- - 1

-- Adopted R e gu lati o n R 14 5

- 13 ATTACHMENT A

June 5, 2014 SIP Revision Nevada Division of Environmental Protection

ADOPTED R E G ULA T ION OF THE S TATE

EN V IRON M E NTAL COM M I SS ION

LCB F i l e No. R145

- 13

Ma y 2 , 2014

E X P L A N A T I O N

– M a tt e

r i n i t a l i cs i s n e w ; ma t t e

r i n b r ac k e t s [ o mi t t e d m a t e r i a l ] i s m a t e

r i al t o b e o m i tt e d

.

A U TH O R I TY: §§1 a nd 2 , NRS 445 B .2 1 0.

A REG U L A T I O N re lati n g to a ir pollut i on; r e vis i ng pro v is i ons g ov e rni n g a mb i e nt air qu a l i t y stand a rds a nd ce rt a in e n v ironm e ntal e v a luation s ; a nd p r ovid i ng other m a t te rs p r op e r l y

r e lating t h e r e to.

S ec tion 1. N A C 445 B

. 22097 is h e r e b y a men d e d to r ea d a s follows:

445 B .22097 1. The t a ble c ontain e d in t his s ec t i on l i sts the min i m u m s t a nd a rds of qu a l i t y

for a mb i e nt ai r

.

N E V A D A S T A N D A R D S A N A TI O N A L S T A N D A R D S B

PO L L U T A NT A

V ER A G I NG TI M E C ON C E N TR A TI ON C M ET HOD D P R I M A R Y C, E S E C ONDA R Y C, F M ET HOD D

O z o ne 8 h o u r s 0

. 075 ppm C h e m i l u m i n e s c e nce 0

. 075 ppm S a m e as p r im a r y C h e m i l u m i n e s c e n ce

O z o ne

- L ake T a h o e

B a s in

, #90 1 h o ur 0

. 10 ppm

( 195 μg/ m

3 ) U l t r av i o l et a b s o r p t i

o n

-- -- --

C a r b o n m o n o x i de

l e s s t h a n 5

, 000′

a b o v e m e a n s e a l e v e l
8 h o u r s 9 ppm

( 10

, 500 μg/ m

3 )

N o n d i s p e rs i ve

i n f r a r ed p h o t o m

e t r y 9 ppm

( 10 m g / m 3 ) N o ne N o n d i s p e rs i ve

i n f r a r ed p h o t o m

e t r y A t or g r ea t e

r

t h an 5

, 000′ a b o v e

m e a n s e a l e v e l 6 ppm

( 7

, 000 μg/ m

3 )

C a r b o n m o n o x i de at

any e l e v a t i

o n 1 h o ur 35 ppm

( 40

, 500 μg/ m

3 ) 35 ppm

( 40 m g / m 3 )- - 2

-- Adopted R e gu lati o n R 14 5

- 13 N E V A D A S T A N D A R D S A N A TI O N A L S T A N D A R D S B

PO L L U T A NT A

V ER A G I NG TI M E C ON C E N TR A TI ON C M ET HOD D P R I M A R Y C, E S E C ONDA R Y C, F M ET HOD D

N i t r o gen d i o x i de An n

u a l a r i t h m e t i c

m e a n 0

. 053 ppm

( 100 μg/ m

3 ) G a s p h a s e

c h e mi l u m i n e s c e n ce 53 pp b G S a m e as p r im a r y G a s p h a s e

c h e mi l u m i n e s c e n ce 1 h o ur [

-- ] 100 ppb

-- 100 ppb N o ne

S u l f ur d i o x i d e An n

u a l a r i t h m e t i c

m e a n 0

. 030 ppm

( 80 μg/ m

3 )

U l t r av i o l et

f l u o r e s ce nc e 0

. 03 pp m H

( 1971 s t a n da r d)

N o ne Spec t r o p h ot o m e t r y

( Pa r a r o s ani li ne

m e t h o d) 24 h o u r s 0

. 14 ppm

( 365 μg/ m

3 ) 0

. 14 pp m H

( 1971 s t a n da r d)

3 h o u r s 0

. 5 ppm

( 1

, 300 μg/ m

3 ) N o n e 0

. 5 ppm

1 h o ur [

-- ] 75 ppb

-- 75 ppb N o ne

Pa r t i c u l a t e m a tt er

as P M 10 An n u a l a r i t h m e t i c

m e a n 50 μg/ m 3

H i g h v o l u m e PM 10

s a m p li ng N o n e N o ne

--

24 h o u r s 150 μg/ m 3 150 μg/ m 3 S a m

e as p r im a r y H i

g h o r l o w v o l u m e

P M 1 0 s a m p li ng

Pa r t i c u l a t e m a tt er

as P M 2

. 5 An n u a l a r i t h m e t i c

m e a n [

-- ] 15

. 0 μg / m 3

-- 15

. 0 μg/ m 3 S a m

e as p r im a r y L o w v o l u m e PM 2

. 5

s a m p li ng 24 h o u r s [

-- ] 35 μg / m 3

-- 35 μg/ m 3 S a m

e as p r im a r y

L ead ( P b ) R o l l i ng 3 m o

. a v e r age 0

. 15 μg/ m 3 H i g h v o l u m e

s a m p li ng, a c i d

e x t r ac t i o n a n d at o mi c

ab s o r p t i o n

s pec t r o m e tr y 0

. 15 μg/ m 3 S a m

e as p r im a r y H i

g h v o l u m e

s a m p li ng, a c i d

e x t r ac t i o n a n d

at o mi c a b s o r p t i

o n

s pec t r o m e tr y

H y d r o gen s u l f

i d e 1 h o ur 0

. 08 ppm

( 112 μg/ m

3 ) I U l t r av i o l et

f l u o r e s ce nc e -- -- --

Not e s:

Note A: The Di r ec tor sh a ll use the N e v a da s t a nd a r ds in c onsid e ring wh e th e r to issue a p e rmit for

a station a r y sour c e a nd s h a ll e nsure that the stati o n a r y sour c e will not c a u s e the Ne v a da

stand a rds to be e x cee d e d in a rea s w h e re t h e g e n e ral pub l ic h a s a c c e ss. For t h e 2006 particu l

ate- - 3

-- Adopted R e gu lati o n R 14 5

- 13 m a t ter as PM

2

. 5 24

- h o u r a n d a n n u al s t

a n dar d s, t h e 2010 n i t

rogen dioxi

d e 1

- h o u r s t

a n dard

a n d t h e 2010 s u lfur d

io x ide 1

- h o u r s t

a n dard, t h e Dire c tor s h all u se t

h e f orm of t h e

sta n dards s e t forth in 40 C.F

. R. § § 50.11, 50.13 a n d 50.17, as t h ose p rovisio n s exis t

e d on

t h e e f f e c t i v e date of t

h is r e g ul at i o n , t o e n s u re t

h at t h e N ev a d a sta n dard is n o more s t

ri n g e n t

th a n t h e Nat i o n al s t a n d a rd in d e t e r m i n i n g w h e t

h e r t h e s t at i o n ary sour

c e wi l l c o mp l y wi t h

t h e N ev ada sta n dards i n are a s w h e r e t h e g e n e ral p u bl

i c h as a cce ss.

Note B : The N a t i on a l s ta nd a rds a r e u s e d in det er m i n a t i ons of a t t a in m e nt or non a t t a in m e nt.

The fo r m of a N a t i on a l s t a nd a rd is the c rite r ia whi c h m ust be s a t i sfi e d for e ac h r e spe c t i ve

c on ce nt r a t i on lev e l of a s tand a rd f or t h e purp oses of a t t a in m e nt. The f o rm f or eac h N a t i on a l

stand a rd is s e t forth in 40 C. F .R. P a rt 50 a nd m a y be vie we d a t

h t t p ://w w w
. e p a.gov/a i r / cr it e r ia. ht m l.

Note C: W h e re a ppl i ca b l e a nd e x ce pt as oth e r w ise d e s c rib e d in Note G, c o n ce ntr a t i on is

e x p re ssed f

irst i n uni t s in wh i c h it w a s ad o pted. [ All m ea sur e ment s ] M e a s u r e m e n t

s of a ir

qu a l i t y that a re e x p re ssed a s ma s s per unit volu m e , such a s m i c ro g r a ms per c ubic met e r, must be

c o r re c ted to a r e f

e r e n c e t e mpe ra tu r e of 25 d e g r e e s C e nt i g r a d e a nd a r e f e r e n c e pr e ss u re of 7 6 0

mm of H g ( 1,013.2 m i l l iba r s [ ) ; ] ), e x c e pt m e as u r

e m e n ts of pa r t i cu la t e m a t t e r as P M 2

. 5 a n d

lead ( Pb ), w h ich are c alcu l

ated in m icrogr

a m s p e r cubic m e ter at lo c al cond i t i o n s; “ ppb” in

th i s table re fers to p a rts p e r billion b y volu m e , or n a nomo l e s of r e g ula t e d a ir pol l utant p e r mole

of g a s; “ ppm” r e fers to p a rts p e r m i l l ion b y volu m e , or mic r omo l e s of re g u l a ted a ir pollutant p e r

mo l e of g a s; “μ g / m 3 ” r ef

e rs to m i c r o g r a ms p e r c u bic m e te r

.

Note D: R e f

e r e n c e met h od a s des c rib e d b y the EP A. A n y r e fer e n c e meth o d sp ec ified in

acc o r d a n c e with 40 C

. F

. R. P a rt 50 or a n y r e f e r e n c e method or e qui v a lent method d e si g n a t e d in

acc o r d a n c e with 40 C

. F

. R. P a rt 53 m a y be subs t i t uted.

Note E: N a t i on a l prim a r y stand a rds a r e the l e v e ls of a ir qu a l i t y n e c e ssa r y , with an- - 4

-- Adopted R e gu lati o n R 14 5

- 13 a d e qu a t e ma r g in o f s a f

e t y , to pro t e c t t he publ i c h ea l t h.

Note F : N a t i on a l se c on d a r y stand a rds a re t h e le v e ls of a ir qu a l i t y n e c e ss a r y to p r o t ec t the

publ i c w e lf

a r e f rom a n y known or a nt i c ipat e d a d v e rse e f f ec ts of a re g ulat e d a ir po l lu t a nt.

Note G: The o f

fi c ial N a t i on a l annu a l s t a nd a rd f or ni t ro g e n dio x ide is 0.053 ppm. The N a t i o n a l

a nnu a l s t a nd a rd is identi f ied in th i s table in e quival e nt un i ts of p a rts p e r billion for the pu r pose

o f si m pl if y i n g i t s comp a rison with t he N a t i on a l 1

- h o ur stand a rd w h i c h is also i d e nt i fi e d in pa r ts

per bi l l i on.

Note H: The 1971 N a t i on a l su l fur dio x ide stand a rds re main in e f f ec t f o r a n a r e a unt i l 1 y e a r

aft e r the a rea is desi g n a ted f o r the 2010 Na t i on a l su l fur dio x ide stand a rd, e x ce pt t h a t i n a n a rea

d e si g n a t e d non a t t a in m e n t for the 1971 Na t i on a l s ulfur dio x ide stand a rds, the 1971 st a nd a rds

r e main in e f

f ec t un t il a n i mp l e ment a t i on plan to a t t a in or maintain the 2010 Na t i on a l su l fur

dio x ide stand a

rds is a ppro ve d.

Note I : The a mb i e nt a ir q u a l i t y stand a rd f or h y d r o g e n sulfi d e do e s not inc l ude

n a tur a l l y o cc u r

ri n g b ac k g round c o n ce ntr a t i ons.

2. Th e se stand a rds of q u a l i t y f or a mb i e nt air a re m i ni m um g o a ls, and it is t he in t e nt of

the Com m is s ion in t his s ec t i on to prot ec t t he e x is t ing qu a l i t y of N e v a d a ’ s air to the e x tent

that it is ec onom i ca l l y a nd t e c hni c a l l y f ea sib l e

.

