ENVIRONMENTAL PROTECTION 

protecting the future for generations 

August 30,20 10 

Jared Blumenfeld, Regional Administrator 

OAR- 1, USEPA Region IX 

75 Hawthorne Street 

San Francisco, CA 94 105 

Dear Mr. Blurnenfeld: 

On behalf of Governor Gibbons, as his appointed designee, this letter transmits to the U.S. 

Environmental Protection Agency (EPA) a second supplement to the Clark County Carbon 

Monoxide Redesignation Request and Maintenance Plan (2008 Plan) that was submitted to EPA 

on September 18,2008. The first supplement was submitted on March 26,20 10. Five hard 

copies of the second supplement are enclosed. The Nevada Division of Environmental 

Protection requests that, taking this additional information into account, EPA finalize its 

proposed approval (75 FR 44734) of the 2008 Plan into the Nevada State Implementation Plan 

and redesignate the Las Vegas Valley nonattainment area to attainment status for the carbon 

monoxide National Ambient Air Quality Standards. 

The enclosed supplement provides the letter of commitment requested by EPA in its proposed 

approval of Clark County's 2008 Plan. The enclosed letter from the Nevada Department of 

Agriculture commits to implementing a contingency measure contained in the 2008 Plan, i.e., 

reinstating the previous wintertime Reid Vapor Pressure maximum for gasoline, if necessary. 

Documentation of the public participation process for the commitment is also enclosed. 

If you have any questions about this submittal, you may contact Robert Tekniepe of the Clark 

County Department of Air Quality and Environmental Management at (702) 455-4063. 

Sincerely, 

M' Colleen Cripps, Ph.D. 

Acting Administrator 

Enclosures 

cc WIO enclosures: Robin Reedy, Chief of Staff, Office of the Governor 

Leo Drozdoff, Acting Director, DCNR 

Greg Remer, Chief, Bureau of Air Quality Planning, NDEP 

Robert Tekniepe, Planning Office, Clark County DAQEM 

'bKarina O'Connor, Planning Office, EPA Region IX, AIR-2 

Jefferson Wehling, Air Attorneys (ORC-2), EPA Region IX 

Certified Mail No. 7009 341 0 0000 1454 1388 

90 1 S. Stewart Street, Suite 400 1 Carson City, Nevada 8970 1 p: 775.687.4670 f: 775.687.5856 www.ndep.nv.gov S+ 

prrnted an recycled poper 

----."- ---- -".- -.'-..--.--- 
August 20, 201 0 

DEPARTMENT OF AIR QUALIlY & ENVIRONMENTAL MANAGEMENT 

500 S Grand Central Parkway 1st Floor. Box 555210 . Lor Vegar, NV 89155-5210 

(702) 455-5942 . FOX (702) 383-9994 

Lewis Wollmmsyer Director . Tina tin rar krorlonl Dtreclor 

RECEIV~D 

Ms. Colleen Cripps, PhD, Acting Administrator 

Nevada Division of Environmental Protection 

901 South Steward Street, Suite 4001 

Carson City, Nevada 89701 -5249 

AUG 2.3 2010 

ENVlRONENTAL PROTECllON 

Re: Supplemental Data in Support of the Clark County Carbon Monoxide Redesignation 

Request and Maintenance Plan, September 2008 

Dear Ms. Cripps: 

On September 10, 2008 the Clark County Department of Air Quality and Environmental 

Management (DAQEM) submitted to the Nevada Division of Environmental Protection 

(NDEP) the Clark County Carbon Monoxide Redesignation Request and Maintenance Plan 

(Plan). On September 18, 2008 NDEP forwarded the Plan to the U.S. Environmental 

Protection Agency (EPA) and requested that EPA approve the Plan into the Nevada State 

Implementation Plan and redesignate the Las Vegas Valley nonattainment area to 

attainment status for the carbon monoxide National Ambient Air Quality Standards. 

On February 17, 201 0 - at the request of EPA - DAQEM provided evidence of adoption, 

appropriate public notice and attestation of stakeholder participation for the changes to the 

control measures contained in the Plan, i.e., suspension of Clark County Air Quality 

Regulation Section 54 (Cleaner Burning Gasoline), and amendment of Nevada 

Administrative Code 590.065 to change the Reid Vapor Pressure for wintertime fuels sold 

in Clark County from 9 to 13.5 pounds per square inch. 

