Application to the U.S. EPA for a

Prevention of Significant 

Deterioration Permit 

Pio Pico Energy Center 

San Diego County, California 

prepared for:

Pio Pico Energy Center, LLC

April 2011

prepared by: 

Sierra Research, Inc. 

1801 J Street 

Sacramento, California 95811 

(916) 444-6666
DRAFT REPORT 

Application to the U.S. EPA for a 

Prevention of Significant 

Deterioration Permit 

Pio Pico Energy Center 

San Diego County, California

prepared for: 

Pio Pico Energy Center, LLC 

April 2011 

Principal author: 

Steve Hill 

Sierra Research, Inc. 

1801 J Street 

Sacramento, CA 95811 

(916) 444-6666 
-iApplication to the U.S. EPA for a 

Prevention of Significant 

Deterioration Permit 

Pio Pico Energy Center 

San Diego County, California

Table of Contents 

Page 

1. Introduction ................................................................................................................... 1

2. AFC Sections Incorporated into the PSD Permit Application ...................................... 4

3. Class I Area Impact Analysis ........................................................................................ 5

4. Class II Visibility Impairment Analysis ....................................................................... 7

4.1 Methodology ......................................................................................................... 7

4.2 Results ................................................................................................................. 10

5. Impacts on Soils and Vegetation ................................................................................. 13

6. Growth-Inducing Impacts ........................................................................................... 14

7. Demonstration of Compliance with NAAQS ............................................................. 15

7.1 Compliance with the Federal 1-Hour NO2 Standard ........................................... 15

7.2 Compliance with the Federal 24-hour PM2.5 Standard ........................................ 24
-iiList of Figures 

Figure Page 

Figure 7-1 NOx Stationary Sources in Near Vicinity (within 10 km) of PPEC ...............20

Figure 7-2 NOx Stationary Sources in Vicinity (within 50 km) of PPEC ........................21

Figure 7-3 PM2.5 Stationary Sources in Near Vicinity (within 10 km) of PPEC ..............26

Figure 7-4 PM2.5 Stationary Sources in Vicinity (within 50 km) of PPEC ......................27
-iii- 

 List of Tables 

Table Page 

Table 1-1 PSD Applicability ...............................................................................................2

Table 2-1 AFC Sections Incorporated into the PSD Permit Application ...........................4

Table 3-1 Class I Air Quality Impact Screening Analysis ..................................................6

Table 4-1 Visibility Parameter Significance Thresholds ....................................................9

Table 4-2 FLM Class II Areas Within 50 km of PPEC ....................................................10

Table 4-3 PPEC Impacts on Visibility in Cleveland National Forest (Worst Case) ........11

Table 4-4 PPEC Impacts on Visibility in Cabrillo National Monument (Worst 

Case) ..................................................................................................................................12

Table 5-1 Project Maximum Concentrations and EPA Guidance Levels .........................13

Table 7-1 Identification of Nearby Sources ......................................................................29
-1- 

1. INTRODUCTION 

In this Application for a Prevention of Significant Deterioration (PSD) permit, Pio Pico 

Energy Center, LLC (PPEC LLC or “Applicant”) is seeking approval from the U.S. 

Environmental Protection Agency (EPA) to construct and operate a power generation 

facility, the Pio Pico Energy Center (PPEC), within the County of San Diego. PPEC 

LLC seeks EPA approval in order to satisfy an obligation to supply electrical capacity 

and energy to San Diego Gas & Electric (SDG&E) under a 20-year Power Purchase 

Agreement (PPA). 

PPEC is a proposed simple-cycle power generation project that consists of three General 

Electric (GE) LMS100 natural gas-fired combustion turbine generators (CTGs). The 

total net generating capacity would be 300 megawatts (MW), with each CTG capable of 

generating 100MW. The proposed plant will be owned and operated by PPEC LLC. The 

electricity generated by this project would be in support of a contract with SDG&E. 

The generating facility will include three GE LMS100 natural gas-fired combustion 

turbine generators (CTGs), each equipped with water injection to the combustors for 

reducing production of oxides of nitrogen (NOx), a selective catalytic reduction (SCR) 

system with 19 percent aqueous ammonia (NH3) injection to further reduce NOx 

emissions, and an oxidation catalyst to reduce carbon monoxide (CO) emissions. The 

total net generating capacity would be approximately 300 MW. The new emitting units 

will be installed on a 9.9 acre parcel in the southeast quadrant of the intersection of Alta 

Road and Calzada De La Fuente Road, adjacent to the Otay Mesa Energy Center. The 

Project will be a new major source under the federal Prevention of Significant 

Deterioration (PSD) program because it will have the potential to emit more than 100,000 

TPY of greenhouse gases (GHGs), a federally regulated pollutant, and construction will 

commence after July 1, 2011. 
-2- 

Table 1-1 

PSD Applicability 

Pollutant

Major 

Source 

Thresholda

(TPY) 

PSD 

Significant 

Emission 

Thresholdb

(TPY)

PPEC 

Emissionsc

(TPY)

Major 

Source?

Significant 

Emissions?

Subject to 

PSD? 

SO2 250 40 4.1 No No No 

PM10 250 15 37.2 No Yes Yes 

PM2.5 250 10 37.2 No Yes Yes 

NOx 250 40 70.4 No Yes Yes 

VOC 250 40 20.7e No No No 

CO 250 100 96.4 No No No 

Lead 250 0.6 0.0 No No No 

GHGs 100,000d 75,000d 685,000 Yes Yes Yes 

a

 40 CFR 52.21(b)(1) 

b

 40 CFR 52.21(b)(23) 

c

 AFC Table 5.2-31 

d

 40 CFR 52.21(b)(49) 

e

 AFC Table 5.2-35 

Portions of the Application for Certification (AFC) submitted to the California Energy 

Commission and the San Diego Air Pollution Control District are also relevant to EPA’s 

PSD review, and are incorporated by reference. The relevant sections, and the portions of 

EPA’s review that they address, are listed in Section 2. 

USEPA’s New Source Review Workshop Manual, Prevention of Significant Deterioration 

and Nonattainment Area Permitting states the following: 

Although each applicant for a PSD permit must perform an additional impacts 

analysis, the depth of the analysis generally will depend on existing air quality, 

the quantity of emissions, and the sensitivity of local soils, vegetation, and 

visibility in the source's impact area.*

These topic areas are addressed in the various AFC sections incorporated into this PSD 

permit application. 

The additional impacts analysis required by federal regulation†

 is also contained in this 

application report. 

 

* Ibid, page D.1. 

† Ibid. 
-3- 

The remaining sections of this permit application are as follows: 

 Section 3 presents the Class I Impact Analysis. 

 Section 4 presents the Class II Visibility Impairment Analysis. 

 Section 5 describes impacts on soils and vegetation. 

 Section 6 describes the potential for growth-inducing impacts 

 Section 7 describes the methodology for demonstrating compliance with 1-hour 

NO2 and 24-hour PM2.5 ambient air quality standards, and presents the list of 

nearby sources to be included in cumulative impact modeling. 

 Attachment 1 comprises relevant sections of the Application for Certification 

(AFC), submitted on February 9, 2011 to the California Energy Commission. 

