Nevada Regional Haze 5-Year Progress Report, November 2014 2-1

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 ................................................................ 12
Nevada Regional Haze 5-Year Progress Report, November 2014 2-2

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). 

Additional reductions will be gained by the implementation of Nevada Best Available Retrofit 

Technology (BART) regulations and other state measures. The federal measures incorporated in 

the 2018 projected emission estimates have all been enacted and are in full effect. The existing 

state 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 generating unit (EGU) emissions and 

stronger renewable energy portfolio requirements. The 2018 emission projections also included 

a large coal-fired power plant that has since ceased operations and been decommissioned, and

three proposed power plants whose permit applications have been withdrawn (Appendix B, 

Section 1). These actions have led to substantial reductions in both the actual and projected 

emissions of visibility-impairing pollutants from Nevada sources. 

Finally, several new and proposed federal and state 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 Visibility 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 State. 

Visibility modeling was used to 

determine the expected 2018 visibility 

improvements for the Jarbidge WA

resulting from existing federal and 

state regulations, including 

presumptive SO2 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 planning 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 aligns closely with the 2018 uniform rate of progress value for Jarbidge WA.
Nevada Regional Haze 5-Year Progress Report, November 2014 2-3

This chapter focuses on anthropogenic emission sources and describes the emission reduction 

measures that were included in the 2018 projected emission inventory modeling effort. The 

status and associated benefits of these controls and regulations are discussed below. The

benefits are quantified where possible in Chapter Five. This chapter also discusses significant 

federal and state emission reduction measures that were not included in the 2018 inventory,

including the status of existing and future expected controls for Nevada’s EGUs. Finally, the 

status of the implementation of BART, both in Nevada and in adjacent states, 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 (NOx) 

and non-methane hydrocarbons of 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These diesel 

engine NOx 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 year. 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 NOX

emissions below a specified value. The program focuses especially on NOx, because that is 

where the largest air quality gains can be achieved; however, it also reduces VOC and other 
Nevada Regional Haze 5-Year Progress Report, November 2014 2-4

emissions. Mobile emissions continue to benefit from this program as motorists replace older, 

more polluting vehicles with cleaner vehicles.

Non-road Mobile Diesel Emissions Program – 40 CFR Part 89

USEPA adopted standards for emissions of NOx, hydrocarbons, and carbon monoxide from 

several groups of non-road engines, including industrial spark-ignition engines and recreational 

non-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 vehicles 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 vehicles with cleaner vehicles. 

The non-road diesel rule sets 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 reduction 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 implementation of federal 

rules. Although section 6.5.2.1 claims emissions from various MACT programs were 

incorporated into the PRP18a emission inventory, further review of two documents2prepared for 

the WRAP by their contractor, Eastern Research Group (ERG), indicate 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 necessary 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 sources 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-benefits. These reductions were not considered in 

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 Preliminary 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-Year Progress Report, November 2014 2-5

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

manner. 

Mercury and Air Toxics 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 SO2 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 SO2 National Ambient Air Quality Standards 

On June 2, 2010, USEPA strengthened the SO2 national ambient air quality standards (NAAQS)

by revising the primary SO2 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 ppb 

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 the remaining areas once it 

has collected sufficient monitoring or modeling 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 SO2 emissions such as fossil-fuel fired power 

plants. Any reductions in SO2 emissions brought about by the 2010 SO2 NAAQS will enhance

protection of visibility in federal Class I areas.

2010 NO2 National Ambient Air Quality Standards

On January 22, 2010, USEPA established an additional primary standard for NO2 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 NO2 levels near major 

roadways. 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 account when permitting new or 

modified major sources of NOx emissions, such as fossil-fuel fired power plants, boilers, and a 

variety of other manufacturing operations. Any reductions in NOx emissions brought about by 

the 2010 NO2 NAAQS will enhance protection of visibility in federal Class I areas.

2012 PM2.5 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 required by the Act.
Nevada Regional Haze 5-Year Progress Report, November 2014 2-6

On December 14, 2012, USEPA strengthened the annual NAAQS for fine particles to 12.0 

micrograms per cubic meter. 78 FR 3086 (Dec. 14, 2012). Emission reductions from USEPA 

and states’ rules already on the books will help 99 percent of counties with monitors to meet the 

revised PM2.5 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 PM2.5. 

North American Emission Control Areas

On March 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 NOx, 90,000 tons for PM2.5, and 920,000 tons 

for SO2, 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 their 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 content 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 NOx 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 NOx standard.

Tier 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 

state measures that contribute to attaining Nevada’s 2018 reasonable progress goal. As set forth 

in detail below, some noteworthy changes in Nevada since the 2009 RH SIP submittal include 
Nevada Regional Haze 5-Year Progress Report, November 2014 2-7

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 state.

