D-93D-94

### SECTION D.2.2.4.2

TECHNI CAL REVIEW BY AI R RE SOURCE SPECI A LISTS, INC.

D-95D-962.2.4.2 Technical Review pre p ared by Air Resource Specialists, Inc.

D-97TABLE O F CONTENTS

Section Page

1.0 I N TRO DUC TIO N AND BA CK GRO U ND 1

1.1 Overview 1

1.2 Stud y Meth o d s 1

1.3 Report Organization 2

2.0 OVER VI E W OF NE V ADA R E GI ONA L HA ZE STATE I M PLEMEN TATI ON PL AN 4

2.1 Regulatory S e tting 4

2.2 Existing Visibility Cond itions at Jarbidge Wilderness 4

2.3 E m issions Inventor y for Visibilit y Precursor Polluta nts in Nevada 5

2.4 E m issions Inventor y for Visibilit y Precursor Polluta nts in Nevada 6

3.0 PROJEC TE D GR OWT H OF E G Us AND OTHE R IND U STR I AL SOUR C E S 7

3.1 Future Coal EGU and Other Industrial Coal-Projects 8

3.1.1 Toquo p Ener g y Project 8

3.1.2 Ely Energ y C e nter 8

3.1.3 White Pine Energ y Station 9

3.1.4 TS Power Plant 10

3.1.5 Sevier Power (UT) 10

3.1.6 Interm ountain Power Proj ect Unit 3 (UT) 11

3.1.7 Power Count y Advanced Energ y Center (ID) 11

3.2 Co m p arison to Nevada Re gional Haze SIP 12

4.0 BART ANALYSES 15

4.1 Summary of Proposed BART at Nevada Sources 15

4.2 Review of Reid Gardner BART Analy s is 17

4.2.1 SO 2 BART at Reid Gardner 18

4.2.2 NO

x BART at Reid Gardner 19

4.3 Visibility Improvem e nts from BART Implem entation 21

4.3.1 Mohave Generation Station 22

4.3.2 Reid Gardner 23

4.4 Options for “ B ey on d-BART” Controls 2 4

5.0 CUMUL ATI V E IMPA C T S AT SOU T HWES TE RN PAR K S 26

6.0 SUMMAR Y AND C O N C L USI O NS 28

7.0 REFERENCES 31

ATTA CHM E NT 1 Information on Author: D. Howard Gebhart 33

D-98LIST OF TABLES

Table Page

2-1 Baseline Vi si bility Conditions at Jarbidge Wilderness 5

2-2 Nevada Contributio n to S u l f ate and N itrate Extinction – Worst Case Day s 6

3-1 Proposed 20 1 8 EGUs and Current Permit Activity 7

3-2 Co m p arison of Perm itted SO 2 & NO

x E m issions to Nevada Regi onal Haze SI P 13

4-1 Nevada BA R T -Eligible Sources 15

4-2 Proposed Nevada BART-Em i ssion Reductions: SO 2 Em issions 16

4-3 Proposed Nevada BART Em ission Reductions: NO

x Em issions 17

4-4 Summary of BART-Im p ro vem e nt Modeling Results Mohave Generating Station 22

4-5 Summary of BART-Im p ro vem e nt Modeling R esults Reid Gardner Generating Station 23

5-1 Cu m u lative Im p acts on Re gional Haze a nd Utah and Arizona Clas s I Area s 26

D-991.0 INTRO DUCTION AND BACKGROUND

1.1 OVERVIEW

Air Resourc e Specia lis ts , Inc. (ARS) has b een requested by Wester n Resource Advocates

and the National Parks Conservation Associati on to conduct a technical review of the Draft regional haze State Im plem entation Plan (SIP) released for public review and comm ent by the

Nevada Division of Environm ental Protec tion ( NDEP), Bureau of Air Quality Pla nning (date d April 2009 ). The enclo s ed repo rt co nstitu tes the re ques t ed technical rev i ew of the d r aft Nevada regional haze SIP and supporting docum e nts.