S ec . 2. N A C 445 B .311 is he re b y a men d e d to r e a d a s follows:

445 B .311 1. An e nvi r onment a l ev a luation wh i c h is r e quir e d for a n e w o r modifi e d

station a r y so u r c e p u rsu a n t t o N A C 445 B .308 to 445 B .314, inclusiv e , or a s r e quir e d b y the

Dir e c tor must c ontain a c a r e ful a nd d e tailed a s s e s s ment of the e nvironme n t a l asp ec ts of- - 5

-- Adopted R e gu lati o n R 14 5

- 13 the p r opos e d st a t i on a r y sou r c e a nd must also c ontain:

( a ) The n a me a nd a dd r e ss of the a ppl i ca nt;

(b) The n a m e , a dd r e ss a nd loc a t i on of the stationa r y sour c e ;

( c ) A d e s c ription of the p r opos e d st a t i on a r y sou r ce , includi n g the no r mal hours of

op e r a t i on of the f

a c i l i t y a nd the g e n e r a l t y

p e s of ac t i vi t ies to be p e r f o rm e d;

(d) A m a p showi n g the l o ca t i on of the stationa r y sour c e a nd t h e topogr a p h y of the a r ea ,
including e x is t ing prin c i p a l str ee ts, ro a ds a nd highw a y s within 3 m i l e s of the station a r y

sour c e ;

( e ) A site pl a n showi n g t he loc a t i on a nd h e i g ht of bui l din g s on the si t e ;

(f ) A n y a ddi t ional info r mation or do c ument a t i on whi c h the D ir e c tor d e e ms ne ce ss a r y to

d e te r m i ne the e f

f e c t of t h e station a r y sour c e on the qu a l i t y of the a mb i e nt a i r, in c lud i ng

me a sur e d d a ta on the qu a l i t y o f the a mb i e nt air a n d met e o r olo g i ca l condit i ons a t t he

pro p osed si t e b e fo r e c onstru c t i on o r modifi ca t i on; a nd

(g) [ A ] E x ce pt as ot h e r w ise pro v ided in s u bse c t io n 5, a dispe r sion an a l y s is of eac h re g ulat e d

a ir pollutant.

2. W h e re a ppro v a l i s sou g ht for s t a t i on a r y sour c e s to be c onstru c ted in p h a s e s, the

info r mation r e quir e d b y s ubse c t i on 1 must be submit t e d for eac h p h a se of t he

c onstru c t i on p r oje c t.

3. An e nvironm e ntal e v a luation m ust also consider g ood e n g in e e ri n g pra c t i c e sta c k

h e i g ht. I f the D ir e c tor c onsid e rs a n a n a l y sis of a so u r c e b a s e d on a g ood e n g ine e r i ng p r ac t i c e

s t ac k h e i g ht t h a t e x cee ds t h e h e i g ht sp e c ified in pa ra g ra ph ( a ) or (b) of subs e c t i on 1 o f N AC

445 B .083, the D i r ec tor s h a l l :

( a ) Noti f y the public o f the a v a i l a bi l i t y o f the d e m onstr a t i on stu d y p e r fo r m e d pu r suant

to p a ra g r a ph (c) of subs e c t i on 1 of N A C 445 B .083; a nd- - 6

-- Adopted R e gu lati o n R 14 5

- 13 (b) P rovide a n oppo r tun it y f or a publ i c h e a ri n g on the d e monstr a t i on stu d y in a cc o r d a n c e

with t he re quir e ments f

o r a Class I o p e r a t i ng p e r m it set f o r th i n subse c t i ons 7, 9 a nd 10 of

N A C 445 B .3395.

4. A disp e rsion a n a l y s i s used to d e te r m i ne the l o ca t i on a nd e st i mat e d v a l ue of the

h i g h e st c on ce nt r a t i on of e a c h regulat e d a ir pollutant must i n c lude:

( a ) A disp e rsion mo d e l bas e d on the a ppl ic a ble m od e ls, bas e s and oth e r r e quir e ments

spe c ified in t he “ Guid e l i ne on Air Qu a l i t y Mod e l s,” w hich is App e ndix W of 40 C. F .R. P a rt

51, a s ad o pted b y r e fer e n c e i n N A C 445 B .221, e x ce pt that the D ir ec tor m a y a u thori z e the

mod i fi ca t i on of a model spe c ified in t he “ Guid e l i ne on Air Qu a l i t y Mod e l s” or the use o f a

model not i n c luded in the “ Guid e l i ne on Air Q u a l i ty Models” i f the Dire c to r :

(1) D e t e rmin e s that the mod i fi ca t i on or use is a p p r opri a te;

(2) Obt a ins writ t e n a p p r ov a l of the mod i fi ca t i on or use f rom the A dm i nis t r a tor; a nd

(3) P rovid e s notice of a n d e stablishes a 3 0

- d a y p e riod f or c om m e nt i n a c c o rd a n c e with

t he a ppl i ca ble p r ovis i ons of N A C 445 B .3364, 44 5 B

. 3 395, 445 B .3447, 445 B

. 3 457 or

445 B .3477;

(b) A n a rra t i ve r e port d e s c ribin g :

(1) I f a ppl i ca ble, a ssu m pt i ons a nd p re m i s e s used in the a n a l y si s , includin g , without

l i m i tation:

( I ) Model options c hos e n;

( I I ) U rb a n v e rsus r u r a l s e le c t i on;

( I I I ) B ac k g round c on c e n tr a t i ons;

( I V) Ch a r a c t e ri z a t i on of e m i ss i on sour ce s as point, a re a o r volume;

( V ) Emiss i on dis c h a r g e poin t s; and- - 7

-- Adopted R e gu lati o n R 14 5

- 13 ( V I ) R a te o f e m i ss i on f

r om e ac h e m i ss i on uni t ; and

(2) The g e o g ra phic a rea c onsid e r e d in t he a n a l y si s , includin g , without l i m i tation,

info r mation con c e rnin g :

( I ) The n ea r e st s i g nif

i c a nt t e rra in f

e a tur e s;

( I I ) T h e r e ce ptor g r id or g rids; and

( I I I ) R e strictions on publ i c ac c e ss t o the stationa r y sour ce ; and

( c ) V a l i d met e o r ol o g ic a l info r mat i on pu r suant to the pro v is i ons of A pp e nd i x W of 40 C. F .R.

P a rt 51, a s ad o pted b y r e f e r e n c e in NAC 44 5 B .22 1 , whi c h:

(1) F o r sou r c e s that a r e not subje c t t o the p e rmit t ing re qu i r e ments of 40 C

. F .R. § 52.21,

a s a dopted b y r e f

e r e n c e in N A C 445 B .221:

( I ) I s si t e sp e c ific, if the info r mation e x is t s pursu a nt t o subse c t i on 1 of th i s se c t i on

or subse c t i on 6 of N A C 44 5 B .308, a nd wh i c h c ov e rs a p e riod of not l e ss t h a n 1 y e a r;

( I I ) H a s b e e n obtain e d fr om an o f f

- si t e lo c a t i on rep re s e ntative of t h e pro p o s e d site

a nd whi c h c ov e rs a p e riod of not l e ss t h a n 1 y e a r;

( I I I ) R e p re s e nts t he wo r st

- ca se me t e o r ol o g ic a l c o ndi t ions, a s ap p rov e d b y the D ir ec tor

for s y nthetic d a ta; or

( I V) H a s be e n ob t a ined ov e r the last 5 y e a rs a t t h e n ea r e st N a t i on a l W ea t h e r Se r vi c e

si t e ; or

(2) F o r sou r c e s that a r e subj ec t t o the p e rmit t ing r e quir e ments of 40 C. F .R. § 52.21, a s

a dopted b y r e f

e r e n c e in N A C 445 B .221, is re p r e s e ntative of the sou r c e si t e loc a t i on a nd sour c e

e m i ss i ons a nd whi c h c o v e rs a p e riod of not l e ss t h a n 1 y e a r.

5. A dispersion a n a lysis fo r :

(a) T h e 1

- h o u r n i t

rogen diox i

de sta n dard e stab l

i s h e d in NAC 445B.220 9 7 is n ot required

in an e n v iro n m en tal ev al u at i on f or:- - 8

-- Adopted R e gu lati o n R 14 5

- 13 (1) A n e w sta t io n ary s o u r c e if t h e n e w sta t io n a r

y so u r c e e m i t s, or h as t h e poten t ial to

e m i t , less t h an 40 t o n s of n i t rogen dioxide p e r y e ar; or

(2) A proposed m odifi c at i on to an e xi s t in g st a t i o n ary sour

c e if t h e proposed

m odifi c at i o n h as t

h e po t e n t i al t o e m it less t

h an 4 0 to n s of n i trogen d

i o x i d e p e r y e a r

.

(b) T h e 1

- h o u r s u lfur d

i oxide sta n dard e stab l

i s he d in NAC 445B.22097 i s n ot required in

an e n v iro n m e n tal ev al

u at i on f or:

(1) A n e w sta t io n ary s o u r c e if t h e n e w sta t io n a r

y so u r c e e m i t s, or h as t h e poten t ial to

e m i t , less t h an 40 t o n s of s u lfur diox i

de p e r y e ar; or

(2) A proposed m odifi c at i on to an e xi s t in g st a t i o n ary sour

c e if t h e proposed

m odifi c at i o n h as t

h e po t e n t i al t o e m it less t

h an 4 0 to n s of sulfur dio x ide p e r y e a r

.ATTACHMENT B

June 5, 2014 SIP Submittal TSD Nevada Division of Environmental Protection



# Technical Support Document for Nevada State Implementation Plan Revisions Addressing
Minor Source Permitting ProgramThis page is intentionally blank.B

- 1



### I. Introduction

Section 110(a)(2)(C) of the Clean Air Act (Act) requires that each state implementation plan (SIP) include a program to provide for ‘‘regulation of the modification and construction of any stationary source within the areas covered by the plan as necessary to assure that national ambient air quality standards are achieved, including a permit program as required in parts C and
D’’ of title I of the Act. T he permit programs required in parts C and D of title I of the Act apply to new or modified ‘‘major’’ stationary sources of pollutants. Part C applies to certain new or modified sources in areas designated as attainment or unclassifiable and is designed t o prevent significant deterioration of air quality. The requirements under Part C are commonly referred to as “PSD New Source Review.” Part D applies to sources in nonattainment areas and is commonly referred to as “Nonattainment New Source Review. Both of these programs apply to “major stationary sources” and “major modifications” as those terms are defined in 40 CFR Part 51 Subpart I.

In addition to the PSD and Nonattainment New Source Review requirements, a state’s implementation plan must provide for the regulation of the construction and modification of any stationary source within the areas covered by the plan as necessary to assure that the national ambient air quality standards (NAAQS) are achieved. These general pre

- construction requirements are commonly referred to as ‘‘minor NSR.’’ See 40 CFR 51.160

- 51.164. The requested revisions to the Nevada SIP set forth herein address deficiencies identified by the U.S. Environmental Protection Agency (USEPA) regarding Nevada’s minor NSR program.

The Neva da Division of Environmental Protection (NDEP) Bureau of Air Quality Planning (BAQP) and Bureau of Air Pollution Control (BAPC) is the air pollution control authority for all areas of Nevada except for Clark and Washoe Counties, Nevada. The NDEP retains j urisdiction
over sources that are fossil fuel

- fired steam electrical generating units in Clark County.



### II. Minor NSR Program SIP Revision Submittals

Appendix V to 40 CFR Part 51 sets forth required technical support documentation to support a
SIP submittal or revision. This Technical Support Document (TSD) identifies and responds to the requirements set forth in section 2.2 of that provision to support the State’s proposed SIP
revisions.

