# State Implementation Plan Revision to Meet the

Sulfur Dioxide Infrastructure SIP Requirements of

the Clean Air Act Section 110(a)(2).

Clark County, Nevada

May 2013

Clark County Department of Air Quality

4701 W Russell Road, Suite 200

Las Vegas, NV 89118

# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

Clark County May 2013



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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# ACRONYMS AND ABBREVIATIONS

Acronyms

AERR Air Emissions Reporting Requirements

AQR Clark County Air Quality Regulations

BCC Clark County Board of County Commissioners

CAA Clean Air Act

CFR Code of Federal Regulations

DAQ Clark County Depart ment of Air Quality

EPA U.S. Environmental Protection Agency

FR Federal Register

GHG Green House Gasses

I-SIP Infrastructure State Implementation Plan

NAAQS National Ambient Air Quality Standards

NAC Nevada Administrative Code

NDEP Nevada Division of Environmental Protection

NESHAP National Emission Standard s for Hazardous Air Pollutants

NRS Nevada Revised Statutes

NSPS New Source Performance Standards

NSR New Source Review

SNRPC Southern Nevada Re gional Planning Coalition

PSD Prevention of Significant Deterioration

QA Quality Assurance

QC Quality Control

SIP State Implementation Plan

TAC Technical Advisory Committee

RTC Regional Transportation Commission

USC United States Code

Abbreviations

SO 2 

# Sulfur Dioxide

ppb Parts per billion

μg/m 3 

# Micrograms per cubic meter

# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# Introduction and Background

Sections 110(a)(1) and (2 ) of the federal Clean Air Act (CAA), 42 U.S.C. § 7410(a)(1) and (2) hereafter

referred to as the “Infrastructure” State Implementa tion Plan (I-SIP) requirements, requires states and

delegated local agencies to submit an implementation plan to the U. S. Environmental Protection Agency

(EPA) demonstrating their ability an d authority to implement, maintai n, and enforce each National Ambient

Air Quality Standard (NAAQS).

Section 110(a)(1) addresses the submittal requirements for I-SIPs which are due to EPA not later than 3 years

after promulgation of a new or revise d NAAQS. An I-SI P needs to be submitted rega rdless of whether or not

a jurisdiction has any nonattainment areas.

This SIP revision submittal addresses Clark County’s au thority to implement, main tain and enforce the 2010

Sulfur Dioxide (SO 2 

# ) NAAQS within the C ounty’s jurisdiction.

Section 110(a)(2) lists the required elements that cove r the I-SIP. These elements include: enforceable

emission limitations, air quality modeling, enforcemen t programs, ambient air monitoring programs, and

confirmation of adequate personnel, resources and legal aut horities. The following elements are addressed

in this I-SIP:

 Enforceable Emission Limitations and Ot her Control Measures (110(a)(2)(A))

 Air Quality Monitoring, Compilation, Data Analysis, and Reporting (110(a)(2)(B))

 Enforcement and Stationary Source Permitting (110(a)(2)(C))

 Resources, Conflict of Interest, and Emergency Backstop (110(a)(2)(E))

 Stationary Source Emissions Monito ring and Reporting (110(a)(2)(F))

 Emergency Powers and Contingency Plans (110(a)(2)(G))

 Revision For Revised Air Quality Standards or New Attainment Methods (110(a)(2)(H))

 Consultation and Public No tification (110(a)(2)(J))

 Air Quality Modeling and Reporting (110(a)(2)(K))

 Major Stationary Source Pe rmitting Fees (110(a)(2)(L))

 Consultation with Local Entities (110(a)(2)(M))

In accordance with the EPA guidance memo 1 

# dated October 17, 2011, two elem ents identified in Section

110(a)(2) are not governed by the 3-year submission dead line of Section 110(a)(1). The elements pertain to

part D, in Title I of the CAA, which addresses plan requirements for nonattainment areas. Therefore, the

following Section 110(a)(2) elements ar e considered by EPA to be outside the scope of infrastructure SIP

actions:

(1) Section 110(a)(2)(C) to the extent it refers to permit program s (known as "nonattainment new source

review") under part D; and

(2) Section 110(a)(2)(I) in its entirety.

