AECOM 978.589.3000 tel 2 Technology Park Drive 978.589.3100 fax Westford, MA 01886-3140



# Memorandum

To enhance and sustain the world’s built, natural a nd social environments To: Scott Bohning Page 1

cc: Shirley Rivera

Subject: Final Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analyses for Palmdale

Hybrid Power Project

From:

Richard Hamel

Date: March 30, 2011

On December 14, 2010, EPA Region 9, AECOM, and Inla nd Energy dicussed the last remaining open issues related to the 1-hour NO 2 modeling analysis for the Palmdale Hybrid Power Pr oject (PHPP), which are summarized below. This memorandum provides all remaining requested information and analyses. As such, there are no open items remaining for the PSD modeling analyses for PHPP.

The PHPP application was submitted two years ago an d we have repeatedly provided updated information and analysis, as described below. This final memo resolves all outstanding data requests and analysis except for a greenhouse Best Available Control Technology (BACT) analysis, which will be provided soon. EPA has not indicated that any addi tional information or analysis are needed other tha n what is discussed in this memo. If you have any qu estions about this memorandum or the PHPP, please contact me at the contact information provided abov e. The City of Palmdale, Inland Energy and AECOM look forward to working with the EPA to complete th e PHPP permitting process as expeditiously as possible.


## I. Overview of PSD Application History and Backgrou nd

As was summarized in a prior memo provided on Decem ber 14, 2010, AECOM, on behalf of the City of Palmdale, submitted a Prevention of Significant Det erioration (PSD) permit application to EPA Region 9 for the PHPP on April 1, 2009. Some additional inf ormation was provided in response to unofficial requests. However, it was not until a conference c all between EPA and PHPP representatives in March 2010 that supplemental information was requested by EPA on several items, including the PM2.5, visibility, and growth analyses, as well as the ana lysis with respect to the 1-hour NO2 National Ambie nt Air Quality Standard (NAAQS) that became effective in April 2010. On July 21, 2010, AECOM submitted the "Palmdale Hybrid Power Project (PHPP) - Supplem ental Information for the Application for PSD Permit" in response to that conference call.

Many emails, conference calls and submittals betwee n EPA and the Applicant’s representatives have occurred since that time, all regarding the 1-hour NO 2 NAAQS analysis. Most recently, a conference call between EPA Region 9, AECOM, and Inland Energy was held on December 14, 2010 to discuss theAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 2

status of open issues related to the 1-hour NO 2 modeling analysis for the PHPP. The following pers onnel participated in the call:

• Scott Bohning – EPA Region 9

• Shirley Rivera – EPA Region 9

• Julie Walters – EPA Region 9

• Rich Hamel – AECOM

• Sara Head – AECOM

• Tom Barnett – Inland Energy, Inc.

• Michael Carroll – Latham & Watkins, LLP
On the call, the following issues and resolutions w ere reached, and the requested updated analysis is provided in this memorandum:
1. Background Data Monitor: Use of the Lancaster D ivision Street Monitor for ambient background concentrations of NO 2 was approved.
2. Missing Ozone Data Fill-in: The methodology app lied by AECOM to fill in missing ozone data was approved, though Scott Bohning of EPA requested some examples of the data filling. Those examples are included in this memo.
3. Meteorological Data Duration: Based on informat ion provided by AECOM to EPA on December 14, 2010, EPA determined that the meteorological st ation at Palmdale Regional Airport was effectively site-specific, and therefore the use of three years of meteorological data was sufficient for this application.

4. In-stack Ratio: EPA determined that AECOM had a dequately researched the subject to the point where no further action was required by AECOM, and that EPA would follow up with General Electric.
5. Time-Matched Background Data: EPA expressed con cern over the use of hourly time-matched background and meteorological data as proposed by A ECOM. Rather than extend this debate, AECOM now proposes to use the average 98 th percentile background concentration over the most recent 3-years of available data. This value is more conservative than the background value suggested in the recently (March 2011) update d EPA NO 2 NAAQS modeling guidance, which considers only the daily-maxima in the 98 th percentile calculations.
6. Source Inventory for Cumulative Analysis: AECOM has provided an updated analysis in this memo, following suggestions provided by EPA during the 12/14/10 call. While AECOM followed the approach suggested by EPA which included lookin g at sources beyond 50 kilometers (km) from the PHPP, the new guidance recommends only loo king at sources within 10 km of the project site when determining the cumulative invent ory. Hence, AECOM believes that the source inventory assessed is more than adequate to analyze sources that could cause a significant concentration gradient near the PHPP.
In addition to the updated 1-hour NO 2 NAAQS analysis, this memorandum includes updates t o the modeling based on information received from the Ant elope Valley Air Quality Management District (AVAQMD). Specifically, in December 2010, Chris An derson of AVAQMD notified AECOM that the hourly emissions provided for sources at U. S. Air Force ( USAF) Plant 42 near the proposed PHPP were mislabeled (emissions were labeled lb/hr but were a ctually in tons/hr). As a result, it was necessary to update the cumulative NAAQS modeling for both the 1 -hour NO 2 and 24-hour PM2.5 in support of the PHPP PSD Permit Application. The updated short-ter m modeling provides similar results (minor changes only) from prior submittals, continues to demonstra te that the PHPP will comply with all NAAQS, and hence did not change any of the prior conclusions. The annual emissions for both pollutants at USAF Plant 42 were correct and thus the annual modeling was not affected.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 3

This memo summarizes the revisions to the NO 2 and PM2.5 modeling due to both the changes in the NO 2 background data and cumulative inventory, as well a s to the increases in the USAF Plant 42 emissions used for the NO 2 and PM2.5 cumulative analyses. This memo provides the updated modeling results for both the 1-hour NO 2 and 24-hour PM2.5 analyses, discussing NO 2 first and then PM2.5. Because the modeling adopts EPA’s recommended modeling approach es and/or is more conservative than recent guidance, and since the modeling shows compliance w ith the 1-hour NO 2 and PM2.5 NAAQS, no further analyses should be required.


## II. Updated 1-hour NO 2 

## NAAQS Modeling Analysis

As noted above, the updated NO 2 NAAQS Modeling Analysis presented herein addresses the remaining three of EPA’s requests: A) to provide examples of the ozone data fill-in procedures; B) to update the NO 2 background values; and C) to consider additional so urces for the cumulative source inventory. Also, t his updated modeling includes corrected hourly emission rates and other refinements associated with the USAF Plant 42 sources.

On March 1 st , 2011, EPA issued additional guidance regarding th e modeling of the 1-hour NO 2 NAAQS 1

. Although the modeling performed for this memo was c ompleted prior to the issuance of the updated guidance, a review of the new information shows tha t the methodologies that form the basis of this revised modeling are at least as conservative as th e approaches described in the guidance, and in some cases are more conservative. As a result, AECOM’s opinion is that there is no need to revise the analyses presented herein with respect to that guid ance. However, we have pointed out some of the applicable differences where appropriate.