(a) Identification of all regulated pollutants affected by the plan

The revi sions that are the subject of this TSD concern three criteria pollutants: (1) the 2006

PM 2.5 standard; (2) the 2010 NO 2 standard; and (3) the 2010 SO 2 standard. The latter two
standards are 1

- hour standards, and are, at times, referred to as the 1

- hour standards within thisdocument. The new and revised rules allowing the State to implement those standards were

adopted by the State Environmental Commission on May 2, 2014. The NDEP is the Governor’s designee for submitting official revis ions of the Nevada SIP to the US EPA. The revisions to the
Nevada Administrative Code (NAC) for which the NDEP is requesting approval as revisions to
the Nevada SIP are as follows:

1. NAC 445B.22097:

a. Insertion of the 2006 PM 2.5 24

- hour and annual standards, t he 2010 1

- hour SO 2 standard, and the 2010 1

- hour NO 2 standard into the State side of the table set forth in
NAC 445B.22097.
b. Addition of language in Note A to clarify that the NDEP’s permitting decisions with respect to the 2006 PM 2.5 , 2010 SO 2 , and 2010 NO 2 standards are no more stringent
than under the federal standard.

c. Clarifying language in Note C as the conditions under which PM 2.5 and Lead are to be
measured.

2. NAC 445B.311:

a. Subsection 5 is created and adds new language providing a n air dispersion modeling threshold for an application for the 1

- hour standards if the proposed project or modification has the potential to emit less than 40 tons per year of NO 2 or SO 2

.

(b) Identification of the locations of affected sources including the EP A attainment/ nonattainment designation of the locations and the status of the attainment plan for the affected areas(s).

The NDEP’s jurisdiction extends over all areas of the State of Nevada, with the exception of Clark County and Washoe County. Those tw o counties have their own air quality planning and control departments, with one exception. The NDEP retains jurisdiction over fossil fuel

- fired steam electrical generating units in Clark County. Currently, that constitutes one facility: the
Reid Gardner Generating Station (Reid Gardner). Reid Gardner is subject to state legislation calling for its retirement as a coal

- fired power plant, but the legislation contemplates that the NDEP will retain jurisdiction over that facility if new electrical generatio n units are constructed. (Senate Bill 123 (June 2013)).

The State is designated as follows for the NAAQS that are the subject of this TSD.

1. PM 2.5 : The entire State of Nevada has been designated as attainment/unclassifiable for
the 2006 PM 2.5 National A mbient Air Quality Standards (NAAQS). 74 Fed. Reg. 58688, 58747 (Nov. 13, 2009); see also State Designations, available at http://www.epa.gov/pmdesignations/2006standards/final/region9.htm (last viewed April 11, 2014).
2. NO 2 : The entire State of Nevada has been designated as attainment/unclassifiable for the
2010 1

- hour standard. 77 Fed. Reg. 9523, 9568 (Feb. 17, 2012); see al so 2010 NitrogenDioxide Standards

– Region 9 Recommendations and EPA Responses, available at

http://www.epa.gov/airquality/nitrogenoxides/designations/region/reg ion9.html (last viewed April 11, 2014).
3. SO 2 : The State of Nevada made a recommendation to the U.S. EPA that the State be designated as attainment/unclassifiable. The U.S. EPA has not yet issued area designations for any part of the State for the 2010 1

- hour SO 2 standard.

(c) Quantification of the changes in plan allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affe cted sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.

None of the areas under the NDEP’s jurisdiction are nonattainment, and, therefore, this requirement does n ot appear to apply to these proposed SIP revisions. Nonetheless, the NDEP does not anticipate increases in allowable emissions, current actual emissions from affected sources, or changes in actual emissions from the baseline levels and allowable emissions as a result of these revisions. The revisions instead will require affected sources to comply with three new, more stringent standards, which will likely result in emission reductions.

(d) The State's demonstration that the national ambient air quality stand ards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented. For all requests to redesignate an area to attainment for a national primary ambient air quality standard, under section 107 of the Act, a revision must be submitted to provide for the maintenance of the national primary ambient air quality standards for at least 10 years as required by section 175A of the Act.



### A. Nevada’s Cu rrent Regulatory Structure

1. Federal and State Ambient Air Quality Standards

Under Nevada’s current regulatory structure, Nevada implements both federal NAAQS and state ambient air quality standards. It accomplishes this dual function pursuant to NAC 445B.22097. That regulation lists the federal NAAQS and separately lists the Nevada ambient air quality standards. The federal standards are used for purposes of designating areas as being in attainment or nonattainment with the NAAQS. The Nevada list i s used for making permitting decisions to “ensure that the stationary sources will not cause the Nevada standards to be exceeded in areas where the general public has access.” NAC 445B.22097, Note A.2. Provisions That Protect the Ambient Air Quality Standar ds

Several other regulatory provisions set forth how the NDEP will ensure that a source will not cause the state or national ambient air quality standards to be violated. NAC 445B.308 safeguards the standards by prohibiting the NDEP from issuing a permit if the applicant’s environmental evaluation shows that the facility will prevent the attainment or maintenance of a standard, will violate the SIP, or will violate an applicable requirement. NAC 445B.308(2). The NDEP may impose reasonable conditions upon a source, including monitoring requirements or the requirement to meet standards more stringent than those in the State air quality regulations. NAC 445B.308(6).

NAC 445B.311 requires applicants of sources other than those subject to prevention of sign ificant deterioration (PSD) requirements to submit an environmental evaluation with their applications pursuant to NAC 445B.308 to 445B.314 . The environmental evaluation must include, among other things, an air dispersion model that complies with the requ irements of Appendix W to 40 C.F.R. Part 51. NAC 445B.310 establishes an emission threshold above which the applicant must submit an air dispersion model as part of an environmental evaluation. Currently, new sources that emit 25 tons per year or more, o r existing sources that have a potential to emit of 25 tons per year and which are seeking a modification of 10 tons per year or more, of any regulated air pollutant must perform an air dispersion model according to Appendix

W.

Before the NDEP may issue a permit, it must determine from all “ relevant information that use of the stationary source will not result in any violation of the air quality regulations or the provisions of 40 C.F.R. § 52.21 or 40 C.F.R. Parts 60, 61 and 63, adopted by reference in NA C
445B.221 .” NAC 445B.318; see also NAC 445B.340. The NDEP may not issue a permit if the issuance would prevent attainment or maintenance of the air quality standards set forth in NAC 445B.22097. NAC 445B.308(2). In order to make that determination, the NDEP utilizes air dispersion modeling analyses as necessary.

3. Provisions Regarding Class I Sources

Under Nevada’s regulations, Class I sources are major sources and major stationary sources. They are, therefore, subject to Title V p ermitting and/or PSD permitting rather than minor new
source review. The NDEP may issue an initial, revised or renewed Class I permit only if the permit provides for compliance with “the requirements of NAC 445B.001 to 445B.3689

, inclusive, and any other applicable requirements” and U.S. EPA has had an opportunity to review the proposed permit and has no objections. N AC 445B.340.

4. Provisions Regarding Class II Sources

For Class II sources, which, by definition set forth in the Nevada Administrate Code, are minor sources as defined by U.S. EPA, the NDEP may issue a permit only after taking into account “the effect of such a facility on the maintenance of the state and na tional ambient air qualitystandards contained in NAC 445B.22097 and the applicable state implementation plan.” NAC

445B.3457(4)(c)(3). If the modeling thresholds in NAC 445B.310 are met, the applicant for a Class II permit must submit an environmental ev aluation, which includes an air dispersion model. NRS 445B.308 prevents the NDEP from issuing a permit if the agency determines that the new or modified source will prevent attainment and maintenance of the state or national
standards set forth in NAC 445 B.22097 or will cause a violation of the SIP or any applicable requirement. NAC 445B.308(2). The NDEP makes that determination by evaluating modeling analyses of the new or modified source as necessary

.

5. The Proposed Revisions to Nevada’s Applicable Sta te Implementation Plan

These regulatory revisions submitted for approval into Nevada’s SIP seek to (1) add the revised federal standards to the Nevada list so that those standards are implemented in Nevada’s permitting decisions; and (2) clarify that Nevad a’s implementation of those standards will not be more strenuous than the federal standards. The existing language in Note A prohibits a source from exceeding, in any given year, any Nevada standard where the general public has access. This is equivalent to adopting an annual 100 th percentile (or first

- high) threshold for the pollutant averaged (i.e., hourly, daily, or annual) concentrations. The revised federal standards are promulgated with a statistical “form,” which is the 3

- year average of either the 98 th percentile (24

- hour PM 2.5 ), 99 th percentile (1

- hour NO 2 , SO 2 ), or annual mean (annual PM 2.5 ). Thus, under the revised federal standards, the level of the standard may be exceeded on occasion over the three years without causing a violation of the st andard. The revision to Note A seeks to make clear that any environmental analyses required of the facility or performed by the NDEP will not be more stringent than the federal standard. In other words, currently, sources must perform their modeling anal yses to demonstrate that there will not be a single annual exceedance of the standard in areas where the public has access (i.e., annual 100 th percentile or first high). The NDEP is clarifying that, for the three new standards being adopted into the Nevad a list, modeling performed by the sources or by the NDEP for proposed new facilities or modifications of existing facilities will not be more stringent than the federal standard.

The proposed revisions to NAC 445B.22097 and to 445B.311 would require new so urces to provid e an air dispersion model in the environmental evaluation with their permit application for
the 2006 PM 2.5 standard if those sources had a potential to emit that is 25 tons per year or more of PM 2.5 . For modifications, the revisions require that an applicant submit an air dispersion analysis with the environmental evaluation if the facility emits 25 tons or more per year and the
modification would result in at least 10 tons per year increase. The threshold for requiring the applicant to sub mit a modeling analysis with the environmental evaluation for a modification, if the facility emits 25 or more tons per year of PM 2.5 , is consistent with the significant emission

rate of 10 tons per year set forth in the PSD rule at 40 C.F.R. 51.166(b)(23)(i). As the U.S. EPA
has stated:

The determination of what should be classified as a modification

subject to major NSR is based, in part, on a ‘‘significant emissionsrate.’’ The major NSR regulations d efine this term as a rate above
which a net emissions increase will trigger major NSR permitting requirements, if the increase results from a major modification. Sources are exempt from major NSR requirements if the emissions
increase resulting from a modi fication is below this rate because
EPA considers such lower emissions increases to be de minimis for purposes of the major NSR program.

73 Fed. Reg. 28321, 28332 (May 16, 2008). While the threshold for requiring the applicant to
submit an environmental e valuation for a new project is above the significant emission rate, it is

one

- fourth of the emissions that would trigger PSD review.

The proposed revisions would also establish the air dispersion modeling assignment threshold for
the 2010 1

- hour SO 2 an d NO 2 standards . For those two standards , the applicant would not be required to submit an air dispersion model with the environmental evaluation if the new or modified source were to result in less than 40 tons per year increase of the subject pollutant

. The
40 tons per year is based on the significant emission rate set forth in 40 C.F.R. 51.166(b)(23)(i). Pursuant to that regulation, an emissions increase less than 40 tons per year of SO 2 or NO 2 is not deemed significant for the purposes of PSD permitting. An increase less than that is deemed by

U.S. EPA to be insignificant for PSD applicability determinations. Id. Requiring an applicant to submit an air dispersion model only if the new project or modification exceeds those levels is protective of the NAAQS because such an increase is less than a quarter of the 250 tons per year threshold that would trigger PSD permitting under 40 C.F.R. 52.21(b)(1)(i)(b). It is also less
than half of the 100 t ons per year PSD permitting threshold for certain types of sources. 40 C.F.R. 52.21(b)(1)(i)(a). It is also consistent with the significant emission rates for precursors
for PM 2.5 formation. 40 C.F.R. 52.21(b)(23)(i). Ala. Power Co. v. Costle , 636 F.2d 3 23, at 360

- 361 (D.C.Cir. 1979) (recognizing U.S. EPA’s authority to make a de minimis exception when circumstances so merit)

. Because it is already deemed to be insignificant, it is protective of the NAAQS.