1 

# Guidance on Infrastructure State Implem entation Plan (SIP) Elements Required Under Section 110(a)(1) and 110(a)(2) for the 2008 Lead (Pb)

National Ambient Air Quality St andards (NAAQS), October 17, 2011

# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

Clark County May 2013



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# Section 110(a)(2)(D)(i)(I) is also outside the scope of infrastructure SIP acti ons. This section is exempt from

the I-SIP due to the recent CSAPR 2 

# decision

2 

# Memorandum from Gina McCarthy, November 19, 2012State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 20136CAA 110(a)(2)(A)-(M) Requirements forthe Clark County Infrastructure State Implementation Plan for SO2Element(A)Emission limits and other control measures:Requires State Implementation Plans (SIP)to include enforceable emission limitsand other control measures, means,or techniques, and schedules for compliance.The Clark County Board of County Commissioners (BCC), in accordance with NRS Chapter 445B, has adopted the Clark CountyAir Quality Regulations (AQR) and has delegated enforcement authority to the Department of Air Quality(DAQ). Emission sourceswithin Clark County are required to complywith all existing rules and regulations through federally enforceable state implementationplan regulations3.Clark County has a SIP Approved PSD programand most of the AQRs are SIP approved.Several AQR updates have been adoptedby the BCC and submitted to EPA for incorporation in the SIP (submittal dates in parentheses). Acomplete index of all AQRs (SIPapproved and local-only) is included in Attachment B.The following is a list of rules that have been revised and submitted for incorporation into the SIP:Section 0 - Definitions (revised aspart of the Section 12.1 rulemaking and the Section 12.2 et al rulemaking);Section 12.0 - Applicability, General Requirements, Transition Procedures (adopted 11-09, submitted 02-10);Section 12.1 - Permit Requirements for Minor Sources (adopted 11-09, submitted 02-10);Section 12.2 - Permit Requirements for Major Sources inAttainment Areas (PSD) (adopted 05-10, submitted 8-10);Section 12.3 - Permit Requirements for Major Sources inNonattainment Areas (adopted 05-10, submitted 8-10);Section 12.4 - Authority to Construct Application and PermitRequirements for Part 70 Sources (adopted 05-10, submitted 8-10);Section 12.11 - General Permits for Minor Stationary Sources (adopted 11-09, submitted 02-10);Section 25 - Affirmative Defense ForExcess Emissions Due to Malfunctions, etc. (adopted 05-10, submitted 08-10).Several AQRs such as Section 12.9 – Annual Emissions Inventory Requirement, Section12.10 – Continuous MonitoringRequirements for Stationary Sources, and Section 21 – Acid Rain Permits are local-only rules.Section 0 and Section 12.2 were revised inNovember, 2010 specificallyfor the purpose of meeting the Greenhouse Gas (GHG)Tailoring Rule requirements, submitted as a SIP revision on January 4, 2011.3Although not a SIP rule, DAQ administers the Part 70 (Title V) permit requirements through the implementation of Section 12.5– Part 70 Operating Permit Requirements.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 20137Section 9 - Civil Penalties and Section 10 - Compliance Schedules are partof the DAQ enforcement programs.Clark County also enforces Hazardous Air Pollutants (Section13) rules and New Source Performance Standards (Section 14).Section 28 applies to Fuel Burning Equipment, and Section 45regulates the Idling of DieselPowered Motor Vehicles.Clark County will continue to implement the permitting and enforcement programs and enforce controlmeasures with respect to therequirements in the CAA.Clark County relies on NAC445B.400 – Emissions from Engines tocontrol emissions from vehicles.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 20138Element(B)Ambient air quality monitoring/data system:Requires SIPs to provide for establishment and operation ofambient air quality monitors, collection and analysis ofambient air quality data, and to makethese data available to EPA upon request.Clark County operates an extensive air quality monitoring network, including one SO2monitor, in accordance with 40 CFR § 58.The quality control (QC) flow rate verifications and quality assurance (QA) flow rate audits meet EPA guidelines for all monitors inthe network. An Annual Network Plan Report is completed andsubmitted to EPA as required in 40 CFR § 58.10 (Attachment A).Monitoring data is submitted to EPA via theAir Quality System; monitoring data is also available on DAQ’s website in near-realtime.