1



## Nebraska Department of Environmental Quality

State Implementation Plan

For Regional Haze

And Best Available Retrofit Technology (BART)

Mike Linder, Director Dave Heineman, Governor

June 30, 20112 

### Table of Contents

1 Executive Summary

................................ ................................ ................................ .............................. 5

2 Background and Overview of the Federal Regional Haze Regulation

................................ ............. 7

2.1 General Background / History of Federal Regional Haze Rule

................................ ..................... 7

3 General Planning Provisions

................................ ................................ ................................ ................ 9

4 Regional Planning

................................ ................................ ................................ ............................... 10

5 State/Tribe and Federal Land Manager Coordination

................................ ................................ ... 12

6 Assessment of Baseline and Current Conditions and Estimate of Natural Conditio ns in Class I

Areas

................................ ................................ ................................ ................................ .......................... 13

7 Monitoring Strategy

................................ ................................ ................................ ............................ 15

7.1 Current Monitoring Strategy

................................ ................................ ................................ .......... 15

7.1.1 Measuring Visibility Data

................................ ................................ ................................ ............... 15

7.1.1.1 Nebraska National Forest

................................ ................................ ................................ ............. 15

7.1.1.2 Crescent Lake Wild Life Nation al Refuge

................................ ................................ ................... 16

7.1.1.3 Omaha Tribe

................................ ................................ ................................ ................................ 17

7.1.2 Characterizing Visibility Data

................................ ................................ ................................ ........ 18

7.1.3 Data Validation and Reporting

................................ ................................ ................................ ....... 18

7.2 Special Monitoring Studies

................................ ................................ ................................ ............. 18

7.3 Future Monitoring Strategy

................................ ................................ ................................ ............ 19

8 Emissions Inventory

................................ ................................ ................................ ............................ 20

8.1 2002 Emissions Inventory Summary

................................ ................................ .............................. 20

8.1.1 Po int Source Emissions

................................ ................................ ................................ ................... 21

8.1.1.1 Electric Generating Units

................................ ................................ ................................ ............. 21

8.1.1.2 Fuel Ethanol Manufacturing Facilities

................................ ................................ ......................... 22

8.1.2 Area Source Emissions

................................ ................................ ................................ ................... 22

8.1.3 On

- road Source Emissions

................................ ................................ ................................ .............. 24

8.1.4 Non

- road So urce Emissions

................................ ................................ ................................ ............ 24

8.1.5 Biogenic Source Emissions

................................ ................................ ................................ ............. 25

8.2 2005 Emissions Inventory and Periodic Updates

................................ ................................ .......... 25

8.3 2018 Predicted Emissions Inventory

................................ ................................ .............................. 26

8.3.1 Discussion of 2018 Predicted Emissions Inventory

................................ ................................ ........ 28

8.3.1.1 Volatile Organic Compounds

................................ ................................ ................................ ....... 28

8.3.1.2 Nitrogen Oxides

................................ ................................ ................................ ........................... 28

8.3.1.3 Sulfur Dioxide

................................ ................................ ................................ .............................. 30

8.3.1.4 Particulate Matter

................................ ................................ ................................ ......................... 30

8.3.1.5 Ammonia

................................ ................................ ................................ ................................ ...... 313

9 Modeling Assessment

................................ ................................ ................................ .......................... 32

9.1 Modeling Protocol

................................ ................................ ................................ ............................ 32

9.2 Quality Assurance Project Plan

................................ ................................ ................................ ...... 33

9.3 Model Inpu ts

................................ ................................ ................................ ................................ ..... 33

9.3.1 Year Selection

................................ ................................ ................................ ................................ . 33

9.3.2 Domain

................................ ................................ ................................ ................................ ............ 34

9.3.3 Emissions In puts

................................ ................................ ................................ ............................. 34

9.3.4 Meteorological Input Preparation

................................ ................................ ................................ ... 34

9.4 Model Performance Evaluation

................................ ................................ ................................ ...... 34

10 Best Available Retrofit Technology (BART)

................................ ................................ .................. 36

10.1 Identification of BART

– Eligible Sources in Nebraska

................................ ............................. 36

10.2 Determination of Units Subject to BART

................................ ................................ .................... 38

10.3 Determination of BART Requirements for Subject

- to

- BART Sources

................................ .... 40

10.4 B ART Determination Process

................................ ................................ ................................ ....... 41

10.5 Summary of BART Determination

- OPPD

................................ ................................ ................. 42

10.5.1 Nebraska City Station Unit #1

– Not a Presumptiv e Unit

................................ ............................ 42

10.5.2 BART Determination Summary for PM

................................ ................................ ....................... 44

10.5.3 BART Determination Summary for SO 2

................................ ................................ ...................... 45

10.5.4 BART Determination Summary for NO

x ................................ ................................ ...................... 46

10.6 Summary of BART Determination

- NPPD

................................ ................................ .................. 47

10.6 .1 BART Determination Summary for PM

................................ ................................ ....................... 47

10.6.2 BART Determination Summary for NO

x ................................ ................................ ...................... 48

10.6.3 BART Determination Summary for SO 2

................................ ................................ ...................... 49

10.6.3.1 Unique Water Impacts in the Twin Platte Basin

................................ ................................ ........ 50

10.6.3.2 Platte River Recovery and Implementation Program

................................ ................................ . 55

10.6.3.3 Acquisition of Allocations and Offsets (Costs of Water)

................................ .......................... 56

10.6.3.4 Economic Impacts from Irrigated Agriculture

................................ ................................ ........... 61

10.6.3.5 Visibility Impacts

................................ ................................ ................................ ....................... 62

10.6.4 Dry Sorbent Injection (DSI) Evaluation

................................ ................................ ....................... 64

10.6.4.1 Updated BART Analysis for SO2

................................ ................................ .............................. 64

10.6.4.2 Technical Feasibility

................................ ................................ ................................ .................. 64

10.6.4.3 Eliminate technically infeasible optio ns

................................ ................................ .................... 65

10.6.4.4 Evaluate control effectiveness

................................ ................................ ................................ ... 65

10.6.4.5 Evaluate impacts and document the results

................................ ................................ ............... 65

10.6.4.6 Cost of Compliance

................................ ................................ ................................ .................... 65

10.6.4.7 Energy Impacts

................................ ................................ ................................ .......................... 66

10.6.4.8 Other (Non

- Air Quality ) Environmental Impacts

................................ ................................ ...... 66

10.6.4.9 Remaining Useful Life

................................ ................................ ................................ ............... 67

10.6.4.10 Visibility Impacts

................................ ................................ ................................ ..................... 67

10.6.4.11 SO 2 BART Determination for GGS

................................ ................................ ......................... 70

11 Reasonable Further Progress/Long Term Strategy

................................ ................................ ....... 71

11 .1 Determining Visibility Impact

................................ ................................ ................................ ...... 71

11.2 State Consultation Process

................................ ................................ ................................ ............ 82

11.2.1 Minnesota (Northern Midwest)

................................ ................................ ................................ ..... 824

11.2.2 Central States (Missouri, Arkansas)

................................ ................................ .............................. 83

11.2.3 Wichita Mountains (Oklahoma)

................................ ................................ ................................ .... 85

11.2.4 Badlands National Park and Wind Cave National Park (South Dakota)

................................ ...... 86

11.2.5 Rocky Mountain National Park (Colorado)

................................ ................................ .................. 87

11.3 Long Term Strategy

................................ ................................ ................................ ....................... 89

11.3.1 Federal Measures

................................ ................................ ................................ .......................... 89

11.3.1.1 Clean Air Interstate Rule/ Clean Air Transport Rule

................................ ................................ . 89

11.3.1.2 Mobile Source Related Emissions and Standards

................................ ................................ ...... 90

11.3.1.3 Tier 2 Vehicle and Gasoline Sulfur Program

................................ ................................ ............. 90

11.3.1.4 Locomotives and Marine Engines

................................ ................................ .............................. 91

11.3.1.5 Small Engines (Personal Watercraft; Lawn and Garden Equipment)

................................ ........ 91

11.3.1.6 NESHAP MACT Standards

................................ ................................ ................................ ....... 91

11.3.2 Visibility Requirements under the New Source Review and Prevention of Significant Deterioration Program

................................ ................................ ................................ ................................ 92

11.3.3 Measures to Mitigate the Impacts of Construction Activities

................................ ....................... 92

11.3.3.1 Water Regulations on Construction Activities

................................ ................................ ........... 93

11.3.3.2 Fugitive Dust Regulations

................................ ................................ ................................ .......... 93

11.3.4 Agricultural and Forestry Smoke Management

................................ ................................ ............ 93

11.3.5 Enforceability of Emission Limitations and Control Measures

................................ .................... 94

11.3.6 Source Retirement and Replacement Schedules

................................ ................................ ........... 94

11.3.7 Anticipated Net Effect on Visibility Resulting from Projected Changes to Emissions

................ 94

11.4 Reasonable Further Progress Conclusion

................................ ................................ .................... 95

12 Plan Revisions and Progress Reports

................................ ................................ .............................. 965

1 Executive Summary In amendments to the Clean Air Act (CAA) in 1977, Congress set a national goal to restore national parks and wilderness areas to pristine cond itions by preventing any future, and remedying any existing man

- made visibility impairment. In 1999, the U.S. Environmental Protection Agency (EPA) finalized the federal Regional Haze Rule, which aims to fulfill the goals set forth in the CAA by the year 2 064. The Regional Haze Rule addresses the combined effects of several pollution sources over large geographic areas. It was therefore necessary to use a regional planning approach.

EPA designated five regional planning organizations (RPOs); the Central Reg ional Air Planning Association (CENRAP) was designated as the RPO representing the central portion of the United States. Since its inception, the State of Nebraska has been actively involved in CENRAP. The Nebraska Regional Haze Plan incorporates data anal yses, modeling results, and technical support documents prepared for CENRAP members by various contractors. In addition, CENRAP has served as a platform for consultation between states, tribes, federal land managers (FLMs), and

stakeholders.

The federal Re gional Haze Rule requires states to submit revisions to their State Implementation Plans by December 17, 2007. The Regional Haze Rule applies to all states that contribute to visibility impairment, even those states that do not have Class I areas.

States are required by 40 CFR 51.308 to set reasonable progress goals for achieving natural visibility conditions, develop a long

- term emissions reduction strategy, and maintain a monitoring network and emissions inventory to support regional haze programs. In ad dition, Section 51.308(e) outlines the requirements for applying Best Available Retrofit Technology (BART) to certain older emission sources that were not previously regulated by the CAA.

In July of 2005, EPA published a revised final rule, including Appen dix Y to 40 CFR Part 51 ―Guidelines for BART Determinations under the Regional Haze Rule.‖ Nebraska followed these guidelines in its selection of sources that are subject to BART requirements. We further followed these rules when making determinations on control technology requirements. Appendix Y of the guidelines outlines a presumptive emission rate or percent of control for SO 2 and NO

x , for certain types of facilities, unless the state can demonstrate, based on careful consideration of the statutory fiv e factors. The five factors are: c ost effectiveness, e nergy and non

- air environmental impacts , e xisting controls at source , r emaining useful life of source , and the

d egree of visibility improvement which may be reasonably anticipated from the technology

. Nebraska has three subject

- to

- BART emission units at two facilities. One facility, OPPD Nebraska City was not subject to presumptive levels of control; however

, NDEQ used the statutory factors as a guide for making the BART determination. For the othe r facility which has two BART units, NPPD Gerald Gentleman Station, due to unique non

- air environmental impacts and cost effectiveness and relative degree of visibility improvement, NDEQ determined presumptive levels of sulfate control were not appropriate and that presumptive levels of nitrate control were appropriate. The BART requirements are outlined in Chapter 10 of this document.

In addition to requiring BART controls at subject facilities, the state also evaluated whether other

sources need to be ad dress ed at this time to reach reasonable progress goals. This analysis is referred to as the statutory factor analysis, or four

- factor analysis.6

Nebraska has no mandatory Class I areas, but in an effort to support the planning process,

Nebraska worked th rough CENRAP to coordinate regional efforts to reduce visibility at Class I areas within the CENRAP states. For areas outside the region, Nebraska consulted with other states that may have required reductions to improve visibility from emissions from Nebr aska

sources. Nebraska will continue to participate and cooperate in regional efforts to reduce visibility impairment at Class I areas outside its borders by maintaining a n IMPROVE visibility monitoring network and emissions inventory, and providing perio dic progress reports and SIP revisions as required by the Regional Haze Rule.7

2 Background and Overview of the Federal Regional Haze Regulation

2.1 General Background / History of Federal Regional Haze Rule

In amendments to the Clean Air Act (CAA) in 1977, C ongress added Section 169 (42 U.S.C. 7491) setting forth the following national visibility goal of restoring pristine conditions in certain national parks and wilderness areas, which it named Class I areas:

“ Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from man

- made air pollution. ”

Over the following years, modest steps were taken to address the visibility prob lems in Class I areas. The control measures taken mainly addressed ― plume blight ‖ from specific pollution sources, and did little to address regional haze issues in the Eastern United States. Plume blight is the visual impairment of air quality that manif ests itself as a coherent plume. This is a result from specific sources, such as a power plant smoke stack, emitting pollutants into a stable atmosphere. The pollutants are then transported in some direction with little or no vertical mixing.

When the C AA was amended in 1990, Congress added Section 169B (42 U.S.C. 7492) authorizing further research and regular assessments of progress. In 1993, the National Academy

of Sciences concluded: “current scientific knowledge is adequate and control technologies a re available for taking regulatory action to improve and protect visibility

. ” 1

In addition to authorizing creation of visibility transport commissions and setting forth their duties, Section 169B(f) of the CAA specifically mandated creation of the Grand C anyon Visibility Transport Commission (Commission) to make recommendations to the U.S. Environmental Protection Agency (EPA) for the region affecting the visibility of the Grand Canyon National Park. Following four years of research and policy development the Commission submitted its report to EPA in June of 1996. This report, as well as the many research reports prepared by the Commission, contributed invaluable information to EPA in its development of the federal Regional Haze Rule.

EPA‘s Final Regional H aze Rule was adopted July 1, 1999, and went into effect on August 30, 1999. The Regional Haze Rule aims at achieving national visibility goals by 2064. This rulemaking addressed the combined visibility effects of various pollution sources over a wide

geogr aphic region. This wide

- reaching pollution net meant that many states, even those without Class I Areas, would be required to participate in haze reduction efforts. EPA designated five regional planning organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility issue. The Central Regional Air Planning Association (CENRAP) was designated as the RPO to represent those states that make up the midsection of the contiguous

United States.

On May 24, 2002 the US Court of Appeals, DC District Court ruled on the challenge brought by the American Corn Growers Association against EPA‘s Regional Haze Rule of 1999. The Court

remanded to EPA the Best Available Retrofit Technology ( BART ) provisions of the rule, and

denied industr y‘s challenge to the haze rule goals of natural visibility and no degradation

1 Protecting Visibility in National Parks and Wilderness Areas

. National Research Council. Washington, DC: 1993.8

r equirements. EPA adopted revisions to the Regional Haze rule pursuant to the remand. To facilitate the review of this State Implementation Plan (SIP) by the Environmental Prote ction Agency (EPA), Federal Land Managers (FLM), stakeholders and the public, a guide is provided to identify where the Section 308 Requirements may be found in this document. (See Appendix

2 .1)

Appendix 2.1 Section 308 Requirements Crosswalk9

3 General Pl anning Provisions Pursuant to the requirements of 51.308(a) and (b), Nebraska submits t his SIP submission as adopted to meet the requirements of E PA‘s Regional Haze rules that were adopted to comply with requirements set forth in the Clean Air Act. Elemen ts of this Plan address the Core Requirements pursuant to 40 CFR 51.308(d) and the Best Available Retrofit Technology (BART) components of 40 CFR 50.308( e). In addition, this SIP addresses Regional Planning, State/Tribe and Federal Land Manager coordinati on, and contains a commitment to provide Plan revisions and adequacy determinations.

Nebraska has adopted this SIP in accordance with Title 115 the Nebraska Administrative

Procedures Act and 40 CFR 51.100

- 105

. The Nebraska Department of Environmental Q uality (NDEQ) provided public notice of the opportunity to comment on the SIP on December 6, 2010

. NDEQ provided notice of public hearing on December 6, 2010. NDEQ held a public hearing regarding the SIP on January 21, 2011

. All p ublic comments on this p roposed SIP , inclusive of those made by the Federal Land Manager (FLM), affected States, and Tribes were addressed and

are summarized in Appendix 3 .1. A complete copy of the public proceedings, including the affidavit of publication and the hearing trans cript may be found in Appendix 3.2.

A copy of this report is available at the NDEQ Offices, 1200 N Street Suite 400; Lincoln, NE

68509

- 8922 and on

- line at www.ndeq.state.ne.us . A notice of this report‘s availab ility for review and comment was submitted to the Omaha World Herald for general state

- wide publication on or before December 6, 2010, and on the Department‘s website. In addition,

Nebraska specifically made the States of Colorado, South Dakota, Missouri, Minnesota, and Oklahoma aware of its availability.

Appendix 3.1 Public Comments & Responsiveness Summary Appen dix 3.2 Affidavit of Publication10

4 Regional Planning In 1999, EPA and affected States/ Tribes agree d to create five Regional P lanning Organizati ons (RPOs) to facilitate interstate coordination on Regional Haze SIP/TIP s. The State of Nebraska is

a member of the Central Regional Air Planning Association (CENRAP) RPO. Members of

CENRAP are in the geographical areas listed in Table 4 .1 . Figure 4 .1 s hows a map of all five regional planning organizations.

Table 4.1 CENRAP Geographical Area *

Arkansas Iowa

Kansas Louisiana

Minnesota Missouri

Nebraska Oklahoma

Texas

*Includes both state and tribal areas

Figure 4.1 Geographical Areas of Regiona l Planning Organizations

The governing body of CENRAP is the Policy Oversight Group (POG). The POG is made up of 18 voting members representing the 9 S tate s and 3 T ribes from each EPA Region within the CENRAP region and non

- voting members representing local agencies, the EPA, the Fish and Wildlife Service, Forest Service and National Park Service. The Policy Oversight Group (POG)

facilitates communication w ith Federal Land Managers, stakeholders, the public, and with

CENRAP staff.11

Since its inception, CENRAP has established an active comm ittee structure to address both

t echnical and non

- technical issues related to regional haze. The work of CENRAP is

accom plished through five standing workgroups: Monitoring; Emission Inventory; Modeling; Communications; and Implementation and Control Strategies. Participation in workgroups is open to all interested parties , including stakeholders and the public . Ad hoc w orkgroups may be formed by the POG to address specific issues. Ultimately, policy decisions are made by the

CENRAP POG. However, SIP decisions are left to the individual State.

CENRAP has adopted the approach that the Regional Haze Rule requires the ― States to establish goals and emission reduction strategies for improving visibility in all 156 mandatory Class I parks and wilderness areas.‖ The rule also encouraged states and tribes to work together in regional partnerships.

This SIP utilizes and r efers to data analysis, modeling results and other technical support documents pre pared for CENRAP members by contractors and provided through the CENRAP

website or file transfer protocol ( FTP ) site.

By c oordinating with CENRAP and other RPOs as well as through direct consultation with other

states , Nebraska has worked to ensure that its long term strategy and BART determinations provide sufficient reductions to mitigate impacts of sources from Nebraska on affected Class I

areas.12

5 State/Tribe and Fede ral Land Manager Coordination

40 CFR Section 51.308(i) require coordination between States and the Federal Land Managers (FLMs). FLMs are an integral part of CENRAP‘s POG and the membership on standing committees. FLMs have contributed to the development of technical and non technical work as a result of that participation. In addition, o pportunities have been provided by CENRAP for FLMs to review and comment on each of the technical documents developed by CENRAP and included

in this SIP

. NDEQ provided FLMs an early opportunity to comment on the draft BART permits for NPPD and OPPD prior to finalization of the SIP. Nebraska provided agency contacts to the

FLMs as required. In development of this plan, the FLMs were consulted in accordance with the

prov isions of 51.308(i)(2).

The State of Nebraska provided FLMs an opportunity for consultation, in person and at least 60 days prior to holding any public hearing on the essential elements of the control strategies of the implementation plan or plan revisi on.

During the consultation process, the FLMs were given the opportunity to address their:

Assessment of the impairment of visibility in any Class I areas Recommendations on the development of reasonable progress goals Recommendations on the development a nd implementation of strategies to address visibility impairment.

Nebraska sent the draft Best Available Retrofit Technology permits to the FLMs in mid

- 2008 and again prior to public notice. The FLM comments on the BART permits were addressed

. No publi c hearings were requested on the BART permits. For the proposed Regional Haze SIP hearing, Nebraska notified all interested parties, including the FLMs , affected and nearby states,

and Tribes o n November 16, 2010, via email. Copies of all appendices were made available upon request via CD. This proposed SIP and appendices were also made available on our website.

Comments received from the Federal Land Managers on the proposed SIP were addressed. Copies of the letters received from the FLMs are attached. A summary of responses to their

comments are included in Appendix 3.1 and in the BART response to comments found in Appendix 10.8 to this plan.

Nebraska will continue to coordinate and consult with the Federal Land Managers during the development of f

uture progress reports and plan revisions, as well as during the implementation of programs having the potential to contribute to visibility impairment in the mandatory Class I

areas. The FLMs must be consulted in the following instances:

Development and review of implementation plan revisions

Review of 5

- year progress reports Development and implementation of other programs that may contribute to impairment of visibility in Class I areas.13

6 Assessment of Baseline and Current Conditions and Estimate of N atural Conditions in

Class I Areas The goal of the Regional Haze Rule is to restore natural visibility conditions to the 156 Class I areas identified in the 1977 Clean Air Act Amendments. Section 51.301(q) defines natural

conditions: ―Natural conditions i nclude naturally occurring phenomena that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration.‖ Regional Haze SIPs must contain measures that make ―reasonable progress‖ toward this goal by reducing anthropogeni c emissions that cause haze. Nebraska does not have any Class I areas

.

T his chapter is provided as background information to support the technical analyses presented throughout this document.

For each Class I area, there are three metrics of visibility that are part of the determination of reasonable progress: 1) Baseline conditions, 2) Natural conditions, and 3) Current conditions. Each of the three metrics includes the concentration data of the visibility pollutants as different terms in the light exti nction algorithm, with respective extinction coefficients and relative humidity factors. Total light extinction when converted to deciviews (dv) is calculated for the average of the 20 percent best and 20 percent worst visibility days.

―Baseline‖ visibili ty is the starting point for the improvement of visibility conditions. It is the average of the IMPROVE monitoring data for 2000 through 2004 and can be thought of as ―current‖ visibility conditions for this initial planning period. The comparison of initi al baseline conditions to natural visibility conditions indicates the amount of improvement necessary to attain natural visibility by 2064.