 Attachment 2 is a subsequent addendum to the AFC submitted on March 8, 2011. 
-4- 

2. AFC SECTIONS INCORPORATED INTO THE PSD PERMIT 

APPLICATION 

Table 2-1 

AFC Sections Incorporated into the PSD Permit Application 

AFC Section PSD Requirement

1.0 Executive Summary Applicant Information, Project Location 

2.0 Project Objectives Project Description 

3.0 Facility Description Project Description 

5.1 Introduction Project Description 

5.2 Air Quality 

Emissions Estimates, Air Quality Data, 

Air Quality Impact Analysis, 

Compliance with Other Regulations 

5.6 Biological Resources Soils and Vegetation, Endangered 

Species 

5.9 Land Use Soils and Vegetation 

5.10 Socioeconomics Growth-inducing Impacts 

5.16 Public Health Additional Information 

Appendix G—Air Quality 

Emission Estimates, Best Available 

Control Technology (BACT) Analysis, 

Air Quality Impact Analysis 

Appendix J—Biological 

Resources 

Soils and Vegetation, Endangered 

Species 

Appendix M—Land Use Soils and Vegetation 

Appendix P—Public Health Additional Information 
-5- 

3. CLASS I AREA IMPACT ANALYSIS 

Class I areas are areas of special national or regional natural, scenic, recreational, or 

historic value for which the PSD regulations provide special protection. If a proposed 

major source or major modification may affect a Class I area, the federal PSD regulations 

require the reviewing authority to provide written notification of any such proposed 

source to the Federal Land Managers (FLM) (and the USDI and USDA officials 

delegated permit review responsibility). The meaning of the term “may affect” is 

interpreted by EPA policy to include all major sources or major modifications which 

propose to locate within 100 kilometers (km) of a Class I area. 

The two nearest Class I areas are listed below, with only one being within 100 km of the 

project site. 

 Agua Tibia Wilderness (91 km) 

 San Jacinto Wilderness (122 km) 

The impact analysis presented below is different than the analysis proposed in the 

modeling protocol submitted for this project (see Appendix G-8 of the AFC). The 

guidance that forms the basis for the analysis below is more recent than the guidance 

upon which the protocol was based, and therefore better reflects current standards of 

review. 

The Federal Land Managers’ Air Quality Related Values (AQRV) Work Group (FLAG) 

has published guidance for a screening approach to determine whether a more refined 

Class I Air Quality Impact Analysis is required.*

 This screening approach, which applies 

to projects located more than 50 km from a Class I area, requires adding all of the 

visibility-related emissions (SO2, NOx, PM10, and sulfuric acid mist) from a project (in 

units of tons per year)†

 and dividing the sum by the distance between the project and the 

Class I area. If the result is less than 10, the project is presumed to have no adverse 

impact. 

Table 3-1 shows that the project’s emissions are well below the FLAG screening criteria. 

As indicated previously, all Class I areas are more than 50 km from the project site. No 

further Class I impact analysis is required. 

 

*

 U.S Forest Service et. al., “Federal Land Managers’ Air Quality Related Values Work Group (FLAG), 

Phase I Report—Revised (2010),” October 2010, p. 18 

†

 Emissions (in tons per year) are equal to the maximum daily emissions (lb/day) * 365 days/2000 lb/ton. 
-6- 

Table 3-1 

Class I Air Quality Impact Screening Analysis 

Pollutant

PPEC Emissionsa

(max 24-hours, 

lb/day)

PPEC Emissionsb

(max 24-hours, 

TPY)

Q/D 

Screening 

Thresholdc

Class I 

Analysis 

Required? 

SO2 136.8 25.0 -- -- 

PM10 411.8 75.2 -- -- 

NOx 864.3 157.7 -- -- 

Sulfuric 

Acid Mist 0 0 -- -- 

Total -- 257.9 -- -- 

Distance, 

km -- 91 -- -- 

Q/D -- 2.8 10 NO a

 AFC Table 5.2-20 

b TPY = max daily emissions (lb/day) *365/2000

c

 U.S Forest Service et. al., “Federal Land Managers’ Air Quality Related Values Work Group 

(FLAG), Phase I Report—Revised (2010),” October 2010, p. 18-19 
-7- 

4. CLASS II VISIBILITY IMPAIRMENT ANALYSIS 

The Class II Visibility Impairment Analysis is distinct from the Class I visibility analysis. 

The goal of the analysis is to determine the degree to which the PSD project will impair 

visibility in sensitive areas such as state parks, wilderness areas, scenic sites, and 

overlooks. 

As proposed in the Modeling Protocol for this project (see AFC Appendix G-8), a 

Class II Visibility Impairment Analysis was performed for this project; however, the 

methodology proposed in the modeling protocol was updated to reflect the procedure 

recently recommended by the Federal Land Managers’ Air Quality Related Values Work 

Group (FLAG).* The methodology and the results are presented below. 

4.1 Methodology 

In general, the Class II Visibility Analysis methodology follows the methodology for a 

Class I Visibility Analysis. The procedure is divided into two parts, reflecting very 

different procedures for near-field analysis (where plumes or layers are compared against 

a viewing background) and far-field analysis (where distant plumes affect the general 

appearance of a scene. 

4.1.1 Distant/multi-source visibility impacts 

 

The first step in evaluating distant visibility impacts is an initial screening step. This step 

is identical to the Class I screening analysis presented in Section 3. If the ratio Q/D of 

emissions to distance is less than 10 when D = 50 km, then no further analysis is required 

for receptors beyond this distance. 

4.1.2 Near-field visibility impairment (plume impact) 

In this part of the analysis, the potential for the project’s plume to affect visibility in 

Class II areas managed by federal land managers (FLM Class II areas) within 50 km of 

the project is evaluated. If there are no FLM Class II areas within the study area, then the 

screening procedure is complete; otherwise, a Visibility Screening Analysis must be 

conducted. 

 

*

 U.S Forest Service et. al., “Federal Land Managers’ Air Quality Related Values Work Group (FLAG), 

Phase I Report—Revised (2010),” October 2010, p. 18-53. 
-8- 

4.1.2.1 Visibility Screening Analysis 

 

Screening Level 1 

The Level 1 visibility screening analysis is a series of conservative calculations designed 

to identify those emission sources that have little potential of adversely affecting 

visibility. The VISCREEN model is used in the Level 1 analysis to model visibility 

impacts for observers located at each sensitive Class II site for which the FLM screening 

value is exceeded. Calculated values relating source emissions to visibility impacts are 

compared to a standardized screening value. Those sources with calculated values 

greater than the screening criteria are judged to have potential visibility impairments. If 

potential visibility impairments are identified, then the Level 2 analysis is undertaken. 

There are two different types of visibility impacts that may be considered, based on 

visibility impairment inside or outside the park. The first type is the potential impairment 

of vistas inside the park. For this, the screening analysis assesses the project’s potential 

to impact the view of one part of the park as seen by an observer elsewhere in the park. 

The second type of visibility impact is the potential impairment of vistas outside the park. 

This screening analysis also assesses the project’s potential to impact views of the 

surrounding area as seen by an observer within the park. Protection of vistas outside of 

Class I areas is not automatic, and protection of vistas outside of Class II areas is 

uncommon. 

