Nevada Regional Haze 5

- Year Progress Report, November 2014 D

- 1



# APPENDIX D

Evidence of Public Participation; Public Comments and Nevada’s ResponsesNevada Regional Haze 5

- Year Progress Report, November 2014 D

- 2 This page is left intentionally blank.Nevada Regional Haze 5

- Year Progress Report, November 2014 D

- 3 

### CONTENTS

D. 1 Evidence of Public Participation

................. ........ ...................... .................... .. .......1

D. 1.1 Notice of Public Hearing

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

D. 1. 2 Notice of Cancellation of Hearing

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

D. 1. 3 Newspap er Affidavits

........................................................................ . ....................5

D. 1. 4 SIP Approval Authority........................................................................................ ..8



### D .2 Public Comment s and Ne vada’s Responses...................................................... .9

D.2. 1 Nevada’s Response...........

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

D.2.2 Sierra Club

- National Parks Conservation Association

C omments

.............. ................... .................................................................................. 32Nevada Regional Haze 5

- Year Progress Report, November 2014 D

- 4 This page is left intentionally blank.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 1 

### SECTION D.1

E VIDENCE OF PUBLIC PARTICIPATIONNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 2 

### D.1 . 1 Notice of Public Hearing

Pursuant to the public hearing r equirements in Title 40 of the Code of Federal Regulations Part 51 section 102, the Nevada Division of Environmental Protection (NDEP) is issuing the following notice.

In 1977, Congress amended the Clean Air Act (CAA) establishing a national goal to prote ct visibility in
Class I federal areas

– primarily national parks and wilderness areas. The amendments called for the “prevention of any future, and the remedying of any existing, impairment of visibility in mandatory class I Federal areas which impairmen t results from manmade air pollution.” Nevada has one mandatory Class I area, the Jarbidge Wilderness Area, in the northeast corner of the state managed by the U.S. Forest Service.

In 1999, the U.S. Environmental Protection Agency (USEPA) adopted the Re gional H aze Rule (RHR) requir ing each affected state to develop and adopt a plan to improve the haziest days and protect the clearest days at each mandatory Class I area in the state with a goal of returning to natural visibility conditions by the year 206 4. The NDEP prepared a R egional H aze state implementation plan ( SIP ) to meet the requirements of the federal rule and submitted it to USEPA on November 18, 2009

. The RHR further requires periodic progress reports every five years after the initial SIP is submitted. The NDEP has prepared a draft “Nevada Regional Haze 5

- Year Progress Report” (Report) to meet the requirements of the federal rule. The Report will be submitted to the USEPA by November 18, 2014.

The draft Report and related m aterials are a vailable on the NDEP website at: http://ndep.nv.gov/admin/public.htm#air_qp or http://ndep.nv.gov/baqp/index.htm . Access to
the draft report may also be obtained by contacting Adele Malone at NDEP, 901 S. Stewart Street, Suite 4001, Carson City, NV 89701; (775) 687

- 9356; or e

- mail to amalone@ndep.nv.gov

.

Persons wishing to comment on the draft 5

- ye ar progress report during the comment period or to request a public hearing should submit their comments or request in writing either in person, by postal service, or fax to Adele Malone at the NDEP address above , or by FAX at (775) 687

- 6396. A request fo r a hearing must be received by October 6 , 2014. Written comments will be received by the NDEP until 5:00 PM PST, October 15, 2014 and will be retained and considered.

Upon receipt of a valid written request, the NDEP will hold a public hearing in Carson City on:

October 15, 2014 10:00 am to 12:00 pm Great Basin Conference Room, 4 th Floor

- South

901 South Stewart Street Carson City, Nevada NOTICE OF PUBLIC COMMENT PERIOD BEGINNING
SEPTEMBER 15, 2014 AND A PUBLIC HEARING ON
OCTOBER 15, 2014, IF REQUESTED

Conducted by the Nevada Division of Environmental Protection

Bureau of Air Quality PlanningNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 3 An agenda will be posted on the NDEP web site at least 3 working days prior to the hearing. Oral

comments will be r eceived at the Hearing. If no request for a public hearing is received by October

6 , 2014, the hearing will be cancelled. Persons may check on the status of the hearing on the NDEP
web site at http://ndep.nv.gov/admin/public.htm#air_qp , or you may call the NDEP Bureau of Air Quality Planning at (775) 687

- 9349.

This notice has been published in the Las Vegas Review

- Journal and the Reno Gazette Journal newspapers. It has been posted at the ND EP offices in Carson City and Las Vegas, at the State Library in Carson City and at County libraries throughout Nevada. Members of the public who are disabled and require special accommodations or assistance at the hearing are requested to notify Adele Ma lone (775

- 687

- 9356) no later than 3 full working days before the hearing. 9 / 10 /2014Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 4 

### D.1 .2 Notice of Cancellation of Hearing



### NOTICE OF CANCELLATION OF PUBLIC HEARING ON OCTOBER 15, 2014

Nevada Division of Environmental Protection Bureau of Air Qu ality Planning

Pursuant to the public hearing provisions in Title 40 of the Code of Federal Regulations Part 51

section 102, the Nevada Division of Environmental Protection (NDEP) is cancelling the following

public hearing because no request for a hear ing was received:

October 15, 2014

10: 0 0 a.m. to 12:00 p.m.

Great Basin Conference Room, 4 th Floor

901 South Stewart Street

Carson City, Nevada

The draft Nevada Regional Haze 5

- Year Progress Report and related m aterials are available on the

NDEP website at http://ndep.nv.gov/admin/public.htm , click on “Air Quality Planning.” Persons

may also check on the status of Nevada’s regional haze progress report by telephone at (775) 687

-

9356.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 5 

### D.1 . 3 Newspape r AffidavitsNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 6Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 7Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 8 

### D.1. 4 SIP Approval AuthorityNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 9 

### SECTION D. 2

PUBLIC COMMENTS AND NEVADA’S RESPONSESNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 10 On September 15, 2015, the Nevada Division of Environmental Protection (NDEP) opened a 30

- day public comm ent period on the draft Nevada Regional Haze 5

- Year Progress Report (Progress Report) with the opportunity for a public hearing in Carson City to be held upon public request. Pursuant to the public hearing provisions in Title 40 of the Code of Federal Reg ulations (CFR) Part 51 section 102, the NDEP cancelled the public hearing as no request for a hearing was received.

The NDEP received one set of written comments during the 30

- day public comment period ending October 15, 2014. The single set of comment s had signatories from the Sierra Club and National

Parks Conservation Association and will be referred to as the non

- governmental organization (NGO) comments in the remainder of this document. The NGO letter in its entirety follows the NDEP’s response be low

.



