SRP files air emissions assessment
On July 1, 2011 SRP filed its first report with the Arizona Corporation Commission (ACC) in compliance with Condition 38 of the Santan Generating Station Expansion Project Certificate of Environmental Compatibility (CEC), issued by the ACC on May 1, 2001. Condition 38 requires SRP to perform an air emissions assessment of the plant every five years following commercial operation of the new units and to file a report with the ACC identifying any changes to the plant or its operation that will reduce emissions.
After conducting a comprehensive emissions assessment of Santan, SRP recommended to the ACC that no additional improvements be installed on the older units at this time because none of the available emissions controls are economically justified and the costs far outweigh the benefits. SRP retrofitted the older units with new emission control technologies in the early 2000s in coordination with the plant expansion. In addition, the new units constructed during the expansion project are still considered state-of-the-art technology.
ACC staff filed its report and recommended order on August 29, 2011. ACC staff concurred with SRP that current emission controls at Santan are appropriate and that no new controls are required at this time. ACC staff also concurred with SRP's request for guidance regarding the future implementation of Condition 38 and recommended changes to Condition 38 in conformance with SRP's request.
However, ACC staff took exception with SRP's analysis of externalities associated with the emission controls. ACC staff stated that SRP failed to appropriately consider the potential benefits of emission controls and requested that the ACC order SRP to consider externalities in future reviews. SRP filed a response to the ACC report, clarifying its externality analysis. SRP noted that is unlikely that any emission reductions resulting from the controls evaluated in SRP's filing would have any measurable effect on ambient air quality or any discernable ambient air quality benefit. Accordingly, SRP does not believe a more in depth analysis of externalities is warranted and would not be expected to change the conclusions of SRP's review.
The ACC commissioners are scheduled to consider SRP's air emissions assessment on October 11 and 12. At that time, the commissioners will determine whether any improvements should be required and will issue a decision to that effect.
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