## Chapter Seven -- Long-Ter m Stra te gy fo r Ne vad a

7.1 LONG-TERM S T RATEGY OVERVIEW

7.1.1 Long-Term Strategy Requirem e nts 7.1.2 Technical Basis of Reasonable Progress Goal



### 7.2 BART CONTROLS

7.3 VISIBILITY IMPROVEMEMT

7.4 MITIGATION OF CONSTRUCTION I M PACTS

7.5 EMISSIONS LIMITATIONS AND SCHEDULES OF COMPLIANCE

7.6 SOURCE RETIREMENT A ND REP L ACEMENT SCHEDULES

7.7 SMOKE MANAGEMENT PROGRAM

7.8 ENFORCEABILITY OF EMI SSION LI MITS

7.9 LONG- TERM STRATEGY

7.9.1 Anthropogenic Sources of Visibility Impair m e nt 7.9.1.1 Major and Minor Stationary Sources 7.9.1.2 Mobile Sources 7.9.1.3 Area Sources 7.9.1.4 International Em issions 7.9.2 Additional Em issions Control Pro g ram s 7.9.2.1 State and Local Mobile S ource Program s 7.9.2.2 Nevada’s Renewable Portfolio Standard 7.9.2.3 Marine Diesel Rule 7.9.3 Other Considerations 7.9.3.1 Uncertainty 7.9.3.2 Contributions to Impairment at Class I Areas Outside of Nevada



### 7.10 REASONABLE PROGRESS ASSESSMENT

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-17.1 LONG-TERM ST RATEGY OVERVIEW
The long-term strategy is the comp ilation of enforceable em issions lim itations, comp liance schedules, and other m easures as necessary to ac hieve the reasonable progress goals and is the

m eans through which th e state ensu res that its reasonable p r o g ress goal (RPG) will be m e t (40 CRF 51.308(d)(3) and Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program , U.S. EPA, 2007). This chapter discusses Nevada’s long-term strategy to restore natural visibility conditions at the Jarbidge W ilderness Ar ea (Jarbidge WA) by 2064 and its rela tionsh i p to the RPG for the Jarbidge W A

. The long-term strategy must have the capability of addressing existing and future impairm e nt situa tions as they face th e sta t e. Gen e rally, Neva da conside r s its pe rm ittin g program m e ets this requirem e nt for existing m a jor sta tionary facilities, as well as pr eventing future impairm e nt from proposed major stationary sources or m a jor m o difi cations to existing faci lities. The New Source Review (NSR) and Prevention of Significant De terioration (PSD) program s are key components of Nevada’s regional haze plan designed to impr ove current visibility on the m o st i mpa ired days and to pro t ect vis i bility conditions at Class I areas. The state m a intains that its existing regulations, including the Best Available Retrofit Technology (B ART) regulations adopted for this SIP, a l o ng with the stra tegies an d activ it ies o u tlin ed in C h apter S i x a nd below pr ovide f o r reasonab l e p r ogress toward the na tion a l vis i bility goal.

The star ting point f o r the identif i catio n of addition a l em ission contro l strategi es is the visibility improve m e nt achieved as a result of BART and t h e imple m e n tation of other Clean Air Act (CAA) program s, including m easures for attainment of the ozone and PM 2. 5 National Am bient Air Quality Standards. Im plem entation of som e of these CAA control program s was incorporated into the PRP18a em issions invent ory and m odel i ng scenario, as was some of the imple m entation of BART. These program s are de scribed in Chapter Six. Other CAA program s and em issions reduction strategi es are described below.
7.1.1 Long-Term Strategy Requirements
USEPA regulations require the state to: 1) devel op a long-term strategy; 2) coordinate its longterm strateg y with exis ting plans and goals, including those of FLMs, whi c h m a y affe ct impair m e nt in any Class I area; 3) demonstrat e w hy the long-term stra tegy is adequate for

m a king reasonable progress toward the national goa l and state why the minimu m factors (listed in the next paragraph) were or were not addressed in develo ping the long-term strategy; 4) consider the tim e necessary for comp l i ance as we ll as th e econ o m i c, energ y, and non-air quality environm ental impacts o f comp liance, the r e m a ini ng useful life of any affected existing source, as well as th e effect of new s ources; 5) review its strategy no less frequent ly than ev ery three years and consult with FLMs duri ng this process; and 6) repo rt to USEPA and the public on progress ach ieved towar d the nation al vis i bility goal.
During the developm ent of the long-term strategy the state m u st consider, at a m i nim u m, the following six factors: 1) em issi ons reductions due to ongoing air po llution control program s ; 2)

m easures to m itigate the impacts of construc ti on activ ities; 3 ) additional e m issions limita tions

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-2and schedules for comp l i ance; 4) source retirem e nt and replacem ent schedules; 5) smoke

m a nage m e nt techniques for agricultural and fore stry m a nage ment purposes, including such plans as currently exist within the stat e for this purpose; and 6) enfor ceab ility of em ission lim itations and contro l m easures. The long-term strategy f o r region al h aze m u st also address th e anticipated net effect on visibility due to projected changes in point, area and m obile source em issions over the period addressed by th e long-term strategy.
7.1.2 Technical Basis of Reasonable Progress Goal
NDEP has used the analyses of m onitoring, em issions and modeling data in developing Nevada’s long-term strategy. Many of the tools and resources used in these analyses were produced by the Western Regional Air Partnership (WRAP) and its contractors a nd are discussed elsewhere in this docum ent. The analyses discussed in Chapters Two, Three and Four describe the monitoring, em issions, and m odeling inform ation a nd analyses on which Nevada is relying to determ ine the em issions reductions necessary to achieve reaso n able prog ress toward th e nation a l visibility goal by 2018. These anal yses provide the technical basi s of our long-term strategy.

7.2 BART CO NTROLS
The installation of BART controls is an integr al part of the long-term strategy and R P G of Nevada’s regional haze SIP. Chapter Five desc ribes the BART process, identifies Nevada’s seven BART-elig ible so urces and p r esents the B A RT requirem e nts for Neva da’s four subject-toBART f acilities. Ea ch s ource subjec t to BART is required to insta ll and operate BART as expeditiously as practicable, but in no event later than January 1, 2015 or 5 years after USEPA approval of the imple m e n tation plan, which ever o ccurs first. In additi on, each source subject to BART is required to establish pr o ced ures to en sure the con t rol equipm ent is properly o p erated and m a intained.

Seven Nevada facilities were iden tif ied as BART elig ible : NV Energy’s generating stations at Tracy, Fort Churchill, Reid Gar dner and Sunrise; Southern Calif ornia Edison’s generating station at Mohave; Nevada Cem e nt Comp any’s Fern le y f acility; an d Chem ical Lim e Company’s f a cility in Apex, Nevada. Four of these facilities were de term ined to cause or co ntribu te to v i sibility impairm e nt at a Clas s I ar ea and wer e subjec t to f u ll BART determ ination s . These f a c ilitie s are Fort Church ill, T r acy, R e id Gardne r, and Mohav e

. Significant em issions reductions wi ll be achiev e d by the ins t allati on of BART controls on these f

our f acilitie s. Table 7-1 summarizes the em issio n s reduction s resulting f r o m the insta lla tion of BART control technologies be yond those incorporated in the PRP18a e m issions inventory. These em issions reductions raise the overall redu ction from the baseline to 2018 in Nevada’s NO x inventory to 32.9 percent from 16.8 pe rcent and the reduction in the SO 2 inventory to 44.0 percent from 33.0 percent.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-3TABLE 7-1

ADDITIONAL ANNUAL EMISSIONS R E DU CTIONS IN TONS RES U LTING FROM IMP LEMENTATION OF B A RT IN NE VADA

NO x SO x PM 10 Total 2 6
, 4 7 7 7
, 6 1 1 1
, 3 6 0 3 5
, 4 4 8

7.3 VISIBILI TY IMPRO V EMENT
Utilizing W R AP Regional Mode ling Center (RM C ) m odeling results, Nev a da has es tim a ted the expected visibility improvem ents by 2018 at th e Jarbidge W A . Two projected 2018 em issions inventories were utilized by RM C, Base18b and PRP18a, to project visibility improvem ent. These inven t ories are more fully discussed in Chapter Three.
The Base18b inventory included em ission reductions due to known controls (i.e., implem entation of existing f e deral and state regulations), consent decree re ductions, existing SIP control

m easures and other relev a nt regu latio n s that h a ve gone into effect s i nce 20 02 or will g o into effect before the end of 2018. These controls do not include impacts from any future control scenarios that have yet to be determ i n e d, such as the installation of BART.
Figure 7-1 shows the projected 201 8 visibility conditions for the worst days at JARB1 resulting from the controls included in the Base18b em issi ons inventory. The projected visibility is 11.85 dv, reflecting the 0.22 dv or 1.8 percent decrease fr om baseline visibility conditions resulting f r om the implem entatio n of existing regula tions.