Although the modeling assignment threshold of 25 tons per year of PM 2.5 emissions for new sources is greater than the 10 tons per year significant emission rate set forth in 40 C.F.R. 51.166(b)(23), the higher threshold is protective of the state and national ambient air quality
standards for several reasons, as set forth in more detail below. First, the threshold is protective because it is merely one

- fourth of the applicable major source threshold and incorporates the significant emission rates for PM 2.5 precursors. Major sources would be subject to PSD permitting if they emit either 100 tons per year or 250 tons per year of PM 2.5 , depending on the type of the facility. A threshold that is one

- fourth of that is protective. Second, most minor
sources with PM 2.5 emissions would trigger PSD permitti ng requirements for other pollutants
before PM 2.5 emissions even approach the level of the state or federal NAAQS. Third, stationarysource emissions of PM 2.5 contribute a de minimis portion of the PM 2.5 emission inventory for

the State.



### B. The Proposed Th resholds Requiring the Permit Applicant to Submit Air Dispersion Models with an Environmental Evaluation are a Small percentage of the Major Source Thresholds , and are
, Therefore
, Protective.

First, t he existing modeling assignment threshold that would apply to the 2006 PM 2.5 standard is protective because it is merely one

- fourth of the applicable major source threshold

. Major

sources are subject to PSD permitting if they emit either 100 tons per year or 250 tons per year of

PM 2.5 , depending on the type of the facility. If a source’s emissions reach 100 tons per year or 250 tons per year, depending on the type of the source, for any criteria pollutant, it must undergo PSD permitting review for all criteria pollutants. Requiring the applicant to submit an air dispersion model for PM 2.5 with its environmental evaluation only if the potential to emit for a new source is 25 tons or more per year is protective because it is merely one

- fourth of the applicable major source threshold, and even less than one

- fourth for sources that are not subject to PSD permitting unless they emit 250 tons per year or more. Furthermore, applicants are required to submit an air dispersion model for existing sources if the source has a potential to
emit at least 25 to ns per year and the applicant seeks a modification with the potential to emit 10 tons per year or more. The significant emission rate for PM 2.5 under the federal PSD provisions is 10 tons per year. Thus, for modifications of a facility that potentially e mits 25 tons per year, the modeling requirement meets the PSD significant emission rate and is therefore protective of the NAAQS.

The proposed SIP revisions incorporate the significant emission rates for PM 2.5 precursors. The proposed revisions would req uire applicants to submit air dispersion models for the new 1

- hour standards if their sources’ potential to emit meets or exceeds 40 tons per year of NO 2 or SO 2

. Those rates are equal to the significant emission rates for NO 2 and SO 2 as precursors of PM 2. 5

. 40 CFR 52.21(2)(b)(23)(i). Thus, the proposed revisions comport with the levels of direct PM 2.5 emissions and PM 2.5 precursor emissions that the USEPA has deemed to be insignificant.

Similarly, the proposed new threshold for applicants to submit an air dispersion model for the
new 1

- hour standards is 40 tons per year, which is the PSD significant emission rate. Emissions below those levels are deemed to be insignificant.



### C. PM2.5 Sources Would Trigger PSD Permitting for Other Criteria
Pollutants Befo re PM 2.5 

### Emissions Would Interfere with Attainment or Maintenance of the NAAQS.

Second , the existing 25 tons per year threshold is protective because high

- emitting PM 2.5 minor

sources would trigger PSD permitting requirements for other criteria pollutants before PM 2.5 emissions would trigger PSD permitting

. Such facilities would then be subject to PSD review.

PM 2.5 emissions will not approach any level that could interfere with attainment or maintenanceof the state or feder al ambient air quality standards

. To make this determination, the NDEP

researched whether the existing 25 t ons p er y ear emission level is protective of the NAAQS.

The NDEP examined three types of high

- emitting stationary combustion sources in this analysi s. Those stationary combustion sources are deemed to be the ‘worst case scenarios’ for the State, based on the emissions inventory and review of published emission factors. The three combustion sources reviewed are: a) an industrial wood

- fired boiler; b ) an industrial boiler combusting residual oil; and c) an industrial reciprocal internal combustion engine combusting natural gas.

For each one of these sources, multiple emissions scenarios were created based on permit data, published AP

- 42 emission facto rs 1 , uncontrolled operations, and various controlled operating scenarios. AERMOD modeling pursuant to the requirements of Appendix W and statistical approaches were used to determine emission rates and the resulting atmospheric concentrations.

1. Material and Methods

a) Emission rates

Emission rates for each scenario were estimated using the emission factors established in the 5th
Edition of the EPA

- AP 42 (‘Compilation of Air Pollutant Emission Factors’). Besides the actual (i.e. from the permit) control scen arios and production rates, different theoretical scenarios were tested to verify how close the resulting atmospheric concentrations would be to the 24

- hour NAAQS.

b) Pollutant concentrations

Atmospheric pollutant concentrations were estimated using AERMOD v. 12345 and meteorological data processed with AerMet v.12345 pursuant to Appendix W. Five years of representative meteorological data were used, pursuant to Appendix W. The form of the standard was calculated for each scenario by using the rolling

- average of the five annual 98th percentiles (or the 8th highest values of the annual 24

- hour distribution). Finally, the average design value was used within each source type to create statistical relations between the emission scenario and resulting air quality . These relations were used to interpolate and/or extrapolate the
effects of non

- simulated emission scenarios on air quality.

1 These emissions factors are published in the 5 th Edition of the EPA

- AP 42 (‘Compilation of Air Pollutant Emission Factors’).Figure 1 : Schematic of the analysis approach adopted in this work. This diagram was repeated for each ac tivity scenario

and type of source. The definition of a specific activity scenario within the same source type and 5 years of meteorological data are the ’starting points’ of this approach. A relation describing the air quality change (e.g., the hypothetic al design value, expressed in terms of NAAQs percentage) vs. the emission scenarios is the final result.

c) Relation between PM2.5 emission scenario and other criteria pollutant

emissions

This part of the analysis relates the PM2.5 emissions and effects on air quality with the emissions of other regulated criteria pollutants under the same activity scenarios. The main objective was to examine whether the activities under the following three scenarios that cause substantial deterioration of the PM2.5 air qua lity standard would be already regulated under the PSD program. PSD permits are issued for sources that emit more than 250 tons/year of any regulated criteria pollutant (SO2, CO, NOx, and PM10). For this analysis, we also considered the case of

sources e mitting more than 100,000 tons/year of CO2. For the purposes of this analysis, the NDEP did not consider whether the facilities would be subject to PSD permitting as one of the enumerated stationary sources emitting 100 tons per year or more of a regulate d NSR pollutant under 40 C.F.R. 52.21(b)(1)(i)(a). Assumptions were made about the operating scenarios to reflect reasonable operating parameters based on facilities that actually exist or previously
existed in Nevada. The EPA’s AP

- 42 was used to deter mine the emission factors for each pollutant and each type of source considered.

d) Background concentration

Determination of PM2.5 background concentration was performed using two monitor stations. The Jarbidge station (ID 32

- 007

- 9000), located in northern Nevada, is considered the ‘background’ station by the NDEP air quality program. As the station relies on manual samples, design values for the period 2007

- 2011 were calculated based on the reported 3

- day
concentrations. The Jean station located in Clark County (ID 32

- 0031

- 019) is managed by the Clark County Department of Air Quality and was deemed to be representative of PM2.5background concentrations for that area. However, recent analysis showed that this station is

affected by pollutant transport fr om California, possibly from the Los Angeles area. The NDEP nevertheless used this station as representative of PM2.5 background in southern Nevada and used the design values as reported by the EPA for the 2007

- 2011 period.

Table 1 : PM2.5 design values as calculated/reported for the Jarbidge and Jean monitoring stations.

Period Jarbidge (μg/m 3 ) Jean (μg/m 3 )
2007

- 2009 10.60 11 2008

- 2010 8.02 11 2009

- 2011 8.27 10

Considering that both stations reported similar values, we adopted the overall average of the design values (i.e., 9.81 μg/m 3 ) as a PM 2.5 background.

2. Synopsis of results

This section briefly describes the main results obtained from this work.

A chart is shown for each of the three source types (i.e., wood

- fired boiler, industrial oil boiler, and IC engine burning natural gas). Each chart displays the relation between simulated PM 2.5 design values (i.e., the 5

- year average, and expressed in terms of NAAQS percentage) and corresponding emission scenarios. Also, each chart displays the relation between the PM 2.5 emission scenario and the corresponding emissions of other criteria pollutants (see chart label for more details).a) Wood

- Fired boiler

Figure 2 : Average estimated percentage of the 24

- hour PM2.5 NAAQS as a function of the PM2.5 emissions caused by the different operating scenarios. Each empty circle represents the emission and resulting average percentage of the NAAQS from a sp ecific activity scenario. The dashed yellow line is the 24

- hour PM2.5 NAAQS (i.e., 100%). Based on the established linear relation between PM2.5 emissions and percentage of the NAAQS (solid line) and using the emission factors from the AP

- 42, it is possibl e to estimate for each criteria pollutant the resulting PM2.5 concentration (and hence percentage of the NAAQS) caused by an emission of 250 tons/year (100,000 tons/year for CO2). These percentages are shown as red bars. Some criteria pollutants are not sh own in the chart because the corresponding percentages of PM2.5 NAAQS are too high to be included. They are, however, reported in the table below. This chart helps determine what level of activity (and hence PM2.5 emissions) would already fall under PSD pe rmit conditions because of other criteria pollutants. For instance, a system with a wood

- fired boiler operating at 38 MMBtu/hour (scenario 1) would not trigger any PSD conditions. However, a system with the same boiler operating at 152 MMBtu/hour (scenario 3) would trigger PSD conditions because of CO and NOx emissions (and emitting more than 100,000 tons/year of CO2). See Section 3.3 below for further explanation.

Activity levels for the scenarios reported in the chart. Scenario 1 is the actual permitted case. 1 37.95 MMBtu/hour

– actual permit 3 151.8 MMBtu/hour
2 75.9 MMBtu/hour Codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is given between parentheses.

a SO 2 (1442%) c CO (60%) b NO
x (74%) d CO 2 (74%)

e PM 10 (139%)

As Figure 2 shows, a wood fired boiler operating under reasonable conditions (37.95 MMBtu/hour, which was the rate actually permitted), would be just over twenty percent of the NAAQS and less than 25 ton s/year. If we were to double that emission rate to 75.9 MMBtu/hour, its emissions would be approximately 30 tons/year, which would still be less than fifty percent of the NAAQS. It would also be above the threshold requiring the applicant to
model the fa cility or any modifications to the facility. Only if we were to double the emission rate again, from 75.9 MMBtu/hour to 151.8 MMBtu/hour would the NAAQS be potentially threatened. But even before reaching that point, the applicant would have to undergo a PSD permitting analysis for carbon monoxide, nitrogen oxides, and carbon dioxide. In fact, the 1 2 3

d

c b 0 5 10 15 20

0 20 40 60 80 100 120

0 20 40 60 80 100 PM 2.5 Emission (lb/hr) Percentage of NAAQS

PM 2.5 Emission (tons/year)facility would only reach sixty percent of the PM 2.5 NAAQS before having to undergo a PSD

analysis for carbon monoxide. The current 25 tons/year threshold fo r the applicant to provide a modeling analysis for a new facility is protective because PM 2.5 emissions would be well below the NAAQS at that level. Higher PM 2.5 emissions would result in the applicant being subject to a PSD analysis for other criteria po llutants before the PM 2.5 NAAQS were threatened. Additionally, for sources that have a potential to emit 25 tonsperyear, future modifications are subject to modeling at 10 tons per year, which is the level that the U.S. EPA deems significant pursuant to 40 CFR 52.21(2)(b)(23)(i).

b) Industrial boiler combusting residual oil

Figure 3 : Average estimated percentage of the 24

- hour PM2.5 NAAQS as a function of the PM2.5 emissions caused by the different activity scenarios. Each empty circle represents the emission and resulting average percentage of the NAAQS from a specific activity scenario. The dashed yel low line is the 24

- hour PM2.5 NAAQS (i.e., 100%). Based on the established linear relation between PM2.5 emissions and percentage of the NAAQS (solid line) and using the emission factors from the AP

- 42, it is possible to estimate for each criteria pollutan t the resulting PM2.5 concentration (and hence percentage of the NAAQS) caused by an emission of 250 tons/year (100,000 tons/year for CO2). These percentages are shown as red bars. Some criteria pollutants are not shown in the chart because the correspondi ng percentages of PM2.5 NAAQS are too high to be included. They are, however, reported in the table below. This chart helps determine what level of activity (and hence PM2.5 emissions) would already fall under PSD permit conditions because of other criteri a pollutants. For instance, a system with a 0.5% sulfur content residual oil boiler operating at 467 gal/hour and no PM2.5 control (scenario 1) would not trigger any PSD condition. However, a system with the same boiler using 1% sulfur content (scenario 2 ) would trigger PSD conditions because of SO2. See Section 3.4 below for further explanation.

