ordinance th at would req u ire a public vote to ap p r ove any Condition a l Us e Perm it issued for the project.

Sevier is closest to Ca pitol Reef Nationa l Park and o t her Class I areas in Utah and appears to be m o re than 300 km from the Jarb idge W ilderness in Nevada. As such, it probably falls outside the d i stan ce at which ad verse im pacts t o vi s i bi l ity a t Ja r b i d ge c oul d be expe c t e d a n d probably do es not need to be consid ered in Nev a da’s Regio n al Haze SIP. However, this pro j ect

m a y contrib u te to the cum u lative visibility imp acts at Class I areas in south w estern Utah, including Bryce Canyon and Zion National Parks.

3.1.6 Intermoun t ain Pow er Project Unit 3 (UT)

The Interm ountain Power Project (IPP) is owned and operated by the Los Angeles Departm e nt of W a ter and Power ( L ADWP) a nd P acifiCorp. IPP has two existing coal-fired EGUs sized at 900 MW each at a site near Delt a, UT. A third 900 M W c o al-fired EGU has been proposed for this site, which is a bout 300 km distant from Jarbidge.

A f i nal air quality per m it f o r Unit 3 was issued by UDAQ, but this perm it was then appealed by the Sierra Club and Grand Canyon Trust. Then, in 2007, the six California cities that take the m a jority of IPP’s power refused to suppo rt construction of a thir d coal-fired EGU. Also, PacifiCorp form ally announced cancellation of Unit 3 in D ecem ber 2007. However, in January 2008, the Utah Associated Municip a l Power Syst em (UAMPS), a group of 23 Utah comm unities and six electric cooperatives that pledged to purchase 50% of the pow er generated by Unit 3, sued to force LADWP to proceed w ith th e plan to construct Unit 3.

As of May 2009, the final PSD perm it for I PP Unit 3 has not been term inated by UDAQ nor has the air perm it applica tion been withdrawn by the propone nt. In fact, in April 2008, the Utah Departm e nt of Environm ental Quality (UDAQ) granted an extension of the IPP Unit 3 air quality perm it to October 15, 2009 [ Reference 11 ]. The IPP Unit 3 em issions are estim a ted at 3,183 tpy for both SO 2 and NO x [ Ref e rence 12 ].

Because the IPP Unit 3 perm it rem a ins active, these emissions need to be part of Nevada’s SIP planning process. However, as IPP Unit 3 is part of the 2018 WRAP inventory, these em issions were already included in Nevada’s reg i onal h aze SIP.

3.1.7 Pow er County Advanced Energy Center (ID)

The Power County Advanced Energy Center (P CAEC) is a project to gasify coal and petroleum c oke for use in the production of nitrog en fertilizers and elemen tal sulfur. The project developer is Southeast Idaho Ener gy LLC (Ref ined Energy Holdings) and the pro j ec t site is ne ar Am erican Falls, ID.

Based on infor m ation from Source W a tch [ Reference 13 ]
, the o r ig ina l plan s f o r this project included a 520 M W Integrated Gasificati on Com b i n ed Cycle (IGCC) power plant. The original air quality pe rmit filed by PCAEC in 2007 included on- site pow er generation, albeit at a

D-109significantly s m aller size (60-70 MW). However, these plans were later withdrawn in 2008 when PCAEC filed a revised air perm it application.

PCAEC was issued an air qua lity perm it by the Idaho D e partm e nt of Environmental Quality (ID EQ) on February 10, 200 9 (Perm it P-2008.0066). Following is suance of th e perm it, a Petition for Contested C a se Proceed ing was f iled by Sierra Club, Idaho Conservation League, and the Shoshone-Bannock Tribe with the Board of Environmental Quality. This permit appeal is still pend ing

.

The allowable PCAEC em issions lis ted in the ID EQ perm it a r e sm all, 10 9 tpy f o r

NO x and only 23 tpy for SO 2 [ Reference 14 ]

. However, bas e d on an in itial re view of this perm it, it appears that these em issions m a y ha ve been unde restim ated (a detailed review of the PCAE C
perm it docum ents is beyond the scope of the assi gned work for the Nevada Regional Haze SIP review).

For exam ple, the PCAEC per m it does not appe ar to address e m issions that m i ght occur from start-up, shutdown, and/or m a lfunction flar ing at the gasifier unit. Typically, coal gasification system output needs to be routed to a flare during these opera ting events. If untreated gas were be routed to the flare under these circum stances, overall SO 2 em issions could increase substantially.

However, more significantly, the em issions data used by IDEQ in the perm it appear to be inte rnally in consistent w ith re spect to the sulfur em issions. Using the IDEQ Statement of Basis (Page 12), the gasifier capacity is up to 5,000 tons per day (tpd) of input coal/pet coke blend at a

m a xi m u m s u lfur content of 6%. This would equate to sulfur inputs to the gasifier system of 300 tons per day (tpd), or 109,500 tons per year (based on 365 days per year). Since two pounds of SO 2 are created for each pound of sulfur, the potential uncontrolled S O 2 em issions associated with the gasifier would then be 219,000 tpy. Yet, the allowable SO 2 em issions in the PCAEC
perm it only total 23 tpy. In orde r to ach ieve the allowable SO 2 em issions, the le vel of sulfur control for the gasifier process needs to be about 99.99%. This leve l of sulfur control seem s very high for the process equipm ent listed in the perm it (sour wa ter scrubber and Claus sulfur recovery unit). Also, because ID EQ has de term ined th at: 1 ) the sulf ur

rem oval equipm ent is integral to the process and shoul d not be regulated as pollution co ntrol equipm ent, and 2) the sulfur standards contained in the certain New Source Perfor m a nce Standards (NSPS) are not applicable to the un it, there are m i nim a l enforceab le stand a rds in th e perm it to re quire that th e plant equ i p m ent actually achieves thes e high sulfur control levels.