Since that time, EPA has requested DAQEM provide a letter of commitment from the 

Nevada .Department of Agriculture to implement a contingcincy measure contained in the 

Plan, i.e., reverting back to the previous wintertime Reid Vapor Pressure maximum for 

gasoline. 

Enclosed are two copies of the letter of commitment from the Nevada Department of 

Agriculture, documentation of public notice requirements, and public comment report. 

Please forward one copy of enclosed documentation to EPA. 

If you have any questions regarding the aforementioned revision, please contact Robert 

Tekniepe, DAQEM, at your earliest convenience at (702) 455-4063. 

Sincerely, 

Lewis Wallenmeyer 

Director 

Enclosures 

BOARD OF COUNTY COMMISSIONCRS 

Roy Rdd Cho;rmnn . Susan Bmgn Mcr.Choimm 

Lorry Brow. Tom Collins, Chris Giunchiglioni, Stem Sisalok. Lowreme Weekly 

Virginia Volmfinc PE, Counb Manager 
JIM GIBBONS STATE OF NEVADA TONY LESPER ANCE 

Governor 

Sparks Otfice: 

21 50 Frazer Avenue 

Sparks NV 89431-5566 

(775) 688-1 166 

Fax (775) 688-2533 

Las Vegas Office: 

2300 McLeod Street 

Las Vegas NV 89104-4314 

(702) 668-4590 

Fax (702) 668-4567 

DEPARTMENT OF AGRICULTURE 

405 South 21' Street 

Sparks, Nevada 89431 

Telephone (775) 353-3600 Fax (775) 353-3661 

Website: http://www.agri.nv.gov 

Director 

Elko Office: 

4780 E. Idaho Street 

Elk0 NV 8980 1-4672 

(775) 738-8076 

Fax (775) 738-2639 

June 22,2010 

Lewis Wallenmeyer, Director 

Department of Air Quality and Environmental Management 

Clark County Government 

500 S. Grand Central Parkway 

Box 55521 0 

Las Vegas, NV 891 55-521 0 

Dear Sir: 

This letter constitutes a commitment by the Nevada Department of Agriculture to implement the following 

contingency plan contained in the Clark County Carbon Monoxide Redesignation Request and Maintenance 

Plan, September 2008. Section 175A(d) of the Clean Air Act requires that revisions to State Implementation 

Plans (SIP) for maintenance plans must contain contingency provisions to assure that any violation of 

National Ambient Air Quality (NAAQ) Standards will be promptly corrected. In compliance with that 

requirement, the contingency measure proposed for this SIP revision is as follows: 

Upon approval of an increase to the wintertime Reid Vapor Pressure (RVP) maximum for gasoline as 

described in Carbon Monoxide Redesignation Request and Maintenance Plan, September 2008, and in 

the event of a carbon monoxide violation of NAAQ Standards, the Bureau of Petroleum Technology of 

the Nevada Department of Agriculture will request that the Nevada Board of Agriculture revert to the 

previous wintertime RVP maximum for gasoline. 

If a violation of the carbon monoxide NAAQ Standards occurs, Clark County Department of Air 

Quality and Environmental Management will notify the Bureau of Petroleum Technology of the Nevada 

Department of Agriculture. As described in Nevada Revised Statute Chapter 233B, because a change to 

the Nevada Administrative Code (NAC) will be necessary, the Bureau will submit a draft file (amending 

NAC 590.065 to reflect the previous RVP maximum) to the Nevada Legislative Counsel Bureau (LCB). 

Petroleum Technology will then seek approval from the Nevada Board of Agriculture to take action. 

The Board of Agriculture meets quarterly (normally in March, June, September and December), so this 

request will be made at the first Board Meeting following notification, notwithstanding deadlines for 

submitting agenda items for the Board Meeting. 