### A. Example of Methodology Used in Filling Missing O zone Data

The proposed method for filling missing hourly ozon e data, which was accepted by EPA during the conference call on 12/14/10, was described in the Response to EPA Additional Comments on AECOM’s 1-hour NO

2 NAAQS Analysis for Palmdale Hybrid Power Project, submitted by AECOM to EPA on 12/14/10. Examples of the filling methodology used are provided below. As established in the earlier memo, the methodology used to fill missing ozone da ta was as follows:

• Where only 1 or 2 hours of data were missing, the higher of the two endpoints was persisted across the missing hours.

• Where 3 or more hours were missing, the higher of the following was persisted across all hours in the missing period:

o The higher of the two endpoints, or;

o The highest value from any hour in the missing per iod from the day before or after the day on which the missing hours occurred.

In the 3 years of hourly ozone data (26,304 hours), there were 23 instances where 3 or more hours were missing and the approach described in the 2 nd bullet above was used to fill the missing data. O f those 23 instances, 17 were blocks of less than 10 missing h ours. Tables 1 and 2 provide examples of the two methods for data filling when 3 or more hours are m issing. In Table 1, an example in which one of the two missing endpoints was the highest value between either the endpoints or any of the hours matching the missing hours during the previous or next day i s shown. In Table 2, an example in which one of th e concurrent hours from the previous or next day was the highest ozone concentration is shown. The

1 http://www.epa.gov/ttn/scram/Additional_Clarificat ions_AppendixW_Hourly-NO2-NAAQS_FINAL_03-01-2011.pd fAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 4

spreadsheet PHPP Ozone Filling Analysis.xls containing all of the calculations used in filling the missing ozone data is included in Attachment A to this memo

.

In Table 1, ozone concentration data from 7/15/03 w ere missing from hours 10 through 13. Hours 9 and 14 (the endpoints) from that day, along with hours 10 through 13 on the previous and next days were considered. In this case, hour 14 on 7/15/03, one of the endpoints, had the highest monitored ozone concentration of 104 ppb. Thus, the four missing h ours were all filled with 104 ppb.



### Table 1: Example of Ozone Data Filling Where Endpoi nt is the Highest Value (ppb)

Hour Previous

Day Missing

Day Next Day Filled Value

9 64 55 74 N/A

10 63 -9999 74 104

11 62 -9999 74 104

12 74 -9999 82 104

13 84 -9999 82 104

14 100 104 74 N/A

In Table 2, ozone concentration data from 3/2/02 we re missing for hours 10 through 18. Hours 9 and 19 (the endpoints) from that day, along with hours 10 through 18 on the previous and next days were considered. In this case, hours 14 and 15 on 3/1/0 2 had the highest monitored ozone concentrations, o f 48 ppb. Thus, all of the nine missing hours were f illed with 48 ppb.



### Table 2: Example of Ozone Data Filling Where Previo us or Next Day Provides the Highest Value (ppb)

Hour Previous

Day Missing

Day Next Day Filled Value

9 10 5 36 N/A

10 19 -9999 38 48

11 30 -9999 41 48

12 42 -9999 35 48

13 42 -9999 37 48

14 48 -9999 41 48

15 48 -9999 36 48

16 45 -9999 30 48

17 44 -9999 26 48

18 30 -9999 22 48

19 10 35 22 N/A



### B. Ambient Background Concentration
The prior NO 2 NAAQS modeling submitted by AECOM for PHPP had pai red the modeled concentrations with a background value that corresponded to the NO 2 concentration measured in the same hour as the hourly meteorological conditions that produced the modeled result. EPA has indicated that it isAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 5

uncomfortable with the notion of time-matching ambi ent background concentrations with modeled concentrations on an hourly basis on the grounds th at the practice may not be sufficiently conservativ e, and requested the use of a background that was base d on a longer averaging time, related to the applicable meteorological conditions present at the project site. AECOM disagrees that the use of hou rly time-matched background is inappropriate and again points out that the background concentration cannot be more closely associated with the meteorological conditions that contribute to that background value than using the actual meteorological conditions tha t were occurring during that specific hour.

Nonetheless, AECOM researched the possibility of us ing values by season, month, or the average of hourly values for each of the 24 hours of the day f or the ambient background, but found that none of these options worked in the analysis. The maximum N O 2 concentrations that are measured at the Lancaster Division Street Monitor occur during the morning and evening commutes on almost a daily basis. As documented in the response to comment #2 in Response to EPA Additional Comments on AECOM 1-hour NO 2 NAAQS Analysis for Palmdale Hybrid Power Project submitted on 12/14/10, the emissions that create these elevated background con centrations are not present at the project site and thus the background concentrations recorded at the Division Street Monitor are overly conservative.

Rather than attempt to define a longer period for t he time-matched methodology for the application of background concentration, AECOM instead chose an ap proach tied directly to the form of the standard, i.e., the average of the 98 th percentile over a 3-year period was used as the ba ckground concentration, as described in EPA’s Applicability of Appendix W Modeling Guidance for t he 1-hour NO

2 National Air Quality Standard (June 28, 2010)

.
The March 1, 2011 EPA guidance memo, on page 17, in dicated that a new 1 st -tier assumption regarding background should be acceptable:

“Based on these considerations, we believe that a l ess conservative “first tier” for a uniform monitored background contribution based on the moni tored design value from a representative monitor should be acceptable in most cases. The mon itored NO 2 design value, i.e., the 98thpercentile of the annual distribution of daily maxi mum 1-hour values averaged across the most recent three years of monitored data, should be use d irrespective of the meteorological data period used in the dispersion modeling.”

The 3-year period selected for the PHPP modeling wa s the most recent three years where data are available (2007-2009) at the Lancaster station. Th is selection for a background value remains a conservative estimate of the background because the increased NO 2 concentrations caused by commute traffic and trains in the vicinity of the monitor b ut far from the project site are still present, and the 98 th percentile background includes all hours, not just the daily maxima as described in the form of the standard and the recently updated modeling guidance . The resultant background value that was added to the modeled impacts, as shown in Table 3, is 77. 1 μ g/m 3 . The calculation of this value is shown in the spreadsheet Background Data Analysis.xlsx included in Attachment A.



