District Health Department 

AIR QUALITY MANAGEMENT DIVISION 

REVISIONS TO THE NEVADA 

Particulate Matter 

{PM10) 

STATE IMPLEMENTATION PLAN FOR THE 

TRUCKEE MEADOWS AIR BASIN 

[RENO PLANNING AREA (RPA*)] 

*As designated in the Federal Register 

Prepared by: 

The Washoe County District Health Department 

Air Quality Management Division 

August2002 

401 Ryland Street, Suite 331 • P.O. Box 11130 • Reno NV 89520 
Table of Contents 

Page 

Section I - Introduction 1 

Section II - Description of Truckee Meadows Nonattainment area 3 

Section Ill - PM10 Air Quality in the Truckee Meadows Basin 4 

Section IV - PM10 Emissions Inventory 

Summary of Sources 6 

Emissions Trend from 1988 - 2005 7 

Transportation Conformity Demonstration 9 

Section V - Control Strategies 

Summary of Current Strategies 10 

WCDHD Reg. 040.030 -- Dust Control 11 

Emission Reductions 

WCDHD Reg. 040.031 - Street Sanding Operations 12 

Emission Reductions 

WCDHD Reg. 040.032-Street Sweeping Operations 14 

Emission Reductions 

WCDHD Reg. 040.051 - Solid Fuel Burning Devices 16 

Emission Reductions 

Section VI - Attainment Demonstration 18 

Appendix AAppendix 8-

Design Value 19 

2001 Modeled PM10 Concentrations 20 

Washoe County District Health Department Monitoring Network 

Description and PM10 Summary Data for 1989 - 2001 

Washoe County 1999 Emissions Inventory for Particulate Matter 

AppendixC- Regional Transportation Commission's Air Quality Analysis and 

Conformity Determination as submitted and approved for the 2030 

Regional Transportation Plan 

Appendix DAppendix EAppendix FAppendix GWCDHD Regulation 040.030 - Dust Control 

Public Notice, proof of hearing and adoption, and comments 

submitted for WCDHD Reg. 040.030 

Example record keeping form for WCDHD Reg. 040.030 - Dust 

Control 

WCDHD Regulation 040.031 -Street Sanding Operations 

Washoe County - Serious PM10 SIP Revisions - August 2002 ii 
Appendix HAppendix IAppendixJAppendix KAppendix LAppendix MAppendix NAppendixOAppendix PAppendix QAppendix RAppendix SPublic Notice, proof of hearing and adoption, and comments 

submitted for WCDHD Regs. 040.031 and 040.032 

Table summarizing Street Sanding and Sweeping Regulations in 

other Areas 

Example reporting form forWCDHD Regs. 040.031and040.032-

Street Sanding and Sweeping Operations 

Raw data from the Nevada Department of Transportation (NDOT) 

for the Lake Tahoe Basin over 10 winter seasons showing a 

sand/salt reduction since the use of anti-icing methods. 

WCDHD Reg. 040.032 - Street Sweeping Operations 

WCDHD Reg. 040.051 - Solid Fuel Burning Devices 

Public Notice, proof of hearing and adoption, and comments 

submitted for WCDHD Reg. 040.051 

Letter from the District to U.S. EPA Region 9 

1999 Monthly Summary Reports illustrating PM10 concentrations 

Local Climatalogical Data for the Reno area in December 1989 

and January 1999 

State Implementation Plan (SIP) Completeness 

Checklist 

Legal Authority 

Correspondence to and from the Nevada Department of 

Environmental Protection Transmitting the SIP 

Public Notice, proof of hearing and adoption, and comments 

submitted for Revisions to the Nevada PM10 State 

Implementation Plan for the Truckee Meadows Air Basin 

Washoe County - Serious PM10 SIP Revisions -August 2002 iii 
TABLES 

Page 

Table 1 Washoe County 2000 Demographic Data 3 

Table 2 Summary of 2002 Truckee Meadows Serious PM10 SIP 10 

Best Available Control Measures 

Table 3 1996 Modeled Concentrations of PM10 μg/m3 19 

Table 4 2001 Modeled PM10 Concentrations and Base Year 20 

Table 5 Actual Year 2001 Modeled PM10 Concentrations 20 

FIGURES 

Figure 1 Truckee Meadows Exceedance of Annual NAAQS 4 

Figure 2 Number of PM10 24-hour Exceedance Days 4 

Figure 3 1999 PM10 Annual Emissions 6 

Figure 4 1999 PM10 Typical Winter Day 7 

Figure 5 Truckee Meadows PM10 Inventory Trend 8 

Washoe County - Serious PM10 SIP Revisions - August 2002 . iv 
Section I -- Introduction 

By authority of Nevada Revised Statute (NRS) 445B.500 the Washoe County District 

Health Department Air Quality Management Division (District) is the local agency 

responsible for air quality assessment and improvement for the Truckee Meadows Air 

Basin and all of Washoe County. The District has a history of adopting and implementing 

PM10 emission control measures to ensure healthful air for the public. These efforts are 

documented in the August 1991 submittal of the Nevada State Implementation Plan for 

the Truckee Meadows Air Basin - Particulate Matter (PM10}, and the Addendum to The 

Nevada State Implementation Plan for the Truckee Meadows Air Basin - Particulate 

Matter (PMlQ} that was submitted January 1994. 

In accordance with the 1990 Clean Air Act Amendments (CAAA), the Truckee Meadows 

Air Basin was initially classified as Moderate nonattainment for Particulate Matter less 

than 10 microns in size (PM10). However, on January 8, 2001, the nonattainment area 

(NAA) was reclassified to Serious due to failure to attain the particulate standard by 

December 31, 1994. The Serious Area reclassification was effective on February 7, 

2001. 

This document is a Revision to the PM10 Moderate NAA SIP, mentioned above, updating 

it to a Serious NAA SIP. Herein the District addresses: 

);;> Description of the PM10 Nonattainment Area 

);;> PM10 Air Quality and Monitoring Network 

);;> PM10 Emissions Inventory 

);;> Control Strategies 

);;> Attainment Demonstration/Design Value 

In large part because of the regulations the District adopted in the Moderate PM10 SIP 

the Truckee Meadows' air quality improved. In 1996 the Truckee Meadows NAA by legal 

definition was in attainment of both the 24-hour National Ambient Air Quality Standard 

(NAAQS) and the Annual NAAQS for PM10. However, this attainment date was after 

CAAA deadline for Moderate areas thus supporting the Serious bump up. 