Codes for scenarios and activity levels reported in the chart. Scenario 1 is the actual permit Sulfur Content = 0.5% Sulfur Content = 1%
1 467 gal/hour

– no control (actual permitted limit) 2 467 gal/hour

– no control

3 934 gal/hour

– no control 4 934 gal/hour

– no control

6 467 gal/hour

- Multiple Cyclone Controller 5 934 gal/hour

– MCC 1 2 3 4

5 6 a e

f g h

j 0 2 4 6 8 10

0 20 40 60 80 100 120

0 10 20 30 40 50 PM 2.5 Emission (lb/hr) Percentage of NAAQS

PM 2.5 Emission (tons/year)( MCC)

Codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is given between parentheses Sulfur Content = 1% Sulfur Content = 0.5%

a SO 2 (37%) f SO 2 (46%)
b NO
x standard NO burner (124%) g NO
x standard NO burner (77%)

c NO
x low NO burner (145%) h NO
x low NO burner (91%)
d CO (1163%) i CO (725%)

e CO 2 (high sulfur) (95%) j CO 2 (high sulfur) (59%)

As Figure 3 shows, an industrial boiler running residual oil with 0.5% sulfur content would trigger PSD permitting requirements for SO 2 well before the PM 2.5 NAAQS would be in jeopardy. If we were to d ouble the fuel consumption rate to 934 gal/hour, and conservatively assume that no air pollution controls are installed, the facility would still trigger PSD permitting
for SO 2 at less than half of the PM 2.5 NAAQS, no matter the sulfur content of the fuel. Conversely, if the facility we re to emit no more than 25 tons per year of PM 2.5 , it would already be subject to PSD permitting because it would be above the PSD threshold for SO 2 . If burning high sulfur fuel, it would also be subject to PSD permitting f or carbon dioxide. Again, the
current 25 tons per year threshold for the applicant to provide a modeling analysis for a new facility is protective because PM 2.5 emissions would be well below the NAAQS at that level. Higher PM 2.5 emissions would result i n the applicant being subject to a PSD analysis for other criteria pollutants before the PM 2.5 NAAQS were threatened. Additionally, modifications of sources with a potential to emit of 25 tons per year are subject to modeling if the modification is

at lea st 10 tons per year, which is the level that the USEPA deems significant pursuant to 40 CFR 52.21(2)(b)(23)(i).c) Reciprocating Internal Combustion Engine combusting natural gas

Figure 4 : Average estimated percentage of the 24

- hour PM2.5 NAAQS as a function of the PM2.5 emissions caused by the different activity scenarios. Each empty circle represents the emission and resulting average percentage of the NAAQS from a specific activity scenario. The dashed yellow line is the 24

- hour PM 2.5 NAAQS (100%). Based on the established linear relation between PM2.5 emissions and percentage of the NAAQS (solid line) and using the emission factors from the AP

- 42, it is possible to estimate for each criteria pollutant the resulting PM2.5 concentrat ion (and hence percentage of the NAAQS) caused by an emission of 250 tons/year (100,000 tons/year for CO2). These percentages are shown as red bars. Some criteria pollutants are not shown in the chart because the corresponding percentages of PM2.5 NAAQS ar e too high to be included. They are, however, reported in the table below. This chart helps determine what level of activity (and hence PM2.5 emissions) would already fall under PSD permit conditions because of other criteria pollutants. For instance, with this type of system, all the emission scenarios considered would already fall under PSD conditions, caused by NOx and CO emissions. See Section 3.5 below for further explanation.

Codes for scenarios and activity levels reported in the chart. Scenario 5 is the actual permitted case (with the assumption that all PM 10 is PM 2.5 ). The actual permit is considered in scenario 1 1 77 MMBtu/hour

– no control

– actual permit 4 385 MMBtu/hour

– no control
2 154 MMBtu/hour

– no control 5 77 MMBtu/hour

– Factory

- guaranteed (all PM 10 is
PM 2.5 )
3 231 MMBtu/hour

– no control Codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is given between parentheses

a SO 2 (6788%) d CO 90

- 105% load (17%) b NO
x 90

- 105% load (6%) e CO <90% load (12%)

c NO
x <90% load (10%) f CO 2 (41%)

As Figure 4 shows, a reciprocal internal combustion engine running natural gas would trigger PSD permitting requirements for NO x and carbon monoxide well before reachi ng a level of

PM 2.5 emissions that would interfere with maintenance or attainment of the PM 2.5 NAAQS. In fact, PM 2.5 emissions would be subject to PSD permitting before reaching a level that would
threaten the PM 2.5 standard, even assuming a worst case scenario of an IC engine running at 385 1 2 3 4

5

b c d

e f 0 10 20 30 40 50

0 20 40 60 80 100 120

0 50 100 150 200 250 PM 2.5 Emission (lb/hr) Percentage of NAAQS

PM 2.5 Emission (tons/year)MMBtu/hour without controls. Furthermore, even at 77MMBtu/hour, the IC engine would emit

more than 25 tons/year, and, thus would be subject to the modeling requirement. Addition ally, future modifications are subject to modeling at 10 tons per year, which is the level that the U.S. EPA deems significant pursuant to 40 CFR 52.21(2)(b)(23)(i). An internal combustion engine in this scenario would have to be operated under severely restricted hours in order for the applicant to avoid modeling a modification. Hence, the 25 tons/year modeling threshold for new internal combustion engines and 10 tons/year for modifications is protective of the NAAQS.

A quick glance at all sources conf irms the above analyses. In the figure below, the average of all three combustion sources combined is represented by the dashed black line. In this case, to have (on average) 80% of the NAAQS, the PM 2.5 emission threshold should be set to 50 tons/year.

d) A ll source types

Figure 5 : Results from all source types. Symbols and labels are the same as the previous three figures

IC Engine running natural gas: codes for scenarios and activity levels reported in the chart. 1 77 MMBtu/hour

– no control

– actual permit 4 385 MMBtu/hour

– no control
2 154 MMBtu/hour

– no control 5 77 MMBtu/hour

– Factory

- guaranteed (all PM 10 is
PM 2.5 )
3 231 MMBtu/hour

– no control IC Engine running natural gas: codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is given between parentheses

a SO 2 (6788%) d CO 90

- 105% load (17%)
b NO
x 90

- 105% load (6%) e CO <90% load (12%)

c NO
x <90% load (10%) f CO 2 (41%) Boiler running residual oil: codes for scenarios and activity levels reported in the chart. Scenario 1 is the actual permit Sulfur Content = 0.5% Sulfur Content = 1%1 467 gal/hour

– no control (actual permit) 2 467 gal/hour

– no control

3 934 gal/hour

– no control 4 934 gal/hour

– no control
6 467 gal/hour

- MCC 5 934 gal/hour

– MCC Boiler running residual oil: codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is given between parentheses Sulfur Content = 1% Sulfur Content = 0.5%

a SO 2 (37%) f SO 2 (46%)
b NO
x standard NO burner (124%) g NO
x standard NO burner (77%)

c NO
x low NO burner (145%) h NO
x low NO burner (91%)
d CO (1163%) i CO (725%)

e CO 2 (high sulfur) (95%) j CO 2 (high sulfur) (59%)

Wood

- fired boiler: activity levels for the scenarios reported in the chart. Scenario 1 is the actual permitted case. 1 37.95 MMBtu/hour

– actual permit 3 151.8 MMBtu/hour
2 75.9 MMBtu/hour

Wood

- fired boiler: codes used for other criteria pollutants used in the chart. The estimated percentage of the 24

- hour PM 2.5 NAAQS that a criteria pollutant emission of 250 tons/year (or 100,000 tons/year for CO 2 ) would cause is givent between parentheses.

a SO 2 (1442%) c CO (60%) b NO
x (74%) d CO 2 (74%)

e PM 10 (139%)

Figure 5 also demonstrates that for each of the scenarios, even if operated in a best case manner with low sulfur content fuel and controls, PSD permitting requirements would be triggered for other po llutants well before PM 2.5 emissions would threaten to interfere with attainment or maintenance of the NAAQS.

3. Scenario 1

– Wood

- Fired Boiler

As a test source, the wood

- fire boiler used at the NV Dept. of Corrections in Carson City was used (Facility ID A06 70). The wood boiler is no longer in operation. The permit number is
AP9223

- 2093 (2008). The wood fired boiler is described as a 900 HP Hurst Boiler & Welding Company, mfd 2006, 37.95 MMBTU/hr max heat input, steam turbine 1.0 MW output.

a) Meteorological Da ta

A ERMOD v. 12345 was used to estimate atmospheric concentration, employing only regulatory options. Aer M et for v. 12345 was used to pre

- process meteorological data. Even though there is a meteorological station managed by NDEP

- BAQP in Carson City, prel iminary analysis using

Aer M et revealed some issue with the 2008 data. The use of the N ational W eather S ervice (NWS) station in Reno (for hourly surface, 1

- minute ASOS, and upper air data) was less problematic while providing very similar results. For this reason, meteorological data from the Reno NWS (hourly surface, 1

- minute ASOS, and upper air) and from the period 2008

- 2012 were used to perform this analysis.

A preliminary analysis on the total annual precipitation from 1981 to 2011 was used to identify which years in the analysis period had average (30 th

- 70 th percentile, 2008), above average (over70 th percentile, 2009 and 2010) and below average (below 30 th percentile, 2011 and 2012) annu al

precipitation. The station in Reno was considered located in an arid region and at the airport site.

b) Emissions and scenarios

An emission limit of 0.10 pound per million Btu’s of heat input was used in all operating scenarios as required by the New Sour ce Performance Standards set forth in 40 CFR Part 60

, Subpart Dc, §60 .40c (b)(1)

.

The mass fraction of PM 2.5 is highly dependent on the control system in place (AP 42 Table 1.6

- 5). Adopting the worst

- case scenario, we assumed that all the PM is less than or equal to 2.5 μm, i.e., all emitted PM is PM 2.5 . Under this condition, emissions of PM 2.5 is only a function of the system heat input. Therefore, three scenarios with different MMBtu were used for this modeling
exercise. Emissions in each scenario were e stimated as 0.1 lb/MMBtu * MMBtu/hour.

