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 exceptional 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? Is 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 --

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 projected low growth in motor vehicle 

emissions. Where did this percentage come 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 Motor 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 come from? ADEQ will review and send.

3. Data Completeness - Payson

a. Why 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 the “survey” was not 

actually questionnaire to industry. ADEQ did internal review of permits. 
5. Control measures 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 both 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 there are many unpaved roads, and 

ADOT does not keep ADT for unpaved roads. ADT is calculated 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 seasonality of Payson Data – ADEQ will 

send.