APPENDIX C 

FEDERAL LAND MANAGEMENT AGENCY 

COMMENTS AND NEVADA’S RESPONSE 

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Appendix C 

Federal Land Management Agency Comments 

and Nevada’s Response, 

April 17, 2009 

On January 5, 2009, pursuant to 40 C.F.R. 51.308(i)(2), the Nevada Division of Environmental 

Protection (NDEP) provided the Federal Land Managers (FLMs) with a draft Regional Haze 

State Implementation Plan (SIP) for a 60-day review. NDEP received comment letters from: 

• The United States Department of the Interior National Parks Service (NPS) and Fish and 

Wildlife Service (FWS) on March 6, 2009, and 

• The United States Department of Agriculture Forest Service (FS) on March 4, 2009. 

Nevada replied to the FLMs on April 17, 2009 with the responses presented below. The 

responses are organized by SIP chapter. The source of the comment is indicated by NPS-FWS 

or FS. Complete copies of the FLM comment letters follow the set of comments and responses. 

EXECUTIVE SUMMARY

COMMENT 1 (FS): Within this section it seems appropriate to discuss the relationship of the 

regional haze program to other state air permitting programs such as the Prevention of 

Significant Deterioration program. We note that the PSD program can be an effective tool to 

prevent degradation of "Best Days," and that new sources should be consistent with or 

accounted for in RH SIP revisions.

RESPONSE: NDEP added a paragraph to the Executive Summary (see paragraph 7 of the Longterm Strategy for Regional Haze section) noting the value of Nevada’s existing PSD and NSR 

programs to the regional haze program. In addition, we wish to point to Chapter Seven, 2nd

paragraph of section 7.1 (Long-Term Strategy Overview), and 1st paragraph of section 7.9.2 

(Additional Emissions Control Programs), where Nevada also notes the relationship between its 

permitting and regional haze programs. 

CHAPTERS ONE AND TWO – There were no comments on these chapters.

CHAPTER THREE 

COMMENT 2 (NPS-FWS p.2): As noted in Table 3-8 (page 3-19), point and area source 

emissions of nitrogen oxides are predicted to increase over the planning period. The geographic 

location of these emission increases may be important to protecting the best days in nearby 

Class I areas. We recognize that the emissions increase may only reflect the most recent WRAP 

2018 projection and, therefore, not incorporate the controls NDEP is implementing under BART. 

If that is the case, an acknowledgement of BART reductions should be made in Chapter Three. 

RESPONSE: Chapter Three discusses the sources of impairment in Nevada and presents the 

emission inventory data and analyses used in Nevada's SIP. Most of the tables and figures in this 

chapter reference the Plan02d and PRP18a emissions inventories. Chapter One (1.3.2 Emissions 

Analyses and Projections) describes the development of these inventories in detail, but the most 
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significant feature of the PRP18a inventory, as it relates to this comment, is that it incorporates 

presumptive BART emission limits for BART-eligible coal-fired EGUs for SO2 only and not for 

NOx. Text was added to Chapter Three, Section 3.8, to clarify that Plan02d and PRP18a were 

used for the figures and tables. In addition, text was also added to Section 3.8.2 to clarify that 

BART controls for NOx were not included in the PRP18a inventory. 

Additional emissions reductions for both SOx and PM10, beyond those identified in PRP18a, due 

to the implementation of BART controls on Nevada sources are discussed in Chapter Seven 

(section 7.2) and identified in Table 7-1. Please note that the PRP18a inventory also includes LS 

Power's proposed 1500 MW coal-fired White Pine Energy Station near Ely in eastern NV. 

However, LS Power announced on March 5, 2009 that it is indefinitely postponing construction 

due to current economic conditions and increasing regulatory uncertainties (see press release at 

http://www.lspower.com/News/newsArticle030509.htm), which may result in additional 

emissions reductions from the PRP18a inventory. LS Power still has a pending application for 

an operating permit to construct with NDEP as of March 18, 2009, and the emissions will not be 

formally removed from the projected inventory until the application is withdrawn. 

With respect to the geographic location of the sources of emissions, Chapter Three, Section 3.8, 

shows region-wide emissions expressed in the figures of Regional Maps of emissions by 

pollutant as well as bar charts representing a comparison of county level emissions for Plan02d 

and PRP18a. These figures and charts provide the data to assess the regions of Nevada which 

may potentially contribute to the visibility impairment at Class I areas in adjacent states. 

COMMENT 3 (NPS-FWS p.2): We support the plan’s specific identification of the uncertainty 

contained in Section 7.9.3.1 (page 7-16) and we request that the NDEP commit to updating that 

information in the mid-term reporting required by the Regional Haze Rule.

RESPONSE: See response under Chapter Nine. 

CHAPTER FOUR 

COMMENT 4 (NPS-FWS p.2-3): Chapter Four is a good description of the sources that impact 

Jarbidge Wilderness and of the sources in Nevada that affect visibility at Class I areas (in) other 

States. Tables 4-3 and 4-4 show the results of WRAP modeling using the Particulate Matter 

Source Attribution Tracking (PSAT) algorithm. We note that the contribution assigned to 

outside of the model domain in this work is highly uncertain, and likely to underestimate the 

contribution of regions within the model for sulfate and nitrate since it did not account for 

recirculation of pollutant nor natural sources assumptions outside of the domain. 

Yet, as noted in the tables for various pollutants, we agree that Nevada is a minor contributor to 

current and projected visibility impairment for most Class I areas outside of the State. If current 

emissions projections and BART controls are implemented, Nevada’s contributions to extinction, 

particularly for sulfate and nitrate, should keep pace with, or exceed, expectations for attaining 

the uniform rate of reasonable progress in most Class I areas. Again, it is important that new 

source development be fully reviewed to assure that increases in emissions in clean areas still 

provide for Class I progress toward natural conditions. 
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RESPONSE: Chapter Four focuses on visibility and source apportionment and may not be the 

place to discuss the review of new source development. However, NDEP does discuss the 

relationship between NSR and PSD permitting processes and regional haze in the Executive 

Summary, section 7.1 Long-Term Strategy Overview, section 7.6 Retirement and Replacement 

Schedule and section 7.9.2 Additional Emissions Control Programs. See also NDEP’s response 

to Executive Summary and Chapter Seven FLM comments. No modifications were made to 

Chapter Four due to this comment.

COMMENT 5 (FS): Table 4-4. A footnote should be added to Death Valley monitoring site to 

identify it is not a Class I area. 

RESPONSE: NDEP erroneously included Death Valley not only in Table 4-4 but also Table 4-3. 

These tables identify Nevada’s nitrate and sulfate extinction contribution to Class I areas outside 

of Nevada, respectively. Since Death Valley National Park is not a mandatory Class I area, 

NDEP has removed it from these tables and modified the accompanying descriptive text and 

figures on pages 4-14 through 4-18. 

CHAPTER FIVE 

COMMENT 6 (FS): In the BART determinations, NDEP expresses the averaging period for 

NOx emission limits as 12-month rolling averages, SO2 emission limits as 24-hour averages (or 

30-day average for Mohave), and PM10 emission limits as 3-hour averaging period. While an 

annual NOx limit may be appropriate to be protective of the National Ambient Air Quality 

Standard for NO2, this state implementation plan is designed to be protective of regional haze, 

which is an instantaneous phenomenon as experienced by a visitor to a national park or 

wilderness area. As such, we believe a shorter averaging period needs to be defined for NOx

limits. 

The EPA BART rule specifies a 30-day rolling average as appropriate for NOx presumptive 

limits for electric generating units. Additionally, model-predictions of haze are based upon 24- 

hour averages. As such, we request NDEP to specify a shorter averaging period and 

corresponding NOx limit to be consistent with the EPA rule. 

RESPONSE: The EPA BART rule specifies that the BART determination for fossil fuel fired 

power plants having a total generating capacity greater than 750 MW must be made pursuant to 

the guidelines in appendix Y of 40 CFR Part 51. Except for the Mohave Generating Station 

(MGS), all Nevada sources subject to BART determinations (i.e., the NV Energy units) are less 

than this generation threshold and are not required to follow the guidelines. Additionally, the 30-

day average recommended in the EPA guidelines was made in light of ensuring continuous 

compliance while also meeting the requirements of other applicable requirements (e.g., Acid 

Rain) and consistency with a proposed (at that time) NSPS rule. It is worthwhile to note that the 

Acid Rain program is based on annual NOx emissions. 

The 12-month rolling averages were used for the NV Energy units to provide operational 

flexibility for sources. For MGS, in addition to the 12-month rolling average Nevada BART 

establishes a mass emission rate averaged over a 1 hour period for NOx. This mass emission rate 

was based on the original 0.10 lb/MMBtu emission rate. However, it was determined that this 

rate could not be achieved in practice over the range of heat inputs. Mohave did say they could 
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achieve the equivalent mass emission rate of 788 lb/hr, which was what the modeled visibility 

improvements were based on. By having the one hour mass emission rate, the BART limit will 

ensure that the visibility improvements that were modeled would be protected. Nevada believes 

that the NOx averaging periods specified in the SIP are adequate and will result in significant 

visibility improvement.

