Protectingthe airwe share

ENVIRON t’L’-~ivb~ CLARKCOUNTY • DEPARTMENTOFAIRQUALITY

MENTAL PROTEC~ON 4701 W. Russell Road Suite200 • LasVegas. NV89118-2231 (702)455-5942 • Fax(702)383-9994 LewisWallenmeyerDirector November 5, 2014 Nevada Environmental Protection

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## 0V172014 Dr. Colleen Cripps, Administrator Nevada Division ofEnvironmental Protection BAP~ QP 901 South Stewart Street, Suite 4001 Carson City, Nevada 89701-5249 Re: Request for Incorporation of Revisions to Sections 26 and 92 of the Clark County Air Quality Regulations into, and Request for Deletion of Repealed Sections 29, 30, 52, and 60 from, the Nevada State Implementation Plan Dear9j~-~Ipps: The Clark County Board ofCounty Commissioners recently adopted revisions to Sections 26 and 92 ofthe Clark County Air Quality Regulations (AQRs) and repealed Sections 29, 30, 52, and 60. DAQ proposes in corporation ofthe two revised regulations into the Nevada State Implementation Plan (SIP) and deletion of the four repealed ones. Both actions constitute a SIP revision. The Board’s actions were conducted con sistentwith the requirements of40 CFR

## § 51.102 and Appendix V of40 CFR 51. The Board’s rulemaking actions relative to the Nevada SIP consisted ofthe following:

• Adoption ofrevisions to Section 26, “Emission ofVisible Air Contaminants.”

• Adoption ofrevisions to Section 92,”Fugitive Dust from Unpaved Parking Lots and Storage Areas.”

• Repeal ofSection 29, “SulfurContents ofFuel Oil.”

• Repeal ofSection 30, “Incinerators.”

• Repeal ofSection 52, “ Gasoline Dispensing Facilities.”

• Repeal ofSection 60, “Evaporation and Leakage.”

BOARD OF COUNTY COMMISSIONERS Steve Sisolak, Chair• Larry Brown, Vice-Chairman Susan Brager Tom Collins • Chris Giunchigliani

Mary Beth Scow • Lawrence Weekly Don Burnette, County ManagerDr. Colleen Cripps

11/05/2014 Page 2 of2 The revision to Section 26 was designedto remove unapprovablesubsections related to up setloreakdown situations and revise the visible emission evaluation procedures to conform to those specified in the federal Method 9. Section 92 was revised twice to allowthe dust stabiliza tion standard to be metwithout automatically paving such areas where it was eitherunsafe or counterproductive to do so. The revisionsto Section 92 did not relax or revise the stabilization standards defined in the rule. Sections 29, 

### 30, 52, and 60 were repealed because they have been superseded by source-specific federal New Source Performance Standards (NSPS) or National Emission Standards for HazardousAir Pollutants ~NESh’APs), and in some cases conflicted with the NSPS or NESHAPs. As you know, the U.S. Environmental Protection Agency (EPA) Region 9 office has delegated NSPS and NESHAPs authority to Clark County. Pursuantto 40 CFR

## § 51.103, the revised rules are being submitted with the intent thatthe Neva da Division ofEnvironmental Protection (NDEP) forward the package to EPA’s Region 9 office for incorporation into the Nevada SIP. EPAwas made aware ofthis pending submittal during the March 2014 cooperative effort to complete a4-year SIP Management Plan forNevada. Chapter 2 ofthe submittal documents the repeal ofthe fourAQRs listed, which Clark County requests be deleted from the Nevada SIP. Three printed and six electronic copies ofthe rule package are enclosed. We request thatyou forward two printed and five electronic copies to EPA’s Region 9 office. Ifyou have questions or need additional information concerning this submittal, please contact Russell Roberts at (702) 455-1611. Sincere y, Lewis Wallenrneyer, Director Enclosure: AQR Sections 26, 92, 29, 30, 52, and 60 Administrative SIP (3 hard copies) cc: Deborah Jordan, Air Division Director, EPA Region 9 Amy Zimpfer, Air Division Associate Director, EPA Region 9 Gerardo Rios, Permits Chief, EPA Region 9 Laura Yannayon, EPA Region 9 Rory Mays, EPA Region 9 Adele Malone, NDEP