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SECTION D.2.2.4.2 

TECHNICAL REVIEW BY AIR RESOURCE SPECIALISTS, INC. 

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2.2.4.2 Technical Review prepared by Air Resource Specialists, Inc. 

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TABLE OF CONTENTS 

Section Page 

1.0 INTRODUCTION AND BACKGROUND 1 

 1.1 Overview 1 

 1.2 Study Methods 1 

 1.3 Report Organization 2 

2.0 OVERVIEW OF NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN 4 

 2.1 Regulatory Setting 4 

 2.2 Existing Visibility Conditions at Jarbidge Wilderness 4 

 2.3 Emissions Inventory for Visibility Precursor Pollutants in Nevada 5 

 2.4 Emissions Inventory for Visibility Precursor Pollutants in Nevada 6 

3.0 PROJECTED GROWTH OF EGUs AND OTHER INDUSTRIAL SOURCES 7 

3.1 Future Coal EGU and Other Industrial Coal-Projects 8 

3.1.1 Toquop Energy Project 8 

 3.1.2 Ely Energy Center 8 

 3.1.3 White Pine Energy Station 9 

 3.1.4 TS Power Plant 10 

 3.1.5 Sevier Power (UT) 10 

 3.1.6 Intermountain Power Project Unit 3 (UT) 11 

3.1.7 Power County Advanced Energy Center (ID) 11 

3.2 Comparison to Nevada Regional 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 Analysis 17 

 4.2.1 SO2 BART at Reid Gardner 18 

 4.2.2 NOx BART at Reid Gardner 19 

4.3 Visibility Improvements from BART Implementation 21 

 4.3.1 Mohave Generation Station 22 

 4.3.2 Reid Gardner 23 

 4.4 Options for “Beyond-BART” Controls 24 

5.0 CUMULATIVE IMPACTS AT SOUTHWESTERN PARKS 26 

6.0 SUMMARY AND CONCLUSIONS 28 

7.0 REFERENCES 31 

ATTACHMENT 1 Information on Author: D. Howard Gebhart 33 

 

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LIST OF TABLES 

Table Page

2-1 Baseline Visibility Conditions at Jarbidge Wilderness 5 

 

2-2 Nevada Contribution to Sulfate and Nitrate Extinction – Worst Case Days 6 

 

3-1 Proposed 2018 EGUs and Current Permit Activity 7 

 

3-2 Comparison of Permitted SO2 & NOx Emissions to Nevada Regional Haze SIP 13 

 

4-1 Nevada BART-Eligible Sources 15 

 

4-2 Proposed Nevada BART-Emission Reductions: SO2 Emissions 16 

 

4-3 Proposed Nevada BART Emission Reductions: NOx Emissions 17 

 

4-4 Summary of BART-Improvement Modeling Results Mohave Generating Station 22 

 

4-5 Summary of BART-Improvement Modeling Results Reid Gardner Generating Station 23 

 

5-1 Cumulative Impacts on Regional Haze and Utah and Arizona Class I Areas 26 

 

 

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1.0 INTRODUCTION AND BACKGROUND 

 

1.1 OVERVIEW 

 

Air Resource Specialists, Inc. (ARS) has been requested by Western Resource Advocates 

and the National Parks Conservation Association to conduct a technical review of the Draft 

regional haze State Implementation Plan (SIP) released for public review and comment by the 

Nevada Division of Environmental Protection (NDEP), Bureau of Air Quality Planning (dated

April 2009). The enclosed report constitutes the requested technical review of the draft Nevada 

regional haze SIP and supporting documents. 

 

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

 

 • Does the SIP sufficiently allow for known and planned future growth of air emission 

sources in Nevada and neighboring states, in particular coal-fired electrical generating 

units (EGUs)? 

 

• Does the SIP contain adequate emission control measures under Best Available Retrofit 

Technology (BART) for “BART-eligible” emission units under jurisdiction of the 

NDEP? 