### D.2. 1 Nevada’s Response

SUMMARY OF COMMENTS

The NGO comments focus on the basis of Nevada’s negative declaration that emissions management measures in the 2009 RH SIP are being implemented on schedule and visibility improvement appears to be con sistent with reasonable progress goals. Specifically

, the NGO

comments focus on the following :

 The perceived need for a modeling demonstration that the significant emissions reductions

that have and will occur at numerous EGUs in the State have significant visibility impacts
on the Jarbidge Wilderness Area (Jarbidge WA) ;

 The assertion that Nevada’s progress evaluation is based on a reasonable progress goal that
purportedly used a flawed modeling analysis and an outdated emission invento ry;

 The NGO’s contention that v isibility monitoring data do not show that the Jarbidge WA is
on a path consistent with the reasonable progress goals; and

 The NGO’s conclusion that Nevada should revise its haze plan to include new strateg ies to
improve the progress towards remedying visibility impairment at the Jarbidge WA

NEVADA’S RESPONSE

The NDEP respon d s first to the general NGO comments as presented on the first two and half pages

of the comment letter and summarized above, and then to the four specific comments detailed in the

remainder of the letter.

General Comments

The NDEP appreciates the NGO ’s thorough review of Nevada’s Progress Report and their comments. However, the NGO comments overlook some of the basic facts and science supporting

Nevada’s Progress Report . The NDEP maintains that the Progress Report fulfills every requirement

set forth in the Regional Haze Rule (RHR) using the best data available at the time the report wasNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 11 written. T he report documents the first five years of progress for a 60

- year planning horizon. 40

CFR 51

. 308(d)(1)(i)(B). Nevada will submit a full SIP revision in 2018 with an evaluation of progress likely informed by Regional Planning Organization ( RPO ) ph otochemical grid modeling for visibility assessment and source apportionment.

The NDEP emphasizes that thre e

- quarters of visibility impairing emissions i n Nevada are emitted by natural (non

- anthropogenic) sources. 2009 RH SIP, Table 3

- 2. The Progress Report focuses on the major sources of anthropogenic emissions in Nevada, SO 2 and NO

x . Emissions of SO 2 and NO

x from Nevada point sources have decreased by 78 percent and 50 percent between 2002 and 2008, respectively , with additi onal reductions through 2011

. Progress Report

, Section s 3.1 and 5.5

.

Nevada has one mandatory Class I area, the Jarbidge WA. The Progress Report demonstrates that Nevada’s contribution to visibility impairment at Jarbidge WA is minimal. Five

- year rol ling averages of annual worst days visibility conditions from 2010 to 2012 (2006

- 2010, 2007

- 2011 and

2008

- 2012) show nitrate contributes between 3.5 and 4.2 percent

, and sulfate contributes between 15.1 and 16.6 percent of total l ight extinction on the worst days at JARB1. Progress Report

, Table

4

- 4. Source apportionment modeling ( Table 2 and Table 3 below) shows that i n the worst case

scenario , Nevada NO

x and SO 2 emissions contribut e at most only 0.6 and 0.9 percent , respectively

, to total light extinction at the Jarbidge WA

. 1 When emissions from only point sources are considered, the contributions drop to 0. 3 and 0.6 percent, respectively.

The RHR requires each state to adopt a plan to improve the haziest days and protect the clearest days at each mandatory Class I area in the state . The Progress Report shows that from the baseline to the

progress period

, t here is no degradation of the best days sulfate or nitrate light extinction at the Jarbidge WA. Figure 5, below. Furthermore, n itrate is not impeding worst days visibility progress at the Jarbidge WA

. Five

- year averages of annual worst days visibi lity conditions for nitrate show a persistent downward trend for the last six 5

- year periods and are below the glidepath for nitrate for

the last four 5

- year periods. Progress Report

, Figures 4

- 14 and 4

- 15 ; and Fig ure 3 , below. Five

year averages of annual worst days visibility conditions for sulfate show a persistent downward trend consistent with the sulfate glidepath for the last seven 5

- year periods

, although the averages are above the glidepath. Sig nificantly , three of the last six annual averages are on or below the glidepath for sulfate. Progress Report

, Figures 4

- 12 and 4

- 13 ; and Figure 3

, below. Trend analysis of the 2000 to 2012 nitrate and sulfate annual extinction values demonstrates that the slopes of the trend lines are comparable to (sulfate) or better than (nitrate) the speciated glide slopes for Jarbidge

WA from baseline to n atural conditions

. Progress Report, Section 4.6.

The NGO comments suggest in several places that the significant emissions reductions achieved by Nevada do not equate to visibility improvement at both the Jarbidge WA as well as out

- of

- state
Class I areas

, but fail to present any hard data to substantiate these suggestions. The NDEP presents evidence to the contrary in our responses below. The 2018 regional haze SIP revisions are expected

1 The NDEP calculated Nevada’s contributions to visibility i mpairment at the Jarbidge WA using: 1) the monitoring data for sulfate and nitrate from JARB1; and 2) the WRAP’s nitrate and sulfate source appointment modeling results for

JARB1

. The speciated contribution to the monitored light extinction was multiplie d by Nevada’s percent contribution according to the source apportionment modeling to calculate Nevada’s contribution to sulfate and nitrate light extinction

at JARB1

. Essentia lly, Nevada’s point sources contribute a percentage of a percentage.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 12 to be supported by RPO modeling that will demonstrate how emissions reductions impact visibility impairment and will be the basis to further evaluate reasonable progress goals for the Jarbidge WA and impacts on out

- of

- state Class I areas.

In addition, the USEPA is proceeding with guidance and potential rule changes for the regional

haze SIPs due in 2018. There are indications 2 the guidance and rule changes may include revis ions

to the four

- factor analysis requirement and setting reasonable progress goals based on controllable

emissions . There may also be consideration of a revised regional haze metric to replace the current

metric of the deciview glidepath

, as well as reconsideration of what natural conditions represent.

Specific Comments

NGO Com ment 1 : NDEP Must Revise Its Reasonable Progress Goal f or Jarbidge Wilderness t o Be Based o n the WRAP’s Revised Modeling w ith i ts 2018 PRPB Emissions Projections

.

The NGOs support this comment with observations that Nevada’s reasonable pro gress goal is based on modeling subsequently found to be in error and based on outdated 2018 emission projections.

The y further contend that emissions reductions in Nevada have not been demonstrated to impact or improve visibility at the Jarbidge WA

, and the 2018 projected emission inventory does n o t include emissions for oil and gas development.

NDEP Response:

Page 1

- 6 of the Progress Report discusses Nevada’s rational e for retaining its 2018 reasonable

progress g oal in light of the corrected modeling results noted by the NGO comments. The NDEP evaluated the status of control measures included in the 2009 RH SIP and changes in source activity

that have occurred since then that would affect emissions included in co rrected modeling. The NDEP presents evidence not only of emissions reductions from the control measures included in the 2009 RH SIP, but also further reductions from the full implementation of best available control technology ( BART ) and new state legisla tion. The NDEP notes the 2018 emissions projections included a large power plant that has since be en decommissioned and three proposed power projects that are no longer viable. The Progress Report presents evidence th at 2008 emissions from anthropogenic sources in Nevada are less than the 2018 emissions projections use d by the WRAP in the 2018 visibility modeling. Based on these lines of evidence

, the NDEP concluded that it was appropriate to retain the reasonable progress goal of 11.05 deciviews. The N DEP responds to the four components of this NGO comment below.

