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P <br />F. <br />r <br />Environmental Consultants <br />October 18, 2010 <br />File No. 01203117.12 <br />3900 Kilroy Airport Way 562-426-9544 <br />Suite 100 FAX 562-427-0805 <br />Long Beach, California 90806 www,scsengineers.com <br />Mr. Frank G. DeMaris <br />San Joaquin Valley Air Pollution Control District <br />Northern Office <br />4800 Enterprise Way <br />Modesto, CA 95356-8718 <br />SUBJECT: ADDENDUM TO AUTHORITY TO CONSTRUCT/TITLE V APPLICATION <br />(No. N-1103269), LANDFILL GAS -TO -ENERGY FACILITY, FOOTHILL <br />LANDFILL, LINDEN, CALIFORNIA <br />Dear Mr. DeMaris: <br />On behalf ofArneresco Foothill LLC (Ameresco), SCS Engineers (SCS) hereby submits to the San <br />Joaquin Valley Air Pollution Control District (SJVAPCD), this Addendum to the Authority to <br />Construct {ATC} and Title V Permit Application Landfill Gas -Fired IC Engines and VOC Flare for the <br />Foothill Landfill (Foothill), located in Linden, California. The original application, dated August 2010, <br />was also prepared by SCS. A Response to Notice oflncomplete Application was also submitted to the <br />SJVAPCD on October 1, 2010 by SCS. This addendum provides additional information and revisions <br />to the original application and response document based on the meeting with Ameresco, SCS, and <br />SJVAPCD on October 7, 2010. <br />PROPOSED REVISIONS <br />Based on discussions during the meeting, the proposed landfill gas (LFG)-to-energy (LFGTE) facility, <br />consisting of two (2) internal combustion (IC) engines and a waste gas flare, will require revised <br />emission factors and emissions estimates based on the additional backend control equipment that will <br />be installed. A summary of the changes and revisions are provided in detail below. <br />Engine Emissions <br />Ameresco proposes to revise the nitrogen oxide (NOx) emission rate to 0.15 grams per brake <br />horsepower -hour (g/bhp-hr), based on 12,000 hours experience to date at the Ox Mountain facility. <br />The revised emission level is based on installing similar, NOx control technology at the Foothill <br />project, a selective catalytic reduction (SCR) system This equipment will result in the lowest <br />achievable emission rate possible. Results of the handheld testing at the Ameresco Ox Mountain <br />facility can be found in Appendix B. <br />The NOx emissions will be reduced from the original estimate of 34.90 tons per year (tpy) to 8.73 <br />�j tpy for the two engines, lower than the non -attainment area NSR offset threshold of 10 tpy. The <br />j revised emission estimates using this updated emission factor are attached (Appendix A). <br />Iiq <br />II� <br />