## Chapt er Eight - Monitori ng Strat e

gy

8.1 INTRODUCTION

8.2 NEVADA’S REGIONAL HAZE VISIBILITY MONITORING

STRATEGY

8.3 COORDINATION WITH §51.305 MONITORING STRATEGY REQUIREMENT

8.4 ASSOCIATED REGIONAL HA ZE MONITORING STRATEGY REQUIREMENTS

8.5 OVERVIEW OF IMPROVE SITE AT THE JARBIDGE W I LDERNESS

AREA

8.6 COMMITMENT TO FUTURE MONI TORING

NEVADA REGIONAL HAZE S T ATE IMPLEMEN TATI ON PLAN, October 2009 8-1NEVADA REGIONAL HAZE STATE IMPLEMEN TATION PLAN, October 2009 8-2 8.1 INTRODUCTION

The Regional Haze Rule (RHR) at 40 CFR 51.308(d )(4) requires states to submit a monitoring strategy for measuring, characterizing and reporting of regional haze visibility impairment that is representative of all mandatory Class I areas within the state. The regional haze monitoring strategy must also coordinate with the monitoring strate gy required in 40 CFR 51.305 for reasonably attributable visibility impairment , as well as provide for a variety of other requirements designed to evaluate re asonable progress toward meeting na tional visibility goals.

8.2 NEVADA’S REGIONAL HAZE VISI BILITY IMPAIRMENT MONITORING

STRATEGY

Visibility conditions are presen tly measured by the Interagency Monitoring of Protected Visual Environments (IMPROVE) monitoring network. In the mid-1980’s, the IMPROVE network was established to measure visibility impairment in mandatory Class I areas throughout the United States. The monitoring sites are operated and maintained through a formal cooperative relationship between the USEPA and Federal La nd Managers (FLM) agencies, which include: the National Park Service, the U.S. Fish and W ildlife Service, the Bureau of Land Management

and the U.S. Forest Service.

The objectives of the IMPROVE program are:

1. To determine current visibility and aeroso l conditions in mandatory Class I areas;

2. To identify chemical species and emission s ources responsible for existing human-made visibility impairment;

3. To document long-term trends for assessing progress towards the national visibility goals; and

4. With the enactment of the regional haze program, to provide regional haze monitoring representing all visibility in manda tory Class I areas, where practical.

Given that the IMPROVE monitoring data from 2000 through 2004 serves as the baseline for the regional haze program, the future regional haze monitoring strategy must necessarily be based on, or directly comparable to the IMPROVE program. The IMPROVE measurements provide the only long-term record available for tracking visi bility improvement or degradation. The data collected at these sites are used by a variety of professionals in indus try and at regulatory agencies to better understand and protect the visu al air quality resources in mandatory Class I

areas. The IMPROVE network documents the visual air quality in wilderness areas and national parks throughout the United States.

Nevada’s regional haze monitoring strategy relies on info rmation generated through the IMPROVE network for the Jarbidge Wilderness Area (Jarbidge WA). It is expected that the IMPROVE program will: 1. Maintain a stable configuration of the individual monitors and sampling sites, and stability in network operations for the pur pose of continuity in tracking reasonable progress trends; 2. Assure sufficient data capture at each s ite for all visibility-impairing species;NEVADA REGIONAL HAZE STATE IMPLEMEN TATION PLAN, October 2009 8-3 3. Comply with the USEPA quality contro l and assurance requirements; and 4. Prepare and disseminate period ic reports on IMPROVE operations.

8.3 COORDINATION WITH §51.305 MONI TORING STRATEGY REQUIREMENT

Nevada is subject to a federal vi sibility protection plan (visibility FIP) as opposed to having an approved visibility protection SI P. Nevada’s visibility FI P is found at 40 CFR 52.1488. The visibility monitoring strategy provisions of 40 CFR 52.26 are incorporated into Nevada’s visibility FIP. 40 CFR 52.26(c)(1 ) requires the USEPA in coopera tion with the appropriate FLM to monitor visibility within each visibility pr otection area in the state. Accordingly, the FLMs operate the IMPROVE program which addresses vi sibility monitoring at the Jarbidge WA, as well as visibility protection areas outside the state, and establis hes background visibility for the purposes of the regional haze requirements.

