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# Chapter Six

– Assessment of Changes Impeding Visibility Progress (40 CFR 51.308(g)(5))

Table of Contents

6.1 Status Summary

................................ ................................ ................................ ................ 2

6.2 Significant Emission Changes within Nevada

................................ ................................ . 2

6.3 Non

- Nevada Sources Impacting the Jarbidge Wilderness Area

................................ ...... 4

6.4 Nevada’s Impacts on Nearby Class I Areas

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### 6.1 Status Summary
This chapter evaluates visibility conditions measured at JARB1 from the baseline to the 2008 through 2012 progress period

, and triennial NEI years from 2002 to 2011 ( and 2012 for Nevada point sources ) to determine if progress has been impeded by changes in anthropogenic emissions within the State

. I t further considers changes in anthropogenic emissions

, or the status of BART

, in neighboring s tates that could affec t progress at the Jarbidge WA

. Finally, Nevada’s contribution to Class I areas in nearby states is reviewed. Nevada concludes that progre ss towards achieving its 2018 visibility conditions goal ha s not been impeded by any significant anthropogenic emissions changes within or outside the State.



### 6.2 Significant Emission Changes within Nevada

40 CFR 51.308(g)(5) requires “[a]n assessment of any significant changes in anthropogenic emissions within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibilit y.” Figure 6

- 1 shows the baseline and rolling 5

- year average s of speciated light extinction at JARB1 for the 20 percent worst days from 2005 t hrough 2012. Figure 6

- 2 presents similar information

, but for the best days. For the worst days, the data show a reduction in sulfate and nitrate for the three most recent 5

- year periods ( see also the assessment of visibility conditions at Jarbidge WA in Chapter Four). Figure 6

- 1 also shows very clearly how the worst days data is influenced by natural sources from year to year. Note how t he most recent rolling 5

- year average data is skewed by an exceptionally high ye ar of wildfires ( particulate organic matter ) in 2012, contributing to an increase of more than 2.5 Mm - 1 from the preceding 5

- year average (discussed in detail in Chapter Four)

. For the best days, there are noticeable reduction s in visibility impairment d ue to sulfate, nitrate, particulate organic matter , and elemental carbon from the baseline to the current planning period. Light extinction for s oil, coarse mass and sea salt remain fairly constant for the best days.

51.308(g) . . . Periodic progress reports
must contain at a minimum . . .

(5) An assessment of any significant changes in anthropogenic emissions
within or outside the State that have occurred over the past 5 years that have limited or impeded progress in reducing pollutant emissions and improving visibility.Nevada Regional Haze 5

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Figure 6

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. Worst Days for Baseline and Rolling 5

- Year Averages Speciated Light

Extinction through Planning Period Measured at JARB1

Figure 6

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. Best Days for Baseline and Rolling 5

- Year Average s Speciated Light Extinction

through Planning Period Measured at JARB1Nevada Regional Haze 5

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Table 6

- 1 presents actual emissions in tons per year for Nevada point sources for SO 2 , NO x , P M 10 and VOC for years 2002, 2005, 2008, 2011 and 2012. Years 200 2, 2005, 2008 and 2011 were chosen as they are the most complete inventory years submitted to US EPA for the NEI

. 2012 was the most recent dataset available for Nevada’s point sources. It is noteworthy that f or all four pollutants, there has been a decrease realized in actu al emission s over the ten

- year period. SO 2 decreased by nearly an order of magnitude and NO x decreased almost seven

- fold. Further reductions are expected as BART is imple mented in Nevada. Th e s e reduction s in emissions could only help to assist the progress toward improving visibility, not impede it.

Table 6

- 1 . Actual Emissions (tpy) for Nevada Point Sources 2002, 2005, 2008, 2011, 2012 *

Year SO 2 NO x PM10 VOC

2002 50,619 55,876 6,868 2,132

2005 54,243 52,087 4,643 1,646

2008 10,497 21,680 3,465 1,600

2011 5,959 10,548 3,331 971

2012 5,278 8,324 2,629 986

* 2002 through 2011 data are actual emissions values submitted by the NDEP to the NEI. 2012 data are actual emissions values for major and minor point sources from the NDEP permitting database.