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 20139Element(C)Program for enforcement of control measures:Requires SIPs to include a program providing for enforcement of all SIP measures and the regulation of constructionof new and modified stationary sources as necessary to assure that the NAAQS are achieved, including a permitprogram as required in Parts C and D.AQR Section 4 - Control Officer, authorizes the Control Officer to enforceall AQRs including the following sections:Section 10 - Compliance Schedules;Section 12.1 - Permit Requirements for Minor Sources;Section 12.2 - Permit Requirements for Major Sources in Attainment Areas;Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas;Section 12.4 - Authority to Construct Application and Permit Requirements for Part 70 Sources;Section 12.11 - General Permits for Minor Stationary Sources;Section 13 - National Emission Standards for Hazardous Air Pollutants;Section 14 - New Source Performance StandardsSection 25 - Affirmative Defense ForExcess Emissions Due to Malfunctions;Section 26 - Emission of Visible Air Contaminants;Section 27 - Particulate Matterfrom Process Weight Rate;Section 28 - Fuel Burning Equipment.The annual significant level for SO2in Section 12.2 is 1.0 μg/m3.Section 12.2 was revised in November2010 to include provisions for GHG, theSIP revision was submitted January 4, 2011.Other sections from the AQRs are not part ofthe SIP; therefore they are local-only rules. They have been adopted by the BCC andare enforced by the Control Officer.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201310Element(D)Interstate transport provisions:Requires SIPs to contain adequate provisions prohibiting emissions generatedwithin the state from contributingsignificantly to nonattainment in, or interfering with maintenance by, any otherstate with respect to the NAAQS, orfrom interfering with measures required to be includedin the SIP of any other state to prevent significantdeterioration or toprotect visibility.Additionally, PSD and NSR review provisionsin the subsections of Sections 12.2 -Permit Requirements for Major Sources inAttainment Areas, and 12.3 - Permit Requirements for Major Sourcesin Nonattainment Areas, of the AQR require an assessment ofvisibility impairment as partof the environmental review.The Maximum Allowable Increases forareas designated as Class I, II orII are defined in Section 12.2.3.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201311Element(E)Adequate resources:Requires SIPs to provide necessary assurances for adequatepersonnel, funding, and authority under state law to carryout its SIP, to contain requirements addressing potential conflicts of interest, and to provide necessaryassurances thatthe state retains responsibility for ensuring adequate implementation of the SIP where the state relies on a local orregional government for implementation of any SIP provision.NRS 445B.500 authorizes Clark County to implement and administer air quality management programs within the geographicboundaries of Clark County. Theseprograms are managed through the DAQ, with a current air quality budget of approximately$28.7 million, and 97 full-time equivalent staffpositions. Primary sources of funding are:Permits and technical services fees collected from regulated emission sources;Federal grants;Fund distributions and grants from the NevadaAir Pollution Control Account per NRS 445B.830;RTC transportation tax revenue,as established by NRS 377A.090;Federal Congestion Mitigation and Air Quality Program (CMAQ) funds.NRS 445B.520 gives the State Environmental Commission4the authority to supersede the county program.Clark County Code Chapter 2.42 – Ethical Standards - specifies conflict ofinterest requirements for Clark County public officers andofficials, including members of the BCC and the Control Officer. These requirementsspecifically prohibit all local public officialsfrom participating in governmental decisionsin which they have a financial interest.The following provisions of state law address the requirements of CAASections 110(a)(2)(E)(ii) and 128:NRS 281A.150 (“‘Public employee’ defined”)NRS 281A.160 (“‘Public