6.0 SUMMARY AND CO NCLUSIONS

This chapter summ arizes the m a jor findings from the review of the April 2009 draft Nevada regional haze SIP. The findings are lis ted with respect to the m a jor question s identified
f o r this rev i e w

.

1. Does the SIP sufficiently allow for known a nd planned future growth of air em ission sources in Nevada and neighborin g states, in particular coal-f ired electrical generating units (EGUs)?

• Future growth in coal-fired EGUs appears to be underrepresented in the 2018 em ission

invento r y projections co ntained in the draft Nevada region al haze SIP. If the proposed Ely Energy Center and White Pine Power Projects are included, the 2018 em issions projections appear to be low by about 5,700 tpy for SO 2 emissions and 6,200 tpy for
NO
x em issions. Recently, develop e rs for th e Ely and White Pine Projec ts h a ve announced that these p r ojects will n o t go forward in the imm e diate future. However, as of early May 2009, the air perm it applicati ons being processed at NDEP for both Ely
and W h ite Pine appe ar to rem a in a c tive. Th e E l y and W h ite Pine Projects need to be part of Nevada’s SIP planning process until suc h tim e that the air p e rm it applica tion s are form ally withdrawn. At IPP Unit 3 (wit hin 300 km of Jarbidge ), these em issions appear to be part of the 2018 W R AP regi onal e m ission projections and as such are included as part of Nevada’s SIP pl anning process. However, NDEP should acknowledge that IPP is part of the re gional inventory with in their SIP.

• There are inconsistencies between the em issi ons listed in the 2018 em issions inventory for the Nevada region al haze SIP and a llowable em issions established by NDEP air quality per m its f o r several sou r ces, i.e. TS Power Plant and W h ite Pine Power Project.
The 2018 em ission inventory projec tions in the regional haze SI P need to be accurate if one is to rely on the results of any modeling to dem onstrate whether “reasonable further progress” has been achieved.

• The proposed Toquop Energy Project near Mesquite is not expl icitly listed in the 2018

em issions inventory, but these em issions are r e la tive l y clo s e to the em issions ass i gne d
to an “unnam e d” coal-fired EGU. Alt hough the em issions from the unnam e d plant

m a tch with the Toquop Project, the resul ting visibility impact projections for 2018 depend also on how the “unnam e d” plant was incorporated into the 2018 visibility modeling. Based on the proposed lo cation for T oquop, it is expected that this plant will potentially affect regional haze at Zi on National Park, Bryce Canyon National Park, and Grand Canyon National Par k. The projections of 2018 vi sibility at these areas appear to be in error as the future Toquop e m issions were not properly represented in
the 2018 m o deling.

• The April 2009 Nevada SIP does not include future em issions from the Power County Advanced Energy Center, which was recently issued a permit by the Idaho Departm e nt of

Environ m ental Quality f o r

a site nea r Am erican Falls, ID. This project could have the poten tia l to im pact visibility at th e Jarbidg e W ilderness.

D-1252. Does the SIP contain adequate m easures under Best Available Retrofit Technology (BART) f o r “BART-eligible” em ission units under jurisdiction of the NDEP?

• The proposed SO 2 BART e m ission rate for Reid Gardner Units 1, 2, and 3 would

actually allo w for an increase in SO 2 e m issions above the baseline. By allowing for a n

em issions in creas e, the Nevada SIP is incons is te nt with th e r e gulato r y in tent of BART. It is proposed that Nevada rectif y this erro r by e s tablishing a “two-tiered ” BART limit
for SO 2 em issions at Reid Gardner. The curr ent proposed B A RT lim it could be applied
to a short-term (i.e., 1-hour) averaging tim e, while a m o re stringent lim it could be established based on a 30-day rolling average. This would allow for short periods of higher em issions which appear to be presen t based on historical data, but would also require that the com p any operate the Reid Gardner SO 2 con t rol system s in a m a nner consistent with their historical pract ice. Based on the W R AP 2018 em ission projections, Reid Gardner already achieves SO 2 e m issions in the range of 0.03 to 0.04 lb/MMBtu, so the 30 -d ay rolling average BA RT lim it needs to b e in this range to prevent any future degradation of the lo cal and regional v i sib i lity conditio n s.

