**CLASS I APPLICATION TECHNICAL REVIEW**

FOR:

**Nellis Air Force Base**

Nevada Test and Training Range

## Lincoln & Nye Counties, Nevada

**Minor Revision** to Class I Operating Permit #AP9711-1233

#### Application Log Numbers 06AP0339

![](media/image1.jpeg){width="4.447222222222222in"
height="2.8847222222222224in"}

BY

STATE OF NEVADA

DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES

DIVISION OF ENVIRONMENTAL PROTECTION

BUREAU OF AIR QUALITY

Tobarak Ullah, P.E.

Staff Engineer

**July 06, 2006**

**1.0 INTRODUCTION**

The permittee (US Air Force, Nellis Air Force Base) has submitted an
application requesting Minor Revision to their existing Class I Air
Quality Operating Permit #AP9711-1233 on April 13, 2006 to the Nevada
Division of Environmental Protection, Bureau of Air Pollution Control
(NDEP-BAPC).

*[Refer to the Technical Review dated October 7, 2003 (edited
12/03]{.underline}):*

The Nevada Test and Training Range (NTTR) is a closed, restricted-access
United States Air Force facility located in Nye, Lincoln and Clark
counties. Those portions of the range that fall within Clark County are
excluded from this application and are managed by the Clark County
Department of Air Quality Management. The portions of the range that
fall into Nye and Lincoln Counties are regulated through the Nevada
Division of Environmental Protection, Bureau of Air Pollution Control
(BAPC). The Standard Industrial Classification (SIC) code for all Air
Force operations is 9711 (National Security). Industrial and maintenance
functions within the northern NTTR are mostly confined to three
centralized operating locations. These operations are designated as the
Tonopah Test Range (TTR), the Tonopah Electronic Combat Range (TECR) and
the Tolicha Peak Electronic Combat Range (TPECR). TTR is the main
industrial area where the main airfield and major support facilities are
located. The TECR compound is located approximately 20 miles to the east
of the main base. The TPECR compound is located approximately 30 miles
southwest of TTR.

NAFB has requested that national emergency provisional language be
included as part of their permit. This language would allow NAFB to
exceed permitted throughputs and limits when a specific national
emergency provision was invoked. However, since all equipment is
permitted at maximum throughputs and the equipment emissions are based
on 8,760 hours of operation per year, BAPC does not see a need to
include this language. The only facility that might be limited is the
paint booth, however, BAPC does not have sufficient evidence to view the
paint booth operations as an essential national security element to
NAFB's mission. Therefore, the permit contains no emergency provisions
for increasing emissions above proposed permit levels.

The permittee is requesting for a minor revision to replace the existing
rock crushing equipment. The permittee indicated that the existing rock
crushing equipment has exceeded the expected life of the equipment and
can no longer be relied upon to perform up to the rated maximum
capacity. Due to the unreliability of the existing equipment, the
permittee is replacing the equipment with a new Eagle Rock Crusher
1200-25CC. An Eagle Rock Crusher is a fixed configuration system
consisting of a double screen, hopper, crusher, two conveyors, and
powered by a 335 horsepower diesel engine (which is attached to the
crusher system).

The new rock crusher system will replace the following Emission Systems
currently listed in the existing permit as: A. System 01; B. System 02;
F. System 06; H. System 8; I. System 9; O. System 15; R. System 18; S.
System 19; T. System 20; U. System 21; V. System 22; W. System 23; X.
System 24; Y. System 25; AA. System 27; AB. System 28; AC. System 29;
and AG. System 33 (a total of 34 emission units). The details of the
deleted emission units are included at the end of the permit.

The minor revision also includes the addition of a stationary 181
horsepower generator at Gap Filler to operate a radar site. The
generator is replacing an old generator that has exceeded the expected
life of the generator (currently listed in the existing permit as an
insignificant activity, emission unit #IA1.045). Pursuant to NCA
445B.288.(g), the new generator will also be considered as an
Insignificant Activity.

[]{.mark}

Pursuant to NAC 445B.3425.1., the application submitted by the permittee
qualifies as a Minor Revision to a Class I Operating Permit. After
preliminary review of the submitted materials, the NDEP-BAPC has
determined that the application is administratively complete (NAC
445B.3395.5.). The Notification of Initial Completeness letter was
mailed to the permittee and a copy including minor revision application
to U.S. EPA on April 28, 2006.

The NDEP-BAPC has determined that the minor revision application
submitted by the Permittee does not result in a significant change
(refer to the attached spreadsheet "Summary of Facility-wide total PTE
estimated emissions") in air quality at any location where the public is
present on a regular basis. Therefore, the requirements to provide a
30-day public notice participation and comment period do not apply (NAC
445B.3395.8.).

