CLASS I APPLICATION TECHNICAL REVIEW

FOR: 

Nevada Power Company 

Reid Gardner Generating Station

Clark County, Nevada 

Minor Revision to Class I Operating Permit #AP4911-0897 

FIN # A0379

Application Log Numbers – Permit Reopening (Consent Decree Requirements) 

 

BY 

STATE OF NEVADA 

DEPARTMENT OF CONSERVATION AND NATURAL RESOURCES 

DIVISION OF ENVIRONMENTAL PROTECTION 

BUREAU OF AIR QUALITY 

Tobarak Ullah, P.E. 

Staff Engineer 

December 11, 2007
1.0 INTRODUCTION 

The Nevada Division of Environmental Protection, Bureau of Air Pollution Control (NDEPBAPC) has issued a letter to Nevada Power Company, Reid Gardner Generating Station (NPC) 

on April 3, 2007 and confirmed on September 12, 2007 regarding the reopening and revision of 

the NPC’s existing Operating Permit #AP4911-0897. In a letter and Order, dated April 3, 2007, 

NDEP-BAPC required NPC to install natural gas igniters on Units 1-4 at Reid Gardner 

Generating Station no later than July 1, 2009, and install baghouses on Units 1-3 Reid Gardner 

Generating Station no later than July 1, 2010. These requirements were also found in the Reid 

Gardner Consent Decree entered between NPC, NDEP-BAPC and the United States 

Environmental Protection Agency on April 3, 2007, which was approved by the United States 

District Court on June 14, 2007. NDEP-BAPC’s April 3rd letter informed NPC that NDEPBAPC would reopen Reid Gardner Operating Permit AP4911-0897 in order to include the 

required gas igniters and baghouses into the permit. The Operating Permit has been reopened 

pursuant to NDEP-BAPC’s April 3rd notice and Nevada Administrative Code 445B.325. 

Paragraph 74 of the Reid Gardner Consent Decree states that no later than six months after the 

commencement of operation of any of the newly installed gas igniters or baghouses required by 

the Consent Decree NPC “shall apply to include the requirements . . . into either a federally 

enforceable permit (other than a Title V permit) or an amendment to the SIP.” Due to the fact 

that NDEP-BAPC has already reopened the Reid Gardner Operating Permit to include the gas 

igniters on Reid Gardner Units 1-4 and the baghouses on Reid Gardner Units 1-3 it is 

unnecessary for NPC to submit an application for their inclusion into the Reid Gardner Operating 

Permit. Additionally, since NDEP-BAPC has a consolidated construction and Title V permit 

program, it is unnecessary to separately apply for a construction permit and roll it over to the 

Title V operating permit. 

Paragraph 75 of the Reid Gardner Consent Decree states that “the incorporation of the 

requirements of this Consent Decree into the Operating Permit shall be in accordance with state 

Title V rules, including applicable administrative amendment provisions of such rules.” As 

stated above, NDEP-BAPC’s reopening of the Reid Gardner Operating Permit meets the 

guidelines outlined in the Reid Gardner Consent Decree and makes the application by NPC for 

permit changes pursuant to Paragraph 74 of the Reid Gardner Consent Decree unnecessary. 

In addition to the above mentioned permit changes to incorporate the baghouses and gas igniters 

into the Reid Gardner Operating Permit, NDEP-BAPC is also incorporating the new SO2 

limitations found in Paragraph 23 of the Reid Gardner Consent Decree. Accordingly, it is 

unnecessary for NPC to apply to NDEP-BAPC for these changes pursuant to Paragraph 74 of the 

Reid Gardner Consent Decree as NDEP-BAPC has already begun the process to incorporate 

them into the operating permit. 

These permit revisions will go through the public participation process as follows: There will be 

a 30-day public comment period established to receive comments on the draft permit; followed 

by the 45-day EPA review under NDEP-BAPC’s Title V program. 

The existing Class I (Title V) PSD permit is for operating four (4) steam generating boilers (coal-
fired) and other related systems including cooling water and treatment systems; coal processing 

systems; fly ash systems; flue gas desulfurization systems; fuel storage and transfer systems; etc. 