Table 2 : Scenarios and associated activity rates and PM2.5 emissions

Scenario # Heat input (MMBtu/hour) Emission (g/s)
1 37.95 (the actual permitted) 0.478 2 75.9 0.956 3 151.8 1.913

c) Modeling and results

A ERMOD v12345 was used to model PM 2.5 emissions. Receptors were placed across a grid 250

m

- spaced and a nested 100 m

- spaced grid. Also, discrete receptors were placed along the plant fence line, but no receptors were placed within the plant area. Only regulatory options were selected for running A ERMOD

.
Maps of annual 98 th percentile values of the 24

- hour average distribution (i.e., the 8 th highest) were produced for each year considered (2008 to 2012). PM 2.5 standards were calculated a s the
3

- year average of the max imum annual 98 th percentile.Figure 6 : Example of PM2.5 concentrations (8th highest max of 24

- hour average over 1 year, μg m

- 3). The scenario

represented is #3 for year 2012. The red cross is the loca tion of the source, and the white region is the plant area. Topography is shown in meters asl.

Table 3 : Emissions (g/s) and max 8th highest of 24

- hour average PM2.5 for each scenario and year (μg m

- 3)

Scenario Emissions 2008 2009 2010 2011 2012
1 0.478 6.11 6.19 5.84 6.08 6.16
2 0.956 12.22 12.39 11.68 12.16 12.32
3 1.913 24.44 24.79 23.37 24.33 24.65

Table 4 : Emissions (g/s) and estimated 24

- hour design values (3

- year rolling

- average of values in Table 3 ) for each scenario and year (μg m - 3 )

Scenario Emissions 2008

- 2010 2009

- 2011 2010

- 2012
1 0.478 6.05 6.04 6.03 2 0.956 12.10 12.08 12.05 3 1.913 24.20 24.16 24.12Figure 7 : Time

- series of annual max 8th

- highest 24

- hour average for all the scenarios and years considered in this

analysis. The red dashed line is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 24

- hour E PA NAAQS minus the estimated background concentration for 24

- hour PM2.5 (i.e., 35 minus 9.81 μg/m3).

Figure 8 : Average estimated desi gn values ( Table 4 ) as a function of PM2.5 emissions. Numbers identify the scenarios ( Table 4 ). The red dashed line is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 2 4

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM2.5 (i.e., 35 minus 9.81 μg/m3). The equation for the linear fit is shown as well.

Codes for scenarios reported in the figure 1 37.95 MMBtu/hour 3 151.8 MMBtu/hour
2 75.9 MMBtu/hour

From the above equ ation, an emission of 2.77 g/s (22.0 lb/hour, or 96.4 tons/year) would be required to produce PM 2.5 concentrations above the 24

- hour NAAQS, assuming no background.If a background of 9.81 μg/m 3 is assumed, the required emission would be 1.99 g/s (15.79

lb/hour, or 69.16 tons/year).

d) Other Criteria Pollutant Emissions

In this section, we estimated the emissions of other criteria pollutants based on the scenario(s)
that would cause a violation of t he PM 2.5 hourly NAAQS. In particular, a PM 2.5 emission of 1.99 g/s (15.79 lb/hour, or 69.16 tons/year) is required to cause an exceedance of the 24

- hour NAAQS (averaged over three 3

- year periods, see previous section). With a PM em ission cap set to 0.1

l b/MMBtu and assuming that all PM is PM 2.5 , the heat input required to produce PM 2.5 emissions that would violate the hourly NAAQS is 158 MMBtu/hour. Using this heat input, we estimated the emissions of the other criteria pollutants and CO 2 (using EPA AP

- 4 2, 1.6

- 2 and 1.6

- 3 tables).

Table 5 : Emissions of other criteria pollutants and CO2 under the scenario that would cause an exceedance of the PM2.5 NAAQS. All annual emissions are expressed in short tons per year and assume a constant hourly emission for 24 hours a day, 365 days per year.

Pollutant Annual Emission (short tons/year)
SO 2 17.3 NO x 338.9 CO 415.0
PM 10 134,862.4 CO 2 179.8

The previous table shows the annual emissions for other criteria pollutants when PM 2.5 emission
levels cause exceedances of the PM 2.5 NAAQS. Using a similar approach, it is also possible to
estimate the PM 2.5. emissions when the other criteria pollutants reach a level of emission equal to 250 tons/year (which triggers a PSD permit type, or 100,000 tons/year for CO 2 ). The assumption behind this calculation is that emissions are constant and continuous for the entire year (i.e., for 8760 hours per year).Figure 9 : Same as Figure 8 . In addition, the PM2.5 emissions and concentrations caused when other criteria pollutants

are emitted at 250 tons/year (10,000 tons/year for CO2) are shown with red bars. Some criteria pollutants are not shown because the corresponding PM2.5 emissions and concentrations are too high to be represented in this graphic. The related PM2.5 concentrations (μg/m3) are, however, reported in the table below. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM2.5 (i.e., 35 minus 9.81 μg/m3).

Codes for scenarios reported in the figure 1 37.95 MMBtu/hour 3 151.8 MMBtu/hour
2 75.9 MMBtu/hour Codes and pollutants for each of the scenarios considered. The PM 2.5 emission (g/s) when the other criteria pollutant emission is 250 tons/year (or 100,000 tons/year for CO 2 ) is reported between parentheses.

a SO 2 (363.3) c CO (15.1) b NO
x (18.5) d CO 2 (18.6)

e PM 10 (34.93)

4. Scenario 2

- Industrial Boiler combusting residual oil 2

The model exercise was built upon the permit case for the Idahoans Foods LLC (formerly known as Winnemucca Farms). The facility was stripped of all sources but the main industrial boiler. In the original permit, the boiler was set to run oil #6 with 0.5% sulfur content at 467 gallons/hour for only a portion of the year (about 5346 hours) and run natural gas for the remaining part. In all the scenarios presented in this work, we have assumed that the boiler burns residual oil for t he entire year.

a) Meteorological Data

The facility did not have on

- site met data. Aer M et v12345 was used to process the met data. Only regulatory options were used, and a 0.5 m/s threshold was used to determine calms with 1

- min automated surface observing systems ( ASOS ) . The years from 2008 to 2012 were used for

2 Residual oil is defined as “ crude oil, fuel oil that does not comply with the specifications under the definition of distillate oil, and all fuel oil numbers 4, 5, and 6, as defined by the American Society for Testing and Materials in ASTM D396 (incorporated by reference, see § 60.17 ).” 40 CFR § 60.41c.the modeling. Daily total precipitation (from NOAA Integrated Surface Database,

http://www.ncdc.noaa.gov/oa/climate/isd/index.php) from 1981 to 2011 was used to define the
30

- year norm for annual precipitation in Winnemucca. The 30 th and 70 th percentiles of this distribution were used to classify the years between 2008 and 2012 as dry, wet, or average with respect to precipitation.

Table 6 : Type and source of meteorological data used for this scenario.

Type of met Source Note
Surface Winnemucca Municipal Airport ASOS

- 1min Winnemucca Municipal Airport 0.5 m/s threshold Upper Air Elko

b) Emissions and scenarios

AP

- 42 table 1.3

- 5 was used to estimate PM 2.5 emissions for the industrial boiler under different working scenarios.

Table 7 : Working scenarios used for the industrial boiler scenario.

Scenario # Sulfur

content Oil consumption

(gallons/hour) Control Emissions (g/s)

1 0.5% 467 None 0.256 g/s
2 1.0% 467 None 0.409 g/s 3 0.5% 934 None 0.511 g/s
4 1% 934 None 0.819 g/s 5 1% 934 Multiple Cyclone Controller 0.06 g/s 6 0.5% 467 Multiple Cyclone Controller 0.02 g /s

c) Modeling and results

Aermod v12345 was used to model PM 2.5 emissions. Receptors were placed using a nested grid, with high receptor density in proximity of high PM 2.5 concentrations. Also, discrete receptors were placed along the plant fence line, but no receptors were placed within the plant area. Only regulator y options were selected for running Aermod.

Maps of annual 98 th percentile values of the 24

- hour average distribution (i.e., the 8 th highest) were produced for each year considered (2008 to 2012). PM 2.5 standards were calculated as the
3

- year average of t he max annual 98 th percentile.Figure 10 : Example of PM2.5 concentrations (8th highest max of 24

- hour average over 1 year, μg m

- 3). The scenario

represented is #1 for year 2011. The red cross is the location of the source, and the white region is the plant area. Topography is shown in meters asl.

Table 8 : Emissions (g/s) and max 8th highest of 24

- hour average PM2.5 for each scenario and year (μg m

- 3)

Scenario Emissions 2008 2009 2010 2011 2012
1 0.26 7.86 7.84 7.55 7.28 6.57 2 0.41 12.57 12.54 12.09 11.65 10.51 3 0.51 15.71 15.67 15.10 14.56 13.13 4 0.82 25.17 25.10 24.20 23.33 21.04 5 0.06 1.78 1.71 1.71 1.65 1.49 6 0.02 0.55 0.55 0.53 0.51 0.46

Table 9 : Emissions (g/s) and estimated 24

- hour design values for each scenario and year (μg m - 3 )

Scenario Emissions DV 2008

- 2010 DV 2009

- 2011 DV 2010

- 2012
1 0.26 7.75 7.56 7.13 2 0.41 12.40 12.09 11.42 3 0.51 15.49 15.11 14.26 4 0.82 24.82 24.21 22.86 5 0.06 1.73 1.69 1.62 6 0.02 0.55 0.53 0.50Figure 11 : Time

- series of annual max 8 th

- highest 24 - hour average for all the scenarios and years considered in this

analysis. The red dashed line is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ).

Figure 12 : Average estimated NAAQS as a function of PM 2.5 emissions. Circles identify the scenarios. The red dashed lin e is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ). The equation for the linear fit is shown as well.

Codes for scenarios reported in the figure (same for Figure 11 ) (MMC: Multiple Cyclone Controller) Solfur Content = 0.5% Solfur Content = 1%
1 467 gal/hour

– no control 2 467 gal/hour

– no control
3 934 gal/hour

– no control 4 934 gal/hour

– no control
6 467 gal/hour

- MCC 5 934 gal/hour

- MCCFrom the above equation, an emission of 1.195 g/s (9.5 lb/hour, or 41.62 tons/year) would be

required to produce PM2.5 concentrations above the 24

- hour NAAQS, assuming no background. If a background of 9.81 μg/m 3 is assumed, the required emission would be 0.8603 g/s (6.83 lb/hour, or 29.92 tons/year), which is still above the modeling threshold of 25 tons per year for a new facility and 10 tons per year for a modification of an existing facility with a t otal potential to emit of 25 tons per year or more

.

d) Other Criteria Pollutant Emissions

In this section, we estimated the emissions of other criteria pollutants based on the scenario(s)
that would cause a violation of the PM 2.5 hourly NAAQS. From the previous section, a PM 2.5 emission of 0.8603 g/s (6.83 lb/hour) would cause a violation of the hourly NAAQS (averaged
over three 3

- year periods, see previous sections). Using this threshold and the associated heat input, we estim ated the concurrent emissions of the other criteria pollutants and CO 2 (using EPA

AP

- 42 1.3). Only the scenarios with no controls were considered for this simulation, as they likely produce the worst conditions. Two options in each scenario were consider ed: sulfur content at 1% and 0.5%. The following table shows the results of this calculation.

Table 10 : Emissions of other criteria pollutants and CO 2 under the conditions that would cause a violation of the PM 2.5 NAAQS. Two option s for each scenario were considered: 1% and 0.5% sulfur content for oil#6. Table AP 42 1.3

- 2 (boilers >100 MMBtu/hours) was used for SO 2 , NO
x , and CO. Table AP 42 1.3.12 was used for CO 2 . All annual emissions are expressed in short tons per year and assume a constant hourly emission for 24 hour a day, 365 days per year. NO
x emissions are estimated using both standard and low NO burners (i.e., standard/low NO).