 

• Does the SIP adequately address and mitigate Nevada’s contribution to visibility

impairment at Class I areas outside of Nevada, in particular National Parks in the

southwestern United States that are presently known to be adversely impacted by 

Nevada emissions (i.e., Zion, Bryce Canyon, and Grand Canyon National Parks)? 

Nevada’s regional haze SIP is somewhat unique compared to most other states. There is 

only one Class I area in Nevada, which is the Jarbidge Wilderness in the northeastern part of the 

state. However, due to the relatively isolated location of Jarbidge, large “BART-eligible” 

emission sources under Nevada’s jurisdiction are located over 300 kilometers (km) away and do

not significantly contribute to visibility impairment at Jarbidge. According to the SIP, most of 

the industrial emissions that contribute to visibility impairment at Jarbidge come from outside 

the State of Nevada. Existing large emission sources located within Nevada only significantly 

impact Class I areas outside of the state. Emission sources in northern Nevada (generally in the

area of Reno) impact Class I areas in the Sierra Nevada Mountains of northern California. 

Emission sources in southern Nevada (generally in the area of Las Vegas) impact Class I areas in 

Utah, Arizona, and southern California. 

 

1.2 STUDY METHODS 

 

This report provides a review and assessment of the Draft regional haze SIP (dated April 

2009) which has been prepared by the Nevada Division of Environmental Protection (NDEP). 

Initially, the SIP was reviewed to obtain general information about regional haze issues in 

Nevada. Then, a more detailed investigation was conducted on sections of the SIP which were of

interest to the topics under consideration, in particular: 

 

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• Chapter 3: Sources of Impairment in Nevada 

• Chapter 4: Visibility and Source Apportionment Modeling 

• Chapter 5: Best Available Retrofit Technology 

• Chapter 6: Reasonable Progress for the Jarbidge Wilderness Area 

• Chapter 7: Long-Term Strategy for Nevada 

• Appendix C: Federal Land Management Agency Comments and Nevada’s Response 

 

The technical review addressed several important items as they related to Nevada’s SIP 

planning process 

 

• Did Nevada consider all relevant and available information in developing the regional haze 

SIP? 

• Does the SIP summarize and/or explain all of the important and relevant information, 

including emissions data and modeling data? 

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

• Are there any alternative explanations or conclusions that can be reached based on the data 

presented in the SIP? 

• Are the conclusions and justifications reached in the Nevada regional haze SIP consistent

with similar conclusions and justifications applied in other states? 

• Does the SIP achieve the overall planning objective of improving visibility 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 primarily technical issues as they relate to 

regional haze in general and Nevada’s regional haze SIP planning process in particular. Less

emphasis was placed on the SIP and whether it met the current Environmental Protection Agency 

(EPA) administrative requirements for the regional haze SIPs. In other words, this report looked

beyond the mere content of the technical data provided in the SIP in an attempt to judge the 

quality and scientific credibility of the information presented. 

 

1.3 REPORT ORGANIZATION 

 

 The technical report is organized as follows: 

 

• Chapter 2 provides a summary of the Nevada regional haze SIP, especially with

respect to the areas of interest described above. 

 

• Chapter 3 provides information on known proposed or planned coal-fired EGUs and 

other coal-fired industrial emission units in Nevada and adjacent states. 

 

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

emphasis on the Reid Gardner Generating Station in southern Nevada. Reid Gardner 

emissions have the potential to impact Class I areas outside Nevada, especially Grand 

Canyon, Zion, and Bryce Canyon National Parks. 

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• Chapter 5 addresses the cumulative impacts to visibility at Class I areas in Arizona

and Utah that are impacted by Nevada emissions and also reviews the level of 

improvement expected at these areas from BART and other controls recommended by 

Nevada’s regional haze SIP. 

 

• Chapter 6 discusses the major conclusions and findings of the report. 

 

• Chapter 7 lists the technical references cited by the report. 

