GREAT BASIN UNIFIED AIR POLLUTION CONTROL DISTRICT 

RULE 701 – AIR POLLUTION EPISODE PLAN FOR PARTICULATE MATTER 

ADOPTED MARCH 3, 2014 

ENCLOSURE 5 

Public Comments and GBUAPCD Responses 
Los Angeles Department of Water & Power

ERIC GARCETTI

Mayot

Commission

MEL LEVINE, President

WILLIAM W. FUNDERBURK ,R., Vice Presídcnt

JILL BANKS BARAD

M¡CHAEL F, FLEMING

CHRISTINA E. NOONAN

BARBARA E. MOSCHOS, Sectetary

March 3,20'14

Honorable John Eastman, Chairman

Governing Board of the Great Basin Unified Air

Pollution Control District

do Ms. Tori DeHaven

157 Short Street

Bishop, CA 93514-3537

Dear Chairman Eastman:

Subject Proposed Great Basin Unified Air Pollution Control District (District)

Rule 701 - Air Pollution Episode Plan for Particulate Matter (PM), Agenda

Item 6

Thank you for the opportunity to review and comment on the District's proposed

adoption of Rule 701 on Air Pollution Episode Plan for Particulate Matter (PR 701).

The Los Angeles Department of Water and Power (LADWP) respectfully requests that

the District's Governing Board not adopt PR 701 for the reasons discussed below.

LADWP does not understand District's staff reasons for proposing this brand new rule,

in light of the historic agreement our agencies reached last summer under which the

District took sole responsibility to control dust emissions from the Keeler Dunes.

Adoption of this rule would make the District the only District in the state with such a rule

and appears to be entirely unnecessary under the circumstances. At the very least,

LADWP requests the District's Governing Board postpone action on PR 701 untilthe

District staff has had an opportunity to explain it to LADWP staff and LADWP has an

opportunity to propose amendments. Please also include this letter in the administrative

record for this matter.

1.

Plan lSlPl Do Not Reouire the District Adopt PR 701.

The District already has the authority its staff claims it needs to comply with the

CAA. The District staff claims that PR 701 is required to address CAA

Sections 110(aX2XG) and 303. (Board Package , p. 42.) This is not correct. These

CAA sections require that states have authority comparable to the United States

Environmental Protection Agency's (USEPA) authority to halt emissions of air

pollutants causing or contributing to injury of the public or welfare. Only the state

los An0eles llqrcduct telttennial Celebralin0 100 Years tlf Watur lglS-2013

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Chairman John Eastman

March 3,2014

Page 2

Legislature can grant the District the authority required by these CAA sectíons, and

the Legislature has already done so. Health and Safety Code Section 41700,

prohibits sources from emitting any pollutant(s) that cause injury, detriment,

nuisance, or annoyance to the public or that endanger the comfort, repose, health,

or safety of the public, Health and Safety Code Section 42450, et seq,, gives districts

authority to abate emissions from any source violating Health and Safety Code

Section 41700 or any other order, rule, or regulation that prohibits or limits the

discharge of pollutants, consistent with applicable notice and hearing requírements.

Because PR 701 cannot grant the District authority in excess of the existíng Health

and Safety Code it is superfluous and not required for the District to comply with the

CAA.

Further, the CAA requires states to develop emergency episode plans designed to

prevent air pollution in the lntrastate Air Quality Control Regions (IAQCR) from

reaching specific significant harm levels for Sulfur Oxides (measured as SO2),

Nitrogen Dioxide, and Ozone. Under 40 Code of Federal Regulations (CFR) 51.152,

the most comprehensive emergency episode plans are required for Priority I areas,

and less rigorous plans are required for Priority ll areas. No plans are required for

Priority lll areas. Great Basin Valley is classified as a Priority lll area for these

pollutants, and a plan is not required.

The USEPA regulations, 40 CFR 51 .150, do not specifiT any threshold concentration

or significant harm levelfor PM10 and PM2.5. ln USEPA's 2009 PM2.5

lnfrastructure Sl recommends

using a 24-hour entify P¡iority I

areas and a con .4 pg/m3 to

identify Priority ll areas. There is no USEPA recommendation or requirement for a

PM10 episode plan. USEPA has not yet classified any areas in California which

would trigger recommendation for an episode plan for PM2.S.