- -- 

NEVADA BOARD OF AGRICULTURE 

Alan Perazzo. Chair: Dairy Dean Baker: Livestock Benny Romero: Livestock 

Ramona Morrison, Vice-Char: General Agricunure Grady Jones: Pest Control Boyd Spratling. DVM: Lwestock 

Martin Plaskett' General Farm~ng Jim Snyder : Row Crops Hank Vogler: Sheep 

Paul Anderson: Petroleum Paul Noe: Nursery 
As described in Nevada Revised Statute Chapter 233B, a workshop and hearing will be scheduled and 

held, to provide for public comment and discussion, following approval of the request by the Board of 

Agriculture. 

The comments will be presented to the Board at their next meeting for approval, and the final draft file 

sent back to LCB for processing, and placement on the agenda of the next meeting of the Legislative 

Commission. 

If there are any additional questions or comments, I can be reached at (775) 688-1 166 x231, or at 

wstriejewske~aari.state.nv.us. 

Respectfully submitted, 

Director 

Nevada Department of Agriculture 3 

-3 

NEVADA BOARD OF AGRICULTURE 

Alan Perazzo. Chair: Dairy Dean Baker: Livestock Benny Romero: Livestock 

Ramona Morrison, Vice-Chair: GeneralAgriculture Grady Jones: Pest Control Boyd Spratling, DVM: Livestock 

Martin Plaskett: General Farming Jim Snyder : Row Crops Hank Vogler: Sheep 

Paul Anderson: Petroleum Paul Noe: Nursery 
Nevada Department of Agriculture 

&lr. MIESP&~G D~dDo/l 

Home - About Us r Divisions BoardsJCommissions r FAQs SEARCH Site Map 

D4partrnerrt d AgdcuHura 

Estabrshed 111 1915 by Chapler 581. hlevada Revised Statutes 

d6hiCi . or Request a Public Hearlng - July 12, 2010 - August 11, 2010 - Notice of Intent to Sollcit Public Comment 

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Home r About Us r Divisions * BoarddComnissions * FMs SEARCH Site Map Contact Us 

July 12,2010 -August 11,2010 - Notice d Intent to Solicit Public Comment 

or Request a Public Hearing -Click hem ........................................................................................................................................... 

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NOTICE OF INTENT TO SOLICIT PUBLIC COMMENT OR REQUEST A 

PUBLIC HEARING 

From July 12, 201 0 until August 1 1, 2010, the Nevada Department of Agriculture is soliciting from all 

interested persons comment, or a request to hold a public hearing, regarding a contingency plan 

included in an update of the Clark County CO Maintenance Plan. In the case of violations to this 

updated plan, the contingency calls for a reversion to a gasoline standard codified previously in Nevada 

Administrative Code section 590.065. See subsection 2 below for the text of the Contingency Plan to be 

submitted to the EPA. 

I. The need for and the purpose of this notice. 

The Clark County Department of Air Quality and Environmental Management (DAQEM) has 

been working with the Environmental Protection Agency (EPA) on a revision to a Carbon 

Monoxide Maintenance Plan, as outlined in Section 175A of the Clean Air Act (CAA). The 

existing plan called for a maximum vapor pressure for gasoline of 9.0 pounds per square inch 

(psi) from October 1 through March 31. This maximum was codified in Nevada Administrative 

Code chapter 590. In the revision to the maintenance plan, Clark County DAQEM petitioned the 

Nevada Board of Agriculture to increase the vapor pressure maximum to 13.5 psi. This change 

was approved by the Board of Agriculture in December 2009, and approved by the Legislative 

Commission in January, 2010. Section 175A(d) of the CAA states that this plan revision must 

include contingency provisions in the event of violations to the new standard. 

As stated in Title 40 of the Code of Federal Regulations, $51.102, it is required to provide a 30 

day period for the public to submit written comment or for a request to be made to hold a public 

hearing on this issue. 

