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# Chapter Two

– Status of Implementation of Control Measures (40 CFR 51.308(g)( 1 ))

Table of Contents

2.1 Status Summary

................................ ................................ ................................ ................ 2

2.2 Nature of the Visibility Problem in Nevada

................................ ................................ ..... 2

2.3 Federal Programs

................................ ................................ ................................ .............. 3

2.3.1 Existing Federal Measures

................................ ................................ ........................ 3

2.3.2 New Federal Measures

................................ ................................ .............................. 4

2.4 State Measures other than BART

................................ ................................ ..................... 6

2.4.1 Closures and Cancellations

................................ ................................ ....................... 7

2.4.2 Emissions from Coal

- Fired Power Plants

................................ ................................ . 7

2.4.3 Renewable Portfolio

................................ ................................ ................................ .. 8

2.4.4 State Implementation Plans

................................ ................................ ....................... 9

2.5 Review of BART Determinations

................................ ................................ .................. 10

2.5.1 Nevada’s BART Implementation

................................ ................................ ........... 10

2.5.2 Adjacent States’ BART Implementation

................................ ................................ 12Nevada Regional Haze 5

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51. 308(g) Periodic progress reports

must contain at a minimum . . .

( 1 ) A description of the status of implementation of all measures included in the implementation plan for achieving reasonable progress goals for mandatory Class I Federal areas both
within and outside the State. 

### 2.1 Status Summary
Chapter Two discusses the implementation of control measures included in Nevada’s 2009 RH SIP to achieve reasonable progress goals for Class I areas in Nevada and nearby

. Nevada’s strategy for achieving reasonable progress during the initial planning period is based on the federal and state measures considered in developing the 2018 emissions inventory ( PRP18a )

. A dditional reductions will be gained by the implementation of Nevada Best Available Retrofit Technology ( BART ) regulations and other s tate measures. The f ederal measures incorporated in the 2 018 projected emission estimates have all been enacted and are in full effect. The existing

s tate measures described in the 2009 RH SIP not only remain in place, but have been enhanced by legislation mandating a reduction in coal

- fired electrical generati ng unit (EGU) emissions and stronger renewable energy portfolio requirements. T he 2018 emission projections also included

a large coal

- fired power plant that has since ceased ope rations and been decommissioned, and three proposed power plants whose permit applications have been withdrawn ( Appendix B, Section 1)

. These actions have led to substantial reduction s in both the actual and projected emission s of visibility

- impairing pollutants from Nevada sources.
Finally, several new and proposed f ederal and s tate actions are discussed that will result in further reductions of visibility impairing pollutants through the next planning period , including the status of BART controls at Nevada facilities as well as those in adjacent states.



### 2.2 Nature of the Visibil ity Problem in Nevada

40 CFR 51.308(g)( 1 ) requires “[ a ] description of the status of implementation of all measures included in the implementation plan for achieving ” reasonable progress goals for Class I areas both within and outside the S tate

. Visibility modeling was used to determine the expected 2018 visibility improvements for the Jarbidge WA resulting from existing federal and state regulations, including presumptive SO 2 BART limits for coal

- fired EGUs with capacity greater than 750 megawatts ( MW ) . The resulting modeled haze index in deciviews , as captured by the WRAP’s projected PRP18a emissions inventory, was adopted as Nevada’s reasonable progress goal for the first pl anning period

. 2009 RH SIP Chapter Six. 1

1 See the discussion in Chapter One of the correction to the 2018 visibility projection for Jarbidge WA conducted by the Regional Modeling Center. Nevada concludes that it is reasonable to retain the reasonable progress goal of 11.05 deciviews, which align s closely with the 2018 uniform rate of progress value for Jarbidge WA.Nevada Regional Haze 5

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This chapter focus es on anthropogenic emission sources and descri bes the emission reduction measures that were included in the 2018 projected emission inventory modeling effort. T he

status and associated benefits of these controls and regulations are discussed below. The benefits are quantified where possible in Chapter Five

. This c hapter also discusses significant federal and state emission reduction measures that were not included in the 2018 inventory

, includ ing the status of existing and future expected controls for Nevada’s EGUs

. Finally, t he status of the implementation of BART, both in Nevada and in adjacent s tates, is discussed as it relates to the reduction of baseline emissions.



