Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 1

3 

# Chapter Three

– Summary of Emission Reductions Achieved (40 CFR 51.308(g)(

2 ))

Table of Contents

3.1 Status Summary

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

3.2 Overall NO x and SO 2 Emission Reductions

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

3.3 NO x and SO 2 Emission Reductions from Federal Programs

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

3.4 EGU NO x and SO 2 Emission Reductions due to State Measures other than BART

........ 3

3.4.1 Emission Reductions due to Closures and Cancellations

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

3.4.2 Emission Reductions from EGUs

................................ ................................ ............. 4Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 2



### 3.1 Status Summary
Chapter Three discusses the emission reductions achieved as a result of implementation of control measures outlined in Nevada’s 2009 RH SIP to ward achieving Nevada’s reasonable progress goal

. SO 2 and NO x emissions have decreased substantially in Nevada due to the implementation of these control measures and other noteworthy changes in source activity

. Emissio n reductions have occurred in Nevada as a result of implementation of federal and state measures, closure of a large coal

- fired power plant , as well as the withdrawal of permit applications that were included in the original 2018 emissions inventory. Sinc e the baseline inventory, Nevada has reduced EGU emissions of SO 2 by more than 40,000 tons and emissions of NO x by more than 37,000 tons. SO 2 p oint source emissions alone decreased by 78 percent between the baseline and 2008 inventories , while NO x point source emissions decreased by over 50 percent. The majority of th e s e decrease s were due to the closure of the Mohave Generating Station , but as can be seen in Figure 3

- 1 , there has been a steady continued decrease in SO 2 and NO x emissions since the shutdown , as well

.


### 3.2 Overall NO x 

### and SO 2 

### Emission Reductions

40 CFR 51.308(g)(2) requires “[ a ] summary of the emissions reductions achieved throughout the State through implementation of the measures described in paragraph (g)(1 ) ” and discussed in Chapter Two of this progress report. This chapter discusses the emission reductions due to these control measures

, spe cifically the reduction of controllable anthropogenic emissions of SO 2 and NO x . Since the submittal of Nevada’s
RH SIP in November 2009, the most significant decrease in emissions of SO 2 and NO x h as result ed from the closure of the Mohave

. Other reductio ns stem from federal and state programs, cancellations of proposed coal

- fired power plants

, and BART upgrades at the Tracy and Fort Churchill power plants.



### 3.3 NO x 

### and SO 2 

### Emission Reductions from Federal Programs

Emission reductions will be seen as a result of several federal programs. However, these emissions are not easily qua ntified

. As described in Chapter Two, these federal programs include:

 The Heavy

- Duty Highway regulation

, which focused on reducing PM, NO x , and non

methane hydrocarbons from new heavy duty engines. It also mandated a reduction in 5 1.308(g) . . . Periodic progress reports
must contain at a minimum . . .

(2 ) A summary of the emissions reductions achieved throughout the State through implementation of the measures described in paragraph (g)(1) of this section.Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 3

sulfur content in fuel by 97 percent. These regulations were phased in between 2006 for sulfur and 2007 for NO x .

 The Tier 2 Vehicle and Gasoline Sulfur Progr am , which requires average NO x emissions below a specified limit on the mix of vehicles that a manufacturer sells each year and realizes a reduction in VOC and other emissions, as well

.

 The Non

- road Mobile Diesel Emissions Program , which focus e s on reducin g emissions of NO x , hydrocarbons and CO. This rule set standards that reduced emissions by more than 90 percent with full implementation by 2012. B eginning in 2007 , the rule also reduced the level of sulfur in non

- road diesel fuel by 99 percent with full implementation by 2012.

 Maximum Achievable Control Technology Programs

. A s noted in Chapter Two , these
programs were not estimated as part of the PRP18a emission inventory due to the substantial effort required to gather necessary data. However, these MACT programs will result in a reduction of emissions beyond projections that were made for the 2018 inventory. These programs are difficult to quantify due the sh eer number of programs.

