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

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)

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 LM 6000 turbines  Option LM 6000 turbines and 2 GE FA turbines

GRIC Permit Review (cont.)  Facility major PSD source of NOx and CO > 250tpy  PM 10 and VOC < 250tons/yr but exceeds significance level and requires PSD review

GRIC Permit Review (cont.)  Pinal County in attainment for NOx, SOx, PM 10 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, PM 10 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) NOxCOPM 10 SOxVOC 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)

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 concerned  Modeling indicated highest area of pollutant impact on eastern ridges of Sacaton Mountains within GRIC (NOx & PM 10 )  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

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

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

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.

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