Overall, the ability of P C AEC to actually ach ie ve the low SO 2 em issions allowed by the
perm it is suspect. However, whether SO 2 em i ssions at PCAEC coul d potentially increase to levels which would cause visibility impairm ent at Jarbidge cannot be determ ined at present.

3.2 COMPARI SON TO NEVA DA REGIONAL HAZ E SIP

This section summ arizes the 2018 regional em issions described above in relation to the projections contained in Nevada’s draft regional haze SIP. In de veloping these data, em issions from the following projects were included in this analysis based on the developer’s current intent

D-110to proceed with project construction and develop m en t and/or the fact that final air quality perm its have been issued by the regulatory agency:

• Toquop Energy

• TS Po wer Plant

• Power County Advanced Energy Center

In the case of the Ely Energy Center an d W h ite Pine Power Project, the project developers h a ve recen tly announced that th ese pr ojects will n o t proceed in the imm e diate future. However, no action has been taken (as of early May 2009) to for m ally withdraw the air perm it application s for these projects or term inate the dr af t PSD perm its issued f

o r these f acilities. As long as the perm it applications are still active at NDEP, these projects need to be part of Nevada’s regional haze SIP planning efforts. Due to this regula to ry unce r ta inty, the r e sults in this section are listed both with and with out Ely and White Pine em issions.

For Sevier Power, the project app ears to be proceeding forward pe nding resolution of the air qua lity perm it appe al cur r en tly bef o re the Utah Suprem e Court. However, Sevier Power appears to be too far rem oved from Jarbidge to be rea listica lly co nsidered a s a potentia l contributing em ission source. Sevi er Power em issions m a y impact Class I areas with in Utah, but visibility im pacts within Utah f a lls o u tside the scope of Nevada’s Regional Haze SIP.

For IPP Unit 3, the PSD perm it for this pr oject has been extende d until October 15, 2009. However, as the IPP Unit 3 em issions are part of the WRAP 2018 em ission projections, they appear to have been considered by NDEP in their regional haze SIP. Therefore, Nevada’ regional haze SIP should acknowledge that IPP’s e m issions have been included in order to prevent any confusion over the issue.

Table 3-2 s u mm arizes the future projects c onsidered in Nevada’s SIP and com p ares the projected 2018 em issions to allowable perm it leve ls. In Table 3-2, the natural gas fired EGUs listed in the April 2009 draft SIP have not been considered.

Table 3-2

Com p arison of Perm itte d SO 2 & NO x Em issions to Nevada Regional Haze SIP (Based on Future Coal E GUs within Ne vada or that m a y affect Jarbidge)

SO 2 Emissions (tpy) NO x Emissions (tpy) Project Permit NV SIP Permit NV SIP

Toquop Energy 1,352 0 1,614 0

TS Power Plant 845 670 596 499

P o w e r C o u n t y Advanced Energy Center 23 0 109 0

D-111Ely Energy Center 4,628 0 4,853 0

White Pine Power Project 6,071 4,356 4,812 3,909

IPP Unit 3 3,183 3,183 3,183 3,183

Unna m e d C o a l EGU 0 1,452 0 1,340

Totals 15,402 9,661 15,167 8,931 Totals (w ithout Ely & White Pine) 5,403 5,305 5,502 5,022

If the Ely and W h ite Pine Projects are inc l u d ed, the da ta show that the SIP has significantly underes timated future SO 2 and NO x em issions associated with future coal-b ased EGU developm ent in Nevada. The Nevada SIP has underestim ated these em issions by roughly 5,700 tons SO 2 and 6,200 tons NO x . If Ely and White Pine are excluded, the Ne vada SIP still underestimates future EGU

em issions, although the error is sm aller (about 100 tpy for SO 2 and about 500 tpy for NO x ). However, any m odeling projections reported in th e SIP could still be significantly affected by these differences. As noted in Table 3-2, the Toquop Energy Project m a y m o re or less be represented (from an em issions basis) by the “unnam e d coal EGU” project in the April 2009 draft Nevad a region al h aze SIP. However, th e location of the “unnam e d coal EGU” does not

m a tch the Toquop plant. As such, this plant does not have sim ilar Class I visibility im pacts to Toquop. Due to its location, Toquop would be expected to have its greatest im pact at Class I areas in southwestern Utah, nam e ly Zion and Bryce Canyon and also at Grand Canyon. Based on the W R AP 2018 em issions inform ation [ Reference 15 ], the unnam e d Nevada coal-fired EGU

was m odeled at a site close to the proposed W h i t e Pine Project. However, even if the m a gnitude of the Toquop e m ission s is accurately reproduced in the 2018 inventory, errors hav e likely been introduced in the m odeling of futur e 2018 e m i ssions at Zion and Bryce Canyon (and perhaps even other Class I areas).

4.0 BART ANALYSES

The Nevada Division of Environmental Pr otection (NDEP) has identified five EGUs within Neva da that are “ B ART-eligible.” Table 4-1 summ arizes thes e facilities.

