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BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS <br /> PROPOSED AMERESCO LANDFILL GAS TO ENERGY PROJECT <br /> FORWARD LANDFILL <br /> MANTECA, CALIFORNIA <br /> On behalf of Ameresco Forward, LLC (Ameresco), SCS Engineers (SCS) has developed the <br /> following information and analysis concerning Best Available Control Technology (BACT) for <br /> the 2.175 MW landfill gas (LFG)-fired IC engines and the 200 standard cubic feet per minute <br /> (SCFM) @ 47%methane (188 scfm @ 50% methane) flare that Ameresco proposes to install at <br /> the Forward Landfill. Ameresco is submitting an application to the San Joaquin Valley Air <br /> ' Pollution Control District(SJVAPCD)to operate two (2) engines and one (1) flare. <br /> SJVAPCD defines BACT as the following: <br /> • Any new emissions unit or relocation from one Stationary Source to another of an <br /> existing emissions unit with a Potential to Emit exceeding 2.0 pounds in any one day; <br /> • Modifications to an existingemissions unit with a valid Permit to Operate resulting in an <br /> p g <br /> Adjusted Increase in Permitted Emissions exceeding 2.0 pounds in any one day; <br /> • Any new or modified emissions unit, in a stationary source project,which results in an <br /> SB 288 Major Modification or a Federal Major Modification, as defined in this rule. <br /> For the engines, we are requesting a Nitrogen Oxide (NOx) limit of 0.15 grams per brake <br /> horsepower-hour(g/bhp-hour), Carbon Monoxide (CO) limit of 1.80 g/bhp-hour, Particulate <br /> Matter less than 10 microns (PM10) limit of 0.07 g/bhp-hour, 150 parts per million by volume <br /> (ppmv) limit on reduced sulfur compounds (TRS) in the LFG as a surrogate for Sulfur Oxide <br /> (SOx), and 20 ppmv as hexane @ 3%oxygen or 98% destruction efficiency by weight limit for <br /> Volatile Organic Compounds (VOCs) in the engine exhaust in the submitted application. <br /> Engines Limits <br /> NOx 0.15 /bhp-hr <br /> CO 1.80 /bhp-hr <br /> PM10 0.07 /bhp-hr <br /> TRS 150 ppmv <br /> VOC 20 ppmv as hexane @ 3% oxygen or <br /> 98% destruction efficiency by weight <br /> For the flare, we are requesting a NOx limit of 0.041 pounds per million British thermal units <br /> (lb/MMBtu), CO limit of 0.2 lb/MMBtu, PM10 limit of 0.21b/MMBtu, 150 ppmv TRS limit for <br /> SOx, and 20 ppmv as hexane @ 3% oxygen outlet concentration for VOCs in the submitted <br /> application, and believe these limits are the only ones that can be considered to be "achieved in <br /> practice." Any lower limits would need to be considered as "cost-effective" and/or <br /> "technologically feasible" BACT, which allows an analysis of costs and other implementation <br /> factors associated with achieving the more stringent levels. <br />