Once an area is designated Serious, Title I, Part D, Subpart 4, Section 189(b)(1)(B) of 

the CAAA states that all significant sources of PM1o must apply Best Available Control 

Measures (BACM). The District believes that some the regulations adopted for the 

Moderate PM1o SIP were BACM at the time of submittal, especially Washoe County's 

Residential Wood Combustion (RWC) regulation. 

For this submittal the District reviewed the Moderate PM10 SIPs control strategies and 

addressed only the regulations that were adopted for the most significant sources in the 

NAA as indicated in the recent PM10 Emission Inventory, and based on previous 

modeling and source apportionment studies conducted for the Moderate PM10 SIP. As a 

result of that review three sources were determined as significant and in need of BACM: 

);;> Residential Wood Combustion (RWC) 

);;> Fugitive Dust from Construction Activity and Disturbed Land 

);;> Re-entrained dust from Paved Roads 

Washoe County - Serious PM10 SIP Revisions - August 2002 1 
The District requested that the U.S. EPA review the current regulations as submitted in 

the Moderate PM10 SIP for Dust Control and RWC, and give comments regarding 

whether or not the regulations could be considered BACM for this area. Based on their 

comments and subsequent public hearings the District adopted revised versions of the 

regulations that are herein submitted for the Truckee Meadows' Serious PM10 SIP and 

discussed in more detail in Section V, Control Strategies. 

The third source, re-entrained dust from paved roads, was only addressed in the 

Moderate PM10 SIP under the Dust Control Regulation references to construction site 

track-out, and with a regulation that addressed the specification of the sand used for 

winter time traction control during storm events. The revised Dust Control Regulation in 

this submittal applies BACM to all fugitive dust sources including track-out. Based on the 

fact that the last exceedance of the 24-hour PM10 NAAQS can be linked to the winter 

time application of sanding/traction control material, the District is submitting a newly 

adopted regulation to address paved Street Sweeping Operations and a revised Street 

Sanding Operations regulation. The District believes both the Street Sweeping and 

Sanding regulations are BACM. 

Washoe County - Serious PM10 SIP Revisions -August 2002 2 
Section II -- Description of Truckee Meadows Nonattainment Area 

Washoe County is located in the northwestern portion of Nevada. California borders it on 

the west and Oregon to the north. Within Nevada, Washoe County is bounded by 

Carson, Storey, Lyon, Churchill, Pershing and Humboldt Counties. Washoe County 

encompasses a land area of 6,608 square miles. The Truckee Meadows NAA is located 

in the southern part of Washoe County on the eastern slope of the Sierra Nevada 

mountain range and is comprised of three governmental entities including two 

unincorporated cities, Reno and Sparks, and portions of unincorporated Washoe 

County. 

Oregon Idaho 

At an average elevation of 4,500 feet it 

has a dry, high desert climate averaging 

around 7 inches of rain a year. The urban 

population for Washoe County is located 

within the NAA surrounded by mountain 

ranges. This topography can create an 

inversion when in the winter a layer of cold 

air is contained in the valley by the 

mountains. Above the cold, denser layer is 

warm air. The warm air inversion acts as a 

lid on the valley trapping all of the 

pollutants below it. The low winter sun 

angle provides only slight warmth, making 

the break up of the inversion doubtful if 

there is no wind or a storm front. Dry 

afternoon winds are common in the spring 

and summer, which can aggravate fugitive 

dust conditions. 

When the District first submitted the Moderate PM10 SIP in 1991 the population of the 

Truckee Meadows NAA was just under 200,000. Table 1 below gives the current 

Demographic Data. 

TABLE 1 

Washoe County 2000 Demographic Data 

City of City of PM10 Washoe 

Demographic Parameter Reno Sparks NAA County 

Population 180,480 66,346 271,588 339,486 

Land Area (square miles) 56 20 203 6,608 

Number of Households 80,618 27,179 116,340 145,425 

PM10 Season Temp Range 50-25 50-25 50 - 25 50 - 25 

PM10 Season Mean Temp (°F) 35 35 35 35 

Washoe County - Serious PM10 SIP Revisions - August 2002 3 
Section Ill -- PM10 Air Quality in the Truckee Meadows Basin 

The District currently monitors the ambient air quality, including PM10 concentrations, at 

7 air monitoring stations within Washoe County. Five of those stations are within the 

Truckee Meadows air basin. The trend in PM10 levels for the Truckee Meadows NAA is 

presented in Figures 1 and 2. Appendix A contains site descriptions for the PM10 network 

and a table summarizing the data for the past 13 years. The District has an excellent 

history of data that is consistently over 98% complete, and conforms to the applicable 

quality assurance requirements, air monitoring methodology, and siting criteria given in 

40 CFR Part 58. The District's Moderate PM10 SIP contained documentation of the 

Network's Quality Assurance and Quality Control procedures. 

Figure 1 

Truckee Meadows Exceedance of Annual NAAQS 

70 

c;)60 .+ ~~"""7"~~~~~..;......;.~~~~~.....;.;;.~..;......;.'"-----1 

E 

~SOf?',,_.._. __ lliii-______ ~"""'-.--.... .._._,-._,.._ .... ......., 

c 

0 i 40+-~~~~~~~~~ ~~~~~~------

... 

-

c 

B Jo+--------------------------------------1 c 

0 

u 20+---~---------------------------------1 0 

..... 

~ 

~ 10+-------------------------------------- 0+---.---..---.---...--.---.---.---.---.---.---.---.---f 

Figure 2 

Number of PM10 24-hour Exceedance Days 

1• ,., 1tt1 1"2 1tsl 1tM 1ttl5 19" 19'7 1!911 1999 2000 2001 

Washoe County - Serious PM10 SIP Revisions - August 2002 

-+-Annual 

-NAAQS 

4 
The annual PM10 National Ambient Air Quality Standard (NAAQS) is 50 micrograms per 

cubic meter. Since 1989 the annual standard was exceeded in 1990, 1991, 1992, 1993, 

1994, and 1999. The 24-hour PM1o NAAQS is 150 micrograms per cubic meter. Back in 

1989 and the early 1990's the Truckee Meadows would experience 5-7 exceedance 

days a year; however, in 1993 there was only one exceedance day, and then between 

1994-2001 the Truckee Meadows only experienced a single PM10 exceedance day in 

1999. 