The relevant visibility parameters are “apparent contrast” and “delta E,” which can be 

computed by the screening visibility model VISCREEN. The significance thresholds for 

these two visibility parameters, used as significance criteria in the Class II screening 

analysis, are the Class I area thresholds (i.e., 0.05 and 2.00 for apparent contrast and 

delta E, respectively) increased by the ratio of the PSD Class II PM10 increment to the 

PSD Class I PM10 increment (i.e., 30 μg/m3

 divided by 8 μg/m3). As shown in Table 4-1, 

the Class II significance thresholds are an apparent contrast of 0.19 and a delta E of 7.50.*

 

*

 The Class I threshold is the level at which the FLM is likely not to object to the issuance of the PSD 

permit based on near field visibility impacts to a Class I area. The Class II threshold has been extrapolated 

from the Class I thresholds using the ratio of Class II PM10 increment to Class I PM10 increment. A lessstringent threshold for triggering the much more complex Level 2 analysis is justified because (a) there is a 

distinction between the degrees of protection applicable to Class I and Class II areas; (b) Class I areas can 

be protected through AQRV analysis, whereas protection of Class II areas can be achieved using BACT 

requirements; (c) the results of the visibility analysis are for informational, not regulatory, purposes. 
-9- 

Table 4-1 

Visibility Parameter Significance Thresholds 

Visibility 

Parameter or 

Criteria 

Pollutant

Averaging 

Period/Units

Federal

Class I 

Area PSD 

Ambient Air 

Increment

Federal

Class II 

Area PSD 

Ambient Air 

Increment

Federal 

Class I 

Area 

Significance 

Threshold

Federal 

Class II 

Area 

Significance 

Threshold

Apparent 

Contrast 1 hour a/(-) NA NA 0.05b 0.19c

Delta E 1 hour a/(-) NA NA 2.00b 7.50c

PM10

24 hours/ 

(μg/m3

) 8d 30d Not used Not used

NA = not applicable 

a

 Shortest-period emission rates of visibility-related criteria pollutants used in VISCREEN model. U.S. 

EPA, Workbook for Plume Visual Impact Screening and Analysis (Revised), EPA-454/R-92-023, 

October 1992. b U.S Forest Service et. al., “Federal Land Managers’ Air Quality Related Values Work Group (FLAG), 

Phase I Report—Revised (2010),” October 2010, p. 21. c

 Estimated by multiplying the federal Class I area significance threshold for the visibility parameter by 

the ratio of the 24-hr average federal Class II and Class I area PM10 PSD increments. d

 These maximum allowable increases are found in the Code of Federal Regulations, Title 40, Part 52, 

Section 52.21(c), Ambient air increments. 

Screening Level 2 

The Level 2 screening procedure is similar to the Level 1 analysis in that its purpose is to 

estimate impacts during worst-case meteorological conditions; however, more specific 

information regarding the source, topography, regional visual range, and meteorological 

conditions is assumed to be available. The analysis may be performed with the aid of 

hand calculations, reference tables and figures, VISCREEN, or a computer-based 

visibility model called “PLUVUE II.” 

If the Levels 1 and 2 screening analyses indicate the possibility of visibility impairment, a 

still more detailed analysis is undertaken in Level 3. 

Level 3 Analysis 

The Level 3 analysis, no longer a screening analysis, uses the plume visibility model and 

meteorological and other regional data to provide an accurate description of the 

magnitude and frequency of occurrence of impact. The procedures for utilizing the 

plume visibility model are described in the document User’s Manual for the Plume 

Visibility Model, which is available from EPA. 
-10- 

4.2 Results 

4.2.1 Distant/multi-source visibility impacts 

As shown in Table 3-1, Q = 257.9 TPY. At 50 km, Q/D = 5.2. Because Q/D is less than 

10 for all receptors 50 km away or further, there are no receptors for which distant/multisource visibility impacts must be evaluated. No further analysis of distant receptors is 

required. 

4.2.2 Near-field visibility impairment (plume impact) 

The FLM Class II areas listed in Table 4-2 were identified as being wholly or partially 

located within a 50 km radius of the project, with the minimum distance to the project as 

indicated. A Level 1 visibility screening analysis was conducted for each of these areas. 

 

Table 4-2 

FLM Class II Areas Within 50 km of PPEC 

Site 

Distance from 

Project (km) 

FLM Screening 

Value (tons/km) 

Cleveland National Forest 23 11.2 

Cabrillo National Monument 33 7.8 

Screening Level 1 

The methodology used for these analyses was described above. Results of these analyses, 

using absolute worst-case project emissions, are summarized in Tables 4-3 and 4-4. 

These tables show that, under absolute worst-case project emissions and dispersion 

conditions, the project’s potential visibility impacts inside Class II areas are below the 

Class I thresholds for significance. Impacts on views outside the Class II areas are below 

the Class II thresholds for significance, but above the Class I thresholds. Because all 

project visibility impacts are below the Class II thresholds, and because the vistas outside 

the parks are unlikely to be subject to the stringent visibility protection standards 

applicable to Class I areas, no further analysis is required. 
-11- 

Table 4-3 

PPEC Impacts on Visibility in Cleveland National Forest (Worst Case) 

 Background Ozone:0.04 ppm Emission Density Diameter 

 Background Visual Range: 95 kmb Particulate: 2.08 g/s 2.5 1 

 Source-Observer Distance: 23 km NOx: 4.54 g/s 

 Min. Source-Class II Distance: 23 km Primary NO2 0.00 g/s 

 Max. Source-Class II Distance: 50 km Soot 0.00 g/s 2.0 1 

 Stability: 6 Sulfate 0.00 g/s 1.5 4 

 Wind Speed: 1.00 m/s 

Maximum Visual Impacts INSIDE Class II Area a

 Delta E Contrast 

Background Theta Azi Dist Alpha Criterion Plume Criterion Plume 

Sky 10 145 32.8 24 7.5 1.26 0.19 -0.011 

Sky 140 145 32.8 24 7.5 0.902 0.19 -0.006 

Terrain 10 159 50 9 7.5 1.184 0.19 0.014 

Terrain 140 159 50 9 7.5 0.528 0.19 0.015 

Maximum Visual Impacts OUTSIDE Class II Area a 

 Delta E Contrast 

Background Theta Azi Dist Alpha Criterion Plume Criterion Plume 

Sky 10 1 1 168 7.5 2.376 0.19 -0.04 

Sky 140 1 1 168 7.5 1.896 0.19 -0.014 

Terrain 10 1 1 168 7.5 5.445 0.19 0.069 

Terrain 140 1 1 168 7.5 2.438 0.19 0.077 

a Impacts based on 4 startups and 4 shutdowns of each turbine in a single day, remainder of day at peak 

operation. b National Park Service, Visibility Monitoring Data, 

http://www.nature.nps.gov/air/monitoring/vismon.cfm#data (accessed 3/17/2011) 
-12- 

Table 4-4 

PPEC Impacts on Visibility in Cabrillo National Monument (Worst Case) 

