Date: Tuesday, June 22, 1999 2:21 PM
Subject: Metcalf Energy Center Data Adequacy

Please find some questions about the proposed Metcalf Energy Center enclosed:

Jeff Wade,
Attitude Controls, and Spaceflight Analysis, L8-30
Lockheed Martin Missiles and Space
(xxx) xxx-xxxx

Lorraine White
Project Manager
California Energy Commission
Cc: www.southsanjose.com

Dear Ms. White,

I have reviewed the Metcalf Energy Center application for compliance (AFC) as a member of the neighboring community, and I have uncovered several apparent inadequacies. Please consider these issues in your review of the application. The issues identified thus far are specific to the air quality section of the AFC, i.e., section 8.1.

1. The dispersion coefficients used in the math model for air pollution dispersion are referred to as "rural dispersion coefficients" in section 8.1.5.1.2. The proposed Metcalf center is adjacent to a heavily populated urban area. Please ensure that conservative coefficients are used.

2. EPC document Appendix W to part 51 -"Guidelines on Air Quality Models" pp. 7 section 5.1.a defines complex terrain as that which is "exceeding the height of the stack being modeled". Tulare Hill is immediately adjacent to the proposed site has an elevation of 565 feet compared to the stack exit of 395. We infer that the proposed site meets the definition and should be characterized as "complex terrain." The same document (ibid pp 47 section A.5) recommends the use of CTDMplus for modeling complex terrain. The applicant claims that modeling of complex terrain was performed yet fails to provide information about the model, nor programs used for this purpose. Reference is made instead to ISCST3 which is applicable to "flat or rolling terrain" (ibid pp 45 section A.5.a). We are particularly concerned about large scale air pollution stagnation leeward of Tulare hill affecting the Encinal School to the southwest, and the Los Paseos neighborhood to the north.

3. The applicant does not provide modeling input data for dispersion modeling to an extent necessary for independent verification. Please provide all input data files.

I appreciate your attention to our questions and your thorough effort. We are encouraged by your presentations to the community groups and with the emphasis you place on an open review process.

Sincerely,

Jeffrey Wade, PE