PM10 continues to be sampled using the federal reference method (FRM) of size 

selective inlet high volume (SSI) samplers that collect airborne particles with a diameter 

approximately 10 micrometers and smaller. PM10 samples are collected on a quartz fiber 

filter over a 24-hour period. The filters are returned to the District's laboratory for 

weighing. PM10 samples collected with the SSI samplers are run every sixth day 

following a national schedule giving an approximate sample number of 60 a year if data 

is complete. 

The District also currently operates three PM10 monitors that give continuous hourly 

concentrations using a radioactive source that can detect beta rays and the reduction in 

beta particles and can then determine the mass, known as the Beta Attenuation Mass 

(BAM) Measurement Technique. The District began using a BAM in the late 1980s to 

help determine the Air Quality Index (AQI) on a daily basis since filter based PM10 

concentrations take days to determine. The first instrument the District purchased was 

not considered an equivalent method to the FRM. The District still operates that 

instrument at the Sparks Monitoring Station. 

The other two instruments the District operates are considered equivalent to the FRM for 

PM10. One is the Andersen BAM and the other is a Met-One 1020 BAM. (The Sparks 

BAM is the same model design as the Met-One 1020 BAM. Met-One purchased the 

design from a Japanese company and then completed the testing and paper work to get 

EPA equivalency - so one could argue that the Sparks BAM is an equivalent method 

also). The District had just begun operating the Andersen BAM in 1999 at the Reno 

Monitoring Station where it continues to run. The Met-One 1020 BAM will soon be 

operating at the Galletti Monitoring Station where some of the highest PM10 

concentrations are measured. The District is committed to monitoring the ambient air 

quality to ensure public health using the approved techniques. 

Washoe County- Serious PM10 SIP Revisions-August 2002 5 
Section IV -- PM10 Emissions Inventory 

Particulate Matter in the Truckee Meadows is the result of local primary PM10 from both 

stationary and mobile sources. The District conducted its first comprehensive PM10 or 

Base-Year Inventory in 1988 and included it as part of the Moderate PM10 SIP submittal. 

Another comprehensive inventory was completed in 1995, and as part of this SIP 

Revision staff updated the PM10 Emissions Inventory using 1999/2000 data. 

In these Inventories the District addresses all sources of PM10: 

1. Point or industrial sources like concrete batch plants; 

2. Stationary area sources such as construction projects; 

3. On-road mobile sources which include passenger vehicles, trucks and 

motorcycles; and 

4. Non-road mobile sources that include all off road equipment, airplanes, and 

trains. 

The Washoe County District Health Department 1999 Emissions Inventory for 

Particulate Matter is attached as Appendix B. Figure 3 below lists the major sources and 

the percent contribution on an annual basis attributed to each source in the 1999 PM10 

Emissions Inventory. Figure 4 lists the sources and their contribution on a typical winter 

day. 

Figure 3 

1999 PM10 Annual Emissions 

.: 

I FUEL COMBUSTION · 1.2% 

I UNPAVED STREETS 2.1% 

l 

i!:' MOBILE ON·ROAD. 

VEHICLES· 3.6% . 0 

"' 

~ () 

I 

MOBILE OFF-ROAD 

VEHICLES· 3.8% 

I •••• STATIONARY/INDUSTRIAL. Iii! PROCESSES· 7.6% 

0.0 

I RESIDENTIAL WOOD. 

COMBUSION • 8.5% 

500.0 1,000.0 1,500.0 

tons of PM10/year 

Washoe County - Serious PM10 SIP Revisions - August 2002 

2.000.0 

PAVED STREETS/RE· 

TRAINED DUST • 48% 

2,500.0 

6 
Figure 4 

1999 PM10 Typical Winter Day 

; J 

I FIRES - WILD & OTHER -

. 0.3% 

i I . FUS. COMBUSTION - 1.5" 

i I . UNPAVED STREETS - 1.8% 

i I illl!!ll MOBILE OFF-ROAD 

llllllllllil VEHICLES - 2.3% 

i l 

-

. MOBILE ON-ROAD 

VEHICLES · 2.9% 

i I •••• STREET SANDING -6.7% 

'I l 

l •••• STATlONARYnNOUSTRIAL PROCESSES · 7.4% 

I f •••• , •• CONSTR, CTION - 10.1% I 

I 

RESIDENTIAL WOOD 

COMBUSION • 24.1% 

I 

' ' 

' i 

l 

~ 

I 

i 

! 111111 ······················· PAVEDSTREETS/RE RAINED OUST - 42.7% t:;. I I I I I I ' 

0.0 2,000.0 4,000.0 6,000.0 8,000.0 10,000.0 12,000.0 14,000.0 

lbs of PM10/typlcal winter day 

In every PM10 Emission Inventory completed by the District the top four sources that 

contribute over 80% of the emissions on both an annual and seasonal basis are: paved 

street emissions from re-entrained dust; residential wood combustion (RWC) from wood 

stoves and fireplaces; fugitive dust from construction activities; and emissions from 

industrial processes. 

The 1988 Inventory estimated total PM10 emissions to be 6,514 tons/year. In 1995, 

which was an attainment year, the Inventory estimated 3,979 tons of PM1olyear. The 

most recent Inventory, which gives PM10 estimates for 1999, the year of the most recent 

exceedances of the annual and 24-hour PM10 NAAQS, occurred; the PM10 emissions 

were estimated at 4,571 tons/year. This document submits new regulations that have 

been adopted that specifically reduce the PM10 emissions from the primary source 

(sanding material applied for wintertime traction control) that caused the 1999 

exceedance (Section V, Control Strategies). The control strategies and their estimated 

emission reductions should be fully implemented in 2005 (see Section V). If a 2005 

Inventory is estimated using the 1999 estimates with population growth factors, and the 

emission reduction credits estimated in Section V are applied, the calculated emission 

estimate of 3,905 tons of PM1olyear is less than the attainment year 1995 estimate (see 

Figure 5). In 2001 the road agencies voluntarily used the new Sand Specification, and 

reduced their sand use so the 2001 emission estimates would have partial emission 

reductions. 

