from concluding that N D EP 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 compila tions of BART propo sals 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 Comm ent 7 by noting NDEP’s alternative cost an alyses inco rporate NPS’ cost con c erns by reducing N V 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 co mpiling the referenced cost data. However, without
additional d o cum e ntation of these co mpilation s , it is difficult to utilize these data o r to place
them in m e a n ingful context (e.g., Do the costs re present controls identified as BART or only proposed as BART? [see NPS follow-up comm ent to Comm e n t 16]). NDEP is unaware of the
docum entation NPS suggests it has provided as b ackground for the data NPS references in this comment. No changes have been made to Nevada RH SIP as a result of this comm e n t.

NPS follow-up: The BART Guidelines require that NDEP consider th e effects of the techni cally feasible options on visibility. Because there are no “traditional m e as ures of cost effectiveness,” to rely upon in this context, we have suggested t hat $/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 pres ented $/dv values in their BART analyses.) And, if NDEP were to inspect th e info rmation we provided to it recen tly in our compilation of BAR T proposals, it would find that $/dv is being used by many other states
and BART s ources. And, we believe that the $/dv metric inherently addresses the concern expressed by NDEP about its uncer tainty about “how the number and placement of Class I areas with respe c t to the facility may affect the usefulness of $/decivi ew as an effectiveness m e asure”— the calculation of the impact in dv is directly related to the relative locations of the source and
the Class I a r ea, and the cost va lue is complete ly objective an d fits the “tr aditiona l” a pproach
that NDEP desires.

NDEP follow-up response: As NDEP has noted above, Nevada views BART as a case-by-case determ ination, while EPA guidance in Appendix Y directs st ates to use average and increm ental costs to determ ine the
reasonableness of com p l i ance costs. The $/dv m e tric suggested by NPS is an optional cost
effectivenes s m easure that NDEP has chosen not to ut ilize due to its inherent unce r ta inties. It is
clear that other states have sim ilar reservat ions, as noted by Oregon DEQ for the Boardm an Power Plant, which states 12 : “There are se veral different metrics that can be considered when evaluating the cost-benefit relationships of different emission control tec hnolo g i es. A co mm o n l y used m e tric is dollars per ton of pol lution red u ced ($/to n). An other comm o n m e tri c is the incremental cost difference between one control opti on an d a nother. Th e Department believes that the
metric s of dollars per ton and incremental cost differe nces best express the relati ve value of

12 DEP BART R e p o rt for th e Bo ard m an Power Plan t , update d Decem ber 19, 2008, pre p are d by Ore g on Departm e nt

o f

Env i ron m en tal Qu ality, p a g e 2 3 , av ailab l e at http://www.deq.state.or.us/aq/ haze/doc s /deqBa rtReport.pdf

D-77various control options and are m o st co m p arable wit h other decision m a king processe s used by state and federal air quality agenci es to evalua te e m is sion controls for m a jor
industr y

. As discussed in the next section, the Department has also evaluated the am ount of
visibilit y im provement gained in relation to cost in dollars per deciview i m provem e nt ($/dv). Dollar s per deciview can be inform a tive and im portant to consider, how ever this type of m e tri c is not comm only used t o assess the cost effectiven ess of industrial controls
and has m o re inherent uncertainty in ex pressing the full visibility and environm en tal
benefit of an y given o p tio n. This uncertaint y p o tentiall y m a kes this me tric less helpful than $/ton or incremental costs. “

Finally, the NPS com p ilation of BART proposals does not provide context regarding how the
states utilize d these da ta in the i r BART de term ination process (as NDEP discussed in our response to NPS’ follow-up comm ent above). N e vada’s evaluation of $/dv as a cost
ef

f ectivenes s m e tric is p r esented in NDEP’s f o llow-up respo n se to NPS’ f o llow-up comm ent to Comm ent 7.

No changes were m a de to Nevada’s RH SIP as a result of these comm ent s

.

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 comm unity to m odify the Control Cost Manual.
Given the o pportunity, NDEP will review the do cum e ntation regard ing th e changes O AQPS and
NPS m a de t o the Control Cost Manual and the workbook NPS created.

