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Nebraska 

Regional Haze /BART

SIP Submittal

Shelley Schneider 

NDEQ Air Quality Division Administrator 

April 12, 2012 
Overview

• Nebraska State Implementation Plan 

– Regional Haze & Best Available Retrofit Technology 

(BART) 

• Baseline Emissions vs. Projected Emissions 

– SIP Effectiveness 

• Summary of BART Determinations 

– OPPD 

– NPPD 

• Remainder of Haze SIP 

 

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2002 Baseline Emissions

 

 

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2018 Emissions – Projected

As controlled by SIP

 

 

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Nebraska SIP Effectiveness

• Overall Emission Reductions due to NE SIP 

– VOCs 16,804 tons (↓ 12%) 

– NOx 110,459 tons (↓ 43%) 

– SO2 1,620 tons (↓ 1.7%) 

– PM10 143,673 tons (↓ 30%) 

– PM2.5 28,010 tons (↓ 28%) 

• Reductions achieved primarily through 

implementation of BART 

 

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Impacts on Visibility –

Pre Control

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What’s a deciview dV?

Badlands

Baseline Conditions

20% worst 17.14 dV

20% least 6.91 dV

Natural Conditions

20% worst 8.06 dV

20% least 2.32 dV

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1 deciviews

10 deciviews

15 deciviews

10 deciviews

17 deciviews

7 deciviews
BART Requirements

• BART Process

– Presumptive levels must be met for electric 

generation units (EGUs) unless otherwise 

justified based upon statutory factors

– Statutory factors are considered in the analysis: 

cost effectiveness, existing controls, remaining 

useful life, degree of visibility improvement, and 

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BART Determinations

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OPPD BART Summary

• PM determined to be insignificant, current controls 

adequate

• Presumptive level of control for NOx 

– Cost effectiveness 

• $135/ ton NOx removed (10,181 tons)

• $1,380,000 cost of control 

• $ 6,751,613 average cost/ dV of improvement

– 0.228 dV improvement

• Low NOx burners w/ over-fired air deemed 

appropriate

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OPPD BART Summary

• Presumptive level of control for SO2 

– Cost effectiveness 

• $1,636/ ton SO2 removed

• $34,720,000 cost of control 

• $85,747,879 average cost/ dV of improvement

– 0.408 dV improvement

– Causes of Haze Study – lack of evidence supporting 

need for SO2 control

• NDEQ determined that high costs for amount of 

visibility improvement did not warrant additional 

SO2 control

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NPPD - GGS BART Summary

• Units #1 & #2

• PM determined to be insignificant, current controls 

adequate

• Presumptive level of control for NOx 

– Cost effectiveness 

• $198/ ton NOx removed (14,956 tons)

• $2,960,000 cost of control 

• $ 4,464,555 average cost/ dV of improvement

– 0.663 dV improvement

• Low NOx burners w/ over-fired air deemed 

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NPPD-GGS BART Summary

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• Presumptive level of control for SO2 - Scrubbers 

– Cost effectiveness - Scrubbers

• $2,935 ton SO2 removed

• $123,933,694 (annualized) cost of control 

• $146,667,093 annual cost/ dV of improvement

– 0.845 dV improvement

• NDEQ used $40,000,000/dV as threshold for 

reasonableness

• Presumptive control is wet or semi-dry scrubbing 

– Both require substantial amounts of consumptive 

water
NPPD Water Demands

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Gallons

/Min

(dry)

Gallons

/Min

(wet)

Acre-Feet 

per Year 

(dry)

Acre-Feet 

per Year 

(wet)

NPPD 2,007 2,402 3,238 3,877

Industry 

Average

1,280 1,652 2,065 2,666
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NPPD-GGS BART Summary

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• Presumptive level of control for SO2 – Dry Sorbent 

Injection 

– Cost effectiveness – Dry Sorbent Injection

• $2,058 ton SO2 removed

• $81,958,000 (annualized) cost of control 

• $95,189,314 annual cost/ dV of improvement

– 0.861 dV improvement

• NDEQ used $40,000,000/dV as threshold for reasonableness

• Landfill requirements would quadruple – 400,000 tons of waste per 

year

– Shortening life span of current landfill – Hazardous waste??

– Lost revenue from fly-ash 

• Water is used to wash trona mills – 5 gallons/min
NPPD-GGS BART Conclusion

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• Water Resources within the river basin are 

scarce

– Moratorium in place on new uses of water

– Unique circumstances exist related to water 

resources in this region of the state

• DSI poses substantial other environmental 

impacts related to waste

– Visibility benefit while greater than 0.5 dV is smaller 

than 1.0 dV

• These small gains in visibility do not warrant the high costs 

and excesseive waste generated

• Continue to use low sulfur coal
Remainder of Haze SIP

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• Demonstration of Consultation with States

• Long Term Strategy

– Federal Measures

• CAIR/Clean Air Transport / Cross State Air Pollution Rule

– Mobile Source Related Standards

– Air Toxics Standards

– Federal Construction Permit Program

– Fugitive Dust Regulations

– Open Burning 

• Commitment to Periodic Emission Inventories & 

Plan Revisions