Sulfur Content PM 2.5

emission factor (lb/10 3 gal) Energy

Input (gal/hour) SO 2

emissions (tons/year) NO x

emissions (tons/year) CO

emissions (tons/year) CO 2

emissions (tons/year)

1.0% 6.96 982 675 202/173 22 104,949 0.5% 4.34 1573 540 324/276 34 168,064

The previous table shows the resulting annual emissions for other criteria pollutants when PM 2.5 emission levels would cause a violation of the PM 2.5 NAAQS. By using a similar approach, it is also possible to estimate the PM 2.5 emissions when the other criteria pollutants reach a level of emission equal to 250 tons/year (which triggers a PSD permit type, or 100,000 tons/year for
CO 2 ). Th is calculation a ss umes that emissions are constant and continuous for the entire year (i.e., for 8760 hour per year).Figure 13 : Same as Figure 12

. In addition, the PM 2.5 emissions and concentrations caused when other criteria pollutants

are emitted at 250 tons/year (10,000 tons/year for CO 2 ) are shown with red bars. Some criteria pollu tants are not shown because the corresponding PM 2.5 emissions and concentrations are too high to be represented in this graphic. The related
PM 2.5 concentrations (μg/m 3 ) are, however, reported in the table below. The 1% and 0.5% sulfur fuel content scenari os are considered here as well. Some criteria pollutants and scenarios are not shown because the corresponding PM 2.5 emissions are too high to be represented in this graphic. They are, however, reported in the table below. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ).

Codes for scenarios reported in the figure (same as Figure 11 ) Sulfur Content = 0.5% Sulfur Content = 1%
1 467 gal/hour

– no control 2 467 gal/hour

– no control
3 934 gal/hour

– no control 4 934 gal/hour

– no control
6 467 gal/hour

- MCC 5 934 gal/hour

- MCC Codes, pollutants, and descriptions for each all the scenarios considered. The PM 2.5 emission (g/s) when the other criteria pollutant emission is 250 tons/year (or 100,000 tons/year for CO 2 ) is reported between parentheses. Sulfur Content = 1% Sulfur Content = 0.5%

a SO 2 (9.3) f SO 2 (11.6) b NO
x standard NO burner (31.2) g NO
x standard NO burner (19.4)

c NO
x low NO burner (36.6) h NO
x low NO burner (22.8)
d CO (293.0) i CO (182.7)

e CO 2 (high sulfur) (24.0) j CO 2 (high sulfur) (15.0)

5. Scenario 3

– Internal Combustion Engine combusting natural gas

The model exercise for this type of source was built upon the permit case for the Western102 power plant owned by Barrick Goldstrike Mines, Inc. The power plant has 14 natural gas
Wartsilla 4

- stroked lean

- burn IC engines (77 MMBtu/hour) using natural gas and an emergency generator using natural gas. All of them were modeled.a) Meteorological Data

The facility does not have an on

- site met station. However, the Tracy Power Plant owned and

oper ated by NVEnergy is very closely located to the Western102 power plant and has on

- site data. Therefore, when available, the Tracy on

- site data were used as the on

- site data for

Western102.

In particular, met time

- series for years 201 1 and 201 2 were re

- pr ocessed using Aer M et v12345 and Tracy on

- site data, Reno Airport surface data (1

- min ASOS) and Reno upper

- air data. Time

series for 20 09 and 20 1 0 were not readily accessible and pre

- existing surface and profile A er M et files (v.11059) were used. These fil es were processed using the same Tracy on

- site and Reno surface and upper

- air data. For the year 2008, no on

- site data were used, but only surface (1

- min ASOS) and upper

- air data from Reno. Only regulatory options were used to process met data. The optio n to estimate scale temperature using the bulk Richardson number was used for the years 201 1 and 201 2

.

b) Emissions and scenarios

AP

- 42 table 3.2

- 2 was used to estimate the primary (i.e., sum of filterable and condensable)

PM 2.5 emission rates. The energy inp ut (MMBtu/hour) was increased from the original 77 MMBtu/hour to 154 MMBtu/hour , 231MMBtu/hour, and 385 MMBtu/hour. Also, a scenario was constructed by assuming that all the PM 10 factory

- guaranteed emissions were PM 2.5.

Table 11 : Energy use, control and emissions for the different scenarios used for the natural gas IC.

Scenario # Energy use (MMBtu/hour) Control Emissions (g/s) for each IC Engine
1 77 None 0.0969 2 154 None 0.1938 3 231 None 0.291 4 385 None 0.4844 5 77 Factory

- guaranteed (all PM 10 is PM 2.5 ) 0.3263

c) Modeling and results

Aermod v12345 was used to model PM 2.5 emissions. Receptors were placed using a nested grid, with high receptor density in proximity of high PM 2.5 concentrations. Also, discrete receptors were placed along the plant fence line, but no receptors were placed within the plant area. Only regulatory options were selected for running Aermod.

Maps of annual 98 th percentile values of the 24

- hour average distribution (i.e., the 8 th highes t) were produced for each year considered (2008 to 2012). PM 2.5 standards were calculated as the
3

- year average of the max annual 98 th percentile.Figure 14 : Example of PM 2.5 concentrations (8 th highest max of 24

- hour average over 1 year, μg m - 3 ). The scenario

represented is #4 for year 2012. The red cross is the location of the source, and the white region is the plant area. Topography is shown in meters asl.

Table 12 : Total emissions for the entire facil ity (g/s) and max 8 th highest of 24

- hour average PM 2.5 for each scenario and year (μg m - 3 )

Scenario Emissions 2008 2009 2010 2011 2012
1 1.42 5.42 4.08 4.12 6.67 6.17 2 2.77 10.55 8.15 4.23 10.30 9.19 3 4.13 15.69 12.24 6.29 14.69 13.62 4 6.84 25.93 20.38 10.44 23.13 22.67 5 4.63 17.56 13.73 7.05 16.05 15.27

Table 13 : Total emissions for the entire facility (g/s) and estimated 24

- hour design values for each scenario and year (μg

m - 3 )

Scenario Emissions NAAQS 2008

- 2010 NAAQS 2009

-

2011 NAAQS 2010

-

2012
1 1.42 4.54 4.96 5.65 2 2.77 7.64 7.56 7.91 3 4.13 11.41 11.07 11.53 4 6.84 18.92 17.98 18.74 5 4.63 12.78 12.28 12.79Figure 15 : Time

- series of annual max 8 th

- highest 24

- hour average for all the scenarios and years considered in this

analysis. The red dashed line is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ).

Figure 16 : Average estimated design values as a function of PM 2.5 emissions (for the entire facility) and linear fit. Empty circles identify the scenarios. The red dashed line is the 24

- hour EPA

- NAAQS. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ). The equation for the linear fit is shown as well.

Codes for scenarios reported in the figure (same for Figure 15 ) 1 77 MMBtu/hour

– no control 4 385 MMBtu/hour

– no control
2 154 MMBtu/hour

– no control 5 77 MMBtu/hour

– Factory

- guaranteed (all PM 10 is PM 2.5 )
3 231 MMBtu/hour

– no control

From the above equation, an emission rate of 9.6 g/s from each IC engine (76 lb/hour, or 332 tons/year) would be required to produce PM 2.5 concentrations above the 24

- hour NAAQS,assuming no background. If a background of 9.81 μg/m 3 is assumed, the requir ed emission

would be 0.68 g/s (5.39 lb/hour, or 23.61 tons/year).

d) Other Criteria Pollutant Emissions

In this section, we estimated the emission of other criteria pollutants based on the scenario(s) that
would cause a violation of the PM 2.5 hourly NAAQS. From the previous section, a PM 2.5 emission of 0.68 g/s (5.39 lb/hour) from each IC engine would cause a violation of the hourly NAAQS (averaged over three 3

- year periods, see previous sections). Using this threshold, we
estimated the conc urrent emissions of the other criteria pollutants and CO 2 (using EPA AP

- 42
3.2

- 2) from each engine. Only the scenarios with no controls were considered for this simulation.

Table 14 : Concurrent emissions of other criteria pollutant s and CO 2 from each IC engine under the conditions that would cause a violation of the PM 2.5 NAAQS. Table AP 42 3.2

- 2 was used for SO 2 , NO
x , CO, and CO 2 . All annual emissions are expressed in short tons per year and assume a constant hourly emission for 2 4 hour a day, 365 days per year. NO
x and CO emissions are estimated using both a 90

- 105% and a <90% load (i.e., 90

- 105%/<90%).

PM 2.5 emission factor (lb/MMBtu) Energy Input

(MMBtu/hour) SO 2

emissions (tons/year) NO x

emissions (tons/year) CO

emissions (tons/year) CO 2

emissions (tons/year)

9.91E10 - 3 544 1.4 9721/2018 775/1327 262,099

The previous table shows the resulting annual emissions for other criteria pollutants when PM 2.5 emission levels would cause an exceedance of the PM 2.5 NAAQS. By using a similar approach, it is also possible to estimate the PM 2.5. emissions when the other criteria pollutants reach a level of emission equal to 250 tons/year (which triggers a PSD permit type, or 100,000 tons/year for
CO 2 ). The assumption behind this calcu lation is that emissions are constant and continuous for the entire year (i.e., for 8760 hour per year).Figure 17 : Same as Figure 16 . In addition, the PM 2.5 emissions and concentrations caused when other criteria pollutants

are emitted at 250 tons/year (10,000 tons/year for CO 2 ) are shown with red bars. Some criteria pollu tants are not shown because the corresponding PM 2.5 emissions and concentrations are too high to be represented in this graphic. The related
PM 2.5 concentrations (μg/m 3 ) are, however, reported in the table below. Some criteria pollutants and scenarios are not shown because the corresponding PM 2.5 emissions are too high to be represented in this graphic. They are, however, reported in the table below. The yellow dashed line is the 24

- hour EPA NAAQS minus the estimated background concentration for 24

- hour PM 2.5 (i.e., 35 minus 9.81 μg/m 3 ).

Codes for scenarios reported in the figure (same for Figure 15 ) 1 77 MMBtu/hour

– no control 4 385 MMBtu/hour

– no control
2 154 MMBtu/hour

– no control 5 77 MMBtu/hour

– Factory

- guaranteed (all PM 10 is PM 2.5 )
3 231 MMBtu/hour

– no control Codes and pollutants for each all the scenarios considered. The estimated PM 2.5 emission (g/s) that causes the pollutant emission to b e 250 tons/year (or 100,000 tons/year for CO 2 ) is reported between parentheses.

a SO 2 (1709.8) d CO 90

- 105% load (4.4) b NO
x 90

- 105% load (1.5) e CO <90% load (3.0)

c NO
x <90% load (2.4) f CO 2 (10.4)



### D. STATIONARY SOURCE EMISSIONS OF PM 2.5
, 

### NO 2 

### , and SO 2 

### HAVE A DE

MINIMIS CONTRIBUTION TO THE PM 2.5 

### EMISSION INVENTORY FOR THE

STATE.



### C ONTRIBUT ION TO THE 

### PM 2.5 

### E MISSION 

### I NVENTORY FOR THE 

### S TATE



### .
Third, the portion of PM 2.5 that stationary sources contribute to Nevada’s emission inventory is

de minimis

. The NDEP first quantified the contribution of minor PM 2.5 sources to the overall emissions inventory in Nevada using the National Emissions Inventory (NEI) database. The emissions inventory reflects both quality

- assured monitoring data and emissions estimates tha t have been vetted through the public participation process. The NDEP evaluated the PM 2.5 emissions, as calculated by the U.S. EPA, in the 2008 and 2011 NEI databases. The 2008 and 2011 NEI datasets were used because they were complete datasets for all s ources. As set forth in
Table 15 and Table 16 , the 2008 and 2011 NEI data d emonstrate that in 2008, the minor sourcecontribution to the total PM 2.5 emission inventory was a scant 1.3%. In 2011, the minor source

contribution was slightly more at 2.8%. The difference is largely due to wildfire emissions. There was significant w ildfire activity in 2008 as compared to 2011: 55,493 tons emitted in 2008 compared to 6,718 tons in 2011. Importantly, minor source emissions decreased by nearly

one

- third in that timeframe, from 912 tons in 2008 to 648 tons in 2011. Because the minor
source contribution to the PM 2.5 emission inventory is so small, the modeling threshold of 25 tons per year is protective of the 2006 PM 2.5 ambient air quality standard.



