1-18 Air

RESPONSE:

The Project’s impact to air quality in the area surrounding the Facility is detailed in Section 6.1 of the EFSB application.  The Project will require a Major Source Air Permit from RIDEM prior to its construction.  RIDEM will require the Project to comply with all applicable state and federal air pollution control regulations, implement Best Available Control Technology and the Lowest Achievable Emission Rate for applicable pollutants, fully offset its NOX and VOC emissions, and complete an air quality impact assessment and health risk assessment prior to approval.  The Major Source Air Permit application process will ensure that the Project’s impacts to air quality in the area surrounding the Facility have been minimized to the greatest extent that is technologically feasible for such a source.                    

Section 6.1.5 details the air quality impact assessment completed for the Project.  This assessment concluded that the maximum predicted criteria pollutant air quality impacts resulting from Facility operation, when combined with existing background concentrations, and the maximum impact concentrations from other nearby sources, will not exceed any of the National Ambient Air Quality Standards (“NAAQS”) at any location at or beyond the property line of the Facility.  The NAAQS, which have been established by the EPA and adopted by RIDEM, are ambient concentration which have been determined through health studies to be protective of human health and welfare, including the most vulnerable of the population, with a margin of safety. 

The Project air quality impact assessment also concluded that the maximum predicted air toxics air quality impacts resulting from Facility operation will not cause an exceedance of a RIDEM Acceptable Ambient Level (“AAL”) at any location at or beyond the property line of the Facility.  The AALs have been established by RIDEM through health studies to be protective of human health, with a margin of safety.  Invenergy has also submitted a Project Health Risk Assessment to RIDEM which demonstrates that all of the applicable health risk standards established by RIDEM to protect the local residents will be met during Facility operation.

As described in Section 6.1 of the EFSB application, and with the completion of each of the assessments required by RIDEM for a Major Source Permit Application, Invenergy has demonstrated that the Project’s air quality impacts at all locations at or beyond the property line will comply with all applicable health based air quality standards during Facility operation.

DATE:

March 31, 2016