Each state must estimate natural visibility levels for Class I areas within its borders in

consultation with federa l land managers and other states [40 CFR 51.308(d)(2)]. ―Current conditions‖ are assessed every five years as part of the SIP review where actual progress in reducing visibility impairment is compared to the reductions committed to in the SIP. EPA‘s

Guida nce for Estimating Natural Visibility Conditions under the Regional Haze Program (2) provides states a ―default‖ estimate of natural visibility. The default values of concentrations of visibility pollutants are based on a 1990 National Acid Precipitation A ssessment Program report (3). In the guidance, the United States is divided into ―East‖ and ―West‖ along the western
b oundary of the states one tier west of the Mississippi River. This division divides the C ENRAP states into ―East‖ (MN, IA, MO, AR, LA) wit h seven Class I areas, and ―West‖ (NE, KS, OK, TX) with three Class I areas. In the two equations, only sulfate and organic carbon have different values, but the calculated deciview difference is significant.

In the guidance, EPA also provides that states may use a ―refined approach‖ to estimate the values that characterize the natural visibility conditions of the Class I areas. The purpose of such a refinement would be to provide more accurate estimates with changes to the extinction algorithm that may in clude the concentration values, factors to calculate extinction from a measured particulate species and particle size, the extinction coefficients for certain compounds,14

geographical variation (by altitude) of a fixed value, and the addition of visibility pollutants. States can choose between the default and refined equations. One equation is used to calculate baseline and current conditions of visibility due to haze

- causing pollutants and, with natural concentrations of the same pollutants; the same equati on is used to calculate natural visibility.

The old (default) algorithm:

b ext = 3 f ( RH) [Sulfate]

+ 3 f (RH) [Nitrate]

+ 4 [Organic Carbon]

+ 10 [Elemental Carbon]

+ 1 [Fine Soil]

+ 0.6 [Coarse Mass]

+ 10

The new (refined) algorithm: (Di fferences from the default are in bold)

b ext = 2.2 f

S (RH) [Small Sulfate] + 4.8 f L (RH) [Large Sulfate]

+ 2.4 f

S (RH) [Small Nitrate] + 5.1 f L (RH) [Large Nitrate]

+ 2.8 f

S (RH) [Small Organic Carbon] + 6.1 f L (RH) [Large Organic Car bon]

+ 10 [Elemental Carbon]

+ 1 [Fine Soil]

+ 1.7 f

SS (RH) [Sea Salt]

+ 0.6 [Coarse Mass]
+ Rayleigh Scattering (Site Specific)

+ 0.33 [NO 2 (ppb)]

The choice between use of the default or the refined equation for calculating the visibility

met rics for each Class I area is made by the state in which the Class I area is located [40 CFR 51.308(d)(2)]. Nebraska consulted with other CENRAP states as those states assessed baseline

and natural visibility conditions in their respective Class I areas.15

7 Monitoring Strategy Section 51.308(d)(4) of the federal Regional Haze Rule requires a monitoring strategy for measuring, characterizing, and reporting regional haze visibility impairment that is representative of all mandatory Class I areas. The monitori ng strategy relies, in large part, upon participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network. The

IMPROVE website is located at http://vista.cira.colostate.edu/ improve/

.

7.1 Current Monitoring Strategy

7.1.1 Measuring Visibility Data Shortly after creation of the Central Regional Air Planning Association (CENRAP), the organization‘s Monitoring Workgroup identified large visibility data voids in southern Arkansas,
Iowa, Kansas, southern Minnesota, Nebraska, and Oklahoma. Only five IMPROVE sites were

located in the entire 9 state CENRAP region. Between 2000 and 2003, five more IMPROVE

sites and 15 IMPROVE Protocol sites (i.e., sites not managed by IMPROVE directly

, but by

individual government or tribal organizations) were established in the CENRAP region.

In conjunction with CENRAP and EPA Region 7, Nebraska installed one IMPROVE protocol sampler at Nebraska National Forest County near Halsey, NE in the central part of th e State, and

another at Crescent Lake National Wild Life Refuge in the Panhandle of the state. A third IMPROVE Protocol sampler in Nebraska is operated independently in Thurston County , by the

Omaha Tribe of Nebraska.

7.1.1.1 Nebraska National Forest

The IMPROVE Protocol site at Nebraska National Forest near Halsey, NE is located in the Sandhills of central Nebraska. The 90,000 acre forest area was first established in 1902 by Charles Bessey, a University of Nebraska Botanist, and is known to be the world‘s larg est man

made forest. In addition to forest land, the area is characterized by rolling sand dunes covered with native grasses. The area is known for wildlife, including white tailed and mule deer, antelope, turkey, sharp

- tailed grouse and the greater prai rie chicken.

The primary purposes of the site are to evaluate regional haze and the contributions that may impact Federal Class I areas in National Parks and Wilderness Areas. The Nebraska National Forest site is regional in scale and the purpose is desig ned to understand background and transport of pollution into and out of the state. The monitor measures on a continuous basis for fine particulate matter ( PM 2.5 ) and speciates the particles to understand the composition.16 Figure 7 .1 Nebraska National Fore st IMPROVE Protocol Site

County: Thomas County (pop. 851)

Latitude: 41.8888 Longitude:

- 100.3387

Elevation: 883m above M SL

Region: Central Great Plains

Dates: 7/2002

– Present

7.1.1.2 Crescent Lake Wild Life National Refuge

The site at Crescent Lake Wild Life National Refuge in the panhandle of Nebraska s erves as another background and transport site for evaluating backgroun d levels in rural Nebraska as well as understanding regional transport patterns. Like the Nebraska National Forest site, the monitor measures on a continuous basis for fine particulate matter ( PM 2.5 ) and speciates the particles to understand the compositi on.

This isolated refuge consists of 45,818 acres of rolling sandhills, the largest continuous sand dune area in America. The grass covered dunes were created from the windblown sands of an

ancient sea.

The twenty

- one lakes and numerous ponds are supported by an aquifer lying below the hills. The grasslands range from the densely vegetated meadows to the sparsely covered areas and support a wide variety of wildlife.17

Figure 7.2 Crescent Lake Wild Life National Refuge IMPROVE Protocol Site

County: Garden County (pop. 2460)

Latitude: 41.7627 Longitude:

- 102.4336

Elevation: 1207m above MSL Region: Central Great Plains

Dates: 7/2002

- Present

7.1.1.3 Omaha Tribe

The Omaha Tribe also operate d an IMPROVE Protocol sampler in Thurston County in northeast

Nebraska

. The monitor operate d on a continuous basis and measure d the same constituents as the other two monitors. For a period of time the Omaha Tribe also operated a nephelometer.

Figure 7.3 Omaha Tribe IMROVE Protocol Monitor

County: Thurston County (po p. 6936)

Latitude: 42.1487 Longitude:

- 96.4318

Elevation: 429m above MSL Sponsor: TRIBE Region: Central Great Plains

Dates: 8/2003

- uknown18

7.1.2 Characterizing Visibility Data The State of Nebraska does not have any mandatory Class I Federal areas. In accordance with 40 CFR 51.308(d)(4) (iii), Nebraska, along with other states that do not have Class I areas, must establish procedures by which monitoring data and other information are used in determining the

contribution of emissions from with in the stat e to regional haze visibility impairment at affected mandatory Class I areas in other states. The procedures Nebraska used were established through the work completed by contractors retained by CENRAP, and are only briefly described here.

IMPROVE monit oring data for the 2000

- 2004 period was used to define baseline, natural, and

2018 conditions for each of the Class I areas. PM 10 was speciated into six components (sulfate, particulate nitrate, organic carbon, elemental carbon, soil, and coarse mass) whic h were used to develop relative response factors (RRFs) between current and predicted concentrations for each component. The RRFs were multiplied by current baseline values to estimate future

c oncentrations. The visibility improvements for 2018 were then c alculated using the original or new IMPROVE equation. Additional information about these analyses can be found in Chapter 4 of the Technical Support Document (TSD) prepared by ENVIRON and the Causes of Haze Assessment work performed by Sonoma Technology fo r CENRAP (Appendix 9.1 and Appendix 10.10)

.

Nebraska also relied upon source apportionment modeling (CAMx PSAT) in determining the State‘s contribution to other Class I areas. This type of modeling provides the best available estimate of the potential vis ibility impacts Nebraska may have on various surrounding Class I

areas in 2018. Source apportionment modeling for the CENRAP region is outlined in Chapter 11

of this document.

7.1.3 Data Validation and Reporting The filter samples from all IMPROVE modules from the three IMPROVE

- protocol sites in

Nebraska are sent for analysis to the University of California in Davis (UC

- D) , and the resultant data are subjected to preliminary review and quality assurance/quality control (QA/QC) procedures. After validation, dat a from the three IMPROVE

- protocol sites in Nebraska are sent by UC

- D for posting to the IMPROVE website and the Visibility Information Exchange Web System (VIEWS) website [http://vista.cira.colostate.edu/views/].

7.2 Special Monitoring Studies CENRAP, in coo peration with member states and tribes, studied the impacts of ammonia on visibility impairment in the CENRAP region. Preliminary monitoring studies and monitoring data analysis suggest that ammonia could contribute to visibility impairment in the CENRAP

g eographical area. CENRAP conducted studies to provide more information on ammonia

emission inventories. Given the extent of estimated ammonia emissions from natural and man

made sources such as fertilizer application, CENRAP determined that there was eno ugh excess ammonia in the air such that it would not be feasible to control fine particle formation by controlling ammonia emissions. Rather, control of the other chemicals that combine with ammonia, such as nitrates or sulfates, is more conducive to redu cing fine particle formation and consequent visibility impairment.19

During two measurement periods in 2002 (August 24

– October 23 and November 18

– December 31), an intensive study was conducted to characterize ambient fine particulate matter ( PM 2.5 ) at

the Sac and Fox Nation IMPROVE Protocol site in Reserve , Kansas . The sampling station was configured in the same manner as the St. Louis, Missouri Supersite. Selected semi

- continuous monitors remained in operation during the six

- week interim period. This spec ial study was funded by CENRAP and EPA Region 7. Daily 24

- hour mass reconstructions demonstrated the episodic nature and seasonal variations of sulfate (summer/fall) and nitrate (fall/winter). Ion

balances for 24

- hour sampling periods were consistent with conditions favorable for formation of ammonium nitrate. A sulfate transport episode was captured as well as elevated local ammonia levels possibly associated with seasonal application of anhydrous ammonia to corn and soybean

fields.

From November 1, 2003 through June 28, 2006, the Sac and Fox Nation also operated a passive ammonia monitoring station for a CENRAP ammonia monitoring project. Denuder

- based gas phase ammonia, nitric acid, and sulfur dioxide were monitored at the Reserve, Kansas site and

six ot her sites within the CENRAP region. Twenty

- four hour samples were collected on a one in

six day schedule. The denuder

- based samples were analyzed by the Illinois State Water Survey Laboratory. IMPROVE Protocol samplers were in operation at all but one of the CENRAP ammonia study sites. This special ammonia study was conducted to collect data for evaluation of the role of ammonia in regional haze formation in the CENRAP region.

7.3 Future Monitoring Strategy In order to assess progress in reducing visibility i mpairment in Class I areas, the existing IMPROVE and IMPROVE Protocol sites will be maintained contingent upon continued federal 103 grant funding. Data from the IMPROVE Protocol sites in Nebraska will be used to

characterize and model conditions within th e State of Nebraska . Data from IMPROVE monitors

will be used to compare visibility conditions in Nebraska to regional haze visibility impairment

at Class I areas affected by emissions from Nebraska to satisfy requirements of 40 CFR 51.308(d)(4)(i). The Sta te of Nebraska will evaluate the monitoring network periodically, including an evaluation of changes in technology and the need for new monitors. With continuation of adequate funding, the network will be reconfigured as necessary to enable

assessment of r easonable progress toward goals for each of mandatory Class I area potentially affected by emissions from within the State of Nebraska

. This assessment will be done as part of the monitoring network assessment required by federal regulation 40 CFR Part 5 8

.20

8 Emissions Inventory

Nebraska is required by 40 CFR 51.308(d)(4)(v) to provide a statewide emissions inventory of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I area(s). Nebraska wor ked with CENRAP on the compilation of a statewide inventory using EPA guidance on inventorying all sources of anthropogenic and biogenic

emissions

. Nebraska‘s emissions inventory for 2002 may be found in Appendix 8.1.

8.1 2002 Emissions I nventory Summary

As s pecified in the applicable EPA guidance , the pollutants inventoried for Nebraska include volatile organic compounds (VOCs), nitrogen oxides (NO x ), fine particulates ( PM 2.5 ), coarse particulates ( PM 10 ), ammonia (NH 3 ), and sulfur dioxide (SO 2 ). An inventory was developed for the baseline year 2002; a summary of those inventory results is presented in Table s 8 .1 and 8.2

.

Table 8.1 2002 Nebraska Emissions Summary, by Pollutant and Source Category Source Category VOC NO

x SO 2 PM 10 PM 2.5 Tons per Year

Point 2 7,274 58,619 73,487 13,105 4,638

Area 3 66,769 15,023 7,748 447,703 83,852

On

- Road 4 43,113 61,850 1,822 1,277 930

Non

- Road 5 24,882 119,568 11,011 7,491 6,785

Fires 6 (Ag & Prescribed) 3,204 679 268 5,057 3,956

Nebraska Total 145,242 255,739 94,336 474,633 100,161

Table 8.2 2002 Nebraska Ammonia (NH 3 ) Emissions Summary, by Source Category 7

Source Category NH 3 (TPY)

Livestock 96,983 Fertilizer Application 64,443 Biogenic s (Soil) 7,829

Point 800

On

- Road 1,521

Non

- Road 320

Miscellaneous 7,912

Nebraska Total 179,808

2 Point Source Information taken from Table 2c Summary of Point Source Emissions by State and Pollutant Pechan, Refinement of CENRAP’s 2002 Emissions Inventories (August 31, 2005)

3 Area Source Information taken from Table 2b Summary of Area Source Emis sions by State and Pollutant Pechan, Refinement of CENRAP’s 2002 Emissions Inventories (August 31, 2005)

4 On Road Information taken from Table 2e Summary of On Road Source Emissions by State and Pollutant Pechan, Refinement of CENRAP’s 2002 Emissions Inve ntories (August 31, 2005)

5 Non Road Information taken from Table 2d Summary of Non Road Source Emissions by State and Pollutant Pechan, Refinement of CENRAP’s 2002 Emissions Inventories (August 31, 2005)

6 Fire information taken from Table 2

- 1 and Table 2

- 2 of Research and Development of Planned Burning and Emission Inventories for the Central States Regional Air Planning Association (July 2004)

7 Ammonia information taken from Table B

- 1 Appendix B of Research and Development of Ammonia Emission

Inventorie s for the Central States Regional Air Planning Association (October 2003)21

Methodologies for the 2002 emissions inventory are documented in the Appendix 8. 3

. Nebraska, along with the other members of CENRAP agen cies submits emission inventory information to EPA for purposes of building the National Emissions Inventory Report. This information formed the basis for the CENRAP 2002 emissions inventory. Sonoma Technology supplemented the National Emissions Inventor y ( NEI ) data with area (non

- point) source inventories specifically developed for CENRAP. These inventories addressed agricultural and prescribed burning, on

- road and non

- road mobile sources, agricultural and livestock dust, and agricultural ammonia. Info rmation on fires was obtained from the Research and Development of Planned Burning and Emission Inventories for the Central States Regional Air Planning Association (July 2004) found in Appendix 8.3.

8.1.1 Point Source Emissions NDEQ conducts an annual emissio ns inventory of all Class I major sources. Synthetic minor sources are required to submit emissions inventories at least once every three years or as otherwise specified in their permit in accordance with Title 129 Chapter 6. This cycling of synthetic mi nor sources is to ensure a complete inventory once at least every three years. NDEQ followed internal quality assurance procedures and submitted the data to EPA for the 2002 national emissions inventory. Following submission to the national emissions inv entory, CENRAP provided additional quality assurance and revision opportunities for data improvement. E.H. Pechan & Associates, (Pechan) through a contract with CENRAP, obtained

the Nebraska point

- source inventory and worked with N DEQ and the Nebraska loc al agencies to
make corrections and to fill gaps where necessary

.

8.1.1.1 Electric Generating Units The majority of visibility

- impairing point source emissions in Nebraska currently come from the electric utility sector. This sector represented 92% of the repor ted point source SO 2 emissions

and 82 % of the point source NO

x emissions for the 2002 inventory year. Nebraska‘s utility system is structured in a manner where power is provided to businesses and citizens through public (municipal or rural) utility distri cts. The largest units are found in the eastern part of Nebraska and in the panhandle of the state. Mid

- size units servicing moderate sized communities are located throughout the state. In 2002, the continuous emission monitors (CEMs) from the 13 units reporting to the EPA Clean Air Markets Division averaged between 5,000

- 6,000 tons of SO 2 per month and about 4,000 tons of NO

x per month.

Figure 8.1 Monthly CEM Profiles for Nebraska’s 13 EGUs22

8.1.1.2 Fuel Ethanol Manufacturing Facilities In 2002, there were six ethanol plants in operation in Nebraska. From 2002

- 2008 , due to a number of factors, production capacity expanded to where 24 plants are currently operating, with a production capacity of over 2 billion gallons per year. 8 A map of the locations is s hown in Figure 8.2. 9 Since 2008

, expansion of the fuel ethanol industry in Nebraska has slowed dramatically. The actual emission rate of NO

x for these plants is relatively low compared to

EGUs

. The majority of ethanol plants are fueled with natural gas and report NO

x emissions well below 100 tons per year. Four plants have the capability to be fueled by coal. The largest coal fired ethanol plant reported NO

x emissions around 200 tons per year. One facility is partially fueled by landfill gas. One pl ant that is currently idle has the capacity to be fueled by methane that is generated from waste collected from a co

- located feedlot. Many are exploring alternatives fuel scenarios to maximize efficiency of operations. Nebraska does not anticipate visibi lity impacts due to the operation of additional facilities as those facilities will likely be subject to the Prevention of Significant Deterioration (PSD) program.

Figure 8.2 Locations of Operating Ethanol Plants

In Operation Under Construction Idle

8.1.2 Area Source Emissions

EPA treats each class of stationary area sources collectively by county. Neither EPA nor N DEQ

can feasibly collect specific information from each area source emission point; therefore EPA provides estimates over larger regions based upon factors such as population. Residential heating is an example of a stationary area source. The area

- source inventory for 2002 builds on

EPA

- provided estimates for area

- source emissions. It includes emissions estimates that N DEQ

and C ENRAP prepared and data from the national emissions inventory to fill gaps.

8 From Nebraska Ethanol Board http://www.ne

- ethanol.org/industry/ethplants.htm

. 9 From Nebraska Ethanol Board http://www.ne

- ethanol.org/industry/ethplants.htm

.23

Sonoma Technology prepared the following reports which are r eferenced in the Technical Support Document (Appendix 9.1) for CENRAP and found in Appendix 8.3 : Research and Develop ment of Planned Burning Emission Inventories for the Central States Regional Air Planning Association (July 30, 2004),
Emission Inventory Development for Mobile Sources and Agricultural Dust Sources for the Central States (October 28, 2004), and

Researc h and Development of Ammonia Emission Inventories for the Central States Regional Air Planning Association (October 30, 2003)

. The Sonoma reports were used to inform the bases of the prescribed burning, agricultural dust,

and ammonia emissions inventorie s for CENRAP

.

Under contract with CENRAP, Pechan consolidated the area

- source inventories from these various inventory sources, conducted additional quality assurance, and worked with states to revise this consolidated inventory. Two documents reference d in Appendix 9.1 describe the

work of Pechan in detail: The Consolidation of Emissions Inventories (April 28, 2005) and Refinement of CENRAP’s 2002 Emissions Inventories (August 31, 2005 ) , both may also be found in Appendix 8. 3

. University of California at Riverside (UCR), under contract with CENRAP, removed selected sources from the consolidated area inventories to process them as separate subcategories. UCR created these subcategories to allow specialized processing within the Sparse Matrix Operator Ker nel Emissions (SMOKE) model in anticipation of particulate source apportionment within the Comprehensive Air Quality Model with extensions (CAMx).

Area sources account for the majority of the Nebraska PM 10 emission inventory at 94%

. As Figure 8.3 shows, u npaved roads comprise 52% of the PM 10 emissions, 34% come from crop production. 10 These values are based on the 2002 National Emissions Inventory.

Figure 8.3 Compositions of PM 10 Emissions

10 Nebraska Air Quality Report 2005

- 2006.24

Area sources account for approximately 4 6 % of the total ant hropogenic VOCs emitted in the

state of Nebraska. The top VOC area source sectors include: solvent utilization, storage and transport, residential fuel combustion, and waste disposal and recycling.

Area Source NO

x and SO 2 emissions are relatively small portion s of the overall NO

x and SO 2 emissions from the state. Less than 6% of the total NO

x emissions and approximately 8% of the

total SO 2 emissions come from area sources. The top sectors include residential, industrial,

commercial/institutional combust ion, and storage and transport.

8.1.3 On

- road Source Emissions CENRAP developed the on

- road mobile source emissions inventory for 2002 with contractor

support. For all counties in Nebraska and elsewhere throughout the CENRAP region, Sonoma Technology provided vehicle miles traveled data for all months of 2002 and MOBILE6 input

files only for the months of January and July 2002, using the methods and data described in the

report Emissions Inventory Development for Mobile Sources and Agricultural Dust Sources for

the Central States (October 28, 2004), referenced in Appendix 8. 3

. CENRAP contractors then prepared MOBILE6 input files for the remaining months of 2002 and processed the mobile emissions using the MOBILE6 model within the SMOKE framework. The two sets of results from the SMOKE process were then merged together to obtain an on

- road mobile source emissions file for the entire CENRAP region.

8.1.4 Non

- road Source Emissions

The non

- road source emissions category includes aircraft operations, marine vessels, recr eational boats, railroad locomotives, and a broad category of other equipment ranging fro m large construction equipment to lawn equipment

. Calcula tion methods for emissions from non

- road engine sources are based on information abo ut equipment population, engine horsepower, load factor, emission factor, and annual usage.

Sonoma Technology, under contract to CENRAP, used the NONROAD model to prepare and develop broad emissions estimates for the non

- road mobile source 2002 emission inventory.

Sonoma Technol ogy documented the method s and data used to generate the 2002 emissions inventory in the report Emissions Inventory Development for Mobile Sources and Agricultural Dust Sources for the Central States (October 28, 2004) referenced in Appendix 8. 3

.

Pechan consolidated the estimates of Sonoma Technology with those of EPA to generate the full

non

- road emissions inventory. In the process of consolidating the emissions estimates, Pechan assured quality of the data and worked with N DEQ to make necessary correcti ons before creating SMOKE model formatted files. The local air agency, Lancaster County Health Department (LLHD) provided its own non

- road inventory for Source Classification Code ( SCC ) 2260000000 (Off

- highway Vehicle Gasoline, 2

- Stroke: 2

- Stroke Gasoline except Rail and Marine: All). Pechan removed inventories for SCCs starting with 226 in Lancaster County to

correct double

- counting of emissions. This adjustment was made by Pechan for Base02b modeling. Pechan made specific corrections to the fuel oxygena te content used in the NONROAD model. Two documents referenced in Appendix 8. 3 describe Pechan‘s work: The Consolidation of Emissions Inventories (April 28, 2005) and Refinement of CENRAP’s 2002 Emissions Inventories (August 31, 2005)

.25

Of all non

- road cat egories, non

- road diesel engines made up the majority of the SO 2 and NO

x emis sions for the nonroad sector. Non

- road sources are the second highest source of SO 2 emissions in Nebraska, yet comprise only about 11.6% of the total SO 2 inventory. However, non

road NO

x emissions are 47% of the statewide total for non

- biogenic sources and are the largest sector for this pollutant, at more than double the total from all point sources combined.

