# APPENDIX C

FEDERAL LAND MANAGEMENT AGENCY

COMMENTS AND NEVADA’S RESPONSE

# C - 1 

# Appendix C Federal Land ManagementAgency 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 Ma nagers (FLMs) with a draft Regional Haze State Implementation Plan (SIP) for a 60-day re view. 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 Agricu lture Forest Service (FS) on March 4, 2009.

Nevada replied to the FLMs on April 17, 2009 w ith 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 th e FLM comment letters follow the set of comments and responses.

EXECUTIVE SUMMARY

COMMENT 1 (FS): Within this section it seems appropriate to discuss the re lationship of the regional haze program to other state air pe rmitting 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 ne w 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) noti ng the value of Nevada’s existing PSD and NSR programs to the regional haze program. In a ddition, we wish to point to Chapter Seven, 2 nd 

# paragraph of section 7.1 (Long-Te rm Strategy Overview), and 1 st 

# paragraph of section 7.9.2 (Additional Emissions Control Programs), where Ne vada 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 im portant 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 th e controls NDEP is implementing under BART. If that is the case, an acknowle dgement 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) describe s the development of these inventories in detail, but the most

# C - 2 significant feature of the PRP18a i nventory, as it relates to this comm ent, is that it incorporates presumptive BART emission limits for BA RT-eligible coal-fired EGUs for SO 2 

# only and not for NO x 

# . Text was added to Chapter Three, Sectio n 3.8, to clarify that Plan02d and PRP18a were used for the figures and tables. In addition, text was also adde d to Section 3.8.2 to clarify that BART controls for NO x 

# were not included in the PRP18a inventory.

Additional emissions reductions for both SO x 

# and PM 10 

# , beyond those identified in PRP18a, due to the implementation of BART controls on Ne vada 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 th at it is indefinitely postponing construction due to current economic conditions and increasing regulatory uncertainties (see press release at http://www.lspower.com/N ews/newsArticle030509.htm ), which may result in additional emissions reductions from the PR P18a inventory. LS Power s till 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 inve ntory until the application is withdrawn.

With respect to the geographic location of the sources of emi ssions, Chapter Three, Section 3.8, shows region-wide emissions expressed in th e 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 th e data to assess the regions of Nevada which may potentially contribute to the visibility im pairment 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 th e 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 descript ion of the sources that impact Jarbidge Wilderness and of the sources in Nevada t hat affect visibi lity 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 lik ely 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 impa irment for most Class I areas outsi de of the State. If current emissions projections and BART c ontrols 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.

# C - 3 RESPONSE: Chapter Four focuses on visibility a nd source apportionment and may not be the place to discuss the review of new source deve lopment. 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 co mments. 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 on ly in Table 4-4 but also Table 4-3. These tables identify Nevada’s nitrate and sulfat e extinction contribution to Class I areas outside of Nevada, respectively. Since Death Valley Na tional 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, SO 2 

# emission limits as 24-hour averages (or 30-day average for Mohave), and PM 10



# emission limits as 3-hour averaging period. While an annual NO x 

# limit may be appropriate to be protective of the National Ambient Air Quality Standard for NO 2 

# , this state implementation plan is design ed to be protective of regional haze, which is an instantaneous phenomenon as experien ced by a visitor to a national park or wilderness area. As such, we believe a shorte r averaging period needs to be defined for NO x 

# limits.

The EPA BART rule specifies a 30-day rolling average as appropriate for NO x 

# presumptive limits for electric generating units. Additionally, model-predic tions of haze are based upon 24- hour averages. As such, we request NDEP to specify a shorter averaging period and corresponding NO x 

# limit to be consistent with the EPA rule.

RESPONSE: The EPA BART rule specifies that the BA RT determination for fossil fuel fired power plants having a total gene rating 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 de terminations (i.e., the NV Energy units) are less than this generation threshold a nd 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 fo r the NV Energy units to provide operational flexibility for sources. For MGS, in additi on to the 12-month rolling average Nevada BART establishes a mass emission rate av eraged over a 1 hour period for NO x 

# . 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

# C - 4 achieve the equivalent mass emissi on 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 protec ted. Nevada believes that the NO x 

# averaging periods specified in the SIP ar e 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 th e control technology aspects of the sources subject to BART and subsequent BART determ inations, 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. Wh ile 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 contro l efficiency, the slope of the cost curve will also increase. For this reason, rigid use of incr emental cost effectivenes s 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 alte rnatives cannot be used by itself to argue one dominant alternative is preferred to another.” Instead, it should be used to compare closely performing options. (footnot e: 40 CFR Part 51 Appendix Y, “Guidelines for BART Determinations Under the Regional Haze Rule” Pa rt IV(D)(4)(e): “You should consider the incremental cost effectiveness in combinati on with the average cost effectiveness when considering whether to eliminat e a control option.” And (IV) (D)(4)(g): “You should exercise caution not to misuse these [average and incremental cost effectiv eness] techniques...[but consider them in situation where an option s hows]...slightly greater emissions reductions...”)

RESPONSE: NDEP did consider the incremental cost s 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 id entified in the BART analysis consistent with Appendix Y, Part IV(D)(4)(e)(2). We then c onsidered the breaks in the combined economic factors to identify the BART control technology fo r further evaluation. The cost data from the NV Energy facilities is presente d in Table 1, attached.

