# DISTRICTHEALTHDEPARTMENT AIR QUALITYMANAGEMENTDIVISION PublicHealth 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 ofNESHAPs, 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 PaperMs. 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 1 110
-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
- 63.115 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 delegationof amendments made, as of December 3, 1997,to any previously-delegated standards. A copy of the currentWashoe 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 authorityto implement and enforceNew Source Performance Standards (NSPS) pursuant to Title 40 ofthe 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 ofthe federal rules by reference into our local regulations.
Washoe County is requesting delegationfor the following NSPS in 40 CFR Part 60: Subpart TTT
- Standards ofPerformance for Industrial Surface Coating: Surface Coating of Plastic Parts for Business Machines (60.720 - 60.726) Subpart UUU
- Standards ofPerformance for Calciners and Dryers in Mineral Industries (60.730 - 60.737) Subpart VVV - Standards ofPerformance for Polymeric Coating of Supporting Substrates Facilities (60.740 - 60.748) Subpart WWW - Standards ofPerformancefor 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, 1999or 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 ofthe current Washoe CountyDistrict 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