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0 United States Environmental Protection Agency, Region IX Air Division Technical Support Document for the Washoe County District Board of Health Section 030.2 18, Demonstration

of Compliance Section 030.230, Record Keeping Section 030.235, Requirements
for Source Sampling and Testing Section 030,970A, Part 70 Permit Monitoring and Compliance Prepared by: Cynthia G. Allen Reviewed by: Andrew Steckel July 20120 Submitted Rules for Parallel Processing: Section 030.218, Demonstration

of Compliance Section 030.230, Record Keeping Section 030.23
5, Requirements
for Source Sampling and Testing Section 030.970A, Part 70 Permit Monitoring and Compliance Previous Rule Submittals There areno superseded submittals
of these rules uponwhich EPA has not acted. SIP-Approved Rules There areno SIP-Approved versions of these rules. Purpose of New Rules Section 110(a) of the Clean Air Act (CAA) requires states to submit regulations that control volatile organic compounds, oxides of nitrogen, particulate matter, and other air pollutants which harm human health and the environment. These rules were developed

as part of the local agency’s program
tocontrol these pollutants. Washoe County submitted these rules to support the infrastructure SIP requirements

of section

1 10(a)(2) of the CAA. The purposesof the newrules areasfollows: •Section 030.2 18, Demonstration

of Compliance, states that the Control Officer may require the operator of asourceto provide any applicable data to demonstrate compliance with the conditions
of the Permit to Operate. •Section 030.230, Record Keeping, states that the Control Officer may require anyholder of aPermit to Operate
to keep adequate records concerning contaminant emissions for any equipment

or processfor which the permit wasissued. •Section 030.235, Requirement For Source Sampling and Testing, requires the APCO to determine the exact quantity and effect of emissions produced by stationary sources.The APCO may require sourcestack testing, orother typesof source testing including, but not limited to, massbalance types of analysis, be made by the operator. •Section 030.970A, Part 70 Permit Monitoring and Compliance, requires sources subject to 40 CFR Part 70 permitting requirements

tosubmit anannual statement of compliance covering certain specified items. EPA Evaluation and Action Generally, prohibitory SIP rules must be enlbrceable (see section 110(a) of the CAA) and must not relax existing requirements (see sections 110(1) and 193). We have evaluated this SIP revision to determine whether

it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or anyother applicable requirement
of the Act (CAA 110(1)).

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C Overall, the new rules improve the SIP and are enforceable. Therefore, we propose
to determine that our approval of the submittal would sufficiently comply with sections 110(a), 110(1), 193 and other relevant CAA provisions. EPA Recommended Actions We recommend full approval of Washoe County Section 030.2 18, Section 030.230, Section 030.235, and Section 030.970A. References 1. Submitted Rules. 2. Requirements
for Preparation, Adoption, and Submittal of Implementation Plans, U.S. EPA, 40 CFR part 51. 3. Issues Relating
to VOC Regulation Cutpoints, Deficiencies, and Deviations, EPA (May 25, 1988) (The Bluebook). 4. Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region

9 (August 21, 2001) (The Little Bluebook). -3-0

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