(a total of 20 systems); and ten (10) other insignificant activities. Certain non-boiler related 

activities at the facility are permitted by the Clark County Department of Air Quality 

Management (CC-DAQM) since the facility is located in Clark County. 

The facility is located in Clark County, Nevada approximately one mile southwest of the city of 

Moapa, Nevada and approximately 50 miles north of the city of Las Vegas. The Standard 

Industrial Classification (SIC) number for the facility is 4911 (Electric Services), since the 

primary product is electric power for sale. 

The facility operations are located in Hydrographic Area 218 (California Wash). The California 

Wash is currently designated as unclassifiable and/or attainment for all criteria air pollutants. 

However, a short distance from Basin HA218 is Basin HA212 (Las Vegas Valley) which is 

designated as non-attainment for CO and PM10. The facility triggered the minor source baseline 

date for PM10, NOx and SO2. The facility began operation in 1965 with boiler Unit #1, boiler 

Unit #2 in 1968 and boiler Unit #3 in 1976. PSD permitting requirements were triggered with 

the addition of a fourth coal-fired boiler (Unit #4) permitted by US EPA in 1980 and constructed 

in 1983. 

 

NPC has already met the consent decree requirements for Unit #4. A minor revision permit was 

issued on June 18, 2007 for the installation of a Rotating Opposed Fired Air (ROFA) combustion 

system on Steam Boiler Unit #4 (B-04). The purpose of the ROFA system will be to reduce 

NOx emissions (approximately 855.71 tons/yr) from Unit #4. The operating scenario for the 

Steam Boiler Unit #4 (B-04) will be 100% coal fired with natural gas igniters. The natural gas 

will be combusted for the purposes of startup, shutdown and/or flame stabilization only. 

NPC has certified (re: NPC’s letter dated October 17, 2007) that installation of natural gas 

igniters have also been completed on Units #1 and #3. The natural gas will be combusted for the 

purposes of startup, shutdown and/or flame stabilization only. 

2.0 STATE-ISSUED ORDER AND CONSENT DECREE 

REQUIREMENTS 

NDEP’s Order: 

Pursuant to Order dated April 3, 2007, NPC is required to install gas igniters on Units 1-4 at Reid 

Gardner no later than July 1, 2009, and install baghouses on Units 1-3 at Reid Gardner no later 

than July 1, 2010 [re: NDEP-BAPC’s letter dated September 12, 2007, Reid Gardner Generating 

Station Permit Reopening]. NPC is required to comply with following requirements as listed in 

the Order: 

1. Igniter Installation Project: NPC shall replace the fuel oil igniters for Units 1-4 by 

installing natural gas igniters in Units 1-4; replace the Burner Management System for 

Units 1-4 as necessary to operate natural gas igniters; construct a natural gas pipeline 
connecting the Facility to the Kern River Natural Gas Pipeline; and undertake any other 

modifications at the Facility necessary to operate natural gas igniters in Units 1-4. 

NPC shall complete construction of the Igniter Installation Project required herein no later 

than July 1, 2009. On or after July 1, 2009, NPC shall not use oil for start-up or flame 

stabilization of any EGU at the Facility. 

2. Installation and Operation of Baghouses: NPC shall complete construction and begin 

operation of three separate baghouses at the Facility, for Units 1, 2, and 3, respectively. 

The completion of construction and commencement of operation of all of the baghouses 

shall occur on or before July 1, 2010. 

If construction of any one of the three baghouses has not been completed on or before July 

1, 2010, NPC may shut down and cease operation of any one of the Units not operating a 

Baghouse at the Facility. 

If NPC does not receive approval from the Public Utilities Commission of Nevada (PUCN) 

for the installation and operation of the Baghouses for Units 1-3, NPC may decommission 

Units 1-3. If NPC chooses to decommission Units 1-3 due to disapproval of the Baghouse 

installation and/or operation, NPC shall provide written notice to the NDEP-BAPC that it 

intends to decommission Units 1-3 no later than November 30, 2007, or within one year of 

the PUCN decision on NPC’s Integrated Resource Plan, whichever is sooner; and, NPC 

shall shut down and permanently cease operation of Units 1-3 on or before November 30, 

2008. 

