Chapter Five – Best Available Retrofit Technology 

5.1 OVERVIEW OF THE BART PROCESS 

5.2 BART-ELIGIBLE SOURCES IN NEVADA 

5.3 EXEMPTION MODELING SETUP AND ANALYSIS 

5.4 SUMMARY OF EXEMPTION MODELING RESULTS 

 

5.4.1 Subject-to-BART Sources 

 5.4.2 BART-Exempt Sources

5.5 SUMMARY OF BART CONTROL ANALYSES 

5.5.1 BART at Tracy 

5.5.2 BART at Fort Churchill 

5.5.3 BART at Reid Gardner 

5.5.4 BART at Mohave 

5.5.5 Cumulative Emissions Reductions

5.6 VISIBILITY IMPROVEMENT DUE TO BART IMPLEMENTATION 

5.6.1 Tracy 

5.6.2 Fort Churchill 

5.6.3 Reid Gardner 

5.6.4 Mohave 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-1 
5.1 OVERVIEW OF THE BART PROCESS 

The Regional Haze Rule (RHR) at 40 CFR 51.308(e) requires the installation of Best Available 

Retrofit Technology (BART) controls on a specific set of existing sources as one tool to meet the 

CAA visibility protection provisions. A BART-eligible source is one which meets the following 

criteria: 

1. Contains an emission unit from one of 26 source categories identified in the CAA and 

regulations, 

2. The emission unit was in existence on August 7, 1977; however, not in operation before 

August 7, 1962. 

3. The potential emissions from all the emission units identified in steps 1 and 2 are 

currently 250 tons per year or more of any air pollutant. 

A BART-eligible source that is responsible for a 1.0 deciview (dv) change or more is considered 

to “cause or contribute” to visibility impairment. Although the appropriate threshold may vary, 

the USEPA guidelines indicate that the cause or contribute threshold used for BART 

applicability should not exceed 0.5 dv. Thus, Nevada considers a BART-eligible source that is 

responsible for a 0.5 dv increase or more to cause or contribute to visibility impairment. Any 

BART-eligible source determined to cause or contribute to visibility impairment in any 

mandatory Class I area is subject to a BART determination. 

To assess visibility impairment from BART-eligible sources in Nevada, an individual source 

attribution approach was used to predict single source contribution. The USEPA guidelines 

direct that states review sulfur dioxide (SO2), nitrogen oxides (NOx) and particulate matter (PM) 

emissions in determining whether sources cause or contribute to visibility impairment. States 

may use their best judgment to determine whether volatile organic compounds or ammonia 

emissions are likely to have an impact on visibility in an area. 

Sources identified as subject to BART are required, through a BART engineering analysis, to 

identify what types of controls, if any, should be placed on the source. The RHR also requires 

states to consider the following factors in making BART determinations: 

1. The technology available, 

2. The costs of compliance, 

3. The energy and nonair quality environmental impacts of compliance, 

4. Any existing pollution control technology in use at the source, 

5. The remaining useful life of the source, and 

6. The degree of improvement in visibility which may reasonably be anticipated to result 

from the use of such technology. 

Upon determination of BART, each source is required to install and operate BART as 

expeditiously as practicable, but in no event later than 5 years after approval of the SIP.

5.2 BART–ELIGIBLE SOURCES IN NEVADA 

The BART-eligible sources were identified using the methodology in the Guidelines for BART 

Determinations under the Regional Haze Rule or “Guidelines” found in 40 CFR 51, Appendix Y. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-2 
Fourteen units at seven facilities were identified as BART-eligible. The BART-eligible facilities

are: NV Energy’s generating stations at Tracy, Fort Churchill, Reid Gardner and Sunrise; 

Southern California Edison’s (SCE) generating station at Mohave; Nevada Cement Company’s 

Fernley facility; and Chemical Lime Company’s Apex facility. BART-eligible sources in 

Nevada are listed in Table 5-1. 

TABLE 5-1

BART-ELIGIBLE SOURCES IN NEVADA

Facility Potential to 

Emit (tons per year) 

Source Location Unit Source

Category 

Date 

in 

Operation NOx SO2 PM10

Boiler 

1 1963 

Boiler 

2 Tracy 1965 Mustang, 

NV 

Boiler 

3 

Electric 

Generating 

Station

1974 

1,167 21 125

Boiler 

1 1968 Fort 

Churchill Yerington, NV Boiler 

2 

Electric 

Generating 

Station 1971 

2,221 9 41

Boiler 

1 1965 

Boiler 

2 1968 Reid 

Gardner Moapa, NV 

Boiler 

3 

Electric 

Generating 

Station 

1976 

7,045 1,020 1,343

Sunrise Las Vegas, NV 

Boiler 

1 

Electric 

Generating 

Station 

1964 851 1 13

Boiler 

1 1969 

Mohave Laughlin, NV Boiler 

2 

Electric 

Generating 

Station 1969 

20,267 40,347 1,958

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-3 
Facility Potential to 

Emit (tons per year) 

Source Location Unit Source

Category 

Date 

in 

Operation NOx SO2 PM10

Nevada Kiln 1 1963 

Cement 

Company 

Fernley, NV Kiln 2 

Portland 

Cement 

Plant 1967-1968 2,065 96 80

Chemical 

Lime

Company 

Apex, NV Kiln 3 

Portland 

Cement 

Plant 

1968 1,121 178 241

5.3 EXEMPTION MODELING SETUP AND ANALYSIS 

Air quality modeling was conducted by the Western Regional Air Partnership (WRAP) Regional 

Modeling Center (RMC), at the request of Nevada, to initially assess which BART-eligible 

sources are subject to a full BART determination and which are exempt. Modeling was 

conducted for all of the sources listed in Table 5-1 by the WRAP. Nevada Cement Company 

later exercised their option to conduct their own assessment. 

