### January 5, 2012

Mr. Gerardo Rios

Chief, Permits Office

U.S. EPA Region 9

75 Hawthorne Street

San Francisco, CA 94105

Subject: Pio Pico Energy Ce nter PSD Permit Application

Modeling Questions

Dear Mr. Rios:

As requested by EPA in the December 9, 2011 meeting between representatives of EPA

and Pio Pico Energy Center, LLC (Applicant), we are herein submitting additional

information on behalf of Applicant. Specifi cally, EPA requested additional analysis and

information to support the modeling performed for the Pio Pico PSD Permit Application.

It should be noted that Applicant submitted the proposed modeling protocol for the Pio

Pico Energy Center (Project) to EPA on D ecember 1, 2010, with a request for review and

comment, consistent with EPA’s policy en couraging early consultation on modeling

issues. 1 

### EPA did not respond to Appl icant’s request. In the ab sence of any questions or

concern expressed by EPA regarding the protocol, the Applicant proceeded with

modeling and analysis consistent with the pr otocol, and has expended considerable time

and effort in reliance on EPA’s tacit approval.



## Data Substitution

Comment : Provide tables showing the measured data (prior to data substitution).

Response: The requested information has been pr epared by the San Diego Air Pollution

Control District (District), and is included on the enclosed disk.



## Meteorological Data

Comment : Justify the use of Otay Mesa meteorologi cal data to characterize conditions

in the project area.

1 Appendix W, Section 10.2.1: “[e]very effort should be made by the Regional Office to meet with all

parties involved in a SIP revision or a PSD permit a pplication prior to the start of any work on such a

project. During this meeting, a protocol should be established between the preparing and reviewing parties

to define the procedures to be followed, the data to be collected, the model to be used, and the analysis of

the source and concentration data.” 

# sierra

research

1801 J Street

Sacramento, CA 95811

Tel: (916) 444-6666

Fax: (916) 444-8373

Ann Arbor, MI

Tel: (734) 761-6666

Fax: (734) 761-6755

### Gerardo Rios -2- January 5, 2012

Response: The following discussion is based on criteria described in Section 3.1

(Representativeness) in EPA’s Meteorol ogical Monitoring Guidance for Regulatory

Modeling Applications (February 2000).

The guidance states that “Repre sentativeness has been defined as ‘the extent to which a

set of measurements taken in a space-time domain reflects the act ual conditions in the

same or different space-time domain ta ken on a scale appropriate for a specific

application.’” The guidance indicates th at “a quantitative met hod does not exist for

determining representativeness ab solutely.” There are no generally accepted analytical or

statistical techniques to determine repres entativeness of meteorological data or

monitoring sites.

In general, for use in air quality modeling applications, meteorologi cal data should be

representative of conditions affecting the transport and di spersion of pollutants in the

“area of interest” as determined by the locations of the sources and receptors being

modeled. For this project, the “area of interest” includes the project site and the

significant impact area (the area where screeni ng modeling predicts pr oject impact of any

pollutant above Significant Impact Levels).

In steady-state modeling applications, one typically focuses on the meteorological

conditions at the release height of the source or sources, or th e plume height in the case of

buoyant sources. Representativeness for st eady-state modeling applications must

necessarily be assessed in concert with the steady-state assumption that meteorological

conditions are constant within the space-time domain of the application; as typically

applied, measurements for a single location, somewhere near the source, are assumed to

apply, without change, at all po ints in the modeling domain.

As can be seen in Figure 1, the Project site , the Otay Mesa monitoring site, and Brown

Airfield, from whose meteorological monitoring station the few substituted

meteorological data were obtained, are all situ ated on the same flat mesa within three

miles of each other. The Otay Mesa monito ring site is less than two miles from the

project site. Air flow over all three locations is sufficiently identical to consider

meteorological data monitored at the Intern ational Border Crossing to represent the

meteorological conditions at the project site (see wind roses for Otay Mesa and Brown

Airfield monitoring data in Figures 2 and 3, respectively). Wind speeds at the Otay Mesa

monitoring site are somewhat slower than those at Brown Airfield, leading to more

conservative air quality concentrations com puted by AERMOD from Project emissions.

Consistency would call for site selection criteria consistent wi th the steady-state

assumption; i.e., to the extent possible, sites should perhaps be selected such that factors

that cause spatial variations in meteorologi cal conditions are inva riant over the spatial

domain of the application, whatever that mi ght be. Such factors would include surface

characteristics such as ground cover, surface roughness, the presence or absence of water

bodies, etc. Similarly, the representativeness of existing third-part y databases should be

judged, in part, by comparing the surface ch aracteristics in th e vicinity of the

meteorological monitoring site wi th the surface characteristics that generally describe the

analysis domain.

### Gerardo Rios -3- January 5, 2012

Figure 1

PPEC Project Site and Vicinity

### Gerardo Rios -4- January 5, 2012

Figure 2

Wind Rose, Otay Mesa International Border Crossing Meteorological

Monitoring Station, 2006-2008

### Gerardo Rios -5- January 5, 2012

Figure 3

Wind Rose, Brown Field Meteorological Monitoring Station, 2006-2008

### Gerardo Rios -6- January 5, 2012

The surface characteristics around the Otay Mesa meteorological station at the

International Border Crossing and the pr oject site are shown in Table 1.

