# Redesignation Request and Maintenance Plan

for the

Truckee Meadows 24 -Hour PM 10 

# Non

Attainment Area

August 28 , 2014

Washoe County Health District

Air Quality Management Division

P.O. Box 11130

Reno, Nevada 89520-0027

(775) 784-7200

www.OurCleanAir.com

## i TABLE OF CONTENTS

Page

Acknowledgements ....................................................................................................................v

Chapter 1: Introduction ..............................................................................................................1

Chapter 2: Attainment of the Standard ......................................................................................2

National Ambient Air Quality Standard ........................................................................2

Washoe County Monitoring Network ............................................................................2

Monitoring Data .............................................................................................................4

Summary ........................................................................................................................7

Chapter 3: State Implementation Plan Approval .......................................................................8

Chapter 4: Permanent and Enforceable Improvement in Air Quality ......................................10

Fe derally Enforceable Control Programs in the Truckee Meadows Portion

of the Nevada SIP ........................................................................................................10

1. Residential Wood Combustion Program ............................................................10

2. Street Sanding and Sweeping Program ...............................................................11

3. Dust Control ........................................................................................................11

4. Emergency Episode Plan ....................................................................................11

Other Programs That Provide Additional PM 10 

## Be nefits ............................................12

1. Non -Road Diesel Emission Standards ................................................................12

2. Ultra Low Sulfur Diesel (ULSD) ........................................................................12

3. Washoe County Smoke Management Program ..................................................12

Economic Conditions ...................................................................................................13

Meteorological Conditions...........................................................................................13

Summary ......................................................................................................................16

Chapter 5: Section 110 and Part D Requirements ...................................................................17

Section 110 Requirements ...........................................................................................17

Part D Requirements ....................................................................................................18

Chapter 6: Maintenance Plan ...................................................................................................23

Attainment Inventory ...................................................................................................23

Point Sources ......................................................................................................23

Nonpoint Sources ................................................................................................23

Non -Road Mobile Sources ..................................................................................24

On -Road Mobile Sources ....................................................................................24

Maintenance Demonstration ........................................................................................24

Truckee Meadows Maintenance Emissions Limit ...............................................25

Maintenance of the NAAQS ................................................................................26

1. Baseline Emission Projections .............................................................26

2. EPA Models .........................................................................................26

3. E mission Category Surveys .................................................................27

## ii TABLE OF CONTENTS (continued)

Page

Summary ..............................................................................................................27

Motor Vehicle Emissions Budget ................................................................................28

Monitoring Network ....................................................................................................29

Verification of Continued Attainment .........................................................................29

1. Periodic Emissions Inventories ........................................................................29

2. Consolidated Emissions Reporting Rule (CERR) and Air Emissions Reporting

Rule (AERR) ....................................................................................................29

3. Residential Wood Use Survey .........................................................................29

Contingency Plan .........................................................................................................30

Contingency Plan “A”.........................................................................................31

Trigger Mechanism “A” ............................................................................31

Contingency Measure “A” .........................................................................31

Summary .............................................................................................................32

List of Tables ........................................................................................................................... iii

List of Figures .......................................................................................................................... iii

Appendices ............................................................................................................................... iii

Acronyms ................................................................................................................................. iv

## i ii LIST OF TABLES

Table Page

2-1 Seasonal PM 10 

## Concentrations and Exceedances ( 1999-2012) ...............................4

2-2 Galletti Ambient Air Monitoring Data ( 2005) .........................................................6

2-3 Operational History of PM 10 

## Monitoring Network and Sampling Methods............6

4-1 2011 Emission Reductions from Federally Enforceable Programs .......................12

4-2 Washoe County Demographic and Economic Indicators (1999-2011) .................13

5-1 Part D Requirements and Actions for the T ruckee Meadows PM 10 

## NAA ............19

6-1 2011 Attainment Inventory (lbs/day) .....................................................................24

6-2 Historic Truckee Meadows PM 10 

## Wildfire Emission Inventories (lbs/day) ..........25

6-3 Truckee Meadows PM 10 

## Emission Inventories (lbs/day) ......................................26

6-4 Truckee Meadows PM 10 

## Maintenance Emission Inventories (lbs/day) .................27

6-5 Truckee Meadows PM 10 

## Safety Margin (lbs/day) .................................................28

6-6 Truckee Meadows PM 10 

## MVEB (lbs/day) .............................................................28

6-7 Potential PM 10 

## Contingency Measures ..................................................................32

LIST OF FIGURES

Figure Page

1-1 Washoe County, Nevada ..........................................................................................1

2-1 PM 10 

## Monitoring Network (1999-2012) ..................................................................3

2-2 Seasonal PM 10 

## Concentrations and Exceedances (1999-2012) ...............................5

4-1 Precipitation Days (1990-2012) .............................................................................14

4-2 Mean Wind Speed (1990-2012) .............................................................................15

4-3 Mean Station Barometric Pressure (199 0-2012)....................................................16

6-1 South Reno Monitoring Site ..................................................................................29

APPENDICES

Appendi x

A. Permanent and Enforceable Reduction Calculations

B. Growth Factors for 20 15, 2020, 2025, and 2030 Projections

C. Truckee Meadows Projected PM 10 

## Seasonal Emissions

## iv ACRONYMS

ADT Average Daily Traffic

AERR Air Emissions Reporting Requirements

AIRS Aerometric Information Retrieval System

AQI Air Quality Index

AQMD Washoe County Health District - Air Quality Management Division

AQS Air Quality System

BACM Best Available Control Measure

BAM Beta Attenuation Monitor

CAA Clean Air Act

CERR Consolidated Emissions Reporting Rule

CFR Code of Federal Regulations

EI Emissions Inventory

EPA United States Environmental Protection Agency

FR Federal Register

HA Hydrographic Area

HDD Heating Degree Days

MPO Metropolitan Planning Organization

MVEB Motor Vehicle Emissions Budget

NAA Non

- Attainment Area

NAAQS National Ambient Air Quality Standard

NCore National Core Multi

- Pollutant Monitoring Station

NO

x 

## Nitrogen oxides

NRS Nevada Revised Statute

NSR New Source Review

PM 10 

## Particulate m atter less tha n or equal to a nominal 10 microns in aerodynamic

diameter

PSD Prevention of Significant Deterioration

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RE Rule Effectiveness

RP Rule Penetration

RTC Regional Transportat ion Commission

RWC Residential Wood Combustion

SIP State Implementation Plan

SLAMS State and Local Air Monitoring Station

SMP Smoke Management Program

SPM Special Purpose Monitoring

ULSD Ultra Low Sulfur Diesel

VMT Vehicle Miles Traveled

WCDBOH Washoe County District Board of Health

## v ACKNOWLEDGEMENTS

Washoe County District Board of Health

Matt Smith, Chair

Kitty Jung, Vice Chair

George Hess, MD

Denis Humphreys, OD

Julia Ratti

David Silverman

Neoma Jardon

Washoe County Health District

Kevin Dick, District Health Officer

Washoe County Health District, Ai r Quality Management Division

Charlene Albee, Director

Daniel Inouye, Branch Chief

Yann Ling-Barnes, P.E., Environmental Engineer II, Project leader

Julie D. Hunter, Senior Air Quality Specialist

Brendan Schnieder, Air Quality Specialist II

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 1 

## CHAPTER 1

INTRODUCTION

The Washoe County Health District - Air Quality Management Division (AQMD) is requesting

the U.S. Environmental Protection Agency (EPA) to redesignate the Truckee Meadows 1 

## nonattainment area (NAA) to attainment/maintenance status for the 24

- hour Particulate Matter less

than 10 microns in aerodynamic diameter (PM 10 

## ) National Ambient Air Quality Standard

(NAAQS). The Truckee Meadows has not v iolated the NAAQS since 2002 and is currently

classified as a “Serious” NAA. 2



## T he AQMD also requests that the “Redesignation Request and Maintenance Plan for the Truckee

Meadows, 24-Hour PM10 Non-Attainment Area” submitted to EPA on July 13, 2009 be

wit hdrawn.

Washoe County is located in the northwest portion of Nevada and is bounded by the states of

California, Oregon, and the counties of Humboldt, Pershing, Storey, Churchill, Lyon, and Carson

City (Figure 1

- 1). The Truckee Meadows is approximately 200 square miles in size and situated

in the southern portion of Washoe County. It is geographically identified as Hydrographic Area

(HA) 87 as defined by the State of Nevada , Division of Water Resources . It is surrounded by

mountain ranges, which can le ad to wintertime temperature inversions

, where a layer of cold air

is trapped in the valley. Warmer air above the inversion acts as a lid, containing and

concentrating air pollutants. Much of Washoe County’s urban population lives in the Truckee

Meadows. Anthropogenic activities, such as automobile use and residential wood combustion,

are also concentrated here.

The Truckee Meadows covers an area governed by three

political entities - the County of Washoe, the City of Reno,

and the City of Sparks. The AQMD is the designated agency

responsible for air quality management throughout the entire

county.

This Redesignation Request and Maintenance Plan was

prepared in accordance with Section 107(d)( 3)(E) of the Clean

Air Act (CAA) as amended in 1990 and follows guidance

contained in the Calcagni Memorandum. 3 

## The following five

sections are structured and organized as presented in

Subsections (i) through (v) of Section 107(d)(3)(E).

1 Identified as the “Reno Planning Area” in 40 CFR 81.329.

2 40 CFR 81.329.

3 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Divi sion (MD

15); September 4, 1992. 

## Figure 1

- 1

Washoe County, Nevada

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 2 

## CHAPTER 2

ATTA INMENT OF THE STANDARD

The first condition for redesignation is demonstration of attaining the NAAQS. This condition is

met when ambient PM 10 

## monitoring data are representative, complete, quality-assured, and

reported in accordance with 40 Code of Feder al Regulations ( CFR ) 50, 53, and 58, and meet the

NAAQS. Ambient air monitoring data demonstrate that the Truckee Meadows area attained the

NAAQS in 2002. The following information further validates the long- term air quality

improvements within the Truck ee Meadows.

National Ambient Air Quality Standard

The level of NAAQS for PM 10 

## is 150 μ g/m 3 

## over a 24-hour averaging period; the number of

times a monitor is expected to exceed this concentration must be less than one per year for the

NAAQS to be attained . The rounding convention in the standard specifies that values be

rounded to the nearest 10 μ g/m 3 

## (i.e., values ending in 5 or greater are to be rounded up). If less

than everyday sampling occurs, an adjustment factor must be applied to the number of me asured

exceedances to determine the number of expected exceedances. 4



## Washoe County Monitoring Network

Between 1999 and 2012, the AQMD maintained eight State and Local Air Monitoring Station s

(SLAMS) , one of which is also a National Core Multi-Pollutant Monitoring Station (NCore),

within Washoe County (Figure 2- 1). Six of the eight active monitoring sites were located within

the Truckee Meadows. All of these sites were sited in accordance with 40 CFR 58 and utilized

monitoring equipment designated as reference or equivalent methods under 40 CFR 53. In

addition, Washoe County’s PM 10 

## monitoring network was reviewed annually pursuant to 40

CFR 58.10 to ensure the network meets the monitoring objectives defined in 40 CFR 58,

Appendix D. The data were collected and quality assured in accordance with 40 CFR 58 and

recorded in the Air Quality System (AQS), formerly referred to as Aerometric Information

Retrieval System (AIRS).

4 40 CFR 50, Appendix K.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 3 

## Figure 2 -1

PM 10 

## Monitoring Network (1999-2012)

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 4 

## Monitoring Data

PM 10 

## monitoring data were collected, complete

, 

## quality assured, recorded in AQS, and available

for public review in accordance with 40 CFR 58. Expected exceedance rates were calculated

following guidance in the 40 CFR 50, Appendix K. Table 2- 1 summarizes the exceedances and

expected number of exceedances from 1999 to 2012 . These data are from SLAMS and NCore

sites within Washoe County, including the Truckee Meadows.

Based on these data, the Truckee Meadows violated the 24 -hour PM 10 

## NAAQS as recent as

2001. However, the long- term trend has been a decline in ambient PM 10 

## exceedances (See Table

2-1 and Figure 2-2). Since 2002, the Truckee Meadows expected exceedance rate has been equal

to or less than one and therefore, has attained the NAAQS i n accordance with 40 CFR 50.6.

