addendum to an initial study/mitigated negative

ADDENDUM TO AN INITIAL STUDY/MITIGATED NEGATIVE DECLARATION CORONADO DRIVE DATA CENTER AND STREET VACATION PROJECT

(FILE NUMBERS: PLN2013-09881!CEQ2013-0ll66)

June 16,2016

1.0 Purpose of the Addendum and Background

The California Environmental Quality Act (CEQA) recognizes that between the date a Mitigated Negative Declaration (MND) is adopted and the date the project is fully implemented, one or more of the following changes may occur: I) the scope of the project may change; 2) the environmental setting in which the project is located may change; 3) certain environmental laws, regulations, or policies may change; and/or 4) previously unknown information may arise. CEQA requires a Lead Agency to evaluate these changes and determine whether or not they are significant or otherwise substantially affect the conclusions in a previously certified environmental document.

The CEQA Guidelines (Section 15162) describes a process for determining whether a subsequent ISIMND is warranted:

a) When a negative declaration is adopted for a project, no subsequent MND shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:

1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects; or

3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:

City of Santa Clara

A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;

B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;

C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more

Coronado Drive Data Center and Street Vacation Project Addendum to ISIMND

September 2016

significant effects of the project, but the project proponents decline to

adopt the mitigation measure or alternative; or D) Mitigation measures or alternatives which are considerably different from

those analyzed in the previous MND would substantially reduce one or more significant effects on the environment, but the project proponents

decline to adopt the mitigation measure or alternative.

The City of Santa Clara (City) prepared an Initial Study (IS) and draft MND for the Coronado

Drive Data Center and Street Vacation Project in March 2014. The 2014 ISIMND evaluated the potential environmental impacts which might reasonably be anticipated to result from the

proposed project, which consisted of two main components: I) demolition of existing building on the site and construction of a new data center building and 2) vacation of a segment of

Coronado Drive to create an internal roadway on the project site.

The IS/MND was amended in 2015 to eliminate the Coronado Drive street vacation and proposed the internal roadway circulation currently designed for the project. The 20 I 5 addendum also evaluated the effects of a slightly reduced building footprint for the data center. The 2015 addendum determined that the project changes did not change the conclusions in the IS

or result in the identification of new significant environmental impacts or mitigation measures.

The City adopted the IS/MND addendum in February 2015.

In accordance with CEQA and the City's requirements for the preparation of environmental documents, the purpose of this addendum is to disclose the environmental impacts associated

with additional proposed changes to the project, as described below.

2.0 Proposed Changes to the Project

Since the adoption of the ISIMND, plans for the project's backup generators have changed from the originally proposed Tier 4 engines to Tier 2 engines with diesel particulate filters. The

generator engines would be fueled using ultra low sulfur diesel fuel with a maximum sulfur content of 15ppm. The Tier 2 generator engines would meet U.S. EPA Tier 2 emission standards.

The generator equipment and operating specifications for the proposed generators are provided

in Table 1.

City of Santa Clara 2 Coronado Drive Data Center and Street Vacation Project

Addendum to IS/MND September 2016

T bl 1 E a e . ngme G t s t E t dO f I f f enera or ~ys ems "qmpmen an Jpera mg n orma IOn Description Value

10 Cummins 2500DQKAN Generators QSK60-G19 engines (EPA Tier 2 engines)

Generator Output (at I 00% load) 2,500 kW

Engine Output (Standby) at I 00% Load 3,640 horsepower

Diesel Fuel Consumption at I 00% Load 173.1 gallons/hour

Diesel Fuel Sulfur Content 0.0015% (15 ppm)

Exhaust Flow Rate at 100% Load 18,269 actual cubic feet/minute Stack Height (above ground level) 60 feet

Stack Inside Diameter 18 inches

Exhaust gas Temperature at 100% Load 1,022 °F

The remaining aspects of the project (i.e., building footprint, power usage, etc.) that were

previously evaluated in the ISIMND, as amended in 2015, have not changed.

3.0 Environmental Impacts of the Proposed Change to the Project

The area of disturbance, amount of soil excavation, and client and employee trips would be the same as disclosed and analyzed in the adopted IS/MND. The project changes would have the

same impacts in regard to the following environmental issues:

• Aesthetics • Mineral Resources

• Agricultural and Forest Resources • Noise

• Biological Resources • Population and Housing

• Cultural Resources • Public Services

• Geology and Soils • Recreation

• Greenhouse Gas Emissions • Transportation

• Hazards and Hazardous Materials • Utilities and Service Systems

• Hydrology and Water Quality • Cumulative Impacts

• Land Use

The revised project includes changes in the backup generators for the SV7- 3032 Coronado

Drive Data Center building. Therefore, air quality impacts of the revised project are evaluated below.



Air Quality

The information in this section is based on an updated air quality analysis that Illingworth &

Rodkin, Inc., conducted for the changes to the proposed back-up generators for the project (Attachment 1). Given that all other aspects of the project would remain unchanged, air quality impacts related to the project's consistency with the construction activities, and the associated

mitigation measures, would not change.