The NDEP-BAPC has provided a copy of the Application Technical Review
document of the Minor Revision Application and the Proposed Operating
Permit (reflecting all requested changes) to the U.S. Environmental
Protection Agency (EPA), Region IX to initiate their 45-day review
period. If approved, the issuance of the revised Class I Operating
Permit (#**AP9711-1233**) will allow the permittee to continue operation
of their existing processes.

**2.0 DESCRIPTION OF PROCESS**

*[Refer to the Technical Review dated October 7, 2003 (edited
12/03]{.underline}):*

**2.1 Aggregate Processing**

NAFB processes aggregate at numerous locations throughout the NTTR.
Aggregate is processed to construct roads, runways, etc., for operations
supporting NAFB's various national defense missions. As such, NAFB needs
flexibility to move equipment around the NTTR between multiple borrow
pit locations. Additionally, NAFB needs flexibility in how the equipment
is configured at each point. As such, BAPC determined that each piece of
aggregate processing equipment would be independently permitted instead
of any specific configuration. This would allow the highest degree of
flexibility to NAFB for aggregate processing. There are several emission
units consisting of conveyors, crushers, hoppers and screens. Included
in this number is a wash plant of fixed configuration consisting of a
hopper, washing screen and conveyor.

**2.2 Surface Coating Operations**

NAFB has one paint booth for the coating of miscellaneous metal parts
and pieces. The surface coating facility does not conduct any activity
regulated under 40 CFR Part 60 (NSPS), nor is it subject to 40 CFR Part
63 (MACT). The paint booth is not major for HAPs and would, therefore,
not be subject to any future MACT promulgated for surface coating of
miscellaneous metal parts and pieces.

**2.3 Fuel Operations**

[Fuel Loading Operations]{.underline}

TTR has a gas station with gasoline and diesel loading operations and
six JP-8 hard stands. TTR also has a JP-8 and Diesel loading rack. In
addition, there are two other gas stations, one at TPECR and one at
Cedar Peak. These stations load only gasoline and diesel. The only
permittable activity is the gasoline loading at the TTR gas station. The
rest of the operations have been determined to be insignificant.

[Fuel Dispensing Operations]{.underline}

TTR has four diesel and eight gasoline dispensers. JP-8 fuel is
dispensed from tanker truck to AGE and aircraft. TPECR and Cedar Peak
each have one diesel and one gasoline dispenser. These activities have
also been determined to be insignificant.

[Tank Farm]{.underline}

The only tank farm is in TTR. There are two diesel and four JP-8 storage
tanks. The diesel tanks have a storage capacity of 136,000 gallons each;
the JP-8 tanks have a storage capacity of 300,000 gallons each.
Emissions from the diesel tanks are controlled via a pressure relief
valve. Emissions from the JP-8 tanks are controlled via an internal
floating roof.

**2.4 Surface Area Disturbance**

NTTR has surface area disturbances in excess of 20 acres. NAFB submitted
a dust control plan on December 19, 2002 with the Minor Modification
application. The dust control plan covers activities conducted at
specified borrow pits.

**2.5 *[Minor Revision]{.underline}***

The permittee is requesting for a minor revision to replace the existing
rock crushing equipment. The permittee indicated that the existing rock
crushing equipment has exceeded the expected life of the equipment and
can no longer be relied upon to perform up to the rated maximum
capacity. Due to the unreliability of the existing equipment, the
permittee is replacing the equipment with a new Eagle Rock Crusher
1200-25CC. An Eagle Rock Crusher is a fixed configuration system
consisting of a double screen, hopper, crusher, two conveyors, and
powered by a 335 horsepower diesel engine (which is attached to the
crusher system).

The permittee stated that the rock material is loaded by front end
loader or bull dozer into the screen which dumps into the system hopper.
The hopper then drops the rock material into the crusher which crushes
the rock into the required size and drops the rocks to the conveyor. The
conveyor then drops the rock to the second conveyor which drops the rock
to the stockpile. The rock crushing equipment emits PM /PM~10~ emissions
which are controlled with water sprays.

The new rock crusher system will replace the following Emission Systems
currently listed in the existing permit as: A. System 01; B. System 02;
F. System 06; H. System 8; I. System 9; O. System 15; R. System 18; S.
System 19; T. System 20; U. System 21; V. System 22; W. System 23; X.
System 24; Y. System 25; AA. System 27; AB. System 28; AC. System 29;
and AG. System 33 (a total of 34 emission units). The details of the
deleted emission units are included at the end of the permit.

The minor revision also includes the addition of a stationary 181
horsepower generator at Gap Filler to operate a radar site. The
generator is replacing an old generator that has exceeded the expected
life of the generator (currently listed in the existing permit as an
insignificant activity, emission unit #IA1.045).