### 2.3 Federal Programs

This section describes the existing federal programs that were included in the 2018 future year emissions estimate and new federal programs that will result in additional reductions of visibility impairing pollutants beyond those captured in the projections.

2.3.1 Existing Federal Measures

The emission reductions associated with the following existing federal measures were incorporated into the WRAP’s 2018 projected emission inventory. These are the “on

- the

- way” and “on

- the

- books” federal control programs that are part of Nevada’s long term strategy for reaching its reasonable progress goal

. 2009 RH SIP

, Chapter Seven.
Heavy

- Duty Highway Rule

-- 40 CFR Part 86 In this regulation, USEPA set a particulate matter (PM) emissions standard for new heavy

- duty engines of 0.01 gram per brake horsepower

- hour (g/bhp

- hr), which took full effect for diesel engines in the 2007 model year. This rule also included standards for oxides of nitrogen (NO x ) and non

- methane hydrocarbons of 0.20 g/bhp

- hr and 0.14 g/bhp

- hr, respectively. These diesel engine NO x and non

- methane hydrocarbons standards were successfully phased in together between 2007 and 2010.
The rule also required that sulfur in diesel fuel be reduced to facilitate the use of modern pollution

- control technology on these trucks and buses. The 97 percent reduction in the sulfur content of highway diesel fuel mandated by USEPA

– from levels of 500 parts per million (ppm) (low sulfur diesel) to 15 ppm (ultra

- low sulfur diesel)

– became effective in Nevada in October 2006

. Tier 2 Vehicle and Gasoline Sulfur Program

– 40 CFR Part 80 Subpart H; Part 85; Part 86 USEPA ’s Tier 2 fleet averaging program for on

- road vehicles, modeled after the California low emitting vehicles (LEV) II standards, became effective in the 2005 model y ear. The Tier 2 program allows manufacturers to produce vehicles with emissions ranging from relatively dirty to very clean, but the mix of vehicles a manufacturer sells each year must have average NO X emissions below a specified value. The program focuses especially on NO x , because that is where the largest air quality gains can be achieved ; however, it also reduces VOC and otherNevada Regional Haze 5

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emissions

. Mobile emissions continue to benefit from this program as motorists replace older, more polluting vehicles with clea ner vehicles.

Non

- road Mobile Diesel Emissions Program

– 40 CFR Part 89 USEPA adopted standards for emissions of NO x , hydrocarbons, and carbon monoxide from several groups of non

- road engines, including industrial spark

- ignition engines and recreational

no n

- road vehicles. Industrial spark

- ignition engines power commercial and industrial applications and include forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and construction applications. Non

- road recreational vehic les include snowmobiles, off

- highway motorcycles, and all

- terrain vehicles. These rules were initially effective in 2004 and were fully phased in by 2012. Mobile emissions continue to benefit from this program as motorists replace older, more polluting veh icles with cleaner vehicles.

The non

- road diesel rule set s standards that reduced emissions by more than 90 percent from

non

- road diesel equipment and, beginning in 2007, the rule reduced fuel sulfur levels by 99 percent from previous levels. The reductio n in fuel sulfur levels applied to most non

- road diesel fuel in 2010 and applied to fuel used in locomotives and marine vessels in 2012.
Maximum Achievable Control Technology (MACT) Programs

– 40 CFR Part 63 Chapter Six of Nevada’s 2009 RH SIP discusses reasonable progress for Jarbidge WA

, including a discussion of emissions reductions due to existing air pollution control measures and specifically

, in section 6.5.2.1

, emissions reductions resulting from the implementati on of f ederal rules. Although s ection 6.5.2.1 claims emissions from various MACT programs were incorporated into the PRP18a emission inventory, further review of two documents 2 prepared for the WRAP by their contractor, Eastern Research Group (ERG), indic ate that MACT emission reductions from WRAP sources were not estimated. ERG concluded that credible estimates of the MACT impacts could not be developed based on readily available information and that substantial effort would be required to gather the nec essary data.

This finding does not affect the outcome of the visibility modeling, or the selection of Nevada’s reasonable progress goal

. Rather, implementation of the MACT programs and their co

- benefits will further reduce emissions from the subject sou rces beyond the WRAP’s projection.