NDEP has c hosen to utilize the control costs derive d by the facilities on a case-by -cas e basis. In addition, NDEP has evaluated the co st concerns expressed by the FLM comm unity in alternative cost analyses, discussed in NDEP’s response to NPS’ follow-up comm ent to Comm e n t 7. No changes were m a de to Nevada’s RH SIP as a result of this comment.

COMMENT 18 (NPS-FWS p.9) NPS follow-u p : NDEP is correct in noting that the EPA BART Guid elines 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 cons ider 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 sim p le insp ectio n of the mod e ling r e sults presented b y NV Energy shows that, by evaluating impacts only at the closest Class I area, N D EP 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 w ould result from any reduc tions in emissions at thee fa cilities.

NDEP follow-up response:
This comm e n t duplicates NPS’ follow-up comments to Comm ent 8 and Comm ent 17. Please see
NDEP’s f o llow-up respo n ses to th ese NPS f o llow-up comm ents.

D-78NPS follow-up: We agree with NDEP that, “In general, ther e is a linear relationship between CALPUFF modeled visibility and emission rates. The vi sibility improvement resulting from BART installation is expected to be proportional to the difference in modele d annual emissions and the
annual NDEP BART emi ssions.” However, if on e inspec ts th e results in NV Energy’s Table 3-2 for NO
x reductions and Table 5-4 for visi bility 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 th e 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 vis i bility 7.5 times as much as a one ton reduction resulting form
LNB+SCR. )

NDEP follow-up response:
This comm e n t duplicates NPS’ follow-up comment to Comm ent 8. Please see NDEP’s followup response to Comm ent 7, above.

COMMENT 19 (NPS-FWS p.8) NPS follow-up: NDEP is correct in noting that the EPA BART Guid elines allow it to “choose not to analyze the other Class I areas any further as ad ditiona l ana lyses migh t be unwarranted.” However, we believe that it is good public policy to at least cons ider 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 sim p le insp ectio n of the mod e ling r e sults presented b y NV Energy shows that, by only evaluating impacts at the closest Class I area, N D EP 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 w ould result from any reduc tions in emissions at thee fa cilities.

NDEP follow-up response:
This comm e n t duplicates NPS’ follow-up commen ts to Comm ents 8, 17 and 18. Please see
NDEP’s f o llow-up respo n ses to th ese NPS f o llow-up comm ents.

COMMENT 20 (NPS-FWS p.9-10): Commen t s on BART determ inat ions for Ft. Churchill, Mohave and Tracy EGUs. NPS follow-up: It appears that NDEP ar rived at its emission ra tes counter to the approach used by NVE in
which NVE estimated th e emission r a te tha t was achievable and then calculated the corresponding reduction efficienci es. Instead, NDEP used the “ar tificially” calculated control efficiencies that resulted from NVE’s emission estimates, and then applied those artificial values
to its esca lated baseline emission and heat input scenarios. A s a result, th e NDEP emi ssion 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.

D-79NDEP follow-up response:
NPS has reached the s a m e conclusion as NDEP regard ing th e determ ination of BART control technology f o r these facilities; see N PS follo w-up response to Comm ent 7. Therefore, no changes were m a de 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 impro vement as a measure of cost effectiveness” as NDEP contends, the NDEP response simply hi ghlights the problems in its approach to improving visibility by focusing on other paramet ers unrelated to visibility improvement. As a result, NDEP has created a BART pr ogram that w ould allow the source that causes the most visibility impairment to spend le ss per unit of visibility impro vement 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 recogn ize the unique situation and impacts of a given source on visibility in the Class I areas that it affects.

NDEP follow-up response: The origin al FLM comment ref e r s to NDEP’s BA RT determ inations f o r Fo rt Church ill, Tracy and Mohave Generating Stations. N PS has reach ed the sam e conclus i ons regard ing th e BART

contro l tech nologies f o r these f acilities, so this co mment has little r e lev a n ce. However, NDEP has determ ined BART on a case-by-case bas i s and does not subscribe to cost benchm arks, especially those based on the us e of $/dv as a cos t effectivenes s m e tric. Nevada has explained our rational for these positions in NDEP’s follo w-up responses to NPS follow-up comm ents as presented above. In addition, NDEP believes NPS has em pha sized visibility im provem e nt in the
BART determ ination process m o re than is supported by the RHR.

