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u 11 C C BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS PROPOSED AMERESCO LANDFILL GAS TO ENERGY PROJECT FORWARD LANDFILL MANTECA, CALIFORNIA On behalf of Ameresco Forward, LLC (Ameresco), SCS Engineers (SCS) has developed the following information and analysis concerning Best Available Control Technology (BACT) for the 2.175 MW landfill gas (LFG)-fired IC engines and the 200 standard cubic feet per minute (SCFM) @ 47% methane (188 scfm @ 50% methane) flare that Ameresco proposes to install at the Forward Landfill. Ameresco is submitting an application to the San Joaquin Valley Air Pollution Control District (SJVAPCD) to operate two (2) engines and one (1) flare. SJVAPCD defines BACT as the following: • Any new emissions unit or relocation from one Stationary Source to another of an existing emissions unit with a Potential to Emit exceeding 2.0 pounds in any one day; • Modifications to an existing emissions unit with a valid Permit to Operate resulting in an Adjusted Increase in Permitted Emissions exceeding 2.0 pounds in any one day; • Any new or modified emissions unit, in a stationary source project, which results in an SB 288 Major Modification or a Federal Major Modification, as defined in this rule. For the engines, we are requesting a Nitrogen Oxide (NOx) limit of 0.15 'grams per brake horsepower -hour (g/bhp-hour), Carbon Monoxide (CO) limit of 1.80 g/bhp-hour, Particulate Matter less than 10 microns (PM10) limit of 0.07 g/bhp-hour, 150 parts per million by volume (ppmv) limit on reduced sulfur compounds (TRS) in the LFG as a surrogate for Sulfur Oxide (SOx), and 20 ppmv as hexane @ 3% oxygen or 98% destruction efficiency by weight limit for Volatile Organic Compounds (VOCs) in the engine exhaust in the submitted application. For the flare, we are requesting a NOx limit of 0.041 pounds per million British thermal units (lb/MMBtu), CO limit of 0.2 lb/MMBtu, PM10 limit of 0.2 lb/MMBtu, 150 ppmv TRS limit for SOx, and 20 ppmv as hexane @ 3% oxygen outlet concentration for VOCs in the submitted application, and believe these limits are the only ones that can be considered to be "achieved in practice." Any lower limits would need to be considered as "cost-effective" and/or "technologically feasible" BACT, which allows an analysis of costs and other implementation factors associated with achieving the more stringent levels. Engines Limits NOx 0.15 /bhp -hr CO 1.80 /bhp -hr PM10 0.07 /bhp -hr TRS 150 ppmv VOC 20 ppmv as hexane @ 3% oxygen or 98% destruction efficiency by weight For the flare, we are requesting a NOx limit of 0.041 pounds per million British thermal units (lb/MMBtu), CO limit of 0.2 lb/MMBtu, PM10 limit of 0.2 lb/MMBtu, 150 ppmv TRS limit for SOx, and 20 ppmv as hexane @ 3% oxygen outlet concentration for VOCs in the submitted application, and believe these limits are the only ones that can be considered to be "achieved in practice." Any lower limits would need to be considered as "cost-effective" and/or "technologically feasible" BACT, which allows an analysis of costs and other implementation factors associated with achieving the more stringent levels.