### Table 3: Lancaster Division Street Monitor 1-hour N O 2 

### Annual 98 th 

### Percentile Concentrations ( μ g/m 3 

### ) from 2007 – 2009

2007 2008 2009 3-year Average

80.88 77.12 73.36 77.1AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 6



### C. Selection of Cumulative Non-Project Sources of N O 2

During the conference call on 12/14/10, EPA request ed further analysis of sources in the vicinity of P HPP to determine whether there were additional sources of NO x emissions in the region that could potentially cause a significant concentration gradient near PHP P. On 12/20/10, AECOM contacted Antelope Valley Air Quality Management District (AVAQMD) and reques ted an inventory of all permitted sources of NO x emissions within 60 km of PHPP (note that the new E PA guidance issued on 3/1/11 suggests that only sources within 10 km need be considered for inclusi on in the cumulative modeling). From that inventor y, AECOM extracted all facilities with emissions great er than 20 tons per year (tpy) of NO x . The locations of these facilities relative to PHPP are shown in Figu re 1.

Also during the call, EPA recommended a “Q/D analys is” of sources in the region to screen out sources too distant to have an impact near PHPP based on th eir emission rates. A Q/D analysis is an approach used to quantify the source strength as a function of the amount of emissions from a source and the distance between that source and the project source s. This methodology determines if sources in the area are close enough to the project to have an imp act on the modeling results. This screening is accomplished by creating a ratio of emissions to di stance, and then determining whether each nonproject source is within the distance specified by the Q/D formula. If it is, the source is close eno ugh to contribute to modeled concentrations near the propo sed project. If not, the source is “screened out” and removed from consideration. Although EPA suggested that a Q/D analysis be used to screen non-project sources, no specific Q/D formula was provided or su ggested by EPA.

To the list of sources provided by AVAQMD, AECOM ap plied the Q/D “ Screening Method for PSD ” developed by the North Carolina Air Quality Section of the North Carolina Department of Natural Resources (NCDNR). A copy of the North Carolina le tter which described this Q/D approach is included in Attachment B. This Q/D methodology uses the fol lowing formula to screen out sources that are not expected to contribute to the air concentrations ne ar the subject of the modeling analysis:

Q = 20D

Where Q = the source’s maximum NO x emissions in tpy.
The NCDNR letter defines D as the distance (in kilo meters) from “the source in the screening area to t he PSD source defining the impact area, for short term analysis”.

Rearranging the formula to solve for D yields:

D = Q/20.

Sources that are farther from the PSD source than t he calculated value for D are excluded from the modeling analysis, while those closer must be inclu ded. Table 4 shows the sources included in the AVAQMD inventory that have emissions greater than 2 0 tpy, the resulting value of D, and their distance from PHPP. As seen in Table 4, only the USAF Plant 42 sources are closer than their respective values of D and therefore are recommended for inclusion in the cumulative modeling analysis. Per AVAQMD, the Bolthouse Farms emission sources are mobile and widely distributed amongst several agricultural areas in the Antelope Valley, with the majority of the emissions occurring in the eastern part of the valley near Lake Los Angeles, a point over 20 km from PHPP . Because of the distributed nature of these sources, the distance from PHPP to most of the loca tions where the emissions occur, and the fact that these emissions all occur to the east, or downwind of the prevailing wind direction from PHPP, Bolthou se Farms was not included in the modeling. As a resul t, only the USAF Plant 42 sources (Lockheed and Northrop) were included in the cumulative modeling in addition to the PHPP sources. The email from AVAQMD regarding Bolthouse Farms is included in Att achment C.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 7



### D. USAF Plant 42 Sources and Boundary

The USAF Plant 42 sources were included in the prev ious PHPP cumulative 1-hour NO 2 modeling analysis submitted by AECOM to EPA on October 7, 20 10. However, in December 2010, Chris Anderson of AVAQMD notified AECOM via email that the emissio ns provided for the USAF Plant 42 sources were mislabeled (emissions were labeled lb/hr but were a ctually in tons/hr), requiring new modeling with th e revised emissions. Prior AECOM modeling analyses h ad conservatively combined the emissions into fewer sources to simplify and facilitate the model runs. However, due to the significantly higher emi ssion rates with the corrected units, for this updated mo deling it was decided to model each source in its c orrect location rather than use the condensed source metho dology that had been previously applied. There are a total of 53 permitted emission sources at USAF Pl ant 42, 36 at Lockheed-Martin and 17 at Northrop Grumman. The characteristics and emissions of each source are given in Table 5 (volume sources) and Table 6 (point sources).

A further review of the USAF Plant 42 sources showe d that of the 53 sources, 32 are emergency engines, either providing power in the case of emergency or powering fire pumps in the case of a fire. The EPA guidance memo goes into great detail (pages 8 and 9 ) discussing the problems associated with sources that operate only intermittently being modeled agai nst a probabilistic (e.g., 98 th percentile) standard such as the new 1-hour NO 2 NAAQS, eventually concluding:

“For the reasons discussed above, EPA believes the most appropriate data to use for compliance demonstrations for the 1-hour NO 2 NAAQS are those based on emissions scenarios that are continuous enough or frequent enough to contribute significantly to the annual distribution of daily maximum 1-hour concentrations.”

Despite the discussion above that would likely elim inate the need to model the emergency engines at USAF Plant 42 (along with other intermittent source s such as the test jet stand) completely, and despi te the fact that no more than a handful of these sourc es would be tested at any given time, the PHPP cumulative modeling (that was completed prior to th e release of the new EPA guidance) takes the extremely conservative step of not only including t he PHPP emergency sources as well as all of the USAF Plant 42 sources, but also assumes that these engines are being tested simultaneously, and therefore all 32 of them are modeled as if a full h our of emissions occurred in the same hour. It was also assumed that testing would occur during the daytime anytime in a 12 hour window (6 am – 6 pm) on any single day. Given that the majority of these source s are limited by permit to 20 hours testing per yea r, and testing typically occurs only once every week for l ess than one hour, modeling a full hour of operatio ns during any of 12 hours in the day remains a very co nservative assumption.

