from concluding that NDEP should re-evaluate what constitutes reasonable average cost 

effectiveness. We would be pleased to share any additional information we have, if NDEP wishes 

to pursue this. (Footnote 5: Our compilations of BART proposals can be found at 

http://www.wrapair.org/forums/ssjf/bart.html)

NDEP follow-up response:

Nevada has addressed this cost issue in NDEP’s response to NPS follow-up comments to 

Comment 7 by noting NDEP’s alternative cost analyses incorporate NPS’ cost concerns by 

reducing NV Energy costs by 30 percent, as well as EPA guidance that BART determinations are 

conducted on a case-by-case basis. 

NDEP appreciates NPS’ effort in compiling the referenced cost data. However, without 

additional documentation of these compilations, it is difficult to utilize these data or to place 

them in meaningful context (e.g., Do the costs represent controls identified as BART or only 

proposed as BART? [see NPS follow-up comment to Comment 16]). NDEP is unaware of the 

documentation NPS suggests it has provided as background for the data NPS references in this 

comment. No changes have been made to Nevada RH SIP as a result of this comment. 

NPS follow-up: 

The BART Guidelines require that NDEP consider the effects of the technically feasible options 

on visibility. Because there are no “traditional measures of cost effectiveness,” to rely upon in 

this context, we have suggested that $/dv can be a useful metric in doing so. (It appears that NV 

Energy and NDEP must also find some value to this metric, as they both presented $/dv values in 

their BART analyses.) And, if NDEP were to inspect the information we provided to it recently in 

our compilation of BART proposals, it would find that $/dv is being used by many other states 

and BART sources. And, we believe that the $/dv metric inherently addresses the concern 

expressed by NDEP about its uncertainty about “how the number and placement of Class I areas 

with respect to the facility may affect the usefulness of $/deciview as an effectiveness measure”—

the calculation of the impact in dv is directly related to the relative locations of the source and 

the Class I area, and the cost value is completely objective and fits the “traditional” approach 

that NDEP desires. 

NDEP follow-up response:

As NDEP has noted above, Nevada views BART as a case-by-case determination, while EPA 

guidance in Appendix Y directs states to use average and incremental costs to determine the 

reasonableness of compliance costs. The $/dv metric suggested by NPS is an optional cost 

effectiveness measure that NDEP has chosen not to utilize due to its inherent uncertainties. It is 

clear that other states have similar reservations, as noted by Oregon DEQ for the Boardman 

Power Plant, which states12: 

“There are several different metrics that can be considered when evaluating the cost-benefit 

relationships of different emission control technologies. A commonly used metric is dollars 

per ton of pollution reduced ($/ton). Another common metric is the incremental cost 

difference between one control option and another. The Department believes that the 

metrics of dollars per ton and incremental cost differences best express the relative value of 

 

12 DEP BART Report for the Boardman Power Plant, updated December 19, 2008, prepared by Oregon Department 

of Environmental Quality, page 23, available at http://www.deq.state.or.us/aq/haze/docs/deqBartReport.pdf

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various control options and are most comparable with other decision making processes 

used by state and federal air quality agencies to evaluate emission controls for major 

industry. As discussed in the next section, the Department has also evaluated the amount of 

visibility improvement gained in relation to cost in dollars per deciview improvement 

($/dv). Dollars per deciview can be informative and important to consider, however this 

type of metric is not commonly used to assess the cost effectiveness of industrial controls 

and has more inherent uncertainty in expressing the full visibility and environmental 

benefit of any given option. This uncertainty potentially makes this metric less helpful than 

$/ton or incremental costs. “ 

Finally, the NPS compilation of BART proposals does not provide context regarding how the 

states utilized these data in their BART determination process (as NDEP discussed in our 

response to NPS’ follow-up comment above). Nevada’s evaluation of $/dv as a cost 

effectiveness metric is presented in NDEP’s follow-up response to NPS’ follow-up comment to 

Comment 7. 

No changes were made to Nevada’s RH SIP as a result of these comments. 

NPS follow-up: 

We suggest that NDEP reconsider its position in view of our discussion of the OAQPS Control 

Cost manual and the workbook we created base upon that document.

NDEP follow-up response:

Nevada appreciates the efforts by the FLM community to modify the Control Cost Manual. 

Given the opportunity, NDEP will review the documentation regarding the changes OAQPS and 

NPS made to the Control Cost Manual and the workbook NPS created. 