NPS’ follow-up comm ent im plies that NDEP has determ ined BART for Reid Gardner without significant cost im plications to the facility. Ne vada notes the capital co st of i m ple m entation of
BART at Re id Gardner is m o re than $20 m illion, n early three tim es the capital cost for any other Nevada facility and the capital cost per unit is nearly twice th at for a ny other Nevada unit.
Modeled v i s i bility im provem ent resulting from BART i m plem entation at each Reid Gardner unit is nearly double the visibility im provem e nt at the closest Class I area for any other N e vada subjec t-to -BART f acility . Ne vada’s implem e ntation of its BART program m a kes reasonable progress toward the nationa l v i sib ility goal.



### NPS Comments on NDEP BA RT Determination Revie w s NDEP prepared BART determ ination reviews of the BART re ports subm itted by NV Energy for their subject-to-BART facilities, as noted in Appendix B of this SIP. N D EP reviews were
conducted f o r the Fort Churchill, Tracy and Reid Gardner Generating Stations 13 . NPS included comments regarding these review docum en ts in their May 20, 2009 letter.

However, since NPS has stated its concurren ce with NDEP’s BART determ inations f o r Fort Churchill and Tracy, NDEP believes that no ch an ges to th is S I P ar e necessary and has therefore not responded to NPS comm ents regarding NDEP’s review docum ents for th ese two facilities. NDEP responds to NPS comments regarding the Re id Gardner review docum e nt below.

13 The re ports a r e available at http://ndep.nv.gov/ baqp /pla nmodeling/rhaze.html

.

D-80Nevada has listed the m a jor sections of the NDEP review report in bold text below, followed by
NPS comme nts in italics. The NDEP responses, in plain text, follow the NPS comm ent s

.

STEP 1 – I d entify all available ret rofit emissions control techniques
NPS: NDEP evaluated a reasonable sp ectrum of control options.

NDEP response: Nevada concurs. No changes were m a de to Neva da’s RH SIP as a result of this comm ent.

STEP 2 – Eliminate techni cally inf e asible opt i ons NPS: While we agree with the basic premise that upgrading the exis ting scrubbers is the most practical approach and no analysis of other is therefore necessary, that is only true if the BART emission limit repr esen ts th e 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 SO 2 removal or less than 0.15 lb/mmBtu, while a new w e t lime/limestone scrubber installati on would have similar removal effic iency. Essentially the same level of SO 2 reduction can be achieved through scrubber upgrades and new wet scrubber installation. Therefore, the new we t lime/limestone scrubber option is eliminated because little additional scrubber capital or oper ating cost is require d by improving the current wet soda ash scrubber.”)

NDEP response: The existing wet soda as h FGD system arguably represen ts th e m o st effective SO 2 control technology available and has historically achieved SO 2 rem o val rates as high as 95 percent. Only a new wet lim e/lim estone sc rub b er has s i m ilar control ef f i ciencies. NDEP did not consid er a new scrubber during the BART de term ination fo r the sim p le reason that it doesn’t m a ke sense to spend cap ita l rep l ac in g an exis ting system with a new system that has essentially equal control perform a nce.

This NPS comment then becom e s a question of the SO 2 em ission lim it, which Nevada has addressed in NDEP’s responses to U S EPA Comm ent 2 and NPS follow- up comments to Comm ent 9 and 10 in Appendix D.2. Please se e NDEP’s response to USEPA comm e n t 2, which identifies where chang e s were m a de to the SIP as a resu lt of comments on the SO 2 BART

em ission lim it for Reid Gardner.

STEP 3 – Evaluate con t rol effectiv eness of remaining co ntrol option s NPS: This is a misleading statement. NVE estimated the emission rate that could be achieved by each control technology option. Instead, N D EP used the “a rtificially” calculated control efficiencies that resulted from NVE’s emi ssion estimates, and then applied t hose artificial values to its
escalated baseline emission and heat input scenarios.

