# 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) 444-6666DRAFT 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-i

### Application 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 NO 2 Standard ........................................... 15 7.2 Compliance with the Federal 24-hour PM 2.5 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 Vicin ity (within 50 km) of PPEC ........................21

Figure 7-3 PM 2.5 Stationary Sources in Near Vi cinity (within 10 km) of PPEC ..............26

Figure 7-4 PM 2.5 Stationary Sources in Vici nity (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 Parame ter 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 Concentr ations and EPA Guidance Levels .........................13

Table 7-1 Identificatio n of Nearby Sources ......................................................................29-1- 

### 1. INTRODUCTION

In this Application for a Prevention of Signi ficant Deterioration (PSD) permit, Pio Pico Energy Center, LLC (PPEC LLC or “Applican t”) 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 suppl y 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 generati on project that consis ts of three General Electric (GE) LMS100 natural gas-fired com bustion 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 inject ion to the combustors for reducing production of oxides of nitrogen ( NOx), a selective catalytic reduction (SCR) system with 19 percent aqueous ammonia (NH 3 ) injection to further reduce NOx emissions, and an oxidation catalyst to re duce 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 so utheast quadrant of the intersection of Alta Road and Calzada De La Fuente Road, adjace nt 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 ha ve 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 Threshold a (TPY) PSD Significant Emission Threshold b (TPY) PPEC Emissions c (TPY) Major Source? Significant Emissions? Subject to PSD?
SO 2 250 40 4.1 No No No
PM 10 250 15 37.2 No Yes 

### Yes

PM 2.5 250 10 37.2 No Yes 

### Yes

NOx 250 40 70.4 No Yes 

### Yes
VOC 250 40 20.7 e No No No

CO 250 100 96.4 No No No
Lead 250 0.6 0.0 No No No GHGs 100,000 d 75,000 d 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 Cont rol 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 addre ss, are listed in Section 2.

USEPA’s New Source Review Workshop Manual, Preven tion 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 genera lly will depend on existing air quality, the quantity of emissions, and the sensiti vity of local soil s, 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 pe rmit application are as follows:

 Section 3 presents the Class I Impact Analysis.

 Section 4 presents the Class II Vi sibility Impairment Analysis.

 Section 5 describes impact s on soils and vegetation.

 Section 6 describes the potent ial for growth-inducing impacts

 Section 7 describes the methodology for demonstrating compliance with 1-hour NO 2 and 24-hour PM 2.5 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, sc enic, recreational, or historic value for which the PSD regulations provide special prot ection. If a proposed major source or major modification may affect a Class I area, the federal PSD regulations require the reviewing authorit y to provide written notific ation of any such proposed source to the Federal Land Managers (F LM) (and the USDI and USDA officials delegated permit review res ponsibility). The meaning of the term “may affect” is interpreted by EPA policy to include all ma jor 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 on e being within 100 km of the project site.

 Agua Tibia Wilderness (91 km)

 San Jacinto Wilderness (122 km)

The impact analysis presented below is di fferent than the analysis proposed in the modeling protocol submitted for this proj ect (see Appendix G-8 of the AFC). The guidance that forms the basis for the analys is below is more recent than the guidance upon which the protocol was based, and theref ore better reflects current standards of review.

The Federal Land Managers’ Air Quality Re lated Values (AQRV) Work Group (FLAG) has published guidance for a screening appro ach 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 (SO 2 , NOx, PM 10 , and sulfuric acid mi st) from a project (in units of tons per year) † and dividing the sum by the dist ance 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 proj ect’s emissions are well below the FLAG screening criteria. As indicated previously, all Cl ass 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., “Fed eral Land Managers’ Ai r 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 Emissions a (max 24-hours, lb/day) PPEC Emissions b (max 24-hours, TPY) Q/D Screening Threshold c Class I Analysis Required?

