4 Attachments 

Here is the District’s response regarding non-project sources.

--Steve Hill

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

Sent: Friday, December 17, 2010 1:03 PM 

To: Steve Hill; Eric Walther 

Cc: Mar, Albert; Gould, Cynthia; Desiena, Ralph 

Subject: New or Proposed Sources Near Relocated Pio Pico Energy

 

FW: New or Proposed Sources Near Relocated Pio Pico Energy 

Steve Hill 

to: 

Carol Bohnenkamp 

05/31/2011 08:17 AM 

Cc: 

"Gary Rubenstein", djenkins 

Hide Details 

From: "Steve Hill" <SHill@sierraresearch.com>

To: Carol Bohnenkamp/R9/USEPA/US@EPA 

Cc: "Gary Rubenstein" <GRubenstein@sierraresearch.com>, 

<djenkins@apexpowergroup.com>

History: This message has been forwarded. 

Facilitywide EASIER NOx PM10 and Location 120910.xlsx OMEC PDOC Amendment 1b - modeling report.doc

New Apps Query VAX 120910.xlsx CA State Dept Corrections 121310 Rev.xlsx

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Steve and Eric, 

 

Here is a partial response to your public records request dated November 22, 2010, on behalf of Apex Power 

Ltd. The District databases are not currently set up to provide information on sources within a certain distance 

of a location. The best we can do is provide addresses and zip codes. In addition, the District is transitioning to 

a new permit database system for which the query capabilities are not as well developed as for the legacy 

system, which stoped collecting data on July 31, 2009. The information in the attached spreadsheets was 

derived from the legacy database and the District’s emission inventory database that communicates with the 

legacy database, but not with the new database. Hence, the data only covers the period up to July 31, 2009. 

The District is working to provide the additional information, as available. 

 

For emissions, annual and maximum hourly emissions of NOx and PM10 are provided—the District is not in 

general separately quantify PM2.5 emissions. Please note that the District does not inventory all facilities in the 

District nor does it inventory every facility that is inventoried every year. 

 

With regard to release parameters, this information is sometimes provided by the facility to the District as part 

of their emission inventory submittal. However, this information is not directly relevant to emission inventory 

and is not QA’d and exact stack locations are not provided. A better source for this data would be the individual 

permit files (the information in which should also be QA’d), which would have to be searched manually if it is 

necessary to obtain and compile this information. Even those may not have exact stack locations. The District 

will make permit files available upon request. 

 

Request 1: New Sources.

The spreadsheet “New Apps Query VAX 120910” is filtered on zip codes 91902, 91910, 91913, 91914, 91915, 

91978, and 92154 and is based on a query of our legacy database for startup authorizations for new emission 

units issued after 12/31/2003. If it is determined more or different zip codes need to be included as part of the 

6 mile radius, all zip codes are in the spreadsheet. As mentioned above, startups after July 31, 2009, are not 

addressed. Also not included are open applications under review or with an approved authority to construct but 

no startup authorization. 

 

 

Request 2: Existing Sources.

 

Otay Mesa Power Plant. The Otay Mesa Power Plant does not have an actual emissions inventory data on file at 

the District. The District intends to conduct an emissions inventory for 2009 operations. However, attached is 

the District’s approval of the AQIA for the Otay facility which contains relevant emissions and stack release 

parameters, except for precise stack locations, for which the District is searching its AQIA files. 

 

CA State Dept of Corrections (Donovan Prison). See attached spreadsheet with filename “CA State Dept 

Corrections 121310 Rev” for the emissions for all the equipment at the facility for all years back to 1997 and the 

release parameters in the District emission inventory database (a zero means missing data). The combustion 

turbine at the facility was not operating in 2007, the latest emission inventory year for the facility. However, it 

is now back in operation and was operating in previous inventory years. 

 

 

Additional Information About Existing Sources. The spreadsheet “Facilitywide EASIER NOx PM10 and Location 

120910” lists all 5 TPY facilities for PM10 or NOx in the emissions inventory database and their locations based 

on the latest emission inventory for each facility. This may include sources more than 80 km from the proposed 

location. 

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In addition to the information requested, other information such as the NO2/NOx ratio in the exhaust stacks 

may be relevant to the AQIA modeling you are proposing. The District is currently compiling source test data 

from its files for this purpose and may be in a position to make preliminary recommendations on appropriate 

NO2/NOx ratios for some equipment in the near future. 

 

If you have any questions concerning the above, please contact me or Albert Mar at 858-586-2738 of our 

emission inventory group. 

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!

 

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