• The proposed NO

x BART lim it for Reid Gardner Unit 3 is higher at 0.28 lb/MMBtu

com p ared to the proposed NO

x li m it of 0.20 lb/MMBtu for Units 1 and 2. The draft SI P does not provide an adequate explanation or justif ica tion f o r why Unit 3 requires a higher NO

x em ission rate for BART.

• The SIP explains th at selective c a taly tic r e du ction (SCR) was evaluated f o r potentia l applic ation as BART at Reid Gar dner, but rejected based on cost considerations. However, it does not appear that NDEP c onducted a critical evaluation of the SCR costs supplied by NV Energy and instead ha s accepted th e com p any’s costs “at face value.” If cost is to be used as part of the decision to reject SCR as BART for Reid Gardner, the com p any’s SCR cost esti m a tes need to be properly vetted.

• The control efficiency used by Nevada in evaluating SCR for Reid Ga rdner appears to

be underestim ated. In other situations wh ere SCR was reviewed under BART, the postSCR NO
x e m ission rate is consistently 0.07 lb/ MMBtu. At Reid Gardner, the proposed post-SCR em issions rate ranged from 0.083 to 0.098 lb/MMBtu. The draft SIP does not explain why 0.07 lb/MMBtu cannot be achieved using S CR at Reid Gardner. If the draft SIP applied a m o r e realistic post-SCR e m ission rate, the cost evaluation for SCR
at Reid Gardner would also be m o re favorable.

• The post-BART m o deling for Reid Gardne r shows no significant improvem e nt in

visibility at nearby Clas s I areas. Th e lack of improvem e nt in the post-B ART m odeling

m a y reflect an inaccu rate em issions invento r y th at failed to account for changes in the post-BART em issions proposed at Reid Gard ner. If so, the inventory needs to be
corrected and accurate m odeling perform e d at Reid Gardner in ord e r to m eet the procedural requirem e nts of the SIP. On the other hand, if th e Reid Gardner inventory is accurate, then the m odeling indicates a failu re of the draft SIP to craft a BART proposal

D-126that contains any meaningful em issions reductions and associated visibility
im prove m e nt. If a m o re appropriate BART e m i ssion lim it were established at Reid Gardner, it is b e lieve d that th e pos t-BART m odeling would show visibility
im prove m e nt at Grand C a nyon and other nearby Class I areas.

• Even after application of BART t echnologies at Mohave and Reid G a rdner, the postBART visibility m odeling continues to show that em issions from Mohave and Reid
Gardner wo uld con tinu e to “caus e or contri bu te” to v i sib i lity im pairm e nt at nea r by Class I areas, including Grand Canyon Nati onal Park. If these m odeling results are accurate, N e vada shou ld consider more stri ng ent BART em ission levels that further
reduce or elim inate visibility im pairm e nt caused by these sources and even consider

em ission reductions that are “beyond BART” as have oth e r states wh ere BART has proven to be ineffective at providing th e em ission reductions needed to achieve “reasonable further progress” toward the national visibility goal.

3. Does the SIP adequately address and m i tigate Nevada’s contribution to visibility
im pair m e nt at Class I areas outside of Ne vada, in particular National Parks in the
southwestern United States th at are presentl y known to be adversely impacted by N e vada

em issions (i.e., Zion, Bryce Canyon, a nd Grand Canyon National Parks)?