For example, at Reid Gardner Unit #1 the control option identified as NO x 

# BART, ROFA with Rotamix, has capital costs of nearly $8 million, control cost of approximately $1100 per ton and

# C - 5 incremental cost of just over $800 per ton reducing NO x 

# emissions by 1308 tons from baseline emissions. The next most stringent control optio n, LNB with OFA and SCR, has capital costs of more than $35 million (more than 4 times great er), 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 ba se 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 concer n is that NDEP does not appear to have given much weight to the visibility benefits that c ould 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 a ppears to be great inconsistency among the costs and visibility benefits that woul d result from the various control strategies chose by NDEP as representing BART.

We are focusing our comments on the BART determ ination for the Reid Gardner (RG) facility operated by NV Energy (NVE) since it has larg er 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 re sponse above. As USDOI pointed out in their initial comm ents 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 ourevaluation of visibility improvement due to the various proposed BART control scenarios.

However, Table 5-4 in each of NV Energy’s BA RT analysis reports compares the modeled visibility improvement for each proposed NO x 

# control scenario at the closest Class I area. These data were considered by NDEP in our evaluation of BART contro ls 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 c hoose not to analyze the other Class I areas any further as additional analyses might be unwarra nted.”. These tables show clear breaks in visibility improvement, annualized costs, and co st per deciview reduction, paralleling those reflected by the cost factors. All of these data were consider ed in NDEP’s identification of BART. Table 1, attached, compile s and presents the cost and visibility improvement data considered by NDEP.

The modeling conducted by NV Energy does not al ways reflect the BART emission limits proposed by NV Energy, especially for NO x 

# and PM 10 

# . NV Energy’s consideration of NDEP’s comments regarding their initial identification of BART limits resulted in NV Energy identifying more restrictive NO x 

# emission limits in their final BART an alysis 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 emi ssion 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).

# C - 6 Chapter 5, Table 5-8 of Nevada’s regional haze SI P, 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 improveme nt resulting from BART implementation in Nevada. In general, there is a linear relationship between CA LPUFF modeled visibility and emission rates. The visibility improvement resu lting 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 (SO 2 

# ). We are pleased that the proposed SO 2 

# 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 lo w (0.05 lb/mmBtu) actual annual SO 2 

# 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 de termine 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 av erage emission rate calculated using annual emissions data. If that ratio hol ds true for the units at RG, the facility ma y be able to meet a 24- hour average emissions limit of 0.10 lb/mmBtu or lower.

RESPONSE: Although the proposed BART SO 2 

# emission rates for Reid Gardner 1 

# are higher than baseline emissions (in lb/MMBtu), NDEP has identified SO 2 

# BART controls for Reid Gardner in consideration of the CAA factors, as well as uncertain ties in future coal supply for this facility and changes in boi ler operation from the current pr essurized operation to balanced draft operation. NDEP has opted for a less string ent 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 SO 2 

# . It is the nature of the scrubbers a nd 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 opera ted in their highly-efficient historic manner and do not see the need to impose an additional limit outside of re gulatory 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 NDE P’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 th e proposed 24-hour limit would become the most stringent SO2 lim it applicable to this facility. As a consequence, there appears to be no other constraint on RG that would prevent it from operati ng continuously at that

1 

# After Nevada’s response to FLM comments on the 60-d ay consultation draft of Neva da’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 SO 2 

# emission limits for units 1, 2 and 3 from 0.25 to 0.15 lb/10 6 

# Btu, 24-hour average, has been submitted to the State Environmental Commission for presentation at their December 9, 2009 H earing. See Appendix A for details.

# C - 7 emission limit, and this could result in subst antially 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 emi ssions from increasing. In addition to a morestringent 24-hour limit, we also suggest th at 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 change s 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 filtera ble PM10, no justificati on 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 actualstack 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 Domi nion Power for it Southwest Virginia Hybrid Energy Center that limits filte rable 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 PM 10 

# emission rate shown is equal to the fabric filter vendor guarantee.” (section 2.0) and Table 2-1 lists 0.015 lb/MMB tu, “A fabric filter retrofit pr oject 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/MMB tu.” (section 3.2.3.2), and “The guaranteed PM 10 

# 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 BA RT is in line with new construction Prevention of Significant Deterioration (PSD) Best Availa ble Control Technology (BACT) determinations. For example, NDEP has three coal-fired EGU’s th at have conducted BACT analyses that have undergone public review in the last two years. One plant selected a PM 10 

# (filterable) BACT of 0.02 lb/MMBtu on a 24-hour average. Another se lected 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 ha ve 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 (A ppendix Y) has not identified specific reference to control of condensable particul ate matter under BART. The Guidelines do make reference to direct particulat e matter emissions for determin ing whether sources cause or contribute to visibility impairment. In addi tion, no guidance has been provided on how to

# C - 8 evaluate whether condensable PM 10 

# is a significant component of particulate matter that causes or contributes to visibility impairment at any Class I area.

Additionally, at this time ther e is no post-combustion technology to directly control condensable particulate emissions. Condens able emissions can be contro lled through application of combustion controls and the control of precursor s 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 BA RT 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. How ever, 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 cont rol efficiencies, are proposed for Unit #3.