D-112Table 4-1

Nevada BART-Eligible Sources

Ow ner Facility Unit Si z e Location Operat ional Date Unit 1 55 M W 1963
Unit 2 83 M W 1965 NV Energy Tracy

Unit 3 113 M W Mustang, N V

1974
Unit 1 113 M W 1968 NV Energy Fort Churchill Unit 2 113 M W Yerington, NV
1971
Unit 1 100 M W 1965
Unit 2 100 M W 1968 NV Energy Reid Gardner

Unit 3 100 M W Moapa, NV

1976 NV Energy Sunrise Unit 1 Not Specified Las Vegas, NV 1964
Unit1 790 M W 1969 Southern Cal Edison Mohave
Unit 2 790 M W Laughlin, N V

1969

Of the above facilities, only Reid Gardner is presently coal -fired. Tracy, Fort Churchill, and Sunrise are all natural gas-fired. The Mohave Station was for m erly a coal-fired EGU, but ceased operations at th e end of 2005. If Mohave reopens, it would b e as a natural gas-fired f acility.

The Valm y Station is no t a “BART-Eligib le” E GU as its date of operation falls outside of the BART tim e window.

All of the BART-eligible sources in Neva da are m o re than 300 km from the Jarbidge W ilderness, which is Nevada’s only Class I PSD area. Thus, the BART controls for Nevada

sources a r e intended to p r ovide v i sib i lity im prove m e nts at Class I ar eas ou tside of Nevada.

4.1 SUMMARY OF P R OPOSED BART AT NEVADA S O URCES

Tables 4-2 and 4-3 summ arize the em ission reductions expected to be generated for SO 2 and NO x e m issions respectively by implem e ntation of the proposed Nevada BART decisions. In these tab l es , the “baseline” em ission estim a te s were developed by NDEP from acid rain monitoring data for each unit (generally ove r the period 2002 through 2007). The “baseline”

em issions are repo rted b y NDEP to repres ent th e average em issions over th e peak 2-year perio d at each unit for which monitoring data were av ailable. The d r aft SI P goes on t o st ate t h at t h ese estim ates are generally lower than th e W R AP “b aseline” em issions, which were estim a ted based on the peak-24 hour em issions ove r the 2001-2003 period.

D-113Table 4-2

Proposed Nevada BART-Em i ssion Reductions: SO 2 Em issions

Facility Unit Si z e Baseline Emissions (tpy) BART Emissions (tpy) Emissions Reduction (tpy)
Unit 1 55 M W 1 34 -33
Unit 2 83 M W 2 73 -71 Tracy

Unit 3 113 M W 82 146 -64
Unit 1 113 M W 8 147 -139 Fort Churchill Unit 2 113 M W 11 147 -136
Unit 1 100 M W 621 1,144 -523
Unit 2 100 M W 398 1,251 -853 Reid Gardner

Unit 3 100 M W 422 1,233 -811
Unit1 790 M W 21,507 45 21,462 Mohave
Unit 2 790 M W 21,083 45 21,038
Totals 44,135 4,265 39,870 Net Change w / o Mohave -2,630

Table 4-3

Proposed Nevada BART Em ission Reductions: NO x Em issions

Facility Unit Si z e Baseline Emissions (tpy) BART Emissions (tpy) Emissions Reduction (tpy)
Unit 1 55 M W 221 130 91
Unit 2 83 M W 321 156 165 Tracy

Unit 3 113 M W 795 498 297
Unit 1 113 M W 1,209 524 685 Fort Churchill Unit 2 113 M W 862 403 459
Unit 1 100 M W 2,267 959 1,308
Unit 2 100 M W 2,445 1,002 1,443 Reid Gardner

Unit 3 100 M W 2,268 1,399 869
Unit1 790 M W 10,761 2,347 8,414 Mohave
Unit 2 790 M W 10,068 2,347 7,721
Totals 31,217 9,765 21,452 Net change w / o Mohave 5,317

D-114The net change in emissions attributable to the proposed Nevada BART controls is dom i nated b y the situation at Mohave. Sin ce Mohave ceased operations in 2005, th e Mohave

em issions reductions reported in Tables 4-2 and 4-3 ha ve already occurred. In order to assess the expected change in em issions com p ared to the current situation, one need s to look at the “net change without Mohave” results, also shown in Tables 4-2 and 4-3. W h en Mohave is excluded from the evaluation, it is seen that the e m ission reductions are m u ch le ss substantial and in the case of SO 2 em issions, Nevada’s proposed BART e m ission controls actually lead to increases in

em issions com p ared to the baseline condition.

4.2 REVIEW OF REID G ARDNER BART ANALYSI S

In this study, special attention was paid to the B A RT analysis prepared by NDEP for the Reid Gardner Station. Reid Gardner is the onl y “BART-eligible” Nevada EGU that rem a ins a coal-fired facility in th e post- BART operating scenario. Reid Gar dner is also generally upwind of Class I areas in Utah and Arizona, such as Zion National Park, Bryce Canyon National Park, and Grand Canyon National Park and would be expe cted to im pac t these Class I areas.

The Reid Gardner Station was originally c onstructed in 1965 (Unit 1). Unit 2 was added in 1968, Unit 3 in 1976, and Unit 4 in 1983. Units 1- 3 are all sized at 100 M W each, while Unit 4 is sized at 265 MW . Unit 4 was not subject to B A RT review as its construction/operational dat e (1983) falls outside the BART ti m e window. EGUs m u st have been in existence prior to Augus t 7, 1977, but not prior to August 7, 1962 in order to be “BART-eligible.” Based on infor m ation available from NDEP [ Reference 16 ], the Reid Gardner B A RT review f o llowed th e f i ve-step process ou tlined in th e Environm ental Pro t ectio n Agency (EPA) BART guidelines [ Reference 17 ]. The BART decision for Reid Ga rdner is su mmarize d and reviewed below.