Modeling Error Assessment Nevada’s reasonable progress goal is based on the visibility modeling results as captured by the Plan02d and PRP18a emission inventories, which provided the best a vailable information at the

time the 2009 RH SIP was prepared and will be referred to as the original visibility modeling results

in the discussion below

. Note to Readers

, 2009 RH SIP preface (noting cutoff date of January 5,

2 National Association of Clean Air Agencies, Criteria Pollutants Committee September 24, 2014 conference call, agenda item 6 briefing by Rhea Jones, Group Leader, Geographic Strategies Group, Air Quality Policy Division. See

also Inside EPA’s Clean Air Report , Nov ember 6, 2014, page 16.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 13 2009 )

. Modeling results from the PRP18b emission inventory were not available until after this

cutoff date. As noted in the NGO comments, the WRAP memorandum describing the modeling

e rror was released in April 2011

, a year and a half after Nevada submitted its initial regional haze SIP. Therefore, results based on PRP18b and the corrected modeling results were not evaluated for Nevada’s original regional haze SIP.

In response to th is comment, the NDEP evaluated how the visibility modeling results for the Jarbidge WA changed based on use of: 1) the corrected modeling , which is identified as modeling scenario Plan02d_rev, and 2) a second revisio n to the 2018 emissions inventory projections for point and area sources (or updated modeling) in the WRAP region identified as modeling scenario

PRP18b. Table 1 presents the modeling results for the original visibility modeling, the corrected modeling, and the updated modeling.

Table 1 . Comparison of Visibility Modeling Results for the Jarbidge WA

Table 1 shows that visibility impairment, as measured in deciviews, increased by only seven percent due to correction of the modeling error ( i.e., the difference between Plan02d_rev/PRP18a and Plan02d/PRP18a)

, with the greatest extinction increases occurring for elemental carbon (EC) at 32 percent, nearly 20 percent for particulate organic matter (P OM, ) and 1 7 percent for soil . The se increases are primarily the result of non

- anthropogenic emissions. Further, v isibility impairment is only slightly impacted by the emissions inventory update from PRP18a to PRB18b ( i.e., the

difference between Plan02d_rev/PRP18 b and Plan02d _rev /PRP18a) with no change to the haze index and the minor changes to speciated extinction noted in Tabl e 1

.

Based on this evaluation of the modeling results, the NDEP concludes : 1) the correct ed modeling results suggest an increase in visibility impairment at the Jarbidge WA resulting mostly from large

increases in non

- anthropogenic sources ; and 2) modeling based on the updated 2018 emissions projections did not change the visibility impairment as measured in deciviews

, and most speciated extinction values declined slightly with a s light increase in sulfate extinction. Nevada stands by its

evaluation of the status of control measures included in the 2009 RH SIP and the changes that have occurred that would affect emissions included in the 2018 visibility projections

, as well as its decision to retain the reasonable progress goal of 11.05 deciviews.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 14 Emissions Projections As noted in the NGO comments, Nevada used modeling results based on projected 2018 emissions as captured by the PRP18a inventory to identify Nevada’s reasonable progress goal. Since Nevada’s reasonable progress goal was based on the PRP18a inventory, it makes sense to use this inventory as a basis of comparison ( Progress Report

, Table 5

- 1) to determine the emissions reductions achieved through the implement ation of the measures included in Nevada’s 2009 RH SIP. The NDEP also notes that the more refined PRP18b inventory

, while reduc ing emissions from some source categories and increasing others

, does not change the modeled visibility impacts (as

measu red in deciviews) at the Jarbidge WA

, and all speciated light extinction improves with the exception of sulfate extinction (see Table 1 , above).

The NDEP notes that all emission inventories are outdated imme diately upon completion due to the changing nature of sources and their emissions. The PRP18b projections are no exception and do

not reflect the changes noted in the Progress Report.

Impact of Emissions Reductions on Visibility at Jarbidge WA

Th e NGO comments acknowledge the significant reductions of anthropogenic emissions from Nevada sources documented in the Progress Report

, but suggest these reductions do not improve visibility at the Jarbidge WA (i.e., emissions reductions have “ not been sho wn to equate to an improvement in visibility impairment at the Jarbidge Wilderness Area ” ) (NGO comment letter, page 4) . The NGO comments also suggest that projected emissions from facilities that were included in the WRAP modeling inventory (PRP18a) , but ultimately were not constructed

, also have not been shown to impact visibility at the Jarbidge WA because of a lack of single source visibility modeling. T he NGOs do not provide any evidence to su pport these suggestions. The NGOs further fault the NDEP for using PRP18a emissions projections in evaluating the adequacy of its reasonable progress goal.

The NDEP disagrees with this assessment. The RHR was established to address “widespread haze from a multitude of sources which impairs visibility in e very direction over a large area. ” 40 CFR 51.300 (a). The NDEP purports that although Nevada’s point source contribution to haze at Jarbidge WA is small, the significant reductions in SO 2 and NO

x emissions during the progress period are reflected in visi bility improvement at Jarbidge WA.

First, Table 1 above shows no change in visibility impairment at Jarbidge WA, as measured in deciviews, resulting from the update to the 2018 emissions projections. It shows only small decreases in the speciated light extinction, except for a slight increase in light extinction due to

sulfate. T he SO 2 emissions increases and NO

x decreases noted in the April 29, 2009 (revised October 16, 2009) technical memorandum from Eastern Research Group (ERG)

, 3 WRAP PRP18b

Emissio ns Inventory

– Revised Point and Area Source Projections

, may account for the increase in modeled sulfate concentrations and the decrease in modeled nitrate concentrations at the Jarbidge

3 WRAP PRP18b Emissions Inventory

– Revised Point and Area Source Projections. April 29, 2009 (Revised October 16, 2009) . Technical Memorandum from Marty Wolf and Paula Fields, Eastern Research Group, to the WRAP staff. http://www.wrapair.org/forums/ssjf/documents/Pivot_Tables/PRP18b/Final_PRP18b_point_area_source_memo_erg_10 1609_revised.pdf ( last viewed 11/5/2014)Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 15 WA. Table 8e of the ERG memorandum shows an increase in Nevada SO 2 point source emissions of 13,532 tons per year from the PRP18a to PRP18b inventories, as well as a decrease of 8,876 tons per year of NO

x point source emissions. Table 9e shows no changes to the area source inventory for

NO

x or SO 2 , indicating that all of the changes in model results are due to changes in the point source inventory.

