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Mr. Frank DeMaris
<br />i October 18, 2010
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<br />any configuration as long as the emissions remained at 199,999 lb/yr or 99.99 tpy or less. As noted
<br />above, these emission estimates are based on 100% uptime and 100% load. During the course of a
<br />year, both the engines and flare will be down for maintenance. In addition, the flare is not expected to
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<br />operate 24 hours per day, 365 days per year because it operates in a cyclical, batch -type operation or
<br />- 24 hours in every 48-hour period. Finally, LFG engines usually have on-line times of approximately
<br />95%. Therefore, Ameresco believes the total CO emissions will remain under the cap. Compliance
<br />would be determined with throughput and source test data and calculated on a 12 -month rolling
<br />.,� average basis. As with the SOx, Ameresco requests that the SJVAPCD work with us to develop a
<br />reasonable testing program for CO emissions to demonstrate compliance with the cap, which reflects
<br />the changing CO levels experienced at the Ox Mountain facility.
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<br />To demonstrate compliance for the VOC, SOx, and CO emission caps, Ameresco proposes the
<br />following recordkeeping procedures:
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<br />1. For the LFG IC engines, the monthly VOC, SOx, and CO emissions from each engine shall be
<br />calculated using the calculated flow (scf/month) to each engine taken from the measured total
<br />plant flow from the totalizing flow meter and the VOC, SOx, and CO emission factors from the
<br />most recent annual source test or other periodic testing with a hand-held device for each engine,
<br />as appropriate.
<br />2. For the waste gas flare, the monthly CO emissions from the flare shall be calculated using the
<br />monthly heat input rate (MMBtu per month) and CO emission factor from the most recent
<br />annual source test for the flare. The VOC emissions from the flare shall be calculated using the
<br />monthly heat input rate (MMBtu per month) and VOC emission factor from the most recent
<br />annual source test for the flare. The SOx emissions from the flare shall be calculated using the
<br />monthly heat input'rate (MMBtu per month) and SOx emission factor from the most recent
<br />annual source test for the flare.
<br />3. Ameresco shall maintain records of any supporting data used to determine the monthly
<br />emission rate from each device subject to the 12 -month rolling average for VOCs, SOx, and
<br />CO. These data may include but not limited to equipment capacities, fuel heating values,
<br />certifications, guarantees, compliance demonstration results, meter readings, operating records,
<br />calculation procedures, and conversion factors.
<br />4. When VOC, SOx, and/or CO emission factors need to be increased to reflect new source test
<br />data, the new emission factor shall become effective for the month in which the test was
<br />conducted and each subsequent month until a new test is completed. If the new VOC, SOx,
<br />and/or CO emission factor is lower than the factor currently in effect, Ameresco has the option
<br />to continue using the higher factor and to not use this new lower factor. Any changes to the
<br />VOC, SOx, and/or CO emission factors, monthly operating rates, and resulting monthly VOC,
<br />SOx, and CO emissions records shall be incorporated into these records within 6 months of the
<br />effective date of the new data.
<br />5. Using the monthly VOC, SOx, and CO emission data from each device pursuant to the
<br />conditions noted above, Ameresco shall calculate and record the total monthly VOC, SOx, and
<br />CO emissions from all non-mobile, non -road combustion devices operated at this facility.
<br />6. Using the monthly site -wide VOC, SOx, and CO emissions total, Ameresco shall calculate and
<br />record the total annual site -wide VOC, SOx, and CO emissions from all non-mobile, non -road
<br />combustion devices, for each rolling consecutive 12 -month period.
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