# 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 

### AirQuality 

### 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 PM 10 SIP Revisions - August 2002 ii

### Appendix HAppendix 

### IAppendixJAppendix KAppendix LAppendix MAppendix NAppendixOAppendix PAppendix Q

### Appendix 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 otherAreas 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 10winter 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 Letterfrom the Districtto 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 forthe Truckee Meadows Air Basin

Washoe County - Serious PM 10 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 PM 10 SIP Revisions - August 2002 . iv

### Section 

### I -- Introduction By authority of Nevada Revised Statute (NRS) 445B.500 the Washoe County District Health DepartmentAir Quality Management Division (District) is the local agency responsible for air quality assessment and improvement for the Truckee Meadows Air Basin and all ofWashoe County. The District has a history of adopting and implementing PM10 emission control measures to ensure healthful airfor 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 ofthe 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 forthe 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 forthe 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 ofthat 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 dustfrom Paved Roads

Washoe County - Serious PM10 SIP Revisions - August 2002 1The 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 underthe Dust Control Regulation references to construction site track-out, and with a regulation that addressed the specification ofthe 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 ofthe 24-hour PM 10 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 PM 10 SIP Revisions -August 2002 2

### Section II -- Description ofTruckee 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 ofWashoe County on the eastern slope of the Sierra Nevada mountain range and is comprised ofthree governmental entities including two unincorporated cities, Reno and Sparks, and portions of unincorporated Washoe County.

Oregon Ida ho 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 slightwarmth , making the break up of the inversion doubtful if there is no w ind 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 ofthe 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 PM 10 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 ofthose 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 forthe 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 ofAnnual 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 - Se rious PM 10 SI P Revisions - August 2002 -+-Annual -NAAQS



### 4The 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 of60 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 atthe 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 paperwork 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 Mon itoring 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 PM 10 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 ofthe 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 F UEL CO MBUSTION · 1 .2% 

# I U NPAVED STRE ETS 2. 1% 

# l i!:' MOBILE ON·ROAD. VE HICLE S·3.6% . 0 

### "'**~** () 

### I MOBI LE OFF-ROAD VE H ICLES · 3.8% 

### I •••• STATIONARY/I NDUSTRIAL. Iii! PROCESSES· 7.6%

0

.0 

### I RESIDENTIAL WOOD. CO MBUSION • 8 .5%

500.0 1,000.0 1,500.0 tons ofPM10/year

Washoe County - Serious PM 10 SIP Revisions - August 2002 2.000.0 PAVED STRE ETS/RE · TRAINED DUS T • 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

. U NPAVED STREETS - 1 .8% 

## i 

# I illl!!ll M OBILE OFF-ROAD llllllllllil V EHICLES - 2.3% 

### i l

- . M OBILE ON -ROAD VEHICLE S · 2.9% 

## i 

# I •••• STR EET SANDING -6.7% 

# 'I l l •••• STA TlON ARYnNOUSTRIA L PROCESSES · 7.4% 

## I f •••• , •• CON STR, CTION - 10. 1% 

# I I RESIDENTIAL WOOD COMBUSION • 24. 1% 

## I ' ' ' 

## i 

# l**~** 

### I i 

## !**······················· PAVEDSTREETS/RE**  111111 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% ofthe 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 dustfrom 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 ofthe most recent exceedances ofthe annual and 24-hour PM10 NAAQS, occurred ; the PM 10 emissions were estimated at 4,571 tons/year. This document submits new regulations that have been adopted that specifically reduce the PM 10 emissions from the primary source (sanding material applied forwintertime 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 PM 10 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 PM 10 SIP Revisions - August 2002 1999 2005

8Transportation conformity in the Truckee Meadows The Truckee Meadows has a current Conformity Determination that was approved in November 2001 as part ofthe Regional Transportation Commissions 2030 Regional Transportation Plan (see Appendix C forAir 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) ofthe Federal Register) since the Truckee Meadows did not have a motorvehicle "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 PM 10 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 PM 1

### o emissions. The Moderate PM 10 SIP that the District submitted in 

### 1991 based on a source apportionment study, a base-year PM 10 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 PM 10 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 ofthe 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 PM 10 

### 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 ofsandina 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 PM 10 SIP Washoe County - Serious PM 10 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 PM 10 SIP and comment on what may be necessary to update itto 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 fortrack-out control devices and clarification ofwhen 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 forWashoe County in 1972 so that is the official regulation that this newly adopted BACM version replaces . The District also includes a copy ofthe 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 ofWCDHD Reg . 040.030 in the newformat 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 ofthe public listing, proof of public hearing, and comments generated are contained in Appendix 

### E. The District has always operated underthe 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 PM 10 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 ofthe changes made to this version ofWCDHD 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 PM 10 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 . 

