Transcript Navajo Nation Interest`s in EPA Rulemakings Affecting EGU`s

Navajo Nation Interest’s In EPA
Rulemakings Affecting EGU’s
National Tribal Forum
May 22-24, 2012
Tulsa, Oklahoma
Anoop Sukumaran, Navajo Nation Environmental Protection Agency
Navajo Nation
-Natural resources
include oil, gas,
timber, coal, uranium,
hunting, fishing,
agriculture
The Nation’s most
valuable saleable
natural resource is its
coal reserves
-Land base
approximate size of
West Virginia;
Population > 250,000
Coal Fired EGU’s Surrounding Navajo Nation
NGS
FCPP
SJGS
EPA R9
• BART
(PENDING)
• NOx
• Mercury (Final)
• Coal Ash Rule
• Climate Change
• BART
(PROPOSED)
• NOx, PM
• Mercury (Final)
• Coal Ash Rule
• Climate Change
• BART
(FINALIZED)
• NOx
• Mercury (Final)
• Coal Ash Rule
• Climate Change
Navajo Nation
Comment Team
Navajo Nation
President
Navajo Nation
Vice President
NNEPA Executive
Director
Navajo Division of
Natural Resources
Air & Toxic
Department
Manager
Operating Permit
Program
Natural Resource
Attorney
Air Quality
Attorney
NN Attorney
General
Water Rights Unit
Attorney
Regional Haze Rule (RHR)
40 CFR Subpart §51.300-51.309
• The Clean Air Act requires (Best Available Retrofit
Technology) BART review when any source that
“emits any air pollutant which may reasonably be
anticipated to cause or contribute to any impairment
of visibility” in any 156 Federal Class I area
• There are sixteen (16) and eleven (11) Class I area
within 300 km (186 mi) radius of the Four Corners
Power Plant and Navajo Generating Station
• Predicted visibility impact with baseline emissions
exceeds 0.5 delta- deciview
Regional Haze Visibility Impact
Best 24-hr avg visibility
Worst 24-hr avg visibility
Timeline For Proposed Activities
2011
53 Years
2064
“Goal is to achieve
natural background
levels by 2064 (i.e., no
manmade visibility
impairment)”
Every 10 years beginning in 2018 the previous SIP/FIP must be updated to account for current visibility and progress made toward the
2064 goal
7
Federal Class 1 Areas Within NGS & FCPP
BART Five Factor Analysis
Cost of Compliance
Existing pollution
control technology at
the source
Energy and non-air
quality environmental
impacts of compliance
Remaining useful life
of the source
Degree of visibility
improvement which
may be anticipated
from the use of BART
Four Corners Power Plant
Pre- BART Operation
APS = 100% unit 1,2,3, Unit 4,5 : SCE 48 %, APS 15%,
PNM 13%, SRP 10%, EPE 7%, TEP 7%
Unit 4 &5
750MW per unit
Unit 3
280MW
Unit 1 &2
185MW
per unit
Four Corners Power Plant
Better Than BART Proposal
APS = 100% unit 1,2,3, Unit 4,5 : SCE 48 %, APS
48+15=63%, PNM 13%, SRP 10%, EPE 7%, TEP 7%
Unit 4 &5
750MW per unit
Unit 3
280MW
Unit 1 &2
185MW
per unit
Navajo Nation Position
BART for FCPP
• The Nation Generally Supports Alternative Emission
Control Strategy (AECS).
• The AECS will achieve greater visibility improvements
than October 2010 EPA BART FIP Proposal
• The AECS seems realistically achievable with a
phased approach
• EPA still must analyze the adverse economic impacts
on the Navajo Nation by closing units 1-3
• EPA must consider the cumulative effects of the
BART FIP for FCPP Regionally
Navajo Generating Station (NGS)
BART Decision Pending !!!!
U.S.BOR =24.3%, SRP = 21.7%, LADWP = 21.2% , APS = 14%, NPC = 11.3%, TEP = 7.5%
Unit 1, 2 and 3 = 750 MW each
NGS Studies
Navajo Nation
Phased Approach for NGS
• Allow the facilities to install the Advanced Combustion Controls (New
LNB/ SOFA) and meet the BART presumptive limit with respect to each
unit.
• Revisit the BART for NGS in 2017 and review whether the power plants
current emission control strategies will achieve the EPA 2064 goal and
reasonable progress.
• 2010- 2017 will help EPA, Facilities, NNEPA to review the following
issues
– Lease Renewal Negotiations.
– New regulations such as GHG, MACT (mercury) which will require
the facilities to come up with new control equipment's which will
further reduce NOx and PM ( BART pollutant).
– Ammonia Monitoring Plan between facilities, EPA , NNEPA , FLMs ,
and conduct more detail visibility modeling analysis .
– Explore other new pollution control equipment by 2017 and
upgrade older units.
San Juan Generating Station
BART-Nation Position
•
•
•
•
•
EPA R6 BART FIP
NMED Failed to
Submit RH SIP
SCR on all Four
Units
BART FIP will
have No Tribal
Implications
No Economic
Impacts
Analyzed
Compliance
timeline
increased from 3
to 5 years
•
•
•
•
NMED RH SIP
• SNCR on all Four
Units
• Meet Presumptive
BART Limits
• Visibility
Improvement
aligns with SIP
• Economic Impact
to NM ratepayers
analyzed
• SCR cost too high
compared to SNCR
Navajo Nation Position
EPA Consider NM RH SIP
EPA failed to conduct full five factor analysis
EPA analysis of no Tribal implications is not supported
Economic Impacts, Regional Cumulative Benefits
MERCURY
National Rule
V
/
S
BART
by EPA HQ
Regional Rule by
EPA R 9
ONE SIZE FITS ALL
Plant specific,
region specific
Deadline 3+1
years
5 years or more
2015
2016-2018
Cost for Hg for
NGS $330 million
Cost for NOx for
NGS $ 500 million
Economic Impact
analysis not
required
Five Factor
analysis
economic
analysis
No local data
considered
EPA considering
NREL study
$ 1 billion
EPA Response to Comments
Final Utility MACT-NGS
• Because of concerns raised by several tribes, and in
order to help us better understand their concerns,
we also participated in a face-to-face meeting with
tribes in Arizona who were concerned about the
potential impact of this rule on their income and
water rights.
• EPA recognizes the significance of NGS to the Central
Arizona Project and has been consulting with
affected Indian tribes and working closely with other
federal agencies, including the Department of the
Interior, on these issues.
Gina McCarthy, Assistant Administrator for EPA Office of Air and Radiation
visited NGS and met with Navajo Nation President Ben Shelly
on January 29, 2012
EPA
HQ
Mercury,
Greenhouse
Gases
G2G
Coal Ash Rule,
Ozone NAAQS
Power
Plants&
Coal
Mines
Lease
Navajo
Nation
G2G
EPA R 9
EPA R 6
G2G
DOI
BART, CAP, EIS,
Leases
USBR,
NPS, BIA
BART FCPP, NGS, SJGS
EPA Policy