The proposed change of utilizing tier 2 generators rather than tier 4 generators will have a less than significant impact on air quality. Furthermore, because the project will not co~flict with

measures in the Bay Area 2010 Clean Air Plan (20 10 CAP) to reduce air pollutant emissions, and would not affect forecasts used for Clean Air Plan projects, the project would not conflict with implementation of the 2010 CAP. No changes to the 2010 CAP consistency analysis in the

adopted IS/MND are warranted.

Operational-Related Emissions

Section 4.3.2.4, Operational-Related Impacts from the Project, of the IS/MND discusses the

operational sources of air pollutants from the project. Under the currently proposed Tier 2 generators average daily and annual emissions from routine back-up generator testing would increase. The two changes to the analysis of air quality impacts in the IS/MND would be (1) an increase in annual and daily average emissions of criteria air pollutants and ozone precursors and

(2) and change in community risk impacts. A detailed analysis of these changes is included as

Attachment 1 to this addendum. The following is a summary of the changes to air quality analysis in the adopted IS/MND.

The project would install ten Cummins Model QSK60-G19 NR2 Engines (Tier 2 equipped with Miratech LTR Diesel Particulate Filters). These generators would be located in the same location

as evaluated in the IS/MND, within the data center in the northwest corner of the first floor. During normal facility operation these engines would not be operated other than for periodic

testing and maintenance requirements. The generator engines would be fueled using ultra low sulfur diesel fuel with a maximum sulfur content of 15 ppm and would meet U.S. EPA Tier 2

emission standards. These generators will require pe1mits to construct (or install), known as an "Authority to Construct," and a permit to operate by the Bay Area Air Quality Management

District (BAAQMD). The BAAQMD has evaluated the air quality permitting issues associated with the project and released draft permit conditions to ensure that their requirements are met by

the facility when operating:

a) The owner/operator shall not exceed a total of 2 hours per day for reliability-related testing ofall10 engines combined (Basis: CEQA).

b) The owner/operator shall monitor and record the following in a District-approved log (Basis: CEQA):

1) engine load;


Addendum to ISIMND September 2016

2) date and times of all reliability-related testing c) The owner/operator shall ensure the average daily load during reliability-related testing

does not exceed 80%, averaged on an annual basis. The average load shall be calculated as follows (Basis: CEQA):

I) For each day of operation with reliability-related testing, calculate that day's average load: [(loadi x hours of operation at loadi)+(loadii x hours of operation at loadii)+ ... ]/(hours of operation)

2) Every 12 months, calculate the average daily load: [loaddayl + loadday2 + ... ]/(days of operation with reliability-related testing)

The generator equipment and operating specifications for the proposed generators are provided in Table 1. These operating specifications incorporate the BAAQMD permit conditions presented above.

Testing of the generators would generally be performed once per month to make sure that they are ready to come online when needed in the event of a power failure. The testing is proposed to normally take place between the hours of9:00 AM to 5:00PM. During normal generator testing, the engines would be operated one at a time for I 0 minutes with an engine load of less than 20 percent. In addition to the normal engine testing and operation for maintenance purposes, each engine would w1dergo generator load testing for up to four hours per year with an engine load of

up to 50 percent. Total generator engine operation under normal conditions is expected to be about 6 hours per year, per engine. However, engine operation may occur more frequent due to increased testing or maintenance requirements. BAAQMD permit conditions limit daily testing of generators to 2 hours per day at SO-percent of full engine load, averaged annually. In addition, operation of each diesel generator is limited to 50 hours per year of non-emergency use (i.e. testing and maintenance) by the State's Air Toxic Control Measure for Stationary Compression Ignition Engines.

The estimated emissions from the engines under maximum operating conditions are shown in Table 2. Assuming each generator is operated at 80-percent load for 50 hours per year, the average daily emissions ofNOx from the project would not exceed the significance threshold of

54 pounds per day and the annual threshold of I 0 tons per year. Therefore, the project will have a less-than-significant operational air quality impact for criteria pollutants under the proposed Tier 2 generators. (Less Than Significant Impact)


Addendum to ISIMND September 2016

T bl 2 T t IE ' ' f a e oa miSSIOnS rom p 0 roJect JperatJon Nitrogen Reactive Respirable Fine Oxides Organic Particulates Particulates

Emission Source (NOx) Gases (ROG) (PM to) (PM2.s)

Emergency Generators 5.8 tons 0.3 tons 0.14 tons 0.14tons Mobile Sources 0.1 tons 0.04 tons 0.04 tons 0.02 tons Total in tons 5.9 tons 0.34 tons 0.18tons 0.16tons BAAQMD Threshold 10 tons 10 tons 15 tons 10 tons Average Daily 32 pounds 2 pounds I pounds <I pounds BAAQMD Threshold 54 pounds 54 pounds 82pounds 54 pounds Sif(nificant? No No No No