Nevada’s regional haze monitoring strategy will coordinate with the Ne vada visibility FIP by continuing to utilize the data collected by th e IMPROVE program and will promote reasonable progress toward the national visibility goal. Under Nevada’s visibility FIP, Southern California Edison’s Mohave Generating Station 1 is required to meet certain emission control and limitation requirements for SO 2 ; emission control and opacity requirements for PM; and emission controls

for NO

x . Under this regional haze (RH) SIP, the M ohave Generating Station is subject to Best Available Retrofit Technology (BAR T). The BART requirements re sult in substantially greater

reductions of SO 2 and PM 10 emissions than the expected reduc tions from the visibility FIP. NO

x emissions are also expected to decrease as a result of BART when compared to the visibility FIP. Chapter Five includes a discussion of the BA RT process for the Moha ve Generating Station.

8.4 ASSOCIATED REGIONAL HAZE MONITORING STRATEGY REQUIREMENTS

Other associated monitoring strategy component s, as required by 40 CFR 51.308(d)(4)(i-vi) for Nevada’s SIP commitment, are presented below. The RHR requirement is shown below in italics, followed by Nevada’s response.

The implementation plan must al so provide for the following:

(i) The establishment of any addi tional monitoring sites or e quipment needed to assess whether reasonable progress goals to address regional haze for all mandatory Class I

Federal areas within the State are being achieved.

Sufficient funding for a complete and repres entative monitoring network within the IMPROVE program is supported by the USEP A. The IMPROVE site representing

Nevada’s Class I area at the Ja rbidge WA is considered to be sufficiently representative to support a determination of reasona ble progress for the Jarbidge WA.

1 On June 10, 2009, the owners of the Mohave Generating Station, including Southern California Edison (SCE), announced the decision to decommission the station and remove the generating facility from the site. The SCE news release states that in 2010, the plant’s generating equipment will be removed and its operating permits terminated ( http://www.edison.com/pressroom/pr.asp?bu=sce&year=2009&id=7234 ).NEVADA REGIONAL HAZE STATE IMPLEMEN TATION PLAN, October 2009 8-4 (ii) Procedures by which monitoring data and othe r information are used in determining the contribution of emissions from within the State to regional haze vi sibility impairment at mandatory Class I areas both within and outside the State.

Visibility monitoring data is presently pro cessed and maintained through the coordination of the IMPROVE program. Nevada e xpects the IMPROVE program monitoring operation and data collection to continue, with the fundament al assumption that network data collection operations will not change, or if changed, will remain directly comparable to those operated by the IMPROVE program during the 2000 through 2004 RHR baseline period.

Generally, the Western Regional Air Partnership (WRAP) has analyzed, reduced and provided information on relative contributions to visibility impairment. Nevada has and will continue to use data reported by the IM PROVE program as input into the regional technical support analysis tool found at the Visibility Info rmation Exchange Web System (VIEWS) and WRAP’s Technical Support System (TSS), as well as other analysis tools and efforts sponsored by the WRAP. The state will continue to participate in the regional analysis activities of the WRAP to collec tively assess and verify the progress toward reasonable progress goals, as the RHR is implemented. If the technical support service that the WRAP has provided for this SIP is not available in the future, Nevada is uncertain how it would fulfill this requirement . Nevada does not have the resources to replace the functions that the WRAP has pr ovided in support of the first planning period

for the RH SIP.

Evaluation activities, using the technical support provided by the WRAP as long as possible, will occur no less than every five years in association with 5-year progress reports and 10-year SIP revisions.