In addition to updated emissions from USAF Plant 42 , AECOM also revisited the fence line receptors to be used for the USAF Plant 42. AECOM requested and received from AVAQMD in January 2011 a figure depicting the fence line of USAF Plant 42. Prior m odeling had assumed receptor locations within the USAF Plant 42 property, but since USAF Plant 42 is a fenced, secure area without public access, the area within the fence line would not be considered to be ambient air with respect to USAF Plant 42 sources (EPA memo from Joseph Tikvart, 1/21/86). T he updated fence line used in this cumulative analysis is shown in Figure 2, and a copy of the em ail from AVAQMD is included in Attachment C.AECOMUpdate to 1-hour NO2and 24-hour PM2.5 NAAQS Analysis for PHPPMarch 20118Table 4: Sources Considered for Inclusion in PHPP 1-hour Cumulative NO2 ModelingFacility NameStreet CityNOx(tpy)Lat LongDistance(miles)Distance(km)Q/20USAF Plant 421Palmdale 22.5 34.638 -118.100 0.25 0.40 1.13Calmat Co. DBA VulcanMaterialsEast Ave T Little Rock 43.3 34.543 -118.014 8.49 13.66 2.17Vulcan Materials Co.155th and Hwy 138PearblossomLlano 25.3 34.506 -117.853 17.07 27.48 1.26Granite Construction Co. East Ave T Little Rock 21.7 34.543 -118.010 8.66 13.93 1.08Holliday Rock Company East Ave T Palmdale 35.9 34.543 -117.993 9.29 14.96 1.80Mtn. High Ski Area East Hwy 2 Wrightwood 21.3 34.377 -117.692 29.76 47.89 1.07Mtn. High Ski Area West Big Pines Hwy Wrightwood 23.8 34.384 -117.706 28.83 46.39 1.19Lancaster Landfill East Ave F Lancaster 43.5 34.748-118.120 7.51 12.09 2.18Antelope Valley Recycling West City Ranch Rd. Palmdale 56.1 34.570 -118.150 5.45 8.77 2.81Bolthouse Farms2District Wide Lancaster 136.1 varies Varies 2.8-164.5-25 6.811. Consists of both the Lockheed-Martin and Northrop-Grumman sources.2. Bolthouse Farms emissions are from mobile sources widely distributed across Antelope Valley agricultural sites. Per Chris Anderson of AVAQMD, the majorityof these emissions occur in the eastern part of thevalley near Lake Los Angeles, a distance of more than 20 km from PHPP.Table 5: USAF Plant 42 Volume Source ParametersSource ID FacilityUTM Easting(NAD27)UTM Northing(NAD27)Base Elev.(m)Rel. Hgt.(m)Sigma-Y Sigma-ZNOX(lb/hr)NOX(g/s)S024 Lockheed 398081.6 3830683.0 746.8 3.05 222.491.86 4.10 0.517S048 Lockheed 399992.6 3831386.0 746.8 5.80 1.21 6.98 0.94 0.118AECOMUpdate to 1-hour NO2and 24-hour PM2.5 NAAQS Analysis for PHPPMarch 20119Table 6: USAF Plant 42 Point Source ParametersSource ID FacilityUTM Easting(NAD27)UTM Northing(NAD27)BaseElev.(m)StackHgt.(m)Temp(°K)ExitVel.(m/s)Exit.Diam.(m)NOX(lb/hr)NOX(g/s)S066 Lockheed 400264.6 3833225.0 746.8 2.6 505.4 4.3 1.68 0.37 0.047S067 Lockheed 400236.6 3833225.0 746.8 3.1 505.4 4.3 1.68 0.35 0.044S068 Lockheed 400230.5 3833236.0 746.8 16.8 883.2 90.0 0.10 3.87 0.488S070 Lockheed 400595.6 3833212.0 746.8 1.5 783.2 69.9 0.08 3.21 0.405S071 Lockheed 400244.6 3833417.0 746.8 1.8 835.9 44.6 0.10 3.81 0.480S072 Lockheed 397548.7 3830488.0 746.8 0.5 713.7 51.3 0.25 15.90 2.003S073 Lockheed 397548.6 3830677.0 746.8 3.0 713.7 51.3 0.25 15.90 2.003S074 Lockheed 397469.6 3831064.0 746.8 3.0 713.7 35.5 0.20 5.81 0.732S075 Lockheed 398078.7 3830369.0 746.8 3.1 505.4 22.8 1.22 0.46 0.058S076 Lockheed 398040.7 3830366.0 746.8 2.6 505.4 21.6 1.22 2.02 0.254S077 Lockheed 398050.6 3830366.0 746.8 5.4 505.4 21.6 1.22 3.67 0.462S078 Lockheed 398097.6 3830381.0 746.8 12.2 830.9 85.0 0.15 10.60 1.336S081 Lockheed 397550.6 3830881.0 746.8 6.1 883.2 131.3 0.05 3.75 0.472S085 Lockheed 397437.6 3830322.0 746.8 13.7 820.9 54.4 0.15 4.89 0.617S087 Lockheed 397689.7 3830861.0 746.8 3.7 883.2 69.8 0.05 1.30 0.164S088 Lockheed 397749.6 3830401.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S089 Lockheed 397753.6 3830401.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S090 Lockheed 397748.6 3830415.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S091 Lockheed 397753.7 3830415.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S092 Lockheed 397885.6 3830400.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S093 Lockheed 397885.6 3830415.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S094 Lockheed 397880.7 3830415.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S095 Lockheed 397875.6 3830400.0 746.8 1.5 727.6 66.5 0.15 8.51 1.072S097 Lockheed 398045.6 3830521.0 746.8 2.1 505.4 14.4 0.31 0.14 0.017S098 Lockheed 398053.6 3830521.0 746.8 2.1 505.4 14.4 0.31 0.13 0.017AECOMUpdate to 1-hour NO2and 24-hour PM2.5 NAAQS Analysis for PHPPMarch 201110Source ID FacilityUTM Easting(NAD27)UTM Northing(NAD27)BaseElev.(m)StackHgt.(m)Temp(°K)ExitVel.(m/s)Exit.Diam.(m)NOX(lb/hr)NOX(g/s)S099 Lockheed 398083.6 3830535.0 746.8 3.1 477.6 20.0 1.22 0.09 0.011S105 Lockheed 399337.7 3830928.0 746.8 16.8 802.6 40.5 0.08 2.21 0.279S106 Lockheed 399511.6 3831148.0 746.8 2.0 505.4 8.5 0.92 1.24 0.156S107 Lockheed 399504.6 3831154.0 746.8 7.6 505.4 9.5 0.92 1.24 0.156S108 Lockheed 399502.6 3831136.0 746.8 12.2 816.5 47.6 0.08 2.70 0.340S110 Lockheed 399563.6 3831102.0 746.8 18.3 802.6 40.5 0.08 2.16 0.272S112 Lockheed 399652.6 3831240.0 746.8 21.3 802.6 40.5 0.08 2.21 0.279S114 Lockheed 397299.6 3830864.0 746.8 6.1 780.4 54.3 0.08 1.88 0.237S115 Lockheed 398550.6 3831532.0 746.8 12.2 862.0 26.6 0.08 0.68 0.086S208 Northrop 401314.2 3833302.0 789.3 12.5 505.4 6.6 0.92 0.39 0.049S209 Northrop 401325.6 3833300.0 789.3 12.5 505.4 8.8 0.92 0.39 0.049S210 Northrop 401325.7 3833302.0 789.3 12.5 505.4 11.1 0.92 0.39 0.049S211 Northrop 402121.3 3833533.0 789.3 10.7 505.4 0.0 0.61 1.03 0.130S212 Northrop 402126.2 3833533.0 789.3 10.7 505.4 0.0 0.61 1.03 0.130S215 Northrop 402103.5 3833516.0 789.3 10.7 466.5 18.3 0.31 0.61 0.077S216 Northrop 402104.7 3833516.0 789.3 10.7 466.5 18.3 0.31 0.61 0.077S217 Northrop 401067.7 3833333.0 789.3 2.3 797.0 12.1 0.13 3.27 0.412S218 Northrop 400951.6 3833528.0 789.3 2.9 797.0 18.7 0.23 3.05 0.384S219 Northrop 401083.8 3833145.0 789.3 2.3 797.0 12.1 0.13 3.27 0.412S220 Northrop 401527.6 3833989.0 789.3 1.5 797.0 2.6 0.10 0.34 0.043S221 Northrop 401330.7 3833302.0 789.3 2.5 797.0 12.2 0.10 2.99 0.377S222 Northrop 402128.7 3833515.0 789.3 10.4 549.8 1.4 0.20 11.93 1.503S223 Northrop 402130.7 3833516.0 789.3 3.0 752.6 16.3 0.17 2.35 0.296S224 Northrop 402132.9 3833516.0 789.3 0.3 741.5 12.4 0.12 2.35 0.296S225 Northrop 401989.3 3833728.0 789.3 3.0 797.0 12.2 0.17 0.46 0.058S226 Northrop 401461.5 3833769.0 789.3 3.0 797.0 12.2 0.17 5.89 0.742AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 11