• Regional modeling us ing the 201 8 W R AP invent ory pro j ection s show that visib i lity a t Grand Canyon, Zion, and Bryce Canyon National Parks will not achieve the Uniform Rate of Progress (URP) goals and that the “g lide path” for visibility improvem e nt to natural conditions by 20 64 will not be achieved without additional em ission reductions. This finding occurs even without considering that future growth from Nevada coal-fired EGUs appears to be significantly underrepr esented in the 2018 inventory. Given that

source em issions from within Nevada are show n to “cau se and contribu te” to vis i bility
im pair m e nt at Class I areas outside of the state after 2018, Nevada needs to revisit its draft reg i on al haze S I P and craft an em issions reduction p l an that helps achiev e the URP goals at Class I areas outside of Nevada . Achieving the nationa l visibility goa l a nd

m eeting the 2018 URP m ilestones will requ ire aggr ess i ve actions from all states in the region, including Nevada. Nevada has estab lished BART em ission lim its in the draft SIP that fail to provide m eaningful im pr ovem e nt in visibility conditions and that
continue to show Nevada’s em issions sources will “caus e an d contribu te” to visib ility
im pair m e nt. These findings dem onstrate th at Nevada’s d r aft reg i onal haze SIP as written f a ils to m eet its prim ary objectiv e of providing the initial step toward m eeting the national visibility goal.

D-1277.0 REFERENCES

1. Clean Air Act, Section 169A.

2. Stationary Sources Joint Forum

, Western Regi onal Air Partnership, infor m ation available at

www. wrapair.org

3. Air Quality Modeling Forum

, Wes t ern Regional Air Partnership, inform ation available at

www. wrapair.org

4. Director’s Review and Prelim inary Determ ination of Perm it Issuance for Toquop Energy LLC, Toquop Energy Project; Nevada Division of Environm ental Protection, Decem ber 17,
2007.

5. Directo r ’s Review and Prelim inary Determ ination of Perm it Issuance for Sierra Pacific
Resources Com p any, Ely Energy Center; Nevada Division of Environm e n tal Protection, October 29, 2007.

6. Business W i re; February 9, 2009, available at http://investors.nvenergy.com

7. Class I Application Review f o r W h ite Pin e Energy Associates LLC, W h ite Pine Energy Station; Nevada Division of Envi ronm ental Protection, December 28, 2006.

8. Las Vegas Sun, March 5, 2009, available at www.lasvegassun.com

9. Class I A i r Quality Operating Perm it No. AP 4911-1349; Nevada Division of Environm ental
Protection.

10. Sevier Power Com p any, LLC; http://s evie rp ower.com

11. Conditional Extension of Approval Order #DAQE-AN0327010-04; Utah Departm e nt of
Environm ental Qual ity; April 25, 2008.

12. WRAP 2018 Base Case (Version I) Em issions Inventory, available at www. wrapair.org

13. Sourcew atch; www.s ourcewatch.org

14. Statem e n t of Basis, Southeast Idaho Energy LLC/Power County Advanced Energy Center, Idaho Departm e nt of Environm ental Quality.

15. WRAP 2018 Point Source Em issions-P ivot Tables; available at www.wrapair.org

16. Revised Nevada Division of En vironm ental Protection B A RT Determ ination Review of NV Energy’s Reid Gardner Generating Sta tion Units 1, 2, and 3; April 15, 2009.

D-12817. Regional Haze Regu lations and Guidelines for Best Availab l e Retrofit Techno lo gy (BART)

Determ inations; Final Rule; Fede ral Register July 6, 2005.

18. WRAP 2018 Prelim inary Reasonable Progress Em issions Inventory – Final, Revised; Prepared for W R AP by Eastern Research Group, June 18, 2007.

19. WRAP Regional B A RT Status; March 27, 2009, available at www.wrapair.org

20. DEQ BART Report for the Boa r dm an Power Pl ant; Oregon Departm e nt of Environm ental Quality, Updated December 19, 2008.

21. National Park Service comm ent l e tter on Nevada ’s draft regional haze State Im plem entation Plan, March 6, 2009.

22. BART Analysis f o r

Reid Gardn e r Sta tion U n it 1; Prepa r ed by CM2 M Hill f o r N V Energy, Inc.; Revised October 2008.