WRAP’s BART modeling was performed in accordance with the WRAP Modeling Protocol 

(2006) and the April 2007 explanation of changes using the CALPUFF modeling system

(Version 6). The modeling analysis utilized three years (2001, 2002, 2003) of 36-km MM5 

meteorological data, processed through CALMET. Modeled emissions represent the 24-hour 

average actual emission rate from the highest emitting day of the meteorological period modeled. 

The results for a given year of meteorology are presented as the 98th percentile delta dv for each 

Class I area and the number of days that exceed 0.5 delta dv. In other words, the results are 

based on the eighth highest delta dv results for each year of analysis. Modeled species included 

SO2, NOx and PM10. The modeling procedures used are outlined in the WRAP BART Modeling 

Protocol and Explanation of Changes in the April 2007 Revised Final Modeling Analysis

available at http://pah.cert.ucr.edu/aqm/308/bart.shtml . The modeling domain included all 

mandatory Class I areas within 300 km of the BART–eligible sources. Figure 5-1 depicts the 

location of the facilities and Class I areas. 

Nevada Cement developed their own exemption modeling protocol consistent with the WRAP’s 

modeling protocol with the exception of refinements to the meteorological data and the use of 

the EPA-approved version of the CALPUFF modeling system (i.e., Version 5). Their protocol is 

available at http://ndep.nv.gov/baqp/planmodeling/rhaze.html. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-4 
FIGURE 5-1 

LOCATION OF NEVADA’S BART SOURCES

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-5 
5.4 SUMMARY OF EXEMPTION MODELING RESULTS 

 BART-eligible sources responsible for a 0.5 dv change or more in visibility at any Class I area are 

subject to a full BART determination to identify and implement BART. BART-eligible sources 

that do not cause or contribute to visibility impairment at a threshold greater than 0.5 dv are exempt 

from further BART determination. The RMC produced BART exemption modeling reports for 

BART-eligible sources, available at http://ndep.nv.gov/baqp/planmodeling/rhaze.html. Nevada 

Cement Company conducted their own exemption modeling, and their report is also available at 

http://ndep.nv.gov/baqp/planmodeling/rhaze.html. 

5.4.1 Subject-to-BART Sources 

Four BART-eligible facilities modeled above the 0.5 dv “cause or contribute” visibility 

impairment threshold and are subject to a full BART analysis. These subject-to-BART facilities 

are the generating stations at Tracy, Fort Churchill, Reid Gardner and Mohave. Table 5-2 lists 

the Class I areas within 300 km of each source and identifies the 98th percentile dv value for 

2001 through 2003 and the number of days the modeled impact exceeded the 0.5 dv threshold. 

Only those Class I areas impacted by visibility impairment at a value of 0.5 dv or greater are 

listed. 

TABLE 5-2

BART EXEMPTION MODELING RESULTS – SOURCES SUBJECT TO BART1

Facility Class I Area Distance to 

Class I 

Area (km) 

98th Percentile dv 

2001-2003 

Days 

> 0.5 dv 

2001-2003 

Tracy Desolation

Mokelumne 

Hoover 

Yosemite 

Caribou 

Lassen Volcanic 

South Warner 

Lava Beds 

81 

101 

142 

153 

170 

175 

189 

286 

1.20 

0.88 

0.52 

0.50 

1.03 

0.94 

0.99 

0.74 

47 

32 

11 

11 

48 

44 

62 

25 

Fort Churchill Mokelumne 

Desolation 

Hoover 

Emigrant 

Yosemite 

Ansel Adams 

John Muir 

Caribou 

78 

85 

99 

100 

112 

132 

169 

226 

1.24 

1.25 

1.00 

0.68 

1.00 

0.70 

0.56 

0.77 

69 

72 

32 

25 

29 

28 

24 

34 

 

1 A summary of the WRAP RMC BART modeling for these facilities is available at 

http://ndep.nv.gov/baqp/planmodeling/rhaze.html. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-6 
Facility Class I Area Distance to 

Class I 

Area (km) 

98th Percentile dv 

2001-2003 

Days 

> 0.5 dv 

2001-2003 

Lassen Volcanic 

South Warner 

Thousand Lakes 

231 

245 

265 

0.77 

0.72 

0.60 

33 

62 

21 

Reid Gardner Grand Canyon 

Zion 

Joshua Tree 

85 

148 

292 

1.72 

0.83 

0.88 

60 

38 

48 

Mohave Grand Canyon 

Joshua Tree 

Sycamore Canyon 

San Gorgonio 

San Jacinto 

Zion 

Pine Mountain 

Dome Land 

Mazatal 

Agua Tibia 

Cucamonga

110 

137 

223 

225 

234 

262 

265 

268 

279 

286 

287 

4.61 

4.58 

1.51 

1.44 

1.62 

2.58 

1.21 

1.97 

1.19 

1.15 

1.38 

498 

248 

111 

75 

74 

270 

49 

72 

45 

54 

51 

5.4.2 BART-Exempt Sources 

Three facilities modeled below the 0.5 dv visibility impairment threshold and are not required to 

perform a BART determination. These facilities are the Sunrise Generating Station, the Nevada 

Cement Company facility and the Chemical Lime Company facility. The 98th percentile dv 

value for 2001 through 2003 and the number of days the dv value exceeded 0.5 dv are presented 

in Table 5-3. 

