-Road Lawn & Garden Equipment (Com) 0.6 0.1 

Non-Road Lawn & Garden Equipment (Res) 0.5 0.1 

Non-Road Railroad Equipment 0 0 

Highway Vehicles (Exhaust, Brake & Tire Wear) 292.1 53.3 

Totals: 1,359 248.0 

Population Trends in Lamar and Prowers County 

The population trend data (see Figure 4 below) for Prowers County and the City of 

Lamar over the most recent 10-year period (2000-2010) indicates a gradual annual 

decline of about -1.4% and -1 .3% respectively. The State Demography Office (SDO) 

anticipates a gradual increase in county population will begin in 2011 and continue into 

the future. Population projections for smaller towns/cities are not typically done by the 

SDO, consequently, the Prowers County projections must be used as an indicator of 

future growth for the Lamar area. The Prowers County/City of Lamar annual population 

growth rate over next 15 years (2010-2025) is projected at about 0.88% 

Figure 4: Population Trends and Forecasts for Prowers County and City of Lamar 

Population Trends and Forecasts 

• Prowers County • City of Lama r 

15,000 

14.000 

13,000 

12,000 

c 11,000 0 10,000 .... 9.000 ro 

::J s.ooo - - - - - - - -

a. 7.000 - I- f- - - - f- fa.. 

0 6,000 - - - - - - - - 5,000 - - - - - - - - 4,000 - I- f- - - - 3,000 - - f- - -- -- 2.000 - - -- - - - - - - 1,000 - - f- - f- - f- f0 T T 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 25 

August, 2012 
2. 2020 Interim Emission Inventory 

Table 9 presents the 2020 PM10 emission estimates for each source category in 

pounds per winter/spring average day and tons per year. 

The 2020 point source emissions are increased to potential to emit for each stationary 

source in the maintenance area. Woodburning, construction and unpaved road dust 

are estimated to increase at a rate of 0.6% per year (or 6% over the 10 year period). 

Paved road dust is estimated to increase at a rate of 1.41 % per year (1.014078 or 

14.1 % over the 10 year period) based on the Prowers County Highway Database for 

2010. The 2020 mobile source tailpipe PM emissions were reduced by an annual 

compounded rate of 0.34% per year (1.00336 or -3.4% over the 10 year period). The 

reduction in PM emissions is associated with anticipated fleet turnover projected by 

MOVES. Detailed information on the growth rate may be found in the Emission 

Inventory Technical Support Document. 

The road paving that the City of Lamar and Powers County plan on completing is not 

assumed in the 2020 inventory as the paving is considered voluntary and not 

enforceable by the State. 

Table 9: 2020 PM10 Emission Inventory - Lamar Attainment/Maintenance Area 

Source Category 2020 PM10 2020 PM10 % Increase 

[lbs/day] [tons/yr] over 10-yrs 

Point Sources (Potential Emissions) 205.5 37.5 10% 

Helicopters 0.1 0.0 0% 

Construction 273.1 49.8 6% 

Fuel Combustion 0.6 0.1 8% 

Railroads 1.1 0.2 5% 

Structure Fires 0.5 0.1 0% 

Wood-burning 123.5 22.5 6% 

Paved Road Dust 222.1 40.5 14% 

Unpaved Road Dust 242.7 44.3 6% 

Non-Road Commercial Equipment 1.5 0.3 -23% 

Non-Road Construction & Mining Equipment 35.2 6.4 -54% 

Non-Road Industrial Equipment 0.7 0.1 -56% 

Non-Road Lawn & Garden Equipment (Com) 0.6 0.1 14% 

Non-Road Lawn & Garden Equipment (Res) 0.5 0.1 13% 

Non-Road Railroad Equipment 0 0 0% 

Highway Vehicles (Exhaust, Brake & Tire Wear) 282.3 51.5 -3% 

Totals: 1,390 253.7 

3. 2025 Emission Inventory 

Table 10 presents the 2025 PM10 emission estimates for each source category pounds 

per winter/spring average day and tons per year. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 26 

August, 2012 
The 2025 point source emissions are increased to potential to emit for each stationary 

source in the maintenance area. Woodburning, construction and unpaved road dust 

are estimated to increase at a rate of about 0.6% per year (or about 9.4% over the 15 

year period). Paved road dust is estimated to increase at a rate of 2.5% per year 

(1 .014078 or 21.1 % over the 15 year period). The 2020 mobile source tailpipe PM 

emissions were reduced by an annual compounded rate of 0.34% per year (1.00336 or 

-5.0% over the 15 year period). The reduction in PM emissions is associated with 

anticipated fleet turnover projected by MOVES. Detailed information on the growth rate 

may be found in the Emissio,n Inventory Technical Support Document. 

The road paving that the City of Lamar and Powers County plan on completing is not 

assumed in the 2025 inventory as the paving is considered voluntary and not 

enforceable by the State. 

The projected 2025 emissions are 1,408 pounds/day are higher than the 2020 interim 

year emission projections of 1,390 pounds/day. Consequently, since the 2020 interim 

year emissions are below the 2025 projected emissions, the 2025 demonstration of 

PM10 NAAQS maintenance is adequate to demonstrate maintenance for all years 

before 2025. 

Table 10: 2025 PM10 Emission Inventory - Lamar Attainment/Maintenance Area 

Source Category 2025 PM10 2025 PM10 % Increase 

[lbs/day] [tons/yr] over 15-yrs 

Point Sources (Potential Emissions) 205.5 37.5 10% 

Helicopters 0.1 0.0 0% 

Construction 281.9 51.4 9% 

Fuel Combustion 0.7 0.1 17% 

· Railroads 1.1 0.2 10% 

Structure Fires 0.5 0.1 0% 

Wood-burninQ 127.5 23.3 9% 

Paved Road Dust 235.8 43.0 21% 

Unpaved Road Dust 250.6 45.7 9% 

Non-Road Commercial Equipment 1.3 0.2 -35% 

Non-Road Construction & Mining Equipment 23.3 4.3 -69% 

Non-Road Industrial Equipment 0.6 0.1 ~62% 

Non-Road Lawn & Garden Equipment (Com) 0.7 0.1 25% 

Non-Road Lawn & Garden Equipment (Res) 0.6 0.1 25% 

Non-Road Railroad Equipment 0 0 0% 

Highway Vehicles (Exhaust, Brake & Tire Wear) 277.5 50.6 -5% 

Totals: 1,408 259.9 

The mobile source PM10 emission budget (denoted in bold shading) for the Lamar 

Attainment/Maintenance area is the sum of PM 10 emissions from paved roads, 

unpaved roads and highway vehicles, which totals 764 lbs/day for 2025 and beyond. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 27 

August, 2012 
C. MAINTENANCE DEMONSTRATION 

In order for this maintenance plan to be complete and approvable, the CAA requires 

that the maintenance plan provide for continued maintenance of the 24-hour PM 10 

NAAQS for at least 10 years following EPA's approval of the plan. As stated earlier in 

this document, attainment of the 24-hour PM10 NAAQS has been demonstrated in the 

Lamar area and this maintenance demonstration will show continued maintenance of 

the 24-hour NAAQS through the year 2025. 

Data presented throughout this document are utilized to demonstrate continued 

maintenance of the PM 10 NAAQS for the Lamar area. If the 2025 projection is below 

the 24-hour PM10 NAAQS of 150 ug/m3, then maintenance is demonstrated. Based 

on the two analysis options presented below, the 24-hr PM10 maintenance 

concentration projected for 2025 in the Lamar attainment/maintenance area is either 

140.2 μg/m3 or 125.6 μg/m3. Since both projections are below the daily PM standard 

(150 μg/m3), continued maintenance is demonstrated. 

1. Emission Inventory Roll-Forward Analysis 

The 1993 SIP Element for Lamar relied upon the use of the emission inventory rollforward analysis to demonstrate maintenance; consequently the same approach is 

used below. 

Analysis Using Municipal Complex Data: 

As discussed above, because of the siting deficiencies with the Lamar Power Plant 

monitor, the maintenance demonstration for this plan should be based on monitored 

data from the Lamar Municipal Complex. Based on the analysis presented in Section 2 

the design day PM10 concentration is 122 μg/m3. A background concentration of 21 

μg/m3 is assumed to occur on any given day in the Lamar area, as described in Section 

8.1 of the 1993 SIP Element. The PM 10 background concentration is subtracted from 

the design day PM10 concentration because the background PM10 concentration 

would remain if all emissions in the emissions inventory were reduced to zero. 

Design Day PM10 Concentration: 122 μg/m3 

Background PM10 Concentration: - 21 μg/m3 

101 μg/m3 

The following analysis presents the emissions inventory roll-forward approach used to 

calculate the 2025 maintenance concentration: 

PM 10 baseline = PM 1 0 projection 

PM 10 201 O emissions PM 10 2025 emissions 

Where: 

PM10 projection =to be calculated (unknown) 

PM10 baseline = 101 μg/m3 is the baseline PM10 concentration w/o background 

PM10 2010emissions = 1,359 lbs/day is the baseline PM10 emissions 

PM 10 2025 emissions = 1,408 lbs/day is the projection PM 10 .emissions 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 28 

August, 2012 

• 
Solving the roll-forward equation for the unknown: 

101 μg/m3 = PM10 projection 

1,359 lbs/day 1,408 lbs/day 

PM10 projection= 104.6 μg/m3 

Calculating the 2025 PM10 maintenance concentration : 

PM102025 = PM10 projection+ background 

PM102025 = 104.6+21 .0=125.6 μg/m3 

Since the PM10202s value is below the 24-hour PM10 NAAQS (150 ug/m3), 

maintenance of the standard is demonstrated. 

Analysis Using Power Plant Data: 

Alternatively, if monitored data from the Power Plant is considered, the calculation is as 

follows: 

Design Day PM10 Concentration: 136 μg/m3 

Background PM10 Concentration: - 21 μg/m3 

115 μg/m3 

The following analysis presents the emissions inventory roll-forward approach used to 

calculate the 2025 maintenance concentration: 

PM10 baseline = PM 10 orojection 

PM 1 0 201 O emissions PM 10 2025 emissions 

Where: 

PM10 projection =to be calculated (unknown) 

PM 10 baseline = 115 μg/m3 is the baseline PM 10 concentration w/o background 

PM10 201oemissions = 1,359 lbs/day is the baseline PM10 emissions 

PM 10 2025 emissions = 1 ,408 lbs/day is the projection PM 10 emissions 

Solving the roll-forward equation for the unknown: 

115 μg/m3 

1,359 lbs/day 

PM 10 projection = 

= PM 1 0 projection 

1,408 lbs/day 

119.2 μg/m3 

Calculating the 2025 PM 10 maintenance concentration : 

PM102025 = PM10 projection+ background 

PM102025 = 119.2+21.0=140.2 μg/m3 

Since the PM102025 value is below the 24-hour PM10 NAAQS (150 ug/m3), 

maintenance of the standard is demonstrated. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area 

August, 2012 

Page 29 
D. MAINTENANCE PLAN CONTROL MEASURES 

There are no mandatory control measures adopted specifically for the Lamar area 

because the area demonstrates long-term maintenance of the 24-hour PM10 NAAQS 

without specific controls. This Maintenance Plan retains the elimination of mandatory 

SIP contingency measures as these are not required for re-designated areas. 

The following regulations serve to control PM10 emissions from stationary sources: 

• Common Provisions, 5 CCR 1001-2; 

• Regulation No. 1, Emission Control Regulation for Particulates, Smoke, 

Carbon Monoxide and Sulfur Oxides; 

• Regulation No. 3, Air Contaminant Emissions Notices, 5 CCR 1001-5; 

• Regulation No. 4, New Woodstoves and Woodburning Appliance Use 

During High Pollution Days; 

• Regulation No. 6, Standards of Performance for New Stationary Sources, 

5 CCR 1001-8; and 

• Certain aspects of the Lamar Natural Events Action. 

The Common Provisions, and Parts A and B of Regulation No. 3, are already included 

in the approved SIP. Regulation No. 6 implements the federal standards of 

performance for new stationary sources, but is not part of the SIP. 

This maintenance plan makes no changes to these regulations. This reference to 

Regulation No. 6 shall not be construed to mean that this regulation is included in the 

SIP. 

E. PM10 EMISSION BUDGET 

Federal "transportation conformity" regulations provide for the use of mobile source 

emission budgets in making conformity determinations in the area. The emission 

budget serves as a ceiling on mobile source emissions that federally funded or 

approved transportation projects must comply or conform. 

This revised maintenance plan establishes a mobile source PM10 emission budget for 

the Attainment/Maintenance area of 764 lbs/day for 2025 and beyond. This budget is 

the total of the 2025 mobile source PM10 emissions (see Section 5.8.3. above), which 

includes PM10 emissions from highway vehicles, paved roads, and unpaved roads. 

This budget has been adopted in the AQCC's "Ambient Air Quality Standards for the 

State of Colorado" regulation. 

F. MONITORING NETWORK/VER/FICA TION OF CONTINUED 

ATTAINMENT 

The APCD has monitored ambient PM10 concentrations in the Lamar area since 1985. 

The APCD has operated, and will continue to operate, the Lamar PM10 monitoring 

network in full accordance with the federal provisions of 40 CFR Part 58 and the EPADraft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 30 

August, 2012 
approved Colorado Monitoring SIP Element. The APCD will also analyze the 

monitoring data to verify continued attainment of the PM10 NAAQS. This information 

will provide the necessary information to determine whether the Lamar area continues 

to attain the PM10 NAAQS. Detailed information regarding the State's monitoring 

efforts and historical monitoring data can be found in Section 2 of this document. 

In addition, the State will track the progress of the maintenance plan through a periodic 

review (every three years) of the assumptions made in the emissions inventories to 

assure continued maintenance of the PM10 NAAQS. A revised inventory will be 

developed if assumptions indicate a significant change in the factor(s) used to develop 

the attainment inventory. 

As discussed in Section 2, the Division submitted a request to EPA in 2011 for the 

removal of the Lamar Power Plant monitoring site because it does not provide 

representative data of the public's exposure to PM10. Contingent upon formal EPA 

approval of the removal request, the Division would need to update and amend the 

maintenance plan to reflect any changes to the Lamar area monitoring network. 

G. CONTINGENCY PLAN 

Section 175(A)(d) of the CAA requires that the maintenance plan contain contingency 

provisions to assure that the State will promptly correct any violation of the PM10 

NAAQS that may occur after the redesignation of the area to attainment. EPA's 

redesignation guidance notes that the State is not required to have fully adopted 

contingency measures that will take effect without further action by the State. However, 

the contingency plan should ensure that contingency measures are adopted 

expediently once the need is triggered. The primary elements of the contingency plan 

involve the tracking and triggering mechanisms to determine when contingency 

measures would be needed and a process for implementing appropriate control 

measures. 

1. Tracking 

The tracking plan for the Lamar area will consist of monitoring and analyzing PM 10 

concentrations. In accordance with 40 CFR Part 58, Colorado will continue to operate 

and maintain a representative PM10 monitoring network for the Lamar area. 

2. Trigger and Response 

Triggering of the contingency plan does not automatically require a revision of the SIP 

nor is the area necessarily redesignated once again to nonattainment. Instead, the 

State will normally have an appropriate time-frame to correct the violation with 

implementation of one or more adopted contingency measures. In the event that 

violations continue to occur, additional contingency measures will be adopted until the 

violations are corrected. 

Upon notification of a PM10 NAAQS exceedance not attributed to natural high wind 

events and blowing dust, the APCD and local government staff in the Lamar area will 

develop appropriate contingency measure(s) intended to prevent or correct a violation 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 31 

August, 2012 
of the PM10 standard. Information about historical exceedances of the standard, the 

meteorological conditions related to the recent exceedance(s), and the most recent 

estimates of growth and emissions will be reviewed. The possibility that an exceptional 

event occurred will also be evaluated and if appropriate, a request will be sent to EPA 

for data exclusion along with a technical analysis demonstrating that high winds were 

associated with the exceptional event. Generally, the Division notifies the Air Quality 

Control Commission (AQCC) of any PM10 exceedance at least twice during each year, 

once after the summer season (around October) and after the winter season (around 

April). 

If a violation of the PM 10 NAAQS has occurred, a public hearing process at the State 

and local level will begin. If the AQCC agrees that the implementation of local 

measures will prevent further exceedances or violations, the AQCC may endorse or 

approve the local measures without adopting State requirements. If, however, the 

AQCC finds locally adopted contingency measures to be inadequate, the AQCC will 

adopt State enforceable measures as deemed necessary to prevent additional 

exceedances or violations. 

Contingency measures will be adopted and fully implemented within one year of a 

PM 10 NAAQS violation. Any State-enforceable measures will become part of the next 

revised maintenance plan, submitted to the Colorado Legislature and EPA for approval. 