The PRP18a inventory refined the Base18b inventory by applying presumptive BART SO 2 em ission lim its to BART-eligible coal-fired electric genera ting unit (EGUs) greater than 750 M Wacross the W R AP region. BART NO x lim its were not incorporated into this inventory. Other, less significant refinem e nts to the PRP 18a inventory are described in Chapter One, section 1.3.2.2. Figure 7-2 shows the m odeled 2018 visibility projection of 11.05 deciviews (dv), a 1.02 dv or 8.45 percen t reduction in v i sib i lity impairment. These results suggest the full implem entation of BART across th e W R AP-regi on will r e sult in add ition a l and notice a ble improve m e nt of visibility impair m e nt at the Jarbidge W A for the worst days.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-4FIGURE 7-1

CMAQ 201 8 W O RST DAYS MODEL PR OJ ECTIONS F O R JAR B 1 USING BASE18b EMI SSIONS INVENTORY

7.4 MITIGATION OF CONSTRUCTION IMPACTS

Nevada m a nages the release of fugitive dust fr om construction related activities throu gh the imple m entation of regulations set forth in the Nevada Adm i nistrative Code (NAC).
NAC 445B.22037 requires fugiti ve dust to be controlled (regar dless of the size or amount of acreage disturbed), and requires an ongoing program
, using best practical m e thods, to prevent particulate m a tter from becom i ng airborne. All ac tiv ities wh ich have the potential to adversely affect the lo cal air quality m u st impl em ent a ll ap propria te m easures to limit con t rollab le

em issions. Appropriate m easures for dust control m a y consist of a phasedapproach to acreag e disturbance rather than disturbi ng the entire area all at once; using wet suppression through such application m e thods as water trucks or water sprays system s to control wind blown dust; the application of soil binding agents or chem ical surfactant to roadwa ys and areas of disturbed soil; as well as the use of wind-break or wind-lim iting fencing designed to lim it wind erosion of soils.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-5FIGURE 7-2

CMAQ 201 8 W O RST DAYS MODEL PR OJ ECTIONS F O R JAR B 1 USING P R P 18a EMISSIONS INVE NTOR Y

Furtherm ore, no person m a y disturb or cover 5 acre s or m o re of land or its topsoil until he has obtained an operating perm it for surface area dis t urba nce to clear, excavate or lev e l th e land or to deposit any foreign m a terial to fi ll or cover the land. In additi on to requiring a perm it for all disturb a nces greater th an 5 acres, a d u st control p l an m u st be subm itted f o r all dis t urba nces greater th an 20 acres. Th e approval o f the dust co ntrol plan does not lim it the perm it holder' s need to control fugitive dust from the disturbance and its related activities, nor from putting into effect an ongoing program for using the be st practical m e thods of dust control.
In addition to the requirem ents detailed above , there are guidelines for the Pahrump Valley (HA 162) in southern Nevada. In this area, a dust control plan is required for any disturbance greater than 5 acres. W a shoe and Clark counties have their own respec tive air quality departm e nts and, therefore, are responsible for m a naging their part icular fugitive dust program s (see Chapter S i x, section 6.5.2.3).

It is important to note the requirem e nts above do not apply to agricultu ral activities occurring on agricultural land and m i ning exploration projec ts pursuant to Nevada Revised Statute 519A.180.

7.5 EMISSIONS LIMITATIONS A ND SCHEDULES OF COMPLIANCE

BART e m is sions lim itations and schedule for comp liance is addressed directly by a revision to the Nevada Adm i nistrative Code (NAC) adopted on February 11, 2009 1 (Appendix A). The regula tion id entif ies the e m ission lim its and con t r o l techno log i es requ ir ed as BART. F o r the NV Energy facilities it identified Ja nuary 1, 2015 or five years after approval of Nevada’s SIP, which

1 I n re sp o n se t o pu bl i c com m ent s on t h e dra f t R H S I P (c ont a i ned i n Ap pe n d i x D )
, Ne vada i s re vi si n g t h e B A R T req u irem ents at NV E n er gy ’s Reid-Gar dne r Gene ratin g Statio n

. A regu lato ry am en d m en t lo wering th e SO 2 e m issio n limits fo r un its 1, 2 an d 3 fro m 0

. 2 5 to 0

. 1 5 lb /10 6 Btu
, 2 4 -hou r av erag e, h a s b e en su b m itted to th e State Environm ental Commission for prese n tation at their December 9, 2009 He aring. See Appendix A.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-6ever occu rs first, as the s c hedule for installati on and operation of BART; for the Mohave facility, BART must be installed and operatin g at the tim e each unit resum e s operation. 2

The CAA pr ogram s described in Chapter Six and below have specific em issions lim itations and schedules of comp liance unique to each program

. These lim itations and s c hedules are identified in the sp ecif i c ru les.

7.6 SOURCE RETIREM E NT AND REPLACEMEN T SCHEDULES

The construction of new sources, which will ensure the early or scheduled retirem e nt of older, less well-controlled sources, can greatly aid progre ss toward the nation a l vi sibility goal over the long term . Nevada’s continued impl em enta tion of NSR and PSD requirem e nts with FLM involvem e nt for Class I area impact review will p r otect the least impaireddays from further degrada tion and will a s s u re tha tno Class I ar eas experience degrada tion f r om expansion or growth of a single new source or large scale regi onal developm ent of stationary sources.

7.7 SMOKE MANAGEMENT P R OGRAM
Anthropogenic fire em issions for 2002 were estim at ed to be approxim a tely 250 tons per year out of nearly 64,000 tons per year of total fire em i ssions in Nevada or less than 0.5 percent of the total fire em issions in Nevada. Further control of anthropogenic fire em i ssions within the state

m a ybe of little benef it in improving visibili ty at N e vada and other Class I ar eas.
In Nevada, preventing and m a naging em i ssions from s m oke are achieved through implem entation of two separa te elements of th e a i r qua lity p r ogram . Open burning is contro lled through a comprehensive set of open burning regulati ons. Prescribed fires used specifically for land m a nagem e nt purposes are controlled th rough imple m entation of the Nevada Sm oke Managem e nt Program

. Open burning regulations are found in NAC 445B .22067. The regulations apply to f e deral, state and private lands equally and prohi bit open burning of com bus tible re fuse, waste, garbage, oil or open burning for any salvage operation. Exempt ions are granted for open burning conducted for the purposes of weed abatem ent, conservation, dis ease control, gam e or for e st m a nagem e nt and fire training. Burning for agricultural purposes is exempt, as is the burning of yard waste and untreated w ood at single-fa m ily residences. Sm all fires used for cooking, recreation, education

or cerem oni al purposes are also exempt.

