Re: NO2/NOx In-Stack-Ratio Documentation and Test Results for Pio Pico 

Shirley Rivera to: Steve Hill 05/11/2012 07:24 PM

Cc: Cleveland Holladay, Gerardo Rios, Roger Kohn

[Roger / Gerardo - FYI, per our discussion this afternoon. - S.]

============

Steve,

This email is a follow-up to our telephone conversation this morning among:

l Pio Pico team - Steve Hill, Dave Jenkins

l San Diego APCD (SDAPCD) - Steven Moore

l EPA Region 9 - Cleve Holladay, Self

SHORT VERSION: EPA requests an alternative modeling evaluation that uses the following in-stack

NO2/NOx ratio of 0.56 for Donovan Detention Center. 

DETAILS / DISCUSSION: With regards to our March 22 request (see below email), EPA currently has 

information responsive to both Items 1 and 2. EPA has reviewed Pio Pico's proposed in-stack NO2/NOx 

ratios used for the Pio Pico Energy Center turbines in the conduct of its air quality modeling analysis. 

SDAPCD has provided information to EPA Region 9, which includes the data we requested of Pio Pico, 

as well as describing (during our telephone conversation) the District's methodology for determining the 

recommended values of 0.24 and 0.13 for startup/commissioning and normal operations, respectively. 

For the 4 facilities listed in Item 2, we acknowledge that Pio Pico performed the full impacts analysis 

using the following in-stack NO2/NOx ratios for the 4 nearby sources:

Calpeak Border = 0.10

Larkspur 1 and 2 = 0.10 (for each)

Otay Mesa (Turbine 1, 2) = 0.05 (for each)

Donovan Detention Center = 0.10

- as well as for the fifth facility -

Pacific Recovery Landfill (engines) = 0.75 (for each)

(Please note: We did not request additional information for Pacific Recovery.)

As we discussed this morning, we will continue to proceed with our development of the air quality impacts 

analysis portion of our fact sheet, considering the information Pio Pico has provided regarding the 

in-stack NO2/NOx ratios. Meanwhile, as we also discussed this morning, EPA requests an alternative 

modeling evaluation that uses the following in-stack NO2/NOx ratios:

Calpeak Border = 0.10

Larkspur 1 and 2 = 0.10 (for each)

Otay Mesa (Turbine 1, 2) = 0.05 (for each)

Donovan Detention Center = 0.56

Pacific Recovery Landfill (engines) = 0.75 (for each)

Please note that the difference is specific only to the proposed Donovan Detention Center ratio, i.e., in 

addition to the evaluation provided at 0.10, we are requesting that 0.56 also be modeled. We base this 

request on our review of the information provided by the SDAPCD, i.e., the average of 7 source tests (i.e., 

2004-2006 and 2008-2011). 

The summary table below contains excerpts from an SDAPCD Excel worksheet for 2004-2009 available 

data. We have added the source test data for 2010 and 2011, based on additional information SDAPCD 

forwarded to us via email this morning. 
============

- Shirl

Week of May 7: Out of office - Mon (05/07), Wed (05/09)

Week of May 14: Out of office - Mon (05/14), Tentative Out Fri (05/18)

____________________________________________________________

Shirley F. Rivera

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov | Workspace #17112 

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

Cleveland Holladay Steve, As I agreed to do in the March 8, 2012... 03/22/2012 06:36:29 PM

From: Cleveland Holladay/R9/USEPA/US

To: Steve Hill <SHill@sierraresearch.com>

Cc: Shirley Rivera/R9/USEPA/US@EPA

Date: 03/22/2012 06:36 PM

Subject: NO2/NOx In-Stack-Ratio Documentation and Test Results for Pio Pico

Steve,

As I agreed to do in the March 8, 2012 meeting, I called Steve Moore of the San Diego Air Pollution 
Control District this afternoon about the NO2/NOx in-stack-ratio documentation that was provided to Pio

Pico by the district. Based on that call, I am requesting the following information which needs to be 

provided by the applicant for our administrative record for this project.

1: Pio Pico has selected an in-stack NO2/NOx ratio for its three combustion turbines as

follows: equal to 0.13 for normal operations and equal to 0.24 for startup operations. Pio

Pico stated that the ratios were derived from source test data for four natural-gas-fired

LM6000PC Sprint turbines (equipped with water injection, SCR, and oxidation catalysts)

and eleven natural-gas-fired GE Frame 5 turbines (with water injection but no other NOx

controls and no oxidation catalyst). EPA needs to confirm the proposed ratios for use in the

1-hour NO2 NAAQS air quality modeling.

Specific information regarding the four LM6000 PC Sprint turbines and eleven GE Frame 5 

turbines has not been provided. The applicant should provide the source test data that it 

has relied upon to justify the 0.13 and 0.24 ratios. This should include, at a minimum:

l source test results, 

l source test support information to confirm test conditions and equipment operations, 

and 

l the source test methodology.

The applicant should confirm if the source test data relied upon is a result of emissions 

compliance testing or a result of other circumstances (such as CEMs info which may have 

been used formally or informally to determine the ratios). Based on this information, the 

applicant should provide a discussion that demonstrates the representativeness and 

comparability of this information for its selection of the proposed ratios for normal and 

startup operations for the proposed project.

2: In addition, source test information (similar to the format requested above) for the

following six emission units (with their NO2/NOx ratios) (below):

Calpeak Border

Unit 1 0.1

Larkspur 1 and 2

Larkspur 1 0.1

Larkspur 2 0.1

Otay Mesa

Turbine 1 0.05

Turbine 2 0.05

Donovan Detention Center

Solar Turbine 0.10 

identified in the air quality modeling input files and the application (Table 4-27, p. PSD - 

4.47) should be provided for similar reasons. 

Thank you, 

Cleve Holladay
Phone 415-947-4140

U.S. EPA, Region 9, Air Quality Analysis Office (AIR-7) | 75 Hawthorne St., San Francisco, CA 94105