Ungvarsky, John 

From: Ungvarsky, John 

Sent: 

To: 

Thursday, June 19, 2014 8:40AM 

Ungvarsky, John 

Subject: Email record re YSAQMD rules 

From: Matt Jones <mjones@ysaqmd.org> 

Sent: Wednesday, June 18, 2014 4:59PM 

To: Ungvarsky, John 

Subject: RE: Following Up to our May 30 call 

The 1994 inventory for YSAQMD was approximately 0.46 tpd VOC. 

From: Ungvarsky, John [mailto:Ungvarsky.John@epa.gov] 

Sent: Wednesday, June 18, 2014 4:01 PM 

To: Matt Jones 

Subject: RE: Following Up to our May 30 call 

Hi MattThis is very helpful. 

RE 2.26, are you saying the reduction or the inventory was 0.46 tpd? 

Thanks 

John Ungvarsky 

Environmental Scientist 

USEPA, Region 9 

75 Hawthorne St. (AIR-2) 

San Francisco, CA 94105 

415-972-3963 

510-667-9743 (alternate work site) 

From: Matt Jones [mailto:mjones@ysaqmd.org] 

Sent: Wednesday, June 18, 2014 3:57PM 

To: Ungvarsky, John 

Subject: RE: Following Up to our May 30 call 

JohnIn response to your questions: 

1. The 80% reduction was from a 0.23 tpd inventory for our district from this category in 1999. 

2. For Rule 2.26 -In the staff report for the most recent amendment, it specifically gives an estimate of 0.12 tpd 

VOC reductions from the amendment to Rule 2.26 alone. However, it looks to me like that was a combination of 

lowered VOC limits for the coatings (coatings limits were kept in the rule) and reductions in VOC from the 

solvents used by the automotive refinishing industry in our district (the solvent limits were taken out of the auto 

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refinishing rule, and lowered solvent limits were added to the district solvent rule). So essentially the 0.12 

represents lowered limits for the coatings and solvents used by auto refinishers in the YSAQMD. 

3. For Rule 2.26- the estimated VOC from this category in our district in 1994 was 0.46 tpd. 

OK, hopefully that clears things up a bit. I understand that #2 (above) might be a little confusing, but if so, just let me 

know and I'll try and do a better job explaining. 

Thanks, 

Matt 

From: Ungvarsky, John [mailto:Ungvarsky.John@epa.gov] 

Sent: Wednesday, June 18, 2014 2:28PM 

To: Matt Jones 

Subject: RE: Following Up to our May 30 call 

Thanks MattSee my comments below. 

Thanks 

John Ungvarsky 

Environmental Scientist 

USEPA, Region 9 

75 Hawthorne St. {AIR-2) 

San Francisco, CA 94105 

415-972-3963 

S10-667-9743 (alternate work site) 

From: Matt Jones [mailto:mjones@ysagmd.orgl 

Sent: Wednesday, June 18, 2014 2:15 PM 

To: Ungvarsky, John 

Subject: RE: Following Up to our May 30 call 

Hi JohnFunny, I was just working on this when you sent the email. .. 

Here is what I have found so far: 

For Rule 2.39- We did not estimate a VOC reduction in the 1999 staff report, but we did estimate that we would reduce 

total emissions from this category by 80% as a result of the rule adoption. JU comment: 80% reduction from_ tpd 

estimate in inventory. 

For Rule 2.26- For the most recent rule amendment (2008), we estimated a 0.12 rons-per-day VOC reduction as a result 

of the rule amendment. JU comment: The 0.12 tpd is not from 2.24/2.31, right? For the prior rule versions, we did not 

estimate total VOC reductions. In the analysis that was conducted for the 1994 Regional Ozone Attainment Plan, we did 

estimate that we would accrue a 75% total reduction in VOC from this category as a result of the 1994 rule. JU comment: 

75% reduction from_ tpd estimate in inventory. 

OK, 1 hope that helps- please just let me know if that's not the kind of info you are looking for. 

