==~ DAVID J. POWERS - State of California

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Nov 18, 2011 ... David J. Powers & Associates, Inc. is a Certified Green Business .... SLA obligations for data centers typically require power to be available all ...
==~ DAVID J. POWERS

& ASSOCI,ATES. INC. B~~

':~~ -\11:,~(Cl~ill(:~~) h\~) ~}cJ:hic..· ,,~ ... t~' ":~ i I 'l)1~~: ~;'l~)

November 18,2011

DOCKET

Dockets Unit California Energy Commission 1516 Ninth Street, MS 4 Sacramento, CA 95814

'l-S -0 DATE NOV f 8 2011

RECD~OV

22 2011

Re: Santa Clara SC-l Data Center, Application for Small Power Plant Exemption ­ Response to Informal Data Requests Dear Docket Unit Clerk: Pursuant to requests from members of the staff of the California Energy Commission, Xeres Ventures LLC hereby submits the enclosed responses to informal data requests regarding the SPPE Application for the Santa Clara SC-l Data Center project in Santa Clara, California. One hard copy and one CD are being provided for filing. The attached responses address the technical information needed for a Visible Plume and Plume Velocity Analysis by the California Energy Commission and supplemental Air Quality information for the proposed 16 emergency backup generators and cooling towers used for building cooling at the Santa Clara SC-l Data Center. Please contact me if additional information or clarification of the data is needed.

Sincerely,

~1J~ Nora Monette Principal Project Manager

c.c. w/enclosures Robert Worl, CEC Project Manager

Richard Waddell, DuPont Fabros/Xeres Ventures LLC

Monica Schwebs, Bingham McCutchen

---

Green Business Sanb oatil ec.mty

David J. Powers & Associates, Inc. is a Certified Green Business 1871 The Alameda • Suite 200 • San Jose, CA 95126 Tel: 408-248-3500 • Fax: 408-248-9641 • www.davidjpowers.com

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS Technical Area: Air Quality Author: Joseph Hughes Project Modeling BACKGROUND Operational emission air dispersion modeling needs to be evaluated to determine if it demonstrates project compliance with all ambient air quality standards, including the new Federal 1-hour NO2 standard. Staff is interested in modeling parameters that reflect permitted emissions and operation. Emission factors should reflect load percentages and emissions likely to occur during testing and maintenance scenarios as allowed in the Authority to Construct permits. CLARIFICATION ISSUE 1.

Please provide the operations modeling analysis, which includes all on-site operations emission sources that represent expected worst case operational impacts (not emergency situations). Alternatively, if you want us to get the information from the air district, please let us know.

Sierra Research conducted an air quality impacts analysis for compliance with both the federal 1-hour NO2 National Ambient Air Quality Standard (NAAQS) and the California 1-hour NO2 standard. Sierra’s initial modeling results were presented in a report submitted to BAAQMD entitled “NO2 Air Quality Impact Analysis & Diesel Particulate Health Risk Assessment for Xeres Ventures, LLC, Santa Clara Data Center, Santa Clara, California”, October 2009 (Attachment A). This analysis considered both non-emergency operations at various load levels (operation of one engine for: 30-minute test runs at 75%, 50% and 25% loads; load-banked startup at 100%, 75% and 50% loads; uncontrolled startup at 25% load; and controlled operation at 100%, 75%, 50% and 25% loads), as well as emergency operations (operation of all 32 engines for: 30-minute emergencies at 75% and 50% load; emergency startup at 75% and 50% loads; and controlled emergency operation at 75% and 50% load). At BAAQMD’s request, Sierra Research performed more refined modeling analysis for compliance with the 1-hour NO2 NAAQS and California ambient air quality standard, as summarized in a memorandum dated March 12, 2010, “OneHour NO2 Air Quality Impact Analysis and Health Risk Assessment for Xeres Ventures Santa Clara Data Center” (Attachment B). BAAQMD reviewed these analyses and the underlying modeling filed and confirmed their results. Specifically with respect to the 1-hour NO2 NAAQS, BAAQMD’s Engineering Evaluation Report provides as follows: b) Federal 1-hour NAAQS for NO2 The Applicant's refined NO2 modeling, described above, also indicates that the project will not result in a violation of the new 1-hour national ambient air quality standard for NO2, which is expressed as the 8th highest 1-hour concentration in any year, not to exceed 188 µg/m3. Further discussion of this finding can also be found in the District's addendum to the Mitigated Negative Declaration (see Appendix E of Santa Clara SC-1 Data Center Application for Small Power Plant Exemption, November 2011). Engineering Evaluation Report, Xeres Ventures LLC, P#18801, July 7, 2010, prepared by Tamiko Endow (BAAQMD Air Quality Engineer) at p. 12. The Engineering Evaluation Report is provided in Appendix I of the Santa Clara SC-1 Data Center Application for Small Power Plant Exemption (SPPE). November 2011

1

Santa Clara SC-1 Data Center Data Requests

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS The referenced Addendum to the Mitigated Negative Declaration confirms this conclusion as follows: The modeling also shows that the project will not result in a violation of the new federal 1-hour NO2 NAAQS (188 µg/m3, based on the 3-year average of the 98th percentile or 8th highest 1hour NO2 concentrations in any year). Addendum to Mitigated Negative Declaration, Santa Clara SC-1 Data Center Project (Xeres Ventures, LLC), June 15, 2010, at 4 . The Addendum to the Mitigated Negative Declaration is included in Appendix E of the Santa Clara SC-1 Data Center Application for SPPE.

Project Engine Testing BACKGROUND Staff wants to know the minimum readiness testing requirements (minutes per week) to meet the engine availability requirements. This will help staff estimate realistic (rather than permitted) engine operation and expected impacts. CLARIFICATION ISSUE 2.

Please provide information on the minimum readiness testing requirements to meet the engine availability requirements. Please identify the source of the requirements (e.g., NFPA, reliability agreements or specification, insurance, local fire, etc,),

The minimum readiness testing requirements for the data center are what Xeres Ventures believes are necessary to meet its Service Level Agreement (“SLA”) obligations to those who lease space from the data center. SLA obligations for data centers typically require power to be available all the time, with substantial reductions in lease payments applied for failure to meet the agreed availability standard. The SLA is the foundation of the business operation, and requires all support systems be available to attain the performance standards. These standards can only be met through periodic test regimens. Xeres Ventures developed estimates of the amount of time that it would have to be able to test the backup generators and electrical distribution equipment in Santa Clara SC-1 in order to meet its typical SLA obligations. These estimates were used to develop the limits in the BAAQMD Authority to Construct Permit issued in July 2010.

November 2011

2

Santa Clara SC-1 Data Center Data Requests

Attachment A NO2 Air Quality Impact Analysis October 2009

rH NO2

Air Quality Impact Analysis Particulate Health Risk

Diesel

Assessment

for Xeres

Ventures LLC

Santa Clara Data Center Santa Clara California

Submitted

by

Xeres Ventures LLC

Washington

D.C

October 2009

prepared

Sierra

1801

by

Research Inc Street

Sacramento

916

California 95811

444-6666

NO2 AIR QUALITY IMPACT ANALYSIS DIESEL PARTICULATE HEALTH RISK ASSESSMENT for

XERES VENTURES LLC SANTA CLARA DATA CENTER SANTA CLARA CALIFORNIA

Submitted

by LLC

Xeres Ventures

Washington

DC

October 2009

Prepared

by

Sierra Research

1801 Sacramento

916

Inc

Street California 95811

444-6666

-p

EXECUTIVE SUM11ARY

In

November 2007 Xeres Ventures

Quality

new

Management

to

install

an application

filed

District for Authority to

be constructed

to

thirty-two

City of Santa

Environmental issued

32

with the Bay Area Air

Construct

ATC

Santa Clara California

in

diesel emergency

permits

for

Xeres Ventures

and four permit-exempt

generators

Negative

does not require an

standards

the

an

AQIA for

contain

health

risk

diesel particulate

risk

This

report evaluates

hour

NO2 AAQS

emissions

proposed SC

AAQS

compliance

an

or

AQIA

process

even though

for

Furthermore

AQIA that

health

from the emergency

the District

this

ambient

showed an

air

apparent

the original permit

demonstrating

emissions

project of

with the national

NO2 the

HRA

DPM

analysis

permitting

risks

type

and

quality

exceedance

application associated

did not

with

would comply

generators

thresholds

of the proposed SC1 project with the California one-

compliance

and with the Districts

associated

would not cause

its

dioxide

assessment

matter

with the Districts

as part of

NO2

in

quality impact

nitrogen

of the California 1-hour

review

Declaration

demonstrated

AQIA

AAQS

air

Lead Agency with respect to the California The City prepared an Initial Study and March 2008 The November 2007 ATC

the role of

CEQA

Act

Quality

contained

While

assumed

Clara

Mitigated

application

size

LLC

heaters

space

The

SC

data center

proposed

District

with non-emergency exceedance

data center

health

operation

of the 1-hour

project

risk thresholds

are below

NO2

The

AQIA

of the proposed

AAQS

the Districts

The

health

SC1

indicates

data

center

risks for the

risk thresholds

that

fl

NO2 AIR QUALITY IMPACT ANALYSIS DIESEL PARTICULATE HEALTH RISK ASSESSMENT for

XERES VENTURES LLC SANTA CLARA DATA CENTER SANTA CLARA CALIFORNIA Table of Contents Page