This report focuses on three areas of speci al concern. The areas of interest are:

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

• Does the S I P contain adequate em ission cont ro l m easures u nder Bes t A v ailab l e Retrofit Technology (BART) for “BAR T-eligible” em ission units under jurisdic tion of the

NDEP?

• Does the SIP adequately addre s s and m itiga t e Nevada’s contribu tio n to visib i lity

im pairm e nt at Clas s I a r eas ou tsid e of Ne vada, in pa rticula r Nation a l Parks in the southwestern United States that are pres ently known to be adversely im pacted by

Nevada em i ssions (i.e., Zion, Bryce Ca nyon, and Grand Canyon National Parks)?

Nevada’s regional haze SIP is som e what unique com p ared to m o st other sta t es. There is only one Class I area in Nevada, which is the Jarb idge W ilderness in the northeas te rn part of the state. However, due to the r e la tiv ely iso l a t ed loca tion o f Jarbidge, large “BART-elig ible ”

em ission sources under Nevada’s jurisdiction are lo cated over 300 kilom e ters (km ) away and d o not sign if ica n tly con t r i b u te to v i sib i lity im pairme nt at Jarb id ge. According to the S I P, m o st of

the indus trial em issions that con t rib u te to vis i bi lity im pairment at Jarbidge com e from outside

the State of Nevada. E x isting large em ission s ources loca ted within Ne vada only significantly

im pact Class I areas outside of the s t ate. Em issi on sources in northern Neva da (ge n erally in th e area of Reno) im pact Class I areas in the Sie rra Nevada Mountains of northern California.

Em ission sources in southern Nevada (generally in the area of Las Vegas ) im pact Clas s I areas in Utah, Arizona, and southern California.

1.2 STUDY M ETHODS

This report provides a review and assessm ent of the Draft regional haze SIP (dated April 2009) which has been prepared by the Nevada Division of Environm ental Protection (NDEP). Initially, th e SIP was reviewed to obtain gen e ral inform ation about regional h aze issues in Nevada. Then, a m o re detailed investigation was conducted on sections of the SIP which were of interest to the topics under consideration, in particular:

D-100• Chapter 3: Sources of Impairm e nt in Nevada

• Chapter 4: Visibility and Source Apportionm ent Modeling

• Chapter 5: Best Availa ble Retrofit Technology

• Chapter 6: Reasonable Progress fo r the Jarb idge W ilderness Area

• Chapter 7: Long-Term Strategy for Nevada

• Appendix C: Federal Land Managem e nt Agen cy Comm ents and Nevada’s Response

The techn i cal rev i ew ad dressed several im porta nt item s as they related to Nevada’s S I P planning process

• Did Nevada consider all relevant and availabl e inform ation in developing the regional haze

SIP?

• Does the SIP summ a r ize and/or explain all of the im portant and relevant inform ation, including em issions data and m odeling data?

• Are the conclusions and plans developed by the SIP supported by the data presented?

• Are there any altern ativ e explanatio ns or conclu sions that can be reached based on the data presented in the SIP ?

• Are the conclusions an d justifications reached in the Nevada region al haze SIP consisten t
with sim ilar conclus i ons and justif ic a tions app lie d in other states?

• Does the SIP achieve the overall planning obje ctive of im proving visi bility conditions by

the end of 2018 to the level needed based on the “glide path” toward achieving natural visibility conditions by 2064?

The review presented in this report addresses prim ar ily tech nical issues as they relate to regional haze in general and Nevada’s reg i ona l haze SIP planning pro cess in particular. Les s

em phasis was placed on the SIP and whether it met the cu rren t Environm ental Pro t ection Agency (EPA) adm i nistrative requirem e nts for the reg i o n al haze SIP s . In other words, this report looked beyond the m e re content of the technical data pr ovided in the SIP in an attem p t to judge the quality and s c ientif ic cr e d ibility of the inform ation presented.