SO 2 136.8 25.0 -- --

PM 10 411.8 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., “F ederal 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 Impairme nt 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 fo r this project (see AFC Appendix G-8), a Class II Visibility Impairment Analysis wa s performed for this project; however, the methodology proposed in the modeling protocol was updated to reflect the procedure recently recommended by the Federal Land Mana gers’ Air Quality Related Values Work Group (FLAG). * The methodology and the resu lts are presented below.



### 4.1 Methodology

In general, the Class II Visibility An alysis methodology follows the methodology for a Class I Visibility Analysis. The procedure is divided into two parts, reflecting very different procedures for near-fie ld analysis (where plumes or layers are compared against a viewing background) and far-fie ld 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 im pacts is an initial scr eening 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 fo r the project’s plume to affect visibility in Class II areas managed by federal land mana gers (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., “Fed eral Land Managers’ Ai r 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 conservativ e 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 sensit ive Class II site for which the FLM screening value is exceeded. Calculated values relati ng source emissions to visibility impacts are compared to a standardized screening value. Those sources with calculated values greater than the screening crit eria are judged to have potentia l visibility impairments. If potential visibility impairments are identifie d, then the Level 2 anal ysis 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 scr eening 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 poten tial 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 th e park. Protection of vistas outside of Class I areas is not automatic, and protecti on of vistas outside of Class II areas is

uncommon.
The relevant visibility parameters are “appa rent contrast” and “delta E,” which can be computed by the screening vi sibility model VISCREEN. Th e significance thresholds for these two visibility parameters, used as si gnificance criteria in th e Class II screening analysis, are the Class I area thresholds (i .e., 0.05 and 2.00 for appa rent contrast and delta E, respectively) increased by the ratio of the PSD Class II PM 10 increment to the PSD Class I PM 10 increment (i.e., 30 μg/m 3 divided by 8 μg/m 3 ). As shown in Table 4-1, the Class II significance thresholds are an appa rent 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 PM 10 increment to Class I PM 10 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 protec tion of Class II areas can be achieved using BACT requirements; (c) the results of the visibility analys is 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 0.05 b 0.19 c

Delta E 1 hour a

/(-) NA NA 2.00 b 7.50 c

PM 10 24 hours/ (μg/m 3 ) 8 d 30 d 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 PM 10 PSD increments.
d These maximum allowable increases are found in th e 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 analys is in that its purpose is to estimate impacts during worst-case meteor ological conditions; however, more specific information regarding the s ource, topography, regional visu al range, and meteorological conditions is assumed to be available. The analysis may be performed with the aid of hand calculations, reference tables and fi gures, VISCREEN, or a computer-based visibility model called “PLUVUE II.”

If the Levels 1 and 2 screening analyses indicat e 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 anal ysis, 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 we re 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 conducte d 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 de scribed 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 wo rst-case project emissions and dispersion conditions, the project’s potenti al visibility impacts inside Class II areas are below the Class I thresholds for significance. Impact s on views outside the Cl ass 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 th e stringent visibility protection standards applicable to Class I areas, no further analysis is required.-11- Table 4-3 PPEC Impacts on Visibility in Clevel and National Forest (Worst Case) Background Ozone:0.04 ppm Emission Density Diameter Background Visual Range: 95 km b 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 km b 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, ambi ent concentrations of criteria pollutants below the secondary NAAQS will not result in harmful effe cts because the secondary NAAQS are set to protect public welfare, incl uding 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: Se ction 5.6 – Biological Resources. This section is incorporated by referen ce into the PSD permit application.