On April 19, 2011, EPA published a final rule determining that the Truckee Meadows area is

currently attaining the PM 10 

## NAAQS, based upon complete, quality- assured PM 10 

## air quality

monitoring data during the years 2007-2009. 5 

## Certified data through December 2012 contained

in EPA’s AQS are also consistent with continued attainment of the 24-hour PM 10 

## NAAQS.

Because the Truckee Meadows area is currently attaining the PM 10 

## NAAQS, EPA also finaliz ed

its determination that the obligation to make submissions to meet certain CAA requirements

related to attainment is not applicable for as long as the area continues to attain the PM 10 

## NAAQS. 6



## Table 2 -1

Seasonal PM 10 

## Concentrations and Exceedances (1999-2012)

Monitored Concentration

and Exceedan ces * 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

1 st 

### High (ug/m 3 

### ) 215 109 81 97 108 126 172 106 130 87 93 142 121 100

2 nd 

### High ( u g/m 3 

### ) 197 100 7 4 8 5 100 90 103 104 1 08 76 91 7 7 113 92

Exceedances (Measured) 1 0 0 0 0 0 1 0 0 0 0 0 0 0

Exceedances (Expected) 6.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

3

- Year Average of

Expected 2.0 2.0 2.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* For the PM 10 

### Season ( November

, December, January ).

5 76 FR 21807 (April 19, 2011).

6 Ibid.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 5 

## Figure 2-2

Seasonal PM 10 

## Concentrations and Exceedances (1999-2012)

* For the PM 10 

### Season (January, November, and December ).

** PM 10 

### NAAQS is 150 μ g/m 3 

### ; however, due to EPA ’s rounding convention for PM 10 

### , a concentration of 154

μ g/m 3 

### would still be considered not exceed ing the NAAQS.



## Historically, t he regular PM 10 

## sampling schedule using manual methods in the Truckee Meadows

is once every six days, 7 

## with the exception of air pollution episodes when monitoring wa s

conducted more frequently. However, more frequent monitoring after the PM 10 

## exceedance in

January 1999 was not initiated . In accordance with the procedures in Appendix K of 40 CFR 50,

this single measured exceedance equals six expected exceedances.

In January 2005, ano ther PM 10 

## episode occurred resulting from record snowstorms followed by

strong temperature inversions. The storms required many applications of road sand that was

eventually ground into smaller particles and re- entrained by vehicle traffic. The regular PM 10 

## sampl e day was Sunday, January 16. Because PM 10 

## concentrations were increasing to unhealthy

levels at two monitoring sites (Reno3 and Sparks sites), additional PM 10 

## sampling began at the

Galletti site on Friday, January 14. The PM 10 

## concentration on January 14 was 172 μ g/m3 and

everyday sampling, as required by 40 CFR 58.12, continued at this site through the end of

calendar year 2005 (Table 2-2). Due to the daily sampling of this site, the single measured

exceedance equals one expected exceedance for 2005.

7 “Waivers for PM 10 Sampling Frequency”; William F. Hunt, Jr., Director, Emissions, Monitoring, and Analysis Division (MD

- 14); December 2,

1997. 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Expected Exceedance Rate 2.0 2.0 2.0 0.0 0.0 0.0 0.3 0.3 0.3 0.0 0.0 0.0 0.0 0.0

Exceedance Rate Std. 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

1st High PM10* 215 109 81 97 108 126 172 106 130 87 93 142 121 100

2nd High PM10* 197 100 74 85 100 90 103 104 108 76 91 77 113 92

PM10 NAAQS** 154 154 154 154 154 154 154 154 154 154 154 154 154 154 

### 0 50 100 150 200 250

0.0 1.0 2.0 3.0 4.0 5.0 6.0Expected Exceedance RatePM10 Concentration (ug/m3)

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 6 

## Table 2 -2

Galletti Ambient Air Monitoring Data (2005)

Number of Samples Data

Capture Concentration ( μ g/m 3 

## ) Exceedances

Quarter Valid Possible 1 st 

## High 2 nd 

## High Measured Expected

Jan

- Mar 74 90 0.82 172 153 1 1

Apr - Jun 88 91 0.97 116 90 0 0

Jul

- Sep 87 92 0.95 91 86 0 0

Oct

- Dec 79 92 0.86 103 102 0 0

Summary 172 153 1 1



## Per 40 CFR 50, Appendix K, Section 3.1(f), the number of measured and expected exceedances

is one because: 1) There was only one exceedance in the calendar quarter, 2) everyday sampling

was initiated and maintained for four calendar quarters, and 3) data capture of at least 75 % was

achieved for each quarter.

As of 2006 , there are six PM 10 

## monitoring sites in the Truckee Meadows (Figure 2-1).

Currently , e ach monitoring site utilizes the continuous PM 10 

## B eta Attenuation Monitor (BAM)

method, with the exception of the Reno site, which has an additional manual PM 10 

## method.

Table 2

- 3 delineates the timeline and transition dates of the PM 10 

## monitoring methods from

manual to continuous sampling for each site.

Table 2 -3

Operational History of PM 10 

## Monitoring Network and Sampling Methods

Monitoring Site Sampling Method Sampling Frequency AQS Submittal Period

Galletti Manual 1:6 Jan 1990

- Dec 2012

BAM Continuous Dec 2012

- present

Incline Manual 1:6 Oct 1999

- Mar 2002

Plumb

- Kit Manual 1:6 Jan 2006

- Nov 2011

BAM Continuous Nov 2011

- present

Reno Manual 1:6 Apr 1988

- Mar 2009

Manual 1:3 Mar 2009

- present

BAM Continuous Dec 2010

- present

S. Reno Manual 1:6 Jan 1990

- Oct 2011

BAM Continuous Oct 2011

- present

Sparks Designated Manual 1:6 Apr 1988

- Dec 2012

BAM Continuous Dec 2012

- present

Sparks Collocated Manual 1:6 Jan 1990

- Dec 2012

BAM Continuous Dec 2012

- present

Toll Manual 1:6 Jan 2002

- Oct 2011

BAM Continuous Oct 2011

- present

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 7 

## Summary

The EPA has determined that the Truckee Meadows is currently attaining the 24-hour PM 10 

## NAAQS, based upon complete, quality- assured PM 10 

## air quality monitoring data during the years

2007 - 2009. 8 

## Certified data through December 2012 contained in EPA’s AQS are also

consistent with continued attainment of the 24-hour PM 10 

## NAAQS.

From 1999 through 2012, PM 10 

## ambient air monitoring data from the Truckee Meadows:

• Were collected from a PM 10 

## monitoring network that was sited, operated, and maintained

in accordance with 40 CFR 53 and 58; and

• Were complete, quality assured, and reported in accordance with 40 CFR 58.

From 2002 through 2012, PM 10 

## ambient air monitoring data from the Truckee Mead ows:

• Demonstrated that the number of times a monitor was expected to exceed a 24 -hour PM 10



## concentration of 150 μ g/m 3 

## (as determined in accordance with 40 CFR 50, Appendix K)

was less than one per year.

Therefore, the Truckee Meadows has attained the 24 -hour PM 10 

## NAAQS in accordance with 40

CFR 50.6.

8 76 FR 21807 (April 19, 2011).

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 8 

## CHAPTER 3

STATE IMPLEMENTATION PLAN APPROVAL

The second condition for redesignation is that the applicable implementation plan requirements

have been fully approved by the EPA under Section 110(k) of the CAA.

On November 15, 1990, the date of enactment of the 1990 CAA Amendments, PM 10 

## areas

meeting the qualifications of Section 107(d)(4)(B) of the CAA were designated non- attainment

by operation of law. Once an area is designated non-attainment, Section 188 of the CAA

outlines the process for classification of the area and establishes the area’s attainment date.

Pursuant to Section 188(a), all PM 10 

## non- attainment areas were initially classified as “ Moderate”

by operation of law upon designation as non- attainment. The Truckee Meadows “Moderate”

non-attainment designation was codified in 40 CFR 81.329 in a Federal Register ( FR ) notice

published on November 6, 1991. 9



## States containing areas, which were designated as “Moderate ” non-attainment by operation of

law under section 107(d)(4)(B), were to develop and submit state implementation p lans (SIPs) to

provide for the attainment of the PM 10 

## NAAQS. Pursuant to section 189(a)(2), those SIP

revisions were to be submitted to EPA by November 15, 1991.

EPA has the responsibility, pursuant to sections 179(c) and 188(b) (2) of the Act, of determ ining

within six months of the applicable attainment date, whether PM 10 

## NAAs have attained the

NAAQS. Section 179(c)(1) of the Act provides that these determinations are to be based upon

an area’s “air quality as of the attainment date”, and section 188(b )(2) is consistent with this

requirement. EPA makes the determinations of whether an area’s air quality is meeting the PM 10 

## NAAQS based upon air quality data gathered at monitoring sites in the non- attainment area.

Th ese data are reviewed to determine the area’s air quality status in accordance with EPA

guidance in 40 CFR 50, Appendix K.

Pursuant to Appendix K, attainment of the 24-hour standard is determined by calculating the

expected number of exceedances of the 150 μ g/m 3 

## limit per year. The 24 -hour standard is

attained when the number of times a monitor is expected to exceed this concentration is equal to

or less than one per year . A total of three consecutive years of clean air quality data is generally

necessary to show attainment of the 24-hour standard for PM 10 

## . A complete year of air quality

data, as referred to in 40 CFR 50, Appendix K, is comprised of all four calendar quarters with

each quarter containing data from at least 75 % of the scheduled sampling days.

Under section 188(b)(2)(A), a “ Moderate” PM 10 

## NAA must be reclassified as “ Serious ” by

operation of law after the statutory attainment date if the Administrator finds that the area has

failed to attain the NAAQS. Pursuant to section 188(b)(2)(B) of the Act, EPA must publish a

notice in the FR identifying those areas that failed to attain the standard and the resulting

reclassifications. As a result, the Truckee Meadows was reclassified to a “ Serious ” NAA on

February 7, 2001.

9 56 FR 56694 (November 6, 1991).

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 9 

## In response to the “ Serious ” designation, the AQMD prepare d a PM 10 

## SIP. The SIP included a

periodic emission inventory that identified the significant wintertime PM 10 

## sources in the

Truckee Meadows as construction/grading, street sanding, street sweeping, and residential wood

combustion (RWC). In “Serious” PM 10 

## NAAs, Best Available Control Measures (BACM) is

required to be applied to these sources. To ensure that BACM is properly applied, the AQMD

follows EPA guidance, consults with EPA during the rule development process, and participates

in the EPA Region IX PM 10 

## SIP BACM working group. T his group meets twice per year to

discuss and share knowledge about control measures affecting “Serious” PM 10 

## NAAs in the

Pacific Southwest. However, no meeting has taken place after 2009.

Th e “Serious” PM 10 

## SIP was adopted by the Washoe County District Board of Health

(WCDBOH) on July 26, 2002 and submitted to EPA on August 5, 2002. Additional SIP

elements were submitted in 2006 to address deficiencies in the RWC regulation and emergency

episode plan. EPA has approved many of these submittals, but has not fully approved the PM 10



## SIP.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 10 

## CHAPTER 4

PERMANENT AND ENFORCEABLE IMPROVEMENT IN AIR QUALITY

The third condition for redesignation is EPA must determine that air quality improvements are

due to permanent and enforceable emission reductions. Long

- term air quality improvements in

the Truckee Meadows are attributed to permanent and enforceable federal, state, and local

emission reduction programs. In addition, improvements were not a result of temporary

reduction in emission rates or unusually favorable meteorology.

Federally Enforceable Control Programs in the Truckee Meadows Portion of the Nevada SIP

The following programs have significantly reduced PM 10 

## emissions and contributed to the air

quality improvements in the Truckee Meadows. These programs are federally enforceable and

included in the Truckee Meadows portion of the Nevada PM 10 

## SIP. They are implemented by

federal, state, and local regulatory agencies. Emission reductions from the state and local

programs are summarized in Table 4-1. D etailed documentation is located in Appendix A.

1. Residential Wood Combustion Program : R WC has been identified as a significant source

of wintertime PM 10 

## emissions. WCDBOH Regulation 040.051 10 

## addresses and reduces

these emissions. This regulation: 1) Establishes wood stove / fireplace insert control

areas; 2) requires use of seasoned wood; 3) clarifies “Prohibited Fuels”; 4) requires

removing or upgrading existing solid fuel combustion devices upon real estate sale; and

5) includes a mandatory burning curtailment during Stage 1 episodes. Approximately

784 lbs/day of PM 10 

## emissions were reduce d from the Truckee Meadows in 2011 due to

the RWC program.