2.3.2 New Federal Measures

New federal programs will provide further reductions in visibility

- impairing pollutants , either as a result of direct control requirements or as co

- benefit s . These reductions were not considered i n the development of the WRAP’s PRP18a future year emissions estimates. Any additional emission reduction benefits achieved by the implementation of these requirements will help

2 ERG, 2006, WRAP Point and Area Source Emissions Projections for the 2018 Base Case Inventory, Version 1

, available at http://wrapair.org/forums/ssjf/documents/eictts/docs/WRAP_2018_EI

- Version_1

- Report_Jan2006.pdf (last viewed 6/2/2014) and ERG, 2007, WRAP 2018 Pre liminary Reasonable Progress Emission Inventory

– Final, Revised , available at http://wrapair.org/forums/ssjf/documents/eictts/Projections/PRP18_EI_ tech%20memo_061607.pdf (last viewed 6/2/2014).Nevada Regional Haze 5

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ensure that all Class I areas in the WRAP region meet their reasonable progre ss goals in a timely

manner. Mercury and Air Toxi c s Rule On December 16, 2011, USEPA finalized national CAA standards to reduce mercury and other toxic air pollution from coal and oil

- fired power plants. 77 FR 9304 (Dec. 16, 2011)

. The final rule established power plant emission standards for mercury, acid gases, and non

- mercury metallic toxic pollutants that will prevent 90 percent of the mercury in coal

- fired power plants from being emitted to the air; reduce acid gas emissions from power plants by 88 percent ; and cut power plant SO 2 emissions by 41 percent beyond the reductions expected by the Cross

- State Air Pollution Rule . These reductions are expected in the 2016 time frame.

2010 S O 2 National Ambient Air Quality Standards On June 2, 2010, US EPA strengthened the SO 2 national ambient air quality standards ( NAAQS ) by revising the primary SO 2 standard to 75 parts per billion ( ppb ) averaged over one hour. This short term standard is significantly more stringent than the revoked standards of 140 p pb averaged over 24 hours and 30 ppb averaged over a year. On August 5, 2013, USEPA designated planning areas with monitoring data from the years 2009 to 2011 indicating violations of the new standard as nonattainment. 78 FR 47191 (August 5, 2013)

. Under the CAA, these areas are required to attain the NAAQS as expeditiously as practicable

, but no later than five years after designation. USEPA has indicated that it will designate t he remaining areas once it has collected sufficient monitoring or mode ling data on which to base a designation. 3 79 FR 27446 (May 13, 2014)

. Additionally, the new standard must be taken into account when permitting new or modified major sources of SO 2 emissions such as fossil

- fuel fired power plants. Any reductions in SO 2 emissions brought about by the 2010 SO 2 NAAQS will enhance protection of visibility in federal C lass I areas.

2010 NO 2 National Ambient Air Quality Standards O n January 22, 2010, USEPA established an additional primary standard for NO 2 at 100 ppb, averaged over one hour

, while retaining the annual standard. 75 FR 6474 (Jan. 22, 2010)

. Along with the new standard, USEPA set new requirements to monitor NO 2 levels near major road ways. Once the new monitoring network has collected three years of data , USEPA will redesignate areas in 2016 or 2017, as appropriate, based on the new data. Areas designated nonattainment will be required to reduce emissions to attain the NAAQS within a prescribed time. Additionally, the new standard must be taken into acco unt when permitting new or modified major sources of NO x emissions

, such as fossil

- fuel fired power plants, boilers, and a variety of other manufacturing operations. Any reductions in NO x emissions brought about by the 2010 NO 2 NAAQS will enhance protecti on of visibility in federal C lass I areas.

2012 PM 2.5 National Ambient Air Quality Standards

3 USEPA’s failure to promulgate area designations by the deadlines set forth in the CAA is in litigation as of May 2014. Several states, including Nevada, are pushing for tighter designation deadlines, as re quired by the Act.Nevada Regional Haze 5

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On Dec ember 14, 2012, USEPA strengthen ed the annual NAAQS for fine particles to 12.0 micrograms per cubic meter. 78 FR 3086 (Dec. 14, 2012)