 Background Ozone:0.04 ppm Emission Density Diameter 

 Background Visual Range: 95 kmb Particulate: 2.08 g/s 2.5 1 

 Source-Observer Distance: 23 km NOx: 4.54 g/s 

 Min. Source-Class II Distance: 23 km Primary NO2 0.00 g/s 

 Max. Source-Class II Distance: 50 km Soot 0.00 g/s 2.0 1 

 Stability: 6 Sulfate 0.00 g/s 1.5 4 

 Wind Speed: 1.00 m/s 

Maximum Visual Impacts INSIDE Class II Area a

 Delta E Contrast 

Background Theta Azi Dist Alpha Criterion Plume Criterion Plume 

Sky 10 93 33 75 7.5 0.752 0.19 -0.005 

Sky 140 93 33 75 7.5 0.524 0.19 -0.003 

Terrain 10 84 32 84 7.5 0.603 0.19 0.004 

Terrain 140 84 32 84 7.5 0.234 0.19 0.005 

Maximum Visual Impacts OUTSIDE Class II Area a 

 Delta E Contrast 

Background Theta Azi Dist Alpha Criterion Plume Criterion Plume 

Sky 10 0 1 168 7.5 1.75 0.19 -0.028 

Sky 140 0 1 168 7.5 1.034 0.19 -0.01 

Terrain 10 0 1 168 7.5 3.621 0.19 0.051 

Terrain 140 0 1 168 7.5 1.548 0.19 0.055 

a Impacts based on 4 startups and 4 shutdowns of each turbine in a single day, remainder of day at peak 

operation. b National Park Service, Visibility Monitoring Data, 

http://www.nature.nps.gov/air/monitoring/vismon.cfm#data (accessed 3/17/2011) 
-13- 

5. IMPACTS ON SOILS AND VEGETATION 

For most types of soils and vegetation, ambient concentrations of criteria pollutants 

below the secondary NAAQS will not result in harmful effects because the secondary 

NAAQS are set to protect public welfare, including animals, plants, soils, and materials. 

One section of the AFC submitted to the CEC provides a discussion of the Facility’s 

potential impacts on soils and vegetation: Section 5.6 – Biological Resources. This 

section is incorporated by reference into the PSD permit application. 

EPA provided guidance* in 1980 to determine if maximum modeled ground-level 

concentrations of project-emitted criteria pollutants NO2, SO2, and CO could have an 

impact on plants, soils, and animals. As shown in Table 5-1, the maximum modeled 

concentrations from the Project are well below the thresholds. 

Table 5-1 

Project Maximum Concentrations and EPA Guidance Levels 

Criteria Pollutant 

and Guidance a

Averaging Time 

EPA Screening 

Concentration 

(μg/m3) 

Modeled Maximum 

Concentrations b

(μg/m3) 

Averaging 

time 

SO2 1-Hour 917 6 1 hour 

SO2 3-Hour 786 3 3 hour 

SO2 Annual 18 <0.1 Annual 

NO2 4-Hours 3,760 111 1 hour 

NO2 1-Month 564 111 1 hour 

NO2 Annual 94 0.3 Annual 

CO Weekly 1,800,000 52 8 hour 

a “A Screening Procedure for the Impacts of Air Pollution Sources on Plants, Soils, and 

Animals,” EPA 450/2-81-078, December 1980. b Table 5.2-27 of Section 5.2 of the AFC. 

 

*

 USEPA. A Screening Procedure for the Impacts of Air Pollution Sources on Plants, Soils, and Animals,” 

EPA 450/2-81-078, December 1980.
-14- 

6. GROWTH-INDUCING IMPACTS 

The project’s less-than-significant potential growth-inducing impacts on population, 

housing, schools, utilities, and emergency and other services are discussed in the AFC, 

Section 5.10 – Socioeconomics, pages 5.10-7 through 5.10-18. 

Little to no associated commercial growth is expected as a result of the project. The 

proposed project is an electrical generating station. The proposed plant will be located 

immediately adjacent to another existing electrical generating station. Immediately to the 

north of the project are state and county detention facilities, and a third privately run 

detention facility has been proposed nearby. Therefore, little or no associated industrial, 

commercial, or residential source growth is expected to occur in the area due to the 

project. 
-15- 

7. DEMONSTRATION OF COMPLIANCE WITH NAAQS 

The worst-case modeling analysis, in which maximum project impacts were added to 

maximum measured background concentrations, demonstrated compliance with all 

ambient air quality standards except for the federal 1-hour NO2 standard and the federal 

24-hour PM2.5 standard (see Appendix G-4 of the AFC; note that some tables were 

amended in the AFC supplement). A more refined analysis that more closely matches the 

actual ambient concentrations with the modeled project impact under the same 

meteorological conditions is presented below to provide a more realistic assessment of 

the expected impacts of the proposed project. 

The methodology for performing this more refined analysis is described in detail in the 

modeling protocol submitted to EPA on December 1, 2010 (Appendix G-8 of the AFC). 

The methodology described in that protocol has been, for the most part, be followed; 

some changes have been made, however, to incorporate newly available modeling 

guidance. The methodology that was followed and the changes from the protocol are 

described below. It should be noted that this analysis, although more refined than the 

screening analysis, is still conservative, for reasons that are discussed below. 

Before the analysis can be completed, EPA must review and approve the list of stationary 

sources to be included in the cumulative impact portion of the analysis. The proposed list 

of sources, and the basis for their selection, are presented below. 

The stack parameters used for this analysis are shown in Table G-7.1 in Appendix G-7 of 

the AFC, as amended in the AFC supplement. 

7.1 Compliance with the Federal 1-Hour NO2 Standard 

7.1.1 Form of the Standard 

The federal 1-hour NO2 standard is met if the 3-year average of the 98th percentile 

highest daily 1-hour average NO2 concentration, including background, does not exceed 

100 ppb. At standard temperature and pressure, this is equivalent to 188 μg/m3

. The 

standard is converted to μg/m3

 for the analysis because the modeling results are in those 

units. 

The procedure for determining compliance is to determine the highest 1-hour NO2

concentration, including background, for each calendar day in the year at every receptor. 

These concentrations are rank-ordered at each receptor, highest to lowest, and the 98th 
-16- 

percentile value (8th highest concentration for a reasonably complete data set) is selected 

to represent that year for that receptor. These values are then averaged, for each receptor, 

over the five years included in the analysis. The resulting average must be less than or 

equal to 188 μg/m3

 for all receptors. 

7.1.2 Compliance Demonstration Procedure 

The output from the dispersion model provides the worst-case project impact at all of the 

receptors in the impact area (the area where the maximum project impact exceeds the 

Significant Impact Level [SIL])*

 for each hour of the year (see Figures G-7.1 and G-7.2, 

as amended in the AFC supplement). Receptors outside the impact area are excluded 

from the analysis because the project impact cannot, by definition, cause or contribute 

significantly to a violation of the standard if the project impact, by itself, does not exceed 

the SIL.†

Use of the worst-case modeled impact is the first conservative assumption in this 

analysis. It is conservative because it assumes that the project will be operating under its 

worst case conditions (i.e., all three turbines in simultaneous startup, for NO2) every 

single hour of the year. Although this is clearly unrealistic, it is not possible to further 

refine the assumptions for a peaking turbine facility; given the expected frequency of 

turbine startups, it is possible, although extremely unlikely, that such operation will line 

up with each of the 8 highest background hours during the year. 