2. The following is the text of the proposed contingency plan: 

This letter constitutes a commitment by the Nevada Department of Agriculture to implement the following 

contingency plan contained in the Clark County Carbon Monoxide Redesignation Request and Maintenance Plan, 

September 2008. Section 175A(d) of the Clean Air Act requires that revisions to State Implementation Plans (SIP) 

for maintenance plans must contain contingency provisions to assure that any violation of National Ambient Air 

Quality (NAAQ) Standards will be promptly corrected. In compliance with that requirement, the contingency 

measure proposed for this SIP revision is as follows: 

Upon approval of an increase to the wintertime Reid Vapor Pressure (RVP) maximum for 

gasoline as described in Carbon Monoxide Redesignation Request and Maintenance Plan, 

September 2008, and in the event of a carbon monoxide violation of NAAQ Standards, the 

Bureau of Petroleum Technology of the Nevada Department of Agriculture will request that the 

Nevada Board of Agriculture revert to the previous wintertime RVP maximum for gasoline. 

If a violation of the carbon monoxide NAAQ Standards occurs, Clark County Department of Air 

Quality and Environmental Management will notify the Bureau of Petroleum Technology of the 

Nevada Department of Agriculture. As described in Nevada Revised Statute Chapter 233B, 

because a change to the Nevada Administrative Code (NAC) will be necessary, the Bureau will 

submit a draft file (amending NAC 590.065 to reflect the previous RVP maximum) to the Nevada 

Legislative Counsel Bureau (LCB). Petroleum Technology will then seek approval from the 

Nevada Board of Agriculture to take action. 
The Board of Agriculture meets quarterly (normally in March, June, September and December), / 

so this request will be made at the first Board Meeting following notification, notwithstanding 

deadlines for submitting agenda items for the Board Meeting. 

As described in Nevada Revised Statute Chapter 233B, a workshop and hearing will be scheduled 

and held, to provide for public comment and discussion, following approval of the request by the 

Board of Agriculture. 

The comments will be presented to the Board at their next meeting for approval, and the final 

draft file sent back to LCB for processing, and placement on the agenda of the next meeting of 

the Legislative Commission. 

3. If the action is required pursuant to federal law, a citation and description of the federal law. 

As stated in subsection 1 above, Section 175A(d) of the Clean Air Act requires a revision to a 

maintenance plan to include contingency provisions. Likewise, Title 40 of the Code of Federal 

Regulations, 551.102 requires a 30 day period for the public to submit written comment or for a 

request to be made to hold a public hearing on this issue. 

Persons may address their comments, or request that a public hearing be held, by submission in 

written form, to . 

Nevada Department of Agriculture 

2150 Frazer Avenue 

Sparks, NV 89431 

ATTN: William Striejewske 

wstriejewske@agri.state.nv.us 

Written comments or requests for public hearing must be received by the Nevada Department of 

Agriculture on or before the close of business August 11, 201 0. 

If there is no request for a public hearing, the Nevada Department of Agriculture will announce that fact 

on the department website, at htt~:llaqri.nv.qovl, following the deadline date given above. Information 

about the public comment period and whether a hearing will be held or not will also be available by 

calling the Nevada Department of Agriculture Weights & Measures office at (775) 688-1 166. 

A copy of this notice and the proposed Contingency Plan will be on file at the State Library, 100 Stewart 

Street, Carson City, Nevada, for inspection by members of the public during business hours. This 

notice can also be viewed on the Department of Agriculture website, htt~:Naqri.nv.qov/, as well as at the 

Department of Agriculture offices in Sparks, Elko, and Las Vegas between the hours of 8:00 a.m. and 

500 p.m. Monday through Friday. 

Nevada Department of Agriculture Nevada Department of Agriculture 

405 South 2 1" Street 2300 McLeod 

Sparks, NV 8943 1 Las Vegas, NV 89 104 

Nevada Department of Agriculture Nevada Department of Apculture 

4780 E. Idaho Street 2 150 Frazer Street 

Elko, NV 8980 1 Sparks, NV 8943 1 
inspection and copying by members of the publicduring business hours. Copies of this notice and the 

proposed regulation will also be mailed to members of the public upon request. A reasonable fee may 

be charged for copies if it is deemed necessary. 