EXECUTIVE

SUMMARY

INTRODUCTION Facility Information

Background Project Description

Equipment

Description

Operations

EMISSION ASSESSMENT Maximum

Hourly

Maximum

Annual

NOx

Emissions

Diesel

Particulate

Matter Emissions

NO2 AIR QUALITY IMPACT ANALYSIS

Source

Model

12 14

Data

Building

11 11

Project Location Dispersion

10

Downwash

17

MeteorologicalData

17

Receptor Grids

18

Ambient

Air Quality

DIESEL PARTICULATE Dose-Response

18

Impacts

SCREENING RISK ASSESSMENT

Assessment

20 20

Exposure Assessment

20

Risk Characterization

22

Conclusions

22

Appendix

Equipment

Appendix

Emission

Specifications Calculations

11

List of Figures

Figure

Page

Figure

Location

Figure

Site

Figure

Wind Rose

Figure

Location

Map

Santa

Clara Data

Center

Santa Clara Data Center

Plan

San Jose

of

Maximum

Airport

Station

Meteorological

Exposed

13

Individuals

23

List of Tables

Table

Page

Table

Emergency Generator Design

Table

Uncontrolled

Table

Controlled

Table

Startup

Table

30-Minute

Table

DPM

Emissions

Table

Stack

Characteristics

NOx NOx

NOx

Emissions

Emissions

Emissions

NOx

Specifications

from an Emergency

from an Emergency

from an Emergency

Emissions

and

NOx

Generator

Generator

from an Emergency

from an Emergency

Generator

Generator

10

Generator

Emission

Rates

10

Non-Emergency 15

Operation

Table

Stack

Characteristics

and

NOx

Emission

Rates

Emergency

Table

Stack

Characteristics

and

NOx

Emission

Rates

Commissioning

Table 10 Building/Structure

Dimensions

Table 11 Project Air Quality Table 12 Total Impacts Table 13 Stack

to

17

18

Impacts

Ambient Air

16

17

Quality

Characteristics

Table 14 Modeled

Operation

Non-Emergency

Operation

19 21 21

Impacts

Table 15 Risk Characterization

22

111

INTRODUCTION

Facility

Information

Owner

Xeres Ventures

Mailing Address

1212

New

LLC

York Avenue

DC

Washington

20005

535 Reed Street

Facility Address

Santa

CA

Clara

General Business

Data Center

Contact

Dan

95054

Hopkins

Director Data Center Operations

DuPont Fabros Technologies

202

538-4638

Inc

Sierra Research

Consultants

1801

Street California

Sacramento Contact

916

95811

Dan Welch

444-6666

Background

In

November 2007 Xeres Ventures

Inc

DFT

District

filed

for

in

constructed diesel

Act

Quality

Negative

original

and an

CEQA

Declaration

air

ATC

in

AQIA

application

permitting

monoxide

or

analysis

demonstrated compliance

exceedance

an

new

to

install

to

The

heaters

the California

Initial

District

SC

data center

to

be

thirty-two

32

City of Santa

Environmental

Study and issued

process

CO and

contain

for

even though the

nitrogen

dioxide

NO2

risk

District

of this type

project

with the national

health

forms drawings

application

AQIA

of the California one-hour did not

respect

prepared

contained

as part of

for carbon

with

Agency The City

AQIA

its

Management

Mitigated

March 2008

application

quality impact

for

permits

and four permit-exempt space

the role of Lead

review

of DuPont Fabros Technology

Xeres Ventures proposed

Clara California

generators

emergency

Clara assumed

The

Santa

ATC

Construct

to

subsidiary

with the Bay Area Air Quality

an application

Authority

LLC

ambient

NO2 the

AAQS

assessment

air

does not require an

and size

While the

quality standards

AQIA

Furthermore

HRA

emission estimates

showed an

AAQS

apparent

the original permit

demonstrating that health

associated

risks

comply

This

with

with toxic

report demonstrates

AAQS and

with

TAC

contaminant

air

the Districts

from the project would

emissions

risk thresholds

of the proposed SC1 project with the

compliance

the Districts

health

risk thresholds

during

1-hour

non-emergency

NO2

operation

Project Description

The proposed SC1 Street

just

illustrated

west of the San Jose in

UPS

supply

will install

will be located

Figure to

assure that

the following

Thirty-two

International

The SC1 the

diesel-fired

Four

32 selective NOx emissions from

The

1.4

natural gas-fired

114.1.2 fired

space

heaters

natural

space heaters

of Rule 2-1 General

heaters

kW

rated less

than

has

electrical

SCR

the emergency space

generators

systems

MMBtufhr

Therefore

-2-

to

control

nitrogen

heaters

will be permit-exempt devices

further in these

as

generators and

Requirements

were not addressed

Santa Clara California

power power supply Xeres Ventures with the SC1 project

which

10

in

and Reed

Cruz Boulevard

reliable

reduction

gas-fired

DeLa

redundant uninterruptible

emergency

catalytic

MMBtuhr

Airport include

in conjunction

2250

Thirty-two oxides

project

will

data center

equipment

of

the intersection

at

pursuant

exempts from permitting the proposed

analyses

natural

to

Section natural

gas-fired

gas

Figure Location

Map

Santa Clara Data Center

5g10E

7k

3-

Equipment

Description

The 32 emergency generators will The emergency generators will be Detroit

Diesel

electrical

The

generator

to

Control

Measure

for

pollution control

compression

emergency

generator

Boards

Ignition

on each engine will consist of an

controls

of NOx emissions installed on the engine exhaust the

through

SCR

oxidation-reduction

The SC1

project

operation

of

reaction

will

Equipment Engineering

ammonia and

will convert

also include

load

which

bank

generator

The proposed

specifications

scheduled

is

locations

for the

the

system

emergency in

designed

generators

Manufacturer

Generator

NOx to

nitrogen

for

gas

are

generators

non-emergency

Model Generator/Engine

at

shown

Figure

Engine Fuel

Diesel

6V4000G83 Diesel

Generator

Power Output

Work

2250

Consumption

Heat Input Rate

Rate

163.6

HIV

gal/hr

MMBtu/hr

22.9

Exhaust Flow Rate

17832 wacfin

Exhaust Temperature

940

Exhaust Pipe Diameter Exhaust Pipe Exit Height

kW

3350 bhp

Output

18

Above Grade

-4-

inches

54.5 feet

in

in Table

Specifications

Fuel

system

operation

are summarized

Detroit

and water

SCR

the

non-emergency

MTU

Generator/Engine

90% will

and the catalyzed

Appendix

Design

air

obtain

to

Table

Emergency

Toxic

Engine exhaust

piping

startup period

for longer

emissions

Post-combustion

will allow full load

of the emergency

are contained

specifications

CARBs Airborne

urea will be injected

single engine in order to shorten

the emergency

reduced load

into which

reactor

more

not

District-required

Engines

SCR

with

ignition design

will be operated

and testing excluding

Compression

Stationary

engine will drive

four-stroke

Each

the California Air Resources

pursuant

when

are

engines

UPS 3350 bhp MTU each 2250 kW for the primary

power

with Diesel

exclusively

combustion

50 hours per year for maintenance

testing

pass

fueled

internal

and intercooling

turbocharging than

16V4000G83

redundant backup

provide

//

/7

Site Plan

Figure

-5-

Santa Clara Data Center

____________P

1TE

PLAN

PASF

rwnPDsRI

tWA

DATA CENTSR SANTA CLARA

Sc

GOG

EMISSION

The SC1

project will emit affected

diesel particulate

Hourly

NOx

maximum Annual

DPM

Maximum Hourly emissions

the

show

at

generator engine

emergency

Sd

to

characterize

project

characterize

to

generators

for uncontrolled

will never be operated

below

well

NOx

50%

emissions

operation controlled

manufacturer output

the health

operation

emission calculations

more than 30 minutes without

uncontrolled

emissions

of non-emergency calculated

3350 bhp

are presented

were

obtained

emissions

are summarized

generator

load

were

loads

Maximum

rate of

for

at

were

operation

load

from

calculated

based upon

NOx

Spreadsheets

full

containing

from an Emergency

NOx

detailed

Engine Load

g/kW-hr

Generator

Emissions

g/bhp-hr

lb/hr

100%

3350

7.174

5.35

39.5

75%

2513

5.631

4.20

23.3

50%

1675

5.175

3.86

14.2

25%

838

4.747

3.54

6.53

Notes from

MTU

Detroit

Diesel the engine

.7-

manufacturer

load

from an

emissions

in Appendix

NOx Emissions

from

bhp NOx emission MTU Detroit Diesel the

Table Uncontrolled

to

emissions

in

Uncontrolled hourly in Table

the use of

are presented

l00%/75%/50%/25%

and the engine work output

in g/bhp-hr l00%/75%/50%/25%

factors

Obtained

the

and

Operation

hourly

work

generators

operation

system except

emission

and

Emissions

the basis for subsequent calculation

Uncontrolled

factors

NOx

NOx

to

project

characterized

were

the generators

SCR

SC

limited

only the following

with the

from the emergency

with the

Hourly

Uncontrolled

impacts

associated

not

but

including

This report addresses

emissions

and 30-minute

Though

NO2

hourly

pollutants

from the emergency

emissions

associated

risks

startup

DPM

matter

ASSESSMENT

Controlled

Controlled efficiency but

Operation

NOx

hourly for the

calculated

Controlled

system

SCR

once the

rather operation

from an emergency detailed emission

emissions were

SCR

system

is

generator

are presented

reflect

in Table

control conditions

startup

Controlled

operating

are summarized

calculations

do not

NOx

90%

assuming

emissions

hourly

Spreadsheets

NOx

emissions

containing

in Appendix

Table Controlled

NOx

from an Emergency

Emissions

NOx Engine Load

Uncontrolled

Emissions

Generator

lb/hr

Eff

Control

Controlled

100%

39.5

90%

3.95

75%

23.3

90%

2.33

50%

14.2

90%

1.42

25%

6.53

90%

0.65

Notes Presented Routine

Table

in

previously

emissions

SCR

system fully

operational

i.e

excludes