1.3 REPORT ORGANI ZATION

The technical report is organized as follows:

• Chapter 2 provides a s u mm ary of the Neva da regional h aze SIP, especially with

respect to the ar eas of interest described above.

• Chapter 3 provides inform ation on known propos ed or planned coal-fired EGUs and

other coal-fired industria l em ission units in Nevada and adjacent states.

• Chapter 4 provides a review of the pr oposed BART for Nevada sources, with

em phasis on the Reid Gardner Generating St ation in southern Nevada. Reid Gardner

em issions have the pote n tia l to im pact Cla ss I areas outside Nevada, especially Grand Canyon, Zion, and Bryce Canyon National Parks.

D-101• Chapter 5 a ddresses the cum u lative im pacts to visibility at Class I a r ea s in Arizona

and Utah that are im pacted by N e vada em issions and also reviews the level of

im provem e nt expected at these areas from BART and other c ontrols recommended by Nevada’s regional haze SIP.

• Chapter 6 discusses the m a jor conclu sions and findings of the report.

• Chapter 7 lis t s the techn i cal references cited by the report.

2.0 OVERVIEW OF NEVADA REGIONAL HAZ E STATE IMPLEMENTATION

PLAN

This chapter provides an overview of the April 2009 draft Nevada regional haze SIP.

This overview is not intended to be a com p rehe nsive summary of all SIP elem ents, but instead

focuses on those com p onents of the SIP which are of m o st interes t with r e spect to the conten ts of

this r e por t.

2.1 REGULATORY SETTING

The Nevada State Im plem entation Plan (SIP ) for regional haze addresses Clean Air Act requirem e nts to protect visibility in designa ted Class I areas, m a inly national parks and

wildernes s areas. The 19 77 Clean Air Act Am endm en ts call for “prevention of any future and the

rem e dying of any existing im pairment of visibi lity in m a ndatory Clas s I Federal areas which

im pair m e nt results from m a n- m a de air pollution” [ R eference 1 ]

. Nevada has one such Class I

area, the Jarbidge W ilderness in no rtheastern Ne vada. The U S DA/Forest Se rvice ac ts as Fed e ra l Land Manager (FLM) responsible for the Jarbidge W ilderness.

In respon se to the Clean Air A c t requ irem ents, th e United State s Environm ental Protection Agency (EPA) has adopted requirem ents ai m e d at achieving the national goal of restoring visibility to “natural conditions” by 2064. Each state is required to prepare a plan that

addresses two elem ents: 1) im proving visibility on the haziest days, and 2) protecting visibility on clear days from being degraded. Plans m u st also add r es s how em issi on sources in the state

m a y affect visibility at Class I areas in neighboring states. The second com ponent of the SIP i s particularly im portant in Nevada as m a ny of th e m a jor Neva da e m ission sources im pact visibility

at Class I areas outs i de of Nevada.

The current regional haze SIP prim arily addr e s ses the initial plan ning period covering 2008 through 2018. The SIP is requir ed to provide for “reasonabl e further progress” over the initial planning period toward achieving the nationa l visibility goal. The Nevada SIP establishes this goal as a “uniform rate of progress” (UR P ), based on achieving a linear rate of visibility

im prove m e nt from the current conditions to “natural cond itions” in 2064.

2.2 EXISTI NG VISIBILIT Y CONDIT I ONS AT J ARBI D GE WILDERNESS

D-102Jarbidge W ildernes s is located in northeas te rn Nevada and is relatively isolated from anthropogenic em ission sources. As such, Jarbidge has som e of the cleanest visibility conditions

m easured at Class I areas in the con t inental United States.