The ambient background NO2 concentration for each hour is then added to the modeled 

impact at each receptor. The ambient background concentration is comprised of two 

components: regional background and nearby sources. The regional background 

concentration is developed from ambient measurements at a nearby monitoring station or 

stations. Nearby sources are those that have the potential to create significant 

concentration gradients in the significant impact area, creating locally elevated 

concentrations that are not adequately reflected in the ambient monitoring data. 

Once the modeled impact for each hour has been added to the corresponding ambient 

background concentration, the highest combined impact for each calendar day is 

determined. Daily maxima are rank ordered; because the data set is complete, the 8th 

highest result at each receptor is averaged with those from the other years in the analysis 

to determine compliance with the ambient air quality standard. 

The final step of the significant contribution analysis is based on the source’s 

contribution to a modeled violation paired in time and space. The significant contribution 

 

*

 It should be noted that the U.S. EPA has not adopted a SIL for the 1-hour NO2 standard. Following EPA 

guidance, the interim SIL value of 4 ppb (7.5 μg/m3

) was used for this analysis. 

†

 “[W]e deem it appropriate and acceptable in most cases to limit the cumulative impact analysis to only 

those receptors that have been shown to have significant impacts from a proposed new source based on the 

initial SIL analysis, assuming that the design of the original receptor grid was adequate to determine all 

areas of ambient air where the source could contribute significantly to modeled violations.” Memo, T. Fox 

(EPA) to Regional Air Division Directors, “Additional Clarification Regarding Application of Appendix W 

Modeling Guidance for the 1-hour NO2 Ambient Air Quality Standard,” March 1, 2011, p. 3. 
-17- 

analysis is not limited to analyzing the source’s contribution associated only with the 

modeled design value based on the 98th percentile cumulative air quality impact at the 

receptor, but rather must examine all cases where the air quality impact exceeds the 

NAAQS at or below the 98th percentile. The analysis will examine the source’s 

contribution, paired in time and space, to every multiyear average of daily maximum 1-

hour, beginning with the 8th highest (98th percentile), continuing down the ranked 

distribution until the cumulative impact is below the NAAQS. If the project impact at 

any of these receptors at any of these times exceeds the SIL, the project may not be 

approved as proposed. 

Regional Background Concentrations 

EPA has requested that the actual background concentrations corresponding in time to the 

meteorological conditions not be used for this analysis. Instead, another conservative 

adjustment has been made to the results: for each calendar month, a composite daily 

background profile has been used. The composite daily background profile for a given 

calendar month is comprised of the highest ambient monitor NO2 reading from the month 

for each clock GMT hour. The same 24 hourly values are repeated as the background 

concentrations for each day of the month.*

All ambient air quality data used in this analysis were published by the California Air 

Resources Board (CARB) on the ADAM website and/or by U.S. Environmental 

Protection Agency (EPA) on the AIRS data website. Ambient air concentrations of 

ozone (O3), NO2, SO2, CO, PM10, and PM2.5 are recorded at monitoring stations 

throughout San Diego County. The immediate area surrounding the project site (within 

1.5 to 2 miles) is an area with sparse population. Further out, areas to the north, 

northeast, east, and southeast are all vacant, hilly terrain with very sparse population. 

However, areas more than 2 miles to the south (Tijuana), 5 miles west (Otay Mesa West), 

and northwest (Sunbowl) are urban or suburban areas with moderate to high-density 

residential areas. Most air quality monitoring stations in the region record measurements 

for only one or two criteria pollutants, except for those stations located in urban areas. 

The monitoring stations were generally positioned to represent area-wide ambient 

conditions rather than the localized impacts of any particular emission source or group of 

sources. In rural areas of the county, pollutant concentrations are not expected to vary 

dramatically from one location to the next, because the emission sources are few and 

widely distributed. Concentrations of pollutants emitted by industrial and vehicular 

sources are generally higher in the more populated areas of greater San Diego than in the 

rest of the county. 

The closest air quality monitoring station to the Project is located in Otay Mesa at the 

Otay Mesa-Paseo International Border crossing 1.2 miles south of the Project. However, 

the pollutant concentrations recorded at this station are heavily influenced by the 

emissions from the hundreds of Mexican vehicles waiting each hour at the border entry 

 

*

 Memo, T. Fox (EPA) to Regional Air Division Directors, “Additional Clarification Regarding 

Application of Appendix W Modeling Guidance for the 1-hour NO2 Ambient Air Quality Standard,” 

March 1, 2011, p. 18-19. 
-18- 

point of Otay Mesa-Paseo International, burning fuels that do not meet strict United 

States and California standards. In contrast, the Chula Vista station is not impacted by 

nearby sources, and is only 9 miles from the project site. Comparison of the highest 24-

hour PM10 data collected at the two monitors*

 shows that maximum PM10 concentrations 

at the border station are about twice as high as maximum concentrations at the alternate 

site. The border trucks impact all combustion pollutant measurements at the Otay Mesa 

monitor, not just PM10. 

The San Diego - Overland Street and San Diego - 1110 Beardsley Street monitoring 

stations are each more than 15 miles away from the PPEC facility, and each is located in 

the coastal area. The air quality data at these monitoring stations are not representative of 

the greater Lower Otay Lake area. 

Therefore, after consultation with the District, data from the Chula Vista monitoring 

station located at 80 East J Street, approximately 9 miles northwest of the project site, 

were used to represent background air pollutant concentrations for the vicinity of the 

Project. 

Processed background air quality data files were obtained from the District. Data for 

periods of time with invalid data were replaced by the District using data substitution 

procedures consistent with EPA guidance. Data substitution ensures that there will be no 

gaps in the data. This prevents exclusion of modeled high impact hours because of 

missing monitoring data. 

Nearby Sources 

Identification of non-project sources to be included in characterization of background 

concentrations for the compliance demonstration begins by developing a list of facilities 

with emissions above a threshold. The threshold that is selected for this purpose is low 

enough to ensure that potentially significant sources are not overlooked. The 

geographical area included in the search is large enough to ensure that sources that may 

have a significant impact anywhere in the project’s impact area are identified. The most 

distant receptor with a significant project impact was 24 km east of the project site. 

The District was asked to provide a list of all stationary sources within the District and 

within 80 km of the project (approximate distance to the farthest significant impact plus 

50 km), with actual emissions above 5 TPY of either NOx or PM10.

†

 The District was 

also asked to provide a list of all new projects with recently issued permits (i.e., after 

January 1, 2005) or recently submitted applications and a potential to emit above 5 TPY 

NOx or PM10. Because the District’s database could not determine whether a source was 

 

*

 CARB ADAM database, accessed November 28, 2010. Because the Otay Mesa-Richard Correctional 

Facility monitor collects only PM10 data, and does not include data from 2004, data from this monitor will 

not be used for this air quality impact analysis. 

†

 District emission inventories for PM10 are more complete than for PM2.5. Because PM2.5 is a subset of 

PM10, the list of facilities generated by a PM10 threshold will be more extensive, and completely overlap, 

the list of facilities that would have been generated using a PM2.5 threshold. 
-19- 

within 80 km of the project, the District provided a list of all facilities within the District 

with emissions above 5 TPY of either pollutant. This list is presented in Table 7-1 (at the 

end of this section). 