startup

Startup

During heated

startup to

its

NOx

design

uncontrolled

emissions

temperature

operating

and controlled

SCR

Uncontrolled

and controlled

respectively

Xeres Ventures

operate start

up more

startup times

load

rates

at

startup to

proposing

startup emissions

load and

calculations at

the required

reducing

estimated

load back

75%

and

operation to

install

startup

emissions

at

loads

but

full-load to

the

in

quickly

-8-

heat

SCR

Startup

the

system

NOx

to to

emissions

SCR

emissions

containing

Load-banking

would yield higher

25%

generator

emissions during

Spreadsheets

Appendix

and

subsequent operating

hour of operation in Table

load

from uncontrolled

similarly calculated

first

are presented

NOx

hour

first

in Tables

allow

to

which will enable the

at

from

over the

previously

bank

is

catalyst

0O%/75%/50%125%

for

load

emission rates

are summarized

50%

appropriately

DFT

SCR

calculated

were

will better control

were

controlled

over the

by

while the

were presented to

minutes and

15

generator

detailed emission emissions

is

appropriately

from an emergency

due

i.e

full

load apportioned

were

NOx emissions

upon non-emergency

quickly

Load-banked

startup emission

Startup

emission rates apportioned

of operation

at full

will be uncontrolled

initially

will at

reduce

25%

system prior

to

load

Table Startup

NOx

from an Emergency

Emissions Startup

Duration

Generator

NOx

Startup

mm_a

Emissions

lb/br

Engine

W/o Load

Load

Bank

Bank

100%

15

75%

w/

Load

Load

w/o

wI Load

Bank

Bank

15

12.8

12.8

30

15

12.8

11.6

50%

60

15

14.2

10.9

25%

60

15

6.53

10.4

Notes Startup

duration

in

and

Tables

at

at

not

will

emissions

Therefore apportioned

containing

than

30-minute

75%

than

over

NOx test

previously

the

over

at

first

hour

the

full

At

first

presented

and

load

previously

previously

hour of operation controlled

in

emission

and

Tables

of operation

for

up

operation would non-emergency

30 minutes of non-emergency

Thirty-minute

with and without load-banking

operation

NOx

-9-

in

30

or greater

for 30 minutes

emission rates

Uncontrolled

are summarized are presented

startups plus

yield comparable

from uncontrolled

over 30 minutes of operation

detailed emission calculations

to

these lower loads load-banked

were calculated

in Table

system is operational

rates

Emissions

uncontrolled

emissions

rates

emission

load presented

the generators

load

non-emergency

would

appropriately

were presented generator

frequently

more

minutes of controlled

NOx

Operation

emission

operating

appropriately

Thirty-Minute

operation

appropriately

SCR

the

until

and controlled

apportioned

the subsequent

apportioned

Xeres Ventures

from ignition

the time

from uncontrolled

Calculated rates

is

from uncontrolled

Calculated

NOx

emissions

emissions from an emergency in Table

Appendix

Spreadsheets

Table

NOx

30-Minute

from an Emergency

Emissions

NOx Engine Load

Emissions

Generator

lb/hr

Load-Banked

Uncontrolled

N/A

100%

N/A

75%

11.0

11.6

50%

10.6

7.12

25%

10.2

3.27

Notes from uncontrolled

Calculated

load for 15

full

Table

the subsequent

at

emission

as presented

emission load for

operating

from uncontrolled

Calculated

rate

and controlled

minutes

emission

rates

in

previously as presented

rates

Table

at in

previously

30 minutes presented

in

previously

Table

for

30 minutes

Maximum

Particulate

100% PM10

matter

DPM were

Annual

obtained

emissions

limit

operating

to

Engines Spreadsheet

were

calculated

excluding

emissions

containing

calculated

at

was assumed

load

full

engine

emissions

Measure

from an emergency

load

bhp

output

rate

is

Compression

presented

in

Emissions

from an Emergency

DPM Engine Load

Generator

Emissions

g/kW-hr

g/bhp-hr

lb/hr

lb/yr

0.065

0.049

0.36

17.9

75%

2513

0.092

0.069

0.38

19.0

50%

1675

0.185

0.138

0.51

25.5

25%

838

0.382

0.285

0.53

26.3

Notes Detroit

Diesel the engine manufacturer -10-

generators Ignition

Appendix

3350

MTU

and testing

in Table

100%

Obtained from

bhp

from the

conditions

are summarized

generator

from

Hourly

of 3350

Table

DPM

load

PM10 emission

for emergency

testing

for Stationary

detailed emission calculations

in

CARB maintenance

and the 50-hour-per-year

Control

comprise

manufacturer

work

100% and 15%

for the

to

100%/75%/50%/25%

Diesel the generator

District-required

the Airborne Toxic

DPM

Detroit

based upon

hourly emissions

corresponding

pursuant

calculated

PM10

and the engine work output

in gfbhp-hr

MTU

in diameter

were

emissions

from

Matter Emissions

Particulate

10 microns

DPM

factors

were

emissions

Diesel

than

less

Hourly

emission

factors

Annual

NO2 AIR QUAlITY IMPACT ANALYSIS

An AQIA modeling

with non-emergency and

data center

AAQS

The

District

Sd

provided

Sierra with electronic

of

copies

This

analysis

section

AQIA

e.g

periods

NO2

to

describes

The

impacts

input files which

impacts

NO2

which focused only upon one-hour

added

with the

analysis of the

modeling

were

e.g

used

to

carbon monoxide scope of

the

beyond

District

subsequently

the methods

Other pollutants

NO2

annual

associated

operation comply

one-hour

modeling

its

District

when

concentrations

dispersion

evaluated

and the subsequent results

and other averaging analysis

which

project

formed the basis for Sierras perform the

performed

previously

proposed

data center

NO2

with

concentrations

of impacts from non-emergency

the case

in

these ambient

accordance

emissions from the proposed SC1

emergency and commissioning determine whether

to

levels

background

in

ambient one-hour

characterize

to

guidelines

impacts was performed

NO2

for one-hour

this

impacts

Project Location

SC1

will be located

Airport

on approximately 17.3 acres west of the San Jose

The

in Figure

approximately 52

is

the project

surrounding

industrial

including terrain

The

mild winters Clara Valley

the high

70s

to

SC

i.e

the

lowlands

to

20 inches

is

the

west

the

to

Pacific

High

north-south

summer

Hawaii bringing

the

between

to

its

Desert

summer

allowing

wind and rain

to

climatic

the Diablo the

south

40W

position

originating

During

air to

The

mix of

and

land

Clara Valley

At

the

northern

range from

temperatures

the winter

summer

the

from 13 inches

ranging

controls

Range

to

the San

50W

the east

11

the

low

the convergence

Francisco

Bay

meridians

to

results

low

and

in

Ocean

in

In the

strong

pressure

area from the

High moves southwestward

periods inversions

the north

oscillates

weather

in the Gulf of Alaska to reach northern rainy

to

in the

in the Santa Clara Valley

governs Californias which

cool

end of the

flow onshore over the San Francisco

the Pacific

the winter

uses

by warm summers with

thermal

site

area

system over the eastern Pacific

precipitation

also causes

The nominal

the high SOs-low 60s during

northernmost position

In the winter

storms

to

the

Its

seasonally

moves

property

are

There are no prominent

in the Santa

modest

High pressure

flow and negligible

Sonoran-Mojave

much of

centered

direction

the high

northwesterly

is

Pacific

are

The major

of the Gabilan Range and Diablo Range

The

as urban with

range from the high SOs during

in the hills

and the semi-permanent

intersection

meters Northing

of precipitation

summer

as illustrated

Street

this

level at this location

characterized

amounts

Rainfall

27

of

Airport mean maximum

San Jose

Cruz Mountains

are the Santa

sea

located

amounts

80s during

the winter

is

Clara Valley

and modest

the low

4135220

and commercial

and mean minimum temperatures 40s during

and

above mean

can be characterized

residential

of the Santa

climate

NAD

coordinates

feet

features in the vicinity as

nights Santa

site

and Reed

Cruz Boulevard

UTM

meters Easting

approximately 593816 elevation

of DeLa

the intersection

at

previously

International

are

Bay

area

toward California

weak

or

nonexistent

winds are often moderate

summer and

fall

when

winds

are surface-based

The wind

tule

prevailing

dominant

In

summer

the Pajaro

through

parallel

greatest in the spring and

hours have

morning

occasional

drainage

winter

from the northwest

rose

Figure

The mixing

the

the San

at

at

inversions

mixing heights

of

sources

air

No exist

meteorology scale terrain

and

of the

the vicinity

Dispersion

The ambient Version associated

air

07026

selection of

site that

would

The

Pacific

and buses

calendar

the

wind

year

of

the top

strong

inhibit

and can

system layer

no slope

is

of

Inland

ground-based of low-lying

in high pollutant

result

have an

on the

effect

and length

height

2004

for the

dispersion

that would

roughness

affect

significantly

come

through

distribution

high pressure at

the area and play

There

patterns

calm conditions

of the winds

conditions

often experience

surface

only with an

of the marine environment

These inversions

throughout

wind

of large-

large role in the

or topographical

effect

aspect

in

conditions

meteorological

Model

model

to

number of

default model

analysis was

modeling

quality dispersion evaluate

one-hour impacts

from non-emergency

of the proposed

the District

effects

vertical

with emissions

commissioning

regulatory

site

20% 43%

during

often found

