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Ameresco submitted a detailed BACT analysis for the exact same set of sources for the Foothill <br />Landfill. We believe that the emission levels proposed herein will meet or exceed what has been <br />determined to be BACT. In the case of the engines, the proposed emission levels for NOx and <br />CO represent the lowest achievable emission rates (LAER) for LFG-fired engines. Although we <br />do not believe they meet cost-effective BACT criteria, Ameresco is willing to install the LAER <br />level of controls to avoid emission offsets for NOx and modeling requirements for CO. For the <br />flare, the proposed emission levels meet BACT for the type of flare being proposed — waste gas <br />flare. In order to achieve proper emission control of the waste gas, the emission levels proposed <br />as BACT are the only ones that can be considered achieved for this type of unit. All of these <br />levels are consistent with the draft ATC for the Foothill's LFGTE project. <br />Flare Limits <br />NOx <br />0.041 lb/MMBtu <br />CO <br />0.2 lb/MMBtu <br />PM10 <br />0.2 lb/MMBtu <br />TRS <br />150 ppmv <br />VOC <br />20 ppmv as hexane @ 3% oxygen or <br />98% destruction efficiency by weight <br />Ameresco submitted a detailed BACT analysis for the exact same set of sources for the Foothill <br />Landfill. We believe that the emission levels proposed herein will meet or exceed what has been <br />determined to be BACT. In the case of the engines, the proposed emission levels for NOx and <br />CO represent the lowest achievable emission rates (LAER) for LFG-fired engines. Although we <br />do not believe they meet cost-effective BACT criteria, Ameresco is willing to install the LAER <br />level of controls to avoid emission offsets for NOx and modeling requirements for CO. For the <br />flare, the proposed emission levels meet BACT for the type of flare being proposed — waste gas <br />flare. In order to achieve proper emission control of the waste gas, the emission levels proposed <br />as BACT are the only ones that can be considered achieved for this type of unit. All of these <br />levels are consistent with the draft ATC for the Foothill's LFGTE project. <br />