Table 1: Otay Mesa Meteorological Station Surface Characteristics a



### Month Sector Alb Bo Zo b



### 1 1 0.18 1.09 0.7

2 1 0.18 1.09 0.7

3 1 0.16 0.65 0.7

4 1 0.16 0.65 0.7

5 1 0.18 0.70 0.7

6 1 0.18 0.70 0.7

7 1 0.18 0.70 0.7

8 1 0.18 0.70 0.7

9 1 0.18 0.70 0.7

10 1 0.18 1.09 0.7

11 1 0.18 1.09 0.7

12 1 0.18 1.09 0.7

Sector = 360 degrees, Alb = Albedo, Bo = Bowen Ratio, and Zo = surface roughness.

a Used in AERMET for AERMOD Air Dispersion Modeling.

b Values adjusted by SDAPCD from the AERSURFACE values of 0.2.



### Table 2: “Area of Interest” Surface Characteristics a



### Month Sector Alb Bo Zo

1 1 0.17 1.26 0.5

2 1 0.17 1.26 0.5

3 1 0.17 0.85 0.5

4 1 0.17 0.85 0.5

5 1 0.17 0.76 0.5

6 1 0.17 0.76 0.5

7 1 0.17 0.76 0.5

8 1 0.17 0.76 0.5

9 1 0.17 0.76 0.5

10 1 0.17 1.26 0.5

11 1 0.17 1.26 0.5

12 1 0.17 1.26 0.5

Sector = 360 degrees, Alb = Albedo, Bo = Bowen Ratio, and Zo = surface roughness.

a Area immediately east of project site. Values generated using AERSURFACE.

.

### Gerardo Rios -7- January 5, 2012

The data in Table 1 were developed by the District with guidan ce methodology described

in its February 3, 2011 email (see Attachment D), as follows:

The recommended approach for processing digitized land cover data to determine

the effective Bowen ratio and Albedo for input to AERMET is to average the

surface characteristics across a represen tative domain without any direction or

distance dependency. The recommended de fault domain is a 10km by 10km region

centered on the measurement site. A domai n representative of the application site

may be more appropriate for some applic ations, particularly if the majority of

sources are elevated releases.

For this project we chose to use the pr oposed Pio Pico facility location as the

center of the domain used in determina tion of the Bowen Ratios and Albedos on a

monthly basis since the propos ed facility is comprise d of elevated sources.

AERSURFACE was used for this purpose. We modify the se asonal categories for

San Diego County for input to the AERSURFACE program as follows:

o Transitional Spring: March and April

o Midsummer: May, June, July, August, September

o Autumn with unharvested cropland: October, November,

December, January, February

Since AERSUFACE currently uses a Land Use data base from 1992, and does not

take buildings in to account, we th en modified the Surface Roughness value

determined for the actual Meteorol ogical tower location (SDAPCD Otay

monitoring station), which is located appr oximately 1.8 miles SW of the proposed

facility site. The value obtained us ing AERSURFACE was approximately 0.2.

We replaced this with a Surface Roughness value of 0.7 based on a review of

aerial photos for the area. We feel that this better repr esents the vicinity of the

Meteorological tower as a light industri al and residential ar ea that includes

northern Mexico and the U.S border area. 2



### For comparison, average surface characteris tics were developed using AERSURFACE

for the 10 km by 10 km analysis domain with its western border near the project site, and

its southeast corner close to the U.S.-Mexico border (see Figure 4). This domain covers

most of the significant impact area, includi ng the areas with the highest impacts. It

therefore best represents the “area of intere st” for the project. The results are shown in

Table 2.

2 Email from Ralph DeSiena (District) to Eric Walther (Sierra Research), February 3, 2011.

### Gerardo Rios -8- January 5, 2012

Figure 4

Location of Domain Repres enting Area of Interest

for Surface Characteristic Analysis

### Gerardo Rios -9- January 5, 2012

Surface characteristics affect modeling results. 3 

### As shown in Tables 1 and 2, the albedos

for the two domains are very similar ( 0.16 - 0.18 for the Otay Mesa meteorological

station, and 0.17 for the area of interest). Th e Bowen Ratios in Table 2 are consistently

slightly higher than the Bowen Ratios in Table 1, reflecting a small difference between

surface moisture present in th e light industrial and residential area surrounding the Otay

Mesa Station and in the relatively uniform sparse desert ground cover/vegetation that

characterizes the area of in terest. The higher the Bowe n Ratio, the dryer the ground

surface, and the less late nt heat transfer contributes to overall heat flux from convective

turbulence (i.e., the more sensible heat tran sfer contributes to ove rall heat flux from

convective turbulence). Increasing this surf ace characteristic causes a small increase in

the calculated ground-level concentration. 4 

### The surface roughness difference between

0.7 and 0.5 meters in the two tables, respectively, is similar, with both values determined

to be in the same Category 2 (medium r oughness) according to the Texas Commission on

Environmental Quality. 5 

### For 35 meter stacks, the higher the surface roughness, the

higher the concentration.

In summary, the albedo for the meteorological station is essentially the same for the area

of interest; the Bowen Ratios at the meteorologi cal station are consistently lower than for

the area of interest, which would tend to lower maximum modeled concentrations; and

the surface roughness is higher at the meteorologi cal station than for the area of interest,

which would tend to increase modeled concentrations. Overall, comparison of the

surface characteristics at the meteorological monitoring site with the surface

characteristics in the area of interest supports the us e of the Otay Mesa border

station meteorological data as representative.