 

2.0 OVERVIEW OF NEVADA REGIONAL HAZE 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 comprehensive summary of all SIP elements, but instead 

focuses on those components of the SIP which are of most interest with respect to the contents of

this report. 

2.1 REGULATORY SETTING 

 

The Nevada State Implementation Plan (SIP) for regional haze addresses Clean Air Act 

requirements to protect visibility in designated Class I areas, mainly national parks and 

wilderness areas. The 1977 Clean Air Act Amendments call for “prevention of any future and the 

remedying of any existing impairment of visibility in mandatory Class I Federal areas which

impairment results from man-made air pollution” [Reference 1]. Nevada has one such Class I 

area, the Jarbidge Wilderness in northeastern Nevada. The USDA/Forest Service acts as Federal 

Land Manager (FLM) responsible for the Jarbidge Wilderness.

 

In response to the Clean Air Act requirements, the United States Environmental 

Protection Agency (EPA) has adopted requirements aimed at achieving the national goal of 

restoring visibility to “natural conditions” by 2064. Each state is required to prepare a plan that 

addresses two elements: 1) improving visibility on the haziest days, and 2) protecting visibility 

on clear days from being degraded. Plans must also address how emission sources in the state 

may affect visibility at Class I areas in neighboring states. The second component of the SIP is

particularly important in Nevada as many of the major Nevada emission sources impact visibility

at Class I areas outside of Nevada. 

 

The current regional haze SIP primarily addresses the initial planning period covering 

2008 through 2018. The SIP is required to provide for “reasonable further progress” over the 

initial planning period toward achieving the national visibility goal. The Nevada SIP establishes 

this goal as a “uniform rate of progress” (URP), based on achieving a linear rate of visibility 

improvement from the current conditions to “natural conditions” in 2064. 

 

2.2 EXISTING VISIBILITY CONDITIONS AT JARBIDGE WILDERNESS 

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Jarbidge Wilderness is located in northeastern Nevada and is relatively isolated from

anthropogenic emission sources. As such, Jarbidge has some of the cleanest visibility conditions 

measured at Class I areas in the continental United States. 

 

Baseline visibility conditions measured at Jarbidge are summarized in Table 2-1. The unit 

of measurement for visibility is the deciview (dV). The deciview is a sliding scale where a 

change of 1 dV is intended to represent a level of perceptible change in visibility. Since visual 

changes tend to be more perceptible in clean environments, a 1 dV change results from lower 

levels of pollution in a cleaner environment such as Jarbidge. These measurements are collected 

by the Interagency Monitoring of Protected Visual Environments (IMPROVE) program. 

Table 2-1 

 

Baseline Visibility Conditions at Jarbidge Wilderness 

(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 

matter carbon (OMC) and elemental carbon (EC) are the primary contributor to light extinction 

on the worst 20% days. These pollutants cause almost one-half of the reconstructed extinction on 

the worst-case days. Sulfates and nitrates, caused generally by anthropogenic emissions of sulfur 

dioxide (SO2) and nitrogen oxides (NOx), represent only 20% of the reconstructed extinction on 

the worst-case days at Jarbidge. In highly polluted Class I areas, the sulfate and nitrate 

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

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

impairment at Jarbidge. Emissions from industrial sources make only a small contribution to 

visibility impairment at Jarbidge. According to NDEP, the industrial sources impacting Jarbidge 

are mostly from Idaho as the large industrial sources in Nevada are generally more than 300 km 

away. 

 

2.3 EMISSIONS INVENTORY FOR VISIBILITY PRECURSOR POLLUTANTS IN 

NEVADA

 

The draft Nevada regional haze SIP has prepared an inventory of pollutants for visibility 

precursor emissions for the baseline period (2002) and the end of the planning period (2018). 

The Nevada inventory relies heavily on data prepared by the Western Regional Air Partnership 

(WRAP) [Reference 2]. For the baseline period, SO2 and NOx emissions are dominated by point 

and area sources (anthropogenic emissions). For the other visibility precursor emissions, natural 

sources such as fire are the largest contributors, along with fugitive dust for particulate matter

emissions. 