Based on District's staff recommendation, California Aír Resources Board (CARB)

has announced that it intends to recommend to USEPA that all areas of California

except the Great Basin Valley IAQCR be considered Priority lll with respect to

PM2.5, lt appears from CARB's lnfrastructure SIP that the District also asked CARB

to request that USEPA treat the Great Basin Valley IAQCR as Priority ll based on a

single windblown dust event when a24-hour PM2.5 concentration of 208 pg/m3was

recorded at the Keeler-Cerro Gordo Road monitoring station on December 1, 2011.

CARB evaluated all of the data collected during 2010 through2012, and determined

that there were no other 24-hour PM2.5 concentrations measured in California that

were greater than 140.4 pg/m3.Therefore, the District is purporting to adopt PR 701

to address a single concentration that occurred during a two-year span at Keeler
Chairman John Eastman

March 3,2014

Page 3

Dunes, which the District is solely responsible for addressing under the Section ll.b.i.

of the Settlement Agreement and Release between LADWP and the District

concerning modification to the Phase 7a stipulated order for abatement and the

Keeler Dunes project (Settlement Agreement).

LAqWP.

ln Section 9 of PR 701 , the District states that it "shall investigate the nature of the

problem and determine if abatement actions could be taken to reduce the pollution

levels." The District's purported authority under Section 9 (abatement actions), with

respect to LADWP, is strictly limited. lf the District attempts to require LADWP to

"abate" pollution (i.e. PM10 or PM2.5) in the Keeler Dunes (or other Dunes) areas,

this will violate the release provisions of the Settlement Agreement. Also, exposing

LADWP to potential action from citizens via PR 701 is also a violation of the spirit of

the release provisions, specifically the Dístrict's agreement not to "request,

encourage or join" Ín any other enforcement action by any other agency related to

dust emissions from the Keeler Dunes, regardless of origin. With respect to areas

that are outside the scope of the SettlementAgreement and release, the District

cannot rely on the purported broad "abatement" authority in PR 701 to require

LADWP to control "pollution" without complying with and making the requisite

findings under Health and Safety Code Section 42316.

PB,70l Far Exceeds USEPA Recommendations.

USEPA has not recommended any area adopt a PM10 episode plan. The District is

doing this strictly on its own.

with respect to the proposed PM2.5 episode issuance of

a Stage t health advisory when hourlyPV2. 3and 

a

Stage 2 health advisory when hourly PM2.5 USEPA

already has an Air Quality lndex, or AQl, that is a nationally uniform index for

reporting and forecasting daily air quality which is used by local media - newspapers,

television and radio, and which is based on 24-hour concentrations for PM2.5 and

PM10. The District provides no sound technical basis for establishing an hourty

concentration standard at these levels for PM2.5 (or PM10) or confusing the public

with a different system.
Chairman John Eastman

March 3,2014

Page 4

4.

Plan.

The District is well aware of the problems LADWP has noted with its network

monitoring system and plan. As such, LADWP will briefly summarize its concerns

and incorporates into this letter and the administrative record for PR 701 all of the

letters LADWP has sent to the District and USEPA (copying the District) on any of

the Network Monitoring Plans and its components including the Quality Assurance

Project Plan (QAPP).

USEPA monitoring regulations require the presence of only one air quality monitor

within the Owens Valley Planning Area (OVPA). The District far exceeds this

requirement. The excess monitors are not located near population centers and do

not reflect actual potential population exposure. Therefore, utilizing the data from

these monitors for episode declaration and notifications is meaningless. The District

has also been operating the network monitors without conducting the required audits

to ensure the monitoring data is accurate and without any quality control and

assurance requirements.

LADWP is Not Responsible for Fundinq PR 701 lmplementation.

PR 701 contemplates several new District costs and expenses including, but not

limited to, maintaining "strategic air monitoring stations" for the purpose of

measuring and predicting air pollution episodes, reviewing and dissemination of

episode information, and investigating the nature of the problem and determining if

abatement actions could be taken. LADWP's obligations for funding District activities

is strictly limited by Health and Safety Code Section 42316 to "activities associated

with the development of the mitigation measures and related air quality analysis with

respect to those activities of the city." PR 701 compliance costs and expenses are

not within the scope of costs specified in Health and Safety Code Section 42316.