3. Potential Contingency Measures 

The APCD and local government staff may choose one or more of the following 

contingency measures to recommend to local officials and the AQCC for consideration. 

Contingency measures will be selected that quickly bring the area back into compliance 

with the PM 10 NAAQS and that specifically meet the needs of Lamar area. It is likely 

that no federal or State monies will be available to fund the implementation of the 

selected contingency measure(s). Most, if not all, of the costs will be borne by local 

citizens and governments, local businesses, and State government agencies. 

• Street sweeping requirements 

• Road paving requirements 

• Street sand specifications 

• Woodburning restrictions 

• Use of alternative de-icers 

• Re-establishing new source review permitting requirements for stationary 

sources 

• Controls at existing stationary sources 

• Transportation control measures designed to reduce vehicle miles 

traveled 

• Other emission control measures appropriate for the area based on the 

following considerations: cost-effectiveness, PM10 emission reduction 

potential, economic and social concerns, and/or other factors that the 

State deems appropriate. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 32 

August, 2012 
H. SUBSEQUENT MAINTENANCE PLAN REVISIONS 

This revised maintenance plan provides for continued maintenance of the PM10 

NAAQS for an additional ten years beyond the original ten-year period. Consequently, 

no further maintenance plan updates are required or anticipated. 

Draft PM10 Maintenance Plan for Lamar Attainment/Maintenance Area Page 33 

August, 2012 
APPENDIX A: Revised Natural Events 

Action Plan 

For High Wind Events in Lamar, Colorado 

Page 34 
[Blank Page] 
' 

2012 REVISED 

NATURAL EVENTS ACTION PLAN 

FOR 

HIGH WIND EVENTS 

LAMAR, COLORADO 

Prepared by: 

Colorado Department 

of Public Health 

and Environment 

AIR POLLUTION CONTROL DIVISION 

4300 Cherry Creek Drive South 

Denver, Colorado 80222-1530 

(303) 692-3100 

and 

CITY OF LAMAR 

PROWERS COUNTY COMMISSIONERS 
I. EXECUTIVE SUMMARY 

This document updates the previous Natural Events Action Plan 7 that was approved by 

EPA as part of the Lamar redesignation request and associated PM 10 maintenance 

plan (see 70 FR 61563). 

Over the past eleven years (2001-2011), the monitors located at the Power Plant and 

Municipal Complex in Lamar, Colorado experienced occasional exceedances of the 24-

hour National Ambient Air Quality Standard (NAAQS) for PM 10 (particulate matter 

having a nominal aerodynamic diameter equal to or less than 10 microns). Each of 

these exceedances was associated with unusually high winds and blowing dust in the 

Lamar area. 

Recognizing that certain uncontrollable natural events, such as high winds, wildfires, 

and volcanic/seismic activity can have on the NAAQS, the Environmental Protection 

Agency (EPA) issued a Natural Events Policy (NEP) in 1996. The NEP specifies the 

procedures for mitigating PM10 impacts which includes the development of a Natural 

Events Action Plan (NEAP) for protecting public health in areas where the PM10 

standard may be violated due to these uncontrollable natural events. The guiding 

principles of the policy are: 

• Federal, State, and local air quality agencies must protect public health; 

• The public must be informed whenever air quality is unhealthy; 

• All valid ambient air quality data should be submitted to the EPA Aerometric 

Information Retrieval System (AIRS) and made available for public access; 

• Reasonable measures safeguarding public health must be taken regardless of 

the source of PM10 emissions; and. 

• Emission controls should be applied to sources that contribute to exceedances 

of the PM 10 NAAQS when those controls will result in fewer violations of the 

standards. 

The original 1998 Lamar NEAP was developed in response to three exceedances of 

the PM10 NAAQS (two in 1995 and one in 1996), the Colorado Department of Public · 

Health and Environment's Air Pollution Control Division (Division), in conjunction with 

the City of Lamar's Public Works Department, Parks and Recreation, and Prowers 

County Commissioners, the Natural Resources Conservation Services, the Burlington 

Northern Santa Fe Railroad, and other agencies. That Plan was presented to EPA in 

1998 and subsequently approved. · 

Since the last update to the Lamar NEAP in 2003, the EPA promulgated in 2007 an 

Exceptional Event Rule (EER) which establishes a process for the treatment of data 

influenced by exceptional everits. The EER is based on amendments to Section 319 of 

the Clean Air Act which defines an exceptional event as an event that: (i) affects air 

quality; (ii) is not reasonably controllable; (iii) is caused by human activity not likely to 

7 See "Revised (2003) Natural Events Action Plan for High Wind Events Lamar, Colorado" 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 11 Page 
recur at a particular location, or is a natural event; (iv) and is determined by EPA 

through the process established in regulation to be an exceptional event. The EER 

provisions require that states address the following six elements in a request for data 

exclusion: 

• The event affects air quality 

• The event was not reasonably controllable or preventable 

• The event was caused by human activity that is unlikely to recur at a particular 

location, or was a natural event 

• There exists a clear causal relationship between the specific event and the 

monitored concentration; 

• The event is associated with a measured concentration in excess of the normal 

historical fluctuations including background 

• There would have been no exceedance or violation but for the event 

Unlike the original EPA Natural Events Policy, the 2007 Exceptional Events Rule does 

not require the development of a Natural Events Action Plan (see 72 FR 13576). 

Nevertheless, since the Lamar NEAP is an element of the EPA approved Lamar PM10 

Maintenance Plan; the NEAP must remain in place and be updated no less than every 

five years - as specified in the original plan. 

Furthermore, the Lamar NEAP has assisted the area in addressing blowing dust due to 

uncontrollable winds and is designed to protect public health, educate the public about 

high wind events and blowing dust; mitigate health impacts on the community during 

future events; and, identify and implement Best Available Control Measures (BACM) for 

anthropogenic sources of windblown dust. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 21 Page 
II. INTRODUCTION 

The City of Lamar is located in Prowers County in southeastern Colorado (see Figure 

1 ). Situated along the Arkansas River and near the Kansas border, Lamar serves as 

the largest city and the agricultural center for southeast Colorado. The area 

surrounding Lamar consists of gently rolling to nearly level uplands where the dominant 

slopes are less than 3 percent. The climate is generally mild and semiarid. Annual 

precipitation is about 15 inches. Summers are long and have hot days and cool nights. 

In winter and spring, windstorms are common, especially in drier years including year 

2002, one of the driest periods in over 350 years. These high velocity dust storms and 

drought conditions are associated with most elevated PM10 issues that the Lamar area 

experiences. 

Figure 1: State of Colorado Map 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 31 Page 
In recognition of the need to protect public health in areas where PM 10 exceeds the 

NAAQS due to natural events such as the unusually high winds, this Natural Events 

Action Plan was revised based on the 1998 and 2003 NEAPs, which were developed 

for the Lamar area based on the original NEP guidance. This plan outlines specific 

procedures to be taken in response to wind-blown events. In short, the purpose of the 

plan is to: 

• Educate the public about the problem; 

• Mitigate health impacts on exposed populations during future events; and 

• Identify and implement Best Available Control Measures (BACM) for 

anthropogenic sources of windblown dust. 

A. Background 

High winds are common to the southeast region of Colorado. Under some conditions, 

these winds are strong enough to lift particulate matter into the air and cause elevated 

levels of PM10 above the Federal and State standards. Due to observed problems in 

Lamar with dirt, dust, and particulate, area monitoring of total suspended particle 

pollution was instituted at the Power Plant site in 1975. In June 1985, monitoring for 

PM10 began. A new site, the Municipal Complex, was selected in August, 1986. This 

site was considered to better meet the maximum siting criteria and more adequately 

reflect worse case population exposure. The Power Plant site was re-established in 

February 1992 and has since operated along with the Municipal Complex site on an 

everyday sampling schedule. 

Lamar's monitoring history shows that the annual PM 10 standard of 50 μg/m3 averaged 

over an annual period has never been exceeded. The Lamar area has however 

experienced exceedances of the 24-hour PM 10 standard of 150 μg/m3 since 1985. The 

associated weather conditions on each of the exceedance days conform to a repeated 

pattern of regional high winds and blowing dust. In each case an intense, fast-moving, 

surface low-pressure system tracked through eastern Colorado. Typically these 

systems had surface lows that were not collocated with a closed upper low or nearly 

closed upper level trough. This distinction is important because the collocated or 

vertically "coupled" systems usually bring significant up slope snow or rain to the region . 

The intensity of the lows associated with the PM 10 exceedances is evident in the 

average central pressure of 990 mb (corrected to sea level). This value is typical of a 

deep, well-organized system. Such well-organized systems usually generate high winds 

in the vicinity of the low center. 

The past exceedances of the PM10 NAAQS classified Lamar as a moderate 

nonattainment area for PM10. In response to this designation, Lamar with the 

assistance of the State prepared the Lamar PM 10 Non-Attainment Plan and the 

Redesignation Request and Maintenance Plan. The Lamar PM10 Maintenance Plan 

was submitted to EPA in 2002 and was approved on October 25, 2005. According to 

EPA's 1996 Natural Events Policy, states may request that a moderate nonattainment 

area not be reclassified as serious if it can be demonstrated that the area would attain 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 41 Page 
the standards by the statutory attainment date but for emissions caused by natural 

events. 

In 2007, EPA promulgated the Exceptional Events Rule (EER) that supersedes the 

NEP, thus this plan update reflects the requirements of the EER but also retains the 

previous commitments approved under the Lamar PM10 Redesignation Request and 

associated Maintenance Plan. 

B. The Natural Events Policy 

(1) Background 

On May 30, 1996, EPA issued the Natural Events Policy in a memorandum from Mary 

D. Nichols, Assistant Administrator for Air and Radiation. In this memorandum EPA 

announced its new policy for protecting public health when the PM 10 NAAQS are 

violated due to natural events. Under this policy three categories of natural events are 

identified as affecting the PM10 NAAQS: (1) volcanic and seismic activity; (2) wildland 

fires; and, (3) high wind events. Only high wind events will be addressed in this NEAP. 

Based on EPA's natural events policy high winds are defined as uncontrollable natural 

events under the following conditions: (1) the dust originated from nonanthropogenic 

sources; or, (2) the dust originated from anthropogenic sources controlled with best 

available control measures (BACM). Furthermore, the conditions that create high wind 

events vary from area to area with soil type, precipitation, and the speed of wind gusts. 

Prior to EPA guidance on PM10 exceedances due to natural events, the Guideline on 

the Identification and Use of Air Quality Data Affected by Exceptional Events and 

Appendix K to 40 CFR, Part 50, were issued by EPA to address situations where 

natural sources strongly influence an area's air quality. Similar to EPA's natural events 

policy, Appendix K provides, in part, that measured exceedances of the PM10 NAAQS 

may be discounted from decisions regarding nonattainment area status if the data are 

shown to be influenced by uncontrollable events caused by natural sources of 

particulate matter. Then in 1990, the Clean Air Act Amendments added section 188(f) 

that provides EPA with discretionary statutory authority to waive either a specific 

attainment date or certain planning requirements for serious PM10 nonattainment areas 

that are significantly impacted by nonanthropogenic sources. 

According to EPA's Natural Events Policy the section 188(f) waiver provision, Appendix 

K, and the Exceptional Events Guidance are to be considered revised by the 

requirements of the May 30, 1996 NEP. Additional justification of the revisions can be 

found in the Appendix of EPA's natural events policy. 

(2) NEP Content Elements 

Consistent with the original NEP, EPA will potentially consider exceedances of the 

NAAQS as a "natural event" if a Natural Events Action Plan is developed and 

implemented to address future events. The following is a summary of the specific EPA 

guidance regarding development of a NEAP: 

Element 1: Analysis and documentation of the event should show a clear causal 

relationship between the measured exceedance and the natural event. The type 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 51 Page 
and amount of documentation provided should be sufficient to demonstrate that the 

natural event occurred, and that it impacted a particular monitoring site in such a 

way as to cause the PM10 concentrations measured. 

Element 2: Establish education programs. Such programs may be designed to 

educate the public about the short-term and long-term harmful effects that high 

concentrations of PM10 could have on their health and inform them that: (a) certain 

types of natural events affect the air quality of the area periodically, (b) a natural 

event is imminent, and (c) specific actions are being taken to minimize the health 

impacts of events. 

Element 3: Minimize public exposure to high concentrations of PM10 through a 

public notification and health advisory program. Programs to minimize public 

exposure should (a) identify the people most at risk, (b) notify the at-risk population 

that a natural event is imminent or currently taking place (c) suggest actions to be 

taken by the public to minimize their exposure to high concentrations of PM10, and 

(d) suggest precautions to take if exposure cannot be avoided. 

Element 4: Abate or minimize appropriate contributing controllable sources of 

PM10. Programs to minimize PM10 emissions for high winds may include: the 

application of BACM to any sources of soil that have been disturbed by 

anthropogenic activities. The BACM application criteria require analysis of the 

technological and economic feasibility of individual control measures on a case-bycase basis. The NEAP should include analyses of BACM for contributing sources. If 

BA CM are not defined for the anthropogenic sources in question, step 5 listed below 

is required. 

Element 5: Identify, study, and implement practical mitigating measures as 

necessary. The NEAP may include commitments to conduct pilot tests of new 

emission reduction techniques. For example, it may be desirable to test the 

feasibility and effectiveness of new strategies for minimizing sources of windblown 

dust through pilot programs. The plan must include a timely schedule for conducting 

such studies and implementing measures that are technologically and economically 

feasible. 

Element 6: Periodically reevaluate: (a) the conditions causing violations of a PM10 

NAAQS in the area, (b) the status of implementation of the NEAP, and (c) the 

adequacy of the actions being implemented. The State should reevaluate the NEAP 

for an area every 5 years at a minimum and make appropriate changes to the plan. 

Element 7: The NEAP should be developed by the State in conjunction with the 

stakeholders affected by the plan. 

Element 8: The NEAP should be made available for public review and comment and 

may, but is not required, to be adopted as a revision to the State Implementation 

Plan (SIP) if current SIP rules are not revised. 

Element 9: The NEAP should be submitted to the EPA for review and comment. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 61 Page 
The following describes the Lamar NEAP and its conformance with the original EPA 

guidance on natural events, which was used to develop the original Lamar NEAP: 

Ill. NATURAL EVENTS ACTION PLAN 

Element 1: Documentation & Analysis 

According to the Natural Events Policy, "the conditions that create high wind events 

vary from area to area with soil type, precipitation and the speed of wind gusts." Thus, 

states are to determine the conditions that define high winds in an area. Making a 

precise determination, however, is a complex task that requires detailed information on 

soil moisture, daily wind speeds, temperature, and a number of other variables that are 

not readily available at this time. Historically, the Division has used, in the absence of 

Lamar specific studies, the definition of high winds specified in the Guideline on the 

Identification and Use of Air Quality Data Affected by Exceptional Events. Based on 

this guidance, high winds are defined as: "An hourly wind speed of greater than or 

equal to 30 mph or gusts equal to or greater than 40 mph, with no precipitation or only a 

trace of precipitation." However, EPA recently proposed Draft Guidance on the 

Preparation of Demonstrations in Support of Requests to Exclude Ambient Air Quality 

Data Affected by High Winds under the Exceptional Events Rule (June 2012) that 

suggests that EPA will accept a threshold of sustained wind of 25 mph for areas in the 

west provided the agencies support this as the level at which they expect stable 

surfaces (i.e., controlled anthropogenic and undisturbed natural surfaces) to be 

overwhelmed.

8 Nevertheless, since this new EPA guidance is not finalized , the Division 

may need to rely on earlier EPA guidelines. 

Since the last update to the Lamar NEAP in 2003, the EPA promulgated in 2007 an 

Exceptional Event Rule (EER) which establishes a process for the treatment of data 

influenced by exceptional events. The EER is based on amendments to Section 319 of 

the Clean Air Act which defines an exceptional event as an event that: (i) affects air 

quality; (ii) not reasonably controllable; (iii) is caused by human activity not likely to 

recur at a particular location, is a natural event; (iv) and is determined by EPA through 

the process established in regulation to be an exceptional event. The EER provisions 

require that states address the following six elements in a request for data exclusion: 

• The event affects air quality 

• The event was not reasonably controllable or preventable 

• The event was caused by human activity that is unlikely to recur at a particular 

location, or was a natural event 

• There exists a clear causal relationship between the specific event and the 

monitored concentration; 

8 See page 16, Section 3.1.4 - Consideration of Wind Speed, EPA Draft for Public Comment of 

Draft Guidance on the Preparation of Demonstrations in Support of Requests to Exclude 

Ambient Air Quality Data Affected by High Winds under the Exceptional Events Rule (6/2012) 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 71 Page 
• The event is associated with a measured concentration in excess of the normal 

historical fluctuations including background 

• There would have been no exceedance or violation but for the event 

Unlike the original EPA Natural Events Policy, the 2007 Exceptional Events Rule does 

not require the development of a Natural Events Action Plan (see 72 FR 13576). 