COMMENT 7 (NPS-FWS p.5): The core purpose of the BART program is to improve visibility 

in our Class I areas. BART is not necessarily the most cost-effective solution but instead, BART 

represents a broad consideration of technical, economic, energy, and environmental (including 

visibility improvement) factors. We believe that it is essential to consider both the degree of 

visibility improvement in a given Class I area as well as the cumulative effects of improving 

visibility across all of the Class I areas affected. 

In general, NDEP did a good job in assessing the control technology aspects of the sources 

subject to BART and subsequent BART determinations, and we applaud NDEP’s decisions to go 

beyond company proposals. However, we do want to share two concerns. 

In addition to performing an analysis of the cost for removing each ton of pollutant for the 

control strategies selected as feasible and for further evaluation, NDEP also evaluated those 

strategies on the basis of incremental cost. While that is certainly a valid and useful parameter, 

it must be used with caution and its results placed into the proper perspective. The basic 

premise underlying the incremental cost analysis is to identify those strategies that contribute 

relatively little environmental benefit in proportion to their cost. Because, in most cases, the cost 

of pollution control rises exponentially with control efficiency, the slope of the cost curve will 

also increase. For this reason, rigid use of incremental cost effectiveness will always result in 

the choice of the cheapest option if carried to its ultimate extent. (For example, if this approach 

were used to evaluate PM controls, it is likely that all controls more expensive than a multiple 

cyclone would be rejected.) According to the NSR Workshop manual, “As a precaution, the 

difference in incremental costs among dominant alternatives cannot be used by itself to argue 

one dominant alternative is preferred to another.” Instead, it should be used to compare closely 

performing options. (footnote: 40 CFR Part 51 Appendix Y, “Guidelines for BART 

Determinations Under the Regional Haze Rule” Part IV(D)(4)(e): “You should consider the 

incremental cost effectiveness in combination with the average cost effectiveness when 

considering whether to eliminate a control option.” And (IV)(D)(4)(g): “You should exercise 

caution not to misuse these [average and incremental cost effectiveness] techniques...[but 

consider them in situation where an option shows]...slightly greater emissions reductions...”) 

RESPONSE: NDEP did consider the incremental costs for the various proposed control 

strategies and we recognize the limitations of this method. However, NDEP evaluated the 

control cost, incremental cost, and capital cost in combination and used a “least-cost envelope” 

to identify dominant alternatives by generating graphical plots of total annualized costs for total 

emissions reductions for all control alternatives identified in the BART analysis consistent with 

Appendix Y, Part IV(D)(4)(e)(2). We then considered the breaks in the combined economic 

factors to identify the BART control technology for further evaluation. The cost data from the 

NV Energy facilities is presented in Table 1, attached. 

For example, at Reid Gardner Unit #1 the control option identified as NOx BART, ROFA with 

Rotamix, has capital costs of nearly $8 million, control cost of approximately $1100 per ton and 
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incremental cost of just over $800 per ton reducing NOx emissions by 1308 tons from baseline 

emissions. The next most stringent control option, LNB with OFA and SCR, has capital costs of 

more than $35 million (more than 4 times greater), control cost of more than $2500 per ton 

(more than 2 times greater) and incremental cost of more than $6000 per ton (more than 7 times 

greater) and is projected to reduce annual emissions by 1850 tons from baseline emission, an 

increase of only 542 tons. In consideration of these three cost factors, NDEP identified the 

BART control technology. Thus, NDEP did not base our decision on “rigid use of incremental 

cost effectiveness”. No changes were made to the SIP as a result of this comment. 

COMMENT 8 (NPS-FWS p.5-6): Our second overarching concern is that NDEP does not 

appear to have given much weight to the visibility benefits that could be realized from the control 

strategies evaluated. At least, it is not clear how NDEP applied this factor in developing its 

BART conclusions. As we discuss later, there appears to be great inconsistency among the costs 

and visibility benefits that would result from the various control strategies chose by NDEP as 

representing BART. 

We are focusing our comments on the BART determination for the Reid Gardner (RG) facility 

operated by NV Energy (NVE) since it has larger emission than the other BART sources. We 

have conducted a preliminary review of the other BART sources and also have some initial 

questions and comments.

RESPONSE: NDEP has consistently evaluated the economic factors as part of our evaluation of 

proposed BART controls on a unit-by-unit basis, as described in our response above. As USDOI 

pointed out in their initial comments above, NDEP has identified BART controls more stringent 

than those proposed by the facilities. One of the results of this decision is a lack of additional 

modeling results, which has somewhat hampered our evaluation of visibility improvement due to 

the various proposed BART control scenarios. 

However, Table 5-4 in each of NV Energy’s BART analysis reports compares the modeled 

visibility improvement for each proposed NOx control scenario at the closest Class I area. These 

data were considered by NDEP in our evaluation of BART controls consistent with guidance 

provided in Appendix Y, Part IV(D)(5), which states, in part “If the highest modeled effects are 

observed at the nearest Class I area, you may choose not to analyze the other Class I areas any 

further as additional analyses might be unwarranted.”. These tables show clear breaks in 

visibility improvement, annualized costs, and cost per deciview reduction, paralleling those 

reflected by the cost factors. All of these data were considered in NDEP’s identification of 

BART. Table 1, attached, compiles and presents the cost and visibility improvement data 

considered by NDEP. 

The modeling conducted by NV Energy does not always reflect the BART emission limits 

proposed by NV Energy, especially for NOx and PM10. NV Energy’s consideration of NDEP’s 

comments regarding their initial identification of BART limits resulted in NV Energy identifying 

more restrictive NOx emission limits in their final BART analysis reports. However, these more 

restrictive limits were not modeled, nor were the emission rates NDEP identified as BART. NV 

Energy’s reports identify the BART emission limits proposed by NV Energy (see the 

Recommendations section of each BART analysis report) as well as the modeled emission rates 

(see Table 5-1 of each BART analysis report). 
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Chapter 5, Table 5-8 of Nevada’s regional haze SIP, identifies the differences in emissions 

modeled by NV Energy and the emissions based on the BART controls identified by NDEP. 

Section 5.6 discusses the visibility improvement resulting from BART implementation in 

Nevada. In general, there is a linear relationship between CALPUFF modeled visibility and 

emission rates. The visibility improvement resulting from BART installation is expected to be 

proportional to the difference in modeled annual emissions and the annual NDEP BART 

emissions. No changes were made to the SIP as a result of this comment. 

COMMENT 9 (NPS-FWS p.6): Comments on Reid Gardner BART Determination, Sulfur 

Dioxide (SO2). We are pleased that the proposed SO2 limit has been reduced from 0.40 pounds 

pr million Btu of heat input (lb/mmBtu) to 0.25 lb/mmBtu on a 24-hour average basis. However, 

in view of the extremely low (0.05 lb/mmBtu) actual annual SO2 emissions presented in the US 

EPA Clear Air Markets (CAM) database, we note that the limit could better reflect the lower 

actual emissions. 

We suggest a full review of the CAM data to determine the actual performance of the existing 

scrubbers and the variability in their emissions. Normally, maximum 24-hour average emissions 

are approximately 50 percent higher than the average emission rate calculated using annual 

emissions data. If that ratio holds true for the units at RG, the facility may be able to meet a 24-

hour average emissions limit of 0.10 lb/mmBtu or lower.

RESPONSE: Although the proposed BART SO2 emission rates for Reid Gardner1

 are higher 

than baseline emissions (in lb/MMBtu), NDEP has identified SO2 BART controls for Reid 

Gardner in consideration of the CAA factors, as well as uncertainties in future coal supply for 

this facility and changes in boiler operation from the current pressurized operation to balanced 

draft operation. NDEP has opted for a less stringent BART emission limit to provide operational 

flexibility during this time of transition and to ensure the limits are achievable under the new 

operating scenario. 

NDEP notes that Reid Gardner has been operating at its current emission levels in absence of a 

permit limit for SO2. It is the nature of the scrubbers and the operation of such that has led to 

these unprecedented low annual emissions from units of their age. NDEP is confident that these 

units will continue to be operated in their highly-efficient historic manner and do not see the 

need to impose an additional limit outside of regulatory guidance until operational history is 

established under the new scenario. Emissions from Reid Gardner, as well as other sources will 

be reviewed under the auspices of reasonable progress for the 2018 SIP update. NDEP has 

added explanatory text to NDEP’s BART Review documents and Chapter 5 of Nevada’s 

regional haze SIP as a result of this comment. 

COMMENT 10 (NPS-FWS p.6): It is our understanding that the proposed 24-hour limit would 

become the most stringent SO2 limit applicable to this facility. As a consequence, there appears 

to be no other constraint on RG that would prevent it from operating continuously at that 

1

 After Nevada’s response to FLM comments on the 60-day consultation draft of Nevada’s RH SIP, the SIP was 

revised and a revised draft was released for a 30-day public comment period in April-May 2009. In response to 

public comments (contained in Appendix D), Nevada is revising the BART requirements at NV Energy’s Reid 

Gardner Generating Station. A regulatory amendment lowering the SO2 emission limits for units 1, 2 and 3 from 

0.25 to 0.15 lb/106 Btu, 24-hour average, has been submitted to the State Environmental Commission for 

presentation at their December 9, 2009 Hearing. See Appendix A for details. 
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emission limit, and this could result in substantially higher annual emissions. However, a limit 

that reflects good utilization of the existing scrubbers would not require scrubber upgrades or 

incur additional costs, but would also prevent emissions from increasing. In addition to a morestringent 24-hour limit, we also suggest that an annual limit (e.g., 0.06 lb/mmBtu) be included 

that reflects the normal clean operation of this facility. 

