# 0

0 WASHOE COUNTY HEALTH DISTRICT AIR QUALITY MANAGEMENT DIVISION Public Health Prevent. Promote. Protect. 

# J 21 2012

Nevada UflC 

# Environm@ntal Prot,cton Ms. Colleen Cripps, P1tD.

JUN

25 

# RECEIVED Administrator BAPC!AQP 

# Division of Environmental Protection

12 901 S. Stewart St., Suite 4001 ENVIRONMENTALPROTECDN Carson City NV 89701-5249 Dear Ms. Cripps: The Washoe County Health District- 

# Air Quality Management Divisi-(WCHD-AQMD)

is in the process of submitting

a revision to the Washoe County portion of Nevada’s PM2.5 Infrastructure State Implementation Plan (I-SIP). This revision will include formal submittal of the following five existing Washoe County District Board of Health Regulations Governing Air Quality Management: • 030.023 Evaluation of Registration Application • 030.218 Demonstration

of Compliance • 030.230 Record Keeping • 030.235 Requirements
for Source Sampling and Testing • 030.970 Part 70 Permit Monitoring and Compliance In order to expedite the approval process and in accordance with 40 CFR 51, Appendix V.2.3, the WCHD-AQMIJ requests that the Nevada Division of Environmental Protection request the U.S. Environmental Protection Agency (EPA) to initiate parallel processing of the revision to the Washoe County portion of the Nevada’s PM2.5 Infrastructure State Implementation Plan (attached). The 30-day public comment period for the revision opened on May 25, 2012 with the public hearing scheduled for June 28, 2012. Submittal of this revision to NDEP will be no later than July 31, 2012. If you have any questions
or comments, feel free to contact me or Mr. Daniel Inouye of my staff at (775) 784-7200. Sincerely, 

# 7 -- 

# & Kevin Dick Division Director cc: Daniel Inouye, WCHD-AQMD Attachments P.O. BOX 11130 Reno, NV 89520-0027

• 

# (775) 784-7200

• 

# FAX (775) 784-7225 www.washoecounty.us/health WASROR COUNTY ISAN EQUAL OPPORTUNITY EMPLOYER WRING EMPlOYMENT ELIGIBLE APPLICANTS Printed an Recycled Pipero

0 030.023 EVALUATION
OF REGISTRATION APPLICATION When an Authority
to Construct application

is received by the Control Officer, he shall evaluate

it to determine

if all necessaryinformation
onthe source processeshas been included. When all the required information has been received, the Control Officer will review the proposal using standard engineering practices and methods, decide which local, state orfederal regulations apply tothe source,determine by approved modeling orother methods

if the proposed control technology will meet regulatory requirements, and determine what,
if any, pre-construction monitoring
orother testing will be required before the authority
to construct

is issued.

If it is determined that the equipment proposed

in the Authority
to Construct application

is insufficient

to meet regulatory requirements, the Control Officer will notify the applicant of the deficient items in writing and state what additions maybe made to bring the project into compliance with regulatory requirements.

In nocase maythe review of the project take morethan 180 days to complete. 030.218 DEMONSTRATION

OF COMPLIANCE The Control Officer may require the operator of asourceto provide any applicable data to demonstrate compliance with the conditions
of the Permit to Operate. Such data submission requirements may include, but would not be limited to, graphs, charts orother records of items such as plant operational temperatures, plant production levels, continuous stack monitor outputs, plant operating hours, equipment engineering and design specifications

orchemical product consumption. Requested data must be provided

in a timely manner,as specified by the Control Officer. Failure to provide this data as requested by the Control Officer constitutes

aviolation of the conditions
of the Permit to Operate, and the affected sourcewould be subject toacitation under these regulations, suspension
of their Permit to Operate orboth. 030.230 RECORD KEEPING (Amended 9/23/92) The Control Officer may require anyholder of aPermit to Operate
to keep adequate records concerning contaminant emissions for any equipment
or processfor which the permit wasissued. All permittees operating add-on emissions control equipment will maintain records sufficient
to legally demonstrate that the equipment has operated

in compliance with all applicable Federal, State and District regulations. The permittee shall also record anytimes oroccasions when the emissions control equipment

is not in operation due to equipment failure, maintenance

or anyother reason. 030.235 REQUIREMENTS FOR SOURCE SAMPLING AND TESTING To determine the exact quantity and effect of emissions produced by stationary sources,the Control Officer may require sourcestack testing, orother types of source testing including, but not limited to,massbalance types of analysis, be made by the operator. Alternatively, and after consultation with the permittee, the Control Officer may require that testing be reviewed and overseen by an independent third party of the Control Officer’s selection
to insure the quality and accuracyof the test results, The Control Officer mayalso require other types of pollutant impact analysis, including but not limited to, epidemiological testing of personswho maybe affected by the operations
of the source,risk assessment determinations, sourceor receptor modeling and off-site ambient pollutant level monitoring. Completion
of testing maybe required prior tothe issuance or continuance

of a permit to operate. The Control Officer may require that all costs of any testing required under this section be borne by the operator orsourceowner.

# 0 030.970 PART 70 PERMIT MONITORING AND COMPLIANCE (Adopted 10120193, Revised 10125/95) A. Compliance Statements Sources subject to Part 70 permits shall submit

a statement
of compliance signed by a responsible official. The annual compliance statement shall be due each year on the anniversary
of the date of issuance (or more frequently

if required
in an applicable requirement). The compliance statement shall address each term or condition
of operation on an item by item basis. The compliance statement shall contain the following: 1. Identification
of each term or condition of operation that is the basis for certification. 2. The compliance status of the facility with respect to each term or condition
of operation and a statement that the operator will continue
to comply with such requirements. 3. Whether the compliance with each term or condition of operation was continuous
or intermittent. 4. The method(s) used for determining the compliance status of the source including

a description
of monitoring, record keeping and reporting requirements, and test methods. 5. For any term or condition of operation for which the source
is not in compliance, the source must submit

a compliance schedule and a narrative description
of how the source will achieve compliance with such requirements

as described

in 030.970 (B) of these regulations. 6. For any source for which the Control Officer has established requirements
for progress reports on compliance schedules, the source must provide these progress reports
in a timely manner and address dates milestones and other activities that have been specified by the Control Officer. The progress report shall also include the dates on which any milestones were achieved and an explanation
of any dates or milestones that were not or are not expected
to be met, why they were not met and any corrective actions to be taken as a result. 7. Any other specific information needed to determine compliance
as required by the Control Officer. 8.
A certification

of the truth, accuracy and completeness

of the compliance statement by a responsible official. 9. Any additional requirements

as may be specified pursuant
to sections 114(a) and 504(b) of the Act All Statements

of compliance must be made in writing to both the EPA Administrator

as well as to the Control Officer. Failure to submit

a statement
of compliance

in a timely manner may result in citation, penalties, suspension
or revocation
of the Part 70 permit..S ‘C

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