NDEP has chosen to utilize the control costs derived by the facilities on a case-by-case basis. In 

addition, NDEP has evaluated the cost concerns expressed by the FLM community in alternative 

cost analyses, discussed in NDEP’s response to NPS’ follow-up comment to Comment 7. No 

changes were made to Nevada’s RH SIP as a result of this comment. 

COMMENT 18 (NPS-FWS p.9) NPS follow-up: 

NDEP is correct in noting that the EPA BART Guidelines allow it to “choose not to analyze the 

other Class I areas any further as additional analyses might be unwarranted.” However, we 

believe that it is good public policy to at least consider the consequences of that choice. If the 

other Class I areas were so distant as to be essentially unaffected, NDEP’s choice could be 

justified. However, a simple inspection of the modeling results presented by NV Energy shows 

that, by evaluating impacts only at the closest Class I area, NDEP has ignored from 50% to 90% 

of the cumulative impacts at the Class I areas for which results are presented. Thus, NDEP has 

also ignored 50% to 90% of the benefits that would result from any reductions in emissions at 

thee facilities. 

NDEP follow-up response:

This comment duplicates NPS’ follow-up comments to Comment 8 and Comment 17. Please see 

NDEP’s follow-up responses to these NPS follow-up comments. 

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NPS follow-up: 

We agree with NDEP that, “In general, there is a linear relationship between CALPUFF 

modeled visibility and emission rates. The visibility improvement resulting from BART 

installation is expected to be proportional to the difference in modeled annual emissions and the 

annual NDEP BART emissions.” However, if one inspects the results in NV Energy’s Table 3-2 

for NOx reductions and Table 5-4 for visibility improvement, it can be seen that, if, for example, 

a 95 ton per year reduction due to LNBw/OFA at Reid Gardner #3 produces an improvement of 

0.407 dv at Grand Canyon, then a reduction of 1,136 tons per year after application of LNB 

w/OFA+SCR should produce more than the 0.652 dv improvement presented by NV Energy.6

 If 

NDEP is to use the NV Energy data, it must insure that the data is valid and that it is properly 

presented and interpreted. It is apparent that the NVE data that NDEP is using requires further 

explanation, at the very least. (Footnote 6: Similar inconsistencies can be found throughout the 

Reid Gardner analyses. For example, the NVE model results indicate that a one ton/yr reduction 

by LNB will improve visibility 7.5 times as much as a one ton reduction resulting form 

LNB+SCR.)

NDEP follow-up response:

This comment duplicates NPS’ follow-up comment to Comment 8. Please see NDEP’s followup response to Comment 7, above. 

COMMENT 19 (NPS-FWS p.8) NPS follow-up: 

NDEP is correct in noting that the EPA BART Guidelines allow it to “choose not to analyze the 

other Class I areas any further as additional analyses might be unwarranted.” However, we 

believe that it is good public policy to at least consider the consequences of that choice. If the 

other Class I areas were so distant as to be essentially unaffected, NDEP’s choice could be 

justified. However, a simple inspection of the modeling results presented by NV Energy shows 

that, by only evaluating impacts at the closest Class I area, NDEP has ignored from 50% to 90% 

of the cumulative impacts at the Class I areas for which results are presented. Thus, NDEP has 

also ignored 50% to 90% of the benefits that would result from any reductions in emissions at 

thee facilities. 

NDEP follow-up response:

This comment duplicates NPS’ follow-up comments to Comments 8, 17 and 18. Please see 

NDEP’s follow-up responses to these NPS follow-up comments. 

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

Mohave and Tracy EGUs. NPS follow-up: 

It appears that NDEP arrived at its emission rates counter to the approach used by NVE in 

which NVE estimated the emission rate that was achievable and then calculated the 

corresponding reduction efficiencies. Instead, NDEP used the “artificially” calculated control 

efficiencies that resulted from NVE’s emission estimates, and then applied those artificial values 

to its escalated baseline emission and heat input scenarios. As a result, the NDEP emission rates 

are often higher than the rates presented by NVE. We agree with NVE’s approach and it is the 

approach taken by the overwhelming majority of BART sources across the nation. 

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NDEP follow-up response:

NPS has reached the same conclusion as NDEP regarding the determination of BART control 

technology for these facilities; see NPS follow-up response to Comment 7. Therefore, no 

changes were made to Nevada’s RH SIP as a result of this comment. 