Community Risk Impacts


The proposed project would be a source of air pollutant and toxic air contaminant (TAC) emissions from operation of emergency generators for testing and maintenance purposes. These generators are diesel-fueled, so they emit diesel particulate matter (DPM), which is a TAC. The generators are also a source ofPM2.5, which has known adverse health effects. Community risk impacts from air pollutants and TACs were addressed in the IS/MND; however, an updated risk analysis was completed to reflect the changes in emissions from proposed Tier 2 generators, and to assess potential risks to the proposed residential areas of the recently approved Santa Clara Square Project, which was not proposed when the original IS/MND was prepared. In addition, the cancer risk calculations conducted as part of this updated analysis incorporate the latest State guidance issued by The State of California Office of Environmental Health Hazard Assessment (OEHHA). A detailed analysis of the updated community risk impacts, including methodology and assumptions, is included as Attachment 1 to this addendum.

Table 3 shows the predicted community risk levels from the operation of the proposed emergency generators for the closest off-site residence to the data center, under maximum generator operating conditions (50 hours per year). Since the increased cancer risks from exposure to DPM emissions from the proposed project would be much less than I 0 in one million, and annual PM25 concentrations at sensitive receptors are less than 0.3 J.Lglm3

(BAAQMD thresholds of significance), the changes to the project back-up generators would not result in a local community risk and hazards impact. (Less-Than-Significant-Impact)



Table 3. Maximum Increased Community Risk Levels from Emergency Generator 0 (SOH Y G ) Jperatwn ours per ear per en era tor

Maximum Cancer Risk Annual PM2.s Maximum

Sensitive Receptor (per million) (Jtg/m3) Hazard Index Off-Site Residence 1.6 < 0.01 < 0.01

BAAQMD Single Source Threshold 10.0 0.3 1.0 Significant? No No No

4.0 Conclusion

The changes to the type of back-up generators for the project would not result in any new

significant environmental effects or substantial increases in the severity of the previously

identified significant effects of the adopted ISIMND.

None of the conditions described in § 15162 of the CEQA Guidelines requiring for the

preparation of a subsequent FEIR have occurred. Therefore, this Addendum to the adopted

IS/MND is an appropriate level of environmental review for the proposed project changes, as

identified in §15164 of the CEQA Guidelines.

/£ec;>~,)J Jc~~ _;#) ~rew Crabtree /

Community Development Director


Date


Attachment 1 Air Quality Assessment

IUJNGWORTH&RoDKIN,INC. 1111• A co us tics • A i r 0 u a I it y IIIII

1 Willowbrook Court, Suite 120 Petaluma, California 94954

Tel: 707-794-0400 www.Jllingworthrodkin. com

July 18, 2016

Jennifer Gallerani Marquez Circlepoint 1814 Franklin Street, Suite 1 000 Oakland, CA 94612

Via Email: Jennifer Gallerani <J [email protected]>

Fax: 707-794-0405 illro@illingworthrodkin. com

Subject: 3032 Coronado Data Center Revised Air Quality Ana lysis

Dear Jennifer:

Illingworth & Rodkin, Inc. evaluated air quality impacts from a proposed data center at 3032 Coronado Drive in Santa Clara and rep01ted those results in November 2013 1

• The primary source of emissions from the data center would be from operation of the generator engines during testing and maintenance of emergency generators. During normal facility operation these engines would not be operated other than for periodic testing and maintenance requirements. The 2,500 kW generators would use diesel-fueled engines that meet U.S. EPA Tier 4 interim emission standards, the most recent emission tier level for new diesel engines of this size.

We understand the project has slightly changed in that the generators would be different. The proposed project would install ten 2,500 kW emergency generators with Cummins dieselfueled engines that would instead meet U.S. EPA Tier 2 emission standards. These generators will requ ire permits to construct (or install), known as an "Authority to Construct," and a permit to operate by the Bay Area Air Quality Management District (BAAQMD). The District has evaluated the air quality permitting issues associated with the project and released draft pennit conditions to ensure that their requirements are met by the facility when operating:

1. The owner/operator shall not exceed a total of 2 hours per day for reliability-related testing of alii 0 engines combined. - [Basis: CEQA]

2. The owner/operator shall monitor and record the following in a District-approved log:

a. engine load; b. date and times of all reliability-related testing - [Basis: CEQA]

1 lllingworth & Rodkin, Inc. 201 3. Coronado Data Center 3032 Coronado Drive Santa Clara California- Air Quality Assessment. November 6.

Jennifer Gallerani Marquez Circlepoint

July 18,2016 -Page 2

3. The owner/operator shall ensure the average daily load during reliability-related testing does not exceed 80%, averaged on an annual basis. The average load shall be calculated as follows:

For each day of operation with reliability-related testing, calculate that day's average load: [(!oadi x hours of operation at loadi)+(loadii x hours of operation at Joadii)+ .. .]/(hours of operation)

Then each 12 months, calculate the average daily load: [loaddayl + loadday2 + .. .]/(days of operation with reliability-related testing) -[Basis: CEQA]

The conditions listed above are assumed to be part of the project description and were incorporated into the revised air quality analysis. The two issues are addressed in this reanalysis: (I) change in annual and daily average emissions of criteria air pollutants and ozone precursors and (2) and change in community risk impacts. This letter describes the changes in air quality impacts.

