1 NPS Initial Comments

Nebraska Draft Regional Haze State Im plementation 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 ha ve reviewed the draft plan and provide our initial comments below. T hese initial comments are intended to facilitate discussion

with Nebraska on our conference call on December 1 5 , 2010. Formal comments will be submitted prior to the end of the Federa l 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 n ot demonstrated that the State has met the requirements of the regional haze rule. T he 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 N ational Park s 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 W estern Regional Air Partnership (W RAP ) and the Central Regional Air Partnership ( CENRAP )

. Nebraska is not requiring controls of sulfur dioxide (SO 2 ) 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 rea ding, 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 SO 2 emissions account for 78% of total SO 2 e missions in Nebraska’s 2002 inventory. Electric generating units (EGU) account for 92% of point source SO 2 emissions. Section 8.3.1.3 indicates that the 2018 inventory assumes significant reductions in SO 2 from electric generating units based on assumptions of the Integrated Planning Model

, but no actual

emission controls are present ed. I t can be inferred that no reductions in SO 2 emissions from point sources are now expected and that, based on Tables 8.1 and 8.3

, SO 2 emissions from

Nebraska in 2018 a re underestimated by 21,218 tons, or 25% in the CENRAP and WRAP 20182

modeling

. Nebraska does not discuss this discrepancy in Chapter 11 when presenting results of

the 2018 source apportionment modeling or 2018 visibility p rojections 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 ha ve potential

SO 2 emissions of 79,200 tons/year and Nebraska City Unit 1 has potential SO 2 emissions of 45,696 tons/year. Please confirm and provide the a ctual annual SO 2 emiss ions from the 2002 CENRAP inventory for these t hree units, similar to the NO

x 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 facto r 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 Unit s 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

unac ceptable 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 improvemen t 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 o nly information that supports its case, not objective information. Why were dry sorbent injection and lime spray dryer techno logies not evaluated for SO 2 controls? Why was Selective Non

- Catalytic Reduction not evaluated for NO

x controls?

We disagree with Nebraska’s BART determination of no SO 2 controls for Gerald Gentleman

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

areas. W ere 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

contributio ns, 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?3

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 (NH 3 )

emissions in Nebraska in 2002 . Please add for NH 3 the same di scussion and piechart as presented in Figure 8.3 for PM10. Please include a discussion of the change in NH 3 in 2018 in

Table 8.3 and Section 8.3.1.5 ; we disagree with ignoring NH 3 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 SO 2 and NO

x . This information was not presented in either Appendix 8 .2 (SMOKE reports in Microsoft Access) or Appendix 9 .1 (ENVIRON technical repo rt)

. 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 r eports the net improvement in Light Extinction at neighboring Class I areas based on source apportionment modeling and what appear to be incorrect assumptions for SO 2 emissions

in Nebraska. If t he emissions assumptions are invalid

, Nebraska’s d emonstratio n 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 SO 2 emissions used in setting reasonable progress goals for Badlands and Wind Cave Nationa l Parks. This is 23,623 tons lower than we infer is appropriate based on no EGU SO 2 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 ho w 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 g oals 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 consi dered in4

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.