GRIC Case Study GRIC Case Study Permit Review Permit Review

Dan Blair, Compliance and Enforcement Mgr.

Gila River Indian Community (GRIC)

Department of Environmental Quality

Background: Gila River Background: Gila River Indian CommunityIndian Community

Akimel O’odham (Pima) & Pii Pash Akimel O’odham (Pima) & Pii Pash (Maricopa)(Maricopa)

Located in Maricopa & Pinal countiesLocated in Maricopa & Pinal counties Established in 1859 by Executive Established in 1859 by Executive

OrderOrder 374,000 acres374,000 acres Population 15,500 people Population 15,500 people (on- (on-

reservation)reservation)

GRIC Permit Review

Received Notice of Proposed Power Plant from Pinal County (2001)

GRIC does not currently have authority under Section 505 (Courtesy Notice)

Public Notice Contains General Information of Proposed Project (see handout “Public Notices”)

GRIC contacted Pinal County AQCD for complete copy of Permit Application

GRIC Permit Review (cont.)

Received Proposed Permit Application from Pinal County (dated 2000)

600MW Natural Gas Fired Power Plant (peaking )

Simple Cycle Turbines Option 1 - 12 LM 6000 turbinesOption 2 - 6 LM 6000 turbines and 2 GE FA

turbines

GRIC Permit Review (cont.)

Facility major PSD source of NOx and CO > 250tpy

PM10 and VOC < 250tons/yr but exceeds significance level and requires PSD review

GRIC Permit Review (cont.)

Pinal County in attainment for NOx, SOx, PM10 and VOCs

Pinal County AQCD is agency responsible for permitting facility

Facility must obtain PSD Permit Title V Operating Permit

and comply with Title IV Acid Rain requirements

GRIC Permit Review (cont.)

Title V operating permit required because NOx, CO, PM10 and VOCs > 100tpy

Facility also subject to Title IV, Acid Rain requirements due to > 25 MW capacity

GRIC Permit Review (cont.)

Sundance Energy (Proposed) Annual Emissions

12 GE LM 6000 SPRINT Turbines (Permit App)

NOx CO PM10 SOx VOC

Annual total tons/yr

(12 Units)

Annual total tons/yr

(12 Units)

Annual total tons/yr

(12 Units)

Annual total tons/yr

(12 Units)

Annual total tons/yr

(12 Units)

1563.9 2839.2 195.0 35.1 167.7

GRIC Permit Review (cont.)

Permitee proposed in application that SPRINT atomized water spray system increased

efficiency and Reduced emissions to level of Best Available Control

Technology (BACT) or 25ppmvd

Annual potential emissions based on 6500 hours/year at 100% load

HAPs emissions calculated < major source thresholds

GRIC Permit Review (cont.) Emissions modeled to determine impacts on

Visibility Soils Vegetation

in two Class I areas within 100 km Superstition Wilderness Area (55km) and Saguaro West National Park (75km)

PSD Class II increment analysis for Nox conducted Ambient Air Impacts below ambient air quality

standards and PSD Class II significant levels for all pollutants

GRIC Permit Review (cont.)

Why GRIC concernedModeling indicated highest area of pollutant impact on

eastern ridges of Sacaton Mountains within GRIC (NOx & PM10)

Hig- impact area near town of SacatonPermit proposals for additional power plants (18) in

greater Phoenix areaOther Turbine plants proposing SCR for NOx control

to 5 ppmvd

GRIC Permit Review (cont.)

GRIC submitted comments (see Handout) concerning High NOx emissions Cultural concernsAdverse air quality impacts

Pinal County reevaluated BACT analysis in response to GRIC comments, required facility to install SCR, reducing NOx emissions from proposed 25 ppmvd to 5.0 ppmvd

GRIC Permit Review (cont.)

Total NOx emissions reduced from 1563.9 tons/yr to max of 448 tons/yr

Conclusion

Conclusion When commenting on a permit, pick a

pertinent issue to comment onEmissionsMACT, BACT, LAERPipeline/power line issuesCultural issuesTransport of fuelsWater availability, etc.

Conclusion (cont.)

Comments simply stating you don’t want plant built will be ignored