Figures 7-1 and 7-2 show the location and relative strength of NO2 sources near the 

project. Also shown are the site of the meteorological monitor, the site of the ambient air 

quality monitor, the impact area for 1-hour NO2 standard, and a wind rose for the area. 
-20- 

Figure 7-1 

NOx Stationary Sources in Near Vicinity (within 10 km) of PPEC 
-21- 

Figure 7-2 

NOx Stationary Sources in Vicinity (within 50 km) of PPEC 
-22- 

Table 7-1 also indicates which non-project facilities and emissions are proposed for 

inclusion in the compliance demonstration: NOx emissions from Larkspur Energy 

Facility (a small peaking plant located 2.5 km west of the project site); NOx emissions 

from Pacific Recovery Corp (landfill gas waste-to-energy facility 9.2 km west of the 

project site); and NOx and PM2.5 emissions from Otay Mesa Generating Company (a 

power plant located adjacent to the project site). These facilities are all large enough and 

close enough to the project site to have the potential to directly impact the project’s 

significant impact area. Additionally, the energy facilities are likely to operate at peak 

capacity at the same time as PPEC. 

The decision to include or exclude a specific facility is based on a number of 

considerations. The purpose of the analysis is to identify non-project sources that might 

contribute to a modeled violation at a time and place where the project has a significant 

impact; the size of the non-project source is important. A preliminary analysis that 

evaluated the combined impact of project and regional background, but no non-project 

sources, indicated that the project would raise the design value only 3 μg/m3

, from 

153 μg/m3 to 156 μg/m3.

*

 In order to result in a violation, a non-project source (or 

combination of non-project sources) would therefore have to have an impact of more than 

32 μg/m3 at the same time and place as the project’s significant impact—about 10 times 

as great as the project’s impact. 

Because the averaging time is a short one (hourly for NO2, daily for PM2.5), a non-project 

source would need to be on the same (windward) side of the project impact area as the 

project in order to impact the project impact area at the same time. 

Described below are the factors taken into account while reviewing the list of candidate 

sources. 

 Proximity: Current EPA guidance† suggests that “emphasis on determining which 

nearby sources to include in the modeling analysis should focus on the area within 

about 10 kilometers of the project location in most cases.” 

 Size: In order to affect the analysis, the candidate project or projects must have an 

impact 10 times as great as the project’s impact at the same time and place as the 

project. 

 Location relative to impact areas: For short-term impacts, a non-project facility 

must be on the same side of the impact area as the project in order to have an 

impact at the same time and place as the project. 

 Location relative to the ambient monitor: Sources upwind of the ambient monitor 

are more likely to be adequately reflected in ambient monitoring data. 

 

*

 AFC Addendum, Table G-7.2. 

†

 Memo, T. Fox (EPA) to Regional Air Division Directors, “Additional Clarification Regarding 

Application of Appendix W Modeling Guidance for the 1-hour NO2 Ambient Air Quality Standard,” March 

1, 2011, p. 12-16 
-23- 

 Operating schedule: The variability of source operation, and the frequency of 

relatively high emission operations, can affect the source’s contribution to 

significant concentration gradients. In this case, high emissions from peaking 

power plants are likely to align with startup emissions from the project. 

Most of the facilities in Table 7-1 are proposed for exclusion from the analysis because 

they are too far away from the project to be likely to create a significant impact gradient 

in the project’s impact area. All of the excluded facilities except for Hanson Aggregates 

are more than 10 km away from the project, and more than 10 km away from the relevant 

significant impact area. 

Based upon project modeling, the extent of the project’s significant NO2 impact was 

24 km for an annual emission rate of 70 TPY. The ratio of emissions to distance to the 

limits of significant impact for the project is 70/24 TPY/km, or 2.9.* This ratio was used 

as a rough screening tool for estimating the impact of other facilities relative to the 

project. A facility with about the same emissions and about the same stack height can be 

expected to have similar impacts at a given distance. Because a non-project facility 

would need to have a much higher impact than the project in order to result in 

noncompliance, this screening level was a useful starting point for considering nonproject facilities. 

It should be noted that distance over which a facility might have a significant impact for 

short-term standards (e.g., hourly NO2) is determined by short-term maximum emission 

rates rather than annual emission rates. In fact, the PPEC impact area is determined by 

the peak emission rates that occur during startup and shutdown. District emission 

inventories report annual emission rates. If a candidate facility is operated in a way that 

the ratio of peak emissions to average emissions is much higher than for PPEC, use of the 

ratio of annual emissions distance to screen for impact is less valid. For this reason, 

facilities that were screened out because the annual emission-to-distance ratio of 

2.9 TPY/km or lower were examined to determine if there was a likelihood that shortterm emission rates would be much higher than annualized emission rates. 

Other sources were screened out for the reasons outlined below. 

 Otay Landfill; Sycamore Landfill; Hanson Aggregates – These facilities are on 

the list because they have large PM10 emissions. However, the PM2.5 fraction of 

fugitive dust emissions is low (on the order of 20% of PM10). If the PM2.5

emissions are estimated by adjusting total PM10, the emission-to-distance ratio 

falls below the screening level. Furthermore, PM2.5 from fugitive dust would be 

expected to settle out close to the source, when compared with combustion PM2.5

emitted from a hot stack. Finally, the ratio of peak emissions to annual average 

emissions will be much lower for the fugitive dust sources. All of these factors 

combine to support excluding these sources from the analysis. 

 

*

 The ratio for PM2.5 impacts is much higher (35.8TPY/3.8 km = 9.4). 
-24- 

 Manson Construction and Engineering – This is the storage location for portable 

equipment. Emissions occur throughout the District. 

 Solar Turbines, Inc. – Peak emissions from this turbine testing facility are lower 

than peak emissions from the 300 MW PPEC, and the distance from the facility to 

the PPEC significant impact area is much more than 24 km. Based on the PPEC 

modeling, it is not likely that this facility will have a significant impact on 

concentrations in the PPEC significant impact area. 

 Dynegy South Bay – This facility is in the process of being decommissioned, and 

ceased operation on December 31, 2010. 

The next step in the compliance demonstration is to include the modeled impacts at all 

receptors in the significant impact area from the nearby sources identified above in 

background impacts for the compliance demonstration. This step will be performed after 

EPA has reviewed and approved the list of nearby sources to include in the analysis. 

 

7.2 Compliance with the Federal 24-hour PM2.5 Standard 

7.2.1 Form of the Standard 

The federal 24-hour PM2.5 standard is met if the three-year average of the 98th percentile 

daily 24-hour average PM2.5 concentration, including background, does not exceed 

35 μg/m3. 

The procedure for determining compliance is to determine the 24-hour PM2.5

concentration, including background, for each calendar day in the year at every receptor. 

These concentrations are rank-ordered, highest to lowest, and the 98th percentile value 

(8th highest concentration for a reasonably complete data set) is selected to represent that 

year. These values are then averaged over the three years included in the analysis. The 

resulting average must be less than or equal to 35 μg/m3

. 

