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NPS Initial Comments

Nebraska Draft Regional Haze State Implementation Plan (SIP)

December 14, 2010

The National Park Service and Fish and Wildlife Service received Nebraska’s draft regional haze 

state implementation plan (SIP) on November 16, 2010. We have reviewed the draft plan and 

provide our initial comments below. These initial comments are intended to facilitate discussion 

with Nebraska on our conference call on December 15, 2010. Formal comments will be 

submitted prior to the end of the Federal Land Manager consultation period. 

The National Park Service and Fish and Wildlife Service provided recommendations to Nebraska

in August 2006 that detailed our priorities in reviewing the state plans. We address those 

priorities in our initial comments below. Hopefully Nebraska will be able to address our major 

concerns before going to public comment. We are available to assist Nebraska in addressing our 

recommendations. 

Reasonable Progress

Fundamentally, we are concerned that Nebraska has not demonstrated that the State has met the 

requirements of the regional haze rule. The Regional Haze Rule Section 308(d)(3) requires:

Each State must submit a long-term strategy that addresses regional haze visibility 

impairment for each mandatory Class I Federal area within the State and for each 

mandatory Class I Federal area located outside the State which may be affected by 

emissions from the State. The long-term strategy must include enforceable emissions 

limitations, compliance schedules, and other measures as necessary to achieve the 

reasonable progress goals established by States having mandatory Class I Federal 

areas. 

Nebraska does not meet this requirement. The reasonable progress goals established by South 

Dakota for Badlands and Wind Cave National Parks and by Missouri for Hercules Glade assume 

that Nebraska will require presumptive BART controls for the Gerald Gentleman and Nebraska 

City power plants as modeled by the Western Regional Air Partnership (WRAP) and the Central 

Regional Air Partnership (CENRAP). Nebraska is not requiring controls of sulfur dioxide (SO2) 

for any of the BART units. Most states demonstrate that they will accomplish greater emissions 

reductions than modeled by regional planning organizations (RPOs). To our reading, Nebraska’s 

long term strategy does not include the controls required to meet its contribution to the 

reasonable progress goals established by its neighboring states through the RPO process. 

Point source SO2 emissions account for 78% of total SO2 emissions in Nebraska’s 2002 

inventory. Electric generating units (EGU) account for 92% of point source SO2 emissions. 

Section 8.3.1.3 indicates that the 2018 inventory assumes significant reductions in SO2 from 

electric generating units based on assumptions of the Integrated Planning Model, but no actual 

emission controls are presented. It can be inferred that no reductions in SO2 emissions from 

point sources are now expected and that, based on Tables 8.1 and 8.3, SO2 emissions from 

Nebraska in 2018 are underestimated by 21,218 tons, or 25% in the CENRAP and WRAP 2018 
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modeling. Nebraska does not discuss this discrepancy in Chapter 11 when presenting results of 

the 2018 source apportionment modeling or 2018 visibility projections for Class I areas. 

Best Available Retrofit Technology (BART)

We have several concerns with the BART analyses for Nebraska City Unit 1 and Gerald 

Gentleman Units 1 and 2. Please include a description of the emissions for the BART eligible 

units. Appendix 10.1 indicates that Gerald Gentleman Units 1 and 2 combined have potential 

SO2 emissions of 79,200 tons/year and Nebraska City Unit 1 has potential SO2 emissions of 

45,696 tons/year. Please confirm and provide the actual annual SO2 emissions from the 2002 

CENRAP inventory for these three units, similar to the NOx information in Table 8.5.

We disagree with Nebraska’s decision not to consider sulfur dioxide controls for Nebraska City. 

Nebraska should summarize the results of the five factor analysis and the visibility impacts in the 

SIP and not just refer to Appendices. The text in Section 10.5 incorrectly refers to Unit 2 as 

BART eligible. Please correct and provide the MW capacity of Units 1 and 2. Even if 

Nebraska’s interpretation is that Unit 2 does not need to be considered in MW capacity and 

presumptive controls are not required, the capacity of Unit 1 alone is 616 MW and suggests that 

controls should be carefully considered independent of the presumptive requirement. It is 

unacceptable that Nebraska only discusses the legal requirement for presumptive controls rather 

than discussing the BART analysis and visibility impacts from Unit 1. In Table 10.5 the costs 

for a scrubber are less than $2000/ton and the visibility improvement from a scrubber are close to 

0.5dv. Nebraska then discusses source apportionment results from the CAMx model as evidence 

to avoid the visibility benefits defined by CALPUFF. The reader is left with the conclusion that 

the State is choosing to present only information that supports its case, not objective information. 