officer’ defined”)NRS 281A.400 (“General requirements; exceptions”)NRS 281A.410 (“Limitations on representing or counseling private persons beforepublic agencies; disclosure required bycertain public officers.”)NRS 281A.420 (“Requirements regarding disclosure of conflicts of interest and abstention from voting because of certaintypes of conflicts; effect of abstention on quorum and voting requirements; exceptions”).4State Environmental Commission is defined in NRS 445B.200State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201312Element(F)Stationary source monitoring system:Requires SIPs to establish a system to monitor emissionsfrom stationary sources, tosubmit periodic emissionsreports, to correlate the emissions reports with the corresponding SIP emission limits and standards, and to makeemissions reports available to the public.The following AQR Sections provide the authority for the installation and maintenanceof sampling and testing facilities to measureemissions of air contaminants, and for data collection:Section 12.1 - Permit Requirements for Minor Sources;Section 12.2 - Permit Requirements forMajor Sources in Attainment Areas;Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas;Section 12.4 - Authority to Construct Application and Permit Requirements for Part 70 Sources;Section 12.9 - Annual Emissions Inventory Requirement;Section 12.10 - ContinuousMonitoring Requirements for Stationary Sources;Section 12.11 - General Permits for Minor Stationary Sources;Section 25 - Affirmative Defense ForExcess Emissions Due to Malfunctions.Sections 12.9 and 12.10 have not been submitted as SIP rules; they are local-only rules.Section 22 – Acid Rain ContinuousMonitoring is a local-only rule.Emissions data is submitted according to the Air Emissions Reporting Requirements (AERR). Emissions data is available to thepublic, except when the data is deemed confidential in accordance with AQR Section 12.6 and NRS 445B.570.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201313Element(G)Emergency episodes:Requires SIPs to provide for authority to address activities causing imminent and substantial endangerment to publichealth and to provide for adequate contingency plans to implement such authority.In accordance with NRS 445B.500(1)(d), Clark County has the authority to provide by rules and regulations for alert, warning, andemergency standards and abatement proceduresrelative to air pollution episodes or emergencies constituting, or likely to constitute,an imminent and substantial danger to people’s health pursuant to NRS 445B.560.Clark County has adopted AQR Section 70 - Emergency Proceduresof the AQRs, which addresses emergency procedures.AQR Section 6 - Injunctive Relief, allowsClark County to apply to a court of competent jurisdiction to enforce compliance with—orrestrain violations of—any provision of the AQRs.Element(H)Future SIP revisions:Requires SIPs to provide for SIP revisions in response to changes in theNAAQS, or availability of improvedmethods for attaining the NAAQS, and in response to anEPA finding that the SIP is substantially inadequate.Clark County must provide a method for revision of SIPs when air quality standards are revised, new attainment methods becomeavailable, or EPA informs states that current SIPs are inadequate for attaining standards or complying with additional CAArequirements.AQR Section 2 - Procedures for Adoption and Revision of Regulations and for Inclusion of those Regulations in the StateImplementation Plan of the Clark County AQR set forth the generalprocedural requirements for adoption of regulations and othermaterials to be incorporated in the SIP.These procedures apply to submission of:(a) Any revision to the SIP described by 40 C.F.R. § 51.104(a);(b) Any individual compliance schedule under 40 C.F.R. § 51.260;(c) Any other SIP revision submitted toNDEP pursuant to 40C.F.R. § 51.104(d).State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201314Element(J)CAA § 121Consultation with government officials, publicnotification, PSD and visibility protection:Requires states to provide a process for consultation withlocal governments and Federal Land Managers carrying outNAAQS implementation requirements pursuant tosection 121 relating to consultation.Clark County will continue including local governments and managers of affected federal lands in its consultation process