### ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Fife Svrnington, Ge,vemor EdwardZ. Fnx, Directnr August 15, 1994
Ms. Felicia Marcus Regional Administrator U.S.E.P.A. Region IX 75 Hawthorne Street San Francisco, California 94105
RE: Submittal of State Implementation Plan

- New Source Review and Prevention of Significant Deterioration (NSRJPSD) Program for Major Sources and Major Modifications and New Source Review (NSR) for Minor Sources
Dear Ms. Marcus: Consistent with the provisions of Arizona Revised Statutes (ARS) 

### § 49-404 and 406 (See Attachment 1), 40 CFR, Part 51, Subparts F and I, the Arizona Department ofEnvironmental Quality (ADEQ) hereby submits to the U.S. EnvironmentalProtectionAgency five copies ofthe State’s statutes and rules governing permits for stationary and portable airpollution sources as a revision to the State Implementation Plan (SIP). This submittal is intended to meet all applicable requirements of Title I ofthe Clean Air Act with respect to New Source Review (NSR) and Prevention ofSignificant Deterioration (PSD). The following constitutes adescriptionofthe contents, geographic scope andapplicability ofthis submittal.
Contents This submittal includes a number ofattachments, as follows: Attachment 1 ARS, Title 49, Chapter 3, Articles 1 and 2 Attachment 2 NSR and SIP Completeness Checklist Attachment 3 NSR Checklist

3033 North Central Avenue, Phoenix Ari:oiia 85012, (602)207-2300Ms. Felicia Marcus August 15, 1994 Page 2
Attachment 4 Certified Rules, including evidence ofcompliance with Arizona Administrative Procedures Act Attachment 5 ADEQ permit rules identifying portions to be included in the applicable SIP for the purposes ofNSRJPSD for Major Sources Attachment 6 ADEQ permit rules identifying portions to be included in the applicable SIP for the purposes ofNSR for Minor Sources Attachment 7 Evidence that public participation requirments of40 CFR 51.102 are satisfied: A) Public Notice B) Evidence ofPublic Hearing C) Written Comments Received D) Response to Comments Geographic Scope In this submittal, ADEQ is requesting approval ofMajor Source NSRJPSD and Minor Source NSR forthe entire State, excluding Indian Reservations. This is being sought for two reasons: 1. 

### §1 10(a)(2)(E) ofthe Clean AirActrequires the State to assure adequate implementation of plan revisions being implemented by local governments, and, as such, ARS §49- 402(B) authorizes the Director ofADEQ to assertjurisdiction over sources subject to countyjurisdiction; and 2. ARS §49-402(A) provides ADEQ original jurisdiction over certain classes of major stationary sources and all portable sources. In requesting approval Statewide, ADEQ recognizes that Maricopa, Pima and Pinal counties currently possessjurisdiction overminor sources withintheirboundaries, andhave acquired, or are intheprocess ofacquiringjurisdictionovermajor sources, as provided inARS §49-402(A). All necessary submittals to perfect approval oftheir NSR and PSD programs will be submitted under separate cover. Applicability Arizona does not have the authority to issue permits for approvals to constructthat are separate and distinct from operating permits. Also, permiting requirements for major sources and modifications, and those for minor sources are substantially similar. As a result, theMs. Felicia Marcus August 15, 1994 Page 3
demarcation of Title I permits requirements (the SIP program) and Title V permitting requirements (a delegated program) is not readily apparent. ADEQ has provided EPA with specific guidance on which portions ofthe State permitting program are to be included in the applicable SIP. Attachments 

### 5 and 6 identify thoseportions oftherules thatare being submitted into the SIP andtheir applicability withrespectto classificationas Major Sources/Modifications (Attachment

### 5) or Minor Sources (Attachment 6). Portions ofthe rules proposed forexclusion from the applicable SIP relate only to requirements outside of Title I, Parts C and D, and implementing federal regulations.
Ifyouhave any questions regardingthis submittal, please call Nancy Wrona, at (602) 207-2308, or Ira Domsky, at (602) 207-2365.
Thank you for your consideration in this matter. Sincerely,

frEdward Z. Fox Director

Attachments

c: Nancy Wrona Ira Domsky Ken Bigos