8.1.5 Biogenic Source Emissions EPA calculates biogenic emissions based on l and use data that characterize types of vegetation as

county

- total or grid

- cell values.

NDEQ‘s biogenic source emissions were estimated through the use of CENRAP‘s contractor

who ran the Biogenic Emissions Inventory System 3 (BEIS3) model within the SMOK E framework to generate a biogenic emissions inventory. Th e BEIS3 system derives estimates of biogenic gas

- phase emissions from land

- use information, emissions factors for different plant species, and hourly meteorological data on a coordinate grid. The te chnical support document

found in 9.1 describes the development of the biogenic emissions inventory.

Nebraska‘s Biogenic Emissions are found in Table 8. 3 :

Table 8. 3 Nebraska 2002 Biogenic Emissions Inventory

Source Category VOC NO

x SO 2 PM 10 PM 2.5 NH 3

T ons per Year Biogenic 533,705 39,446 0 0 0 7,829

8.2 2005 Emissions Inventory and Periodic Updates States are required by 40 CFR 51.308(d)(4)(v) to include in their SIPs a commitment to update their statewide emissions inventories periodically. Nebraska‘s E missions Inventory for 2005 is

the most recent state

- wide emissions inventory available. This inventory is available on EPA‘s

website at http://www.epa.gov/ttn/chief/eiinformation.html

.

Nebras ka tracks air emissions over time as required by current EPA regulations and the Air Emissions Reporting Rule (AERR). This federal rule , proposed in December 2005 and finalized in December 2008, consolidates the current emission inventory reporting require ments, and will require that emissions be reported every three years from the following source categories in all parts of the State, excluding sources located on tribal lands:

• Point

• Area

• On

- road mobile

• Nonroad mobile

In addition, all visibility

- im pairing pollutants are required to be included for the reportable categories listed above. These pollutants will include NO

x , SO 2 , PM 10 , PM 2.5 , VOCs, and NH 3
. The rule requires that starting in 2009, emissions reports will be d ue 12 months after the end of the year

. The rule can be found at: http://www.epa.gov/ttn/chief/aerr/

.26

Nebraska intends to follow the reporting requirements of the AERR where funding and staffing

allow. We commit to updating its point source emissions in ventory annually and to anal yze sectors identified in the regional haze planning process that need improvement on a periodic

basis

.

In the past, due to available resources, Nebraska chose to utilize the EPA

- generated nonpoint,

on

- roa d, and nonroad inventories when available. It is anticipated that practice will continue unless an error is noted in the EPA generated inventory that requires correction or there is another reason for NDEQ to generate the information. Nebraska will work with EPA to correct any errors in the aforemention ed inventories.

8.3 2018 Predicted Emissions Inventory

The 2002 emissions were grown to year 2018, primarily using the Economic Growth Analysis System (EGAS6), MOBILE 6.2 vehicle emission modeling software, and the Integrated Planning Model (IPM) version 2. 93 for electric generating units (EGUs). Again, this work was done through CENRAP contractor support

. Table 8

. 4 is a summary of those inventory results

. The complete 2018 emissions inventory is submitted as Appendix 8

. 2

. The 2018 emissions for most

sour ce categories were based on projections of the 2002 inventory assuming growth and ―on the

books‖ control. The 2018 emissions for Electrical Generating Units (EGUs) were based on

simulations of the I PM that took into the account the effects of the Clean Ai r Interstate Rule (CAIR) on emissions from EGUs in CAIR states using an IPM realization of a CAIR cap

- and

trade program.

At the time modeling was conducted, Best Available Retrofit Technology (BART) decisions had not been made. Regardless, r eductions a nticipated from BART controls for electric generating units (EGU) in Oklahoma, Arkansas, Kansas, and Nebraska were included in projections of 2018

emissions before the BART decisions were complete . These anticipated reductions were based on actual operatin g conditions and estimated control efficiencies from utilities.

Newly permitted coal

- fired utilities were also included in 2018 projections. Therefore, two newly permitted units in Nebraska have been factored into the projections. The permitted

allowab le emissions were included into the projections. Conservatively, none of new units the IPM model projected to be installed, but not currently planned or permitted, were removed from

the simulation . This is likely to project higher than needed allowable e missions, because the majority of the additional power that is projected to be needed is already factored in with the cleaner, newly permitted facilities. It is expected that with the new, cleaner units coming online, older units will be relied upon less.

To correct the 2018 projections to account for the BART decisions, Table 8. 5 has been updated. NDEQ also noted that other states in the MANE

- VU region used a 2018 projection of 73,629

tons SO 2 per year. That value was obtained from IPM v 2.1.9.

Some source categories were held constant between 2002 and 2018 because either stagnant growth was deemed appropriate or insufficient data was available to adequately project future growth or controls. These categories include: biogenic VOC and NO

x emissions

, windblown dust, and emissions from fires.27 Table 8.4 Actual SO 2 Emissions from EGUs (Tons per Year)

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Gerald

Gentleman

Station 31,297 32,152 31,089 32,035 28,171 31,135 28,815 31,362 31,931 29,741

Whelan Energy

Center 2,008 2,007 2,152 2,352 2,563 2,330 2,207 2,22 9 2,001 2,301

Lon D Wright

Power Plant 1,088 978 1,017 1,183 1,332 1,401 1,708 1,958 1,250 1,206

Nebraska City Station 16,205 12,820 15,052 15,593 17,550 14,994 14,173 17,498 19,074 14,296

North Omaha

Station 11,799 11,509 11,730 16,125 16,705 14,315 14,749 15,012 13,159 10,515

Platte 2,436 2,250 2,194 2,158 2,476 2,637 2,641 3,086 2,679 2,365

Sheldon 5,410 5,624 4,478 4,768 4,878 4,403 4,627 4,552 5,395 3,758

70,243 67,340 67,712 74,214 73,675 71,215 68,920 75,697 75,489 64,182 70,869

The average SO 2 emissions for t he last 10 years from the coal fired power plants have been 70,869 tons per year. Emissions have been within 7

- 10 % of that tonnage since 2001, with the low being in 2010. According to the US Census the population in Nebraska grew 6.7% from

2000

– 2010. Assuming that the population grows another 6.7% from 2010 to 2018, and that there is a commensurate growth in EGU emissions, it is reasonable to anticipate the EGU point

source SO 2 contribution to be 75,617 tons per year in 2018. If EGU emissions contribu te 92% overall, SO 2 point source emissions would be anticipated to be 82,193 tons per year in 2018

.

Table 8. 5 2018 Nebraska Projected Emissions Summary, by Pollutant and Source Category

Source Category VOC NO

x SO 2 PM 10 PM 2.5

Tons per Year

Point 13,34 4 56,190 82,193 18,654 8,596

Area 78,417 17,737 9,793 303,578 56,193

On

- Road 18,862 19,702 236 432 432

Non

- Road 14,611 50,972 226 3,269 2,974

Fires 3,204 679 268 5,057 3,956 Biogenic 533,705 39,446 0 0 0

Totals 660,868 185,040 92,716 335,012 76,610

Methodologies used to develop the non

- SO 2 2018 emissions inventory are documented in the

CENRAP T echnical S upport D ocument found in Appendix 9.1.

Table 8

. 6 presents percen t changes in the inventory between 2002 and 2018.28 Table 8. 6 2018 Percent Changes in Nebraska Emissions 2002 to 2018,

By Pollutant and Source Category

VOC NO

x SO 2 PM 10 PM 2.5

Tons per Year

83%

- 4% 12 % 42% 85%

17 % 18% 26%

- 32%

- 33%

- 56 %

- 6 8 %

- 87%

- 66%

- 54%

- 41 %

- 57 %

- 9 8 %

- 56%

- 56%

0% 0% 0% 0% 0%

0% 0% N/A N/A N/A

- 12 %

- 43 %

- 1.7 %

- 30%

- 2 8 %

8.3.1 Discussion of 2018 Predicted Emissions Inventory

8.3.1.1 Volatile Organic Compounds Although VOC emissions from area and point sour ces are projected to grow by 2018 , t he on

road and non

- road sectors are expected to decrease due to fleet turnover and improvement in efficiency of engines. Therefore, overall VOCs are expected to decrease state

- wide by 12% by

2018. Furthermore, as evidenced in the zero

- out modeling done b y ENVIRON and UCR for

CENRAP to measure the impact of VOCs from BART

- eligible facilities to Class I areas, VOC is not anticipat ed to be a large contributor to visibility impairment from point sources in the Class I areas surrounding Nebraska . When VOCs we re zeroed out, the maximum improvement was less

than 0.25 Δ dv at any Class I area. Nebraska‘s VOC emissions inventory is the smallest of all 9 states in the CENRAP region in both 2002 and 2018, so it follows that Nebraska‘s VOCs would likely have less imp act than other states. Therefore, VOCs were not considered for reductions.

8.3.1.2 Nitrogen Oxides For the point source sector, reductions in NO

x by 2018 were predicted

, primarily through BART

controls. Even with the projected growth predicted by the models fo r 2018, NDEQ expects that the point source sector will achieve at least a n overall reduction of 4% for NO

x emissions. However, it is anticipated that the NO

x reductions achieved in practice may be more than what is predicted through the model. Table 8. 7 details the NO

x reductions anticipated from installation

of BART controls at the three BART subject units in Nebraska.29 Table 8. 7 Potential NO

x Emission Reductions in BART

- Subject Units Subject to

Bart Unit Baseline

Emissions (BART assumption) 200 2

Actual

Emissions 11

(CENRAP baseline) Permitted

BART

Emissions Max imum

Expected

Reduction Max

Percent

Reduction Reduction

from

CENRAP

baseline Percent

Reduction

Tons per Year of NO

x OPPD

Nebraska City #1 17,020 8,132 6,827 10,193 59.9% 1,305 16.0%

NPP D

Gerald

Gentleman

Station #1

& 2 30,243 21,878 15,287 14,956 49.5% 6,591 30.1%

Total 47,263 30,010 22,114 25,149 53.2% 7,896 26.3%

The baseline emissions ( BART assumption ) were established using the maximum 24

- hr emissions over a three year period (2001

- 2003), assuming continuous maximum operation to establish the maximum potential emissions. The units were then assumed to be able to meet at least BART presumptive levels for NO

x which are 0.23 lb/MMBtu. The CENRAP baseline is based on actual emissions from emission year 2002.

These three units represent 51.1% of the total actual NO

x emissions from 2002 (30,010 tons of 58,619 tons) for the entire point source sector. Reducing emissions from this sector by over 25% represents a significant reduction in the overall emissions for the point source sector.

NO

x make s up a relatively small proportion of the non

- biogenic (less than 6%) 2002 area source emissions inventory for Nebraska

, at 15, 023 tons/yr. By 2018, area source NO

x emissions are projected to increase by 18% respectively. Despite the increase, the area source contribution is

about 9.6% of the overall NO

x inventory in 2018

.

Models predict reductions for NO

x from the combined o n

- road and non

- road sector of about 61 %

between 2002 and 2018

. These reducti ons are anticipated due to vehicle turnover and full implementation of current federal regulations, including the federal emission standards for light

duty vehicles and light

- duty trucks and the Tier 2 Program. Reductions are also at tributed to the

use of newer equipment subject to more stringent emissions requirements, including the Clean

Air Nonroad Diesel Rule, locomotive emission standards, the Large

- Spark Ig nition and

Recreati onal Vehicle Rule, and Emissions Standards for New Nonroad Small Spark

- I gnition Engines, Equipment, and Vessels. These rules are discussed in more detail in Chapter 1 1

.

11 As reported and used in the CENRAP emissions inventory. This value was used for the modeling into the 20 18 projections.30

8.3.1.3 Sulfur Dioxide For the point source sector, the IPM procedure predicts reductions in SO 2 by 2018 . Reductions were presumed primarily from the installation of BART controls. However, a s discussed in Chapter 10, additional controls for SO 2 were not required by NDEQ during the BART

determination. Despite the lack of additional controls on the BART subject sources, and assuming utility SO 2 emissions were to remain constant, SO 2 would still be reduced overall by

1.7 % due to the other sector categories. As discussed later, these r eductions are presumed to
result f rom the use of lower sulfur fu els for on

- road and non

- road equipment. Additionally, it is expected that due to other federal measures, SO 2 emissions are expected to be reduced

.

SO 2 make s up a relatively small proportion of the Nebraska‘s 2002 area emissions inventory at 7,748 tons/y r

. By 2018

, area source SO 2 emissions are projected to increase by 26 % . T he major contributing source categories for SO 2 are associated wi th fuel combustion and storage and

transport

. However, i n reality, due to the lack of availability of higher sulfur fuels, the distillate

and residual oil combustion in the area source sector are likely to remain unchanged or decrease

between 2002 and 2018. Therefore, NDEQ believes the 2018 projections for area source

emissions are overstated. At worst, if the 2018 p rojec tions are correct, the nonpoint emissions

for SO 2 are still only about 15% of the total SO 2 inventory.

Models predict significant reductions for SO 2 from the combined on

- road and non

- road sector s of about 96 % between 2002 and 2018

. These reducti ons are anticipated due to vehicle turnover and full implementation of current federal regulations, including the federal emission standards for light

- duty vehicles and light

- duty trucks and the Tier 2 Program. This large reduction is also

due to the requirem ent to use low sulfur diesel fuel by 2010. Nebraska also participates in the Diesel Emissions Reduction Act program which provides financial incentives to reduce emissions from diesel engines. These rules are discussed in more detail in Chapter 1 1

.

The models did not take into account the Clean Air Transport Rule which is currently proposed by EPA. Nebraska is named under the rule and expects that when the final rule comes out, if

SO 2 emissions are deemed to be a significant contributor to downwind ozo ne or PM2.5 nonattainment, reductions will be required.

8.3.1.4 Particulate Matter Area sources account for the majority of the Nebraska PM. As shown earlier in Figure 8.3, unpaved roads comprise 52% of the PM 10 emissions, whereas 34% come from crop production. 12
These values are based on the 2002 National Emissions Inventory. Since CENRAP held windblown dust from nonagricultural land

- use categories and fire emissions constant from 2002

to 2018 , reductions in the PM were most likely from other sectors such as the implementation of area MACT standards and reduction in dust from crops through alternative land practices. While the point source sector is predicted to increase, the overall contribution of point source PM emissions to the total inventory is relatively l ow. The on

- road and non

- road sector reductions are anticipated due to fleet turnover and full implementation of current federal regulations, including

the federal emission standards for light

- duty vehicles and light

- duty trucks and the Tier 2 Program. Th e lo w sulfur fuel requirements are expected to result in reduced PM levels as well.

12 Nebraska Air Quality Report 2005

- 2006.31

Nebraska also participates in the Diesel Emissions Reduction Act program which provides financial incentives to reduce diesel particulates emissions from engines.

For B ART, all units subject to BART were determined to be adequately controlled through either an electrostatic precipitator (ESP) or through baghouses. Furthermore, BART subject facilities provided information supporting a conclusion that, as currently contro lled, PM had a small impact on visibility. OPPD NCS Unit #1 greatest impact was 0.933 dV at Hercules Glades (MO), of which only 0.32% could be attributed to PM , or 0.00299 Δ dV . For NPPD Units #1 and #2, the greatest impact was in the Badlands (SD). Their total impact was predicted to be 3.121 dV, but only 0.69% of that could be attributed to PM for a 0.0215 Δ dV potential contribution. Therefore, eliminating a ll PM from these BART subject sources would have an insignificant impact on visibility improvement.

8.3.1.5 Ammonia Livestock production and fertilizer application contribute collectively about 90% of the ammonia

emissions in Nebraska

. These sources mostly li e beyond the currently active regulatory purview

of the air quality program at N DEQ. Furthermore, EPA currently does not consider ammonia for regulation as a prec ursor of PM 2.5 , but does allow states to make case by case decisions

. With regard to this, N DEQ has followed the lead of EPA . But most significantly, because NO

x and

SO 2 are considered limiting pollutants with regard to PM 2.5 formation and the significant

uncertainties in the ammonia inventories as well as in assessing the effect of ammonia emis sions reductions on visibility, Nebraska does not consider ammonia among visibility

- impairing pollutants. For these reasons, the 2018 projections are not included here, but may be found in the Appendix 8. 2

.

Appendix 8.1 2002 Emissions Inventory Appendi x 8.2 2018 Emissions Inventory Appendix 8.3 Consolidation of Emissions Inventories (April 28, 2005)

,

Refinement of CENRAP‘s 2002 Emissions Inventories (August 31, 2005)

, Research and Development of Planned Burning and Emission Inventories for the

Central States Regional Air Planning Association (July 2004)

, Emission Inventory Development for Mobile Sources and Agricultural Dust Sources for the Central States (October 28, 2004), and Research and Development of Ammonia Emission Inventories for the Central States Regional Air Planning Association (October 30, 2003)32

9 Modeling Assessment 40 CFR Part 51, A ppendix W provides modeling guidelines for conducting regional

- scale modeling for particulate matter and visibility. The U.S. EPA recommends the use of o ne of the three following models to simulate pollutants impairing visibility: CMAQ, CAMx, and REMSAD. CENRAP contractors performed regional modeling using CMAQ and CAMx.

Community Multi

- scale Air Quality (CMAQ) Model is an Eulerian model that simulates t he atmospheric and surface processes affecting the transport, transformation and deposition of air pollutants and their precursors. An Eulerian model computes the numerical solution of partial differential equations of plumes on a fixed grid, while other models may lose accuracy or need

re

- gridding as the plumes expand.

The Comprehensive Air quality Model with extensions (CAMx) is a computer modeling system for the integrated assessment of photochemical and particulate air pollution. CAMx incorporates all of the technical attributes demanded of state

- of

- the

- art photochemical grid models, including two

- way grid nesting, a sub grid

- scale Plume

- in

- Grid module to treat the early dispersion and chemistry of point source NO

x plumes, and a fast chemistry solve r.

Particulate Matter (PM) Modeling: CAMx Mechanism 4 (M4) provides "1

- atmosphere" modeling for fine and coarse PM and ozone. Aqueous phase chemistry is modeled using the RADM mechanism. Inorganic sulfate/nitrate/ammonium chemistry is modeled with

ISORRO PIA. Secondary organic aerosols are modeled using a semi

- volatile scheme called SOAP. Wet and dry deposition processes are included for gasses and particles. Gridded deposition information is output along with the concentrations.

In the July 1, 1999 publi cation of the Regional Haze Rule in the Federal Register, EPA defined the uses of regional modeling as follows:

Analyses and determination of the extent of emissions reductions needed from individual

States Analyses and determination of emissions needed t o meet the progress goal for the Class I

area Analyses to support conclusion that the Long

- Term Strategy provides for reasonable

progress Analyses to calculate the resulting degree of visibility improvement that would be

achieved at each Class I area Analy ses to compare visibility improvement between proposed control strategies

9.1 Modeling Protocol CENRAP‘s contractor, Environ, prepared a modeling p rotocol to serve as a road map for performing the CENRAP emissions and air quality modeling and to communicate t he modeling plans to the CENRAP participants. The Modeling Prot ocol was prepared in accordance with the

EPA guidance available at the time. This Modeling Protocol can be found on the CENRAP modeling Website at: http://pah.cert.ucr.edu/aqm/cenrap/docs/CENRAP_Draft2.0_Modeling_Protocol_120804.pdf33

9.2 Quality Assurance Project Plan The CENRAP contractor prepared a Quality Assurance Project Plan (QAPP) for the CENRAP

emissions and air quality modeling study that described the quality management functions performed by the modeling team. The QAPP was prepared and was based on the national

consensus standards for quality assurance and followed EPA‘s guidelines for qualit y assurance project plans for modeling and took into account recommendations from the North American Research Strategy for Tropospheric Ozone (NARSTO) Quality Handbook for modeling projects.

The EPA and NARSTO guidance documents were developed specifical ly for modeling projects,

which have different quality assurance concerns than environmental monitoring data collection projects. The work performed in this project involves modeling at the bas ic research level and for regulatory/planning applications. In order to use model outputs for these purposes, it must be established that each model is scientifically sound, robust, and d efensible. This is accomplished by following a project planning process that incorporates the following elements : • A systematic pla nning process including identification of assessments and related performance criteria; • Peer reviewed theory and equations; • A carefully designed life

- cycle development process that minimizes errors; • Documentation of any changes from original plans;

• Clear documentation of assumptions, theory, and parameterization that is detailed enough so others can understand the model output; • Input data and parameters that are accurate and appropriate for the analysis; and • Output data that can be used to help inform decision makers. The CENRAP QAPP can be found at: http://pah.cert.ucr.edu/aqm/cenrap/docs/CENRAP_QAPP_Nov_24_2004.pdf

.

A key component of the CENRAP emissions and air quality modeling QAPP was the graphical display of model inputs and outputs and multiple peer

- revi ew of each step of the modeling process. This was accomplished through use of the CENRAP modeling website where modelers posted displays of work products (e. g., emissions plots, model o utputs, etc.) for review by the CENRAP modeling team, modeling workgroup and others. This website can be found at: http://pah.cert.ucr.edu/aqm/cenrap/index.shtml

.

9.3 Mo del Inputs

9.3.1 Year Selection For regional haze, the full 2002 modeling year was chosen as the episode period to evaluate. The 2002 calendar year, which lies in the middle of the 2000

- 2004 baseline period in the regional haze rule, was selected for the followi ng reasons:

Based on available information, 2002 appears to be a fairly typical year in terms of meteorology for the 5

- year b aseline period of 2000

- 2004; 2003 and 2004 appeared to be colder and wetter than typical in the eastern US;

The enhanced IMPROVE an d IMPROVE Protocol and Supersites PM monitoring data were fully operational by 2002. Much less IMPROVE monitoring data was available during 2000

- 2001, especially in the CENRAP region; IMPROVE data for 2003 and 2004 were not yet available at the time that t he CENRAP modeling was initiated; and 2002 was being used by the other RPOs.34

9.3.2 Domain As one of the five national regional planning organizations (RPOs), CENRAP chose to use the unified grid domain developed by all of the other RPOs. This domain covers all RPO areas and was chosen to enable sharing of data and results between RPOs i n a consistent manner. The grid consists of 36km grid cells and is 148 x 112 in size. Sensitivity simulations were also performed for episodes on a 12 km modeling domain covering the central states, however the results were very similar to the 36 km results so CENRAP elected to proceed with the 2002 annual modeling using the 36 km domain for computational efficiency.

9.3.3 Emissions Inputs Generating the source inventory for modeling i s intertwined with the creation of the pollutant inventory. Each emission source and the type of pollutants it emits must be specifically identified. For dispersion modeling, each source must be classified as a point source, area source, mobile source (o n

- road and off

- road), and biogenic sources

. The CENRAP Technical Support Document (TSD) provides the methodologies for this process and is found at Appendix 9.1. Emission inventory information can be found in Chapter 8.