steering mechanisms

features are consistent

on the horizontal

is

nature

weaker

is

or other

the project

the eastern

provide favorable

generally

such as cars trucks

terrain

at

by

the inversion

of the cooler

influence

pollution

concentrations

that

Speeds are

from southeast

station

meteorological

weather periods

cold

during

Airport

end of the

south

seasons while summer

area are light

19%

the

Nighttime and early

and wind speed frequency

direction

because

the marine

Jose

north and approximately

Jose

the

in

from the

flowing

air

into

an annual basis approximately

wind

during

north-northwesterlies

all

and

the late

sometimes observed

is

Hill when

calm in

axis

the afternoon

during

Strong winds are rare coming

in the San

The base of

dispersion of pollutants

areas where

On

the terrain

by

in the fall and winter

least

of the area are affected

heights

and marine influences marine air

and

The winds

through

depicts

recorded

are

Bay Area and

northwest-southeast

gets channeled northward

Gap

are quite breezy

storm

zone

convergence

winds and are frequently

and predominantly bimodal

south

During

and often

strong

the

flow occurring

Gilroy and Morgan

summer

light

and evenings

afternoon

into

low

very

These periods

high

greatly

the valley

up

Clara Valley and meets with the prevailing

Santa

is

become

is

the Valleys

to

south-southeasterly

light

end of the Valley between

Bay

potential

inversions

are influenced

sea breeze extending

evening and early morning

Monterey

pollution

flow out of the Central Valley

that

flow roughly

north-northwesterly

southern

air

fog

early evening and

that

High

is

patterns in the Santa Clara Valley

resulting in

with

and the

and the pollution potential

are light

by winds

often characterized often include

the Pacific

options options

SC1 that in

data affect its

using the

The

AERMOD

model output

preliminary ratio

ambient ozone

-12-

AERMOD

on ambient concentrations

operation emergency

center

used the plume volume molar

of ozone limiting with 2004

performed

The

dispersion

method

of

operation

model allows

the

District

primarily

modeling

analysis

PVMRM to

data obtained

NO2

and

used the except

evaluate

from the San Jose

the

Figure

Wind Rose

San Jose Airport Meteorological

Station

WIND SPEED Knots 22

17-21 11-17 7-11

4-7 1-4 Calms 20.02%

-13-

Jackson

Street

used the

identical

model options with

disks enclosed

compact

station and an assumed

meteorological

for this

this

AQIA

N02-to-NOx

The

AERMOD

were

established

of

ratio

data

files

10%

Sierra

are included

on

report

Source Data

Stack

operation

NOx

and hourly

characteristics

operation

emergency

emissions

and commissioning

for non-emergency

as discussed

in the following

sections

Non-Emergency

DFT

has

use

with the worst-case

modeled for

exhaust

MTU

only

analysis identified emergency

were assumed

operation

of impacts

with non-emergency

test

Load-banked

startup operation

at

i.e

The

load

with

be the single

impacts were

non-emergency and

NOx emission

Exhaust temperatures were

calculated following

with respect

to

obtained

operating

scenarios

to the California

of the emergency

and

from

1-hour

NO2

generators

loads

100%/75%/50%

25%

EG9

generator

in Table

non-emergency

during

characteristics

were

operation

75%/50%/25%

at

startup at

Uncontrolled Controlled

runs

velocities

manufacturer

for the determination

associated

Stack

are summarized

exhaust

Diesel the generator

30-minute

EG9

generator

emergency

non-emergency

Therefore

hourly impacts

flow rates from which

Detroit

AAQS

for

will be operated

so that only one generator

modeling

screening

engine

rates

designed SC1

Oneration

loads

and

SCR

fully

operational

at

100%/75%150%125%

loads

Although each locations

result

engine in

has identical stack

slightly

different

impacts

parameters

when

and emission

individual

-14-

engines

rates

the

slight

are evaluated

differences

in stack

Table Stack Characteristics

NOx

and

Emission

Rates

Non-Emergency

Stack

Exhaust

Exhaust

Stack

Height

Temperature

Velocity

Diameter

Emission Rate

msec

Source

30

Non-Emergency

Operation

g/sec

Minutes

100%Loada

N/A

N/A

N/A

75%Loadb

N/A 16.6

698

44.5

0.46

1.47

50%Loadb 25% Load

16.6

643

34.2

0.46

0.90

N/A

N/A

N/A

N/A

16.6

778

51.3

0.46

1.62

16.6

778

51.3

0.46

1.47

16.6

778

51.3

0.46

1.38

16.6

598

14.0

0.46

0.82

100%Load1

16.6

778

51.3

0.46

0.50

75% Load1

16.6

698

44.5

0.46

0.29

50%Load

16.6

643

34.2

0.46

0.18

25%Load1

16.6

598

14.0

0.46

0.08

N/A

Non-Emergency

Startup

100%Load 75% Load

N/A

Cd cd

50%Load 25%Loade

Controlled

Non-Emergency

Notes The emergency

NOx Stack

will not

generators

emission

were derived

rates

conditions

100%

reflect

be tested

at full

from Table

load

load or

25%

load for

for uncontrolled

because most

emissions

startup

30 minutes

than

less

for

operation

will occur

30 minutes during

load-banking

at

100% load

NOx

emission

Reflects

emissions than

greater

uncontrolled

NOx

were derived

rates

an uncontrolled

from Table

because

startup

uncontrolled

for

load-banked

load-banking at

operation

operation to

preparatory

25% NOx

operation

emission

rate

at

25%

load

would yield

from Table

was derived

for

operation

emission

were derived

rates

from Table

Emergency Operation Under will is

emergency

not

anticipated

DFT

does

Stack

characteristics

Table

approximately

NO2

were

and

assumed

AAQS

30-minute

Emergency Controlled

emergency

on emergency

All 32 engines

scenarios

estimates

50%

neither is emergency

anticipate

restrictions

accept

hour

not

DFT

conditions

operate between

NOx were

that

and

operation

rates

emergencies startup

at

emergency

75%/50%

75%/50% operation

engines

their

at

emergency

25%

load

generators operation

Although

DFT

cannot

nature are not predicable

for emergency

operation

32 emergency

of these conditions

of impacts

with emergency

all

Full load

under these conditions

for the determination

associated

all

which by

operations

emission

of

as

many

load

at either

operations

modeled

as

75%

operation

The

are summarized

following

with respect

to the

of the emergency

operating California

generators

loads

loads and

i.e

with

loads

-15-

SCR

fully

operational

at

in

75%/50%

1-

Table

and

Stack Characteristics

NOx

Emission

Stack

Exhaust

Height

Temperature

Rates

30

Emission

Stack

Diameter

Velocity

Rate

m/sec

Source

Emergency

Emergency_Operation

Exhaust

glsec

Minutes

l00%Loada

N/A

N/A

N/A

75%Loadb

16.6

698

44.5

0.46

1.47

50%Loadb

16.6

643

34.2

0.46

0.90

25%Loada

N/A

N/A

N/A

N/A

N/A

Emergency

N/A

N/A

Startup

N/A

N/A

N/A

N/A

N/A

75%Loadc

16.6

698

44.5

0.46

1.61

50%Loadc

16.6

643

34.2

0.46

1.80

25%Loada

N/A

N/A

N/A

N/A

N/A

100%Loada

Controlled

Emergency

N/A

N/A

N/A

N/A

N/A

75%Loadd

16.6

698

44.5

0.46

0.29

50%

16.6

643

34.2

0.46

0.18

N/A

N/A

N/A

N/A

N/A

100%Loada

Loadd

25%Loada Notes The emergency

are not expected

generators

to operate

at

25%

100%

or

under emergency

load

conditions

NOx NOx NOx

rates

were derived

from Table

for

uncontrolled

operation

emission

rates

were

derived

from Table

for

uncontrolled

startup

emission

rates

were derived

from Table

emission

Commissioning

generators emission blocks

DFT

commissioning

During

will operate rates

for

were

must simulate emergency

impacts

The

to

operating

Uncontrolled Controlled

range of loads

i.e

not

operation

full

scenarios 1-hour

were

NO2

block

and

assumed

Two

in Table

Commissioning

uncontrolled

AAQS

of 16 emergency

characteristics

are summarized

Consequently

NOx separate activities

startup emissions

for the determination associated

are

of

with

generators

load-banked

i.e

as Stack

under these conditions

the California

of the emergency

many

that as

activities

modeled operation

following

with respect

commissioning

full

commissioning

of 16 engines

evaluated

estimates

over the

SCR

at

startup

at

OO%/75%150%/25%

lOO%/75%/50%/25%

-16-

loads

loads and

Table

and

Stack Characteristics

NOx Emission

Rates

Exhaust

Stack

Temperature

Height

Stack

Velocity

Diameter

Source

Commissioning

Commissioning

Exhaust

Emission Rate

glsec

rn/see Startup

l00%Loada

16.6

778

51.3

0.46

1.62

75%Loada

16.6

698

44.5

0.46

1.61

50%Loada

16.6

643

34.2

0.46

1.80

25%Loada

16.6

598

14.0

0.46

0.82

Controlled

Commissioning

100%Load

16.6

778

51.3

0.46

0.50

75%Loadb

16.6

698

44.5

0.46

0.29

50%Load

16.6

643

34.2

0.46

0.18

25%Loadb

16.6

598

14.0

0.46

0.08

Notes

NOx NOx

emission

rate

emission

rates

yield high fenceline

Bowmans

District

effects

BPIP

The

modeling used

analysis but

USEPAs to

direction-specific

Dimension

Meteorological

its

preliminary

data collected

approximately

in

10

BPIP

in

within

dimensions

so that

Sierra used

the

AQIA

10 Dimensions

Length

1100

Width

280

Height

48

feet

feet feet

Data

dispersion

modeling

analysis

east-southeast

the District

used surface

Airport meteorological

station

meteorological located

of the proposed SC1 data center and upper -17-

its

or

Distance

2004 from the San Jose

km

in Table

Program building

in this

effects

of the

any other buildings

be evaluated

could

files without any modifications