3. Monitoring, Recordkeeping and Reporting. NPC shall comply with the monitoring, 

recordkeeping, and reporting requirements set forth in the Facility Operating Permit. 

Consent Decree Requirements: 

Reid Gardner Consent Decree was agreed to between the NPC, NDEP-BAPC and the United 

States Environmental Protection Agency on April 3, 2007, which was entered by the United 

States District Court on June 14, 2007. NPC is required to comply with following requirements 

as listed in the Consent Decree: 

1. Igniter Installation Project: NPC shall replace the fuel oil igniters for Units1-4 at the 

Facility by installing natural gas igniters in Units1-4; replace the Burner Management 

System for Units 1-4 as necessary to operate natural gas igniters; construct a natural gas 

pipeline connecting the Facility to the Kern River Natural Gas Pipeline; and undertake any 

other modifications at the Facility necessary to operate natural gas igniters in Units 1-4. 

NPC shall complete construction of the Igniter Installation Project required by this 

Paragraph no later than twenty-four months (24) after the Effective Date of this Decree. 

Beginning twenty-four (24) months after the Effective Dated of this Decree NPC shall not 

use oil for start up or flames stabilization of any EGU at the facility.” 

2. Installation and Operation of Baghouses: By no later than thirty-six (36) months after the 
Effective Date of this Decree NPC shall complete construction and begin operating three 

separate Baghouses at the Facility, for Units 1, 2, and 3 respectively. 

If construction of any one of the three Baghouses is not completed by within thirty-six (36) 

months after the Effective Date of this Decree NPC may, in its discretion, shut down and 

cease the operation of any one of the Units not operating a Baghouse at the Facility. NPC 

may, at its discretion, recommence operation of a Unit shutdown pursuant to this 

paragraph, provided that construction of a baghouse for the Unit is complete and the 

baghouse is operational. 

If NPC does not receive approval from the PUCN for the installation and operation of the 

Baghouses for Units 1-3 in its Integrated Resource Plan, NPC may, in its sole discretion, 

choose to decommission Units 1-3. If NPC chooses to decommission Units 1-3 pursuant to 

this Paragraph, the following shall apply: 

i. NPC shall notify the EPA and NDEP in writing, pursuant to Section XVI (Notices), 

that it intends to decommission Units 1-3 no later than November 30, 2007, or within 

one year of the PUCN decision on NPC’s Integrated Resource Plan, whichever is 

sooner; and 

ii. NPC shall shut down and permanently cease operation of Units 1-3 on or before 

November 30, 2008.” 

3. Monitoring, Recordkeeping and Reporting. NPC shall comply with the monitoring, 

recordkeeping, and reporting requirements set forth in the Operating Permit. 

4. SO2 Limitations and Operating Permit Modification

a. Beginning on the Effective Date of the Decree, measured separately, Units 1, 2 and 3 

shall not have SO2 emissions in excess of 0.40 LB/MMBtu, based on a 10-day rolling 

average period. 

b. Compliance with the SO2 emission limitations in this Paragraph shall be 

demonstrated with SO2 CEMS and the procedures established in the appropriate 

section of NPC’s Operating Permit. 

c. In accord with Section XII (Permits), NPC shall modify its Operating Permit to 

include the SO2 emissions limitations required by this Paragraph. 

3.0 DESCRIPTION OF PROCESS 

3.1 OVERVIEW

The project consists of (4) coal-fired external combustion boilers that serve to produce electricity 
for sale for various locations in Nevada. Units #1-3 are similar in design and output and share 

support processes. Unit #4 is a larger, newer unit and has its own support systems separate from 

those of units #1-3. 