Nevertheless, since the Lamar NEAP is an element of the EPA approved Lamar PM 10 

Maintenance Plan; the NEAP must remain in place and be updated no less than every 

five years - as specified in the original plan. 

Moreover, the Lamar NEAP has assisted the area in addressing blowing dust due to 

uncontrollable winds and is designed to protect public health, educate the public about 

high wind events and blowing dust; mitigate health impacts on the community during 

future events; and, identify and implement Best Available Control Measures (BACM) for 

anthropogenic sources of windblown dust. 

The below table lists eighteen (18) PM10 events identified as exceedances of the 

primary 24-hour PM10 NAAQS that were recorded at the Lamar Power Plant and 

Municipal Complex for the eleven year period (2001 - 2011 ). The PM10 exceedances 

were recorded on days with unusually high wind speeds and are flagged as high wind 

events, except for four events; one in 2001 and two in 2009 that were inadvertently not 

flagged before the regulatory deadline but are associated with high winds and another 

in 2009 was flagged as a high wind event but no demonstration was submitted before 

the regulatory deadline. 

Table 1: Lamar Area PM10 Exceedances (2001-2011) 

Event Monitor Site PM10 Value Data Flag EPA Review/Filing Status Date [μg/m3] 

04/11/01 Power Plant 152 none Event not flagged 

02109102 Power Plant 246 High Wind EPA Concurrence on Flag 

03/07/02 Power Plant 246 High Wind EPA Concurrence on Flag 

05/21/02 Power Plant 196 High Wind EPA Concurrence on Flag 

05/21/02 Municipal -183 High Wind EPA Concurrence on Flag 

06120102 Power Plant 181 High Wind EPA Concurrence on Flag 

06120102 Municipal . 162 High Wind EPA Concurrence on Flag 

04/05/05 Power Plant 203 High Wind EPA Concurrence on Flag 

04/05/05 Municipal 164 High Wind EPA Concurrence on Flag 

05/02/08 Power Plant 367 High Wind Under EPA Consideration 

05/22/08 Power Plant 227 High Wind Under EPA Consideration 

01/19/09 Power Plant 174 High Wind Under EPA Consideration 

01/19/09 Municipal 173 High Wind Under EPA Consideration 

02106109 Power Plant 233 none Event not flaaaed 

03/05/09 Municipal 176 High Wind Flaaaed - Not submitted 

03/26/09 Power Plant 171 none Event not flagged 

04/03/11 Power Plant 169 High Wind Prelim Analysis 

11/05/11 Power Plant 192 High Wind Prelim Analysis 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado Bl Page 
The Division, after an extensive meteorological analysis of each event, has confirmed 

that all of the above listed PM10 events are due to blowing dust associated with high 

winds, which caused exceedances of the 24-hr PM10 NAAQS that otherwise would not 

have occurred "but for" the event. 

Consistent with the original EPA Natural Events Policy and as required by 2007 

Exceptional Events Rule, each exceedance that is associated with high winds is flagged 

by the Division's Technical Services Program in the AIRS system. All supporting 

analysis and documentation of each high wind event is submitted to EPA Region VIII 

after public review and/or comment. According to EPA guidance, the type and amount 

of documentation provided for each event should be sufficient to demonstrate that the 

natural event occurred, and that it impacted a particular monitoring site in such a way 

as to cause the PM10 concentrations measured. 

In the below Figure 2, the daily PM10 concentrations for the past eleven (11) years are 

compiled for the Power Plant monitor. The values above the 24-hour PM10 NAAQS 

are tagged with notes indicating the regulatory status of the exceptional events, which 

are all associated with high winds. 

Figure 2: Power Plant PM10 Concentrations Over 11 Years 

Lamar Power Plant Monitor 

Daily PM10 Concentrations 2001-2011 

Hi:f'i Wind Fl11 

367 u&/ml 

05/ 02/ 0I 350 +--------------------------------

';;j' 300 

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02/ 09/ 0l 

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03/ 07 / 0l EPA Appronl Hl&h Wind Aoe • 2H u&/ml 

203 u&Jml 227 •&/ml + 02/06/'1J Hi&fl Wind Roe 

EPAApprovol 04/05/'15 05/ 22/ 118 1'2 u&/ml 

196u&/m3 ~-------------------~--------, Hflli}ll 

05/ 21/ 0l 

EPA Approv~ Hie!> Wind Aoc 

111 uJ/ml 174 u&/ml + + ~~-::.::: + 

~ 

HW~R. __ .;, 02-------....Wl:iiiiiaJiii!di§l.-- ,_'1J __ .::o:;J/ 2::6'.:'1J __ " i

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Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 91 P age 
In the below Figure 3, the daily PM10 concentrations for the past eleven (11) years are 

compiled for the Municipal Complex monitor. The values above the 24-hour PM10 

NAAQS are tagged with notes indicating the regulatory status of the exceptional events, 

which are all associated with high winds. 

Figure 3: Municipal Complex PM10 Concentrations Over 11 Years 

200 

EPAApprov• 

1UuJ/m3 

OS/ 21/ 02 • 

EPAApprov• 

1UuJ/m3 

06/ 20/ 02 

;;;- 150 

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s 

.... 

Q 

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Lamar Municipal Complex Monitor 

Daily PM10 Concentrations 2001-2011 

• 

. . . ... . 

. 

:g :g :g ...... ::::- ...... .... 

0 0 0 ...... ...... ...... .... "' "' 0 0 0 

EPA Approval 

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04/ 0S__ / OS ,. 

.... 

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The foregoing data analysis, in conjunction with previously provided technical 

documentation, fulfills the documentation and analysis requirements of Element #1 of 

the Natural Events Policy as described on page 5 of the NEAP. 

Element 2: Public Education Programs 

The purpose of this program is to inform and educate the public about the problem. 

The Division has worked closely with the City of Lamar, Prowers County 

Commissioners, local media, and interested community groups to educate the public 

about the problems associated with elevated levels of PM10 in the Lamar area. Over 

the years numerous meetings have taken place with the City and County governments 

to discuss these issues and to develop a plan to address future high wind events in 

Lamar. Elements of the program include: informing the public when air quality in the 

area is unhealthy; explaining what the public can expect when high wind events occur; 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 10 I P age 
what steps will be taken to control dust emissions during future high wind events; and, 

how to minimize their exposure to high concentrations of PM10 during high wind 

conditions. The public notification and education programs have included but are not 

limited to: 

• An informational and health-related brochure has been and will continue to be 

distributed by the local governments, the. Prowers County Health Nurses, the 

Prowers County conservation and agricultural extension agencies to sensitive 

populations (elderly and local school districts) as well as the general public. 

Distribution of the Blowing Dust Health Advisory Brochure began in January 

1998 (see Appendix C). In the revised (2003) NEAP the Division also committed 

to develop a Spanish language brochure for the non-English speaking 

community. 

• Back in 2002, an Air Quality Task Force was established in the community, 

which included local health department personnel, staff from city and county, the 

business community, a public health nurse representative, and the Division itself. 

The charge before the task force is to identify any unresolved air quality issues, 

ensure area exceedances are minimized, and work to ensure the community is 

aware of ongoing air quality issues and efforts to minimize impacts. The 2002 

Task Force activities were not part of the original 1998 NEAP but demonstrate 

the additional efforts by the local agencies and the Division to improve area air 

quality. 

• During the period 2005 to 2011 , the Division coordinated the issuance of blowing 

dust advisories with Prowers County Department of Public Health and 

Environment. The Division would contact Prowers County staff when a blowing 

dust advisory was first issued, which is based on meteorological forecasts 

prepared by the Technical Services Program. Upon notification, Prowers County 

would issue a local public health advisory. 

• Since late 2011 , the Division has assumed the lead role for issuing blowing dust 

advisories statewide throughout the year. Based on meteorologist forecasts, the 

Division issues blowing dust advisories that are posted to the Colorado Air 

Quality Summary webpage and sent to members of the public on a list serve. 

• Since 2002, over twelve (12) blowing dust advisories have been issued to ensure 

minimization of the public's exposure elevated concentrations of PM10. 

This section fulfills the Element 2 requirement of the Natural Events Policy as described 

on page 6 of the NEAP. 

Element 3: Minimize Public Exposure to High PM10 

The Blowing Dust Health Advisory Program notifies the public to the possibility that a 

high wind event is imminent or currently taking place, and includes an advisory 

suggesting what actions can be taken to minimize exposure to high concentrations of 

particulate matter. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 111 Page 
Originally, blowing dust advisories were issued by the Lamar area Environmental Health 

Southeastern offices with forecasting assistance provided by the Division and the 

National Weather Service. This forecasting methodology was approved as part of the 

1998 NEAP submittal. 

Since late 2011 , the Division Technical Services Program has assumed the 

responsibility for issuing blowing dust advisories throughout the year for all areas of the 

state. For the Lamar region , a meteorologist evaluates the potential for blowing dust 

and prepares a daily forecast. These forecasts are based on a full meteorological 

forecast for the current and subsequent days, an assessment of statewide and regional 

soil moisture conditions, an evaluation of a variety of satellite data products, evaluation 

of surface weather observations, review of output from two models that forecast blowing 

dust in the United States, and an assessment of any blowing dust or wind advisory 

forecasts issued by National Weather Service Forecast offices in Colorado, Utah, New 

Mexico, and Arizona. 

The meteorological forecast includes a review of wind (the potential for sustained winds 

of 30 mph or higher or gusts of 40 mph or higher), stability, and precipitation forecast 

products from the National Centers for Environmental Prediction (NCEP) NAM12 

meteorological model and the National Weather Service Graphical Forecast products: 

http://mag.ncep.noaa.gov/NCOMAGWEB/appcontroller?prevpage=index&MainPage=index&cat 

=MODEL +GUIDANCE&page=MODEL +GUIDANCE 

http:/ lg ra ph ical. weather. gov/sectors/centrockies. php#tabs 

Soil moisture conditions are determined by checking the NCEP soil moisture product 

pages or the recent 30-day total precipitation maps from the High Plains Regional 

Climate Center: 

http://www.cpc.ncep.noaa.gov/products/Soilmst Monitoring/US/Soilmst/Soilmst.shtml 

http://www. hp rec. un I. ed u/maps/current/i ndex. php ?action=u pd ate datera nge&daterange=30d 

In general widespread , anomalously dry conditions and/or 30-day precipitation totals of 

0.5 inches or less are a good indicator for the potential for blowing dust. 

Visible satellite imagery and satellite aerosol optical depth (AOD) products are 

evaluated for evidence of blowing dust upwind of the forecast area or developing in the 

area itself. A variety of such products are used, but they include NASA MODIS Tera 

and Aqua images and GOES Aerosol and Smoke Product (GASP) AOD imagery: 

http://ge.ssec.wisc.edu/modis-today/ 

http://www.ssd.noaa.gov/PS/FIRE/GASP/gasp.html 

Surface weather observations are checked for reports of winds of 30 mph or higher, 

gusts of 40 mph or higher, and visibility restrictions, blowing dust or haze. 

Blowing dust products from the Navy Aerosol Analysis and Prediction Model or NAAPS 

are examined to look for the potential for local or transported dust during the next one 

to three days. The National Weather Service Air Quality Forecast Guidance System 

includes output from a blowing dust forecast model. Forecasters use the following 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 121 Page 
output maps from this model to assess blowing dust potential for the next one to three 

days: 

http://www.nrlmrv.navy.mil/aerosol/ 

http://airquality.weather.gov/ 

Finally, the forecaster reviews zone forecast products and forecast discussions from the 

relevant National Weather Service Forecast offices to see if they are calling for high 

winds and/or blowing dust. The Division forecaster weighs the information from each of 

these sources in the context of his or her experience and determines a final forecast. If 

the foregoing analysis indicates blowing dust, the forecaster will issue a blowing dust 

advisory that is posted to the "Colorado Air Quality Summary" webpage at the following 

link: 

http://www.colorado.gov/airqualitv/colorado summarv.aspx 

The below Figure 4 provides a screen view of the Colorado Air Quality Summary 

webpage. If a blowing dust advisory is issued for the Lamar area, the "Air Quality 

Advisories" portion of the webpage would display an advisory under the "Other Areas" 

section (circle in red). 

Figure 4: Colorado Air Quality Summary Webpage 

Colorado Department 

of Public Health 

and Environment 

Au Pollubon Conlfol OJV1s1on 

T ~ Servrces Home 

All Colorado <Msortes 

Front Ran9e.10enver <Msolie.s 

i.lr Quallt/ Toda, 

Colo<ado -'llr Quaht, Summari 

About Us 

lnlto to Reporting Systems 

AJr Quall IAap View 

AJr Qualtt Report ew 

OpenBuming 

Smo~e r.tanaoement Pro m 

Teclmlcal Reports 

Permrt Modeling 

Emissions Inventor; 

Wlldftre Information 

Technical S.f\ices Contads 

Qtjck Unks » 

National Standards (N'AOS) 

AJr Qua! Index ( QI) 

L.t.e Image of Oen;er 

Networl Plan Neiv! 

Ozone Summar, Table 

Related L.Jn~s 

ColorHo Air Qualty Summ•ry 

About th• Air Quality Index (AQI) 

Today's Air Quality Summary d•tail•d) 

Air Quality Advisories 

Front Range: 

The Colorado Departmenl of Public Health and Environment and the Regional Al' 

Quality council have Issued an OZONE ACTION DAY ALERT at .\ p m on 

Wedn Front Range UrtJan (cllck for more ... ) 

Denvers current vlslllillty 

Fl COiiins' current visibility 

(VSI i• u lc:u lete<! b• twe.• n 12PM •nd 4PM local tim e ) 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 

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131 Page 
The blowing dust advisory is also sent to a winter air quality list serve, which emails the 

advisory to all registered recipients. Figure 5 provides an example blowing dust 

advisory that specifies the duration of the advisory along with exposure 

recommendations for sensitive populations. 

Figure 5: Example Blowing Dust Air Quality List Serve Email 

• • ;: [Winterairquality.denvermetro] Blowing Oust Adllisory Northwest Colorado • Messa_ - ~ x 

x }\\ Fmd 

Ddde Move to Cre1te Other Block 

folder • Rult Actions • Sender 

k C1tegcnze Folow M1rtc as 

• Up • Unre1d Select • 

'""' Frora: "*1. tcr•~ty. dem-ermeiro:tttseve aim Stnt. Tut 6'5!20123:06 PM 

To: Mite"atOOlilty.denveintO'oeistserw.com 

Cc 

SWJt ct tyfinur1ifq1Hllty.dtl1ftnnttroj l!lloW1r1 g Oust Ac:Msol)' Northwest Colorado 

The Colorado D~anmmt of Public Health and En\Uonmmt has issued a Blowing Dust Ad\iso1y for nonhwestan Colorado 

Cities in the Blowing Dust Advisory include, but are not limited to, Rangay, Craig, Meeker, and Grand Junction 

Valid: Tuesday June 5, 10 11, 3 PM to Midnight 

In areas whtte blO\\ing dust has reduced visibilities to less than 10 miles, people \.,,-ith bean or lung disease, ld~ adults, and the 

H~ry young should rcdu~ prolonged or hca\·y indoor or outdoor amion 

Strong gusty winds arc expected to de\·clop across Wcstan Colorado, Utah, and Nonhea.st Arizona These winds \ \ill create 

periods \\;th bl o~ing dust. The ruong winds \vill transport the dust long disunces u.using potential bel.lth issues in portions of 

Colorado including areas that do not have local blowing dust 

For the latest statewide condition.s, foreca.su, and ad\isorics, \isit: 

http: w·ww.colondo.gov a.i.rgualitv colorado summan·.aspx 

Social Medii and Air Quality Notification: 

http tvww.facebook.com cdpheaocd 

bnp· miner.com=' cdphca.ocd 

bnp www.cnviroflasb.info signup.c:fm 

The Division is committed to continually investigating blowing dust issues and improving 

the blowing dust advisory process to ensure timely notification in order to minimize 

public exposure. The website air quality summary and list serve notification are new 

activities that were not part of the original 1998 NEAP or the revised 2003 NEAP and 

demonstrate additional efforts by the Division. 

This section fulfills the Element 3 requirement of the Natural Events Policy as described 

on page 6 of the NEAP. 