EPA provided guidance * in 1980 to determine if maximum modeled ground-level concentrations of project-emitted criteria pollutants NO 2 , SO 2 , 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/m 3 ) Modeled Maximum Concentrations b (μg/m 3 ) Averaging time
SO 2 1-Hour 917 6 1 hour
SO 2 3-Hour 786 3 3 hour
SO 2 Annual 18 <0.1 Annual
NO 2 4-Hours 3,760 111 1 hour
NO 2 1-Month 564 111 1 hour
NO 2 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-si gnificant potential growth-i nducing 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 facilitie s, and a third privately run detention facility has been proposed nearby. Th erefore, 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 COMP LIANCE WITH NAAQS

The worst-case modeling analysis, in whic h maximum project impacts were added to maximum measured background concentratio ns, demonstrated compliance with all ambient air quality standards ex cept for the federal 1-hour NO 2 standard and the federal 24-hour PM 2.5 standard (see Appendix G-4 of the AFC; note that some tables were amended in the AFC supplement). A more refi ned analysis that more closely matches the actual ambient concentrati ons with the modeled proj ect 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 refine d 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 th at protocol has been, for th e 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 th e list of stationary sources to be included in the cumulative imp act portion of the analys is. The proposed list of sources, and the basis for thei r 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 NO 2 

### Standard

7.1.1 Form of the Standard

The federal 1-hour NO 2 standard is met if the 3-year average of the 98th percentile highest daily 1-hour average NO 2 concentration, including background, does not exceed 100 ppb. At standard temper ature and pressure, this is equivalent to 188 μg/m 3 . The standard is converted to μg/m 3 for the analysis because the modeling results are in those units.

The procedure for determining compliance is to determine the highest 1-hour NO 2 concentration, including background, for each cale ndar 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 da ta set) is selected to represent that year for that receptor. Thes e 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/m 3 for all receptors.

7.1.2 Compliance Demonstration Procedure

The output from the dispersion model provides th e worst-case project impact at all of the receptors in the impact area (the area wh ere 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). Recep tors outside the impact area are excluded from the analysis because the project imp act cannot, by definition, cause or contribute significantly to a violat ion of the standard if the projec t 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 a ssumes that the project will be operating under its worst case conditions (i.e., all three tu rbines in simultaneous startup, for NO 2 ) 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 extr emely unlikely, that such operation will line up with each of the 8 highest background hours during the year.

The ambient background NO 2 concentration for each hour is then added to the modeled impact at each receptor. The ambient b ackground concentration is comprised of two components: regional background and n earby sources. The regional background concentration is developed from ambient meas urements at a nearby monitoring station or stations. Nearby sources are those that have the potential to create significant concentration gradients in the significan t impact area, creating locally elevated concentrations that are not adequately re flected in the ambient monitoring data.

Once the modeled impact for each hour has been added to the corresponding ambient background concentration, the highest combin ed 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 fr om the other years in the analysis to determine compliance with the ambient air quality standard.

The final step of the significant contri bution 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 NO 2 standard. Following EPA guidance, the interim SIL value of 4 ppb (7.5 μg/m 3 ) was used for this analysis. † “[W]e deem it appropriate and acceptable in most cas es 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 gr id 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 NO 2 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 98 th 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 98 th 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 8 th highest (98 th percentile), continuing down the ranked distribution until the cumulative impact is be low 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 co ncentrations 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 mont h, a composite daily background profile has been used. The com posite daily background profile for a given calendar month is comprised of the highest ambient monitor NO 2 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 we bsite. Ambient air concentrations of ozone (O 3 ), NO 2 , SO 2 , CO, PM 10 , and PM 2.5 are recorded at monitoring stations throughout San Diego County. The immediate ar ea 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 sout h (Tijuana), 5 miles west (Otay Mesa West), and northwest (Sunbowl) are urban or suburba n 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 loca ted in urban areas. The monitoring stations were generally pos itioned to represent area-wide ambient conditions rather than the localized impacts of any particular emissi on source or group of sources. In rural areas of the county, polluta nt 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 populat ed areas of greater San Diego than in the rest of the county.

The closest air quality monitori ng station to the Project is lo cated in Otay Mesa at the Otay Mesa-Paseo International Border crossi ng 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 vehi cles 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 NO 2 Ambient Air Quality Standard,” March 1, 2011, p. 18-19.-18- point of Otay Mesa-Paseo Inte rnational, 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 PM 10 data collected at the two monitors * shows that maximum PM 10 concentrations at the border station are about twice as high as maximum con centrations at the alternate site. The border trucks impact all combustion pollutant meas urements at the Otay Mesa monitor, not just PM 10
. The San Diego - Overland Street and Sa n 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 thes e monitoring stations are not representative of the greater Lower Otay Lake area.