23. State of Kansas Air Quality S t ate Im plem entation Plan, Regional Haze, July 15, 2008 (Draft).

Additional Data Sources Considered

Nevada Division of Environm ental Protecti on, B u reau of Air Quality Planning, General
inform ation on April 200 9 draft reg i o n al haze S t ate Im plem entation Plan; availab l e a t http://ndep.nv.gov/baqp/planning.htm l

D-129ATT ACH MENT 1

Information on Author: D. How a rd Gebhart

D-130D-131Previous Service as Ex pert Witnes s

Mr. Gebhart has not served as an expert witne ss a t tr ial in the most recent four years.

Mr. Gebhart did serve as an expert w itness in a recent arbitration case:

• Adkins Energy, LLC v. Lurgi PSI, Inc. v. Ronning Engineering Com p any, Inc.
Am erican Arbitration Association, C a se No. 51 198 Y 00300 05.

Mr. Gebhart has served as an expert witn ess in two recent ad m i nistrativ e hearings :

• Appeal of Air Quality Perm it # 1756 Issued to Vulcan Materials Com p any. Hearing
before the A l buquerque – Bernalillo County Air Quality Con t rol Board.

• Hearing on Air Quality Perm it for Wester n W a ter & Power Production, LLC, Proposed
Estancia Biom ass Power Gene ration Plant. Hearing befo re State of New Mexico Secretary of Environm en t, Case AQCA 06-42(P).

Mr. Gebhart was retained as an expert witne ss in two other cases i nvolving an appeal of an air qu ality perm it. Both cases were se ttled prior to any hearing or trial.

• Stanley R. Atherton, D a vid B. Gooch, and Mark A. Hertel et al v. Abengoa Bioenergy of Indiana. Appeal of Air Quality Perm it 129-23484-00050 issued by the Indiana Departm e nt of Environmental Managem e nt.

• Coshocton County Citizens for a Safe Community et al v. Koncelik et al. Appeal of air

quality perm it for Coshocton Ethanol LLC , Coshocton, OH. ERAC Case Nos. 165768-
72 and 99773.

Publication s

Mr. Gebhart has not authored any peer-reviewed publications in the last four years.

D-132

### SECTION D.2.2.4.3

NEVADA’S RESPONSE

(to Conservation Organiz ations’ Comment Letter)

D-133D-1342.2.4.3 Nevada’s Response

NDEP received written comments via em ail and FAX fro m a group of NGOs regarding Nevada’s draft regional haze SIP on May 20, 2009. Attached to the NGO letter and included in
the comm ents by reference is a report by D. Howa rd Gebhart of Air Resources Specialists, Inc. prepared for the W e stern Resource Advocates and National P a rks Cons ervation Association
titled Technical Review of Draft Nevada State Implementation Pl an for Regional Haze (April 2009) Expert Report (Tech Review). The Tech Review is a support docum ent for issues
summarized in the NGO comments.

The NGO c o mm ents fo cus on 5 m a in areas: the FLM consultation process, the projected 2018

em ission inventory, the BART determ ination fo r Reid Gardner Generating Station, reasonable progress for Class I areas in adjacent states, and inclusion of s p ecific sou r ces in the projected
2018 em ission inventory. The NGO comments are reproduced belo w in italics, while NDEP’s responses are in plain text. The NGOs listed fi ve specific comments with bullets under som e comments. NDEP has not identified any specific comments in the Tech Review and, as such, has not responded specif i cally to item s contained therein.

NGO General Comment: Below is a summary of comments on the Nevada Dr aft RH SIP. For a full description of our comments, please refer to the Technica l Review, which is attached hereto.

NDEP Response: As indicated above, Nevada has reviewed the Te ch Review and determ ined that all of the significant co mm ents in the Tech Review are well summ arized in the NGO co mm ent letter. Therefore, NDEP has u s ed the Tech Review to assist in understandi ng the NGO co mm ents, but has only responded to the item s pres ented in the NGO letter.

NGO Comment 1: 1. The public notice for the RH SIP fails to contai n evidence that the State of Nevada has met in person with the Federal land manage rs for the affected Class I area s as is required by 42 U.S.C. § 7491(d) . I n addition, the public no tice for th e Nev ada RH SIP fails to contain a su mmary of the conclusions and recommendations of the Federal land manager as is required by 42 U .S.C. § 7491(d)

.