9.3.4 Meteorological Input Preparation

The Fifth

- Generation NCAR / Penn State Mesoscale Model (MM5) is the latest in a series that developed from a mesoscale model used by Anthes at Penn State in the early 70's that was later documented by Anthes and Warner (1978). Since that time, it has unde rgone many changes designed to broaden its usage. These include (i) a multiple

- nest capability, (ii) non

- hydrostatic dynamics, which allows the model to be used at a few

- kilometer scale, (iii) multitasking capability on shared

- and distributed

- memory machi nes, (iv) a four

- dimensional data

assimilation capability, and (v) more physics options. The model (known as MM5) is supported by several auxiliary programs, which are referred to collectively as the MM5 modeling system. Since MM5 is a regional model, it requires an initial condition as well as a lateral boundary condition to run. To produce a lateral boundary condition for a model run, one needs gridded data to cover the entire time period that the model is integrated. The T SD in Appendix 9.1 refers

to t he methodologies and process used to collectively support the MM5 system for CENRAP.

9.4 Model Performance Evaluation Model evaluations compared concentrations of various pollutants simulated by CMAQ and

CAMx with observations from: Interagency Monitoring o f PROtected Visual Environments (IMPROVE)
Clean Air Status and Trends Network ( CAST Net ) Speciated Trends Network (STN) Aerometric Information Retrieval Systems (AIRS)
South Eastern Aerosol Research and Characterization (SEARCH)

Environ evaluated t he CMAQ and CAMx models against ambient measurements of PM species,

gas

- phase species and wet deposition. Numerous iterations of CMAQ and CAMx 2002 base case simulations and model performance evaluations were conducted during the course of the CENRAP modeling st udy, most of which have been posted on the CENRAP modeling website ( http://pah.cert.ucr.edu/aqm/cenrap/cmaq.shtml )

. Details on the final 2002 Base F35

36 km CMAQ base case modeling performance eval uations are provided in the TSD. Due to resource constraints and the similarity between 2002 Base F and 2002 Base G

, the model

evaluation was not re

- conducted for Base G . In general, the model performance of the CMAQ and CAMx models for sulfate (SO4) and e lemental carbon (EC) was good. Model performance for nitrate (NO3) was variable, with a summer underestimation and winter overestimation bias.

P erformance for organic mass carbon (OMC) was also variable, with the inclusion of the enhancement in CMAQ Versi on 4.5 greatly improving the CMAQ summer OMC model performance (Morris et al., 2006c). Model performance for Soil and coarse mass (CM) was generally poor. Environ concluded that the poor performance for Soil and CM was due, in part,

to I MPROVE measured va lues for local fugitive dust sources that are not captured in the model‘s emission inputs and the 36 km grid resolution which is not conducive to modeling localized

events.

The CENRAP TSD contains a detailed model performance, including performance eval uations at

each Class I area in CENRAP. (Appendix 9. 1 )

Appendix 9.1 CENRAP Technical Support Document Appendix 9.2 CENRAP Modeling Protocol36

10 Best Available Retrofit Technolog y (BART) The U.S. EPA‘s 1999 Regional Haze Rule singles out certain older emis sion sources that have not been regulated under other provisions of the Clean Air Act for additional controls. The State

of Nebraska is to require that those older sources that contribute to visibility impairment in a mandatory Class I area to install Best Available Retrofit Technology (BART) unless an

alternative level of control is warranted

. On July 6, 2005, U.S. EPA published a revised final rule, including Appendix Y to 40 CFR part 51 ―Guidelines for BART Determinations Under the Regional Haze Rule‖ t hat provides guidance to states on determining which of these older sources may need to install B ART and how to determine BART.

The rule states that in the case of any fossil

- fuel fired power generation plan t (EGU) having a total generating capacity in ex cess of 750 megawatts, the BART determination must be made pursuant to the guidelines in A ppendix Y. Appendix Y of the guidelines outlines a presumptive emission rate or percent of control for SO 2 and NO
x , dependent of the fuel type (i.e. coal, oil) and

u nit type (i.e. dry

- bottom wall fired, tangentially fired). These presumptive emission rates should be determined as BART for an EGU having a total generating capacity of 750 megawatt
or greater u nless the state can demonstrate, based on careful considerat ion of the statutory five

factors. The five factors are: c ost effectiveness, e nergy and non

- air environmental impacts

,

e xisting controls at source , r emaining useful life of source , and the d egree of visibility improvement which may be reasonably anticipa ted from the technology

.

10.1 Identification of BART

– Eligible Sources in Nebraska

The BART

- eligible sources were identified using the method ology in the Guidelines for BART Determinations under the Regional Haze Rules or ―Guidelines‖

. [ 40 CFR Part 51, App endix Y. ]

For an emission unit source to be identified as BART

- eligible, Nebraska used these criteria from

the Guidelines: One or more emissions units at the facility fit within one of the 26 categories listed in the Guidelines;

T he emission unit (s) were in existence on August 7, 1977 and bega n operation at some point on or after August 7, 1962 ; and

The limited potential emissions from all emissio n units identified in the previous two

bullets emission units were greater than 250 tons or more per year of a ny of these visibility

- impairing pollutant s: SO 2 , NO

x , and PM 10

.

N DEQ utilized its Integrated Information System (IIS) database to identify potential BART

eligible units and major facilities with emission units in one or more of the BART categories

. Onl y those facilities with emission units in one or more of the 26 source categories below are eligible for BART, regardless of emissions potential.37 26 BART Source Categories

(1) Fossil

- fuel fired steam electric plants of

more than 250 million British th ermal units (BTU) per hour heat input, (2) Coal cleaning plants (thermal dryers), (3) Kraft pulp mills, (4) Portland cement plants, (5) Primary zinc smelters, (6) Iron and steel mill plants, (7) Primary aluminum ore reduction plants, (8) Primary cop per smelters, (9) Municipal incinerators capable of charging more than 250 tons of refuse per day, (10) Hydrofluoric, sulfuric, and nitric acid plants, (11) Petroleum refineries, (12) Lime plants, (13) Ph osphate rock processing plants, (14) Coke oven batteries, (15) Sulfur recovery plants, (16) Carbon black plants (furnace process), (17) Primary lead smelters, (18) Fuel conversion plants, (19) Sintering plants, (20) Secondary metal production facilities, (21) Chemical process plants, (22) Fossi l

- fuel boilers of more than 250 million BTUs per hour heat input, (23) Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, (24) Taconite ore processing facilities, (25) Glass fiber processing plants, and (26) Charcoal p roduction facilities.

A survey of facilities was conducted to solicit information concerning potential emissions, age of units, and other relevant factors. The information was compared to known records and the list

was narrowed to the one found in Tab le 10.1.

The facilities with BART

- eligible units in the State of Nebraska are shown in Table 10 .1. More detailed information regarding each facility‘s BART

- eligible units may be found in Appendix

10. 2

.

Table 10 .1 Facilities with BART

- eligible Units in Nebraska Facility Name City Location Facility ID SIC

Code Beatrice Nitrogen Plant Beatrice 3106700001 2873

Ash Grove Cement Louisville 3102500002 3241 Don Henry Power Center Hastings 3100100061 4911

NPPD Gerald Gentlemen Station Sutherland 3111100019 4911 Lon D. Wright Power Plant Fremont 3105300001 4911 CW Burdick Generating Station Grand Island 3107900001 4911

North Denver Station Hastings 3100100040 4911 OPPD Nebraska City Nebraska City 3113100036 4911

NPPD Sheldon Station Hallam 311090005 491 1

OPPD North Omaha Station Omaha 310550002 4911

The Guidelines recommend addressing these visibility

- impairing pollutants: sulfur dioxide (SO 2 ), nitrogen oxides (NO

x ), and Particulate Matter. Nebraska addressed these three pollutants and used particul ate matter less than 10 microns in diameter ( PM 10 ) as an indicator for38

particulate matter to identify BART

- eligible units, as the Guidelines suggests. Consistent with the Guidelines, Nebraska did not evaluate emissions of Volatile Organic Compounds (VOCs)

and ammonia in BART determinations because :
T he majority of VOC emissions in Nebraska are biogenic , rather than anthropogenic, in

nature

. Table 8.2 shows that biogenic VOC emissions are 533,705 tpy. Comparatively, anthropogenic VOCs as shown in Table 8 .1 are 145,242, or just 21.4% of the total.

T he largest areas of anthropogenic VOC emissions in Nebraska exist in the eastern part of the state, in particular the largest metropolitan area of Omaha where VOC emission

control is being u ndertaken as part of an innovative Community Based Planning process where the community is taking proactive steps to control emissions of VOC and NO

x to mitigate ozone levels. The program is called C lean A ir Performance Agreement. As explained in section 8.3.1.5 above, bec ause NO

x and SO 2 are considered limiting pollutants with regard to PM 2.5 formation and the significant uncertainties in the ammonia

inventories as well as in assessing the effect of ammonia emissions reductions on visibility, NDEQ does not consider ammonia among visibility

- impairing pollutants. NDEQ did not identify additional sources with greater than 250 tpy ammonia that required a subsequent BART analysis.

10.2 Determination of Units Subject to BART Under the Guidelines, Nebraska has these options regardi ng its BART

- eligible units : a) make

BART determinations for all units or b) consider exempting some from BART because they do not cause or contribute to visibility impairment in a Class I area. Nebraska chose option  ̳b.‘ Under option  ̳b‘, the Guidelines s uggest three sub

- options for determining that certain sources need not be subject to BART:

(1 ) Individual source attribution approach (dispersion modeling). (2) Use of model plants to exempt sources with common characteristics. (3) Cumulative mode ling to show that no sources in a state are subject to BART.

Nebraska chose the first option and with one exception, required the owner/operator of each

BART

- eligible source to conduct the dispersion modeling using the CALPUFF model

. NDEQ

conducted mod eling for one source (Lon D. Wright). NDEQ reviewed source

- specific analyses conducted by the sources to determine which ones cause or contribute to vis ibility impairment

. The CALPUFF modeling protocol used for determining which facilities are subject to BART is

included in Appendix 10

. 3 . In accordance with the Guidelines, a contribution threshold of 0.5

deciviews

, based on the 98 th percentile of daily modeled visibility impact over an annual period, was used for determining which sources were subject to BART. The Guidelines provide S tate s the discretion to set a lower deciview threshold than 0.5 deciviews if ―the location of a large

number of BART

- eligible sources within the State and in proximity to a Class I area justifies this approach.‖ The 0.5 deci view threshold was selected because it is consistent with the guidelines, the nearest Class I area from any BART

- eligible source is over 300 km away , stretching the reliability of the model, and Nebraska did not have any significant clusters of BART

- eligib le

sources

.39

During the time that NDEQ was reviewing the modeling provided by sources, NDEQ requested the assistance of an EPA Region 7 modeler

. Although, Appendix Y states that CALPUFF is ―the best regulatory modeling application currently availabl e for predicting a single source‘s contribution to visibility impairment and is currently the only EPA

- approved model for use in estimating single source pollutant concentrations resulting from the long

- range transport of primary pollutants‖, the person pr oviding assistance utilized a different model (CAMx) to compare the results provided by one of the facilities, OPPD

- North Omaha Station, and included additional Class I areas in the analysis. The CAMx results were not comparable to the

CALPUFF results; ho wever, the conclusions were the same.

Table 10.2 summaries the conclusions for each of the BART

- eligible units. In order for the NDEQ to consider the source to be contributing to visibility impairment, and thus subject to
BART, the 98 th percentile chan ge in deciview (dV) must have been equal to or greater than 0.5

dV for the source. Table 10.3 details the facilities with BART

- eligible units found to be subject to BART by the State of Nebraska

. Appendix 10.4 contains copies of the letters sent to source s deemed to be not BART

- subject. Appendix 10

. 5 contains more detailed results of the modeling analyses for each BART

- eligible source.

Table 10. 2 BART

- Eligible CALPUFF Modeling Conclusions

F acility Name Modeling Conclusion Beatrice Nitrogen Plant (Koch Nitrogen) Visibility impacts < 0.5 dV. Not BART

- subject.

Ash Grove Cement Visibility impacts < 0.5 dV. Not BART

- subject.
Don Henry Power Center Visibility impacts < 0.5 dV. Not BART

- subject.

NPPD Gerald Gentlemen Station Visibility impacts > 0.5 dV. BART

- subject.

See Table 10.3
Lon D. Wright Power Plant Visibility impacts < 0.5 dV. Not BART

- subject.
CW Burdick Generating Station Visibility impacts < 0.5 dV. Not BART

- subject.

North Denver Station Visibility impacts < 0.5 dV. Not BART

- subject.
OPPD Nebraska City Visibility impacts > 0.5 dV. BART

- subject.

See Table 10.3

NPPD Sheldon Station Visibility impacts < 0.5 dV. Not BART

- subject.

OPPD North Omaha Station Visibility impacts < 0.5 dV. Not BART

- subject.40 Table 10

. 3 Facilities with Units Subject to BART in the Nebraska Facility Name Emission

Units Subject to

BART Pollutants

Evaluated in

BART

Determination 98 th

Percentile

Contribution (dV) Class I area

& Year of Impact

OPPD Nebraska City Unit #1 PM, NO

x , SO 2 0.933 Hercules Glades, M O (2001)

0.556 Hercules

Glades, MO (2002)

0.686 Wichita

Mtns, OK (2003)

NPPD Gerald Gentleman

Station Units #1 &

#2 PM, NO

x , SO 2 2.845 Badlands, SD (2001)

2.828 Badlands, SD

(2002)

3.121 Badlands, SD

(2003)

10.3 Determination of BART Require ments for Subject

- to

- BART Sources

As part of the BART determination, NDEQ considered EPA‘s BART Guidelines (Appendix Y to
40 CFR Part 51 ) for those sources that were required to complete a five factor BART analysis. NDEQ also considered th e State‘s authori ty to implement the regional haze rule under Title 129 Chapter 43 (Appendix 10.9)

.

One of the more important decisions in the BART Guidelines relates to EGUs and facilities that met the presumptive threshold

. NDEQ expec ted these presumptive levels of co ntrol to be cost
effective in most cases. If a facility proposed controls or emission limits less stringent than these presumptive levels, justification incorporating the statutory factors was required.

BART determinations for the three subject

- to

- BART un its in Nebraska were carried out by third

party contractors on behalf of the sources‘ two owners and submitted to the State for evaluation

. All three of the BART units are EGUs, but only two are located at a 750 MW facilit y (NPPD) and are considered by the state to be ―presumptive‖ units.

The third unit, located at OPPD

– Nebraska City Unit #2 (NCS) , is no t considered by the state to be a presumptive BART unit.

A summary of the BART determinations for the BART

- subject sources in Nebraska is shown in

Tab le 10

. 4 for each visibility impairing pollutant. BART is the emission limit for each pollutant based on the degree of reduction achievable through the application of the best system of continuous emission reduction, taking into consideration the technolog y available, the costs of compliance, the energy and the non

- air quality environmental impacts of compliance, any41

pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in vi sibility which may reasonably be anticipated to result from the use of such technology. BART

- subject sources provide an estimated emission

reduction from the 2002 baseline year of 25,137 tons per year of nitrogen oxides

.

Table 10

. 4 BART Determinations f or BART

- subject units in Nebraska Facility Name BART subject

Unit Pollutant Standard /Determination

OPPD Nebraska City Unit #1 PM Existing controls and requirements. Electrostatic precipitator is subject to an existing permit

limit of 0.1 lb/MMBtu.

NO

x Install Low NO

x Burner s

with over fired air. Meet presumptive level of

0.23 lb/MMBtu.

SO 2 No additional controls.

Source currently uses low

sulfur coal.

NPPD Gerald Gentleman

Station Units #1 & #2 PM Existing controls and requirements. Baghouses sub

ject to an existing permit limit of 0.1

lb/MMBtu.

NO

x Install Low NO

x Burner s

with over fired air. Meet presumptive level of

0.23 lb/MMBtu.

SO 2 No additional controls.

Continue to use low sulfur

coal.

10.4 BART Determination Process

The BART determina tion process is comprised of the following basic steps:

Step 1: Identify all retrofit control technologies: All control technologies for similar processes, as well as Best Available Control Technology ( BACT) and Lowest Achievable Emission Rate (LAER) tech nologies must be considered. Control technologies should include pollution prevention, use of add

- on controls, and combinations of the two. The owner/operator is not expected to purchase or construct a process or control device that has not already been de monstrated in practice. Step 2: Eliminate technically infeasible options: Technologies demonstrated to be technically infeasible based on physical, chemical, and engineering principles are excluded from further consideration. Physical modifications needed to resolve technical obstacles do not, by themselves, provide justification to eliminate a technology.42

Step 3: Rank remaining technologies by control effectiveness: Technically feasible control technologies are ranked in the order of highest expected emis sion

reduction to lowest expected emission reduction. The ranking also includes expected emission rate, control effectiveness, energy impacts, environmental impacts (including toxic and hazardous air emissions), economic impacts, and visibility impacts.

S tep 4: Evaluate most effective controls (non

- air quality impacts) and document results: The technology ranking is evaluated and case

- by

- case consideration is given to costs of

c ompliance, energy impacts, non

- air quality and other environmental impacts, and remaining

useful life of the unit. NDEQ used an incremental cost effectiveness threshold of $5,000 per ton. Step 5: Evaluate Visibility Impacts: Modeling analyses are performed on the pre

- and post

- contro l emissions to determine actual impact on visibilit y. The NDEQ has evaluated visibility improvement balanced with the cost of compliance in determining the best, most appropriate option for BART as allowed under Appendix Y. This was done through a cost per deciview of visibility improvement factor, which

i s similar to the cost per ton of pollutant removed from the atmosphere that is used in the BACT

process.

The Regional Haze Rules provide that States may conduct the analysis in the order they choose and that they may weigh each factor as they deem appropr iate.

There were a few factors that informed Nebraska‘s decision as to how to evaluate visibility improvement. First, the purpose of this program is to drive visibility improvement; therefore, any control technology would need to have a benefit on visi bility improvement in order to

warrant further evaluation. Nebraska does not have Class I areas. The closest Class I areas are located in the states of Missouri, South Dakota, Oklahoma, and Colorado. For the two BART

subject sources, the nearest Class I areas are over 300 km away. The CALPUFF model has limited reliability at distances beyond 200 km, therefore, NDEQ took into account, the magnitude and frequency of predicted improvement, whether additional control provided sign ificant, measureable avera ge benefit (>0.5 dV ) at the closest Class I areas and whether such control would improve this average level of visibility for less than $40,000,000 per deciview and $400,000 per day of improvement. NDEQ used the cost per deciview and cost per day of impro vement as indices of the frequency of improvement as well as the cost effectiveness.

The NDEQ als o weighed the non

- air quality impacts very carefully, in particular whether the

amount of visibility improvement would result in other environmental issues. For example, if there was information indicating that investing in controls for haze purposes would result in another significant environmental (non

- air quality) burden, such as impacts to water or land, NDEQ weighed that information heavily against the level of visibility benefit. NDEQ believed it was important to weigh all of these factors carefully because of the distance to Class I areas, the

limited number of BART sources and the limitations of the model.

10.5 Summary of BART Determination

- OPPD

10.5.1 Nebrask a City Station Unit #1

– Not a Presumptive Unit Prior to embarking on a BART determi nation, NDEQ first needed to d e termine whether the OPPD NCS Unit #1 should be included as a presumptive unit.43

On July 6, 2005, the US EPA issued guidelines on conducting a BART determination, which are

contained in Appendix Y of 40 CFR Part 51. States must follow these guidelines in making

BART determinations on a source

- by

- source basis for 750 megawatt (MW) and larger power plants but are not required to use the guidelin es when making BART determinations for other types of BART sources, including those with a total plant capacity less than 750 MW.

When an early draft of the BART proposal was shared with the Federal Land Managers, a question was raised as to the status o f the total plant capacity at NCS. At i s sue was whether NCS Unit 2 should now be considered part of the total plant capacity at NCS for purposes of determining BART applicability. Since the CAA and the BART regulations did not speak to the specific issue o f a source becoming a 750 MW facility after the BART rules were promulgated, the NDEQ raised the question with the US EPA and received a response on November 10, 2008. The response read ―we believe that it is a reasonable interpretation to assume that if t he plant is greater than 750 megawatts at the time the BART determination is made by the state (i.e. at the time the state places the BART determination on public notice) then any unit at the plant greater then [sic] 200 megawatts is subject to presumptive BART.‖ US EPA Region 7‘s response did not
address whether it is sufficient to have commenced or begun actual construction on Unit 2, or whether Unit 2 must be operational. The NDEQ‘s conclusion is that the plant‘s commercial operational capacity must be 7 50 MW or more. Since Unit 2 was not yet commercially operational at the time of the BART determination , NDEQ determined th at NCS, for purposes of

BART had a plant capacity of less than 750 MW. Therefore, it is not mandatory for NDEQ to follow 40 CFR 51 App endix Y for federal purposes.

To further substantiate NDEQ‘s conclusion, NDEQ conducted a careful review of the June 2005 ―Regulatory Impact Analysis for the Final Clean Air Visibility Rule or the Guidelines for Best Available Retrofit Technology (BART) D eterminations under the Regional Haze Regulations‖ (RIA), the Federal Register July 2005 final preamble, and the rule. NDEQ believes that t hese documents provide clarification as to how the US EPA intended for states to aggregate multiple units at a power plant in order to determine whether the 750 MW threshold is crossed.

First, in the preamble to the July 6, 2005, Regional Haze/BART rule, on page 39112, middle column, EPA states:

“Finally, the approach to identifying a “BART

- eligible source” in the gu idelines is based on the definitions in the regional haze rule of the relevant terms. For 750 MW power plants, States are required to apply the definitions as set forth in the guidelines; for other sources, States may adopt a different approach to the tas k of identifying BART eligible sources, so long as that approach is consistent with the ACT and the implementing regulations. In other words

, while the guidelines adopt an approach for large power plants which involves the aggregation of all emission unit s put into place between 1962 and 1977 (emphasis added) , States have the flexibility to consider other reasonable approaches to the question of identifying BART

- eligible sources for other source categories.”

Therefore, NDEQ determined that individual EGU s that were put into place between 1962 and 1977 be aggregated for purposes of determining whether a power plant meets the 750 MW capacity threshold for applying presumptive

- level BART.44

Further support of the NDEQ determination is found in Appendix B of the RIA includes a memo from Perrin Quarles Associates, Inc (PQA) dated July 19, 2004. The memo provides a summary of the analysis PQA conducted for EPA to develop supporting materials for the Regional

Haze/BART rule. The memo states that “Based on EPA guidance, the original analysis also

assumed that BART

- eligible units are only those that are located at a plant where the total capacity of all units within the BART timeframe exceeds 750MW.” Attached to the memo are

two tables which include NCS #1 with the listed capacity at around 616 MW. The first table also lists much smaller units located in Nebraska that were potentially put into place during the BART timeframe (1962

– 1977). The second table includes NCS #1 as a potentially BART

subject source, b ut no

- where does the table indicate that the sources on the table are subject to the presumptive levels in the guidelines. The reasonable conclusion NDEQ draws from the inclusion of NCS #1 in the second table is that NCS #1 could potentially have a contri bution to a Class I area above the 0.5 deciview threshold on more than one day, triggering the need for further analysis and the potential need for BART to be applied to one or more visibility impairing pollutants.

