DEOH Agenda Item No. 12 

June 28, 2012 

District Board of Health 

FROM: Kevin Dick, Director 

Air Quality Management Division 

SUBJECT: Public Hearing: Proposed approval and adoption of the revisions to the "Washoe 

County Portion of the Nevada Infrastructure State implementation Plan for the 

2006 PM2.5 National Ambient Air Quality Standard" 

Agenda Item: 12 

Staff Recommendation 

Approve and adopt revisions to the "Washoe County Portion of the Nevada Infrastructure State 

Implementation Plan for the 2006 PM2.5 National Ambient Air Quality Standard" 

Background 

The U.S. Environmental Protection Agency (EPA) establishes health based national ambient air 

quality standards (NAAQS) for six criteria pollutants including PM2.5. The Clean Air Act (CAA) 

directs states to address basic State Implementation Plan (SIP) requirements to implement, 

maintain, and enforce the NAAQS. Many of the CAA Section 110(a)(2) SIP elements relate to 

the general information and authorities that constitute the "infrastructure" of a state's air quality 

management program. States are required to submit an Infrastructure SIP (I-SIP) within three 

years after promulgation of a new or revised standard. 

In November 2009, the Washoe County Health District, Air Quality Management Division (AQM) 

submitted an I-SIP to the U.S. Environmental Protection Agency (EPA) to address these CAA 

Section 110(a)(2) SIP elements. EPA identified several portions of the I-SIP that did not fully 

address these elements. 

To fully address EPA's comments, the AQM is proposing to formally adopt five existing 

regulations and submit them to EPA as a revision to the Nevada PM2.5 I-SIP. This will provide 

documentation of the regulation adoption process which is required for the I-SIP approval by 

EPA. These five existing Washoe County District Board of Health Regulations Governing Air 

Quality Management are: 030.023 (Evaluation of Registration Application), 030.218 

(Demonstration of Compliance), 030.230 (Record Keeping), 030.235 (Requirements for Source 

Sampling and Testing), and 030.970.A (Part 70 Permit Monitoring and Compliance). 

This revision to the I-SIP was prepared in coordination with the Clark County Department of Air 

Quality, Nevada Division of Environmental Protection, and EPA Region IX. 

A notice of today's public hearing was published in the Reno Gazette-Journal on May 25, June 

6, and June 19, 2012. The I-SIP has been available for public inspection at the AQM D office 

since May 25,2012. 

P.O. BOX 11130 NV " .. FAX (775) 784-7225 

www.washoeconnty.ns/health WASHOE COUNTY IS AN EQUAL OPPORTUNITY EMPLOYER HilliNG EMPLOYMENT ELIGIBLE APPLICANTS 

Printed on Recycled Paper 
June 28,2012 

District Board of Health 

PM2.5 Infrastructure State Implementation Plan 

Page 2 of 5 

Recommended Motion 

Move to approve and adopt revIsions to the "Washoe County Portion of the Nevada 

Infrastructure State Implementation Plan for the 2006 PM2.5 National Ambient Air Quality 

Standard", and direct Staff to forward them to EPA as an amendment to the Washoe County 

portion of the Nevada PM2.5 State Implementation Plan. 

Alternatives 

The District Board of Health may: 

1. Elect not to adopt the revision to the I-SIP; or 

2. Continue this public hearing and direct Staff to research some portion of the I-SIP 

and report back to the Board at a future meeting. 
June 28,2012 

District Board of Health 

PM2.5 Infrastructure State Implementation Plan 

Page 3 of 5 

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 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. 

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 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. 

REQUIREMENTS FOR SOURCE SAMPLING AND TESTING 

To determine 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, 
June 28, 2012 

District Board of Health 

PM2.5 Infrastructure State Implementation Plan 

Page 4 of 5 

030.970 

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 

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. 

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. 

8. A certification of the truth, accuracy and completeness of the compliance 

statement by a responsible official. 
June 28,2012 

District Board of Health 

PM2.5 Infrastructure State Implementation Plan 

Page 5 of 5 

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.