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 NOx and SO2 Emission Reductions..................................................................... 2

3.3 NOx and SO2 Emission Reductions from Federal Programs............................................ 2

3.4 EGU NOx and SO2 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............................................................................. 4
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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 toward achieving Nevada’s reasonable 

progress goal. SO2 and NOx emissions have decreased substantially in Nevada due to the 

implementation of these control measures and other noteworthy changes in source activity. 

Emission 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. Since the baseline 

inventory, Nevada has reduced EGU emissions of SO2 by more than 40,000 tons and emissions 

of NOx by more than 37,000 tons. SO2 point source emissions alone decreased by 78 percent 

between the baseline and 2008 inventories, while NOx point source emissions decreased by over 

50 percent. The majority of these decreases 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 SO2 and 

NOx emissions since the shutdown, as well. 

3.2 Overall NOx and SO2 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, specifically the

reduction of controllable 

anthropogenic emissions of SO2 and 

NOx. Since the submittal of Nevada’s 

RH SIP in November 2009, the most 

significant decrease in emissions of 

SO2 and NOx has resulted from the 

closure of the Mohave. Other 

reductions 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 NOx and SO2 Emission Reductions from Federal Programs

Emission reductions will be seen as a result of several federal programs. However, these 

emissions are not easily quantified. As described in Chapter Two, these federal programs 

include: 

 The Heavy-Duty Highway regulation, which focused on reducing PM, NOx, and nonmethane hydrocarbons from new heavy duty engines. It also mandated a reduction in

51.308(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 NOx. 

 The Tier 2 Vehicle and Gasoline Sulfur Program, which requires average NOx 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 focuses on reducing emissions 

of NOx, hydrocarbons and CO. This rule set standards that reduced emissions by more 

than 90 percent with full implementation by 2012. Beginning 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. As 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 sheer number of programs.

 The Mercury and Air Toxics Rule, which was finalized 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 SO2, NO2 and PM2.5 NAAQS. The SO2 and NO2

NAAQS were both revised in 2010 to add a 1-hour standard. Additionally, the annual 

PM2.5 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 NOx and SO2 Emission Reductions due to State Measures other than 

BART

3.4.1 Emission Reductions due to Closures and Cancellations

As discussed in Section 2.4.1, the 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 NOx and 8,701 tpy of SO2. Emissions from Mohave represented 19 

percent of the projected PRP18a statewide SO2 emissions and 14 percent of projected statewide 

NOx emissions. 

Five proposed power plants were also included in the projected PRP18a inventory (Table 3-1), 

however, three of these proposed plants withdrew their permit applications. The SO2 and NOx
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emissions projected for the three plants were 5,814 tons and 6,136 tons, respectively. 

Additionally, the two power plants that began operating actually emitted fewer total tons per year 

of NOx, PM10 and SO2 combined than was projected. The two plants operated at a combined 

total of 472 tons of NOx and 244 tons of SO2 for 2012. This is 766 tons of NOx and 431 tons of 

SO2 less than projected for the PRP18a inventory. Total emissions of SO2 and NOx

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 and Current Permit Activity (shading indicates the project 

was withdrawn)

PROPOSED EGUS IN 2018 EMISSION INVENTORY (PRP18a)

NOx

(tpy)

PM10

(tpy)

SO2

(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 Associates/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 EGUs are 

presented in Table 3-2. EGU emissions are consistently reported and tracked in the USEPA’s 

Air Markets Program Database for permitted Title V facilities in the state.

http://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 NOx and SO2 for Nevada EGU 

sources between 1995 and 2013, 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. The 
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CAMD data show a sharp decline for SO2 and NOx between 2005 and 2006, mainly due to the 

closure of the Mohave Generating Station in Clark County, eliminating approximately 20,000 

tpy of NOx and 41,000 tpy of SO2 emissions. Further discussion later in this section details the 

continued decreases in NOx and SO2 at Reid Gardner, Fort Churchill and Tracy, three of

Nevada’s subject-to-BART facilities. Table 3-2 shows that since the closure of Mohave on 

December 31, 2005, SO2 emissions have continued to decline, while NOx emissions have 

decreased by over 10,000 tpy. 