Emergency Generator Emissions

During normal facility operation these engines would not be operated other than for periodic testing and maintenance requirements. The generator engines would be fueled using ultra low sulfur diesel fuel with a maximum sulfur content of 15 ppm. The engines would meet U.S. EPA Tier 2 emission standards. These generators would be located within the data center in the northwest corner of the first floor (see Figure 1 ). The generator equipment and operating specifications for the proposed generators are provided in Table 1. These operating specifications incorporate the BAAQMD permit conditions presented above.

T bl 1 E a e ngme G s E enerator systems cqm mentan dO I f 1peratmg n ormatiOn Description Value

10 Cummins 2500DQKAN Generators QSK60-G19 engines (EPA Tier 2 engines)

Generator Output (at 1 00% load) 2,500kW Engine Output (Standby)

at 100% Load 3,640 horsepower Diesel Fuel Consumption

at 100% Load 173 .I gallons/hour Diesel Fuel Sulfur Content 0.0015% (15 ppm) Exhaust Flow Rate

at 100% Load 18,269 actual cubic feet/minute Stack Height (above ground level) 60 feet Stack Inside Diameter 18 inches Exhaust gas Temperature at 100% Load 1,022 °F

2


July 18, 2016 -Page 3

Testing of each generator would generally be performed once per month to make sure that they are ready to come online when needed in the event of a power failure. The testing is proposed to normally take place between the hours of 9:00 AM to 5:00 PM. During normal generator testing, the engines would be operated one at a time for I 0 minutes with and engine load of less than 20 percent In addition to the normal engine testing and operation for maintenance purposes, each engine would undergo generator load testing for up to four hours per year with an engine load of up to 50 percent Total generator engine operation under nonnal conditions is expected to be about 6 hours per year, per engine. However, engine operation may occur more frequently due to increased testing or maintenance requirements. BAAQMD permit conditions limit daily testing of generators to 2 hours per day at SO-percent of full engine load, averaged annually. In addition, operation of each diesel generator is limited to 50 hours per year of non-emergency use (Le. testing and maintenance) by the State's Air Toxic Control Measure for Stationary Compression Ignition Engines?

Emissions from the generators were computed following the method used by BAAQMD. BAAQMD uses the ISO Sl7S D2 cycle emission factors to estimate emissions from diesel engines. Engines are typically tested at low engine load. BAAQMD assumed SO-percent load and used the D2 cycle emission factor using low-sulfur CARB diese1.3 The estimated emissions from the engines under maximum operating conditions (2 hours per day and 50 hours per year per engine) are shown in Table 2. Details of the emission calculations are provided in Attachment I.

Table 2. Average Daily and Annual Emissions from Emergency Generators 0 M . fSOH Y ' Jperation for axtmumo ours per ear Per Engme

Average Total Annual Emissions•: Daily Emissions 50 Hours Operation

AlllO Units' AlllO Units Pollutant (lb/day) (lb/year) (ton/year) NOx' 31.7 11,588 5.79 ROG 1.7 610 0.30 co 6.6 2,408 1.20 PMw 0.8 289 0.14 PM25 0.7 271 0.14 so, <0.1 15 0.01

a Average daily emissions calculated based on annual emissions divided by 365 days. b Assumes operation at 80% engine load for 50 hours/year per engine. c For combined NOx + NMHC factor, assumed 95% NOx, 5% NMHC

2 Section 93115, title 17, California Code ofRegulations 3 see https://powersuite.curnmins.corn/PS5/PS5 Content/SiteContent/en!Binary _ Asset/pdf!Commercial/Datasheets/Emissi ons/epa-1223.pdf

3


July 18, 2016 -Page 4

There would be some emissions associated with worker traffic. Table 4 shows the total emissions from worker traffic and generator operation.

Table 4 Total Emissions from Project Operation Nitrogen Reactive Respirable Fine Oxides Organic Gases Particulates Particulates.

Emission Source (NOx) (ROG) (PM1o) (PMz.s)

Emergency Generators 5.8 tons 0.3 tons 0.14 tons 0.14tons Mobile Sources 0.1 tons 0.04 tons 0.04 tons 0.02 tons

Total in tons 5.9 tons 0.34 tons 0.18 tons 0.16tons BAAQMD Threshold 10 tons 10 tons 15 tons 10 tons

A vera!(e Daily 32pounds 2pounds 1 pounds <1 vounds BAAQMD Threshold 54 vounds 54 vounds 82 pounds 54 vounds

Sif(ni{icant? No No No No


The proposed project would be a source of air pollutant and toxic air contaminant (TAC) emissions from operation of emergency generators for testing and maintenance purposes. These generators are diesel-fueled, so they emit diesel particulate matter (DPM), which is a TAC. The generators are also a source of PM2.5, which has known adverse health effects. Community risk impacts were addressed previously; however, this update includes the effects of the emissions from the different engines now proposed and has included additional sensitive receptors that did not exist when the original analysis was conducted in 2013. In addition, the cancer risk calculations conducted as part of the community risk analysis incorporate the latest State guidance issued by The State of California Office of Environmental Health Hazard Assessment (OEHHA).