NDEP Response: NDEP has fully engaged the Federal Land Manage r (FLM) comm unity through participation in the regional planning process, requesting review and comment on draft BART determ inations beginning O c tober 2008, providing a draft SIP for FLM review in early January 2009, and responding to initial FL M comm ent s on April 17, 2009. This process is in full agreem ent with an August 1, 2006 letter from the FLMs (signed by Sandra V. Silva, USFWS and Chr i stine L. Shaver, NPS) to th e individual s t ates outlin ing th e region al h aze consu lta tion pro cess with the FLM agencies. Mr. Bruce Polkowsky, prim ary Depa rtm e nt of Interior c ontact for regional haze, supports Nevada’s position (June 4, 2009 phone call between Bruce Polkowsky and Frank Forsgren, N D EP) that we have m e t our FLM consultation requirem ents and stated FLMs

D-135typically do not require any “in person” c onsultation (August 22, 2008 phone call between Bruce Polkowsky and Adele Malone, NDEP).

In addition, NDEP included our response to FLM co mm ent s as Appendix C in our public review draft RH SIP dated April 2009. The Notice of Public Comment Period Beginning April 17, 2009 and a Public Hearing on May 20, 2009 provides a link to the draf t SIP, including Appendix C,
which summ arizes and responds to FLM comments on Nevada’s draft RH SI P. Therefore, the public notice does provide a summ ar y of FLM comments by reference.

This comm ent re late s on ly to th e con s ulta tion and public notice process and does not affect the conclusions and recommendations NDEP presents in Nevada’s RH SIP. No changes were m a de
to the SIP as a result of this comm ent.

NGO Comment 2: 2. The RH SIP does not sufficien tly allow for known and planned fu ture growth of air emission

sources in N evada and neighboring states, in parti cular coal-fired elect rical generating units (EG U s )

.

NDEP Response:
Each of the f o llowing f our bulleted c o mm ents will be respon ded to ind i vidually. Ho wever, som e background on the developm ent of regional em ission inven t ories is n ecessary to add r ess these

comments.

Nevada has fully participated in the regiona l planning process though our involvem e nt with
WRAP forum s and workgroups, in cluding the Em issions Forum and Stationary Sources Joint

Forum

. The em issions inventories relied upon by the W R AP and m e mber states were developed by consultants under the direction of these foru ms through a consensus-based process. The inventory developm ent m e thodologies were utili zed for all WRAP states’ inventories. The inventories utilized by WRAP a nd the m e mber states are deem ed by mos t observers to be the
most robust and accurate available.

Two e m issions scenarios were developed by W R AP, a baseline scenario and a projected
scenario. T h e region al haze baselin e pe riod includes years 2 000 through 2004, and is represented by 2002, while the proj ected inventories denote 2018 em issions. The year 2018 was
selec t ed as it repres ents the f i rst m ile stone date for dem onstrating r easonable progress.

The base case 2018 projected em ission inventory was initially developed during 2005 by Eastern Research Group, Inc. (E RG). WRAP Point and Area Source Emissi ons Projections for the 2018 Base Case Inventory, Version 1 14 , prepared by ERG, docum ents the developm ent of the 2018
base case em ission inventory. ERG refined th e 2018 prelim i n ary reas onable progress em ission inventory in early 2007 as docum ented in Technical Mem o randum WRAP 2018 Prelim inary Reasonable Progress E m issions In ventory – Final, Revised 15

.

14 Available at h ttp ://wrap a i r .o rg /fo r u m s/ssj f/do cu m e n t s/eictt s /d o c s/ WRAP_ 201 8_ EI-Versio n_1

- R e po rt _Ja n 20 0 6

. p d f

15 Available at http://wrapai r .org/forum s/ssjf/do cum e nts/eictts/Projections/P RP18_E I_tech%20m em o_061607.pdf

D-136The growth analysis utilized for developm ent of t h e projected i nventory identified future EGUs
needed in o r der to m eet projected electricity dem a nd in 2018. The basis of the projected electricity dem a nd is the Energy Inform ati on Adm i nistration’s (EIA) annual 2018 energy projections f o r four electricity m a rket m odule regions representing the WRAP region. The base case 2018 inventory (base18b) used the EIA projec tions released in 2005, while the prelim inary reasonable progress inventory (PRP18a) utili zed projections released in 2007.

