# STATE OF NEVADA Department of Conservation & Natural Resources 

### DIVISION OF ENVIRONMENTAL P ROT EC T ION

June 3 , 20 13 Jared Blumenfeld, Regional Administrator ORA-l , USEPA Region 9 75 Hawthorne Street San Francisco CA 94105 Brian Sandoval , Governor
Leo M. Drozdoff , P

. E

. , Director

Colleen Cripps , Ph

. D

. , Administrator

plementation Plan for the 2010 Sulfur Dioxide Primary NAAQS

On behalf of Governor Sandoval, as his appointed de signee, this letter transmits to you one hard copy and one exact duplicate ofthe hard cop y in electronic form of The Nevada State Implementation Plan for the 2010 Sulfur Diox ide Primary NAAQS. This " infrastructure " SIP is submitted pursuant to Clean Air Act (CAA) section s 110 (a)(l) and (2) and embodies Nevada ' s plan for meeting the CAA requirements for implementing, maintaining and enforcing the 2010 sulfur dioxide (S02 ) primary NAAQS

. The Nevada Division of Environmental Protection (NDEP) requests approval of the enclosed S02infrastructure SIP into the applicable Nevada state implementation plan

. The following documents comprise the SIP: • The Nevada Division of Environmental Protection Portion of the Nevada State Implementation Plan for the 2010 Sulfur Dioxide Primary N AAQS and appendices. • May 29 , 2013 letter from the Clark County Department of Air Quality transmitting their 2010 sulfur dioxide NAAQS infrastructure SIP to the NDEP. • State Implementation Plan Revis ion to Meet t he Sulfur Dioxide Infrastructure SIP Requirement s of the Clean Air Act Section 1 1 0(a)(2) and attachments

. Clark County , Nevada. • May 24 , 2013 letter from the Washoe County Health District-Air Quality Management Division transmitting their 2010 sulfur dioxi de NAAQS infrastructure SIP to the NDEP. • The Washoe Coun ty Portion of the Ne vada St ate Implementation Plan to Meet the Sulfur Dioxide Infrastructure SIP Requirement s of Clean Air Act Section 110(a)(2) and attachments.
The enclosed demonstrations from each ofthe 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 (USEPA) for the 2010 sulfur dioxide infrastructure SIP , Nevada followed USEPA's October 14 , 2011 guidance for lead infrastructure SIPs (USEPA , Memorandum to Regional Air Division Directors , Guidan ce on Infrastructure State Implementation Plan Elements Required Under Sections 110(a ) (l) and (2) for the 2008 Lead (Pb) National Ambient A ir Quality Standards (NAA QS)

. S. Page , OAQPS ). Nevada's S02infrastructure SIP selects those regulatory and statutory provisions from the N evada applicable SIP that address sulfurJared Blumenfeld Page 2 June 3 , 2013 dioxide specifically. This should not be interpreted as an intent to exclude other more general provisions from the applicable SIP from applying to S0 2 sources in Nevada. 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 2010 S02 NAAQS because they are incorporated into the ND EP ' 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 S0 2infrastructure SIP is included with the respective submittals. For the NDEP portion of the SIP , the Administrator of the NDEP has the authority to adopt and submit state implementation plans to USEPA (see Appendix D). The NDEP portion ofthe 

### SOz infrastructure SIP was public-noticed from April19 through May 20 , 2013, and adopted by the NDEP Administrator as ofthe date of this submittal. The Clark County portion ofthe S02 infrastructure SIP was adopted by the Clark County Board of Commissioners on May 7, 2013, after a 30-day public notice period. The Washoe County sulfur dioxide infrastructure SIP was adopted by the Washoe County District Board of Health on March 28 , 2013 , after a 30-day public notice period.
With the exception of those elements or sub-element s that depend on a SIP-based PSD program , the NDEP requests that the USEPA propose approval ofthe enclosed plan to implement, maintain and enforce the 2010 S0 2 primaryNAAQS

. The NDEP further requests that as provisions in Nevada ' s applicable SIP are replaced or removed through subsequent approvals by USEPA of SIP revisions submitted by the NDEP , USEPA update the affected provisions in all of Nevada ' s CAA 110(a)(2) SIPs accordingly.
If you should have any questions about this submittal or require additional clarification, you may contact Jasmine Mehta, Chief, Bureau of Air Quality Planning at (775) 687-9495

. Sincerely ,

Enclosures

cc w /o enclosures: Cory Hunt, Policy Analyst , Office ofthe Governor Amy Zimpfer , Associate Director, Air Division , US E PA Region IX (AIR-1) Doris Lo , Acting Chief , Planning Office , USEPA Re g ion IX (AIR-2) Kevin Dick, Director, Air Quality Management Divi s ion , Washoe County Health District Lewis Wallenmeyer, Director, Department of Air Qu ality & Environmental Management, Clark County ec w /o enclosures Leo Drozdoff , Director, Nevada Department of Con servation and Natural Resources Michael Elges , Deputy Administrator, ND EP Jasmine Mehta , Chief , Bureau of Air Quality Planning, NDEP Rob Bamford , Chief , Bureau of Air Pollution Contro l, NDEP
Certified Mail No. 9171 9690 0935 0011 8844 98