Pollution, Parks, Public Health and the Navajo Generating Station

On 10/22/2013, Sandy Bahr, local Chapter Director of the Sierra Club, gave an informative and engaging presentation on Pollution, Parks, Public Health and the Navajo Generating Station.

The Environmental Protection Agency (EPA) will be holding public hearings on Navajo Generating Station (NGS) in the middle of November. See the flyer below for details to attend or get involved:

Open issues
  1. Clearly quantifying the health and environmental benefits and impacts
    a. Action: # or % human life years in units of [NOx per acre] would be a useful metric.
    b. Reference: Clean Air Task Force estimated $127M in health impacts from NGS.
    c. Reference: The Grand Canyon generates $687M / year
  2. Clearly understanding finance options and rate impacts to different stakeholders
    a. *See "Cost of Pollution Controls for NGS" section below for initial stakeholder impact assessments.

Common Misconceptions Debunked
This is not an “anti-coal” issue. The issue is to support the health of the local people of the state of Arizona, preservation of natural resources, and support for USA leadership in the #1 international political issue – climate change. The barren deserts of Arizona used to be one of the best places for dirty power in the country, but global political interests have changed. Now, the perception is that Arizona is the best place in the country – and one of the best on earth – for clean power. Financing is not the limiting factor; by comparison Maricopa County used a local sales tax to raise over $200M (~70% of the total costs) to build Bank One Ballpark a.k.a. Chase Field in the 1990’s. So, to anyone reading this -- help Arizona stop resisting change, and embrace the opportunity to be the #1 that it should be. As part of America’s growing Wild West, Arizona has the opportunity to be a global leader and role model for developing nations with its excellent infrastructure. Dismiss the fear and hate-mongering, and give  people a reason to be proud live here.

AZ has 6 coal-fired power plants (Navajo is largest)

5 /6 of AZ’s coal plants are subject to Regional Haze Actions – Apache, Cholla, Coronado, H Wilson Sundt, Navajo. The first three have Federal Implementation Plans (FIP) under development by the EPA. Navajo has its own FIP because it’s on tribal land.

On Haze – a “Deciview” is the measurement of haze, includes NOx. 1 unit is a visible difference to the human eye.

EPA’s Regional Haze Rule under The Clean Air Act requires EPA … to take into consideration the costs of compliance, the energy and air quality environmental impacts of compliance, any existing pollution control technology in use at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.  Smelters and cement plants are also included. This provision applies to “Class 1 areas.” i.e. national parks and wilderness areas.

Navajo (NGS) is the single largest source of CO2 emissions in AZ
  • 3 x 750 MW units = 2,250MW total.
  • 20k tons of NOx yearly
  • 16M tons CO2 yearly
    Sox issues were previously addressed
    Note: based on economic activity, lifecycle GHG reductions from retrofitting would be positive within the first year.

NGS Ownership
  • 24% - US Bureau of Reclamation
  • 22% - SRP (operators)
  • 21% - LADWP (looking to sell and get out)
  • 14% - APS
  • 11% - NVE (looking to sell and get out)
  • 8% - TEP

EPA’s BART Proposal (Best Available Retrofit Technology)
  • Plant-wide emission limit for NOx of 0.055 lb/MMBtu by 2018
  •  Achieved with Selective Catalytic Reduction (SCR) – will reduce at least 80% of NOx pollution
EPA Proposed Alternatives (there’s 3)
  •  Sierra Club supports the EPA 5-year plan

Cost of Pollution Controls for NGS
  •  Installing SCR will likely result in 0.02 to 0.06 c/kWh retail rate increase or 0.2% to 0.6% increase in electric rates
  • NGS supplies 92% electricity for the Central Arizona Project (CAP)
  • Costs for CAP are higher, .39 to .48 c/kWh
    • Increase water costs to agriculture and tribes 13 – 16%
    • Increase water costs to munis and industrial by 5-7%

Other Issues for NGS
  • Maximum Achievable Control Technology (MACT) for Mercury Pollution
  • Coal Combustion Waste Rule
  • GHG/CO2 Pollution Rule
  • Kayenta Mine
    • Navajo & Hopi tribes receive a royalty, and employ ~500 / 300k people

Comment deadline January 6, 2014
You May Submit Comments on the Proposed Rulemaking on NGS
By Electronic Mail to: r9ngsbart@epa.gov
Or to the electronic docket for the proposed rulemaking

Anita Lee (AIR-2)
75 Hawthorne St
San Francisco, CA 94105

Thanks again to
Sandy Bahr
Chapter Director
Sierra Club – Grand Canyon Chapter
202 E. McDowell Rd., Suite 277
Phoenix, AZ  85004

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