WRAP assum e d a typical future coal-fired EGU has a capacity of 500 MW and operates at BACT levels with a capacity thre shold of 0.85. WRAP then estim at ed that 18 typical coal-fired
EGUs will need to be bu ilt p r io r to 2 018 to m eet projected dem a nd. The future co al-fired EGUs were allocated based upon current state-level capacity (i.e., su m of existing, under construction, and perm itted). The EGUs were then allocated to specific co unties b a sed on announced plans to
build coal-fired EGUs.

Based on a long history of per m ittin g EGUs in Nevada, the Nevada Bureau of Air Pollution Control (BAPC) expected that not all perm it a pplications would result in operating EGUs. Therefore, BAPC dee m e d that two coal-fired EGUs were eith er being p e rm itted or under construction for the purposes of the projected inventory, the 200 M W Nor t hern Nevada Energy (Newm ont) facility (referred in the N GO comme nts as the T S Power Plant) and the 1500 M W White Pine Energy Association (LS Power) faci lity. In addition to the p e rm itted or under construction EGUs, the 2018 inventory projected one 500 MW coal-fired EGU in Ne vada to

m eet anticipated electricity dem a nd growth.

The three proposed coal-fired EGUs included in the 2018 projected em ission inventory are
shown in Table 3-5 of Nevada’s RH SIP as: Fu ture Coal EGU (Newm o nt – Northern Nevada Energy), Future Coal EGU ( W hite Pine Energy Association/LS Power), and Future Coal EGU (A).

Although Nevada has several valid applications f o r operating perm its to construct EGUs, only one EGU in Nevada, Northern Nevada Energy, has been granted an operating perm it to construct in the last few years. In addition, the W h ite Pine Power Project does no t yet have an approved operating perm it to construct. NDEP cancelled th e public comment period and hearing for this

perm it action as a result of an announcem ent by White Pine Energy Associates, LLC 16 that the plans to build the W h ite Pine Energy Station have been indef i nitely postponed. Ely Energy Center’s perm it application has also b een indefinitely postponed by NV Energy 17 . For this very reason, proposed perm it activities are not, as a m a tte r of course, explicitly included in projected

em ission inventories.

This comm e n t acknowledges the fact that projec ted em issions inventories becom e outdated as soon as they are com p leted. However, Nevada de em s the e m issions inventories as accurate and representative of 2018 em issions as possible. N o changes to Nevada’s RH SIP were m a de as a
result of this comment.

16 h ttp ://lsp o w e r.co m / N e w s /n ew sArticle0 3050 9.h t m
17 http://invest ors.nve n ergy.com /phoe nix.zht m l ? c= 117698&p=irol-news A rticle&ID=1254617& h ighlight=

D-137NGO Comment 2, 1 st bullet: • Future growth in coal-fired EGUs appea rs to be underrepresented in the 2018 emission

inventory projections containe d in the draft Nevada regional haze SIP. If the proposed Ely Energy Center and White Pine Power Projects are included, the 2018 emissions projections appear to be low by about 5,700 tpy for SO 2 emissions and 6,200 tpy for NOx emissions.
NDEP has i ssued draft PSD permits for both th e Ely Energy Center and White Pine power plants. As of early May 2009, the draft PSD pe rmits have not been terminated by NDEP nor have the air permit applications been withdraw n by the applicants. Accordingly, the E l y and White Pine Projects need to be par t of Nevada’s SIP planning process.