Therefore, after consultation with the Dist rict, data from the Chula Vista monitoring station located at 80 East J Street, approxima tely 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 repl aced by the District using data substitution procedures consistent with EPA guidance. Da ta substitution ensures that there will be no gaps in the data. This prevents exclus ion of modeled high impact hours because of missing monitoring data.

Nearby Sources

Identification of non-project s ources to be included in characterization of background concentrations for the compliance demonstrati on begins by developing a list of facilities with emissions above a threshold. The threshol d that is selected fo r this purpose is low enough to ensure that potentially signi ficant sources are not overlooked. The geographical area included in the search is large enough to ensure th at sources that may have a significant impact anywhere in the pr oject’s impact area are identified. The most distant receptor with a signifi cant project impact was 24 km east of the project site.

The District was asked to provide a list of all stationary s ources within the District and within 80 km of the project (approximate distan ce to the farthest significant impact plus 50 km), with actual emissions a bove 5 TPY of either NOx or PM 10
. † The District was also asked to provide a list of all new projects with recentl y issued permits (i.e., after January 1, 2005) or recently submitted appli cations and a potential to emit above 5 TPY NOx or PM 10. Because the District’s database co uld not determine whether a source was

* CARB ADAM database, accessed November 28, 2010. Because the Otay Mesa-Richard Correctional Facility monitor collects only PM 10 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 PM 10 are more complete than for PM 2.5 . Because PM 2.5 is a subset of PM 10 , the list of facilities generated by a PM 10 threshold will be more extensive, and completely overlap, the list of facilities that would have been generated using a PM 2.5 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 loca tion and relative strength of NO 2 sources near the project. Also shown are the si te of the meteorological monitor, the site of the ambient air quality monitor, the impact area for 1-hour NO 2 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 whic h 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 wa ste-to-energy facility 9.2 km west of the project site); and NOx and PM 2.5 emissions from Otay Me sa Generating Company (a power plant located adjacent to the project site). These faci lities are all large enough and close enough to the project site to have the potential to di rectly impact the project’s significant impact area. Additionally, the ener gy 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 proj ect and regional back ground, but no non-project sources, indicated that the project wo uld raise the design value only 3 μg/m 3 , from 153 μg/m 3 to 156 μg/m 3

. * In order to result in a vi olation, a non-project source (or combination of non-project sources ) would therefore have to have an impact of more than 32 μg/m 3 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 NO 2 , daily for PM 2.5 ), 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 proj ect impact area at the same time.

Described below are the factors taken into ac count 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 projec t location in most cases.”

 Size : In order to affect the analysis, the candi date 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 re flected 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 NO 2 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 Tabl e 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 ex cluded 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 NO 2 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 th e project is 70/24 TPY/km, or 2.9. * This ratio was used as a rough screening tool for estimating the im pact 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 give n 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 si gnificant impact for short-term standards (e.g., hourly NO 2 ) 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 emissi ons 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 dete rmine if there was a likelihood that shortterm emission rates would be much hi gher 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 PM 10 emissions. However, the PM 2.5 fraction of fugitive dust emissions is low (on the order of 20% of PM 10 ). If the PM 2.5 emissions are estimated by adjusting total PM 10, the emission-to-distance ratio falls below the screening level. Furthermore, PM 2.5 from fugitive dust would be expected to settle out close to the so urce, when compared with combustion PM 2.5 emitted from a hot stack. Finally, the rati o 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 PM 2.5 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 occu r 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 f acility will have a significant impact on concentrations in the PPEC significant impact area.

 Dynegy South Bay – This facility is in the pr ocess of being decommissioned, and ceased operation on December 31, 2010.