TABLE 5-3

BART MODELING RESULTS – BART-EXEMPT SOURCES2

Facility Class I Area Distance to 

Class I 

Area (km) 

98th Percentile dv 

2001-2003 

Days 

> 0.5 dv 

2001-2003 

Sunrise Grand Canyon 

Zion 

Joshua Tree 

Dome Land 

San Gorgonio 

John Muir 

Bryce Canyon 

95 

207 

228 

237 

271 

282 

284 

0.20 

0.11 

0.16 

0.08 

0.08 

0.06 

0.04 

1 

0 

0 

0 

0 

0 

0 

 

2 A summary of the WRAP RMC BART exemption modeling for these facilities is available at 

http://ndep.nv.gov/baqp/planmodeling/rhaze.html.

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-7 
Facility Class I Area Distance to 

Class I 

Area (km) 

98th Percentile dv 

2001-2003 

Days 

> 0.5 dv 

2001-2003 

Sequoia 

San Jacinto 

Sycamore Canyon 

288 

290 

290 

0.04 

0.06 

0.03 

0 

0 

0 

Nevada 

Cement 

Company 

Desolation 

Mokelumne 

Emigrant 

Hoover 

Yosemite 

Caribou 

Ansel Adams 

Lassen Volcanic 

South Warner 

John Muir 

Thousand Lakes 

Kaiser 

Kings Canyon 

Lava Beds 

101 

115 

148 

150 

161 

185 

186 

191 

224 

224 

254 

267 

294 

294 

0.27 

0.31 

0.16 

0.22 

0.22 

0.48 

0.18 

0.46 

0.49 

0.14 

0.26 

0.08 

0.11 

0.22 

3 

3 

0 

0 

0 

6 

0 

6 

7 

0 

4 

0 

0 

0 

Chemical 

Lime

Company 

Grand Canyon 

Zion 

Joshua Tree 

Dome Land 

Bryce Canyon 

John Muir 

Sycamore 

Sequoia 

San Gorgonio 

89 

185 

254 

256 

263 

290 

292 

296 

297 

0.05 

0.03 

0.04 

0.02 

0.01 

0.01 

0.01 

0.01 

0.02 

0 

0 

0 

0 

0 

0 

0 

0 

0 

5.5 SUMMARY OF BART CONTROL ANALYSES 

A full BART determination was completed for the generating stations at Tracy, Fort Churchill, 

Reid Gardner and Mohave. Emission limitations for BART were established on a case-by-case 

basis taking into consideration the technology available, the costs of compliance, the energy and 

non-air quality environmental impacts of compliance, any pollution control equipment in use or 

in existence at the source or unit, the remaining useful life of the unit and the degree of 

improvement in visibility which may reasonably be anticipated to result from the use of control 

technology. 

The control measures identified by Nevada as BART will be installed and operating for NV 

Energy’s generating stations at Tracy, Fort Churchill and Reid Gardner on or before January 1, 

2015 or no later than 5 years after approval of Nevada’s RH SIP by the USEPA, whichever 

occurs sooner. SCE’s generating station at Mohave is temporarily shut down; they must have 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-8 
BART installed and operating at the time each unit resumes operation.3

 The designated BART 

controls, emission limits and compliance deadlines are enforceable through Nevada state 

regulation R190-08, adopted on February 11, 20094

 (see Appendix A). BART will be 

incorporated into the NV Energy facilities’ Title V operating permits over the normal course of 

renewals. A modification to Mohave’s Title V permit incorporating BART was submitted in 

December 2008 and is being reviewed. 

NV Energy and SCE prepared BART determinations for the eligible units at their respective 

facilities. Based on the data presented by NV Energy, Nevada determined that the BART 

conclusions proposed for Tracy and Fort Churchill were not supported for NOx, but were 

acceptable for SO2 and PM10. The BART conclusions for Reid Gardner were not supported for 

NOx, whereas for SO2 and PM10, the proposed control technologies were acceptable, but the 

emission limits were not supported. Mohave’s BART determination was fully accepted by 

Nevada. Detailed BART determination reports from the facility for each of these sources and 

Nevada’s BART determination reviews of NV Energy’s reports are available at 

http://ndep.nv.gov/baqp/planmodeling/rhaze.html (see Appendix B). 

Where facility BART determinations were not accepted, the state made its own determinations 

using the facility reports as a foundation. NDEP prepared BART determination reviews for each 

of the NV Energy facilities including an economic analysis summary. The economic analysis 

summaries are presented in Table 1 in each of NDEP’s BART determination review reports. 

NDEP established baseline emissions representative of actual emissions using acid rain data for 

NOx and, where available, for SO2. For PM10, annual emissions data reported to NDEP were 

used to establish a baseline. Nevada used the NDEP baseline data in its cost analyses and NOx

BART control technology determinations. The NDEP baseline data were also used to establish 

the BART emission limits for PM10 at Reid Gardner and NOx at all three NV Energy facilities. 