In addition, the AQMD implements a “Green, Yellow, Red” Program 11 

## from November

through February to reduce wintertime RWC PM 10 

## emissions. This public outreach

program consists of a daily burn code that provides the community a recommendation on

whether RWC will impact air quality in Washoe County. RWC is discouraged when the

burn code is Yellow and prohibited when the code is Red. As part of the carbon

monoxide maintenance plan SIP, the AQMD is committed to conducting an RWC survey

at least once every three years

. 12 

## A recent survey conducted in 2013 indicated 88% of all

respondents who burned wood were aware of the “Green, Yellow, Red” Program

, and

74% of those respondents followed the Yellow and Red recommendations. 13 

## Emission

reductions from the “Green, Yellow, Red” Program are quantified under the Emergency

Episode Plan.

Additional benefits are realized in the Truckee Meadows because the RWC Program is

applicable to the entire geographic area o f Washoe County.

10 72 FR 33397 (June 18, 2007)

. 11 The “Green, Yellow, Red” was u pdated and rebranded to “Keep it Clean, Know the Code” in November 2012.

12 73 FR 38124 (July 3, 2008).

13 “Washoe County Health District; Air Quality Management Division; Residential Wood Use Survey”; InfoSearch International; May 2013.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 11 

## 2. Street Sanding and Sweeping Program : The Truckee Meadows receives approximately 2 3

inches of snow per year. Wintertime traction control is a significant source of PM 10 

## emissions. Emissions are generated directly from application of tra ction control material

(i.e., sand, salt, and chlorides) and indirectly from the increased silt loading on the paved

streets. Motor vehicle traffic grinds and re- entrains the material into the atmosphere.

In 2002, the WCDBOH adopted revisions to Regulations 040.031 and 040.032. 14 

## These

revisions required municipalities to: 1) Use a harder and cleaner type of sand, 2) reduce

the sand application rate by 50% compared to 1999 rates, 3) remove the sand within four

days after a storm event, and 4) only purcha se new sweepers that are PM 10 

## certified.

Approximately 1,555 lbs/day of PM 10 

## emissions were reduced in the Truckee Meadows

in 2011 because of the Street Sanding and Sweeping program. Additional benefits are

realized in the Truckee Meadows because the Street Sanding and Sweeping Programs are

applicable to additional geographic areas of Washoe County. This area encompasses all

of the urbanized portions of Washoe County south of Township 22N, which includes the

cities of Reno and Sparks.

3. Dust Control : Fugitive PM 10 

## generating sources, such as construction activities and

unpaved roads, are subject to WCDBOH Regulation 040.030. 15 

## The cu rrent regulation

implements BACM and was adopted by the WCDBOH in 2002. In addition, projects that

disturb one acre of more of land are required to obtain a Dust Control Permit from the

AQMD. The Dust Control permit includes additional control and contin gency measures

that are to be implemented before, during, and after completion of the project.

Approximately 431 lbs/day of PM 10 

## emissions were reduced in the Truckee Meadows

because of the Dust Control program. Additional benefits are realized in the Truckee

Meadows because the Dust Control regulation is applicable to the entire geographic area

of Washoe County.

4. Emergency Episode Plan : WCDBOH Regulation 050.001 16 

## addresses actions that the

AQMD shall take during periods of elevated ambient PM 10 

## conce ntrations. When 24-

hour PM 10 

## concentrations reach, or are predicted to reach, Stage 1 levels (154 μ g/m 3 

## ), the

regulation: 1) Implements notification procedures to the public about potential health

problems 2) prohibits all open and prescribed burning, 3) prohibits the use of permitted

incinerators, crematoriums, and pathological incinerators, 4) prohibits the use of solid

fuel burning devices, and 5) activates control plans for the largest PM 10 

## sources in the

county.

Approximately 4,331 lbs/day of PM 10 

## emissions were reduced in the Truckee Meadows

because of the Emergency Episode Plan. The Truckee Meadows receives additional

benefits from the Emergency Episode Plan because it is applicable to the entire

geographic area of Washoe County.

14 71 FR 14386 (March 22, 2006).

15 72 FR 25969 (May 8, 2007).

16 72 FR 33397 (June 18, 2007).

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and Maintenance Plan 12 

## Table 4 -1

2011 Emission Reductions from Federally Enforceable Programs

Emissions

(lbs / Typical PM 10 

## Season Day)

Federally Enforceable Program Uncontrolled Controlled Reductions

Residential Wood Combustion 1,784 1,000 784

Street Sanding and Sweeping 1,894 339 1,555

Dust Control 861 431 431

Emergency Episode Plan 5, 88 8 1, 5 57 4, 3 31

Total 10

, 42 7 3,3 27 7, 100

* Totals may not add up due to rounding.



## Other Programs That Provide Additional PM 10 

## Benefits

The Truckee Meadows also benefits from other PM 10 

## control programs. Although these

programs are not part of the Truckee Meadows portion of the Nevada PM 10 

## SIP, they contribute

to air quality improvements in the area. These programs are applicable to the entire geographic

area of Washoe County.

1. Non -Road Diesel Emission Standards : The Clean Air Non

- Road Diesel Rule, which was

signed in 2004, established stringent Tier 4 PM and Nitrogen Oxides ( NO

x 

## ) emission

standards. This rule is the most recent of a series of regulations addressing non-road

diesel emi ssions. These standards will dramatically reduce PM emissions nationwide as

the diesel fleet turns over.

2. Ultra Low Sulfur Diesel (ULSD) : The Clean Air Non -Road Diesel Rule, along with the

2007 Highway Rule, lowers the sulfur content of diesel fuel. All diesel fuel for on

- road

and non-road uses will have a maximum sulfur content of 15 ppm by 2014.

3. Washoe County Smoke Management Program : Particulate matter is a major component

of smoke. The AQMD has developed and implemented a Smoke Management Program

(SMP) to balance the need for forest fuels management while maintaining clean air

requirements. Major components of the SMP are: 1) Consideration of alternatives; 2)

stringent meteorological prescriptions; 3) notification procedures; and 4) contingency

me asures. Section C.2.a.(2) of WCDBOH Regulation 050.001 addresses PM 10 

## impacts

from prescribed burning by prohibiting these projects during Stage 1 air pollution

episodes. Washoe County’s SMP was adopted by the WCDBOH in 2003 and submitted

to EPA Region IX in 2006.

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and Maintenance Plan 13 

## Economic Conditions

Between 1990 and 2011, Washoe County, including the Truckee Meadows, experienced growth

in population, full and part

- time employment, total industry earnings, and vehicle miles traveled

(VMT)

. Table 4

- 2 lists these indicators and their overall rate of growth.

Table 4 -2

Washoe County Demographic and Economic Indicators (1990-2011)

Indicator Source* 1990 2011 2011/1990 Ratio

Population A 257,120 42 1,593 1.6 40

Full

- and Part

- time Nonfarm Employment B 173,790 244,438 1.407

Total Nonfarm Industry Earnings** C $4,541,507 $11,732,922 2.583

Vehicle Miles Traveled*** D 4,225,134 7,870,307 1.863

* A: Nevada State Demographer, Washoe County Population.

B: Bureau of Economic Analysis, “CA25N Total full

- time and part

- time employment for Washoe County”, 1990

is by SIC industry and 2011 is by NAICS industry

. C: Nevada Workforce Informer, Nevada Department of Employment, Training and Rehabilitation, 2011 Annual

Employment and Wages for Washoe County

. D: 1990 Emission Inventory of Carbon Monoxide, Amended Final; November 2, 1993; 2011 Periodic Emissions

Inventory; November 2012; Table 1

- 2.

** Total Industry Earnings are in 20 12 Dollars (1,000’s).

*** Vehicle Miles Traveled are in miles per day and represent only the Truckee Meadows PM 10 

### NAA portion of

Washoe County.



## Washoe County’s air quality continued to improve despite substantial growth in population,

economic activity, and VMT

. Based on these demograp hic and economic data, long- term

improvement in Washoe County’s air quality was not due to temporary reductions in emission

rates.

Meteorological Conditions

As described earlier, the Truckee Meadows sits in a valley surrounded by mountain ranges.

Wintertime high

- pressure systems are characterized by stable atmospheric conditions, light

winds, sunny days, and clear, cold nights. Cold nights, combined with local topography, can

create temperature inversions where a layer of cold air is contained in the va lley. Warm air

above the inversion acts as a lid trapping and concentrating pollutants. The low winter sun angle

provides only slight warmth deterring the break -up of the inversion without wind or a storm

front. This wintertime atmospheric condition is the major contributor to th e Truckee Meadows

experiencing its highest PM 10 

## concentrations.

An indicator of unusually favorable wintertime meteorology is periods of unstable atmospheric

conditions. Wind, clouds, milder night temperatures, good dispersion, and precipitation

characterize these unstable conditions. Figure 4 -1 displays the annual number of days of

precipitation of 0.01 inches or greater during the months of November, December, and January

. The historic normal number of days (18 .3) is also included as a reference. These data were

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and Maintenance Plan 14 

## recorded at the Reno -Tahoe International Airport. 17 

## Favorable meteorology conditions leading

to low PM 10 

## concentrations would mean a greater than normal number of precipitation days.

Wintertime precipitation data indicate that 12 of the 23 years between 1990 and 2012 were above

the historic normal number of 1 8.3 precipitation days per year. Of the four years with PM 10



## exceedances , two were above (1993 and 2005) and t wo were below (1991 and 1999) the historic

normal number of precipitation of days. Over the years, the monitored PM 10 

## exceedances and

expected exceedance rate declined while the number of precipitation days fluctuated above and

below the historic normal . Therefore , improvements in air quality cannot be solely attributed to

favorable precipitation conditions.

Figure 4 -1

Precipitation Days (1990-2012)

Wind speed is another meteorological indicator for PM 10 

## concentrations. In the Truckee

Meadows, higher wind speeds typically reflect unstable conditions and favorable PM 10



## conditions. Figure 4

- 2 displays the mean wintertime wind speeds from 1990 through 2012.

Of the 13 years with wind speeds below the historic mean, three years had at least one PM 10



## exceedance and the other 10 had zero. Because the monitored PM 10 

## exceedances and expected

exceedance rate declined while the m ean wind speed fluctuated above and below the historic

mean, improvements in air quality cannot be solely attributed to favorable wind speeds.

17 The official site where precipitation, wind speed, and atmospheric pressure data are recorded was relocated three times since 1931. The

precipitation data collected were from sites located: 1) within a two mile radius of each other; 2) at the same elevation (less than ten feet

difference); and 3) within the Truckee Meadows PM 10 NAA. 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Precipitation Days 15 10 15 20 18 22 30 24 18 12 14 22 20 13 15 25 15 13 26 17 27 5 22

Historic Normal 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 0 50 100 150 200 250

0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0PM10Concentrations (ug/m3)Precipitation Days(0.01 inches or greater)

Trend Line

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and Maintenance Plan 15 

## Figure 4 -2

Mean Wind Speed (1990-2012)

Another indicator of favorable meteorological conditions is barometric pressure. Lower

pressures are associated with unstable conditions, increased atmospheric mixing, weaker

temperature inversions, and lower PM 10 

## concentrations. Figure 4-3 displays the mean barometric

pressure s in the Truckee Meadows. Only January and November data were available for 1996

and 1998. These years are not included in the figure, but the mean pressures for the two months

of these two years were below the historic mean. 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Wind Speed 5.0 4.4 6.0 6.2 6.2 5.6 6.0 3.7 5.3 4.4 4.8 4.6 5.3 4.5 3.6 4.8 5.6 3.8 4.5 3.3 4.7 3.5 5.1

Historic Mean 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 0 50 100 150 200 250

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0PM10Concentrations (ug/m3)Mean Wind Speed (mph)

Trend Line

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and Maintenance Plan 16 

## Figure 4 -3

Mean Station Barometric Pressure (1990-2012)

Note: blank cells indicate i ncomplete data for 1996 and 1998 ; however, partial data indicated both years

were below the historic mean.



## Of the 21 years with complete mean barometric pressure data, 12 years were above and nine

years were below the historic mean of 2 5.63 inches of mercury

. Eight of the 12 years with

barometric pressures at or above the historic mean did not have a monitored PM 10 

## exceedance.

The monitored PM 10 

## exceedances and expected exceedance rate declined over the years while

the precipitation days, wind speeds, and barometric pressures fluctuated above and below the

historic averages . Therefore, improvements in air quality cannot be solely attributed to f avorable

meteorological conditions.

