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GRIC Case Study Permit Review

This case study highlights the Gila River Indian Community's (GRIC) review of a proposed 600MW natural gas-fired power plant in Pinal County. Although GRIC lacks authority under Section 505, they actively engaged with Pinal County regarding the permit which required a detailed PSD review due to significant emissions of NOx and other pollutants. The study explains GRIC's concerns regarding air quality impacts and cultural preservation, the modeling conducted to assess pollutant effects, and ultimately how GRIC's comments led to improved emission controls at the facility.

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GRIC Case Study Permit Review

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  1. GRIC Case Study Permit Review Dan Blair, Compliance and Enforcement Mgr. Gila River Indian Community (GRIC) Department of Environmental Quality

  2. Background: Gila River Indian Community • Akimel O’odham (Pima) & Pii Pash (Maricopa) • Located in Maricopa & Pinal counties • Established in 1859 by Executive Order • 374,000 acres • Population 15,500 people (on- reservation)

  3. 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

  4. 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 turbines • Option 2 - 6 LM 6000 turbines and 2 GE FA turbines

  5. 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

  6. 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

  7. 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

  8. GRIC Permit Review (cont.)

  9. 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

  10. 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

  11. GRIC Permit Review (cont.) • Why GRIC concerned • Modeling indicated highest area of pollutant impact on eastern ridges of Sacaton Mountains within GRIC (NOx & PM10) • Hig- impact area near town of Sacaton • Permit proposals for additional power plants (18) in greater Phoenix area • Other Turbine plants proposing SCR for NOx control to 5 ppmvd

  12. GRIC Permit Review (cont.) • GRIC submitted comments (see Handout) concerning • High NOx emissions • Cultural concerns • Adverse 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

  13. GRIC Permit Review (cont.) • Total NOx emissions reduced from 1563.9 tons/yr to max of 448 tons/yr

  14. Conclusion Conclusion • When commenting on a permit, pick a pertinent issue to comment on • Emissions • MACT, BACT, LAER • Pipeline/power line issues • Cultural issues • Transport of fuels • Water availability, etc.

  15. Conclusion (cont.) • Comments simply stating you don’t want plant built will be ignored

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