An alternative dataset was used in conjunction with the baseline emissions to establish the BART 

SO2 emission limits for Reid Gardner. Finally, the NDEP baseline heat input was used in 

conjunction with the BART emission limits to calculate the post-BART-control annual emissions 

for the NV Energy facilities. The following describes how Nevada established baseline 

emissions for the NV Energy facilities. 

For Tracy and Fort Churchill, NDEP established baseline emission scenarios for NOx and SO2

using acid rain data reported for calendar years 2002 through 2007. These years were 

determined to be most representative of operations for these units since they are load-following 

and not base-load units. For Mohave, a base-load unit, NDEP used acid rain data reported for 

calendar years 2001 through 2005 for the SO2 and NOx baseline. Mohave suspended operation 

at the end of 2005. Reid Gardner is also a base-load unit; therefore, NDEP used acid rain data 

 

3

 On June 10, 2009, the owners of the Mohave Generating Station, including Southern California Edison (SCE),

announced the decision to decommission the station and remove the generating facility from the site. The SCE news

release states that in 2010, the plant’s generating equipment will be removed and its operating permits terminated

(http://www.edison.com/pressroom/pr.asp?bu=sce&year=2009&id=7234). 4

 In response to public comments on the draft RH SIP (contained in Appendix D), Nevada is revising the BART

requirements at NV Energy’s Reid-Gardner Generating Station. A regulatory amendment lowering the SO2

emission limits for units 1, 2 and 3 from 0.25 to 0.15 lb/MMBtu, 24-hour average, has been submitted to the State 

Environmental Commission for presentation at their December 9, 2009 Hearing. See Appendix A. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-9 
for NOx and SO2 reported for calendar years 2001 through 2007 to calculate baseline emissions. 

The baseline emissions scenario for PM10 was established from the annual emissions data 

reported to NDEP for the calendar years indicated above for each facility. 

Consistent with the calculation of baseline emissions for the Prevention of Significant 

Deterioration program, the average of the highest two consecutive years of annual emissions, on 

a pollutant-by-pollutant basis, were used to establish a baseline emission scenario for each 

pollutant, except Reid Gardner, which was established as follows. The SO2 acid rain data for 

Reid Gardner contained periods (Q1, 2003) of invalid data due to O2 monitor problems identified 

by NDEP during a compliance investigation, which lead to the joint NDEP/EPA enforcement 

action and consent agreement described in Chapter Six, section 6.5.2.2. Therefore, NDEP 

omitted the invalid data from the calculation of baseline SO2 emissions. The omission of the 

invalid data effectively lowered the baseline emissions, in lb/MMBtu, by nearly half. 

The baseline annual heat input and baseline annual emissions were used to calculate baseline 

emission rates in lb/MMBtu. The control efficiencies provided by NV Energy were then applied 

to the baseline NOx emission rates to calculate the BART emission limits in lb/MMBtu and the 

post-BART annual emissions, as shown in Table 1 of the NDEP BART reviews. 

Nevada initially (for the January 2009 FLM review draft) used the NDEP baseline in its 

determination of the BART SO2 emissions limits for the three units at Reid Gardner. The 98th

percentile emissions value, after discarding the invalid data, was determined to be the SO2 BART 

emission limit for Reid Gardner’s units. These BART emission limits allowed for future 

operation within 98 percent of historical emissions (after discard of the invalid data) and 

provided some flexibility under a new post-BART operating scenario including operation under 

a balanced draft versus forced draft scenario due to the installation of fabric filters and a potential 

change in coal type. 

However, in late 2008 and early 2009, fabric filters required by the consent decree described in 

section 6.5.2.2 of this SIP were installed at Reid Gardner upstream of the existing wet soda ash 

FGD, resulting in a new dataset to evaluate the proposed SO2 BART emission limit. NDEP 

conducted further review of NV Energy’s BART analyses and the acid rain dataset. Because the 

acid rain data is not compliance data, Nevada incorporated the recent 40 CFR Part 60 CEMS 

emissions compliance data into the evaluation. These data represent actual operations of the 

fabric filter controls coupled with the existing wet soda ash FGD system and provided the basis 

of the SO2 BART emission limit for all three units at Reid Gardner. 

A comparison of the post-BART annual emissions from the 2001 through 2003 WRAP baseline 

and the NDEP baseline are presented for each facility below. The WRAP calculated baseline 

emissions using the highest 24-hour emissions rate from each unit at each facility for the period 

2001 through 2003. The WRAP emissions rates result in an inflated annual baseline emissions 

scenario because the units did not operate at the highest 24-hour rate consistently for the full 

year. Nevada deems the NDEP baseline annual emissions as more representative of actual 

baseline emissions from each unit at each facility on a per pollutant basis than those of the 

WRAP. The BART control technologies, emissions limit for each unit and the estimated 

emissions reductions upon implementation of BART are presented for each facility below. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-10 
5.5.1 BART at Tracy 

For units 1 and 2, BART for NOx is low NOx burners (LNB) with flue gas recirculation (FGR) 

with emission limits of 0.15 lb/MMBtu and 0.12 lb/MMBtu, based on a 12-month rolling 

average, respectively. For unit 3, BART for NOx is LNB with selective non-catalytic reduction 

(SNCR) with an emission limit of 0.19 lb/MMBtu, based on a 12-month rolling average. For all 

units at Tracy, BART for SO2 is pipeline natural gas (PNG) and/or No. 2 fuel oil with an 

emission limit of 0.05 lb/MMBtu, based on a 24-hour averaging period. For PM10, BART is also 

PNG and/or No. 2 fuel oil, but with an emission limit of 0.03 lb/MMBtu, based on a 3-hour 

averaging period, for all units. 

