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Construction Air Permit 4.2. 1 Criteria Pollutants Criteria pollutant emissions from the IC engines and flare will be generated during combustion, which includes VOC,NOx, SOx, CO, and PM-10. Criteria pollutants were calculated based on the following: IC Engine Flare NOx 0.041 lb/MMBtu 0.15 g/bhp-hr(Lowest achievable emission (Manufacturer's Guarantee and levels with backend controls) BACT CO 1.8 g/bhp-hr(Lowest achievable emission 0.21b/MMBtu(Manufacturer's levels with backend controls) Guarantee and BACT Sox 150 ppmv(BACT) 150 ppmv BACT VOC 20 ppmv outlet as hexane at 3% oxygen or 20 ppmv outlet as hexane at 3% 98% destruction efficiency by weight oxygen or 98% destruction (HSPS/BACT) efficiency by weight SPSBACT PM-10 0.07 g/bhp-hr(BACT) 0.2 lb/MMBtu(Ameresco testing) Ammonia 15 ppmv at 15% oxygen(Foothill ATC) N/A H3 Please note that during the permitting process for the Ameresco Foothill LLC facility, which was recently issued draft ATCs,the SJVAPCD noted that individual emission limits for SOx must be included for individual combustion devices. As such, Ameresco requested, and was subsequently approved,to apply the emissions limit for SOx using the worst-case scenario of the total possible combined emissions of the flare and the engines being emitted from one device. Ameresco recommends using a worst-case scenario as a result of the siloxane pretreatment system's reaction to hydrogen sulfide in the raw LFG. The siloxane pretreatment system's media bed has an affinity with hydrogen sulfide,which will cause hydrogen sulfide to collect on the media bed. However, its affinity toward hydrogen sulfide is less than its affinity to siloxane compounds and other VOCs. As a result, as the media bed operationally approaches its regeneration cycle and its media bed becomes saturated, hydrogen sulfide may be released from the media bed. Therefore,the flare may exhibit higher than 150 ppmv concentrations, but the facility-wide average will be under 150 ppmv. Ameresco requests to apply this same approach and permit limits as was granted for the Ameresco Foothill LLC facility. 4.2.2 Major Source According to Section 3.23 of Rule 2201, for each pollutant, a Stationary Source with post-project emissions or a post-project Stationary Source Potential to Emit(SSPE2), equal to or exceeding one or more of the following threshold values is considered a major source. As shown below, the combined engine and flare emissions are not mayor sources for any pollutant since Ameresco proposes an emissions cap for CO and VOCs (see section 5.1); therefore,the project is not considered a major source. As such, the project would not trigger the requirements of Title V. 7