Summary of Oregon DEQ’s Response to Exceptional Events and Natural Events
October 20, 2004
Wildfire Natural Events Action Plan
Oregon DEQ was required by EPA to complete a Natural Events Plan because of PM2.5 daily and annual violations in Klamath Falls caused by the massive 2002 forest fires. The plan responds to a need for better human-health protection associated with natural events such as wildfires. The plan outlines actions in the following categories:1) public notification and education, 2) minimizing public exposure, 3) abating or minimizing controllable sources, 4) implementing mitigation measures and ,5) periodically evaluating the plan.
1) Public Notification and Education
New Public Notification Process: In addition to the 24-hour AQI notification program, ODEQ has developed a communication plan and is in the process of developing a notification system using shorter term action levels to better reflect the needs of public information.
a)Coordination with Oregon Department of Forestry:
ODEQ will expand our coordination with Oregon Department of Forestry (ODF). Qualified meteorologists are employed by ODF to address smoke management forecasting. A natural extension of their duties is to provide a wildfire smoke forecast which will assist ODEQ in issuing advisories based on smoke impacts. ODF has agreed to help ODEQ and local health agencies by forecasting smoke movement during the wildfire season, tracking major wildfire smoke and being part of a communications network to predict the drift of smoke from a wildfire event.
b)Planning and Rulemaking Process: At this time, there are no plans for rulemaking or other State Implementation Plan (SIP) additions.
2) Minimize Public Exposure
a)Monitoring: The Federal Clean Air Act requires States to establish air quality surveillance systems. The Oregon DEQ laboratory has a surveillance system consisting of a network of monitoring stations measuring ambient concentrations of criteria pollutants for which standards have been established. ODEQ also has real time visibility monitors which are used to monitor particulate levels throughout the state. The information is updated to internet hourly.
b)Air Quality Advisory Program: Staff at ODEQ and ODF will be alerted when smoke enters a community by using ODEQ’s monitoring data, public notification, fire reports and other information sources. ODF staff will be alerted by their forestry contacts if smoke from a large fire may impact a local community. In both cases, staff from each agency will coordinate activities and share information. ODEQ will use this shared information, and communicate with the local health officials.
c)Fire and Meteorological Forecasts: ODEQ can provide more real-time and rapid response to pollution events in a particular community. The Oregon Department of Forestry will be contacted through their meteorological center to determine the potential of wildfire smoke impacting Oregon cities in the future.
d)Health Effects Documents: ODEQ established a web site entitled Wildfire Smoke. The website is periodically updated with information or fact sheets related to health and wildfire smoke.
3) Abate or Minimize Contributing Sources
a)Wildfire Smoke Impact and Requests for Voluntary Curtailment: Oregon Department of Forestry will be consulted when there is a potential for wildfire impacts and pollution thresholds will be used to characterize the impact of the wildfire smoke in the form of an advisory.
b)Wildland Fire Use: The Federal Wildland and Prescribed Fire Management Policy requires federal land managers to decide within two hours of discovering a fire whether to manage the fire for resource benefit or suppress the fire (USDI and USDA, 1998).
c)National Fire Plan: The National Fire Plan implements activities in five key program areas in order to respond to the severe wildfires, reduce their impacts on rural communities, and enhance firefighting capabilities in the future.
d)Wildland Urban Interface Communities: The interface between areas of urban and forest use is called the Wildland Urban Interface (WUI). State and federal forestry and land management agencies provide grant money to communities to mitigate fuel buildup and fire hazard in the WUI.
e)ODEQ Chipper Tax Credit: ODEQ offers a chipper tax credit on the Oregon income tax to encourage homeowners and businesses to invest in removing vegetation surrounding their homes and properties. Current credit is 35% of the Oregon tax burden.
4) Identify, Study and Implement Mitigating Measures
a)Review and Update State Forestry Smoke Management Program: Currently, ODF is reviewing their entire Smoke Management Program. This is a periodic review conducted by ODF every five to 10 years.
b)Web Updates: ODEQ is in the process of creating an Air Quality Index (AQI) website for wildfire exposure levels using one hour average health categories instead of the standard 24 hour average.
5)Periodic Evaluation
The wildfire Natural Events Action Plan will be evaluated as needed but no later than five years from the date of this plan.
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Data Flagging
If ODEQ determines that a sample exceedence is caused by a exceptional event or natural event then we will use the process outlined in the EPA Exceptional Events Guidance EPA-450/4-86-007 to prove that data was impacted by highly localized and unrepresentative sources such as a portable generator situated under a carbon monoxide probe or natural events such as forest fires. Based on this guidance, Region 10 calls for proof by submitting:
- Photos and documentation such as emails from eyewitnesses.
- Where pertinent, wind speed, wind direction, and pollutant levels graphed together to show cause and affect.
- Newspaper articles if the event is slightly larger such as a building fire.
- For small forest fires, satellite photos should be submitted.
5. Background information to show what the non impacted concentration might be.
This guidance works well for small isolated events but is burdensome for wide spread elongated events such as the Oregon 2002 forest fires. These 2002 forest fires burned over one million acres from early July through early September. The fires resulted in elevated PM10 and PM2.5 values all over southwest Oregon including the cities of Grants Pass, Medford, Klamath Falls, and Lakeview. Just after the fires, EPA Region 10 required ODEQ to follow the standard procedure to document the event for each city for each day impacted. EPA also wanted background particulate levels from previous years for comparison. By compiling all this evidence ODEQ was able to prove to EPA that over 100 samples had elevated PM2.5 and PM10 levels caused by the forest fires. This project required about two months to complete.
In the spring of 2004, Alaska DEC was also faced with flagging numerous samples because of massive forest fire impacts. At their request ADEC, ODEQ, IDEQ, WDOE, and EPA Region 10 met and agreed that extensive ODEQ 2002 forest fire proof was not necessary and was overly burdensome. The states also reminded EPA that they were facing budget cuts and reduced or shifting resources. EPA agreed with the states that massive forest fires were the obvious cause of coinciding elevated pollution levels and the proof for massive natural events would only consist of:
1. Accounts of the fire issued by the NationalFireCenter
2. Visibility information on the days impacted
3. Newspaper articles which describe the effects of the fire in the impacted area.
PM2.5
ODEQ has received written agreement from EPA Region 10 that PM2.5 data will be flagged and treated in the same way as PM10 data under the Exceptional Events and Natural Events Policy, pending EPA update to those policies.