The U.S. Environmental Protection Agency is taking final action to extend the compliance date for NOX emission limits, under the Best Available Retrofit Technology (BART) section of the Regional Haze Rule, for Units 1-3 at the Reid Gardner Generating Station (RGGS) by 18 months from January 2015, to June 2016.
EPA’s BART determination was promulgated in a Federal Implementation Plan (FIP) in August 2012, the agency said in a notice to be published in the Aug. 28 Federal Register. On March 26, EPA granted reconsideration of the compliance date and proposed to extend the compliance date for the NOX emission limits at Units 1-3 at RGGS.
In October 2012, NV Energy filed a petition to the EPA Administrator for reconsideration of the BART compliance date. On March 26, EPA granted the petition for reconsideration and also proposed to extend the BART compliance date for NOX for the affected units by the 18 months.
In a comment letter to EPA dated May 14, NV Energy provided additional information regarding an amendment to Senate Bill 123 introduced to the Nevada Legislature in April, under a plan known as NVision. NVision proposed to retire some of the coal-fired units owned by NV Energy on an accelerated schedule and to replace retired generation with energy from new natural gas-fired units and renewable sources. NVision would require early retirement of Units 1-3 at RGGS by the end of 2014, prior to the original compliance date in EPA’s August 2012 final rulemaking and the extended compliance date the federal agency proposed on March 26.
Because NV Energy must also file its plan to the Nevada Public Utilities Commission for review and approval, NV Energy said that the earliest date it would receive a decision on the plan would be in the first quarter of 2014. Given the current uncertainty regarding approval of NVision, NV Energy stated in its letter that it will continue to move forward on an expeditious schedule to comply with BART emission limits for NOX at RGGS by June 30, 2016.
Therefore, EPA’s action is still necessary despite NV Energy’s plans to retire Units 1-3 at RGGS. This final action requires that in the event these units continue operation and are not retired by the end of 2014, they must comply with BART emission limits by June 30, 2016, a date which is as expeditious as practicable and within five years of the final rule, EPA said.
In the Aug. 28 notice, EPA responds to various criticisms of the BART plan. For example, EPA said it disagrees with the comment that RGGS is operating without controls. The plant currently operates with SO2 and particulate matter controls, as well as older low-NOX burners with overfire air. Units 1-3 at RGGS are subject to BART based on their age, emissions of visibility-impairing pollutants, and their impact on visibility at Class I areas.
Reid Gardner Generating Station has four operating units. Units 1 and 2 are nearly identical and went into service in 1965 and 1968. A third similar unit (#3) was added in 1976. Each of these units produces 100 MW with Foster Wheeler boilers and General Electric turbine-generators. The plant’s largest generating unit (#4) is jointly owned by NV Energy and California Department of Water Resources. This 257-MW unit was commissioned in 1983.