### E. Updated 1-hour NO 2 

### Cumulative NAAQS Modeling Results

The updated PHPP cumulative NO 2 modeling was performed using the same methodology as discussed in section 3.0 of the Palmdale Hybrid Power Project PSD Application, Supp lemental Information (AECOM, July 20, 2010) , except that the USAF Plant 42 sources were includ ed in addition to ambient background. Because emission sources cannot contribute to an ai r quality standard violation on their own property, the cumulative model run included only those receptors not located within the USAF Plant 42 ambient air boundary. Compliance with the 1-hour NO 2 NAAQS for PHPP-only sources was already demonstrat ed at all receptors within the boundary in the PHPP Suppl emental Information submittal.

The model was run for both the startup / shutdown a nd normal operations scenarios with the following assumptions regarding the PHPP ancillary equipment sources. Again, the new modeling guidance suggests that these intermittent sources do not nee d to be modeled at all, but since the modeling is conservative and in order to not redo it again, we continue to include these sources in the modeling:

a. The PHPP emergency generator and fire water pump w ill not be tested while the combustion turbines are in the startup or shutdown process.

b. The PHPP emergency generator and fire water pump e ngine will not be tested simultaneously.

The output from the AERMOD run was then processed u sing the “Post-1hr” post-processor created by AECOM and described in section 3.2 of the PHPP Supp lemental Information submittal, and the worst case impact was compared to the standard. The resu lts are presented below with the 3-year average 98 th percentile background added to all modeled impacts as described previously. The results, as shown in Table 7, demonstrate that the worst case impacts occur during startup / shutdown scenario, an intermittent case that the 3/1/11 EPA guidance memo suggests can be excluded in some cases, but was kept in the modeling to be conservative. When the 3-year average 98 th percentile background from 2007 – 2009 is added to the very conservative modeling, the maximum impact of 186.9 μ g/m 3 is below the NAAQS of 188 μ g/m 3 . Therefore, compliance with the NAAQS is demonstr ated for PHPP, and no further analysis is required.

All modeling and calculation files associated with the cumulative 1-hour NO 2 modeling analysis are included in Attachment A to this memo.



### Table 7: Revised Cumulative 1-hour NO 2 

### NAAQS Modeling Results

**Modeled Concentrations (** μ **g/m 3**  

### )

Modeling Scenario PHPP with updated USAF Plant 42 Sources and Receptors Background a Sum % of Standard

Normal Operations - No PHPP Emergency generator 88.2 77.1 165.3 87.9%

Normal Operations - No PHPP Fire Water Pump 108.2 77.1 185.3 98.6%

Startup/Shutdown - No PHPP Emergency generator 109.7 77.1 186.9 99.4%

a. Background based on 3-year average 98 th percentile background from 2007 – 2009AECOM

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## III. Updated 24-hour PM2.5 NAAQS Cumulative Modelin g

The PHPP PSD Application submitted on April 1, 2009 contained a cumulative PM2.5 NAAQS analysis which included other nearby (i.e., USAF Plant 42) s ources of PM2.5 emissions. The USAF Plant 42 sources were the only ones that the AVAQMD had reco mmended be included for the cumulative modeling analysis for PM10/PM2.5. However, in Marc h 2010, EPA requested that this cumulative analysis be expanded to include additional sources up to 50 km from the PM10 Significant Impact Area (SIA) from the power plant site. Since modeling ha d determined that the PM10 24-hour impacts fell to less than the Significant Impact Level (SIL) within 400 meters of the PHPP, an area of 51 km was used to assess the cumulative PM2.5 impacts. Two other sou rces, Granite Rock Construction and Robertson’s Ready Mix, were identified for inclusion in the PM2 .5 cumulative NAAQS analysis. An updated cumulative PM2.5 NAAQS analysis was submitted to the EPA by AE COM in PHPP PSD Application, Supplemental Information , in July 2010. No comments have been received to date from EPA on the PM2.5 analyses submitted in July 2010.



### A. Updated USAF Plant 42 Sources

Similar to the NO x emissions provided by the AVAQMD for the USAF Plan t 42 sources, the AVAQMD notified AECOM in December 2010 that the short-term PM2.5 emissions for these sources were mislabeled as lb/hr, when they were actually in ton s/hour. Therefore, updating of the cumulative 24-h our PM2.5 NAAQS analysis with the corrected emissions w as necessary. Similar to the cumulative NO 2 analysis discussed in this memo, AECOM implemented the same refinements to the sources and receptor grids to account for the higher emission l evels. That is, the sources were now modeled as individual sources rather than being combined for s implification and the USAF Plant 42 fence line was used as the ambient air boundary for the cumulative modeling (see Figure 2).

At Lockheed Martin, there are 88 sources included i n the PM2.5 inventory, of which 55 are permitted an d 33 were unpermitted. At Northrop Grumman, there ar e 129 sources included in the inventory, of which only 23 are permitted, and the remaining 106 source s are unpermitted. At Lockheed Martin, 25 of the sources are emergency combustion engines, while at Northrop Grumman 7 of the sources are emergency combustion engines. These engines are on ly tested up to one hour per week and would rarely, if ever, be tested at the same time. The 3 /1/11 EPA modeling guidance memo regarding 1-hour NO 2 NAAQS discusses how the modeling of intermittent s ources like emergency engines is likely overly conservative for standards with a probabilistic for m (i.e., a 98 th percentile value). As the 24-hour PM2.5 NAAQS is a similar probabilistic form, it can be ar gued that the emergency engines should be excluded from the PM2.5 modeling as well. Nonetheless, they were conservatively included in the modeling as if they were all being tested simultaneously.