The NDEP notes that the emissions changes between PRP18a and PRP18b may not reflect actual changes in facility emissions. The changes were made to address certain changes in projections and

corrections that were identified since the January 2007 revision to the 2018 projection inventory. 4
Note that many of the facilities or units at the facilities listed below were not built, have been or are scheduled to be shut down, or wi ll be converted from coal

- fired to natural gas before 2018. For example, the Ely Energy Center, Toquop and the White Pine Energy Center all modeled with

increases in NO

x and SO 2 in the PRP18b update, however, none of those facilities were permitted;

there fore, the projected increases in emissions are unreal. Progress Report, pages 2

- 7, 2

- 8 and 3

- 3,

3

- 4. In addition , the NO

x and SO 2 decreases for Mohave are underestimates, because they are based on BART limits, whereas the facility was actually shut down a t the end of 2005.

Nevertheless, t he data demonstrate that changes in Nevada’s point source inventory do impact Jarbidge WA. The data in Tables 5 and 6 of the ERG memorandum show increases in SO 2 emissions and significant decreases in NO

x from Reid Gardn er, Fort Churchill, and Tracy, as well as large reductions in NO

x and SO 2 from Mohave, as a result of updates to BART. Additional documentation of the inventory changes between the PRP18a and PRP18b inventories is presented

in the Nevada

– Point Sources t able, which incorporates the changes noted in tables 5 and 6, in

Attachment 1 of the ERG memorandum. The Nevada

– Point Sources table shows:

 NO

x and SO 2 increases for Ely Energy Center, Toquop, TS Power (Newmont Nevada Energy Investment), North Valmy, an d White Pine Energy Center;

 NO

x increases for Graymont Western and Nevada Cement;

 SO 2 increases at Reid Gardner;

 NO

x and SO 2 decreases for Mohave; and

 NO

x decreases for Reid Gardner, Fort Churchill, and Tracy.

These data and the data in Table 1 of this re sponse suggest that emissions reductions from facilities across the state, including those in southern Nevada, do contribute to visibility improvement at the Jarbidge WA, since approximately half of the listed facilities are not located in northern Nevada.

T he WRAP conducted source apportionment modeling that included regional contributions to modeled sulfate and nitrate concentrations at the Jarbidge WA, including emissions from all Nevada point sources. The percent contribution to modeled sulfate on t he worst 20 percent visibility days by region and source category is presented in Table 2 , while the contribution to modeled nitrate for the worst 20 percent visibility days is presented in Table 3

. Table s 2 and 3 show Nevada’s point source emissions contribute 2.7 percent and 3.5 percent to the total modeled sulfate concentration in 2002 and 2018, respectively, and 3.9 percent and 6.3 percent to the to tal modeled nitrate

4 See supra n. 3.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 16 concentration in 2002 and 2018, respectively. 5 Recalling that light extinction due to sulfate

accounts for approximately 15 percent and nitrate for 3.5 percent of total light extinction on worst days at Jarbidge WA (Progress R eport, Table 4

- 4, 2008

- 2012 5

- year average)

, overall c ontributions by Nevada point sources to worst days visibility impairment is about 0.5 percent and 0.2 percent for sulfate and nitrate, respectively. 6 The NDEP contends that the large reductions in point source emissions of SO 2 and NO

x during the progress period do contribute to visibility improvement at the Jarbidge WA; however, Nevada ’s overall point source contribution to light extinction at Jarbidge WA is small, while other source category contributio ns have a larger impact. Clearly, emissions

from the North Valmy Generating Station are not a significant source of visibility impairment at the Jarbidge WA.

Table 2 . Percentage Contribution to Modeled Worst Days Sulfate Concentration at the Jarbidge WA by Source Region and Category for 2002 (plan02c) and 2018 (base18b)

Point Anthro

Fire Mobile Natural Fires

and Biogenics Area Total

2002

Canada 2.3 % 0% 0.2% 0% 1.9% 4.3%

Central US 1.5% 0% 0.2% 0% 0.2% 1.9%

Eastern US 2.6% 0% 0% 0% 0.2% 2.8%

Mexico 2.1% 0% 0% 0% 0.4% 2.6%

Outside Domain * n/a n/a n/a n/a n/a 41.8%

Pacific Offshore 0.8% 0% 0.4% 0% 5.3% 6.6%

WRAP 18.8 % 0 .5 % 6.4 % 10.1 % 4.3 % 39.9%

WRAP States

AZ 0.6% 0% 0.1% 0% 0% 0.7%

CA 2.1% 0% 0.6% 1.3% 0.6% 4.6%

CO 0.4% 0% 0% 0% 0.0% 0.4%

ID 2.3% 0.1% 1.1% 5.1% 0.9% 9.5%

MT 0.1% 0% 0.1% 0% 0.1% 0.3%

NV 2.7% 0% 0.3% 0.9% 0.6% 4.5%

NM 0.3% 0% 0% 0% 0% 0.4%

ND 0.1% 0% 0% 0% 0% 0.1%

OR 2.9% 0.2% 1.5% 2.1% 1.0% 7.7%

SD 0% 0% 0% 0% 0% 0%

UT 1.0% 0% 0.4% 0.1% 0.1% 1.6%

WA 5.4% 0.1% 2.1% 0.1% 0.8% 8.6%

5 To replicate the data in Tables 2 and 3

, enter the TSS website at http://vista.cira.colostate.edu/TSS/ . Under the

“Resources” tab on the left select: Haze Plann ing. On the map select the Jarbidge WA, then click on “Emissions and Source Apportionment”. Under the “Source Apportionment Results” select “Sulfate/SOx Tracer

– All Source Regions”. Here you can switch between Nitrate/NOx and Sulfate/SOx "parameter cho ices. Narrow the selection to Nevada. The data can then be expanded below the figure under “Show Data

. ”

6 See supra n.1.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 17 Point Anthro

Fire Mobile Natural Fires

and Biogenics Area Total

WY 1.0% 0% 0% 0.3% 0.1% 1.5%

2018

Canada 2.4% 0% 0.2% 0% 2.0% 4.3%

Central US 1.2% 0% 0% 0% 0.2% 1.4%

Eastern US 1.2% 0% 0% 0% 0.2% 1.4%

Mexico 2.2% 0% 0% 0% 0.6% 2.8%

Outside Domain * n/a n/a n/a n/a n/a 43.8%

Pacific Offshore 1.0% 0% 0.2% 0% 5.5% 6.9%

WRAP 22.3 % 0 .3 % 1.4 % 10.5 % 4.9 % 39.4%

WRAP States

AZ 0.7% 0% 0% 0% 0% 0.7%

CA 2.5% 0% 0.4% 1.4% 0.7% 5.0%

CO 0.3% 0% 0% 0% 0% 0.3%

ID 3.6% 0.1% 0.3% 5.3% 1.0% 10.3%

MT 0.2% 0% 0% 0% 0.1% 0.3%

NV 3.5% 0% 0.1% 1.0% 0.8% 5.4%

NM 0.3% 0% 0% 0% 0.1% 0.4%

ND 0.1% 0% 0% 0% 0% 0.1%

OR 3.7% 0.1% 0.2% 2.2% 0.9% 7.2%

SD 0% 0% 0% 0% 0% 0%

UT 1.5% 0% 0.1% 0.1% 0. 1% 1.8%

WA 4.5% 0% 0.2% 0.1% 1.0% 5.9%

WY 1.5% 0% 0% 0.3% 0.1% 2.0%

* n/a means not available

Source: http://vista.cira.colostate.edu/tss/ , last viewed 11/07/2014

Table 3 . Percentage Contribution to Modeled Worst Days Nitrate Concentration at the Jarbidge WA by Source Region and Category for 2002 (plan02c) and 2018 (base18b)