RESPONSE: NV Energy discusses control cost and e xpected 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 esti mates 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 br oadly classified as Ameri can 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 ra nge of cost estimates to be included in the BART analysis. They are primarily a resu lt 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, obtain ing engineering and construction in formation 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 al so 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 informati on, 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 ob taining vendor emission guarantees and associated equipment/construction costs at this stage of analys is when retrofitting older boiler units. Site specific engineering is required on a “unit by unit” basis to determine the most effec tive 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

# C - 9 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: El iminate 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 explai ns the use of different baseline emissions (in lb/MMBtu) as the startin g 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. Th erefore, NDEP had no reason to question the higher NO x 

# control efficiencies for one unit over the other. It is also bene ficial 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 c ontrols indicates that typical NOx reduction efficiencies range between 15 and 63 percent. We request that NDEP review the effectiveness assumptions in its BART determ ination and provide s upport for variations from engineering

norms.

RESPONSE: NV Energy has proposed combustion controls for Reid Gardner with NO x 

# 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, pr ovided 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 pos ition that the effectiveness as sumptions presented by NV Energy do not vary significantly from e ngineering norms based on the information presented by USDOI. Therefore, no additional support ma terials will be provi ded. 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 Selectiv e Catalytic Reduction (S CR) technologies could reduce NOx emissions to 0.085 lb/mmBtu, result ing in a 77 percent reduction of potential emissions. Our review (provided in Appendix B) of eastern coal-f ired 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 operatio n. 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 reque st that NDEP review its a ssumption regarding achievable emissions limits for a combina tion of combustion controls and SCR and provide support for any annual rate higher than 0.06 lb/mmBtu.

# C - 10 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 simila r data. Note the differences in annual heat input and NO x 

# 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 emi ssion 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 engineeri ng 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 th e combination of combustion control and SCR are $278 per kilowatt (kW) of ener gy output. Those costs are higher than any real-world costs found in available literatu re. (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 th at RG would experience any exceptional BART retrofit costs. As a result, th e 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 es timate 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 co st estimates for SCR at RG are also lower thtn the BART strategies proposed by North Dako ta 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 reque st 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 th ese 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 cap ital 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 EP A Control Cost Manual approach, NDEP has issue with the use of the “N PS 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

# C - 11 version of EPA’s Control Cost Manual for num erous reasons, the most obvious being that the modifications are unilateral by th e 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 En ergy are not overestimated but are in line with other proposals across the natio n (when compared with those li sted in Appendix C) and it is therefore not necessary to provide additiona l 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 Nitr ogen Oxides) identifying the problems with securing cost and emission data from vendor s without formal contracts in place.

It is also our position that the se lection of BART is specific to the individual facility based on expected emission rate, emissions performance le vel, expected emissions reductions, costs of compliance, energy impacts, non-air quality e nvironmental impacts and modeled visibility impacts. Control costs at ot her 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 alternativ es to the costs and benefits i nherent 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 milli on 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 SC R scenario at RG are well w ithin 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 Appendi x E) (footnote: Appendix E to our comments contains proposals to reduce NOx, SO2, and PM 10, either individually, or in combination. While it may be relevant to cite cost/ton of pollu tant 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 di fferent from a dv of improvement due to reducing SO2 or PM10.) are le ading us to the conclusi on 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 de termined that Low-NOx Burners plus Flue Gas recirculation represent BART for Tr acy Unit #3. NVE estimated, in its BART submittal, that this option would result in a cost-e ffectiveness value of $10 million per dv.) The NVE analysis suggests that, at $7 million pe r dv, RG could install the RO FA/combustion control plus SCR scenario at a much more favorable cost-per-dv e ffectiveness 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 effici ency of the equipment an d lower costs equate to a $3 million cost per dv of improvemen t 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

# C - 12 facilities [see Appendix Y Part IV(D)(5)], as discussed in our response to USDOI comments above. Tabulated model results, shown on attach ed Table 1, clearly iden tify breaks in the visibility impacts (both number of days and pe rcent deciview reduction), total annualized costs and $/dv reduction consistent with the br eaks observed in the cost factors.

NDEP takes exception to the statement “...acce pting the (likely overstated) costs and underestimated benefits...”. Nevada has demonstr ated, using data provid ed by USDOI, that the control costs are in line with BA RT proposals at a variety of f acilities across th e 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 m easure 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 provi ded 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 f acility 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 modi fied Control Cost Manual, as stated in our responses above, and so NDEP choo ses not to address the comments related to Appendix D. No changes were made to the SIP textas 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 mode ling results showing that the faci lity causes or contributes to visibility impairment at three Cl ass I areas, (footnote: RG caus es visibility impairment at Grand Canyon National Park, and contributes to visib ility 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 visibil ity 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 pr esent and discuss the visibility improvement for all Class I areas within 300 km of each s ubject-to-BART facility and concludes with a discussion of the visibility improvement consid ering all Nevada BART sources in a regional context. In addition, NV Energy presented modeling results for a ll 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. Neva da anticipates greater visibility improvement than that modeled by NV Energy consistent with the data presented in Table 5-8 of Nevada’s

# C - 13 SIP, which lists the WRAP baseline emission ra tes, 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 reduci ng 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 RGare reduced, the benefits willbe 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, ne ither NVE nor NDEP have explained how they incorporated this information on impacts upon al l Class I areas into their BART decision. For example, the Oregon Department of Environmenta l 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 insta ll a dry scrubber and SCR. As part of its BART determination, ODEQ evaluated the benefits of various control strate gies 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 ap proach to estimating visibility impairment. As such, they require several assumptions, simplifications, an d 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, especia lly 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 sim ilar 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 consider ation 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 applicati on of the ROFA/combustion control plus SCR scenarios. We would be pleased to work with ND EP to further develop this approach.