COMMENT 21 (NPS-FWS p. 10) NPS follow-up: 

Instead of showing “problems with the $/dv improvement as a measure of cost effectiveness” as 

NDEP contends, the NDEP response simply highlights the problems in its approach to 

improving visibility by focusing on other parameters unrelated to visibility improvement. As a 

result, NDEP has created a BART program that would allow the source that causes the most 

visibility impairment to spend less per unit of visibility improvement than a source that causes 

far less impairment. We believe that placing more weight on $/dv provides a clear and objective 

way to produce BART determinations that recognize the unique situation and impacts of a given 

source on visibility in the Class I areas that it affects. 

NDEP follow-up response:

The original FLM comment refers to NDEP’s BART determinations for Fort Churchill, Tracy 

and Mohave Generating Stations. NPS has reached the same conclusions regarding the BART 

control technologies for these facilities, so this comment has little relevance. However, NDEP 

has determined BART on a case-by-case basis and does not subscribe to cost benchmarks, 

especially those based on the use of $/dv as a cost effectiveness metric. Nevada has explained 

our rational for these positions in NDEP’s follow-up responses to NPS follow-up comments as 

presented above. In addition, NDEP believes NPS has emphasized visibility improvement in the 

BART determination process more than is supported by the RHR. 

NPS’ follow-up comment implies that NDEP has determined BART for Reid Gardner without 

significant cost implications to the facility. Nevada notes the capital cost of implementation of 

BART at Reid Gardner is more than $20 million, nearly three times the capital cost for any other 

Nevada facility and the capital cost per unit is nearly twice that for any other Nevada unit. 

Modeled visibility improvement resulting from BART implementation at each Reid Gardner unit 

is nearly double the visibility improvement at the closest Class I area for any other Nevada 

subject-to-BART facility. Nevada’s implementation of its BART program makes reasonable 

progress toward the national visibility goal. 

NPS Comments on NDEP BART Determination Reviews

NDEP prepared BART determination reviews of the BART reports submitted by NV Energy for 

their subject-to-BART facilities, as noted in Appendix B of this SIP. NDEP reviews were 

conducted for the Fort Churchill, Tracy and Reid Gardner Generating Stations13. NPS included 

comments regarding these review documents in their May 20, 2009 letter. 

However, since NPS has stated its concurrence with NDEP’s BART determinations for Fort 

Churchill and Tracy, NDEP believes that no changes to this SIP are necessary and has therefore 

not responded to NPS comments regarding NDEP’s review documents for these two facilities. 

NDEP responds to NPS comments regarding the Reid Gardner review document below. 

 

13 The reports are available at http://ndep.nv.gov/baqp/planmodeling/rhaze.html. 

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Nevada has listed the major sections of the NDEP review report in bold text below, followed by 

NPS comments in italics. The NDEP responses, in plain text, follow the NPS comments. 

STEP 1 – Identify all available retrofit emissions control techniques 

NPS: 

NDEP evaluated a reasonable spectrum of control options. 

NDEP response:

Nevada concurs. No changes were made to Nevada’s RH SIP as a result of this comment. 

STEP 2 – Eliminate technically infeasible options 

NPS: 

While we agree with the basic premise that upgrading the existing scrubbers is the most 

practical approach and no analysis of other is therefore necessary, that is only true if the BART 

emission limit represents the 95% reduction capability of the control strategy.1

 (Footnote 1. 

According to NVE, “The projected emission rate for an upgraded wet soda ash FGD system for 

Reid Gardner 1 is 95 percent SO2 removal or less than 0.15 lb/mmBtu, while a new wet 

lime/limestone scrubber installation would have similar removal efficiency. Essentially the same 

level of SO2 reduction can be achieved through scrubber upgrades and new wet scrubber 

installation. Therefore, the new wet lime/limestone scrubber option is eliminated because little 

additional scrubber capital or operating cost is required by improving the current wet soda ash 

scrubber.”)

NDEP response:

The existing wet soda ash FGD system arguably represents the most effective SO2 control 

technology available and has historically achieved SO2 removal rates as high as 95 percent. 

Only a new wet lime/limestone scrubber has similar control efficiencies. NDEP did not consider 

a new scrubber during the BART determination for the simple reason that it doesn’t make sense 

to spend capital replacing an existing system with a new system that has essentially equal control 

performance. 

This NPS comment then becomes a question of the SO2 emission limit, which Nevada has 

addressed in NDEP’s responses to USEPA Comment 2 and NPS follow-up comments to 

Comment 9 and 10 in Appendix D.2. Please see NDEP’s response to USEPA comment 2, which 

identifies where changes were made to the SIP as a result of comments on the SO2 BART 

emission limit for Reid Gardner. 