Washoe County - Serious PM10 SIP Revisions - August 2002 7 
Figure 5 

Truckee Meadows PM10 Inventory Trend 

7,000.0 ..--------------.-------------..--------------. 

6,000.0 

5,000.0 

.. 4,000.0 

l 

c 

~ 3,000.0 

2,000.0 

1,000.0 

0.0 

Base-Year 1988 1995 

PM10 Emission Estimates 

Washoe County - Serious PM10 SIP Revisions - August 2002 

1999 2005 

8 
Transportation conformity in the Truckee Meadows 

The Truckee Meadows has a current Conformity Determination that was approved in 

November 2001 as part of the Regional Transportation Commissions 2030 Regional 

Transportation Plan (see Appendix C for Air Quality Analysis and Conformity 

Determination). The Analysis was done using the methodology of "action" scenario 

emissions do not exceed the "no action" scenario emissions (Section 93.119(c) of the 

Federal Register) since the Truckee Meadows did not have a motor vehicle "emission 

budget" nor did the Moderate PM10 SIP have any Traffic Control Measures (TCMs). This 

approach was approved by both the U.S. EPA and the Federal Highway Administration 

in November of 2001 (See Appendix C) and that Conformity Determination is still valid. 

The Truckee Meadows has been in attainment since 1996, ·and the U.S. EPA does not 

require conformity determinations for years after the attainment year so an emission 

budget is not being established for transportation conformity purposes. 

Washoe County - Serious PM10 SIP Revisions -August 2002 9 
Section V -- Control Strategies 

Since early 1988, the District along with other local governmental agencies has adopted 

a number of regulations to reduce PM1o emissions. The Moderate PM10 SIP that the 

District submitted in 1991 based on a source apportionment study, a base-year PM10 

Emissions Inventory and modeling included Washoe County District Health Department 

(WCDHD) regulations that addressed: 

> Dust Control for fugitive dust sources (WCDHD Reg. 040.030). 

> New stationary sources by requiring Lowest Achievable Emission Rate (LAER) 

(WCDHD Reg. 030.700). 

> Highway deicing specifications (WCDHD Reg. 040.031). 

> Food establishments/charbroilers by requiring Best Available Control Technology 

(BACT) (WCDHD Reg. 040.033). 

> Residential Wood Combustion (RWC) (WCDHD Reg. 040.0514). 

> Diesel Engine Idling (WCDHD Reg. 040.200). 

The Addendum to the Moderate PM10 SIP that was submitted in January of 1994 

included: 

> Additional RWC regulations that were existing prior to the 1991 submittal but 

were not included with the original submittal (WCDHD Reg. 040.051 and Reg. 

040.0512). 

> A Revised Version of the Dust Control regulation (WCDHD Reg. 040.030). 

> City of Reno (Section 18.06.340) and City of Sparks (Title 20) ordinances that 

require parking lots to be .paved. 

With the Truckee Meadows bump up to a Serious NAA effective February 7, 2001, this 

Revision to the PM10 SIP ensures that all significant sources are applying BACM as per 

CAA and that the source of the 1999 exceedance was addressed. 

TABLE 2 

Summary of 2002 Truckee Meadows Serious PM10 SIP Best Available Control 

Measures 

Control Measure Source Category Adoption Date Effective Date 

Regulation Number 

Construction/Disturbed Land 

040.030 Dust Control July 26, 2002• Sept. 15, 2002 

Paved Streets Feb.27,2002 

040.031 Street Sanding Operations 

Sand Specification March 2002 

20% Sand Reduction June 2003 

35% Sand Reduction June 2004 

50% Sand Reduction June 2005 

Annual Usage Reporting March 2002 

Paved Streets 

040.032 Street Sweeping Operations Feb.27,2002 

PM10 Certified Sweepers March 2002 

Expeditious Sweeping March 2002 

Sweepina within 4 days of sandina Nov. 1, 2003 

Routine Sweeping once/month March 2002 

Annually Report Sweepina Efforts March 2002 

Residential Wood Combustion 

040.051 Solid Fuel Bumina Devices June 19, 2002 Jan. 1,2003 

*Final version adopted at the same Public Hearing as the Revisions to the PM10 SIP 

Washoe County - Serious PM10 SIP Revisions -August 2002 10 
040.030- Dust Control: Revision to update regulation to conform to current 

Best Available Control Measure BACM re uirements. 

The District believes the Dust Control Regulation as adopted in the Moderate PM10 SIP 

helped the Truckee Meadows reach attainment. However, since the bump up to a 

Serious NAA the regulation must conform to BACM. The District requested the U.S. 

EPA review the regulation as submitted in the Moderate PM10 SIP and comment on what 

may be necessary to update it to current BACM requirements. 

The U.S. EPA responded indicating that the District should include: 

1. Additional definitions 

2. Performance standards and test methods for control of fugitive dust during 

activities and from disturbed surfaces left vacant. 

3. Basic record keeping requirements to verify sources are implementing dust 

control measures. 

4. A requirement for track-out control devices and clarification of when track-out 

should be cleaned-up. 

5. Specific requirements addressing fugitive dust from inactive disturbed open 

areas, etc. 

Appendix D contains the version of WCDHD Reg. 040.030 recently adopted and historic 

versions of the District's Dust Control regulation. The U.S. EPA last approved the Dust 

Control Regulation for Washoe County in 1972 so that is the official regulation that this 

newly adopted BACM version replaces. The District also includes a copy of the 

regulations as submitted in the Addendum to the Moderate PM10 SIP because that is the 

version that has helped the area achieve attainment. Finally there is a strikeout copy of 

the Moderate PM10 SIP version of WCDHD Reg. 040.030 in the new format and with the 

new BACM requirements. 