The emission reductions resulting from the installation of BART control technologies and the 

associated emission limits are shown below. NDEP used the NDEP baseline heat input and 

BART emission limits to calculate the post-BART annual emissions for NOx, SO2 and PM10. 

Table 5-4 shows the annual emission reductions from the WRAP baseline, as well as emission 

reductions from the NDEP baseline. 

TABLE 5-4 

TRACY: BART EMISSIONS REDUCTIONS IN TONS PER YEAR

WRAP NDEP 

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Unit 1 - 55 MW

NOx 1,361 133 1,228 221 133 88

SO2 3 44 -41 1 44 -43

PM10 6 27 -21 34 27 7

Unit 2 - 83 MW 

NOx 1,728 156 1,572 321 156 165

SO2 2,317 65 2,252 2 65 -63

PM10 836 39 797 70 39 31

Unit 3 - 113 MW 

NOx 1,587 521 1,066 795 521 274

SO2 2,720 137 2,583 82 137 -55

PM10 267 82 185 122 82 40

Total NOx 4,676 810 3,866 1,337 810 527

Total SO2 5,040 246 4,794 85 246 -161

Total PM10 1,109 148 961 226 148 78

Note: Negative values reflect annual emissions increases. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-11 
5.5.2 BART at Fort Churchill 

For units 1 and 2 at Ft. Churchill, BART for NOx is LNB with FGR with emission limits of 0.20 

lb/MMBtu and 0.16 lb/MMBtu, based on a 12-month rolling average, respectively. For SO2, 

BART is PNG and/or No. 2 fuel oil for all units with an emission limit of 0.05 lb/MMBtu, based 

on a 24-hour averaging period. For PM10, BART is also PNG and/or No. 2 fuel oil for all units, 

with an emission limit of 0.03 lb/MMBtu, based on a 3-hour averaging period. 

The annual emission reductions resulting from the installation of BART controls and the 

associated emission limits are shown below. NDEP used the NDEP baseline heat input and 

BART emission limits to calculate the post-BART annual emissions for NOx, SO2 and PM10. 

Table 5-5 shows the annual emission reductions from the WRAP baseline, as well as emission 

reductions from the NDEP baseline. 

TABLE 5-5

FORT CHURCHILL: BART EMISSIONS REDUCTIONS IN TONS PER YEAR

WRAP NDEP 

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Unit 1 - 113 MW

NOx 2,509 547 1,962 1,209 547 662

SO2 3,364 137 3,227 8 137 -129

PM10 110 82 28 166 82 84

Unit 2 - 113 MW

NOx 2,405 416 1989 862 416 446

SO2 3,601 130 3,471 11 130 -119

PM10 231 78 153 160 78 82

Total NOx 4,914 963 3,951 2,071 963 1,108

Total SO2 6,965 267 6,698 19 267 -248

Total PM10 341 160 181 326 160 166

Note: Negative values reflect annual emissions increases.

5.5.3 BART at Reid Gardner 

For all units at Reid Gardner, BART controls for NOx are rotating opposed fire air (ROFA) with 

Rotamix with emission limits of 0.20 lb/MMBtu for units 1 and 2, and 0.28 lb/MMBtu for unit 3, 

based on a 12-month rolling average. Rotamix is a technology for adding SNCR using ammonia 

or urea-based reagent. BART controls for SO2 are wet soda ash flue gas desulfurization on all 

units with an emission limit of 0.15 lb/MMBtu, based on a 24-hour averaging period. For PM10, 

BART controls are fabric filter on all units with an emission limit of 0.015 lb/MMBtu, based on 

a 3-hour averaging period. 

The emission reductions resulting from the installation of BART controls and the associated 

emission limits are shown below. NDEP used the NDEP baseline heat input and BART 

emission limits to calculate the post-BART annual emissions for NOx, SO2 and PM10. Table 5-6 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-12 
shows the emission reductions from the WRAP baseline, as well as emission reductions from the 

NDEP baseline. 

TABLE 5-6

REID GARDNER: BART EMISSIONS REDUCTIONS IN TONS PER YEAR

WRAP NDEP 

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Unit 1 - 100 MW

NOx 3,145 982 2,163 2,267 982 1,285

SO2 1,751 736 1015 621 736 -115

PM10 252 74 178 602 74 528

Unit 2 - 100 MW

NOx 3,379 1,050 2,329 2,445 1,050 1,395

SO2 1,490 788 702 398 788 -390

PM10 234 79 155 653 79 574

Unit 3 - 100 MW 

NOx 3,207 1,409 1,798 2,268 1,409 859

SO2 1,734 755 979 422 755 -333

PM10 217 75 142 658 75 583

Total NOx 9,731 3,441 6,290 6,980 3,441 3,539

Total SO2 4,975 2279 2,696 1,441 2,279 -838

Total PM10 703 228 475 1,913 228 1,685

Note: Negative values reflect annual emissions increases.

5.5.4 BART at Mohave 

Mohave is currently in a temporary period of non-operation and will not operate in the future 

without first meeting the requirements specified in the Nevada visibility federal implementation 

plan (FIP) (40 CFR 52.1488). Notably, these requirements are based on the consent decree 

entered into by SCE and the Grand Canyon Trust, the Sierra Club and the National Parks and 

Conservation Association on December 15, 1999. The NDEP was not a party to the consent 

decree. In addition, state regulation requires Mohave to install and operate BART controls prior 

to the time that each unit resumes operation (Appendix A). 

