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Mr. Frank DeMaris
<br /> October 18, 2010
<br /> Page 6 of 7
<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
<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.
<br /> To demonstrate compliance for the VOC, SOx, and CO emission caps, Ameresco proposes the
<br /> following recordkeeping procedures:
<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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