The proposed minor revision will not result in any increases in
permittee's existing permitted emission limits.

**3.0 APPLICABLE REQUIREMENTS**

[Minor revision to add and delete some systems]{.underline}: The
proposed minor revision will not result in any significant increases
(rather it decreases) in permittee's existing permitted emission limits.
All the existing applicability requirements stay same, with the
exception that the new emission units will be subject to applicable NAC,
ASIP, and NSPS Subpart OOO requirements.

*[Refer to the Technical Review dated October 7, 2003 (edited
12/03]{.underline}):*

Applicable requirements are those regulatory requirements that apply to
a stationary source or to emissions units contained within the
stationary source. In Nevada\'s program, the regulations governing the
emissions of air pollutants from which the applicable requirements
originate, are derived from four categories of regulations. These four
categories consist of the requirements contained in the Nevada Revised
Statutes (NRS), the Nevada Administrative Code (NAC), the Applicable
State Implementation Plan (ASIP), and the Code of Federal Regulations
(CFR), contained in various Parts within Title 40.

**3.1 GENERALLY APPLICABLE REQUIREMENTS**

Of the four categories of regulations governing emissions of air
pollutants, there are many generally applicable requirements that apply
to stationary sources and emission units located at a stationary source.
A comprehensive summary of all the generally applicable permit
requirements is contained in Sections I through V of the proposed
operating permit provided in Attachment 2.

**3.2 SPECIFIC APPLICABLE REQUIREMENTS**

The remainder of this section of the review will focus on specific
applicable requirements associated with each emission unit or process at
the NTTR generating station. A list of the emission units, as identified
in the application, and a summary of the specific applicable
requirements is contained in Table 3.2.1.