4.2.1 SO 2 BART at Reid Gardner

Current SO 2 control at R e id Gardner Units 1, 2, and 3 consists of a soda ash scrubber. For BART, NDEP evaluated additional em ission contro ls to replace and/o r upgrade the current SO 2
em ission controls, spec if ically :

• Dry flue gas desulf urization (FGD)

• Dry sorbent injection

• Furnace sorbent in jectio n

• New wet FGD system ( r eplace current wet FGD system )

• I m prove and/or upgrade existing wet FGD system

In the federal BART gui delines, EPA recomm e nded a “presum p tive BART” level of 0.10 to 0.15 lb/MMBtu or 95% control for SO 2 e m issions [ Reference 17 ]. However, the “presum p tive BART” appl ies only to EGUs sized 250 M W and la rger, so technically the “presum p tive BART”

recomm endation would not apply to any of the R e id Gardner units du e to their si ze (100 MW vs

. the “presumptive BART” threshold of 250 M W )

. NDEP has proposed in the draft regional haze

D-115SIP that the curren t wet FGD system (wet soda ash scrubber) represents BART for Units 1, 2, and 3. However, the BART SO 2 em issions lim it in the d r af t SIP was set a t 0.2 5 lb/MMBtu. Nevada’s proposed BART SO 2 emissions lim it at Reid Gardner is a pproxim a tely twice the “presum p tive BART” level recommended by EPA for SO 2 e m issions at coal-fired E GUs.

NDEP’s BART report for Reid Gar dner suggests that the proposed SO 2 em issions lim it of 0.25 lb/MMBtu was selected based on the 98t h percentile em issions value from the valid continuous em issions monitoring data . In other words, the Reid Ga rdner historical em issions are at or below 0.25 lb/MMBtu about 98 percent of the tim e. In this m a nner, NDEP has proposed a BART lim it such that Reid Gard ner would comply near ly all of the tim e based on historical

em issions monitoring data. At the proposed em issi on lim its in the region al haze SIP, Nevada’s proposed BART would not lead to Reid Gar dner em ploying the “best available retrofit technology” for SO 2 as required by the Clean Air Act.

In fact, by estab lish i ng the BART SO 2 lim it in this m a nner, the result is tha t the April 2009 draft Regional Haze SIP would allo w for a substantial increase in SO 2 em issions from each Reid Gardner EGU. As proposed, the draft Nevad a visibility SIP would allow each Reid Gardner unit to em it continuously at their peak em issions rate based on historic al data. Using NDEP’s data p r esen ted in the SI P, SO 2 em is sions from all three units com b ined could increase by alm o st 2,200 tpy, which represents an increase of 2.5 ti m e s over the “baseline.” This would exceed the projected “new” em issions associated with the T oquop Power Plant.

Also, based on W R AP’s em ission projections [ Reference 18 ], Rei d Gardner already achieves SO 2 e m issions in the range of 0.03 to 0.04 lb/MMBtu. WRAP ’s 2018 e m ission inventory projections also appea r to utilize SO 2 em ission va lues in this range at Reid Gardner. Since Reid Gardner has already demonstr ated the ability to achieve average SO 2 em issions in the range of 0.03 to 0.04 lb/MMBtu, this e m issions range establishes a m o re appropriate SO 2 BART lim it f o r Reid Gardner.

Fortunately, there is a re latively easy f i x whic h s till re ta ins what appe ars to be Nevad a ’s intent in establishing the proposed Reid Gardner SO 2 BART lim it. NDEP could inste a d set a “two-tiered ” SO 2 e m iss i ons lim it under BART that would allow for peak short-term SO 2
em issions consistent with the historical data, yet also set a lower lim it averaged over a longer tim e period that would more clos ely align with the historical SO 2 em ission levels and require Reid Gardn e r to m a inta in the h i gh- level of pe rfor m ance already dem onstrated at its pollution
contro l sys t em s. For exam ple, an SO 2 lim it set at 0.04 lb/MMBtu (30-day rolling average), would yield an annual em issions total roughly equi valent to the W R AP em issions estim ate, yet would still allow occasio nal s hort-term periods for higher S O 2 e m issions. This approach would be a m o re prudent way under BART to set lim its that provide for variab ility in short-term

em issions, yet require that Reid Gardner m a intain em issions contro l at or near the current lev e ls so as not to degrade f u rther vis i bility at downwind Class I a r e a s.

In the end, allowing a substantial increase in SO 2 em issions above the baseline level goes agains t th e regulato r y in te nt of the BART program

. BART is intended to provide for em ission reductions and should not be used as a m echanism to perm it substantial increases in em issions a t a facility. There is no valid reason why SO 2 control at Reid Gardner under BART s hould not at

D-116the ve ry le as t m a tch the perf orm a nce leve ls histo r ic a lly achie ved at this f acility. W h en viewed in that context, a long-term (30-day rolling average) SO 2 BART lim it should be set for Reid Gardner at or below 0.04 lb/MMBtu.

