DISTRICT HEALTH DEPARTMENT 

AIR QUALITY MANAGEMENT DIVISION 

Public Health Prevent Promote Protect 

January 15,2009 

Deborah Jordan 

Director, Air Division 

U.S. EPA Region IX 

75 Hawthorne Street (AIR-1) 

San Francisco, California 94105 

Dear Ms. Jordan: 

Washoe County Health District, Air Quality Management Division, is requesting 

formal delegation of the authority to implement and enforce National Emission Standards 

for Hazardous Air Pollutants (NESHAPs) pursuant to Title 40 of the Code of Federal 

Regulations (CFR) Part 63. As stated in our Memorandum of Agreement with U.S. EPA 

Region IX, dated June 24, 1997, regarding delegation of NESHAPs, Washoe County's 

mechanism for obtaining the regulatory authority necessary to accept delegation is 

through incorporation of the federal rules by reference into our local regulations. 

Washoe County is requesting delegation for the following NESHAPs in 40 CFR Part 63: 

Subpart VW - National Emission Standards for Hazardous Air Pollutants: Publicly 

Owned Treatment Works (63.1580 - 63.1595) 

Subpart EEEE - National Emission Standards for Hazardous Air Pollutants: Organic 

Liquids Distribution (Non-Gasoline) (63.2330 - 63.2406) 

Subpart WWWW - National Emission Standards for Hazardous Air Pollutants: 

Reinforced Plastic Composites Production (63.5780 - 63.5935) 

Subpart ZZZZ -National Emission Standards for Hazardous Air Pollutants for 

Reciprocating Internal Combustion Engines (63.6580 - 63.6675) 

Subpart WWRWW - National Emission Standards for Hospital Ethylene Oxide 

Sterilizers (63.10382 - 63.10448) 

Subpart BBBBBB - National Emission Standards for Hazardous Air Pollutants for 

Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants and Pipeline 

Facilities (63.1 1080 - 63.1 1100) 

P.O. BOX 11130 Reno, NV 89520-0027 401 Ryland Street, Ste. 331 (775) 784-7200 FAX (775) 784-7225 

www.washoecounty.us \VASHOE COLINTY IS AN EQUAL OPPORTUNITY EMPLOYER HIRING EMPLOYMENT ELIGIBLE APPLICANTS 

Printed on Recycled Paper 
Ms. Jordon/U.S. EPA Region IX 

January 15,2009 

Page 2 

Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants for 

Source Category: Gasoline Dispensing Facilities (63.1 1 1 10 - 63.1 1 132) 

Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint 

Stripping and Miscellaneous Surface Coating Operations at Area Sources 

(63.11169-63.11180) 

Subpart 000000 - National Emission Standards for Hazardous Air Pollutants: 

Flexible Polyurethane Foam Fabrication Operations (63.1 1414 - 63.11420) 

Subpart WWWWWW -National Emission Standards for Hazardous Air Pollutants: 

Area Source Standards for Plating and Polishing Operations (63.1 1475 - 63.1 15 12) 

Subpart XXXXXX - National Emission Standards for Hazardous Air Pollutants: Area 

Source Standards for Nine Metal Fabrication and Finishing Source Categories 

(63.11514 - 63.1 1523) 

Washoe County is also requesting delegation of amendments made, as of 

December 3, 1997, to any previously-delegated standards. A copy of the current Washoe 

County District Board of Health Regulations, specifically Section 030.106, National 

Emission Standards for Hazardous Air Pollutants for Source Categories is enclosed. 

Additionally, Washoe County Health District, Air Quality Management Division, 

is requesting formal delegation of the authority to implement and enforce New Source 

Performance Standards (NSPS) pursuant to Title 40 of the Code of Federal Regulations 

(CFR) Part 60. As previously stated, Washoe County's mechanism for obtaining the 

regulatory authority necessary to accept delegation is through incorporation of the federal 

rules by reference into our local regulations. 

Washoe County is requesting delegation for the following NSPS in 40 CFR Part 60: 

Subpart TTT - Standards of Performance for Industrial Surface Coating: Surface 

Coating of Plastic Parts for Business Machines (60.720 - 60.726) 

Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral 

Industries (60.730 - 60.737) 

Subpart VVV - Standards of Performance for Polymeric Coating of Supporting 

Substrates Facilities (60.740 - 60.748) 

Subpart WWW - Standards of Performance for Municipal Solid Waste Landfills 

(60.750 - 60.759) 
Ms. Jordon/U.S. EPA Region IX 

January 15,2009 

Page 3 

Subpart AAAA - Standards of Performance for Small Municipal Waste Combustion 

Units for Which Construction is Commenced After August 30, 1999 or for Which 

Modification or Reconstruction is Commenced After June 6,2001 (60.1000 - 60.1465) 

Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste 

Incineration Units for Which Construction Is Commenced After November 30, 1999 or 

for Which Modification or Reconstruction Is Commenced on or After June 1,2001 

(60.2000 - 60.2265) 

Subpart EEEE - Standards of Performance for Other Solid Waste Incineration Units for 

Which Construction is Commenced After December 9,2004, or for Which Modification 

or Reconstruction is Commenced on or After June 16,2006 (60.2880 - 60.2977) 

Subpart 1111 - Standards of Performance for Stationary Compression Ignition Internal 

Combustion Engines (60.4200 - 60.42 19) 

Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal 

Combustion Engines (60.4230 - 60.4248) 

Subpart KKKK - Standards of Performance for Stationary Combustion Turbines 

(60.4300 - 60.4420) 

Washoe County acknowledges that delegation constitutes our agreement to follow 

all applicable provisions of 40 CFR Part 60, including the use of U.S. EPA's test methods 

and procedures. We also understand that U.S. EPA retains the exclusive right for 

authorizing approval of equivalent and alternative control technologies and test methods. 

Therefore we understand that the applicable subsections of the requested NSPS may not 

be delegated. A copy of the current Washoe County District Board of Health 

Regulations, specifically Section 030.100, New Source Performance Standards is 

enclosed. 

If you have any questions regarding these delegation requests, please contact 

Charlene Albee at (775)784-7211 or via email at calbee@washoecounty.us. 

&drew Goodrich, REM 

Director 

Cc: Mae Wang, EPA Region IX 

Cynthia Allen, EPA Region IX