February 23, 1993 MEMORANDUM SUBJECT: AES Guayama, Puerta Rico Proposal to Use the Rough Terrain Dispersion Model with Off-Site Meteorological Data FROM: Joseph A. Tikvart, Chief Source Receptor Analysis Branch (MD-14) TO: Kenneth Eng, Chief Air Compliance Branch, Region II (2AWM) In response to your request, the Model Clearinghouse has reviewed your position requiring AES to collect on-site meteorological data at their proposed plant site. We agree with your rationale and conclusion. Your reasoning is sound and your conclusion is consistent with guidance and with a number of precedents for similar situations, including the Pfizer situation which you cite. In addition to Pfizer, there is also a more recent example of a precedent in Region IX that is especially relevant. In this case, which also involved AES, the Company proposed to utilize nearby off-site meteorological data for a Complex I analysis for a proposed plant in Hawaii. In this case, the Clearinghouse agreed with Region IX that use of such data would be inappropriate. A copy of that determination is attached. If you have any further questions, please contact Dean Wilson at 919- 541-5683. Attachment cc: W. Barrett A. Colecchia D. deRoeck S. Riva D. Wilson