4.2.2 NO x BART at Reid Gardner

Current nitrogen oxides (NO x ) em ission con t ro ls a t Reid Gardner Units 1-3 consist of low- NO x burners with over-fire air (OFA). For potential application as BART, Nevada evalua ted th e f o llowing NO x e m ission control options:

• Low- NO x burners (LNB) with overfire ai r (current configuration)

• LNB with Selective N on-Cataly tic Reduction ( S NCR)

• Rotating Opposed Fire Air (ROFA) with Rotomix

• LNB with Selective Ca taly tic Redu ction (SCR)

• ROFA with Selective C a ta ly tic Red u ction (SCR)

In the EPA guidelines, the “presum p tive BART” NO x em issions lev e l for a coal-fired boiler depends on the boiler configuration and fuel. Reid Gar dner Units 1

- 3 are wall-f ired boiler s using m o stly bitum i nous coal. Under “p resum p tive BART”, the recommended NO x lim it is 0.39 lb/MMBtu [ Reference 17 ]. Again, Reid Gardner Units 1- 3 technically do not fall under “presum p tive BART’ be cause the unit size (100 M W ) is below the 250 M W threshold used to trigg e r “p res u m p tive BART.”

NDEP’s BART evaluation for Reid Gardner has derived a B A RT e m issions lim it of 0.20 lb/MMBtu f

o r Units 1 a nd 2 a nd 0.28 lb/MMBtu for Unit 3. Th e need for a h i gher BART NO x lim it at Unit 3 is not discusse d in N D EP’s summ ary BART re port. NDEP should provide clear evidence as to why Un it 3 is unique and cannot achieve the sam e NO x BART lim it as Units 1 and 2. W ithout this inform ation, the need for a higher N O x BART lim it at Unit 3 cannot be confirm e d by ARS or any other m e mber of th e public. The proposed BART e m issions lim it is based on installation of ROFA with Rotom i x as the preferred technology.

Lower NO x em issions could be achieved using one of the SC R technology alternatives. If SCR were employed along with ROFA with Rotom i x, the NO x e m issions could decrease to a range of 0.083 to 0.098 lb/MMBtu using NDEP data (the exact em issions level depends on the Unit). This would represent an additional 60-65% reduction in NO x f r om Reid Gardner Units 1

- 3. Based on the NDEP evaluation, cost was the prim ary factor in not sele cting one of the SCR options as B A RT. Cost is an allowable c onsideration under E P A’s BART guidelines.

W h en SCR is added to ROFA with Rotom i x, the capital costs increas e from about $8

m illion to ro ughly $38.5 m illion for each unit (o ver $90 m illion for SCR at all three units). The

em issions control cost-effectiveness with SCR incr eases by about a factor of two or three, from around $1,000 per ton to an average of about $2,800 per ton at Units 1 and 2 and from about $1,600 per ton to about $3,000 per ton at Unit 3. Although N D EP has re jected these costs as too expensive, it should be noted that NO x BART determ inations in North Dakota determ ined that costs in the $3,000 to $4,000 per ton range were acceptab l e [ Reference 19 ]. On an i n crem ental

D-117basis com p ared to ROFA with Rotom i x, the S CR costs for Reid Gard ner are rep o rted to be around $7,000 per ton at Units 1 and 2 and $4,500 per ton at Unit 3. The above cost num bers were developed by NV Energy and used by NDEP to evaluate the BART costs.

Because cost was th e prim ary parameter us ed by NDEP to exclude the S CR technolo g ies as BART for Reid Gardner, it is important that the cost inform ati on used to support this decision is a ccura te. Based on th e SIP, NDEP ha s c h os en t o us e t h e SCR cost infor m ation provided by NV Energy, but there is no evidence that NDEP critic ally reviewed the com p any’s SCR cost inform ation. Since regulated com p anies know that cost inform ation is part of the B A RT review process, these com p anies have a vested interes t in trying to present m a xim u m or “ w orst-case” costs for a particular control technology. An independent review of NV Energy’s cost inf o rm ation is essen t ial if NDEP is to rely on cost data to exclude SCR as BART.

In the Oreg on region al haze S I P, the Ore gon Departm e nt of Enviro nm ental Qu ality (ODEQ) did conduct an independent evaluation of the company-provided costs for SCR at the Boardm an Power Plant [ Reference 20 ]. The Or egon DEQ concluded that capital costs for the SCR alternative at Boardm an were ove restim ated by the company by 27%.

An independent evaluation of the Nevada regional haze SIP conducted by the Na tional Park Service also found that the reported SCR costs for Reid Gardner were likely overstated [ Reference 21 ]. NPS estim ated costs were about 33% lower than those developed by NV Energy. NPS concluded that a lower cost wo uld resu lt in cost-effectiveness valu es that sugg est th at SCR is viable as BART from an econom ic standpoi nt. Coupled with the Boardm an infor m ation presented above, this shows the need for a crit ical evaluation of the SCR cost inform ation subm itted by NV Energy.

The cost inform ation should also be coupled with the NO x em ission levels assum e d for SCR. In the April 2009 draft Nevada region al haze SIP, th e resu lting SCR NO x em issions are higher than what would nor m a lly be assigned to this technology. At newer coal-fired units for which Nevada has issued draft perm its (i.e., Toquop Energy Project), NO x control using SCR achieves emissions as low as 0.06 lb/MMBtu [ Referen ce 4 ]. W h ile it is recognized that control technologies when applied in a re trofit situation m a y not be as effective, the proposed BART lim its at Reid Gardner are m o re than 60% high er than when the sam e pollution technology is applied at new e m ission units.