Using EPA guidance as a basi s, the factors listed belo w were considered in the

determination of representativeness:

 In general, the representativeness of the meteorological data used in an air

quality modeling analysis is dependent on the proximity of the meteorological

monitoring site to the “area-of-interest.” As previously indicated, the source of

the meteorological data used in this anal ysis is two miles from the project site

away with no intervening structures, hills , or water bodies that might significantly

affect meteorological conditions. Factor weighs in favor of considering the

data representative.

 Spatial representativeness of the data will almost always be adversely affected

(degraded) by increasing the distance between the sources and receptors

(increasing the size of the area-of-interest) . This is inevitable in a steady-state

3 The qualitative description of the effects of surface characteristics on modeling results are from T.G.

Grosch and R.F. Lee, “Sensitivity of the AERMOD Air Quality Model to the Selection of Land Use

Parameters,” http://www.environmentalexpert.com/Files%5C20658%5Carticles%5C4842%5Ctp_wessex99.pdf

4 Grosch and Lee. Ibid.

5 Texas Commission on Environmental Quality, “AERMOD Training,”

http://www.cabq.gov/airquality/pdf/tceqsfcroughnessguidance.pdf , accessed December 22, 2011.

### Gerardo Rios -10- January 5, 2012

model, and provides no basis for disti nguishing between one set of data and

another. Factor is neutral with regard to considering the data representative.

 Although proximity of the meteorological m onitoring site is an important factor,

representativeness is not simply a functi on of distance. In some instances, even

though meteorological data are acquired at the location of the pollutant source,

they may not correctly characterize the important atmospheric dispersion

conditions; e.g., dispersion conditions affe cting sources located on the coast are

strongly affected by off-shore air/sea boundary conditions - data collected at the

source would not always reflect these conditions. The source of meteorological

data, the project site, and the area-of-interest are all located well inland, in close

proximity to each other, and have surface ch aracteristics that are similar to each

other. Factor weighs in favor of considering the data representative.

 Representativeness is a function of the he ight of the measurement. For example,

one can expect more site-to-site variabili ty in measurements taken close to the

surface compared to measurements taken aloft. As a consequence, upper-air

measurements are generally representative of much larger spatial domains then

are surface measurements. The meteorological se nsors at the Otay Mesa

monitoring station are located at the 10 me ter (32.8 feet) stan dard height. The

sensors therefore provide wind speed, wi nd direction, and temperatures that

appropriately characterize a realistic bounda ry layer near the monitoring station

and throughout the analysis domain that includes the Project site. Factor weighs

in favor of considering the data representative.

 Factors that should be considered in selecting a monitori ng site in complex

terrain include: the aspect ratio and slope of the terrain, the ratios of terrain

height to stack height and plume hei ght, the distance of the source from the

terrain feature, and the effects of terrai n features on meteorological conditions,

especially wind speed and wind direction. The Project site is somewhat closer to

the San Ysidro Mountains to the east than is the Otay Mesa monitoring station.

The San Ysidro Mountains have maximum elevations around 2,000 feet. The

wind roses in Figures 2 and 3 and the wi nd roses for Chula Vi sta and El Cajon

contained included as Figures 1 and 2, respectively, in our December 1, 2011

letter all show the dominance of the we sterly sea breezes throughout this region

west of the mountains. The fact that the mountains are downwind of both the

Project site and the monitoring station almost all of the time assu res that effects of

the elevated terrain in the mountains on the monitored values of wind speed and

direction are likely to be simila rly minimal for both sites. Factor weighs in favor

of considering the data representative.

In summary, consideration of the factors li sted in EPA guidance on determination of the

representativeness of meteorol ogical data results in the co nclusion that the Otay Mesa

data are adequately representativ e of the area of interest for this Project. Furthermore,

any objections that might be raised concer ning the Otay Mesa da ta would be equally

applicable to data that might be collected onsite. Therefore, there is no basis for

requiring collection of onsite meteorological data.

### Gerardo Rios -11- January 5, 2012



## In-Stack NO 2 

## /NOx Ratio

Comment: Provide the documents that were used to derive the in-stack NO 2 

### NOx ratios

for the NO 2 

### modeling analysis.

Response: At the direction of the District, the NO 2 

### /NOx ratios used for PPEC in the

dispersion modeling were re vised to 13% during normal operations and 24% during

startup and commissioning. The District justified those levels in an email 6 

### to the

applicant as follows:

The tentative recommendation for normal operations is based on source tests of

four natural-gas-fired LM6000PC SPRINT turbines equipped with water

injection, SCR, and oxidation catalysts. Preliminarily, these appear to be the

closest analogue to the LMS100 as proposed for Pio Pico (i.e., aeroderivative,

simple cycle, diffusion flame combustors, same NOx controls, oxidation catalysts,

and interstage cooling—albeit with water injection for the SPRINTs). The value

is an average over the four turbines (rounded up) of the average NO2/NOx ratio

for each turbine. The average NO2/NO x ratios for the four turbines were .0393

(2 tests), .0603 (2 tests), 0.185 (1 test ), and 0.205 (1 test), respectively.

For situations when the SCR is not oper ating, the tentative ratio is based on

source tests of 11 natural-gas-fired GE Fr ame 5 turbines. These turbines all have

water injection but no other NOx cont rols and no oxidation catalyst. The

NO2/NOx ratio for these tu rbines ranges from about 0.18 to 0.285 (averaged over

7-10 source tests of each turbine).

The source tests were all at greater than 80% load.