RESPONSE: NDEP will duly consider this comment during permitting associated with Reid 

Gardner’s BART control installation. No changes have been made to the regional haze SIP due 

to this comment. 

COMMENT 11 (NPS-FWS p.6): Particulate Matter (PM10). While we agree that a fabric 

filter represents BART for filterable PM10, no justification is presented for the proposed limit of 

0.015 lb/mmBtu. We have seen stack results and permit limits at 0.010 lb/mmBtu and lower, 

(footnote: We have seen actual stack test data from the East Kentucky Power-Spurlock Unit #3 

which indicates that a much lower limit can be achieved. As a result, the East Kentucky PowerJK Smith Unit #1 & #2 project has proposed a limit on filterable PM10 of 0.0009 lb/mmBtu and 

a total PM10 limit of 0.012 lb/mmBtu. Also, on June 30, 2008, the Virginia Department of 

Environmental Quality issued a permit to Dominion Power for it Southwest Virginia Hybrid 

Energy Center that limits filterable particulate emissions to 0.010 lb/mmBtu and total PM10 to 

0.012 lb/mmBtu.) and believe that RG can achieve a lower limit on filterable PM10 than 

proposed by NDEP. 

RESPONSE: NV Energy’s BART analysis reports for Reid Gardner state “For Table 2-1 below, 

the PM10 emission rate shown is equal to the fabric filter vendor guarantee.” (section 2.0) and 

Table 2-1 lists 0.015 lb/MMBtu, “A fabric filter retrofit project is currently planned to be 

installed by July 1, 2010, on Reid Gardner 1 with guaranteed filterable particulate emissions 

from the fabric filter of 0.015 lb/MMBtu.” (section 3.2.3.2), and “The guaranteed PM10 control 

technology emission rate is 0.015 lb/MMBtu.”(section 3.2.3.3). NDEP will not specify 

emissions limits lower than vendor’s guarantees. 

NDEP notes that the emission limit chosen as BART is in line with new construction Prevention 

of Significant Deterioration (PSD) Best Available Control Technology (BACT) determinations. 

For example, NDEP has three coal-fired EGU’s that have conducted BACT analyses that have 

undergone public review in the last two years. One plant selected a PM10 (filterable) BACT of 

0.02 lb/MMBtu on a 24-hour average. Another selected 0.01 lb/MMBtu on a 3-hour average. 

The BART limit selected by R-G is 0.015 lb/MMBtu on a 3-hour average. This retrofit limit is 

comparable to the limits for new construction. Therefore, NDEP does not see the benefit in 

further analysis of the BART limit. No changes have been made to the SIP text as a result of this 

comment. 

COMMENT 12 (NPS-FWS p.7): We also request an analysis of controls for condensable PM10 

which can represent a substantial component of total PM10 emissions, and can thus affect 

visibility.

RESPONSE: Comprehensive review of 40 CFR Part 51 (Appendix Y) has not identified specific 

reference to control of condensable particulate matter under BART. The Guidelines do make 

reference to direct particulate matter emissions for determining whether sources cause or 

contribute to visibility impairment. In addition, no guidance has been provided on how to 
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evaluate whether condensable PM10 is a significant component of particulate matter that causes 

or contributes to visibility impairment at any Class I area. 

Additionally, at this time there is no post-combustion technology to directly control condensable 

particulate emissions. Condensable emissions can be controlled through application of 

combustion controls and the control of precursors of condensable particulate emissions, the 

primary constituents of which are oxides of nitrogen and sulfur. The post combustion control of 

both these oxide species have been discussed with appropriate BART limits applied. No changes 

were made to the SIP text as a result of this comment.

COMMENT 13 (NPS-FWS p.7): Nitrogen Oxides (NOx). We are pleased that, by proposing 

addition of Rotating Over-Fire Air (ROFA) with Rotamix, NDEP is moving beyond the 

combustion controls proposed by NVE. However, NDEP is proposing a higher NOx limit for RG 

Unit #3 than for units #1 and #2, even though the CAM data show that RG Unit #3 has the 

lowest current emission rate among the units at the plant. We request a justification of why 

higher NOx emissions, and therefore lower control efficiencies, are proposed for Unit #3.

RESPONSE: NV Energy discusses control cost and expected emission information in their 

BART Analysis for Reid Gardner Station Unit 3 report under Establishing Emission Reduction 

Levels from BART Analysis Results in the Executive Summary. This text describes the 

difficulty in securing cost estimates and vendor guarantees without contracts. The relevant 

portions are reproduced below: 

“As an integral part of the BART analysis process, control cost and expected emission information was 

developed for NOx, SO2, and PM10. This information is assembled from various sources including 

emission reduction equipment vendors, NV Energy operating and engineering data, and internal CH2M 

HILL historical information. 

The level of accuracy of the cost estimate can be broadly classified as American Association of Cost 

Engineers (AACE) Class V or “Order of Magnitude,” which can be categorized as +50 percent/-30 

percent. There are several reasons for selecting this range of cost estimates to be included in the BART 

analysis. They are primarily a result of the difficulty in receiving detailed and accurate information 

from equipment vendors based on limited available data provided to the vendors. Because of the active 

power industry marketplace, obtaining engineering and construction information is restricted due to 

vendor workload. Material and construction labor costs also change rapidly in today’s active economy. 

However, this level of cost estimate precision is adequate for comparison of control technology 

alternatives. The accuracy of expected emissions may also be questionable, and is also attributable to 

the inability to gain timely and accurate vendor information. This is exemplified by the difficulty in 

obtaining background information, and the vendor time required to develop accurate emission 

projections for study purposes in comparison to their response to actual project request for proposals. 

Also, variance in expected emissions can be dependent upon the pollutant under consideration (i.e., 

particulate emissions can generally be more accurately predicted than NOx emissions). Therefore, when 

establishing emission limitations in permits, consideration of variability in cost and expected emissions 

information must be considered.” 

The report goes on to say: 

“There is significant uncertainty involved in obtaining vendor emission guarantees and associated 

equipment/construction costs at this stage of analysis when retrofitting older boiler units. Site specific 

engineering is required on a “unit by unit” basis to determine the most effective control technology.” 

Executive Summary, Recommendations, NOx Emission Control 

“For this BART analysis, information pertaining to LNB with OFA, ROFA with Rotamix, SNCR, and 

SCR was based on a combination of vendor information, internal CH2M HILL information, and the 

EPA Air Pollution Cost Control Manual. Sources of cost estimates for Reid Gardner 3 are listed in 
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Table 3-1, which also summarizes the control technology options evaluated in this BART analysis, 

along with projected NOx emission rates. .... 

It should be noted estimated emissions information from NOx technologies presented represent design 

targets. With a significant potential for variability in emissions due to changes in unit operation, a 

longer averaging period results in a higher probability in meeting the permit emissions value. Emissions 

based on a 24-hour averaging period are not directly comparable to emissions targets based on a longer 

averaging time.” 3.2.1.3 Step 2: Eliminate Technically Infeasible Options 

NDEP utilized the control efficiency data presented by NV Energy with the associated caveats 

reproduced above. The higher emission rates for Unit 3 are further explained in NDEP’s 

response to the next USDOI comment which explains the use of different baseline emissions (in 

lb/MMBtu) as the starting point for calculation of emission limits. In addition, NDEP generally 

lends latitude to the experienced operators of a given facility. They understand the operational 

history and idiosyncrasies of a given unit. Therefore, NDEP had no reason to question the higher 

NOx control efficiencies for one unit over the other. It is also beneficial to understand that these 

units were not constructed at the same time, and even if they were, identical units have been 

proven to not operate identically. No changes were made to the SIP text as a result of this 

comment.

COMMENT 14 (NPS-FWS p.7): In reviewing the effectiveness of combustion controls as a 

precursor to application of SCR, NVE and NDEP have assumed that combustion controls can 

achieve NOx reductions in a range of 6 to 24 percent. Our data (provided in Appendix A) on 

BART sources and/or states proposing combustion controls indicates that typical NOx reduction 

efficiencies range between 15 and 63 percent. We request that NDEP review the effectiveness 

assumptions in its BART determination and provide support for variations from engineering 

norms.

RESPONSE: NV Energy has proposed combustion controls for Reid Gardner with NOx control 

efficiencies ranging from 6 to 24 percent for LNB with OFA and 38 to 59 percent for ROFA 

with Rotamix. The corresponding emission limits are 0.355 to 0.421 lb/MMBtu and 0.191 to 

0.278 lb/MMBtu, respectively. Appendix A, provided by USDOI, lists proposed combustion 

controls with efficiencies ranging from 15 to 63 percent and emission limits of 0.15 to 0.43 

lb/MMBtu. It is Nevada’s position that the effectiveness assumptions presented by NV Energy 

do not vary significantly from engineering norms based on the information presented by USDOI. 

Therefore, no additional support materials will be provided. No changes to the SIP text were 

made as a result of this comment. 