LADWP is Not Responsible for Kegler Dunes Emissions.

The District's Board Report (p. 43) states: "Dust storm events, like the one at Keeler,

are caused by windblown dust from the anthropogenically dried Owens Lake bed

and are unique to the Owens and Mono Lakes areas in the District." The District staff

is making this assertion without any evidence that Keeler dust storms are the result

of anthropogenic activities involving Owens Lake. LADWP submítted evidence to the

District demonstrating that the alleged anthropogenically activities involving Owens

Lake are not responsible for emissions at Keeler Dunes. The Board may recall that

6.
Chairman John Eastman

March 3,2014

Page 5

the District Board decided to settle the issue of the origin of dust emissions at Keeler

Dunes without deciding the issue. The settlement Agreement states:

Recital (pp. 2-3)- "The District Governing Board has not made any

findings or issued any order concluding that the Keeler Dunes are

anthropogenic in nature and/or caused by LADWP's activities in the

production, diversion, storage, or conveyance of water. The District

Governing Board has not made any findings or issued any order

concluding that LADWP is liable for, or that LADWP's activities in the

production, diversion, storage, or conveyance of water has caused or

contributed to any violations of state or federal air quality standards in

the Keeler Dunes or other dunes areas, including the Swansea and

Olancha Dunes, in the vicinity of Owens Lake."

Section ll.b.i.: "Release for Keeler Dunes: The District forever releases

LADWP from any and all liability under any and allfederal, state and

local laws that the District can enforce and settle, including but not

limited to the Health and Safety Code, those portions of the 2008 SIP

that can be enforced by the District, and fugitive dust emission rules,

for dust emissions, regardless of origin, from the Keeler Dunes,

including but not limited to portions of the Keeler Dunes owned by

LADWP. The District forever agrees not to request, encourage, or join

in an enforcement action by any other agency against LADWP related

to dust emissions from the Keeler Dunes, regardless of origin,

including but not limited to portions of the Keeler Dunes owned by

LADWP. A map defining the geographical boundaries of the Keeler

Dunes is attached as Exhibit 2 and incorporated into this Agreement."

The statement in the District's Governing Board Report is inconsistent with the District

Governing Board's agreement that it has not made any findings or issued any order

concluding that the Keeler Dunes are anthropogenic in nature andlor caused by

LADWP's activities in the production, diversion, storage, or conveyance of water.

Further, to the extent that the District intends to utilize PR 701 to requíre LADWp to

mitigate dust in Keeler Dunes, this would violate the Settlement Agreement, in addition

to Health and Safety Code Section 42316.

Thank you for your consideration of these comments,
Chairman John Eastman

March 3,20'14

Page 6

Please contact me at (2131367-1014 or Mr. Milad Taghavi, Manager of Owens Lake

Regulatory Affairs and Long-Term Planning, at (213) 3or-'1139, ¡f you have any

questions.

Sincerely,

Director of Water Operations

MT:rdn

c: Mr. Ron Hames, District

Mr. Matt Kingsley, District

Ms. Linda Arcularius, District

Ms. Mary Rawson, District

Mr. Byng Hunt, District

Mr. Larry Johnston, District

Mr. Theodore D. Schade, District

Mr. Milad Taghavi

artin L. Adams
Theodore D. Schade

Air Pollution Control Officer

GnE¡.r BeSIru UTIr.IED A.IR POIIUTION COTINOL DISTRICT

157 Short Street, Bishop, California 935L4-3537

Tel : 760-87 2-82LI E-m ail : tsch ade @ gbua pcd.org

}l4ay 7,2014

Mr. Martin L. Adams

Director of V/ater Operations

Los Angeles Dept. of Water & Power

111 North Hope Street

Los Angeles, California 90012-2607

Subject: Great Basin Unified Air Pollution Control District (District)

Rule 701 -Air Pollution Episode Plan for Particulate Matter (PM)

Dear Mr. Adams:

This letter is in response to LADWP's letter submitted as public comment during the Great Basin

Unified Air Pollution Control District's Governing Board Meeting on March 3,2014 in

Mammoth Lakes, California.