Building/Structure

downwash

effects

are summarized

Profile Input

Building

determine

can cause

downwash

did not consider

of the SC1 data center building

output

stack

to

evaluated

District

Table

In

startup

building whose dimensions

software

modeling

downwash Districts

dispersion

The

structures

close

sufficiently

impacts

proposed SC1 data center preliminary

uncontrolled

for

from Table

located

or structures

Buildings

from Table

derived

were derived

Downwash

Building

that

was

air

already

further modify the data

the Oakland

at

contained

sounding station

from the proposed emergency

data for this

meteorological

files that

input

with emissions

associated

impacts

the identical

2004

in

data collected

meteorological

AQIA

the processed

the modeling

provided

data

meteorological

Sierra used

generators

BAAQMD

The

model the

to

Sierra did

set

Receptor Grids

In

its

20 meter

20 meters

emergency receptor

generators

modeling

Ambient

The modeled emergency

at

Air quality

boundary

fine

generated

receptor

receptors

SC1

data center

Sierra did data

further modify the contained

in

the

Impacts

The

with emissions

from non-emergency

of the proposed

AERMOD

SC1

operation

data center

data files are included

are

on compact

disks

report

Table

11

Project Air Quality Impacts Ambient

Impacts

tg/m3 25%

100%

75%

Load

Load

Load

N/A

164

144

115

169

166

165

135

79

50

35

23

3OMinutes

N/A

595

503

N/A

Startup

N/A

626

704

N/A

Controlled

N/A

372

348

N/A

598

575

620

613

697

692

562

548

Source

3OMinutesb Startup Controlled

Emergency

50%

Load

EG9

Non-Emergency

32

engines

Commissioning

StartupEG1EG16 Startup EG17 EG32 Controlled

EG1EG16

399

401

366

371

Controlled

EG17

348

322

243

221

EG32

Notes Reflects operation

modeled

impacts

of emissions

and commissioning

at

grid also

of approximately 750 meters from the midpoint of the

operation and commissioning

this

placed

further modify the elevation

impacts associated

with

District

District

files

input

summarized in Table 11 enclosed

The

the proposed

Sierra also did

grid

Districts

distance

to

the

analysis

along the fenceline

intervals

at

spaced

modeling

dispersion

preliminary

Does

The emergency generators

will not be

The emergency generators

will

associated

not include tested

not operate

at

at

with

non-emergency

background

full

25%

-18-

load or

for

100%

operation

emergency

concentrations less

load

than

30 minutes

under

emergency

conditions

The modeled

Sd for

impacts associated

center were

data

NO2

concentration

are summarized

emergency

in

NO2

this

Table 12

The

from non-emergency concentrations

hourly were

station

five-year

with emissions

NO2

AQIA

indicates

Sd

that

data center

obtain

ppb

the total for

of the impacts

20042008

The maximum one-hour

reviewed

was 80

period

to

operation

concentrations

from non-emergency

of the proposed

operation

the one-hour

Background

Central monitoring during

associated

impacts

added to the background

operation

non-emergency

from the San Jose

with emissions

or

139 JLgm3

total

of the SC1 data center

operation emissions

would

The

with non-

associated

not

cause

an exceedance

of

AAQS

Table Total Impacts

to

Ambient

12

Air Quality

Non-Emergency

Ambient

Impacts

Operation

jtglm3

25%

100%

75%

Load

Load

Load

Load

N/Ab

303

283

254

Startup

308

305

304

274

Controlled

218

189

174

162

Source

30 Minutes

50%

Notes Reflects

background

concentration

non-emergency

operation

The emergency

generators

of

139

jig/rn3

plus

modeled

impacts

of emissions

EG9

will not

be tested

at

full

-19-

load for

less

than

30

minutes

associated

with

DIESEL PARTICULATE

TAC5

contaminants

engines the

risk screening

the health

that

exceed

As

presented

DPM

with

health

carcinogenic

Assessment Health use potencies

defines result

URF

URF

as inverse

exposure

in

as the

of constant

and exceed the

was conducted

to demonstrate generators

generators the

risk and chronic

health

District

hazards

pathway

both the potential

m3/ug

URF

but

has

of

which

established

adverse

for

pathway

DPM

while

scenarios

OEHHA cancer

ug/m3 over

m3/jig

as

70-year

Reference health

non-carcinogenic

REL of 5.0 jig/rn3 for longREL for short-term exposures

chronic

developed an acute

not

concentration

70-kg person contracting

of 3.0xl0

levels above has

for carcinogens

relationships

only the inhalation

probability of

for

Approved Risk

exposure pathway

multiple

values

Dose-response

ambient

jig/rn3

per

non

the probability or risk of cancer

an ambient concentration

to

exposure

e.g

level

Dose-response

characterizes

estimated

DPM

DPM

and

carcinogenic

OEHHA/CARB

indicate

to

characterizes

OEHHA has established exposure levels RELs represent effects are anticipated OEHHA to

annual

are 229 lb/yr

emergency

cancer

2009 doses

lifetime

term exposure

For Diesel

via the inhalation

Values February

given

factor the

screening

maximum

from the emergency

resulting from exposure to

potency slope in kg-day/mg unit risk

SRA

from the Consolidated Table of

expressed

with

associated

II.B the

an

For Diesel

Assessment

effects

obtained

were

in Section

emissions

assessment characterizes

dose-response

which has

of toxic

emissions

thresholds

DPM

generators

of the incremental

emissions

Dose-Response

DPM

DPM

that

requires

whose

projects

screening

of

Therefore

with

new

risk

previously

risk thresholds

requires only the evaluation

The

the Districts

thresholds

District

Air Contaminants for

only the evaluation

associated

risks

would not exceed

associated

of Toxic

be performed

from the proposed emergency

emissions

Districts

SRA

requires

of 0.58 lb/yr

threshold

DPM

District

Review

Source

assessment

risk

screening air

New

Rule 2-5

District

SCREENING RISK ASSESSMENT

Exposure Assessment

The exposure assessment previously Since

presented

DPM

the

emergency

annual

emissions

generators

estimates

TAC

emissions

from each source

were

modeled

i.e in jig/rn3 per g/sec and 25% load conditions

emissions load

and

and the worst-case

25%

The

are summarized

derived

to

DPM

from the proposed emergency

i.e

emergency

engines

rate

from information

Table 13

-20-

of

g/sec

II.B

generators

to obtain

under

both the worst-case

characteristics

Section

generator are identical

were modeled

which represents

dispersion

load which were

exposure

using an emission

unit impacts conditions

of public

the extent

full

load

hourly

Stack characteristics presented

the

annual

previously

for

100%

in Table

Table

13

Stack Characteristics

100% Load

25% Load

Stack

Height

16.6

16.6

Stack

Diameter

0.46

0.46

Stack

Exhaust Velocity

51.3

14.0

778

598

mlsec

Exhaust Temperature

The to

SRA

modeling

evaluate

annual

analysis

number of

used the

identical

model options

of the SC1 data center building

maximum of

rate

glsec

locations

The

annual

the 32

and the annual

Jig/m3

unit impact

for

is

located

2600

both 100% and

slightly

overstated

of the southern

25%

because

fenceline

is

for the

METs

MET

are

is

25%

glsec

per

Maximum

Annual

Maximum

Annual

14

the

at

in

in g/sec Table 14 The rate

The

in Figure

residential

generators

MEl

are

approximately 100 meters south

load

condition

14 Impacts

MEl

Workplace

MET

100%

25%

100%

25%

Load

Load

Load

Load

28.2

38.9

331

571

2.58x10

3.79x10

2.58x10

3.79x104

Impact

Emissions gisec Impact

tg/m3

MET

for the

emissions

condition

load

Criteria

igm

The

analysis

for the residential

located

Residential

Unit

shown

along the west fenceline for the 100%

Modeled

Annual

effects

grid

Table

Maximum

downwash

of the annual emission

Concentrations

the residential

located

Sierra

the workplace

are also summarized

per g/sec

used the

analysis

in Table

MEl and

individual

model allows

the unit emission

to

resulting from the annual

conditions

edge of the modeling

The workplace MET the south

load

the

with

from the midpoint of the proposed emergency

south

feet

are summarized

exposed

locations of the residential and workplace

MEl

AQIA

the

07026

Version

District

modeling

corresponding

as the product

jig/rn3

The

as part of the modeling

per g/sec

concentrations

in

dispersion

As with

generators

calculated

generators

SRA

model

AERMOD

The

model output

preliminary

for this

maximum

ambient

average

32 emergency

its

emergency

of the residential

annual

in

in

AERMOD

of emissions associated

result

were considered

unit impacts

for

as

that affect

options

options

DPM

using the

for 50 hours per year

generators

default model

regulatory

of

concentrations

of emergency

operation

the selection of

was performed

0fl7 0Oo13

-21-

0.0

147

0.0853

0.2

16

and

Risk Characterization

The

characterization

risk

exposure assessment effects

The

Potential

excess

was

and the from

calculated

REL

risks

cancer

risks

jig/rn3

determine

modeling

are summarized

generators

MEIs

DPM

hazard index resulting from the annual

as the product

of the annual

health

and non-carcinogenic

carcinogenic

for the residential and workplace

calculated

and chronic

calculated

in Table

average

DPM

15

The

excess

concentration

DPM URF 3.0x10 m3/p.g The chronic hazard indices HIs were the annual average DPM concentration jig/m3 and the chronic DPM Risks/hazards