COMMENT 15 (NPS-FWS p.7): NDEP has assumed that control of NOx through a 

combination of combustion controls and Selective Catalytic Reduction (SCR) technologies could 

reduce NOx emissions to 0.085 lb/mmBtu, resulting in a 77 percent reduction of potential 

emissions. Our review (provided in Appendix B) of eastern coal-fired Electric Generating Units 

(EGUs) retrofitted with SCR indicates that those EGUs can achieve 0.06 lb/mmBtu on a 30-day 

rolling average basis while they are in operation. We note that Nevada Energy assumed that 

these controls could achieve an emission rate of 0.07 lb/mmBtu for its cost and air quality 

modeling analyses. We request that NDEP review its assumption regarding achievable 

emissions limits for a combination of combustion controls and SCR and provide support for any 

annual rate higher than 0.06 lb/mmBtu.
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RESPONSE: As described in Chapter Five, section 5.5 Summary of BART Control Analyses, 

NDEP evaluated CAM and other emissions data to determine baseline emissions in lb/MMBtu. 

These data are tabulated in Table 1 of NDEP’s BART Determination Reviews. Appendix A of 

NV Energy’s BART analysis reports presents similar data. Note the differences in annual heat 

input and NOx emissions, 9,048,563 MMBtu and 1452 tons by NV Energy and 10,063,851 

MMBtu and 2268 tons by NDEP, for Reid Gardner Unit 3. Analysis of these data demonstrate 

that the uncontrolled emission rate using NV Energy’s baseline is 0.32 lb/MMBtu while it is 0.45 

lb/MMBtu using NDEP’s baseline. The emission rates calculated by applying the control 

efficiencies provided by NV Energy are 0.07 lb/MMBtu and 0.098 lb/MMBtu, respectively. 

Thus, the proposed emission rates are calculated from the control efficiencies, which NDEP has 

confirmed are within engineering norms, based on data provided by USDOI (see NDEP response 

to comment above). No changes were made to the SIP text as a result of this comment. 

COMMENT 16 (NPS-FWS p.7-8): The capital costs noted for the combination of combustion 

control and SCR are $278 per kilowatt (kW) of energy output. Those costs are higher than any 

real-world costs found in available literature. (Please see the “PSNM Survey” page of 

Appendix C.) We did not find any facility-specific information in the SIP record that supports 

these costs, nor was there any indication that RG would experience any exceptional BART 

retrofit costs. As a result, the cost-effectiveness values noted in the NDEP BART analysis ranged 

from $2,386 to $2,600 per ton of NOx removed. Nevertheless, those values are substantially 

lower then the $3,778 per ton estimated by the North Dakota Department of Health for its 

proposed BART controls for NOx emissions from Great River Energy’s Stanton facility that 

impacts only two Class I areas. 

Using data found in the SIP documentation and US EPA Control Cost Manual approach 

(recommended by the BART Guidelines), we estimate cost (in Appendix D) to achieve an 

emission rate of 0.06 lb/mmBtu, representing 83 to 86 percent control efficiency on an annualaverage basis, would result in cost of $135 to $163 per kW and a range of $1,568 to $1,752 per 

ton of NOx removed. Our cost/kW is well within the range of real-world values cited above, and 

our cost per ton is similar to that accepted by NDEP for its proposed BART strategy, but with 

greater benefits to visibility. [footnote: Our cost estimates for SCR at RG are also lower thtn 

the BART strategies proposed by North Dakota for EGUs at Leland Olds, Stanton, and MR 

Young facilities (provided in Appendix E to our comments).] Based on our calculations, we 

believe that NDEP’s cost are overestimated and request that documentation of facility-specific 

conditions affecting cost be provided.

RESPONSE: Nevada has evaluated this comment in light of the cost per kW data provided in 

Appendix C. NDEP notes the most recent cost data (2008) in the literature for the combination 

combustion controls and SCR are from ODEQ for Boardman and these costs are similar to those 

proposed for Reid Gardner ($278/kW vs $207-267/kW). The most recent “real-world” costs (see 

PSNM Survey of Appendix C) date back to 2006. In addition, Summary of Summaries in 

Appendix C shows average and median total capital investment of $320 and $301/kW for SCR 

and $346 to $334/kW for combustion control plus SCR. These costs were compiled by USDOI 

from many sources/agencies and reflect costs higher than those proposed by NV Energy. 

Although NDEP can concur with use of the EPA Control Cost Manual approach, NDEP has 

issue with the use of the “NPS version of corrected OAQPS Cost Manual...” spreadsheets 

included as Appendix D of the USDOI comments. We do not concur with the use of a modified 
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version of EPA’s Control Cost Manual for numerous reasons, the most obvious being that the 

modifications are unilateral by the FLM community and have not been properly vetted through a 

public process or formally accepted by USEPA. Therefore, we acknowledge the discussion of 

costs based on the modified Cost Manual and but do not address them. 

NDEP believes the BART costs proposed by NV Energy are not overestimated but are in line 

with other proposals across the nation (when compared with those listed in Appendix C) and it is 

therefore not necessary to provide additional documentation of facility-specific conditions 

affecting cost. NDEP has provided text from NV Energy’s BART Analysis Reports (see NDEP 

response to the first USDOI comment under Nitrogen Oxides) identifying the problems with 

securing cost and emission data from vendors without formal contracts in place. 

It is also our position that the selection of BART is specific to the individual facility based on 

expected emission rate, emissions performance level, expected emissions reductions, costs of 

compliance, energy impacts, non-air quality environmental impacts and modeled visibility 

impacts. Control costs at other facilities with their unique circumstances should not be a 

controlling factor in the selection of BART. No changes were made to the SIP text as a result of 

this comment. 

COMMENT 17 (NPS-FWS p.8): We are especially concerned that the NDEP BART analysis 

did not address improvements in visibility in a quantitative manner, for example, by comparing 

the various RG control alternatives to the costs and benefits inherent in the BART proposals by 

other states and/or sources. In its BART analysis, NVE estimates that aggressive NOx controls 

(ROFA+SCR or combustion controls+SCR) at RG result in about 0.7 deciview (dv) 

improvements at Grand Canyon National Park. As presented in NVE’s BART analysis, that 

equates to approximately $7 million per dv of improvement. Even just considering the one Class 

I area for which benefits were estimated, and accepting the (likely overstated) costs and 

underestimated benefits presented by NVE, the costs per unit of visibility improvement for the 

ROFA/combustion control plus SCR scenario at RG are well within the range of what was 

selected or proposed for BART controls at EGUs in other states. Our ongoing analysis of BART 

proposals from around the US (provided in Appendix E) (footnote: Appendix E to our comments 

contains proposals to reduce NOx, SO2, and PM10, either individually, or in combination. 

While it may be relevant to cite cost/ton of pollutant in terms of the specific pollutant removed, it 

is not necessary to categorize the cost per dv of improvement because that parameter is not 

pollutant-specific. A dv of improvement due to reducing NOx is no different from a dv of 

improvement due to reducing SO2 or PM10.) are leading us to the conclusion that a cost per dv 

of $10 - $20 million represents a reasonable average cost-effectiveness for improving visibility 

at the most-impacted Class I area. (NDEP has determined that Low-NOx Burners plus Flue Gas 

recirculation represent BART for Tracy Unit #3. NVE estimated, in its BART submittal, that this 

option would result in a cost-effectiveness value of $10 million per dv.) The NVE analysis 

suggests that, at $7 million per dv, RG could install the ROFA/combustion control plus SCR 

scenario at a much more favorable cost-per-dv effectiveness ratio than the typical state or EGU 

proposing BART. Furthermore, our estimates (on the Appendix D “Gardner (NPS)” page) of 

more visibility improvement from increased efficiency of the equipment and lower costs equate to 

a $3 million cost per dv of improvement at Grand Canyon National Park alone.

RESPONSE: NDEP has determined that additional modeling beyond the efforts of NV Energy is 

unwarranted, since the highest modeled effects are observed at the Class I area nearest the 
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facilities [see Appendix Y Part IV(D)(5)], as discussed in our response to USDOI comments 

above. Tabulated model results, shown on attached Table 1, clearly identify breaks in the 

visibility impacts (both number of days and percent deciview reduction), total annualized costs 

and $/dv reduction consistent with the breaks observed in the cost factors. 

NDEP takes exception to the statement “...accepting the (likely overstated) costs and 

underestimated benefits...”. Nevada has demonstrated, using data provided by USDOI, that the 

control costs are in line with BART proposals at a variety of facilities across the nation, as are 

the control efficiencies and emission limits. The demonstrations were provided as NDEP 

responses to USDOI comments above. 

NDEP does not subscribe to the use of $/dv as a measure of cost effectiveness as this is an 

optional measure [from Appendix Y Part (V) (1) (4) “...and/or any other cost-effectiveness 

measures (such as $/deciview);...”] beyond the use of annualized costs, cost effectiveness, and 

incremental cost effectiveness. EPA has provided no guidance on the use of $/deciviews as a 

cost effectiveness measure and NDEP is concerned that it may be misused in that role. NDEP is 

unsure how the number and placement of Class I areas with respect to the facility may affect the 

usefulness of $/deciview as an effectiveness measure and therefore rely on the traditional 

measures of cost effectiveness. In addition, it is not the place of USDOI to conclude what 

constitutes reasonable average cost effectiveness. That is the role of states. 

Finally, we cannot concur with the use of a modified Control Cost Manual, as stated in our 

responses above, and so NDEP chooses not to address the comments related to Appendix D. No 

changes were made to the SIP text as a result of this comment. 