Point Anthro

Fire Mobile Natural Fires

and Biogenics Area Total

2002

Can ada 0.3% 0% 1.0% 0% 0.3% 1.9%

Central US 0% 0% 0% 0% 0% 0%

Eastern US 0% 0% 0% 0% 0% 0%

Mexico 0% 0% 0% 0% 0% 0%

Outside Domain * n/a n/a n/a n/a n/a 20.8%

Pacific Offshore 0% 0% 0.3% 0% 0.6% 1.0%

WRAP 13.1 % 1.5 % 43.2 % 8.2 % 10.2 % 76.3%Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 18 Point Anthro

Fire Mobile Natural Fires

and Biogenics Area Total

WRAP States

AZ 0% 0% 0.1% 0% 0% 0.2%

CA 0.6% 0.1% 5.3% 0.5% 0.9% 7.3%

CO 0% 0% 0% 0% 0% 0%

ID 3.2% 0.3% 16.1% 3.9% 8.2% 31.7%

MT 0.1% 0% 0.3% 0.1% 0% 0.5%

NV 3.9% 0% 6.0% 1.6% 0.2% 11.6%

NM 0% 0% 0% 0% 0% 0.1%

ND 0% 0% 0% 0% 0% 0%

OR 0.8% 0.4% 3. 0% 0.7% 0.2% 5.1%

SD 0% 0% 0% 0% 0% 0%

UT 4.0% 0% 7.8% 0.6% 0.3% 12.8%

WA 0.4% 0.6% 4.6% 0.8% 0.3% 6.7%

WY 0.1% 0% 0.1% 0% 0% 0.2%

2018

Canada 0.4% 0% 1.3% 0% 0.4% 2.1%

Central US 0% 0% 0% 0% 0% 0%

Eastern US 0% 0% 0% 0% 0% 0%

Mexico 0% 0% 0% 0% 0 % 0%

Outside Domain * n/a n/a n/a n/a n/a 27.5%

Pacific Offshore 0% 0% 0% 0% 0.8% 1.3%

WRAP 18.9 % 0 .9 % 23.2 % 9.5 % 16.5 % 69.2%

WRAP States

AZ 0.1% 0% 0.1% 0% 0% 0.2%

CA 0.8% 0.1% 2.6% 0.6% 1.0% 5.1%

CO 0% 0% 0% 0% 0% 0%

ID 4.6% 0.2% 7.4 % 4.5% 13.6% 30.3%

MT 0.1% 0% 0.2% 0.1% 0% 0.4%

NV 6.3% 0% 4.5% 1.9% 0.3% 13.1%

NM 0% 0% 0% 0% 0% 0.1%

ND 0% 0% 0% 0% 0% 0%

OR 1.2% 0.4% 1.9% 0.8% 0.3% 4.6%

SD 0% 0% 0% 0% 0% 0%

UT 5.0% 0% 4.3% 0.8% 0.6% 10.6%

WA 0.6% 0.3% 2.2% 0.9% 0.4% 4.4%

WY 0 .1% 0% 0% 0% 0.1% 0.3%

* n/a means not available

Source: http://vista.cira.colostate.edu/tss/ , last viewed 11/07/2014Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 19 Failure to Include E missions from Oil and Gas Development

The NGO comments contend that emissions resulting from oil and gas development were included

in the 2002 inventory for Nevada , but Nevada did not report oil and gas emissions for 2008 and the assumption of zero emissions for 2008 is at odds with publicly reported information

. In fact, Nevada did not report oil and gas emissions in either 200 2 or 2008. Sections 5.3 and 5.4 of the Progress Report have been revised to make this clear. L ike many other states, Nevada does not report oil and gas emissions directly to the NEI, relying on US EPA for this portion of the area source inventory in the NEI.

T he fact that Nevada did not report oil and gas emissions does not necessarily mean that there were

no estimates

. The NDEP notes that emissions resulting from oil and gas development were projected for Nevada’s PRP18a inventory (2009 RH SIP, Tables 3

- 7, 3

- 8, and 3

- 9 ) and, therefore, incorporated in Nevada’s reasonable progress goal. For the 2002 baseline inventory

, t he WRAP

built on the 2002 NEI and developed a robust inventory that included oil an d gas emissions

estimates for Nevada

. F or the WestJump2008 inventory

, t he WRAP built on the 2008 NEI

. A lthough the WRAP developed robust oil and gas inventories for other areas within the WRAP region, it did not conduct the same for Nevada. Progress Report, Sections 5.3 and 5.4. Nonetheless, such emissions must be put in to perspective : in 2002 only 63 tons per year (tpy) of

NO

x and 129 tpy of VOC emissions were reported compared to a state

- wide 2002 inventory of 162,397 tpy of NO

x and 897,102 tpy VOC and the state

- wide 2008 inventory of 11 8,766 tpy NO

x and 351,142 tpy VOC

. Progress Report, Table 5

- 7 and Table 5

- 10

.

The NDEP is aware of the limited oil and gas exploration efforts in northeastern Nevada to assess potential targets suitable for enhanced oil recovery methods such as fracking (see BLM Environmental Assessment for Huntington Valley Oil and Gas Exploration Project DOI

- BLM

- NV

E020

- 2014

- 0003

- EA ). In Nevada, o il and gas developme nt and production , as reflected by rig

counts

, is either declining or steady. Table 4 shows annual average rig counts by state from 2000 to

2013 and demonstrates that Nevada is not expe riencing any sort of oil and gas development boom

as are some western states such as North Dakota or Utah. Figure 1 shows a steady decline in Nevada’s oil and gas production from 1990 to 2013. These data su ggest that oil and gas development and production is not a significant activity in Nevada. The NDEP notes that oil and

gas development and production in Nevada is currently subject to permitting requirements.

Table 4

. Baker Hughe s Rotary Rig Count Annual Averages by State 9

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Colorado 18 32 28 39 54 74 89 107 114 50 58 72 65 63

Montana 7 10 8 14 20 24 22 17 11 3 7 9 20 1 2

Nevada 0 0 0 1 2 2 1 2 3 3 6 3 1 3

New

Mexico 68 68 42 65 67 83 94 78 78 44 62 79 84 77

N Dakota 13 14 10 14 15 21 32 39 68 50 114 168 188 173

9 Modified from information downloaded from http://phx.corporate

- ir.net/phoenix.zhtml?c=79687&p=irol

- reportsother on October 23, 2014.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 20 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Utah 16 21 13 14 22 28 40 42 42 18 27 28 37 29
Wy oming 41 55 40 54 74 78 99 74 74 40 40 48 47 48

Figure 1

. Oil Production in Nevada 1990 to 2013. 10

The NDEP considered the applicable RHR requirements and available data in reaching the

c onclusion to retain the reasonable progress goal of 11.05 deciviews for the Jarbidge WA. The NDEP acknowledges the modeling error, but notes the update to the emission inventory

demonstrates that state

- wide reductions in Nevada point source emissions have reduced visibility impairment at the Jarbidge WA. Emissions from Nevada’s oil and gas development are not a significant emissions source and are not likely to have significant influence on visibility at the Jarbidge WA. Nevada stands by its co nclusion to retain the reasonable progress goal of 11.05

deciviews.