Therefore, NDEQ concluded that EPA‘s r ecord support ed a decision that OPPD Nebraska City Station is not a presumptive BART source.

Nevertheless

, given the size of the unit at OPPD, NDEQ concluded it was still appropriate to evaluate the necessity of BART controls at NCS Unit #1, and used th e five

- factor analysis as a guideline.

The BART analysis conducted for OPPD NCS is included in Appendix 10.6. Appendix 10.7

contains any additional supporting information that was provided by the OPPD

.

BART for each subject

- to

- BART source was deter mined by the State using the methodology in

the Guidelines. These BART emission standards summarized above have been included in BART permits for each source and are in Appendix 10.8. Included in Appendix 10.8 is the State‘s rationale, including its eval uation of the full five

- factor analysis for the BART

determinations

, and responses to comments received during the public processing of each of the BART permits.

10.5.2 BART Determination Summary for PM Prior to evaluating BART, NDEQ evaluated whether PM control would be necessary for purposes of visibility improvement.

The baseline case model indicated that the direct particulate emissions were generally responsible for well under 1% of the total predicted change in deciview impa ct from NCS . In fact, PM only a ccounted for 0.32% of the greatest deciview impairment Unit 1 estimated for (0.933 in 2001 at Hercules Glades in Missouri). This would indicate that the predicted deciview impact is from a pollutant or pollutants other than PM. The results confirm ed that t he direct particulate matter emissions from NCS do not significantly contribute to visibility impairment

.

NDEQ concluded that b ased on the fact that NCS Unit 1 appears to be currently adequately controlled by an electrostatic precipitator (ESP), is subje ct to an emissions limitation of 0.145

lb/MMBtu (Title V OP), and the modeling results revealed that direct particulate emissions do not significantly contribute to visibility i mpairment in Class I areas, BART for PM is existing controls and requirements.

10.5.3 B ART Determination Summary for SO 2 For a full summary of the SO2 control technologies evaluated and eliminated during the BART process, please see Appendices 10.6

– 10.8.

S crubber technology is a technically feasible SO 2 retrofit technology that could be implemented

on Nebraska City Station (NCS) Unit 1. NDEQ evaluated the effectiveness of this technology at

the 0.15 lb/MMBtu and at 0.1 lb/MMBtu levels for SO 2

. Table 10. 5 provides a summary of the

cost effectiveness at 0.10 lb/MMBtu

.

Table 10.5 SO 2 Controls (0.10 lb/MMBtu level)

2001 (Hercules Glades) 2003

(Wichita Mtns) Average

Baseline 0.933 0.686

98 th Percentile Impact 0.493 0.311 dV improvement 0.440 0.375 0. 0.408 Baseline Days 14 10 12 Days over 0.5 dV 7 6 7 Total Days improved 7 4 5

C ost per dV $78,909,091 $92,586,667 $ 85,747,879 Cost per ton $1,636 Cost per ton per dV $3,718 $4,362 $4

, 040 Cost per day of Improvement $4,960,000 $8,680,000 $ 6,820,000

As stated in Chapter 8 of the Regulatory Impact Analysis (RIA) the US EPA prepar ed for the Regional Haze rule, high cost control measures that have only minimal effect on visibility improvement can be avoided. Using scrubbing technology would be expected to result in the number of days where NCS‘s impact contributed to more than 0.5 dV to decrease from 14 days to 7 days during the worst meteorological year for Hercules Glades and from 10 days to 6 days

for Wichita Mountains. The BART guidelines do not provide a level to which individual sources must reduce their visibility impact, lea ving it up to the state‘s judgment. As further discussed and substantiated in Chapter 11, the PSAT apportionment modeling and the Causes of Haze study show that SO 2 emissions contributing to visibility in the Class I areas in Missouri are coming from the Ohio River Valley area

.

Areas of influence and apportionment of Nebraska‘s SO 2 emissions were evaluated in the August
31, 2005, Causes of Haze Study conducted by Sonoma Technology, Inc. This study may be

found on CENRAP‘s website (www.cenrap.org). Sonom a concluded that because the emission impact potentials (EIPs) of potentially BART

- eligible sources are relatively small, the enforcement of BART requirements will produce limited improvement in visibility conditions and require the need for additional emi ssion reduction strategies. Emission impact potentials relate the probability of transport of SO 2 and NO

x pollution from an area such as a state to a Class I area and the scale of emissions in that given area (State). In Figures 4

- 8 and 4

- 9 of the46

study, N ebraska BART sources have an insignificant EIP, specifically for the Hercules Glades

Class I area.

Therefore, due to the costs for the amount of visibility improvement being high, meaning that the amount of visibility improvement would be small compared to the amount of investment, the

lack of certainty of contribution of sulfate from Nebraska sources , given the distance, and the lack of Missouri needing controls from Nebraska at this time, NDEQ concluded NCS did not require additional SO 2 controls.

10.5.4 BART Determination Summary for NO

x For a full summary of the NOx control technologies evaluated and eliminated during the BART process, please see Appendices 10.6

– 10.8.

Low NO

x burner with over

- fire air (LNB/OFA) technology is a feasible NO

x retrofit tech nology that could be implemented on NCS Unit 1. The cost effectiveness of this control technology is $135.55 per ton NO

x removed ($1,380,000 / 10,181 tons NO

x removed ) . The lowest incremental visibility impairment improvement cost is $4,600,000 per year pe r change in deciview at
Hercules Glades in Missouri . The NDEQ determined that at a minimum, LNB/OFA would be required for BART. Using LNB /OFA technology would be expected to result in the number of days where NCS‘s impact contribut ing to more than 0.5 dV t o decrease from 14 days to 9 days during the worst meteorological year for Hercules Glades and from 10 days to 9 days for Wichita

Mountains in Oklahoma

.

The incremental costs of adding s elect catalytic reduction (SCR) to the LNB/OFA system would be $8,583 per ton of NO

x . NDEQ estimated that the incremental visibility impairment improvement cost of approximately ranged $82,479,167

- $1,799,545,455 for a SCR+LNB/OFA

system

. The incremental visibility improvement of adding SCR to the LNB/OFA system ranged

0 .022

– 0.48 dV with an average of 0.17 dV.

Table 10.6 Low NO

x Burner with Over

- Fired Air Evaluation

– OPPD NCS 1

2001 (Hercules Glades) 2003

(Wichita Mtns) Average

Baseline 0.933 0.686

98th Percentile Impact 0.633 0.531

dV improvement 0.300 0.155 0. 228 dV Baseline Days 14 10 12 Days over 0.5 dV 9 9 9 Days improved 5 1 3 Cost per dV $4,600,000 $8,903,226 $ 6,751,613 Cost per ton $136 Cost per day of improvement $276,000 $1,380,000 $ 828,00047

Table 10.7 Low NOx Burner with Over

- Fired Air Ev aluation with SCR

– OPPD NCS 1

2001 (Hercules Glades) 2003

(Wichita Mtns) Average

Baseline 0.933 0.686

98 th Percentile Impact 0.453 0.447

Incremental dV improvement over

LNB/OFA 0.180 0.084 0. 132 dV

Total dV improvement 0.480 0.239 0. 360 dV

Baselin e Days 14 10 12 Days over 0.5 dV 7 6 6 Incremental days improved over LNB/OFA 2 3

Total Days improved 7 4 6 Cost per dV $82,479,167 $165,648,536 $ 124,063,851 Incremental Cost per dV $212,277,778 $454,880,952 $ 333,579,365 Cost per ton $2,706

Incre mental cost per ton $8,583 Cost per day improvement $5,655,714 $9,897,500 $6,598,333
Incremental cost per total days improvement $5,458,571 $9,552,500 $6,368,333

As stated in Chapter 8 of the RIA EPA prepared for the Regional Haze rule, high cost con trol measures that have only minimal effect on visibility improvement can be avoided. Adding SCR to LNB/OFA technology would be expected to result in the number of days where NCS‘s impact contributed to more than 0.5 dV to decrease to 6 days during the wor st meteorological year for Hercules Glades and to 7 days for Wichita Mountains. As indicated in the Causes of Haze assessment for Glades (see http://www.coha.dri.edu/doc/ conceptualmodels/ConceptualModel

HEGL1.pdf

), sulfates comprise more than 50% of the components contributing to light extinction. Nitrates make up an average of 13.5%, of which Nebraska contributes less than

4.4%. Using incremental cost effectiveness p er ton of $5

, 000, the addition of SCR was deemed

not cost effective. For the above reasons, LNB/OFA control was deemed appropriate for OPPD

NCS. Therefore BART for OPPD NCS Unit 1 was determined to be the installation of

LNB/OFA with an emission limitati on of 0.23 lb NO

x /MMBtu.

For more details on the BART determination for OPPD, see Appendices 10. 6

– 10.8

10.6 Summary of BART Determination

- NPPD

10.6.1 BART Determination Summary for PM Prior to evaluating BART, NDEQ evaluated whether PM control would be necessar y for purposes of visibility improvement.

The baseline case model results indicated that the direct particulate emissions were generally responsible for less than 1% of the total predicted change in deciview impa ct from NPPD GGS48

Units 1 and 2 at any Clas s I areas

. The se results demonstrate that the direct particulate matter

emissions from GGS Units 1 and 2 do not significantly contribute to visibility impairment

. Furthermore, GGS Units 1 and 2 are controlled by the baghouses, the best technology availab le for PM. NDEQ concluded that b ased on the fact that GGS Unit s 1 and 2 are currently controlled by the best technology available for direct PM emissions, and are subject to an emissions limitation of 0.1 lb/MMBtu (Title V OP), and the modeling results re vealed that direct particulate emissions do not significantly contribute to visibility i mpairment in Class I areas, BART for PM

is existing controls and requirements.

10.6.2 BART Determination Summary for NO

x For a full summary of the NOx control technologies ev aluated and eliminated during the BART process, please see Appendices 10.6

– 10.8.

LNB/OFA technology is a feasible NO

x retrofit technology that could be implemented on GGS

Units 1 and 2. The total annualized cost associated with the installation of LN B/OFA is $2,960,000. The average cost effectiveness of this control technology is $198 per ton NO

x removed ($2,960,000 / 14,956 tons NOx removed).

Utilizing SCR technology is also feasible , however in order to install SCR, LNB/OFA must also

be utili zed. The incremental cost effectiveness (incremental cost SCR) is $5,445 per ton NO

x removed, over 25 times the amount of LNB/OFA alone. The average incremental improvement in visibility for the addition of SCR to LNB/OFA is less than 0.5 dV and improvem ent would be seen on an average of 7.3 days per year. Refer to Table s 10. 8 & 10.9 for a comparison of the control options and the effectiveness.

Table 10.8 Low NO

x Burner with Over

- Fired Air Evaluation

- NPPD

2001

Badlands 2002

Badlands 2003

Badlands Average

Baseline 2.845 2.828 3.121

98 th Percentile Impact 2.224 2.162 2.419 dV improvement 0.621 0.666 0.702 0.663 Baseline Days 54 55 60 56 Days over 0.5 dV 49 52 54 51 Days improved 5 3 6 5 Cost per dV $4,766,506 $4,444,444 $4,216,524 $4,464,555 Cost per ton $198 Cost per day of improvement $953,301 1481481 $702,754 $ 592,000

The total annualized cost associated with the installation of LNB/OFA and SCR is $57,251,000.

The cost effectiveness of LNB/OFA and SCR is $2,297 per ton NOx removed ( $57,251,000 / 24,926 tons NOx removed). The incremental cost effectiveness calculation compares the costs and performance level of a control option to those of the next most stringent option. The incremental cost analysis of installing LNB/OFA and SCR as opposed to LNB/OFA alone is $5,445 ([$57,251,000

- $2,960,000] / [24,926

– 14,956]).49

Table 10.9 L ow NO

x Burner with Over

- Fired Air Evaluation with SCR

- NPPD

2001

Badlands 2002

Badlands 2003

Badlands Average

Baseline 2.845 2.828 3.121

98 th Percentile Impact 1.732 1.728 1.879

Incremental dV improvement over

LNB/OFA 0.492 0.434 0.540 0.489

Total dV improvement 1.113 1.10 1.242 1.118

Baseline Days 54 55 60 56 Days over 0.5 dV 44 41 48 44 Incremental days improved over LNB/OFA 5 11 6 7

Total Days im proved 10 14 12 12 Cost per dV $51,438,454 $52,046,363 $46,095,813 $ 51,208,408 Incremental Cost per dV $110,347,560 $125,094,470 $100,538,889 $ 111,024,540 Cost per ton $2,297
Incremental cost per ton $5,445 Cost per day of Improvement $5,725,100 $4,089,357 $4,770,917 $ 4,770,917

Incremental Cost per total day s improvement $5,429,100 $ 3,877,929 $ 4,524,250 $ 4,524,250

NDEQ determined that the incremental cost for the addition of SCR is excessive (>$5,000 per ton) and that LNB/OFA would be required for BART.

For more details on the BART determination for NPPD, see Appendices 10. 6

– 10.8

.

10.6.3 BART Determination Summary for SO 2 The BART Determination for SO 2 for NPPD was different from OPPD in that impacts to water were raised during NDEQ‘s review that required consideration. Appendix Y to Part 51

– Guidelines for BART Determinations under the Regional Haze Rule provides guidance on evaluation of the ―costs of compliance‖ and ―non

- air quality environmental impacts.‖ One of the factors is taking into co nsideration the extent of the short term environmental gains at the expense of long term environmental losses and the extent to which there may be an irreversible or irretrievable commitment of resources. The water demands of scrubber systems (wet or dry) relate to a commitment of scarce water resources, costs of compliance, and non

- air quality environmental impacts. NDEQ conducted further analysis into the available water resources in Nebraska and discussed the impact with the agencies and persons respons ible for the management of water quantity in the state. NDEQ solicited the assistance of the State Department of Natural Resources, the Twin Platte‘s Natural Resource‘s District Manager, and

the Nebraska Association of Natural Resource Districts in its re view as well as answering initial questions raised by EPA Region VII.50

The BART Determination Process is summarized here , more details may be found in Appendices

10. 6

- 10.8. The information on the DSI evaluation may be found in Appendix 10.13.

Upon comp letion of Steps 1

– 2 of the BART Determination Process, scrubbing technology was

identified as a technically feasible SO 2 retrofit technology for NPPD Gerald Gentleman Station ( GGS ) Units 1 and 2.

Prior to taking into account the other environmental ef fects

, t he average cost effectiveness of using scrubbing control technology is approximately $2,500

– $2,700 per ton SO 2 for both units

, combined. NDEQ believes this cost per ton removed seems reasonable. However, as discussed further below, NDEQ has det ermined that additional SO 2 controls are not reasonable, due, in part to the excessive cost effectiveness in terms of cost per benefit in terms of visibility improvement.

10.6.3.1 Unique Water Impacts in the Twin Platte Basin Surface water and groundwater are bot h used for irrigation for purposes of crop production in the

state

. Irrigated crops have higher yields and irrigated lands are of higher value than non

- irrigated cropland. (Lamphear October 2005) (See Appendix 10.7.) Water resources are also critical to

c onservation of endangered and threatened species and their habitats. The State of Nebraska has

several unique laws in place to not only protect , but also increase, stabilize and allocate its water

resources.

In 2004, the Nebraska Legislature enacted LB 9 62, which went into effect in July 2004. This law required the Department of Natural Resources (DNR) to identify geographic areas where surface water and ground water are hydrologically connected. Th is innovative law requires the integrated management of water resources through the identification of river basins where water resources were already fully

- appropriated and other areas where the basins were over

appropriated.

A basin is considered fully

- appropriated if the current uses of hydrologically con nected surface water and groundwater in a basin cause, or will cause in the reasonably foreseeable future, (a) the surface water to be insufficient to sustain over the long term the beneficial purposes for which the existing surface water appropriations we re granted, (b) the stream flow to be insufficient to sustain over the long term the beneficial uses from wells constructed in aquifers dependent on recharge from the basin‘s river or stream, or (c) reduction in stream flow sufficient to cause

Nebraska to be in noncompliance with an interstate compact or decree, formal state contract, or state or federal laws. Therefore, in fully

- appropriated and over

- appropriated basins, a plan for

future water use must be established

.

The statutory definition of an ov er

- appropriated basin is very precise and relate s to conditions at a single point in time, July 16, 2004. Areas that were designated as over

- appropriated were required to develop a n integrated management plan to reduce water use to the 1997 level of use

w ithin the next 10 years. In over

- appropriated areas, the water demand already exceeds the current availability of water and the law requires steps be taken to mitigate the situation. An

over

- appropriated area is causing depletion to occur not only in t he immediate area, but potentially downstream as well. For both fully and over

- appropriated areas, moratoriums are presently in place on the construction of new large capacity water wells (greater than 50 gallons per minute) and surface water rights

.51

O nce a basin has been designated as fully or over

- appropriated , each local Natural Resource District (NRD) must work in conjunction with the State N DNR to develop an Integrated Management Plan (IMP) to either make certain the basin does not become over

- appr opriated or to find ways to recharge or augment the water resources in a manner such that the basin is no longer over

- appropriated. The 23 local NRDs are distinctive to Nebraska and have been in existence since 1972. They are charged with water shed mana gement and are equipped to best respond to the local needs of their district.

The concept of developing an integrated management plan for watershed management is analogous to the air quality state implementation planning process for non

- at tainment or

at tainment areas. While t he development of the basin IMP may take three to five years,

r echarging the system to a sustainable level is expected to take many more years.

GGS is located in a semi

- arid region of Nebraska in a portion of the Twin Platte NRD t hat has been designated by the Department of Natural Resources Director as over

- appropriated. Below are maps detailing the relationship between the surface water and ground water in the area, the areas that have been identified as being fully

- appropriated or over

- appropriated, and the areas within the Twin Platte NRD that are currently under a moratorium prohibiting the construction of

new water wells greater than 50 gallons per min ute or increasing irrigated acres (effective June 18, 2007).

As previously noted, the NDNR and the local NRDs involved are required to jointly develop and implement an integrated management plan within three to five years of a fully or over

appropriated d esignation. An Integrated Management Plan (IMP) for the Twin Platte NRD h as been approved and took effect September 15, 2009 (Appendix 10. 11 ). The purpose of the IMP is to manage all hydrologically connected groundwater and surface water for the purpose of sustaining a balance between demand and availability so that the econom ic viability, social and environmental health, safety, and welfare of the basin can be achieved and maintained for both the near and long

- term.

The Twin Platte NRD estimates that in order to return to 1997 levels, the NRD will need to

return 7,700 acre

- fe et of already difficult to find offset water to the river that i s hydrologically connected within the region and another 33,750

- 67,450 acre

- feet in order to return to fully appropriated status.52

Figure 1: Areas with Hydrologically Connected Su rface Water to Ground Water

Approximate Location of GGS

Figure 2 : Over Appropriated Surface Water of Nebraska53 Figure 3 : Current Moratoriums on New Water Uses

Approximate Location of GGS

Figure 4 : Well Drilling Suspensions and Stays on Irrigation within Twin Platte NRD54

ND EQ searched for information on the water demands of dry scrubbers to determine whether th e estimates provided by NPPD were reasonable. Actual water usage information for comparable operating existing facilities that had been retrofitted was difficult to locate, but information on proposed units was found, and is summarized in T able 10. 10 belo w:

Table 10. 10 Scrubber Water Usage Gallons Per Minute/Megawatt (GPM/MW) Facility Name State MW GPM/MW (dry) GPM/MW

(wet) Round Up Montana 780 0.743 1.03

Dave Johnston (existing) Wyoming 360 0.689 0.917

Noborne Missouri 680 0.912 1.22 Dry Fork Montan a 590 0.578 0.723 Dry Fork Texas 920 0.707 0.891 Paradise (existing) Kentucky 1150 1.47 1.92

NPPD Nebraska 1365 1.47 1.76

Average 0.938 1.21

NPPD projected water usage at 1.47 GPM/MW of generation for dry scrubbing and 1.76

GPM/MW for wet scrubbin g . While, it would appear that the water usage estimates submitted by NPPD are higher than the average, NPPD stated during a meeting with NDEQ that their estimates were for total water consumption for the project, not just for the scrubbers.

Information relating to water quality, additives, pH, and other parameters, were not available to the NDEQ for analysis. Quality of water available to a source could have an impact on the efficiency of the device, how it is designed and ultimately how much water must be used to

achieve the desired level of control. Although on the high side, t he water values provided by NPPD are within the range of other facilities currently in operation, particularly the one of a similar size in Kentucky as noted in the table above.

Based on the information available, NDEQ concluded that NPPD‘s water consumption estimates for wet and dry scrubbers were not unreasonable. To be conservative in its analysis , NDEQ used both the average and NPPD‘s values for analyzing NPPD‘s water dem ands against water availability in Nebraska.

Table 10.11 Potential Scrubber water requirements for NPPD

- GGS

GPM/MW (dry) GPM/MW

(wet) MW GPM

(dry) GPM (wet) Acre

- Feet

per Year (dry) Acre

- Feet

per Year (wet)

NPPD 1.47 1.76 1365 2007 2402 3238 3877

Ave rage 0.938 1.21 1365 1280 1652 2065 2666 1 million gallons = 3.07 acre

- feet 525,600 minutes per year55

10.6.3.2 Platte River Recovery and Implementation Program

As is evident with the over

- appropriated status designation, the demand for beneficial uses of

water i n the area where GGS is located is considerable. In 1997, the Governors of Nebraska, Colorado, and Wyoming, and the U.S. Secretary of the Interior signed a cooperative agreement outlining a proposed basin

- wide recovery implementation program for endangere d species in the Central and Lower Platte river basins. In 2007, the Department of Interior, Colorado, Wyoming and Nebraska entered into an agreement called the Platte River Recovery and Implementation Program (PRRIP) to restore shortages to U.S. Fish and Wildlife Service (USFWS) target flows in the Platte River, thereby protecting endangered and/or threatened species whose habitat is the

Platte River. These agreements were the result of settlement negotiations in the Grayrocks Dam litigation and the FER C relicensing of Lake McConaugh y. The threatened and endangered species identified for protection include the piping plover

, pallid sturgeon, least tern, and whooping crane. Substantial offsets to current water use are required in order to meet the PRRIP needs as well as the required IMP reductions. While the total potential water needs for both the PRRIP and IMP may not necessarily be mutually exclusive, they are substantial over the near and long term.

The requirements of the PRRIP are in addition t o the requirements of LB962. The PRRIP is also set up to restore the shortages to USFWS target flows in an incremental fashion. During the first increment, the goal is to restore between 130,000 and 150,000 acre

- feet per year. Of this, 80,000

acre

- feet per year has already been obtained through project commitments from the three states, for a remaining requirement of 50,000 to 70,000 acre

- feet per year

. For more information about

the PRRIP see http ://platteriverprogram.org/default.aspx

. Should the requirements of the PRRIP not be met, Lake McCona ug hy‘s FERC license would be reopened.