+-----+-----------+--------+---------+-------+-------+------+-------+
| TA  |           |        |         |       |       |      |       |
| BLE |           |        |         |       |       |      |       |
| 3.  |           |        |         |       |       |      |       |
| 2.1 |           |        |         |       |       |      |       |
| ‑   |           |        |         |       |       |      |       |
| L   |           |        |         |       |       |      |       |
| ist |           |        |         |       |       |      |       |
| of  |           |        |         |       |       |      |       |
| Em  |           |        |         |       |       |      |       |
| iss |           |        |         |       |       |      |       |
| ion |           |        |         |       |       |      |       |
| Un  |           |        |         |       |       |      |       |
| its |           |        |         |       |       |      |       |
| and |           |        |         |       |       |      |       |
| A   |           |        |         |       |       |      |       |
| sso |           |        |         |       |       |      |       |
| cia |           |        |         |       |       |      |       |
| ted |           |        |         |       |       |      |       |
| Sp  |           |        |         |       |       |      |       |
| eci |           |        |         |       |       |      |       |
| fic |           |        |         |       |       |      |       |
| A   |           |        |         |       |       |      |       |
| ppl |           |        |         |       |       |      |       |
| ica |           |        |         |       |       |      |       |
| ble |           |        |         |       |       |      |       |
| Sta |           |        |         |       |       |      |       |
| nda |           |        |         |       |       |      |       |
| rds |           |        |         |       |       |      |       |
+=====+===========+========+=========+=======+=======+======+=======+
| EU  | Unit      | Appl   |         |       |       |      |       |
| \#  | De        | icable |         |       |       |      |       |
|     | scription | Sta    |         |       |       |      |       |
|     |           | ndards |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
|     |           | NAC    | ASIP    | NSPS  | NE    | PSD  | Acid  |
|     |           |        |         |       | SHAPS |      | Rain  |
|     |           | (445B) | (A      | (Part |       | (    |       |
|     |           |        | rticle) | 60)   | (     | Part | (     |
|     |           |        |         |       | Parts | 52)  | Parts |
|     |           |        |         |       | 61,   |      | 7     |
|     |           |        |         |       | 63)   |      | 2-78) |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Johnson   | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Hopp      | 22017, | 45.721, | bpart |       |      |       |
| 001 | er/Screen | .      | 445.731 | OOO   |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Cedar     | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Rapids    | 22017, | 45.721, | bpart |       |      |       |
| 002 | Jaw       | .      | 445.731 | OOO   |       |      |       |
|     | Crusher   | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Cedar     | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Rapids    | 22017, | 45.721, | bpart |       |      |       |
| 003 | Roll      | .      | 445.731 | OOO   |       |      |       |
|     | Crusher   | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Kohlber   | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | g-Pioneer | 22017, | 45.721, | bpart |       |      |       |
| 004 | Roll      | .      | 445.731 | OOO   |       |      |       |
|     | Plant     | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Ross Wash | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Plant     | 22017, | 45.721, | bpart |       |      |       |
| 005 | Hopper    | .      | 445.731 | OOO   |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Fabtec    | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Conveyor  | 22017, | 45.721, |       |       |      |       |
| 006 |           | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Fabtec    | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Conveyor  | 22017, | 45.721, |       |       |      |       |
| 007 |           | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Fabtec    | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Conveyor  | 22017, | 45.721, |       |       |      |       |
| 008 |           | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Unknown   | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Conveyor  | 22017, | 45.721, |       |       |      |       |
| 009 |           | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Cedar     | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Rapids    | 22017, | 45.721, |       |       |      |       |
| 010 | Conveyor  | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Cedar     | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Rapids    | 22017, | 45.721, |       |       |      |       |
| 011 | Conveyor  | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Ross Wash | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Plant     | 22017, | 45.721, | bpart |       |      |       |
| 012 | Conveyor  | .      | 445.731 | OOO   |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Kohlber   | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | g-Pioneer | 22017, | 45.721, | bpart |       |      |       |
| 013 | Wash      | .      | 445.731 | OOO   |       |      |       |
|     | Plant     | 22033, |         |       |       |      |       |
|     | Sand Prep | .252   |         |       |       |      |       |
|     | Screen    | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Universal | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| F1. | Screen    | 22017, | 45.721, |       |       |      |       |
| 014 |           | .      | 445.731 |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .252   |         |       |       |      |       |
|     |           | 305,   |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | TTR Gas   | .      | N/A     | N/A   | N/A   | N/A  | N/A   |
| 001 | Station   | 22017, |         |       |       |      |       |
|     | (         | .305,  |         |       |       |      |       |
|     | Gasoline) | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | Building  | .      | 445.721 | N/A   | N/A   | N/A  | N/A   |
| 002 | 535 Paint | 22017, |         |       |       |      |       |
|     | Booth     | .      |         |       |       |      |       |
|     |           | 22033, |         |       |       |      |       |
|     |           | .305,  |         |       |       |      |       |
|     |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | TTR       | .      | N/A     | N/A   | N/A   | N/A  | N/A   |
| 003 | Diesel    | 22017, |         |       |       |      |       |
| --  | Storage   | .305,  |         |       |       |      |       |
| S2. | Tanks     | .3405  |         |       |       |      |       |
| 004 | (136,000  |        |         |       |       |      |       |
|     | gallons   |        |         |       |       |      |       |
|     | and true  |        |         |       |       |      |       |
|     | vapor     |        |         |       |       |      |       |
|     | pressures |        |         |       |       |      |       |
|     | less than |        |         |       |       |      |       |
|     | 0.51      |        |         |       |       |      |       |
|     | psia))    |        |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | TTR JP-8  | .      | N/A     | N/A   | N/A   | N/A  | N/A   |
| 005 | Storage   | 22017, |         |       |       |      |       |
|     | Tank      | .305,  |         |       |       |      |       |
|     | (300,000  | .3405  |         |       |       |      |       |
|     | gallons   |        |         |       |       |      |       |
|     | and true  |        |         |       |       |      |       |
|     | vapor     |        |         |       |       |      |       |
|     | pressures |        |         |       |       |      |       |
|     | less than |        |         |       |       |      |       |
|     | 0.51      |        |         |       |       |      |       |
|     | psia)     |        |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | TTR JP-8  | .      | N/A     | N/A   | N/A   | N/A  | N/A   |
| 006 | Storage   | 22017, |         |       |       |      |       |
| --  | Tanks     | .305,  |         |       |       |      |       |
| S2. | (300,000  | .3405  |         |       |       |      |       |
| 008 | gallons   |        |         |       |       |      |       |
|     | and true  |        |         |       |       |      |       |
|     | vapor     |        |         |       |       |      |       |
|     | pressures |        |         |       |       |      |       |
|     | less than |        |         |       |       |      |       |
|     | 0.51      |        |         |       |       |      |       |
|     | psia)     |        |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| \-- | Surface   | .365   | SIP 7.3 | N/A   | N/A   | N/A  | N/A   |
|     | Area      |        |         |       |       |      |       |
|     | Di        |        |         |       |       |      |       |
|     | sturbance |        |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| P   | Eagle     | .      | 4       | Su    | N/A   | N/A  | N/A   |
| F1. | Rock      | 22017, | 45.721, | bpart |       |      |       |
| 015 | Crusher   | .      | 445.731 | OOO   |       |      |       |
| --  | 1200-25CC | 22033, |         |       |       |      |       |
| P   |           | .252   |         |       |       |      |       |
| F1. |           | 305,   |         |       |       |      |       |
| 026 |           | .3405  |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+
| S2. | 335 HP    | .      | 4       | N/A   | N/A   | N/A  | N/A   |
| 009 | Diesel    | 22017, | 45.721, |       |       |      |       |
|     | Engine    | .305,  | 445.731 |       |       |      |       |
|     | (Eagle    | .3405  |         |       |       |      |       |
|     | Rock      |        |         |       |       |      |       |
|     | Crusher)  |        |         |       |       |      |       |
+-----+-----------+--------+---------+-------+-------+------+-------+