RESPONSE: Chapter Five, section 5.2 Dispersion M odeling Results, Table 5-3 and Figures 5-1 through 5-2, presents the visibility improvementresulting from implementation of the BART limits proposed by NV Energy in their BART Analys is reports for Reid Ga rdner. 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 th e 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 evalu ated thos e NDEP determinations, we observed that there w e re some apparent discre pancies between the levels of control that the sources said were achievable by a given control strategy and th e level of control assumed by NDEP in its determina tio n. For example, the tabl e below pres ents th e NOx limits used by the sources as they evaluated the control technolog ies 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 so urces in evaluating those control strategies. (There also appear to be some discrepancies among the Tracy Unit #3 emission rates, control efficiencies, and visibility im provements presented by the source and discussed and adopted by NDEP. )

RESPONSE : The short answer is that both NDEP and NV Energy appliedcontro l efficiencies to calcu late emission rates, however the baseline emission rates used we re different. NDEP independently arrived at the pr oposed BART li mits based on data reported to the EP A Clean Air Markets Division (acid rain data) and in form ation presented by the sources.

Nevada discusses the analyses of BART controls in section 5.5, Summ a r y of BART Control Analyses of our region al haze SIP. This section includes a d i scussion of the m e thodology

employed in the determ ination of baseline emissions and BART e m ission lim its. A sim ilar explanation is presented in NDEP BART review docum ents (see NDEP Analysis section under Step 5). Of note is NDEP’s determ ination of base line em issio n s scenar ios utilizing acid rain da ta for NO x 

# and SO 2 

# and annual em ission data reported to NDEP for PM 10 

# . The m a jor difference between NDEP’s and NV Energy’s calculation of BART e m ission lim its is the cho i ce of the baseline em issions. NV Energy’ s co ntrol efficiencies were applied to NDEP’s baseline

em issions, in lb/MMBtu, to calcu late the proposed BART e missi on rates presented in Chapter Five.

Generally, DOI is concerned that the level of control assum e d by NDEP is disparate from the levels of control that the s ources stated were achievable by a given control strategy. The requested ex planations for the d i fferences are id entified by DOI’s table. Specifically, DOI asks why the NDEP estim ate and the source estim a te are not the s a m e

.

C - 14

# C - 15 In Chapter 5 of NDEP’s BART report, NDEP explai ns that a different base line data set is used based on data reported to the EPA Clean Air Mark ets 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 NO x 

# for each BART eligible unit as proposed by the source to establish the BART NO x 

# 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 co st-effective to spend $10 million per dv to apply Low-NOx Burners plus Fl ue Gas recirculation at Tracy Unit #3, then application of that same criteri on to the other proposals would re sult in determinations that lower emission rates could be achieved. We al so 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 res ponse to FLM comments, cost per deciview of visibility improvement is not a required m easure 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 emi ssion control technology available, the costs of compliance, the energy and non-air environmental impacts of complia nce, any pollution control equipment in use at the source, the remaining usef ul 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 BA RT for Tracy Unit 3 witha cost effectiveness of $2,383 per ton, incremental cost of $1,952 pe r 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 hi ghest 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, show s BART controls for Reid Gardne r 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 Na tional Park, and capital costs of $7.9M for a visibility improvement of 0.514 to 0.63 dv at th e Grand Canyon (the closest Class I area). Analysis of these data suggest some of the pr oblems 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 progr ess 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 ot her 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 reas onable 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 determ ination 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 visibi lity 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 no tes that reductions in anthropogenic emission is consistent with Nevada’s share of emissions reduc tions to meet RPG’s of Class I areas in other States. While these conditions are laudable and fo rm key aspects of what is an appropriate longterm strategy, there needs to be a more rigorous assessment of what additi onal 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 bas ed 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 indica tes that reductions in Nevada address its share of visibility impairment from key anthropogenic po llutant 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 st rategies on a dollar-per-ton basis with baseline emissions reduction programs would suffice if costs are extremely high for the amount of visibility improvemen t likely to occur.

RESPONSE: NDEP has added citations from USEPA’s June 2007 Guidance for Setting Reasonable Progress Goals Unde r 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 th e text of section 6.7, Demonstration That the RPG for Worst Days is Reasonable, explaining th at 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 Ne vada’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 ar e negative implying that Nevada’s contribution to those areas is moving in the wrong direction.

Given the uncertainties of future projections, espe cially the type and placem ent of future energy sources, we request the long-term strategy co ntain a statement that new source review and prevention of significant deterioration program s are key components of a regional haze plan

# C - 17 designed to improve current vi sibility 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 potenti al data and noted the description of the WEP methodology and its limitations presented in Chap ter 1 (section 1.3.3.2). The new text also references figures in Chapter Three showing a map of gridded SO 2 

# emissions for the WRAP region (Figure 3-10) and a breakdown of Nevada SO 2 

# emissions by county (Figure 3-11) which provide data to assess the regions of Neva da which maybe contribu ting 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 inventor y and modeling scenarios, including WEP, are conservative portrayals of the visibility imp acts 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 re sponses are reproduced below from Appendix F of California’s Regional Haze SIP:

Comment: Nevada has a significant impa ct on several California Class 1 Areas, so the SIP should note that those areas rely on Nevada sufficiently addressing their contribution in or der to achieve reasonable progress. Response: California does not character ize 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 co ncentrations of nitrates and sulfates attributable to Nevada sources are gene rally less than 10 percent of the total concentrations of nitrates and sulfates in each of the California sub-regions. However, when these concentrations ar e converted to per cent contribution to total light extinction for the worst days annual average, their impact drops to barely 1 percent of to tal 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 m odeling 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 per cent 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.