In the Oregon regional haze SIP, SCR contro ls have been proposed for the Boardm an Power Plant (a coal-fired EGU) as “beyond BART” e m is sion controls (See Section 4.4). At Boardm an, t h e SCR control efficiency is about 70%, reducing NO x e m issions to 0.07 lb/MMBtu from a “pre-SCR” level of 0.23 lb/MMBtu [ Refer e nce 20 ]. Thi s “pre-SCR” NO x em ission ra te is higher than the “pr e -SCR” rate a t R e id Gardne r for Units 1 and 2, yet the draft Nevada SIP is based on higher “post-SCR” NO x em issions. The April 2009 draft Nevada SIP only presum es that SCR control achiev es a contro l efficiency in the range of 60-65% at Reid Gardner, com p ared to 70% else where. If 70 % con t rol for SCR were used, the resulting NO x em ission rate at Reid Gardner Units 1 and 2 w ould be less than 0.06 lb/MMBtu and would be 0.083 lb/MMBtu at Unit 3. In f a c t , th e BART analysis f o r Reid Gardne r s u bm itted by NV Energy also us ed a “post-SCR”

em ission rate of 0.07 lb/MMBtu [ Reference 22 ].

D-118Also, in New Mexico, SCR is being consider ed for i m plementation as BART for t h e San Juan Power Plant at a NO x em issions level of 0.07 lb/MMBtu [ Reference 19 ]. The reported SCR cost factor at San Ju an is $6,500 per ton NO x rem oved. Presum ably, the higher cost of NO x contro l at San Juan is justif ied by the sign if ic a n t vis i bility im provem e nt tha t would occur f r om im ple m entation of this technology (estim ated at up to 1.3 dV). The SCR costs reported for Reid Gardner and rejected by NDEP as too expensive ar e less than 50% of the costs being considered by New Mexico for im plem entation of SCR at San Juan.

In summary, Nevada’s regional haze SIP needs to use a m o re realistic NO x control efficiency for SCR or explain why the sam e NO x em issions control achieved elsewhere cann o t be achieved using SCR at Reid Ga rdner. If a lower NO x e m ission level were achievable, the

econom ic cost effectiveness of SCR would also im prove. Al so, because NDEP did not critically review the com p any-subm itted SCR cost inf o rm ation and other ind i cations ar e that costs subm itted by regulated com p anies are som e tim e s in f l ated, the conclusions of the Nevada SIP regard ing th e cost-effectiveness of SCR at Reid Ga rdner are deem ed to be unreliable. Finally, if

a m o re realistic NO x em issions le vel were us ed to repr es ent SCR at Reid Gard ner, th e NO x reductions would be higher and the cost-eff ectiveness of SCR would improve.

4.3 VISIBILITY IMPROVEMENTS FR OM BART IMPLEMENTATI ON

The April 2009 draf t reg i onal haze SIP includes inform ation on the expected im prove m e nt in visibility conditions result ing from the proposed BART technologies and

em ission rates. Inform at ion related to the m ode l e d BART improvem e nt s is provided for Mohave and Reid Gardner, as these em ission sources impact the C l ass I ar eas of greates t interes t with
respec t to th e issues in this repo rt.

Details on the specifics of how the BART -i mprovem e nt modeling was prepared by NDEP are not contained within the draft SIP docum entation.

4.3.1 Mohave Generation Station

Table 4-4 summarizes the results from the Mohave Generating Station BARTim prove m e nt m odeling. BART for Mohave was the e lim ination of coal-fired electric generation and operation of natural gas. Mohave’s m odeling re sults are presented for the p l ant as a whole rather than f o r individual units. Although part of the “baseline” SIP em i ssions, Mohave is not currently operating. As such, any visibility be nefit associated with e m ission reductions at Mohave has already been achieved.

Table 4-4 sh ows that the BART controls at Mohave should have a strong positiv e ben e fit at im proving visibility at nearby Class I areas. Despite a strong positive benefit, even after im ple m entation of BART contro ls, the Mohave plant rem a ins above the “cause and contribute” visibility thresholds at Grand Canyon and Joshua Tree (98 th percentile extincti on at or above 0.5 dV). These results sugg est th at add i tional em i ssion reductions are likely needed at Mohave in order to rea c h the nation al vis i bility goal.

D-119Table 4-4

Summ ary of BART-I m p rovem e nt Modeling Results Mohave Generating Station

Baseline Condition Post-BART Condition Class I Area Dist. (km)

98 th % dV Days > 0.5 dV 98 th % dV Days > 0.5 dV
Grand Canyon 110 2.91 194 0.53 8 Joshua Tree 137 3.96 90 0.76 14 Zion 262 1.45 80 0.20 0 Sycam ore Canyon 223 1.38 29 0.12 0 Agua Tibia 286 1.11 19 0.10 0 Cucam onga 287 1.05 20 0.11 0 San Gorgonio 225 1.50 27 0.14 1 San Jacinto 234 1.46 29 0.15 1 Mazatal 279 0.98 25 0.04 0 Pine Mountain 265 0.98 23 0.04 0
Dom e Land 268 1.34 26 0.10 0

4.3.2 Reid Gardner

Table 4

- 5 s u mm arizes the Reid G a rdner BART-im p rove m e nt m odeling results. The proposed B A RT at Reid Gardner provides for NO x control through instal lation of ROFA with Rotom i x on each un it. Also, even though th e p r oposed BART used the in-p lace SO 2 em issions control technology at R e id Gar dner, the proposed SIP em ission rate actually allows for SO 2
em ission increases compared to the baseline co ndition. The Reid Gardner m odeling results are presented in the draft SIP for individual units.