### 6.3 Non

- Nevada Sources Impacting the Jarbidge Wilderness Area
Chapte r Two discusses the status of implementation of proposed regional haze control measures, including S ection 2.5.2

, which specifically addresses the status of BART implementation in states adjacent to Nevada that may impact Jarbidge WA . Because of the locat ion of the Jarbidge WA, it is likely more strongly affected by emissions originating from within the Snake River Plain than those emitted from within the Great Basin (see Chapter Two). 2018 source apportionment modeling, discussed in Chapter 4 of Nevada’s 2009 RH SIP and summarized in Table 4

- 5 of that document , indicates that Idaho is the second largest contributor (contributing 10.3 percent ) to modeled sulfate concentrations at JARB1 on the worst days and Oregon is the third (contributing 7.2 percent) (Outside Domain is first at 43.8 percent) . Idaho is the highest contributor to modeled nitrate concentrations at JARB1 on the worst days (Outside Domain is next at 27.5 percent)

. Therefore, t his section discusses the changes to anthropogenic emission

so urces in Idaho and Oregon focusing on the implementation of BART during this first 5

- year progress period.

As discussed in S ection 2.5.2, two facilities in Idaho were subject to BART : the Monsanto/P4 Production in Soda Springs and the Amalgamated Sugar C ompany (aka TASCO Nampa ) in Nampa. The emissions changes resulting from BART implement ation at these facilities are detailed below and summarized in Table 6

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Table 6

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. Comparison of Projected 2018 and Actual 2011 Emissions from BART Facilities in Idaho and Oregon

Facility NO x (tpy) SO 2 (tpy)

Plan 02d 2011 NEI PRP18a Plan 02d 2011 NEI PRP18a
Monsanto/P4 1,531 2,520 2,231 12,197 1,020 3,397 Amalgamated Sugar (TASCO) * 1,101 1,042 944 1,798 1,659 1,235

Boardman ** 8,378 4,049 4,960 12,248 13,103 3,235

Totals 11,010 7,611 8,135 26,2 43 15,782 7,867

* BART c ompliance required by July 22, 2016

.
** BART compliance required by July 1, 2014

. At the Monsanto/P4 facility, no new NO x controls were required for BART

, and existing SO 2 controls were determined to be BART. Emissions of NO x in the PRP18a inventory were predicted to increase by 700 tp y from the Plan 02d inventory, while SO 2 emissions were predicted to decrease by 8,800 tpy. Emissions reported in the 2011 NEI for NO x are consistent with the projected PRP18a inventory , while SO 2 emissions are even lower than predicted

. Annual NO x emissions in the projected 2018 inventory are 2,231 tpy with actual emissions of 2,520 tpy reported in the 2011 NEI, while annual SO 2 emissions were projected to be 3,397 tpy with actual emissions of 1,020 tpy reported in the 2011 NEI

.
SO 2 emissions from the TASCO Nampa facility were predicted to decrease 563 tpy and NO x emissions by 157 tpy from the Plan02d to PRP18a inventories. E missions reported in the 2011
NEI are somewhat greater than those in the projected PRP18a i nventory

. P rojected 2018 annual NO x emissions were 944 tpy and actual 2011 emissions were 1,042 tpy ; projected 2018 annual SO 2 emissions were 1,235 tpy and 2011 actual emissions were 1,659 tpy. Thus, the TASCO Nampa facility emitted more pollutants in 2011 than projected in the PRP18a inventory. However, full compliance with BART is not required until July 22, 2016 and is fully expected. Thus, one of Idaho’s BART facilities is currently achieving the emissions reductions which Nevada dep ended on in setting its RPG, while a second BART facility in Idaho is not , yet

.
As discussed in S ection 2.5.2, one facility in Oregon was subject to BART: the PGE Boardman Power Plant (Boardman) . The emissions changes resulting from BART implementation a t this facility are detailed below and shown in Table 6

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.
SO 2 emissions from Boardman were projected to decrease by 9,013 tpy and NO x emissions to decrease by 3,418 t py from the Plan02d to the PRP18a inventor y . However, SO 2 emissions reported in the 2011 NEI are much greater than those in the projected PRP18a inventory