The outstanding existing commitments and obligations of both LB962 and the PRRIP are

estimate d below:

1 ST Inc rement of PRRIP

3 Sta te Projects 80, 000AF

Remainder 50,000

– 70,000AF

Return to 1997 Levels (LB962) 26,200 AF (Current Estimate

- Basin ) Twin Platte NRD only 7,700 AF

Potential 2 ND Increment

– PRRIP 137,500 AF (Current Estimate)

Return to “Fully Appropriated

– LB 962 114,750

– 229,500 AF (Current Estimates

- Basin ) Twin Platte NRD only 33,750

- 67,450 AF

Potential 3 rd Increment

– PRRIP 137,500 AF (Current Esti mate)

TOTALS 545,950

– 680,700 AF

The expected demands of scrubbing at the NPPD GGS facility is 2,000 to 3,900 acre

- feet per

year, or 26%

- 51% of Twin Platte‘s estimate for their requirements for meeting initial obligations under LB962, and 7.6

– 29% for the entire basin‘s initial obligations to return to 199756

levels. The NDNR has informed the NDEQ that this additional demand represents a significant amount of the overall initial increment required for the basin, and that placing this additi onal demand on the basin jeopardizes Nebraska‘s ability to meet commitments made to other states and the federal government, as well as the requirements of State Law relating to over

appropriated basins described above.

10.6.3.3 Acquisition of Allocations and Offs ets (Costs of Water) In order for NPPD to obtain sufficient water for the scrubbers, it would need to acquire water from somewhere or someone else. There are two options for this: 1) transport the water from a location that has a suitable water supply, or 2) purchase existing water rights owned by someone

else and retire the wells to ensure the offset is permanent.

Costs of Transporting Water

A study conducted by the State of Nebraska Water Management Board, the Report on Water Rights Transfer Study (1988 ), found that since water rights were not traded routinely in a market situation, there was no demand curve for determining a cost schedule. The report concluded that

economics in these situations will rely on willingness or ability to pay and the least c ost alternatives. For industries, water is relatively hard to transfer compared to other inputs because transfers of water for industrial purposes are subject to additional statutory requirements , so typically a site is chosen where there is an adequate s upply of water. Several other factors impact the costs of transferring water: well construction, pipeline construction, pumping plants, land, energy, operation and maintenance. Pipeline costs are the most significant fixed cost. Energy is the largest cost of operation.

A study conducted by the High Plains Study Council, ―A Summary of Results of the Ogallala Aquifer Regional Study, With Recommendations to the Secretary of Commerce and Congress‖ (1982), evaluated the potential for transferring water w ithin the High Plains area. Four routes were evaluated, including one that started at Fort Randall, South Dakota, moved southwesterly

across Nebraska

, nearin g the Sutherland, Nebraska area, to storage near Bonny Reservoir in

Eastern Colorado. In 1977 dol lars the average costs for this project were:

Table 10. 12 Summary of Costs to Transfer Water

Water

Studied

for

Transfer Route

Length Elevation

Change #

Pumping

Stations Total Energy

Requirements (Million KWHr/yr) Total

Construction

Costs (1977 $) Avera ge

Annual

Cost ($/acre

- ft)

1.91

– 3.4

million

acre

- ft 813

miles 0 ft 18 6,600

– 14,300 5.4

– 8.9

billion 291

The acre

- ft involved in the above study is significantly larger than that which would be required for NPPD. Looking at the construction costs alone, the costs equate to $ 6.6

– 10.9 million per

mile in 1977 dollars ($5.4

- 8.9 billion/813 miles)

. Converting to 2007 dollars would increase the costs to $16.46

- 27.1 billion/813 miles, or $20.2

– 33.3 million/mile. Sutherland, NE is approximately 30 0 miles from Fort Randall, SD. Using the above study as a guide, i t would cost NPPD, and thus the citizens of Nebraska, nearly $ 6 billion to construct a water pipeline ( 200 7 dollars) from Fort Randall, SD

. If water could be found closer, in an area that was not fully or57

over appropriated, where a moratorium does not currently exist, the closest area would be approximately 50 miles from NPPD, making it just over $1 billion to transport water. Annualizing costs at a rate of 7% over 20 years resulted in the costs associated with water transport to be estimated at $94,392,925

– $566,357,554.

The costs to transport water increased t he annu alized cost associated with FGD at GGS from $108,450,000 to $ 202,842,925

- $674,807,554. The cost per ton for this control technology is $ 4,702

– $15,643 per ton SO 2 removed ($202,842,925

- $674,807,554 / 43,138 tons SO 2 removed) based on an emissions rate of 0.1 0 lb/MMBtu. The mean (average) cost per ton removal rate would be $10,172 per ton. The NDEQ determined that the cos ts to transport water

were cost s prohibitive for NPPD as a BART SO 2 measure

.

Costs of Obtaining Water Rights and Retiring Wells

There are two sources of water in the state: surface water and groundwater.

Surface water is subject to prior appropriation and governed by water rights under the jurisdiction of the NDNR which are prioritized by the legal concept of ―first in time, first in
right.‖ (Neb. Rev. Stat. § 46

- 203 th rough 46

- 205 ) See Appendix 10.12

. Therefore, were NPPD

to find a surface water ri ght that was available, retiring that right would only mean that the next existing priority in line would receive that water. NPPD could not obtain a new water right given that the basin in which it is located or near are all fully

- appropriated or over

- ap propriated. Even if a new surface water appropriation could be obtained, NPPD would be the newest and lowest priority water right in the chain. Therefore, surface water rights are not considered to be available to NPPD for purchase or transfer

.

Groundwa ter is managed by the regional Natural Resource s Districts , which are political subdivisions created by statute

. Historically, groundwater has not been subject to an appropriation system similar to that applied to surface water. The owner of the overlyin g land could use groundwater for reasonable uses subject to the correlative rights of other landowners. Groundwater in and of itself is publicly owned in the State of Nebraska. Consequently, the value of groundwater to a landowner is often inextricably l inked to the value of the land itself, i.e. irrigated cropland versus non

- irrigated cropland.

Management of groundwater use is becoming increasingly integrated with surface water after the passage of LB 962 discussed above. Due to the moratorium on new wells described above,

NPPD would have to find existing groundwater wells , such as irrigation wells and retire those

wells , before NPPD could drill a new groundwater well

.

The cost of retiring a groundwater well will vary depending upon the situation l argely based on the existence of a willing seller

. For agricultural uses of water, the decision to retire a well would be made only when/if the irrigator felt it would be more advantageous to sell than

continue to irrigate

— the seller could convert to dry land agriculture but could not resume irrigation after the well has been retired . If the irrigator were willing to forego the use of this resource, the price for that water right would presumably have to be sufficient to compensate for

decreased net retur ns over a period of years and a decrease in overall land value from irrigated to

non

- irrigated

. Decreased land value impacts a variety of other entities, including taxing authorities, which have not been evaluated here. The long

- term economic value of i rrigation58

water to a farmer is based on the expected return over a number of years discounted into present values, i.e. the opportunity cost. Furthermore, offset credits would be depend ent upon how the retired well is hydrologically connected to the river

, therefore, not all irrigation wells would necessarily given the same offset credit.

Figure 10. 5 is an aerial view of GGS station and the surrounding area. The circles are pivot

irrigation, clearly showing the irrigated cropland in the area surroundin g GGS. The star

identifies the location of the NPPD GGS station. The black numbers in each box represent the Section within the Township and Range. The green numbers represent the percent stream depletion factors (SDF) for that section. This SDF value represents how wells in that section are hydrologically connected to the river. The higher the value, the more connected the well is to the river. Wells that would be retired with higher SDFs would receive more offset credit than those

with lower SDF val ues. The Twin Platte NRD provided NDEQ with example offset calculations

for NPPD near their GGS station. The calculations are found in Table 10. 1 3 and coincide with Figure 10. 5 : Table 10. 1 3 Offset Water Calculations

Section Township Range Stream Depletio n Factor (SDF) % Offset H2O Calculation to

South Platte River IF 100 Acres of Irrigated Corn w/i Section no longer irrigated

Acre

- Feet

35 14 34 81 37.03

2 13 34 96 39.37

11 13 34 74 25.39

14 13 34 59 20.57

23 13 34 48 16.66

26 13 34 39 13.62

35 13 3 4 33 11.59

3 12 34 28 9.88

10 12 34 15 5.33

NDEQ estimated that NPPD would need up to 38 77 acre

- feet per year to scrub SO 2 . In order to determine how much irrigated land NPPD would need to acquire and retire sufficient offsets, NDEQ used the informati on provided by the Twin Platte NRD. NDEQ visually estimated the amount of irrigated land based upon pivot coverage. NDEQ assumed all irrigated land was corn. Given that a section has 640 acres, the estimates in Table 10. 1 4 were derived.59 Table 10. 1 4 E stimates Acres and Acre

- Feet

Section Township Stream Depletion

Factor (SDF) % Offset H2O

Calculation to

South Platte River

IF 100 Acres of Irrigated Corn w/i Section no longer irrigated

Acre

- Feet Estimated

Irrigated Acres Estimated

Offset

Acre

- Feet

35 14 81 37.03 320 119

2 13 96 39.37 160 63

11 13 74 25.39 480 122

14 13 59 20.57 320 66

23 13 48 16.66 384 64

26 13 39 13.62 480 65

35 13 33 11.59 480 56

3 12 28 9.88 480 47

10 12 15 5.33 384 20

Total 3488 622

NPPD would require more than 6 times mo re acre

- feet to offset their need. This would mean over 21,5 00 acres of irrigated crop land. This is about 6 times more acreage than was originally

estimated in the NPPD fact sheet because stream depletion factors were not factored in.

Center pivot irr igated crop land sells for a higher price than non

- irrigated crop land. In the Lincoln County area, prices went up 3.5% over last year. The ave rage price as of February 2010

wa s $2

, 475 per acre, not including the value of the pivot ( http://www.agecon.unl.edu/Cornhuskereconomics/3

- 10

- 10.pdf ). However, i n 2008, according

to newspaper reports, 30 square miles of a Lincoln County irrigated farm near North Platte sold for about $3,000 per acre. In 2009, Lincoln County irrigated farmland sold for about $3,200

- $3,500 per acre. Also, according to a prospective buyer in the area, when an offer of $2

, 500 per acre was made for irrigated land, the offer was not accepted. Given the amount of land that

would be needed to be acquired and the fact that prices went up 3.5% in 2009, it is expected that

if NPPD were in demand for irrigated land

, the price per acre would be driven up. Furthermore, price for the irrigated land would likely be influen ced by the fact that several farmers would no longer being able to farm their land. For this reason, NDEQ assumed NPPD would require approximately 22,000 acres of land at $ 4

, 00 0 per acre. NDEQ determined t he cost of irrigated land for purposes of offsets is estimated to be $ 88,00 0 ,000. Any offsets would be calculated and subject to approval from the local NRD through issuance of a variance.

The annualized costs to install sc rubber alone are $108,450,000. The annualized costs of obtaining the water offs ets at 7% over 20 years is $8,306,590, increasing t he total annualized

cost with the installation of scrubbers at GGS to $ 1 16

, 756

, 590

. Over 14 % of the costs would be for obtaining water

.60 Figure 10. 5 Aerial View of GGS & Surrounding Area61

10.6.3.4 Economic Im pacts from Irrigated Agriculture Agriculture is the main stay of Nebraska ‘s economy

. Irrigated cropland has a significant direct economic impact to the state, as well as indirect and consumptive effects within the state.

Whenever irrigated cropland is tak en out of service, it is appropriate to evaluate that impact to the state. Lincoln County was ranked in the top five counties for agriculture sales in 2007. Nebraska‘s leading commodities accounting for 98% of the state‘s total cash receipts are: cattle

, corn, soybeans, hogs, wheat, chicken eggs, dairy products, hay, dry beans, and sorghum.

Nebraska has been first in red meat production, cattle slaughter, great northern beans production, irrigated land and popcorn production. Nebraska is ranked thir d in corn and grain sorghum production.

In 2008, net farm income was just over $4 billion and cash receipts from all crops just under $9

billion. The 2008 farm marketing cash receipts contributed $17 billion to Nebraska‘s economy

and 5% of the United S tates total. When cropland is permanently taken out of production or irrigated cropland is converted to dry land farming , wealth is being removed from the state. The effect of this is direct on the farmer, the employees, and their families, but there is also an indirect effect that trickles out from reductions in crop income. Reduced crops in an agricultural state result in fewer grains for livestock and for export out of the state. This reduction impacts more people and their jobs, including grain elev ators and slaughter houses. According to the USDA, for every $1 in agricultural exports another $1.40 is generated in transportation, financing, warehousing and production. It follows that for every $1 reduced in agricultural exports, another $1.40 is red uced in those areas as well. Nebraska‘s $5.9 billion in agricultural exports translate into $8.3 billion in additional economic activity. When the foundational industries to our economic structure begin to weaken, the service sectors start to suffer as we ll.

NPPD GGS Station is located in Lincoln County. Within Lincoln County, there are 322,916 irrigated acres of farmland . Should NPPD take 22,000 acres of irrigated farmland out of service

that would be 6.8% of the total irrigated cropland in service a s of the 2007 USDA Census. ( http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_

Level/Nebraska/ind ex.asp )

.

According to http://www.fedstats.gov/qf/states/31/31111.html

, the current unemployment rate is

lower in Lincoln Coun ty than in the rest of Nebraska; however, the percentage of peop le living in poverty is greater in Lincoln County. Were NPPD to be required to take about 6.8% of irrigated acres out of service, ther e could be an adverse ripple effect to the economy of Lincoln County. As indicated above, agriculture is the primary econ omic industry for Lincoln County. Irrigated land corn yields are about 74% higher than dry land farming. The approximate yield for 22,000 acres of irrigated corn cropland is 4,081,000 bushels. For dry land farming, the approximate yield for 22,000 acres is 2,347,400 bushels. While the corn market has experienced great volatility the last couple years, the average price in 2007 was $ 4.20 per bushel nationally, and $4.14 per bushel in Nebraska

. Table 10.1 5 details the economic differences as a result of reduced corn yield at various price points since 2004

. http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1050

.62 Table 10.1 5 Differences Value of Yields

Year Average Price

per Bushel of

Corn in

Nebraska Estimated Value

Irrigated Yield (4,081,000 bushels) Estimated Value

Dry land Yield (2,347,400

bushels ) Difference

2004 $ 2.02 $ 8,243,620 $ 4,741,748 $ (3,501,872)

2005 $ 1.92 $ 7,835,520 $ 4,5 07,008 $ ( 3,328,512)

2006 $ 3 .00 $ 12,243,000 $ 7,042,200 $ (5,200,800)

2007 $ 4.14 $ 16,895,340 $ 9,718,236 $ (7,177,104)

2008 $ 4.05 $ 16,528,050 $ 9,506,970 $ (7,021,080)

2009 $ 3.70 $ 15,099,700 $ 8,685,380 $ (6,414,320)

According to the USDA ( http://www.agcensus.usda.gov/Publications/2007/Online_ Highlights/County_Profiles/Nebraska/cp31111.pdf ), the value of grains, oilseeds, dry beans and dry peas in Lincoln County totaled $185,812,000. The loss of the 1,733,600 bushels of corn yield would have equated to loss of 3.9% of the total value in grain, oilseeds, dry beans, and dry peas in Lincoln County for 2007 had the 22,000 acres b een converted to dry land farm land.

To illustrate an example: Livestock producers rely on grains from nearby farmers to supply feed. Reduced yields mean livestock producers must pay more to find feed trucked in from further away. Reduced yields coul d also affect the corn markets. Increased costs to livestock producers reduce their margins which could drive up prices to the meat packing facilities, which in turn could cause the prices of meat to increase in grocery stores. The farmer, livestock produ cer, meat packing facility, and grocery store owner all are operating with tight budgets and profit margins; therefore, when there is an upset to the market system, they make resource adjustments, find efficiencies, and may ask employees to do more work wi th less people. The ripple economic impacts to the livestock producer, the meat packing facility, grocer, and the general consumer are difficult to quantify. The ripple effects from the potential loss of jobs are impossible to predict. Usually businesse s know how to manage through temporary, short

- term fluctuations, however, in this case, the change is permanent, and therefore any affects as a result,

permanent. Furthermore, as public power district, NPPD does not pay property taxes, resulting

in lost t ax revenue to Nebraska. Losses in tax revenue impact the local and state government services such as the NRD, the school district, the rural fire department, and the county health department. However, for purposes of the cost effectiveness analysis, only the loss of revenue (2007 figures) was added to the annualized costs, which increased the total annualized costs to $123,933,694. Approximately 5.7% of the costs are associated with the loss of crop value. Overall, the impact as a result due to water

- rel ated issues increased the annualized costs from $108,450,000 to $123,933,694, a 14.3% increase. The NDEQ concluded this is a significant

economic impact.

10.6.3.5 Visibility Impacts Air dispersion modeling using CALPUFF was conducted to determine the impact on vi sibility from GGS Units 1 and 2 at several Class I areas. The highest impacts were observed at Badlands in South Dakota. The second highest were in Wind Cave in South Dakota, which is just west of

the Badlands. Badlands is the Class I area closest to GG S at approximately 300 km.63

Improvements seen at the Badlands are expected to be seen at Wind Cave as well. Appendix Y

to Part 51

– Guidelines for BART Determinations under the Regional Haze Rule provides under STEP 5: Determining Visibility Impacts: ― 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... ‖ Given the direction provided by Appendix Y and the uncertainties of the model beyond 200km, NDEQ

concluded that the an alysis of the Badlands was appropriate.

The total baseline impact from NPPD GGS is shown in Table 2 of the May 11, 2010 NPPD

BART Permit Fact Sheet. The number of days above 0.5 dV for the 7 Class I areas analyzed ranged from 10

– 60 days. The area with the greatest impact was Badlands in all 3 years analyzed. Additional benefits analyses beyond the Badlands are unwarranted because controls on the GGS Units 1 and 2 will not likely exhibit greater visibility improvement than what is predicted in the Badl ands. However, given the comment received by the federal land managers and the relative proximity of Wind Cave National Park , NDEQ assumed similar benefits would be expected there

. Furthermore, model accuracy is highly uncertain at distances greater than 200

km. Table 10. 1 6 shows the modeled visibility effectiveness of SO 2 control options, based on the estimated impacts at the Badlands. Included in the analysis is an evaluation of putting the control cost into perspective as they relate to visibility imp airment.

Table 10. 1 6 : Visibility Effectiveness ( SO 2 Controls)

2001 2002 2003 Average

Control Option Class I Area with Greatest

Impact from GGS Badlands Badlands Badlands Baseline (no SO 2 Control) SO 2 Modeled Emission Rate (lb/MMBtu) 0.749 0.749 0 .749

Modeled 98 th Percentile Value (dV) 2.845 2.828 3.121 2.93 1

Number of Days Exceeding

0.5 dV 54 55 60 56 FGD Control Added (0.10 lb/MMBtu) Modeled 98 th Percentile Value (dV) 1.790 2.026 2.443 2.086

Visibility Impairment Improvement ( dV) 1.055 0.802 0.678 0.845

Number of Days Exceeding

0.5 dV 33 33 36 34

Days of Improvement 21 22 24 22

Impairment Improvement Cost ($/yr/ dV) $ 117, 472,696 $ 154,530,791 $ 182,793,059 $ 146,667,093

Cost per Day of Improvement $ 5,901,604 $ 5,633,350 $ 5,163,904 $ 5,633,350

If we assume similar benefits are achieved at Wind Cave National Park, and consider the benefits

as cumulative:

Average impairment improvement cost = $ 73,333,547 $/ yr/ dV Cost per Day of Improvement = $2,816,67564

The cost per day of improveme nt index is an indicator of the frequency of impact (and benefit) a source has on a Class I area. The impairment improvement cost is an indicator of how much benefit is derived from the investment in the control. Nebraska used a $40,000,000/ yr/ dV and $5 00,000 per day as thresholds for determining what would be considered reasonable investment for visibility improvement. In conclusion, as indicated in the discussion above, the water

resources with in the river basin in which GGS is located and in surroundi ng river basins are scarce. A moratorium has been placed on new consumptive uses of water . Offsets of existing uses are difficult to find and economically prohibitive given the distances and infrastructure needed to transport water from a reliable supply location . The unusual and unique circumstances related to the scarce water resources in this region of the state and the State of Nebraska‘s commitments to other states and the federal government under the PRRIP when compared to the limited visibility im provement that might result from the additional control justifies not requiring GGS to install scrubbing technology as a BART control measure for SO 2

.

10.6.4 Dry Sorbent Injection (DSI) Evaluation On December 14, 2010, the federal land managers commented on Ne braska‘s proposed Regional Haze (RH) State Implementation Plan (SIP), while it was on public notice, concerning the extent to which dry sorbent injection (DSI) should be considered as a sulfur dioxide (SO2) control option for Nebraska Public Power District ‘s (NPPD‘s) Gerald Gentleman Station (GGS) Units 1

and 2.

NDEQ had eliminated scrubbing as BART as document in Sections 10.6.3 above, but had failed to evaluate DSI, a control option use s very little water. The NDEQ cited the water requirements

of We t Flue Gas Desulfurization (FGD) and Dry FGD as one contributing factors for eliminating

them as BART for GGS Units 1 and 2.

The purpose of the following sections is to supplement the analyses on the other SO 2 controls previously analyzed.

10.6.4.1 Updated BAR T Analysis for SO2 The objective of this analysis is to complete a five

- factor analysis for DSI, as it pertains to SO 2 removal. The five basic steps for BART analysis are:

Step 1

- Identify all available retrofit control technologies Step 2

- Eliminate t echnically infeasible options Step 3

- Evaluate control effectiveness of remaining control technologies Step 4

- Evaluate impacts and document the results Step 5

- Evaluate visibility impacts

10.6.4.2 Technical Feasibility

DSI DSI involves the injection of a sorb ent into the ductwork upstream of the unit‘s particulate control system. The sorbent for SO 2 removal is typically either mineral trona (sodium sesquicarbonate) or refined sodium bicarbonate. This BART analysis only considers trona as the65

sorbent since it has a wider active flue gas temperature range and is less expensive than refined

sodium bicarbonate. 13

10.6.4.3 Eliminate technically infeasible options Utilities have installed DSI on several smaller boilers (88 megawatts (MW) to 200 MW) since

2006. Midwest Gen eration, LLC recently conducted pilot scale testing at their Powerton and Joliet facilities on boilers ranging in size from 700 MW to 900 MW that demonstrated the technology is transferable to larger boilers.

In addition , the Illinois Environmental Prote ction Agency 14 and the Oregon Department of Environmental Quality 15 are requiring DSI on large utility boilers in their states in order to satisfy BART requirements. However, NPPD continues to refute the claim that DSI is a proven technology for coal

- fired power plants with the size of the GGS Units 1 and 2

. 16

10.6.4.4 Evaluate control effectiveness Since DSI is considered a feasible technology, its effectiveness was measured by the amount of

SO 2 removed based on a comparison of the controlled emission rate of 0.15 pounds per million British thermal units (lb/MMBtu) to the uncontrolled baseline emission rate of 0.749 lb/MMBtu. The 0.15 lb/MMBtu is the presumptive BART limit in 40 CFR Appendix Y for electrical generation units above 200 megawatts (MW) at plants great er than 750 MW. NPPD used the baseline emission rate of 0.749 lb/MMBtu in the original BART analysis, which is based on the

maximum actual 24

- hr SO 2 emissions over a three

- year baseline period (2001

- 2003).