 The Mercury and Air Toxics Rule , which was finaliz ed by USEPA in December 2011 to reduce mercury and air toxics from coal and oil

- fired power plants. USEPA projects that this rule will also reduce sulfur emissions from power plants

. These emission reductions are expected by 2016.

 Revised NAAQS, including the SO 2 , NO 2 and PM 2.5 NAAQS. The SO 2 and NO 2 NAAQS were both revised in 2010 to add a 1

- hour standard

. Additionally, the annual PM 2.5 NAAQS was strengthened in 2012. These new and revised standards must be taken into account when permitting new or modified major sources resulting in additional reductions in emissions of these pollutants.

 The Tier 3 Vehicle Emission and Fuel Standards Program , which imposes stronger tailpipe and evaporative emissions standards, as well as a lower sulfur content for gasoline. These tighter standards will result in lower sulfur emissions from motor vehicles beginning in 2017.



### 3.4 EGU NO x 

### and SO 2 

### Emission Reductions due to State Measures other than
BAR T

3.4.1 Emission Reductions due to Closures and Cancellations

As discussed in S ection 2.4.1, t he PRP18a inventory included estimates of emissions from Mohave, which was permanently closed at the end of 2005. This closure resulted in the elimination of 19,595 tpy of NO x and 8,701 tpy of SO 2 . Emissions from Mohave represent ed 19 percent of the projected PRP 18 a statewide SO 2 emissions and 14 percent of projected statewide NO x emissions

. Five proposed power plants were also included in the projected PRP18a inventory ( Table 3

- 1 )
, however, t hree of the se proposed plants withdrew their permit application s . The SO 2 and NO xNevada Regional Haze 5

- Year Progress Report, November 2014 3

- 4

emissions projected for the three plants were 5,814 tons and 6,136 tons, respectively

. Additionally , the two power plants that beg a n operating actually emitted fewer total tons per year of NO x , PM 10 and SO 2 combined than was projected. The two plants operated at a combined total of 472 tons of NO x a nd 244 tons of SO 2 for 2012

. This is 766 tons of NO x and 431 tons of SO 2 less than projected for the PRP18a inventory

. Total emissions of SO 2 and NO x overestimated in the PRP18a inventory from these five power plants was 14,946 tons and 26,497

tons , respectively. These reductions would certainly result in lower modeled visibility impacts for the 2018 plan year, particularly at Class I areas adjacent to southern and eastern Nevada.

Table 3

- 1

. Proposed 2018 EGUs a nd Current Permit Activity (shading indic ates the project was withdrawn)

PROPOSED EGUS IN 2018 EMISSION INVENTORY (PRP18a) NO x (tpy) PM 10 (tpy) SO 2

(tpy)

Future Coal EGU (Newmont TS Power Plant, 241 MW

- Northern Nevada Energy) ( actual 2012 emissions ) 499 ( 254 ) 89

( 189 ) 670

( 213 ) Future Natural Gas EGU (Copper Mountain

- Sempra Energy) 887 71 6
Future Natural Gas EGU (Chuck Lenzie , 1,102 MW

- NV Energy) ( actual 2012 emissions ) 739 ( 218 ) 59

( 185 ) 5

( 31 ) Future Coal EGU (White Pine Energy Associat es /LS Power) 3,909 670 4,356 Future Coal EGU (A) 1,340 261 1,452
Total Emissions from proposed 2018 EGUs 7,374 1,150 6,489
2018 Emissions Reductions due to Cancellations 6,136 5,814 5,814

Source: Modified from Table 3

- 5 in Nevada Regional Haze State Implementation Plan

, October 2009 (2009 RH SIP), page 3

- 8.

3.4.2 Emission Reductions from EGUs To account for year

- to

- year changes in emissions, annual emission totals for Nevada EGU s are presented in Table 3

- 2

. EGU emissions are consistently reported and tracked in the US EPA’s Air Markets Program Database for permitted Title V facilities in the s tate

. htt p://ampd.epa.gov/ampd/

, last viewed 9/ 2/ 2014

. RHR implementation plans are required to pay specific attention to certain major stationary sources, including EGUs, built between 1962 and 1977.

