From: Colleen McKaughan/R9/USEPA/US 

To: melges@ndep.nv.gov, rbamford@ndep.nv.gov, amalone@ndep.nv.gov, gremer@ndep.nv.gov

Cc: Amy Zimpfer/R9/USEPA/US@EPA, Thomas Webb/R9/USEPA/US@EPA, Eugene 

Chen/R9/USEPA/US@EPA, Ann Lyons/R9/USEPA/US@EPA 

Date: 12/23/2011 10:09 AM 

Subject: Reid Gardner Information Request - Use this version 

Hi, Everyone, 

In my haste to get the list to you, I sent the wrong version. Please use this one instead. We refined it a bit 

more. 

Colleen W. McKaughan 

Associate Director, Air Division 

USEPA, Region 9 

(520) 498-0118 

Reid Gardner NOx BART - Information request letter (2011_1222).docx 

Attachment 

On December 13, 2011, EPA signed a final rule in which we approved most of the Nevada RH 

SIP. We took no action on the Best Available Retrofit Technology (BART) Determination 

for nitrogen oxides (NOx) at the Reid Gardner Generating Station (Reid Gardner). As 

discussed in our final rule, we do not consider the currently available information to be 

sufficient for us to take final action on the Nevada Division of Environmental Protection's 

(NDEPs) determination that rotating overfire air (ROFA) with Rotamix is the NOx control 

technology that represents BART at Reid Gardner. In order to better inform further action on 

the Reid Gardner NOx BART determination, we have included the following list of 

information we consider important to our deliberations. 

1. The Regional Haze Rule does provide for the consideration of the affordability of 

controls (70 FR 39171) when evaluating the use of a particular technology. If unusual 

circumstances exist at Reid Gardner that justify taking into consideration the condition of 

the plant or the economic effects of requiring the use of Selective Catalytic Reduction 

(SCR), please provide an economic analysis documenting these circumstances. 

2. Additional information and documentation that supports the levels of performance 

determined for the various NOx control technologies considered in the BART analysis. 

Such documentation could include copies of preliminary vendor proposals, descriptions 

of retrofit difficulties at Reid Gardner, or technical reports or evaluations describing 

physical restrictions or unique operational characteristics of the Reid Gardner units. The 

two control options of the greatest concern are ROFA with Rotamix and SCR with LNB 

and OFA. 
3. Additional information and documentation that supports the capital and annual costs for 

the various NOx control technologies considered in the BART analysis. Such 

documentation could include copies of preliminary vendor proposals, design basis 

specifications, cost calculation spreadsheets, or design software output. Again, the two 

control options of the greatest concern are ROFA with Rotamix and SCR with LNB and 

OFA. 

4. A more detailed and explicit explanation of the various baseline scenarios modeled (e.g., 

WRAP baseline, Title V emission limit baseline, NVEBL) and of which baseline was 

used to determine the degree of visibility improvement attributable to the various NOx 

control technologies.

1

5. Copies of the input and output files for CALMET, CALPUFF, POSTUTIL, and 

CALPOST for each of the baseline scenario model runs, and for each of the NOx control 

scenario runs. 

a. Please note that we do not require the binary concentration or meteorological data 

files, but are seeking the plain text input and list output files. 

b. When postprocessing visibility results, it is common practice to extract the 

visibility results from the various scenarios and years modeled into a spreadsheet 

to assist in summarizing and organizing these results. If available, please provide 

a copy of these spreadsheets and other documents or tools used to summarize the 

visibility results from the baseline model runs and NOx control scenario model 

runs. 

c. Based on the Nevada Energy BART Analysis, baseline scenario visibility 

modeling was performed for multiple Class I areas. NOx control scenario results, 

however, were only included for Grand Canyon National Park (GRCA). As a 

result, it is unclear if NOx control scenario modeling was performed for other 

Class I areas. Please provide the CALPOST input and output files corresponding 

to each Class I area that was considered in the visibility modeling. 

While responding to many of these items will primarily involve collecting existing files (such as 

Item 5) and documentation, it may potentially be more expeditious in certain cases (such as Item 

2) to revise or update an existing analysis. With the exception of Item 1, which will necessarily 

involve production of a new analysis or report, we do not require updated estimates or analyses 

but will consider the results of such updated information in our deliberations. Please respond as 

soon as possible, but no later than Friday, February 3, 2012. 

 

1 As summarized in Table 5-4 of the respective NVE BART Analyses