2 
Matt 

From: Ungvarsky, John 

Sent: Wednesday, June 11, 2014 10:17 AM 

To: 'Matt Jones' 

Cc: Tong, Stanley 

Subject: RE: Following Up to our May 30 call 

Hi MattThanks for getting back to me. I think we are almost on the same page, but not quite. 

For Rules 2.26 and 2.39, I am also trying to figure out the reductions from the pre-2002 rules already credited in the 

plan. 

Rule 2.26 was revised 4 times (i.e., Nov 9, 1994; Aug 13, 1997; May 14, 2008; and Dec 10, 2008) compared to the Apr 

1994 version in the SIP. Is the 0.058 tpd from the Dec 2008 revision? Assuming so, what were the reductions from the 

Nov 1994 and Aug 1997 changes? 

For Rule 2.39, what were the reductions from the initial adoption in Feb 1999? 

Please let me know if you'd like to discuss further. 

Thanks 

John 

From: Matt Jones [mailto:mjones@ysaqmd.org] 

Sent: Wednesday, June 11, 2014 9:53AM 

To: Ungvarsky, John 

Cc: Tong, Stanley 

Subject: RE: Following Up to our May 30 call 

Hi JohnI looked into the emissions reductions associated with the rules you listed. For the most recently adopted ozone 

attainment plan in our nonattainment area (adopted in 2009), a base year of 2002 was used, but emissions forecasts 

extended out to 2018 in order to demonstrate attainment. 

Based on the relevant staff reports, emission reductions from the rules are as follows: 

Rule 2.26- Auto Refinishing: We estimated 0.058 tons per day of VOC reductions from this rule by 2018. These future 

reductions were accounted for in the most recent ozone attainment plan. 

Rule 2.39- Wood Products Coating Operations: The emissions reductions associated with this rule would h9ve been 

incorporated into the 2002 emissions baseline in the most recent ozone attainment plan, since the VOC limits went into 

effect prior to 2002. The rule was amended in 2008, but the amendment didn't lower VOC limits for coatings, it just 

removed the VOC limits for solvents and put those limits in a separate solvent rule. 

Rule 2.44- Central Furnaces: This rule was adopted after the emissions forecasting was conducted for the most recent 

ozone attainment plan. Consequently, the emission reductions are not reflected in the Plan's 2018 emissions 

forecast. We estimate that the rule will result in NOx reductions of 0.026 tons per day by 2018. 

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01<, I hope that helps to answer your questions- please just let me know if there's anything else I can clarify. 

Regards, 

Matt Jones 

Supervising Air Quality Planner 

Yolo Solano AQMD 

530-757-3668 

mjones@ysaqmd.org 

From: Ungvarsky, John [mailto:Unqvarsky.John@eoa.gov] 

Sent: Monday, June 09, 2014 9:08 AM 

To: Matt Jones 

Cc: Tong, Stanley 

Subject: Following Up to our May 30 call 

Hi MattAs a follow up to our May 30 call, can you please provide me with an estimate of the reductions achieved from 

the following measures? I need this information for the notice of proposed rulemaking I am working on for the 

Sacramento ozone plan. My understanding is that reductions from Rules 2.26 and 2.39 have already been 

credited in the baseline 2018 emissions inventory in the Sacramento ozone nonattainment area plan. 1 also 

understand that reductions from Rule 2.44 have not been credited in the 2018 baseline. Are these also your 

understandings? 

• Rule 2.26 (reductions compared to Apr 1994 version in the SIP. See 

· http://yosemite.epa.gov/R9/r9sips.nsf/AgencyProvision/4F6F8C07558E6B41882569A5006EE2D4/$file/ 

YS+2.26.PDF?OpenEiement) 

• Rule 2.39 (not in the SIP) 

• Rule 2.44 (not in the SIP) 

Please let me know when you might be able to provide this information to me. 

Thanks 

John Ungvarsky 

Environmental Scientist 

Air Planning Office, Air Division 

USEPA Region 9 

415-972-3963 (primary office) 

510-667-9743 (alternate work site) 

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