When revising this regulation the District held two advertised Public Workshops, one on 

November 13, 2001, and one on May 14, 2002, as well as many meetings with various 

interested parties such as construction industry representatives. WCDHD Reg. 040.030 

was _also heard at two Public Hearings, one on May 22, 2002, and one on July 26, 2002. 

Documentation of the public listing, proof of public hearing, and comments generated 

are contained in Appendix E. 

The District has always operated under the basic premise in regards to dust control that 

all dust generating sources must apply measures to control the emissions. Dust 

generating sources include, but are not limited to, construction activities such as land 

clearing, drilling and blasting, cut and fill activities, and windblown emissions from 

disturbed surfaces. WCDHD Reg. 040.030 specifically: 

)> Prohibits visible emissions lasting longer than 5 minutes within any 60 minute 

consecutive interval; 

)> Requires stabilization for unpaved staging areas, unpaved haul roads, open 

disturbed areas, and storage piles; 

)> Requires any disturbance over 1 acre to submit a plan to control fugitive dust 

emissions with various measures such as water application and obtain a Dust 

Control Permit from the District; 

)> Requires Project Information Signs; 

)> Gives guidelines for certain work practices such as bulk material hauling and 

track out; 

Washoe County - Serious PM10 SIP Revisions -August 2002 11 
> Administrative requirement of Dust School Attendance if issued a citation; 

> Lists specific test methods that can be used for Compliance Determinations; 

and 

> Requires record keeping and retention (See Appendix F for the District's 

sample record keeping form). 

Many of the changes made to this version of WCDHD Reg. 040.030 strengthen its 

enforceability. Such as the Dust Control Permit, in the version of the regulation 

submitted with the Moderate PM10 SIP surface area disturbances had to submit Dust 

Control Plans, but they were not considered Permits, and Citations were not issued 

solely based on the "plan" not being followed. 

Emission Reductions 

Various studies that have monitored PM10 emissions from construction activities have 

determined that effective water programs alone can reduce PM10 emissions by 60 to 90 

percent. Many of the reductions can already be attributed to the Moderate PM10 SIP 

version of WCDHD Reg. 040.030 because that regulation could be considered at least 

Reasonable Available Control Measures (RACM). The District estimates reductions 

associated with this upgraded BACM version, that has more specific guidelines to 

control track-out and increased enforceability, conservatively at 10 percent based on the 

previous RACM reductions. 

I 040.031 -- Street Sanding Operations 

The District submitted with its Moderate PM10 SIP a version of WCDHD Reg. 040.031 

that tightened the specifications for the sand used for wintertime traction control. Based 

on the fact that the 1993 and 1999 24-hour PM10 exceedance days could be linked to the 

application of sanding material, the sand specification previously submitted needed to be 

tightened requiring the sand to be more durable with even less fines. 

Appendix G contains WCDHD Reg. 040.031 submitted with the Moderate PM10 SIP, a 

clean copy as adopted on February 27, 2002, and a stikeout version indicating the 

changes. Immediately after the January 6, 1999 exceedance the District contacted the 

road agencies responsible for applying the sanding material and verified that they were 

using sand with the proper specifications. The Agencies were alerted that the sanding 

practices had created a PM10 problem and that the District was going to be looking at 

. ways to reduce PM10 emissions that result from sanding. 

The District began formal meetings with the road agencies in December of 2000 and 

formed the Road Sanding and Sweeping Working Group to discuss what alternatives 

existed to ensure safe roads and reduce PM10 emissions. This working group met almost 

monthly during 2001 and continues to meet on a quarterly basis now to keep everyone 

informed on the latest technologies and up to date with reporting requirements. A Public 

Workshop was held on December 7, 2001, and the Public Hearing for adoption was held 

on February 27, 2002. Documentation of the public listing, proof of public hearing, and 

comments generated are contained in Appendix H. 

Washoe County - Serious PM10 SIP Revisions - August 2002 12 
· To determine what may be considered BACM the District reviewed what type of 

regulations other areas that have winter time sanding events required: Colorado, 

Montana, Utah and Washington. (Appendix I contains a summary of each area's control 

strategies). One of the most comprehensive regulations for both sanding and sweeping 

was found in Colorado for the Denver area and the District modeled both the Sand and 

Sweeping control strategies after Regulation 16 of the Colorado Air Quality Control 

Commission. The BACM version of WCDHD Reg. 040.031 Street Sanding Operations: 

Ji>- Tightens the durability and reduces the amount of fines allowed in the sand used 

as wintertime traction control material. 

Ji>- Requires road agencies to submit a Reduction Plan (due April 1, 2002) stating 

how they plan to reduce the amount of sanding material used per lane mile by at 

least fifty percent by 2005. 

Ji>- Requires road agencies to report annual material usage and verification that the 

approved sanding material was used. (See Appendix J for an example form that 

lists all the information the District needs annually to track compliance with the 

regulation.) 

During the Road Sanding and Sweeping Working Group meetings it was determined that 

it was possible for the Agencies to go from using around 1200 lbs/lane mile of sanding 

material to 600 lbs/lane mile (50% reduction) using various techniques. It was further 

discovered that the total 50% reduction could be achieved solely by using anti-icing 

techniques. Anti-icing involves treating the roadways with a salt solution prior to a storm 

event to prevent the moisture from bonding with the pavement creating icy conditions. 

The Nevada Department of Transportation (NDOT) has documented such a reduction 

because they began using anti-icing techniques in the Lake Tahoe Basin over ten years 

ago, but just in 2001 began using it in the Truckee Meadows Basin. (See Appendix K for 

NDOT data for the La~e Tahoe Basin.) 

Other techniques that road agencies can use to help achieve the 50% reduction are to 

be conscious of how much material they apply, and not applying more than is necessary 

to ensure public safety, such as only applying the material at intersections not on 

straight-aways. They can calibrate the spreaders on their sanding trucks and have 

spreaders that are locked at a fixed application rate that cannot be increased manually. 

WCDHD Reg. 040.031 required that each road agency submit a Reduction Plan stating 

how they would reduce the PM10 emissions. All the entities involved have submitted their 

Reduction Plans. 