Because such a large number of sources at USAF Plan t 42 operate only intermittently or are mobile sources that operate at different locations across the facility at irregular schedules, including them all in the modeling operating 24 hours a day is unrealisti cally conservative. In order to better characteriz e the sources to be modeled, copies of the operating perm its for the two USAF Plant 42 facilities were obtai ned from AVAQMD, and several email requests were made t o the contractors responsible for submitting emissions information for USAF Plant 42. As a resu lt, a number of refinements were made. The PM2.5 emissions for all USAF Plant 42 sources used in the updated modeling are provided in the spreadsheet USAF Plant 42 Source Characteristics.xlsx in Attachment A. Copies of all email corresponden ce regarding USAF Plant 42 sources are included in Att achment C.

It should be noted that the HARP file presented the emissions as PM, not PM2.5. Most sources had an extremely conservative conversion rate from PM to P M2.5 associated with them in the HARP file. In order to expedite the completion of the modeling, r efinement of PM emissions to PM2.5 was onlyAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 13

performed for those sources showing high modeled im pacts. Additionally, the majority of the sources i n the HARP files specified limits in the number of ho urs the source could run in a 24-hour period. For this analysis, only the emergency engines were restricte d by their listed hours of operation. This is yet another factor in the conservatism of the modeling analysis: many sources’ emissions are total PM, not PM2.5 emissions, and many sources are allowed to op erate more hours in the modeling than they would in reality. The following is a summary of the refi nements made to USAF Plant 42 sources:

• Hours of operations restrictions: Similar to the N O 2 modeling, it was assumed that testing of the 37 sources representing emergency generator and fir e water pump engines, along with jet test stands, would occur during the daytime, which was c onservatively assumed to be up to 12 hours per day, from 6 am through 6 pm.

• As a refinement to some of the sources showing the highest modeled impacts, the given HARP conversion rate from PM to PM2.5 for 4 of the sourc es was applied.

• Source S055, the cooling tower at Lockheed, had in correct emissions in the transaction file. Email correspondence with the consultant responsibl e for Lockheed emission reporting (included in Attachment C) confirmed the error and provided t he correct emission rate of 0.225 lb/hr which was corrected in the modeling.

• Source S046, various jet engine testing at Lockhee d, was characterized in the HARP files with short-term emissions that would exceed the permitte d annual emissions limit in less than one day. Email correspondence with Lockheed’s consulta nt indicated that these are mobile sources with a variable operating schedule and intermittent use. Because these sources are not permitted, are rarely used, and the emissions occur at different locations at various times, this source was omitted from the modeling.

• Source S051 represents various small motors used i n ground support tasks at Lockheed. Short term emissions for these sources were characterized in the HARP files at levels that would exceed the permitted annual emissions limit in less than one day. Again, email correspondence with the consultant indicated that these were mobil e, non-permitted sources with no predictable schedule or location of use. Therefore, this sourc e was excluded from the modeling.

Figure 3 shows the locations of the PHPP and USAF P lant 42 facilities/sources that were included in th e cumulative PM2.5 modeling.



### B. Updated Ambient Background Data

Ambient background data for PM2.5 are available fro m the monitor located at 43301 Division St. in Lancaster, California, located approximately two mi les from the PHPP site. Background data for 2005 – 2007 were used in the PSD Application, while data f or 2006 – 2008 were used in the July 2010 submittal

. For this updated analysis, data for 2007-2009 were used, since the data available on the AIRS database website ( http://www.epa.gov/ttn/airs/airsaqs/detaildata/down loadaqsdata.htm ) are not yet complete for 2010. For the 24-hour period, the 3-year average o f the 98 th percentile values was used. For the annual period, the 3-year average annual mean was used. T he PM2.5 background values for 2007 – 2009 from the Division Street Monitor are shown in Table 8.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 14



### Table 8: Ambient PM2.5 Background Concentrations at Lancaster Monitoring Station

Pollutant Period Measure PM2.5 Ambient Background (μg/m 3 )

2007 2008 2009 Max. 3-Year Average

PM2.5 24-hour 1 st -high 25 24 20 25 23

2 nd -high 20 13 16 20 16.3

98 th % 20 13 a 16 20 16.3

Annual Mean 8.0 7.1 7.8 8.0 7.6

a. The July 2010 submittal contained an error in th e 98 th percentile value for 2008. This PM2.5 value has been corrected in this updated analysis

.



### C. Modeling Methodology

Beside the changes discussed above, all other aspec ts of the PM2.5 cumulative NAAQS analysis remain unchanged from the analysis presented in July 2010. These aspects include the EPA modeling guidance followed (i.e., the March 23, 2010 EPA memo regardi ng the modeling of PM2.5 found at http://www.epa.gov/region07/air/nsr/nsrmemos/pm25me mo.pdf ), the PHPP sources/stack parameters and emission scenarios, the meteorological data, an d the receptor grids (except as indicated above for USAF Plant 42 fence line).

In order to streamline this updated 24-hour PM2.5 a nalysis, the receptor grid was then reduced to incl ude only those receptors at which PHPP sources had a si gnificant impact and therefore could potentially contribute to an exceedence of the NAAQS/CAAQS. Th e refined receptor grid used in the 24-hour cumulative PM2.5 model runs is shown in Figure 4.



### D. PM2.5 Updated Modeling Results and Discussion

The results of the cumulative PM2.5 modeling are sh own in Table 9. In the table, the average of the maximum modeled high-1 st -high over the three years by receptor is summed wi th the 3-year average of the 98 th percentile ambient background values for the 24-ho ur period. Similarly, the maximum annual impact over the three years is added to the average annual mean ambient background averaged over three years. The results are then compared to the 24-hour NAAQS for PM2.5 (35 μ g/m 3 ) and annual NAAQS/CAAQS for PM2.5 (15/12 μ g/m 3 ). As shown in the table, the cumulative impacts f or both periods are below their respective standards and thus compl iance is demonstrated.

The maximum modeled impact from the PHPP sources (i ncluding the emergency generator and fire water pump engine) is 12.57 μ g/m 3 . The non-PHPP sources (including the other two mo re distant sources [Granite Rock Construction and Robertson’s Ready Mi x], as well as the USAF Plant 42 sources), contribute only 0.01 μ g/m 3 to the maximum total impact. This contribution is the same as the previous modeling, demonstrating that non-Project sources ha ve little or no impact at locations where PHPP sources have the most impact, which are relatively close to the plant site (as shown in Figure 4).