. Emission reductions from US EPA and states ’ rules already on the books will help 99 percent of counties with monitors to meet the revised PM 2.5 standards without additional emission reductions. These rules include clean diesel rules for vehicles and fuels, and rules to reduce pollution from power plants, locomotives and marine vessels, among others. Additionally, the new standard must be taken into account when permitting new or modified major sources of PM 2.5
. North American Emission Control Areas On Marc h 26, 2010, the International Maritime Organization officially designated waters off North American coasts as an area in which stringent international emission standards will apply to ships. These standards will reduce air pollution from ships and deliver air quality benefits that extend hundreds of miles inland. In 2020, USEPA expects emissions from ships operating in the designated area to be reduced by 320,000 tons for NO x , 90,000 tons for PM 2.5 , and 920,000 tons for SO 2 , which is 23 percent , 74 percent , and 86 percent , respectively, below predicted levels in 2020 absent the Emissions Control Area designation.
Implementation of the Emission Control Area means that ships entering the designated area are required to use compliant fuel for the duration of t heir voyage that is within that area, including time in port as well as voyages whose routes pass through the area without calling on a port. The requirements for quality of fuel change over time. From the effective date in 2012 until 2015, the sulfur co ntent of fuel used by all vessels operating in designated areas cannot exceed 10,000
ppm. Beginning in 2015, the sulfur content of fuel used by vessels operating in these areas cannot exceed 1,000 ppm. With regard to NO x emissions, marine diesel engines installed on a ship constructed on or after January 1, 2011, must comply with the Tier 2 standard. Marine diesel engines installed on a ship constructed on or after January 1, 2015, will be required to comply with the more stringent Tier 3 NO x standard.

T ier 3 Vehicle Emission and Fuel Standards Program The Tier 3 program is part of a comprehensive approach to reducing the impacts of motor vehicles on air quality and public health and builds on USEPA ’s Tier 2 program

. The program considers the vehicle and its fuel as an integrated system, setting new vehicle emissions standards and lowering the sulfur content of gasoline beginning in 2017. The vehicle standards will reduce both tailpipe and evaporative emissions from passenger cars, light

- duty trucks, medium

- duty passenger vehicles, and some heavy

- duty vehicles. The gasoline sulfur standard will enable more stringent vehicle emissions standards and will make emissions control systems more effective.



### 2.4 State Measures other than BART
In addition to federal programs and Nevada BART (discussed in the next section) , there are other

s tate measures that contribute to attaining Nevada’s 2018 reasonable progress goal

. As set forth in detail below, s ome noteworthy changes in Nevada since the 2009 RH SIP submittal includeNevada Regional Haze 5

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power plant closures and cancellations; legislation mandating a reduction in coal

- fired power plant emissions; stronger renewable energy portfolio requirements; and attainment of the NAAQS throughout the s tate

.

2.4.1 Closures and Cancellations
The PRP18a future year emissions estimate included emissions from power plants that have since been closed, as well as projected future power plants that are no longer viable. The Southern California Edison Mohave Generating Station (Mohave) located near the southern tip of Clark County, Nevada, was a coal

- fired plant with 19,595 tons per year ( tpy ) of NO x and 8,701 tpy of SO 2 included in the 2018 emission inventory. This power plant ceased operation on December 31, 2005 and has since been fully decommissioned and demolished

. Its operating permit was officially cancelled on April 9, 2010

. This closure eliminated the largest combined source of SO 2 and NO x emissions in the s tate

. Appendix B, Section 1.
Five proposed power plants were included in the projected emissions inventory for 2018

. S ee Chapter Three , section 3.4.1

. Of the five, only two have moved forward and are now operational. The largest coal

- fired power plant application, White Pine Energy Associates /LS
Power
, was withdrawn

. The power plant designated as “Future Coal EGU (A)” in the PRP18a regional modeling was considered a surrogate for the Sithe Global Toquop Energy Project ( located 14 miles northwest of Mesquite); its application was also withdrawn

. Finally, Sempra Energy and NV Energy withdrew their applications for natural gas and coal

- fired plants, respectively, at Copper Mountain and the Ely Energy Center (the latter is not in T able 3

- 1 and was not included in the 2018 projected emissions inventory)

. Appendix B, Section 1.