Element 4: Abate or Minimize Contributing Sources (BACM) and Element 5: Identify, 

Study and Implement Practical Control Measures 

1. Best Available Control Measures (BACM) Determination 

According to the NEP, BACM must be implemented for anthropogenic sources 

contributing to NAAQS exceedances in moderate PM 10 nonattainment areas. BACM 

for PM10 is defined (see 59 FR 42010 -August 16, 1994) as techniques that achieve 

the maximum degree of emissions reduction from a source as determined on a caseby-case basis considering technological and economic feasibility. Through a series of 

meetings beginning in 1997 between the Division and Lamar officials representing the 

City of Lamar, Prowers County Commissioners, local farmers , a county health 

specialist, the local media, the Natural Resources Conservation Service, the county 

extension office, and concerned citizens, issues were discussed surrounding the NEAP 

and its efforts. Specifically covered were issues of the meteorological data, monitoring 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 141 Page 
data, potential contributing sources to the high wind events, and potential candidate 

BACM. The community meetings, coupled with the analyses of the supporting 

documentation, identified two distinct set of circumstances that lead to Lamar's high 

wind exceedances of the PM10 NAAQS: 

• High concentrations of PM10 caused by a mixture of anthropogenic and nonanthropogenic sources coming largely from outside the nonattainment area 

under high wind conditions - from about the 270 degree to 360 degree wind 

directions (west, northwest, and north directions); and, 

• Prolonged climatic conditions of low precipitation over an extended period of time 

that act to dry area soils making them more susceptible to airborne activity under 

high wind conditions. 

The meetings also identified potential BACM candidates including the Burlington 

Northern Santa Fe rail line, agricultural lands, other open areas, limited construction 

activity (which has been since completed), the city landfill, and area gravel pit. Specific 

documentation for these candidate BACM can be found in the original 1998 NEAP. 

BACM Options Considered: 

To determine the most appropriate and viable control measures for the community, 

both a review of the area emission inventory and consideration of all BACM was 

undertaken. Note that numerous other BACM options have been considered for the 

revised (2003) NEAP that were not part of the original (1998) NEAP. 

Based on the contributing source analysis and in review with community stakeholders, 

the following BACM options were considered as possible PM 10 control measures for 

the community: 

(a) Street Sweeping Activities - Community Street sweeping programs have 

demonstrated effectiveness in other communities. Such activities were considered 

as a local control measure. Expanding the current street sweeping program and 

purchasing additional, more effective equipment were also reviewed. 

(b) Construction/Demolition Activity - local ordinances to control emissions from 

construction and demolition sites have been implemented in other parts of the 

state with good success. Also, several work practice could be applied to reduce 

emissions from the site including watering, a track out policy, and an area lane:! use 

plan. Based on the contributing source analysis, this option was discussed with 

the City of Lamar and Prowers County officials as part of the 1998 NEAP as well. 

(c) Wind Erosion of Open Areas - several practices were reviewed regarding the wind 

erosion of open areas, including both local and regional efforts. 

Recommendations under consideration included sodding of local parks, tree 

breaks planted at the area transfer station, gravel/chips along railroad corridor, 

and chemical stabilization applied by the city along the railroad corridor in a twoblock area. Based on the contributing source analysis, this option was discussed 

with the City of Lamar and Prowers County officials as part of the 1998 NEAP as 

well. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 151 Page 
(d) Control of Stationary Source Emissions - as identified elsewhere in this NEAP, a 

review of stationary sources and their relative contribution to overall PM 

concentrations was completed. It was determined that few PM10 sources exist in 

the area, appearing to contribute a very small amount of particulate matter to the 

overall inventory. 

(e) Road Stabilization - In a effort to better understand the effects of road stabilization, 

several options were reviewed including the use of chemical stabilizers and water 

as a stabilizing measure. Also, periodic assessments to determine if traffic levels 

on unpaved roads surpass Colorado Regulation No. 1 limits were considered. If 

daily traffic counts exceed 200 trips per day on unpaved roads, state regulations 

apply that reduce PM10 emissions from those roads. Specifically, a periodic 

assessment of traffic levels on unpaved roads within the city limits and within one 

mile of the city limits were considered. State regulation calls for a road traffic 

count and dust control plan for roads that exceed the 200 trips threshold. In 

addition, Lamar currently suggests that drivers maintain their vehicles at a slow 

speed on unpaved roads and other dirt surfaces to reduce dust emissions. This 

information is disseminated throughout the community. 

(f) Woodburning Curtailment Programs - the possibility of instituting a citywide 

curtailment program was reviewed and considered. This has been a consideration 

for the community and includes discouraging wood burning on high wind days. 

(g) Open Burning - The usefulness of imposing and maintaining an open burning 

curtailment program during high wind events was reviewed. Current state air 

pollution control laws and regulations provide some guidance on the effort. 

(h) Avoidance of Dust Producing Equipment - The effectiveness of avoiding the use of 

dust producing equipment has also been considered. Currently Lamar discourages 

the use of dust-producing equipment (e.g., leaf blowers) in an effort to reduce 

PM10 emissions and does so through public education and outreach efforts. 

(i) Reducing or Postponing Tilling and Plowing or Other Agricultural Practices that 

Contribute to PM 10 Emissions - It is well recognized that dust-producing activities 

such as tilling, plowing, and other agricu~tural practices increase the amount of 

PM10 released . As such, these control measures were discussed as part of the 

effort to reduce PM10 impacts on Lamar. Review of existing and potentially future 

control practices were considered at the local, regional, state, and federal (e.g. , 

Natural Resources Conservation Service) level. 

U) Wind Break - Various trees are found throughout Lamar. However, the placement 

of one row of barrier trees (e.g., Russian Olives) would block potential contributing 

sources. The Russian Olive is a quick growing large shrub/small tree that will do 

well given the windy climate of Lamar. According to section 3.5.2.1 of EPA 

guidance entitled Fugitive Dust Background Document and Technical Information 

Document for Best Available Control Measures, dated September 1992, one-row 

of trees is considered an effective windbreak. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 16 I P age 
(k) Vegetative Cover/Sod - Efforts elsewhere in the State have demonstrated the 

usefulness of using a vegetative cover at sites where dust is known to blow. 

Efforts to use this control measure were reviewed for applicability and 

effectiveness. 

(I) Railroad Corridor - Two categories of surface treatments were considered to 

control fugitive dust emissions lifted from the 400'-wide railroad corridor under dry, 

high wind conditions. This option was fully explored in the 1998 NEAP and details 

of this option can be found there. 

Lamar Stationary Sources Emission Inventory 

To ensure that significant changes in PM10 emissions from local stationary sources are 

not a significant contributing factor to area exceedances, an emission inventory was 

prepared and reviewed. In the Lamar PM10 Maintenance Area, the following Table 2 

indicates that stationary sources comprise about 13.7 percent of the total emission 

inventory of 1,359 pounds per day: 

Table 2: Lamar Area PM10 Emission Inventory- 2010 Actual Emissions 

Source 2010 PM10 Emissions 

[tpyJ flbs/davl 

Lamar Feed & Grain - White Stone Farms* 23.50 128.8 

Lamar Utility Board 15.88 87.0 

Front Range Aggregate - West Pit* 12.76 70.0 

Colorado Mills, LLC 12.30 67.4 

Carder - Hard Scrabble Pit 1.08 5.9 

All Rite Pavinq & Redi-Mix Inc.* 5.29 29.0 

Dragon ESP 5.06 27.7 

JB Five Rivers Cattle Feeding Co.* 0.83 4.6 

Carder 0.75 4.1 

Prowers County - Walker Pit North* 0.65 3.6 

Prowers County - Walker Pit South* 0.65 3.6 

All Rite Paving & Redi-Mix Inc.* 0.27 1.5 

Carder Inc. - J&S Pit* 0.04 0.2 

Southeastern Colorado Coop 0 0 

(Greater Lamar Area) Totals: 85.2 467.1 

(Lamar Maintenance Area Only) Totals: 34.0 186.3 

Bold denotes sources in Lamar PM 10 Maintenance Area 

*Denotes sources located outside of Lamar PM10 Maintenance Area 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 171 Page 
In the below Figure 4, a number of the stationary sources are indentified in the Lamar 

area along with the location of the Power Plant PM10 monitor. The other local 

stationary sources listed in the above table are located outside the portion of the map 

shown. The PM10 maintenance area is denoted by the bright green line. 

Figure 4: Map of Lamar Point Sources nearby the Power Plant Monitor 

BACM Options Discounted 

Several BACM options were discounted from consideration based on the 

meteorological analysis, onsite inspection and discussion with area residents and local 

government officials. A complete discussion of these previous efforts can be found in 

the 1998 NEAP. 

For this revised Plan, the community remains committed to meeting BACM in all 

instances, where feasible. For example, the ongoing regional drought significantly 

impacts the amount of water available as a control measure (e.g. , watering of area 

roads to reduce PM10). Accordingly water restrictions (and related economic impacts 

of the drought) will likely dictate the practicality of this control measure. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 181 Page 
IV. STAKEHOLDER AGREEMENTS 

The City of Lamar and Prowers County have identified contributing sources for 

developing BACM as required by NEP. The following descriptions include BACM that 

has either already been put into place or will be phased in as economically and 

technically feasible. 

City of Lamar 

The City of Lamar has been very active in addressing potential PM10 sources within the 

Lamar area through efforts such as sodding baseball fields , implementing and 

enhancing a street sweeping program, and chip-seal paving of many unpaved roads. In 

addition to these type of control measures already taken by the City, the Public Works 

Department implemented the following BACM within the area: 

1. Wind Break 

Beginning in the Spring of 1997, a wind break of trees was planted north of the Power 

Plant monitoring site. The Russian Olive tree wind break is located approximately one 

half mile north of the Power Plant monitoring site and will block potential contributing 

sources such as the Lamar Transfer Station and other unpaved equipment traffic areas 

to the north. The Russian Olive is a quick growing large shrub/small tree will do well 

given the semi-arid and windy climate of Lamar. According to section 3.5.2.1 of EPA 

guidance entitled "Fugitive Dust Background Document and Technical Information 

Document for Best Available Control Measures", dated September 1992, one-row of 

trees is considered an effective windbreak. In addition to this commitment, more recent 

efforts include: the installation of a drip irrigation system to irrigate these tree groves. 

2. Landfill Shutdown 

The East Lamar Landfill is located approximately six (6) miles east of the city limit. 

According to section 3.5.1 of the "Operations and Closure Plan for the East Lamar 

Landfill", the Director of the Public Works Department and/or the landfill operator is 

required to do the following litter control measures under high wind conditions: 

• Soil cover is required to be placed on the working face of the landfill daily during 

periods of wind in excess of 30 mph; and , 

• The landfill must be closed down when sustained winds reach 35 mph or greater. 

An on-site wind gauge is used to monitor wind speeds at the landfill. Operators have 

radios in their equipment connecting them with the main office so that when the 

decision to close the landfill is made, it can take place immediately. According to the 

previous Director of Public Works, landfill operators have been directed to close the 

landfill at their discretion. Because paper begins to lift and blow into the debris fences 

at wind speeds of 25 to 30 mph, the operator usually closes the landfill prior to wind 

speeds reaching 30 mph. The City of Lamar has agreed to make the closure of the 

Lamar landfill mandatory when wind speeds reach 30 mph. This also reduces 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 191 Page 
windblown dust from the landfill as earth moving activities are reduced or eliminated 

during periods of shut down. 

In addition to this commitment, more recent efforts include: the placement of chain link 

fencing and various debris fences in place of the previous litter entrapment cage. This 

effort is to better minimize the release of materials during high wind conditions. 

3. Vegetative Cover/Sod 

The Lamar Recreation Department installed 100,000 square feet of sod at a 

recreational open space called Escondido Park. Escondido Park is located in northwest 

Lamar at 11th and Logan Streets. A sprinkler system has also been installed by the 

Parks and Recreation Department. The sod provides a vegetative cover for the open 

area. This dense, complete cover provides an effective control against windblown soil 

from the open area of the park. 

In addition to the commitment above, more recent efforts include: the commitment by 

the Lamar Public Works Department to stabilize the entrance road leading to and from 

Escondido Park to reduce track out onto city streets and minimize additional releases of 

PM10. 

4. Additional Public Works Projects 

In addition to the PM10 control efforts of the original NEAP, new Public Works projects 

to further reduce emissions of PM10 include: 

• The recent purchase of a TYMCO regenerative air street sweeper which is much 

more effective in reducing dust during street sweeping activities. The use of this 

sweeper allows for improved cleaning of the streets (e.g., sweeps the gutter and 

street); 

• The fencing of an area around the City Shop to reduce vehicle traffic that may be 

responsible for lifting dust off of the dirt area between the railroad tracks and the 

Shop; 

• The stabilization of a large dirt and mud hole on the north side of the City Shop. 

This project is credited with keeping mud from being tracked out into the street 

and becoming airborne by vehicular traffic; 

• The ongoing commitment to search for other stabilization projects that benefit 

the community and improve area air quality, and; 

• The relocation of the Municipal Tree Dump (formerly located in the northeastern 

corner of the city) to approximately six miles east of the city (now housed at the 

Municipal Landfill). This relocation eliminates a major source of smoke from 

agricultural burns that may have previously affected the community. 

Burlington-Northern/Santa Fe Rail Line 

The rail line running east-west of the Power Plant monitoring site was deemed to be an 

important PM10 source during conditions of high winds and low precipitation. Vehicle 

traffic which damages vegetation and break up the hard soil surfaces, highwinds, and 

passing trains re-entrains the dust into the air. This area is particularly problematic in 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 20 I P age 
the two block area immediately west of the Power Plant monitoring site. Control of this 

open area requires a close working agreement between the Burlington-Northern/Santa 

Fe Railroad Company (BNSF), the Division, and the City of Lamar Public Works 

Department. The purpose of this BACM is to reduce the amount of particulate matter 

susceptible to wind erosion under high wind conditions and general re-entrainment of 

dust in the ambient air as a result of local train traffic passing in close proximity of the 

PM10 monitor. 

In September 1997, the City chemically stabilized exposed lands north of the rail line 

between Fourth and Second Street where there was evidence of vehicle traffic. All 

other lands on either side of the rail road tracks between Main Street (Fifth) and Second 

Street and extending westward have either natural, undisturbed ground cover or it is 

used for commercial/recreation purposes that do not allow for significant re-entrainment 

(BNSF is responsible for maintaining 50 feet of property on either side of the main 

track). Most of these lands are leased by the City. After September 1997 the City 

negotiated the lease of these lands. Once acquired, a long term plan, will be developed 

for these lands such as restricting vehicle access, permanently stabilizing lands with 

vegetation and gravel, increasing park and recreational use, and using the lands for city 

maintenance and storage activities. 

According to John Meldrum, Manager of Environmental Operations for BNSF, the 

railroad company owns the main rail line and 200 feet on either side of the track. Much 

of this property has been sold or leased under private contracts. At this time BNSF is 

responsible only for the main rail line and for 50 feet of property on either side of the 

main track. All property sold or under contract is not the responsibility of BNSF. As a 

result, BNSF has stabilized the railroad corridor 50 feet on either side of the main rail 

line. 

In May 1997, Burlington Northern Santa Fe placed chips (gravel) 50 feet on either side 

of the main track from Main Street to Second Street (three blocks) to control fugitive 

dust emissions from this section of the track. Graveling exposed surfaces not exposed 

to regular vehicle traffic is considered a permanent mitigation measure. Details of this 

arrangement can be found in the documentation under the 1998 submittal. 

USDA: Natural Resources Conservation Service (NRCS) 

1. Conservation Reserve Program (CRP) 

Prowers County is a predominately agricultural area that is made up of over one million 

acres of land area - 882,165 acres (or 84.6%) of which is land in farms . Of the farm 

land acreage, cropland accounts for over half of the total (467,650 acres). Water, and 

often the lack of it, coupled with the frequent high winds experienced during late fall and 

early spring can destroy crops, encourage pests, and damage soil surfaces lending 

them susceptible to wind erosion. Most of Prowers County cropland acreage is farmed 

using dryland practices (versus irrigated) and consists of soils classified as highlyerodible-land (HEL) by the Department of Agriculture. 

Recognizing the problems associated with erodible land and other environmentalsensitive cropland, the U.S. Department of Agriculture (USDA) included conservation 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 211 Page 
provisions in the Farm Bill. This legislation created the Conservation Reserve Program 

(CRP) to address these concerns through conservation practices aimed at reducing soil 

erosion and improving water quality and wildlife habitat. 

The CRP encourages farmers to enter into contracts with USDA to place erodible 

cropland and other environmentally-sensitive land into long-term conservation practices 

for 10-15 years. In exchange, landowners receive annual rental payments for the land 

and cost-share assistance for establishing those practices. 

The CRP has been highly successful in Prowers County by placing approximately 

146,000 acres of Prowers County cropland, or 28% of total cropland, under contract. 

Most of this land has been planted with a perennial grass cover to protect the soil and 

retain its moisture. Strong support of the program by Prowers County farmers continues 

as 38% of the counties HEL cropland has been offered for conservation practices. 