The baseline emissions modeled by the WRAP reflect maximum coal-fired operations at Mohave 

for 2001 through 2003. SCE has proposed a fuel conversion from coal to natural gas as part of 

their BART determination. Despite the fuel conversion to natural gas, the Nevada visibility FIP 

prohibits Mohave from emitting pollutants in amounts greater than that allowed by paragraph (d) 

of 40 CFR 52.1488. SCE’s BART determination proposes that the installation of LNB with 

OFA will meet or exceed the emission reductions specified in the consent decree and the 

requirements of the visibility FIP. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-13 
For units 1 and 2, BART for NOx is LNB with OFA and a fuel conversion to PNG with an 

emission limit of 0.15 lb/MMBtu, on a 12-month rolling average, and a mass emission limit of 

788 lb/hr. For SO2 and PM10, BART is conversion to PNG only with emission limits of 0.0019 

lb/MMBtu, on a 30-day rolling average, and 0.0077 lb/MMBtu, on a 3-hour average, 

respectively. 

The emission reductions resulting from the installation of BART controls and the associated 

emission limits are shown below. NDEP used the NDEP baseline heat input and BART 

emission limits to calculate the post-BART annual emissions for SO2 and PM10. The postcontrol NOx annual emission rates were calculated using an hourly mass emission rate of 788 

lb/hr and applying the annual capacity factor calculated from the acid rain data. Table 5-7 shows 

the emission reductions from the WRAP baseline, as well as emission reductions from the NDEP 

baseline. 

TABLE 5-7

MOHAVE: BART EMISSIONS REDUCTIONS IN TONS PER YEAR

WRAP NDEP 

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Baseline 

Emissions

Emissions after 

BART Controls

Emission 

Reductions

Unit 1 - 790 MW

NOx 16,342 2,457 13,885 10,761 2,457 8,304

SO2 27,852 50 27,802 21,507 50 21,457

PM10 1,564 230 1,361 1,317 230 1,114

Unit 2 - 790 MW 

NOx 15,007 2,423 12,579 10,068 2,423 7,645

SO2 27,195 49 27,146 21,083 49 21,034

PM10 1,853 200 1,653 1,342 200 1,142

Total NOx 31,344 4,880 26,464 20,829 4,880 15,949

Total SO2 55,047 99 54,948 42,590 99 42,491

Total PM10 3,417 403 3,014 2,659 403 2,256

5.5.5 Cumulative Emissions Reductions 

Substantial reductions in NOx, SO2 and PM10 emissions result from the installation of BART 

controls. Post-BART emissions reductions from the WRAP baseline are calculated to be 40,571 

tpy for NOx, 69,136 tpy for SO2 and 4,631 tpy for PM10. Comparatively, post-BART emissions 

reductions from the NDEP baseline, calculated from the reported acid rain data, are 21,123 tpy 

for NOx, 41,244 tpy for SO2 and 4,185 tpy for PM10. Figures 5-2 and 5-3 show cumulative preBART and post-BART emissions for NOx, SO2 and PM10 as calculated from the WRAP and 

NDEP baselines, respectively. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-14 
FIGURE 5-2 

CUMULATIVE PRE-BART AND POST-BART EMISSIONS 

CALCULATED FROM WRAP BASELINE

50665

10094

72027

2891

5570

939

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

Pre-BART Post-BART

Annual E

missions (tpy)

NOx

SO2

PM10

FIGURE 5-3 

CUMULATIVE PRE-BART AND POST-BART EMISSIONS 

CALCULATED FROM NDEP BASELINE

31217

10094

44135

2891 5124

939

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

Pre-BART Post-BART

Annual E

missions (tpy)

NOx

SO2

PM10

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-15 
Table 5-8 compares the emission rates in both lb/MMBtu and tons per year for WRAP’s BART 

exemption modeling, NV Energy’s modeled rates (discussed in the following section) and the 

NDEP BART emission limits. 

TABLE 5-8

COMPARISON OF EXEMPTION MODELING EMISSION RATES, NVENERGYMODELED EMISSION RATES AND BART EMISSION LIMITS

NOx SO2 PM10 NOx SO2 PM10

(lb/106Btu) (lb/106Btu) (lb/106Btu) (tpy) (tpy) (tpy)