 

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In the baseline period, Nevada’s industrial emissions are dominated largely by the 

Mohave Generating Station, a coal-fired electric generating unit (EGU). Operations at Mohave 

were terminated at the end 2005, so any emission reductions from Mohave have already 

occurred. If Mohave were to reopen, current regulations would require that the EGU be operated 

on natural gas. 

 

Major industrial emissions inside and outside of Nevada were also considered when 

evaluating visibility conditions at Jarbidge. Within Nevada, major emission sources that could 

affect Jarbidge include the Valmy Station, a coal-fired EGU, along with major gold mines and 

other mineral operations in the state. All of these emissions appear to be included in the WRAP 

emissions inventories relied upon by NDEP for the regional haze SIP. 

The 2018 inventory prepared by WRAP provides emissions for future growth of 

industrial emissions sources in Nevada, including planned EGUs. This topic is explored more 

fully in Chapter 3 of this report. 

 

2.4 IMPACTS OF NEVADA EMISSION SOURCES AT NON-NEVADA CLASS I 

AREAS 

 

The visibility impact of Nevada emission sources on visibility at Class I areas outside of 

Nevada has been reported in the draft SIP. These estimates are primarily based upon dispersion 

modeling. NDEP has relied upon modeling prepared by the Western Regional Air Partnership 

(WRAP) for this assessment [Reference 3]. 

 

For the purposes of this report, we are most interested in how Nevada sources affect

visibility at nearby National Parks in the southwest United States, namely Grand Canyon 

National Park, Zion National Park, and Bryce Canyon National Park. All of these parks generally 

lie within 300 km of the major point source EGUs in southern Nevada. 

 

The modeling results for sulfate and nitrate extinction at Grand Canyon, Zion, and Bryce 

Canyon are summarized in Table 2-2. 

 

Table 2-2 

 

Nevada Contribution to Sulfate and Nitrate Extinction – Worst 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% 

 

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For sulfate extinction, the WRAP modeling shows Nevada sources will be contributing 

less of the total extinction in 2018 compared to the 2002 baseline condition. Again, the large SO2 

emission reductions associated with the Mohave closure are the likely cause of the decreased 

sulfate impact. On the other hand, for nitrate extinction, the overall contribution from Nevada

emission sources changes only slightly, and actually increases on a percentage basis at Grand

Canyon. Even though the percentage attributable to Nevada sources increase, the overall 

contribution would be expected to decrease due to the projected improvement in the overall 

nitrate extinction component by 2018. 

 

The contribution of individual Nevada emission sources to visibility is discussed more in 

the BART section (Chapter 4) and the cumulative modeling section (Chapter 5) of the report. 

 

3.0 PROJECTED GROWTH OF EGUs AND OTHER INDUSTRIAL SOURCES 

 

The April 2009 draft Nevada regional haze SIP includes projections of future growth in 

industrial emissions as part of the 2018 emissions inventory. Presumably, these emissions were

included in the WRAP modeling conducted as part of the SIP to determine whether or not 

Nevada would achieve “reasonable further progress” as it relates to the national visibility goal. 

Because emissions and modeling are inherently related, an accurate accounting of future 

emissions is a very important element of the SIP planning process. If the projected future growth 

in emissions is underrepresented, the draft SIP may be overestimating the level of improvement 

of visibility associated with any proposed regulatory actions and Nevada’s ability to achieve 

“reasonable further progress” could be questioned. 

 

Table 3-1 summarizes the future EGU and other industrial sources listed by Nevada in 

the April 2009 draft regional haze SIP. 