While the following initiatives are not meant to be enforceable, many efforts are 

underway that further reduce blowing dust and its impacts. These include: 

• The CRP has moved to include all available area lands into area contracts. 

These contracts are good through 2007. Success of the CRP initiatives is 

measured through ongoing monitoring of the contracts to ensure ample grass 

coverage to minimize blowing dust. 

• CRP sends out information several times per year through radio and the area 

newspaper to further reach farmers interested in topsoil protection. 

• In response to the significant Colorado drought the CRP is working with multiple 

parties in extensive annual planning efforts to limit blowing dust and its impacts. 

These planning efforts change year to year depending on the severity of the 

drought. 

These programs were in effect during the period addressed in the analysis in this 

attachment (2004-2009). The NRCS in Colorado has also worked through the CRP and 

other programs to bring erosion control practices to croplands throughout eastern 

Colorado. 

Beginning in September of 2009, however, 743,238 acres of the 2,412 ,238 acres of 

Colorado land under the CRP were to become eligible to come out of the CRP in the 

subsequent five-year period. Much of this land is in eastern and southeastern 

Colorado. Land released from the CRP has the potential to increase the amount of 

lands contributing to blowing dust in eastern Colorado. The NRCS, however, has 

identified a variety of alternatives and options to promote soil conservation on the lands 

that will be released from CRP contracts (http://www.co.nrcs.usda.gov/programs/CRP/crp.html). 

These include conservation easements, enrollment in the Continuous CRP (a subset of 

CRP), transition to grazing land, and managing land for wildlife. Returning the land to 

cropland is also an option, and the NRCS is encouraging conservation tillage for these 

lands. The Colorado office of the NRCS has a form letter that will be sent to those 

whose contracts will be expiring. It includes the following: 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 221 Page 
"Over the next five years, approximately two million acres of land contracted under the 

Conservation Reserve Program (CRP) will expire in Colorado. A significant portion of 

<<COUNTY NAME>> County land enrolled in CRP either expired last September, or will 

be expiring within the next few years. " 

"The current crop prices are causing many landowners to consider farming their CRP 

land by returning it to crop production. However, there are some valuable information 

and alternatives that must be considered prior to making this major decision ... " 

"While some fields may return to cropland, many acres of CRP are environmentally 

sensitive and not suited to annual crop production. By making the decision to return 

CRP land to cropland you will impact the local economy, landscape, and environment. It 

is important for you to consider several factors before deciding what to do when your 

CRP contract expires: soil productivity and limitations, past yields, commodity prices, 

production, conversion or renovation costs, and other required investments." 

"There are several options available to landowners who have expiring CRP contracts. 

These options include: re-enrolling eligible acres into Continuous CRP, returning land to 

a cropland rotation, utilizing and enhancing forage as pasture or hay/and, or managing 

the expired CRP for wildlife." 

"It is important for you to develop an NRCS approved conservation plan, particularly 

when considering converting expired CRP acres to cropland. It requires proper planning 

and good management. NRCS conservation plans provide an inventory and complete 

assessment of a landowner's resources, as well as recommendations for improving 

those resources, which if implemented can positively impact your bottom line." 

According to the NRCS brochure: (see http://www.co.nrcs.usda.gov/programs/CRP/CCRP 1.pdf) 

''The Continuous CRP program (CCRP), a subset of the Conservation Reserve Program, 

offers year round enrollment and increased incentives to keep these small sensitive 

areas in permanent cover. 

Practice Incentive Payment (PIP) - This is an additional incentive of 40% of eligible 

practice establishment costs. 

Signing Incentive Payment (SIP) - This is a one-time incentive payment for signing the 

Continuous CRP contract. 

Rental Incentive Payment - This is an additional incentive payment equal to the shown 

percentage of the CRP rental rate. All of the above incentives are in addition to the 

regular CRP rental payment. For more information on CCRP, contact your local USDA 

Service Center." 

Details on the incentive payments for various categories of land use conservation 

practices can be found in the NRCS brochure link above. Additional information on 

NRCS post-CRP programs is presented in Figures 5 - 7 below. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 231 Page 
Figure 5: NRCS Overview of Post-CRP Options in Colorado 

'°'NRCS Natural Resources Conservation Service 

Currently, there are 

2,412,238 Conservation Reserve Program (CRP) acres in 

Colorado. On September 30, 2009, 

7 43,238 acres are 

eligible to come out 

of CRP. 

Conversion to Grazing Land 

Requirements and Options 

-Develop a conservation plan that outlines grazing management and development needs. 

-Install identified conservation measures for proper grazing distribution. 

>If using Environmental Quality 

Incentives Program funds to install identified practices producer MUST WAIT UNTIL CRP 

CONTRACT EXPIRES. 

Post-CRP Options 

in Colorado 

State of Colorado Common Land UNI! and CRP Fields 

Conversion to Cropland 

Requirements and Options 

-Develop a conservation plan to maintain 

compliance and program eligibility. 

>Identified measure must be installed 

within the first year. 

>Must address Threatened and Endangered Species and Species of 

Concern. 

-Current policy allows some work to 

begin up to 6-months prior to expiration of contract. 

>May be able to locate and use -Will be a minimum of 12-months before inother funds to begin some work come begins. 

prior to contract expiration. 

-Conservation Easements. 

>Grassland Reserve Program 

(grazing land only). 

>Farm and Ranchland Protection Program (crop and grass 

lands). 

-Will again be subject to market and weather 

changes, both negative and positive. 

For further Information, contact your local conservation district, Natural Resources Conservation 

Service, or Farm Service Agency office. 

NRCS IS "" Equal Opportunity ProYlcMr and Employ.r 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 241 Page 
Figure 6: NRCS Information on Transition to Grazing Land 

USDA 

- NRCS 

Uni ed States Department of Agriculture 

Natural Resources Conservation Service 

Expiring CRP Option -

Transition to Grazingland 

USDA Nalnral ~CllH ~ Conservatioo Se:vice - Colorado Marchl009 

Between~ years 009 and ,_013, approximate I 2 million acres 

ofCRP contracts will expire tn Colorado_ This mas contract expiration~ the potential co impact soil era ion, wildlife habitat, 

water quality. furmincomes and rural economies_ However_ the 

USDA atural Resource!:. Con ervation Service provides teclmic.al assistance and financial incennves to producen. i)Dd landowners as they cho e to transit: on these landS to other uses. 

Inceutins for Grazing l\Ianagemeut 

Through its Enviromneutal Quality Inceunves Progra.i:n. the 

NRCS offer; technical and financial assistance for prodooers 

witli expirine CRP who want to transition that land management intc a grazing management system. The iRCS can provide financial assistance for installine necessary infrastructure 

suc:h as fences, livestock pipeline and The NR.CS also 

provides management incenti ·e payments for grazing lllllllagemeut, ' ·eed control and wildlife habitat management. 

p o ·a1 p teub a~"llli' ts t or CRP trans1 on to G ldZlll2 - l

1 and 

Practice ~mple Incentive Payment ffllf'ltllNa co&ts 

fOr Noflheasl C<*:lf'ildOI 

382-Fence $0.85/Foot 

516-Pipeline $1 .35f oot -

61 4-Watering Facililty $0.60-$'1 _35/gallon 

528-G ra~ng Management $'10/acre 

595-Pes-_ Management $10/acre 

645-Upland Wildlife Habitat Management $10-$15/acre 

!\""RCS Technical Assistance 

l\J"RCS Field Office staff Range Consen.-ationii.ts and WU.dlife Biologists ai-e available to offer 

technic.al advice on implementing or expanding a grazing ystem onto CRP grol.ltld. 

Foa· Iore Information 

To leam more about the e inc~tiv~. or for other options for expiring CRP, C'Olltact your local 

"l'.'iRCS Field Office. Log on to www.nrcs.usdagov to find your nearest office. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 251 Page 
Figure 7: NRCS Brochure on Post-CRP Options (pages 1 and 2) 

As a ConsetvatJOn Aes.t!rw 

Program (CRP) conuaa 

nears its end, Landowntf"S 

wMt b9 making decisions on 

wNt to do next With thtir 

land. 

Wore deciding what to do 

wMn a CRP contract expires. 

it k amporunt to comid41" 

sweral factors 1ndudmg soil 

productJVJty and limnations. 

past yiolds. mmmodrty 

~ productk>f\ COl'N@rSK>n 01 renovation costs, Mld 

other required irwestments.. 

The Natural Resources 

ConwrvatJOn Servt«P CNACS) 

encour~ &andownHs to 

vtSil their k>c.M NACS Mid 

otfia for mistance wllh 

devek>ping a c~henstve conwrvation p&an prior 

to milUng a deosion on 

expired CRP contracts. 

An NRCS~pprowd Consef"-

nnon p&an is crttbl and Is 

dewloped by6rst u.-. standing thl' resoul'CC' needs 

and a Sandowlll'f's dtsin!d 

land use goats. thin created bHad on sound, ~tific 

practlCO<. 

These- assusments help 

NACS technksains develop 

solutions that best match 

each landowMf's g<>1ls 

with the needs of the land. 

At tlwt very l.ast npired 

CRP contracts, whkh 

will be returned to crop 

ptoductk>n llffds to get an updated conservation 

ptan on file since many parcels art openting under outdated plans. 

The Con!oervat1on Reserve Program (CAP) 

protecu mllhons of acres or Ame1ican top~il 

from erosion and ts designed to safeguard the 

Nation's natural resources. 

Acreage enroUed in the CAP IS planted to 

resource-conserving vegetative covers, 

making the program a n'UJOt contributor to 

Increased wildlife populations In many parts 

of the country. 

Ov•r two million acres of Colorado's grasslands are currently listed within the CRP w1 rh 

contn1cts ixplring through 201 J. 

Out to changes In the 2008 Farm Bill, agricultural producers having the.se grasslands may 

ftnd little opportunity to r .. enroll their land in 

tht CRP. 

According to 1ho Cotorado Oopumont of 

Agriculture. Jf a large portion ol exp1ring CAP 

acres 90 back into crop..,11d. Co!Ofado will lose 

many of its important conservation benefits 

accrued ov~ the lifetime of the contracts 

that ~tablished thes• grasslands including 

reduced soil eroslon and improved wildDfe 

habitat 

However, 1t some of the expifing CAP lands 

are kept in grass and managed for other uses, 

many of the conse1vation benefits realized 

during the CAP contracts could be maintained 

or enhanced. 

'°'NRCS Eugene Backhaus " ReJource Con~rvatlonlst 

655 P~rf•t StrHt. ElOOC 

Lakewood. co 1021 5 

PH: 720-S-44-2868 

Options for Expiring Conservation Reserve Program Lands 

Coomsioo to Grazing Land RlQ!,l l R.lMENTS A.ND OPTIONS 

• Develop a conservaUon plan that outlines 

grazing management and development 

needs 

• Install identified conservation measures tor 

proper grazing disuibution 

• If using Environme ntal Quality Incentives 

Program funds to Install identlned 

prac tices, producer MUST WA.IT UNTIL 

CRP CONTRACT EXPIRES 

• May be able to locate and use other fu nds 

to begin some work prior to conuact 

expiration 

• Conservation Easements 

• Grassland Reserve Program (grazing 

land only) 

'°'NRCS 

Helping People 

Help t he Land 

• Farm and Ranchland Protection Program 

fcrop and grass lands) 

Conrersion to Cropland R£Q..UIRlMCNTS ANO OPTIONS 

• Develop a conservation plan to maintain 

complia nce and program eligibility 

• Identified measure must be Installed 

within the·flrst year 

• Must address Threatened and Endandered 

Species and SpectM of Concern 

• Current policy allows some work to begin 

up to five months prior to expiration of 

contract 

• Will bt at lea st untll July 2010 before 

Income begms 

• Will again be subject to market and 

weuhtr changes, both negative and 

pmitlve. 

Enrollment in Continuous CRP • SAFE · The new State acres for wildlife 

Enh•n<•m•nt (5AfE) progr•m focuHs on 

high puouty wildlife habitat areas, and atms 

to retain desirable cover to halt the decline 

of numerous aMhk spe-cles. 

• CREP ·the Conservatton Reserve Enhance· 

ment Proqram helps protect environment<11ly 

sensitive land. decrease erosion, and restore 

wildlife habitaL 

• High priorit y conservation pra ctices -

an opportunity to r•""'8nrolt a portion of 

expired land Into Continuous CAP and 

focuses on •nvfronmentalty senslttve la nd. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 261 P age 
2. Limestone-Graveyard Creeks Watershed Project 

A watershed improvement project in the Limestone-Graveyard Creeks Watershed 

involved approximately 60,000 acres of land north of the Arkansas River between Hasty 

(Bent County) and Lamar. An estimated 44,500 acres of the watershed area are 

classified as priority land due to the highly erodible nature of the soil. Over 2,000 acres 

of agricultural cropland northwest of Lamar are included in this watershed project. 

Working with the NRCS, each farmer will create their own conservation plan with costs 

for improvements split equally between farmers and the federal government. The 15-

year project will help reduce soil erosion and improve water quality and efficiency 

through conservation tillage practices and/or other conservation efforts. In short, the 

Limestone-Graveyard Creeks Watershed Project will help to reduce soil erosion and 

lower the impacts of blowing soils during future high wind events. The Watershed 

project is regarded as an ongoing successful program as most eligible acres are 

enrolled. 

3. New Initiatives 

The Natural Resources Conservation Service has many efforts underway that further 

reduce blowing dust and its impacts through the following initiatives, which are not 

meant to be enforceable: 

• A comprehensive rangeland management program; 

• Tree planting program; 

• Drip irrigation purchase program, and; 

• A multi-party drought response planning effort coordinated through the State of 

Colorado Governor's office. 

These are but a few of the efforts at the local, county, and regional level underway to 

reduce emissions of PM10 and limit impacts. 

Colorado State University Co-Op Extension Office 

The CSU Co-Op Extension Office has many efforts underway that further reduce 

blowing dust and its impacts through the following initiatives, which are not meant to be 

enforceable: 

• Crop residue efforts that encourage no- or low-till practices. These have been 

deemed appropriate and useful in reducing blowing dust. 

• Ongoing outreach efforts to educate area agricultural producers on soil 

management programs. These include one-on-one visitations and annual 

meetings with various corn and wheat programs to discuss crop management. 

• Drought workshops to protect topsoil throughout the county. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 271 Page 
Prowers County 

Prowers County Land Use Plan 

Beginning in 1997, Prowers County with the assistance of local officials, environmental 

health officers and the general public began preparing a county land use plan. The 

Prowers County Land Use Plan is designed to have wide-reaching authority over the 

myriad of land use issues involving building (construction sites), siting , health, fire, 

environmental codes, and other social concerns associated with the City of Lamar and 

Prowers County. The county land use plan, entitled "Guidelines and Regulations for 

Areas and Activities of State Interest - County of Prowers - State of Colorado", was 

adopted on April 19, 2004 and amended on August 17, 2006. The plan incorporates 

provisions to minimize airborne dust including re-vegetation of disturbance areas 

associated with land development. 

This section fulfills the requirements of Elements 4 and 5 of the Natural Events Policy 

as described on page 6 of the NEAP. 

Element 6: Periodic Evaluation 

EPA's Natural Events Policy guidance requires the state to periodically reevaluate: 1) 

the conditions causing violations of the PM10 NAAQS in the area, 2) the status of 

implementation of the NEAP, and 3) the adequacy of the actions being implemented. 

This plan represents the third revision to the original NEAP dated April 1998. 

Evaluation of the effectiveness of the NEAP included several key strategies to ensure 

protection of public health and a robust plan. Strategies included: review of Natural 

Events Policy in specific relation to the Lamar community, review of the effectiveness 

and appropriateness of ongoing control strategies, review of meteorological and 

climatological conditions leading to blowing dust, a review of local and regional PM10 

monitoring data, review of the established emission inventory and identification of any 

new emission sources, review of the blowing dust advisory protocol and notification 

records, public/stakeholder meetings and community outreach/education efforts. The 

Division commits to continually review the effectiveness of the Lamar Natural Events 

Action Plan and improve the effort, where feasible. 

This section fulfills the requirements of Element 6 of the Natural Events Policy as 

described on page 6 of the NEAP. f 

Element 7: Stakeholder Involvement and Element 8: Public Review & Comment 

Stakeholder Involvement: 

The EPA's NEAP development guidance states that the NEAP should be developed by 

the State in conjunction with the stakeholders affected by the Plan. The Division worked 

with stakeholders mentioned throughout this document. Numerous meetings and 

telephone conversations occurred with stakeholders, and the final agreement here 

reflects strategies offered as part of the NEAP. 