Baseline visibility conditions m easured at Ja rbidge are summ a r ized in T a ble 2-1. The unit

of m easurem ent for visibility is th e deciv i ew (dV). The d ecivi ew is a slid ing sca l e where a change of 1 dV is inten d ed to repr e s ent a lev e l of perceptible change in visibility. Since visual changes ten d to be m o r e perceptible in clean environm ents, a 1 dV change results from lower

levels of pollution in a c l eane r envir o nm ent suc h as Jarbidg e . These m easurem ents are co llected by the Interagency Monitoring of Protected Vi sual Environm e n ts (IMPROVE) program.

Table 2-1

Baseline Visibility Conditions at Jarbidge W ilderness (Based on IMPROVE data from 2000-2004 as reported in Nevada’s Draft Regional Haze SIP)

Best 20% Days Worst 20% Days

2.56 dV 12.07 dV

NDEP’s review of the IMPROVE monitoring data for Jarbidge suggest that organic

m a tter carbon (OMC) and elem ental carbon (EC) are the prim ary contributor to light extinction on the worst 20% days. These pollutants cause almo st one-half of the reconstructed extinction on the worst-case days. Sulfates and n i trates, caus e d generally by anthropogeni c em issions of sulfur dioxide (SO 2 ) and nitrogen oxides (NO

x ), represent only 20% of the reconstructed extinction on

the wors t-c a se days at Jarb i dge. In highly polluted Class I ar e a s, the sulf ate and nitra t e

com ponent of reconstructed extinction is typically very large. On this basis, NDEP concluded

that windblown dust and fire em issions are the most significant contributors to existing visibility

im pair m e nt at Jarbidge. Em issions from industr ial sources m a ke only a sm all contribution to visibility impairm e nt at Jarbi dge. According to NDEP, the industr ial sources im pacting Jarbidge

are m o stly from Idaho as the large industrial sources in Nevada are generally m o r e than 300 km

away.

2.3 EMISSIONS INVE NT ORY FO R VISIBILIT Y PRE C UR SOR POLLUTANTS IN

NEVADA

The draft Nevada reg i o n al haze SIP has prepared an invento r y of polluta nts for visib ility

precursor em issions for the baseline period (20 02) and the end of the planning period (2018). The Nevada inventory relies heavily on data pr epared by the W e stern Re gional Air P a rtnership (W RAP) [ R eferen ce 2 ] . For the baseline period, SO 2 and NO

x em issions are dom inated by point and area sources (anthropogenic em issions). For the other visibility precursor em issions, natural

sources su ch as fire are the larges t contributor s, along with fugitive dus t for particu l ate m a tter

em issions.

D-103In the baseline period, Nevada’s industria l em issions are dom inated largely by the Mohave Generating Station, a coal -fired electric generating unit (EGU). Operations at Mohave

were term inated at the end 2005, so any em i ssion reductions from Mohave have already occurred. If Mohave were to reopen, current re gulations would require that the EGU be operated on natural gas.

Major industrial em issions inside and outside of Nevada were also considered when evaluating visibility conditions at Jarbidge. W ithin Nevada, m a jor e m ission sources that could affect Jarbidge include the Valm y Station, a co al-fired EGU, along with m a jor gold m i nes and

other m i neral opera tion s in the state. All of thes e em issions appear to b e included in the WRAP

em issions in ventories relied upon by NDEP for the region al h aze SIP.

The 2018 inventory prepared by WRAP prov ides em issions for future growth of

industrial em issions sources in Nevada, includi ng planned EGUs. Thi s topic is explored m o re fully in Chapter 3 of this report.

2.4 IMPACTS OF NEVADA EMISS I ON SOURCES AT NON-NEVADA CLAS S I

ARE AS

The visibility im pact of Nevada em ission sour ces on visibility at Cl ass I areas outs i d e of Nevada has been reported in the draft SIP. These estim ates are prim arily based upon dispersion modeling. NDEP has relied upon modeling prepared by the W e stern Regional Air Partnership (W RAP) for this as sess m e nt [ R eference 3 ]

.

