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Construction Air Permit Table 4-1, Emissions Offset Threshold Levels Pollutant SSPE2 Emissions Triggers Proposed Emissions (lbs/yr) for two Offset Cap Offsets Engines and (lbs/yr) Required Flare (lbs/yr) -- VOC 20,000 21,307 Yes, 19,999 NOx 20,000 19,476 No CO 200,000 219,291 Yes 199,999 sox 54,750 18,025 No PM 10 29,200 27,179 No The SSPE2 for CO and VOC pollutants are above offset thresholds. Therefore, CO and VOC triggers offset requirements. However,Ameresco requests to cap the emissions of VOCs and CO to avoid triggering the offsite requirements as detailed below. Ameresco requests to cap the emissions of VOCs to 9.99 tpy. The LFGTE facility could operate in any configuration as long as the emissions remained at 19,999 lb/yr or 9.99 tpy or less. The total VOC emissions for the engines and flare are 21,3071b/yr or 10.65 tpy. This is 1,307 lb/yr or 0.65 tpy (6.5%) over the offset threshold of 20,000 lb/yr or 10 tpy. Note that the emission estimates in Table 1 and 2 are based on 100%uptime and 100% load for both the engines and the flare. During the course of a year, both the engines and flare will be down for maintenance. In addition, the flare is not expected to operate 24 hours per day, 365 days per year because it operates in a cyclical, batch-type operation or 24 hours in every 48-hour period. Finally, LFG engines usually have on-line times of approximately 95%. Therefore, Ameresco believes the total VOC emissions will remain under the cap. Compliance would be determined with throughput and source test data and calculated on a 12-month rolling total basis. In order to avoid emission offsets for CO or modeling to demonstrate compliance with ambient standards (to avoid modeling), Ameresco requests to cap the emissions of CO to 99.99 tpy. The total CO emissions for the engines and flare are 219,291 lb/yr or 109.65 tpy. This is 19,291 ib/yr or 9.65 tpy (9.65%) over the offset threshold of 200,000 lb/yr or 100 tpy. The LFGTE facility could operate in any configuration as long as the emissions remained at 199,999 lb/yr or 99.99 tpy or less. As noted above,these emission estimates are based on 100%uptime and 100% load. During the course of a year, both the engines and flare will be down for maintenance. In addition,the flare is not expected to operate 24 hours per day, 365 days per year because it operates in a cyclical, batch-type operation or 24 hours in every 48-hour period. Finally, LFG engines usually have on-line times of approximately 95%. Therefore, Ameresco believes the total CO emissions will remain under the cap. Compliance would be determined with throughput and source test data and calculated on a 12-month rolling total basis. This would be similar to the draft ATCs at the Ameresco Foothill, LLC facility that were issued by the SJVAPCD in March 2011. To demonstrate compliance for the VOC and CO emission cap, Ameresco proposes to follow similar procedures as is proposed in the draft ATCs for the Ameresco Foothill LLC facility with the following modifications: 11