D-81For example, for the LN B with Selective Ca talytic Reduction (SCR ) option, NDEP as sumed 0.083 – 0.098 lb/mmBtu. However, NVE estimated that it could achieve 0. 07 lb/mmBtu. EPA Clean Air Markets (CAM) data (A ppendix A) and vendor guarantees 2 show that SCR can typically meet 0.05 lb/mmBtu on an annual a verage basis. N e ither NVE nor NDEP have provided any documentation or just ification to support the higher va lues used in their analyses. (Footnote 2. Minnesota Power has st ated in its Taconite Harbor BART a nalysis that “The use of an SCR is expected to achieve a NO
x emission ra te of 0.05 lb/mmBtu based on recent emission guarantees offered by SCR system suppliers.”)

NDEP response: Nevada evaluated the influence of the em issi on rate in the B A RT determination process by conducting alternative cost analyses for Reid Ga rdner as described in NDEP’s response to NPS follow-up to Comm ent 7 above. No changes were m a de to Nevada’s RH SIP as a result of this

comment.

STEP 4 – I m pact analysis
NPS: NVE has overestimated the cost of SC R. 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 ju stifica tion o r documenta ti on for it co st estimates. As a result, the NDEP estimates for SCR at RGGS equate to capital co sts 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 determ ination process by conducting alternative cost analyses for Reid-Gardner as d e scribed in NDEP’s response to NPS follow-up to
Comm ent 7 above. No changes were m a de to Neva da’s RH SIP as a result of this com m e nt.

STEP 5 – Determine visibility imp a cts
NPS:
NDEP shoul d have continued the five-step analysis by evaluating the visibility benefits of at least
the more-s tr ingent techn i cally- feasib le control options that it reject ed. Furthermore, RGGS’ impacts at G r and Canyon represent only 49% of its cumulative impact on the five Class I areas modeled. By focusing on only the Grand Canyon Cl ass I area, NDEP ignore d the impacts at the other four C l ass 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 Comm ents 8, 17, 18 and 19. No changes were m a de to Nevada’s RH SIP as a result of this

comment.

D-82NDEP Anal ysis
NPS: We believe that a proper considera t ion of the co s t -effec t iveness of reducin g NO
x to improve visibility (e.g., $/dv) would le ad to the conclusion that LNB+ SCR with an emission level at 0.05 lb/mmBtu (annual average) is BART. 3 (Footnote 3. Because visibi lity is a short- term Air Quality Re la ted Value, w e recommend that sta t es set corr espo nding 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/m mBtu 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
visib i lity in the five Class I areas imp a cted by RG GS are less than $4 million/dv for ea ch unit, which is well below the $10 - $17 million /dv means for BART proposals nationwide, 4 (Footnote 4. Our compilations of BART propo sals can be found at http://www.wrapair.org/forums/ssjf/bart.html) a nd even below the $9.8 million/dv that NDEP
determined was reasonable to reduce NO
x at TGS #3.

We used EP A’s OAQPS Control Cost Manual (a s recommended by the BA RT 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 t hat NDEP determined was reasonable at TGS #1 for LNB+FGR. (Our analyses are contai ned in Appendix C.)

We used NVE’s modeling results to derive estimates of vis i bility improvement that w ould result from our greater annual emissions reductions and tr anslated that to cost-e ffectiveness values of $1.8 - $2.5 million /

dv at Grand Canyon and $0.9 - $1.2 m illion/dv acros s 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 ar eas modeled

. RGGS #2 $2.1 million /

d

v at Grand Canyon and $1.0
million /

dv a c ross the five Class I areas mode led. RGGS #3 $1.8 million /

dv at Grand Canyon and $0.9 million /

dv across th e five Class I areas mod e led.) The benefits of improving visibility in Grand Canyon NP and the other four Class I area s impacted by RGGS ar e well below the $10 - $17 million /dv means fo r BART proposals natio nwide, 6 (Footnote 6. Our compilations of BART propo sals can be found at http://www.wr apair.org/forums/ssjf/bart.html) and even below the $9.8 million/dv that NDEP determined was reasonable to reduce NO
x at TGS #3.