The modeling and supporting files used in this anal ysis are included in Attachment A.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 15



### Table 9: PHPP Cumulative PM2.5 Modeling Results

Pollutant Averaging

Period Maximum AERMOD

Modeled Concentrations

(μg/m 3 ) Background b
( μ g/m 3 ) Maximum

Cumulative Modeled Result Plus Background ( μ g/m 3 ) NAAQS

( μ g/m 3 ) PHPP only a PHPP with

Cumulative Sources

PM2.5 24-hour 12.57 12.58 16.3 28.9 35

Annual 1.2 1.3 7.6 8.9 15 c

a. 3-year average of High-1 st -high value by receptor;
b. 3-year average 98 th percentile value for 24-hour and 3 year annual aver age mean from Table 8
c. The annual PM2.5 CAAQS is 12 μg/m 3 , there is no separate 24-hour PM2.5 CAAQS

Please feel free to contact Richard Hamel at 978-58 9-3275/richard.hamel@aecom.com or Sara Head at 805-388-3775/sara.head@aecom.com if you have any qu estions or comments regarding this information.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 16



### Figure 1: Relative Location of the PHPP Site and No n-Project Sources of NO X 

### .AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 17



### Figure 2: Updated USAF Plant 42 Ambient Air Boundar yAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 18



### Figure 3: USAF Plant 42 Sources included in the PH PP Cumulative PM2.5 Modeling AnalysisAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 19



### Figure 4: Receptors Used in Refined PHPP Cumulativ e PM2.5 Modeling AnalysisAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 20



# Attachment A:

Electronic Modeling and Calculation Files ArchiveAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 21



# Attachment B:

Q/D Analysis Methodology from the North Carolina Air Quality Section “Screening Method for PSD”AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 22



# Attachment C:

Correspondence with Antelope Valley AQMDAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 23

Emails between Chris Anderson of AVAQMD and Rich Hamel of AECOM Regarding Cumulative NO X Source Inventory for PHPP 12/20/10 – 1/4/11

.

From: Hamel, Richard [mailto:richard.hamel@aecom.com] Sent: Monday, December 20, 2010 10:04 AM To: Chris Anderson Subject: More Requests Regarding PHPP

Chris,

2 requests



### 1) Regarding Plant 42. Per my voicemail, the impacts w eren’t as bad as I thought all things considered, and I think that with some reasonable a ssumptions regarding the operations of the many ICU’s at the two sites we should be able to sh ow compliance. Could you send me the permits for both Lockheed and Northrop-Grumman to t ake a look at so that I can identify what these sources are and what limitations I might be a ble to use in the modeling? 2) Cumulative Sources: EPA is still uneasy about the s election of sources for cumulative modeling. I think what they are mostly looking for is a list of sources with some explanation of the criteria we subsequently used to eliminate some. As a result , I’d like to request a list of all sources within 60 km of the PHPP site that have annual emis sions of NO 2 

### > 20 tpy.

Please let me know if you need any other informatio n or want to discuss.

Rich

From: Chris Anderson [mailto:canderson@mdaqmd.ca.gov] Sent: Monday, December 20, 2010 2:51 PM To: Hamel, Richard Cc: Alan De Salvio Subject: RE: More Requests Regarding PHPP

RichAttached are all active permits for both Northrop G rumman and Lockheed Martin. This should satisfy request #1.

All permitted sources within 60 km that have annual emissions NO2 >20 tpy: The two sources we have named from the start, Northrop and Lockheed, are th e only two that we have judged and determined to satisfy your request. Both sources have PTE >20 tp y for NOx (assume NOx=NO2) but not actuals.

Bolthouse Farms is an agricultural source which we have recently permitted and inventoried. Their operations mainly take place on the east side of th e Antelope Valley. These operations include using diesel ICE for crop irrigation purposes. NOx emiss ions from Bolthouse Farms DICE operations exceeds 20 tpy, however these emissions are from their enti re operation of DICE throughout the AV. Bolthouse has been assigned one facility number within the Di strict, however they do have multiple facilites. A t this time the AVAQMD is working with Bolthouse Farms to determine the exact size and number of these facilities.AECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 24

Please review the attached and let me know if you h ave any questions or comments.

Regards

Chris A.

From: Hamel, Richard [mailto:richard.hamel@aecom.com] Sent: Tuesday, January 04, 2011 10:48 AM To: Chris Anderson Subject: RE: More Requests Regarding PHPP

Chris,

We’re back to looking at this again. Question for y ou as I’m not that familiar with the boundaries of Antelope Valley: When you say that Bolthouse Farms operations are mainly on the east side of the valley, where exactly is the eastern side of the va lley? Can you give me a particular town or landmark it is near?

Thanks,

Rich

From: Chris Anderson [mailto:canderson@mdaqmd.ca.gov] Sent: Tuesday, January 04, 2011 2:14 PM To: Hamel, Richard Cc: Alan De Salvio Subject: RE: More Requests Regarding PHPP

RichWhen I say east side of the District I am referring to all areas east of Division St. Looking at an a erial photo from Google Earth you will notice that there are Agriculture Operations (AO) in City of Lancaste r and Palmdale area due east of Plant 42 and then Nor theast of Lancaster. Further east in the areas of Lake Los Angeles and further east near the county l ine there is also AO. Many of these sources are Bolthouse Farms, however there is a mix of smaller AO that can be seen that I chose not to include based on size of source. Again, with its emission across the District’s east side aggregated together

, Bolthouse appears to be one large facility in HARP, however their emissions are spread out across the entire east side of the District.

Let me know if these answers satisfy your requests completely and/or if you should have any other questions.

Regards,

Chris AndersonAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 25

Email from Chris Anderson of AVAQMD to Rich Hamel Regardin g Plant 42 Ambient Air Boundary 1/5/11

From: Hamel, Richard [mailto:richard.hamel@aecom.com] Sent: Tuesday, January 04, 2011 1:48 PM To: Chris Anderson Cc: Alan De Salvio Subject: RE: More Requests Regarding PHPP

Chris,

I do have one more follow up question: Do you have anything that would indicate the ambient air boundaries the two facilities (Lockheed and Northro p) use for their air modeling? With Plant 42 being restricted to the public there are a lot of fences around there, I’d like to see if I’ve got the fence lines for modeling set up correctly. I’ve taken a minimalisti c approach in the previous modeling, but at this po int I need to know what is considered within the ambient air boundary and to make sure I’m not considering some areas within the fence line of either facility as publicly accessible.

Thanks,

Rich

From: Chris Anderson [mailto:canderson@mdaqmd.ca.gov] Sent: Wednesday, January 05, 2011 6:09 PM To: Hamel, Richard Cc: Alan De Salvio; Bret Banks Subject: RE: More Requests Regarding PHPP

RichThe District has reviewed the boundaries of AF Plan t 42 and its adjacent Aerospace Companies. As a result we have generated an aerial view outlining w hich areas are not available to the general public, i.e. location is fenced off, gated, guarded, and need to obtain permission prior to entering site.