STEP 3 – Evaluate control effectiveness of remaining control options 

NPS: 

This is a misleading statement. NVE estimated the emission rate that could be achieved by each 

control technology option. Instead, NDEP used the “artificially” calculated control efficiencies 

that resulted from NVE’s emission estimates, and then applied those artificial values to its 

escalated baseline emission and heat input scenarios.

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For example, for the LNB with Selective Catalytic Reduction (SCR) option, NDEP assumed 

0.083 – 0.098 lb/mmBtu. However, NVE estimated that it could achieve 0.07 lb/mmBtu. EPA 

Clean Air Markets (CAM) data (Appendix A) and vendor guarantees2

 show that SCR can 

typically meet 0.05 lb/mmBtu on an annual average basis. Neither NVE nor NDEP have 

provided any documentation or justification to support the higher values used in their analyses. 

(Footnote 2. Minnesota Power has stated in its Taconite Harbor BART analysis that “The use of 

an SCR is expected to achieve a NOx emission rate of 0.05 lb/mmBtu based on recent emission 

guarantees offered by SCR system suppliers.”)

NDEP response:

Nevada evaluated the influence of the emission rate in the BART determination process by 

conducting alternative cost analyses for Reid Gardner as described in NDEP’s response to NPS 

follow-up to Comment 7 above. No changes were made to Nevada’s RH SIP as a result of this 

comment. 

STEP 4 – Impact analysis 

NPS: 

NVE has overestimated the cost of SCR. The BART guidelines advise that: 

The basis for equipment cost estimates also should be documented, either with 

data supplied by an equipment vendor (i.e., budget estimates or bids) or by a 

referenced source (such as the OAQPS Control Cost Manual, Fifth Edition, 

February 1996, EPA 453/B-96-001). In order to maintain and improve 

consistency, cost estimates should be based on the OAQPS Control Cost Manual, 

where possible. 

NVE failed to provide justification or documentation for it cost estimates. As a result, the NDEP 

estimates for SCR at RGGS equate to capital costs of $350/kW for units #1 - #3, compared to the 

$50 - $267/kW typical cost of SCR found in survey data (Appendix B).

NDEP response:

Nevada evaluated the influence of cost in the BART determination process by conducting 

alternative cost analyses for Reid-Gardner as described in NDEP’s response to NPS follow-up to 

Comment 7 above. No changes were made to Nevada’s RH SIP as a result of this comment. 

STEP 5 – Determine visibility impacts

NPS: 

NDEP should have continued the five-step analysis by evaluating the visibility benefits of at least 

the more-stringent technically-feasible control options that it rejected. Furthermore, RGGS’ 

impacts at Grand Canyon represent only 49% of its cumulative impact on the five Class I areas 

modeled. By focusing on only the Grand Canyon Class I area, NDEP ignored the impacts at the 

other four Class I areas affected by this facility.

NDEP response:

Nevada discusses the evaluation of the visibility benefits in NDEP’s response to NPS follow-up 

to Comments 8, 17, 18 and 19. No changes were made to Nevada’s RH SIP as a result of this 

comment. 

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NDEP Analysis 

NPS: 

We believe that a proper consideration of the cost-effectiveness of reducing NOx to improve 

visibility (e.g., $/dv) would lead to the conclusion that LNB+SCR with an emission level at 0.05 

lb/mmBtu (annual average) is BART.3

 (Footnote 3. Because visibility is a short-term Air 

Quality Related Value, we recommend that states set corresponding short-term limits. For 

example, our data suggests that an annual average emission rate of 0.05 lb/mmBtu equates to a 

30-day rolling average of 0.06 lb/mmBtu and a 24-hour block average rate of 0.07 lb/mmBtu.) 

Even if we use NDEP’s cost estimates and modeling results, the cumulative benefits of improving 

visibility in the five Class I areas impacted by RGGS are less than $4 million/dv for each unit, 

which is well below the $10 - $17 million /dv means for BART proposals nationwide,4

 (Footnote 

4. Our compilations of BART proposals can be found at 

http://www.wrapair.org/forums/ssjf/bart.html) and even below the $9.8 million/dv that NDEP 

determined was reasonable to reduce NOx at TGS #3. 

We used EPA’s OAQPS Control Cost Manual (as recommended by the BART Guidelines) to 

estimate cost-effectiveness values of $1,570/ton for RGGS #1, $1,346/ton for RGGS #2, and 

$1,660/ton for RGGS #3 which are significantly less than the $3,050/ton that NDEP determined 

was reasonable at TGS #1 for LNB+FGR. (Our analyses are contained in Appendix C.)