Table 3-2. Nevada Acid Rain CAMD Data - Annual EGU Emissions of SO2 and NOx

Reporting 

Year

SO2 (tpy) NOx (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)
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Figure 3-1. EGU Emissions of SO2 and NOx Reported 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 case 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 SO2 and NOx, 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 subject-to-BART. 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 

SO2 and 924 tpy of NOx. If Unit 4 were to be retired by December 2017 (Appendix B, Section 

3.3), this would result in an additional decrease in SO2 of 533 tpy and NOx of 924 tpy. In 

contrast, emission projections for the PRP18a inventory for Reid Gardner were 1,758 tons of SO2

and 8,893 tons of NOx. The closure of these units will eliminate all emissions of SO2 and NOx. 

Nevertheless, even without the closures, there has been a steady decrease in SO2 and NOx

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 Mohave
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Figure 3-2. CAMD Acid Rain Database SO2 EGU Emissions for Reid Gardner 1995 - 2013

Figure 3-3. CAMD Acid Rain Database NOx EGU Emissions for Reid Gardner 1995 - 2013

Figure 3-4 and Figure 3-5 show CAMD Acid Rain data for SO2 and NOx, respectively, at Tracy 

for years 1995 through 2013. Units 1, 2 and 3 are presented here because these units were 

identified as being subject-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 the energy 

crisis and high natural gas prices, Tracy combusted significant amounts of residual fuel oil in 
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2001, and all three units ran a significant number of hours during that year. Appendix B, Section 

1.8. This resulted in greater than 2,500 percent increase in SO2 emissions from 2000 to 2001. In 

2002, after the energy crisis, SO2 emissions dropped back to levels seen in 1999, a decrease of 99 

percent. For NOx, emissions increased seven percent from 2000 to 2001 and decreased by 52 

percent from 2001 to 2002. 

Tracy Units 1 and 2 will be retired by the end of 2014, and BART upgrades at Unit 3 will not 

allow for the continued use of oil-firing capacity beyond December 31, 2014. Appendix B, 

Sections 3.1 and 3.2.

Figure 3-4. CAMD Acid Rain Database SO2 EGU Emissions at Tracy 1995 - 2013
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Figure 3-5. CAMD Acid Rain Database NOx EGU Emissions at Tracy 1995 - 2013

Figure 3-6 and Figure 3-7 represent CAMD Acid Rain data for SO2 and NOx at Fort Churchill (a 

peaking plant) for Units 1 and 2 for years 1995 through 2013. Like Tracy, the Western Energy 

Crisis affected fuel use at Fort Churchill. Fort Churchill combusted 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 SO2 and NOx are shown in both figures for 2001. This resulted in 

more than a 2,000 percent increase in SO2 emissions and a 38 percent increase in NOx emissions

from 2000 to 2001. 

In 2002, after the energy crisis, Fort Churchill reverted to primarily using pipeline natural gas, 

resulting in significant decreases in both SO2 (74 percent) and NOx (16 percent) below 1999 

emission levels. Beginning in 2007, there was a notable decline in fuel oil use at Fort Churchill; 

in 2007, fuel oil was used a total of only 14 hours in Units 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 Units 1 and 2 will not allow for the continued use of oil-firing capacity beyond December 31, 

2014. Appendix B, Section 3.2. As can be seen in Figure 3-6 and Figure 3-7, there has been a 

steady decrease in SO2 and NOx emissions since the baseline period. 
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Figure 3-6. CAMD Acid Rain Database SO2 EGU Emissions at Fort Churchill 1995 - 2013

Figure 3-7. CAMD Acid Rain Database NOx EGU Emissions at Fort Churchill 1995 - 2013

In summary, Nevada has shown evidence of a decrease in emissions of SO2 and NOx 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.