Ad ininistrator

Division ofEnviroiiniental Protection

901 S. Stewart St., Suite 4001

Carson City NV 89701-5249Dear Ms. cripps:

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

the process ofsubmitting a revision to the Washoe County portion of Nevada’s PM2.5

Infrastructure State Implementation Plan (ISIP). This revision will include formal submittal of

the following five existing Washoe County District Board ofHealth Regulations Governing Air

Quality Management:

• 030.023 Evaluation ofRegistration Application

• 030.218 Demonstration ofCompliance

• 030,230 Record Keeping

• 030.235 Requirements for Source Sampling and Testing

• 030.970 Part 70 Permit Monitoring and Compliance

In order to expedite the approval process and In accordance with 40 CFR 51, Appendix V.2.3,

the WCI-ID-AQMD requests that the Nevada Division of Environmental Protection request the

U.S. Environmental Protection Agency (EPA) to initiate parallel processing ofthe revision to the

Washoe County portion ofthe Nevada’s PM2,5 Infrastructure State Implementation Plan

(attached).

‘i’he 30-day public comment period for the revision opened on May 25, 2012 with the public

hearing scheduled for Juno 28, 2012. Submittal ofthis revision to NDEP will be no later than

July 31, 2012.

If you have any questions or comments, feel free to contact me or Mr. Daniel Inouye of my staffat (775) 784-7200.

Sincerely,

7344,f (‘

Kevin Dick

Division Director

cc: Daniel Tuouye, WCHD-AQMD

Attachments

P.O. BOX 11130 Reno, NV 89520-0027 • (775) 784-7200 ‘ FAX (775) 784-7225

www.washoecouaty.us/health

WASHO COUNTY mAN EQ1)AL oP’ORrvNrry EMPLOVERUIRING E P1OYMP1r ELIGIULE APPLICANrS

PtItiedon Recyclcd Popor
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y requirements, and determine what 1 if any, pre

construction monitoring or other

testing will be required before the authorty to construct is issued. If it is determined that the

equipment proposed in the Authority to Construct application is insufficient to meet regulatory

requirements, the Control Officer will notify the applicant of the deficient items In writing and state

what additions may be made to bring the project into compliance with regulatory requirements. In

no case may the review of the project take more than 180 days to complete.

030.218 DEMONSTRATION OF COMPLIANCE

The Control Officer may require the operator of a source to provide any applicable data to

demonstrate compliance with the conditions of the Permit to Operate. Such data submission

requirements may Include, but would not be limited to, graphs, charts or other records of items

such as plant operational temperatures, plant production levels, continuous stack monitor outputs,

plant operating hours, equipment engineering and design specifications or chemical productconsumption. Requested data must be provided In a timely manner, as specified by the ControlOfficer. Failure to provide this data as requested by the Control Officer constitutes a violation of

the conditions of the Permit to Operate, and the affected source would be subject to a citation

under these regulations, suspension of their Permit to Operate or both.

030.230 RECORD KEEPING (Amended 9/23/92)

The Control Officer may require any holder of a Permit to Operate to keep adequate records

concerning contaminant emissions for any equipment or process for which the permit was issued.

All permittees operating add-on emissions control equipment will maintain records sufficient to

legally demonstrate that the equipment has operated in compliance with all applicable Federal,State and District regulations. The permittee shall also record any times or occasions when the

emissions control equipment is not in operation due to equipment failure, maintenance or any other

reason.

030.235 REQUIREMENTS FOR SOURCE SAMPLING AND TESTING

To determine the exact quantity and effect of emissions produced by stationary sources, theControl Officer may require source stack testing, or other types of source testing including, but not

limited to, mass balance types of analysis, be made by the operator. Alternatively, and afterconsultation with the permittee, the Control Officer may require that testing be reviewed and

overseen by an independent third party of the Control Offlces selection to insure the quality and

accuracy of the test results. The Control Officer may also require other types of pollutant impactanalysis, including but not limited to, epidemlologicai testing of persons who may be affected by the

operations of the source, risk assessment determinations, source or receptor modeling and off-site

ambient pollutant level monitoring. Completion of testing may be required prior to the Issuance or

continuance of a permit to operate. The Control Officer may require that all costs of any testing

required under this section be borne by the operator or source owner,
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following:

1. ldenflcation of each term or condiUon of operation that is the basis for certificaion.2. The compliance status of the facility with respect to each term or condition of operation and a

statement that the operator will continue to comply with such requirements.

3. Whether the compliance with each term or condiUon of operation was continuous or intermittent.

4. The method(s) used for determining the compliance status of the source Including a descriptIon of

monitoring, record keeping and reporting requirements, and test methods.

5. For any term or condition of operation for which the source is not in compliance, the source must

submit a compliance schedule and a narrative description of how the source will achieve

compliance with such requirements as described in 030.970 (8) of these regulations.

6. For any source for which the Control Officer has established requirements for progress reports on

compliance schedules, the source must provide these progress reports In a timely manner and

address dates milestones and other activities that have been specified by the Control Officer. The

progress report shall also include the dates on which any milestones were achieved and an

explanation of any dates or milestones that were not or are not expected to be met 3 why they were

not met and any corrective actions to be taken as a result.

7. Any other specific information needed to determine compliance as required by the Control Officer.

8.

A certification of the truth, accuracy and completeness of the compliance statement by a

responsible official.

9. Any additional requirements as may be specified pursuant to sections 114(a) and 504(b) of the Act.

All Statements of compliance must be made in writing to both the EPA Administrator as well as to the

Control Officer. Failure to submit a statement of compliance in a timely manner may result in citation,

penalties, suspension or revocation of the Part 70 permit.