Potential health impacts from operation of the project's generators for testing and maintenance purposes and aruma! load testing were evaluated using air quality dispersion modeling and applying BAAQMD recommended health impact calculation methods, as described in Attachment 2. DPM concentrations and potential cancer risks from operation of the generators were evaluated at existing residences south of the project and at locations of proposed residential areas of the recently approved Santa Clara Square project. Receptor grids with 25-meter spacing were placed in the residential areas to the north and south of the project site. Figure 1 shows the proposed data center and locations of the proposed emergency generators and the receptors points used to represent the locations of off-site residential receptors. The closest receptors to the proposed generators are about 980 feet northeast of the emergency generators4

The maximum average annual off-site DPM concentrations were used to calculate potential increased cancer risks from the project. Average annual DPM concentrations were used as being representative of long-term (30-year) exposures for calculation of cancer risks.

Air quality modeling of annual average DPM concentrations was conducted using the EPA's AERMOD dispersion model. The AERMOD model is a steady-state, multiple-source,

4 Note that residential development is proposed at this location as part of the Santa Clara Square residential project.

4



dispersion model designed to calculate pollutant concentrations from single or multiple sources. The model is recommended by BAAQMD for predicting air pollutant/contaminant concentrations associated with various emissions sources. The AERMOD model predicts pollutant concentrations at receptors located in areas of flat or complex terrain from a variety of emission source types including point, area, volume and line sources. Since there are minimal elevation differences in the topography in the vicinity of the project site, flat terrain was assumed. The land use classification of the area was assumed to be urban. The modeling used a five-year data set (2006 -2010) of hourly meteorological data from the San Jose Airport that was prepared by BAAQMD for use with the AERMOD model.

Annual average DPM and PM2.5 concentrations were modeled assuming that generator testing would occur between the hours of 9:00 AM and 5:00 PM and each generator is operated for 50 hours per year at SO-percent load. This is the hypothetical worst-case scenario, since generators would operate less than 50 hours per year and testing would usually occur at partial load conditions. The generator engine source parameters used in the modeling are listed in Table I. DPM emissions for the proposed emergency generators were assumed to be the PM2.5

emissions reported in Table 2.

DPM and PM2.5 concentrations were calculated at the locations of residential receptors, as shown in Figure I. Annual DPM and PM2.s concentrations from project operation were calculated at receptor heights of 1.5 meters ( 4.9 feet).

The maximum modeled annual DPM concentration from operation of the proposed generators was 0.0021 flg/m3 at a receptor south of the project site. DPM concentrations at all other residential locations would be lower than the maximum concentration. The location of the maximum modeled DPM concentration, and TAC impacts, are shown on Figure I.

Based on the maximum modeled DPM (and PM2.5) concentrations, maximum increased cancer risks and non-cancer health impacts were calculated using BAAQMD recommended methods, as described in Attachment 2. Table 5 shows the maximum predicted community risk levels from the operation of the proposed emergency generators.

Table 5. Maximum Increased Community Risk Levels from Emergency Generator 0 f (SOH Y G t ) •pera wn ours per ear per enera or

Cancer Risk Maximum Maximum (per Annual PM2.s Hazard

Sensitive Receptor million) (Jtg/m3) Index Off-Site Residence 1.6 < 0.01 < 0.01

BAAQMD Single Source Threshold 10.0 0.3 1.0 Significant? No No No

Due to the distance of the closest sensitive receptors from the project site where maximum impacts occurred, the residential area more than 2,100 feet south of the project site, cumulative health impacts were not evaluated.

5

Details of the community risk calculations are provided in Attachment 2,

* * *


Julyl8,2016 -Page6

This concludes our update to the air quality assessment for the 3032 Coronado Drive Data Center Project Please feel free to contact us with any questions or if you need additional information,

Sincerely,

James A, Reyff Senior Consultant- Principal Illingworth & Rodkin, Inc,

16-126

Attachment : Figure I Attachment I: Data Center Emergency Generators Emission Calculations and Engine Data Attachment 2: Health Risk Calculation Methodology Attachment 3: Data Center Emergency Generators Health Impacts and Modeling Information

6

Figure 1. Project Site and Locations of Sensitive Receptor

590800 591000 591 200

UTM- East (meters)

7

591400


July 18, 2016 -Page 7

Attachment 1:

Jetu1ifer Gallerani Marquez Circlepoint


Data Center Emergency Generators Emission Calcnlations and Engine Data

8

C. Power Generation

Compliance Information:


July 18, 2016 -Page 9

2016 EPA Tier 2 Exhaust Emission Compliance Statement

2500DQKAN Stationary Emergency 60 Hz Diesel Generator Set

The engine used in this gener:~tor set complies with Tier 2 emissions limit of U.S. EPA New Source Perform:~nce St:~nd:~rds for st:~tion:~ry emergency engines under the provisions of 40 CFR 60 Subp:~rt 1111 when tested per 1508178 02.