Why were dry sorbent injection and lime spray dryer technologies not evaluated for SO2

controls? Why was Selective Non-Catalytic Reduction not evaluated for NOx controls? 

 

We disagree with Nebraska’s BART determination of no SO2 controls for Gerald Gentleman. 

Please summarize the five factor analysis and the visibility impacts of the plant on the Class I 

areas. Were dry sorbent injection and lime spray dryer technologies considered? If not, why 

not? Nebraska provides an elaborate justification that water use is an issue at Gerald Gentleman

without discussing the viable alternatives that are being used in western states. The economic 

factors influencing the economy of Nebraska are much greater than the possible retirement of 

irrigated acreage to obtain water rights for the power plant. The BART determination is not 

acceptable as written. 

Additional comments on specific chapters are detailed below.

Chapter 6 Baseline, Current, and Natural Visibility Conditions

Please include summary of baseline conditions at key Class I areas impacted by Nebraska 

emissions to establish the relative contributions of pollutant species, seasonal trends in pollutant 

contributions, and priority for emissions controls. 

Chapter 7 Monitoring Strategy

Measurements at IMPROVE protocol sites and from special studies are discussed but no results 

are presented. How are the ammonia monitoring data being used? 
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Chapter 8 Emissions Inventory

The discussion of area source contributions to particulate matter (PM10) in the 2002 inventory is 

good. According to values in Table 8.1, area sources contribute 97% of ammonia (NH3) 

emissions in Nebraska in 2002. Please add for NH3 the same discussion and piechart as 

presented in Figure 8.3 for PM10. Please include a discussion of the change in NH3 in 2018 in 

Table 8.3 and Section 8.3.1.5; we disagree with ignoring NH3 as a contributing pollutant. 

Please amplify the discussion of the 2018 projections to provide better explanation of the source 

categories contributing to point source emissions of SO2 and NOx. This information was not 

presented in either Appendix 8.2 (SMOKE reports in Microsoft Access) or Appendix 9.1 

(ENVIRON technical report). This information is critical to supporting an adequate reasonable 

progress analysis. 

Chapter 10 BART

See our general comments above. We are still reviewing the BART exemptions and BART 

determinations in the Appendices. 

The CENRAP BART Modeling Protocol is not included in Appendix 10.3 although it is 

referenced in the BART Modeling Protocol for Gerald Gentleman and Nebraska City. Where 

can we find the CENRAP BART Modeling Protocol?

Chapter 11 Reasonable Progress/Long Term Strategy

Table 11.1 reports the net improvement in Light Extinction at neighboring Class I areas based on 

source apportionment modeling and what appear to be incorrect assumptions for SO2 emissions 

in Nebraska. If the emissions assumptions are invalid, Nebraska’s demonstration of reasonable 

progress is also invalid. Nebraska is not achieving the modeled emissions reductions and 

Nebraska’s conclusion that no additional control measures are warranted is not supported. 

Section 11.2: We note that Colorado in its regional haze SIP specifically mentions consultation 

with Nebraska on the BART determination for Gerald Gentleman due to the plant’s impact to 

Rocky Mountain National Park. Nebraska does not include Colorado in its summary. 

South Dakota’s SIP lists a 36% reduction in Nebraska SO2 emissions used in setting reasonable 

progress goals for Badlands and Wind Cave National Parks. This is 23,623 tons lower than we 

infer is appropriate based on no EGU SO2 controls in Nebraska. This disconnect should be 

addressed in consultation with South Dakota and EPA Regions 7 and 8.

Section 11.3.2: Please include discussion about how the visibility improvement goals under the 

regional haze rule are incorporated in Nebraska’s Prevention of Significant Deterioration 

program. 

Section 11.3.7: Nebraska must re-evaluate what reductions are necessary to support the 

reasonable progress goals of neighboring states. The regional haze rule requires that the State 

include in its long term strategy all measures needed to achieve its apportionment of emission 

reductions and to identify all anthropogenic sources of visibility impairment considered in 
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developing the long term strategy. Nebraska needs to demonstrate that its emissions sources are 

being controlled and that Nebraska is making reasonable progress in reducing anthropogenic 

emissions.