From: John J. Englander
To: Tax, Wienke
Cc: LEVIN, NANCY ; Law, Nicole ; Lisa M. Tomczak ; Phil B. Denee ; Steve M. Calderon Subject: RE: Payson & Bullhead LMP questions
Date: Tuesday, July 16, 2013 5:18:37 PM
Attachments: image001.png image003.png image005.png image006.png Copy of Bullhead City CDV summary only.xls



### Wienke, Nancy & Nichole,

Please see the following for the requested additional information following our 07/02/13 call. If you need any additional information regarding the questions we addressed on the call, please let me
know.

1.a. The exceptional event package for the August 19, 2011 event should be released for public comment July 15, 2013.

1.b. ADEQ believes the August 19, 2011 event qualifies for exclusion based on the exceptional events policy and, therefore, did not include the calculation of the design value for continued LMP eligibility for the Bullhead City area in the annual report submitted 08/29/12.

1.c. The CDV calculation including the August 19, 2011 event is attached.

2.a.i. Analysis of the change in VMT for both Payson (Gila County) and Bullhead City (Mohave County).

On the Arizona Department of Transportation (ADOT) website at the time the Payson and Bullhead City Limited Maintenance Plans (LMP) were being written (2009) the previous ten year data had some very large swings and the linearly interpolated data showed an annual VMT increase of about 30% for both cities. The large data swings were brought to ADOT’s attention by ADEQ and ADOT promised to review the data. A plot of both the old (1999 to 2008) and the new (2001 to 2010) Gila County data is shown in Figures 1 along with their linear trendlines. The Currently ADOT website was revised and ADEQ was able to use the previous ten year linearly interpolated data to establish an annual VMT increase of 4.3% for Payson (Gila County). This is shown in Figure 2.

### Figure 1

Figure 2



### 2.a.ii. The DV mv 

### value in the Bullhead City document was miscalculated. It appears that only the

### unpaved road portion of the onroad inventory was considered in the submittal. The DV mv 

### calculation should have also included emissions in the area and should have been calculated to be 8.232 μg/m 3 

### . The VMTpi should have been noted as 31.8% as well (based on our original motor vehicle growth projections). With these two numbers, the calculation in Figure 4.2 should be 98 + (0.318 * 8.232) = 100.62.

2.c. A plot of both the old (1999 to 2008) and the new (2001 to 2010) Mohave County data is shown in Figures 3 along with their linear trendlines. The Currently ADOT website was revised and ADEQ was able to use the previous ten year linearly interpolated data to establish an annual VMT increase of 6.3% for Bullhead City (Mohave County). This is shown in Figure 4.

Figure 3

### Figure 4



### 3. Seasonality of Payson Data – ADEQ reviewed quarterly data for the Payson Area and it appears that, seasonally, the first quarter of the year (the one with incomplete data) does not have significantly higher, or lower, observed PM10 concentrations. Please take a look at the following
table for recent data:

Year Quarter No. Of Actual Samples Average PM10 (ug/m 3 ) Max 24-hour Sample 2 nd Highest Sample No. of Actual
Exceedances

2004 1 15 15.7 37 32 0
2 14 19.4 32 24 0
3 14 20.4 53 49 0
4 14 20.6 36 30 0
Annual 57 19.0 53 49 0
2005 1 7 22.9 81 24 0
2 15 19.7 33 29 0
3 14 19.6 33 30 0
4 14 26.2 47 47 0
Annual 50 81
2006 1 15 32.3 66 62 0
2 15 21.4 32 29 0
3 14 14.6 41 22 0
4 16 26.3 43 40 0
Annual 60 23.7 66 62 0
2007 1 14 22.2 43 31 0
2 15 23.5 62 34 0
3 15 18.8 32 31 04 15 27.8 41 39 0
Annual 59 23.1 62 43 0
2008 1 14 22.3 32 30 0
2 15 25.3 43 38 0
3 15 14.2 20 17 0
4 15 25.5 39 39 0
Annual 59 21.8 43 39 0
2009 1 13 25.0 36 34 0
2 16 21.0 40 39 0
3 15 18.7 38 28 0
4 14 23.1 38 34 0
Annual 58 22.0 40 39 0



### John J. Englander ADEQ – Air Quality Division Phone: (602) 771-4781

Please consider the environment before printing this email.

From: Tax, Wienke [ mailto:Tax.Wienke@epa.gov ] Sent: Wednesday, June 19, 2013 2:07 PM To: John J. Englander Cc: LEVIN, NANCY; Law, Nicole Subject: LMP questions



### Hi John –

Even though we are rescheduling the call, here are the remaining questions.

Thanks
Wienke

Wienke Tax Senior Air Quality Planner USEPA Region 9 tax.wienke@epa.gov

415.947.4192

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information and is intended only for the use of the specific individual(s) to whom it is addressed. It may contain information that is privileged and confidential under state and federal law. This information may be used or disclosed only in accordance with law,and you may be subject to penalties under law for improper use or further disclosure of the information in this email and its attachments. If you have received this e-mail in error, please immediately notify the person named above by reply e-mail, and then delete the original e-mail. Thank you.