COMMENT 18 (NPS-FWS p.9): There are five Class I areas with 300 kilometers of RG. NVE 

presented baseline air quality modeling results showing that the facility causes or contributes to 

visibility impairment at three Class I areas, (footnote: RG causes visibility impairment at Grand 

Canyon National Park, and contributes to visibility impairment at Zion and Joshua Tree national 

parks. Impacts at Bryce Canyon National Park and Sycamore Canyon Wilderness Area are 

below the threshold for contributing to visibility impairment.) but only calculated improvement 

based on impacts at Grand Canyon National Park. Neither NVE nor NDEP discussed visibility 

improvement in the context of the benefits to all the impacted Class I areas.

RESPONSE: The BART guidelines recommend analyzing visibility improvement for the highest 

impacted Class I area with the assumption that any improvement in the worse impacted area would 

result in improvement in the lesser impacted areas. Chapter Five, section 5.6 Visibility 

Improvement Due to BART Implementation, does present and discuss the visibility improvement 

for all Class I areas within 300 km of each subject-to-BART facility and concludes with a 

discussion of the visibility improvement considering all Nevada BART sources in a regional 

context. In addition, NV Energy presented modeling results for all Class I areas within 300 km 

of their BART facilities. 

NV Energy conducted limited modeling for their determination of BART and, as discussed 

above, not all BART control scenarios have been modeled for the BART emission limits 

proposed by NDEP. However, it is commonly held that there is a linear relationship between 

emissions and modeled visibility impacts. Nevada anticipates greater visibility improvement 

than that modeled by NV Energy consistent with the data presented in Table 5-8 of Nevada’s 
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SIP, which lists the WRAP baseline emission rates, NV Energy modeled emission rates and the 

NDEP BART emission rates. No changes were made to the SIP text as a result of this comment. 

COMMENT 19 (NPS-FWS p.8): It simply does not make sense to use the same metric to 

evaluate the effects of reducing emissions from a BART source that impacts only one Class I 

area as for a BART source that impacts multiple Class I areas. And, it does not make sense to 

evaluate impacts at one Class I area, while ignoring others that are similarly significantly 

impaired. If emissions from RG are reduced, the benefits will be spread well beyond only the 

most-impacted Class I area, and this must be accounted for. While NVE presented data 

describing improvements to visibility at Grand Canyon National Park that would result from the 

various control scenarios it investigated, neither NVE nor NDEP have explained how they 

incorporated this information on impacts upon all Class I areas into their BART decision. For 

example, the Oregon Department of Environmental Quality (ODEQ) has recently posted on its 

website (footnote: http://www/deq.state.or.us/aq/haze/pge.htm) a proposal to require under the 

BART program that the Boardman power plant install a dry scrubber and SCR. As part of its 

BART determination, ODEQ evaluated the benefits of various control strategies on all 14 of the 

Class I areas within 300 km of the plant. The following is an excerpt from comments we sent to 

ODEQ in January 2009: 

The BART Guidelines represent an attempt to create a workable approach to estimating visibility 

impairment. As such, they require several assumptions, simplifications, and shortcuts about when 

visibility is impaired in a Class I area, and how much impairment is occurring. The Guidelines do not 

attempt to address the geographic extend of the impairment, but assume that all Class I areas are 

created equal, and that there is no difference between widespread impacts in a Class I area and 

isolated impacts in a Class I area. To address the problem of geographic extent, we have been looking 

at the cumulative impacts of a source on all Class I areas affected, as well as the cumulative benefits 

from reducing emissions. While there are certainly more sophisticated approaches to this problem, we 

believe that this is the most practical, especially when considering the modeling techniques and 

information available. In this case, we applied this cumulative approach to the Boardman analysis and 

found that the cumulative impact form the baseline condition on visibility in the 14 Class I areas is 29.7 

dv, with a total of 2,367 “days” of impaired visibility across the 14 Class I areas. 

We note that ODEQ used a similar approach in its analyses. 

NDEP has effectively ignored the other Class I areas where RG is also causing or contributing 

to visibility impairment. The dollar cost per increment of visibility improvement would be 

substantially lower if full consideration is given to all affected Class I areas that would benefit 

from emissions reductions at RG. We request that NVE present data showing the improvement 

that would result from application of the ROFA/combustion control plus SCR scenarios. We 

would be pleased to work with NDEP to further develop this approach. 

RESPONSE: Chapter Five, section 5.2 Dispersion Modeling Results, Table 5-3 and Figures 5-1 

through 5-2, presents the visibility improvement resulting from implementation of the BART 

limits proposed by NV Energy in their BART Analysis reports for Reid Gardner. In addition, 

Table 5-4 presents the visibility improvement at Grand Canyon National Park, the closest Class I 

area to the facility, for all proposed BART controls. As NDEP has discussed above, this 

approach is consistent with the guidelines given in Appendix Y. No changes were made to the 

SIP as a result of this comment.

COMMENT 20 (NPS-FWS p.9-10): Comments on BART determinations for Ft. Churchill, 

Mohave and Tracy EGUs. In general, we are pleased that NDEP has chosen BART controls 

that are more stringent than those proposed by the sources. (Those BART determinations for 
NOx are summarized in Appendix F.) However, as we evaluated those NDEP determinations, 

we observed that there were some apparent discrepancies between the levels of control that the 

sources said were achievable by a given control strategy and the level of control assumed by 

NDEP in its determination. For example, the table below presents the NOx limits used by the 

sources as they evaluated the control technologies and fuels determined by NDEP to represent 

BART. 

We suggest that NDEP include explanations as to how it arrived at its BART limits and why they 

differed from the emission rates used by the sources in evaluating those control strategies. 

(There also appear to be some discrepancies among the Tracy Unit #3 emission rates, control 

efficiencies, and visibility improvements presented by the source and discussed and adopted by 

NDEP.)

RESPONSE: The short answer is that both NDEP and NV Energy applied control efficiencies to 

calculate emission rates, however the baseline emission rates used were different. NDEP 

independently arrived at the proposed BART limits based on data reported to the EPA Clean Air 

Markets Division (acid rain data) and information presented by the sources. 

Nevada discusses the analyses of BART controls in section 5.5, Summary of BART Control 

Analyses of our regional haze SIP. This section includes a discussion of the methodology 

employed in the determination of baseline emissions and BART emission limits. A similar 

explanation is presented in NDEP BART review documents (see NDEP Analysis section under 

Step 5). Of note is NDEP’s determination of baseline emissions scenarios utilizing acid rain data 

for NOx and SO2 and annual emission data reported to NDEP for PM10. The major difference 

between NDEP’s and NV Energy’s calculation of BART emission limits is the choice of the 

baseline emissions. NV Energy’s control efficiencies were applied to NDEP’s baseline 

emissions, in lb/MMBtu, to calculate the proposed BART emission rates presented in Chapter 

Five. 

Generally, DOI is concerned that the level of control assumed by NDEP is disparate from the 

levels of control that the sources stated were achievable by a given control strategy. The 

requested explanations for the differences are identified by DOI’s table. Specifically, DOI asks 

why the NDEP estimate and the source estimate are not the same. 

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In Chapter 5 of NDEP’s BART report, NDEP explains that a different baseline data set is used 

based on data reported to the EPA Clean Air Markets Division. This baseline emission strategy 

is well documented in Chapter 5, page 5-9 of the draft Regional Haze SIP. NDEP used this 

reported baseline emission data and applied the expected performance of the control technology 

for NOx for each BART eligible unit as proposed by the source to establish the BART NOx

emission limit. No changes were made to the SIP text as a result of this comment. 

COMMENT 21 (NPS-FWS p. 10): As we suggest above, we believe that greater emphasis 

should be placed upon the degree of visibility improvement that could be achieved in this 

program designed for that specific purpose. It follows that, if it is cost-effective to spend $10 

million per dv to apply Low-NOx Burners plus Flue Gas recirculation at Tracy Unit #3, then 

application of that same criterion to the other proposals would result in determinations that 

lower emission rates could be achieved. We also suggest that, if NDEP were to consider the 

cumulative benefits that could be achieved at this $10 million/dv benchmark, the degree of 

emission reductions would be still greater. 

RESPONSE: As Nevada has stated earlier in our response to FLM comments, cost per deciview 

of visibility improvement is not a required measure of cost effectiveness [Appendix Y Part (V) 

(1) (4)]. In addition, Nevada is concerned with the rigorous application of this single matrix by 

the FLM community without guidance from EPA regarding its use. NDEP identified BART 

through the evaluation of the emission control technology available, the costs of compliance, the 

energy and non-air environmental impacts of compliance, any pollution control equipment in use 

at the source, the remaining useful life of the source and the degree of visibility improvement. 

Table 1, attached, clearly shows the breaks in cost and visibility factors at the control identified 

by NDEP as BART (shown by shaded cells in Table 1). 

Note that NDEP identified LNB with SNCR as BART for Tracy Unit 3 with a cost effectiveness 

of $2,383 per ton, incremental cost of $1,952 per ton, a cost of $9.8M per deciview of 

improvement at the Desolation Wilderness Area, and a capital cost of $4.4M for a visibility 

improvement of 0.072 dv at Desolation (the closest Class I area). Unit 3 has the lowest cost 

effectiveness of the three Tracy units, but the highest capital costs and highest cost per deciview 

of visibility improvement of any of the control options identified as BART for a NV Energy 

facility. Table 1, attached, shows BART controls for Reid Gardner have a cost effectiveness of 

$1,038 to $1,588 per ton, incremental costs of $833 to $1,560 per ton, costs of $2.4M to $2.7M 

per deciview of improvement at Grand Canyon National Park, and capital costs of $7.9M for a 

visibility improvement of 0.514 to 0.63 dv at the Grand Canyon (the closest Class I area). 

