# WASHOE COUNTYHEALTHDISTRICT AIR QUALITYMANAGEMENTDIVISION

June 21, 2012

Ms. Colleen Cripps, Ph.D. Administrator Division ofEnvironmental Protection 901 S. Stewart St., Suite 4001 Carson City NV 89701-5249
Dear Ms. Cripps: PubHcHealth Prevent. Promote. Protect.

The Washoe CountyHealthDistrict

- Air Quality Management Division (WCHD-AQMD) is in the process ofsubmitting a revision to the Washoe County portion ofNevada'sPM2.5 Infrastructure State Implementation Plan (I-SIP). This revision will include formal submittalof the following five existing Washoe CountyDistrict Board ofHealth Regulations Governing Air Quality Management:

• 030.023 • 030.218 • 030.230 • 030.235 • 030.970 Evaluation ofRegistration Application DemonstrationofCompliance Record Keeping Requirements for Source Sampling and Testing Part 70 Permit Monitoring and Compliance
In orderto expedite the approval process and in accordance with 40 CFR 51, Appendix V.2.3, the WCHD-AQMD requests that theNevada DivisionofEnvironmentalProtectionrequest the U.S. EnvironmentalProtection Agency (EPA) to initiate parallel processing oftherevision to the Washoe Countyportion ofthe Nevada's PM2.5 Infi'astructure State ImplementationPlan (attached).
The 30-daypublic comment period for the revision opened onMay25,2012 with the public hearing scheduled for June 28, 2012. Submittal ofthis revision to NDEP will be no laterthan July 31, 2012.
Ifyou have any questions or comments, feel free to contact me orMr. Daniel Inouye ofmy 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 COUNTYISANEQUALOPPORTUNITY EMPLQYERlllRINGEl\IPLOThIENfELlGIBLEAPPLICANfS Printedon Rffyded Paper030.023

030.218

030.230

030.235 EVALUATION OF REGISTRATION APPLICATION When an Authority to Constructapplication is received bythe Control Officer, he shall evaluate itto determine if all necessary information on the source processes has been included. When all the required information has been received, the Control Officerwill reviewthe proposal using standard engineering practices and methods, decide which local, state or federal regulations apply to the source, determine by approved modeling orother methods ifthe proposed control technologywill 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 ofthe deficient items in writing and state what additions may be made to bring the project into compliance with regulatory requirements. In no case maythe review ofthe projecttake 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 monitoroutputs, plant operating hours, equipment engineering and design specifications or chemical product consumption. Requested data must be provided in atimely manner, as specified by the Control Officer. Failure to provide this data as requested by the Control Officer constitutes aviolation of the conditions of the Permit to Operate, and the affected source would be subject to acitation underthese regulations, suspension oftheir Permitto 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 forwhich 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 oranyother 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 stacktesting, or othertypes ofsource 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 othertypes of pollutant impact analysis, including but not limited to, epidemiological testing of persons who maybe affected bythe operations ofthe source, risk assessment detenminations, source or receptor modeling and off-site ambient pollutant level monitoring. Completion oftesting may be required priorto the issuance or continuance of apermit to operate. The Control Officer may require that all costs of any testing required underthis section be borne bythe operatororsource 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 astatement of compliance signed by aresponsible 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 ofeach term orcondition ofoperation that is the basis forcertification. 2. The compliance status of the facility with respect to each term or condition of operation and a statementthatthe operatorwill continue to complywith such requirements. 3. Whetherthe compliance with each term orcondition ofoperation was continuous or intermittent. 4. The method(s) used for determining the compliance status of the source including adescription 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) ofthese 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 atimely 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 ofany dates or milestones that were notorare not expected to be met, why theywere not metand anycorrective actions to betaken as aresult. 7. Any otherspecific information needed to determine compliance as required bythe 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 pursuantto sections 114(a) and 504(b) ofthe 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 ofthe Part70 permit.