- - - - - - - 

County Library 

553 South Maine Street 

Fallon, NV 89406 

- -- 

Las Vegas - Clark County Library 

833 Las Vegas Boulevard North 

Las Vegas, NV 89 10 1 

720 Court Street 

Elko, NV 89801 

Esmeralda County Library 

P.O. Box 430 

Goldfield, NV 890 13-0430 

Eureka Branch Library 

P.O. Box 293 

1 0 190 Monroe Street 

Eureka, NV 893 16-0293 

Humboldt County Library 

85 East 5Ih Street 

Winnemucca, NV 89445 

Lincoln County Library 

P.O. Box 330 Lyon County Library 

20 Nevin Way 

Yerington, NV 89447 

- 

Mineral County Library 

P.O. Box 1390 

(First & A Street) 

Hawthorne, NV 89415-1390 

P.O. Box 430 

(Forth & Crook Street) 

Goldfield, NV 8901 3-0430 

Tonopah Public Library 

P.O. Box 449 

17 1 Central Street 

Tonopah, NV 89049-0449 

- -- - 

Pershing County Library 

P.O. Box 78 1 

1 125 Central Avenue 

Lovelock, NV 894 19-078 1 

Storey County Library 

P.O. Box 14 

95 South R Street 

Virginia City, NV 89440-0014 

Washoe County Library 

P.O. Box 215 1 

301 South Center 

Reno, NV 89505-2 151 

White Pine County Library 

950 Carnpton Street 

Ely, NV 89301 

Lander County Library 

625 South Broad Street 

Battle Mountain, NV 89820 

Carson City Library 

900 N. Roop Street 

Carson City, NV 89701 

Douglas County Library 

P.O. Box 337 

1625 Library Lane 

Minden, NV 89423-0337 

State Library 

100 North Stewart Street 

Carson City, NV 89701 -4285 

Smith Valley Library 

22 Day Lane 

Smith, NV 89430 

Las Vegas Review Journal 

Ed Vogel/Capital Bureau 

102 N. Curry Street 

Carson City, NV 89703 

Nevada Farm Bureau Federation 

2 165 Green Vista Drive, Suite 205 

Sparks, NV 8943 1 

Battle Mountain Branch Library 

P.O. Box 141 

Battle Mountain, NV 89820-01 41 
Comment Period for Contingency Plan as regards Clark County CO M... mailbox:///C//Documents%2Oand%2OSettingshills/Applicaiion%:!OD 

Subject: Comment Period for Contingency Plan as regards Clark County CO Maintenance P1 

From: William Striejewske <wstriejewske@agri.state.nv.us> 

Date: Fri, 09 Jul2010 16:29: 13 -0700 

/"/ +zl 

To: Keith Wells <kdwells@motorpool.nv.gov>, Yann Ling <yling@mail.co.washoe.nv.us>, Andy 

Goodrich <agoodric@mail.co.washoe.nv.us>, Lea Rogers <lrogers@rtcwashoe.com>, "Long, Nancy" 

<nkl@jonesvargas.com>, Crayton Jones <Crayton.Jones@swgas.com>, John Sande 

<jps@jonesvargas.com>, Deborah Wong <deborah~wong@csaa.com>, "Dennis Ransel (CCAQM)" 

<"ransel"@co.clark.nv.us>, Duane Sikorski <dsikorsk@mail.co.washoe.nv.us>, "Ed Hamey (NHP)" 

<ehamey@dps.state.nv.us>, Ellen Shapiro <ESHAPIRO@autoalliance.org>, "Geeser, Michael" 

<Michael~Geeser@csaa.com>, Gina Grey <gina@wspa.org>, "John Saxon (Haycock)" 

<JSaxon@HaycockPetroleum.com>, Lawrence Waugh <lawrencew@nellaoil.com>, Jalyn Rowser 

<Jalyn.Rowser@flyingj.com>, Christy Lew <clew@agri.state.nv.us>, Tom Koehler 

<tomk@pacificethanol.net>, Norma McCusker <wenergetix@aoI.com>, Robert Tekniepe 

<tekniepe@co.clark.nv.us>, Randy White <RWhite@co.clark.nv.us>, Bonnie Kaufman 

<brk@stateside.com>, "Ron Levine (NMTA)" <vegas@nmta.com>, Nick Economides 

<Nick.Economides@chevron.com>, Russ Kinzig <KinzigR@kindemorgan.com>, "Santana Gonzalez 