Analysis of these data suggest some of the problems with the $/dv improvement at a measure of 

cost effectiveness. No changes were made to the SIP text as a result of this comment. 

Regarding the cost per deciview, this is not an approach identified in 40 CFR 51.308 or in 40 

CFR 51 Appendix Y. The preferred approach is based on cost per ton of pollutant removed. 

CHAPTER SIX 

COMMENT 22 (NPS-FWS p.3): The setting of reasonable progress goals is linked to the 

development of a long-term strategy in that a state must consider appropriate measures, 

developed using the four statutory factors plus other considerations the state deems appropriate, 

then set reasonable progress goals for its Class I area(s) based on the projected results from 
C - 16

implementing those measures. In addition, a state SIP should discuss how its long-term strategy 

addresses its share of reasonable progress at Class I areas located in other states. 

Chapter Six is focused on the setting of reasonable progress goal for Jarbidge Wilderness and 

out-of-State Class I areas. While BART is part of a long-term strategy, the SIP discusses BART 

emissions limits in Chapter 5. We address specific BART determination issues later in this 

document. 

Section 6.7 (page 6-15) states the NDEP rationale for its conclusions that the reasonable 

progress goal for the worst visibility days is reasonable. Item 1 notes that Jarbidge Wilderness 

is projected to attain or exceed the uniform rate of progress assessment guide that EPA 

established. In addition, Item 3 in Section 6.7 notes that reductions in anthropogenic emission is 

consistent with Nevada’s share of emissions reductions to meet RPG’s of Class I areas in other 

States. While these conditions are laudable and form key aspects of what is an appropriate longterm strategy, there needs to be a more rigorous assessment of what additional strategies, if any, 

are possible. Some reasonable number of control options must be evaluated and the State must 

decide whether to include them in the long-term strategy based on the statutory factors. 

Given that Jarbidge is meeting the rate of progress in guidance from EPA, and that the 

assessment in Section 7.9.3.2 indicates that reductions in Nevada address its share of visibility 

impairment from key anthropogenic pollutant in most Class I areas, an examination focused on 

costs of some additional controls may be sufficient to complete the assessment four factor 

analysis. A comparison of costs of additional strategies on a dollar-per-ton basis with baseline 

emissions reduction programs would suffice if costs are extremely high for the amount of 

visibility improvement likely to occur. 

RESPONSE: NDEP has added citations from USEPA’s June 2007 Guidance for Setting 

Reasonable Progress Goals Under the Regional Haze Program supporting our rational for not 

assessing additional control options during the first regional haze planning period (see page 6-2 

to 6-3, 6-7 to 6-8 and 6-16). A seventh factor has been added to the text of section 6.7, 

Demonstration That the RPG for Worst Days is Reasonable, explaining that any additional costs 

for compliance are unreasonable at this time and justifying why further analysis of the four 

statutory factors is unnecessary. 

CHAPTER SEVEN 

COMMENT 23 (FS): Table 7-6 (page 7-18) summarizes Nevada’s contribution to improvement 

in Class I areas outside of the State. We note that reductions in emissions from baseline to 2018 

are given in State-wide totals. It would be more appropriate to assess regions of the State that 

are most contributing to the Class I area listed in the table. The column related to the weighted 

emission potential (WEP) reduction may address this issue but needs further elaboration in the 

text. Some of the WEP entries are negative implying that Nevada’s contribution to those areas is 

moving in the wrong direction. 

Given the uncertainties of future projections, especially the type and placement of future energy 

sources, we request the long-term strategy contain a statement that new source review and 

prevention of significant deterioration programs are key components of a regional haze plan 
C - 17

designed to improve current visibility on the most impaired days and to protect visibility 

conditions at Class I areas. 

RESPONSE: NDEP has included new text and figures in section 7.9.3.2 elaborating on the 

interpretation of the weighted emission potential data and noted the description of the WEP 

methodology and its limitations presented in Chapter 1 (section 1.3.3.2). The new text also 

references figures in Chapter Three showing a map of gridded SO2 emissions for the WRAP 

region (Figure 3-10) and a breakdown of Nevada SO2 emissions by county (Figure 3-11) which 

provide data to assess the regions of Nevada which maybe contributing to the visibility 

impairment at Class I areas in adjacent states. 

In addition, see NDEP’s response to the FLMs Chapter Three comments. NDEP’s response 

describes why the projected emissions inventory and modeling scenarios, including WEP, are 

conservative portrayals of the visibility impacts due to Nevada’s emissions. NDEP expects 

greater emissions reductions and correspondingly greater visibility improvement than is 

presented in the SIP. 

NDEP also notes California’s responses to FLM comments regarding Nevada’s impacts on 

California’s Class I areas. The comments and responses are reproduced below from Appendix F 

of California’s Regional Haze SIP: 

Comment: Nevada has a significant impact on several California Class 1 

Areas, so the SIP should note that those areas rely on Nevada sufficiently 

addressing their contribution in order to achieve reasonable progress. 

Response: California does not characterize Nevada’s impacts on total light 

extinction at California’s Class 1 Areas as significant. ARB examined the SOx 

and NOx tracer studies which show that concentrations of nitrates and sulfates 

attributable to Nevada sources are generally less than 10 percent of the total 

concentrations of nitrates and sulfates in each of the California sub-regions. 

However, when these concentrations are converted to percent contribution to 

total light extinction for the worst days annual average, their impact drops to 

barely 1 percent of total light extinction. 

Comment: DOA suggests that the plan acknowledge the point source 

contribution of nitrates from Nevada to the Desolation, Mokelumne, and 

Hoover Wilderness Areas on the 20% worst days.

Response: Please refer to the response to DOI’s comment 8. In Chapter 4 of the 

Plan, current out-of-state influences were evaluated for all source categories at 

Class 1 Areas on worst days. Despite modeling which shows elevated nitrate 

concentrations attributable to Nevada point sources on a few days each year, the 

actual contribution to total light extinction is less than one percent of the annual 

worst days average. Future impacts from Nevada could be more or less of the nit 

rate light extinction share, depending on the reductions of California mobile 

source nitrates in comparison with anticipated BART reductions from Nevada 

point sources. As noted in response to DOI’s comments 18 and 19, the modeled 

impact of these future reductions will be evaluated during the mid-course 

review. 
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Nevada has modified text in the 4th paragraph on page iv of the Executive Summary and the 2nd

paragraph on page 7-2 of section 7.1 Long-Term Strategy Overview to relate Nevada’s NSR and 

PSD permitting programs to regional haze. We have also noted the relationship between our 

permitting program and regional haze in Section 7.6 Source Retirement and Replacement 

Schedule on page 7-7, and the 1st paragraph of section 7.9.2 Additional Emissions Control 

Programs, page 7-14.

COMMENT 24 (FS): Please clarify that NDEP will revisit Nevada Cement, Fernley Plant 

during its mid-term review (5 years after EPA approval of the SIP) to clarify if the facility has 

been shut down or if not, to consider emission reductions as part of its reasonable further 

progress goals for Class I areas within and adjacent to Nevada. 

RESPONSE: Nevada Cement, Fernley Plant is BART eligible, but was found not to cause or 

contribute to visibility impairment at any Class I area. As such, this facility is not subject to a 

full BART determination. Thus, this source, along with all other Nevada sources will be 

reviewed during Nevada’s adequacy determination as part of its five-year progress report. 

Chapter Nine (sections 9.3 Commitment to Progress Reports and 9.4 Determination of Current 

Plan Adequacy) explains this process and potential actions. No modifications were made to the 

SIP text due to this comment.

COMMENT 25 (FS): While Jarbidge WA is projected to meet the 2018 URP, other Class I 

areas in adjacent states affected by emission sources in Nevada are not projected to meet the 

2018 URP. Nevada analyzed its contribution to impacts in Class I areas in neighboring states 

and presented its analysis in Section 7.9.3.2 Please expand this table to include the Hoover, CA 

IMPROVE monitoring site. 

RESPONSE: Table 7-6 has been modified to include the IMPROVE monitor HOOV1 

representing the Hoover Wilderness Area.

COMMENT 26 (FS): Please use caution in citing or referring to other legally binding 

documents, which if modified may require re-opening the regional haze SIP. For example, please 

cite and use the Clean Air Act in terms of following the emission reduction and mitigation 

objectives instead of using an MOU between effected agencies. This will reduce the need to 

modify the RH SIP, should the MOU which only lasts 5 years, be modified, or expired. 

RESPONSE: NDEP is aware that a change in the Smoke Management Plan, the MOU or the 

NAC would necessitate a SIP revision. However, since these are the current state 

programs/regulations to manage smoke, we believe it is appropriate to include them specifically 

and will update the SIP as necessary. 

COMMENT 27 (FS): To aid in the public's understanding, please include a map showing the 

region within 15 miles of the specific areas (i.e., class I areas, smoke sensitive areas, and nonattainment areas) which have smoke management restrictions.