Table 2.1 Boiler Overview: 

Unit Manufacture

d Manufacturer / Model Annual Op. Hours MMBtu/hr MW (maximum) 

#1 1965 Foster-Wheeler External wall-fired 

(FFFSG) 8,760 1,215 110 

#2 1968 Foster-Wheeler External wall-fired 

(FFFSG) 8,760 1,215 110 

#3 1976 Foster-Wheeler External wall-fired 

(FFFSG) 8,760 1,237 110 

#4 1983 Foster-Wheeler External wall-fired 

(FFFSG) 8,760 2,956 295 

4.0 APPLICABLE REQUIREMENTS

Applicable requirements are those regulatory requirements that apply to a stationary source or to 

emission units contained within the stationary source. Certain activities at the Reid Gardner 

station are regulated and/or permitted by the Clark County Health District, Department of Air 

Quality Management. The County-level regulations will apply to conditions outside the scope of 

this Class I operating permit and will not be discussed in this technical review. 

In Nevada’s program, the regulations governing the emissions of air pollutants from which the 

applicable requirements originate are derived from four categories of regulations. These four 

categories consist of the requirements contained in the Nevada Revised Statutes (NRS), the 

Nevada Administrative Code (NAC), the Approved State Implementation Plan (ASIP) and the 

Code of Federal Regulations (CFR, contained within various Parts within Title 40). 

 

4.1 STATE STATUTE AND ADMINISTRATIVE CODE

The Nevada Revised Statutes (NRS) and the Nevada Administrative Code (NAC) require that 

where state regulations are more stringent in comparison to Federal regulations, the State 

regulations are applicable. The Reid Gardner Station will be subject to NAC and NRS. 

4.1.1 NEVADA REVISED STATUTES 

The Nevada Revised Statutes (NRS) are the statutory authority for the adoption and 

implementation of administrative regulations. Reid Gardner is subject to NRS stipulated in NRS 

445B.100 through 445B.640, which refer to the control of air pollution. The NRS specifies the 

State Environmental Commission is the governing body given the power to adopt administrative 

regulations. Because the NRS is the enabling statutory authority, very few specific requirements 

are contained in the statutes. Rather, the NRS provides broad authority for the adoption and 

implementation of air pollution regulations. 

4.1.2 NEVADA ADMINISTRATIVE CODE 
The Nevada Administrative Code (NAC) are administrative regulations that contain specific 

requirements relating to the control of air pollution. Reid Gardner is also subject to the NAC 

445B.001 through 445B.3791, inclusive that govern the control of air pollution from regulated 

facilities in Nevada. The State Environmental Commission adopts these regulations. The NAC 

requires that, where State regulations are more stringent in comparison to Federal regulations 

that the State regulations are applicable. 

4.2 NEVADA APPLICABLE SIP (ASIP) 

The Applicable State Implementation Plan (ASIP) is a document that is prepared by a State or 

local air regulatory agency and required to be submitted to the USEPA for approval. Title I of 

the Clean Air Act is the statutory authority for the USEPA regulations that require a State to 

submit a SIP. The contents of the SIP are intended to show how a State, through the 

implementation and enforcement of the regulations contained in the SIP, will either show 

attainment of the National Ambient Air Quality Standards (NAAQS) will be achieved or how a 

State will continue to maintain compliance with the NAAQS. 

In general, the regulations contained in the ASIP closely parallel the current NAC regulations. 

However, because the ASIP is currently on the process of being updated, compliance with all of 

the current NAC regulatory requirements does not necessarily ensure compliance with all of the 

current ASIP regulatory requirements. All of the equipment considered in this application must 

meet, at minimum, the standards set forth in the ASIP. 

4.3 CODE OF FEDERAL REGULATIONS 

The Code of Federal Regulations (CFR) are regulations adopted by the USEPA and published in 

the Federal Register pursuant to the authority granted by Congress in the Clean Air Act. The 

CFR addresses multiple topics, including but not limited to: permitting requirements, 

performance standards, testing methods and monitoring requirements. 

4.3.1 NEW SOURCE PERFORMANCE STANDARDS 

The Reid Gardner facility is subject to performance standards under the New Source 

Performance Standards, 40 CFR Part 60. 

NSPS Overview. 

System Applicability 

#1 Not applicable based on construction date of 1963. 
#2 Not applicable based on construction date of 1965. 

#3 Applicable. Subpart D boiler. Standards of Performance for Fossil-fuelfired steam generators for which construction is commenced after August 

17,1971.