The Pacific Recovery NO 2 

### /NOx ratio of 75% was taken fr om source test data for the

facility. The data were provided by the Dist rict to be used for this analysis (see

Attachment B). Over four test runs, average NO 2 

### /NOx ratios ranged from 55% to 75%.

For the cumulative impact analysis, the appl icant selected the most conservative average

value to characterize this source.

The Otay Mesa NO 2 

### /NOx ratio of 5% was taken from s ource test data for the Otay Mesa

facility. The data were provided by the Dist rict to be used for this analysis (see

Attachment C). The NO 2 

### /NOx ratio ranged from 4% to 6% with the duct burners, and

4% to 7% without duct burners. For the cumulative impact an alysis, the applicant

selected a round number within the range.

The NO 2 

### /NOx ratios for the small Calpeak Boarder and Larkspur units (all 10%) were

based on a conservative interpretation of data provided by the District (see

Attachment C).

6 See the December 23, 2010 email from Steve Moore to Steve Hill provided in Attachment A.

### Gerardo Rios -12- January 5, 2012



## PM BACT for Turbines

Comment: Provide the data from the Panoche Energy Center project used to

develop the proposed turbine PM BACT emission level of 5.5 lb/hr.

Response: The Panoche Energy Center source test data are summarized in Table 3.

Please note that these few source tests are not sufficient to demonstrate that the

measured emission rates are achievable under all conditions and for the lifetime of the

turbines. Furthermore, the test method used to measure PM is not very accurate at the

low levels being measured; there is considerable variability in the results. For these

reasons, the applicant has proposed a complia nce level that takes into account (a) the

vendor guarantee; (b) the emission levels demonstrated in the source tests; (c)

reasonable variability in performance that ca n be expected over the lifetime of a wellmaintained unit; and (d) the variability inherent in the source test methodology.

Taking all of the above into account, test results provide sufficient support for the

Applicant to determine that it can comply with a 5.5 lb /hr emission limit, which is

equivalent to 0.0065 lb/MMBtu measured at or near peak turbine load.

Source test reports and/or summarie s are included on the enclosed CD.Gerardo Rios -13- December 27, 2011Table 3. Panoche Energy CenterPM Emission Tests Results (lb/MMBtu)4 x 100 MW GE Model LMS100 combustion turbinesDate 5/13/2011 5/12/2011 5/11/2011 5/10/2011 5/11/2010 5/12/2010 5/18/2010 5/19/20104/30/09 -5/1/09 4/27/2009 4/23/2009 4/24/2009Unit 1 2 3 4 1 2 3 4 1 2 3 4UnitLoad100% 100% 100% 100%Run 10.00298 0.00402 0.00314 0.00184 0.00279 0.00141 0.00168 0.00249 0.002 0.005 0.012 0.002Run 20.00261 0.00192 0.00420 0.00182 0.00213 0.00107 0.00176 0.00198 0.002 0.003 0.002 0.007Run 30.00167 0.00169 0.00605 0.00185 0.00169 0.00155 0.00149 0.00310 0.004 0.001 0.002 0.006Average0.00242 0.00254 0.00446 0.00184 0.00220 0.00134 0.00164 0.00252 0.003 0.003 0.005 0.0052011 2010 2009 OverallAverage0.00282 0.00193 0.004 0.003Std Deviation0.00136 0.00060 0.003 0.002Relative StdDeviation48% 31% 78% 73%Mean plus 2 S.D0.0055 0.0031 0.0103 0.0072

## GHG BACT for Turbines

Comment: In Step 4 of the BACT analysis, Applic ant made the followi ng statement:

“A larger-capacity unit would be operated at less than optimum (full) output more

frequently than a smaller-c apacity turbine, and since gas turbine efficiency drops

rapidly at less than full l oad, this mode of operation w ould likely reduce the overall

efficiency of the combined-cycle units to be low that of the proposed simple-cycle gas

turbines.” Please provide the basis for this claim.

Response: As shown in Figure 5, turbine efficien cy drops rapidly at less than full

load. A single, high-efficiency combined-c ycle unit (such as an F-class unit in a 1x1

configuration) cannot effec tively operate through the br oad range of loads that

multiple simple-cycle units can. 7 

### Figure 5 compares the efficiency curves for the

proposed LMS100 configuration with an F-class combined cycle unit (GE S107FB).

It is important to note that while the LMS 100 configuration provide s the flexibility to

operate across the full range of loads be tween approximately 50 MW and 300 MW, it

will most likely be dispatched to operate at the more efficient loads of 100 MW, 200

MW or 300 MW.

Figure 5

Turbine Efficiency Curves

7 As designed, PPEC is capable of providing load-follo wing capability from a minimum of 50 MW up to its

full capacity of 300 MW. The GE S107FB is limited to a range of approximately 110-280 MW. The

broader range of response is an important feature of PPEC’s proposal to SDG&E. 0 2,000 4,000 6,000 8,000 10,000 12,000

0 100,000 200,000 300,000NetHeatRate,BTU(HHV)/KW‐hr

Net Power Productions, KW LMS

‐ 100 (3 turbines)

F

‐ Class Combined Cycle 1 turbine 2 turbines 3 turbines

### If you have any questions regarding this in formation, please contact the Applicant’s

representative David Jenkins at (317) 431-1004, or Gary Rubenstein or me at

(916) 444-6666.