LADWP claims to not understand District's staff reasons for proposing this brand new rule. In

consideration of LADWPs comments, the District encourages the LADV/P to review the

District's "Air Quality Episode Plan for Particulate Matter Great Basin Unified Air Pollution

Control District Rule 701 Supporting Technical Document (TSD)." The TSD for Rule T0ldetails

staff reasoning, documents supporting air pollution monitoring data and establishes appropriate

criteria levels for public health alert notifications in order to protect the people and environment

of Alpine, Mono and Inyo Counties form the harmful effects of particulate matter air pollution.

The District reiterates that Rule 701 only requires the District to notifu the public when

particulate matter levels reach unhealthy levels. Rule 701 does not provide Great Basin with any

additional authority or require any actions beyond those currently provided by law.

Thank you for your comments.

Please contact me at (760) 872-8211, if you have any questions.

Sincerely,

Theodo're p. Schade, P.E.

Air Pollutioh Control Officer
Mr. Martin L. Adams

Cc (via e-mail):

John EastmarU District Goveming Board

Ron Hames, District Governing Board

Matt Kingsley, District Governing Board

Linda Arcularius, Dishict Goveming Board

Mary Rawson, District Governing Board

Byng Hunt, District Governing Board

Larry Johnston, District Governing Board

Mr. Milad Taghavi, DWP
Air Quality Episode Plan for

Particulate Matter

Great Basin Unified Air Pollution

Control District Rule 701

Supporting Technical Document 

Prepared by:

Phill Kiddoo

Great Basin Unified Air Pollution Control District

March 3, 2014

Great Basin Unified Air Pollution Control District 

157 Short Street, Bishop, California 93514-3537 

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

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

Air Pollution Episode Plan for Particulate Matter

Great Basin Unified Air Pollution Control District Rule 701

Supporting Technical Document

TABLE OF CONTENTS

            Page

1 Introduction                   1

2 Geographic and Air Quality Setting               3

2.1 Geographic Setting, Weather and Climate

2.2 Major Sources of Air Pollution

2.3 District Air Quality Monitoring Network

   

3 Health Advisory Program Background           7

3.1 Particulate Matter Health Impacts

3.2 Owens Lake Health Advisories

4 Windblown Particulate Matter             10

4.1 Wind, PM10 and PM2.5

4.2 Particulate Matter Size Comparisons

5 Air Pollution Episode Criteria               15

6 Air Quality Improvements               23

7 References

LIST OF APPENDICIES

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

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

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

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

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

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

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

Figure 2.2   District Air Quality Monitoring Network (Map)         6

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

Figure 4.1   Keeler Windblown PM10, 1993 – 2013           11

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

Figure 4.3   Keeler Hourly Particulate Matter Comparisons         13

Figure 4.4   Keeler Daily Particulate Matter Comparisons         14

Figure 5.1 Significant Harm Events for PM10           17

Figure 5.2   Keeler PM10 Episode Criteria Analysis           19

Figure 5.3   Keeler PM2.5 Episode Criteria Analysis             20

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

Tables                   Page

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

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

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

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

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

Introduction

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

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

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

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

Authority to Halt Pollutant Emissions

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

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

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

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

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

environment.

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

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

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

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

Infrastructure SIP, January 23, 2014).

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

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

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

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

plans.  

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

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

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

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

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

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

hour maximum.  

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

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

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

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

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

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

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

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

Episode Plan.

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

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

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

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

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

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

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

per EPA’s 2009 I‐SIP guidance.

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

Priority Level III < 140.5

Priority Level II 140.5 – 210.4

Priority Level I and IA > 210.4

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

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

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

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

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

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

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

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

Standard (NAAQS).

Wildfire Smoke:

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

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

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

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

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

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

   

                                                            

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

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

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

Page 2
2

Geographic and Air Quality Setting

2.1 Geographic Setting, Weather and Climate

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

pressure begins to build back over the area.

2.2 Major Sources of Air Pollution

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

since 2000.  

2.3 District Air Quality Monitoring Network

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

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

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

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

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

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

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

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

Dust ID program.