Unit 1 0.425 0.001 0.002 1361 3 6

Unit 2 0.393 0.527 0.019 1728 2317 836

Unit 3 0.315 0.540 0.053 1587 2720 267

Unit 1 0.434 0.582 0.019 2509 3364 110

Unit 2 0.416 0.623 0.040 2405 3601 231

Unit 1 0.591 0.329 0.0474 3,145 1,751 252

Unit 2 0.635 0.280 0.044 3,379 1,490 234

Unit 3 0.592 0.320 0.040 3,207 1,734 217

Unit 1 0.40 0.05 0.03 269 34 20

Unit 2 0.40 0.05 0.03 580 73 44

Unit 3 0.40 0.05 0.03 1,169 146 88

Unit 1 0.40 0.05 0.03 1,079 135 81

Unit 2 0.40 0.05 0.03 1,102 138 81

Unit 1 0.46 0.40 0.03 1,962 1,706 128

Unit 2 0.46 0.40 0.03 2,050 1,783 134

Unit 3 0.46 0.40 0.03 2,081 1,810 136

Unit 1 0.15 0.05 0.03 133 44 27

Unit 2 0.12 0.05 0.03 156 65 39

Unit 3 0.19 0.05 0.03 521 137 82

Unit 1 0.20 0.05 0.03 547 137 82

Unit 2 0.16 0.05 0.03 416 130 78

Unit 1 0.20 0.15 0.015 982 736 74

Unit 2 0.20 0.15 0.015 1,050 788 79

Unit 3 0.28 0.15 0.015 1,409 755 75

Fort Churchill

Reid Gardner

WRAP Exemption Modeling Rates

NVEnergy Modeled Rates

NDEP BART Emission Limits

Fort Churchill

Reid Gardner

Tracy

Tracy

Fort Churchill

Reid Gardner

Facility and Unit

Tracy

5.6 VISIBILITY IMPROVEMENT DUE TO BART IMPLEMENTATION 

A comparison of the visibility improvement between pre-BART and post-BART controls at the 

Tracy, Fort Churchill, Reid Gardner and Mohave facilities is presented in Tables 5-9 through 5-

12. These comparisons summarize visibility impacts presented in each facility’s BART 

determination report and indicate future visibility improvement based upon installation of BART 

controls. Nevada anticipates even greater visibility improvement at each Class I area because 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-16 
more stringent final emission limits than those proposed and modeled by NV Energy will be 

implemented at Tracy and Fort Churchill for NOx. Likewise, more stringent emission limits for 

NOx, SO2 and PM10 will be implemented at Reid Gardner. In general, there is a linear 

relationship in CALPUFF modeled visibility and emission rates. The emissions data are 

presented in Table 5-8 above, to provide comparison of the modeled emission rates and BART 

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

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

emissions.

5.6.1 Tracy 

 

Emission reductions due to the installation of BART controls at Tracy result in 82 less days with 

visibility impacts greater than 0.5 dv at Class I areas with 300 km of the facility, as shown in 

Table 5-9. In addition, most Class I areas show a decrease in the 98th percentile dv impact, 

although for some Class I areas the visibility impact remains the same or slightly increases. The 

improvement in visibility impairment resulting from BART controls is significant. However, 

Nevada anticipates even greater visibility improvement than that shown in Table 5-9, as the total 

annual post-control emissions are 50 percent of the modeled emissions. 

TABLE 5-9

TRACY 

PRE-BART AND POST-BART CONTROL MODELED VISIBILITY RESULTS

98th Percentile 

NV Energy 

Baseline 

NV Energy Modeled 

Class I Area Rate Distance 

(km) Unit 

dv days

>0.5 dv 

dv days

>0.5 dv 

1 0.22 1 0.26 1

Desolation 81 2 0.52 11 0.30 2

3 0.57 13 0.33 5

1 0.17 1 0.19 1

Mokelumne 101 2 0.42 5 0.25 1

3 0.44 6 0.28 1

1 0.09 0 0.09 0

Emigrant 139 2 0.23 2 0.13 0

3 0.27 2 0.16 1

1 0.10 0 0.11 0

Hoover 143 2 0.23 1 0.15 0

3 0.25 2 0.18 1

1 0.10 0 0.10 0

Yosemite 153 2 0.23 2 0.14 0

3 0.26 2 0.17 0

Caribou 171 1 0.24 1 0.26 1

2 0.53 9 0.34 3

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-17 
98th Percentile 

NV Energy 

Baseline 

NV Energy Modeled 

Class I Area Rate Distance 

(km) Unit 

dv days

>0.5 dv 

dv days

>0.5 dv 

3 0.51 9 0.36 5

1 0.22 1 0.25 1

Lassen Volcanic 176 2 0.54 8 0.32 2

3 0.45 6 0.28 1

1 0.06 0 0.06 0

Ansel Adams 182 2 0.17 1 0.08 0

3 0.19 1 0.095 0

1 0.18 1 0.19 1

South Warner 190 2 0.44 7 0.25 2

3 0.46 8 0.30 3

1 0.11 0 0.12 0

Thousand Lakes 210 2 0.31 5 0.17 0

3 0.33 6 0.21 1

1 0.07 0 0.07 0

John Muir 221 2 0.19 0 0.09 0

3 0.21 0 0.11 0

1 0.04 0 0.04 0

Kaiser 249 2 0.14 0 0.06 0

3 0.15 0 0.07 0

1 0.06 0 0.06 0

Kings Canyon 265 2 0.18 0 0.09 0

3 0.20 0 0.10 0

1 0.09 0 0.09 0

Lava Beds 286 2 0.22 1 0.12 0

3 0.24 1 0.14 0

1 0.04 0 0.04 0

Yolla Bolly 287 2 0.16 2 0.06 0

3 0.20 2 0.07 0

5.6.2 Fort Churchill 

Emission reductions due to the installation of BART controls at Fort Churchill result in 227 less 

days with visibility impacts greater than 0.5 dv at Class I areas with 300 km of the facility, as 

shown in Table 5-10. In addition, all Class I areas show significant decreases in the 98th

percentile dv impact (e.g., approximately half of the pre-BART value). The improvement in 

visibility impairment resulting from BART controls is significant. However, NDEP anticipates

substantially greater visibility improvement than that shown in Table 5-10, as the total annual 

post-control emissions are 53 percent of those modeled. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-18 
TABLE 5-10