The only change made to the Progress Report based on this NGO comment was to clarify the discussion of oil and gas emissions reporting, as noted above

.

10 Figure downloaded from http:/ /minerals.nv.gov/uploadedImages/mineralsnvgov/content/Programs/Oil_and_Gas/OilProdInNV1990

- 2013.jpg October 23, 2014Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 21 NGO Comment 2 : NDEP Must Consider a nd Evaluate Reasonable Progress Measures f or t he Jarbidge Wilderness a nd Other Class I Areas Impacted b y Nevada Sources.

This NGO comment hinges on the opening statement that the NDEP must find its implementation plan “is or may not be adequate to ensure reasonable progress due to emissions from sources within

the State

. ” NGO comment letter, page 6. The NGO s suggest that NO

x and SO 2 emissions from Nevada point sources have significant contributions to visibility impairment at the Jarbidge WA and that Nevada should consider emission control requirements for the North Valmy Generating Station as well as potential visibility impacts from oil and gas development in Nevada.

NDEP Response: T he NDEP maintains Nevada’s implementation plan is adequate to ensure reasonable progress due to emissions from sources within the State. Nevada’s initial regional haze progress report focuse s on controllable anthropogenic emission s ources. T h e Progress R eport documents progress for the first five years of a 60

- year planning horizon and not all controls

identified in the State’s 2009 RH SIP have been implemented because they are not required to do so

until 2015 ( Prog ress Report , S ection 2.5.2 )

. Furthermore, the majority of visibility impairing emission sources at the Jarbidge WA are out of Nevada’s jurisdiction ( P rogress R eport

, S ection 4.4

and 2009 RH SIP

, S ection 4.3 ). L ong

- term monitored light extincti on trends are either better than or comparable to the speciated glide slopes for nitrate and sulfate ( Progress Report

, S ection 4.6 )

. Finally, the 5

- year annual average nitrate extinction on the worst days is below the nitrate glide slope

, and the re is no degradation of visibility resulting from nitrate or sulfate on the best days.

Nevada Point Source Contributions to Visibility Impairment Emissions from outside of Nevada contribute more to visibility impairment at Jarbidge WA than Nevada point sources. The sulfate modeling results for Nevada’s point sources are presented graphically in Figure 2

. C oupled with the information presented in Table 2 , the data show that for

2002

, Canada, Eastern US, Pacific Offshore, and Outside Domain each contribute more to modeled worst days sulfate concentratio ns at the Jarbidge WA than d o emissions from Nevada point sources

. Similarly, point sources in Oregon and Washington contribute more than Nevada point sources

, while point sources in Idaho contribut e nearly as much. When total state

- wide emissions are considered, California, Idaho, Oregon and Washington all contribute more to modeled sulfate concentrations at Jarbidge than do Nevada’s state

- wide emissions.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 22 Figure 2

. Contributions to Modeled Sulfate Concentrations at the Jarbi dge WA on the Worst Days

For 2018

, a similar situation exists

. E missions from Canada, Pacific Offshore and Outside Domain

each contribute more to the modeled worst days sulfate concentration than emissions from Nevada point sources, as d o point sourc es in Idaho, Oregon, and Washington. When state

- wide emissions are considered, Idaho, Oregon, and Washington each contribute more than Nevada’s state

- wide emissions with California contributing nearly as much as Nevada. The source apportionment modeling supports Nevada’s conclusion that the IMPROVE monitor for the Jarbidge WA is “likely more strongly impacted by emissions originated from with the Snake River Basin than those

emitted from within the Great Basin” (Progress Report

, p age 9

- 3) and emissions f rom sources within the State are not impeding reasonable progress at the Jarbidge WA

. As noted in the NDEP’s response to the NGO comment 1, emissions from the North Valmy Generating Station are clearly not a significant source of visibility impairment at the Jarbidge WA.

Emissions from Outside Domain and Pacific Offshore contribute approximately 50 percent of modeled sulfate at Jarbidge with all sources outside of the WRAP contributing approximately 60 percent of modeled concentration. WRAP states, exclu ding Nevada

, contribute approximately 35 percent. The source apportionment modeling demonstrates the majority of emission sourcesNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 23 contributing to sulfate visibility impairment at Jarbidge are outside the jurisdiction of Nevada or its

WRAP co

- regulators. As noted in S ection 4.6 of the Progress Report, monitored sulfate extinction for the worst days at the Jarbidge WA is trending downward, both on an annual and five

- year average basis.

The NDEP is unsure why the NGO s commented on nitrate extinction at Ja rbidge WA and the need for further emission controls when, as shown by Figure 3 , five

- year rolling averages of worst days nitrate extinction for the last 4 years (2006

- 2010, 2007

- 2011, 2008

- 2012, and 2009

- 2013) are below the nitrate glideslope. Figure 4 graphically shows the contributions to modeled worst days nitrate concentrations at Jarbidge WA

. Regarding the NGO comments about Nevada’s contributions to the best days

, there is no degradation in visibility resulting from sulfate or nitrate for the least impaired (best ) days at the Jarbidge WA over the current planning period ( Figure 5 )

.

Figure 3

. Baseline and Five

- Year Rolling Averages of Worst Days Sulfate and Nitrate Light Extinction at the Jarbidge WA

.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 24 Figu re 4 . Contributions to Modeled Nitrate Concentrations at the Jarbidge WA on the Worst Days

Figure 5 . Baseline and Five

- Year Rolling Averages of Best Days Sulfate and Nitrate Light

Extinction at the J arbidge WA

.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 25 Consideration of Emissions from Oil and Gas Development The NGO comments state Nevada must consider emissions from oil and gas development and the potential visibility impact, using information from a couple of newspaper articles to sugges t oil development could be increasing, as it has in recent years in Utah. However, as discussed under the first NGO comment, the data in Table 4 shows that oil and gas development in Nevada has a considerably slow er pace than other oil and gas areas in the western US

, and the data in Figure 1 show that Nevada’s oil production has been in a state of steady decline since the 1990 s. The NDEP continues to monitor the pace of oil and gas development in Nevada and will evaluate emissions sources resulting from increased activity as warranted. However, given the very limited oil and gas activity to date

, implementation of additional emission controls on this sector at this time would be premature

.

