Region 9

Overview of EPA Proposal

N j G ti St ti Navajo Generating Stati

Plans to Red ce Plans to Reduce Emissions of Nitrogen O i

Emissions of Nitrogen Oxi

Improve Visibility at Federally Protected Na

Parks Affected by NGS

Location Place DateLeChee, Navajo Nation LeChee Chapter House November 12Page, Arizona Page High School November 12Kykotsmovi, Hopi Tribe Hopi Day School November 13Phoenix, Arizona Phoenix Convention Center November 14Phoenix, Arizona Phoenix Convention Center November 14Tucson, Arizona Pima Community College –

West Campus

November 15
Region 9

Why are we here today

• To hear your comments on two EPA propos

requiring NGS to reduce emissions of nitrogoxides (NO )x and the visibility impairment it 

at National Parks and Wilderness Areas

• The purpose of this presentation is to briefly The purpose of this presentation is to briefly

describe

– What we proposed What we proposed– Why we proposed it– How y pp ou can submit comments on these prop
Region 9

I t f Fl t h Insert map from Fletcher
Region 9

Why are we evaluating NGS

• Congress required EPA to improve visibility a

National Parks and Wilderness Areas (Class 

– Regional Haze Program Regional Haze Program

• Large, old sources of air pollution that affect 

in Class I areas must be evaluated to determin Class I areas must be evaluated to determ

new air pollution controls should be required Available Retrofit Technology – BART)

• NGS affects visibility at 11 Class I areas, incl

Grand Canyon and Canyonlands National Pa

i bj t t th BART i t f th R is subject to the BART requirement of the Re

Haze Program 
Region 9

How do we improve visibili

• Air pollutants (for example, particles and gases like N

form particles) cause regional haze

• By reducing emissions of air pollutants that cause ha

By reducing emissions of air pollutants that cause ha

improve visibility 

• The same pollutants that impair visibility are a conce

human health therefore reducing haze also improves human health, therefore reducing haze also improves 

• In general, states evaluate whether new controls sho

required for all facilities that are subject to BART requ

through State Implementation Plans

• The Navajo Nation EPA has not sought to develop a 

Imp , 

lementation Plan for NGS, therefore EPA is deve

Federal Implementation Plan to implement BART
Region 9

How is BART determined

• BART is determined based on a 5-Factor ana• Factor 1 – How much would controls cost?• Factor 2 – Are there energy, economic, or oth

environmental impacts of the controls?

• Factor 3 – What are the existing controls at th• Factor 4 – What is the remaining useful life of 

facility?

• Factor 5 – What are the anticip y ated visibility

improvements from adding controls?
Region 9

EPA’s Proposals

• Based on our BART analysis, EPA has propo

new controls at NGS to reduce NOx emission

– are cost are cost-effective effective, 

– and would reduce the visibility impairment caused 

11 Class I areas.

– Please see poster for a more detailed discussion 

factor analysis

• We also proposed two Alternatives that provi

We also proposed two Alternatives that provi

additional flexibility (Alternative 1 and an Altefrom the Technical Work Group ) on NGS) as 

than BART”
Region 9

( )

Why can EPA Propose an Altern

• The Regional Haze Rule (RHR) requires eith

BART or an alternative measure that will ach

greater reasonable progress than BART greater reasonable progress than BART

(Alternatives must be better than BART)

• EPA is proposing to determine that Alternativ

EPA is proposing to determine that Alternativ

the TWG Alternative will achieve greater emreductions than our BART proposal (both are 

th BART) than BART)

• EPA is using our authority and discretion un

CAA d EPA l ti t t d th CAA and EPA regulations to extend the com

timeframe for Alternatives to BART 
Region 9

1st Proposal (February 5, 20

• Proposed to require NGS to comply with an emissi

for nitrogen oxides (NOx) of 0.055 lb/MMBtu within 

fina ue l r l

• This limit can be met with selective catalytic reduct

in combination with low NOx burners with separate

air (LNB/SOFA) installed and operated on all 3 unitair (LNB/SOFA) installed and operated on all 3 unit

• We also proposed an Alternative to BART (Alterna

credits NGS for early ( installation of LNB/SOFA (in 

2011) and proposes flexibility in the compliance da– 2023)

• Total emissions reductions under Alternative 1 are 

Total emissions reductions under Alternative 1 are 

than under our BART proposal (Better than BART) 
Region 9

2nd Proposal (October 22, 2

• B d Alt ti t BART t f th b th T h 

Based on Alternative to BART put forth by the Tech

Work Group on NGS (TWG Alternative)

• TWG Alternative sets a cap in total TWG Alternative sets a cap in total NO emissions 

x emissions 

2009-2044 and calls for closure of 1 unit by end of curtailment of electricity generation), and installatio

by end of 2030 on two units to meet limit of 0 07 lb/by end of 2030 on two units to meet limit of 0.07 lb/

• Two current owners (Los Angeles Department of W

Power and NV Energy) intend to divest from NGS bPower and NV Energy) intend to divest from NGS b

due to state law in CA and NV

• The 2009-2044 NOx cap ensures total emissions fr

Alternative are less than under BART (TWG Altern

better than BART) 
Region 9

To make Oral Comments: Fill out a Speaker R

How can I comment?

• To make Oral Comments: Fill out a Speaker R

Form and put it in the Speaker Box at the Re

Table

• To make Written Comments: 

– Fill out a comment form and put it in the Fill out a comment form and put it in the Comme

Comme

the Registration Table 

– Mail or e-mail comments to Anita Lee:

• 75 Hawthorne Street; US EPA (Air-2); San Francisco• Email: r9ngsbart@epa.gov

• The Comment Period Ends January 6
Region 9

What happens after January 6, 

• EPA will review and consider all comments 

making a final decision

• We will respond to all substantive comment

writing and incorporate any changes to the as a result of comments in our final decision as a result of comments in our final decision

• When we make a final decision, we will not

email those individuals who registered on themail those individuals who registered on th

in Sheets and provided an email address

Documents will also be posted on the EPA 

• Documents will also be posted on the EPA 

website and in our docket for this rulemakin