Sincerely,

Steve Hill

cc: John McKinsey, Stoel Rives LLP

David Jenkins, Apex Power Group

Steve Moore, San Diego Ai r Pollution Control District

Attachments

Enclosure: CD

### ATTACHMENT A

December 23, 2010 Email from Steve Moore to Steve Hill1 

### Steve Hill

From: Moore, Steve <Steve.Moore@sdcounty.ca.gov>

Sent: Thursday, December 23, 2010 2:36 PM

To: Steve Hill

Cc: Eric Walther

Subject: RE: Pio Pico NO2/NOx

Follow Up Flag: Follow up

Flag Status: Completed

Expires: Sunday, December 20, 2020 12:00 AM

Steve,

The tentative recommendation for normal operations is based on source tests of four natural

‐ gas

‐ fired LM6000PC

SPRINT turbines equipped with water injection, SCR, and oxidation catalysts. Preliminarily, these appear to be the

closest analogue to the LMS100 as proposed for Pio Pico (i.e., aeroderivative, simple cycle, diffusion flame combustors,

same NO x controls, oxidation catalysts, and interstage cooling—albeit with water injection for the SPRINTs). The value is

an average over the four turbines (rounded up) of the average NO2/NOx ratio for each turbine. The average NO2/NOx

ratios for the four turbines were .0393 (2 tests), .0603 (2 tests), 0.185 (1 test), and 0.205 (1 test), respectively.

For situations when the SCR is not operating, the tentative ratio is based on source tests of 11 natural

‐ gas

‐ fired GE

Frame 5 turbines. These turbines all have water injection but no other NOx controls and no oxidation catalyst. The

NO2/NOx ratio for these tu rbines ranges from about 0.18 to 0.285 (averaged over 7

‐ 10 source tests of each turbine).

The source tests were all at greater than 80% load.

Thanks.

Steven Moore

Senior Air Pollution Control Engineer

San Diego County Air Pollution Control District

10124 Old Grove Road, San Diego, CA 92131

858-586-2750

Celebrating 50 years of air quality progress!

From: Steve Hill [mailto:SHill@sierraresearch.com]

Sent: Thursday, December 23, 2010 1:48 PM

To: Moore, Steve; Eric Walther

Cc: Gary Rubenstein

Subject: RE: Pio Pico NO2/NOx

Thank you for the guidance.2 Can you please provide the justification for using those values? We need to be able to explain to EPA the basis for any

value that we use. We can refer to San Joaquin’s published guidance for a ratio of 0.10, but have been unable to find

source test data to support a different va lue.

‐‐ Steve

From: Moore, Steve [mailto:Steve.Moore@sdcounty.ca.gov]

Sent: Thursday, December 23, 2010 1:16 PM

To: Steve Hill; Eric Walther

Subject: Pio Pico NO2/NOx

Steve & Eric,

For purposes of the AQIA in a submittal of a new or revised application for the Pio Pico Energy Center, the District

tentatively recommends the following in

‐ stack NO2/NOx ratios for the LMS100 turbine proposed for the project:

Normal Operations: 0.13

Commissioning, Startup, or any other situation when the SCR is no t fully operational: 0.24

Please be aware that the District is continuing to investigate this issue and reserves the right to change these tentative

recommendations based on reevaluation of existing information or new information.

Thanks.

Steven Moore

Senior Air Pollution Control Engineer

San Diego County Air Pollution Control District

10124 Old Grove Road, San Diego, CA 92131

858-586-2750

Celebrating 50 years of air quality progress!

### ATTACHMENT B

Pacific Recovery Test DataNO2Priority PO_NUM ID_NUMDBAEQUIP_DESCMfg Model1 40247-1 6068Pacific Recovery, OtayLandfill, Eng @1One Cooper Superior model 16SGTA pre-chamberlean burn piston engine, rated at 2650 bhp at 900rpm. Fueled with landfill gas from a landfill gascollection system consisting of 62 wells andassociated landfill gas venting system which alsosupplies fuel to engine #2.Cooper 16SGTA1 40247-2 6068Pacific Recovery, OtayLandfill, Eng #2One Cooper Superior model 16SGTA pre-chamberlean burn piston engine, rated at 2650 bhp at 900rpm. Fueled with landfill gas from a landfill gascollection system consisting of 62 wells andassociated landfill gas venting system which alsosupplies fuel to engine #1.Cooper 16SGTA1 979979-3 6068Pacific Recovery, Engine #3,Otay LandfillOne Cooper Superior model 16SGTA pre-chamberlean burn piston engine, rated at 2650 bhp at 900rpm. Fueled with landfill gas from a landfill gascollection system consisting of 62 wells andassociated landfill gas venting system which alsosupplies fuel to engine #1Cooper 16SGTA1 979979-4 6068Pacific Recovery, Engine #4,Otay LandfillOne Cooper Superior model 16SGTA pre-chamberlean burn piston engine, rated at 2650 bhp at 900rpm. Fueled with landfill gas from a landfill gascollection system consisting of 62 wells andassociated landfill gas venting system which alsosupplies fuel to engine #1Cooper 16SGTATC = TurbochargedAC = Aftercooled4DR = Timing retarded by 4 degreesDPF Diesel Particulate FilterSCR = Selective Catalytic ReductionOxCat = Oxidation CatalystLB = Lean BurnLFG = Landfill GasBHPSparkIgnitedEngineType Turbocharged Aftercooled TimingDieselParticulateFilterAdd-onNOxControlInCombutorNOxControlCO/VOCControl Fuel No. TestsAverageNOx,ppmv @15% O2AverageNO2/NOx2650 LB —— — — — — — LFG 10 56.93 54.982650 LB —— — — — — — LFG 8 59.31 55.512650 LB —— — — — — — LFG 2 23.70 74.852650 LB —— — — — — — LFG 3 30.30 56.37MaximumNO2/NOxMinimumNO2/NoxNO2/NOxStandardDeviationAverageLoad, %67.9 5.1 18.13075 97.5%71.2 6.6 20.77605 97.5%78.2 71.5 4.737615 97.4%72.3 33.8 20.08889 95.5%

