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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
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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 1 - 12 LM 6000 turbines • Option 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.) • 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 & 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
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 1563.9 tons/yr to max of 448 tons/yr
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.
Conclusion (cont.) • Comments simply stating you don’t want plant built will be ignored