MEMO to File From: Nancy Levin To: File
Re: July 2, 2013 conference call with John Englander, Arizona Department of Environmental Quality ( ADEQ ) Date: July 2

, 2013

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Questions on the LMPs for ADEQ

– Sent via email 6/19/13 from Wienke Tax, EPA to John Englander, ADEQ Note: ADEQ answers are in bold italics

a. Exceptional Event for August 19, 2011
b. Does ADEQ plan to put together an exception al event package for this event ? YES If so, when do they intend to submit it to EPA ? ADEQ will send.

c. Did ADEQ assume this particular event would be concurred on by EPA and not be used for regulatory purposes ? I s this why a CDV was not calculated in the annual report submitted on 8/29/12 ? ADEQ will review and send.
d. Can ADEQ calculate a CDV for 2011? ADEQ will review and send.

2. Motor Vehicle Growth Analysis

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a. Bullhead City
i. The 30% VMT increase over a 10

- year period for the area seems very large from an
area that qualified for an LMP due to project ed low growth in motor vehicle
emissions

. Where did this percentage co me from? ADEQ will review and send.
ii. How was the DVm (motor vehicle DV ) calculated ? Is it 5.0 ug/m3 or 8.232 ug/m3? ADEQ will review and send.
b. Payson M otor Vehicle Growth Analysis
i. The 24% VMT increase over a 10

- year period for the area seems very large for an
area that qualified for an LMP due to projected low growth in motor vehicle
emissions. Where did this percentage co me from? ADEQ will review and se nd.
3. Data Completeness

- Payson

a. W hy was the data capture below 50% in 2005 1st quarter? ( ADEQ provided this on 6/17/13

– largely due to lab weighing issue. )

4. Emission Inventory

– Industrial Sources

a. For Payson, industrial source data was collected in an “ annual survey .” For BHC, the data was obtained from reported 2008 emissions.
i. Did the difference in methodology (if that’s the case) result in any substantive
differences in the emissions inventories? No

– ADEQ says all the data was from point source permits

. ii. What type of data did the Payson survey ask for? Did all the main sources of industrial emissions respond with the key data? ADEQ says t he “survey” was not actually questionnaire to industry. ADEQ did internal review of permits.5. Control measur es in the 2002 LMPs

– Confirm with ADEQ that the LMP Updates do not rely on

additional control measures to continue to maintain the NAAQS for PM10 and that the LMPs have
not revised these measures

. ADEQ says b oth relied on paving activities for reductions, which took place before the 2002 LMP. No additional local measures relied upon.

6. Emission Inventory

– Unpaved Roads

a. Why was there a lack of localized data ? ADEQ says t here are many unpaved roads, and ADOT does not keep ADT for unpaved roads. ADT is calcul ated for most paved roads.

7. Why was there early implementation of the opacity standard if not needed? ( Payson p23)

. There was a change in a statewide rule, updated for any area that was NAA to implement opacity standard (reduced from 40 to 20%)

On the July 2, 2013 call we asked ADEQ to send us data on the s easonality of Payson Data

– ADEQ will
send.