2.4.2 Emissions from Coal

- Fired Power Plants
In 2013, t he Nevada Legislature enacted S enate B ill 123 (SB123) , which establishes requirements for the reduction of emissions from coal

- fired electric generating plants i n Nevada. The new law requires major utilities in Clark County to submit a plan for the retirement of 8 0 0 MW of capacity from coa l

- fired power plants and replace that with renewable energy facilities and other electric generating plants

. NRS 704.7316

. The legislation mandates the retirement or elimination of not less than 300 MW of coal

- fired capacity on or before December 31, 2014; an additional 250 MW on or before December 31, 2017; and an additional 250 MW on or before December 31, 2019. It further requires the construction or acquisition of 350 MW from new renewable energy facilities. The utility must issue r equests for p roposal s for 100 MW of new renewable supp ly by December 31, 2014; 100 MW by December 31, 2015; and 100 MW by December 31, 2016. An additional 50 MW of new renewable energy capacity, owned and operated by the electric utility

, must be complete d by December 31, 2021. Finally, the utility

must con struct or acquire and own facilities with a total capacity of 550 MW to replace the coal

fired capacity eliminated between 2014 and 2019.

The major electric public utilit y serving Clark County is the Nevada Power Company d/b/a NV Energy

. NV Energy submitted its Emissions Reductions and Capacity Replacement plan (ERCRNevada Regional Haze 5

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Plan) to the Public Utilities Commission of Nevada on May 1, 2014

. Appendix B , Section 3.3

. The ERCR Plan was developed pursuant to SB 123 , and is designed to meet the requirement to eliminate 300 MW by December 2014 by retir ing units 1, 2 and 3 at the Reid Gardner Generating Station ( Reid Gardner ) near Moapa in Clark County, Nevada. These units have a capacity of 100 MW each. The fourth unit at Reid Gardner has a capacity of 2 57 MW and is scheduled to be retired by December 31, 2017. This elimination of coal

- fired capacity from Reid Gardner will result in the reduction of 1,758 tons of SO 2 and 8,893 tons of NO x from the PRP18a inventory during the 2008

- 2018 regional haze planning period.

2.4.3 Renewable Portfolio
Nevada was one of the first states to adopt a renewable portfolio standard. The standard establishes a schedule requir ing each provider of electric service in Nevada to generate, acquire

or save a certain percentage of its elec tricity ( sold to customers ) from renewable energy systems or efficiency measures

. NRS 704.7821

. For calendar years 2015 through 2019, inclusive, not less than 20 percent must come from renewable energy or efficiency measures. For calendar
year 2025 and for each calendar year thereafter, the percentage increases to 25 percent

. However, the 25 percent must be solely from renewable energy, not energy efficiency measures.

The Nevada Legislature enacted the “ Solar Energy Systems Incentive Program, ” which requires the Public Utilities Commission of Nevada to set incentive levels and schedules, with a goal of approving solar energy systems totaling at least 250,000 kilowatts (250 MW) of capacity in this State for the period beginning on July 1, 2010, and ending on December 31, 2021. NRS 701B.005 and NRS 701B.010

- 290

. To date, $160 million has been spent installing a total of 38 MW of installed capacity in Nevada

. Appendix B , Section 1 .7

. Similarly, Nevada has a “ Solar Thermal Demonstrations Program, ” which has the goal of promoting th e installation of at least 3,000 solar thermal systems in homes, businesses, schools and other governmental buildings throughout this State by 2019

. Appendix B , Section 1 .7

. NRS 701B.300

- 345

. The “ Wind Energy S ystems Demonstration Program” establishes a goal of installing at least 5 MW of wind energy systems by 2012. NRS

- 701B.400

- 650

. To date, $25 million has been spent installing a total of 9 MW of installed capacity in Nevada. The “ Waterpower Energy Systems Demonstration Program ” similarly provides for the installation of at least 5 MW of waterpower energy systems in Nevada by 2016. NRS

- 701B.700

- 880

. To date, $1.4 million has been spent constructing a total of 600 kW of in stalled capacity in the State. Appendix B, Section 1 .7

. Table 2

- 1 itemizes new and proposed generation plants in Nevada as of December 2013

. It is noteworthy that all of the generation comes from renewable sources.