Emission Reductions 

Ji>- Emission Reductions from more durable sand specification - 20% 

The first control strategy contained in WCDHD Reg. 040.031 is the tightening of 

the sanding material specifications. The newly adopted specification reduces the 

amount of fines smaller than 200-mesh sieve by 50% (from 5 percent fines to 2.5 

percent fines). On an exceedance day paved street contributions were estimated 

at 66% so the reduction in PM10 emissions associated with a 50% reduction in 

fines could be calculated as follows: 

[0.66paveddust *(1-(1-(Percent fine reduction /100))"0.8))] X 100 

Washoe County - Serious PM10 SIP Revisions - August 2002 13 
[0.66 *(1-(1-(50/100))"0.8))] x 100 = 28% 

The wintertime exceedance day dust fraction attributable to paved dust and road sanding is 0.66, 

and the power of 0.8 is based on EPA established methodology. 

If you take into account that, in addition to the 50% reduction in the 200-mesh fines, the 

material is harder (durability index increased from 55 to 75), the specification now 

contains a hardness index, and restricts fines smaller than the 100-mesh sieve the PM10 

emission reduction would be greater than 28 percent. However, without further studies 

on the benefits of the less fine more durable material, the District conservatively 

estimates the emission reductions at 20 percent. 

The road agencies voluntarily began using this new material in 2001 so this 20% 

reduction can be applied in 2001. 

> Emission reductions that will be realized by reducing the amount of sanding material 

applied - By 2005 -- 28% 

Voluntary in 2001 -16.4% 

All the entities have submitted plans to reduce the amount of sanding material they use 

per lane mile by at least 50% by 2005: 

On a wintertime exceedance day, paved street contributions were estimated at 

66% so the reduction in PM10 emissions associated with a 50% reduction in 

sanding material could be calculated as follows: 

[0.66paved dust *(1-(1-(Percent fine reduction /100))"0.8))] X 100 

[0.66 *(1-(1-(50/100))"0.8))] x 100 = 28% 

The wintertime exceedance day dust fraction attributable to paved dust and road sanding is 0.66, 

and the power of 0.8 is based on EPA established methodology. 

The road agencies voluntarily began reducing the amount of sand used per lane mile in 

2001. End of season reports show average sand use reduction was around a 30 percent 

which calculates as: 

[0.66paveddust *(1-(1-(Percent fine reduction /100))"0.8))] X 100 

[0.66 *(1-(1-(30/100))"0.8))] x 100 = 16.4% 

The wintertime exceedance day dust fraction attributable to paved dust and road sanding is 0.66, 

and the power of 0.8 is based on EPA established methodology. 

I 040.032 - Street Sweeping Operations 

This is a new control strategy that the District determined was necessary based on the 

fact that the 1993 and 1999 24-hour PM1oexceedance days could be linked to the 

application of sanding material and the lack of expeditious clean up of the material. 

As mentioned under the Street Sanding control strategy the District began formal 

meetings with the road agencies in December of 2000 and formed the Road Sanding 

and Sweeping Working Group to discuss what alternatives existed to ensure safe roads 

Washoe County - Serious PM10 SIP Revisions - August 2002 14 
and reduce PM10 emissions. This working group met almost monthly during 2001 and 

continues to meet on a quarterly basis now to keep everyone informed on the latest 

technologies, and up to date with reporting requirements. 

This is a new WCDHD regulation (see Appendix L) and the Public Workshop was held 

on December 7, 2001 . The Public Hearing for adoption was held on February 27, 2002. 

Documentation of the public listing, proof of public hearing, and comments generated 

are contained in Appendix H. 

Since this was a brand new regulation and control strategy for the area, the District 

same as with the sanding control strategy, reviewed related regulations from other 

areas: Colorado, Montana, Utah, Washington, South Coast AQMD, and Las Vegas. 

Based on that review WCDHD Reg. 040.032 requires: 

);:> The purchase of Street Sweepers that are certified by the California South Coast 

Air Quality Management District to be PM10 efficient. 

);:> Maintenance of sweeping equipment to keep it operating efficiently 

);:> Expeditious cleaning of streets after application of sand for traction control -

within 4 days of event starting November of 2003. 

);:> Routine sweeping streets in the Road Network. 

);:> Record keeping to verify expeditious sweeping. (See Appendix J for an example 

of the annual reporting format.) 

The requirement to sweep within 4 days has a delayed implementation date of 

November 2003 to allow time for the agencies to acquire the necessary number of 

sweepers to meet the requirement. To assist the road agencies in complying with these 

new control strategies the District was successful in applying for and securing over 4 

million dollars in federal Congestion Mitigation and Air Quality (CMAQ)-funds for the 

agencies to purchase certified street sweepers. Most of those agencies plan to purchase 

the sweepers this next fiscal year. A few of the road agencies have already purchased 

some sweepers that are PM10·certified. 

Emission Reductions 

Many street sweeping studies have been conducted in the last few years that all seem to 

indicate that the quicker the material can be cleaned up the better the PM10 reduction 

benefit. For routine sweeping the U.S. EPA recommended emission reduction credit is 

34% as stated in the Control of Open Fugitive Dust Source document. It can be 

assumed that if a sweeper is more efficient (80% as per the South Coast AQMD 

certification) and the material is collected quicker than what EPA considers a routine 

basis that the emission reduction credit should be even greater than 34%. 

Colorado did an Emission Benefit Analysis comparing different sweeping technologies, 

etc. in October of 1999 when they were adopting their regulations. That analysis 

determined that credit applied for PM10 emissions if swept within 4 days could range 

between 32%-84%. This analysis did not compare any sweepers that were considered 

certified to be 80% efficient, and if it did the upper percentage would probably be 

somewhat greater - around 72%. 

Without the benefit of a local study the District is assuming 40% emission reduction 

credit for the street sweeping regulations. This is slightly higher than the U.S. EPA 

recommended reduction credit of 34% for routine sweeping; however, the District will be 

Washoe County - Serious PM10 SIP Revisions - August 2002 15 
tracking the agencies clean up efforts in the future. Therefore, with sanding events or 

heavy loads that require expeditious clean up, the emission reduction benefit will be 

based on the type of equipment similar to the Colorado analysis and will have reductions 

greater than the 34% (at least 60%). This event-driven increase would increase the 

overall emission reduction credit for this source category. As will the fleet of sweepers 

becoming more efficient. (South Coast AQMD estimates a 7% reduction per year from 

certified sweepers.) 