Public Review: 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 281 Page 
The Division made this documentation available for, and presented the NEAP to, the 

public to ensure ample public review and comment. Examples of these efforts, 

beginning with the earliest community involvement, include: 

• "Air Quality Documentation in Support of High Wind Events in Lamar available 

for Public 

• Review/Comment at the Lamar Public Library ... " February 1997 

• Briefing of the Prowers County Board of Commissioners, February 1997 

• "Media Advisory" notifying the public of upcoming Lamar City Council meeting to 

discuss the NEAP, January 1998 

• Briefing the Lamar City Council, January 1998 

• Dissemination of the "Blowing Dust Health Advisory Brochure - Lamar Area" 

through the Southeast Land and Environment offices, January 1998 through the 

present 

• Briefing of the Colorado Air Quality Control Commission, February 1998 

• "Lamar Area Air Quality Natural Events Action Plan to be Available for Public 

Review" at the Lamar Public Library and Lamar City Complex - February 6 

through March 6, 1998" this notice was published in the Lamar Daily News on 

February 6, 1998 

• Briefing of the Lamar City Council on the PM10 Maintenance Plan, including a 

discussion of the Maintenance Plan's relationship to attainment status and the 

use of other air quality tools (e.g., Lamar NEAP), August 2000 

• "Media Advisory" notifying the public of an upcoming Lamar area meeting to 

discuss air quality issues. This notice ("Lamar Air Quality Topic of Public Meeting 

Tonight") was published in the Lamar Daily News, August 29, 2000 

• Local meeting with public to discuss air quality issues in the Lamar area including 

the planned PM10 Maintenance Plan, the area Natural Events Action Plan, and 

other initiatives to reduce blowing dust and its impacts on the public, August 

2000 

• Briefing of the Prowers County Board of Commissioners on the PM10 

Maintenance Plan including a discussion of the Maintenance Plan's relationship 

to attainment status and the use of other air quality tools (e.g., Lamar NEAP), 

August 2000 

• Briefing of the Lamar City Council on the Update to the Draft PM10 Maintenance 

Plan and its relationship to attainment status and the use of other air quality tools 

(e.g., Lamar NEAP), February 2001 

• Briefing of the Lamar City Council on the Update to the Final PM10 Maintenance 

Plan and its relationship to attainment status and the use of other air quality tools 

(e.g., Lamar NEAP), August 2001 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 291 Page 
• Briefing of the Colorado Air Quality Control Commission, May 2002 

• Briefing of the Lamar Air Quality Task Force, May 2002 

• Briefing of the Colorado Air Quality Control Commission, January 2003 

• Public Notice, "Revised (2003) Natural Events Action Plan for Lamar, Colorado" 

Available for Public Review and Comment at the Lamar Public Library, April 

2003 

• Briefing the Lamar City Council, April 2003 

• Public Notice, "Revised (2012) Natural Events Action Plan for Lamar, Colorado" 

Available for Public Review and Comment, September 2012 

This section fulfills the requirements of Elements 7 and 8 of the Natural Events Policy 

as described on page 6 of the NEAP. 

Element 9: Submittal to EPA 

The original Lamar NEAP was submitted to EPA in April 1998. The second NEAP was 

revised in 2003 and submitted to EPA. This third NEAP was revised in 2012 and will be 

submitted as an Appendix to this second revision to the Lamar PM10 Maintenance 

Plan. According to the Natural Events Policy, the NEAP should be revised on a fiveyear schedule. 

This section fulfills the requirements of Element 9 of the Natural Events Policy as 

described on page 6 of the NEAP. 

Draft 2012 Revised Natural Events Action Plan for Lamar, Colorado 30 IP age 
APPENDIX B: High Wind Events 

Data Analysis 

Page 68 
Figure B-1 provides a map of Colorado and Lamar is located in the southeastern 

portion of the state along the Arkansas River. 

Figure B-1: State of Colorado Map - Location of Lamar Area 

Appendix B: Lamar High Wind Events - Data Analysis 11 Page 
There are two meteorological (MET) stations identified in Figure B-2 below, that monitor 

wind speed and direction in the area, the Lamar Municipal Airport (operated by NWS -

labeled A) and Lamar Port of Entry (operated by CDPHE-APCD - labeled B). The 

Municipal Airport MET station is located west of Lamar off County Road 3.5 and Port of 

Entry MET station is located north of Lamar at 7100 US Highway 50. 

Figure B-2: Location of Meteorological Stations in Lamar Area 

Appendix B: Lamar High Wind Events - Data Analysis 21 Page 
There are a number of exceedances of the 24-hour PM 10 NAAQS that were recorded 

at the two Lamar PM10 Monitoring stations that were either not flagged as exceptional 

events or the events were flagged but no technical analysis was prepared and 

submitted to EPA. The below Table I provides a list of these exceedances which are 

analyzed in this document to confirm that high winds were the likely factor contributing 

to the exceedance. 

Table I: Lamar Area PM10 Exceedances (2001-2011) 

Event Date Monitor Site PM10 Value Data Flag EPA Review/Filing Status [μg/m3] 

1 04/11/01 Power Plant 152 none Event not flaaaed 

2 02106109 Power Plant 233 none Event not flaaaed 

3 03/05/09 Municipal 176 High Wind Flagged - Not submitted 

4 03/26/09 Power Plant 171 none Event not flagged 

5 04/03/11 Power Plant 169 High Wind Prelim Analysis 

6 11/05/11 Power Plant 192 High Wind Prelim Analysis 

The following data sources were used in the evaluation of the above listed PM10 

exceedances: 

The Lamar Airport meteorological data was obtained at the following link: 

http://mesowest.utah.edu/cgibin/droman/download ndb.cgi?stn=KLAA&year1 =2012&day1 =27&month1 =7&hour1 =&t 

imetype=GMT&unit=O 

The wind speed at the Lamar Airport is recorded using an Automated Surface 

Observing System (ASOS), which archives wind speed data for every 2-minute period 

of each hour. Consequently, the "average hourly wind speed" is the arithmetic average 

of the 2-minute values over the hour. The "maximum wind speed" is the highest 2-

minute wind speed recorded during the hourly period. 

The Lamar Airport Wind Rose graphs can be obtained at the following link: 

http://www.wrcc.dri.edu/sod/arch/eeF.html 

The meteorological data for the Lamar Port of Entry site can be obtained from the 

following website link (use "Air Quality Monitoring Site" Option): 

http://www.colorado.gov/airquality/report.aspx 

The US Drought Maps for the western US can be found at the following link: 

http://droughtmonitor.unl.edu/archive.html# 

Appendix B: Lamar High Wind Events - Data Analysis 31 Page 
1. PM10 Exceedance of 152 ug/m3 on April 11, 2001 

Table II provides the wind speed data from the Lamar Municipal Airport for the April 11, 

2001 PM10 exceedance of 152 μg/m3 that was not flagged as a high wind event by the 

Division. 

Table II: Lamar Municipal Airport - Meteorological Data for April 11, 2001 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l :OOAM 10.4 170 42.1 82 

2:00AM 24.2 250 39 86 

3:00AM 16.1 240 37 89 

4:00AM 23 290 27.6 43 82 

S:OOAM 42.6 320 55.2 39 82 

6:00AM 44.9 330 59.8 39 79 

7:00AM 46 320 66.7 41 73 

8:00AM 50.6 320 65.6 41 79 

9:00AM 48.3 330 63.3 39.9 83 

10:00 AM 54.1 330 69 42.1 76 

11:00 AM 57.5 330 73.6 45 60 

12:00 PM 50.6 340 70.2 46.9 56 

1:00 PM 54.1 340 67.9 48 51 

2:00 PM 43.7 340 59.8 48.9 48 

3:00 PM 42.6 350 54.1 so 46 

4:00 PM 41.4 0 52.9 48 47 

5:00 PM 32.2 0 43.7 45 53 

6:00 PM 23 0 32.2 43 60 

7:00 PM 11.5 290 42.1 62 

8:00 PM 9.2 310 39 70 

9:00 PM 9.2 270 36 75 

10:00 PM 9.2 270 37 75 

11:00 PM 6.9 270 34 79 

12:00 AM 5.8 260 36 79 

Average 31.6 312 41.8 70 

Maximum 57.5 73.6 50 89 

Minimum 5.8 34 46 

For 13 hours, the average hourly wind speed (in bold) ranged from 32.2-57.5 miles per 

hour (mph) with peak gusts (in bold) from 27.6-73.6 mph, which is sufficient to entrain 

and suspend particulate matter and exceeds the suggested minimum sustained wind 

speed threshold in the Draft EPA Guidance on High Wind Events. No measureable 

precipitation fell during the 24-hour period. The wind rose for the April 11, 2001 event 

Appendix B: Lamar High Wind Events - Data Analysis 41 Page 
(see Figure B-3 below) indicates the winds were predominantly from a northnorthwesterly direction. 

Figure 8-3: Lamar Municipal Airport - Wind Rose for April 11, 2001 

Station 

Latitude 

l..Dnqitude 

Elevation 

Element 

Lamar Municipal 

.3B D 04 • 12" N 

102 D 41 ' 17" ~ 

0 ft. 

Colorado 

N 

30% 

25% 

---:~--------------, ____ ___ 

---- ....... 

Start Date: Apr. 11, 

End Date: Apr. 11 , 

~ of Days : 1 of 1 

~ ob:s: po:s:s: 24 of 24 

I 

·-

---- ----~-.... 

--.... ...._ .. 

--------~-. 

\.. 

----...... ... ~,. 

.. ~\ 

\ 

\ 

\ 

''f 

I 

I 

I 

.. _ .. l 

( 

{ 

/ / 

-........ ./ 

------- ~ ---------- _ ..... 

--.... ---------

----...... __ ---"" ~-~--------_.. 

s e:stern Regional Climate Center 

\ 

\ 

.. .. 

\ 

\ 

\ 

I 

/ I 

/ 

I 

//' 

( 

f 

{ 

\ 

I, 

I 

\ 

I 

I 

I 

i I 

I 

/ 

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

Sub-interval inde».':s 

Start End 

Date: Jan. 01Dec. 3 

Hour: 00 23 

No wind speed data is available for the April 11, 2001 date at the Lamar Port of Entry 

site. 

Appendix B: Lamar High Wind Events - Data Analysis 51 Page 
The Western Drought Map (see below Figure B-4) indicates no drought conditions in 

southeast Colorado. 

Figure 8-4: Western US Drought Monitor Map - Released April 19, 2001 

U.S. Drought Monitor April 17, 2001 

Valid 7 a.m. EST 

West 

None 

current 48-4 51.6 37.8 19.5 0.6 00 

Last Wee+r. 48.7 51.3 37.6 19.5 0.6 o.o f04111l121ll 1 map) 

3MonthsAgo 55-4 44.6 71 2.9 0.2 OQ 

(Olr.?3/2001 map) 

&anor 

Galendar Year 78.1 21.9 71 2.7 0.2 0.0 OW212001 ma 

&anor 

Water Year 36.3 63.7 33.1 11.5. 1-3 0.0 

(04/lar.OOD map 76.5 23.5 49 1.7 0.0 00 

Jn tensity: 

00 Abnorma'ly Ory • 03 OfOlJ9hl - Extreme 

D 1 Drooght - Moderate • 04 Drooght- Exceptional 

02 Drought -Severe 

The Drought Monitor focuses on broad-scale conditions_ USDA 

Local conditions may vary. See accompanying text summary ~ 

for forecast statements_ 

Released Thursday, April 19, 2001 

http://drought.unl.edu/dm Author: David Miskus, NOAAICPC!JAWF 

Appendix B: Lamar High Wind Events - Data Analysis 6 I P a g e 
2. PM10 Exceedance of 233 ug/m3 on February 6, 2009 

Table Ill provides the wind speed data from the Lamar Municipal Airport for the 

February 6, 2009 PM10 exceedance of 233 μg/m3 that was not flagged as a high wind 

event by the Division. 

Table Ill: Lamar Municipal Airport- Meteorological Data for February 6, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l:OOAM 6.9 230 23 35 

2:00AM 0 0 25 34 

3:00AM 3.5 290 24.1 35 

4:00AM 4.6 220 27 34 

5:00AM 4.6 220 25 37 

6:00AM 8.1 260 25 37 

7:00AM 6.9 240 24.1 39 

8:00AM 6.9 260 34 33 

9:00AM 8.1 250 46.9 19 

lO:OOAM 15 280 60.1 13 

11:00 AM 28.8 290 44.9 70 10 

12:00 PM 34.5 290 48.3 71.1 8 

1:00 PM 38 280 49.5 71.1 8 

2:00 PM 38 280 49.5 71.1 8 

3:00 PM 39.1 290 47.2 70 7 

4:00 PM 29.9 280 38 69.1 8 

5:00 PM 21.9 290 28.8 64.9 9 

6:00 PM 18.4 280 60.1 12 

7:00 PM 13.8 260 52 16 

8:00 PM 16.1 280 52 17 

9:00 PM 8.1 280 43 24 

10:00 PM 4.6 240 39.9 27 

11:00 PM 8.1 220 39.9 29 

12:00 AM 5.8 230 36 34 

Average 15.4 266 46.8 22 

Maximum 39.1 49.5 71.1 39 

Minimum 0 23 

For six hours, the average wind speed (in bold) ranged from 28.8-39.1 miles per hour 

(mph) with peak gusts (in bold) from 28.8-49.5 mph, which is sufficient to entrain and 

suspend particulate matter and exceeds the suggested minimum sustained wind speed 

threshold in the Draft EPA Guidance on High Wind Events. No measureable 

precipitation fell during the 24-hour period. The wind rose for the February 6, 2009 

7 

Appendix B: Lamar High Wind Events - Data Analysis 71 Page 
event (see Figure B-4 below) indicates the winds were predominantly from a westerly 

direction. 

Figure B-5: Lamar Municipal Airport - Wind Rose for February 6, 2009 

Station 

Latitude 

1.onqitude 

Elevation 

Element 

Lamar Municipal 

38 D 04 1 12" N" 

102° 41' 17"' N 

0 ft. 

/ 

Colorado 

N 

42% 

21% _..,,.-------------~--------...... -...... __ 

_/ 14% ·-'"'-._ 

Start Date: Feb. 6, 2009 

End Date: Feb. 6, 2009 

~ of Days : l of l 

~ obs:poss: 24 of 24 

.... ~ .------..___ 

/ ,,r···/ .......... 

7% ~~- ,.-- -..... , 

'~~ 

s 

© Nestern Reqional Clim.ate Center 

Appendix B: Lamar High Wind Events - Data Analysis 

'-. 

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

Sub-interval indmvs 

Start End 

Date: Jan. 01Dec. 3 

Hour: 00 23 

81 Page 
Table IV provides the wind speed data from the Lamar Port of Entry for the February 6, 

2009 PM 10 exceedance of 233 μg/m3 that was not flagged as a high wind event by the 

Division. 

Table IV: Lamar Port of Entry - Meteorological Data for February 6, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l:OOAM 1.2 271.9 26.7 

2:00AM 0.9 255.6 26.0 

3:00AM 3.9 277.2 25.0 

4:00AM 1.7 262.3 25.3 

5:00AM 3.6 267.8 25.6 

6:00AM 5.8 270.3 26.8 

7:00AM 6.1 262.5 28.2 

8:00AM 9.4 254.2 38.0 

9:00AM 14.2 261.1 51.1 

lO:OOAM 21.3 256.7 64.4 

11:00 AM 34.S 256.4 69.0 

12:00 PM 35.4 253.0 69.8 

1:00 PM 33.1 258.6 69.7 

2:00 PM 31.9 258.9 69.6 

3:00 PM 29.0 264.9 69.1 

4:00 PM 22.0 262.7 67.4 

5:00 PM 16.1 265.2 62.1 

6:00 PM 12.0 243.3 56.8 

7:00 PM 11.0 268.3 51.1 

8:00 PM 11.3 261.0 49.7 

9:00 PM 6.8 237.6 44.7 

10:00 PM 4.3 269.0 39.9 

11:00 PM 3.1 289.1 39.9 

12:00 AM 

Average 13.4 262.1 47.2 

Maximum 35.4 69.8 

Minimum 0.9 25.0 

For five (5) hours, the average wind speed (in bold) ranged from 29.0 to 35.4 miles per 

hour (mph), which is sufficient to entrain and suspend particulate matter and exceeds 

the suggested minimum sustained wind speed threshold in the Draft EPA Guidance on 

High Wind Events. Until very recently, the Lamar Port of Entry Met station did not have 

the data retention capabilities to track with peak wind gusts. 

Appendix B: Lamar High Wind Events - Data Analysis 91 Page 
The Western Drought Map (see below Figure 8-6) indicates moderate drought 

conditions in southeast Colorado. 