Summary

The Truckee Meadows experienced long

- term air quality improvements attributed to federal,

state, and local control measures. In addition, Washoe County did not experience an economic

downturn or unusually consistent favorable meteorology. 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Mean Station Pr. 25.6 25.7 25.6 25.6 25.6 25.6 25.6 25.7 25.7 25.6 25.6 25.7 25.7 25.7 25.7 25.7 25.6 25.7 25.4 25.7 25.6

Historic Mean 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 0 50 100 150 200 250

25.30 25.50 25.70 25.90 26.10 26.30 26.50PM10Concentrations (mug/m3)Mean Station Pressure (inches of Hg)

Trend Line

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and Maintenance Plan 17 

## CHAPTER 5

SECTION 110 AND PART D REQUIREMENTS

For the purposes of redesignation, all of the general non- attainment area requirements of the

1990 CAA Section 110 and Part D must be met.

Section 110 Requirements

In gener al, the requirements of Section 110(a)(2) are:

• The establishment and implementation of enforceable emission limitations;

• The monitoring, compiling, and analyzing of ambient air quality data;

• Pre -construction reviews and permitting of new and modified major stationary sources;

• Consulting with and providing for the participation of local governments that are affected

by the plan;

• Assurance that the State has the adequate funds and authority to enforce the SIP element

and the associated regulations; and

• P ermit fees for stationary sources.

Nevada Revised Statute (NRS) 445B.500 18 

## addresses the Section 110(a)(2) requirements by

authorizing the WCDBOH to implement and administer air quality management programs within

the boundaries of Washoe County. These programs are managed through the AQMD. The

AQMD currently consists of 18 allocated full -time staff with an annual budget of $2.2 million

. Primary funding sources are: 1) Operating permit fees; 2) EPA grants; 3) Nevada DMV funds;

and 4) the City of Reno, City of Sparks, and County of Washoe County via an inter- local

agreement with the Washoe County Health District.

Should the AQMD be unable to meet the Section 110 requirements, NRS 445B.520 19 

## and

445B.530 20 

## allows the State Environmental Commission to assume j urisdiction over the local air

quality management program to ensure that the CAA requirements are satisfied. In addition,

EPA has authority to impose sanctions on a State where EPA “. . . finds that any requirement of

an approved plan (or approved part of a plan) is not being implemented . . .”. 21

18 “ Establishment and administration of program; contents of program; designation of air pollution con trol agency of county for purposes of

federal act; powers and duties of local air pollution control board; notice of public hearings; delegation of authority to de termine violations and

levy administrative penalties; cities and smaller counties; regulation of certain electric plants prohibited”; May 23, 2007.

19 “ Commission may establish or supersede county program”.

20 “ Commission may assume jurisdiction over specific classes of air contaminants”.

21 1990 CAAA; Section 179 “Sanctions and Consequences of Failure to Attain”.

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and Maintenance Plan 18 

## Part D Requirements

The 1990 CAA lists the requirements for “Serious” PM 10 

## NAAs in Part D, Subparts 1 and 4, and

the General Preamble. These requirements were completed, implemented, and submitted to EPA

by the dates specified in Section 187(a). A summary of these SIP elements is detailed in Table

5-1. EPA has not taken forma l action on these elements. Table 5 -1 also describes current

activities by AQMD to revise and resubmit certain materials previously submitted to EPA based

on consultation between the AQMD and EPA. In accordance with the Calcagni Memorandum,

the AQMD requ ests that EPA simultaneously approve the applicable SIP elements and

redesignation request.

PM 10 

## NAAs reclassified as “ Serious” under section 188(b)(2) of the CAA are required to submit,

within 18 months of the area’s reclassification, SIP revisions providing for the implementation of

BACM no later than four years from the date of reclassification. The SIP must also contain,

among other things, a demonstration that the implementation of BACM will provide for

attainment of the PM 10 

## NAAQS no later than Dece mber 31, 2001 (See CAA sections 188(c)(2)

and 189(b)). EPA has provided specific guidance on developing “Serious” area PM 10 

## SIP

revisions in an addendum to the General Preamble to Title I of the Clean Air Act. 22



## In response to the “Serious” designation, t he AQMD prepared a PM 10 

## SIP. The SIP included a

periodic emission inventory that identified the significant wintertime PM 10 

## sources in the

Truckee Meadows as construction/grading, street sanding, street sweeping, and RWC. In

“Serious” PM 10 

## NAAs, BACM is required to be applied to these sources. To ensure that BACM

is properly applied, the AQMD follows EPA guidance, consults with EPA during the rule

development process, and participates in the EPA Region IX PM 10 

## SIP BACM working group.

This group meets twice per year to discuss and share knowledge about control measures

affecting “Serious” PM 10 

## NAAs in the Pacific Southwest. However, no meetings ha ve taken

place since 2009.

The “Serious” PM 10 

## SIP was adopted by the WCDBOH on July 26, 2002 and submitted t o EPA

on August 5, 2002. Additional SIP elements were submitted in 2006 to address deficiencies in

the RWC regulation and emergency episode plan. EPA has approved many of these submittals,

but has not fully approved the PM 10 

## SIP.

In order to ensure that the Prevention of Significant Deterioration (PSD) program will become

fully effective immediately upon redesignation (to replace the Part D new source review

program), the Count y must either be delegated the F ederal PSD program or make any needed

modifications to its rules to have the approved PSD program apply to the affected area upon

redesignation. EPA granted full delegation of the Federal PSD program (40 CFR 52.21) to

Washoe County in March 2008.

22 

### 59 FR 41998 (August 16, 1994).

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and Maintenance Plan 19 

## Table 5-1

Part D Requirements and Actions for the Truckee Meadows PM 10 

## NAA

CAA

Section Requirement Reference Submitted to

EPA Comments

172(c)(1) Reasonably

Available Control

Measure ( RACM )/

Reasonably

Available Control

Technology

( RACT ) --- --- BACM subsumes RACM.

172(c)(2) RFP EPA’s General

Preamble, 23



## Calcagni

Memorandum at

page 6, 24 

## and

Clean Data

Policy 25 

## --- Attained the 24

- hour PM 10 

## NAAQS in 2002 based on

ambient air monitoring

data. A ttain ed the 24-hour

PM 10 

## NAAQS based on

EPA’s clean data finding

for 2007-2009. 26



## 172(c)(3) Emission

Inventories EPA’s General

Preamble, 27



## Calcagni

Memorandum at

page 6. 28 

## Baseline and

periodic

inventories

submitted at

various times,

most recently in

January 2013. The 20 11 periodic

inventory was also used as

a baseline for the 2011

attainment inventory and is

included in Chapter 6,

Maintenance Plan.

172(c)(4) Identification and

Quantification EPA’s General

Preamble, 29



## Calcagni

Memorandum at

page 6. 30 

## --- N/A

23 57 FR 13498, 13564 (April 16, 1992).

24 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Divi sion (MD

15); September 4, 1992.

25 “C lean Data Policy for the Fine Particulate National Ambient Air Quality Standards”; Stephen D. Page, Director, Office of Air Q uality

Planning and Standards; December 14, 2004.

26 76 FR 21807 (April 19, 2011).

27 57 FR 13498, 13564 (April 16, 1992).

28 “Procedu res for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD

15); September 4, 1992.

29 57 FR 13498, 13564 (April 16, 1992).

30 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD

15); September 4, 1992.

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and Maintenance Plan 20 

## Table 5 -1 (continued)

Part D Requirements and Actions for the Truckee Meadows PM 10 

## NAA

CAA

Section Requirement Reference Submitted to

EPA Comments

172(c)(5) NSR EPA’s General

Preamble, 31



## Calcagni

Memorandum at

page 6, 32



## 030.500-

030.508, 33 

## and

Nichols Memo 34 

## April 7, 1994 Lack of approval of NAA

NSR program not an

obstacle to redesignation.

Washoe County’s PSD

program will become fully

effective immediately upon

redesignation, pursuant to

EPA delegation

. 35



## 172(c)(6) Other Measures as

Necessary EPA’s General

Preamble, 36



## Calcagni

Memorandum at

page 6. 37 

## --- N/A

172(c)(7) Compliance with

Section 110(a)(2) NRS

445B.500 38 

## --- Addressed earlier (first

page) in this chapter.

172(c)(8) Equivalent

Techniques EPA’s General

Preamble 39 

## and

Calcagni

Memorandum at

page 6. 40 

## --- N/A

31 57 FR 13498, 13564 (April 16, 1992).

32 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Managem ent Division (MD

15); September 4, 1992.

33 WCDBOH Regulations Governing Air Quality Management; Section 030.050

- 030.508, “Federal New Source Review (NSR)”.

34 “Part D New Source Review (part D NSR) Requirements for Areas Requesting Redesignation to Attainme nt”; Mary D. Nichols, Assistant

Administrator for Air and Radiation (6101); October 14, 1994.

35 Agreement for Delegation of the Federal Prevention of Significant Deterioration (PSD) Program by the United States Environmen tal

Protection Agency, Region 9 to the Washoe County District Health Department, 3/13/08.

36 57 FR 13498, 13564 (April 16, 1992).

37 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Divi sion (MD

15); September 4, 1992.

38 “ Establishment and administration of program; contents of program; designation of air pollution control agency of county for purposes of

federal act; powers and duties of local air pollution control board; notice of public hearings; delegation of authority to determine violations and

levy administrative penalties; cities and smaller counties; regulation of certain electric plants prohibited”.

39 57 FR 13498, 13564 (April 16, 1992).

40 “Procedures for Processing Requests to Redesignate Areas to Attainment”; Jo hn Calcagni, Director; Air Quality Management Division (MD

15); September 4, 1992.

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and Maintenance Plan 21 

## Table 5 -1 (continued)

Part D Requirements and Actions for the Truckee Meadows PM 10 

## NAA

CAA

Section Requirement Reference Submitted to

EPA Comments

172(c)(9) Contingency

Measures EPA’s General

Preamble, 41



## Calcagni

Memorandum

at page 12, 42



## and Clean Data

Policy (Maintenance

plan

contingency

measures

supersede the

172(c)(9)

attainment

contingency

measure

requirement.) Attained the 24

- hour

PM 10 

## NAAQS in 20 11

based on ambient air

monitoring data. A ttain ed

the 24-hour PM 10 

## NAAQS based on EPA’s

clean data finding for

2007-2009.

176(c) Conformity

--- March 2 1, 2013 No EPA action. Lack of

approval not an obstacle

to redesignation.

189(a)(1)(A) NSR 030.500

-

030.508 43 

## and

Nichols Memo April 7, 1994 No EPA action. Lack of

approval not an obstacle

to redesignation.

189(a)(1)(B) Demonstration of

Attainment or

Impracticality Clean Data

Policy --- Attained the 24

- hour

PM 10 

## NAAQS in 20 11

based on ambient air

monitoring data. Attain ed

the 24-hour PM 10 

## NAAQS based on EPA’s

clean data finding for

2007-2009.

189(a)(1)(C) RACM

--- --- BACM subsumes RACM.

41 57 FR 13498, 13564 (April 16, 1992).

42 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Divi sion (MD

15); September 4, 1992.

43 WCDBOH Regulations Governing Air Quality Management; Section 030.500

- 030.508, “Federal New Source Review (NSR)”.

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## Table 5 -1 (continued)

Part D Requirements and Actions for the Truckee Meadows PM 10 

## NAA

CAA

Section Requirement Reference Submitted to

EPA Comments

189(b)(1)(A) Attainment

Demonstration Clean Data

Policy --- Attained the 24

- hour

PM 10 

## NAAQS in 20 11

based on ambient air

monitoring data. Attain ed

the 24-hour PM 10 

## NAAQS based on EPA’s

clean data finding for

2007-2009.

189(b)(1)(B) BACM 010.117, 44



## 040.005, 45



## 040.030, 46



## 040.031, 47



## 040.032, 48 

## and

040.051 49 

## Various times

from 2002

through 2006. Adopted BACM for dust

control, street sanding,

street sweeping, and

residential wood

combustion.

189(c) Milestones EPA’s General

Preamble, 50



## Calcagni

Memorandum at

page 6, 51 

## and

Clean Data

Policy --- Attained the 24

- hour

PM 10 

## NAAQS in 20 11

based on ambient air

monitoring data. Attain ed

the 24-hour PM 10 

## NAAQS based on EPA’s

clean data finding for

2007-2009.