The Nevada Sm oke Managem e nt Program was de veloped to coordinate an d facilitate the statewide managem e nt of prescribed outdoor bur ning. This program is designed to m eet the requirem e nts of Nevada’s air qua lity statu t es lis te d in Nevada Revised Statutes (NRS) 445B.100 through 445B.845 , inclusive, and the requirem e nts of the USE P A Interim Air Quality Policy on W ildland and Prescribed Fires (EPA OAQPS, April 23, 1998). It supports the visibility

2 O n J une 1 0
, 2 0 0 9
, t h e o w ne r s o f t h e M o ha v e Ge nerat i n g S t at i on, i n cl u d i n g S o ut he rn C a l i f or ni a E d i s o n (SC E )
, an nou n c ed t h e d ecision to d e co mmissio n th e statio n an d rem o v e th e g e n e ratin g facility fro m th e site. Th e SCE n e ws release states t h at in 20 10 , the p l an t ’ s g e n e ratin g eq u i p m e n t will b e rem o v e d and its op eratin g p e rm its t e rm in ated ( ht tp : / / www .ed i son

. com / press r o o m / pr.asp ? b u=sce&y ear= 2 00 9&i d =7 2 3 4 ).

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-7protection goals for Federal class I areas in Se ction 169A of t h e CAA. The program does not, however, su persede the authority of local governm ents to regul ate and control sm oke and air pollution under NRS 244.361 and NRS 268.410 or the aut hority of the state forester to regulate controlled fires under NRS 527.122 through 527.128

.
The Nevada Sm oke Managem e nt Program is ad ministered by NDEP and c o mp liance is achieved through a Mem o randum of Understanding (MO U ) betw een the various state and federal agencies that conduct prescribed burning, including the U.S. Bureau of Land Managem e nt, the U.S. Forest Service, the U.S. National Park Serv ice, th e U. S. Fish and Wildlife Service and Nevada state agencies. The MOU lists the objectives as well as both the m u tual and in dividual responsibilities of the signatory parties. The MOU has a term of five years an d will be ren e wed in 2011. Land

m a nagers recognize the importance of the Neva da Sm oke Managem e nt Program and provide fiscal support for its con tinuation through various financ ial assistance agreem ents.

The Smoke Management Plan ( http://ndep.nv.gov/baqp/t echnical/SMP2005.htm l ) is a collaborative docum ent, written by the signers of the MOU, and is the guiding document of the program . It details the applicabil ity of the program and responsibilit ies of affected parties. It provides inform ation on open burn variance requ irem ents for those land managers using prescribed fire and wildland fires for land m a nage m e nt purposes. It also includes inform ation on air quality monitoring at prescr ibed fires, burner qualificati ons and em ission reduction m e thods.

The Smoke Management Plan applies to all areas of Neva da except Clark County, W a shoe County and Bureau of Indian Affairs trust la nds. Applications for open burn variances are processed by NDEP. Applicants must estim a te the pres crib ed fire’s PM 10 e m issions. For larger f i res, additio nal inf o rm ation is ne ede d and str i cte rrequirem e nts are imposed. For f i re s em itting greater than 1 ton but less than 10 tons PM 10 and located greater than 15 m iles from a Class I
area, a sm oke sensitive area or a nonattainm e nt area, th e application m u st include an estim ate of

em issions from a m odel predicting the impact of sm oke on s m oke sensitive receptors. For prescr ibed f i re projects e m itting grea ter than 25 t ons, or m o re than 10 ton s if the burn area is within 15 m iles of a Class I area, a smoke sensi tive area or a nonattainm e nt area, the application must also include a sm oke m a nage ment plan thatlists sm oke m i ni m i zation m e thods to be used and the m o del or calculations used to m a ke em is s i on estim a tes. The plan must have a list of saf e ty and c ontingency m easures, identif ica tion of sm oke sensitiv e ar eas that m a y potentially be affected, a list of air regulators to be notified and air m onitoring to be conducted.

Variance co nditions inte nded to m itigate sm oke impacts apply to open bu rn variances issued by NDEP. The s e include: variances will be invali d during declared air pollution em ergencies and alerts in affected areas ; p r e-ign i tion n o tific ation and approval is required; best sm oke

m a nage m e nt and em ission reduction techniques shall be practiced; and varian c e s are issued with provision s related to sup e rvis ion, ins p ection a nd availability of the varian ce. Additio nal restrictions and requirem e nts a pply where wildland fires are used to achieve land m a nagem e nt objectives in cluding a bu rn plan, app l icable m a ps, a lis t of conditions un de r which burn i ng will be suppressed and a stipulation re quiring daily fire evaluation. Burn m a nagers are expected to

assess m e teorological conditions, o b tain a bu rn day forecast and not proceed to ign i tion unless conditions are favorable. All personnel c onducting prescribed burns m u s tm e et burner qualif ica tion s

.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-8Agencies conducting prescribed fires in excess of 10 tons of PM 10 annually are required to supply NDEP with an annual fire activity repor t. This report provide s a summ ary of fire activ ities in c l uding a lis ting of : pe rm i tnum ber, acreage burned, fuel type, em issions estim ates and em ission factors used. NDEP is in the pro cess of assessing current fire em ission data collection procedures and future data needs. Consideration is being given to augm enting data collection efforts and emission tracking m e thods for the purpose s of enhancing regional haze

assessm ents. This m a y include participation in the W R AP’s Fire Em i ssion Tracking System or use of other fire em ission tracking tools.

NDEP’s we bsite includes additional inform ati on on the Nevada Sm oke Managem e nt Program and can be found at http://ndep.nv.gov/baqp/technical/sm oke.htm l . Per m it applications, an instruction sheet, links to app licable statutes and regulations and contact infor m ation are provided.

7.8 ENFORCEABILITY OF EMISSIONS LIMITS
Enforceability of the BART e m ission lim its will b e through ru le. Am endm ents to the NAC were approved by the State Envir onm ental Comm ission during thei r February 11, 2009 hearing. 3 Where CAA program s specify em issions lim its, these lim its are enforceab le th rough federal rule. Som e state and local po llution con t ro l program s do not have enforceable em issions limits but are still ef f

ectiv e in redu cin g em issions of visibility impairing pollutants.

7.9 LONG-TERM STRATEGY
Projected 2018 visibility conditi ons at the Jarbidge W A are be tter than the glidepath toward achieving natural visibility conditions by 2064. For this reason and other factors discussed in Chapter Six (see section 6.7) and below, Nevada ’s long-term strategy will be lim ited to those pollution control program s described in Chapter Six and below (i.e., the “on-the-books” and “onthe-books” controls included in the P R P18a e m i ssion inventory in Chapte rs Three and Six and the redu ctio ns realized f r om the i mplem entation of BART) that resu lt in the RPG identif ied in Chapter Six.

For the sam e reasons, N e vada did not take into consideration the cos t s of comp liance; the tim e necessary for comp liance; the energy and non-air quality environm ental impacts of compliance; and the remaining useful life of any non-BART sources in es tablishing our RPGs for this planning period. Theref ore, this SIP does not in clude a dem onstration showing how these factors were taken into consideration in selecting the goals.

3 I n re sp o n se t o pu bl i c com m ent s on t h e dra f t R H S I P (c ont a i ned i n Ap pe n d i x D )
, Ne vada i s re vi si n g t h e B A R T req u irem ents at NV E n er gy ’s Reid-Gar dne r Gene ratin g Statio n

. A regu lato ry am en d m en t lo wering th e SO 2 e m issio n limits fo r un its 1, 2 an d 3 fro m 0

. 2 5 to 0

. 1 5 lb /10 6 Btu
, 2 4 -hou r av erag e, h a s b e en su b m itted to th e State Environm ental Commission for prese n tation at their December 9, 2009 He aring. See Appendix A.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-97.9.1 Anthropogenic Sources of Visib i lity Impairment

Table 7-2 id entif ies the r e lative contribution of each visibil ity impairing pollutant f r o m anthropogenic and natural em ission sources. These data suggest SO 2 and NO x are th e dom inant anthropogenic em issions of prim ary particulate m a tter from Nevada sources. Natural sources include em issions from t h e biogenic, natura l fire and windblown dust source categories. Emissions from natural sources re present nearly three-quarters of all emissions or iginating from within Nevada’s borders. Natural sources are uncontro llable and have little potential for effective control of visibili ty impairing em issions.