NDEP Response: As discussed above, the 2018 EGU i nventory is based on projected electricity dem a nd. The
dem a nd side suggested that not all perm it applica tions would result in operating EGUs, as did BAPC’s perm itting experience with EGUs. Theref ore, only o n e of the two proposed coal-fired EGUs in White Pine County was included in the 2018 em ission inventory. Note that the perm it applications for both the Ely Energy Center and White Pine Energy Association have been indefinitely postponed by the applicants, alt hough the perm it applications have not been withdrawn. In addition, S outhern California Edison 18 has announced a decision to decommission the Mohave Generating Station and rem ove the generating facility from the site.

Therefore, since em issions from the Mohave Generating Station and proposed W h ite Pine project are included in the 2018 em i ssion invent ory (PRP18a), the inventory actually overrepresents 2018 em issions from co al-fired EGUs in Nevada.

NDEP also notes that although the E I A energy proj ections suggest additi onal generating capacity will be required in the f u ture, the ele c tr ical inf r as truc ture ha s absorbed th e reduction in generating capacity in N e vada (in part due to the suspension of activ ities at the Mohave Generating Station at the end of 2005) and elsewhere withou t significant problem . NDEP
antic ipates r e newable en ergy projects will prov id e substan tia l genera ting capacity to m eet f u ture electrical dem a nd in Ne vada.

No changes were m a de to the SI P in response to this comm ent.

NGO Comment 2, 2 nd bulle t: • There are inconsistencies between the emissi ons listed in the 2018 emissions inventory for

the Nevada regional haze SIP and allowable em issions established by NDEP air quality permits fo r several sou r ces. For exa mple, the proposed emissions from the TS Power Plant and White Pine Power Project are undere stimated in the RH SIP inventory.

NDEP Response: The TS Power Plant Operating Perm it to Constr uct application was revised August 2007, and the first source tests were conducted April 2008. A com p lete Class I application was recently
subm itted to the Nevada BAPC by the f acility. T h e W h ite Pine Power Project op era t ing perm it to construct application was revised in Decem be r 2006. Note that the White Pin e Power Project has been indefinitely postponed, as noted above.

18 h ttp ://www.ediso n.co m / p r essroo m / p r .asp ? b u = &year=0 &i d = 723 4

D-138The base case 2018 em ission inventory was prep ared in 2005 and the prelim inary reasonable progress inventory was revised in early 2007. The em issions listed in these inventories represent
NDEP’s best estim a te at the tim e the inventories were prepared. No changes were m a de to the SIP in respo n se to th is c o mm ent.

NGO Comment 2, 3 rd bullet: • The proposed Toquop Energy Project near Mes quite is not explicitl y listed in the 2018

emissions in ventory, bu t these em is sions are rela tively clos e to the emissions assigned to an “unnamed” coal-fired E GU. Although the emissi ons from the unnamed plant are similar to those of the Toquop Project, th e resu lting vis i bi lity impact pro j ections fo r 2018 depend also on how the “unnamed” plant was incorporated into the 2018 visibility m odeling. Based on the proposed location fo r Toquop, it is expected that this p l an t will po tentially a ffect regional haze at Zion Na tional Park, Br yce Canyon National Park, and Grand Canyon National Park. The projections of 2018 visibility at these areas are in error if the future Toquop emissions are not properly represented in the 2108 modeling.

NDEP Response: Future Coal EGU (A) identified and disc ussed under the NGO co mm ent above, m a y be
considered as an em issions surrogate for the proposed Toquop Energy Project. The T oquop Energy Project has applied for and NDEP has issu ed a draft operating perm it to construct for public com m e nt. As of Septem ber 4, 2009 NDEP is in the process of responding to public comment and has not yet issued an operating perm it to construct.

The rational for projecting future EGUs has been described above in Nevada’s responses to NGO comments. NDEP acknowledges that Future Co al EGU (A) was not located in imm e diate proxim ity to the proposed Toquop Energy Project, wh ich m a y slightly effect the 2018 visibility projection if the Toquop Energy Project is, in fact, built as pro posed. However, recall that Future Coal EGU (A) is only a placeho l der to accoun t for em issions resulting from increased electrical
dem a nd in 2018.