 

Table 3-1 

 

Proposed 2018 EGUs and Current Permit Activity 

(from April 2009 Nevada Draft Regional Haze SIP)

 

Emissions Unit NOx

(tpy) 

SO2

(tpy)

Future Coal EGU (Newmont – Northern Nevada Energy) 499 670 

Future Natural Gas EGU (Copper Mountain – Sempra 

Energy) 

887 6 

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

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

Future Coal EGA (Unnamed – Plant A) 1,340 1,452 

Total Growth in Emissions from New EGUs 7,374 6,489 

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For this report, an independent review was conducted of proposed EGUs in Nevada and 

adjoining states. This review focused on coal-based EGUs and other coal-based industrial 

projects. The information presented in this section was obtained from public documents, 

including newspaper and magazine reports, public documents from companies involved with 

these projects, and public documents from regulatory agency files, including NDEP. Most of the 

public documents reviewed for this assessment were obtained via the Internet. 

 

3.1 FUTURE COAL EGU AND OTHER INDUSTRIAL COAL-PROJECTS 

3.1.1 Toquop Energy Project

 

The Toquop Energy Project (Toquop) is a proposed 750 MW coal-fired electric 

generating plant to be located in Lincoln County, Nevada, about 12 miles northwest of Mesquite. 

The project developer is Sithe Global Power, under the subsidiary Toquop Energy LLC. 

 

A draft air quality permit for Toquop was released by NDEP in December 2007 and a 

public hearing on the proposed permit was held February 7, 2008. However, as of May 2009, no 

final action has been taken by NDEP on the Toquop permit. The Regional Haze SIP needs to be

amended to clarify if Plant A is the Toquop plant and also specify the exact location of Plant A 

by NDEP/WRAP. 

 

Based on NDEP documents [Reference 4], Toquop emissions will be 1,614 tons per year 

(tpy) for nitrogen oxides (NOx) and 1,352 tpy for sulfur dioxide (SO2). 

 

Toquop is not specifically listed as an emission source in the 2018 emissions inventory 

contained in the draft Nevada Regional Haze SIP or the 2018 WRAP inventory. However, the 

SIP inventory does contain an unnamed generic coal-fired EGU (Plant A) that has emissions 

approximately equivalent to those listed in the draft Toquop permit. 

 

Toquop is located in southeastern Nevada, in relatively close proximity to the existing 

Reid Gardner Generating Station, operated by NV Energy. Because of the proximity of the two 

facilities, it is reasonable to expect that these two facilities would generally impact the same

Class I areas (i.e., Zion National Park, Bryce Canyon National Park, and Grand Canyon National 

Park). As such, the emission increases that would occur from construction and operation of

Toquop would tend to offset any benefits generated from BART-related emission reductions at 

Reid Gardner. 

 

3.1.2 Ely Energy Center

 

The Ely Energy Center (Ely) is a proposed coal-fired EGU planned for White Pine 

County, Nevada at a site about 30 miles north of Ely. The project developer is NV Energy, Inc. 

 

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A draft air quality permit for Ely was released by NDEP in October 2007 and a public 

hearing on the draft permit was held on January 9, 2008. However, no final action has been taken 

by NDEP on the Ely permit. 

 

Based on NDEP documents [Reference 5], project emissions at Ely will be 4,853 tpy for 

NOx and 4,628 tpy for SO2. 

 

Ely is not listed in the 2018 emissions inventory contained in the April 2009 draft Nevada 

Regional Haze SIP, nor is this source listed in the 2018 WRAP emissions inventory projections. 

In fact, if the Ely emissions were to be included, the total emissions increase assigned to future

EGUs in Nevada would be increased by about 65% for NOx and over 70% for SO2. 

 

However, on February 9, 2009, NV Energy announced that construction and development

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 MW natural gas-fired 

generating station (Higgins Generating Station) and would also pursue construction of a 500 

MW natural gas-fired unit at their Harry Allen Generating Station. It is unclear whether or not 

the additional 500 MW natural gas-fired unit at Harry Allen is represented in the 2018 Nevada 

emission inventory. The 2018 WRAP emission projections list future natural gas fired units at 

NV Power’s Chuck Lenzie Station, but no mention is made of additional natural gas-fired units 

at the Harry Allen Station. 