### C ONTRIBUT ION TO THE 

### NO 2 AND 

### SO 2 

### E MISSION 

### I NVENTORY FOR THE 

### S TATE



### .

The results are similar for minor sources of NO 2 and SO 2 . As set forth in Table 17

, Table 18

, Table 19 , and Table 20 below, the minor source contribution to NO 2 based on the 2008 NEI v.2
data was a mere 5.4% of statewide emissions. The minor source contribution of SO 2 based on the 2008 NEI data was even less, at 4.3%. Even if the minor source contributions of NO 2 and

SO 2 cannot be considered de minimis, they are certainly slight. The contribution by minor
sources to the SO 2 and NO 2 emission inventories in Nevada is so small that extinguishing those sources would make little, if any, difference to Nevada’s emission inventories for those two criteria pollutants. Because the minor source contribution is so small, the proposed modeling assignment threshold of 40 tons per year is protective of the 1

- hour standards. Forty tons per year is the level at which the U.S. EPA deems a new source or modification to be significant under PSD permitting. 40 CFR 52.21(2)(b)(23)(i). It is also less than one

- fifth of the 250

- ton threshold that triggers PSD permitting and less than one

- half of 100

- ton threshold for certain

t ypes of sources. As such, it is protective of the NAAQS.

Table 15 : Minor source contribution to PM 2.5 in 2008

2008 Minor Source Inventory Contribution to PM 2.5 Using GPR v.3 data instead GPR of v.2 and county totals by data category report. Summary PM 2.5 - Primary (Tons) Total Emissions (NDEP Only) 70,402
Event 55,643
Prescribed Fires 150
Wildfires 55,493 Nonpoint 11,270
Nonroad 291
Onroad 482
Point

- Total 2,716
Point

- Major 1,783

Point

- Minor 1 912

Minor Source PM 2.5 Contribution 1.3%

1 Does not include airport or rail yard data categories.It should be noted that the Hawthorne Army Depot (AP97110863) appears to have reported

artificially inflated PM10 emissions for the 2008 NEI. For this analysis, the PM 2.5 value from the 2008 GPR v.1 was replaced with the facility wide PTE for PM 10 (with the conservative assumption that 100% of the PM 10 is PM 2.5 ).

Table 16 : Minor source con tribution to PM 2.5 in 2011

2011 Minor Source Inventory Contribution to PM 2.5 Using 2011 NEI v.1 data and county totals by data category report. Summary PM 2.5 - Primary (Tons) Total Emissions (NDEP Only) 23

, 253

Event 7

, 283
Prescribed Fires 565
Wildfires 6

, 718 Nonpoint 13

, 358
Nonroad 257
Onroad 501
Point

- Total 1

, 855
Point

- Major 1

, 185

Point

- Minor 1 648

Minor Source PM 2.5 Contribution 2.8%

1 Does not include airport or rail yard data categories.

Table 17 Minor source contribution to NO 2 in 2008

2008 Minor Source Inventory Contribution to NO 2 Using GPR v.3 data instead GPR of v.2 and county totals by data category report
Summary NO 2 (Tons) Total Emissions (NDEP Only) 58700

Event 5573
Prescribed Fires 24
Wildfires 5549 Nonpoint 15204
Nonroad 2539
Onroad 13841
Point

- Total 21543
Point

- Major 19764
Point

- Minor 1 1196

Minor Source NO 2 Contribution 2.0%

1 Does not include airport or rail yard data categories.Note: The 2008 GPR v. 3 does not include corrections submitted by NDEP in March of 2014.

Table 18 : Minor source contribution to NO 2 in 2011

2011 Minor Source Inventory Contribution to NO 2 Using 2011 NEI v.1 data and county totals by data category report.

Summary NO 2 (Tons) Total Emissions (NDEP Only) 46766
Event 1792
Prescribed Fires 102
Wildfires 1690 Nonpoint 14307
Nonroad 2298
Onroad 17148
Point

- Total 11220
Point

- Major 9310
Point

- Minor 1 1 238

Minor Source NO 2 Contribution 2.6%

1 Does not include airport or rail yard data categories.

Note: The 2011 NEI v. 1 does not include corrections submitted by NDEP in March of 2014.

Table 19 : Minor source contribution to SO 2 in 2008

2008 Minor Source Inventory Contribution to SO 2 Using GPR v.3 data instead GPR of v.2 and county totals by data category report.
Summary SO 2 (Tons) Total Emissions (NDEP Only) 14620
Event 3969
Prescribed Fires 13
Wildfires 3956 Nonpoint 118
Nonroad 17
Onroad 98
Point

- Total 10417
Point

- Major 9848
Point

- Minor 1 560

Minor Source SO 2 Contribution 3.8%

1 Does not include airport or rail yard data categories.Note: The 2008 GPR v. 3 does not include corrections submitted by NDEP in March of 2014.

Table 20 : Minor source contribution to SO 2 in 2011

2011 Minor Source Inventory Contribution to SO 2 Using 2011 NEI v.1 data and county totals by data category report.

Summary SO 2 (Tons) Total Emissions (NDEP Only) 6902
Event 809
Prescribed Fires 53
Wildfires 756 Nonpoint 145
Nonroad 6
Onroad 68
Point

- Total 5873
Point

- Major 5474
Point

- Minor 1 389

Minor Source SO 2 Contribution 5.6%

1 Does not include airport or rail yard data categories.
Note: The 2011 NEI v. 1 does not include corrections submitted by NDEP in March of 2014.



### E. THE STATE MAY PERFORM THE MODELING ANALYSES FOR FACILITIES WITH EMISSIONS LESS THAN 25 TONS PER YEAR, OR 40 TONS PER YEAR

FOR THE 1

- HOUR STANDARDS

Fourth, the State must be able to determine, as r equired by NAC 445B.308(2), that the new or modified source will not prevent attainment and maintenance of the state or national standards set forth in NAC 445B.22097 or cause a violation of the SIP or any applicable requirement. Toward that end, t he Stat e may require an applicant to submit “any other information the Director determines is necessary to make an independent air quality impact assessment.” NAC 445B.308(1). T he State may perform the modeling for applications even if the emissions are below t he threshold in NAC 445B.310 requiring the applicant to submit an air dispersion model with the environmental evaluation. Such practice enables the NDEP to ensure that the ambient air quality standards are protected.

(e) Modeling information required t o support the proposed revision, including input data, output data, models used, justification of model selections, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumption s, and other information relevant to the determination of adequacy of the modeling analysis.See above. Also, the NDEP continue s to use models as approved in Appendix W.

(f) Evidence, where necessary, that emission limitations are based on continuous emissio n reduction technology.

This element is not applicable, as these rule revisions are for minor new source review.

(g) Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels.

For the standards at issue in this TSD, the areas under the NDEP’s jurisdiction are attainment/unclassifiable or the USEPA has not yet promulgated a designation. The items set forth in this section are more appropriately addressed toward ameliorating an area designated as nonattainment. Nonetheless, these elements are addressed in the NDEP’s relevant infrastructure

SIPs.

(h) Compliance/ enforcement strategies, including how compliance will be determined in practice.

Nevada’s approved applicable SIP demonstrates that the NDEP has statutory authority to implement and enforce its air quality regulations through site and record inspections, compliance orders, stop orders, notices of alleged violation, and penalties. The proposed revision s included in this SIP submittal do not abrogate the NDEP’s compliance and enforcement authority. The NDEP’s compliance and enforcement strategies will be expanded in practice to encompass the new standards being adopted here.

(i) Special economic and techno logical justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary.

No special economic and technical justifications are required for the NDEP’s implementation of USEPA’s 2006 PM2.5, 2010 1

- hour S O2, and 2010 1

- hour NO2 standards. The State is adopting those new standards into the State side of the table set forth in NAC 445B.22097 so that it may incorporate those standards in its permitting decisions and compliance and enforcement strategies. It is noteworthy that these revisions apply to the minor sources (i.e. sources not subject to PSD permitting) under the NDEP’s jurisdiction. Minor sources make a de minimis contribution to the PM2.5, and NO2 and SO2 inventories in the State, and, therefore, should enjoy some flexibility in terms of permitting. For the reasons set forth above, the revisions proposed are protective of the ambient air quality standards.



### III. Conclusions

The revisions to the Nevada Administrative Code, and incorporation of those r evisions into the SIP, provide more protection for the state and national ambient air quality standards than currently exists. The proposed regulations insert the 2006 PM 2.5 standard, and the 1

- hourstandards for NO 2 and SO 2 , into the state side of the ta ble in NAC 445B.22097, which requires

the State to incorporate those standards into its permitting analyses and issuance.

The modeling threshold of 25 tons per year of PM 2.5 emissions for new sources , which exists in Nevada’s current regulations, is greater than the 10 tons per year significant emission rate set forth in 40 C.F.R. 51.166(b)(23) . Nonetheless , the higher threshold is protective of the state and national ambient air quality standards for several reasons

. First, that threshold is me rely one

fourth of the applicable major source threshold and incorporates the significant emission rates for

PM 2.5 precursors. Major sources would be subject to PSD permitting if they emit either 100 tons per year or 250 tons per year of PM 2.5 , depending on the type of the facility. A threshold that is

one

- fourth of that is protective. Importantly, the modeling threshold for modifications is 10 tons per year, which is the same as the PSD significant emission rate for PM 2.5 . Also, the State is proposing to revise its modeling threshold for the 1

- hour standards so that it matches the PSD significant emission rates as well as the PM 2.5 precursor significant emission rates for NO 2 and
SO 2 . Thus, these revisions address not only direct PM 2.5 emissions but precursor emissions as well. Second, the Nevada

- specific analyses included herein demonstrate that minor source combustion processes with the highest rates of PM 2.5 emissions (worst case scenarios), as found
in AP

- 42 and Nevada’s NEI submitt al, would trigger PSD permitting requirements for other pollutants first, and subject the facility to PSD review before PM 2.5 (alone) reached the PSD permitting threshold. T hird, stationary source emissions of PM 2.5 are a de minimis contribution
to the PM 2.5 emission inventory for the State. Fourth, the State may only issue a minor source permit if it determines that the source will not prevent attainment and maintenance of the state or
national standards set forth in NAC 445B.22097 or cause a violation o f the SIP or any applicable requirement. The NDEP may require more information and conduct modeling analyses even for sources below the significant emission rate levels, or, in the case of new sources emitting PM 2.5 , below 25 tons per year in order to mak e such a determination

.

For the 1

- hour standards, the revisions incorporate the PSD significant emission rates of 40 tons per year of NO2 and 40 tons per year of SO2. Because emissions less than 40 tons per year are deemed by EPA to be insignificant, se tting a modeling assignment threshold at this level is protective of the NAAQS.

In sum, the revisions strengthen the NDEP’s minor new source review program. For that reason, the NDEP requests that these revisions be incorporated into the applicable SIP.ATTACHMENT C

June 5, 2014 SIP Submittal Support Nevada Division of Environmental Protection



# Evidence of Public Participation and AdoptionThis page is intentionally blank.C

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### C.1 State Environmental Commission Public Hearing NoticeC

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### C.2 Affidavits of PublicationC

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### C.3 State Environmental Commission Hearing Agenda, May 2, 2014C

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