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 NOx and 

8,701 tpy of SO2 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 SO2 and NOx emissions in the state. Appendix B, Section 1.

Five proposed power plants were included in the projected emissions inventory for 2018. See 

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 Table 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, the Nevada Legislature enacted Senate Bill 123 (SB123), which establishes 

requirements for the reduction of emissions from coal-fired electric generating plants in Nevada.

The new law requires major utilities in Clark County to submit a plan for the retirement of 800 

MW of capacity from coal-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 requests for proposals for 100 MW of new 

renewable supply 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 completed by December 31, 2021. Finally, the utility 

must construct or acquire and own facilities with a total capacity of 550 MW to replace the coalfired capacity eliminated between 2014 and 2019.

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

Energy. NV Energy submitted its Emissions Reductions and Capacity Replacement plan (ERCR 
Nevada Regional Haze 5-Year Progress Report, November 2014 2-8

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 retiring 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 257 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 SO2 and 8,893 tons of NOx 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 requiring each provider of electric service in Nevada to generate, acquire 

or save a certain percentage of its electricity (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 the 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 Systems 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 installed 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 Construction
Nevada Regional Haze 5-Year Progress Report, November 2014 2-9

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 Power Purchase Agreement

Source: State of Nevada Public Utilities Commission http://puc.nv.gov/Utilities/Electric/Generation/ (last viewed 

9/8/2014).

Furthermore, the 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 SIP 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 control measures remain in place. These include
Nevada Regional Haze 5-Year Progress Report, November 2014 2-10

fugitive dust regulations, oxygenated fuel programs, gasoline vapor recovery, transportation 

control measures, residential wood burning regulations, woodstove replacement programs and

the State Alternative Fueled Vehicle program. 

Table 2-2. Nonattainment Areas: Redesignation Status as of 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

PM10

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

SO2

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 SO2 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 SO2

emissions from Reid Gardner were below the presumptive emission limit, so actual emissions 

were modeled. Mohave was subject to a consent decree with an SO2 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 

 

4The 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 April 9, 2010. Appendix B, Sections 1.1 and 1.2.
Nevada Regional Haze 5-Year Progress Report, November 2014 2-11

exception of NOx 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 NOx 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 being 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 Utilities 

Commission of Nevada to retire Tracy Units 1 and 2 by the 2009 RH SIP compliance date. 

Appendix B, Sections 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 compliance 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-Fired Power Plants.

Table 2-3. BART Implementation Status

Facility

Emission 

Unit

BART Emission Limits

(lb/MMBtu)

SIPRequired 

Control 

Date

BART 

Controls 

Implemented Comments

NOx

(12-month 

rolling 

average)

SO2

(24-hour 

average)

PM10

(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 

supplemental 
Nevada Regional Haze 5-Year Progress Report, November 2014 2-12

Facility

Emission 

Unit

BART Emission Limits

(lb/MMBtu)

SIPRequired 

Control 

Date

BART 

Controls 

Implemented Comments

NOx

(12-month 

rolling 

average)

SO2

(24-hour 

average)

PM10

(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 SO2 and 

PM10

controls 

by Jan. 1, 

2015. 

NOx

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- -NAFacility ceased 

operations Dec 31, 

2005. Permit 

terminated April 9, 

2010. Facility has 

been fully 

decommissioned.

2 -NA- -NA- -NA2.5.2 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 Great 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 percent 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 Environmental Quality (phone conversation with Frank Forsgren, 
Nevada Regional Haze 5-Year Progress Report, November 2014 2-13

NDEP, on February 19, 2014), two 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 technically feasible NOx controls were identified for the two subject 

units and no new BART NOx controls were required. For SO2, 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 PM10 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 facility 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 an SO2 BART alternative measure, which EPA fully approved (79 FR 23273 (April 28, 

2014)) with a compliance date of July 22, 2016. BART consists of low NOx burners (LNBs) for 

NOx control and the existing baghouse for PM10 control on the one subject-to-BART boiler, 

while the SO2 BART alternative consists of imposing NOx 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 boiler may be 

fired only using natural gas and may not be fired with coal until the LNBs are installed and 

operated. 

Oregon

Only one facility in Oregon was subject to a BART determination: the PGE Boardman Power 

Plant (Boardman). Five other facilities chose the option of a federally enforceable permit 

condition exempting them from BART determinations. According to Mark Fisher, a permit 

writer 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 NOx emission limitations (phone conversation with Frank Forsgren, 

NDEP, on February 26, 2014). Boardman completed installation of BART SO2 controls 

consisting of a semi-dry flue gas desulfurization system in early 2014 and is expected to be in 

compliance with the BART SO2 emission limitation when it resumes operation later in 2014. 

The compliance date for the BART SO2 controls is July 1, 2014. Compliance with a further 

reduced BART SO2 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 into effect since the WRAP analyses for the 2009 RH SIP were completed.