Protecting the air we share

ENVIRONMENTAL t’L’-~i vb~PROTEC~ON 4701 W.CLARK RussellCOUNTY Road Suite• DEPARTMENT 200 • Las Vegas. OFNVAIR89118-2231 QUALITY

(702) 455-5942 • Fax (702) 383-9994

Lewis Wallenmeyer Director

November 5, 2014 Nevada Environmental Protection

- - 0V172014 Dr. Colleen Cripps, Administrator

Nevada Division of Environmental 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Regulations into, and Request for Deletion of Repealed Sections 29, 30, 52, and 60 from,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

Dear 9j~-~Ipps:

The Clark County Board of County Commissioners recently adopted revisions to Sections 26 and 92 of the

Clark County Air Quality Regulations (AQRs) and repealed Sections 29, 30, 52, and 60. DAQ proposes in

corporation of the 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the four repealed ones.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

sistent with the requirements of 40 CFR § 51.102 and Appendix V of 40 CFR 51.

The Board’s rulemaking actions relative to the Nevada SIP consisted of the following:

• Adoption of revisions to Section 26, “Emission of Visible Air Contaminants.”

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

• Repeal of Section 29, “Sulfur Contents of Fuel Oil.”

• Repeal of Section 30, “Incinerators.”

• Repeal of Section 52, “ Gasoline Dispensing Facilities.”

• Repeal of Section 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 Manager
Dr. Colleen Cripps

11/05/2014

Page 2 of 2

The revision to Section 26 was designed to remove unapprovable subsections 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 allow the dust stabiliza

tion standard to be met without automatically paving such areas where it was either unsafe or

counterproductive to do so. The revisions to 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 Sections 29, 30, 52, and 60 were repealed because they have been

superseded by source-specific federal New Source Performance Standards (NSPS) or National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 Hazardous Air 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.

Pursuant to 40 CFR § 51.103, the revised rules are being submitted with the intent that the Neva

da Division of Environmental Protection (NDEP) forward the package to EPA’s Region 9 office

for incorporation into the Nevada SIP. EPA was made aware of this pending submittal during the

March 2014 cooperative effort to complete a 4-year SIP Management Plan for Nevada. Chapter

2 of the submittal documents the repeal of the four AQRs listed, which Clark County requests be

deleted from the Nevada SIP.

Three printed and six electronic copies of the rule package are enclosed. We request that you

forward two printed and five electronic copies to EPA’s Region 9 office. If you 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