For the purposes of this report, we are m o st interes t ed in how Nevada sources affec t visibility at nearby National Parks in the southwest United States, nam e ly Grand Canyon National Park, Zion National Park, and Bryce Canyon National Park. All of these parks generally

lie within 300 km of the m a jor point source EGUs in southern Nevada.

The m odeling results for sulfate and nitr ate extinction at Gra nd Canyon, Zion, and B r yce Canyon are summarized in Table 2-2.

Table 2-2

Nevada Contribution to Sulfate and N itrate Extinction – W o rst Case Days

(based on WRAP Modeling Presented in Nevada’s Regional Haze SIP)

Sulfate Extinction Nitrate Extinction

2002 2018 2002 2018

Grand Canyon 6.0% 2.8% 2.2% 2.8%

Zion 9.0% 5.6% 8.1% 7.9%

Bryce Canyon 8.1% 4.8% 8.8% 8.8%

D-104For sulfate extinction, the W R AP modeling shows Nevada s ources will be contributing less of the total extinction in 2018 compared to the 2002 baseline condition. Again, the large SO 2

em ission reductions ass o ciated with the Mohav e closu r e are the likely cause of the decreased

sulfate im pact. On the other hand, for nitrate ex tinction, the overall contribution from Nevada

em ission sources changes only slig htly, and actually increases on a p e rcentage basis at Gran d Canyon. Even though the percentage attributable to Nevada sources increase, the overall contribution would be expected to decrease d u e to the projected im provem e nt in the overall

nitrate extinction com ponent by 2018.

The contribution of individual Nevada em ission sources to visi bility is d i scussed m o re in

the BART s ection (Chapter 4) and the cum u lative m odeling section (Chapter 5) of the report.

3.0 PROJECTED GROWTH OF EGUs AND OTHER INDUSTRI AL SOURCES

The April 2 009 draft Nevada reg i o n al haze SIP includes p r ojections of future growth in

industrial em issions as part of the 2018 em issions inventory. Presum ably, these em i ssions were

included in the W R AP m odeling conducted as part of the SIP to de term ine whether or not Nevada would achieve “reasonable further progress” as it re late s to the nationa l vis i bility goal.

Because em issions and m odeling are inh e rently related, an accu rate accountin g of future

em issions is a very im portan t elem ent of the SIP planning process. If the projected future growth

in em issions is underrepresented, the draft SIP ma y be overestim ating the level of improvem e nt of visibility associated with any proposed regu latory actions and Nevada’s ability to achieve “reasonable further progre ss” could be questioned.

Table 3-1 summ arizes the future E GU and other industrial sources listed by Nevada in the April 20 09 draft reg i onal haze S I P.

Table 3-1

Proposed 2018 EGUs and Current Perm it Activity (from April 2009 Nevada Draft Regional Haze S I P)

Emissions Unit NO

x (tpy) SO 2 (tpy)

Future Coal EGU (Newmont – Nort hern Nevada Energy) 499 670

Future Natural Gas EGU (Copper Mountain – Sem p ra Energy) 887 6

Future Natural Gas EGU (Chuck Lenzie – NV Energy) 739 5

Future Coal EGU ( W hite Pine Energy – LS Power) 3,909 4,356

Future Coal EGA (Unna m e d – Plant A) 1,340 1,452

Total Grow th in Emissions from N e w EGUs 7,374 6,489

D-105For this report, an independent review wa s conducted of proposed EGUs in Nevada and adjoining states. This review focused on coal-b ased EGUs and other coal-based industrial projects. The inform ation presented in this section was obtained from public docum ents, including newspaper and m a gazine reports, pub lic docum ents from co m p anies involved with these projects, and public docum ents from regulat ory agency files, including NDEP. Most of the public docum ents reviewed for this assessm ent were obtained via the Internet.

3.1 FUTURE COAL EGU AND OTH E R INDUSTRIAL COAL-PROJECTS

3.1.1 Toquop Energy Project

The Toquop Energy Project (Toquop) is a proposed 750 M W c o al-fired electric generating plant to be located in L i ncoln County, Nevada, about 12 m iles northwest of Mesquite. The project developer is Sithe Global Powe r, under the subsidiary Toquop Energy LLC.