# C - 18 Nevada has modified text in the 4 th 

# paragraph on page iv of th e Executive Summary and the 2 nd 

# paragraph on page 7-2 of section 7.1 Long-Term Strategy Overview to re late Nevada’s NSR and PSD permitting programs to regional haze. We have also noted the relationship between our permitting program and regional haze in S ection 7.6 Source Retirement and Replacement Schedule on page 7-7, and the 1 st 

# paragraph of section 7.9.2 A dditional Emissions Control Programs, page 7-14.

COMMENT 24 (FS): Please clarify that NDEP will revi sit Nevada Cement, Fernley Plant during its mid-term review (5 years after EPA approv al of the SIP) to clarify if the facility has been shut down or if not, to consider emissi on reductions as part of its reasonable further progress goals for Class I areas w ithin 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, th is facility is not subject to a full BART determination. Thus, this source, along with all other Ne vada sources will be reviewed during Nevada’s adequa cy determination as part of its five-year progress report. Chapter Nine (sections 9.3 Commitment to Pr ogress Reports and 9.4 Determination of Current Plan Adequacy) explains this process and potential actions. No modificati ons 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 s ources in Nevada are not projected to meet the 2018 URP. Nevada analyzed its contribution to im pacts 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-ope ning 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 effe cted 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. Ho wever, 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 sp ecific areas (i.e., class I area s, smoke sensitive areas, and nonattainment areas) which have smoke management restrictions.

RESPONSE: Nevada’s Smoke Management plan iden tifies 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, hos pitals, nursing homes, airports, recreational

# C - 19 areas, and other locations that may be sensitiv e to smoke impacts for health, safety, and/or aesthetic reasons”. The electr onic 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 regi ons 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 regulati on and what's required fo r prescribed burning.

RESPONSE: Section 7.7 in Chapter Seven has been re written to clarify what types of open burning are regulated under the Ne vada 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 (F IP) 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 a ccomplish 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 PM 10 

# , SO 2 

# and NO x 

# . Nevada’s Regional Haze (RH) SIP in effect supersedes the FIP, in that the BART require ments 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 5 2.26) requires the EPA, in cooperation with the appropriate FLM, to monitor visibility within ea ch visibility protecti on area in the state. Accordingly, the FLMs operate the IMPROVE progr am which addresses visibility monitoring at the Jarbidge WA. The IMPROVE network also a ddresses visibility mon itoring at Class I areas outside the state. Nevada’s RH SIP commits to continue using the IMPROVE monitoring data to evaluate progress toward achieving th e 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.

# C - 20 COMMENT 31 (FS): Specify the frequency in which NV commits to updating its statewide emissions inventory.

RESPONSE: Nevada updates its point s ource emission inventory for major sources every year as required by USEPA. In addition, Nevada upda tes its entire emission inventory every three years as required by USEPA for the National Em ission 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 id entification of the uncertainty contained in Section 7.9.3.1 (page 7-16) and we request that th e NDEP commit to updating that information in the mid-term reporting required by the Regional Haze Rule.

RESPONSE: Nevada has added text to Chapter Ni ne, section 9.3, “Commitment to Progress Reports,” confirming that its mid-term report wi ll include all of the required elements (from 51.308(g)(1-7)), as well as a reassessme nt of the uncertainty in the data.

COMMENT 33 (NPS-FWS p.4): As already noted under the long-te rm strategy comments, there is uncertainty regarding future emissions proj ections from both existing and new sources, so future review requirements are a crucial part of the long-term strategy a nd 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 a nd progress reports) and modified as necessary. This is noted in the Executive Summary, sections on the long-ter m 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 encourage s 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 co mmits to continue to work with neighboring states that may be impacting or exp ected 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, howeverIdaho’s mobile source (both on-road and offroad) emissions of nitrate are projected to decr ease by nearly sixty pe rcent (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 populat ed counties, especially those along the Snake River Plain. Nevada recognizes the uncertainty in projecting ar ea source emissions in section 7.9.3.1, Uncertainty, page 7-16 of our SIP and believe s these same concerns apply to projecting Idaho’s emissions.

Idaho’s point source emissions of SO 2 

# are projected to decrease by more than forty percent (7,600 tons). Additional SO 2 

# reductions are expected due to th e 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 SO 2 

# control

# and low-NO x 

# burners with over-fire air for NO x 

# control. Monsanto’s P4 f acility, located in
extrem e southeastern Idaho, is expe cted to install scrubbers for SO 2 

# control. Idaho is working with thes e f acilities to de term ine the f i nal p r ojected em issions reductions resulting from the insta lla tion of these controls.

Nevada deem s these controls as appropriate stra tegies for Idaho to reduce the impacts of their sources on the Jarbidge W ilderness Area during this initial regional haze planning period.