#4 Applicable. Subpart Da boiler. Standards of Performance for Electric 

Utility Steam Generating units for which construction is commenced after 

September 18, 1978.

Coal unloading and 

conveying systems 

Applicable to Unit #3 and Unit #4 equipment. Subpart Y. Standards of 

Performance for Coal Preparation Plants . (commencing construction or 

modification after October 24, 1974) 

Coal Silos Applicable to Unit #1-4 equipment. Subpart Y. Standards of 

Performance for Coal Preparation Plants . (commencing construction or 

modification after October 24, 1974) 

Coal crushing and 

screening station 

Not applicable, constructed prior to applicability date of October 24, 1974 

for Subpart Y. 

No. 2 Distillate fuel 

oil storage tank 

Not applicable due to installation date of 1964. 

Soda ash, fly ash 

and lime tanks/silos 

Not applicable; no NSPS categories. 

No other emission units, except those previously mentioned in the table above are currently 

subject to NSPS requirements at Reid Gardner. 

4.3.2 PREVENTION OF SIGNIFICANT DETERIORATION REGULATIONS (PSD) 

40 CFR Part 52.21 specifies that PSD review is required for any new major stationary source or 

any major modification. A major source is defined as any pollutant emitting activities, which 

belong to the same two-digit Source Industry Classification and: 

1. emits 100 tons/yr or more of a regulated air contaminant as one of the listed 

categories of sources listed in 40 CFR 52.21; or 

2. emits 250 tons/yr or more of a regulated air contaminant and belong to any other 

category source. 

The facility is a fossil fuel-fired steam electric plant with more than 250 MMBtu/hr heat input 

and has a total potential to emit of regulated pollutants that exceeds 100 tons/year. Therefore, 

the facility is a PSD source. Any modification to the facility that increases the emissions above 

the applicable significant emission threshold will require a new PSD/NSR review of the source. 

It should be noted that the baseline date for the hydrographic area was triggered May 21, 1979. 

As such, additional emissions from this facility will consume increment. A PSD review is not 

required for this permit action because it is being conducted pursuant to a consent decree 

approved by the United States District Court and a State-issued order. 

4.3.3 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS 

The federal National Emission Standards for Hazardous Air Pollutants (NESHAP) provisions are 

contained in 40 CFR Parts 61 and 63. The Reid Gardner Title V permit application and 
NDEP/BAPC HAPs calculations dictate that the facility is not major for HAPs and subject to 40 

CFR parts 61 and 63. However, the USEPA is currently studying the levels and impacts of 

mercury emissions from large coal combustion sources in the U.S. Until new NESHAP 

requirements for coal burning boilers are mandated by the USEPA, there are no underlying HAP 

or NESHAP requirement conditions for the proposed Title V operating permit. 

4.3.4 COMPLIANCE ASSURANCE MONITORING 

The USEPA has promulgated requirements for sources to provide detailed monitoring plans that 

will ensure compliance with all applicable requirements. These monitoring requirements are 

contained in 40 CFR Part 64. Section 64.2 specifies that these monitoring requirements apply to 

a “pollutant specific emission unit at a major source” if all of the following are satisfied: 

- The unit is subject to an emission limit or standard; 

- The unit uses a control device to achieve compliance with any such emission 

limitation or standard; and 

- The unit has the potential pre-control device (uncontrolled) emission equal to or 

greater than 100% of the amount, in tons per year, required for a source to be 

classified as a major source. 

- Part 64.5 requirements specify that a CAM plan be submitted by a facility if it has not 

submitted a Part 70 application by April 20, 1998, or that the Part 70 application was 

not deemed complete by that date. 

According to permit records, the initial Reid Gardner Title V application was received by NDEPBAPC on January 3, 1996. Therefore, the current permit action does not require a CAM plan. 

However, when Reid Gardner renews its permit or requests a significant revision, a CAM plan 

will be required. 

