WASHOE COUNTY HEALTH DISTRICT 

AIR QUALITY MANAGEMENT DIVISION 

June 21, 2012 

Ms. Colleen Cripps, Ph.D. 

Administrator 

Division of Environmental Protection 

901 S. Stewart St., Suite 4001 

Carson City NV 89701-5249 

Dear Ms. Cripps: 

PubHcHealth 

Prevent. Promote. Protect. 

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

the process of submitting a revision to the Washoe County portion of Nevada's PM2.5 

Infrastructure State Implementation Plan (I-SIP). This revision will include formal submittal of 

the following five existing Washoe County District Board of Health Regulations Governing Air 

Quality Management: 

• 030.023 

• 030.218 

• 030.230 

• 030.235 

• 030.970 

Evaluation of Registration Application 

Demonstration of Compliance 

Record Keeping 

Requirements for Source Sampling and Testing 

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 WCHD-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 of the Nevada's PM2.5 Infi'astructure State Implementation Plan 

(attached). 

The 30-day public comment period for the revision opened on May 25,2012 with the public 

hearing scheduled for June 28, 2012. Submittal of this 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 staff 

at (775) 784-7200. 

Sincerely, 

])~.:J c:J~ ~'\ Kevin Dick 

Division Director 

cc: Daniel Inouye, WCHD-AQMD 

Attachments 

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

www.washoecounty.us/health WASHOE COUNTYISAN EQUAL OPPORTUNITY EMPLQYERlllRING El\IPLOThIENf ELlGIBLEAPPLICANfS 

Printed on Rffyded Paper 
030.023 

030.218 

030.230 

030.235 

EVALUATION OF REGISTRATION APPLICATION 

When an Authority to Construct application is received by the Control Officer, he shall evaluate it to 

determine if all necessary information on the source processes has been included. When all the 

required information has been received, the Control Officer will review the proposal using standard 

engineering practices and methods, decide which local, state or federal regulations apply to the 

source, determine by approved modeling or other methods if the proposed control technology will 

meet regulatory requirements, and determine what, if any, pre-construction monitoring or other 

testing will be required before the authority to construct is issued. If it is detenmined 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. 

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 product 

consumption. Requested data must be provided in a timely manner, as specified by the Control 

Officer. 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. 

RECORD KEEPING (Amended 9/23/92) 

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

conceming 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. 

REQUIREMENTS FOR SOURCE SAMPLING AND TESTING 

To detenmine the exact quantity and effect of emissions produced by stationary sources, the 

Control 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 after 

consultation with the permittee, the Control Officer may require that testing be reviewed and 

overseen by an independent third party of the Control Officer's selection to insure the quality and 

accuracy of the test results. The Control Officer may also require other types of pollutant impact 

analysis, including but not limited to, epidemiological testing of persons who may be affected by the 

operations of the source, risk assessment detenminations, 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. 
030.970 PART 70 PERMIT MONITORING AND COMPLIANCE (Adopted 10/20/93, Revised 10/25/95) 

A. Compliance Statements 

Sources subject to Part 70 permits shall submit a statement of compliance signed by a responsible official. 

The annual compliance statement shall be due each year on the anniversary of the date of issuance (or 

more frequently if required in an applicable requirement). The compliance statement shall address each 

term or condition of operation on an item by item basis. The compliance statement shall contain the 

following: 

1. Identification of each term or condition of operation that is the basis for certification. 

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 condition 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, 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. 

a. 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.