Table 2

- 1 . New and Proposed Generation Plants in Nevada as of December 2013

OWNER PLANT

NAME COUNTY SUMMER CAPACITY (MW) ENERGY

SOURCE ACTUAL OR

PROPOSED ONLINE DATE STATUS

Sempra Energy Copper

Mountain 2 Clark 58 MW Sun Dec. 2014 Under ConstructionNevada Regional Haze 5

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OWNER PLANT

NAME COUNTY SUMMER CAPACITY (MW) ENERGY

SOURCE ACTUAL OR

PROPOSED ONLINE DATE STATUS

NVT Licenses, LLC Spectrum

Solar Clark 30 MW Sun Sept. 2013 Permitting

Gradient Resources Patua Phase I Churchill 30 MW Geothermal Nov. 2013 Under Construction

Ormat Wild Rose Mineral 16 MW Geothermal Dec. 2013 Under Construction Tonopah Solar Energy, LLC Crescent

Dunes Solar Nye 110 MW Sun Dec. 2013 Under Construction

NextEra Energy Mountain

View Solar Clark 8 MW Sun Feb. 2014 Permitting

Ormat McGinness

Hills Expansion Lander 48 MW Geothermal July 2016 PPA Pending PUCN Approval

Sempra Energy Copper

Mountain 3 Clark 250 MW Sun Dec. 2016 Under Construction
K Road Moapa Solar LLC K

- Road Clark 250 MW Sun Dec. 2015 Permitting

First Solar Energy LLC Silver State

Solar Power South Clark 250 MW Sun May 2017 Permitting

*PPA means P ower P urchase A greement Source: State of Nevada Public Utilities Commission http://puc.nv.gov/Utilities/Electric/Generation/ (last viewed 9/8/2014).

Furthermore, t he Public Utilities Commission of Nevada has authorized the largest electric and gas utilities serving nearly 95 percent of the population in the State to expend substantial monies to implement various energy efficiency programs (Appendix B , Section 1 .7 ) :
1. Nevada Power Company d/b/a NV Energy

– $44

, 550,000 (2013). 2. Sierra Pacific Power Company d/b/a NV Energy

– $6,100,000 (2013/electric). 3. Sierra Pacific Power Company d/b/a NV Energy

– $445,000 (2014/gas).
4. Southwest Gas Corporation

– $4,400,000 (2014).

2.4.4 State Implementation Plans

The 2009 RH S IP included a table showing the status of nonattainment areas in Nevada

. 2009 RH SIP Table 6

- 2. For each nonattainment area, the air control agency with jurisdiction developed and implemented a state implementation plan with control measures to bring the area into attainment of the NAAQS. Currently, all nonattainment areas in Nevada have either been redesignated attainment and are operating under a maintenance plan or have been granted a “determination of attainment”, indicating that the area is attaining the standard even though it has not yet been redesignated ( Table 2

- 2 ). The c ontrol measures remain in place. These includeNevada Regional Haze 5

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fugitive dust regulations , oxygenated fuel programs , gasoline vapor recovery, transportation control measures, residential wood burning regulations, woodstove replacement programs and the S tate Alternative Fueled Vehicle program

. Table 2

- 2

. Nonattainment Area s: Redesignation Status as o f August 2014

PLANNING AREA (Hydrographic Area) NONATTAINMENT DATE REDESIGNATIONS

Carbon Monoxide
Lake Tahoe Basin (HA90) 3/3/78 USEPA approved 12/15/03; effective 2/13/04 Las Vegas Valley (HA212) 3/3/78 and 11/15/90 USEPA approved 9/27/10; effective 9/27/10 Truckee Meadows (Reno

, HA87) 3/3/78 and 11/15/90 USEPA approved 7/3/08

Ozone

Washoe County 1/6 / 92 (1

- hr) and 1/16/01 (1

- hr) 6/15/05 1

- hr NAAQS revoked; USEPA approved maintenance plan 1/18/08; effective 3/18/08
Clark County 9/13/04 (8

- hr) USEPA approved 1/8/13; effective 2/7/13

PM 10 Las Vegas Valley (HA212) 11/15 / 90 clean data finding 8/3/10; USEPA proposed approval 7/21/14
Truckee Meadows (Reno) (HA87) 11/15/90 Request submitted 7/13/09; clean data finding 4/19/11

SO 2 Central Steptoe Valley (HA179M) 3/3/78 USEPA approved 4/12/02; effective 6/11/02



### 2.5 Review of BART Determinations
The WRAP’s PRP18a future year emissions estimate included presumptive SO 2 BART limits for coal

- fired EGUs with capacity greater than 750 MW. For Nevada sources, the presumptive limits were not applied to the two candidate facilities, Mohave and Reid Gardner . Actual SO 2 emissions from Reid Gardner were below the presumptive em ission limit, so actual emissions were modeled

