NAICSClark County (DAQ) is proposing to issue 13 general permits for the Gasoline Dispensing Facilities (GDF) source class, as listed in Table 1 below. Source classes are composed of facilities that are similar in nature, have substantially similar emissions, and would be subject to the same or substantially similar requirements governing operations, controls, emissions, monitoring, reporting, or recordkeeping. As a GDF, evaluate the maximum throughput of gasoline products to identify the category of permit needed, then see the requirements below that must be met to be approved for a general permit.
For context, Clark County defines a GDF as a minor source of air emissions otherwise subject to the permit requirements of Clark County Air Quality Regulations Section 12.1 and/or Section 102. The proposal states a GDF may instead obtain authority to operate under a general permit pursuant to Section 12.11. The Control Officer has made a preliminary determination that the proposed general permits for the following source categories comply with all Clark County Air Quality Regulations, Nevada Revised Statutes Chapter 445B requirements, and the Clean Air Act (42 USC § 7401, et seq.), and should be issued.
Table 1. Gasoline Dispensing Facilities (GDF) Permit Category Table
| Attainment Status/Control Technology | Permit Category* | Maximum Throughput (gal/yr) | VOC PTE (tons/year) | Billing Category |
| Attainment Area: None | AA-Category 0 | 1,199,999 | 7.8 | Baseline |
| Attainment Area: Phase I | AA-Category I-A
AA-Category I-B | 3,331,000
6,498,000 | 9.99
19.49 | Baseline
Significant |
| Attainment Area: Phase I & II | AA-Category II-A
AA-Category II-B | 4,755,000
11,900,000 | 9.99
24.99 | Baseline
Significant |
| Nonattainment Area: Phase I | NAA-Category I-A
NAA-Category II-B | 3,331,000
6,498,000 | 9.99
19.49 | Baseline
Significant |
| Nonattainment Area: Phase I & II | NAA-Category II-A
NAA-Category II-B | 4,755,000
11,900,000 | 9.99
24.99 | Baseline
Significant |
| Nonattainment Area: Phase I-EVR | NAA-Category I-EVR-A
NAA-Category I-EVR-B | 3,385,000
6,608,000 | 9.99
19.49 | Baseline
Significant |
| Nonattainment Area: Phase I-EVR & Phase II | NAA-Category II-EVR-A
NAA-Category II-EVR-B | 4,997,000
12,495,000 | 9.99
24.99 | Baseline
Significant |
| *GDFs with less than 690,000 gallons per year gasoline product throughput with VOC PTE of less than 4.49 tons per year (tpy) in ozone attainment areas do not need to obtain a permit in the General Permit Category. GDFs with less than 119,000 gallons per year gasoline product throughput with VOC PTE of less than 1.40 tpy in Moderate and Serious Ozone Nonattainment areas need to register with DAQ on the official registration form available on its website. |
Table 2. General Permit Category Requirements
| Category* | Requirements to be Eligible for the General Permit |
| NAICS Code | Emission Units | Control |
| AA-Category 0 | NACIS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | None |
| AA-Category I-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units. | Gasoline storage tank(s) is (are) equipped with Phase I vapor recovery systems and not required to be equipped with Phase II controls. |
| AA Category II-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | Gasoline storage tank(s) is (are) equipped with both Phase I and Phase II vapor recovery control systems |
| NAA-Category I-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | Gasoline storage tank(s) is (are) equipped with Phase I vapor recovery control systems and not required to be equipped with Phase I-EVR and Phase II controls |
| NAA-Category II-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | Gasoline storage tank(s) is (are) equipped with both Phase I and Phase II vapor recovery control systems and not required to be equipped with Phase I-EVR controls |
| NAA-Category I-EVR-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | Gasoline storage tank(s) are equipped with Phase I-EVR control systems and not required to be equipped with Phase II controls |
| NAA-Category II-EVR-A or B | NAICS code 457110 “Gasoline Station” with Convenience Stores: or NAICS code 457120 “Other Gasoline Stations” | Only gasoline tanks, dispensers, waste collection systems and exempt or insignificant units | Gasoline storage tank(s) is (are) equipped with both Phase I-EVR and Phase II vapor recovery control systems |
| **Each category is defined by the attainment area status, throughput limits for gasoline products, and PTE as described in Table 1. |
NOTICE IS FURTHER GIVEN that anyone may submit written comments on the proposed general permits and any relevant documents to DAQ during a 30-day public comment period that starts Tuesday, January 7, 2025, and ends Wednesday, February 5, 2025. DAQ must receive any written comments at its offices at 4701 W. Russell Road, Suite 200, Las Vegas, Nevada 89118 by Wednesday, February 5, 2025, at 5:30 PM. Any person may request a public hearing during this period by filing a written petition with the Control Officer containing the petitioner’s name, address, daytime telephone number, email address, and reason for requesting a hearing. Comments may be submitted electronically to [email protected]. The Control Officer shall consider all written comments, all oral comments if a public hearing is held, and all other documents on the administrative record before taking final action on the proposed general permits.
You can view the draft regulation or leave comments on DAQ’s website here. Public comment started Tuesday, January 7, 2025, and ends Wednesday, February 5, 2025.
If you would like to discuss the new GDF General Permit requirements impacting these sectors and how they may impact your facility, please email Matt Tarnoff in Trinity’s
