STATE OF NEVADA Brian Sandoval, Governor 

Department of Conservation & Natural Resources Leo M. Drozdolf, P.E., Director 

DIVISION OF ENVIRONMENTAL PROTECTION Colleen cnws. Ph.D., Administrator 

Jared Blumenfeld 

Regional Administrator 

ORA-l, USEPA Region 9 

75 Hawthorne Street 

San Francisco CA 94105 

January 18, 2013 

RE: The Nevada State Implementation Plan for the 2010 Nitrogen Dioxide Primary 

NAAQS: emonstration of Adequacy 

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

Environmental Protection (NDEP) certifies that the existing Nevada applicable state 

implementation plan (SIP) contains provisions addressing all the "infrastructure" requirements of 

Clean Air Act (CAA) section 110(a)(2) for the 2010 nitrogen dioxide (N02) primary 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 2010 Nitrogen Dioxide Primary NAAQS: Demonstration of 

Adequacy (Demonstration of Adequacy) and appendices. 

• December 11, 2012 letter from the Clark County Department of Air Quality Management 

(CCDAQ) transmitting their 2010 N02primary NAAQS infrastructure SIP to the NDEP. 

• State Implementation Plan Revision to Meet the Nitrogen Dioxide Infrastructure SIP 

Requirements of Clean Air Act Section 110(a)(2) and attachments. Clark County, Nevada. 

• December 18, 2012letter from the Washoe County Health District-Air Quality 

Management Division (WCHD-AQMD) transmitting their 2010 N02primary NAAQS 

infrastructure SIP to the NDEP with a parallel processing request. 

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

Nitrogen Dioxide Infrastructure SIP Requirements of Clean Air Act Section 11 O(a)(2) 

(draft document) 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 US EPA guidance for the 2010 N02 

infrastructure SIPs, Nevada followed US EPA's October 14, 2011 guidance for lead 

infrastructure SIPs (US EPA, Memorandum to Regional Air Division Directors, Guidance on 
Page2 

January 18, 2013 

Infrastructure State Implementation Plan Elements Required Under Sections JJO(a)(l) and (2) 

for the 2008 Lead (Ph) National Ambient Air Quality Standards (NAAQS). S. Page, OAQPS). 

Nevada's N02 infrastructure SIP selects those regulatory and statutory provisions from the 

Nevada applicable SIP that address N02 specifically. This should not be interpreted as an intent 

to exclude other more general provisions from the applicable SIP from applying to N02 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 2010 N02primary NAAQS because they are incorporated into the 

NDEP's title V operating permits and are federally enforceable. 

We certify that the NDEP and Clark County portions of the infrastructure SIP were properly 

noticed; evidence of public participation 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 US EPA (see Appendix D). For the Washoe County portion of this 

submittal, the NDEP requests parallel processing in accordance with 40 CFR 51, Appendix 

V.2.3. The final, public noticed copy of Washoe County's portion ofNevada's 2010 N02 

infrastructure SIP will be submitted to US EPA by March 15, 2013. 

The NDEP requests that the US EPA propose approval ofthis certification of the adequacy of the 

existing Nevada applicable SIP to implement, maintain and enforce the 2010 N02 primary 

NAAQS. The NDEP further requests that generally 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 also replace or remove those provisions in this submittal and all ofNevada's 

CAA 110(a)(2) SIPs. 

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: 

Sincerely, 

lkk_· 

~!en Cripps, Ph.D. 

Administrator 

Cory Hunt, Policy Analyst, Office of the 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 

Rob Bamford, Chief, Bureau ofAir Quality Planning, NDEP