Richard
Beckstead
<
Beckstead@
Co.
Clark
.
NV.
US>

08/
04/
2004
03:
40
PM
To:
JohnJ
Kelly/
R9/
USE
cripps@
ndep.
nv.
gov
cc:
Harish
Agarwal
<
AG
<
FOLLE@
Co.
Clark.
NV.
US>,
Christine
Robinson
<
ROBINSON@
Co.
Clark.
NV.
US>,
Michael
Subject:
Supplemental
information
to
Clark
County's
11­
factor
analysis.

As
DAQEM
was
finalizing
its
submittal
of
its
11­
factor
analysis
for
the
nonattainment
boundary
in
Clark
County,
John
Kelly,
EPA
Region
IX,
called
in
and
asked
that
Clark
County's
11­
factor
analysis
take
into
consideration
future
growth
issues
such
as:

Ivanpah
Hydrographic
Area
(
164A,
164B
165,
166)
·
Expansion
projects
along
I­
15
corridor
·
Ivanpah
Energy
Power
Plant
(
ATC
issued
by
DAQEM)
·
Future
Airport
in
Ivanpah
Valley
(
Year­
2015)
(
Proposed,
High
Priority)

Apex
Hydrographic
Area
(
216,
217)
·
Duke
Energy
Power
Plant
(
ATC
issued
by
DAQEM)
·
Cal
Pine
Power
Plant
(
straddles
Apex
and
Moapa
Hydrographic
Areas)
·
Harry
Allen
Power
Plant
(
addition
of
a
turbine)
application
in­
house.
·
Chemical
Lime
Company
(
major
modification)
(
proposed)

Moapa
Hydrographic
Area
(
218)
·
Cal
Pine
Power
Plant
(
ATC
issued
by
EPA
Region
IX)
·
Ash
Grove
Cement
Company
(
proposed)

El
Dorado
Hydrographic
Area
(
213)
·
Copper
Mountain
Power
Plant
(
ATC
issued
by
DAQEM)

Each
of
these
new
or
modifying
facilities
and
activities
will
result
in
additional
NOx
and
VOC
emissions
in
the
hydrographic
areas
in
which
they
are
located.
These
sources
were
not
discussed
within
the
section
on
"
Expected
Growth"
in
the
submitted
report
entitled
Nevada
Air
Quality
Designations
Boundary
Recommendations
for
the
8­
Hour
Ozone
NAAQS
for
Clark
County,
Nevada.
John
asked
that
these
be
documented
separately,
if
necessary,
so
that
EPA
can
consider
them,
and
ask
questions
as
it
considers
the
submittal
from
the
State
of
Nevada.
The
impact
of
these
and
other
existing
sources
on
Hydrographic
Area
212
become
significant
due
to
transport
resulting
from
prominent
wind
patterns
within
the
areas
surrounding
212.
Typically,
the
upper
level
winds
will
travel
from
southwest
to
northeast,
west
to
east,
or
from
northwest
to
southeast.
However,
surface
winds
do
travel
from
northeast
to
southwest
and
from
east
to
west
on
occasion.
This
east
to
west
wind
has
occurred
on
at
least
two
occasions
when
exceedances
occurred
in
the
Las
Vegas
and
Apex
valleys.
This
phenomenon
lends
support
to
the
assumption
that
emissions
generated
in
Apex
and
Moapa
valleys
may
have
an
impact
on
the
nonattainment
status
for
the
Las
Vegas
Valley.
DAQEM
records
indicate
that
studies
have
been
done
years
ago
regarding
the
winds
around
the
Las
Vegas
Valley.
We
are
searching
for
copies
of
these
old
reports
and
will
make
them
available
upon
request.
Internet
searches
of
the
meteorological
data
that
is
available
from
various
sites
around
Clark
County
support
the
conclusions
that
emissions
from
hydrographic
areas
216
and
218
can
be
transported
to
hydrographic
area
212
on
occasion.
These
can
be
made
available
upon
request.
If
there
is
anything
DAQEM
can
do
to
assist
in
the
analysis
of
its
submittal,
please
contact
me,
Richard
Beckstead
at
(
702)
455­
1669,
and
we
will
provide
whatever
information
that
is
available.
Sincerely,

Richard
Beckstead
DAQEM
Permitting
Manager
Beckstead@
co.
clark.
nv.
us