Engine Manufacturer: EPA Certificate Number: Effective Date: Date Issued: EPA Engine Family (Cummins Emissions Family):

Engine Information: Model: OSK60 G19 NR2 Engine Nameplate HP: 3640

Cummins Inc GCEXL060.AAD-01 0 11/04/2015 11/04/2015 GCEXL060.AAD (0593)

Bore: 6.25 in. ('159 mm) Stroke: 7.48 in. (190 mm)

Type: 4 Cycle, 60'V, 16 Cylinder Diesel Displacement: 3673 cu. in. ( 60.2 liters ) Aspiration: Turbocharged and Low Temperature Aftercooled

(2P/2L) Emission Control Device: Electronic Control

Diesel Fuel Emission Limits

Compression Ratio: 14.5:1

02 Cycle Exhaust Emissions Grams per BHP-hr Grams per kWm-hr NOx + co PM NOx + co PM NMHC NMHC

Test Results - Diesel Fuel (300-4000 ppm Sulfur) 4.20 0.75 0.10 5.60 1.00 0.14 EPA Emissions Limit 4.80 2.60 0.15 6.40 3.50 0.20 Test Results- CARS Diesel Fuel (< 15 ppm Sulfu r) 3.80 0.75 0.09 5.10 '1.00 0.12 CARS Emissions Limit 4.80 2.60 0.15 6.40 3.50 0.20

The CARB emission values are based on CARB approved calculations for converting EPA (500 ppm) fuel to CARB (15 ppm) fueL Test Methods: EPNCARB Nonroad emissions recorded per 40CFR89 (ref. 1508178-1) and weighted at load points prescriiJed in SuiJpart E. Appendix A for Constant Speed Engines (ref. 1508178-4, D2)

Diesel Fuel Specifications: Cetane Number: 40--48. Reference: ASTM 0975 No. 2-D. Reference Conditions: Air Inlet Temperature: 25' C (77'F), Fuel Inlet Temperature: 40' C (104'F). Barometric Pressure: 100 kPa (29.53 in Hg), Humidity: 10.7 glkg (75 grains H20/I b) of dry air, required for NOx correction, Restrictions: Intake Restriction set to a maximum allowable limit for clean filter; Exhaust Back Pressure set to a maximum allowable limit.

Tests conducted using altemate test methods, instrumentation, fuel or reference condijions can yield different results. Engine operation wrth excessive air Intake or exhaust restriction beyond published maximum limits. or with improper maintenance, may result in elevated emission levels.

Cummins Power Generation Data and Specification$ Sllbject to Change Without Notice EPA-1223b

9

Coronado Drive Data Center -Emergency Backup Generators Emissions From Periodic Generator Testing -10 Engines (50 Hours per Ye~~r per Engine)


July 18,2016 -Page 10

Periodic Generator Load Testm2: Manufacturer/Model Cummins Generator Set 2500DQKAN Engine QSK60-Gt9 Tier 2 Engine Total No. Units 10 Engine Operating Load 8(}%

Generator Output (kW) Load During Testing 80% Engine Output (hp) 2,912

Fuel Use (gallhr) at Load )38.48

Fuel Sulfur Content(%) 0.0015 Emi.~sion Testing Information

Max. Maximum Daily Annual

Testing Testing No. Units Tested. = 10 10

Test Duration/Unit (min)= 60 60 Tests per Period/Unit= 1 50

Operation.!Unit(hours) = 1 50 Total Operation (hours)= 10 500

Operational Operational- Total Emissioni

Emission ' Emission Maximum Emissions per Unit Daily

Factor Rate per Unit Daily Annual Annual Maximum Annual

Pollutant (e:/hn-hr) (lb/hr) lb/dav) (lb/vr) (ton/vr) lb/dav) (IbM\ (ton/vr)

NOx~o 3.61 23.18 23.18 1158.8 0.58 231.76 11,587.9 5.79

HC1' 0.19 1.22 1.22 61.0 0.03 12.20 609.9 0.30

co1" 0.75 4.81 4.81 240.7 0.12 48.15 2,407.5 1.20

PM101' 0.09 0.58 0.58 28.9 0.0144 5.78 288.9 0.144

PM2.53 0.08 0.54 0.54 27.1 0.0135 5.41 270.7 0.135

SOx10 0.029 0.029 1.5 0.0007 0.29 14.6 0.0073 co21d 22.38 lb/gal 3,099 3,099 154,936 77.5 30,987 1,549,362 775

Notes 1) Based on EPA D2 Cycle exhaust erruss10ns With CARB d1esel fuel fur Cumrruns QSK60 Gl9 NR2 engmes

(Cummins Power Generation -Emission Compliance Statement EP A-1223b).