. Mohave wa s subject to a consent decree with a n SO 2 emission limit equal to the presumptive limit ; however, it has since been decommissioned

. 4 No other emissions reductions resulting from the installation of BART at Nevada sources were included in the PRP18a inventory or resulting modeled reasonable progress goal

.
2.5.1 Nevada’s BART Implementation

Table 2

- 3 presents the current status of BART implementation in Nevada

. The 2009 RH SIP requires that control measures will be installed and operating by January 1, 2015, with the

4 The Mohave Generating Station has ceased all operations related to the generation of electricity from burning coal. NDEP approved Southern California Edison’s request to terminate its Air Quality Operating Permit (No. AP4911

- 0774) on A pril 9, 2010. Appendix B, Section s 1 .1 and 1.2

.Nevada Regional Haze 5

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exception of NO x at Reid Gardner, which has a later compliance date

. Therefore, IMPROVE monitoring data for this progress period will not reflect emissions reductions resulting from the implementation of BART in Nevada.
All of the facilities in Nevada that are subject to BART requirements are on schedule to meet the requirements by January 1, 2015; the compliance date for NO x at Reid Gardner is June 30, 2016

, but Units 1, 2 and 3 are expected to be retired before then . In fact , some of the BART controls

are already be ing met as of February 2014: baghouses have been installed at Reid Gardner and the use of fuel oil has been eliminated at Fort Churchill Generating Station (Fort Churchill )

. Appendix B
, Section 1 .8

. Furthermore, NV Energy has approval from the Public Uti lities Commission of Nevada to retire Tracy Units 1 and 2 by the 2009 RH SIP compliance date

. Appendix B, Section s 1 .8 and 3.1

. In April 2013 , NV Energy was granted approval to implement alternative equivalent control technology for BART and supplemental control technology for Unit 3 at Tracy and Units 1 and 2 at Fort Churchill . This option is allowed under the 2009 RH SIP and Nevada Administrative Code. The control measures will be installed and operating by the compliance date to assure continuous c om pliance with the BART emission limits. No change to the BART emission limitations was proposed or approved. The approval of proposed alternative BART control technology and installation of approved alternative BART control technology for Tracy and Fort Churchill is detailed in Appendix B, Section 2

. For more information on the future status of the subject

- to

- BART units at Reid Gardner, see Section 2.4.2

, Emissions from Coal

- F ired Power Plants

. Table 2

- 3 . BART Implementation Status

Facility Emission

Unit BART Emission Limits

(lb/MMBtu) SIP

Required Control Date BART

Controls Implemented Comments NO x (12

- month rolling average) SO 2

(24

- hour average) PM 10

(3

- hour average)

NV Energy Tracy Generating Station 1 0.15 0.05 0.03

Jan. 1, 2015 ▪ Currently

firing exclusively with natural
gas

▪ No other new controls installed recently Units 1 and 2 did

not operate during 2010 to 2012. NV Energy has stated its intent to retire these units by December 31, 2014. 2 0.12 0.05 0.03

3 0.19 0.05 0.03 LNB and supplemental OFA, if needed ; retrofit scheduled for Fall 2014. NV Energy Fort 1 0.20 0.05 0.03 Jan. 1, 2015 ▪ Currently

firing LNB and

supplementalNevada Regional Haze 5

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Facility Emission

Unit BART Emission Limits

(lb/MMBtu) SIP

Required Control Date BART

Controls Implemented Comments NO x (12

- month rolling average) SO 2

(24

- hour average) PM 10

(3

- hour average)

Churchill Generating Station exclusively with natural
gas

▪ No other new controls installed recently OFA, if needed ;

retrofit scheduled for Spring 2014

2 0.16 0.05 0.03 LNB and supplemental OFA, if needed ; retrofit scheduled for Summer 2014

NV Energy Reid Gardner Generating Station 1 0.20 0.015 0.015 SO 2 and PM 10 controls by Jan. 1, 2015. NO x controls by June 30, 2016 ▪ Baghouses

(pulse

- jet fabric filter) installed by April 15, 2009

▪ No other new controls installed recently ▪ Shutdown of

Units 1, 2, and 3 called for in SB123.