7.2.2 Compliance Demonstration Procedure 

The output from the dispersion model provides the worst-case project impact at all of the 

receptors in the impact area (the area where the maximum project impact exceeds the 

Significant Impact Level [SIL]) for each hour of the year. Receptors outside the impact 

area are excluded from the analysis because the project impact cannot, by definition, 

cause or contribute significantly to a violation of the standard if the project impact alone 

does not exceed the SIL. The ambient background concentration for each day is then 

added to the modeled impact at each receptor. 

Once the modeled impact for each day has been added to the corresponding ambient 

background concentration, daily impacts are rank ordered; because the data set is 

complete, the 8th highest result is averaged with those from the other years in the analysis 

to determine compliance. 
-25- 

Regional Background Concentrations 

Regional background concentrations have been obtained from the District. See the 

discussion above for NO2, as well as the discussions in Section 5.2 of the AFC and in the 

modeling protocol, for more information about ambient monitoring, including 

representativeness. 

Nearby Sources 

The decision to include or exclude a specific facility is based on a number of 

considerations. The purpose of the analysis is to identify non-project sources that might 

contribute to a modeled violation at a time and place where the project has a significant 

impact; the size of the non-project source is important. A preliminary analysis that 

evaluated the combined impact of project and regional background, but no non-project 

sources, indicated that the project would raise the design value only 0.1 μg/m3

, from 

25.8 μg/m3 to 25.9 μg/m3.

*

 In order to result in a violation, a non-project source (or 

combination of non-project sources) would therefore have to have an impact of more than 

9 μg/m3 at the same time and place as the project’s significant impact—more than 10 

times as great as the project’s impact. 

Because the averaging time is short (daily for PM2.5), a non-project source would need to 

be on the same (windward) side of the project impact area as the project in order to 

impact the project impact area at the same time. 

Figures 7-3 and 7-4 show the location and relative strength of PM2.5 sources near the 

project. Also shown are the site of the meteorological monitor, the site of the ambient air 

quality monitor, the impact area for 24-hour PM2.5 standard, and a wind rose for the area. 

 

*

 AFC Addendum, Table G-7.2. 
-26- 

Figure 7-3 

PM2.5 Stationary Sources in Near Vicinity (within 10 km) of PPEC 
-27- 

Figure 7-4 

PM2.5 Stationary Sources in Vicinity (within 50 km) of PPEC 
-28- 

The same emission/distance ratio of 2.9, derived from NO2 impacts, was used for initial 

screening of PM2.5 sources. This conservative approach was taken because it simplifies 

the screening process. It avoids the need to account for the contribution that noncombustion sources make to project impacts, and it makes little difference in the number 

of sources that will be included in the cumulative impact analysis. Special factors taken 

into consideration for inclusion or exclusion of PM2.5 sources are described above in 

Section 8.1.2. 

 

7.2.3 Compliance Demonstration Results 

The next step in the compliance demonstration is to include the modeled impacts at all 

receptors in the significant impact area from the nearby sources identified above in 

background impacts for the compliance demonstration. This step will be performed after 

EPA has reviewed and approved the list of nearby sources to include in the analysis. 

 
-29- 

Table 7-1 

Identification of Nearby Sources 

Facility Name Source Type 

Distance from 

Pio Pico 

Project Site 

(kilometers) 

NOx 

Emissions 

(TPY) 

PM10

Emissions 

(TPY) 

Emission/

Distance 

Ratio 

(NOx) 

Emission/

Distance 

Ratio 

(PM2.5) 

Include in 

Cumulative 

Impact 

Basis for 

Exclusion

31. Larkspur Energy 

Facility 

Electricity 

Generation 2.5 50 7.0 20.0 2.8 NOx 

Emissionto-distance 

ratio 

(PM2.5) 

55. Pacific Recovery 

Corp 

Electricity 

Generation 9.2 44.6 15.5 4.8 1.7 NOx 

Emissionto-distance 

ratio 

(PM2.5) 

63. Otay Mesa 

Generating Companya

 Power 0.1 100 99.5 1000.0 995.0 NOx, PM2.5

1. Otay Landfill Inc. Landfill 9.0 20.7 187.5 2.3 20.8 

Fugitive 

Dust 

Sourceb

 

2. Sycamore Landfill 

Inc. Landfill 33.6 9.5 418.5 0.3 12.5 

Fugitive 

Dust 

Sourceb

3. Hanson Aggregates 

– 7th & Main 

Aggregate 

Production 14.4 16.8 1.2 

Emissionto-distance 

ratio 

4. Hanson Aggregates 

– Escondido 

Aggregate 

Production 62.9 9.1 0.1 

Emissionto-distance 

ratio 

5. Superior Ready Mix 

Concrete 

Concrete Mix 

Production 64.0 10.0 0.2 

Emissionto-distance 

ratio 

6. Hamilton 

Sundstrand Power 

Systems 

Aerospace 

components 

(including 

auxiliary power 

systems) 

33.7 12.6 0.4 

Emissionto-distance 

ratio 

7. Hanson Aggregates 

- Otay Valley Rd. 

Aggregate 

Production 6.9 47.1 6.8 

Emissionto-distance 

ratio 

8. Manson 

Construction & 

Engineering 

Marine 

Construction 

and Dredging 

Portable 

source 

13.8 Portable 

Source 

9. Hanson Aggregates 

- Harris Plant 

Aggregate 

Production 37.4 10.4 0.3 

Emissionto-distance 

ratio 

10. USN Air Station 

Noris Unknown 30.7 9.1 0.3 

Emissionto-distance 

ratio 
-30- 

Table 7-1 

Identification of Nearby Sources 

Facility Name Source Type 

Distance from 

Pio Pico 

Project Site 

(kilometers) 

NOx 

Emissions 

(TPY) 

PM10

Emissions 

(TPY) 

Emission/

Distance 

Ratio 

(NOx) 

Emission/

Distance 

Ratio 

(PM2.5) 

Include in 

Cumulative 

Impact 

Basis for 

Exclusion

11. Duplicate facility 

(#28) Duplicate

12. Hanson Aggregates 

- Carroll Canyon 

Aggregate 

Production 42.0 15.5 0.4 

Emissionto-distance 

ratio 

13. USMC Camp 

Pendleton - Military 

Schools 

Unknown 89.0 6.2 0.1 

Emissionto-distance 

ratio 

14. USMC Camp 

Pendleton - 

Unpermitted Sources 

Unknown 89.6 11.6 0.1 

Emissionto-distance 

ratio 

15. Hanson Aggregates 

- Twin Oaks 

Aggregate 

Production 65.0 21.7 0.3 

Emissionto-distance 

ratio 

16. Hanson Aggregates 

- Sycamore Landfill 

Aggregate 

Production 34.6 29.4 0.8 

Emissionto-distance 

ratio 

17. California 

Commercial Asphalt 

Asphalt 

Production 37.4 12.4 0.3 

Emissionto-distance 

ratio 

18. Agri Service Composting 

Facility 79.4 5.5 0.1 

Emissionto-distance 

ratio 

19. J Cloud Inc 

Construction 

Materials 

Recycling 

21.1 6.4 0.3 

Emissionto-distance 

ratio 

20. Encina Wastewater 

Authority 

Wastewater 

Treatment 70.7 6.9 0.1 

Emissionto-distance 

ratio 

21. National Steel & 

Shipbuilding 

Steel and Ship 

Production 24.3 12.9 23.2 0.5 1.0 

Emissionto-distance 

ratio 

22. Hanson Aggregates 

- Hwy 67 Lakeside 

Aggregate 

Production 37.3 18.6 0.5 

Emissionto-distance 

ratio 

23. Pacific Gas 

Turbine Center 

Electricity 

Production 40.7 12.9 0.3 

Emissionto-distance 

ratio 

24. Hanson Aggregates 

- El Cajon 

Aggregate 

Production 21.3 5.0 0.2 

Emissionto-distance 

ratio 

25. So. Cal. Edison - 

San Onofre 

Electricity 

Generation 106.3 27.2 0.3 

Emissionto-distance 

ratio 
-31- 

Table 7-1 

Identification of Nearby Sources 

Facility Name Source Type 

Distance from 

Pio Pico 

Project Site 

(kilometers) 