Please see the attached file.

Should you have any questions please let me know.

ChrisAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 26

Emails between Chris Anderson of AVAQMD and Rich Hamel of AECOM Regarding Cumulative PM2.5 Source Inventory for PHPP 2/4/11 – 3/3/11

.

From: Hamel, Richard [mailto:richard.hamel@aecom.com] Sent: Friday, February 04, 2011 1:09 PM To: Chris Anderson Subject: RE: 2 Questions about emissions in HARP files

Hi Chris,

I was getting into taking a close look at this and it seems to me that the PM emissions (in the HARP f ile they are all listed as PM, no PM10 or PM2.5 breakdo wn) must be in lb/hr as opposed to tons/hour.

Case in point: Lockheed device #90801, stack #50153 is their cooling tower, located (UTM NAD83 at 397937.6 3830600.7). It’s a small 3-cell tower. It’ s PM emissions are listed as 6.48. That can’t possi bly be 6.48 tons/hr out of a cooling tower, and the annual emissions for the same source are only 0.98 tons/year.

Frankly, even 6.48 lb/hr seems high, given that Pal mdale’s 10 cell tower will only emit 1.63 lb/hr PM10/PM2.5, but again that 6.48 is in PM and not br oken down by particle size.

Thoughts?

Rich

From: John Pinsonnault [mailto:John.Pinsonnault@ver dant-env.com] Sent: Tuesday, February 08, 2011 10:02 AM To: Chris Anderson; Been, Laura Subject: Re: FW: 2 Questions about emissions in HAR P files

Chris

There does seem to be a problem with the hourly emi ssion calculation from the cooling tower. The correct emission rate is 0.000113 tons per hour or 0.225 lb/hr. The calculations in our model appear to be correct so I am not sure where the problem occur red. I reviewed the other PM estimates and everything appears to be in line with our assumptio ns.

As to whether these are actual emissions or PTE, th at depends on the source and time period. Annual emissions are actual emissions. Hourly emissions f rom permitted combustion equipment are PTE since we are assuming heaters and permitted IC engines ar e operating at maximum rated capacity for the hour. Hourly emissions from AGE and Jet Engine Testing ar e not PTE. We make assumptions on typical operating profiles. For a spray booth, we have no idea what the max hourly coating rate is so we assu me emissions are spread out over an eight shift.

JohnAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 27

From: Hamel, Richard [mailto:richard.hamel@aecom.co m] Sent: Friday, February 18, 2011 8:14 AM To: Chris Anderson Subject: RE: FW: 2 Questions about emissions in HAR P files

Hi Chris,

I have a couple of additional questions related to the PM emissions included in the Plant 42 emissions inventory. In doing the cumulative modeling, I've f ound 2 sources to be problematic, but I also think the reported emissions are likely very conservative. Bo th of the sources are non-permitted so I only have what information I can find in the HARP transaction files (these are both Lockheed Martin):

Device: 90155, Stack 50141 (volume source): Listed as JP-TS Combustion, Jet Engine Operations: 16 hr/day Emissions: Short term: 2.73E-3 tons/hr = 5.39 lb/hr Annual: 2.7E-4 tons/yr = 53.93 lb/yr.

Comments: Given the short term vs. annual emissions , the source obviously doesn't operate 16 hours / day since that would exceed the annual emissions in less than a day. Can you tell me anything else abo ut how this source usually operates or what it is, or what the correct short term emissions should be? It 's not a permitted source so there aren't any limitations per-se, but I can make operating assumptions in the modeling based on reasonable normal use.

The other is 3 devices combined into stack 50146 (v olume source): 90105: Distillate Combustion - Gas Turbine Operations: 16 hr/day Emissions: Short term: 9.68E-4 tons/hr = 1.94 lb/hr Annual: 27.1 lb/yr. Conversion rate from PM -> PM2.5 = .967

90116: Distillate Combustion - Gas Turbine Operations: 16 hr/day Emissions: Short term: 8.47E-4 tons/hr = 1.69 lb/hr Annual: 8.35 lb/yr. Conversion rate from PM -> PM2.5 = .967

90125: Distillate Combustion - Reciprocating Engine Operations: 16 hr/day Emissions: Short term: 8.44E-4 tons/hr = 1.69 lb/hr Annual: 141.6 lb/yr. Conversion rate from PM -> PM2.5 = .967

Comments: Again, for the first 2, the annual emissi ons would be eaten up in less than one day at the 1 6 hours / day rate, so either the short term emission s are incorrect or the sources don't in reality ope rate nearly that much. Also, the conversion rate listed in HARP is 96.7% of the PM is PM2.5. That seems hig h. Any idea where that reference comes from? Also, I w onder if these 3 sources are active at the same time?

Thanks for any info.

RichAECOM

Update to 1-hour NO 2 and 24-hour PM2.5 NAAQS Analysis for PHPP March 2011 28

From: John Pinsonnault [mailto:John.Pinsonnault@ver dant-env.com] Sent: Thursday, March 03, 2011 12:33 PM To: Erkeneff, Kelly; Chris Anderson Subject: Re: FW: LM Inventory

Chris

None of these sources operate on a well defined sch edule.

Device: 90155, Stack 50141 (volume source): Listed as JP-TS Combustion, Jet Engine

This describes jet engine testing out on the flight line. We typically track the amount of fuel used or operating hours but do not know when testing takes place. In this case the schedule reflects an opera tion that could take place anytime during Lockheed's nor mal operating schedule. We have estimated hourly emissions assuming that an engine is tested for one full hour and based emissions on a typical load profile (ie some minutes at idle, the rest at milit ary load). It is not unreasonable to assume that t he test lasts a full hour. In some cases, Lockheed can tes t more than one engine during the year. In these circumstances, the hourly rates will reflect multip le engines operating at the same time which is not likely.

Stack 50146 (volume source):

90105: Distillate Combustion - Gas Turbine

90116: Distillate Combustion - Gas Turbine

90125: Distillate Combustion - Reciprocating Engine

These devices represent Ground support equipment. Again, this equipment can operate at any time during Lockheed's normal operation. We have no ide a when this equipment operates or how many pieces of equipment operate simultaneously. The ho urly emission rate assumes that all of the equipmen t is operating at 80% of load for one full hour (exce pt for Start carts) which is very conservative. We assume start carts operate for about 15 minutes dur ing the hour.

Estimating hourly emissions from this type of opera tion is very difficult. I was under the impression that these sources would be considered as mobile and exc luded from the modeling. Has that changed?

John