We used NVE’s modeling results to derive estimates of visibility improvement that would result 

from our greater annual emissions reductions and translated that to cost-effectiveness values of 

$1.8 - $2.5 million/dv at Grand Canyon and $0.9 - $1.2 million/dv across the five Class I areas 

modeled.5

 (Footnote 5. RGGS #1 @ $2.5 million/dv at Grand Canyon and $1.2 million/dv 

across the five Class I areas modeled. RGGS #2 $2.1 million/dv at Grand Canyon and $1.0 

million/dv across the five Class I areas modeled. RGGS #3 $1.8 million/dv at Grand Canyon and 

$0.9 million/dv across the five Class I areas modeled.) The benefits of improving visibility in 

Grand Canyon NP and the other four Class I areas impacted by RGGS are well below the $10 - 

$17 million /dv means for BART proposals nationwide,6

 (Footnote 6. Our compilations of 

BART proposals can be found at http://www.wrapair.org/forums/ssjf/bart.html) and even below 

the $9.8 million/dv that NDEP determined was reasonable to reduce NOx at TGS #3. 

NDEP response:

Nevada considers the BART process a case-by-case determination of the costs and benefits of 

visibility improvement. Visibility improvement is only one of the five factors states must 

consider in the BART determination process, although NPS seems to indicate visibility should 

drive the process. Since BART is a case-by-case determination, Nevada has not considered 

benchmarks in our BART determinations, as suggested by NPS. Because of the inherent 

uncertainty of $/dv as a cost effectiveness measure, Nevada does not subscribe to its use in the 

BART process and certainly not as a cost-effectiveness benchmark. NDEP has more thoroughly 

discussed these issues in our responses above. 

No changes were made to Nevada’s RH SIP as a result of this comment. 

NPS: 

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It is not clear how NDEP arrived at emission limits8

 (Footnote 8. Because BART is an emission 

limit, simply specifying the control technology with the expectation that it will perform to the 

fullest of its capabilities is not adequate.) that are more than six times higher than the 2007 

annual average SO2 emission rates (0.035 – 0.039 lb/mmBtu) for these units. According to NVE: 

It is projected that the operation of the present wet soda ash FGD system may be improved as a 

result of the fabric filter installation. However, even with incremental improvements, minimal 

additional improvement to the current low SO2 emission level can be consistently expected from 

upgrades to the existing wet soda ash scrubber. Only scrubber upgrades and new lime/limestone

wet scrubber technology options can equal or exceed the removal efficiency of the current wet 

soda ash scrubber. Therefore, only these two alternatives are considered technically feasible for 

purposes of this analysis... When evaluating the control effectiveness of SO2 reduction 

technologies, each option can be compared against benchmarks of performance. The projected 

emission rate for an upgraded wet soda ash FGD system for Reid Gardner 1 [as well as 2 and 3]

is 95 percent SO2 removal or less than 0.15 lb/MMBtu, while a new wet lime/limestone scrubber 

installation would have similar removal efficiency. 

NDEP should provide more information concerning its statistical analysis and explain in detail 

the factors

9

 (Footnote 9. uncertainties in future coal supply for this facility and changes in boiler 

operation from the current pressurized operation to balanced draft operation, as well as the 

Clean Air Act factors of expected emission rates, emissions performance levels, expected 

emissions reductions, costs of compliance, energy impacts, non-air quality environmental 

impacts and modeled visibility impacts) it used to arrive at its proposed BART limit.

NDEP response:

Please see NDEP’s response to USEPA comment 2, which responds to a similar comment and 

identifies where changes were made to the SIP as a result of comments on the SO2 BART 

emission limit for Reid Gardner, including lowering the SO2 BART emission limit to 0.15 

lb/MMBtu from 0.25 lb/MMBtu. 

NPS: 

NDEP should explain why the new fabric filters at RGGS cannot achieve the same 0.010 

lb/mmBtu rate it proposed in the Toquop and Ely draft permits. 

NDEP response:

The fabric filters at Reid Gardner will be installed upstream of the wet soda ash scrubbers and so 

will not capture any particulates generated by the scrubbers. The guaranteed filterable 

particulate emissions from the fabric filter are 0.015 lb/MMBtu. In addition, installation of

fabric filter at Reid-Gardner is a retrofit, unlike Toquop and Ely where fabric filter is a design 

component of the air pollution control system. 

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SECTION D.2.2.4 

CONSORTIUM OF CONSERVATION ORGANIZATIONS 

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2.2.4 Consortium of Conservation Organizations (NGOs) 

 2.2.4.1 Comment Letter 

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