### ATTACHMENT C

Turbine Test DataNO2PriorityID_NUMM_DBA PO_NUMEQUIP_DESC1 7630WILDFLOWERENERGYLP/LARKSPUR976094ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND AND THE OPTION OF ANOXIDATION CATALYST SYSTEM: UNIT 100 (WEST UNIT) THE COMBINED TOTAL ELECTRICALNOMINAL POWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDES POWER FROMUNIT 100 AND UNIT 200 IS 90 MW. 976094 EAD 01/06/03 (982160 11/04) 976138 AND 97609404/20/05 (981537 04/05) 983806 12/29/05 EAD1 7630WILDFLOWERENERGYLP/LARKSPUR976138ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND THE OPTION OF AN OXIDATIONCATALYST SYSTEM: UNIT 200 (EAST UNIT). THE COMBINED TOTAL ELECTRICAL NOMINALPOWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDING THE POWER FROM UNIT100 AND UNIT 200 IS 90 MW 976094 AND 976136 EAD 1/6/03 (982160 11/04) 979094 AND 976136EAD 4/20/05 (981537 04/20/05) 983806 EAD 12/29/051 7835CALPEAKPOWER LLC976502GAS TURBINE (49.5 MW): PRATT & WHITNEY, MODEL FT-8 (DLN), TWIN-PAC (TWO SIMPLECYCLE GAS TURBINES WITH COMMON GENERATOR AND EXHAUST), 500 MMBTU/HR TOTALHEAT INPUT, NATURAL GAS FIRED, WITH EXHAUST AIR COOLING, A PEERLESSMANUFACTURING COMPANY SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WITH AHALDOR CATALYST, AN ENGELHARD OXIDATION CATALYST SYSTEM, A CONTINUOUSEMISSION MONITORING SYSTEM (CEMS), AND CONTINUOUS PARAMETRIC MONITORS.(976502AFS11JUL2002)(978638 ALC 09/04)(983962 & 984416 EAD 6/07/07)1A 86017 CA ST OF DEPTO860159ONE(1)SOLAR CENTAUR GSC 4500COMBUSTION TURBINE MODEL GS1-CB-KA, SERIALNUMBER CG86N28; ELECTRICL GENRATOR RATED AT 2.93 MW; WASTE HEAT RECOVERY;ONE (1) COEN MODEL GDB-300 DUCT BURNER MODIFIED FOR MAXIMUM HEAT INPUT OF 16MM BTU/HR WITH A BYPASS VALVE AND SECONDARY EXHAUST, WHICH ALLOWS THEEXHAUST TO BYPASS THE DUCTBURNER/HEAT RECOVERY BOILER. APP.#910523 RLB5/25/93 (9/24/02 COMPLIANCE REQUESTED EQ. DESC. CHANGE-AFS)1A OTAY MESA ENE 978379Power Station #1 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.1A OTAY MESA ENE 978380Power Station #2 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.DB = Duct BurnerComb = Combined cycle including combined heat and power (i.e., cogeneration)Simple = simple cycleDF = Diffusion FlameLPM = Lean PremixedAero = AeroderivativeInd = IndustrialSCR = Selective Catalytic ReductionWI = Water InjectionOxCat = Oxidation Catalyst8/11/2011 7:48 PMNG & Diesel Turbine Summary1 of 3M_DBA PO_NUMEQUIP_DESCWILDFLOWERENERGYLP/LARKSPUR976094ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND AND THE OPTION OF ANOXIDATION CATALYST SYSTEM: UNIT 100 (WEST UNIT) THE COMBINED TOTAL ELECTRICALNOMINAL POWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDES POWER FROMUNIT 100 AND UNIT 200 IS 90 MW. 976094 EAD 01/06/03 (982160 11/04) 976138 AND 97609404/20/05 (981537 04/05) 983806 12/29/05 EADWILDFLOWERENERGYLP/LARKSPUR976138ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND THE OPTION OF AN OXIDATIONCATALYST SYSTEM: UNIT 200 (EAST UNIT). THE COMBINED TOTAL ELECTRICAL NOMINALPOWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDING THE POWER FROM UNIT100 AND UNIT 200 IS 90 MW 976094 AND 976136 EAD 1/6/03 (982160 11/04) 979094 AND 976136EAD 4/20/05 (981537 04/20/05) 983806 EAD 12/29/05CALPEAKPOWER LLC976502GAS TURBINE (49.5 MW): PRATT & WHITNEY, MODEL FT-8 (DLN), TWIN-PAC (TWO SIMPLECYCLE GAS TURBINES WITH COMMON GENERATOR AND EXHAUST), 500 MMBTU/HR TOTALHEAT INPUT, NATURAL GAS FIRED, WITH EXHAUST AIR COOLING, A PEERLESSMANUFACTURING COMPANY SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WITH AHALDOR CATALYST, AN ENGELHARD OXIDATION CATALYST SYSTEM, A CONTINUOUSEMISSION MONITORING SYSTEM (CEMS), AND CONTINUOUS PARAMETRIC MONITORS.(976502AFS11JUL2002)(978638 ALC 09/04)(983962 & 984416 EAD 6/07/07)CA ST OF DEPTO860159ONE(1)SOLAR CENTAUR GSC 4500COMBUSTION TURBINE MODEL GS1-CB-KA, SERIALNUMBER CG86N28; ELECTRICL GENRATOR RATED AT 2.93 MW; WASTE HEAT RECOVERY;ONE (1) COEN MODEL GDB-300 DUCT BURNER MODIFIED FOR MAXIMUM HEAT INPUT OF 16MM BTU/HR WITH A BYPASS VALVE AND SECONDARY EXHAUST, WHICH ALLOWS THEEXHAUST TO BYPASS THE DUCTBURNER/HEAT RECOVERY BOILER. APP.