Table 1. BART NO x 

# Cost Factors and Visibility Im prove m e nt for NV Energy Facilities

T racy U ni t 1 L N B w/ S C R R O F A w / Ro t a m i x L N B w / F G R L N B w/ S N C R L N B C a

pi t a

l C o s t $21

, 1 75, 000 $ 7

, 3 8 9

, 835 $1, 820

, 000 $ 4

, 431, 87 5 $ 1

, 2 32, 000 T o t a l Ann u a l C o s t $2, 439

, 8 2 6 $913

, 6 36 $ 276, 6 1 1 $ 5 38, 3 5 7 $ 15 2, 66 1 NOx R e m ova l R ate % 74. 5% 4 9

. 1 % 4 1

. 1 % 31. 3% 8. 4% N O x E m is s i o n R a te (

T ons ) 56 11 2 130 1 5 2 2 0 2 NOx E m i s s i on R a t e (l b/ M M B t u) 0. 064 0

. 1 2 7 0

. 1 4 7 0. 171 0. 228 F i r s t Y e a r C o s t ( $ / t on r e m o v

e d ) $ 1 4

, 84 0 $8, 43 2 $3, 050 $ 7

, 7 9 4 $8

, 235 I n cr em en t a l C o s t ( $/ t o n ) $ 2 7

, 22 7 $ 3 6
, 082

- $ 1 2

, 1 03 $ 7

, 6 3 2 $8

, 235 $ M /d v I m pr o v e m e n t

at

De s o l a t i o n 2 8

. 704 16. 31 5 5

. 8 8 5 1 4

. 9 5 4 16

. 962 98 th Pe r c e n tile ∆ dV R e du c t i o n at D e s o l a t i on 0. 085 0

. 0 5 6 0

. 0 4 7 0. 036 0. 009 

### T racy U ni t 2 L N B w/ S C R L N B w/ SN CR R O F A w/ Ro t

a m i x L N B w/ F G R L N B C a

pi t a

l C o s t $31

, 8 12, 500 $ 4

, 6 2 4

, 375 $8, 013

, 408 $ 2

, 156, 00 0 $ 1

, 5 40, 000 T o ta l A n n u a l C o s t $3, 774

, 1 7 3 $692

, 4 11 $1, 167

, 212 $3 98, 4 2 5 $ 19 6, 52 6 NOx R e m ova l R ate % 85. 2% 5 4

. 0 % 5 2

. 0 % 51. 4% 38. 7 % N O x R e m o v e d ( T on s ) 27 3 1 73 1 6 7 1 6 5 1 2 4 NOx E m i s s i on R a t e (

T ons ) 4 7 1 4 8 154 1 5 6 1 9 7 NOx E m i s s i on R a t e (l b/ M M B t u) 0. 037 0

. 1 1 4 0

. 1 1 9 0. 120 0. 152 Fi rs t Y e a r C o s t ( $/ t on r e m o v

e d ) $ 1 3

, 80 3 $3, 99 5 $6, 994 $ 2

, 4 1 5 $1

, 582 I n c r e m e n t a l C o s t ( $ / t o n ) $ 3 0

, 778

- $73, 97 3 $ 399, 2 5 3 $ 4, 95 4 $ 1

, 582 $ M /d v I m pr o v e m e n t

at

De s o l a t i o n 1 8

. 501 5

. 0 9 1 8

. 9 7 9 3. 113 2. 160 98 th Pe r c e n tile ∆ dV R e du c t i o n at D e s o l a t i on 0. 204 0

. 1 3 6 0

. 1 3 0

. 128 0. 091 

### T racy U ni t 3 L N B w/ S C R R O F A w / Ro t a m i x L N B w / S N CR L N B w / F G R L NB Ca

p i t a

l C o s t $35

, 8 62, 500 $ 9

, 1 8 9

, 145 $4, 431

, 875 $ 2

, 072, 00 0 $ 1

, 2 32, 000 T o t a l Ann u a l C o s t $4, 397

, 2 8 1 $ 1

, 5 2 2

, 890 $ 706, 4 5 9 $ 5 74, 6 1 3 $ 17 5, 86 1 NOx R e m ova l R ate % 78. 3% 4 5

. 2 % 3 7

. 3 % 28. 8% 16. 4 % NOx R e m ove d ( To n s ) 62 2 3 59 2 9 6 2 2 9 1 3 0 NOx E m i s s i on R a t e (

T ons ) 1 72 43 5 498 5 6 6 6 6 4 NOx E m i s s i on R a t e (l b/ M M B t u) 0. 063 0

. 1 5 9 0

. 1 8 2 0. 206 0. 242 F i r s t Y e a r C o s t ( $ / t on r e m o v

e d ) $7

, 067 $4, 24 0 $2, 383 $ 2

, 5 1 1 $1

, 349 I n c r e m e n t a l C o s t ( $ / t o n ) $ 1 0

, 928 $1 3, 005 $1, 9 5 2 $ 4, 04 7 $ 1

, 349 $M / d v I m p r o ve m e nt

at

D e s o l a tio n 29

. 315 17. 50 4 9

. 8 1 2 1 0

. 2 6 1 5. 496 98 th Pe r c e n tile ∆ dV R e du c t i o n at D e s o l a t i on 0. 150 0