1 a) NOx emission factor is assumed to be 95% ofCARB diesel fuel NMHC + NOx emission factor, based on BAAQMD policy.

lb) ROG emission factor is assumed to be 5% ofCARB's diesel fuel NMHC + NOx emission factor, based on BAAQMD policy.

lc) Calculated based on fuel sulfur content and EPA AP-42 Table 3.4-1 emission factor.

ld) C02 emission factor from California Climate Action Registiy, General Reporting Protocol, Version 3.1, January 2009

2) Based on the number of units operating for the specified time period

3) Based on CARB CEIDERS PM profile for diesel IC engines, PM2.5 fraction of PM= 0.937

4) Average daily emissions calculated based on annual emissions divided by 365 days

10

Average Daily

(lb/yr)4

31.748

1.671

6.596

0.791

0.742

0.040

4244.827

Attachment 2: Health Risk Calculation Methodology


July 18, 2016 -Page II

A health risk assessment (HRA) for exposure to Toxic Air Contaminates (TACs) requires the application of a risk characterization model to the results from the air dispersion model to estimate potential health risk at each sensitive receptor location. The State of California Office of Environmental Health Hazard Assessment (OEHHA) and California Air Resources Board (CARB) develop recommended methods for conducting health risk assessments. The most recent OEHHA risk assessment guidelines were published in February of 2015 5 These guidelines incorporate substantial changes designed to provide for enhanced protection of children, as required by State law, compared to previous published risk assessment guidelines. CARB has provided additional guidance on implementing OEHHA's recommended methods 6 This HRA used the recent 2015 OEHHA risk assessment guidelines and CARB guidance. While the OEHHA guidelines use substantially more conservative assumptions than the current Bay Area Air Quality Management District (BAAQMD) guidelines, BAAQMD has not formally adopted recommended procedures for applying the newest OEHHA guidelines. BAAQMD is in the process of developing new guidance and has developed proposed HRA Guidelines as part of the proposed amendments to Regulation 2, Rule 5: New Source Review of Toxic Air Contaminants. 7 Exposure parameters from the OEHHA guidelines and newly proposed BAAQMD HRA Guidelines were used in this evaluation.

Cancer Risk

Potential increased cancer risk from inhalation of TACs are calculated based on the TAC concentration over the period of exposure, inhalation dose, the TAC cancer potency factor, and an age sensitivity factor to reflect the greater sensitivity of infants and children to cancer causing TACs. The inhalation dose depends on a person's breathing rate, exposure time and frequency of exposure, and the exposure duration. These parameters vary depending on the age, or age range, of the persons being exposed and whether the exposure is considered to occur at a residential location or other sensitive receptor location.

The current OEHHA guidance recommends that cancer risk be calculated by age groups to account for different breathing rates and sensitivity to TACs. Specifically, they recommend evaluating risks for the third trimester of pregnancy to age zero, ages zero to less than two (infant exposure), ages two to less than 16 (child exposure), and ages 16 to 70 (adult exposure). Age sensitivity factors (ASFs) associated with the different types of exposure are an ASF of I 0 for the third trimester and infant exposures, an ASF of 3 for a child exposure, and an ASF of I for an adult exposure. Also associated with each exposure type are different breathing rates, expressed as liters per kilogram of body weight per day (Likg-day). As recommended by the BAAQMD, 95"' percentile breathing rates are used for the third trimester and infant exposures, and 80th percentile breathing rates for child and adult exposures. Additionally, CARB and the BAAQMD recommend the use of a residential exposure duration of 30 years for sources with long-term emissions (e.g., roadways).

Under previous OEHHA and BAAQMD HRA guidance, residential receptors are assumed to be at their home 24 hours a day, or 100 percent of the time. In the 2015 Risk Assessment Guidance, OEHHA includes adjustments to exposure duration to account for the fraction of time at home (F AH), which can

5 OEHHA, 2015. Air Taxies Hot Spots Program Risk Assessment Guidelines, The Air Taxies Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Office of Environmental Health Hazard Assessment. February. 6 CARB, 2015. Risk Management Guidance for Stationary Sources of Air Taxies. July 23. 7 BAAQ:r.AD, 2016. Workshop Report. Proposed Amendments to Air District Regulation 2, Rule 5: New Source Review of Toxic Air Contaminants. Appendix C. Proposed Air District HRA Guidelines. January 2016.

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be less than 100 percent of the time, based on updated population and activity statistics. The FAH factors are age-specific and are: 0.85 for third trimester of pregnancy to less than 2 years old, 0. 72 for ages 2 to less than 16 years, and 0.73 for ages 16 to 70 years. BAAQMD recommends using these FAH factors for residential exposures.