Table 7-3 id entif ies the r e lative co ntribution to visibility impa irm e nt by pollutant for the baseline and 2018 and the change in em issions from the ba seline period to 2018. Table 7-4 identifies the larges t source catego r ies for each pollutant and th e change in em issions from the baseline to 2018 by source category. The 2018 em ission inventor y does not include all em issions reductions rela ted to th e f u ll implem entation of BART in Nevada or other WRAP st ates, so additional

em issions reductions beyond those shown are lik ely by 2018. The pollutants are ordered by their relative contribution to the baseline wo rst days visibility impairm e nt.

TABLE 7-2

SUMMAR Y OF NEVADA ANT HROP OGE NIC AND NATUR A L E M ISSIONS

2 002 2 018

Po llu tan t Ant h r o po ge ni c S o u r c e s N a t u r a l Source s Ant h r o po ge ni c S o u r c e s N a t u r a l Source s SO 2 96 % 4 % 9 4 % 6 % NO x 86 % 1 4 % 83 % 1 7 % EC 27 % 7 3 % 17 % 8 3 % PM F 44 % 5 6 % 51 % 4 9 % PM C 38 % 6 2 % 47 % 5 3 % NH 3 86 % 1 4 % 88 % 1 2 % PO A ( O C ) 9 % 9 1 % 9 % 9 1 % VOC 10 % 9 0 % 10 % 9 0 % To tal Em issio n s 28 % 72 % 27 % 73 %

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-10TABLE 7-3

NEVADA’S EXTINCTI ON C ONT R I BUTI ON AND EMISSIONS B Y SP ECIES

W o r s t D a y s B e s t D a y s 2 0 02 20 18 ** Ch a n g e

* O M C 4 0 .0 % 2 6

. 3 % 2 4 ,7 3 4 2 4 ,8 2 2 0

. 4 %

C M 22

. 3 % 9

. 2 % 1 6 1
, 142 1 8 8, 28 7 1 7% SO 4 1 6 .7 % 4 0

. 9 % 6 8 ,9 8 9 4 6 ,2 2 4

- 3 3 % S O I L 9

. 7 % 2

. 8% 20
, 9 6 9 24
, 1 3 4 15 %

E C 6. 5% 9. 4 % 6
, 4 0 9 5
, 6 38

- 1 2% NO 3 4. 5% 9. 8 % 16 2, 475 1 3 5, 49 6

- 1 7 %

* P O Afo r e m is sio n s ** 20 18 em i s s i on s pr oj ec t i o n d o e s n o t i n c l ud e B A R T r e d u c t i o ns A n nu al A v er age B a s e l i n e E x t i nc t i o n C o n t r

i bu t i on E m i s s i o n s (tp y )

Exam ination of Table 7-4 shows th e larges t source catego r ies for f our of t h e visibility im pairing pollutants, organic m a tter carbon (O MC), coarse m a tter (CM), SOIL and elem ental carbon (EC), are natural em issions resulting from natural fi re and windblown dust. Point sources are the dom i nant em ission category for ammonium sulfate (SO 4 ) and ammonium nitrate (N O 3 ), although

area sou r ces are also sig n ificant em itters of SO x ; and m obile sources, both on- and off-road, are im portant e m itters of N O x . Fugitiv e dust is an important so urce ca tegor y f o r CM and SO IL

em issions. The long-term strategy f o r the first planning period focuses on SO x and NO x em issions originating from point and mobile s ources. These s ource catego ries are d i scussed below.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-11TABLE 7-4

NEVADA E M ISSIONS SOUR CE C ONTRIB U T I ONS B Y S P ECIES

L a r g e s t 201 8 S o u r ce C a t ego r y P e r cent o f 2 018 Inv en t or y 20 02 t o 20 18 C h a n ge f o r Ca t e g o r y S eco n d L a r g est 2 0 18 S o u r ce

C a t ego r y P e r cen t of 2 018 I nven t or y 20 02 t o 20 1 8 Ch a n g e f

or Ca t e g or y *O M C N at u ral F i re 90

. 6 % 0 % Ar e a 3

. 1 % 1 3% CM W ind bl o w D u s t 49

. 9 % 0 % F u g i t iv e D u s t 36

. 5 % 4 5% SO 4 P oi n t 6 1

. 3 %

- 4 4 % Ar e a 3 0. 1% 1 0 % SO I L W ind bl o w D u s t 43

. 3 % 0 % F u g i t iv e D u s t 30

. 0 % 4 4% EC N at u ral F i re 8 2

. 9 % 0 % * *M ob i l e 1 4. 0%

- 5 0 % N O 3 P oi n t 5 0

. 0 % 1 3% * * M o b i l e 2 7

. 5 %

- 49

. 5 %

* P O A f

o r em i s si o n s

* * I n c l u d es o n

- r o a d a n d o f f

- r

o a d m o bi l e so ur ces B o ld t e xt i ndi c a t e s na t u ra l s o ur c e s
7.9.1.1 Major and Minor Station a ry Sources

Nevada’s evaluation of the m onitoring, em issions and m odeling data suggests that point source

em issions of SO x and NO x are the m o st likely candidates for additional control, although these

em issions are not the m o st sign if icant contributors to visibility im pair m e nt at the Jarbidge W A

. Baseline and 2018 em is sions of SO x and NO x from within Nevada are dom i nated by anthropogenic sources, as shown on Table 7-4. Although OMC (for m e d from Pri m ary organic aerosol (POA) and Volatile organic com pound ( VOC) e m is sions), EC, PMC and PMF are significant contributors to visi bility impairm e nt, their em issions are dom inated by natural and uncontrollable sources. Nevada’s S O x em issions have a gr e a ter contr i bu tion to v i sib i lity im pairm e nt at JA RB1 than N O x (see Figures 2-7 and 2- 11), although Nevada’s NO x em issions are two to th ree tim e s greater than S O x e m issions.
As noted in Chapter Three and iden tified in Table 7-5, the 2018 em i ssions inventory lists 30 point sources with NO x em issions greater than 100 tpy and 13 with SO x em issions greater than 100 tpy. Point sources with em issions greater than 100 tpy represent 97 percent of Nevada’s total 2018 point source inventories for SO x and NO x .
The 30 NO x point sources include all f our Nevada sources subject to full B A RT determinations,

as w e ll as th ree oth e r f a c ilitie s tha tar e BA RT-elig ible but do not cause or contribute to visibility im pair m e nt at any Class I ar ea. Also included on the NO x list are all five future EGUs proposed for Nevada, described in Chapter Three. The 13 SO x sources include tw o f a cilities sub j ect to a f u ll BA RT analysis, as w e ll a s tw o other f aciliti es that are BART-eligible but do not cause or contribute to visibility im pairm e nt at any Class I area. Also included on the SO x list ar e thr ee proposed coal-fired EGUs.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-12TABLE 7-5

SUMMARY OF SO 2 AND NO X E M ISSIONS FROM NEVADA POINT SOURCES FOR 2018

SO 2 NO x

Annual Emissions (tpy) Number of Facilitie s Cumulative Percent of Total Point Source Emissions Number of Facilitie s Cumulative Percent of Total Point Source Emissions > 10,000 0 0% 1 29.0% 2,000 to 10,000 3 78.7% 6 76.3%

500 to 2000 3 92.5% 8 90.8% 100 to 500 7 97.7% 15 97.0%

A discussion of the BART process in Nevada can be found in Chapter Five where links to reports docu m enting the BART analyses are p r ovided. Exem ption m odeling for one of the BART-eligible facilities, Che m i cal Lim e Company located in Cl ark County, dem ons trated that the m a xi mu m visibility impact of 0.245 delta dv occurred at the Gra nd Canyon approxim ately 90

m iles away, roughly half of the cause or contribute threshold of 0.5 dv. The other BARTeligible facility, Nevada Ce m e nt Company, hol ds a perm it to reconstruct a state-of-the-art f

acility resu lting in an ov er all reduction of e m issions.