A draft air quality perm it for Toquop was released by N D EP in Decem b er 2007 and a public hearing on the proposed perm it was held February 7, 2008. However, as of May 2009, no final action has been taken by NDEP on the Toquop perm it. The Regional Haze SIP needs to be

am ended to clarify if Plant A is the Toquop plant and also specify the exact location of Plant A by NDEP/ WRAP.

Based on N D EP documents [ R efer ence 4 ] , Toquop em issions will be 1,614 tons per year (tpy) for nitrogen oxides (NO

x ) and 1,352 tpy for sulfur dioxide (SO 2 ).

Toquop is not specifically listed as an e m i ssion source in the 2018 e m issions inventory

contain e d in the draft N e vada Regio n al Haze SIP or the 20 18 W R AP inventory. H o wever, the SIP inventory does contain an unnam e d generic co al-fired EGU (Plant A) that has e m issions approxim a tely equivalent to those listed in the draft Toquop perm it.

Toquop is located in southeas tern Nevada, in relatively cl ose proxim ity to the existing Reid Gardner Generating Station, operated by NV Energy. Because of the proxim ity of the two

f acilities, it is r easonab l e to expec t that thes e two facilities would gene rally im pa ct the sam e Class I areas (i.e., Z i on National Park, Bry ce Canyon National Park, an d Grand Canyon National Park). As s u ch, the em ission increases that would occur from construction and operation of Toquop would tend to offset any benefits genera ted from BART-related em ission reductions at

Reid Gardner.

3.1.2 Ely Energy Center

The Ely Energy Center (Ely) is a proposed coal-fired EGU planned for W h ite Pine County, Nevada at a site about 30 m iles north of Ely. The project developer is NV Energy, Inc.

D-106A draft air quality perm it for Ely was re leased by NDEP in October 2007 and a public hearing on the draft perm it was held on January 9, 2008. However, no final action has been taken by NDEP on the Ely perm it.

Based on N D EP documents [ Reference 5 ], project em issions at Ely will be 4,853 tpy for

NO

x and 4,628 tpy for SO 2

.

Ely is not listed in the 2018 e m issions invent ory contained in the April 2009 draft Nevada Regional Haze SIP, nor is this source listed in the 2018 W R AP e m issions inventory projections. In fact, if the Ely em issions were to be included, the total em issions increase as sign ed to future

EGUs in Ne vada would be increased by about 65% for NO

x and over 70% for SO 2

.

However, on February 9, 2009, NV Energy anno unced that construction and developm ent of the Ely Energy Center Project has been postponed [ Reference 6 ]. In lieu of the Ely Energy Center, NV Energy instead announced that they had acquired a 598 M W natural gas-fired generating station (Higgins Generating Station) and would also pursue construction of a 500

M W natural gas-fired unit at their Harry Allen Ge nerating Station. It is unclear whether or not

the additional 500 MW natural gas-f i red unit at Ha rry Allen is represented in the 2018 Nevada

em ission inventory. The 2018 WRAP e m ission projections list future natural gas fired units at NV Power’s Chuck Lenzie Station, but no m e ntion is m a de of additional natural gas

- fired units

at the Ha rry Allen Sta tio n.

As of May 2009, the draft PSD perm it and air perm it application for the Ely Energy Center have not been withdrawn by NV Ene r gy or terminated by NDEP. As such, these

em issions still n eed to b e part of Ne vada’s SIP p l anning p r oc ess.

3.1.3 White Pine Energy Station

The W h ite Pine Energy Station (White Pine ) is a proposed coal-fired EGU planned for White Pine County, Nevada at a s ite near McG ill. The p r oject d e veloper is W h ite Pine Energy

Associate s LLC (LS Power).