. 0 8 7 0

. 0 7 2 0. 056 0. 032



### F t

. C h u r ch il l 1 L N B w/ S C R R O F A w / Ro t a m i x L N B w / S N CR L N B w / F G R L NB C a

pi t a

l C o s t $35

, 7 81, 250 $ 5

, 2 5 0

, 940 $4, 416

, 563 $ 1

, 610, 00 0 $ 1

, 0 50, 000 T o t a l Ann u a l C o s t $4, 499

, 8 5 3 $ 1

, 6 6 9

, 757 $ 893, 2 0 3 $ 4 90, 9 6 9 $ 15 6, 55 9 NOx R e m ova l R ate % 87. 4% 6 5

. 7 % 6 2

. 1 % 56. 7% 49. 5 % NOx R e m ove d ( To n s ) 105 7 7 9 4 751 6 8 6 5 9 8 NOx E m i s s i on R a t e (

T ons ) $15 2 $ 415 $45 8 $524 $ 611 NOx E m i s s i on R a t e (l b/ M M B t u) 0. 056 0

. 1 5 2 0

. 1 6 7 0. 191 0. 223 Fi rs t Y e a r C o s t ( $/ t on r e m o v

e d ) $4

, 259 $2, 1 0 2 $1, 1 9 0 $716 $ 262 I n c r e m e n t a l C o s t ( $ / t o n ) $ 1 0

, 787 $1 7, 842 $6, 1 6 1 $ 3, 84 2 $ 262 $ M /d v I m pr o v e m e n t

at

M oke l u m n e 9

. 000 na 2. 46 7 1

. 479 0. 529 98 th Pe r c e n tile ∆ dV R e du c t i o n at M o ke lu m n e 0

. 500 na 0. 36 2 0

. 332 0. 296 

### F t

. C h u r ch il l 2 L N B w/ S C R R O F A w / Ro t a m i x L N B w / S N CR L N B w / F G R L NB Ca

p ita

l C o s t $35

, 7 81, 250 $ 9

, 1 8 9

, 145 $4, 416

, 563 $ 1

, 610, 00 0 $ 1

, 0 50, 000 T o t a l Ann u a l C o s t $4, 480

, 5 1 4 $ 1

, 6 3 9

, 078 $ 862, 1 4 2 $ 4 90, 9 6 9 $ 15 6, 55 9 NOx R e m ova l R ate % 86. 4% 6 3

. 0 % 5 9

. 1 % 53. 2% 45. 4 % N O x R e m o v e d ( T on s ) 74 5 5 43 5 1 0 4 5 9 3 9 1 NOx E m i s s i on R a t e (

T ons ) 1 17 31 9 353 4 0 4 4 7 1 N O x E m is s i o n R a te (lb /M M B tu ) 0. 045 0

. 1 2 3 0

. 1 3 6 0. 155 0. 181 F i r s t Y e a r C o s t ( $ / t on r e m o v

e d ) $6

, 014 $3, 01 7 $1, 692 $ 1

, 0 7 0 $ 400 I n c r e m e n t a l C o s t ( $ / t o n ) $ 1 4

, 082 $2 3, 103 $7, 2 9 6 $ 4, 97 2 $ 400 $ M /d v I m pr o v e m e n t

at

M oke l u m n e 1 1

. 258 na 3. 15 8 2

. 012 0. 771 98 th Pe r c e n tile ∆ dV R e du c t i o n at M o ke lu m n e 0. 398 na 0. 27 3 0

. 244 0. 203 NO x Con t r o l



# C - 21

### Re i d

- G a r d n e r Uni t 1 R O FA w/ S C R L N B w/ O F A & S C R R O F A w / R o t

a m i x L NB w / O F A & S N C R L N B w / O F A C a

pi t a

l C o s t $38

, 4 84, 900 $35, 04 8, 000 $7, 884

, 900 $ 6
, 945, 50 0 $ 4

, 4 48, 000 T o t a l Ann u a l C o s t $5, 394

, 7 4 6 $ 4

, 7 4 6
, 852 $1, 450

, 193 $ 1

, 132, 86 0 $ 55 1, 73 7 NOx R e m ova l R ate % 81. 6% 8 1

. 6 % 5 7

. 7 % 40. 9% 21. 3 % NOx R e m ove d ( To n s ) 185 0 1 850 130 8 9 27 48 3 NOx E m i s s i on R a t e (

T ons ) 4 17 41 7 959 1340 1 784 NOx E m i s s i on R a t e (

l b/ M M B t u) 0. 085 0

. 0 8 5 0

. 1 9 5 0. 273 0. 364 Fi rs t Y e a r C o s t ( $/ t on r e m o v

e d ) $2

, 916 $2, 56 6 $1, 109 $ 1

, 2 2 2 $1

, 143 I n c r e m e n t a l C o s t ( $ / t o n ) $ 7

, 280 $6, 0 8 5 $83 3 $ 1, 30 8 $ 1

, 143 $ M /d v I m pr o v e m e n t

at

Gr and C any on 7. 729 6

. 8 0 1 2

. 4 5 2

. 174 1. 254 98 th Pe r c e n tile ∆ dV R e du c t i o n at Gr a nd C any o n 0. 698 0