#910523 RLB5/25/93 (9/24/02 COMPLIANCE REQUESTED EQ. DESC. CHANGE-AFS)OTAY MESA ENE 978379Power Station #1 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.OTAY MESA ENE 978380Power Station #2 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.red cycle including combined heat and power (i.e., cogeneration)cycleamemixedativeCatalytic Reductionionn CatalystMfg Model TypeTurbineRatedPowerOutput,MWTurbineRated HeatInput(HHV),MMBtu/hr CombustorDuctBurnerDuctBurnerRatedHeatInput,MMBtuDBCombustorRatedDBHeatInput(HHV),MMBTu/hr CycleAdd-onNOxControlInCombutorNOxControlCO/VOCControlNo. TestsFired onNaturalGas withDB OnNG DB OnAverageNOx, ppmv@ 15% O2NaturalGas DBOnAverageNO2/NOxNaturalGas DBOnMaximumNO2/NOxNaturalGas DBOnMinimumNO2/NOxNaturalGas DBOnNO2/NOxStandardDeviationNaturalGas DBOnAverageLoad, %No. TestsFired onNaturalGas withDB OffNG DB OffAverageNOx, ppmv@ 15% O2NaturalGas DBOffAverageNO2/NOxNaturalGasDB OffMaximumNO2/NOxNaturalGasDB OffMinimumNO2/NOxGELM6000PCSPRINTAero 45 395 DF — — — — Simple SCR. WI — 0 N/A N/A N/A N/A N/A N/A 3 5.16 14.07 17.00 9.30GELM6000PCSPRINTAero 45 395 DF — — — — Simple SCR. WI — 0 N/A N/A N/A N/A N/A N/A 2 4.74 9.60 16.30 2.90PW FT-8 Aero 49.5 500 LPM — — — — Simple SCR. — OxCat 0 N/A N/A N/A N/A N/A N/A 2 2.93 10.52 14.60 6.43SOLARGSI-CB-KAInd 2.93DF DB 1616 Comb — WI — 5 21.50 49.64 69.60 34.10 14.85 85.35 0 N/A N/A N/A N/AGE 7FA Ind 171.7 1607.1 LPM DB 388.1 388.1 Comb SCR — — 2 1.51 5.33 6.13 4.53 1.13 130.46 2 1.55 6.97 7.33 6.60GE7FA Ind 171.7 1607.1 LPM DB 388.1 388.1 Comb SCR — — 2 1.48 4.06 4.26 3.87 0.28 128.70 1 1.46 3.87 3.87 3.878/11/2011 7:48 PMNG & Diesel Turbine Summary2 of 3M_DBA PO_NUMEQUIP_DESCWILDFLOWERENERGYLP/LARKSPUR976094ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND AND THE OPTION OF ANOXIDATION CATALYST SYSTEM: UNIT 100 (WEST UNIT) THE COMBINED TOTAL ELECTRICALNOMINAL POWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDES POWER FROMUNIT 100 AND UNIT 200 IS 90 MW. 976094 EAD 01/06/03 (982160 11/04) 976138 AND 97609404/20/05 (981537 04/05) 983806 12/29/05 EADWILDFLOWERENERGYLP/LARKSPUR976138ONE (1) GENERAL ELECTRIC 45 MW NOMINALLY RATED MODEL LM 6000 PC SPRINT SIMPLECYCLE GAS TURBINE WITH A HEAT INPUT RATING OF 395 MM BTU/HR (LHV) WHENOPERATED ON NATURAL GAS AND 398 MM BTU/HR (LHV) WHEN OPERATED ON LIQUIDFUEL, EQUIPPED WITH A WATER INJECTION SYSTEM AND CORMETECH SELECTIVECATALYTIC REDUCTION (SCR) SYSTEM INCLUDING AUTOMATIC AMMONIA INJECTIONCONTROL SYSTEM FOR CONTROL OF NOX, CONTINUOUS EMISSIONS MONITORING SYSTEM(CEMS), DATA ACQUISITION AND RECORDING SYSTEMS AND THE OPTION OF AN OXIDATIONCATALYST SYSTEM: UNIT 200 (EAST UNIT). THE COMBINED TOTAL ELECTRICAL NOMINALPOWER OUTPUT FROM THE LARKSPUR POWER PLANT, INCLUDING THE POWER FROM UNIT100 AND UNIT 200 IS 90 MW 976094 AND 976136 EAD 1/6/03 (982160 11/04) 979094 AND 976136EAD 4/20/05 (981537 04/20/05) 983806 EAD 12/29/05CALPEAKPOWER LLC976502GAS TURBINE (49.5 MW): PRATT & WHITNEY, MODEL FT-8 (DLN), TWIN-PAC (TWO SIMPLECYCLE GAS TURBINES WITH COMMON GENERATOR AND EXHAUST), 500 MMBTU/HR TOTALHEAT INPUT, NATURAL GAS FIRED, WITH EXHAUST AIR COOLING, A PEERLESSMANUFACTURING COMPANY SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WITH AHALDOR CATALYST, AN ENGELHARD OXIDATION CATALYST SYSTEM, A CONTINUOUSEMISSION MONITORING SYSTEM (CEMS), AND CONTINUOUS PARAMETRIC MONITORS.(976502AFS11JUL2002)(978638 ALC 09/04)(983962 & 984416 EAD 6/07/07)CA ST OF DEPTO860159ONE(1)SOLAR CENTAUR GSC 4500COMBUSTION TURBINE MODEL GS1-CB-KA, SERIALNUMBER CG86N28; ELECTRICL GENRATOR RATED AT 2.93 MW; WASTE HEAT RECOVERY;ONE (1) COEN MODEL GDB-300 DUCT BURNER MODIFIED FOR MAXIMUM HEAT INPUT OF 16MM BTU/HR WITH A BYPASS VALVE AND SECONDARY EXHAUST, WHICH ALLOWS THEEXHAUST TO BYPASS THE DUCTBURNER/HEAT RECOVERY BOILER. APP.#910523 RLB5/25/93 (9/24/02 COMPLIANCE REQUESTED EQ. DESC. CHANGE-AFS)OTAY MESA ENE 978379Power Station #1 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.OTAY MESA ENE 978380Power Station #2 consisting of: one Gas Turbine (171.7 MW nominal): General Electric, Model 7FA,with DLN 2.6 low-NOx burners, natural gas fired, 1607.1 MMBtu/hr nominal heat input (LHV), S/NTBD, with a heat recovery steam generator (HRSG) with a 388.1 MMBtu/hr duct burner, NooterEriksen, vented to a selective catalytic reduction (SCR) system, equipped with a continuous emissionmonitoring system (CEMS); common to both power stations are a steam turbine generator (277 MWnominal), Siemans-Westinghouse, Model KN, S/N TBD; two air-cooled condensers, GEA, 295’L x123’W x 76’H; a wet surface air cooler, Niagara Blower Co., Model RWC 48240-2F16, or equivalent;and an auxiliary boiler, 87 MMBtu/hr, with low-NOx burners.red cycle including combined heat and power (i.e., cogeneration)cycleamemixedativeCatalytic Reductionionn CatalystNaturalGasDB OffNO2/NOxStandardDeviationNaturalGasDB OffAverageLoad, %No. TestsFired onDiesel OilOilAverageNOx, ppmv@ 15% O2OilAverageNO2/NoxOilMaximumNO2/NOxOilMinimumNO2/NOxOilNO2/NOxStandardDeviationOilAverageLoad, %Notes4.16 101.41 1 11.10 5.70 5.70 5.70 #DIV/0! 98.229.48 103.11 1 12.10 2.80 2.80 2.80 #DIV/0! 100.005.77 95.96 0 N/A N/A N/A N/A N/A N/AN/A N/A 0 N/A N/A N/A N/A N/A N/A0.52 133.37 0 N/A N/A N/A N/A N/A N/A#DIV/0! 99.59 0 N/A N/A N/A N/A N/A N/A8/11/2011 7:48 PMNG & Diesel Turbine Summary3 of 3