The next step in the compliance demonstrati on is to include the modeled impacts at all receptors in the significant impact area fr om the nearby sources identified above in background impacts for the compliance demonstra tion. This step will be performed after EPA has reviewed and approved the list of ne arby sources to incl ude in the analysis.



### 7.2 Compliance with the Federal 24-hour PM 2.5 

### Standard

7.2.1 Form of the Standard

The federal 24-hour PM 2.5 standard is met if the three-y ear average of the 98th percentile daily 24-hour average PM 2.5 concentration, including background, does not exceed 35 μg/m 3

. The procedure for determining complia nce is to determine the 24-hour PM 2.5 concentration, including background, for each cale ndar 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 comple te data set) is selected to represent that year. These values are then averaged over th e three years included in the analysis. The resulting average must be le ss than or equal to 35 μg/m 3

.

7.2.2 Compliance Demonstration Procedure

The output from the dispersion model provides th e worst-case project impact at all of the receptors in the impact area (the area wh ere 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 bac kground 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 w ith 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 NO 2 , as well as the discussions in Section 5.2 of the AFC and in the modeling protocol, for more informa tion 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 proj ect and regional back ground, but no non-project sources, indicated that the project wo uld raise the design value only 0.1 μg/m 3 , from 25.8 μg/m 3 to 25.9 μg/m 3

. * 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/m 3 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 PM 2.5 ), a non-project source would need to be on the same (windward) side of the proj ect 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 loca tion and relative strength of PM 2.5 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 PM 2.5 standard, and a wind rose for the area.

* AFC Addendum, Table G-7.2.-26- Figure 7-3 PM 2.5 Stationary Sources in Near Vicinity (within 10 km) of PPEC-27- Figure 7-4 PM 2.5 Stationary Sources in Vici nity (within 50 km) of PPEC-28- The same emission/distance ratio of 2.9, derived from NO 2 impacts, was used for initial screening of PM 2.5 sources. This conservative approach was taken because it simplifies the screening process. It avoids the need to account for the contri bution that noncombustion sources make to project impacts, and it makes little difference in the number of sources that will be incl uded in the cumulative impact an alysis. Special factors taken into consideration for incl usion or exclusion of PM 2.5 sources are described above in Section 8.1.2.

7.2.3 Compliance Demonstration Results

The next step in the compliance demonstrati on is to include the modeled impacts at all receptors in the significant impact area fr om the nearby sources identified above in background impacts for the compliance demonstra tion. This step will be performed after EPA has reviewed and approved the list of ne arby sources to incl ude 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) PM 10 Emissions

(TPY) Emission/ Distance

Ratio (NOx) Emission/ Distance

Ratio (PM 2.5 ) 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 (PM 2.5 )

55. Pacific Recovery Corp Electricity Generation 9.2 44.6 15.5 4.8 1.7 NOx Emissionto-distance ratio (PM 2.5 ) 63. Otay Mesa Generating Company a Power 0.1 100 99.5 1000.0 995.0 NOx, PM 2.5

1. Otay Landfill Inc. Landfill 9.0 20.7 187.5 2.3 20.8 Fugitive Dust Source b

2. Sycamore Landfill Inc. Landfill 33.6 9.5 418.5 0.3 12.5 Fugitive Dust Source b

3. Hanson Aggregates – 7 th & 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) PM 10 Emissions

(TPY) Emission/ Distance

Ratio (NOx) Emission/ Distance

Ratio (PM 2.5 ) 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) PM 10 Emissions

(TPY) Emission/ Distance

Ratio (NOx) Emission/ Distance

Ratio (PM 2.5 ) 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) PM 10 Emissions

(TPY) Emission/ Distance

Ratio (NOx) Emission/ Distance

Ratio (PM 2.5 ) 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 – 3 rd 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) PM 10 Emissions

(TPY) Emission/ Distance

Ratio (NOx) Emission/ Distance

Ratio (PM 2.5 ) 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.