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The air pollution monitoring proposed under this permit is wholly
inadequate for the San Joaquin Valley AQMD which is not in
compliance with EPA standards for criteria air pollutants. There is
only a once in 24 month measurement requirement under condition 19
of the air pollution permit "Source testing to measure NOx, CO,
VOC, and ammonia (NH3) emissions from this unit shall be conducted
at least once every 24 months. [District Rules 1081, 2201, and
4702]" To have a useful effect, monitoring needs to be continuous.
To avoid this problem, methane fuel cells should have been chosen
rather than a combustion driven generator.

Secondly, there is no requirement to measure methane leakage. If
10% of the methane were to leak this would completely invalidate
any benefit to the climate of this activity.
Please do not grant this application until these defects are
remedied.

Original File Name:

Date and Time Comment Was Submitted: 2023-03-07 19:40:56