10.6.4.5 Evaluate impacts and document the results

In o rder to be consistent with the last BART analysis for GGS, the NDEQ has considered DSI‘s cost of compliance, energy impacts, non

- air quality environmental impacts, and the remaining

useful life of the units.

10.6.4.6 Cost of Compliance

NPPD ‘s analysis was conducte d by Sargent & Lundy, LLC

. T hey also provided the supplemental information for the previous BART analysis . Sargent & Lundy is a full

- service firm, providing consulting, design, procurement, construction management, and turnkey services. As such, the anal ysis provided is considered to include vendor quotes as allowed by Appendix Y and supplements guidance contained the Environmental Protection Agency‘s (EPA‘s) Office of Air Quality Planning and Standards‘ Control Cost Manual.

The cost associated with DS I installation include, but are not limited to: storage silos for the trona, construction of rail upgrades to allow for the receiving of trona, and expanding the ash storage system due to increased quantity of solid waste generated by the facility. Detai led information can be found in the supporting materials provided by NPPD. The table below

13 Information provided by Solvay Chemicals, Inc.

14 Faggert, Pamela F. of Dominion Resources Services, Inc., Concerning the Memorandum of Understanding on SO 2 and NO

x Reductions Reflective of BART for Kincaid Units 1 and 2, to James R. Ross of the Illinois Environmental Protection Agency, February 3, 2009.

15 Addendum to the Oregon DEQ BART Report for the Boardman Power Plant, November 30, 2010.

16 Information can be found in NPPD‘s letter dated Apr il 29, 2011 to the NDEQ.66

provides a cost comparison of DSI versus the control technology analyzed in the previous BART

Permit. Costs were adjusted to 2016 because that is the likely time w hen installation would

occur.

Table 1 0.1 7 : Comparison Costs for SO 2 Controls Adjusted to 2016 Dollars

Cost Element Dry FGD 17 Wet FGD 17 DSI
Total Capital Cost $1,057,068,000 $1,109,003,000 $208,330,000

Annualized Capital Cost $86,166,000 $90,422,000 $17 ,500,000

Annualized O&M Cost $30,697,000 $26,368,000 $64,458,000

Total Annualized Cost $116,863,000 $116,790,000 $81,958,000

Annual Tons SO 2 Removed 39,815 39,815 39,815

Cost Per Ton Removed $2,935 $2,933 $2,058

The total annualized cost associated w ith the installation of DSI at GGS is $81,958,000. The average cost effectiveness of this control technology is $2,058 per ton SO 2 removed ($81,958,000 / 39,815 tons SO 2 removed) based on an emissions rate of 0.15 lb/MMBtu. This is assuming a very high r emoval rate at nearly 80%

. The cost per ton removal estimated for GGS

is similar to the values provided in the DSI BART analysis by the Illinois Environmental Protection Agency 14 and the Oregon Department of Envir onmental Quality

. 15 However, t he capital costs are higher when compared to other BA RT determinations requiring DSI. Even though Illinois and Oregon have required the use of DSI on comparable size boilers, there a re

many uncer tainties involved with the insta llation of this control equipment since it is a relatively new technology for boilers the size of GGS Units 1 and 2. In addition, the majority of the dollars per ton of SO 2 removed result from high ongoing oper ating cost due to the use of a sorbent

.

10.6.4.7 Energy Impacts If DSI was employed, 0.6% (7.6 MW) 16 of the units‘ generating capacity would be utilized to operate the control equipment. Seven and six

- tenths megawatts is equivalent to the power utilized by approximately 7,600 homes. The original BART analysis reported a power usage rate 36 MW and 26 MW for Wet FGD and Dry FGD, respectively.

The energy costs were included in the BART analysis cost above.

10.6.4.8 Other (Non

- Ai r Quality) Environmental Impacts

Disposal of Solid Waste

Non

- air quality environmental impacts associated with the installation of DSI include disposal of solid waste generated from the spent trona and fly ash. The cost to dispose of the waste was

includ ed in the cost analysis. The fly ash will be intermixed with trona which will cause it to be unsuitable for third party use requiring it to be land

- filled. 13 From 2004 to 2008, NPPD sold an average of approximately 107,000 tons of fly ash from GGS. 18 8 The revenue lost from fly

- ash sales was not included in the cost analysis. 18

17 Appendix A of NPPD‘s letter dated March 15, 2011 to the NDEQ. Does not account for the costs of water with dry or wet scrubbing.

18 GGS‘s Landfill Permit, pp. 2

- 3, September 2009.67

The use of DSI would require GGS to landfill approximately 400,000 tons of waste per year 16
which is four times more than GGS currently landfills. 18 Therefore, the life of their current

landfill would be vastly shortened, requiring additional landfill capabilities much sooner than previously antici pated.

The NDEQ is also concerned with the possibility that the land

- filled waste may have a hazardous waste classification. The EPA is still pending their determination on the classification of fly ash as a solid waste or hazardous waste. Also, a stud y by the Department of Energy found arsenic and methylene chloride in the ash when DSI was used; however, it is not currently known if the levels of arsenic and methylene chloride discovered would classify the ash as hazardous waste.

This was an issue rai sed by the National Park Service in their comments on Martin Drake.

Disposal of Liquid The DSI application does not use water to improve the mass transfer of SO 2 as is the case with Dry and Wet FGD technologies. However, some water is used in DSI applic ation to wash the trona mills as part of required daily maintenance. The trona mills are filled with water to dissolve the deposits of sodium that accumulate on the mill internals. Based on information provided by NPPD 18 a nd a scaling factor, GGS will av erages less than 5 gallons per minute on an annual basis to wash the trona mill. The resulting liquid waste is high in sodium and, therefore, must be disposed of properly.

10.6.4.9 Remaining Useful Life The useful remaining life of GGS Units 1 and 2 is greater than 20 years under the current NPPD energy resource plan. Therefore, the remaining useful life has no impact on the annualized estimated control technology cost at this time.

10.6.4.10 Visibility Impacts Air dispersion modeling using CALPUFF was conducted to det ermine the impact on visibility from GGS Units 1 and 2 at the Badlands in South Dakota. The highest impacts were observed at the Badlands in the original BART analysis and it is the closest to GGS, at distance of approximately 300 km. 40 CFR Part 51 Appe ndix Y says that if the highest modeled effects are at the nearest Class I area, states may choose not to analyze the other Class I areas any further. The CALPUFF results of the deciview improvement using DSI are compared to GGS‘s previous BART analysis i n the table below.68 Table 10.1 8 : Visibil ity Effectiveness

2001 2002 2003 Average

Control Option Class I Area with Greatest

Impact from GGS Badlands Badlands Badlands Baseline

(no SO 2 C ontrol) SO 2 Modeled Emission Rate

(lb/MMBtu) 0.749 0.749 0.749

Modeled 98 th Percentile

Value (dV) 2.845 2.828 3.121 2.931

# of Days Exceeding 0.5 dV 54 55 60 56 FGD Control Added (0.10 lb/MMBtu) 1 Modeled 98 th Percentile Value (dV) 1.79 2.02 2.44 2.0 8

Visibility Impairment Improvement (ΔdV) 1.055 0.802 0.678 0.845

# of Days Exceeding 0.5 dV 33 33 36 34

Impairment Improvement Cost ($/yr/ΔdV) 2 $ 117,472,696 $ 154,530,791 $ 182,793,059 $146,667,093

Cost per Day of Improvement 3 $ 5,901,604 $ 5,633,350 $ 5,1 63,904 $ 5,633,350 Dry Sorbent Injection (0.15 lb/MMBtu) 4 Modeled 98 th Percentile Value (dV) 1.755 2.147 2.31 2.07

Visibility Impairment Improvement (ΔdV) 1.09 0.681 0.811 0.861

# of Days Exceeding 0.5 dV 35 37 39 37

Impairment Improvement Cost ($/y r/ΔdV) 2 $75,190,826 $120,349,486 $101,057,953 $95,189,314

Cost per Day of Improvement 3 $4,313,579 $4,553,222 $3,902,762 $4,256,521

1 Results from GGS‘s previous BART analysis

2 Total annualized cost / Incremental visibility impairment improvement

3 In cremental Cost per day = Total annualized cost/no. of days improvement (<0.5 dV)

4 Provided in NPPD‘s letter to the NDEQ dated April 29, 2011.

The results for DSI and FGD (both at 0.15 lb/MMBtu) ha d different deciview impacts because

the use of FGD result s in a substantial drop in stack temperature and velocity, compared to when

DSI is used.

If we assume similar benefits are achieved at Wind Cave National Park, and consider the benefits

as cumulative:

Average impairment improvement cost = $47,594,657$/ y r/ dV Cost per Day of Improvement = $2,156,78969

The cost per day of improvement index is an indicator of the frequency of impact (and benefit) a source has on a Class I area. The impairment improvement cost is an indicator of how much

benefit is derived f

rom the investment in the control. Nebraska used a $40,000,000/ yr/ dV and $500,000 per day as thresholds for determining what would be considered reasonable for visibility improvement. EPA Region 7 provided NDEQ with a table comparing the dollars per

deci view ($/dV) impact of several BART SO 2 determinations by other states i n their comments on the NDEQ‘s proposed SIP. The NDEQ has confirmed that EPA Region 7 used the visibility improvement at a single class one area in order to compare the $/dV improvemen t. The table, with DSI incorporated as BART for GGS Units 1 and 2 can be found below.

Table 10. 19 : SO 2 BART Cost Comparisons to other Facilities 1

Operating Company State Facility Proposed

Control Reductions

(tons/year) Capital

Cost ($1000) Annual

Cost ( $1000) $/ton dv $/dv 2

PGE 3 OR Boardman LSD/FF 11,988 $247,300 $36,600 $3,053 1.04 $35,192,308

Colorado Springs Utility 4 CO Martin

Drake LSD/FF 3,610 $44,166 $8,216 $2,276 0.2 $4,192,276

PacifiCorp 5 WY Dave

Johnston Dry

FGD/FF 11,589 $169,500 $21,419 $1,848 1.39 $16,703,531

PacifiCorp 6 WY Dave

Johnston Dry

FGD/FF 5,657 $222,776 $26,833 $4,743 1.15 $25,421,181

PacifiCorp 7 WY Naughton Wet FGD 7,657 $89,400 $13,068 $1,707 1.03 $13,947,954 PacifiCorp 8 WY Naughton Wet FGD 9,934 $117,440 $16,889 $1,7 00 1.14 $15,889,802

Basin

Electric

Power 9,13 ND Leland Olds FGD 32,949 $107,220 $19,310 $586 1.75 $11,065,903

Great River Energy 10,13 ND Stanton LSD/FF 8,438 $79,514 $11,200 $1,330 0.77 $14,533,679

Minnkota

Power 11,13 ND Milton R. Young FGD 20,443 $1 11,776 $22,584 $1,105 1.46 $15,426,230

Otter Tail

Power 12 SD Big Stone

Generation SD/FF 16,120 $141,300 $23,750 $1,462 0.16 $51,350,763

Nebraska

Public Power

District NE Gerald

Gentleman DSI/FF 39,815 $208,330 $64,458 $2,058 0.86 $ 95,189,314

Omaha

Public Power

District 14 NE Nebraska

City Station FGD 21,223 $201,660 $34,720 $1,636 0.49 $79,450,801

1 The costs were based on EPA Region 7's letter dated January 21, 2011.

2 All were confirmed to use a single Class I Area in their $/dv compa rison

3 Table 23 on page D

- 26 of "Appendix D: Supplement BART information for Boardman Power Plant BART Report", June 19, 2009

4 Page 79 of "Colorado Visibility and Regional Haze State Implementation Plan for 12 Mandatory Class I Federal Areas", January 7, 2011

5 Tables 16 and 17 on page 22 and Table 28 on page 39 of "BART Application Analysis (AP

- 6041) for Dave Johnston Power Plant", May 28, 2009

6 Tables 18 and 19 on pages 22 and 23 and Table 29 on page 40 of "BART Application Analysis (AP

- 6041) for Dav e Johnston Power Plant", May
28, 2009

7 Tables 19 and 20 on page 26 of "BART Application Analysis (AP

- 6042) for Naughton Power Plant", May 28, 2009

8 Tables 21 and 22 on pages 26 and 27 of "BART Application Analysis (AP

- 6042) for Naughton Power Plan t", May 28, 2009

9 Pages 6 and 8 of "BART Determination for Leland Olds Station Units 1 and 2" in Appendix B of Departm ent BART Determination.

10 Page 5 of "BART Determination for Stanton Station Unit 1" in Appendix B of Department BART Determination.

11 Page 6 of "BART Determination for Milton R. Young Station Units 1 and 2" in Appendix B of Departm ent BART Determination.

12 Table 3

- 8 on page 18 and Table 6

- 7 on page 87 of "South Dakota‘s Regional Haze State Implementation Plan"

13 Primarily use Da kota Ligni te Coal.

14 Omaha Public Power District BART determination was not to install control equipment for SO 2 due to the high cost for the little benefit70

10.6.4.11 SO 2 BART Determination for GGS DSI technology is a technically feasible SO 2 retrofit te chnology that could be implemented on GGS Units 1 and 2. Not considering all outstanding issues, the average cost effectiveness of using DSI control technology is approximately $2,000 per ton of SO 2 removed; this cost per ton removed is reasonable.

Howev er, when comparing the dV improvement that would be gained and compared to the $/dV improvement to those provided by EPA Region 7, GGS Units 1 and 2 are substantially higher than any other facility included in Table 19

. Furthermore, visibility benefit ga ined does not outweigh the added

burden of the added waste that would be generated through the control of SO 2

. Even though one facility has a $/dV impact higher than that of the threshold NDEQ used, the rules allow for states to use different approaches a nd threshold . A distinguishing factor between Nebraska and South Dakota is that Nebraska does not contain any Class I areas.

NDEQ does reserve the ability to revisit a dditional SO 2 controls at NPPD GGS in the future for purposes

of ―reasonable further p rogress‖. However, at this time the NDEQ has determined that it is inappropriate to require the installation of DSI at GGS Units 1 and 2 due to the excessive cost per benefit in terms of visibility improvement (i.e. $/yr/dV) and the significant solid wast e impact

, and the uncertainty with regard to whether the waste would be considered a hazardous waste.

Appendix 10.1 Detailed Information on BART Eligible Units Appendix 10.2 Information about Identification of BART Eligible Units Appendix 10.3 CALP UFF Modeling Protocols Appendix 10.4 Letters sent to non

- BART subject Sources Appendix 10.5 Modeling Results Appendix 10.6 BART analysis submitted by BART subject Sources Appendix 10.7 Additional supporting information Appendix 10.8 BART permit determinat ions and supporting information Appendix 10.9 Title 129 Chapter 43

- Visibility Protection Appendix 10.10 Causes of Haze Study, Sonoma Appendix 10.11 Twin Platte NRD Integrated Management Plan Appendix 10.12 Nebraska Statutes Appendix 10.13 Supplemental BART i nformation related to DSI Analysis71

11 Reasonable Further Progress /Long Term Strategy The Regional Haze Rule calls for e ach state to ―address regional haze in each mandatory Class I Federal area located within the state and in each mandatory Class I Federal area located outside the state which may be affected by emission s from within the state‖ [40 CFR 51.308(d)]. Although there are no Class I areas located within Nebraska

, the State is still required to address regional haze by mitigating the emissions that may be significantly be impacting a mandatory

Class I area. As part of the CENRAP regional planning process, regional modeling was performed to show the impact on several surrounding Class I areas from Nebraska emissions. The impact from Nebraska emissions is discussed further below.

Despite the minimal impact fr om Nebraska, the State still anticipated the surrounding states

would request that we consult with them to address the requirements to meet reasonable progress

at their Class I areas. As discussed in the consultation section, because of the minimal impact t he

State of Nebraska was not asked by any state, beyond the BART determinations, for any additional specific reductions from any State during their consultation process. The consultation process is described in Chapter 11. 4

.

11.1 Determining Visibility Impac t
Nebraska is required by 40 CFR 51.308(d)(3)(iii) to document the technical basis for the State‘s apportionment of emission reductions necessary to meet reasonable progress goals in each Class I area affected by the State‘s emissions. In order to address the issue of source attribution and apportionment of regional haze for its member states, CENRAP contracted with ENVIRON to carry out PM Source Apportionment Technology (PSAT) modeling, a well known ―probing tool‖ for the CAMx photochemical model. ENVIRO N delivered its results in the form of a customized Microsoft Access database query tool, hereinafter the PSAT tool, which allows users to select among various inputs to produce charts and tables. The PSAT information is available through the CENRAP webs ite http://www.cenrap.org/html/projects.php and on the University of

California Riverside website at http://pah.cert.ucr.edu/aqm/cenrap/camx.sh tml

.

Visibility impact can be represented in terms of absolute light extinction (Bext),inverse

m egameters (Mm

- 1), and percent total light extinction. Visibility impact can be further evaluated in terms of the percent contribution by pollutant spec ies. The relationship between deciviews (dv) and inverse megameters (Mm

- 1 ) is described in detail by Malm, (1999). The following equation defines the Haze Index (HI):

HI = 10 ln(b ext /10)

Thus, one deciview is approximately equal to 11.05 Mm

- 1 and a change of one dv represents a change of approximately ten percent in b ext , ―which is a small but perceptible scenic change under many circumstances‖.

Figures 11.1

- 11. 1 3 are taken from Appendix E of the Cenrap Technical Support Document and the PSAT modeling tool which show the ranked results by source category contributions to the average 2018 extinction (Mm

- 1) for the worst 20% visibility days

.72 Figure 11.1 Caney Creek Wilderness Area, AR (CACR)

F igure 11.2 Upper Buffalo Wilderness Area, A R

( UPBU)73 Figure 1 1.3 Breton Island Wilderness Area, LA (BRET)

Figure 11.4 Boundary Waters Canoe Area Wilderness Area, MN (BOWA)74 Figure 11.5 Voyagers National Park, MN (VOYA)

Figure 11.6 Hercules

- Glades Wilderness Area, MO (HEGL)75 Figure 11.7 Mingo Wilderness Area , M O (MING)

Figure 11.8 Wichita Mountains Wilderness Area, O K (WIMO)76 Figure 11.9 Big Bend National Park (BIBE), TX

Figure 11.10 Guadalupe Mountains National Park (GUMO), TX77 Figure 11.1 1 Badlands National Park ( BADL ), SD

Figure 11.1 2 Wind Ca ve National Park ( WICA ), SD78 Figure 11.1 3 Rocky Mountain National Park ( ROMO ), CO

Figure 11.1 4 Modeled W20% 20 02 Extinction from Nebraska (SO4 & NO3)79

The nearest Class I areas to OPPD N CS is Hercules Glades, located in Missouri

. Hercules

Glades i s just approximately 580km from OPPD NCS

. OPPD NCS is located in the southeastern

corner of the state. Using the PSAT tool, previously discussed , the source apportionment of light extinction causing pollutants can be determined.

Figure 11.15 shows that at Hercules Glades the most significant pollutant to light extinction is

sulfates from elevated point sources.

Figure 11.15 Worst 20% visibility days at Hercules Glade (HEGL), MO Future Year 201880

Figure 11.16 S ource C ategory contributio ns to the average 2018 SO4 extinction (Mm

- 1) for the Worst 20% visibility days at Hercules Glade (HEGL), MO.

Figure 11.17 S ource Category Contributions to the Average 2018 NO3 extinction (Mm

- 1) for the Worst 20% visibility days at Hercules Glade (HEGL), MO81 Figure 11.18 : Worst 20% Sulfate Residence time from 500m

Finally, according to the analysis conducted by Sonoma for CENRAP in the Causes of Haze Assessment (Appendix 10.10 ), sulfates are coming from the east, south and south east of

Hercules Glade s, which further substantiates that reducing sulfates on Nebraska sources will have insignificant impact on visibility improvement in the Hercules Glades Class I area.

Of the 13 Class I areas, Nebraska did not show in the top 30 source category contributo rs of extinction on the worst 20% projected in 2018 for 7 of the Class I areas. Nebraska did not show up in the top 10 for any of the Class I areas. The extinction Nebraska contributed most to was the Class I areas in South Dakota, the Badlands National Park and Wind Cave National Park

, approximately 300km away from NPPD GGS. Nitrates comprised a slightly larger percentage than sulfates at these parks in the baseline year 2002, as shown in Figure 11.14. Therefore, it would seem that mitigating nitrates, as has been done in the BART permits is appropriate.

The Federal Land Managers commented during the comment period of the proposed SIP that since the SO2 emissions were not being reduced from the EGUs (essentially elevated point sources) that the conclus ions from the graphs above would be flawed. That said, using the revised 2018 emission inventory for SO2 and comparing it to the inventory for that of the neighboring Region 7 states:82 Table 11.1

State 2018 Predicted

SO2 Emissions (TPY)

Nebraska 92,716 (previous 62,878)

Iowa 198,264

Kansas 97,070

Missouri 280,887

It would be expected that the predicted impacts would be greater in 2018 than previously predicted. However, even for the Badlands, where Nebraska‘s impact was the greatest, it is highly unlikely that Nebraska would reach the impact level that elevated Iowa point sources have on the Badlands, considering that the SO2 emissions from Iowa are expected to contribute 151,354 tons per year compared to 82,193 (approximately 55%) in Nebr aska. The impact on Wind Cave, SD would likely be higher than previously predicted. Previous models expected elevated point sources to be #24 out of 30 as far as priority. An increase in SO2 emissions would increase this ranking, but is not expected to raise it to the top 10. For the other areas, 8 do not have Nebraska elevated point sources on the top 30 list. It is unlikely that would change. If it were, the most would be commensurate with where Kansas elevated point sources are, which is typicall y in the bottom 10. For the areas in Minnesota, Missouri, and Oklahoma, Nebraska elevated point sources may have a potential impact slightly higher than that predicted previously.

11.2 State Consultation Process

11.2.1 Minnesota (Northern Midwest)

As identified i n the document Reasonable Progress for Class I Areas in the Northern Midwest

– Factor Analysis ( Appendix 11. 1 ), the Lake Michigan Air Directors Consortium (LADCO) identified the following states contributing to Class I area visibility impairment in the LAD CO region: Michigan, Minnesota, and Wisconsin, as well as surrounding states, such as the Dakotas, Iowa, Missouri, Illinois, and Indiana. Figure 11. 19 presents the results of composite back trajectories for light extinction on the 20% worst visibility days . The darkest orange areas are where the air is most likely to come from on poor air quality days, and the darkest green areas are where the air is least likely to come from on poor a i r quality days. As can be seen, poor visibility days are generally assoc iated with transport from regions located to the south of these

class I areas. While Nebraska is in the lightest shade of orange, indicating some impact on poor visibility days, after further evaluation by Minnesota and consultation through the regional pl anning process, no additional emissions reductions from these Nebraska sources were required

to meet Class I area visibility improvement goals at this point in time.83 Figure 11.19 Composite Back Trajectories Worst 20% Visibility Days

11.2.2 Central Sta tes (Missouri, Arkansas) As identified in the document Central Class I Areas Consultation Plan ( Appendix 11. 2 ), CENRAP identified early on in its process that Nebraska was in its area of influence for nitrogen

oxides. Figure 11. 20 presents the AOIs for N O

x and SO4.