A draft air quality perm it for Ely wa s rel eased by NDEP in Decem ber 2006 and a public hearing was on the draft perm it held on March 8, 2007. However, no final action has been taken by NDEP on the W h ite Pine perm it.

Based on NDEP documents [ Reference 7 ], project em issions at W h ite Pine will be 4, 812 tpy for NO

x and 6,071 tpy for SO 2

.

White Pine is part of the 2018 e m issions inventory contained in the April 2009 draft Nevada Regional Haze SIP and the 2018 W R AP inventory. However, the SIP and WRAP inventory substantially underestim ates W h ite Pine ’s em ission s in com p arison to the N D EP draft

perm it. SO 2 em issions are underestim ated in the SIP by about 1,700 tpy (4,356 tpy vs. 6,071 tpy)

and NO

x em issions are underestimated by abou t 900 tpy (3,909 tpy vs. 4,356 tpy).

D-107However, on March 5, 2009, LS Power announced that construction and development of

the W h ite Pine Energy Station has been postponed “indefinitely.” [ Reference 8 ]. Furtherm ore, LS Power withdrew a pending application for the proje c t b e f o re th e Public Utilities Co mmission

of Nevada a nd NDEP also cancelled a public h earing scheduled for March 25, 2009 related to

the revised Statem ent of Basis covering W h ite Pine’s carbon diox ide and greenhouse gas

em issions.

However, as of May 2009, th e d r aft PSD perm it and air perm it applica t ion f o r the W h ite Pine Power Project have not been w ithdrawn by LS Power or term inated by NDEP. As such,

these em issions need to continue to be part of Nevada’s SI P planning process.

3.1.4 TS Pow er Plant

The TS Power Plant (TS Plant) is a 200 M W coal-fired boiler at a site near Dunphy, NV. The project developer is Newm ont Nevada Energy Investm e nt LLC (owned by Newm ont Mining Corporation). T h e TS Plant supplies par t of its ele c tr ical output to operate nearby m i ning operations owned by Ne wm ont with the rem a inder of the power output goi ng to th e electrical grid.

The TS Plant is curr ently operation al and is co vered by a Class I Air Quality Ope r ating

Perm it (Perm it No. AP4911-1349), issued by NDEP.

Based on the allowable em ission li m itation f o r the coal bo iler [ Reference 9 ], project em issions at TS were calculated by ARS to be 596 tpy for NO

x and 845 tpy for SO 2 . The TS Plant operating

perm it lim its annual NO

x em issions, but does not contai n an annualized lim it for the SO 2

em ission. The SO 2 em ission total was estim a ted by ARS us ing the sh ort- term emissions lim it (192.9 lb/hr) and 8,760 hours per year of operation.

The TS Power Plant is part of the 2018 em issions inventory contained in the April 2009

draft Nevad a Regional Haze SIP. However, th e SIP somewhat underestim ates the TS Plant

em issions in com p arison to the a llo wable em issions f r om the Class I p e rm it. SO 2 em issions are

underestim ated in the SIP by about 175 tpy (670 tpy vs. 845 tpy) and NO

x em issions are

underestim ated by about 100 tpy (3,909 tpy vs. 4,356 tpy). The correct perm itted em issions for this facility should be reflected in the Nevada regional haze SIP.

3.1.5 Sevier Pow er (UT)

Sevier Power Com p any LLC (Sevier) has pr oposed a 250 MW (net) circulating fluidized bed coal-fired power plant in central Utah near Sigurd. [ Refer e nce 10]

Sevier was issued a final air quality perm it by the Utah Division of Air Quality (UDAQ)

in October 2004. Howe ver, this perm it has been appealed by the Sierra Club Utah Chapter and

Sevier Citizens for Clean Air a nd Water. A hearing on these two perm it appeals was held before the Utah Suprem e Court on October 8, 2008. As of May 2009, a decision on these appeals has not yet been published by the Court. There is also a legal dispute regardi ng a local Sevier County

D-108