5.0 j.tg/m3

MEl

the residential

the potential

were

risks

from the 32 emergency

emissions cancer

to

health

of the dose-response assessment with the

the results

integrates

is

for the residential

MET

overstated

are slightly

approximately 100 meters south

located

of the southern

because edge of the

grid

Table Risk

15

Characterization Residential

Criteria

Cancer Risk in

Excess Chronic

Hazard

million

Index

MET

Workplace

MEl

100%

25%

100%

25%

Load

Load

Load

Load

2.2

4.4

3.3

8.3

0.0 17

0.043

0.00 15

0.0029

Conclusions

Rule 2-5 establishes allowable limits

specifies

sources

of

in Table Districts

for

TAC

cancer

emissions

15 The risk

excess

health

risks

risk

Project

risks

for

new

sources

of

TAC

and non-carcinogenic

risks are compared

for the proposed

thresholds

-22-

SC1

emissions

chronic

hazards

with the Districts

data center

The

project

policy for

new

risk thresholds

are below

the

Figure Location

of

Maximum

Exposed

Individuals

595000flE

i/

-23-

NAD27

Zone

lOS

595000m5

Table

14

Project Health Risk Criteria

Receptor

Load

25%

Resident Chrothc

Hazard

Index

INearest

Risk 2.2inamillion 4.4

100%

in

million

lOinamillion 10

in

million

0.00 15

25%

0.0029

100%

3.3

in

million

10 in

million

25%

8.3

in

million

10 in

million

Cancer Risk

Offsite

Worker

Threshold

Cancer Risk

Nearest

Excess

Risk

Project

Scenario

100% Excess

Risks

Chronic

Hazard

Index

100%

0.017

25%

0.043

-24-

Appendix

Equipment

Specifications

DETROIT DIESEL

16V4000G83 3D

Engine Percent Engine

Power

EPA

Tier

kWm

Load Speed

Exhaust

Mass Flow

Exhaust

Temperature

1/mm

m3/s

II

Exhaust Temperature

and Flow

2500

1875

1250

100

75

50

25

1800

1800

1800

1800

625

8.4

7.3

5.6

2.3

505

425

370

325

is

data

glkWh

PM

CO PM

HC

NOx

steady

cannot

be

used to to

and

compare

of

EPA

regulations

which

3D

test

data

not

for

guaranleed

to

these

values

shown

NOx HC CO emission data

measuring

The nominal

ISO 8178-1

0278

2144

0577

459

665kW

0382

1547

0476

4747

625kW

0427

1883

0.494

4.549

570KW

EN 590

end

cycle

are

to

89 due

Part fuel

based on weighted

emission

diesel

0171

1018

0277

4678

1370kW

0185

0742

0237

5175

1250kW

0182

0905

0236

4640

1140kW

EPA CFR 40 960 mbar and

in

0109

0884

0182

4958

2055kW

Field

3D

20V4000G43

0092

0740

0170

5631

use values

3D

16V4000G83

1875kW

described end variations

those

25

engine-to-engine

conditions

with

0737 0082

9/kWh

0177

6183

q/kWi

qlkWtf

gWh

2740KW

0065

0943

0120

7174

2500KW

_________-

are consistent

operating

facility

state

measurement

based on

instrumentation

shown

Emission

to

Data

glkWh

CO

UiiW

g/kWh

HO

gine

9/kWh

Unit

WOx

gine

0114

0074

9/kWh

0170 0631

0134

5456

1710kW

0799

glkWh

HC

6933

2280kW

16V4000043

gfWli

gfkWh

Unit

Tier

NOx

Engine

Genset EPA

Co PM

03

measurement procedures

Nominal1

Emission

data

Nominal1

Emission

Emission

Nominal1

Baumuster

Emission

Emissionsdaten

PM subject

and is

Aniage

TKF-Nr 1014-07

Appendix Emission

Calculations

XERES VENTURES LLC SANTA CLARA DATA CENTER AUTHORITY TO CONSTRUCT APPLICATION

MAXIMUM

EMERGENCY GENERATOR ROUTINE OPERATION

EMISSIONS

100%

75%

25%

Work

Output

kW

50%

Engine

2.500

1875

1250

625

Engine

Work

Output

bhp

3350

2513

1675

Exhaust

Temperature

deg

Exhaust

Temperature

deg

Exhaust

Flow wacfin

Exhaust

Flow

Parameter

Annual

wet

505

616

796

697

15477

11873

4876

8.4

7.3

5.6

2.3

50

50

50

50

100%

75%

Emissio Pollutant

325

940

Hours

Operating

838

370

17809

m3/sec

actual

425

Factors

50%

25%

NOx g/kW-hr

7.174

5.63

5.175

4.747

PM1O g/kW-hr

0.065

0.092

0.185

0.382

Emissio

Factors

100%

75%

50%

glbhp-hr

5.35

4.20

3.86

3.54

PM1O e/bhn-hr

0.049

0.069

0.138

0.285

Pollutant

NOx

Hourly

Emi

25%

Ib/lir

100%

75%

50%

NOx

39.5

23.3

14.2

6.53

PM1

0.36

0.38

0.51

0.53

Pollutant

Annual Emissions Pollutant

NOx

25%

lb/yr

100%

75%

50%

1975

1163

712

327

17.9

19.0

25.5

26.3

PM1O

25%

Notes Engine

work

output

in g/kW-hr Annual

were

in

kW

exhaust

obtained

operating hours

reflect

from the

in deg

temperature

MTU

Detroit Diesel

maintenance

and

exhaust the

testing

flow

rate

in m3/sec

and emission

factors

generator manufacturer

limits

of the

ATCM

for

Stationary

Compression

Ignition

Engines Hourly

emissions

in lb/hr

were

calculated

from

the

Annual

emissions

in lb/yr

were

calculated

from

the hourly

emission

factors

emissions

in g/bhp-hr in lb/br and

and engine annual

work

operating

output hours

in

bhp

in hr/yr

XERES VENTURES LLC SANTA CLARA DATA CENTER AUTHORITY TO CONSTRUCT APPLICATION

MAXIMUM

EMERGENCY

NOx EMISSIONS

GENERATOR Engine

Description

Load

100%

75%

50%

25%

1250

625

Work

Output

kW

2500

1875

Engine Work

bhp

3350

2513

1675

838

Output

4.747

Engine

NOx NOx

Emission

Factor

g/kW-hr

7.174

5.631

5.175

Factor

g/bhp-hr

5.35

4.20

3.86

3.54

Emission

39.5

23.3

14.2

6.53

90%

90%

90%

90%

3.95

2.33

1.42

0.65

15

30

60

60

12.8

12.8

14.2

6.53

Uncontrolled

SCR

Control

Controlled

Efficiency

Emissions

Startup Duration Controlled

lb/br

Emissions

SU

lb/br

mm

Emissions

lb/br

12.8

11.6

10.9

10.4

Emissions Uncontrolled

N/A

11.6

7.12

3.27

Emissions Controlled

N/A

11.0

10.6

10.2

w/LoadBanklb/br 30-mm 30-mm

ib lb

Notes Uncontrolled Controlled

emissions

emissions

reflect

reflect

no use of

the

the use of the

SCR system

SCR

system

once

its

operating

temperature

is

reached

Attachment B One-Hour NO2 Air Quality Impact Analysis March 12, 2010

March

sierra

12 2010

research 1801

Street

CA

Sacramento

Memo to

Tamiko

Endow

Bay Area

From

Fax Ann

Arbor

Quality Management

to

District

SC1 to

data center

proposed

32

install

LLC

Ventures

be

constructed

diesel

filed

for

District

an

Santa

the

with

application

Authority

in

emergency

Risk Assessment

Clara Data Center

Santa

Clara California and

generators

Bay Area

ATC

Construct

to

Air

permits for

Xeres Ventures heaters at

permit-exempt space

this facility

The

City of Santa

Clara

City

and

Study

ATC

issued

Mitigated contained

application

assumed the

an

air quality

type and

size

While

ambient

national

air

the

that

permit

health

quality standard

associated

AAQS

did not contain with

diesel

In

2009

October that

California District

Sierra

one-hour

reviewed

Research

evaluated

further

operations such

submitted

and with

report and raised

The report suggested could

that

result

exceedances

process with

risk

to

the

risk

in

the

the following

NOx

emissions

exceedances

might warrant

the

AQIA the

Furthermore

HRA

demonstrating

from

the

thresholds

SC

health

of Xeres Ventures

project with risk

the

thresholds

The

issues

from SC

associated

with

of the California one-hour

further

average

NO2

District on behalf

Districts

the

project of this

for

DPM emissions

matter

Districts

Initial

even though

AAQS

NO2

the

November 2007

The

the annual

assessment

compliance of the proposed

NO2 AAQS

this

health

particulate

emergency

2008

to

an

City prepared

nitrogen dioxide

for

the

with respect

AQIA

analysis

of the California one-hour

generators would comply with

report

The March

its permitting AQIA AQIA demonstrated compliance

application

risks

impact

in

as part of

showed an apparent exceedance original

Agency

review

Declaration

Negative

does not require an

District

of Lead

role

CEQA

Quality Act

California Environmental

evaluation

and/or

emergency

NO2 AAQS

mitigation

and

under

CEQA The Districts calculations of excess

maximum exposed

individual

MEl

cancer

risk

at

Ml

761-6755

Impact Analysis and Health

Air Quality

Xeres Ventures

November 2007 Xeres

District

J3Ii-

NO2

One-Hour for

new

Management

Dan Welch

Subject

In

Air Quality

95811

916 444-6666 916 444-8373

Tel

the location

of the

would exceed the Districts

risk

workplace threshold

Endow

Tamiko

This

memorandum

Based on that

NOx

emissions

on

were

NO2 AAQS

Districts

the

NO Air NOx

potential

related

consulting with

emergency

The

District

of

sufficient

below

decay option

within

minutes

As was

in

impacts

and

and 10%

the

for

corresponding

data were taken

using

at

assumptions

an

receptors driven

ozone

for

staff

for the

account

nearby

account

as

after

conservative

and

limiting

NO

all

NO

to

given of 12

half-life

of the

estimate

90%

that

step

of the

all

of the

This

without

NOx

AERMOD

using

were assumed

NO

be

AERMOD

using

any ozone form NO2

emissions

with

the

exponential

an estimate

provides

were multiplied by 0.9

NOx

of

decay

NO

emissions

are

the

reflecting

emitted

form of

in the

NO

form of NO2

of the third step were

NO2

from the

concentrations

of the

results

first

on an hour-by-hour

basis

analysis was

background the

subtracted

the rate-limited

hour by adding

from

to

emissions

NO2

as

expressed

NOx

four-step process

of 12 minutes

half-life

determine

each

to

of the

90%

remaining

were modeled

in the

results

hour-by-hour

to

reaction to be

the

District

by

thus assuming that

receptor-by-receptor

impact

and

with revised

NO

regarding

generators

available to fully oxidize

10%

AQIA

the

of the second

results

assumption

An

concern

of the

was used

which provides

were modeled

concentrations

to

is

were determined

options

option

AQIA

PVMRM

As recommended

our prior

Project impacts

step

conclude

further

address this concern

AERMOD

not use

the analysis

Project impacts

The

of the

Attachment

see

limiting

To

refined

ozone

form of NO2 and

NO2

The

does

sufficient

case with

the

Project

that

was used

in the

We

expressed

operation

time has not lapsed to allow

reaction time

reaction rate

District

from ozone-oxidized

formation

This method

assumes

the

AAQS

NO2

prepared

NO2

because

sufficient

believe

emergency

triggering

conditions

emergency

Sierra

as

rate

with

outlined

staff

operation

further

the event

we

exceedances

in

of 25 hours per year per engine risk at the workplace MET that would

cancer

submission

associated

impacts

completion

excess

result

of these issues

staff

Quality Impact Analysis

exponential

be

operation

of the engines

if

District

12 2010

threshold

risk

reduced

to

meteorological

California one-hour

to the

and only

adverse

our October 2009

After reviewing

would only

operation

calculated

address both

to

analyses

consultation with

in

infrequently

with

average would yield

One-Hour

for

coincide

to

on non-emergency

limit

not exceed

the

of further

results

emergency

during

California one-hour

that

the

presents

more refined analysis prepared

operation

March

-2-

performed the

NO2

San Jose

calculating

maximum

project

concentration Jackson

Street

the

maximum

NO2

for that

impact

hour

monitoring

total

for

NO2

each

hour to

Background station

NO2

Tamiko

Endow

March

-3-

12 2010

emergency operating scenario the frequency number of hours per year which an exceedance was calculated to occur was determined during For each