. The projected 2018 annual SO 2 emissions are 3,235 tpy

, while SO 2 emissions reported in the 2011 NEI are 13,103 tpy. Boardman’s actual NO x emissions are lower than the 2018 projection of 4,960 tpy at 4,049 tpy reported for 2011. Thus, the Boardman facility emitted more SO 2 and lessNevada Regional Haze 5

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NO x in 2011 than projected in the PRP18a inventory. However, compli ance with the BART SO 2 emission limitation is not required until July 1, 2014

, and significant SO 2 reductions are anticipated when the facility resumes operations in 2014 with the required controls.

NDEP staff spoke with Doug W a l s h, Senior Environmental Engineer with the Oregon Department of Environmental Quality Eastern Regional Office in Pendleton, Oregon , regarding the status of implementation of SO 2 controls (phone conversation with Frank Forsgren, NDEP, on August 19, 2014). M r. Walsh informed the NDEP that the facility had resumed operations and was refining operation of the SO 2 controls and undergoing testing. At this time there is insufficient data to confirm that the Boardman facility is meeting the BART SO 2 emission limit s.

Table 6

- 2 presents the 2002 baselin e emissions, 2018 projected emissions

, and 2011 actual emissions for the three subject

- to

- BART facilities located in Idaho and Oregon. The sum of actual 2011 NO x emissions from these facilities is approximately 500 tpy less than the 2018 projected emissions, while the sum of 2011 actual SO2 emissions is nearly 8,000 tpy greater than the 2018 projected emissions. Note that 2011 precedes the compliance dates for TASCO and Boardman.

Because visibility impairment resulting from nitrate and sulfate is trendin g downward at Jarbidge WA and emission reductions from BART controls in Idaho and Oregon are either in accordance with the projected 2018 inventory or are expected to be before 2018, Nevada concludes that there are no significant changes in anthropogenic e missions from outside the State that are impeding progress at Jarbidge WA.



### 6.4 Nevada’s Impacts on Nearby Class I Areas

This section reviews Nevada’s impacts on nearby Class I areas based on particulate source apportionment modeling conducted by the WRAP

. Analysis of the data demonstrate s that Nevada is reducing its contributions to neighboring states consistent with its impacts

. Section 4.3.3 of Nevada’s 2009 RH SIP discusses the results of the source apportionment modeling and identifies Nevada’s contrib utions to modeled sulfate (Table 4

- 3) and nitrate (Table 4

- 4) at all Class I areas in the five states adjacent to Nevada. The tables show Nevada’s extinction contribution (as a percentage) for the best and worst days for 2002 and 2018. Nevada’s maximum 2 018 best days sulfate contribution (7.2 percent , the fourth largest contributor at this site ) occurs at the Sawtooth Wilderness Area in Idaho and for the worst days at Zion National Park in Utah (5.6 percent , the sixth highest contributor). For nitrate, N evada’s maximum 2018 best days nitrate contribution ( 12.4 percent , the fourth largest contributor) occurs at Joshua Tree National Park and for the worst days at Bliss State Park (20.0 percent contribution, third highest contributor) in California. The Bliss I MPROVE monitor represents the Desolation Wilderness Area and Mokelumne Wilderness Area in California. Table 7

- 6 of the 2009 RH SIP shows Nevada’s share of required emissions reductions to achieve reasonable progress goals at nearby Class I areas.Nevada Regional Haze 5

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Chapter Five of this document summarizes the changes in emissions from all sources within the State resulting from the implementation of Nevada’s 2009 RH SIP . Tables 5

- 5 through 5

- 15 present the 2002 and 2008 emission inventories and the difference between the tw o for each visibility impairing pollutant . Table 5

- 5 documents a 75 percent reduction in the state

- wide sulfur dioxide emissions, while Table 5

- 7 presents similar data for nitrogen oxides and documents a 26 percent reduction in state

- wide nitrogen oxide e missions. These emissions reductions far exceed Nevada’s contribution to visibility impairment in Class I areas in the five adjacent states.