Nevada’s 2009 RH SIP focused on impairment resulting from Nevada’s anthropogenic emissions of

SO 2 and NO

x , the precursors of sulfate and nitrate, respectively. Source apportionment modeling

demo nstrates Nevada emissions do not make a large contribut ion to overall visibility impairment at Jarbidge WA

. T he bulk of impairment result s from emissions beyond Nevada’s jurisdiction. Monitoring data show that the Jarbidge WA is ach ieving levels of improvement in visibility impairment necessary to achieve natural background conditions by 2064 for impairment resulting

from nitrate and sulfate extinction in this first 5

- year planning period

. To the extent that SO 2 and

NO

x emissions from point sources in Nevada contribute to visibility impairment at Jarbidge WA, Nevada’s progress report documents significant SO 2 and NO

x emissions reductions from sources within the State (see Table 5

- 1 of the Progress Report ).

In summary, the NDEP has fully justified Nevada’s negative declaration (i.e., emissions from sources within the State are not preventing Nevada from achieving its reasonable progress goal ) and

deems its 2009 RH SIP adequate to ensure reasonable prog ress towards the national visibility goal for sulfate and nitrate resulting from anthropogenic emissions.

No changes were made to the Progress Report as a result of this NGO comment.

NGO Comment 3 : NDEP Must Revise Its Assessment of Contribution t o Vi sibility Impairment a t
Class I Areas Impacted b y i ts Sources t o Be Based o n t he WRAP’s Revised Modeling with i ts 2018

P RP b Emissions Projections.

This NGO comment contends that Nevada’s assessment of its sources’ impacts on Cla ss I areas

outside Nevada is based on erroneous source appointment modeling

, which in turn is based on an outdated PRP18a emissions projection. The NGO comments go on to suggest that Nevada’s conclusions regarding emissions reductions should be informed n ot by the 2008 inventory data

, but by the 2011 NEI and more recent CAMD data. Further

, the NGO comments suggest that emissions reductions in Nevada may not account for Nevada’s portion of impairment in some Class I area s, and Nevada must revise its analys is of Nevada’s impacts on out

- of

- state Class I areas.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 26 NDEP Response: A comprehensive review of the Nevada regional haze SIP and P rogress R ep ort
and the WRAP’s modeling efforts that supported Nevada ’s regional haze submissions belie this

comment

.

Modeling Assessment

Table 4

- 3 and Table 4

- 4 of the 2009 RH SIP present Nevada’s contributions to li ght extinction at Class I areas in the five states adjacent to Nevada based on the WRAP’s source apportionment modeling. Sections 1.3.2.2, 1.3.3.2 and 4.3 of the 2009 RH SIP describe the modeling framework

and emissions scenarios utilized for this modelin g effort by the WRAP, which relied on the Plan02c

and Base18 b emission inventories. To the NDEP ’s knowledge , there has been no indication by any party that this source apportionment model ing is erroneous or not fully acceptable. This is the most comprehensive and current regional haze source apportionment data available for the WRAP region

.

Table 7

- 6 of the 2009 RH SIP provides a summary of visibility impairment at nearby Class I areas and Nevada’s emissions reductions, which the NGO comments suggest is based on erroneous modeling. However, as noted in S ection 7.9.3.2 of the 2009 RH SIP, the informatio n in the table is

based on monitored baseline light extinction (2000

- 2004) , the uniform rate of progress for 2018 (i.e., the glideslope value for 2018), and Nevada’s contributions to sulfate and nitrate based on the WRAP’s source apportionment modeling. N evada’s emission reduction share is calculated by multiplying the extinction reduction needed at any given Class I area by the 2018 pollutant contribution by Nevada

. Nevada’s share is independent of the WRAP’s corrected visibility modeling.

Emissions Assessment

The NGO s suggest that the analysis should be informed by 2011 NEI data and recent CAMD data,

but later acknowledge that the NDEP did present and evaluate both 2011 NEI and CAMD data through 2013. Table s 5

- 5 and 5

- 7 of the Progress Report compare 2002 baseline emissions as represented by the Plan02d inventory and 2008 progress period emissions as represente d by WestJump2008. However, Tables 5

- 6 and 5

- 8 present 2011 NEI data from the major anthropogenic source categories (point, on

- road mobile and off

- road mobile) and show further reductions in SO 2 and NO

x emissions from 2008 to 2011. In addition, Table 3

- 2 and Figure 3

- 1 of the report present CAMD data through 2013 for annual EGU emissions. Figures 3

- 2 through 3

- 7 present SO 2 and

NO

x CAMD data for specific EGUs through 2013. The 2011 NEI and recent CAMD emission s data have been evaluated by the NDEP and further support Nevada’s emission reduction

conclusions

, contrary to statements in the NGO comments.

Out of State Impact Assessment The NGO comments suggest that the significant emissions reductions i n Nevada may not account for Nevada’s portion of impairment at out

- of

- state Class I areas and use the Sawtooth Wilderness

A rea as an example. B aseline nitrate extinction at the Sawtooth Wilderness Area is better than the

natural cond itions estimate (0.6 3 Mm - 1 for baseline and 0. 65 Mm - 1 for natural conditions), so the extinction reduction needed and Nevada’s emissions reduction share are both negative in Table 7

- 6

of the 2009 RH SIP. The NDEP notes that Table 7

- 6 shows that Nevada’s emission reduction share is 0.5 percent for sulfate while the difference between the Base02d and PRP18a inventories is 33.0Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 27 percent for SO 2 and 16.6 percent for NO

x . Table 5

- 5 of the Progress Report shows state

- wide SO 2 emission reductions of 75 percent b etween 2002 and 2008 with additional reductions shown in

Table 5

- 6 between 2008 and 2011. Table 5

- 7 shows state

- wide NO

x emission s reductions of 26 percent between 2002 and 2008

, which are slightly offset by the emissions growth shown in Table

5

- 8 between 2008 and 2011. The percentage reductions in Nevada’s NO

x and SO 2 emissions are much greater than Nevada’s emissions reduction share presented in Table 7

- 6 of the 2009 RH SIP.

Figure 6 below shows the annual wors t days monitor ing data for the Sawtooth Wilderness A rea with 5

- year rolling averages, natural conditions, and the glideslopes for each species. This figure demonstrates that visibility impairment due to sulfate and nitrate are not preventing reasonab le progress at the Sawtooth Wilderness Area

, even though this site is not achieving the uniform rate of progress for sulfate and nitrate as shown by Figure 7

. Figure 6 shows particulate o rganic matter ( resulting from fire emissions ) is the principle driver of visibility impairment at this Class I area.

Figure 6 . Baseline and Five

- Year Rolling Averages of Worst Days Visibility Conditions at the

Sawtooth Wilderne ss Area.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 28 Figure 7 . Baseline and Five

- Year Rolling Averages of Worst Days Sulfate and Nitrate

Visibility Impacts at the Sawtooth Wilderness Area.