Table 3

- 2 and Figure 3

- 1 depict annual EGU emissions of NO x and SO 2 for Nevada EGU sources between 1995 and 201 3
, as reported in USEPA’s Clean Air Markets Division (CAMD) Acid Rain Program . While these types of facilities are targeted for controls in state RH SIPs, it should be noted that many of the controls planned for EGUs in the WRAP states had not taken place yet in 2010, while other controls separate from the RHR may have been implemented. TheNevada Regional Haze 5

- Year Progress Report, November 2014 3

- 5

CAMD data show a sharp decline for SO 2 and NO x between 2005 and 2006, mainly due to the closure of the Mohave Generating Station in Clark County, eliminat ing approximately 20,000 tpy of NO x and 41,000 tpy of SO 2 emissions. Further discussion later in this section details the continued decreases in NO x and SO 2 at Reid Gardner, Fort Churchill and Tracy, three of Nevada’s s ubject

- to

- B ART f acilities. Table 3

- 2 shows that s ince the closure of Mohave o n December 31, 2005, SO 2 emissions have continued to decline , while NO x emissions have decreased by over 10,000 tpy

.
Table 3

- 2 . Nevada Acid Rain CAMD Data

- Annual EGU Emissions of SO 2 and NO x
Reporting Year SO 2 (tpy) NO x (tpy) Reporting Year SO2 (tpy) NOx (tpy)

1995 50,262 39,249 2005 53,346 43,242

1996 53,234 45,054 2006 9,239 19,985

1997 50,153 43,886 2007 8,545 18,405

1998 49,813 47,822 2008 9,365 16,306

1999 48,673 41,806 2009 7,913 12,514

2000 53,203 46,492 2010 7,889 10,812

2001 54,688 44,262 2011 5,272 7,598

2002 49,240 44,871 2012 4,691 5,832

2003 49,719 40,880 2013 7,427 7,796

2004 54,564 42,781
Source: USEPA Air Markets Program Database ( http://ampd.epa.gov/ampd/

, last viewed 9/2 /2014)Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 6

Figure 3

- 1

. EGU Emissions of SO 2 and NO x R eported in the CAMD Acid Rain Database between 1995 and 2013

Reid Gardner and Tracy are baseload power plants. Baseload plants are the production facilities used to meet some or all of a region’s continuous energy demand. They produce energy at a constant rate and typically run at all times of the year except in c ase of repairs or scheduled maintenance. Fort Churchill is a peaking plant. Peaking power plants generally run only when there is a high demand for electricity.

Figure 3

- 2 and Figure 3

- 3 present CAMD Acid Rain data for SO 2 and NO x , respectively, at Reid Gardner from 1995 through 2013

. Data from Units 1, 2 and 3 are shown here, as they were the units that were identified as s ubject

- to

- B ART

. These units are scheduled to be retired by December 31, 2014

. Appendix B, Section 3.3

. Assuming emission levels based on the most recent year of Acid Rain data (2013), this would result in the immediate reduction of 721 tpy of SO 2 and 924 tpy of NO x . If Unit 4 were to be retired by December 2017 ( Appendix B, Section 3.3 )
, t his w ould result in an additional decrease in SO 2 of 533 tpy and NO x of 924 tpy

. In contrast, e mission projections for the PRP18a inventory for Reid Gardner were 1,758 tons of SO 2 and 8,893 tons of NO x . T he closure of these units will eliminate all emissions of SO 2 and NO x . Nevertheless, even without the closures

, there has been a steady decrease in SO 2 and NO x emissions since the baseline period

.