**3.2.1 NEVADA REVISED STATUTES**

The Nevada Revised Statutes (NRS) is the statutory authority for the
adoption and implementation of administrative regulations. The statutes
relating to the control of air pollution are contained in NRS 445B.100
through 445B.640. The NRS specifies that the State Environmental
Commission is the governing body given the power to adopt administrative
regulations. Because the NRS is the enabling statutory authority, very
few specific requirements are contained in the statutes. Rather, the NRS
provides, generally, broad authority for the adoption and implementation
of air pollution control regulations.

**3.2.2 NEVADA ADMINISTRATIVE CODE**

The Nevada Administrative Code (NAC) is the administrative regulations
that contain specific requirements relating to the control of air
pollution. The State Environmental Commission adopts these regulations.
The NAC requires that, where state regulations are more stringent in
comparison to Federal regulations, the State regulations are applicable.
The NAC sets forth, by rule, maximum emission standards for visible
emissions (opacity), PM10 and sulfur emitting processes. Other
requirements are established for incinerators, storage tanks, odors and
maximum concentrations of regulated air pollutants in the ambient air.
Other NAC regulations specify the requirements for applying for and
method of processing applications for operating permits. All of the
equipment considered in this application must meet, at a minimum, the
applicable standards and requirements set forth in the NAC.
Specifically, the emission standards contained in NAC 445B.2203 for
particulate matter, 445B.22017 for opacity and 445B.22097 for the
ambient air quality standards must not be exceeded.

**3.2.3 NEVADA APPLICABLE SIP (ASIP)**

The Applicable State Implementation Plan (ASIP) is a document, which is
prepared by a State or Local air regulatory agency and required to be
submitted to the U.S. EPA for approval. Title I of the Clean Air Act is
the statutory authority for the U.S. EPA regulations that require a
State to submit a ASIP. The contents of the ASIP are intended to show
how a State, through the implementation and enforcement of the
regulations contained in the ASIP, will either show how attainment of
the ambient air quality standards (NAAQS) will be achieved or how a
State will continue to maintain compliance with the NAAQS. Nevada\'s
most recent ASIP, which was approved by U.S. EPA, is based on State
regulations codified in 1982. In general, the regulations contained in
the ASIP closely parallel the current NAC regulations. However, because
the ASIP is based on older air quality regulations (at this time),
compliance with all of the current NAC regulatory requirements does not
necessarily ensure compliance with the ASIP requirements. All of the
equipment considered in this application must meet, at a minimum, the
standards set forth in the ASIP. Specifically, the emission standards
contained in ASIP 445.731 for particulate matter, ASIP 445.721 for
opacity and 12.1 for the ambient air quality standards must not be
exceeded.

**3.2.4 CODE OF FEDERAL REGULATIONS (CFR)**

The Code of Federal Regulations (CFR) are regulations adopted by the
U.S. EPA and published in the Federal Register pursuant to the authority
of the granted by Congress in the Clean Air Act. The CFR addresses
multiple aspects, including but not limited to, permitting requirements,
performance standards, testing methods, and monitoring requirements.

**3.2.4.1 New Source Performance Standards (NSPS)**

The U.S. EPA has promulgated maximum emission standards and/or
monitoring/ recordkeeping methods for selected source categories. These
standards are contained in Title 40 of the CFR, Part 60, and are known
as the New Source Performance Standards (NSPS).

Some of the permittee's operations are subject to Subpart OOO (refer to
Table 3.2.1) with the exception of PF1.006 -- PF1.009; PF1.1.010 --
PF1.011; and PF1.014; process aggregate at, or less than, 150 tons of
aggregate per hour. The 40 CFR Part 60, Subpart OOO (60.670)
applicability requirements state that "(c) *Facilities at the following
plants are not subject to the provisions of this subpart: (2) Portable
sand and gravel plants and crushed stone plants with capacities, as
defined in 60.671, of 136 megagrams per hour (150 tons per hour) or
less.*"

Each of the Diesel (No. 2 fuel oil) fuel storage tanks and each of the
JP-8 storage tanks have capacities greater than 40,000 gallons and true
vapor pressures less than 0.51 psia (i.e., 3.5 kPa). All these storage
tanks are exempt from the provisions of 40 CFR Part 60, Subparts Ka
(60.110a) and Kb (60.110b).

