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CLARK COUNTY AIR QUALITY FORUM

CLARK COUNTY AIR QUALITY FORUM. SECTION 95 “Fugitive Dust From Stationary Sources”. Rodney Langston, Clark County DAQEM July 11, 2006. Regulation Improvement Program (RIP). County initiative to improve the Clark County Air Quality Regulations

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CLARK COUNTY AIR QUALITY FORUM

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  1. CLARK COUNTY AIR QUALITY FORUM SECTION 95 “Fugitive Dust From Stationary Sources” Rodney Langston, Clark County DAQEM July 11, 2006

  2. Regulation Improvement Program(RIP) • County initiative to improve the Clark County Air Quality Regulations • Current focus is Section 12, “Preconstruction Review of New or Modified Sources” • “Section 95” is a placeholder

  3. Fugitive Dust from Stationary Sources • Section 12 emission unit requirements not written well: • Applicable “emission units” subject to controls detailed in the Section 00 definitions – easy to overlook • Fugitive dust emissions units not listed in sufficient detail

  4. Historical Application ofSection 12 to Fugitive Sources • BACT controls applied to all areas of the county • BACT emissions threshold trigger is two tons • Clark County’s historical interpretation and documentation is detailed in the EPA Technical Support Document (TSD)

  5. SIP Requirements for Hydrographic Area 212 • SIP indicates BACT level controls on stationary sources of 2 tons or greater • SIP does not quantify BACT emissions reductions for use in attainment demonstration • SIP uses unquantified BACT emissions controls to justify no growth of stationary source category above de minimis level

  6. Informal Apex Agreement –Avoiding Redesignation • Clark County made Sections 90-93 applicable to the Apex Valley • Apex permit holders agreed to add fugitive dust controls to permits upon modification • Most permit holders followed through on agreement

  7. Issues Under Review • Determination of detailed Hydrographic Area 212 stationary source requirements under the PM-10 SIP: • Clark County SIP commitments • Commitments vs. requirements • BACT emissions reductions not used in attainment demonstration • BACT emissions reductions used to justify no growth in stationary source categories

  8. Issues Under Review (continued) • EPA view on SIP enforceability: • Clark County DAQEM has developed considerable goodwill with EPA Region IX • Maintaining this goodwill is critical to future Clark County programs • EPA enforcement has not targeted Clark County or overfiled on Clark County permits since formation of DAQEM

  9. Issues Under Review (continued) • Improving readability and clarity of regulation • Stationary source requirements for attainment areas in Clark County • Modification of source emissions thresholds • Modification of emissions units

  10. Comments and Questions Rodney Langston Clark County Department of Air Quality and Environmental Management (702) 455-1661

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