189(e) PM 10 

## Precursors 20 11 periodic

emissions

inventory and

attainment of

the NAAQS N/A No Major sources of

direct PM 10 

## or PM 10 

## precursor emissions (NO

x 

## , SO

x 

## , or VOC) sources in

the Truckee Meadows

NAA.

44 72 FR 33397 (June 18, 2007).

45 72 FR 33397 (June 18, 2007).

46 WCDBOH Regulations Governing Air Quality Manageme nt, Section 040.030, “Dust Control”. Submitted to EPA August 2002.

47 71 FR 14386 (March 22, 2006).

48 71 FR 14386 (March 22, 2006).

49 72 FR 33397 (June 18, 2007).

50 57 FR 13498, 13564 (April 16, 1992).

51 “Procedures for Processing Requests to Redesignate A reas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD

15); September 4, 1992.

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and Maintenance Plan 23 

## CHAPTER 6

MAINTENANCE PLAN

Pursuant to the Calcagni Memorandum and Section 107(d)(3)(E) of the CAA, the EPA must

fully approve a maintenance plan, including a contingency plan, which meets the requirements of

Section 175A. This maintenance plan meets these requirements by including the following core

provisions to ensure maintenance of the 24- hour PM 10 

## NAAQS.

• Attainment Inventory;

• Maintenance Demonstration;

• Motor Vehicle Emissions Budget;

• Monitoring Network;

• Verification of Continued Attainment; and

• Contingency Plan.

In accordance with Section 175A(b) of the CAA, the AQMD will prepare and submit another

maintenance plan eight years after this redesignation/maintenance plan is approved. The purpose

of this revision is to provide for maintenance of the 24-hour PM 10 

## NAAQS for an additional ten

years following the first 10- year per iod.

Attainment Inventory

According to the Calcagni Memorandum, “The State should develop an attainment emissions

inventory to identify the level of emissions in the area which is sufficient to attain the NAAQS.”

Since 1990, the AQMD has been compiling PM 10 

## emission s inventories on a triennial schedule

with the most recent inventory prepared for 2011. These inventories were prepared using EPA

guidance and models.

Below is a summary of procedures used to ensure that PM 10 

## emissions were calculated and

apportioned accurately for the Truckee Meadows . Complete documentation is included in

“Washoe County, Nevada 2011 Periodic Emissions Inventory”.

Point Sources: Lat itude /Long itude coordinates are maintained for each point source.

Geograp hic Information Systems (GIS) software was used to overlay HA 87 onto all

point sources to determine if it was to be included in the Truckee Meadows PM 10 

## emissions inventory.

Nonpoint Sources : Nonpoint sources with an AQMD operating permit are managed in the

emissions inventory as if it were a point source (see above). Other nonpoint sources are

grouped by Source Classification Code (SCC) and assigned a surrogate, which is

spatially representative of that process. Typical s urrogates are population, dwelling units,

employment, and VMT. Surrogates are spatially disaggregated into a variety of

geographies such as census areas (blocks, block groups, and tracts), Transportation

Analysis Zones (TAZ), and ZIP codes . GIS is used to determine what portion of ea ch

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and Maintenance Plan 24 

## surrogate is included in HA 87. This fraction is applied to county- level emissions for

each SCC emissions to determine Truckee Meadows PM 10 

## emissions.

Non -Road Mobile Sources: Non -Road Mobile Sources are grouped by SCCs and

assigned a surrogate which is spatially representative of that process. Surrogate fractions

are applied to county- level emissions for each SCC emissions to determine Truckee

Meadows PM 10 

## emissions.

On -Road Mobile Sources : The Metropolitan Planning Organization (MPO) manages the

re gional transportation demand model. The model includes planning assumptions, such

as population and VMT, for each TAZ in the county. GIS software was used to overlay

HA 87 onto all TAZs to determine if it was to be included in the Truckee Meadows PM 10



## em issions inventory. Data from TAZs within HA 87 were combined and incorporated

into the MOVES model to calculate on -road mobile source PM 10 

## emissions.

As discussed earlier in Chapter 2, the Truckee Meadows attained the 24-hour PM 10 

## NAAQS in

2002 . Because air quality improvements were a result of the SIP, any periodic emissions

inventory from 2002 to 2011 could represent the attainment inventory. This is consistent with

the Calcagni Memorandum, which indicated that “any emission inventories avai lable at the time

and including the emissions during the time period associated with the monit oring data showing

attainment ” can be used to represent the attainment inventory. Therefore, the 2011 emissions

inventory (Table 6-1) 52 

## is identified as the attai nment inventory because it used the best and

updated methodologies for all sources, and it has the most comprehensive and current emission

inventory that is sufficient to attain the NAAQS.

Table 6 -1

2011 PM 10 

## Attainment Inventory (lbs/day)

Category 2011

Attainment Inventory

Point Sources 25

Nonpoint Sources 22,812

Non -Road Mobile 606

On -Road Mobile 1,183

Total* 24,626

* Totals may not add up due to rounding.



## Maintenance Demonstration

Maintaining the PM 10 

## NAAQS may be demonstrated by showing that future emissions will not

exceed the level of the attainment inventory. Also, attainment must be demonstrated for the 10-

52 Washoe County, Nevada; 2011 Periodic Emissions Inventory; November 2012; Table 1

- 4.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 25 

## year period following EPA’s approval action on the redesignation request. The final year o f this

maintenance demonstration is 2030.

Truckee Meadows Maintenance Emissions Limit

The 2011 periodic emissions inventory 53 

## was used as a baseline to develop a maintenance

emissions limit for the Truckee Meadows. This limit is the level considered to be

sufficient to ensure continued attainment of the NAAQS in future planning years.

Growth and control factors were applied to many of the emission categories of the 20 11

inventory to generate a 20 30 Truckee Meadows emissions budget. The growth factors

were based on demographic, economic, VMT, and meteorological data (Appendix B,

Table B -2), and the control factors were based on planned emission reduction strategies.

Several PM 10 

## categories were recalculated because they were either significant (i.e.,

paved roads and RWC) or had models available that could provide specific year

emissions (i.e., non-road and on-road motor vehicles).

2011 was an unusually high emission year for wildfires during the PM 10 

## season. To

approximate a more normal wildfire emis sion during the PM 10 

## season, an average of the

four previous inventory years’ (1999, 2002, 2005, and 2008) wildfire emissions were

used for planning year projections (Table 6

- 2) . The rationale is that wildfire emission

alone should not drive future year planning purposes. F uture large scale wildfire s during

PM 10 

## season will be treated as exceptional events and will be submitted to the EPA for

exclusion when they occur.

Table 6 -2

Historic Truckee Meadows PM 10 

## Wildfire Emission Inventories (lbs/day)

Inve ntory Year PM 10 

## Emission s

1999 19

2002 40

2005 10

2008 1 5

2011 10,947

Average (1999

- 2008) 21

Average (1999

- 2011) 2,206

The 2011 Truckee Meadows PM 10 

## maintenance emissions limit was established at 13,700

lbs/day (Table 6- 3).

53 See Appendix C. Washoe County, Nevada; 2011 Periodic Emission s Inventory and Appendices A, B, C

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 26 

## Table 6 -3

Truckee Meadows PM 10 

## Emission Inventories (lbs/day)

2011 2011

Source Category Periodic Inventory Maintenance Emission Limit

Point 25 25

Nonpoint 22,812 11,885

Non

- Road Mobile 606 606

On

- Road Mobile 1, 183 1, 183

Total* 24,626 13,700

* Totals may not add up due to rounding.



## The 2011 Truckee Meadows maintenance emission limit satisfies Condition 5.a of the

Calcagni Memorandum because it:

• Uses the most accurate emissions inventory methodologies;

• Is a comprehensive and current emissions inventory;

• Identifies the level of emissions in the Truckee Meadows sufficient to attain the

NAAQS; and

• Will be the emissions inventory most consistent with the 2030 projected inventory

required for demonstrating maintenance of the NAAQS.

Maintenance of the NAAQS

The projected 2030 emissions inventory used the 2011 Truckee Meadows Maintenance

E missions Limit as its base line . Each of the emission categories in the 20 11 Truckee

Meadows Maintenance Emissions Limit (Appendix C ) were projected to 2030 levels

using one of the following EPA emission methodologies or models. 54



## 1. Baseline Emission Projections : Washoe County’s 2030 population, dwelling units,

employmen t, and VMT forecasts (Appendix B, Table B-2 ) were used as surrogates to

project the 2030 emissions. These for ecasts were consistent with those used by the

local MPO.

2. EPA Models: The non-road and on-road motor vehicle categories accounted for

approximately 6% of the 2011 Truckee Meadows emissions budget. To ensure

consistency throughout the maintenance demonstration period, the same non-road and

on- road models (NONROAD20 08a and MOVES 2010b ) were used to estimate the

2030 inventory.

The 2030 on- road vehicles category incorporated the latest planning assumptions for

the transportation network including VMT and vehicle speeds. As with previous

54 “Procedures for Preparing Emissions Projections” (EPA

- 450/4

- 91

- 019).

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 27 

## periodic emission inventor ies , these planning assumptions were consistent with those

used by the MPO for their transportation plans.

3. Emission Category Surveys : Residential wood combustion is a significant source of

PM 10 

## emissions. The RWC category is updated on a regular basis via an emission

category survey. As part of the carbon monoxide maintenance plan SIP, the AQMD

is committed to conducting this survey at least once every three years. 55



## Table 6 -5 lists the 2011 Truckee Meadows Maintenance Emission Limit and the 2015,

2020, 2025, and 2030 projected emissions for the four major PM 10 

## emission categories.

A more detailed inventory can be found in Appendix C.

Table 6 -4

Truckee Meadows PM 10 

## Maintenance Emission Inventories (lbs/day)

Category 2011* 2015 2020 2025 2030

Point Sources 25 28 32 37 42

Nonpoint Sources 11,885 11,510 11,379 11,361 11,512

Non -Road Mobile 606 501 386 328 307

On -Road Mobile 1,183 953 839 828 883

Total** 13,700 12,992 12,637 12,554 12,744

* Truckee Meadows Maintenance Emission s Limit

.

** Totals may not add up due to rounding.



## Summary

Population, households, employment, and VMT are projected to increase through 2030

and beyond. Federally enforceable PM 10 

## control programs targeting RWC, dieselpowered motor vehicles, and diesel fuel will help offset this growth. Because future

emissions are not projected to exceed the level of the 2011 T ruckee Meadows

maintenance emissions limit

, 

## the 24-hour PM 10 

## NAAQS wi ll be maintained through the

attainment demonstration period.

Although more stringent control strategies will be in place for RWC, d irect PM 10 

## and

PM 10 

## precursor emissions from RWC are likely to increase on cold winter nights. Their

proportion of the entire inventory is also likely to increase. If PM 10 

## concentrations

approach the 24-hour NAAQS, Washoe County’s emergency episode plan 56 

## is activated

and includes a mandatory curtailment. A recent survey indicated that this program

reduces RWC emission 74% during Stage I alerts. 57 

## This contributes to a 22% reduction

of total PM 10 

## emission for the Truckee Meadows for the horizon year of 2030.

55 73 FR 38124 (July 3, 2008).

56 72 FR 33397 (June 18, 2007).

57 “Washoe County Health District; Air Quality Management Division; Residential Wood Use Survey”; InfoSearch International; May 2013.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 28 

## Motor Vehicle E missions Budget

Transportation conformity is required by Section 176(c) of the CAA. Under EPA’s

transportation conformity regulations, 58 

## transportation plans and improvement programs must be

consistent with, or conform to, the motor vehicle emissions budget (MVEB) defined in the

applicable SIP. These budgets specify the level of on -road motor vehicle emissions that are

consistent with attainment and maintenance of air quality standards and should include an

adequate safety margin. 59



## Emissions inventory da ta for the years 20 15 through 2030 were used to establish the MVEB.

The MVEB includes road construction fugitives, paved road fugitives, unpaved road fugitives,

on- road vehicles, diesel idling, and a safety margin. The safety margin is the excess emissio ns

between the total projected emissions for a specific year and the 20 11 maintenance emissions

limit (Table 6 -5).