Nevada Cem e nt Company applied for and received a constructi on perm it to construct a new, state-of-the-art cem e nt production plant. They n e tted ou t of PSD review by shuttin g down and

rem oving their current kilns and other ancillary production-related processes to m a ke room for the new kiln . The new plant is subject to th e National Em ission Standard s for Hazard ous Air Pollutan t s program and will reduce overall em issi ons, while increasing p r oduction capacity. The net perm itte d (poten tia l to em it) em ission decr eas es f o r N O x , SO 2 and PM 10 are 1,812, 186.59 and 167.29 tons per year, respectively. Actual 2 018 em issions reductions at Nevada Ce m e nt will be sligh tly less.

The effects of Nevada’s Renewable Portfolio Standard (RPS) on EGU source retirement and replacem ent schedules are not well known. The por tf olio s t a ndard requ ir es each electric service provider to generate, acquire or sav e electricity from portfolio energy sy stem s or effi ciency

m easures in an am ount that is not less than 20 percent of the total am ount of electricity sold by the provider by 2015. Current 2018 em issions pr ojections include five proposed EGUs for Nevada, as discussed in Chapter Three and shown on Table 3-5. The demand for one or m o re of these proposed EGUs m a y be m e t by renewabl e energy sources, negating the em issions associated w ith a projected EGU and theref ore reducing 2018 em issions. However, it is im possible to predict at this tim e which or how many of these proposed E GUs will be constructed.
Many of Nevada’s point sources with SO 2 or NO x em issions greater than 100 tpy are well contro lled o r will b e well controlled through the BART process. In add i tion, several of the federal pollution control program s described in C h apter S i x (see section 6. 5.2) address em ission

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-13from point sources (i.e., Maximu m Achievab le Control Technology standards). The SO 2 point source inventory for 2018 represents a nearly 60 percen t reduction from the baseline inventory, and the 2018 NO x point source inventory represents a gr eater than 30 percent reduction from the baseline when proposed BART c ontrols are included. These si gnificant reductions demonstrate reasonable progress from poi nt sources in Nevada.

7.9.1.2 Mobile Sources
Nevada has achieved significant reductions in SO x and NO x em issions from m obile sources through the implem entation of federal, stat e and local em issions control program s

. Im plem entation of the f e deral p r ogra m s w ill resu lt in a 49 per cent r e duction in m obile source NO x e m issions and a 63 percent re du ction in m o bile sou r ce S O x em issions from the baseline to 2018 (PRP18a). These significant reductions de monstrate reasonable progress from mobile sources, both on-road and off-road, in Nevada.

Table 3-15 shows m obile sources are significant source categories for N O x and ammonia (NH 3 ). On-road andoff-road m o bile sou r ces contribute approxim a tely 25 percent of the tota l statew ide 2018 NO x em issions inventory and 23 percent of the NH 3 inventory. Many of the federal pollution co ntrol p r ogra m s identif ied in Chap ter Six (see 6.5.2.1) focus on reducing NO x em issions from m obile sources, both on-road an d off-road. In addition, Washoe and Clark Counties have im ple m e n ted m obile source em issions reduction program s to address nonattainm e nt areas, as d i scussed in Chapter Six (see 6.5.2.3) and this chapter (see 7.9.2.1). The

em issions reductions related to the implem entation of these local prog ram s has not been factored into the PRP18a em issions pr ojections or m odeling.

7.9.1.3 Area Sources
Area sources are by nature, relative ly sm all em issions sourc e s w ith dive rs e chara c te ris tics w h ich

m a ke effective control difficult. Nevada has not evaluated or addre ssed em issions reductions from area so urces in this, the firs t planning period of the sixty

- year regional haze SIP p r ocess.

7.9.1.4 International Emissions

Em issions from outside the m odeling dom a in, as well as those from Canada and Mexico contribute substantially to visib i lity impairm e nt at the J a rbidge W A and other Class I areas across the WRAP. These em ission s are beyond the control by federa l, state or local regulatory agencie s in the U n ited States. A tthe Jarbidge W A , interna tio nal em ission s of SO x and NO x contribute 51 percent and 30 percent of the 2018 SO 4 and NO 3 visibility impairm e nt at JARB1, respec tive l y.

Em issions from Pacific Offshore sources, as di scussed in Chapter Four (see 4.3), although not strictly inter n ationa l, inc l ude em issio n s f r om inte rnational w a ters of the P a cif i c O cean

. Em issions o f SO x and NO x fro m Pac i fi c Offshor e sources contribute 6.9 percent of SO 4 visibility im pair m e nt and 1.3 percent of NO 3 visibility im pairm e nt at J A RB1.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-147.9.2 Additional Emissions Control Programs

Nevada has num e rous existing em ission control pr ogram s to im prove and protect visibility in Class I areas. Generally, Nevada considers its NS R and PSD program s meet the long-term stra tegy r e q u irem ents f o r preven ting f u ture vis i bi lity im pairm e nt f r om proposed m a jor stationary sources or major m odifications to existing faci lities. In addition to Nevada’s perm itting program , Ne vada also has em ission control require m e nts for motor vehicles in Clark and W a shoe Counties and residential burning in Washoe Country, as well as PM 10 nonattainm e nt/m aintenance area requirem ents, dust suppression for construction areas and unpaved roads, and renewable energy requirem e nts.

The state believes that its existing reg u lations alo ng w ith the activ ities ou tlin ed below togethe r provide f o r r easonable pr ogress tow ar d the na tion al vis i bility goal. N e vad a ’s continue d im plem entation of NSR requirem e nts with FLM i nvolvem e nt for Class I area im pact review will protec t the least im paired days f r om f

u rther deg r adation and w ill assu re that no Class I are a s w ith a potential to be im pacted by N e vada em issions w ill expe rie n ce degrad ation f r om expansion or growth of a single new source.
7.9.2.1 State and Local Mobile Source Programs

Nevada’s tw o m a jor m e tropolitan areas, Clark County (Las V e gas) and W a shoe County (Reno), have inspection and m a intenance program s per th e Clean Air Act requirem e nts for areas that were not attaining the national am bient air quality standards for carbon m onoxide (C O). Washoe County has a basic prog ram while Clark County has a lo w enhanced program

. Both reduce CO and VOC e m i ssions from motor vehicles.

Both W a shoe and Clark Counties ha ve Stage I and Stage II gasolin e vap o r recov e ry regula tions. These system s control VOC vapor releases du ring the refilling of underground gasoline storage tanks and the refueling of m o tor vehicles. The Stage II sy stem controls the release of VOC, benzene andtoxics em itted from gasoline. Both counties hav e wintertim e oxygenated fuel program s that reduce CO e m issions.
Nevada statute requires an addi tional statewide program to reduce em issions of pollutants from

m o tor vehic l es, the A l ter n ative Fue l e d V e hicl e p r ogram . The Alternative Fueled Vehicle program requires state and local governm ent fleets to operate 90 percent of their fleet vehicles on alternative fuel. This p r ogram reduces NO x , SO 2 , CO, VOCs and PM. Nevada also h a s a statewide regulation pro h ibiti ng the em ission of sm oke from any gasoline powered motor vehicle.
Washoe and Clark Counties were designated nona ttainm e nt for CO in 1978, along with the Lake Tahoe Basin. The Nevada portion of the Tahoe Basin and Washoe County have each been redesign atedas attainm e nt. Clark C ounty has su bm itted a C O redesignation reques tto USEPA.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-157.9.2.2 Nevada’s Renew a ble Portfolio Stand a rd