### ATTACHMENT D

February 3, 2011 Email from Ralph DeSiena to Eric WaltherFrom: Desiena, Ralph [mailto:Ralph.Desiena@sdcounty.ca.gov]

Sent: Thursday, February 03, 2011 11:39 AM

To: Eric Walther

Cc: Moore, Steve; Reeve, Bill; Desiena, Ralph

Subject: RE: CEC request for met data on th e Pio Pico Energy Center Project

Eric,

I’m attaching the Aermet data you requested for 2004 and 2005.

Also attached is the revised 2008 data, which now includes the missing end period, a little over

one month, of that data.

In response to your request from CEC is the following:

The recommended approach for processing digitized land cover data to determine the effective

Bowen ratio and Albedo for input to AERMET is to average the surface characteristics across a

representative domain without any direction or distance dependency. The recommended

default domain is a 10km by 10km region centered on the measurement site. A domain

representative of the application site may be more appropriate for some applications,

particularly

if the majority of sources are elevated releases.

For this project we chose to use the proposed Pio Pico facility location as the center of the

domain used in determination of the Bowen Ratios and Albedos on a monthly basis since the

proposed facility is comprised of elevated sources. AERSURFACE was used for this purpose.

We modify the seasonal categories for San Diego County for input to the AERSURFACE program

as follows:

Transitional Spring: March and April

Midsummer: May, June, July, August, September

Autumn with unharvested cropland: October, November, December, January, February

Since AERSUFACE currently uses a Land Use data base from 1992, and does not take buildings in

to account, we then modified the Surface Roughness value determined for the actual

Meteorological tower location (SDAPCD Otay monitoring station), which is located

approximately 1.8 miles SW of the proposed facility site. The value obtained using AERSURFACE

was approximately 0.2. We replaced this with a Surface Roughness value of 0.7 based on a

review of aerial photos for the area. We feel that this better represents the vicinity of the

Meteorological tower as a light industrial and residential area that includes northern Mexico and

the U.S border area.

If you have any questions please let me know.

Regards,

Ralph



### Ralph DeSiena

Air Pollution Meteorologist

San Diego County Air Pollution Control

### 10124 Old Grove Rd.

San Diego, CA 92131

858-586-2772 fax 858-586-2759 

### www.sdapcd.org