Table 6 -5

Truckee Meadows PM 10 

## Safety Margin (lbs/day)

Category 2015 2020 2025 2030

2011 Maintenance Emissions Limit 13,700 13,700 13,700 13,700

PM 10 

## Maintenance Emissions Inventory* 12,992 12,637 12,554 12,744

Safety Margin 708 1,063 1,146 955

* Projected 20 15 , 20 20 , 20 25

, 2028, and 20 3 0 emission inventories from Table 6 -4.



## The MVEB is set at a level that keeps the intermediate (2015, 2020, and 2025) and horizon

(2030 ) year Truckee Meadows emissions less than the 20 11 Truckee Meadows m aintenance

e mission s l imit . For years beyond 2030 , the MVEB will remain at the 20 30 level of 6,927

bs/day (Table 6 -6).

Table 6 -6

Truckee Meadows PM 10 

## MVEB (lbs/day)

Category 2015 2020 2025 2030

Road Construction 183 189 185 180

Paved Roads - Fugitives 1,414 1,517 1,627 1,736

Unpaved Roads - Fugitives 2,380 2,479 2,688 3,174

On

- Road Vehicles 946 835 825 880

Diesel Idling 7 4 3 3

Safety Margin 708 1,063 1,146 955

Motor Vehicle Emissions Budget 5,638 6,088 6,473 6,927

58 40 CFR 93.

59 Safety margin means the amount by which the total projected emissions from all sources of a given pollutant a re less than the total emissions

that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance. (40 CFR 93.101)

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 29 

## Monitoring Network

Once the Truckee Meadows has been redesignated to an

attainment/maintenance area, the AQMD will continue to operate

an appropriate PM 10 

## monitoring network, in accordance with 40

CFR 58, to verify the attainment status of the area. In addition,

Washoe County’s PM 10 

## monitoring network will be reviewed

annually pursuant to 40 CFR 58.10 to ensure the network meets

the monitoring objectives defined in 40 CFR 58, Appendix D.

Funding to meet these objectives has, and will be, primarily

obtained from: 1) EPA Section 105 grants, and 2) Nevada

Department of Mo tor Vehicles funds.

Ambient PM 10 

## monitoring data will be collected and quality

assured in accordance with 40 CFR 58, recorded in the AQS, and

will be available for public review. Figure 6 -1 features the South

Reno m onitoring site as an example , and Figur e 2 -1 is a map of

all current PM 10 

## monitoring sites in Washoe County.

Verification of Continued Attainment

As described in the previous section, the AQMD will continue to operate and maintain an

appropriate PM 10 

## monitoring network. Ambient air monitoring data will be used to verify

attainment and maintenance of the 24-hour PM 10 

## NAAQS.

Tracking actual emissions can identify potential increases in ambient PM 10 

## levels. The AQMD

has three existing mechanisms to track emissions. These mechanisms, listed below, will remain

in place and be used to screen for significant increases in actual PM 10 

## emissions.

1. Periodic Emissions Inventories: The AQMD will continue to prepare, and submit to EPA,

comprehensive periodic PM 10 

## emissions inventories via the Emissions Inventory

Gateway on a triennial schedule. The last periodic emissions inventory was prepared for

calendar year 20 11.

2. Consolidated Emissions Reporting Rule (CERR) and Air Emissions Reporting Rule

(AERR) : The CERR and AERR simplify and streamline emissions reporting

requirements. It requires regular updates of point and area sources within Washoe

County. The AQMD will continue to meet the requirements of the CERR and AERR.

3. Residential Wood Use Survey : Reside ntial wood combustion is a significant PM 10 

## source

during the winter season. The AQMD has completed nine residential wood use surveys

between 1993 and 2013 . These surveys estimated the device (fireplaces, woodstoves,

and pellet stoves) population, amount of wood burned, and PM 10 

## emissions in Washoe

County. As part of this maintenance plan, as well as the carbon monoxide maintenance

plan, 60 

## the AQMD is committed to conducting this survey at least once every three years.

60 73 FR 38124 (July 3, 2008). 

## Figure 6

- 1

South Reno Monitoring Site

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 30 

## Furthermore, the AQMD’s Enforcement Branch will continue to enforce the permanent and

enforceable programs addressed in Chapter 4. Currently, the Enforcement Branch consists of

five inspectors to ensure compliance with local air quality regulations. They inspect for permit

conditions, respond to complaints (dust and permit), patrol and enforce no-burn days during the

burn season, and issue warnings and citations for any violations found.

When no-burn days are issued, the enforcement staff will patrol neighborhoods for visible smoke

fro m chimneys. They also respond to complaints from neighbors of the home owners who are

burning their wood burning devices during a no-burn day. They will order the home owner to

stop burning immediately and issue the home owner a warning for the first offense. Then they

will return three to four hours later to ensure that the smoke has ceased to be emitted from the

chimney. If the smoke continues, the home owner would then be issued a citation.

To ensure an effective Street Sanding and Sweeping Program (DBOH regulations 040.031 and

040.032), t he AQMD holds working group meetings twice a year. The street sanding and

sweeping working group is made up of public works road department personnel from all the

municipalities. It meet s twice a year (once in Fal l, before snow fall, and once in Spring) to share

information on sweeping/sanding equipment and discuss sandin g and sweeping related issues.

As part of the enforcement and compliance component of the program, e ach jurisdiction is

required to submit its sa nding and sweeping report on an annual basis (July to June), which

included such information as date of each storm event, amount of sand and salt or brine applied

to roadways, as well as the sand pick up date after each storm event

.

There is a gradual shi ft o ver the last several years from sand to more brine solutions for roadway

deicing. Th e shift was in part due to the proactive approach taken by the jurisdictions to apply

the brine solutions before an impending storm to prevent accidents. In doing so, it also saves

vehicle fuel, reduces emissions, and lowers the need for manpower and time associated with sand

removal after a storm event.

Continued ambient air monitoring, emissions tracking , and enforcement will ensure verification

of continued attainment and maintenance of the 24-hour PM 10 

## NAAQS.

Contingency Plan

Section 175A of the CAA requires that a maintenance plan include contingency provisions, as

necessary, to promptly correct any violation of the PM 10 

## NAAQS that occurs after redesignation

of the area. The plan should clearly identify:

• Specific indicators, or triggers, which will be used to determine when contingency

measures need to be implemented;

• The contingency measures to be adopted;

• A schedule and procedure for adoption and implementation; and

• A specific time limit for action.

The typical PM 10 

## season in the Truckee Meadows is November, December, and January. This is

when the highest ambient PM 10 

## concentrations, and possible exceedances, are most likely to

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 31 

## occur. If monitoring data indicate a PM 10 

## violation, then Contingency Plan “A” begins control

measure development and implementation.

Contingency Plan “A”

Trigger Mechanism “A”: A violation of the 24-hour PM 10 

## NAAQS verified f rom any

SLAMS, S pecial Purpose Monitor (SPM), or NCore site operated by the AQMD

. Violation of the NAAQS is defined as when the expected number of days per calendar

year with a 24-hour concentration above 150 μ g/m 3 

## , as determined in accordance with 40

CFR 50, Appendix K, is greater than one.

Contingency Measure “A” : The AQMD will maintain a list of potential contingency

measures and provide recommendations for implementation to the WCDBOH.

Recommendations to the WCDBOH shall occur at their next regularly scheduled

meeting, but no later than 45 days after reaching Trigger Mechanism “A ” levels. The

recommendations will also include a timeline for adoption and implementation.

Contingency measures recommended to the WCDBOH shall be adopted and

implemented as promptly and expediently as possible. Any rule revision should be

adopted and implemented before the next PM 10 

## season (November, December, and

January). Prompt action and implementation of contingency measures may prevent

future exceedances and violat ions of the PM 10 

## NAAQS.

The list of potential contingency measures will concentrate on the significant emission

categories impact ing PM 10 

## season emissions. Table 6 -7 summarizes the current list.

Because of changes in growth and technology, the effective ness of each measure may

vary over time. A triennial review and reprioritization of the measures in coordination

with the periodic PM 10 

## emissions inventory should be adequate to anticipate the need for

additional emission reductions. In addition, the EPA Regional Office will be notified

within 30 days of implementation of Contingency Measure “A ”.

### PM 10 

### Redesignation Request August 28

, 201 4

and Maintenance Plan 32 

## Table 6 -7

Potential PM 10 

## Contingency Measures

Emission Category Potential Contingency Measure

Paved Streets • Increase stringency of street sanding and sweeping programs

• Improve unpaved shoulders

• Transportation control measures to reduce VMT

Unpaved Streets • Improve unpaved streets and shoulders

• Post speed limits to decrease vehicle speeds

• Restrict access to decrease Average Daily Trips ( ADT ) and VMT

Dust Control • Phased mass grading

• Mass grading allocation system

• Stabilize projects during PM 10 

## season

• Decrease one acre dust control permit exemption

Residential Wood

Combustion • Increase one acre lot size exemption

• Mandatory curtailment at lower PM 10 

## concentrations

• Change

- out program to cleaner burning device

Mobile Sources

(Diesel) • Non

- road & on

- road diesel engine repowers and rebuilds

• Non -road & on-road diesel tailpipe controls (i.e., filters and

catalysts)

• Truck Stop Electrification systems for heavy -duty vehicles

• More stringent heavy- duty diesel vehicle idling limits

• Fleet modernization

• More stringent inspection & maintenance pro gram of light-duty,

medium-duty , and heavy -duty vehicles

Summary

The AQMD contingency plan meets Condition 5.e of the Calcagni Memorandum by

promptly and expediently addressing future exceedances of the PM 10 

## NAAQS with

clearly defined trigger mechanisms, contingency measures, adoption schedules, and

implementation schedules.

## Appendix A

Permanent and Enforceable Reduction Calculations

## Appendix A.1

– Quantification of RWC Program

The 2011 PM 10 

## emission reductions from Washoe County’s RWC program are summarized

below.

Methodology:

1. The emission reductions were determined by applying the difference between the

uncertified (30.6 lbs/ton) and certified (17.15 lbs/ton) woodstove emission factors

to the certified woodstove activity level (6,630 [NAA] and 14,051 tons [County]).

Assumptions:

1. Washoe County’s RWC program is responsible for 100% of the certified

woodstoves/inserts within Washoe County. Without this program, all

woodstoves/inserts in Washoe County would be uncertified.

References:

1. Activity levels, SAF, days per week, emission factors, and PM fractions from

Washoe County, Nevada ’s 2011 Periodic Emissions Inventory ; “2011 RWC Em

projected from 2009-10 RWC survey.xlsx”.

The same methodology and assumption were also used to determine CO and PM 2.5 

## emission

reductions.

Act ivity Level and Emission Factors

– Certified Woodstoves/Inserts

Emission Factor*

(lbs/ton of wood burned)

Area Tons of

Wood Burned CO PM 10 

## PM 2.5



## HA 87 6,630 71.5 13.45 13.45

County 14,051 71.5 13.45 13.45

Emission Benefits

– Certified Woodstoves/Inserts

Emission Reductions

(lbs/typical PM10 season day)

Area CO PM 10 

## PM 2.5



## HA 87 4,167 784 784

County 8,832 1,662 1,662

* Difference between uncertified and certified woodstoves/inserts.

## Appendix A.2 – Quantification of Street Sanding and Sweeping Programs

The 2011 PM 10 

## emission reductions in the Truckee Meadows from Washoe County’s street

sanding and sweeping programs are summarized below.

1999 emissions = 1,894 lbs/day

2011 emissions = 339 lbs/day

2011 emission reductions = 1,555 lbs/day

Methodology:

1. The emission reductions were determined by the difference between the 1999 and

2011 emission inventories.

Assumptions:

1. The 1999 emissions inventory assumed no controls.

2. The 2011emissions inventor ies assumed full implementation of WCDBOH

Regulations Governing Air Quality Management Sections 040.031 and 040.032.

3. Weather conditions in 1999 were similar to 2011.

References:

1. PM 10 

## “Serious” SIP submittal, Section V, Control Strategies, pages 12 -16, August

2002.

2. Washoe County, Nevada; 1999 Emissions Inventory for Particulate Matter; Table

3-4.

3. Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3 -4.

## Appendix A.3 – Quantification of Dust Control Program

The 2011 PM 10 

## emission reductions from Washoe County’s Dust Control program are

summarized below.

2011 controlled emissions = 430.5 lbs/day

2011 uncontrolled = 2 x 430.5 lbs/day = 861 lbs/day

2011 emission reductions = 430.5 lbs/day

Methodology:

1. Activity level and emission factors obtained from Table 3 -10 of the 2011 Periodic

Emissions Inventory.