. 6 9 8 0

. 5 9 2 0. 521 0

. 44 

### Re i d

- G a r d n e r Uni t 2 R O FA w/ S C R L N B w/ O F A & S C R R O F A w / R o t

a m i x L NB w / O F A & S N C R L N B w / O F A Ca

p ita

l C o s t $38

, 4 84, 900 $35, 04 8, 000 $7, 884

, 900 $ 6
, 945, 50 0 $ 4

, 4 48, 000 T o t a l Ann u a l C o s t $5, 469

, 6 2 6 $ 4

, 7 9 5

, 602 $1, 498

, 001 $ 1

, 155, 26 9 $ 55 1, 73 7 NOx R e m ova l R ate % 82. 2% 8 2

. 2 % 5 9

. 0 % 42. 7% 23. 7 % NOx R e m ove d ( T o n s ) 201 0 2 010 144 3 1044 58 0 NOx E m i s s i on R a t e (

T ons ) 4 35 43 5 100 3 1401 1 866 N O x E m is s i o n R a te (

lb /M M B tu ) 0. 083 0

. 0 8 3 0

. 1 9 1 0. 267 0. 355 F i r s t Y e a r C o s t ( $ / t on r e m o v

e d ) $2

, 721 $2, 38 6 $1, 038 $ 1

, 1 0 6 $ 952 I n c r e m e n t a l C o s t ( $ / t o n ) $ 7

, 001 $5, 8 1 3 $86 0 $ 1, 29 9 $ 952 $ M /d v I m pr o v e m e n t

at

Gr and C any on 7. 442 6

. 5 2 5 2

. 3 7 8 2. 063 1. 152 98 th Pe r c e n tile ∆ dV R e du c t i o n at Gr a nd C any o n 0. 735 0

. 7 3 5 0

. 6 3 0

. 5 6 0

. 479 

### Re i d

- G a r d n e r Uni t 3 R O FA w/ S C R L N B w/ O F A & S C R R O F A w / R o t

a m i x L NB w / O F A & S N C R L N B w / O F A C a

pi t a

l C o s t $38

, 4 84, 900 $35, 04 8, 000 $7, 884

, 900 $ 6
, 945, 50 0 $ 4

, 4 48, 000 T o t a l Ann u a l C o s t $5, 401

, 6 6 9 $ 4

, 7 1 7

, 944 $1, 379

, 809 $ 1

, 082, 58 2 $ 55 1, 73 7 N O x Re m o v a l Rat e % 78. 2% 7 8

. 2 % 3 8

. 3 % 29. 9% 6. 5% NOx R e m ove d ( T o n s ) 177 4 1 774 869 6 7 8 1 4 7 NOx E m i s s i on R a t e (

T ons ) 4 94 49 4 140 0 1590 2 121 NOx E m i s s i on R a t e (

l b/ M M B t u) 0. 098 0

. 0 9 8 0

. 2 7 8 0. 316 0. 421 F i r s t Y e a r C o s t ( $ / t on r e m o v

e d ) $3

, 045 $2, 66 0 $1, 588 $ 1

, 5 9 6 $3

, 742 I n cr em en t a l C o s t ( $/ t o n ) $4

, 444 $3, 6 8 8 $1, 5 6 0 $ 1, 00 0 $ 3

, 742 $ M /d v I m pr o v e m e n t

at

Gr and C any on 8. 285 7

. 2 3 6 2

. 6 8 4 2. 232 1. 356 98 th Pe r c e n tile ∆ dV R e du c t i o n at Gr a nd C any o n 0. 652 0

. 6 5 2 0

. 5 1 4 0. 485 0. 407



# C - 22

# Attachm e nt to Comm ent 28 (FS) response:

C - 23

# C - 24

# C - 25 

# Comments

Section 1: Overview

Overall, we commend the State of Nevada on th e content and presentation of the materials contained within the draft Regi onal Haze SIP. The organization of the material facilitated the review.

Section 1 provides an overview of the regional h aze 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 Si gnificant Deterioration program. We note that the PSD program can be an effective tool to prevent degradation of "Bes t 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 Valle y monitoring site to identify that it is not a Class I area.

Section 5: BART

In the BART determinations, NDEP e xpresses the averaging period for NO x 

# emission limits as 12-month rolling averages, SO 2 

# emission limits as 24-hour averages (or 30-day average for Mohave), and PM 10 

# emission limits as 3-hour averag ing period. While an annual NO x 

# limit may be appropriate to be protective of the National Ambient Air Quality Standard for NO 2 

# , this state implementation plan is designed to be protective of regional ha ze, which is an instantaneous phenomenon as experienced by a visitor to a nati onal park or wilderness area. As such, we believe a shorter averaging peri od needs to be defined for NO x 

# limits.

The EPA BART rule specifies a 30-day rolling average as appropriate for NO x 

# presumptive limits for electric generating units. Additionall y, model-predictions of haze are based upon 24- hour averages. As such, we request NDEP to specify a shorter averaging period and corresponding NO x 

# 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 ha s been shut down or if not, to consider emission reductions as pa rt 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 bindi ng 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 wi ll reduce the need to modify the 

# RH SIP, should the MOU which only lasts 

# 5 years, be modifi ed, or expired?

# C - 26 Since anthropogenic fire and prescribed burning c onstitute 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 ar eas and to restore fire as a natural component of the ecosystem, we continue our desi re in working with NDEP in implementing any changes to their smoke management program.

To aid in the public's understanding, please includ e 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 Cl ass I areas in neighborin g 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.

# C - 27

# C - 28

# C - 29

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