The

total

impacts

SC

proposed

associated

NOx

with

data center obtained

The

AERMOD

The

AQIA

indicates

emissions

that

associated

with

SC1 data center would not cause an exceedance 339 ig/m3

emergency

and

of the California one-hour

NO2

the 30-minute

for

Exceedances

which the engines

hour during

the simultaneous

operation

including

frequency

with which

an

emergency

exceedances

is

occurred

startup

each

during

if the

per year

NO2

in

to

50%

the

engines

the model results

hour of the year there

engine

was

at

operation

was

75%

the

and

load case

necessary

of the less

of

for

the

first

hour of

full

indication that

suggest

of the such

if

would be 205

50%

operation

violation

yield

i.e As an

emergency

32

all

aligning with

startup

concentrations

than 2.5%

less

of

engine

subsequent

NO2 AAQS

scenarios

emergency were calculated only

an

for

up

violation might occur

of an emergency

background

AAQS

such

controlled

AAQS

Table

of the proposed

operation

of the California one-hour

fully

startup

per year if the subsequent

exceedances probability

were

started

emergency

in

under separate cover

disks provided

on compact

of the

operation

summarized

refined analysis are

in the

data files are included

from emergency

emissions

load and only

Accordingly

the

meteorology and

NO2

California one-hour

than 0.06%

75%

in the

load case

Table Total

Impacts

Ambient Air

to

Ambient

Emergency

Quality

Refined

Operation

Analysis

Annual Exceedances

tg/rn3

Impacts

75%

50%

75%

50%

Load

Load

Load

Load

330

307

Startup

366

439

Controlled

175

160

Source

30

Minutes

205

Notes Reflects

associated

exponential

Where

the

decay

option

modeled

concentration

with

total

each

for

hour plus of

operation

emergency

32

all

the

maximum modeled determined

as

engines

impacts

of

NOx

the

using

AERMOD

within

startup

same hour yield

the

emissions impact

for

in

hour plus

given

excess

of

the

the

background

California 1-hour

NO2

concentration

for

AAQS

NO2

Risk Assessment

Health

In reviewing

the

worker

pathway Analysis

worker

NO2

background

emissions

October

2009

unit

factor

risk

and Reporting

URF

reflects

HRA

URF

Program

exposure

the

for

District

was

HARP hours

determined

the appropriate

6.29x105 m34tg using

CARBs

multi Hotspots

computer program see Attachment per

day

days

per

week

This

49 weeks per year

Endow

Tamiko

over

40-year that

workplace

MEl

tg/m3

an

additional

Emissions

were

restricted

likely

Fenceline

receptors

to

The maximum annual of

unit

rate

locations

of the residential

25

emission

from

emissions cancer

risk

tgIm3 to

and

days

per

the

the

the

Sd

maximum

not be

32

in

32

14

of Sierras

unit

report

MEl

million

in

emission

g/sec

with

rate

with

with

that

were excluded

the

per

year

in

.tg/m3

also

risk

for the

non-emergency

for

limited to the worst-case

workplace

of the annual also

are

DPM

Table

The

for

cancer

hours risks

thresholds

overstated

excess

concentration

per day or

for the

estimate

dispersion scenario

exposed

Furthermore

because

i.e non-emergency

emission worst-case

from the

workers concurrently

risk is

in

at the

MET

were recalculated

DPM

conservative

provides

the

per g/sec

workplace excess

operation

Table

from the annual

average

MET

unit

in

the product

was not discounted

workplace

was evaluated

modeled

the

resulting

as

summarized

m3/ig

2.81 xl

the exposure

and

operation

calculated

of the annual

The

MET

resulting

are

generators product

i.e

risks

to

summarized

concentrations

impact

cancer

from

were located

that

nearest receptors

non-emergency

generators unit

to

line

are

individual

ambient

average

DPM URF

cancer

neighbor

corresponding

data center project are below the Districts

scenario

workers

the

generators

hours

and

rail

per g/sec

emergency

excess

as

to

were deleted

j.tg/m3

associated

annual

or 49 weeks

associated

the

when

800 am and 500 pm

of nearby

adjacent

maximum exposed

emissions

excess

Table

in

threshold of 10

of the street and

sides

emergency

effective

week

load operating impacts

the

The

was calculated

non-emergency

proposed

The

exposure

the 32 emergency

Table

in

times

at

million at the workplace

hours between

the

in g/sec and the annual

rate

summarized

for

reflect

to

At the maximum annual

m3/tg

modeling analysis i.e

and roadway

emissions

hours per year

risk

URF

hours Monday through

In particular fenceline receptors

impacts

for

g/sec

annual emissions

to

distant

emission

Maximum annual

workday

shown

as

this

concurrently

during

of 60.7 in

not immediately

line

rail

were those on the

at

cancer

simultaneous

modeling analysis

adjacent

discounted

12 2010

assumptions

match the

the

MET

risk

cancer

excess

i.e

of 2.81 xl

refined unit impact

performed

following

excess

Districts

the

URF

the workplace

for

further

would occur

worksite

at the

effective

an

calculated

which exceeds

the

in

resulting

the District

Sierra

was present

District

emissions

non-emergency

of 0.216

impact

The

period

exposure

likelihood

Friday

March

-4-

the

of the

operation of

25% would

25% load

Tamiko

Endow

March

-5-

12 2010

Table Refined

Worker

Health

Risk Assessment

MET

Workplace Criteria

Maximum p.gIm3

25%

100% Load

Annual Unit Impact

Load

119

186

8.9

13.1

per g/sec

Maximum

Annual Emissions

ib/yr

Maximum

Annual Emissions 1.29E-04

1.89E-04

0.0153

0.0351

g/sec

Maximum

Annual Impact

tg/m3 URF m3/ig Excess Risk Note

Cancer Risk

Reflects

for

original

and acute values

HARP-derived

the

hours

exposure per day

hazard

presented

in

million

10 in

million

4.3

Threshold

concurrent

Chronic

2.81x104 m3/ig

to or

worker

of 6.29x

9.9

in

10 in

m3I.tg

million million

further

non-emergency emissions i.e the exposure days per week or 49 weeks per year

indices were

on Page

URF

2.81x104 m3/tg

adjusted

to

not re-calculated for this analysis because

24 of

the

October

2009 report

are

reflect

was not discounted

the

well below the

Districts hazards thresholds

If

you have

Attachments

any questions

about

this

memorandum

please call

me

at

916

273-5130

Attachment

Peradi-Robinson

Memo June

1976

OFFI CT June

TO

ROBINSON

FROM

PERARDI

SUBJECT

NO/NO2

The fractional mated with the

CONVERSION

coflverSjon equation

of

MORANDUM 19/b

CALCULATIONS

IN

source

ambient

NO

to

PERMIT

ANALYSES

NO

can

be

esti

1_eOS77t where NO2 at

is

the

time

at

any

fraction

of original NO which will be converted to after leaving the emission point Thus and time1

minutes

given

location

concentration concentration where The

NO

volume

by

NO by

volu

NO2

NO

important When

N02

element

th

in the

is equation exponential argument the factor provides half-life of 12 minutes as suggested at al science by Davis 186/733 22 Nov This equation 1974 directly applicable when NO emissions are essentially all in the NO form as from many high temperature combustion If sourCes source emits significant quantities of both NO and NO this would analysis apply only to the portion originally emitted as NO Davis found 50% conversion times in plumes to be in the 12 to 60 minute range Using worst case scenario with untab1e conditions and 60 ppb ambient the 12 Ozone minute half-life applies

.0577

is

in

minutes

In RP permit the degree evaluations of ND/NO2 conversio is cal culated with the BASIC computer program NONOX TEP Feb l976 The program requires input of series of ground level NO concentrations along with the corresponding downwind ____ is alsequir that elapsed time can be calcu lated from distance data These data are normally obtained input from Gaussian of NO dispersion0 modeling The region near the for NO is investigated CLCmax for degree of conversion to NO2 For any given distance and corresponding time the concentration of NO2 is equal to times the concentration of NO The NO2 maximum generally occurs moderate distance downwind from th maximum

Thensed

NO

TheGLCa

for

NO2

can

then

which dioxide

NO2

alone

be

were

compared

to

promulgated

the

state

in terms

of

and

federal

nitrogen

air

Attachment

HARP

Output

for

Worker Exposure

to

DPM

file

This

Created

C\HARP\PROJECTS\DjeselpM\wkrCancertxt

by HARP Version Version 99155

Uses

ISC

Uses

BPIP

Dated date

Creation

EXCEPTION

l.4a

Build

23.07.00

04112

92150

6/11/2009

AM

REPORT

there have

been

no

FILES SourceReceptor

changes

or

exceptions

INPUT

file

Averaging period adjustment Emission rates file none Site GLC

file

parameters

factors

file

not

applicable

C\HARP\PROJECTS\DleselpM\project.sit

SOURCE

DATA

concentrations loaded from file c\HARP\STARTUP.CML chemicals concentrations and/or have been edited by User memo CHEMICALS

ADDED/DELETED DieselExhPM

ADDED

mode

Screening

is

USER

Standard

work

schedule

yrs Method Point Analysis Health Effect Cancer SITE

estimate

PARAMETERS

DEPOSITION Deposition DRINKING

m/s

rate

WATER

Pathway

disabled

Pathway

disabled

FISH

PASTURE Pathway HOME

GROWN Pathway

PIGS

disabled PRODUCE disabled

CHICKENS

AND

user

OFF

Duration

Exposure

BY

the

EGGS

0.05

49 wks/yr

days/wk

hrs/day

40

Pathway DERMAL

disabled

ABSORPTION

Pathway SOIL

disabled

INGESTION Pathway

MOTHERS

disabled

MILK disabled

Pathway

CHEMICAL

GROUND

multipathway ABBREV GLC Pasture

LEVEL

CONCENTRATIONS CAS

GLC

CHEMICAL

GLC

TABLE ABBREVIATION

9901

EMISSIONS

DATA

CHEMICALS

ADDED

POLLUTANT

DieselExhPM

Diesel

SOURCE OR DELETED

EMISSIONS FOR FACILITY SOURCE MULTIPLIER CAS

DOSE

BY

CHICK

FAC

DEV

l.000EQ0

exhaust 0.000E0Q

engine

PRO

STK

MULTIPLIER

mg/kg-d

DERM

SOIL

PIG

EGG

0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00

CANCER

CHEM

INHAL CHICK

particulate

matter

NAME BG

ug/m3

FOR CANCER CALCULATIONS MOTHER FISH WATER

5.72E-05

AVERAGE BEEF

PATHWAY

INHAL

0.OOE0Q

0.OOE00

AVRG

lbs/yr

VEG

DAIRY

0.OOE00

0.OOE00

0.OOE00

WATER

VEG

DAIRY

RISK DERM

SOIL

PIG

EGG

MOTHER MEAT

FISH ORAL

TOTAL

6.29E-05 0.OOE00 0.OOE00 0.OOEQ0 0.OOE0Q 0.OCE00 0.OOEO0 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 O.OOE00 6.29E05 SUM 6.29E05 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOE00 0.OOEQ0 0.OOE00 0.OOE0O 0.OOE00 6.29E05 0001

Water

none

ABBREV

0001

GLC

NAME

lbs/br

CHEM BEEF

Max

ug/m

Diesel PM

AVERAGE

not

CROSS-REFERENCE

BACKGROUND

MAX

GLC

Avrg

1.000EOQ

9901

CAS

0001

indicates

Fish

DieselExhPM

CHEM

kk

micrograms/m3

chemical

0.OOE00 0.OOE00

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS Technical Area: Visible Plume and Plume Velocity Analysis Author: Joseph Hughes IC Engines Plume Vertical Velocity Analysis BACKGROUND The proposed project is located 0.4 miles west of the San Jose International Airport. Given the close proximity of the project to the airport, and the potential for low flying aircraft such as helicopters and/or planes to be in the area of the plant, a thermal plume velocity analysis may have to be conducted, based on information you provide, for the 32 diesel-fired internal combustion engines (IC engines). Thermal plumes are a concern to aircraft safety due to the potential for causing unexpected near-ground turbulence. Staff will need the applicant to verify and/or provide several necessary operational and design values for the 32 diesel-fired IC engines to complete the modeling analysis. The information provided should be based on full load operations (i.e., emergency cases when all IC engines are running full load). CLARIFICATION ISSUE 1.

Please provide or verify the following necessary modeling input values: Parameter Number of Exhaust Stacks

Diesel Fired Internal Combustion Engines 1

1 or 32?