as part ofcarrying out CAA requirements. AQR Section 2 – Procedures for adoption and revision of regulations and for inclusion of thoseregulations in the State Implementation Planoutlines the procedures for adoption andrevision of regulations. The proceduresinclude provisions for notice tothe public and governmental entities as well as public hearingsbefore seeking to amend the SIPapplicable to Clark County.Element(J)CAA § 127Requires States to notify the public ifNAAQS are exceeded in an area and to enhance public awareness of measuresthat can be taken to prevent exceedances.AQR Section 70 - Emergency Procedures authorizes the Control Officer to declare anepisode, an alert or an emergency if theoperation of sources of air contaminants are causing or may cause imminentdanger to human health.Additionally, near-real time ambient air monitoring data for SO2is posted on DAQ’s website.Element(J)Requires States to meet applicable requirements of part C related to prevention of significantdeterioration andvisibility protection.Title I, Part C of the CAA requires states to provide measures relating toPSD and visibility protection. The following AQRs containprovisions for PSD areas and visibility protection, as well as provisions for public participation:Section 12.1 - Permit Requirements for Minor Sources;Section 12.2 - Permit Requirements forMajor Sources in Attainment Areas;Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas;Section 12.4 - Authority to Construct Application Permit Requirements for Part 70 SourcesSection 12.11 - General Permits for Minor Stationary Sources;Section 25 - Affirmative Defense For Excess Emissions Due to MalfunctionsState Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201315Element(K)Air quality modeling/data:Requires SIPs to provide for the performance of air qualitymodeling for predicting effectson air quality of emissionsof any NAAQS pollutant and the submission of such data to EPA upon request.Clark County’s air quality modeling work complies with EPA’s final guidance on the use ofmodels in attainment demonstrations forthe NAAQS. Clark County uses the latestmethods and techniques and documents modeling information and computer modelperformance evaluations.Clark County will continue to use air quality models in accordance with approved EPA and DAQ modeling guidance and protocolsand continue to submit data and modeling results to EPA as requested.AQR Section 12.2 - Permit Requirements for Major Sources in Attainment Areas and AQRSection 12.4 - Authority to ConstructApplication and Permit Requirements for Part 70 Sources,provide provisions to require air quality modeling.Element(L)Permitting fees:Requires SIPs to require each major stationary source to pay permitting fees tocover the cost of reviewing, actingupon, implementing and enforcing a permit until such fee requirement is superseded by EPA approval of a feeprogram under Title V of the CAA.Permit and technical service fees are authorized under AQR Section 18 -Permit and Technical ServiceFees. Section 18 includesfees for sources subject to the Title V (Part 70) permit requirements.Clark County will continue to implement and update major stationary source permit fee regulations to comply with the requirementsof CAA Sections 501-507.State Implementation Plan Revisionto Meet the Infrastructure SIP Requirements for Sulfur DioxideClark CountyMay 201316Element(M)Consultation/participation byaffected local entities:Requires SIPs to provide for consultation and participation in SIP development by local political subdivisionsaffected by the SIP.Clark County consults with key stakeholder committees on policy decisions and technical issues. The Air Quality TechnicalAdvisory Committee (TAC) consists of privatesector stakeholders as well as local government representatives, and provides input ontechnical and policy decisions. The TAC has an opportunity to provide input on concerns, challenges, and progress in thedevelopment and implementation of air quality programs in ClarkCounty, but also discusses and recommends solutions to conflicts,challenges, or policy issues.Additionally, NRS 445B.503 requires Clark County to consult with the Southern Nevada Regional Planning Coalition (SNRPC) andthe Regional Transportation Commission (RTC) before adopting or amending a plan, policy, or program, andconduct hearings tosolicit public comment.

# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

Clark County May 2013 

# ATTACHMENT A

2012 Annual Monitoring Network Plan

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# ATTACHMENT B

DAQ SIP approved and local-only rules

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# Highlighted Sections are currently in the SIP, have been submitted as revisions to the SIP, or are

programs delegated by EPA to Clark County. A ll other sections are “l ocal only” rules.

Section 0 Definitions

Section 2 Procedures for Adoption and Revision of Regulations and fo r Inclusion of those Regulations

in the State Implementation Plan

Section 4 Control Officer

Section 5 Interference with Control Officer

Section 6 Injunctive Relief

Section 7 Hearing Boar d and Hearing Officer

Section 8 Persons Liable for Penalties – Punishment: Defense

Section 9 Civil Penalties

Section 10 Compliance Schedules

Section 12.0 Applicability, General Re quirements and Transition Procedures

Section 12.1 Permit Requirements For Minor Sources

Section 12.2 Permit Requirements For Major Sources In Attainment Areas (Pre vention Of Significant

Deterioration)

Section 12.3 Permit Requirements For Major Sources In Nonattainment Areas

Section 12.4 Authority To Cons truct Application And Permit Requi rements For Part 70 Sources

Section 12.5 Part 70 Operating Permit Requirements

Section 12.6 Confidentiality

Section 12.7 Emission Reduction Credits

Section 12.9 Annual Emissions Inventory Requirement

Section 12.10 Continuous Monitoring Re quirements for Stationary Sources

Section 12.11 General Permits for Minor Stationary Sources

Section 12.12 Transfer of Permit

Section 12.13 Posting of Permit

Section 13 National Emission Standa rds for Hazardous Air Pollutants

Section 14 New Source Performance Standards

Section 18 Permit and T echnical Service Fees

Section 21 Acid Rain Permits

Section 22 Acid Rain Continuous Emission Monitoring

Section 25 Affirmative Defense for Excess Emi ssions Due to Malfunctions , Startup, and Shutdown

Section 26 Emission of Vi sible Air Contaminants

Section 27 Particulate Matter from Process Weight Rate

Section 28 Fuel Burning Equipment

Section 32 Reduction of Animal Matter

Section 33 Chlorine in Chemical Processes

Section 40 Prohibitions of Nuisance Conditions

Section 41 Fugitive Dust

Section 42 Open Burning

Section 43 Odors in the Ambient Air

Section 44 Prohibitions on Planting, Selling, or Offering to Sell Fruitl ess Mulberry and European Olive

Trees

Section 45 Idling of Diesel Powered Motor Vehicles

Section 50 Storage of Petroleum Products

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# Section 51 Petroleum Product Loading into Tanks, Trucks And Trailers

Section 53 Oxygenated Gasoline Program

Section 70 Emergency Procedures

Section 80 Circumvention

Section 81 Provisions of Regulations Severable

Section 90 Fugitive Dust From Open Areas and Vacant Lots

Section 91 Fugitive Dust From Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads

Section 92 Fugitive Dust From Unpaved Parking Lots; Material Handling and Storage Yards; and

Vehicle and Equipment Storage Yards

Section 93 Fugitive Dust From Paved Roads and Street Sweeping Equipment

Section 94 Permitting and Dust Cont rol for Construction Activities

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# ATTACHMENT C

Public Participation

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# A. 30-day Public Comment Period Notification

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# Newspaper notification

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# DAQ web pages notifications:

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# B. Public Comment Report

Public Notice: Las Vegas Review-Journal, March 2, 2013

Public Comment Period: March 3, 2013 through April 2, 2013

Formal Comments Received: None

Public Hearing: May 7, 2013

Formal Comments Received: None

# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# C. Board of County Commissioners Meeting – April 16, 2013

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# D. Board of County Commissioners Meeting – May 7, 2013

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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# State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Sulfur Dioxide

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