NOx 

Emissions 

(TPY) 

PM10

Emissions 

(TPY) 

Emission/

Distance 

Ratio 

(NOx) 

Emission/

Distance 

Ratio 

(PM2.5) 

Include in 

Cumulative 

Impact 

Basis for 

Exclusion

26. Kyocera 

Electronic 

Goods 

Production 

34.5 16.9 0.5 

Emissionto-distance 

ratio 

27. CW Mcgrath Quarry 20.6 5.9 0.3 

Emissionto-distance 

ratio 

28. USN Supships - 

32nd St Unknown 23.0 6.4 0.3 

Emissionto-distance 

ratio 

29. Gas Recovery 

System - San Marcos 

Electricity 

Generation 63.2 16.1 0.3 

Emissionto-distance 

ratio 

30. Gas Recovery 

Systems - Santee 

Electricity 

Generation 33.1 20.4 0.6 

Emissionto-distance 

ratio 

32. Encina Power 

Plant 

Electricity 

Generation 73.6 54.6 47.6 0.7 0.6 

Emissionto-distance 

ratio 

33. Grossmont District 

Hospital 

Medical 

Services 24.4 39.1 1.6 

Emissionto-distance 

ratio 

34. San Diego State 

University University 26.6 25.4 1.0 

Emissionto-distance 

ratio 

35. Solar Turbines Inc. 

Small 

Combustion 

Turbine 

Production 

33.4 94.4 7.5 2.8 0.2 

Emissionto-distance 

ratio 

36. Pt. Loma 

Wastewater Treatment 

Plant 

Wastewater 

Treatment 32.9 45.2 11.2 1.4 0.3 

Emissionto-distance 

ratio 

37. Qualcomm - 

Morehouse Dr. 

Electronic 

Goods 

Production 

44.0 26.5 0.6 

Emissionto-distance 

ratio 

38. Minnesota 

Methane - North City 

Facility 

Cogeneration 42.7 25.3 8.5 0.6 0.2 

Emissionto-distance 

ratio 

39. Minnesota 

Methane - Miramar 

Facility 

Cogeneration 37.4 42.2 14.9 1.1 0.4 

Emissionto-distance 

ratio 

40. Canyon Rock - 

Mission Gorge 

Aggregate 

Production 29.9 35.9 1.2 

Emissionto-distance 

ratio 
-32- 

Table 7-1 

Identification of Nearby Sources 

Facility Name Source Type 

Distance from 

Pio Pico 

Project Site 

(kilometers) 

NOx 

Emissions 

(TPY) 

PM10

Emissions 

(TPY) 

Emission/

Distance 

Ratio 

(NOx) 

Emission/

Distance 

Ratio 

(PM2.5) 

Include in 

Cumulative 

Impact 

Basis for 

Exclusion

41. Vulcan Materials Aggregate 

Production 31.2 44.3 1.4 

Emissionto-distance 

ratio 

42. Dynegy South Bay Electricity 

Generation 17.3 35.7 36.8 2.1 2.1 Ceased 

Operation

43. CP Kelco US Inc 

Food 

Ingredients 

Production 

25.3 38.8 6.4 1.5 0.3 

Emissionto-distance 

ratio 

44. Applied Energy 

LLC MCRD 

Electricity 

Generation 32.6 40.4 12.8 1.2 0.4 

Emissionto-distance 

ratio 

45. Solar Turbines - 

Pacific Hwy 

Small 

Combustion 

Turbine 

Production 

29.5 16.6 0.6 

Emissionto-distance 

ratio 

46. RCP Block & 

Brick 

Concrete Block 

and Brick 

Production 

30.8 5.8 0.2 

Emissionto-distance 

ratio 

47. Applied Energy - 

Naval Station 

Electricity 

Generation 22.5 56.2 22.3 2.5 1.0 

Emissionto-distance 

ratio 

48. BAE Systems Ship 

Repair Ship Repair 45.0 7.3 0.2 

Emissionto-distance 

ratio 

49. UC San Diego University 44.9 9.4 9.8 0.2 0.2 

Emissionto-distance 

ratio 

50. San Diego Union 

Tribune 

Newspaper 

Production 31.3 8.0 0.3 

Emissionto-distance 

ratio 

51. US Marine Corps 

Miramar Unknown 39.2 87.7 5.3 2.2 0.1 

Emissionto-distance 

ratio 

52. US Marine Corps 

Miramar – 3rd MAW 

Motor 

Transportation 

Maintenance 

39.6 21.2 0.5 

Emissionto-distance 

ratio 

53. Navy Hospital Medical 

Services 27.3 10.7 0.4 

Emissionto-distance 

ratio 

54. Applied Energy - 

North Island 

Electricity 

Generation 29.3 22.0 15.5 0.8 0.5 

Emissionto-distance 

ratio 
-33- 

Table 7-1 

Identification of Nearby Sources 

Facility Name Source Type 

Distance from 

Pio Pico 

Project Site 

(kilometers) 

NOx 

Emissions 

(TPY) 

PM10

Emissions 

(TPY) 

Emission/

Distance 

Ratio 

(NOx) 

Emission/

Distance 

Ratio 

(PM2.5) 

Include in 

Cumulative 

Impact 

Basis for 

Exclusion

56. Vulcan Materials - 

Black Mtn. Rd. 

Aggregate 

Production 41.2 27.1 0.7 

Emissionto-distance 

ratio 

57. SDG&E Palomar 

Energy Center 

Electricity 

Production 63.3 95.4 37.6 1.5 0.6 

Emissionto-distance 

ratio 

58. Goal Line LP - 

Escondido 

Electricity 

Generation 62.7 18.9 26.0 0.3 0.4 

Emissionto-distance 

ratio 

59. San Diego County 

- San Marcos Landfill Closed Landfill 62.7 9.6 0.2 

Emissionto-distance 

ratio 

60. San Diego City - 

South Chollas Landfill Closed Landfill 22.6 6.3 0.3 

Emissionto-distance 

ratio 

61. San Diego City - 

Miramar Landfill Landfill 38.8 82.2 2.1 

Emissionto-distance 

ratio 

62. San Diego Metro 

Pumping Station #2 

Water Pumping 

Facility 32.2 13.6 0.4 

Emissionto-distance 

ratio 

a

 Emissions from Otay Mesa Generating Company are maximum permitted annual emissions. 

b

 Fugitive dust emission source. See text for discussion of factors resulting in exclusion.