1

Nudd, Gregory

From: Bryan Paris [Paris.Bryan@azdeq.gov]

Sent: Thursday, August 01, 2013 4:29 PM

To: Nudd, Gregory

Cc: 'Greg Nudd'; Phil B. Denee; Tai Wallace; Ryan C. Templeton

Subject: FW: coal fired industrial boiler(s) in Pima county?

Categories: Record Saved - Shared

Greg, 

Please see email below for a brief explanation of the data and its origination. The 2008 data were heavily reliant upon the 

2002 NEI data as we used the 2002 data as a base for 2008. This SCC was not a significant emissions source for much 

of the state (as you indicated), therefore this category did not receive much of the focus (historically, we focused on those 

emissions sources that comprised 95% of the overall emissions). For the 2011 NEI, we are relying more on the EPA 

generated data. We will make sure to review this specific category in detail and ensure that the data are reasonable for 

the 2011 NEI. 

Bryan C. Paris

Arizona Department of Environmental Quality

Air Quality Division 

602-771-7665

PPlease consider the environment before printing this e-mail.

From: Tai Wallace 

Sent: Thursday, August 01, 2013 1:18 PM 

To: Bryan Paris 

Cc: Ryan C. Templeton; Phil B. Denee 

Subject: RE: coal fired industrial boiler(s) in Pima county?

Hi Bryan, 

I pulled the 2002 NEI file and this is what I found. 

ß EPA generated data for SCC 2102002000 for all counties except for Maricopa County. EPA data was generated 

using 2001 activity data according to the file: 2002 NEI V3 NP County Level SCC Sums Annual All Polls. Maricopa 

County used Local Agency generated data, using 2002 activity data. 

ß In the 2002 NEI V3, EPA has the total emissions for Pima at 568.2, still at least an order of magnitude higher than 

any other county. Emissions from Maricopa are unavailable (listed as 0) in this version of the NEI. 

ß Roy Huntley is listed as the contact for this data set. 

ß I found no difference in the 2002 emissions and the 2008 emissions for this source category...they are the same.

It seems like the problem is deeper than the 2002 NEI and lies in whatever data EPA used to compile 2001 activity 

levels. It could be a misplaced decimal or something else. I downloaded the access files to the Jdrive under my personal 

folder since I wasn’t sure where to put it...feel free to open it if you like. Hope this helps. 

Best, 

Tai Wallace 

p: 602.771.4455 

From: Bryan Paris 

Sent: Thursday, August 01, 2013 12:31 PM 
2

To: Tai Wallace 

Cc: Ryan C. Templeton; Phil B. Denee 

Subject: FW: coal fired industrial boiler(s) in Pima county? 

Tai, 

Could you check out the 2002 NEI and determine whether this issue originated with the 2002 data? Since we simply grew 

the 2002 data to determine estimates for the 2008 NEI, I’m assuming this issue originated with 2002 NEI data. Feel free 

to work with Phil on this some if you need any clarifications. 

http://www.epa.gov/ttn/chief/net/2002inventory.html#inventorydata 

Bryan C. Paris

Arizona Department of Environmental Quality

Air Quality Division 

602-771-7665

PPlease consider the environment before printing this e-mail.

From: Nudd, Gregory [mailto:Nudd.Gregory@epa.gov] 

Sent: Thursday, August 01, 2013 12:20 PM 

To: Bryan Paris; Ryan C. Templeton 

Subject: RE: coal fired industrial boiler(s) in Pima county?

Bryan, 

I’m getting this from the following web page: 

http://www.epa.gov/ttn/chief/net/2008inventory.html

I downloaded the full nonpoint set and queried out data for Arizona. 

Here’s the data set that seemed off to me: 

AZ Gila 2102002000 Sulfur Dioxide 27.9 TON 

AZ Yuma 2102002000 Sulfur Dioxide 40.2 TON 

AZ Santa Cruz 2102002000 Sulfur Dioxide 16.0 TON 

AZ Apache 2102002000 Sulfur Dioxide 2.8 TON 

AZ Pinal 2102002000 Sulfur Dioxide 59.0 TON 

AZ Cochise 2102002000 Sulfur Dioxide 11.8 TON 

AZ Mohave 2102002000 Sulfur Dioxide 60.7 TON 

AZ La Paz 2102002000 Sulfur Dioxide 6.0 TON 

AZ Graham 2102002000 Sulfur Dioxide 5.9 TON 

AZ Yavapai 2102002000 Sulfur Dioxide 65.1 TON 

AZ Coconino 2102002000 Sulfur Dioxide 43.1 TON 

AZ Pima 2102002000 Sulfur Dioxide 568.2 TON 

AZ Navajo 2102002000 Sulfur Dioxide 11.2 TON 

AZ Greenlee 2102002000 Sulfur Dioxide 0.2 TON 

With that 568.2 tpy in Pima county, this SCC is the second biggest nonpoint source category for SO2 in Arizona. 
3

Greg 

From: Bryan Paris [mailto:Paris.Bryan@azdeq.gov] 

Sent: Thursday, August 01, 2013 11:17 AM 

To: 'Greg Nudd'; Ryan C. Templeton 

Cc: Nudd, Gregory 

Subject: RE: coal fired industrial boiler(s) in Pima county? 

Hey Greg, 

Could you first clarify what version of the NEI you’re referring to? I’m assuming you’re talking about 2008 version 3? 

Bryan C. Paris

Arizona Department of Environmental Quality

Air Quality Division 

602-771-7665

PPlease consider the environment before printing this e-mail.

From: Greg Nudd [mailto:gregnudd@gmail.com] 

Sent: Wednesday, July 31, 2013 5:18 PM 

To: Bryan Paris; Ryan C. Templeton 

Cc: Greg Nudd 

Subject: coal fired industrial boiler(s) in Pima county?

Bryan and Ryan: 

I’m digging into the area source NEI for Arizona and found something that I think may be an error. The NEI is 

showing 568.2 tons of SO2 from coal fired industrial boilers in Pima county. Is that right? Is that from a 

particular source? The NEI has this data element tagged as something that ADEQ submitted. I've had problems 

with the coal-fired boiler data in the NEI before and this is an order of magnitude higher than the other counties, 

so I wonder if y'all could confirm. 

Thanks in advance, 

Greg Nudd 

EPA Region 9 

(Sorry to send from gmail, but my EPA mail client seems to be flaking out this evening.)