**3.2.4.2 National Emission Standards for Hazardous Air Pollutants
(NESHAP)**

The federal NESHAP provisions are contained in 40 CFR Parts 61 and 63. A
summary of the emissions is contained in Section 4 of this review. HAP
information was provided by NAFB and reviewed by BAPC. NAFB provided the
formulas used to calculate the HAPs and BAPC verified NAFB's
calculations. Based on the emissions, NTTR is a minor emitter of HAPs
(i.e. emits less than 10 ST/yr of a single HAP or 25 ST/yr of a
combination of HAP's).

The largest contributor to HAP generation is the spray paint booth. The
HAP quantification will depend on the specific coating used and will be
based on the assumption that all HAP contained in paint will emit to the
atmosphere. The HAP emissions are not calculated; rather, they represent
the worst-case emissions for each HAP based on a range of coatings
typically sprayed in the booth. The emission limits in the permit
represent maximum emissions for each HAP. The combined HAP emissions
from S2.005 are set based on the paint HAP speciation from the total
potential VOCs emitted. Individual HAP emission levels for S2.005 are
set based on the maximum potential emission for that particular HAP. At
this time there are no standards within 40 CFR Parts 61 and 63 that are
applicable to surface coating of miscellaneous metal parts and products,
and the facility is minor for HAP emissions, therefore there is no MACT
or NESHAP requirement for this facility, nor will the standards apply
once they are promulgated.

**3.2.4.3 Prevention Of Significant Deterioration Regulations (PSD)**

These regulations specify federally required permitting procedures for
each \"major stationary source\". The PSD regulations define a
\"stationary source\" as \"*any building, structure, facility, or
installation which emits or may emit any air pollutant subject to
regulation under the Act.*\" A \"building structure facility or
installation\" is defined as \"*all of the pollutant emitting activities
which belong to the same industrial grouping, are located on one or more
contiguous or adjacent properties, and are under the control of the same
person (or persons under common control) except the activities of any
vessel. Pollutant-emitting activities shall be considered as part of the
same industrial grouping if they belong to the same \'Major Group\'
(i.e., which have the same first two digit code) as described in the
Standard Industrial Classification Manual, 1972, as amended by the 1977
Supplement.*\"

"Major" is defined as the potential to emit of a stationary source,
which equals or exceeds a specified threshold (in tons per year) of any
air pollutant regulated under the Clean Air Act (40 CFR 52.21(b)(1)).
The first threshold is for a stationary source that emits or has the
potential to emit 100 tons per year or more and is defined as one of 28
specific categories of sources (see 40 CFR 52.21(b)(1)(i)(a)). The other
applicability threshold is for any other stationary source that emits or
has the potential to emit 250 tons per year (see 40 CFR
52.21(b)(1)(i)(b)).

The SIC code for this facility is 9711 (National Security). Therefore,
the major SIC grouping is 97, which is identified as \"National Security
and International Affairs\" in the SIC manual. However, none of the 28
specific categories is representative of this facility. Therefore, major
source status is classified at the 250 tons per year emission threshold
for any pollutant regulated under the Clean Air Act.

Currently, this facility is a major NOx (1,138.27 tons/year) source for
PSD purposes. Refer to the attached spreadsheet "Summary of
Facility-wide total PTE estimated emissions"; the permittee's proposed
minor revision will not result in any increases in applicable criteria
pollutant Significant Emission Thresholds for PSD/NSR review purposes.
Therefore, permittee's proposed minor revision application does not
require to undergo any PSD/NSR review at this time.

**3.2.4.4 Compliance Assurance Monitoring (CAM)**

The U.S. EPA has promulgated requirements for sources to provide
detailed monitoring plans that will ensure compliance with all
applicable requirements. These monitoring requirements are contained in
40 CFR Part 64. Section 64.2 specifies that these monitoring
requirements apply to a \"pollutant specific emission unit at a major
source\" if all of the following are satisfied:

> \* The unit is subject to an emission limitation or standard;
>
> \* The unit uses a control device to achieve compliance with any such
> emission limitation or standard; and
>
> \* The unit has potential pre‑control device (uncontrolled) emissions
> equal to or greater than 100 percent of the amount, in tons per year,
> required for a source to be classified as a major source.

The key factors that would require the submission of a CAM plan are: 1)
the facility must be defined as a "major source"; and 2) the units must
be subject to an emission limitation or standard (acid rain limitations
and standards are not included). At this time NDEP-BAPC has determined
that the permittee does not need to submit a CAM plan.

**3.2.4.5 Acid Rain**

The permittee does not operate any emission unit subject to the acid
rain provisions.