0 10,000 20,000 30,000 40,000 50,000 60,000 Tons per Year 

## Annual EGU Emissions in Nevada

SO2 (tpy)
NOx (tpy) Decrease due to shutdown of MohaveNevada Regional Haze 5

- Year Progress Report, November 2014 3

- 7

Figure 3

- 2

. CAMD Acid Rain Database SO 2 EGU Emissions for Reid Gardner 1995

- 2013

Figure 3

- 3

. CAMD Acid Rain Database NO x EGU Emissions for Reid Gardner 1995

- 2013

Figure 3

- 4 and Figu re 3

- 5 show CAMD Acid Rain data for SO 2 and NO x , respectively, at Tracy for years 1995 through 2013. Units 1, 2 and 3 are presented here because these units were identified as being s ubject

- to

- BART.

The Western U.S. Energy Crisis of 2000

- 2001 resulted in a shortage of electricity supply caused by a shortage of generating capacity, bottlenecks in related markets, wholesale generator market power, regulatory missteps, and faulty market design

. Weare 2003. Responding to th e energy crisis and high natural gas prices , Tracy combust ed significant amounts of residual fuel oil inNevada Regional Haze 5

- Year Progress Report, November 2014 3

- 8

2001, and all three un its ran a significant number of hours during that year

. Appendix B, Section 1.8. This resulted in greater than 2,500 percent increase in SO 2 emissions from 2000 to 2001. In 2002
, after the energy crisis, SO 2 emissions dropped back to levels seen in 1999 , a decrease of 99 percent. For NO x , emissions increased seven percent from 2000 to 2001 and decreased by 52 percent from 2001 to 2002.

Tracy U nits 1 and 2 will be retired by the end of 2014, and BART upgrades at U nit 3 will not allow for the continued use of oil

- firing capacity beyond December 31, 2014

. Appendix B, Section s 3.1 and 3.2

.

Figure 3

- 4

. CAMD Acid Rain Database SO 2 EGU Emissions at Tracy 1995

- 2013Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 9

Figu re 3

- 5

. CAMD Acid Rain Database NO x EGU Emissions at Tracy 1995

- 2013

Figure 3

- 6 and Figure 3

- 7 represent CAMD Acid Rain data for SO 2 and NO x at Fort Churchill ( a peaking plant ) for U nit s 1 and 2 for years 1995 through 2013. Like Tracy, the Western Energy Crisis affected fuel use at Fort Churchill. Fort Churchill combust ed a significant amount of residual fuel oil and ran many hours over historical use in 2001

. Appendix B, Section 1 .8. Anomalously high values of SO 2 and NO x are shown in both figures for 2001. This resulted in more than a 2,000 percent increase in SO 2 emissions and a 38 percent increase in NO x emissions from 2000 to 2001

.
In 2002
, after the energy c risis, Fort Churchill reverted to primarily using pipeline natural gas, resulting in significant decreases in both SO 2 (74 percent) and NO x (16 percent) below 1999 emission levels. B eginning in 2007

, there was a notable decline in fuel oil use at Fort Chu rchill ; i n 2007, f uel oil was used a total of only 14 hours in U nit s 1 and 2

. Since 2007
, the sole source of fuel has been from pipeline natural gas. Appendix B, Section 1.8. Essentially, conversion to pipeline natural gas has already been implemented at Fort Churchill. Moreover
, BART upgrades

at U nit s 1 and 2 will not allow for the continued use of oil

- firing capacity beyond December 31, 2014

. Appendix B, Section 3. 2

. A s ca n be seen in Figure 3

- 6 and Figure 3

- 7
, there has been a steady decrease in SO 2 and NO x emissions since the baseline period.Nevada Regional Haze 5

- Year Progress Report, November 2014 3

- 10

Figure 3

- 6

. CAMD Acid Rain Database SO 2 EGU Emissions at Fort Churchill 1995

- 2013

Figure 3

- 7

. CAMD Acid Rain Database NO x EGU Emissions at Fort Churchill 1995

- 2013

In summary, Nevada has shown evidence of a decrease in emissions of SO 2 and NO x due to control measures implemented per Nevada’s 2009 RH SIP
, the closure of an entire coal

- fired power plant and other State measures

. In addition, future reductions will occur due to anticipated closure of specific EGUs.