Although Nevada has proposed NO x BART em ission rates f o r Reid Gardner, it is unc lear to what extent these controls are actually reflected in the W R AP 2108 em issions inventory used to dr ive the model ca lcu l ations sum m a rized abo v e. Based on the m o st recent WRAP em issions update [ Reference 18 ], the planned em ission changes due to BART at Reid Gardner do not appear to be reflected in the W R AP 2018 m odeled inventory. This m a kes the results of the Reid Gardner post-BART m o deling susp ect. The draft SIP should clearly identify the baseline and post-BART em issions used to generate the Reid Gardner m o deling results.

D-120Table 4-5

Summ ary of BART-I m p rovem e nt Modeling Results Reid Gardne r Genera ting Station

Class I Area Dist. (km) Unit Baseline Condition Post-BART Condition

98 th %

dV Days > 0.5 dV 98 th % dV Days > 0.5 dV

1 0.85 19 0.83 19
2 0.86 21 0.73 15 Grand Canyon 86

3 0.79 17 0.73 18
1 0.32 3 0.33 4
2 0.32 3 0.32 3 Joshua Tree 292

3 0.33 3 0.34 4
1 0.22 3 0.22 2
2 0.22 3 0.19 2 Zion 148

3 0.22 3 0.20 2
1 0.13 0 0.12 0
2 0.13 0 0.12 0 Bryce Canyon 227

3 0.13 0 0.13 0
1 0.06 0 0.06 0
2 0.06 0 0.06 0 Sycam ore Canyon 289

3 0.07 0 0.07 0

At Reid Gardner, if the modeling re sults a r e to be believed, the im ple m entation of BART controls is shown to have only m i nim a l effect at reducing visibility im pacts. In fact, in a few cases, the proposed BART e m ission controls at Re id Gardner em issions is actually shown to degrade visibility m a rginally (i.e., see Unit 3 at Grand Canyon and Joshua Tree). The lack of change in the Reid Gardner m odeling results app ears to reinforce the above suspicion that the post-BART em issions are not properly reflected in the 2018 model em issi ons inventory. If the modeled inventory does not accurately reflect th e post-BA RT em issions at Reid Gardner, th e modeling re sults repor te d in the SIP are in erro r and Nevada has failed to provide one of the adm i nistrative requirements of its regional haze SIP (docum entation of the changes in visibility attributable to the proposed BART e m ission controls).

Also of interest is that the “post-BART” im pa ct of Reid Gardner would still be at or above the “cause or contribute” threshold under the federal visibility rules at Grand Canyon (98th percentile extin ction at or ab ove 0.5 dV). Assum i ng the m odeling results are accu rate (which m a y not be the case based on the above analysis), the Reid Gardner m odel results would clearly demonstrate the need fo r a more stringent BART determ ination. Nevada should select

D-121BART technologies and associated em ission lim its that significantly reduce the im pact of Reid Gardner’s em issions on visibility degradation at the Grand Ca nyon and other Class I areas and properly docum e nt the actual effect of thes e changes on visibility. The m ode ling results summarized in Nevada’s draft regional haze S I P suggest that the proposed BART em ission lim its at Reid Gardner fail to provide any signi f i cant vis i b ility im provem e nt at Class I areas outside Nevada.

On a unit-by-unit basis, the 98th percentile extinction from Reid Gardner is less than 0.5 dV at Zion and Bryce Canyon. As such, the indi vidual units do not “cause or contribu te” t o visibility impairm ent at ei ther Zion of Bryc e Canyon, even under the baseline condition. However, the m odeling results as presented in th e draft SIP do not allow for a determ ination of the cum u lative im pact from Reid Gardner Units 1, 2, and 3.

One f i nal note of inter e st with res p ect to the m odeling results is th at the repor ted visibility impacts from Reid Ga rdner at Joshua Tree (292 km away ) are significantly greater than im pacts to other Class I areas that are closer to the f acility (with the exception of Grand Canyon). The infor m ation provided in the draft SIP did not discuss this finding and why it m i ght have occurred.

4.4 OPTIONS FOR “BEYOND-BART” CONT ROLS

Regional haze SIPs in other states have investigated and som e tim es recomm ended additional em ission controls that are “beyond BART” which are jus tified as part of the goal to achieve “reasonable further progress” toward the national visibility goal. Two such e x am ples are summarized in this section.

In Oregon, the Boardm an Power Plant BART analysis concluded that low- NO x burners with m odified overfire air sati sfied the current BART requirem e nts and proposed an allowable NO x e m issions level of 0.23 lb /MMBtu. Although SCR was not recomm ended for imm e dia t e im ple m entation under BART, Oregon has proposed to require installation of SCR at Boardm an no later than July 1, 2017 [ Reference 20 ]. Oregon has proposed additional NO x e m ission controls that are “beyond BART” at Boardm an in order to m a intain the “reasonable further progress” goals of Or egon’s visibility program. The post

- SCR NO x em issions level at Board m an will be 0.07 lb/MMBtu.

The State of Kansas has also elected to im pose “ b eyond BART’ e m ission controls as part of its proposed regional haze SIP [ Referen ce 23 ]. In Kansas, there are no existing federal Class I areas, so K a nsas has adopted its program in or der to assist neighboring states achieve their “reasonable further progress” goals. Kansas al so im ple m ented its program even though the light extinction from Kansas s ources was no greater than 5% of the total extinction on worst-case days at any of the neighboring Class I areas. As descri bed previously, Nevada s ources are projected in 2018 to contribute up to 9% of the nitrate extinc tion at Class I areas in neighboring states.