**4.0 EMISSIONS INVENTORY**

**4.1 EMISSIONS**

Individual emission calculations and emission factor references are
contained in Attachment 1.

+-------------+-------+-------+-------+-------+-------+-------+------+
| **Table     |       |       |       |       |       |       |      |
| 4.1-1:**    |       |       |       |       |       |       |      |
| Summary of  |       |       |       |       |       |       |      |
| Emissions   |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+
| Pollutant / | PM    | P     | NOx   | SO~2~ | CO    | VOC   | HAPs |
|             |       | M~10~ |       |       |       |       |      |
| Source(s)   | (ton  |       | (ton  | (ton  | (ton  | (ton  | (    |
|             | s/yr) | (ton  | s/yr) | s/yr) | s/yr) | s/yr) | tons |
|             |       | s/yr) |       |       |       |       | /yr) |
+-------------+-------+-------+-------+-------+-------+-------+------+
| Fa          | **26  | **12  | **10  | **0   | **2   | **15  | **6. |
| cility-wide | .46** | .80** | .76** | .71** | .32** | .67** | 70** |
|             |       |       |       |       |       |       |      |
| Permitted   |       |       |       |       |       |       |      |
| Units       |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+
| All         | 80.76 | 80.76 | 1,1   | 71.98 | 2     | 96.72 | \    |
| In          |       |       | 19.66 |       | 42.84 |       | -\-- |
| significant |       |       |       |       |       |       |      |
| Activities  |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+
| ***[R       | 1     | 93.56 | 1,1   | 72.69 | 2     | 1     | 6.70 |
| evised]{.un | 07.22 |       | 30.42 |       | 45.16 | 12.39 |      |
| derline}*** |       |       |       |       |       |       |      |
|             |       |       |       |       |       |       |      |
| Total       |       |       |       |       |       |       |      |
| Fa          |       |       |       |       |       |       |      |
| cility-wide |       |       |       |       |       |       |      |
|             |       |       |       |       |       |       |      |
| Emissions   |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+
| ***[Ex      | 1     | 1     | 1,1   | 1     | 2     | 1     | 6.72 |
| isting]{.un | 56.10 | 17.22 | 38.27 | 85.27 | 48.71 | 13.16 |      |
| derline}*** |       |       |       |       |       |       |      |
|             |       |       |       |       |       |       |      |
| Total       |       |       |       |       |       |       |      |
| Fa          |       |       |       |       |       |       |      |
| cility-wide |       |       |       |       |       |       |      |
|             |       |       |       |       |       |       |      |
| Emissions   |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+
| **Net       | (-4   | (-2   | (-    | (-11  | (-    | (-    | (-0  |
| Emissions   | 8.88) | 3.66) | 7.85) | 2.58) | 3.55) | 0.76) | .02) |
| Changes**   |       |       |       |       |       |       |      |
+-------------+-------+-------+-------+-------+-------+-------+------+

[Minor revision to add and delete some systems]{.underline}: The
proposed minor revision will not result in any significant increases
(rather it decreases) in permittee's existing permitted emission limits
(refer to the attached spreadsheet "Summary of Facility-wide total PTE
estimated emissions", Attachment 1).

**5.0 PREVENTION OF SIGNIFICANT DETERIORATION DETERMINATION**

As discussed Section 3.2.4.3 above, 40 CFR Part 52.21 specifies that
Prevention of Significant Deterioration (PSD) review is required for any
new major stationary source or any major modification. A major source is
defined as any pollutant emitting activities, which belong to the same
two digit Source Industry Classification (SIC), and:

> 1\. Emits 100 tons/yr or more of a regulated air contaminate as one of
> the listed categories of sources listed in 40 CFR 52.21; or
>
> 2\. Emits 250 tons/yr or more of a regulated air contaminant and
> belong to any other category sources.

Since this facility is not classified as one of the listed categories of
sources the potential to emit threshold of a regulated pollutant is 250
tons/yr. The facility has a potential to emit NOx emissions of 1,130.42
tons/year (existing permit allows 1,138.27 tons/yr) for all sources
combined, therefore, the facility is a Major Stationary source for
NO~x~. The permittee's proposed minor revision will not result in any
increases in applicable criteria pollutant Significant Emission
Thresholds for PSD/NSR review purposes (refer to the attached
spreadsheet "Summary of Facility-wide total PTE estimated emissions").
Therefore, permittee's proposed minor revision application does not
require to undergo any PSD/NSR review at this time.

**6.0 AMBIENT AIR QUALITY IMPACT**

*[Refer to the Technical Review dated October 7, 2003 (edited
12/03]{.underline}):*

The purpose of the air quality analysis is to demonstrate that the
emissions from the stationary source will not cause or contribute to a
violation of any applicable federal or state ambient air quality
standards prior to the issuance of an operating permit.