2. Emission calculations same as those used for the 2011 inventory with the

exception of control efficiency. Control efficiency used is the difference between

uncontrolled (0%) and controlled (50 % ) efficiencies.

Assumptions:

1. Washoe County’s dust control program is responsible for the 50% control

efficiency used in the periodic emissions inventory calculations.

References:

Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3-10.

## Appendix A.4 - Quantification of the Emergency Episode Plan

The 2011 PM 10 

## emission reductions in the Truckee Meadows from Washoe County’s street

emergency episode plan are summarized below.

1) RWC

2011 PM 10 

## RWC emissions = 5,888 lbs/day

2011 PM 10 

## RW C emission from emergency episode = EM RWC 

## x [1

- (RP)(RE)(CE)]

= (5,888)[1-(0.85)(0.86)(1.00)] = 1,584 lbs/day

2011 PM 10 

## RWC emission reductions from emergency episode = 4,304 lbs/day

2) Prescribed Burnings

2011 PM 10 

## emissions from prescribed burning = 0 lbs/day

2011 PM 10 

## prescribed burning emission reductions from emergency episode = 0 lbs/day

3) Open/Permit Burns

2011 PM 10 

## emissions from open/permit burns = 18 lbs/day

2011 PM 10 

## open/permit burns emission reductions from emergency episode = 18 lbs/day

4) Human/A nimal Cremation

2011 PM 10 

## emissions from human/animal cremation = 9 lbs/day

2011 PM 10 

## human/animal cremation emission reductions from emergency episode = 9

lbs/day

5) Total Emission Reductions = (4,304 + 0 + 18 + 9) lbs/day = 4,331 lbs/day

Methodology:

1. The emission reductions for RWC were determined by applying rule effectiveness

(RE), rule penetration (RP), and a control efficiency (CE) to the RWC category.

2. The emission reductions for the other categories are enforced by Health District

regulations, which included mandatory no burn days during episodic events.

Assumptions:

1. For the RWC emission reduction: RP = 0.85, RE = 0.86, and CE = 1.00.

References:

1. Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3-4.

2. “Washoe County Health District, Air Quality Management Division, Residential

Wood Use Survey”; InfoSearch International; May 2010.

## Appendix B

Growth Factors for Emission Projections

## Appendix B.1 – G rowth Factors for 20 15, 2020, 2025, and 2030 Projections

Appropriate and reasonable growth and control assumptions ensure that planning emissions for

2015 through 2030 are realistical ly projected . Control factors were developed based on historic

data and reasonable assumptions.

Growth and control factors for e ach emission category are listed in Table B- 1. Detailed data for

the growth factors are further listed in Table B-2.

Portions of the growth factors are based on various data from the Washoe County Consensus

Forecast, used by the MPO in the development of its 2035 Regional Transportation Plan (RTP),

provided in 5- year increment.

The historic climatic data were obtained from the National Oceanic and Atmospheric Agency,

with future data based on 30-year normal averages between 1980 and 2010.

## Table B-1 – Growth & Control Factors used for Truckee Meadows PM 10 

## Emissions Projection

Major

Category Sub

- Category Growth

Surrogate(s) Control Factor(s)

POINT SOURCES

Geothermal POP None

Printing EMP None

Airports & Heliports

GSE AP None

Military Aircraft UNI None

Commericial Aircraft AP None

Gen Aviation

- piston AP None

Gen Aviation

- turbine AP None

Air Taxi

- piston AP None

Air Taxi

- turbine AP None

APU AP None

Buffer Zone POP&EMP None

NONPOINT SOURCES

Stationary Source Fuel Combustion

Industrial Fuel Combustion EMP None

Com/Inst Fuel Combustion EMP None

Res. Fuel Combustion HH&HDD None

Res. Wood Combustion

Fireplaces HDD No new solid fuel device is allowed w/in HA87, unless the property has ≥ 1 acre.

Since not many parcels w/in HA87 are ≥ 1 acre, assumed that no new FPs will

be installed. Also assumed that 1%/year of wood FPs will be replaced with gas

FPs.

Woodstoves/Inserts

Non

- certified HDD No new non

- certified WS allowed. Older stoves being removed upon real estate

transaction. Assumed future replacement apportionment of 75% Phase II WS,

20% Pellet stoves, and 5% gas FPs. Replacement % derived from historic data

for Ph II WS & PS.

Certified, Phase 1 HDD No new Phase I WS allowed. Older stoves gradually being removed due to

age. Assumed 5% reduction per year.

Certified, Phase 2 Growth&HDD

Pellet Stoves Growth&HDD

Industrial Processes

Chemical Manufacturing EMP None

Commercial Cooking POP None

Food & Kindred Products

- Manufacturing EMP None

Mineral Processes EMP None

Rubber/Plastic Processes EMP None

Fabricated Metals EMP None

Construction

- Stationary

Road Construction* PGR None

Residential Dust Projects (Non

- Road

Const.) PGR None

Commercial Dust Projects (Non

- Road

Const.) EGR None

Asphalt, Sand and Gravel, Abrasive

Blasting EGR None

Machinery EMP None

Mining and Quarrying

- Stationary EMP None

Miscellaneous Industrial Processes EMP None

Solvent Utilization

Architectural Coatings HH None

Auto Refinishing EMP None

Wood Furniture EMP None

Paper EMP None

Plastic Products EMP None

Machinery & Equipment EMP None

Electronic & Other Electrical EMP None

Misc. Manufacturing EMP None

Other Solvent Utilization

Degreasing EMP None

Dry Cleaning EMP None

Graphic Arts EMP None

Misc. Industrial Processes EMP None

Misc. Commercial Processes EMP None

Misc. Consumer/ Com. Solv. EMP None

Cutback Asphalt Application EMP NoneEmulsified Asphalt Appl. EMP None

Pesticide, Fungicide & Rodenticide EMP None

Storage and Transport

Gas Service Station EMP None

Organic Chemical Storage EMP None

Waste Disp/Treat/Recovery

Commercial/Industrial Incineration EMP None

Publicly Owned Treatment Works POP/HH None

Remediation/Reclamation/ Recycle EMP None

Misc. Non

- Point Sources

Paved Road Fugitive Emissions* VMT(RTP)

Paved Road Fugitive Emissions, Sanding & Salting SNO Sand:Salt ratio shifted over the years. Based on historic data, anticipate 15%

reduction in sand usage per year.

Unpaved Road Fugitive Emissions* LVMT Assumed 2.6% per year of all future unpaved roads to be paved based on WC

historic averages from 1985

- 2011 and past EI unpaved:paved road ratio.

Dirt Road Fugitive Emissions

- -

Wildfires UNI None

Structure Fires UNI None

Motor Vehicle Fires UNI None

Firefighting Training UNI None

Open/Permit Burning UNI None

Prescribed Burning UNI None

Refuse Fires UNI None

Auto & Misc. Repair Shops POP None

Health Services, Hospitals POP None

Essay Labs EMP None

Human & Animal Cremation POP None

NON

- ROAD MOBILE SOURCES

CNG Engines NR2008a None

Diesel Engines NR2008a None

Gasoline Engines NR2008a None

LPG Engines NR2008a None

Locomotives EMP None

ON

- ROAD MOBILE SOURCES

On

- Road Vehicles* MOVES2010b None

HDDV Diesel Idling* MOVES2010b None

* Sub

- Category included in MVEB

## Table B-2 – Growth Factors for 2015-2030 Projections for the Truckee Meadows Hydrographic Area

Growth Factors 2010 2011 2015 2020 2025 2030 Reference

Uniform (UNI) 1.000 1.000 1.000 1.000 1.000 1.000

---

Daily Vehicle Miles Traveled (VMT) 5,773,560 6,080,990 6,157,848 6,596,915 7,040,489 7,390,867

Ratio using 2011 Baseline 1.000 1.013 1.085 1.158 1.215

Local Vehicle Miles Traveled (LVMT) 472,725 497,198 503,316 539,802 585,265 634,418

Ratio using 2011 Baseline 1.000 1.012 1.086 1.177 1.276

Population (POP) 280,881 283,288 292,914 313,771 328,272 341,696

Ratio using 2011 Baseline 1.000 1.034 1.108 1.159 1.206

Population Growth Rate (PGR) 1.000 1.009 1.034 1.071 1.046 1.016

Ratio using 2011 Baseline 1.000 1.025 1.062 1.037 1.007

Households (HH) 113,418 114,468 118,666 127,912 134,278 140,216

Ratio using 2011 Baseline 1.000 1.037 1.117 1.173 1.225

Household Growth Rate (HHGR) 1.000 1.009 1.037 1.078 1.050 1.017

Ratio using 2011 Baseline 1.000 1.027 1.068 1.040 1.008

Employment (EMP) 211,596 215,663 231,931 252,698 274,153 297,252

Ratio using 2011 Baseline 1.000 1.075 1.172 1.271 1.378

Employment Growth Rate (EGR) 1.000 1.019 1.075 1.090 1.085 1.032

Ratio using 2011 Baseline 1.000 1.055 1.069 1.064 1.013

Ag/Mining/Constr Employment (AMC) 14,869 15,114 16,096 17,439 18,847 20,348

Ratio using 2011 Baseline 1.000 1.065 1.154 1.247 1.346

AMC Emp Growth Rate (AMCGR) 1.000 1.017 1.065 1.083 1.081 1.030

Ratio using 2011 Baseline 1.000 1.048 1.066 1.063 1.014

Mfg/Trans/Com/Util/wholesale (MTCUW) 29,049 29,531 31,457 34,059 36,803 39,768

Ratio using 2011 Baseline 1.000 1.065 1.153 1.246 1.347

MTCUW Emp Growth Rate (MTCUWGR) 1.000 1.017 1.065 1.083 1.081 1.031

Ratio using 2011 Baseline 1.000 1.048 1.065 1.063 1.014

Service & Office Emp (SVCOF) 61,942 63,181 68,139 74,567 81,173 88,221

Ratio using 2011 Baseline 1.000 1.078 1.180 1.285 1.396

SVCOF Emp Growth Rate (SVCOGR) 1.000 1.020 1.078 1.094 1.089 1.033

Ratio using 2011 Baseline 1.000 1.057 1.073 1.067 1.013

RNO Airport Passenger (AP) 3,823,393 3,945,186 4,432,360 5,138,320 5,876,196 6,720,031

Ratio using 2011 Baseline 1.000 1.123 1.302 1.489 1.703

2010 is actual data, the rest projected.

Airport Passenger Growth Rate (APGR) 1.000 1.032 1.123 1.159 1.144 1.053

Ratio using 2011 Baseline 1.000 1.089 1.123 1.108 1.020

2010 is actual data, the rest projected.

Heating Degree Days (HDD)* 2,368 2,499 2,501 2,501 2,501 2,501 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 1.001 1.001 1.001 1.001 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Rainfall >= 0.01 inch (Rain)* 34.0 5.0 18.3 18.3 18.3 18.3 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 3.660 3.660 3.660 3.660 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Snowfall >= 1 inch (SNO)* 3.0 1.0 3.8 3.8 3.8 3.8 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 3.800 3.800 3.800 3.800 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Episodic RWC EI Factors:

Rule Penetration 0.85 0.85 0.88 0.88 0.88 0.88

Rule Effectiveness 0.86 0.86 0.74 0.74 0.74 0.74

Control Efficiency 1.00 1.00 1.00 1.00 1.00 1.00

Note: 2011 data is from Washoe County's Emissions Inventory compilation.

* Includes Jan, Nov, & Dec., 2015 - 2030 data are 30-year normal from 1981-2010, from 2013 NOAA Weather Summary file. RTC of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

Note: The population and employment data are not specifically included in the main body of the RTP, but were used

as inputs for the transportation model that generates VMT data. These data (2010, 15, 20, 25, 30) came from 2012

Washoe County Consensu Forecast, as provided by Judy Althoff/RTC. Airport passenger data, which was also

used in the RTP, were provided by Peter Bang/RTC. Washoe County Residential Wood Use Survey

Reports compiled by InfoSearch for 2009-2010

(May 2010) & 2012-2013 (May 2013). RTC of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

RTC of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

RTC of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013. 2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC

of Washoe County; "2035 Regional

Transportation Plan", April 19, 2013.