Figure 11. 20 Initial AOI‘s for Central Class I Areas

The central states determined whether a state was a contributor based on a combined analysis of four approaches, i.e., PMF/Trajectories, Area of Influence ( AOI ) , PSAT, and Q/D. If a stat e was84

found to be a major contributor in at least 3 of the 4 approaches, the central states concluded it was appropriate to include that state as a major contributor.

To be included as a contributor under the PMF/Trajectories (positive matrix factoriza tion) approach

, depended on the level of probability that an air mass originated from the state during the days of high contribution by sulfate or nitrate sources where the emission impact potential

was significant. A state with a high potential of emissio n impact would be considered a significant contributor.

States were included in the AOI listing if they were part of the level 1 group as determined by Alpine Geophysics. This AOI was based primarily on residence time of air masses, along with

evaluation of source emissions of, in this case, nitrate and sulfate.

PSAT analysis was determined based on the 2018 Modeled sulf ate and nitrate contribution to average extinction for the 20% worst days. Any state with the contribution of 2.0 deciview or higher was identified as a candidate.

Lastly, Q/D was determined by dividing total SO 2 and NO 2 precursor emissions for the state by distance from a state geographic centroid. If totals were less than 200, the state was not

indicated as a significant contributor und er Q/D.

Nebraska was found to only be a contributor based upon the AOI and therefore it did not meet the criteria of meeting at least 3 of the 4 methodologies. Nebraska was excluded as a major contributing state to visibility impairment in Class I areas in Missouri and Arkansas . ( See Appendix 11. 2 ). Figure 11.21 below shows the results of each analysis. Red indicates the state has been identified as being a contributor based upon that analytical methodology.85 Figure 11. 21 States Contributing to Hercul es Glade Class I Area

Sulfate Nitrate

11.2.3 Wichita Mountains (Oklahoma) As identified in the document titled Oklahoma‘s Wichita Mountains Wilderness Area Regional Haze Planning ( Appendix 11. 3 ), Oklahoma identified early on in its process that Nebraska was in its area of influence for nitrogen oxides. Figure s 11. 22 & 11. 23 present the AOIs for the

Wichita Mountains.

Figure 11. 22 AOI for Wichita Mountains

– Nitrogen Oxides86 Figure 11. 23 AOI for Wichita Mountains

– Sulfur Dioxide Sources

Nebraska was initially invited to participate in the Oklahoma consultation process. Only BART

controls for NO

x on the NPPD and OPPD were ultimately identified as requiring control

. Nebraska provided copies of the draft BART permits packages to the State of Oklaho ma while on public notice. Oklahoma did not provide any comment, nor did the State request additional controls for the initial planning period.

11.2.4 Badlands National Park and Wind Cave National Park (South Dakota) Nebraska is part of the CENRAP region. Sout h Dakota is part of the WRAP region

. Information on emission inventories and modeling was shared between the two regional planning organizations to assist in the planning process and in the consultation process.

As identified above, Nebraska‘s contribu tion to visibility impairment is limited. To examine Nebraska‘s potential impact closer, during the BART review, reviewed the Causes of Haze Study carefully. We noted that t he wind patterns (wind roses) for the Badlands indicate a high frequency of flow from the north

- northwest year round, with an additional high frequency component of southeasterly flow during the warm months (June

– August). Nebraska‘s primary sources emitting visibility impairing pollutants would be south of the Class I areas in South

Dakota. Figure 11. 24 is a wind rose from August 2002 showing an equal distribution from the

north

- northwest and south

- southeast.87 Figure 11. 24 August 2002 Wind Rose for Rapid City ( Station #24090

- Rapid City, SD Regional Airport)

Nebraska consul ted directly with the State of South Dakota several times through phone and email correspondence. Nebraska provided copies of the draft BART package for NPPD Gerald Gentleman Station because of the potential the units have on visibility impairment in

Clas s I areas in South Dakota. Nebraska wanted to make sure South Dakota had an opportunity to comment on our plans to control emissions the Gerald Gentlemen Power Plant. As noted in

their proposed SIP ( http://denr.sd.gov/des/aq/publicnotices/RegionalHazeSIPDraft.pdf ) , South

Dakota included Nebraska‘s BART plans in their SIP submittal.

11.2.5 Rocky Mountain National Park (Colorado) Nebraska is part of the CENRAP region. Colorado is part of the WRAP region. Information on emission inventories and modeling was shared between the two regional planning organizations to assist in the planning process and in the consultation process. Additionally, during the BART permit development process, Nebraska provided copies of the draft BART package for NPPD Gerald Gentleman Station because of the potential the units have on visibility impairment in Class I areas in Colorado. Nebraska wanted to make sure Colorado had an opportunity to

comment on our plans to control emissions the Gerald Gentlemen Power Plant. The State of Colorado provided comments on the BART permit, as well as on the proposed SIP.

The CDPHE expressed concern over their ability to meet visibility improvement goals for Rocky

Mounta in National Park. They pointed NDEQ to a website where baseline, modeling projections and source apportionment information could be found. The CDPHE noted that the modeling conducted shows the Central Regional Air Partnership (CENRAP) states predicted to be contributing 7.2% of sulfates in 2018 on the 20% worst days. They conclude because of proximity to Colorado, that since Nebraska is one of nine CENRAP states, and that GGS is among the largest sources of sulfur dioxide (SO2) in the CENRAP region, it i s reasonable to88

attribute some portion of the CENRAP contribution to GGS. Therefore, CDPHE requests that NDEQ reconsider SO2 controls at GGS under the Regional Haze rule.

NDEQ reviewed the website information provided by CDPHE. There, NDEQ found a ―Caus es of Haze Assessment‖ (COHA) that maybe found at http://www.coha.dri.edu/ as well as information on contribution for Rocky Mountain National Park, CO. The COHA included information regarding meteorological conditio ns. Below is an annualized wind rose for the Rocky Mountain National Park using the data collected from the station at the Class I area. As NDEQ expected, the patterns indicate the wind rarely comes from the east or northeast,

directions that would have i ndicated a potential for impacts from sources in the state of

Nebraska.

The contribution assessment did not distinguish Nebraska from the other eight CENRAP states. CENRAP includes Minnesota, Iowa, Kansas, Missouri, Oklahoma, Arkansas, Louisiana, an d Texas. Overall, CENRAP‘s contribution was significantly smaller than that of Colorado as shown in the graphs below. Taking into consideration the wind patterns it is most likely that contributions from the CENRAP region are not from Nebraska, but are f rom sources in states located southeast of Rocky Mountain National Park.89

11.3 Long Term Strategy

11.3.1 Federal Measures

11.3.1.1 Clean Air Interstate Rule/ Clean Air Transport Rule At the onset of the regional haze consultation process, many states relied heavily on t he Clean Air Interstate Rule (CAIR), a rule that was to address the interstate transport of air pollution to downwind states. CAIR covered 28 eastern states plus the District of Columbia, and would have reduced SO2 emissions by an estimated 5.4 million ton s and NO

x emissions by an estimated 2 million tons by 2015. Affected states had the choice of either meeting the state‘s emission budget by requiring power plants to participate in a cap and trade system, or by means of a measure of the state‘s choosing.

Although Nebraska was not included in the final CAIR rulemaking, the rule was a major component in the underlying assumptions used to determine source apportionment because of the reductions expected in neighboring states with Class I areas.

In July 2008, the D.C. District Court of Appeals vacated the CAIR rule in its entirety. On September 24, 2008 EPA filed a petition for rehearing or for a remand of the case without vacatur. On December 23, 2008, the D.C. District Court of Appeals remanded the case to E PA without vacatur so that EPA could remedy CAIR‘s flaws as were discussed in their July ruling.

On July 6, 2010, EPA announced a proposed rule to replace CAIR, the Clean Air Transport Rule. In this proposed rulemaking, Nebraska was a named state for pur poses of PM 2.5 , and if finalized as proposed, would be required to control annual SO 2 and NO

x emissions from power plants. It is expected that this rule will still include Nebraska when finalized.90 Figure 11. 25 Clean Air Transport Rule Proposed Stat es

Emissions reductions are to begin to take effect in 2012. EPA estimates that by 2014, the rule would reduce power plant SO 2 emissions by 71 percent over 2005 levels and NO

x emissions by 52 percent. Certainly, should Nebraska be included in the final rule and be required to reduce

emissions of SO 2 and NO

x , the impact on visibility is expected to be positive. A 71% reduction

in SO2 emissions and 52% in NOx over 2005 levels would mean Nebraska EGU emissions would be: 52,309 tons of SO2 and 26,659 tons of NOx.

Nebraska will continue to engage with states in the CENRAP region and will participate in future consultation processes as necessary to address reasonable progress goals at Class I areas.

11.3.1.2 Mobile Source Related Emissions and Standards

Mobile sour ces, both on

- road and non

- road, comprise a significant portion of Nebraska‘s emissions inventory. In 2002, n on

- road sources wer e the second larg est emitter of SO 2 in the

state. O n

- road and non

- road sources ma k e up over 60% of Nebraska‘s total NO

x emissio ns

. Reducing emissions from these mobile sources could have a positive impact on visibility impacts from Nebraska sources. Over the last several years, EPA has promulgated mobile source rules that are under implementation.

11.3.1.3 Tier 2 Vehicle and Gasoline Sulfur Program In December 1999, t he U.S. Environmental Pro tection Agency (EPA) is announced two significant mobile source rulemakings. The first was tai lpipe emissions standards for all passenger vehicles, including sport utility vehicles (SUVs), miniva ns, vans and pick

- up trucks. This regulation mark ed the first time that SUVs and other light

- duty trucks were to be subject to

the same national pollution standards as cars. The second rule that was announced at the same

time was for lower sulfur standard s in gasoline . The lower sulfur standards were put in place to

ensure the effectiveness of low emission

- control technologies in vehicles and reduce harmful air91

pollution. These new standards require passenger vehicles to be 77 to 95 percent cleaner than

those on the previously on the road and reduce the sulfur content of gasoline by up to 90 percent.

The phase

- in of new standards began with model year (MY) 2004, and was completed in MY 2007 for cars and light

- duty trucks, and in 2008 for medium

- duty vehi cles. By 2007, the

emission limit for NO

x was 0.07 grams per mile (g/mi). The sulfur levels in gasoline were capped at 300 parts per million (ppm) and limited to an average of 120 ppm in 2004, and by 2006 the cap was lowered to 80 ppm with a limit on ave rage sulfur levels of 30 ppm.

11.3.1.4 Locomotives and Marine Engines

Like on

- road vehicles, EPA addressed marine engines in two ways, through their fuels and through their emission limits. In May 2004, as part of the Clean Air Nonroad Diesel Rule, EPA

finalized new requirements for nonroad diesel fuel that decrease the allowable levels of sulfur in fuel used in marine vessels by 99 percent. These fuel improvements, which began to take effect in 2007, are creating significant environmental and public health benefi ts by reducing PM from new and existing engines. In March 2008, EPA finalized a three part program that will dramatically reduce emissions from marine diesel engines below 30 liters per cylinder displacement. These include marine propulsion engines used on vessels from recreational and small fishing boats to towboats, tugboats and marine auxiliary. The rule is expected to cut PM emissions from these engines by as much as 90 percent and NO

x emissions by as much as 80 percent when fully implemented. Also i n M arch 2008, EPA finalized a three part program that

d ramatically reduce s emissions from diesel locomotives of all types

-- line

- haul, switch, and passenger rail. Just as with the marine engines, t he rule will cut PM emissions from these engines by as much a s 90 percent and NO

x emissions by as much as 80 percent when fully implemented.

11.3.1.5 Small Engines ( Personal Watercraft; Lawn and Garden Equipment)

EPA has established a new emission control program to reduce VOC and NO

x emissions from small spark

- ignition eng ines by about 35 percent. The new regulations put in place a set of more stringent exhaust standards and establish new evaporative emission standards for the fuel tanks and fuel lines used in this equipment. The rules apply starting in the 2011 model year for Class II engines (above 225 cc) and in the 2012 model year for Class I engines (less than 225 cc, used in

non

- handheld applications).

11.3.1.6 NESHAP MACT Standards National Emission Standards for Hazardous Air Pollutants (NESHAP) have been promulgated by E PA and incorporated into Title 129

- Nebraska Air Quality Regulations in recent years that will not only achieve reductions in hazardous air pollutants (HAPs), but will also reduce visibility impairing pollutants such as SO 2 , NO

x , and PM. Some of the most no table NESHAPS

include:
Commercial, Industrial & Institutional Boilers & Process Heaters

- Subpart

DDDDD
Industrial, Commercial, & Institutional Boilers

- Area Sources

- Subpart JJJJJJ Reciprocating Internal Combustion Engines

- Subpart ZZZZ Stationary Comb ustion Turbines

- Subpart YYYY92

EPA has also proposed a NESHAP for Coal

- and Oil

- Fired Electric Utility Steam Generating

Units

- Subpart UUUUU. This rule, when finalized, is expected to reduce emissions from power plants and have resulting benefits on visib ility impairment.

Nebraska has units subject to each of these standards, and the State has or intends to incorporate these rules into Title 129 as they are updated by EPA.

11.3.2 Visibility Requirements under the New Source Review and Prevention of Significant

Deterioration Program The New Source Review Program is broken down into two parts: nonattainment new source review and prevention of significant deterioration (PSD) program. In Nebraska, since the whole state is currently in attainment with the National Ambient Air Quality Standards, the provisions of the PSD program apply. The visibility provisions of PSD are found under s ection 40 CFR 52.21(o) which requires owners or operators of new major sources or modifications to provide an analysis of visibility impairment as part of the prevention of significant deterioration process. Section 40 CFR 52.21(p) requires notification and consultation with federal land managers (FLMs) of Class I areas which may be affected. Section 40 CFR 52.21(o) requirements have

b een incorporated into Title 129

- Nebraska Air Quality Regulations at Chapter 19 Section 022 ―Additional impact analysis.‖ Notification and consultation requirements under 40CFR 52.21(p) have been incorporated by reference into Title 129 at Chapter 19 Secti on 001.

11.3.3 Measures to Mitigate the Impacts of Construction Activities

Nebraska is required by 40 CFR 51.308(d)(3)(v)(B) to consider measures to mitigate the impacts

of construction activities. When EPA first promulgated the Regional Haze Rule in 1999,

emiss ions related to construction activities such as windblown dust and nonroad diesel engines were a major concern. This was especially a problem in rapidly growing metropolitan areas such as Los Angeles and Phoenix. Construction activities are directly relate d to population growth.

Nebraska has not experienced rapid growth and is not forecasted to in the future. Figure 1 1

. 26 comes from the 2009 Ambient Monitoring Network Plan. It shows the top ten counties population and their respective growth over the las t few years

.93 Figure 11. 26 Population Growth in Nebraska

Population growth is projected to remain at a steady pace and construction activities are not expected to cause a significant impact to visibility.

11.3.3.1 Water Regulations on Construc tion Activities Construction projects in Nebraska that disturb one acre or more are required to obtain a general permit for storm water discharges under the National Pollutant Discharge Elimination System (NPDES). The permitting program was implemented to protect the waters of the State from

sediment and other contaminants, and may also reduce the amount of particulate matter

emissions from these activities. The NPDES permits require permitted entities to develop storm water pollution prevention plan contai ning best management practices to control erosion and

runoff. Many of the best management practices employed to prevent erosion and runoff a re also effective at preventing windblown dust.

11.3.3.2 Fugitive Dust Regulations

Nebraska Title 129

- Chapter 32

– Dust; Duty to Prevent Escape (Appendix 11. 4 ) of includes a provision applicable to construction activities in section 002. This section requires the use of reasonable measures such as paving, cleaning, application of water, planting and maintenance of ground c over, and/or application of dust

- free surfactants to be taken to prevent dust from becoming airborne such that it remains visible beyond the property boundary.

11.3.4 Agricultural and Forestry Smoke Management

Nebraska is required by 40 CFR 51.308(d)(3)(v)(E) t o consider smoke management techniques

for the purposes of agricultural and forestry management in developing reasonable progress goals.94

As evidenced in the emissions inventory in Chapter 8, Nebraska‘s emissions from fires is insignificant.

Nebraska Title 129

- Chapter 30

– Open Fires (Appendix 11. 5 ) is a ban on burning with some exceptions. Exceptions are limited in scope and most exceptions require permits from the NDEQ and the local fire authority. For purposes of agricultural burning, such burnin g is allowed under the following circumstances: Must be in an agricultural setting

No nuisance or traffic hazard can be created Only includes trees or vegetation indigenous to the property Burning is recommended for disposal because of the hazardous nature of the materials. Such materials can only be those that have been used on the property.

For purposes of forestry or land management, such burning is allowed under section 002.06 provided it is conducted by the Nebraska Game and Parks Commission, the US Forest Service, the University of Nebraska , or other entities determined to be acceptable by the Department

.

The University of Nebraska Extension service provides information on how to properly do a prescribed burn. These resources are available throug h their website at: http://www.ianrpubs.unl.edu . Because of the minimal impacts from burning, Nebraska has not further developed a smoke management plan. Existing measures seem to be working to m anage smoke from prescribed fires. However, NDEQ will continue to evaluate the need for additional measures during the periodic SIP reviews.

11.3.5 Enforceability of Emission Limitations and Control Measures

Nebraska is required by 40 CFR 51.308(d)(3)(v)(F) t o ensure that emission limitations and

control measures used to meet reasonable progress goals are enforceable. Nebraska has ensured that all emission limitations and control measures are enforceable by including adopting the appropriate rules into Title 1 29

. Additionally, the other measures needed include the BART limits. These BART permits contain the applicable emission limits and compliance schedules, which will be federally enforceable upon EPA‘s approval of this SIP. The emissions limits and complia nce verification requirements are already incorporated into an enforceable construction permit and will be incorporated into each facility‘s Title V operating permit when the appropriate operating permits are reopened or renewed

.

11.3.6 Source Retirement and Rep lacement Schedules At this time, Nebraska has not identified any source retirement or replacement obligations.

11.3.7 Anticipated Net Effect on Visibility Resulting from Projected Changes to Emissions

Nebraska is required by 40 CFR 51.308(d)(3)(v)(G) to address the net effect on visibility resulting from changes projected in point, area, and mobile source emissions by 2018. The 2002 to 2018 projected visibility improvement at the Class I areas selected for analysis and discussed previously will, for the State of Nebraska , result chiefly from the implementation of NO

x controls on the 3 electric generating units (EGUs) at 2 facilities subject to BART. Additional improvements are expected from the other federal measures that are currently under95

implementation descr ibed earlier in Chapter 11. NDEQ expects additional federal measures to be forthcoming which will have additional visibility improvement.

These projected visibility improvements as a result of implementation of this plan are shown in

Table 11. 1

, based on the ENVIRON PSAT tool, and shown in terms of light extinction . About 36 to 40% improvement is expected in the South Dakota Class I areas.

Table 11. 2 Net Improvement in Light Extinction

Class I Area 2002 Extinction (Mm - 1 ) 2018 Extinction

(Mm - 1 ) Net

I mprovement (Mm - 1 )

Badlands National Park 2.356 1.495 0.861 Caney Creek Wilderness Area 0.772 0.485 0.287

Great Sand Dunes Wilderness Area 0.183 0.115 0. 0 68

Hercules

- Glades Wilderness Area 1.249 0.860 0.389 Mingo Wilderness Area 1.093 0.731 0.362

Rock y Mountain National Park 0.254 0.158 0.096 Upper Buffalo Wilderness Area 0.353 0.226 0.127 Voyagers National Park 0.931 0.699 0.232

Wichita Mountains Wilderness Area 1.831 1.129 0.732

Wind Cave National Park 0.668 0.505 0.163

11.4 Reasonable Further Progr ess Conclusion In summary, during this first planning period, Nebraska has not been asked by any other state to reduce emissions beyond those under BART during the consultation processes. Given that Nebraska was identified as a potential contributor, or a lower

- tier contributor, in some Class I

areas, additional emission reductions from Nebraska sources may be the subject of consultation

discussions in the future. However, the implementation of federal measures such as the Clean Air Transport Rule, Nation al Emission Standards for Hazardous Air Pollutants for various source categories, the lower standards for sulfur on motor vehicles, and other such measures are expected to have a significant effect on visibility improvement.

At this time, consistent wit h the RPG guidance, given the emissions reductions that we anticipate to result from BART and the implementation of other federal CAA programs, and the resultant improvement in light extinction, we find that there are no additional measures necessary to

ac hieve reasonable progress in the first planning period for Nebraska.

Appendix 11.1 Northern Midwest

– Factor Analysis ( LADCO) Appendix 11.2 Central Class I Areas Consultation Plan Appendix 11.3 Oklahoma‘s Wichita Mountains Wilderness Area Regional Haze Planning Appendix 11.4 Nebraska Title 129

- Chapter 32

– Dust; Duty to Prevent Escape Appendix 11.5 Nebraska Title 129

- Chapter 30

– Open Fires96

12 Plan Revisions and Progress Reports Nebraska is required by 40 CFR 51.308(f) to revise its regional haze imp lementation plan and submit a plan revision to EPA by July 31, 2018, and every ten years thereafter. In accordance with the requirements listed in 40 CFR 51.308(f) of the federal rule for regional haze, Nebraska commits to revising and submitting this regi onal haze implement ation plan by July 31, 2018 and every ten years thereafter.

In addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the reasonable progress goals established for each mandatory Class I area. In accordance w ith the requirements listed in 40 CFR 51.308(g) of the federal rule for regional haze, Nebraska commits

to submitting a report on reasonable progress to EPA every five years following the initial

submittal of the SIP. The report will be in the form of a SI P revision. The reasonable progress report will evaluate the progress made towards the reasonable progress goal for each mandatory

Class I area located outside Nebraska , which may be affected by emissions from within

Nebraska

. All requirements listed in 40 CFR 51.308(g) shall be addressed in the SIP revision for

reasonable progress. The first five

- year progress report will be completed by December 31 , 201 6

. Using the findings of this first report, Nebraska will determine whether the adequacy of the plan

i s sufficient and will take appropriate action. Nebraska intends to consult and coordinate with other states, the FLMs, and EPA as required and appropriate.

The 2014 National Emissions Inventory will likely be the most current available inventory at that time and will be used as part of the progress report. However, given the need to consult with other states, an earlier inventory may be required to be used. It is expected that Nebraska w ill also have access to a later point source inventory and continuous emissions monitoring systems (CEMS) data for EGUs. Where this more up

- to

- date information is available, it may be used to supplement the National Emissions Inventory.

Nebraska will use the latest available inventory for the five

- year progress report, and compare that with the projected 2018 inventories. The status of BART controls will be addressed individually in that review. For the remaining sectors, EGAS growth rates will be used, where applicable, and projected growth will be compared with actual emissions. If this comparison indicates overall emissions are growing at a rate significantly (i.e., more than 10%) higher, on an individual species basis than previously projected, Nebras ka will evaluate the need to reassess the visibility impacts on potentially affected Class I areas through consultation with the appropriate federal land manager (FLM) and EPA. If additional controls are required, this could potentially include a SIP rev ision to address the visibility goal for the affected Class I area(s).