4.3.5 ACID RAIN PROGRAM 

The Clean Air Act Amendments of 1990 (Title V) established a requirement to reduce the 

emissions of pollutants contributing to acid rain (SO2 and NOx). The USEPA is responsible for 

developing regulations and implementing the requirements of the acid rain provisions of the 

Clean Air Act. The four boilers at the Reid Gardner facility are applicable to the regulations and 

allowances of Phase II of the Acid Rain Program. The requirements are incorporated into the 

new Title V permit for reference. 

4.3.6 ACCIDENTAL RELEASE PROGRAM

The Chemical Accident Prevention Provisions are contained in 40 CFR, Part 68. The Reid 

Gardner Station is required to comply with the Chemical Accident Prevention Provisions, if the 

facility stores any chemicals regulated by 40 CFR, Part 68, in quantities greater than their 

respective threshold quantity. 

4.3.7 PROTECTION OF STRATOSPHERIC OZONE 

The Protection of Stratospheric Ozone Provisions are contained in 40 CFR, Part 82. The Reid 

Gardner Station is required to comply with 40 CFR, Part 82, if the facility operates any 
equipment or store any products regulated by 40 CFR, Part 82. The permit application states 

that 40 CFR Part 82 requirements are not applicable because the facility does not service its own 

air conditioning equipment or store any regulated products. 

4.3.8 EMERGENCY EPISODES PLAN 

NAC 445B.230.1 requires a plan for the reduction of emissions from any facility that is able to 

cause or permit the emission of 100 tons or more per year of a regulated pollutant from a 

stationary source. The facility is required to prepare and submit to NDEP-BAPC a plan for 

reducing or eliminating emissions in accordance with the episode stages of alert, warning and 

emergency as defined in the air quality plan for the State of Nevada. 

On February 11, 2000, NPC submitted a revised emergency episodes plan (EEP) for the facilities 

owned and operated by NPC in Clark County, Nevada, including Reid Gardner. The plan was 

determined acceptable by NDEP-BAPC. 

4.4 DUST CONTROL PLAN 

The NDEP-BAPC requires that permit holders who disturb 20 acres or more of topsoil must 

submit a dust control plan as one of the necessary measures to prevent particulate matter from 

becoming airborne (ASIP 445.734). The dust control plan is a written plan signed by a facility’s 

responsible official that outlines the methods a facility will use to minimize fugitive dust. 

The Reid Gardner facility disturbs more than 20 acres of topsoil through activities such as 

unpaved roads and coal storage piles. The topsoil disturbance activities are directly related to the 

boiler systems and therefore fall under the jurisdiction of NDEP-BAPC. 

In addition, the previously issued PSD permits for boiler Units #3 and #4 outline specific dust 

control requirements that will be carried into the Title V permit. These include : 

- the main road to the facility be paved; 

- roads within the facility be graveled and treated with surfactant; 

- coal conveyors be completely enclosed; and 

- coal stock piles be compacted and treated with chemical dust suppressant as required. 

 

5.0 AMBIENT AIR IMPACT 

5.1 AIR DISPERSION MODELING 

The facility is located in Hydrographic Area (HA) 218 (California Wash). However, a short 

distance from Basin HA218 is Basin HA212 (Las Vegas Valley). The Reid Gardner facility has 

triggered the minor source baseline date for PSD in these basins. The facility is triggered for 

PM10, NOx and SO2. No modeling is conducted because these permit revisions are pursuant to 

consent decree approved by the United States District Court and a State-issued order. 
6.0 CONCLUSIONS / RECOMMENDATIONS

The operating permit has been modified pursuant to the requirements contained in the Consent 

Decree and State-issued order, and will undergo the full public participation requirements of 

Nevada’s approved Part 70 program. Upon completion of these requirements, the Decree and 

Order requirements will be contained in the Class I Operating Permit as required by the Consent 

Decree. 

_________________________________________________ 

Tobarak Ullah, P.E. Date 

Staff Engineer 

_________________________________________________ 

Matthew A. DeBurle, P.E. Date 

Supervisor, Class I Permitting Branch 

Attachments: 

(1) Draft Air Quality Operating Permit #AP4911-0897 

Attachment 1

Draft Air Quality Operating Permit 

[Note: Changes are in Red.]