(iii)For a State with no mandatory Class I Federa l areas, procedures by which monitoring data and other information are used in determ ining the contribution of emissions from within the State to regional haze visibility impairment at mandatory Class I Federal

areas in other States.

Because Nevada has a mandatory Class I Federal area (Jarbidge WA), this requirement is addressed in paragraph (ii) above.

(iv) The implementation plan must provide for th e reporting of all visi bility monitoring data

to the Administrator at leas t annually for each mandatory Cl ass I Federal area in the State. To the extent possible, the Stat e should report visibi lity monitoring data electronically.

Visibility monitoring data is available to the public, states and the USEPA in an electronic format at the following websites: IMPROVE ( http://vista.cira.colostate.edu/improve/ ) and VIEWS ( http://vista.cira.colostate.edu/views/ ). Nevada will depend on the continued routine timely reporting of monitoring data by these programs.NEVADA REGIONAL HAZE STATE IMPLEMEN TATION PLAN, October 2009 8-5 (v) A statewide inventory of emi ssions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I Federal area. The inventory must include emissions for a baselin e year, emissions for the most recent year for which data are available, and estimates of future projecte d emissions. The State must also include a commitment to update the inventory periodically.

With the support of the WRAP, Nevada has pr epared a statewide inventory of emissions that can reasonably be expected to cause or contribute to visibility impairment in mandatory Class I areas. Chapter Three of this SIP summarizes the emissions by pollutant and source category. Nevada co mmits to updating its statewide emissions inventory periodically. The inventory updates will be used for state tracking of emission changes, determining trends and providing i nput into the WRAP’s evaluation of whether reasonable progress goals are being achieve d, as well as other regional analyses.

Nevada will depend upon and participate in additional periodic collective emissions inventory efforts by the WRAP. Further, the state will continue to depend on and use the capabilities of the WRAP-spons ored Regional Modeling Cent er to simulate the air quality impacts of emissions for haze planni ng purposes. If the t echnical support service that the WRAP has provided for this SIP is not available in the future, Nevada is uncertain how it would fulfill the requirement for estimates of future projected emissions.

(vi) Other elements, including reporting, record keeping, and other measures, necessary to assess and report on visibility.

Nevada will track data related to those sources for which the state has regulatory authority, and will depend on the IMPROV E program and WRAP-sponsored collection and analysis efforts and data support syst ems to assess and report on visibility.

8.5 OVERVIEW OF IMPROVE SITE AT THE JARBIDGE WILDERNESS AREA

The Jarbidge WA, described in Chapter One, is the only mandatory Cl ass I area requiring visibility monitoring within Nevada. The IMPR OVE monitoring site for the Jarbidge WA is located in the Humboldt National Forest in northeastern Nevada, approximately one kilometer north of the city of Jarbidge in the Jarbidge River drainage. The monitoring site has been maintained and operated by the U.S. Forest Se rvice since 1986. As indicated previously, monitoring data may be obtained from the VIEWS and IMPROVE websites, as well as the

WRAP TSS website.

8.6 COMMITMENT TO FU TURE MONITORING

Nevada is committed to continue using the IM PROVE monitoring data. If economic challenges are faced by the IMPROVE monitoring program, Nevada commits to working with federal agencies as a team to try to resolve the situati on. Also, the state commits to continue developing updated emission inventory data to allow for tracking emission incr eases or decreases as related to regional haze, as funding and resources allo w. Nevada updates its point source emissionNEVADA REGIONAL HAZE STATE IMPLEMEN TATION PLAN, October 2009 8-6 inventory for major sources every year as requi red by USEPA. In addition, Nevada updates its entire emission inventory every three years (all point sources, area sour ces and mobile sources) as required by USEPA for the National Emission I nventory. Information collected will be made available on a periodic basis. As part of th e periodic RH SIP revision discussed in Chapter 9, Nevada will re-evaluate the adequacy of the existing monitoring strategy.