# I040.031 -- Street Sanding Operations

The District submitted with its Moderate PM 10 SIP a version ofWCDHD 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 PM 10 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 sand ing 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 of2000 and formed the Road Sanding and Sweeping Working Group to discuss what alternatives existed to ensure safe roads and reduce PM 10 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 ofthe public listing, proof of public hearing, and comments generated are contained in Appendix H.

Washoe County - Serious PM 10 SIP Revisions - August 2002 12· To determine what may be considered BACM the District reviewed what type of regulations other areas that have wintertime sanding events required : Colorado, Montana, Utah and Washington . (Appendix I contains a summary of each area's control strategies). One ofthe 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 ofWCDHD Reg . 040.031 Street Sanding Operations: Ji>- Tightens the durability and reduces the amount offines 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 gofrom 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, butjust 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 howthey 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 offines 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 PM 10SIP Revisions - August 2002 13[0.66 *(1-(1-(50/100))"0.8))]

# x 100

# = 28% The wintertime exceedance day dustfraction 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 smallerthan the 100-mesh sieve the PM10 emission reduction would be greaterthan 28 percent. However, without further studies on the benefits ofthe 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 thatwill 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 dustfraction 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. 

# I040.032 - Street Sweeping Operations

This is a new control strategy thatthe 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 ofthe 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 PM 10 SIP Revisions - August 2002 14and 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 technolog ies, and up to date with reporting requirements. This is a newWCDHD regulation (see Appendix L) and the PublicWorkshop 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 ofthe 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 Districtwas successful in applying for and securing over4 million dollars in federal Congestion Mitigation and Air Quality (CMAQ)-funds for the agencies to purchase certified street sweepers. Most ofthose agencies plan to purchase the sweepers this nextfiscal year. A few ofthe 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 quickerthe material can be cleaned up the betterthe PM10 reduction benefit. For routine sweeping the U.S. EPA recommended emission reduction cred it 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 1999when they were adopting their regulations. That analysis determined that credit applied for PM 10 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 reduc tion credit of 34% for routine sweeping; however, the District will be Washoe County - Serious PM 10 SIP Revisions - August 2002 

### 15tracking 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 yearfrom 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 ofWCDHD Reg . 040.051 recently adopted and copies ofthe regulations as submitted for the Moderate PM10 SIP . The District, when revising the regulations forthe 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 PublicWorkshop forWCDHD 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 ofthe public listing, proof of public hearing, and comments generated are contained in Appendix N. · WCDHD Reg. 040.05 1 requires: )- All wood stoves sold to be certified to the latest EPA emission standards; )- Uncertified existing devices must be r emoved upon change of ownership;
Washoe County - Serious PM 1 0SIP 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 compl iance 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 ofWCDHD 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 ofthe 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 PM 10 Inventory. One ofthe 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 itwas first implemented and continues to use it. Based on data from 5 wood use surveys conducted over the last ten years , on average, 80% ofthe 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 PM 10 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) ofthe 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 ofthe Moderate attainment date because Section 188( d)(2) ofthe CAAA states one could only request an extension ifthe 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) yearaverage 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 Part50, Appendix K, paragraph 2 .3 , Data Requirements, it notes that "More than 3 years may be considered... " Ifthe 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 thatthe 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 nephalometerworking . In January of 1999 that datalogger was not part of the District's official network yet. But it was collecting data forthe 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 AppendixA for monitoring network information) . The District also operates an Andersen Hi-Volume samplerthat is a reference method for PM10 at that site. See Appendix P for Monthly Summary Sheets forthe 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 PM 10 SIP Revisions - August 2002 18for 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 61hat any site in 1999 was 116 μg/m3 on September 9th at the Galletti site. The next highestAndersen 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 yearthat 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 forthe maximum 24-hour average PM10 concentration. Based on contributions estimated in the 1999 PM 10 Emissions Inventory modeling ofthe 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 ofthe 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 ofthe exceedance there were low wind speeds, which indicates that windblown dustwas not a significant contributorto 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 thatforthis 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 PM 10 SIP Revisions - August 2002 19TABLE4 

### 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 IndustrialNeh 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 forthe 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 thatwith 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 PM1 o SIP Revisions - August 2002 20