Functionally, cancer risk is calculated using the following parameters and formulas:

Cancer Risk (per million)~ CPF x Inhalation Dose xASF x ED/ATx FAH x 106

Where: CPF ~Cancer potency factor (mg/kg-day)"1

ASF ~Age sensitivity factor for specified age group ED ~ Exposure duration (years) AT ~ Averaging time for lifetime cancer risk (years) FAH ~Fraction of time spent at home (unitless)

Inhalation Dose~ C,1, x DBR x Ax (EF/365) x 1 o-6

Where: C,1, ~concentration in air (~g/m3) DBR ~daily breathing rate (Likg body weight-day) A ~ Inhalation absorption factor EF ~Exposure frequency (days/year) I o·' ~ Conversion factor

The health risk parameters used in this evaluation are summarized as follows:

Exposure Type -7 Infant Parameter Age Range -7 3rd Trimester 0<2

DPM Cancer Potency Factor (mg/kg-day)"1 l.IOE+OO l.IOE+OO

Daily Breathing Rate (Likg-day)* 361 1,090 Inhalation Absorption Factor I 1 Averaging Time (years) 70 70 Exposure Duration (years) 0.25 2 Exposure Frequency (days/year) 350 350 Age Sensitivity Factor 10 10 Fraction of Time at Home 0.85- 1.0 0.72-1.0

Child 2 < 16

l.IOE+OO

572 1

70 14

350 3

0.72-1.0

Adult 16-30

l.IOE+OO

261 1

70 14

350 I

0.73

* cth " . t 95 percenttle breathmg rates for 3 tnmester and mfants and 80 percenttle for chtldren and adults

Non-Cancer Hazards

Potential non-cancer health hazards from TAC exposure are expressed in terms of a hazard index (HI), which is the ratio of the TAC concentration to a reference exposure level (REL). OEHHA has defined acceptable concentration levels for contaminants that pose non-cancer health hazards. T AC concentrations below the REL are not expected to cause adverse health impacts, even for sensitive individuals. The total HI is calculated as the sum of the His for each TAC evaluated and the total HI is compared to the BAAQMD significance thresholds to determine whether a significant non-cancer health impact from a project would occur.

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Typically, for residential projects located near roadways with substantial TAC emissions, the primary T AC of concern with non-cancer health effects is diesel particulate matter (DPM). For DPM, the chronic inhalation REL is 5 micrograms per cubic meter (f!g/m').

Annual PM25 Concentrations

While not a TAC, fine particulate matter (PM2.5) has been identified by the BAAQMD as a pollutant with potential non-cancer health effects that should be included when evaluating potential community health impacts under the California Environmental Quality Act (CEQA). The thresholds of sigoificance for PM2.5 (project level and cumulative) are in terms of an increase in the annual average concentration. When considering PM25 impacts, the contribution from all sources ofPM25 emissions should be included. For projects with potential impacts from nearby local roadways, the PM2.5 impacts should include those from vehicle exhaust emissions, PM2.5 generated from vehicle tire and brake wear, and fugitive emissions from re-suspended dust on the roads.

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Attachment 3: Data Center Emergency Generators Health Impacts and Modeling Information

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3032 Coronado Drive - SV -7 Data Center, Santa Clara, CA DPM Cancer Risks From 10 Emergency Generators

Maximum DPM Cancer Risk at Off-Site Receptors 1.5 Meter Receptor Heights

Cancer Risk Calculation Method


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Cancer Risk (per million)"" CPF x Inhalation Dose x ASF xED/AT x FAH x 1.0£6

Where: CPF"" Cancer potency factor (mglkg-dayr1

ASF =Age sensitivity factor for specified age group

ED = Exposure duration (years)

AT = Averaging time for lifetime cancer risk (years)

F AH =Fraction oftime spent at home (unitless)

Inhalation Dose= C.rrx DBR x Ax (EF/365) x 10"6

Where: Cair =concentration in air (j.J.g/m3)

Values

DBR =daily breathing rate (Likg body weight-day)

A= Inhalation absorption factor

EF =Exposure frequency (days/year)

10"6 =Conversion factor

Cancer Potency Factors (rnglkg-dayf1

ITAC DPM

I CPF

Infant/Child Age--> 3rd Trimester 0- <2 2 -<16

Parameter ASF 10 10 3

DBR*= 361 1090 572 A~ 1 1 1 EF~ 350 350 350 ED~ 0.25 2 14 AT~ 70 70 70 FAH~ 1.00 1.00 1.00

Adult 16-30

1

261 1

350 14 70

0.73

' 95th percentlle breathmg rates for mfants and 80th percentile for children and adults

MEl Cancer Risk From Emergency Generator Operation 1 5 meter receptor height

Exposure Age DPM DPM

Duration Sensitivity Annual Cone Cancer Risk (years) Age Factor (uglrn3) (per million)

0.25 -0.25 - 0* 10 0.0021 0.03 2 1 - 2 10 0.0021 0.69 14 3 - 16 3 0.0021 0.76 14 17-30 1 0.0021 0.08

Total Increased Cancer Risk 1.6

• Th1rd tnmester of pregnancy

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addendum to an initial study/mitigated negative

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