STATE OF NEVADA 

Department of Conservation & Natural Resources 

DIVISION OF ENVIRONMENTAL PROTECTION 

Jared Blumenfeld 

Regional Administrator 

ORA-l, USEPA Region 9 

75 Hawthorne Street 

San Francisco CA 94105 

April 10, 2013 

Brian Sandoval, Governor 

Leo M. Drozdoff, P.E., Director 

Colleen Cripps, Ph.D., Administrator 

RE: The Nevada State Implementation Plan for the 2008 8-HourOzone NAAQS: 

Demonstration of Adequacy 

Dear Mr. Blumenfeld: 

On behalf of Governor Sandoval, as his appointed designee, the Nevada Division of 

Environmental Protection (NDEP) certifies that with the exception of elements or sub-elements 

that require a SIP-based program for the prevention of significant deterioration (PSD) of air 

quality, the existing Nevada applicable state implementation plan (SIP) contains provisions 

addressing all the "infrastructure" requirements of Clean Air Act (CAA) section 11 O(a)(2) fm the 

2008 8-hour ozone national ambient air quality standard (NAAQS). The NDEP is submitting 

one hard copy and one exact duplicate of the hard copy in electronic form of this certification 

letter and the following documents as demonstration of the adequacy ofNevada's existing SIP 

provisions: 

• The Nevada Division of Environmental Protection Portion of the Nevada State 

Implementation Plan for the 2008 Ozone NAAQS: Demonstration of Adequacy 

(Demonstration of Adequacy) and appendices. 

• February 25, 2013 letter from the Clark County Department of Air Quality (CCDAQ) 

transmitting their 2008 ozone NAAQS infrastructure SIP to the NDEP. 

• State Implementation Plan Revision to Meet the Ozone Infrastructure SIP Requirements 

of the Clean Air Act Section 11 O(a)(2) and attachments. Clark County, Nevada. 

• April4, 2013 letter from the Washoe County Health District-Air Quality Management 

Division (WCHD-AQMD) transmitting their 2008 ozone NAAQS infrastructure SIP to 

the NDEP. . 

• The Washoe County Portion of the Nevada State Implementation Planfor the 2008 

Ozone NAA QS: Demonstration of Adequacy and attachments. 

The enclosed demonstrations from each of the three Nevada air agencies are organized in table 

format and list each CAA section 110(a)(2) element and the existing Nevada SIP provisions that 

satisfy the requirement in each element. In the absence of guidance from the U.S. Environmental 

Protection Agency (US EPA) for the 2008 ozone infrastructure SIP, Nevada followed US EPA's 

October 14, 2011 guidance for lead infrastructure SIPs (US EPA, Memorandum to Regional Air 
Jared Blumenfeld 

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AprillO, 2013 

Division Directors, Guidance on Infrastructure State Implementation Plan Elements Required 

Under Sections 11 O(a)(1) and (2) for the 2008 Lead (Pb) National Ambient Air Quality 

Standards (NAAQS). S. Page, OAQPS). Nevada's ozone infrastructure SIP selects those 

regulatory and statutory provisions from the Nevada applicable SIP that address ozone 

specifically. This should not be interpreted as an intent to exclude other more general provisions 

from the applicable SIP from applying to ozone sources in Nevada. Further, although some of the 

SIP provisions cited in the NDEP table may not be in state regulation, nonetheless those 

provisions support the NDEP's authority to implement, maintain and enforce the 2008 ozone 

NAAQS because they are incorporated into the NDEP's title V operating permits and are 

federally enforceable. 

We certify that this submittal was properly noticed; evidence of public participation for each 

portion of Nevada's ozone infrastructure SIP is included with the respective submittals. For the 

NDEP portion ofthe SIP, the Administrator of the NDEP has the authority to adopt and submit 

state implementation plans to US EPA (see Appendix E). The NDEP portion of the ozone 

infrastructure SIP was public noticed from February 1 through March 6, 2013, and adopted by 

the NDEP Administrator as of the date of this submittal. The Clark County portion ofthe ozone 

infrastructure SIP was adopted by the Clark County Board of Commissioners on February 19, 

2013 after a 30-day public notice period. The Washoe County ozone infrastructure SIP was 

adopted by the Washoe County District Board of Health on February 28, 2013 after a 30-day 

public notice period. The minutes from that meeting were not available for today's submittal and 

will be forwarded to US EPA within a month. 

With the exception of those elements or sub-elements that depend on a SIP-based PSD program, 

the NDEP requests that the US EPA propose approval of this certification of the adequacy of the 

existing Nevada applicable SIP to implement, maintain and enforce the 2008 ozone NAAQS. 

The NDEP further requests that as provisions in Nevada's applicable SIP are replaced or 

removed through subsequent approvals by US EPA of SIP revisions submitted by the NDEP, US 

EPA update the affected provisions in all ofNevada's CAA 110(a)(2) SIPs accordingly. 

If you should have any questions about this submittal or require additional clarification, you may 

contact Rob Bamford, Chief, Bureau of Air Quality Planning at (775) 687-9330. 

Enclosures 

cc w/o enclosures: 

Colleen Cripps, Ph.D. 

Administrator 

Cory Hunt, Policy Analyst, Office of the Governor 

Amy Zimpfer, Associate Director, Air Division, USEP A Region IX (AIR -1) 

Doris Lo, Acting Chief, Planning Office, USEPA Region IX (AIR-2) 
Jared Blumenfeld 

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April 10, 2013 

Kevin Dick, Director, Air Quality Management Division, Washoe County Health District 

Lewis Wallenmeyer, Director, Department of Air Quality & Environmental Management, Clark County 

ec w/o enclosures 

Leo Drozdoff, Director, Nevada Department of Conservation and Natural Resources 

Michael Elges, Deputy Administrator, NDEP 

Rob Bamford, Chief, Bureau of Air Quality Planning, NDEP 

Certified Mail No. 9171 9690 0935 0011 8845 04