RESPONSE: Nevada’s Smoke Management plan identifies smoke sensitive areas as the 

following: “Smoke sensitive areas include but are not limited to Class I areas as well as other 

designated scenic and/or important views especially during times of significant visitor use, urban 

and rural population centers, homes, schools, hospitals, nursing homes, airports, recreational 
C - 19

areas, and other locations that may be sensitive to smoke impacts for health, safety, and/or 

aesthetic reasons”. The electronic version of Nevada’s Smoke Management Plan can be found 

at: http://ndep.nv.gov/baqp/technical/SMP2005.html. It is problematical and unreasonable to 

provide a figure in the RH SIP showing the regions within 15 miles of all specific areas which 

have smoke management restrictions (i.e. smoke sensitive areas described above). However, we 

have attached a figure to NDEP’s response to comments showing the land status surrounding 

Nevada’s Class I area (Jarbidge WA) and a 15 mile radius buffer. The town of Jarbidge has 

approximately 20 permanent residents. The other communities shown on the figure are either 

historic sites or ghost towns and have only a few permanent residents.

COMMENT 28 (FS): As the terminology may sometimes be confusing, please segregate out 

what is required by the open burning regulation and what's required for prescribed burning. 

RESPONSE: Section 7.7 in Chapter Seven has been rewritten to clarify what types of open 

burning are regulated under the Nevada Administrative Code (NAC) and what is managed under 

the Nevada Smoke Management Program. The NAC applies to federal, state and private lands. 

In addition to the NAC, prescribed fires used specifically for land management purposes are 

controlled through implementation of the Nevada Smoke Management Program and compliance 

is achieved through a Memorandum of Understanding. 

CHAPTER EIGHT 

COMMENT 29 (NPS-FWS p.4): Section 8.3 notes that monitoring is currently implemented 

under the visibility Federal Implementation Plan (FIP) for the original visibility protection rules 

for “reasonably attributable” impairment implement by EPA in the 1980’s. We encourage 

NDEP to develop comprehensive rules to replace the FIP and which could still link to the 

cooperative state-federal IMPROVE program to accomplish cost-effective long-term monitoring.

RESPONSE: Nevada’s visibility FIP applies to only one facility in the southernmost tip of 

Nevada, Southern California Edison’s Mohave Generating Station (MGS) and contains emission 

control requirements for PM10, SO2 and NOx. Nevada’s Regional Haze (RH) SIP in effect 

supersedes the FIP, in that the BART requirements for MGS are more stringent than the FIP 

requirements. NDEP will explore the possibility of having the visibility FIP rescinded. 

The monitoring strategy in the FIP (i.e., 40 CFR 52.26) requires the EPA, in cooperation with the 

appropriate FLM, to monitor visibility within each visibility protection area in the state. 

Accordingly, the FLMs operate the IMPROVE program which addresses visibility monitoring at 

the Jarbidge WA. The IMPROVE network also addresses visibility monitoring at Class I areas 

outside the state. Nevada’s RH SIP commits to continue using the IMPROVE monitoring data to 

evaluate progress toward achieving the goals of the Regional Haze Rule. 

COMMENT 30 (NPS-FWS p.4): In Section 8.6 (page 8-5), we would like to see a state 

commitment to work with federal agencies as a team if economic challenges are faced by the 

IMPROVE monitoring program.

RESPONSE: A commitment to this effect has been added into section 8.6 of Chapter Eight. 
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COMMENT 31 (FS): Specify the frequency in which NV commits to updating its statewide 

emissions inventory. 

RESPONSE: Nevada updates its point source emission inventory for major sources every year 

as required by USEPA. In addition, Nevada updates its entire emission inventory every three 

years as required by USEPA for the National Emission Inventory. This information has been 

added into section 8.6 of Chapter Eight. 

CHAPTER NINE 

COMMENT 32 (NPS-FWS p.2): We support the plan’s specific identification of the uncertainty 

contained in Section 7.9.3.1 (page 7-16) and we request that the NDEP commit to updating that 

information in the mid-term reporting required by the Regional Haze Rule.

RESPONSE: Nevada has added text to Chapter Nine, section 9.3, “Commitment to Progress 

Reports,” confirming that its mid-term report will include all of the required elements (from 

51.308(g)(1-7)), as well as a reassessment of the uncertainty in the data. 

COMMENT 33 (NPS-FWS p.4): As already noted under the long-term strategy comments, there 

is uncertainty regarding future emissions projections from both existing and new sources, so 

future review requirements are a crucial part of the long-term strategy and should recognize that 

modifications to the control strategies may be necessary.

RESPONSE: Nevada agrees that its long-term strategy must be reviewed for the 5-year progress 

report (and future SIP revisions and progress reports) and modified as necessary. This is noted 

in the Executive Summary, sections on the long-term strategy and periodic revisions and reports. 

It is also recognized in Chapters Seven and Nine. 

COMMENT 34 (FS): Based upon the source apportionment of sulfates and nitrates for the 

worst-case days, the Forest Service encourages Nevada to work with Idaho in identifying 

strategies to reduce impacts from area sources of nitrate and point sources of sulfates in Idaho 

to the Jarbidge Wilderness area.

RESPONSE: In Chapter Nine, section 9.2.3, Nevada commits to continue to work with 

neighboring states that may be impacting or expected to impact Jarbidge WA. Idaho’s area 

source emissions of nitrate are projected to grow by approximately forty percent (nearly 12,000 

tons) from the baseline period to 2018, however Idaho’s mobile source (both on-road and offroad) emissions of nitrate are projected to decrease by nearly sixty percent (42,000 tons), more 

than offsetting the growth of area source emissions. Growth of area source emissions is 

projected to occur primarily in the most populated counties, especially those along the Snake 

River Plain. Nevada recognizes the uncertainty in projecting area source emissions in section 

7.9.3.1, Uncertainty, page 7-16 of our SIP and believes these same concerns apply to projecting 

Idaho’s emissions. 

Idaho’s point source emissions of SO2 are projected to decrease by more than forty percent 

(7,600 tons). Additional SO2 reductions are expected due to the installation of controls under 

Idaho’s BART requirements as part of Idaho’s regional haze SIP. Amalgamated Sugar’s Nampa 

facility, located in southwest Idaho is expected to install flue gas desulfurization for SO2 control 
and low-NOx burners with over-fire air for NOx control. Monsanto’s P4 facility, located in 

extreme southeastern Idaho, is expected to install scrubbers for SO2 control. Idaho is working 

with these facilities to determine the final projected emissions reductions resulting from the 

installation of these controls. 

Nevada deems these controls as appropriate strategies for Idaho to reduce the impacts of their 

sources on the Jarbidge Wilderness Area during this initial regional haze planning period. 

Table 1. BART NOx Cost Factors and Visibility Improvement for NV Energy Facilities 