In Kansas, the “beyond BART” review focused on sources that were not “BARTelig ible.” The evalu a tio n reviewed the costs of c ontro ls and also the potentia l visibility ben e f i ts

D-122of i m plem e n ting these controls. Of approxim a tely 25 Kansas em i ssion units not regulated under BART, additional em ission controls were proposed for 10 e m ission units at six facilities where the cost was deem ed to be reasonable (at or below $15,000 dollars per ton per deciview of im prove m e nt).

The “beyon d BART” approach cou l d be applie d in Nevad a to s ecur e a ddition a l emission reductions at Nevada em ission sour ces, which would in turn aid ne ighboring states achieve their “reasonable further progress” goals. Candi dates for “beyond BART” would include the im ple m entation of SCR at Reid Gardner Units 1-3 and investigation of i m proved em ission controls at Reid Gardner Unit 4. N D EP needs to ensure that em ission cont r o l s at it s sour ces ar e sufficient to ensure that Nevada s ources contri bute th eir f a ir sh are to im provin g visib i lity conditions at Class I areas in neighboring states. In the draf t SIP, N e vada has relied upon

em ission reductions already achieved at Mohave without developing appropriate em ission control strategies that w ould provi de m eaningful visibility im provem e nt from any other sources.

5.0 CUMULATIVE VI SIBILITY IM PACTS AT SOUT HWESTERN PARKS

One of the item s requested by WRA and NPCA was a revie w of the potentia l cum u lative visibility im pacts a t tribu t able to m u ltiple em issi on sources that occu rs a t Nationa l Parks in the southwestern United States, in pa rticular Zion National Park.

The cum u lative effect of em ission s ources at Z i on and other southwestern Class I areas (Grand Canyon, Syca more Canyon, and Bryce Canyon) is covered in only summa ry fashion within th e April 2009 draft reg i on al haze S I P. Si nce these Class I areas are located outsid e of Nevada, the NDEP does not have prim ary responsib ility for developing the visibility plan for these ar eas. However, Nevada sourc e s do contribute in par t to the vis i bility im pairment at ea c h of these areas and Nevada is responsible for ad dressing in the SIP how their sources im pact the overall vis i b ility plann i n g efforts at these Cla ss I areas. Futu re development of coal-f ired EGUs in Nevada, especially the proposed Toquop Powe r Pr oject (See Section 3.1.1 of this report), m a y also con t rib u te to v i sib i lity im pairment at Class I areas outside of Nevada.

Data from t h e Nevada regional haze SIP on cumu lative effects at Class I areas outs i d e of Nevada are summarized in Tab l e 5

- 1. These d a ta s how the current baseline extinction, the target 2018 extin ction based o n the Uniform Rate of Pr ogress (URP) necessary to achieve the national visibility goal by 2064, and th e projected extinction using m odeling projections based on the 2018 em issions inventory from WRAP.

D-123Table 5-1

Cum u lative Im pacts on Regional Haze a nd Utah and Arizona Class I Areas

Class I Area Baseline Extinction 2018 URP Target Projected 2108 Extinction
dV dV dV Grand Canyon (AZ) 11.66 10.58 11.10
Sycam ore Canyon (AZ) 15.25 13.25 15.08

Zion (UT) 13.24 11.78 12.76 Bryce Canyon (UT) 11.65 10.52 11.22

For each of the Class I areas of interest, th e p r ojection s of visibil ity im pairm e nt based on the 2018 WRAP e m issions inventory fail to achieve the URP target goals, which means that the “glide path” for visibility im provem e nt will n o t be achieved at each of these areas without additional em ission reductions.

NDEP claims tha t th e re duction in S O 2 and NO x em issions outlin ed in th e draf t S I P f r om sources within Nevada (in percen t) is grea te r th an the f r ac tion of the extinc tion con t ribu ted by Nevada sources at each of these areas. However, th is claim in largely an artifact of the larg e

em ission reduction which has already occurred at Mohave associated with discontinuing use of coal at th is facility. NDEP does not appear to have aggressively sought additional em issions reductions at other em ission s ources under its jurisdiction.

In addition, the above claim is based on an assumption that all em ission reductions have an equal effect on vis i b ility at the Class I a r ea s of interes t . In fact, so urces affect visibility differently based on their proxim ity to any particular Cla ss I area. Fo r vis i bility to improve at an individual C l ass I area, em ission reductions m a y be required at specific s ources rather than for the state as a whole. For exam ple, with resp ect to Zion and Bryce Canyon National Parks, an equivalent em ission reductions at Re i d Ga r d ne r woul d be e xpe ct ed to have a larger benefit

com p ared to Mohave due to the clos er proxim ity of Reid Gardner to the areas of interest.

While the em ission reductions at Mohave are i m portant, the data presented in Nevada’s draft region al haze SIP also show that em ission reductio ns at Mohave are insu fficient by them selves to m eet the 2 018 visib i lity target goa ls at Class I areas outs i d e of Nevada. Addition a l

em ission reductions will be needed at other so urces to achieve m e aningful im provem ents to visibility at areas such as Zion and Grand Canyon. For example, if each Nevada source were expected to indiv i dually contribute to “Nevad a’s em issio n reduction share, ” th e em issions reductions and im provem e nt in visibility attrib utable to the proposed BART at Reid Gardner falls short of the goals provided in N e vada’s regional haze S I P.

D-124