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