Stack Height

16.6 (m) [54.5(ft)]

Stack Diameter

2

Stack Exit Velocity

0.4572(m) or 0.6096(m) [1.5(ft) or 2(ft)]? 3

17.3489(m/s) to 28.3461(m/s)? 3

Stack Exit Temperature 643.1500(K) to 778.7056(K)? (1) amec modeling assumed all emissions (including boilers) emit from one stack. (2) Values differ from the amec modeling results and the amec Table 2 “Summary of emission characteristics SC-1”. (3) Provide values for full load emergency situation cases.

RESPONSE: The stack parameters used in the modeling of full load operating scenarios by Sierra Research are summarized below: Parameter

Diesel Fired Internal Combustion Engines 32

Number of Exhaust Stacks Stack Height

16.6 (m) [54.5(ft)]

Stack Diameter

0.4572(m) [1.5(ft))] 51.2 m/s

Stack Exit Velocity

778 K

Stack Exit Temperature

August 2011 (revised October 31, 2011)

1

Santa Clara SC-1 Data Center Data Requests

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS 2.

Please provide a description of the IC engines exhaust stacks including; location, orientation and quantity (i.e., to-scale drawing that shows all engine stacks, new and existing). RESPONSE: All 32 stacks were modeled. The stack locations and elevations were obtained from the ISCST3 model input file that the Bay Area Air Quality Management District provided to Sierra Research. Sierra confirmed that the location of these stacks fit the location of the engine block area on the DFT site plan. A copy of the site plan is included as Attachment A. The UTM coordinates (NAD 27) used to model emissions from the 32 emergency generators are summarized below:

Source ID S1 S2 S3 S4 S5 S6 S7 S8 S9 S10 S11 S12 S13 S14 S15 S16 S17 S18 S19 S20 S21 S22 S23 S24 S25 S26 August 2011 (revised October 31, 2011)

X (m) 593673.1 593674.9 593677.9 593680.4 593683.4 593686.4 593688.2 593690.6 593692.9 593695.4 593697.8 593700.2 593702.6 593705 593708 593710.4 593601.6 593603.4 593605.8 593608.2 593611.8 593614.8 593617.9 593620.9 593624.4 593626.9 2

Base Elevation Y (m) (m) 4135321.2 15.5 4135313.5 15.6 4135307.0 15.7 4135300.2 15.8 4135294.2 15.8 4135287.8 15.9 4135282.2 15.9 4135276.8 15.9 4135272.0 15.9 4135266.0 15.9 4135259.5 15.9 4135254.0 15.9 4135248.0 16.0 4135242.5 16.0 4135236.5 16.1 4135230.0 16.1 4135474.0 14.9 4135467.2 14.9 4135462.0 14.9 4135455.2 14.9 4135448.0 14.9 4135441.5 14.9 4135434.2 15.0 4135427.0 15.1 4135421.0 15.1 4135413.2 15.2 Santa Clara SC-1 Data Center Data Requests

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS

Source ID S27 S28 S29 S30 S31 S32

X (m) 593630.4 593633.5 593636.5 593638.9 593641.9 593644.3

Base Y Elevation (m) (m) 4135406.8 15.2 4135399.5 15.2 4135394.0 15.2 4135388.0 15.2 4135382.0 15.2 4135376.0 15.3

Cooling Tower Visible Plume and Vertical Velocity Analysis BACKGROUND A thermal plume vertical velocity analysis may need to be conducted, based on the information you provide, for the cooling towers for the same reasons as the IC engines. In addition, a visible plume analysis may also need to be conducted to show that the project would comply with the potential significant threshold for visual resources and not interfere with traffic. Water vapor plumes can occur when the plume is more saturated with water than the carrying capacity of the ambient air. A determination is made whether a combination of exhaust and ambient air mixes to become supersaturated, where the water content is greater than the carrying capacity of the air at given temperatures and pressure, and a visible plume forms due to condensation of the water into droplets. Little information was provided on the cooling tower, so staff will need the design and operational criteria to complete the modeling analysis. CLARIFICATION ISSUE 3.

Please confirm that there will be two cooling towers on site. Provide a description of the location and orientation of the cooling towers (i.e., to-scale drawing that shows the layout of the cooling towers). RESPONSE: Upon completion of Phase I and Phase II of the project, there would be two cooling towers for computer server room cooling, each with eight (8) cells. Two of the eight cells would be redundant and only operate in case of failure of other cells. Cooling tower locations are shown in Attachment A. The dimensions of the cooling tower units are shown in Attachment B of this information response document.

4.

Please provide the assumptions for the cooling towers operations (i.e., hours per day, month and year). RESPONSE: Water will continually flow to the cells from the chiller plant. The fan for each cell will operate as needed. Fans will speed up or down based on the temperature of the water leaving the cell and going back to the chiller. The

August 2011 (revised October 31, 2011)

3

Santa Clara SC-1 Data Center Data Requests

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS cooler and drier the outside air, the less the fans have to work. See Response 5 below. 5.

Please summarize for the cooling towers the conditions that affect vapor plume formation including cooling tower heat rejection, exhaust temperature, and exhaust mass flow rate. Please provide values to complete the table below, and additional data as necessary for staff to determine how the heat rejection load varies with ambient conditions and also determine at what ambient conditions cooling tower cells may be shut down. If the cooling load does not change for ambient conditions and the heat rejection remains stable, then inputs are only needed for one operating condition (e.g., ambient temperature and relative humidity). Please include appropriate design safety margins for the heat rejection, exhaust flow rate and exhaust temperature in consideration that the air flow per heat rejection ratio is often used as a Condition of Certification confirmation of design limit. RESPONSE: As noted in Response 3, upon completion of both phases of the project, there would be two cooling towers for building and computer server room cooling, each with eight (8) cells. Six cells operate per cooling tower. The other two cells in each cooling tower are redundancies, or spares in case of failure. When the computer server rooms are fully occupied, the cooling load would not substantially change with ambient conditions and the heat rejection would remain stable. About three (3) percent of the building cooling load would be influenced by outdoor ambient conditions.

Parameter Number of Cells Cell Height Cell Diameter Tower Housing Length Tower Housing Width

Cooling Tower(s) Exhausts 8 (8 x1) per phase; 2 cells per phase redundant (only 6 cells operate per phase at one time) See Attachment B See Attachment B See Attachment B See Attachment B

Ambient Temperature

85.3°F DB

30°F

65°F

100°F

Ambient Relative Humidity Number of Cells in Operation Heat Rejection (MW/hr) Exhaust Temperature (°F) Exhaust Flow Rate (lb/hr) Exhaust Velocity (m/s)

50% 1 of 6 4.72 86.8 1,039,000 9.03

90% 1 of 6 4.74 59.3 1,139,600 8.85

40% 1 of 6 4.73 73.6 1,073,900 8.94

15% 1 of 6 4.72 83.6 1,011,000 8.99

August 2011 (revised October 31, 2011)

4

Santa Clara SC-1 Data Center Data Requests

SANTA CLARA SC-1 DATA CENTER INFORMATION REQUESTS 6.

Please provide the cooling tower manufacturer and model number information and a fogging frequency curve from the cooling tower vendor for the cooling towers RESPONSE: The manufacturer is Marley and the model number is NC8412TAS-01. Attachment C is a “Fogging Frequency Estimate Curve” for one cell of NC8412TAS-01 operating with 3240 gpm/cell at 91.4/81.4/71°F.

7.

Please identify if the cooling tower fan motors will be dual speed or have variable speed/flow controllers for either of two cooling towers. RESPONSE: Premium efficiency inverters provide for variable fan speeds.

August 2011 (revised October 31, 2011)

5

Santa Clara SC-1 Data Center Data Requests

Attachment A Aerial Photograph with Street Names Facility Plot Plans Facility Site Plan

M A RT I N

AVE. Norman Y. Mineta San Jose International Airport

Commercial Industrial Co-Generation Facility

ROBERT AVENUE

MATHEW STREET Private Recreation

Residential

Industrial Site

U.P .R.

S TR

EET Residential

P A RK E R

Industrial/ Office

Industrial Industrial/ Office

REED

STREET

S TR E E T

Industrial

R ST Industrial

T EE

Industrial

REED Reed St. Dog Park

Residential

Industrial

R.

E Residential/ Commercial

BOULEVARD

TT AYE LAF

Residential

Electrical Substation

CRUZ

TREET MATHEW S

DE LA

Industrial

Project Boundary Scale: 1" = ± 440' Photo Date: May 2011

Industrial

AERIAL PHOTOGRAPH WITH SURROUNDING LAND USES

N

Note: Parking lot and Landscaping at project site under construction in May 2011.

FIGURE 2-3

LOCATION OF BACKUP GENERATORS (IC ENGINES)

LA

CR UZ BLV D.

REED

MA THE W

STR EET

DE

SUBSTATION (UNDER SEPERATE PERMIT)

STREET

DATA CENTER

U.P.R.R. PROPOSED PHASE II WATER TANK

PROPOSED PHASE II COOLING TOWERS

EXISTING COOLING TOWERS

Source: CCG, Landscape Plan, LI.2, 2010.

LOCATION OF EXISTING AND PROPOSED COOLING TOWERS

EXISTING TANK

Attachment B Cooling Tower Cell Dimensions

Attachment C Fogging Frequency Estimate Curve

Estimated Fogging Frequency Curve for Holder - SC1- Data Center

CONFIDENTIAL: The Contents of this document are confidential and constitute the exclusive property of SPX Cooling Technologies. This document and its contents may not be made public in any manner, distributed or loaned to others, or reproduced or copied either in whole or in part without the prior written consent of SPX Cooling Technologies. © 2011 As of the date(s) in the title block SPX Cooling Technologies unpublished - All rights reserved under the copyright laws.

Model NC8412TAS-01 Number of Cells 1 Motor Output 40HP Motor RPM 1800 Fan 144" 6-Blade Fan RPM 242 (Full Speed)

90

Relative Humidity (%)

SPX Cooling Technologies TRACS Version 30-JUNE-10

85

Design Conditions: Flow Rate 3240GPM Hot Water 91.40°F Cold Water 81.40°F Wet-Bulb 71.00°F

80

Curve Conditions: Fan Pitch Constant Flow Rate 3240GPM ( 100% Design Flow ) OO# 10025862 Tangency

75

100.0%

FOGGING FREQUENCY CURVE: The curve shown to the left is referred to as a 'Fogging Freqency Curve'. The Fogging Freqency Curve separates entering cooling tower conditions that produce fog at the discharge (Top-Left region of chart) from those that do not produce fog (Bottom-Right region of chart)

70 

40

45

50

55

60 Wet Bulb (°F)

65

70

75

80

 X

10 °F Range Design Point

Time: 16:18:58 Date: 10-05-2011 Drawn By: MP