NAFB provided two modeling analyses as part of their application; an
ISCST3 and the more conservative SCREEN model. Both models demonstrated
compliance with the Ambient Air Quality Standards. NAFB obtained five
years of meteorological data. The most recent complete set of data was
from years 1989 through 1993. Upper air data was obtained from the
Desert Rock monitoring station and surface data was obtained from
Tonopah. The Bureau conducted a review of NTTR's modeling protocol and
the results of the modeling analysis. The Bureau's expectations
generally agreed with the impacts presented in the application. There
are too many source parameters to enumerate in this review, however,
electronic model input data is available for review. Table 6.0-1
contains a summary of the ambient air quality standards and the maximum
resultant impacts expected to occur due to the operations on NTTR, as
modeled by the ISCST3 model.

+-------------------+----------------+-----------------+--------------+
| # Tabl            |                |                 |              |
| e 6.0-1 Summary o |                |                 |              |
| f Modeled Impacts |                |                 |              |
+-------------------+----------------+-----------------+--------------+
| Pollutant         | Averaging Time | Nevada Ambient  | Highest      |
|                   |                | Air Quality     | Modeled      |
|                   |                | Standards       | C            |
|                   |                | (μg/m^3^)       | oncentration |
+-------------------+----------------+-----------------+--------------+
| Carbon Monoxide   | 1 Hour         | 40,000          | 236.89       |
+-------------------+----------------+-----------------+--------------+
|                   | 8 Hour         | 10,000          | **60.09**    |
+-------------------+----------------+-----------------+--------------+
| Nitrogen Dioxide  | Annual         | 100             | 14.64        |
+-------------------+----------------+-----------------+--------------+
| PM10              | 24 Hour        | 150             | **31.64**    |
+-------------------+----------------+-----------------+--------------+
|                   | Annual         | 50              | 12.36        |
+-------------------+----------------+-----------------+--------------+
| Sulfur Dioxide    | 3 Hour         | 1300            | 43.08        |
+-------------------+----------------+-----------------+--------------+
|                   | 24 Hour        | 365             | **7.99**     |
+-------------------+----------------+-----------------+--------------+
|                   | Annual         | 80              | 1.11         |
+-------------------+----------------+-----------------+--------------+
| Lead              | Quarterly      | 1.5             | 0.000        |
+-------------------+----------------+-----------------+--------------+
| Ozone             | 1 Hour         | 235             | 172.33       |
+-------------------+----------------+-----------------+--------------+

This modeling was performed for the modification application, which
consisted of aggregate processing equipment, cement and asphalt plants;
the model excluded insignificant units.

The permittee's proposed minor revision will not result in any
significant increases (rather it decreases) in permittee's existing
permitted emission limits (refer to the attached spreadsheet "Summary of
Facility-wide total PTE estimated emissions", Attachment 1). Therefore,
the permittee has not performed any air quality modeling analysis. The
permitte will require to perform a comprehensive, facility-wide air
dispersion modeling analysis upon any modification (reflecting any
significant emissions changes) or renewal of this facility-wide Class I
(Title V) Air Quality Operating Permit.

**6.1 PSD INCREMENT IMPACT**

The facility is located across all or part of several hydrographic areas
(HA) in Lincoln and Nye Counties: 141, 145, 146, 147, 148, 149, 157,
158A, 158B, 159, 160, 161, 168, 169A, 169B, 170, 173A, 227A, 227B, 228
and 229. None of these basins have been triggered for any pollutants,
however, a modification resulting in emissions above the significance
threshold for any pollutant will trigger these basins and be subject to
a full PSD/NSR review. At this time there is no increment to consume.

**7.0 CONCLUSIONS / RECOMMENDATIONS**

Based on information provided in permittee's minor revision application
submittal and the determinations made in this review, permittee (US Air
Force, Nellis Air Force Base)'s request for a Minor Revision to their
existing Class I Air Quality Operating Permit #AP9711-1233 will not
violate any applicable requirements. As a result, NDEP-BAPC recommends
issuance of this revised Class I Air Quality Operating Permit
#AP9711-1233.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Tobarak Ullah, P.E. Date

Staff Engineer

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Matthew A. DeBurle, P.E. Date

Supervisor, Class I Permitting Branch

[Attachments]{.underline}:

\(1\) Emissions Inventory \[**updated June 2006**\].

\(2\) Proposed Air Quality Operating Permit #AP9711-1233.

**Attachment 1**

**Emissions Inventory**

**\[[updated June 2006]{.underline}\]**

**Attachment 2**

***[Proposed]{.underline}* Air Quality Operating Permit**

**\[ *[Note]{.underline}: Changes are in Red.* \]**