NDEP response: Nevada con s iders the B A RT process a case

- by-case determ ination of the costs and benefits of visibility im provem e nt. Visibility improvem e nt is only one of the five factors states must
consider in the BART de term ination process, although NPS s eem s to indicate visibility should drive the pro cess. Since BART is a case-by- case determ ination, Nevada has not considered
benchm arks in our BART determ inations, as suggested by N PS. Because of the inherent uncertainty of $/dv as a cost effectiv eness m easur e, Nevada does not subscribe to its use in the BART proc ess and certainly not as a cost-effectiveness benchm ark. NDEP has m o re thoroughly
discussed these issues in our responses above.

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

NPS:

D-83It is not clear how NDEP arrived a t emission limits 8 (Footnote 8. Because BART is an emission limit, s i mply specifying the contro l technology with the expectati on tha t it will per f

orm to the fullest of its capabilities is not adequate.) that are more t han six times higher than the 2007 annual average SO 2 emission rates (0.035 – 0.039 lb/mmBtu) fo r these units. Acco rding to NVE:

It

i s p r oj ect ed t

hat t

h e ope rat i on of t

h e prese n t w e t so d a as h F G D syst e m may be i m pr

ov ed as a

resu lt o f

t

h e f a b r ic filter in stalla tio n

. Ho wever, even with i n cremen t a l imp r ovemen ts, mi n i ma l

a d

d itio na l impro v emen t t o the cu rren t lo w SO 2 emission le vel can be c ons istently expected fr om

u p g r a d es to the existin g wet so da a s h scrub b er. On ly scrubb er up g r ad es an d n e w lime/limeston e wet scrubber technology options c a n equal or excee d t h e remov a l efficiency of the c u rre nt wet

so da a s h scrubb er. Therefo r e, on ly th ese two a lte rna tives a r e con s id ered tech n i ca lly fea s i b le fo r
pur p o ses of t

h i s a nal ysi s

... W h en eval uati n g the c ontr o l effectiveness of SO 2 reduct i o n

t echn o l o gi es, e a ch o p t i o n c a n be c o mp are d ag ai n s t be nc h m ark s of pe rf o r

ma nce

. T h e pr oj ect ed

em ission ra te f o r a n upg ra d e d wet so da a s h FGD system f o r Rei d G a rdner 1 [a s well as 2 an d 3 ]
is 95 p e rcen t SO 2 remo va l o r less th an 0

. 15 l b /MMBtu, wh il e a n e w wet li me/limeston e scrub b e r in sta lla tion w o u l d ha ve si milar remo va l efficien cy. NDEP shoul d provide m o re information concerning its statistical analysis and explain in detail the fac t ors 9 (Footnote 9. uncertainties in future coal s upply for this facility and changes in boiler operation from the current pressurized operation to balanced draft operation, as well as the
Clean Air A c t factors o f

expected emission ra tes, emissions perfor mance levels, expected emissions reductions, costs of compliance, en ergy 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 comm ent 2, which responds to a sim ilar comment and identifies where chang e s were m a de to the SIP as a resu lt of comments on the SO 2 BART

em ission lim it f o r Reid Gar dner, including lowering the SO 2 BART e m i ssion lim it to 0.15
lb/MMBtu f r om 0.25 lb/MMBtu.

NPS:
NDEP shoul d 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 instal led upstream of the wet soda ash scrubbers and so will not capture any particulates generated by the scrubbers. The guaranteed filterable particula t e e m issions f r om the f a bric f ilter ar e 0.0 15 lb/MMBtu. In additio n, insta lla tio n of
fabric filter at Reid-Gardner is a retrofit, unlike Toquop and Ely wh ere fabric filter is a design

com ponent of the air pollution control system

.

D-84

### SECTION D.2.2.4

CONS ORTIUM OF CONSE RVAT I ON ORGANIZ A T I ONS

D-85D-862.2.4 Consortium of Conservation Organi z a tions (NGOs)
2.2.4.1 Comment Letter

D-87D-88D-89D-90D-91D-92