STATE OF NEVADA 

Department of Conservation & Natural Resources 

DIVISION OF ENVIRONMENTAL PROTECTION 

June 3, 2013 

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 designee, this letter transmits to you one hard 

copy and one exact duplicate of the hard copy in electronic form of The Nevada State 

Implementation Plan for the 2010 Sulfur Dioxide Primary NAAQS. This "infrastructure" SIP is 

submitted pursuant to Clean Air Act (CAA) sections 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 S02 infrastructure 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 NAAQS 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 Revision to Meet the Sulfur Dioxide Infrastructure SIP 

Requirements of the Clean Air Act Section 110(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 dioxide NAAQS infrastructure SIP to the NDEP. 

• The Washoe County Portion of the Nevada State Implementation Plan to Meet the Sulfur 

Dioxide Infrastructure SIP Requirements of Clean Air Act Section 110(a)(2) 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 (USEP A) 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, Guidance on Infrastructure State Implementation Plan 

Elements Required Under Sections 110(a)(l) and (2) for the 2008 Lead (Pb) National Ambient 

Air Quality Standards (NAAQS). S. Page, OAQPS). Nevada's S02 infrastructure SIP selects 

those regulatory and statutory provisions from the Nevada applicable SIP that address sulfur 
Jared 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 S02 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 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 S02 infrastructure 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-elements 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 S02 primaryNAAQS. The NDEP further requests that as 

provisions in Nevada's applicable SIP are replaced or removed through subsequent approvals by 

USEP A of SIP revisions submitted by the NDEP, USEP A 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, USEPA Region IX (AIR-1) 

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

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 

Jasmine Mehta, Chief, Bureau of Air Quality Planning, NDEP 

Rob Bamford, Chief, Bureau of Air Pollution Control, NDEP 

Certified Mail No. 9171 9690 0935 0011 8844 98