W ith large-scale geotherm al developm ent in Ne vada dating back to th e mid-1980’s and use of hydroelectric energy since the earl y part of the last century, Nevada’s electric utilities have pioneered the use of renewable energy. In coopera tion with the utilities, N e vada was one of the first to adopt a RPS in 1997, which is now a m ong the m o st aggressive in the United States. Nevada’s RPS has set the bar hi gh in term s of its percen t of renewable energy, tim etable and solar quota, requiring that not le ss than 20 percent of the tota l electricity sold in 2015 and thereafter be renewable. Power producers ha ve responded by working with renewable energy

com p anies to bring m a ny new renewable projects into operation. As a result, Nevada now leads the nation in both geotherm al and solar power per capita.
In 2007, two of the world’s largest solar projec ts began operation in southern Nevada, the 64 M WNevada Solar One concentrating solar power plant and the 14 MWSolar Star photovoltaic facility at N e llis AFB. Geotherm al energy is a renewable resource pa rticularly abundant in Nevada. W i t h three new geotherm al plants com p lete d in the past year, and a total of 26 projects under contract, Nevada’s m a in u tility, NV Energy, is on-the-books to doubling the geotherm al portion of its renewable energy por tfolio by 2012 to a to tal of nearly 500 M W . These efforts to

m eet the RPS w ill rep l ac e som e of the need f o r f o ssil f u el f i re d EG U s in N e vada.
7.9.2.3 Marine Diesel Engine Rule
As part of its National Clean Diesel Ca m p aign, USEPA promulga ted a rule to reduce diesel

em issions from m a rine engines less than 30 lite rs per cylinder effective July 7, 2008. These engines are used to power a wide variety of vessels, from s m all fishing and recreational boats to large tugs an d Great Lak e s freighters

. They are also used to generate auxiliary vessel power, includ ing on ocean-go i n g ships. The new st andards will dram atic ally redu ce PM and NO x em issions by: tightening em issions standards fo r rem a nufactured engine s; setting near-term engine-out em issions standards (Tier 3) for ne wly-built m a rine diesel engines; and setting longer-term standards (T ier 4) th at reflect the applic ation of high-efficiency after-treatm ent technology.

USEPA estim ates 90 percent PM reductions and 80 percent NO x reductions from Tier 4 engines

m eeting these standards, com p ared to engines m eeting the current Tier 2 standards. By 2030 this program w ill reduc e ann u al nationw ide em issions of N O x by about 800,000 tons and PM

em issions by 27,000 tons, and those em ission redu ctions continue to grow beyond 2030 as fleet turnover is com p leted. Additional infor m a tion regarding this program can be found at http://www.epa.gov/otaq/regs/nonroad/420f08004.htm

.
7.9.3 Other Considerations

W R AP technical analyses of causes of haze in th e west s how significan t impacts from nonanthropogenic and otherwise non-controllable sour ce sectors, such as fire, dust and sources outside s t a t e jurisd ic ti on. Em issions of NO x and SO 2 from point, m obile and area sou r ces are the predom inant anthropogenic pollutants to be addre ssed through regional haze SIPs in the W e st.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-16The largest catego r y of stationary so urce SO 2 and NO x em issions is e l ec tr ic gene ratin g units, a source category from which substantial reductions have already occurred.
There are significant co ntrol p r ogram s in place in Nevada an d the W R AP region to reduce SO 2 and NO x e m issions betw een the baseline period and 2018. Most notable of these program s is the im ple m entation of BART requirem e nts, which are anticip a te d to resu lt in signif i can t r e duction s of SO 2 and NO x e m issions in the W R AP region. These reductions are in a ddition to significant

em ission reductions of SO 2 and NO x from 2002 to 2006 from EGUs (BART and non-BART sources) in the west, on the order of 30 percent for SO 2 and 10 percent for NO x .

H o w e ver, the f u ll im pact of these sig n if ican t em issions reductions has not yet been fully evaluated by Nevada. Therefore, for the 2013 in terim review, Nevada will determ ine refined reasonab l e p r ogress at th e Jarbidg e WA in consideration of:

• Evolving modeling and technical an alyses ;

• Evolving progress on B A RT and reasonable progress from c ontributing states; and

• Lim ited control N e vad ahas w ith re s p ect to n a tur a l, in ters tate and inte rnational em issions that con t r i bu te to v i sib ility im pairm e nt at the Jarbidge W A

.
W R AP will conduct add ition a l m odeling with up dated 2018 em issions inventories th at reflect additional control m easures iden tified by states

. The updated invento r ies will in corp orate the results of Nevada and other WRAP st ates’ BART determ inatio ns, as w e ll a s other reaso n able

m easures sta t es id entif y f o r im plem entation in th e initial revie w period. A ddition a l r e d u ctions to the W R AP- w ide, as well as statewide em i ssions are expected as states m ove through developm ent of their reg i onal ha ze p r ogram s. These m odeling ef f

o rts w ill be s c heduled by RMC upon com p l e tion of BART determ inations by al l W R AP states, anticipated in 2009 to 2010.

A com p lete assessm ent of Nevada’s RPG cannot be m a de until th e effects on visibility im pair m e nt resulting from e m issions reductions due to full implem entation of BART and other RH SIP control programs are determ ined. Ho wever, 2018 reasonable progress m easured at the Jarbidge W A is expected to be better than show n by the current m odeling projections, which are based on the PRP18a em issions inve ntory. N e va da w ill con t inue to w o rk w ith the W R A P ’s ongoing m o deling program to refine the RPG for the Jarbidge WA as these data becom e available. N e vada does not anti cipate revision of the RPG based on the updated m o deling. The

m odeling re sults w i ll, h o w e ver, pro v ide N e vada w ith additio nal too l s to evalua te andref i ne its long-term strategy as part of the m i d- course regio n al haze S I P review.
Under the proposed long-term strate gy described herein, there m a y be some additional visibility im prove m e nts that occur by 2018 beyond those reflectedin the RPGs identified in Chapter S i x. Em issions r e duction s du e to the im plem entati on of som e state and local pollution control program s have not been or can not be quantified and have not been included or will not be included in the em issions inventories used for visibility and source a pportionm ent m o deling. The f o llow i ng section d e scrib e s add ition a l con t r o l program s in N e vada, the benef its o f w h ich have not been included in Nevada’s RPG identif ied in Chapte r Six.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-177.9.3.1 Uncerta i nty
Nevada’s reasonable progress dem onstration and developm ent of a long-term strategy have identified num e rous factors affecting the im plem entation of our long-term strategy and resulting reasonable progress. These factors have im porta nt but unknown i m pacts to all elem ents of the plan to redu ce or con t ain em issions contributing to reg i onal haze. The most significant facto r is the uncertainty of the projected 2018 em ission inventories, which m a y not reflect actual 2018

em issions for Nevada sources. Some of the f actors affecting Nevada’s reasonable p r o g ress are related to projected em issions inventories a nd the uncertainties associated with growth projections and the im plications of future regulatory actions.
Nevada has seen significant redu ctions in econom i c and population grow th in th e las t tw o years, which m a y c o m p rom i se the earlier growth proj ections. The observed slowdown in population growth m a y reduce actual area and mobile so urce em issions from projected 2018 values. The current econom i c slowdown in Nevada has severe ly cur t ailedresiden t ial a nd com m e rcial real estate construction, a significan t com ponent of off-road m obile source em i ssions. Likewise, the high fuel costs of 2008 have resulted in lower fuel dem a nd and therefore less on-road m obile

source em issions. Current econom ic forecasts on ly highlight the uncertainties of pro j ecting

em issions based on growth estim ates, with som e experts predicting se veral years of slow

econom ic growth.
Nevada acknowledges the m a ny diffi culties asso ciated with the projection of area and m obile

source em issions, but rem a ins confi d ent the inventor ies represent the bes tavailable d a ta at the tim e they were developed. However, Nevada al so acknowledges there is associated uncertainty with the area source projections, which m a y over-pre dict f u tu re em issions in ligh tof the curr ent

econom ic tim es.
Repair and replacem ent schedules fo r larg e poin t sources of NO x and SO 2 are d i fficult for the regula t ory c o m munity to antic ipate. It is also d i f f i cult to pre d ict the pote n tia l perm it revis i ons for other large sources in response to growth of any particular industry sector. Repair and replacem ent of current f acilities will continue to drive perm it revis i ons at their own pace, but will likely reduce em issions as new technology is incorporated into the facilities.