Figure B-6: Western US Drought Monitor Map - Released February 12, 2009 

U.S. Drought Monitor Februarv 1 o, 2009 

l/ilidf a.m. EST 

West 

D.O 

DJJ 

OJJ 

D.O 

D .• O 

IJJJ 

In ensiy: 

DDADnamt3 t>ry • l>J::in:t.. .- E 

01 OJ;lug • d!!t .• • D<.D -

02 D< gttt-:., ~ 

The Droug. t MoT1iior mu e ~ b11>ad-sca e comAfio s 

Lo - conct:tions may vaJ)"- See: ,:Jcocmpanyi g taxi sum - ry 

for forecu atateme t<:. 

http://droughuml.edu/dm 

Appendix B: Lamar High Wind Events - Data Analysis 

Released T11Ursday, February 12, 2009 

A ut or: Rich Tin er, CPCJNOM 

10 I P age 
3. PM10 Exceedance of 176 ug/m3 on March 5, 2009 

Table V provides the wind speed data from the Lamar Municipal Airport for the March 5, 

2009 PM10 exceedance of 176 μg/m3, which was flagged as a high wind event by the 

Division. However, the technical analysis of the event was not completed before the 

EPA submittal deadline. 

Table V: Lamar Municipal Airport - Meteorological Data for March 5, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

1:00 AM 11.5 240 46 38 

2:00AM 8.1 290 46.9 35 

3:00AM 0 0 46 35 

4:00AM 15 230 45 34 

5:00AM 13.8 230 45 34 

6:00AM 23 280 31.1 55.9 14 

7:00AM 20.7 280 55 18 

8:00AM 33.4 280 49.5 64 13 

9:00AM 26.5 280 42.6 66 12 

lO:OOAM 38 270 49.5 69.1 8 

ll:OOAM 33.4 280 46 72 7 

12:00 PM 39.1 290 50.6 73.9 6 

1:00 PM 31.1 280 43.7 75.9 5 

2:00 PM 31.1 290 44.9 75.9 5 

3:00 PM 34.5 290 43.7 77 4 

4:00 PM 31.1 280 41.4 75 4 

5:00 PM 28.8 300 44.9 72 6 

6:00 PM 18.4 290 66.9 8 

7:00 PM 11.5 300 57.9 12 

8:00 PM 8.1 290 52 14 

9:00 PM 12.7 100 50 24 

10:00 PM 9.2 110 46 27 

11:00 PM 9.2 130 43 29 

12:00 AM 5.8 170 39 34 

Average 20.6 275 59 18 

Maximum 50.6 77 38 

Minimum 39 4 

For ten hours, the average wind speed (in bold) ranged from 26.5 - 39.1 mph with peak 

gusts (in bold) from 31.1-50.6 mph, which is sufficient to entrain and suspend 

particulate matter and exceeds the suggested minimum sustained wind speed 

threshold in the Draft EPA Guidance on High Wind Events. No measureable 

Appendix B: Lamar High Wind Events - Data Analysis 111 Page 
precipitation fell during the 24-hour period. The wind rose for the March 5, 2009 event 

(see Figure B-5 below) indicates the winds were predominantly from a west-north 

westerly direction. 

Figure B-7: Lamar Municipal Airport - Wind Rose for March 5, 2009 

Station 

Latitude 

l.Dngitude 

Elevation 

Element 

Lamar Municipal 

38 a 04 ' 12" N' 

l02a 4] • 17" lj 

0 ft. 

Colorado 

N 

36% 

30% 

----------- 24% ------- ""'--. ......... ·~. 

/_,,,..,,,.---~-- ------...... , ___ '-. 

~ -· _ _JJl1-____ .... °"""· 

/ / /-- 12z ·--...___. ' 

,,.. ....... -.• -~----------~-·-..,...... ........ ....... \ 

6% .. ------.. ... '\. -""" ' 

\ \ \ 

\\\\ 

'• \ \ 

) ) )\ 

.,/ I --..---,-_.....~ / 

\. 

\ .. '"·· ....... .._______ _ __ /_,/ 

- ·--- \ 

Start Date: Mar. 5, 2009 

End Date: Mar. 5, 2009 

f of Days : l of l 

f obs:poss: 24 of 24 

estern Regional Climate Center 

--~-.----

s 

Appendix B: Lamar High Wind Events - Data Analysis 

' 

\ 

' \ 

// 

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

Sub-interval indcY~s 

Start End 

Date: Jan. 01Dec. 3 

Hour: 00 23 

121 Page 
Table VI provides the wind speed data from the Lamar Port of Entry for the March 5, 

2009 PM10 exceedance of 176 μg/m3, which was flagged as a high wind event by the 

Division. However, the technical analysis of the event was not completed before the 

EPA submittal deadline. 

Table VI: Lamar Port of Entry- Meteorological Data for March 5, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity{%) 

l:OOAM 0.0 - 47.7 

2:00AM 5.9 299.6 46.3 

3:00AM 3.6 276.5 49.5 

4:00AM 8.8 238.1 52.0 

5:00AM 12.2 257.7 51.9 

6:00AM 15.9 251.4 61.9 

7:00AM 29.6 252.0 64.2 

8:00AM 30.4 258.0 67.0 

9:00AM 33.9 257.3 69.6 

lO:OOAM 36.1 260.0 72.1 

11:00 AM 33.3 257.8 73.6 

12:00 PM 32.9 257.0 74.5 

1:00 PM 31.1 255.9 75.0 

2:00 PM 31.4 259.7 74.5 

3:00 PM 32.5 260.8 73.2 

4:00 PM 29.1 264.3 69.6 

5:00 PM 20.4 270.0 64.7 

6:00 PM 15.5 278.1 60.5 

7:00 PM 10.1 285.8 52.0 

8:00 PM 11.2 26.7 47.7 

9:00 PM 6.5 70.6 43.1 

10:00 PM 5.6 97.7 40.2 

11:00 PM 5.0 94.4 38.4 

12:00 AM 

Average 19.7 229.6 59.5 

Maximum 36.1 75.0 

Minimum 3.6 38.4 

For ten hours, the average wind speed (in bold) ranged from 29.1 - 36.4 mph, which is 

sufficient to entrain and suspend particulate matter and exceeds the suggested 

minimum sustained wind speed threshold in the Draft EPA Guidance on High Wind 

Events. Until very recently, the Lamar Port of Entry Met station did not have the data 

retention capabilities to track with peak wind gusts. · 

Appendix B: Lamar High Wind Events - Data Analysis 131 Page 
The Western Drought Map (see below Figure B-8) indicates moderate drought 

conditions in southeast Colorado. 

Figure 8-8: Western US Drought Monitor Map - Released March 12, 2009 

U.S. Drought Monitor 

West 

None 

current 33.7 66.3 25.1 4.2 0.0 00 

Last Week 351 64. 28.0 8.0 0.6 0.0 

275 72..5 31 .0 100 0.8 00 

374 62.6 289 8.8 0.4 00 

41.3 58.7 28.6 0 0.1 00 

One Year Ago 42-3 57.7 34.2 16 0 0.0 00 

(03/1 /2008 map) 

Intensity_: 

DO bnorma:Jy Ory • 03 Drouoht • Extreme 

0 1 Drough! - Moderate • 04 Drougtit - Excep ·ona1 

02 Drough' - Severe 

The Drought Monitor focuses on broad-scale conditions 

Locaf conditions may vary. See accompanying text summary 

for forecast statements. 

USDA 

~ 

March 10, 2009 

Valid 7 a.m. 'EST 

http://drought.unl.edu/dm 

Released Thursday, March 12, 2009 

Author: M. Brewerll. Love-Brotak, NOAAINESDISINCDC 

Appendix B: Lamar High Wind Events - Data Analysis 141 Page 
4. PM10 Exceedance of 171 ug/m3 on March 26, 2009 

Table VII provides the wind speed data from the Lamar Municipal Airport for the March 

26, 2009 PM10 exceedance of 171 μg/m3 that was not flagged as a high wind event by 

the Division. 

Table VII: Lamar Municipal Airport- Meteorological Data for March 26, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l:OOAM S.8 90 33.1 72 

2:00AM 8.1 110 32 72 

3:00AM 9.2 130 30.9 73 

4:00AM 3.S 20 27 76 

S:OOAM 4.6 so 2S 79 

6:00AM 3.S 90 2S 79 

7:00AM 6.9 120 30 72 

8:00AM 11.S 130 33.1 69 

9:00AM 13.8 110 37.9 S9 

10:00 AM 11.S 100 43 62 

11:00 AM lS 110 44.1 62 

12:00 PM 19.6 140 26.5 44.1 70 

1:00 PM 18.4 130 29.9 48 44 

2:00 PM 24.2 100 33.4 46 Sl 

3:00 PM 28.8 70 39.1 3S.1 72 

4:00 PM 33.4 60 39.1 32 69 

S:OO PM 27.6 so 40.3 28 79 

6:00 PM 27.6 so 34.5 26.1 87 

7:00 PM 20.7 40 34.5 2S 86 

8:00 PM 16.1 40 33.4 24.1 86 

9:00 PM 21.9 40 31.1 23 86 

10:00 PM 18.4 30 27.6 23 86 

11:00 PM 17.3 40 29.9 21.9 83 

12:00 AM 20.7 40 32.2 19.9 87 

Average 16.2 78 31.6 73 

Maximum 33.4 40.3 48 87 

Minimum 3.5 19.9 44 

For four hours, the average wind speed (in bold) ranged from 27.6 - 33.4 mph with 

peak gus~s (in bold) from 26.5-40.3 mph, which is sufficient to entrain and suspend 

particulate matter and exceeds the suggested minimum sustained wind speed 

threshold in the Draft EPA Guidance on High Wind Events. At 8:00 PM, 0.01 inches of 

measureable precipitation fell over the 24-hour period. The wind rose for the March 26, 

Appendix B: Lamar High Wind Events - Data Analysis 151 Page 
2009 event (see Figure B-6 below) indicates the winds were predominantly from a north 

easterly direction. 

Figure B-9: Lamar Municipal Airport - Wind Rose for March 26, 2009 

Station 

Latitude 

Longitude 

Elevation 

Element 

Lamar Municipal 

3B 0 04. 12" N 

l 02 D 41 ' l 7" ;-1 

0 ft. 

/" 

Colorado 

N 

30% 

~~ 

20% 

---- ,,./ _.,....,,....,. /J ----- ~--.........___ .,..... 

15% ,.,. 

( / 

I // 

/ 

I 

( ./ ./ I " / / I I I 

/ 

\ 

I 

I \\ \ 

\ 

" I 

\ 

\ 

\ ... 

Start Date: Mar. 26, 

End Date: Mar. 26, 

~ of Days : l of l 

..... 

~ obs:poss: 24 of 24 

// 

( I 

I 

\ I 

\ 

\\ 

' 

..,.... _,..,,.... ,.-

.•' 

/J..--

estern Regional Climate Center 

~-~ 

----- 10% 

.~--

s 

Appendix B: Lamar High Wind Events - Data Analysis 

··-..... 

.._,_ 

'\\\ 

\ \ I 

// 

_..; .. 

\ 

\ 

' 

\\ 

/ 

I 

} 

I 

\ 

' 

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

I 

/ 

I 

. 

Sub-inteLval ind~s 

Start End 

Date: Jan. 01Dec. 3 

Hour: 00 23 

161 Page 
Table VIII provides the wind speed data from the Lamar Port of Entry for the March 26, 

2009 PM10 exceedance of 171 μg/m3 that was not flagged as a high wind event by the 

Division. 

Table VIII: Lamar Port of Entry- Meteorological Data for March 26, 2009 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l :OOAM 8.1 59 34.0 

2:00AM 5.8 66 30.8 

3:00AM 5.0 32 28.9 

4:00AM 4.1 18 27.7 

5:00AM 6.2 18 27.4 

6:00AM 4.0 85 27.7 

7:00AM 7.1 92 31.0 

8:00AM 11.4 85 34.8 

9:00AM 12.4 81 41.4 

lO:OOAM 15.2 74 43.7 

11:00 AM 16.0 93 44.0 

12:00 PM 21.6 97 47.4 

1:00 PM 23.1 84 46.6 

2:00 PM 23.9 33 37.3 

3:00 PM 23.9 30 33.5 

4:00 PM 24.8 20 29.6 

5:00 PM 21.7 f 15 26.7 

6:00 PM 20.9 12 25.1 

7:00 PM 17.4 14 24.5 

8:00 PM 17.2 8 23.9 

9:00 PM 17.0 5 23.2 

10:00 PM 18.7 7 21.9 

11:00 PM 16.0 5 21.1 

12:00 AM 18.0 2 19.7 

Average 14.2 45.6 31.3 

Maximum 24.3 47.4 

Minimum 3.8 19.7 

The average wind speed appears to be below the EPA suggested minimum wind speed 

threshold to entrain and suspend particulate matter. 

Appendix B: Lamar High Wind Events - Data Analysis 171 Page 
The Western Drought Map (see below Figure B-10) indicates moderate drought 

conditions in southeast Colorado. 

Figure B-10: Western US Drought Monitor Map - Released March 26, 2009 

u .. s. Drought Monitor March 24 2009 

Va "d: 7 a.m_ EST 

W·est 

The rougflt Mrmltcr ft>cU'ses o broad-sea e 011dl -On\S"-

L a cond"tions may .vary. See a-ccompan_v · .g fe· r !l 

for fQrecaat.s ateme ht. 

http·//drought.unl.eduldm 

Releasec/ Thursday, March 26, 2009 

l! utho : B rad Rippey, U_S:. Depanment of lt9riculture 

Appendix B: Lamar High Wind Events - Data Analysis 181 Page 
5. PM10 Exceedance of 169 ug/m3 on April 3, 2011 

Table IX provides the wind speed data from the Lamar Municipal Airport for the April 3, 

2011 PM10 exceedance of 169 μg/m3 that was flagged as a high wind event by the 

Division. 

Table IX: Lamar Municipal Airport - Meteorological Data for April 3, 2011 

Temp Relative Wind Wind Gust Wind Weather Visibility 

Time (MST) (Deg F) Humidity Speed (mph) Direction (miles) 

(%) (mph) (Degrees) 

0:53AM 55.9 22 12.7 200 clear 10 

1:53 AM 54 24 12.7 200 clear 10 

2:53 AM 55 24 11 .5 200 clear 10 

3:53 AM 66.9 16 15 210 clear 10 

4:53 AM 62.1 20 17.3 200 clear 10 

5:53 AM 69.1 15 25.3 31.1 230 clear 10 

6:53AM 69.1 15 20.7 240 clear 10 

7:53 AM 73.9 14 21 .9 31 .1 260 clear 10 

8:53 AM 75.9 14 35.7 44.9 240 clear 10 

9:53 AM 80.1 12 32.2 46 250 clear 10 

10:53 AM 82 10 25.3 44.9 250 clear 10 

11:53 AM 84.9 7 38 47.2 270 clear 10 

12:53 PM 84.9 7 36.8 48.3 250 clear 10 

1:53 PM 84.9 7 36.8 58.7 . 240 clear 10 

2:53 PM 84.9 8 41.4 54.1 250 clear 10 

3:53 PM 55.4 41 41.4 55.2 10 haze 1.25 

4:53 PM 53.6 41 43.7 56.4 10 haze 1 

5:53 PM 53.6 41 34.5 54.1 360 haze 1.25 

6:53 PM 54 41 41.4 54.1 360 haze 1.25 

7:53 PM 53.6 41 36.8 52.9 10 haze 1.5 

8:53 PM 53.6 41 39.1 50.6 10 haze 2 

9:53 PM 53.6 41 32.2 50.6 10 haze 3 

10:53 PM 51 .8 43 41.4 51.8 10 haze 3 

11:53 PM 51 .8 43 33.4 51.8 10 haze 2.5 

Average 59 33 29 212 

Maximum 84.9 72 43.7 58.7 

Minimum 36 7 11.5 31.l 

For 17 hours, the average wind speed (in bold) ranged from 25.3 -43.7 mph with peak 

gusts (in bold) from 31.1- 58.7 mph, which is sufficient to entrain and suspend 

particulate matter and exceeds the suggested minimum sustained wind speed 

Appendix B: Lamar High Wind Events - Data Analysis 191 Page 
threshold in the Draft EPA Guidance on High Wind Events. Around 10:00 PM, light 

snow was reported for two hours over the 24-hour period. 

The wind rose for the April 3, 2011 event (see Figure B-11 below) indicates the winds 

were predominantly from a northerly direction. 

Figure B-11: Lamar Municipal Airport - Wind Rose for April 3, 2011 

Station 

Latitude 

Longitude 

Elevation 

Element 

Lamar Municipal 

.38 D 04 ' 1 2" t.f 

102D 41. 17" N 

0 ft. 