In addition, Nevada BAPC’s Class I Application Review for Toquop Energy, LLC dated

Decem ber 21, 2007 summ arizes the results of th e vi sib i lity analysis cond ucted as p a rt of the

perm it application process, as follow s : “7.9.4 Visibil ity Anal y s is Regional haze m odeling was conducted with CALPUFF using t h e FLAG guidance for Bry ce Cany o n Natio nal Park, Grand Can y o n Nationa l Park, Zion National Park, Capitol Reef National Park and Sy cam or e Cany on Wilderness. In addition, regional haze m odel i ng results have been provided f o r Lake Mead National Recreati on Area using the FLAG guidance. The regional haze m odeling res u lts are prese nted in Table 7.5 below. As indicated, the regional
haze m odeling results using the FLAG guidance have no da y s above a 5% change in
extinction at any Class I area during any y ear m odele d. Therefore, according to the FLAG guidance, the proposed Toquop project does not have a significant regional haze im p act and
no further m odeling is requ ired.

D-139TABLE 7

. 5

– Reg i o n a l Ha ze Mo deling Results - FL AG (2 003

– 2 005 )

2 003 2 004 2 005

Da ys > N%

∆ B
ex t Da ys > N%

∆ B
ex t Da ys > N%

∆ B
ex t Class I

Area

5% 10% MA X %

∆ B
ex t 1

5% 10% MA X %

∆ B
ex t 1

5% 10% MA X %

∆ B
ex t 1

MVI S B K = 2 , FL AG B a ck gr oun d , 2- km G r i d Cap ito l

Reef 0 0 3

. 0 4 0 0 1

. 4 2 0 0 2

. 1 7

Sycam o re Can yon 0 0 1

. 6 9 0 0 1

. 0 1 0 0 1

. 2 2

MVI S BK= 2 , FLAG B a ck gr oun d , 500-m Grid Bryce

Can yon 0 0 4

. 0 3 0 0 0

. 9 1 0 0 1

. 8 5

Gra n d

Can yon 0 0 2

. 7 5 0 0 4

. 3 3 0 0 3

. 3 2

Zi o n 0 0 4

. 7 0 0 0 1

. 9 5 0 0 4

. 6 1

NOT ES: 1 ∆ B e x t = ch ang e in atm o sp h e ric lig h t cond itio n. ”

Therefore, the proposed Toquop Energy Project ha s been fully reviewed f o r its potential visibility im pacts at nearby Class I areas and it has been determ ined that the project does not have significant visibility im pact s at the Class I areas within 300 km of t h e proposed project. No changes were m a de to the SIP in response to this comment.

NGO Comment 2, 4 th bullet: • The April 2009 Nevada SIP does not include fu ture emissions from the Power County

Advanced Energy Center, which was recently iss u ed a permit by the Idah o Department of Environmental Quality for a site near Amer ican Falls, ID. T h is project could have the potential to impact visibility at the Jarbidge Wilderness.

NDEP Response: As stated earlier in our response to NGO co mments, the base case 2018 projected em ission inventory (base18b) was init ially developed during 2005 and the refined 2018 prelim i n ary reasonable progress em ission i nventory (PRP18a) in early 2007. Idaho Departm e nt of
Environm ental Quality issued a Per m it to C onstruct for the South east Id aho Energy Power County Advance Energy Center project Fe bruary 10, 2009, well afte r the 2018 projected

em ission inventories used in Nevada’s RH SIP were com p leted. In spite of this tim ing, it is each state’s decision and responsibility to ensure th at the W R AP’s projected 2018 em ission inventory
for its sources is accurate and com p lete. Nevada has no role in how Idaho reports the em issions
from this proposed project.

Finally, the project was evaluate d by the Idaho D e partm e nt of Environm e n tal Quality and the FLM community f o r potentia l im pacts to sen s i tiv e Class I areas as a m a jor source und er Prevention of Significant Deterioration (PSD) re gulations and the proj ect was found to have negligible impact on the nearest Class I area, C r aters of the Moon, located 70 km fr om the project site. The FLMs determ ined that a m o re detailed Class I visibi lity analysis was not

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