The road agencies voluntarily, and with the District's help (staff has called them to 

request sweeping in problem areas), began more expeditious clean up in 2001; 

therefore, the District is assuming at least a 10 percent reduction could be applied in 

2001. 

040.051 - Solid Fuel Burning Devices: Revision to update regulation to 

conform to current Best Available Control Measure BACM re uirements. 

The District believes the existing Solid Fuel Burning Device regulations that were 

submitted with the Moderate PM10 SIP helped the Truckee Meadows reach attainment. 

The District is confident that when the regulations were adopted and implemented 

(1988-1990) in the Truckee Meadows they were BACM for residential wood combustion 

(RWC). However, since the bump up to a Serious NAA the regulation must conform to 

what the U.S. EPA now may consider BACM. As with the Dust Control regulation, the 

District requested the U.S. EPA review the regulations as submitted in the Moderate 

PM10 SIP and comment on what may be necessary to update those regulations to 

current BACM requirements. 

The U.S. EPA responded indicating that the District should: 

1. Include a requirement regarding selling seasoned wood; 

2. Prohibit certain fuels for use in solid fuel burning devices; 

3. Include all definitions in the rule packet; 

4. Provide additional definitions for new terms; 

5. Clarify that an existing device that is not allowed or certified must be removed 

or upgraded upon real estate sale; and 

6. Clarify which devices the 1-acre limitation pertains. 

Appendix M contains the version of WCDHD Reg. 040.051 recently adopted and copies 

of the regulations as submitted for the Moderate PM10 SIP. The District, when revising 

the regulations for the Serious PM10 SIP, decided to revise the District's regulation 

format. The format change facilitated combining the old RWC regulations {there had 

been three separate regulations) into one regulation. 

The District held an advertised Public Workshop for WCDHD Reg. 040.051 on June 5, 

2002, and held a few meetings with various interested parties such as real estate agents 

and Title Companies. The Public Hearing was on June 19, 2002. Documentation of the 

public listing, proof of public hearing, and comments generated are contained in 

Appendix N. · 

WCDHD Reg. 040.051 requires: 

)- All wood stoves sold to be certified to the latest EPA emission standards; 

)- Uncertified existing devices must be removed upon change of ownership; 

Washoe County - Serious PM10 SIP Revisions - August 2002 16 
»- Visible Emissions greater than Ringlemann 2 are not permitted for more than 3 

minutes in any one-hour. 

»- Burning materials other than seasoned wood is prohibited; 

»- Selling wood that is unseasoned for immediate use is prohibited; 

»- Limitation on the number of Solid Fuel Devices permitted; 

»- Building permits may only be issued for certified devices; 

»- Every device sold in Washoe County must have a completed Dealers Affidavit of 

Sale submitted to the District; 

»- All real estate transactions must be certified in compliance with wood stove 

requirements. Uncertified devices must be removed, certified devices must be 

inspected and issued a Certificate of Compliance; 

»- Curtailment of burning solid fuels during pollution alerts. 

Most of the changes made to this version of WCDHD Reg. 040.051 were cosmetic or for 

clarification. The new sections address not allowing the use of certain fuels and 

unseasoned wood. 

Emission Reductions 

The District believes that the version of the RWC regulations that was submitted with the 

Moderate PM10 SIP helped achieve the cleaner air the Truckee Meadows has today. The 

previous regulations that have been in effect since 1990 have already reduced 

emissions and are probably already reflected in the Truckee Meadows PM10 Inventory. 

One of the biggest emission reduction control strategies that is a product of this 

regulation is the Public Information aspect associated with the curtailment of wood 

burning during high pollution alerts. The District devoted a lot of resources to promoting 

the "Green/Yellow/ Red" program when it was first implemented and continues to use it. 

Based on data from 5 wood use surveys conducted over the last ten years, on average, 

80% of the respondents say they comply with Yellow (curtail unnecessary burning) or 

Red (do not bum). 

At this time the District is not applying any additional reduction credit to this updated 

regulation. · 

Washoe County - Serious PM10 SIP Revisions - August 2002 17 
Section VI -- Attainment Demonstration 

As stated previously in large part because of the regulations the District adopted in the 

Moderate PM10 SIP the Truckee Meadows' air quality has improved. In 1996 the Truckee 

Meadows NAA by legal definition was in attainment of both the 24-hour National 

Ambient Air Quality Standard {NAAQS) and the Annual NAAQS for PM10. 

Subpart 4 Section 188(c) of the CAAA states that the attainment date for Moderate 

areas was December 31, 1994. The District did not meet that date and did not request 

an extension of the Moderate attainment date because Section 188( d)(2) of the CAAA 

states one could only request an extension if the area's mean annual concentration of 

PM10 was less than or equal to the NAAQS. The Truckee Meadows' annual 

concentration was not less than the annual NAAQS until 1995, which was after the 

CAAA attainment date. 

The Truckee Meadows has continued to attain the Annual PM10 standard which is based 

on a three (3) year average for the past six (6) years and the 24-hour standard with the 

exception of one 24-hour exceedance on January 6, 1999. The District believes the 

Truckee Meadows air basin is currently, and as of the Serious Area Attainment deadline 

of December 31, 2001, in attainment of the PM10 Standard. (See Appendix A for a copy 

of the Table taken from the District's Trends report that summaries the PM10 data from 

1989 to 2001 .) 

The January 6, 1999 exceedance is considered 6 exceedance days based on statistical 

calculations that assume since the District only operated federal reference monitors 

(FRMs) on a 1 in 6 day schedule in 1999, it is assumed there were 6 exceedance days 

verses the allowed 1 exceedance day per year. When the District reads the federal 

register referencing the calculation of the PM10 NAAQS, 40 CFR Part 50, Appendix K, 

paragraph 2.3, Data Requirements, it notes that "More than 3 years may be 

considered ... " 

If the last seven years of data are used to average out the 6 exceedance days attributed 

to the 1 exceedance day in 1999 the number is less than the 1 allowed exceedance day. 

(See Appendix 0) for letter dated April 17, 2001 to the U.S. EPA Region 9 stating the 

District's position on the current attainment status.) 