(Chevron)" <sang@chevrontexaco.com>, Shannon Rudolph <srudolph@agri.state.nv.us>, Sigurd 

Jaunarajas <sjaunara@ndep.nv.gov>, Simone Yuan -Newman <simone.yuan-newman@valero.com>, 

Michael Ingham <Michael.Ingham248@gmail.com>, "Teri Baltisberger (DMV)" 

<tbaltisberger@dmv.nv.us>, "Victor Dugan (ExxonMobil)" <victor.m.dugan@exxonmobil.com>, 

"Sandie A. Foley" <safoley@agri.state.nv.us>, Grant Gillham <info@captaing2.com>, Paul Anderson 

<panderson@hpc.bz>, Paul Richmond <paul@wspa.org>, Tony Lesperance 

<tlesperance@agri.state.nv.us>, Marie Kaddell <marie.kaddell@lexisnexis.com>, Peter Krueger - 

i3PublicAffairs <peter@i3publicaffairs.com>, David Patterson 

<David.Patterson@na.mitsubishi-motors.com>, Lew Gibbs <Imgi@chevron.com>, Marilyn Herman 

<mherman697@aol.com>, Roxanne Johnson <Johnson.Roxanne@EPA.GOV>, Rebecca Richardson 

<RRichardson@marciv.com>, "Miller, Stephanie" <stephanie.miller@lexisnexis.com>, David Kennedy 

<dak@stateside.com>, Miles Heller <Miles.Heller@bp.com>, "Garcia, Juan M." 

<JuanGarcia@chevron.com>, "John D. Moms" <john.moms@aftonchemical.com>, "John M. Cabaniss, 

Jr." <JCabaniss@AIAM.org>, Marlene Lockard <marlene@capital-strategies.us>, moe Truman 

<moe@panwestern.com>, Stacy Howard <stacy.howard@aopa.org>, Adele Malone 

<amalone@ndep.nv.gov>, Paul Anderson <panderson@hpc.bz>, Dean Baker 

<deanbaker@peoplepc.com>, Martin Plaskett <diamondvalleyhay@yahoo.com>, Ramona Momson 

<rhmonison@sbcglobal.net>, Alan Perazzo <aperazzo@cccomm.net>, Paul Noe 

<paulnoe@stamursery.com>, "Boyd Spratling, DVM" <boyddvm@wellsrec.net>, Hank Vogler 

<needmoresheepco@yahoo.com>, "Katie S. Armstrong" <KArrnstrong@ag.nv.gov> 

NOTICE OF INTENT TO SOLICIT PUBLIC COMMENT OR REQUEST A PUBLIC 

HEARING 

From July 12, 20 10 until August 1 1,20 10, the Nevada Department of Agriculture is soliciting from all interested 

persons comment, or a request to hold a public hearing, regarding a contingency plan included in an update of the 

Clark County CO Maintenance Plan. In the case of violations to this updated plan, the contingency calls for a 

reversion to a gasoline standard codified previously in Nevada Administrative Code section 590.065. See 

subsection 2 below for the text of the Contingency Plan to be submitted to the EPA. 

1. The need for and the purpose of this notice. 
Comment Period for Contingency Plan as regards Clark County CO M... mailbox:l~lC(lDocuments%2Oand%20Settings/billslApplication%2OD 

M,GLTZO~ 1 G Mbr~d 6 4-0 h& ID a5 / 

The Clark County Department of Air Quality and Environmental Management (DAQEM) has been 2, 62 \ - working with the Environmental Protection Agency (EPA) on a revision to a Carbon Monoxide (9 ' 

Maintenance Plan, as outlined in Section 175A of the Clean Air Act (CAA). The existing plan called for 

a maximum vapor pressure for gasoline of 9.0 pounds per square inch (psi) from October 1 through 

March 3 1. This maximum was codified in Nevada Administrative Code chapter 590. In the revision to 

the maintenance plan, Clark County DAQEM petitioned the Nevada Board of Agriculture to increase the 

vapor pressure maximum to 13.5 psi. This change was approved by the Board of Agnculture in 

December 2009, and approved by the Legislative Commission in January, 2010. Section 175A(d) of the 

CAA states that this plan revision must include contingency provisions in the event of violations to the 

new standard. 