Figure 8 and Figure 9 show the regional as well as the WRAP source region and source type contributions to modeled sulfate and nitrate respectively at the Sawtooth Wilderness A rea . These Figures show how little Nevada emission s sources contribute t o visibility impairment at the

Sawtooth Wilderness Area

.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 29 Figure 8 . Contributions to Modeled Sulfate Concentrations at the Sawtooth Wilderness Area on the Worst DaysNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 30 Figure 9 . Contributions to Mode led Nitrate Concentrations at the Sawtooth Wilderness Area on the Worst Days

In summary, WRAP visibility modeling based on the PRP18b emission inventory has no bearing on the NDEP’s assessment of Nevada’s contribution to visibility impairment at Class I areas impacted by Nevada emission sources. The NDEP’s emissions reductions conclusions are based on the most recent commonly available emissions data as represented by the WestJump2008, 2011 NEI, and CAMD data through 2013, as requested by the NGO comm ents. Nevada’s emission reductions far exceed Nevada’s contributions to visibility impairment at Class I areas impacted by Nevada sources. Emissions from Nevada are not impeding reasonable progress at the Sawtooth Wilderness

Area or other out

- of

- state Cl ass I areas.

The NDEP has not revise d its determination regarding the adequacy of its plan with respect to
Nevada’s impacts on out

- of

- state Class I areas based on this comment

, and no changes were made to the Progress Report.

NGO Comment 4 : NDEP M u st R evise I ts P roposed P rogress R eport to M eet §51.308(g)(2) and §51.308(g)(4).Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 31 The NGOs comment that the Progress Report fails to detail the specific reductions achieved through the implementation of the enforceable measures required by the SIP and req uest that Nevada

include such estimates and revise its assessment of the adequacy of its SIP on this basis. They question whether the significant decrease in SO 2 and NO

x emissions from EGUs is due to enforceable measures and point to the increase in 2013 SO 2 and NO

x emissions at Reid Gardner and

NO

x emissions at Fort Churchill (Progress Report Figures 3

- 2, 3

- 3 and 3

- 7) as support. They

further comment that the use of 2011 NEI data in Chapter Five is not a sufficient basis for evaluating the most recent em issions trends in Nevada . They request the NDEP discuss the EGU

emissions from USEPA’s CAMD database in Chapter Five as well as Chapter Three of the report

and also us e in

- state inventories and Title V reporting from 2008 to at least 2012 to discuss

emis sion trends

. Finally, the NGOs suggest that to the extent the NDEP is relying on measures not included in the 2009 RH SIP to meet its reasonable progress goal, using SB 123 as an example, it should adopt those requirements as enf orceable measures in its regional haze SIP.

NDEP Response: T he 2009 RH SIP requires the implementation of BART as a major enforceable

control measure for the first planning period, 2008

- 2018 . All applica ble BART requirements have been adopted and incorporated into the N evada A dministrative C ode , approved by USEPA into Nevada’s applicable SIP and are enforceable by the State and USEPA . Chapters Two and Three of

the Progress Report discuss BART implementat ion . Table 2

- 3 of the report details the status of BART implementation in Nevada, showing that all BART control measures will be installed and operating by January 1, 2015 with the exception of NO

x controls at Reid Gardner, which has a compliance date of June 30, 2016. Thus, since the controls have n o t been fully implemented at this

time , specific reductions are not yet fully realized. Chapter Five of the 2009 RH SIP, specifically

Tables 5

- 4, 5

- 5

, 5

- 6 and associated text

, provide expected emissions reduc tions following full implementation of BART controls. Section 3.4.2 of the Progress Report notes that NV Energy plans to shut down Units 1 through 4 at Reid Gardner and specifies associated emissions reductions

.

Chapter Three of the Progress Report discu sses the most recent CAMD EGU emissions data through 2013. The fact that there is a small increase in EGU emissions from 2012 to 2013 is diminished by the overall steady decline in EGU emissions , with the exception of increased emissions at Tracy and F ort Churchill during the Energy Crisis of 2000

- 2001

. Indeed, electrical generation demand varies across fleet facilities and could account for the increased emissions in

2013. The NDEP finds the NGOs’ speculation that the miniscule increase in 2013 may i ndicate that

the control measures included in the 2009 RH SIP may be inadequate is unsubstantiated.

Chapter Five of the Progress Report includes 2011 NEI Nevada point and mobile source emissions

in Tables 5

- 6, 5

- 8, and 5

- 11 for SO 2 , NO

x , and VOC, re spectively. 2012 NEI data was not used because it only includes the larger point source data and does not include mobile source data. Thus, it would not provide a complete picture of emissions in Nevada. In addition, 2012 in

- state
emissions data was nei ther quality checked nor available at the time of preparation of the Progress Report. Thus, t he WestJump 2008 and 2011 NEI inventories provide the most recent data available to the NDEP at the time of the Progress Report. The next SIP submission is expected to include new modeling results using the most current available emissions data for use in assess ing the adequacy of Nevada’s SIP.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 32 Lastly, the NGOs suggest Nevada adopt SB123 as an enforceable measure of its regional haze SIP. The NDEP as part of its reasonable progress update review ed all available sources of emission reductions and planned control measures. The NDEP maintains that it is appropriate to include an assessment of the impact of all emissions reduction meas ures occurring since the 2009 RH SIP was adopted. The NDEP did not , however, rely on the emission reductions in SB123 in making its determination that Nevada is making adequate progress overall in improving visibility. It is

unnecessary to incorporate SB 123 in to the Nevada SIP.

No revisions have been made to the Progress Report as a result of this comment.Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 33 

### D.2.2 Sierra Club

- National Parks Conservation Association Comment LetterNevada Regional Haze 5

- Year Progress Report, November 2014

D

- 34Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 35Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 36Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 37Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 38Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 39Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 40Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 41Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 42Nevada Regional Haze 5

- Year Progress Report, November 2014

D

- 43 The NGO comment letter was accompanied by three exhibits

. Because of the length of the exhibits,

the NDEP has not included them in this appendix, but is providing links to these documents on the

in ternet.

1. Correction of WRAP region Plan02d CMAQ visibility modeling results on TSS for Regional
Haze Planning

. April 2 7, 2011

. The final version of the document is available at
http://vista.cira.colostate.edu/TSS/Planning/InformationExchange.aspx ( See Revised Plan 02d
CMAQ Modeling Results (June 2011)

, last viewed 11/10/2014)

2. WRAP PRP18b Emissions Inventory

– Revised Point and Area Source Projections. April 29,
2009. Technical Memorandum from Marty Wo lf and Paula Fields, Eastern Research Group, to

the WRAP staff. http://www.wrapair.org/forums/ssjf/documents/Pivot_Tables/2009

- 04x_Final_PRP18b_me mo_4

- 29.pdf (last viewed 11/10/2014)

3. Summary of WRAP RMC BART Modeling for Nevada. Draft#7. April 24, 2007.
http://www.ndep.nv.gov/baqp/planmodeling/docs/NV _Bart_summary_v7_Apr24_2007.doc

These exhibits are also available on request from the NDEP Bureau of Air Quality Planning at 901 South Stewart Street, Carson City, Nevada 89701 or 775

- 687

- 9349

.