The District was also running two continuous PM10 monitors in 1999 that has data that 

refutes the statistical assumption that the 1 day exceedance day would equal 6 

exceedance days. One of the continuous monitors, the Sparks BAM, is not deemed an 

equivalent method to the FRM, but the other one, the Andersen BAM, is. The District 

was running the Andersen BAM continuous PM10 monitor on a datalogger where we 

were also trying to get a new nephalometer working. In January of 1999 that datalogger 

was not part of the District's official network yet. But it was collecting data for the full year 

with some outages primarily due to changes to the datalogger program because of the 

nephalometer. 

The Andersen BAM is located at the downtown Reno Site (See Appendix A for 

monitoring network information). The District also operates an Andersen Hi-Volume 

sampler that is a reference method for PM10 at that site. See Appendix P for Monthly 

Summary Sheets for the Reno Site in 1999 with the Anderson BAM daily concentrations. 

Appendix P also contains copies of the Monthly Particulate Network Summary Reports 

Washoe County - Serious PM10 SIP Revisions - August 2002 18 
for 1999 that summarize the concentrations from the FRMs at each site and the Sparks 

BAM's daily numbers in 1999. 

At the Reno Monitoring Station on January 6, 1999, the FRM measured a 24-hour PM10 

concentration of 197 μg/m3 and the Andersen BAM measured the 24-hour PM10 

concentration at 168 μg/m3. The next highest FRM 24-hour concentration for any day 

other than January 61

h at any site in 1999 was 116 μg/m3 on September 9th at the Galletti 

site. The next highest Andersen BAM 24-hour concentration for 1999 was 114 μg/m3 

that occurred the day before the exceedance on January 5, 1999. 

Design Value 

The year 1996 was the third year that the Truckee Meadows did not experience an 

exceedance of the PM10 standards. The design values for 1996 are 47.7 μg/m3 for an 

annual average and 151 μg/m3 for the maximum 24-hour average PM10 concentration. 

Based on contributions estimated in the 1999 PM10 Emissions Inventory modeling of the 

1996 Base-year contributions are summarized in Table 3: 

TABLE 3 

1996 Modeled Concentrations of PM10 μg/m3 

Source Percent 1996 Base Year 

Contribution Design Values 

Annual Winter Annual 24-Hour 

Day 

Wood burning 8.5 24 4.05 36.24 

Re-entrained 50.5 52 24.09 78.52 

Road Dust 

lndustrialNehicle 

ExhausUother 16.6 14 7.92 21 .14 

Combustion 

Construction 24.4 10 11.64 15.10 

Total 100 100 47.7 151 

In 1999 the Truckee Meadows experienced an exceedance of the 24-hour PM10 

standard. The exceedance occurred on January 6, 1999, after a series of winter storms 

where a large quantity of sand and salt had been placed on the streets for traction 

control. The storms occurred during the holidays and the sand from the previous storm 

was not swept up before the next storm. On the day of the exceedance there were low 

wind speeds, which indicates that windblown dust was not a significant contributor to the 

exceedance. The Carbon Monoxide levels were not elevated which indicates that the 

wood burning contribution was not higher than typical. The fact that sanding material 

was visible on the streets combined with the meteorological data indicates that for this 

day re-entrained road dust from the sand used for traction control was the primary 

contributor to the exceedance. (Appendix Q contains the local climatological data for 

from December 1998 and January 1999). 

Washoe County - Serious PM10 SIP Revisions - August 2002 19 
TABLE4 

2001 Modeled PM10 Concentrations and Base Year 

Source 

1999-2001 PM10 Levels Baseline 

Annual Annual Percent 24-

Percent (μg/m3) Contribution hour 

Contribution on (μg/m3) 

Exceedance 

Day* 

Wood buminq 8.5 4.02 16.9 36.24 

Re-entrained 50.5 23.89 66.3 142.52 

Road Dust 

Ind ustrialN eh icle 

ExhausUother 16.6 7.85 9.8 21.14 

Combustion 

Construction 24.4 11.54 7 15.1 0 

100 47.3 100 215 

*In relation to a typical Base Year day with street sanding as primary contributor 

** Voluntary cooperation of Road Agencies in 2001: 

Reduction in sand applied: 

30% reduction in the amount of sand applied 

1999-2001 PM10 

Levels with partial 

control 

Annual 24-

(μg/m3) hour 

(μg/m3) 

4.02 36.24 

21.49** 76.45** 

7.85 21.14 

11 .54 15.10 

44.9*** 149** 

= 0.66 (1-(1-(30/1 QO))A0.8)) x 100: 16.4 % reduction credit 

Use of more durable sanding material: 20.0 % reduction credit 

1996 Base Year 

Design Values 

Annual 24-

(μg/m3) hour 

(μg/m3) 

4.05 36.24 

24.09 78.52 

7.92 21 .14 

11.64 15.10 

47.7 151 

Expeditious sweeping: 10.0 % reduction credit - only reduction applied to Annual# 

Total Reduction Credit: 46.4 % 

*** Less than 1996 Base Year/Attainment Year concentration 

TABLES 

Actual Year 2001 Modeled PM10 Concentrations 

Source 

Actual Year 2001 

Annual Winter Day Annual 24-

Percent Percent (μg/m3) hour 

Contribution Contribution (ua/m3) 

Wood burning 8.5 16.9 3.83 27.12 

Re-entrained 50.5 66.3 22.72 58.76 

Road Oust 

lndustrialNehicle 

ExhausUother 16.6 9.8 7.47 15.82 

Combustion 

Construction 24.4 7 10.98 11.3 

100 100 45 113 

This modeling, in addition to the clean ambient air quality data the Truckee Meadows 

has experience for the past 7 years, demonstrates that the NAA is currently in 

attainment of the annual and 24-hour PM10 standard. This Serious PM10 SIP also 

proposes additional control strategies and reduction credits that will be fully implemented 

in 2005. The District is confident that with continued diligent enforcement of all the 

Washoe County District Health Department Regulations Governing Air Quality and all 

adopted SIP control measures, the annual and 24-hour PM10 NAAQS will be met in 

future years. 

Washoe County - Serious PM1o SIP Revisions - August 2002 20