FORT CHURCHILL 

PRE-BART AND POST-BART CONTROL MODELED VISIBILITY RESULTS

98th Percentile 

NV Energy Baseline NV Energy Modeled 

Class I Area Rate Distance 

(km) Unit 

dv days

>0.5 dv 

dv days

>0.5 dv 

1 1.07 41 0.58 14 Mokelumne 79 2 1.08 41 0.58 14

1 1.02 29 0.54 15 Desolation 86 2 1.02 29 0.53 14

1 0.55 13 0.27 1 Hoover 99 2 0.56 13 0.27 1

1 0.57 14 0.27 3 Emigrant 101 2 0.58 15 0.27 3

1 0.48 11 0.24 2 Yosemite 112 2 0.49 11 0.24 2

1 0.32 4 0.14 1 Ansel Adams 133 2 0.33 4 0.14 1

1 0.36 4 0.18 0 John Muir 170 2 0.37 5 0.18 0

1 0.22 1 0.09 0 Kaiser 200 2 0.24 1 0.09 0

1 0.36 5 0.17 0 Kings Canyon 212 2 0.37 5 0.17 0

1 0.48 9 0.25 3 Caribou 227 2 0.50 9 0.26 3

1 0.48 9 0.25 3 Lassen Volcanic 231 2 0.49 9 0.24 3

1 0.62 15 0.35 5 South Warner 246 2 0.62 15 0.35 5

1 0.36 5 0.17 1 Thousand Lakes 266 2 0.37 5 0.17 1

1 0.38 4 0.18 1 Sequoia 274 2 0.39 4 0.18 1

5.6.3 Reid Gardner 

Emission reductions due to the installation of BART controls at Reid Gardner result in only 5 

less days with visibility impacts greater than 0.5 dv at Class I areas with 300 km of the facility, 

as shown in Table 5-11. In addition, most Class I areas show a decrease in the 98th percentile dv 

impact, although for some Class I areas the visibility impact remains the same or slightly 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-19 
increases. However, NDEP anticipates significantly greater visibility improvement than shown 

in Table 5-11, as the total annual post-BART control emissions are 50 percent of those modeled. 

Specifically, the total annual post-BART control NOx emissions are 57 percent of those modeled, 

SO2 is 43 percent and PM10 is 57 percent. 

TABLE 5-11 

REID GARDNER 

PRE-BART AND POST-BART CONTROL MODELED VISIBILITY RESULTS

98th Percentile 

NV Energy Baseline NV Energy 

Class I Area Modeled Rate Distance 

(km) Unit 

dv days

>0.5 dv 

dv days

>0.5 dv 

1 0.85 19 0.83 19

Grand Canyon 86 2 0.86 21 0.73 15

3 0.79 17 0.73 18

1 0.22 3 0.22 2

Zion 148 2 0.22 3 0.19 2

3 0.22 3 0.20 2

1 0.13 0 0.12 0

Bryce Canyon 227 2 0.13 0 0.12 0

3 0.13 0 0.13 0

1 0.06 0 0.06 0

Sycamore Canyon 289 2 0.06 0 0.06 0

3 0.07 0 0.07 0

1 0.32 3 0.33 4

Joshua Tree 292 2 0.32 3 0.32 3

3 0.33 3 0.34 4

5.6.4 Mohave 

Emission reductions due to the installation of BART controls at Mohave result in 538 less days 

with visibility impacts greater than 0.5 dv at Class I areas with 300 km of the facility, as shown 

in Table 5-12. For many of the Class I areas within 300 km of Mohave the number of days with 

visibility impact greater than 0.5 dv has been reduced to zero. In addition, the 98th percentile dv 

impacts are approximately 5 to 15 percent of the pre-BART impacts. The improvement in 

visibility impairment resulting from BART controls is significant. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-20 
TABLE 5-12

MOHAVE 

PRE-BART AND POST-BART CONTROL MODELED VISIBILITY RESULTS

98th Percentile 

SCE Baseline SCE BART Limit Class I Area Distance 

(km) Unit dv days

>0.5 dv 

dv days

>0.5 dv 

1 Grand Canyon 110 2 2.91 194 0.53 8

1 Joshua Tree 137 2 3.96 90 0.76 14

1 Zion 262 2 1.45 80 0.20 0

1 Sycamore Canyon 223 2 1.38 29 0.12 0

1 Agua Tibia 286 2 1.11 19 0.10 0

1 Cucamonga 287 2 1.05 20 0.11 0

1 San Gorgonio 225 2 1.50 27 0.14 1

1 San Jacinto 234 2 1.46 29 0.15 1

1 Mazatal 279 2 0.98 25 0.04 0

1 Pine Mountain 265 2 0.98 23 0.04 0

1 Dome Land 268 2 1.34 26 0.10 0

Significant visibility improvement will be realized in Class I areas within 300 km of Nevada’s 

subject-to-BART sources. Installation of BART controls at Mohave and Reid Gardner result in 

more than 500 fewer days with visibility impact of greater than 0.5 dv to Class I areas in 

southern California, Arizona and Utah. Installation of BART controls at Tracy and Fort 

Churchill result in more than 300 fewer days with visibility impact of greater than 0.5 dv to Class 

I areas in central and northern California. In addition, because NV Energy sources were 

modeled at emission rates greater than those identified as BART by Nevada, greater 

improvement in visibility will be realized than that presented here. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 5-21