Start Date: Apr . .3, 

End Date: Apr. 3, 

f of Day:s : 1 of 1 

f ob:s: po:s:s: 2.3 of 24 

e:stern Regional Climate Center 

Colorado 

N 

36% 

s 

Appendix B: Lamar High Wind Events - Data Analysis 

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

Sub-interval indow:s 

Start End 

Date: Jan. 01Dec. 3 

Hour: 00 23 

20 IP age 
Table X provides the wind speed data from the Lamar Port of Entry for the April 3, 2011 

PM10 exceedance of 169 μg/m3 that was flagged as a high wind event by the Division. 

Table X: Lamar Port of Entry - Meteorological Data for April 3, 2011 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

1:00 AM 10.9 259.6 59 

2:00AM 7.1 264.5 58 

3:00AM 6.0 277.3 60 

4:00AM 12.4 219.5 65 

5:00AM 17.0 229.9 70 

6:00AM 16.1 238.1 69 

7:00AM 16.9 253.8 70 

8:00AM 24.9 251.3 74 

9:00AM 32.2 251 76 

10:00 AM 30.2 257.7 78 

11:00 AM 32.1 261.4 80 

12:00 PM 35.0 257.6 82 

1:00 PM 33.7 246.8 82 

2:00 PM 38.0 255.6 81 

3:00 PM 24.6 338 71 

4:00 PM 34.2 358.4 56 

5:00 PM 33.4 357.2 49 

6:00 PM 30.4 359.2 43 

7:00 PM 27.4 359.7 40 

8:00 PM 24.9 2.6 37 

9:00 PM 22.8 351.1 38 

10:00 PM 19.1 352.1 38 

11:00 PM 15.7 351 39 

12:00 AM 15.6 336.4 39 

Average 23.3 ·218.8 60.6 . 

Maximum 38.0 82.0 

Minimum 6.0 37.0 

For 13 hours, the average wind speed (in bold) ranged from 24.6 - 38.0 mph, which is 

sufficient to entrain and suspend particulate matter and exceeds the suggested 

minimum sustained wind speed threshold in the Draft EPA Guidance on High Wind 

Events. 

Appendix B: Lamar High Wind Events - Data Analysis 211 Page 
The Western Drought Map (see below Figure B-12) indicates severe drought conditions 

in southeast Colorado. 

Figure B-12: Western US Drought Monitor Map - Released April 7, 2011 

U.S. Drought Monitor April 5, 2011 

Valid 7 a.m. EST 

West 

Nolle 

cu nt 76.09 23.91 19.18 13.39 416 0.00 

Last Week 76.08 23.92 18..56 13.12 2.12 o.oo 

(03/2g/2() I D) 

3MonthsAgo 74.72 25.28 11.69 0.8.9 0.00 0,00 

(01 l~J 

Start of 

Galendar Year 73.26 26.74 11.93 0.89 0.00 o.oo 1212812010ma 

Start of 

Water Year 62.50 37.50 8.14 0.56 0.00 0.00 

(!r.!i2812010map 

One Year Ago 42.22 "778 21 40 4.89 0.00 0.00 

Intensity: 

[)() Abi10f1118/fy Dry • 03 Drought - 5rtieme 

Of Dtoughi - Moderate • 04 Drought -&cep/TOllal 

D2 Drought - Severe 

The Drought Monitor focuses on broad-sea e conditions. 

Local conditions may vary. See accompanying text summary 

for forecast statements. 

http://drought.unl.edu/dm 

Appendix B: Lamar High Wind Events - Data Analysis 

U

~ 

SDA 

Re/eased Thursday, April 7, 2011 

National Drought Mitigation Center. 

221 Page 
6. PM10 Exceedance of 192 ug/m3 on November 5, 2011 

Table XI provides the wind speed data from the Lamar Municipal Airport for the 

November 5, 2011 PM10 exceedance of 192 μg/m3 that was flagged as a high wind 

event by the Division. 

Table XI: Lamar Municipal Airport - Meteorological Data for November 5, 2011 

Relative Wind Wind Gust Wind Weather Visibility 

Time (MST) Temp Humidity Speed Direction (miles) (Deg F) (%) (mph) (mph) (Degrees) 

0:53 AM 51 .1 44 5.8 80 clear 10 

1:53 AM 51 .1 44 13.8 180 clear 10 

2:53 AM 48 49 5.8 170 clear 10 

3:53 AM 48 49 9.2 170 clear 10 

4:53 AM 46.9 52 6.9 120 clear 10 

5:53 AM 45 53 13.8 130 clear 10 

6:53 AM 41 62 12.7 110 clear 10 

7:53 AM 37.9 67 16.1 120 clear 10 

8:53 AM 43 55 16.1 110 clear 10 

9:53 AM 51 .1 42 16.1 110 clear 10 

10:53 AM 66.2 24 21 .9 . 28.8 160 clear 10 

11:53 AM 66.9 24 21 .9 28.8 170 clear 10 

12:53 PM 72 19 38 59.8 200 clear 8 

1:53 PM 71 .6 20 54.1 67.9 200 haze 5 

2:53 PM 72 20 49.5 65.6 210 mostly cloudy 8 

3:53 PM 69.8 21 47.2 61 200 partly cloudy 8 

4:53 PM 69.8 21 44.9 57.5 200 haze 6 

5:53 PM 68 24 34.5 55.2 210 mostly cloudy 10 

6:53 PM 66.9 24 32.2 42.6 230 partly cloudy 10 

7:53 PM 62.1 18 33.4 50.6 210 mostly clear 10 

8:53 PM 57.9 17 29.9 40.3 240 partly cloudy 10 

9:53 PM 57 22 28.8 40.3 230 partly cloudy 10 

10:53 PM 54 28 23 220 clear 10 

11:53 PM 54 27 25.3 33.4 240 clear 10 

Average 55.8 37.4 23 173.6 

Maximum 72 73.0 54.1 67.9 

Minimum 37.9 17.0 3.5 28.8 

For 11 hours, the average wind speed (in bold) ranged from 25.3 - 54.1 mph with peak 

gusts (in bold) from 28.8 - 67.9 mph, which is sufficient to entrain and suspend 

particulate matter and exceeds the suggested minimum sustained wind speed 

threshold in the Draft EPA Guidance on High Wind Events. 

Appendix B: Lamar High Wind Events - Data Analysis 231 Page 
The wind rose for the November 5, 2011 event (see Figure 8-13 below) indicates the 

winds were predominantly from a southwesterly direction. 

Figure B-13: Lamar Municipal Airport-Wind Rose for November 5, 2011 

Station 

Latitude 

Longitude 

Elevation 

Element 

w 

Lamar Municipal Colorado 

3B0 o.q• 12" t.f N 

102° .qi' 17" ;.1 

0 ft. 24% 

20% 

,,,..----------

/ 16% 

12% 

8% \ ~ '-.. \ 

~ / i 

,J ~~,/ 

I / ·--u I ~ I • 

_ _,...--/ _, ;' 

.... ~"' 

// // _/ 

......... _/ ..... _ -.....___ __ ____ .. ~ 

---- --- -------.. ----

MPH 

1.3 - 4 

4 - 8 

8 - 13 

13 - 19 

19 - 25 

25 - 32 

32 - 39 

39 - 47 

47 + 

E 

Start Date: Nov. 5, 2011 

End Date: Nov. 5, 2011 * of Day:s : 1 of 1 s 

Sub-interval indcY~:s 

Start End 

Date: Jan. 01Dec. 3 * ob:s: po:s:s: 2.q of 2.q Hour: 00 23 

e:stern Regional Climate Center 

Appendix 8: Lamar High Wind Events - Data Analysis 241 Page 
Table XII provides the wind speed data from the Lamar Port of Entry for the November 

5, 2011 PM10 exceedance of 192 μg/m3 that was flagged as a high wind event by the 

Division. 

Table XII: Lamar Port of Entry- Meteorological Data for November 5, 2011 

Time (LST) Average WS Wind Direction Max. Wind Temperature Relative 

(mph) (Degrees) Speed (mph) (Deg F) Humidity(%) 

l:OOAM S3 

2:00AM 7.2 128.S Sl 

3:00AM 7.8 148.7 Sl 

4:00AM 4.4 110.0 49 

S:OOAM 7.4 98.7 46 

6:00AM 10.0 93.4 43 

7:00AM 10.3 103.l 39 

8:00AM 11.S 104.8 41 

9:00AM 13.S 108.l 46 

10:00 AM 14.1 119.4 S6 

ll:OOAM 24.9 176.0 68 

12:00 PM 39.S 197.4 70 

1:00 PM 38.S 200.6 68 

2:00 PM 31.1 207.1 66 

3:00 PM 30.2 212.1 64 

4:00 PM 31.2 230.3 60 

S:OO PM 26.8 233.6 S8 

6:00 PM 23.1 24S.8 SS 

7:00 PM 21.0 232.2 SS 

8:00 PM 19.0 2Sl.1 S4 

9:00 PM 12.7 294.8 so 

10:00 PM 4.0 302.S 46 

11:00 PM 2.2 34S.8 42 

12:00 AM 39 

Average 16.7 188.1 52.9 

Maximum 39.5 70.0 

Minimum 1.3 39.0 

For 7 hours, the average wind speed (in bold) ranged from 24.9 - 39.5 mph, which is 

sufficient to entrain and suspend particulate matter and exceeds the suggested 

minimum sustained wind speed threshold in the Draft EPA Guidance on High Wind 

Events. 

Appendix B: Lamar High Wind Events - Data Analysis 251 Page 
The Western Drought Map (see below Figure B-14) indicates severe drought conditions 

in southeast Colorado. 

Figure B-14: Western US Drought Monitor Map - Released November 10, 2011 

U.S. Drought Monitor November 8, 2011 

Valid 7 a.m. EST 

West 

Current 73.00 27.00 18.55 14.96 9.50 2.88 

18.67 15.19 9 60 2.87 

18 82 15.30 1088 5.44 

73.26 26 74 11.98 0 .89 000 0.00 

66.72 3328 jg 04 14.99 930 3.81 

69.02 30.98 5.39 0 .19 0 00 0.00 

p l 2'.ll timap) 

Intensity_: 

DO Abnonnally Dly • 0 3 Droughi- Extreme 

Of Drought • Moderate • D4 Drought • Excepbcl}:JJ 

02 Drougnl - Severe 

The Drought Monitor focuses on broad-scafe conditions. 

Locaf conditions may vary. See accompanying text summary 

for forecast statements. 

http://droughtmonitor.unl.edu 

Appendix B: Lamar High Wind Events - Data Analysis 

USDA 

~ 

Released Thursday, November 10, 2011 

Brian Fuchs, Narlonal Droughr Mitigation Center 

261 Page 
[Blank Page] 
APPENDIX C: Blowing Dust Health 

Advisory Brochure 

Page 95 
cause wheezing. ooughi and respiratory 

irritation in iridividu.aJJ with sensitive 

airways 

What 11 ltelag done lo reduce 

the l'M10 polluti-T 

The city of Lamar h1 implemented 

nurnerOUJ dust and PMIO coniroh over 

ye nd the "Lamar N1tural E'lelllS 

Action Plan" has been developed to reduce 

cm~on of PM IO during high wind 

events The following de9Crl'bes many past, 

present and future efforts designed to 

reduce PMIO emi . 

• Intensive sweeping of paved roads 

within the City limi . 

•Tree planting to Conn windbr 

• Oosure of the East Lamar LandfiD 

during extremely "'1ndy conditions 

• Sodding of numcmut parks and 

recreation an:as 

• tabiliution Ind dust suppres io1J 

along the Burlington Nnrthern/Santa 

Fe rail line 

• Pllcemcnt of highly erodible and 

environme11tally sensitive agrialltural 

lands into I ·term c<>me1V1tion 

If 

• Implert11:111atioo of Land Use Plans 

chat reduce dUit es'll • 011J from 

const1uc:hon adJvilics, gravel pit 

and other open areas 

• Co111rols for industrial ources 

• Programs to reduce ~ns from 

woodsto11es 111d fi""lacea 

W1t1 are th re ltlowhlg duet 

llealtla advisories for tll• 

Lamar area? 

The Lem11 ea i 6Ubjcct. to episodes 

or blowing \lust during periods of high 

wwds and drought conditions During 

otany of these evc:rlls, t amount of du:!! 

in the! all' ha exceeded the mlltonal and 

stat air qU1lity Slandilrda for partiailatc 

maucr, subjecting La ar residents aucl 

vi hors to unhealthy levelM f alr P<lllution. 

What. la Uie l,lowln9 dust advl· .. ,, ,,.,,....., 

Though dust. storms can OCCllr 

thro<1.ghout tho year in 50Uthcastern Co 

,._de), the typicll scuon for '4rg scale or 

ma1o.r blowing dUll episodes iu 1be Lam 

area. is between eptetnber I st llld M.y 

3 Isl Duril18 th· period, lhc Eovirollmen· 

Iii Health Soutbmt ullioe will i5sue 

Mvlsorlea WIN lte 

bnNHlcaat e.n loc•I 

redle •ltltl••• KLMR 

HdKVAY 

lldvisorics 

when 

wmd 

~ 

and 

other 

eondttions arc 

aim:ntly or are forecaMcd to be f'avorablo 

f'or blowing dual ep1 The Natiooal 

Wcalher Service in Pueblo and the Colorado Air Pollutiou Conirol l.>i~tin in 

Denver wiU · t with lhe forecasting 

How to 9et addltlonel 

lnformetlon: 

Lemar Area 

Bnviro11men1al Realth Soothe tern 

Colorado Offices • 336-Bn I 

Ci1y of Lamar · 336-9438 

State Asslstanc:e 

Colorado Air Pollution Control Divisi n -

(303) 692-3221 or 692-31 J l 

What acUo • sllould lte l•ke• 

d11rf119 a blowi•1 dust advl· 

eoryf 

WllL-n ID ad"' sory ta i eel by lhd 

EnV1r011mcntal H~th Southeast oJli 

Lamar 11'111 residenu and vi "tors wm be 

asked to: 

• Avoid outdoor eiten:i d strenu· 

ou1 activities and stay indoors · 

windoWI sblil. 'This is cspecilUy 

important for perllQ v.11.h ooronary 

or re pinrtory illnes , and other 

maj I bc.:Jth problerm 

• Reduce or avoid drivina as lhi 

&llllOl'Jle!!dUSl 

• Stop all woodbumi and open 

burning activities 

• Redu or postpone tilling. plowing, 

c:ontilruc1Jlm and other ldiviti thal 

wiU raise dust 

Wut 11 l'•rtlc:ulete Matter •nd 

how i. rour hHltfl a"9ctodf 

Particulate OIJIUer polluunn con I.I of 

very tiey liquid and 10lid panic! floatill!I 

in 1he air The aiu of the p11rti1:leull! I 

then 10 microns in diameter, or I/7th llte 

thiclrne11 ur. human hair. This Q of 

peiticulate matter 's commQOly refcncd 10 

"PMIO." PM IOcanbernad ora 

mlxtllrc of particles includmg u soat, 

SlllO e, ~ts and metals. ome pemclci 

are c:nplblc of 1111dergoing chemical 

rCllCUons in tile atmospltore and cnn be 

formed from sascs. Bec:awe PM I 0 la '° 

Appendix C: Lamar Blowing Dust Health Advisory Brochure 

BLOWING 

DUST 

HEALTH 

ADVIS 

BROCH 

January 1998 

small 0J1d 15 aipablc of being inhaled deep 

into the lungs, il ls an inlportant pubftc: 

health nnd enviro11menta1 concern · eiflecially in areas !IUSOCfltible to frequent wind 

orms wlien: dust and wilJ can be eully 

lifted into I.be air and uamporttd 

Wl11le larger petticle re kepi from the 

lungs by mechanical meaiu, 51lch as impa.cr 

tioo io the l10!IC, throat and laryl)ll. Cho 

smaller PMIO particles can ip pa 

these ri:spiratory 

defenses end 

peneU'ICC deep 

into, lhc ll.UliS 

and harm ll.Ul8 

1111 ue. 

While 

!'MIO C111 

CllllSO eelth 

pro I m• ror eo,ieryunc, ~lato peop e aro ltk.>it 

vul11e111ble I PM IO' health effc:cu than 

otbm. These itive population ncludc 

dlildu:n, lit~ cldcr1 , time ailfcring from 

asthma or bronchiti cxcrclaing lduJ , 

and ll!Qlc who ''"'"d have bean ll!ld lung 

especially among th elderly. 

Pa111c:ullle matter •Ir poUutto .1s ~ 

dally hannful to peof!le with lun9 di 

sud! u uthma ll!ld chroni obstructi)'ll 

pulmonary di ase whlcb lncl11 ~ chronic 

bronchitis and empbyaema. Lu~ cllieiue i 

the third leading cause of deillll in the 

UDired Statel. l!xpolW e 10 particulal &Jr 

pollution can triaser 1hlna attack! and 

11 P age