From: Amir Fanai

To: LEVIN, NANCY

Cc: David Fairley ; dburch@baaqmd.gov Subject: FW: Annual v. winter inventory

Date: Wednesday, November 20, 2013 10:39:49 AM

Attachments: exceedances by month 2006-2012.xlsx



### Hi Nancy Thanks for your call yesterday. For planning inventories, summer is considered May through October and winter is November through April. Below is an email exchange between David Burch and John Ungvarsky on the winter vs annual inventory. And attached is an Excel file from David Fairley showing exceedances of the 24-hour PM2.5 NAAQS by month. Almost all exceedances occur Nov-Feb. The rare exceptions are generally from wildfires. Hope this information is sufficient and useful.

Amir Fanai

From: David Fairley Sent: Wednesday, November 20, 2013 10:24 AM To: David Burch; Amir Fanai Subject: RE: Annual v. winter inventory



### Attached should be an Excel file with a chart showing exceedances of the 24-hour PM2.5 NAAQS by

month. Almost all exceedances occur Nov-Feb. The rare exceptions are generally from wildfires.

From: David Burch Sent: Wednesday, November 20, 2013 10:17 AM To: Amir Fanai Cc: David Fairley Subject: FW: Annual v. winter inventory



### Amir

FYI, below is an email exchange that I had w John Ungvarsky @ EPA back in March 2012. (I didn’t find any email msgs from ARB staff on this issue.)

DB

From: John Ungvarsky [ mailto:Ungvarsky.John@epamail.epa.gov ] Sent: Thursday, March 22, 2012 3:25 PM To: David Burch Cc: Ginger Vagenas Subject: Re: Annual v. winter inventory

If you have documentation showing the PM 2.5 peaks are occurring during a season (e.g., winter), then yes, you should use a seasonal inventory that coincides with the peaks. This assumes it's conclusive to all (including ARB and EPA) that the PM 2.5 peaks are routinely occurring during the same season you want to use, and the Bay Area does not have any "exceptional events" causing competing high peaks in other seasons.Thanks

John Ungvarsky Environmental Scientist USEPA, Region 9 Air Planning Office

415-972-3963

From: David Burch < dburch@baaqmd.gov >

To: John Ungvarsky/R9/USEPA/US@EPA

Date: 03/22/2012 02:13 PM Subject: Annual v. winter inventory

John

We had been planning to submit an annual average inventory for PM2.5 & its precursors for our 2010 attainment year. However, as you’re probably aware, the March 2, 2012 implementation guidance memo from Stephen Page includes a discussion about annual v. winter inventory, and makes the point that the 24-hr NAAQS is aimed at protecting against peak exposures. Given the fact that our highest PM readings almost always occur during the winter months, it may make sense for us to submit a winter inventory instead.

ARB staff says that this is something we should decide in consultation w EPA.

Does EPA have any preference on this? If you’d like to discuss this in detail, I should probably set up a call that
would include our inventory experts.

Thanks.

Dave

From: Melgoza, Elizabeth@ARB [ mailto:emelgoza@arb.ca.gov ] Sent: Monday, March 19, 2012 10:00 AM To: David Burch Cc: Zulawnick, Sylvia@ARB; Velasco, Patricia@ARB Subject: RE: information from today's call (Thanks!)

Hi Dave,

I wanted to get back to you on a couple of issues we discussed on last week’s call. Patricia mentioned the EPA sponsored PM2.5 source testing that included condensables in the Bay Area. Barry Young worked on this with EPA so I would check with him to get that data.

As to whether you should use the annual or the winter inventory for the limited SIP is a decision between the District and EPA. The District has the option of using the annual inventory or a seasonal inventory (winter) since this is the time when all of the exceedances occur. If you wanted to use the winter emission inventory additional analysis would be required. I would encourage you to work with EPA on which inventory they would prefer. Please see the section “ The Use of Seasonal Versus AnnualInventories” in the document below for more information.

http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24-hr_pm2.5_naaqs.pdf

From: David Burch [mailto:dburch@baaqmd.gov] Sent: Friday, March 16, 2012 3:23 PM To: Melgoza, Elizabeth@ARB Cc: Zulawnick, Sylvia@ARB; Velasco, Patricia@ARB Subject: RE: information from today's call (Thanks!)

Thanks, Lizzy! You & Sylvia & Patricia earn top honors for your support and quick responsiveness.

Thanks for making my life easier. Have a good weekend!

Dave

From: Melgoza, Elizabeth@ARB [mailto:emelgoza@arb.ca.gov] Sent: Friday, March 16, 2012 2:56 PM To: David Burch Cc: Zulawnick, Sylvia@ARB; Velasco, Patricia@ARB Subject: information from today's call

Hi Dave,

Gabe will have the VOC and ammonia emission inventory available in a few days.

The language in the CFR that talks about the requirements for public hearing can be found here (40 CFR 51.102) http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol2/pdf/CFR-2011-title40-vol2-sec51-102.pdf

Please let me know if you have any other questions.

Lizzy Melgoza Air Pollution Specialist

California Air Resources Board (916)-322-6161