As stated in Title 40 of the Code of Federal Regulations, 55 1.102, it is required to provide a 30 day 

period for the public to submit written comment or for a request to be made to hold a public hearing on 

this issue. 

The complete notice of intent has been attached to this e-mail. 

Regards, 

-- 

William S. Striejewske 

Senior Petroleum Chemist 

Nevada Department of Agriculture 

Measurement Standards - Petroleum Technology 

(775) 688-1 166 ext. 23 1; Fax: (775) 688-2533 

Cell: (775) 846- 1 166 

wstriejewske@,agri.state.nv.us 

William Striejewske <wstrieiewske@agri.state.nv.us> 

Senlor Petroleum Chemist 

Bureau of Petroleum Technology 

Nevada Department of Agriculture - -. -- - - -- . 

I 

I Content-Type: application/msv NOTICE OF INTENT - Public Comment for Contingency.doc Content-Encoding: base64 
PUBLIC COMMENT REPORT 

Letter of Commitment from the Nevada Department of Agriculture (NDoA) 

Public Notice: Home webpage of NDoA (www.agri.state.nv.us) 

NDoA offices statewide 

Nevada public libraries statewide 

Electronic mailing to petroleum industry and 

federal/state/local government stakeholders 

Public Comment Period: July 12,2010 to August 11,2010 

Formal Comments Received: None 

Informal Comments Received: British Petroleum, Miles Heller, email dtd. July 12, 20 10 

There were no formal public comments received regarding the letter of commitment from 

the Nevada Department of Agriculture to implement a contingency measure contained in the 

Clark County Carbon Monoxide Redesignation Request and Maintenance Plan, September 2008. 

British Petroleum (BP) however, sought clarification of said action during the public comment 

period. 

INFORMAL COMMENTS RECEIVED FROM BP AND NDoA RESPONSE 

While BP stated they "welcome[d] the change" they wanted to make sure they 

maintained a "contingency plan" in the event it was necessary "for switching back . . . in 

the shortest time anticipated." Therefore BPS questions consisted of clarification with 

regards to timelines for reverting back (roll-back) to the previous wintertime Reid Vapor 

Pressure (RVP) maximum for gasoline in the event of a carbon monoxide violation(s). A 

summary of the questions contained in BPS emails and NDoAs responses are as follows: 

1. What is the shortest time from exceedence to reinstituting the RVP 9.0 psi limit? 

Based on the frequency of NDoA Board meetings (quarterly), BP assumes it could 

easily be done within a winter-blending season, especially if the exceedence occurs in 

October or November. Is it one to two months? 

NDoA response: NDoA can implement three types of regulations in the NAC; 

permanent, temporary, and emergency. In earlier conversations with the U.S. 

Environmental Protection Agency (EPA) it was indicated that a RVP roll-back would 

most likely need to be implemented no-later-than the following carbon monoxide (CO) 

wintertime season. As such, NDoA probably would have time to implement a permanent 

or temporary regulation. In the event an exceedence occurs early in the season (October - 

November) - and EPA/Clark County Department of Air Quality and Environmental 

Management (DAQEM) requires the roll-back to occur prior to the end of the CO 

wintertime season - NDoA would need to implement an emergency regulation. 

Emergency regulations require the Governor's signature and can only be in effect for 90 

days. 
Public Comment Report (Cont) 

2. DAQEM has its own Air Quality Regulations (AQR Section 54) that limit fuel sulfur 

content and aromatics. I believe those have already been suspended by the Clark 

County Board of County Commissioners. Since the proposed action only addresses 

RVP limits contained in the Nevada Administrative Code do you know how this 

action could relate specifically to the AQR Section 54 suspension? 

NDoA response: Based on past conversations with DAQEM I deem you are correct; 

Clark County has suspended AQR Section 54. It is also my understanding from talking 

with DAQEM that the proposed roll-back of the RVP maximum for gasoline - in the 

event of a carbon monoxide violation(s) - is a separate action independent of the AQR 

Section 54 suspension. You may, however, want to contact DAQEM directly to verify 

this.