 

As of May 2009, the draft PSD permit and air permit application for the Ely Energy 

Center have not been withdrawn by NV Energy or terminated by NDEP. As such, these 

emissions still need to be part of Nevada’s SIP planning process. 

 

3.1.3 White Pine Energy Station

The White Pine Energy Station (White Pine) is a proposed coal-fired EGU planned for

White Pine County, Nevada at a site near McGill. The project developer is White Pine Energy

Associates LLC (LS Power). 

 

A draft air quality permit for Ely was released by NDEP in December 2006 and a public 

hearing was on the draft permit held on March 8, 2007. However, no final action has been taken 

by NDEP on the White Pine permit. 

 

Based on NDEP documents [Reference 7], project emissions at White Pine will be 4,812 

tpy for NOx and 6,071 tpy for SO2. 

 

White Pine is part of the 2018 emissions inventory contained in the April 2009 draft

Nevada Regional Haze SIP and the 2018 WRAP inventory. However, the SIP and WRAP 

inventory substantially underestimates White Pine’s emissions in comparison to the NDEP draft 

permit. SO2 emissions are underestimated in the SIP by about 1,700 tpy (4,356 tpy vs. 6,071 tpy)

and NOx emissions are underestimated by about 900 tpy (3,909 tpy vs. 4,356 tpy). 

 

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

the White Pine Energy Station has been postponed “indefinitely.” [Reference 8]. Furthermore, 

LS Power withdrew a pending application for the project before the Public Utilities Commission 

of Nevada and NDEP also cancelled a public hearing scheduled for March 25, 2009 related to 

the revised Statement of Basis covering White Pine’s carbon dioxide and greenhouse gas 

emissions. 

 

However, as of May 2009, the draft PSD permit and air permit application for the White 

Pine Power Project have not been withdrawn by LS Power or terminated by NDEP. As such, 

these emissions need to continue to be part of Nevada’s SIP planning process. 

3.1.4 TS Power Plant

 

The TS Power Plant (TS Plant) is a 200 MW coal-fired boiler at a site near Dunphy, NV. 

The project developer is Newmont Nevada Energy Investment LLC (owned by Newmont

Mining Corporation). The TS Plant supplies part of its electrical output to operate nearby mining 

operations owned by Newmont with the remainder of the power output going to the electrical 

grid. 

 

The TS Plant is currently operational and is covered by a Class I Air Quality Operating 

Permit (Permit No. AP4911-1349), issued by NDEP. 

 

 Based on the allowable emission limitation for the coal boiler [Reference 9], project emissions at 

TS were calculated by ARS to be 596 tpy for NOx and 845 tpy for SO2. The TS Plant operating 

permit limits annual NOx emissions, but does not contain an annualized limit for the SO2 

emission. The SO2 emission total was estimated by ARS using the short-term emissions limit 

(192.9 lb/hr) and 8,760 hours per year of operation. 

 

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

draft Nevada Regional Haze SIP. However, the SIP somewhat underestimates the TS Plant 

emissions in comparison to the allowable emissions from the Class I permit. SO2 emissions are 

underestimated in the SIP by about 175 tpy (670 tpy vs. 845 tpy) and NOx emissions are 

underestimated by about 100 tpy (3,909 tpy vs. 4,356 tpy). The correct permitted emissions for

this facility should be reflected in the Nevada regional haze SIP. 

 

3.1.5 Sevier Power (UT)

 

Sevier Power Company LLC (Sevier) has proposed a 250 MW (net) circulating fluidized 

bed coal-fired power plant in central Utah near Sigurd. [Reference 10] 

 

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

in October 2004. However, this permit has been appealed by the Sierra Club Utah Chapter and 

Sevier Citizens for Clean Air and Water. A hearing on these two permit appeals was held before 

the Utah Supreme 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 regarding a local Sevier County 

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