A nother lev e l of uncerta inty in the g r ow th proje c tions r e la tes to regu lato r y uncertainty. The consequences of future regulatory actions ar e not well known at this tim e

. The Clean Air Mercury Ru le w a s re cen tly vac a ted b y the cour ts. W h ether U S EPA w ill reissue this r e gulation

or w h at f o rm it w ill tak e is not kno w n at this tim e . The other ar ea of re gulato r y unc erta inty is how U S EPA w ill regu late gr een ho use gas em issions a nd w h at anc illary benef its to visibility w i ll be realized.

PM 2. 5 and ozone nonattainm ent SIPs are due 201 2 a nd 2013. Most Nevada sources will not b e affected by nonattainm e nt SIPs; how ever sources in W a shoe or Clark Counties m a ybe subject to nonattainm e nt SIPs. Certain l y there will be localized reductions in PM 2. 5 and ozone as SIPs are im ple m ented in nonattainm ent areas, not only in Ne vada, but across the west . Additional control

m easures resulting from nonattainment SIPs andot her regulatory actions will result in direc t

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-18reductions of visibility impairi ng pollutants. The co-benefits of i m plementing additional controls for PM 2. 5 and ozone will also reduce em issions of visibility im pairing pollutants.
7.9.3.2 Contributions to Imp a irment at Class I Areas Outside of Nevada
Tables 4-3 and 4-4 identify Nevada ’s contr i bution to visib i lity im pa ir m e nt at Class I areas in the five states adjacen t to N e vada based on the Pa rticulate Matter Source Attribution Tracking modeling discussed in C h apter Four. In order to evaluate whether Nevad a ’s SIP inclu d es all

m easures necessary to o b tain its sh are of the em i ssion redu ctions needed to m eet the p r ogress goals for tho s e Class I areas, NDEP calculated :

• The visibility reductions needed at these Class I areas to achieve the 2018 URP goal;

• The percentage of the needed reduct ion achieved based on the Base02d em ission inventory and m odeling scenario;

• Nevada’s em issions reduction share;

• The contribution of Nevada em issions to SO 4 an d NO 3 extin ction ;

• The percentage change in Nevada’s em issions from Plan02d to PRP18a; and

• The percentage change in Nevada’s wei ghted em issions potential (W EP) from Plan02d to PRP18a. This information is pres ented in Tab l e 7-6 for th e Class I area in each adjacent s t ate with the highest m odeled SO 4 and NO 3 contribution to visibility im pair m e nt for the 2018 worst days (see Tables 4-3 and 4-4). NDEP has included the Hoover W ilderness Area at the request of the FLMs.

Exam ination of Table 7-6 shows that the per centage of Nevada’s em issions reductions or weighted em issions reductions ex ceed the percentage of Nevada ’s contribution to visibility im pair m e nt at all Class I areas lis ted. Som e of the num bers listed in the W E P change colum n are negativ e, ref l ecting an in creas e in Nevada’s W E P. These increases are an artifact of th e W E P

m e thodology, where all the percentages of e m issi on contribution are norm a lized to the largest valued gr id cell. Th is is especially e v ident f o r S O 4 at Hells Canyon W ilderness Area in Oregon, where Nevada’s W E P c ontribution in creas ed by nearly 30 p e rcent. Th is is due to th e significan t SO x e m issions reductions achieved by sources cl oser to Hells Canyon W ilderness Area (i.e. sources in Idaho, Oregon and W a shington) and the inverse distance f unction of the WEP. Chapter One (section 1.3.3.2 Source Apportionm ent Modeling) describes the W E P me thodology and the lim itations regarding the us e of these data.
In order to more fully understand the significance of the WEP data presented in Table 7-6, the upper portion of Figure 7-3 shows the significant contributions and 2018 reductions for Idaho, Oregon and Washington sources’ potential contri butions and the relati vely sm all potential contribution for Nevada sources at Hells Canyon W ilderness Area. The lower portion of Figure 7-3 presents the SO x weighted em ission potential m a p fo r Hells Canyon Wilderness Area. Note that Nevada has only three grid cells with weighted em ission poten tials g r eater than o n e percen t, one of which is LS Power’s proposed 1500 M W coal-fired E GU in east central Nevada.
Figures 7-4, 7-5 and 7-6 show sim ilar W E P analyses for the S a wtooth W ilderness Area, Desolation W ilderness Area, and Hoover W ilderne ss Area, respectively. Review of Chapter Three (section 3.8.1 Nevada SO x Em ission Inventory for 2002 a nd 2018, Table 3-7) shows that

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-19area sources are the only Nevada source category with significant grow th (1,243 tons or 10 percent) of SO 2 e m issions. Figure 3-10 is a regional m a p of gridded SO x em issions, while Figure 3-11 breaks down Nevada’s SO 2 em issions by county.
These figures and Table 7-6 are all based on th e PRP18a e m ission inventory, which does not incorporate the full im plem entation of BART in Nevada or across the W R AP region (see Chapter One 1.3.2 Em issions Analyses and Proj e c tions ). Tab l e 7-1 identif ies the add i tiona l

em issions reductions from the PRP18a invent o r y resulting f r o m the f u ll implem entation of BART in Ne vada.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-20TABLE 7-6

SUMMARY OF VISIBILITY IMPAIRME NT AT NE ARB Y CLASS I AREAS AND NEVADA’S EM ISSI ONS R E DUC TIONS

Mo n i t o r - Co m p o n en t B a s e lin e Ext i n c t i o n (d

v or Mm -1 ) 20 18 U R P (d v o r Mm -1 ) E x ti n c ti o n Red u c t i o n

Ne e de d (p e r c ent ) 20 18 RP G (dv or Mm -1 ) Re d u c t i o n Ac h e i v e d (p e r c en t ) 20 1 8 Po l l u t an t Co n t r i b u t i o n b y

N e va da fr

om P S A T (p e r c en t ) N e va da ' s Em i s s i o n s R e du ct i o n

Sh ar e (p e r c en t ) R e d u c tio n in N e v a d a Emi s s i o n s B a s e 02 d t o

PR P 1 8 a (pe r c e n t ) Re d u c t i o n N eva da Wei g h t e d Em i s s i o n P o ten t i a

l* ( p er ce nt )