▪ In May 2014, NV Energy applied for PUCN approval to shutdown these units in Dec 2014. 2 0.20 0.15 0.015

3 0.28 0.15 0.015

Southern California Edison Mohave Generating Station 1

- NA

- - NA

- - NA

-

- NA

- - NA

Facility ceased operations Dec 31, 2005. Permit terminated April 9, 2010. Facility has been fully decommissioned. 2

- NA

- - NA

- - NA

2.5.2 Adjacent States’ BART Implementation

The IMPROVE monitor (JARB1) representative of Jarbidge WA is situated on the northern flank of the Jarbidge Mountains less than 10 miles south of the Idaho border and within the Snake River Basin. This location topographically isolates the monitor from pollutants emitted in the rural Nevada portions of the Grea t Basin, but provides for monitoring of pollutants emitted and transported from the well

- populated Snake River Plain largely located in Idaho . Source apportionment modeling conducted for Nevada’s initial RH SIP (see Section 4.3) reveals that only 45 perce nt of the sulfate contributions to visibility impairment at JARB1 are emitted from sources in the entire WRAP region. However, source apportionment modeling did identify substantial contributions from Idaho and Oregon point sources. The NDEP reviewed the BART implementation status of subject

- to

- BART facilities in these nearby states with their air agency staff as discussed below.

Idaho According to Mike Edwards, SIP and Maintenance Plan Analyst for the Air Quality Division of the Idaho Department of En vironmental Quality (phone conversation with Frank Forsgren,Nevada Regional Haze 5

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NDEP, on February 19, 2014), t wo facilities in Idaho were subject to BART : Amalgamated Sugar Company in Nampa (also known as TASCO

- Nampa) and Monsanto/P4 Production, LLC in Soda Springs ( http://www.deq.idaho.gov/air

- quality/air

- pollutants/haze.aspx ). For the Monsanto/P4 facility , no technicall y feasible NO x controls were identified for the two subject units and no new BART NO x controls were required. F or SO 2 , the existing lime

- concentrated dual alkali scrubber, installed in 2005 with a control efficiency of roughly 97 percent was determined to be BART, as were the existing PM 10 controls (see section 10.6 of Idaho’s regional haze SIP available at the link above). Therefore, BART has been fully implemented at the Monsanto/P4 facility.
The BART process for the TASCO Nampa faci lity has had a more complex history. The EPA approved a BART determination based on Idaho’s original 2010 RH SIP submittal, but Idaho submitted a revised BART determination in its 2012 RH SIP submittal. The 2012 submittal also included a n SO 2 BART altern ative measure , which EPA fully approve d ( 79 FR 23273 ( April 28, 2014 ) ) with a compliance date of July 22, 2016. BART consists of low NO x burners ( LNBs ) for NO x control and the existing baghouse for PM 10 control on the one subject

- to

- BART boiler, while the SO 2 BART alternative consists of imposing NO x emission limits on two non

- BART boilers coupled with the permanent shutdown of three non

- BART coal

- fired pulp dryers. In addition, unless the LNBs have been installed by the compliance date, the subject boile r may be fired only using natural gas and may not be fired with coal until the LNBs are installed and operated.
Oregon Only o ne facility in Oregon was subject to a BART determination : the PGE Boardman Power Plant (Boardman) . F ive other facilities chose the option of a federally enforceable permit condition exempting them from BART determinations. According to Mark Fisher, a p ermit

w riter for the Oregon Department of Environmental Quality Eastern Region Office in Bend

, Oregon, Boardman installed new LNBs with a modified over

- fire air system during 2011 and is currently meeting the BART NO x emission limitations (phone conversation with Frank Forsgren, NDEP, on February 26, 2014)

. Boardman completed install ation of BART SO 2 contr ols consisting of a semi

- dry flue gas desulfurization system in early 2014 and is expected to be in compliance with the BART SO 2 emission limitation when it resumes operation later in 2014. The compliance date for the BART SO 2 controls is July 1, 2014. C ompliance with a further reduced BART SO 2 emission limit is required by July 1, 2018

, and the facility must permanently cease burning coal by no later than December 31, 2020.
In summary, in this Chapter

, Nevada has described the implementation status of measures from Nevada’s 2009 RH SIP, including the status of control measures to meet BART requirements, the status of significant measures resulting from USEPA regulations, as well as measures that came in to effect since the WRAP analyses for the 2009 RH SIP were completed.