   

Page 4
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Calendar Year

Owens Lake, Mono Lake and National Annual Max Daily PM10

2000 ‐ 2012

HIGHEST OWENS LAKE HIGHEST MONO LAKE HIGHEST Non‐GBUAP

Figure 2.1.

Page 

5
Great Basin Unified Air Pollution Control District

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Health Advisory Program Background

3.1 Particulate Matter Health Impacts

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

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

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

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

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

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

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

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

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

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

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

3.2 Owens Lake Health Advisories

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

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

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

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

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

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

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

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

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

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

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

found in Appendix B.

Page 7
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L a k e

Alabama

Hills

Lone

Pine

Keeler

Cargago

Olancha

Legend:

!> Continuous Community Monitors

Owens Lake Population Centers

0 1 2

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 1/15/2014 11:43:46 AM Owens Lake Health Advisory Monitors 20140114.mxd

Owens Lake

Figure 3.1. Page 8
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Windblown Particulate Matter  

4.1 Wind, PM10 and PM2.5

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

levels in the Owens Lake area.

4.2 Particulate Matter Size Comparisons

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

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

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

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

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

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

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

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

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

   

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0

500

1000150020002500300035004000

0 5 10 15 

PM10 Daily Average (μg/m3)

Daily Max Hourly Average Wind Speed (m/s)

Keeler PM10 vs. Wind Speed

March 1993 ‐ December 2013

Figure 4.1.

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PM2.5 Daily Average (μg/m3)

Daily Max Hourly Average Wind Speed (m/s)

Keeler PM2.5 vs. Wind Speed

September 2009 ‐ December 2013

Figure 4.2.

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10

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PM10 (μg/m3/hr)

PM2.5 (μg/m3/hr)

Keeler Hourly PM10 vs. PM2.5

September 2009 ‐ December 2013

Figure 4.3. 

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10

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PM10 (μg/m3/day)

PM2.5 (μg/m3/day)

Keeler Daily PM10 vs. PM2.5

September 2009 ‐ December 2013

Figure 4.4.

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Air Pollution Episode Criteria

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

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

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

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

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

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

   

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

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

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

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

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

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

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

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

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

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

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

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Daily Average PM10 (μg/m3)

Significant Harm Events for PM10

1994 ‐ 2013 Significant Harm Day PM10 Concentration

Day After PM10 Concentration

Significant Harm Level for PM10 = 600 μg/m3

Figure 5.1.

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

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

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

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

superior public health protection benefit.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

hour of an upscale pollution event.

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

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

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

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

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

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

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

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

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

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

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

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1 10 100 1000 10000 

PM10 Daily Average (μg/m3/day)

Max Hourly PM10 (μg/m3/hr)

Keeler PM10

March 1993 ‐ December 2013

400 μg/m3

PM10

Stage 1

Episode Criteria

800 μg/m3

PM10

Stage 2

Episode Criteria

150 μg/m3

PM10 NAAQS

600 μg/m3

40 CFR 51.151 Significant Harm Level

Figure 5.2.

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PM2.5 Daily Average (μg/m3/day)

Max Hourly PM2.5 (μg/m3/hr)

Keeler PM2.5

September 2009 ‐ December 2013

350.5 μg/m3

PM2.5 NAAQS

150 μg/m3

PM2.5

Stage 1

Episode Criteria

35 μg/m3

US EPA PM2.5 Significant Harm Level Under Consideration

Figure 5.3.

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Daily Average PM10 (μg/m3)

Mammoth Lakes Wildfire Season PM10

June 1992 ‐ October 2013

Monitor

Down

1992 Rainbow Fire

Monitor Down

Figure 5.4.

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

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

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

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

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

reach emergency episode levels.

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

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Air Quality Improvements

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

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

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

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

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

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

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

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

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

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

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

resulting in further air quality improvements.  

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

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

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

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

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

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

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

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

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

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

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

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

standards for PM‐10.  

   

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REFERENCES

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

Planning Area Demonstration of Attainment State Implementation Plan, GBUAPCD,

Bishop, California, November 16, 1998.

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

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

GBUAPCD, Bishop, California, November 13, 2003.

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

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

GBUAPCD, Bishop, California, January 28, 2008.

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

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

California, November 18, 2011.

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

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

California, November 16, 2012.

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