G R C A 2 - D e ci vi e w 1 1

. 6 6 1 0

. 5 8 9

. 3 % 11

. 1 0 4

. 8 % GRC A 2 - S O 4 5

. 36 4

. 1 1 2 3

. 3 % 4

. 5 6 1 4

. 9 % 2. 8% 0. 7% 3 3

. 0 % 6 5

. 2 % S Y C A 1 - D e c i vi ew 1 5

. 2 5 1 3

. 25 1 3

. 1 % 1 5. 0 8 1. 1 % SYC A 1 - N O 3 2

. 03 1

. 6 9 1 6

. 7 % 1

. 6 7 1 7

. 7 % 4. 3% 0. 7% 1 6

. 6 % 2 2

. 5 %

B LI S 1 - D e c i v i e w 1 2

. 6 3 1 1. 1 0 12

. 1 % 1 2

. 2 2 3

. 2 % BLI S 1 - S O 4 5

. 0 7 3

. 9 6 2 1 .9 % 4 .9 0 3

. 4 % 4 .4 % 1 .0 % 3 3

. 0 %

- 4

. 4 %
BLI S 1 - NO 3 2

. 3 8 2

. 0 1 15

. 5 % 1

. 5 9 3 3

. 2 % 2 0

. 0 % 3

. 1 % 1 6. 6% 36

. 2 % HOO V1 - De c i v i e w 1 2 .8 7 1 1

. 6 6 9

. 4 % 1 2

. 4 5 3 .3 % HOO V1 - S O 4 5

. 0 0 3

. 9 1 2 1 .8 % 4 .6 1 7

. 8 % 2 .6 % 0 .6 % 3 3

. 0 %

- 1

. 0 % HOO V1 - NO 3 1

. 63 1

. 4 3 1 2

. 3 % 1

. 3 5 1 7

. 2 % 8. 3% 1. 0% 1 6

. 6 % 2 3

. 4 %

S A W T 1 - D e c i v i ew 1 3

. 7 8 1 2

. 06 1 2

. 5 % 1 3. 2 5 3. 8 % SAW T 1 - S O 4 3

. 06 2

. 5 0 1 8

. 3 % 2

. 6 2 1 4

. 4 % 2. 5% 0. 5% 3 3

. 0 %

- 7

. 7 % SAW T 1 - N O 3 0. 6 3 0

. 65

- 3

. 2 % 0

. 5 5 1 2. 7 % 3

. 2 %

- 0

. 1 % 1 6

. 6 % 1 2

. 0 %

H E C A 1 - D e ci vi e w 1 8

. 5 5 1 6

. 1 7 1 2

. 8 % 1 6

. 60 1 0

. 5 %
HE C A 1 - S O 4 8

. 37 6

. 3 5 2 4

. 1 % 7

. 4 1 1 1

. 5 % 4. 0% 1. 0% 3 3

. 0 %

- 2 9

. 2 % HE C A 1 - NO 3 2 8

. 4 7 1 9. 6 9 30

. 8 % 2 0

. 5 6 27

. 8 % 5

. 5 % 1

. 7 % 1 6. 6% 13

. 8 %

Z I O N 1 - D e c i v i e w 1 3

. 2 4 1 1

. 78 1 1

. 0 % 1 2. 7 6 3. 6 %
Z I ON1 - S O 4 5

. 29 4

. 04 2 3

. 6 % 4

. 4 8 1 5

. 3 % 5. 6% 1. 3% 3 3

. 0 % 4 3

. 8 %
B R C A 1 - D e ci v i e w 11

. 6 5 1 0

. 5 2 9. 7 % 1 1

. 2 2 3

. 7 % BRC A 1 - NO 3 2

. 5 2 2

. 0 6 1 8 .3 % 2 .2 7 9

. 9 % 8 .8 % 1 .6 % 1 6

. 6 % 2 1

. 7 %

* A n t h r o p o ge ni c s o ur ce c a t e g o r i e s on l y

. Ut

a h Ar

i z o n a

C a

l i fo rn i a

Ida h o

Or

e g o n

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-21FIGURE 7-3

W E IGHTED EMISSION POTENTIAL ANALY SIS FOR HELLS CANYON W I LDERNESS AREA

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-22FIGURE 7-4

W E IGHTE D EMISSION POTE NT IAL ANAL Y SIS FOR SAWTOOT H W I LDERNESS AREA

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-23FIGURE 7-5

W E IGHTE D EMISSION POTE NT IAL ANA L Y SIS FOR DESOL A TI ON W I L D E R NESS AREA

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-24FIGURE 7-6

W E IGHTE D EMISSION POTE NT IAL ANA L Y SIS FOR HOOVER W I LDE R NESS AREA

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-25Baseline and projected annual SO x em issions for the s t ates adjacen t to N e vada are sh own in Figure 7-7, while Table 7-7 shows the per centage change in the inventories.

FIGURE 7-7

BASELINE AND PROJ ECTED SO x EMISSIONS BY ST AT E

TABLE 7-7

BASELINE AND PROJ ECTED SO x INVENT ORIES BY S T ATE

St a t e P l a n0 2d PRP1 8a P e r c en t C h a n g e A Z 1 1 1, 70 9 8 2, 33 4 2 6. 3 % C A 82
, 0 8 9 8 3
, 6 11

- 1

. 9 % I D 39
, 1 6 3 2 6
, 4 65 32

. 4 % N V 68
, 9 7 9 4 6
, 2 24 33

. 0 % O R 52
, 4 4 9 2 9
, 3 36 44

. 1 % U T 55
, 6 4 0 4 5
, 9 16 17

. 5 % W A 86
, 3 2 3 5 2
, 4 93 39

. 2 %

7.10 REASONABLE PRO G RESS ASSESSMENT

Nevada has concluded that the em issions reductions due to fe dera l, sta t e and loca l “o n-thebooks” and “on-the-books” em issions control coupledwith those resulting from the installation of BART requirem e nts represen t a reasonable lon g -term strategy for the first reg i onal h aze planning period. Modeled visibility improvem e nt at the Jarbidge W A for the 20 percent worst days is expected to be better than the uniform rate of progr ess by 2018 based on reductions from

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-26federal and state “on-the-books” and “on-the-books” em issions c ontrols represented by the 18PRPa e m issions inventory. Visibility on the 20 percent best days is al so projected to im prove in 2018 as a result of the em issions reductions ex pected from federal and state control program s.
Nevada’s 2018 RPG shows better visibility im prov em ent at the Jarbidg e W A than the uniform rate of progress. This significant progress paralle ls the uniform rate of visibility im provem e nt needed to restore natural visibi lity conditions by 2064 as requir ed by the regional haze rule. V i sibility impairm e nt at the Jarbidg e W A is dom i nated by em issions from natural or otherwise uncontrollable sources or areas. Air m a nage m e nt agencies are unable to control em issions from natural sources, or em issions from s ources beyo nd the purview of the United States’ regulatory author ity.
For these reasons, Nevada has concluded the long -term strategy identified and discussed herein

m a kes reasonable progress toward the national goal of rem e dying existing im pair m e nt of visibility in the Jarbidg e W A resultin g f r om m a nm ade air pollution f o r th e f i rst p l anning period. It is reasonable for Nevada to defer reductions to late r plann i n g periods in order to m a intain a consistent glidepath toward the long-term goal.

Nevada’s RPG is an interim goal representing in crem ental visibility im provem e nt over the first planning period ending 2 018. As such, Nevada w ill take into account the effects of other sta t e and local controls when setting reasonable progress as they beco m e available, even though they

m a y not be federa lly enf o rceab le pro g ram s . Nevada will take other s t ates’ SIPs and BART determ inations into account dur ing the first review and evalua tion of our long-term strategy, modeling results and RP G.

To summ arize, the regio n al haze S I P presented h e re docum ents the techn i cal b a sis to determ ine our share of em issions reduction obligations n ecessary to achieve reasonable progress in the Jarbidge W A and other Class I areas affected by Nevada’s em issions of visibility im pairing pollutants. Nevada considers our progress to in c r em entally improve visibility at the Jarbidge WA and other Class I areas to be reasonable for the first regional haze planning period. In addition, Nevada has identified several scenarios that suggest additional reductions in Nevada’s projected 2018 em issions inventor y that w i ll lik ely result in b e tte r pro j ected visib i lity im prove m e nt at the m a ndatory Class I areas than curren tly p r edicted.

U nder the lo ng-term stra tegy desc rib e d here in, th ere w i ll be s o m e additio nal vis i bility im prove m e nts that occur by 2018, beyond those reflected in the RPGs identified in Chapter S i x. Beginning in 2009, Nevada will d e v e lop proced ur es and sch e dules for evaluation of source catego r ies to determ ine what additio n al controls are app r opriate to achiev e further reasonable progress. T h is eva l uatio n will take into accoun t any new rele vant m onitoring and m odeling inform ation related to the cont ribution of Nevada anthropogenic sources to Class I im pairm e nt, new regulations that m a y benefit reg i onal haze, and any new guidance related to the identifying additional control m easures consistent with reas onable progress requirem en t of the regional haze rule. Nevada’s comm itm ent to progress reports and future plan revisions is discussed in Chapter Ni ne.

NEVADA REGIONAL HAZE S T ATE IMPLEMENTATI ON PLAN, October 2009 7-27