Tracy Unit 1 LNB w/SCR ROFA w/Rotamix LNB w/FGR LNB w/SNCR LNB

Capital Cost $21,175,000 $7,389,835 $1,820,000 $4,431,875 $1,232,000

Total Annual Cost $2,439,826 $913,636 $276,611 $538,357 $152,661

NOx Removal Rate % 74.5% 49.1% 41.1% 31.3% 8.4%

NOx Emission Rate (Tons) 56 112 130 152 202

NOx Emission Rate (lb/MMBtu) 0.064 0.127 0.147 0.171 0.228

First Year Cost ($/ton removed) $14,840 $8,432 $3,050 $7,794 $8,235

Incremental Cost ($/ton) $27,227 $36,082 -$12,103 $7,632 $8,235

$M/dv Improvement at Desolation 28.704 16.315 5.885 14.954 16.962

98th Percentile ∆dV Reduction at Desolation 0.085 0.056 0.047 0.036 0.009

Tracy Unit 2 LNB w/SCR LNB w/SNCR ROFA w/Rotamix LNB w/FGR LNB

Capital Cost $31,812,500 $4,624,375 $8,013,408 $2,156,000 $1,540,000

Total Annual Cost $3,774,173 $692,411 $1,167,212 $398,425 $196,526

NOx Removal Rate % 85.2% 54.0% 52.0% 51.4% 38.7%

NOx Removed (Tons) 273 173 167 165 124

NOx Emission Rate (Tons) 47 148 154 156 197

NOx Emission Rate (lb/MMBtu) 0.037 0.114 0.119 0.120 0.152

First Year Cost ($/ton removed) $13,803 $3,995 $6,994 $2,415 $1,582

Incremental Cost ($/ton) $30,778 -$73,973 $399,253 $4,954 $1,582

$M/dv Improvement at Desolation 18.501 5.091 8.979 3.113 2.160

98th Percentile ∆dV Reduction at Desolation 0.204 0.136 0.13 0.128 0.091

Tracy Unit 3 LNB w/SCR ROFA w/Rotamix LNB w/SNCR LNB w/FGR LNB

Capital Cost $35,862,500 $9,189,145 $4,431,875 $2,072,000 $1,232,000

Total Annual Cost $4,397,281 $1,522,890 $706,459 $574,613 $175,861

NOx Removal Rate % 78.3% 45.2% 37.3% 28.8% 16.4%

NOx Removed (Tons) 622 359 296 229 130

NOx Emission Rate (Tons) 172 435 498 566 664

NOx Emission Rate (lb/MMBtu) 0.063 0.159 0.182 0.206 0.242

First Year Cost ($/ton removed) $7,067 $4,240 $2,383 $2,511 $1,349

Incremental Cost ($/ton) $10,928 $13,005 $1,952 $4,047 $1,349

$M/dv Improvement at Desolation 29.315 17.504 9.812 10.261 5.496

98th Percentile ∆dV Reduction at Desolation 0.150 0.087 0.072 0.056 0.032

Ft. Churchill 1 LNB w/SCR ROFA w/Rotamix LNB w/SNCR LNB w/FGR LNB

Capital Cost $35,781,250 $5,250,940 $4,416,563 $1,610,000 $1,050,000

Total Annual Cost $4,499,853 $1,669,757 $893,203 $490,969 $156,559

NOx Removal Rate % 87.4% 65.7% 62.1% 56.7% 49.5%

NOx Removed (Tons) 1057 794 751 686 598

NOx Emission Rate (Tons) $152 $415 $458 $524 $611

NOx Emission Rate (lb/MMBtu) 0.056 0.152 0.167 0.191 0.223

First Year Cost ($/ton removed) $4,259 $2,102 $1,190 $716 $262

Incremental Cost ($/ton) $10,787 $17,842 $6,161 $3,842 $262

$M/dv Improvement at Mokelumne 9.000 na 2.467 1.479 0.529

98th Percentile ∆dV Reduction at Mokelumne 0.500 na 0.362 0.332 0.296

Ft. Churchill 2 LNB w/SCR ROFA w/Rotamix LNB w/SNCR LNB w/FGR LNB

Capital Cost $35,781,250 $9,189,145 $4,416,563 $1,610,000 $1,050,000

Total Annual Cost $4,480,514 $1,639,078 $862,142 $490,969 $156,559

NOx Removal Rate % 86.4% 63.0% 59.1% 53.2% 45.4%

NOx Removed (Tons) 745 543 510 459 391

NOx Emission Rate (Tons) 117 319 353 404 471

NOx Emission Rate (lb/MMBtu) 0.045 0.123 0.136 0.155 0.181

First Year Cost ($/ton removed) $6,014 $3,017 $1,692 $1,070 $400

Incremental Cost ($/ton) $14,082 $23,103 $7,296 $4,972 $400

$M/dv Improvement at Mokelumne 11.258 na 3.158 2.012 0.771

98th Percentile ∆dV Reduction at Mokelumne 0.398 na 0.273 0.244 0.203

NOx Control

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Reid-Gardner Unit 1 ROFA w/SCR LNB w/OFA & SCR ROFA w/Rotamix LNB w/OFA & SNCR LNB w/OFA

Capital Cost $38,484,900 $35,048,000 $7,884,900 $6,945,500 $4,448,000

Total Annual Cost $5,394,746 $4,746,852 $1,450,193 $1,132,860 $551,737

NOx Removal Rate % 81.6% 81.6% 57.7% 40.9% 21.3%

NOx Removed (Tons) 1850 1850 1308 927 483

NOx Emission Rate (Tons) 417 417 959 1340 1784

NOx Emission Rate (lb/MMBtu) 0.085 0.085 0.195 0.273 0.364

First Year Cost ($/ton removed) $2,916 $2,566 $1,109 $1,222 $1,143

Incremental Cost ($/ton) $7,280 $6,085 $833 $1,308 $1,143

$M/dv Improvement at Grand Canyon 7.729 6.801 2.45 2.174 1.254

98th Percentile ∆dV Reduction at Grand Canyon 0.698 0.698 0.592 0.521 0.44

Reid-Gardner Unit 2 ROFA w/SCR LNB w/OFA & SCR ROFA w/Rotamix LNB w/OFA & SNCR LNB w/OFA

Capital Cost $38,484,900 $35,048,000 $7,884,900 $6,945,500 $4,448,000

Total Annual Cost $5,469,626 $4,795,602 $1,498,001 $1,155,269 $551,737

NOx Removal Rate % 82.2% 82.2% 59.0% 42.7% 23.7%

NOx Removed (Tons) 2010 2010 1443 1044 580

NOx Emission Rate (Tons) 435 435 1003 1401 1866

NOx Emission Rate (lb/MMBtu) 0.083 0.083 0.191 0.267 0.355

First Year Cost ($/ton removed) $2,721 $2,386 $1,038 $1,106 $952

Incremental Cost ($/ton) $7,001 $5,813 $860 $1,299 $952

$M/dv Improvement at Grand Canyon 7.442 6.525 2.378 2.063 1.152

98th Percentile ∆dV Reduction at Grand Canyon 0.735 0.735 0.63 0.56 0.479

Reid-Gardner Unit 3 ROFA w/SCR LNB w/OFA & SCR ROFA w/Rotamix LNB w/OFA & SNCR LNB w/OFA

Capital Cost $38,484,900 $35,048,000 $7,884,900 $6,945,500 $4,448,000

Total Annual Cost $5,401,669 $4,717,944 $1,379,809 $1,082,582 $551,737

NOx Removal Rate % 78.2% 78.2% 38.3% 29.9% 6.5%

NOx Removed (Tons) 1774 1774 869 678 147

NOx Emission Rate (Tons) 494 494 1400 1590 2121

NOx Emission Rate (lb/MMBtu) 0.098 0.098 0.278 0.316 0.421

First Year Cost ($/ton removed) $3,045 $2,660 $1,588 $1,596 $3,742

Incremental Cost ($/ton) $4,444 $3,688 $1,560 $1,000 $3,742

$M/dv Improvement at Grand Canyon 8.285 7.236 2.684 2.232 1.356

98th Percentile ∆dV Reduction at Grand Canyon 0.652 0.652 0.514 0.485 0.407

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Attachment to Comment 28 (FS) response: 

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Comments

Section 1: Overview 

Overall, we commend the State of Nevada on the content and presentation of the materials 

contained within the draft Regional Haze SIP. The organization of the material facilitated the 

review. 

Section 1 provides an overview of the regional haze rule and requirements. Within this section it 

seems appropriate to discuss the relationship of the regional haze program to other state air 

permitting programs such as the Prevention of Significant Deterioration program. We note that 

the PSD program can be an effective tool to prevent degradation of "Best Days," and that new 

sources should be consistent with or accounted for in RH SIP revisions. 

Section 4: Visibility and Source Apportionment Modeling 

Table 4-4. A foot note should be added to Death Valley monitoring site to identify that it is not a 

Class I area. 

Section 5: BART 

In the BART determinations, NDEP expresses the averaging period for NOx emission limits as 

12-month rolling averages, SO2 emission limits as 24-hour averages (or 30-day average for 

Mohave), and PM10 emission limits as 3-hour averaging period. While an annual NOx limit may 

be appropriate to be protective of the National Ambient Air Quality Standard for NO2, this state 

implementation plan is designed to be protective of regional haze, which is an instantaneous 

phenomenon as experienced by a visitor to a national park or wilderness area. As such, we 

believe a shorter averaging period needs to be defined for NOx limits. 

The EPA BART rule specifies a 30-day rolling average as appropriate for NOx presumptive 

limits for electric generating units. Additionally, model-predictions of haze are based upon 24- 

hour averages. As such, we request NDEP to specify a shorter averaging period and 

corresponding NOx limit to be consistent with the EPA rule. 

Section 7: Long-Term Strategy for Nevada 

Please clarify that NDEP will revisit Nevada Cement, Fernley Plant during its mid-term review 

(5 years after EPA approval of the SIP) to clarify if the facility has been shut down or if not, to 

consider emission reductions as part of its reasonable further progress goals for Class I areas 

within and adjacent to Nevada. 

Section 7.7: Smoke Management Plan 

Please use caution in citing or referring to other legally binding documents, which if modified 

may require re-opening the regional haze SIP. For example, please cite and use the Clean Air Act 

in terms of following the emission reduction and mitigation objectives instead of using an MOU 

between effected agencies. This will reduce the need to modify the RH SIP, should the MOU 

which only lasts 5 years, be modified, or expired? 
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Since anthropogenic fire and prescribed burning constitute a very small component of haze, the 

Forest Service would like to ensure that these practices are not unnecessarily regulated. As the 

Forest Service has responsibility both to ensure protection of wilderness areas and to restore fire 

as a natural component of the ecosystem, we continue our desire in working with NDEP in 

implementing any changes to their smoke management program. 

To aid in the public's understanding, please include a map showing the region within 15 miles of 

the specific areas (i.e., class I areas, smoke sensitive areas, and non-attainment areas) which have 

smoke management restrictions. 

As the terminology may sometimes be confusing, please segregate out what is required by the 

open burning regulation and what's required for prescribed burning. 

Section 7.9: Long-Term Strategy 

While Jarbidge WA is projected to meet the 2018 URP, other Class I areas in adjacent states 

affected by emission sources in Nevada are not projected to meet the 2018 URP. 

Nevada analyzed its contribution to impacts in Class I areas in neighboring states and presented 

its analysis in Section 7.9.3.2. Please expand this table to include the Hoover, CA IMPROVE 

monitoring site. 

Section 8: Monitoring Strategy 

Please specify the frequency in which Nevada commits to updating its statewide emissions 

inventory. 

Section 9: Coordination, Future Commitments and Requirements 

Based upon the source apportionment of sulfates and nitrates for the worst-case days, the Forest 

Service encourages Nevada to work with Idaho in identifying strategies to reduce impacts from 

area sources of nitrate and point sources of sulfates in Idaho to the Jarbidge Wilderness area. 
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