## Appendix B.1 – Residential Wood Combustion

The 2009-2010 RWC survey was used for the 2011 emissions inventory calculation

. 

## An

adjustment factor of 0.921 based on heating degree days and households was applied to the

2009-2010 survey to estimate the 2011 emission. This factor accounts for the colder 2009-2010

winter season and higher population as compared to the 2011-2012 winter season and

population.

The most recent survey was completed for the 2012-2013 winter season. Likewise, adjustment

factor based on heating degree days (HDD) was applied to the 2012-2013 survey to calculate the

emissions from 2015 through 2030. Since non-certified woodstoves are not allowed within the

Truckee Meadows, and new i nstallation of certified phase II or fireplaces are only allowed on a

property with greater or equal to one acre in size, the growth factors for the various RWC

devices vary. Table A-3 is a summary of the adjustment methodologies used to project future

RW C emissions. This factor accounts for the milder 2011-2012 winter season (2,499 heating

degree days) compared to the historic normal (2,501 heating degree days) (Appendix A). This

estimate is conservative and assumes that projected PM 10 

## emissions stay co nsistent with the

heating degree days and allowable future RWC devices within the Truckee Meadows . It is used

because RWC in the Truckee Meadows is controlled by a regulation that: 1) is permanent and

enforceable, 2) does not allow non-EPA certified devices in new dwelling units, and 3) requires

non- EPA certified devices to be upgraded or removed upon real estate transactions.

Table B-3 – Truckee Meadows PM 10 

## Emission Projection Calculation Methodologies for RWC

RWC Device Future Emission Projection

Methodology Rationale

Fireplaces Device number set at 2011 EI level,

adjusted by HDD. No new fireplaces can be installed within the

Truckee Meadows unless the property is greater or

equal to 1 acre in size.

Also assumed when aging fireplaces are replaced

with newer ones, 1% per year will be replaced by

gas fireplaces.

Non

- certified

woodstoves Device number decreases by 128 per

annum from 2011 EI level, based on

the average number of devices

removed from 2006

- 2012, adjusted

by HDD. Non

- certified woodstoves are prohibited from

installation within the Truckee Meadows.

Assumed 100% of the non

- cer tified woodstoves are

replaced by 75% Phase II woodstoves, 20% pellet

stoves, and 5% gas fireplaces.

EPA Certified

Phase I

woodstoves Device number is capped at the 2011

EI level, adjusted by HDD and 5%

replacement per year. Since these Phase I devices we re replaced by Phase

II devices in 1990, no new Phase I devices are

allowed within the Truckee Meadows.

EPA Certified

Phase II

woodstoves Device number increases by 96 per

annum from 2011 EI level, which is

75% of the average non

- certified

stoves being removed annually,

adjusted by HDD. Assumed that 75% of the non

- certified woodstoves

are replaced with EPA certified phase II devices.

This is a more conservative estimate, not accounting

for some of the non

- certified woodstoves that could

have been removed without being replaced.

Pellet stoves Device number increases by 26 per

annum from 2011 EI level, which is

20% of the average non

- certified

stoves being removed annually,

adjusted by HDD. Assumed that 20% of the non

- certified woodstoves

are replaced with pellet stoves. This is a more

conservative estimate, not accounting for some of

the non

- certified woodstoves that could have been

removed without being replaced.

## Appendix B.2 – P aved Road Fugitive Emissions

Paved road fugitive emissions were calculated using the Predictive Emission Factor equations

from AP -42, section 13.2.1.3, updated January 2011. Equation 1 is the annual predictive

emission factor and Equation 2 is the Daily predictive emission factor, derived from Equation 1.

E = k ( sL ) 0

. 91 

## W 1

. 02 

## Equation 1

Where:

E = particulate emission factor (having units matching the units of k);

K = particle size multiplier for particle size range and units of interest;

sL = road surface silt loading (grams per square meter, g/m 2 

## ); and

W = average weight (in tons) of the vehicles traveling the road

E ext 

## = [ k ( sl ) 0

. 91 

## W 1

. 02 

## ] (1

− P

4N 

## ) Equation 2

Where:

E

ext 

## = annual or other long- term average emission factor (in the same units as k);

P = number of "wet" days ≥ 0.01 in ch of precipitation during the aver aging period ; and

N = number of days in the averaging period (e.g., 365 for annual, 91 for seasonal, 30 for

monthly).

Facility class Average Daily Trips (ADT) were based on RTC planning assumption when they

generated the corresponding VMT s .

Silt loading factors for different road way classifications were based on a combination of

Washoe County and EPA data. A survey of Clark County and San Joaquin Valley Air Pollution

Control District determined that a silt loading factor of 0.02 g/m 2 

## were used to calculate paved

road fugitive emissions for interstate freeways, highways and expressways. 0.02 is between the

range of AP -42’s data of 0.015 - 0.03 for high ADT roadways.

Table B-4 – Silt Loading Assumption for Facility Types

Facility Type ADT

Classification Silt Loading

(g/m2) Source

Interstate >10,000 0.02 AP

- 42, 13.2.1.3

, updated 1/11

Other FWYs & ExpWays >10,000 0.02 AP

- 42, 13.2.1.3

, updated 1/11

Other Principal Arterial >10,000 0.02 AP

- 42, 13.2.1.3

, updated 1/11

Minor Arterial 5,000

– 10,000 0.06 AP

- 42, 13.2.1.3

, updated 1/11

Collector 500

– 5,000 0.16 Washoe County

Local 500

– 5,000 0.16 Washoe County

## Appendix B.3 – Unpaved Road Fugitive Emissions

The following assumptions were made when calculating the unpaved road emissions :

1. Dirt roads were not included in the emissions calculation because they have very low

ADT and are used for weekend recreational activities, such as dirt biking.

2. Paving records for the Washoe County Community Services Department (formally Public

Works Department) indicated on average between 1985 and 2011, 8.2% of unpaved roads

were paved per annum. More recent data from 1990 to 2011 showed a 6.4% paving rate.

However, either of these rate s may be too optimistic for future projections; i nstead, a

lower rate of 2.6% was used for calculating unpaved road emissions. This rate was based

on the information from GIS for the average rate of unpaved roads being paved across

jurisdict ion for 2011 and 2013. The rationale was that because 2011 and 2013 data

reflect more current conditions. It is assumed that the region would pave at least 2.6% of

the unpaved roads, as the economy continues to improve.

## Appendix B.4 – Paved Road Fugi tive Emissions, Sanding & Salting

Historically, various jurisdictions in Washoe County used more sand than salt for winter time

anti -skid reduction. Over the years, the practices have shifted to a higher ratio of salt being used

instead of sand, partly due to the fact that sand had to be swept up after a storm event, whereas

the salt just melted into the snow and discharged into drain basins. Based on historic data, a 15%

sand reduction was applied in addition to the growth factor to project emissions from 2015

through 2030.

## Appendix C

Truckee Meadows Projected PM 10 

## Seasonal Emissions

## Table C -1 – T ruckee Meadows Projected PM 10 

## Seasonal Emissions (lbs/day)

Major Category Sub

- Category 2011

Attain EI 2011

Maint Em Limit Projected Emissions (lbs/day)

2015 2020 2025 2030

POINT SOURCES

Geothermal N/A N/A N/A N/A N/A N/A

Printing N/A N/A N/A N/A N/A N/A

Airports & Heliports

GSE 5 5 5 6 7 8

Military Aircraft

- - - - - - Commericial Aircraft 12 12 13 15 18 20

Gen Aviation

- piston N/A N/A N/A N/A N/A N/A

Gen Aviation

- turbine 1 1 1 2 2 2

Air Taxi

- piston N/A N/A N/A N/A N/A N/A

Air Taxi

- turbine 0 0 1 1 1 1

APU 6 6 7 8 10 11

Buffer Zone N/A N/A N/A N/A N/A N/A

Subtotal 25 25 28 32 37 42

NONPOINT SOURCES

Stationary Source Fuel Combustion

Industrial Fuel Combustion 56 56 60 65 71 77

Com/Inst Fuel Combustion 37 37 39 43 47 50

Res. Fuel Combustion 18 18 19 20 21 22

Res. Wood Combustion

Fireplaces 3,535 3,535 3,396 3,229 3,070 2,919

Woodstoves/Inserts

Non

- certified 1,266 1,266 1,062 805 549 292

Certified, Phase 1 550 550 445 334 250 141

Certified, Phase 2 449 449 551 671 783 814

Pellet Stoves 88 88 93 98 104 106

Subtotal 5,998 5,998 5,663 5,264 4,893 4,420

Industrial Processes

Chemical Manufacturing 8 8 8 9 10 11

Commercial Cooking 519 519 537 575 602 626

Food & Kindred Products

- Manufacturing 159 159 171 186 202 219

Mineral Processes 40 40 43 47 51 55

Rubber/Plastic Processes 68 68 73 80 87 94

Fabricated Metals 10 10 11 12 13 14

Construction

- Stationary

Road Construction* 178 178 183 189 185 180

Residential Dust Projects (Non

- Road Const.) 143 143 146 151 148 144

Commercial Dust Projects (Non

- Road Const.) 110 110 116 117 117 111

Asphalt, Sand and Gravel, Abrasive Blasting 29 29 31 31 31 29

Machinery 6 6 6 7 7 8

Mining and Quarrying

- Stationary 85 85 92 100 109 118

Miscellaneous Industrial Processes 34 34 37 40 43 47

Subtotal 1,389 1,389 1,453 1,545 1,603 1,655

Solvent Utilization

Architectural Coatings

- - - - - - Auto Refinishing

- - - - - -

Wood Furniture

- - - - - - Paper

- - - - - -

Plastic Products

- - - - - - Machinery & Equipment

- - - - - - Electronic & Other Electrical

- - - - - - Misc. Manufacturing

- - - - - - Subtotal

- - - - - - Other Solvent Utilization

Degreasing

- - - - - - Dry Cleaning

- - - - - - Graphic Arts

- - - - - -

Misc. Industrial Processes

- - - - - - Misc. Commercial Processes

- - - - - - Misc. Consumer/ Com. Solv.

- - - - - - Cutback Asphalt Application

- - - - - - Emulsified Asphalt Appl.

- - - - - - Pesticide, Fungicide & Rodenticide

- - - - - - Subtotal

- - - - - -Storage and Transport

Gas Service Station

- - - - - - Organic Chemical Storage

Subtotal

- - - - - - Waste Disp/Treat/Recovery

Commercial/Industrial Incineration

- - - - - - Publicly Owned Treatment Works N/A N/A N/A N/A N/A N/A

Remediation/Reclamation/ Recycle

- - - - - - Subtotal

- - - - - - Misc. Non

- Point Sources

Paved Road Fugitive Emissions* 1,453 1,453 1,414 1,517 1,627 1,736

Paved Road Fugitive Emissions, Sanding & Salting 339 339 516 490 466 442

Unpaved Road Fugitive Emissions* 2,623 2,623 2,380 2,479 2,688 3,174

Dirt Road Fugitive Emissions

- - - - - - Wildfires 10,947 21 21 21 21 21

Structure Fires 15 15 15 15 15 15

Motor Vehicle Fires 3 3 3 3 3 3

Firefighting Training

- - - - - - Open/Permit Burning 18 18 18 18 18 18

Prescribed Burning

- - - - - - Refuse Fires 16 16 16 16 16 16

Auto & Misc. Repair Shops 0 0 0 0 0 0

Health Services, Hospitals

- - - - - - Essay Labs 0 0 0 0 0 0

Human & Animal Cremation 9 9 9 10 10 11

Subtotal 15,425 4,499 4,394 4,571 4,865 5,437

TOTAL NONPOINT SOURCES 22,812 11,885 11,510 11,379 11,361 11,512

NON

- ROAD MOBILE SOURCES

CNG Engines 1 1 1 1 1 1

Diesel Engines 377 377 302 174 102 65

Gasoline Engines 192 192 176 186 198 211

LPG Engines 22 22 7 8 8 9

Locomotives 15 15 16 17 19 21

Subtotal 606 606 501 386 328 307

ON

- ROAD MOBILE SOURCES

On

- Road Vehicles* 1,171 1,171 946 835 825 880

HDDV Diesel Idling* 12 12 7 4 3 3

Subtotal 1,183 1,183 953 839 828 883

Grand Total 24,626 13,700 12,992 12,637 12,554 12,744

Safety Margin 708 1,063 1,146 955

* Sub

- Category included in MVEB 5,638 6,088 6,473 6,927