DAQ-2024-011939

DAQE-AN161340002-24

{{$d1 }}

Nevin Edwards
Lightning Renewables, LLC
201 Helios Way, Floor 6
Houston, TX 77079
[e-mail]

Dear Mr. Edwards:

Re: Approval Order: Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8)
Diesel-Fired Engines and Nine (9) Diesel Fuel Storage Tanks
Project Number: N161340002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on June 25,
2024. Lightning Renewables, LLC must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Tooele County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

December 4, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN161340002-24
Modification to Approval Order DAQE-AN161340001-23
to Add Eight (8) Diesel-Fired Engines and
Nine (9) Diesel Fuel Storage Tanks

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Lightning Renewables, LLC - Wasatch RNG Processing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

December 4, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-AN161340002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Lightning Renewables, LLC Lightning Renewables, LLC - Wasatch RNG Processing Facility

Mailing Address Physical Address
201 Helios Way, Floor 6 8833 North Rowley Road
Houston, TX 77079 Grantsville, UT 84029

Source Contact UTM Coordinates
Name: Nevin Edwards 353,218 m Easting
Phone: [phone],523,252 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas Production/Distribution)

SOURCE INFORMATION
General Description
Lightning Renewables, LLC (Lightning Renewables) owns and operates a renewable natural gas (RNG)
processing facility in Tooele County. The RNG plant utilizes landfill gas (LFG) generated from the
Wasatch Regional Landfill as feedstock. The Wasatch Regional Landfill is owned and operated by
Republic Services. The Wasatch RNG processing facility (Wasatch RNG) operates independent of the
landfill.

Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm) of LFG from the
Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes processing consisting of
dewatering/moisture removal, sulfur compound removal via media filtration, particulate filtration,
temperature swing adsorption, membrane separation, and pressure swing adsorption. The refined RNG
consists of greater than 95% methane and is compressed and injected into a nearby natural gas
transmission pipeline. Air pollutant-emitting equipment includes two (2) types of thermal oxidizer
pollution control equipment, diesel-fired emergency and non-emergency engine generators, and diesel
fuel storage tanks.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Tooele County
Airs Source Size: B

DAQE-AN161340002-24
Page 4

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
Lightning Renewables is requesting to add the following equipment to its 2023 Approval Order:

1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired engines, each powering
a 500-kilowatt (kW) generator;
2. Eight (8) 630-gallon diesel storage belly tanks; and
3. One (1) 15,809-gallon diesel storage tank.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 28877 190181.00
Carbon Monoxide 0.35 30.57
Nitrogen Oxides 17.87 38.23
Particulate Matter - PM10 1.40 9.81
Particulate Matter - PM2.5 1.40 9.81
Sulfur Dioxide 0.32 7.43
Volatile Organic Compounds 1.54 10.21

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 283 292
Generic HAPs (CAS #GHAPS) 144 376
Toluene (CAS #108883) 103 264
Xylenes (Isomers And Mixture) (CAS #1330207) 70 174
Change (TPY) Total (TPY)
Total HAPs 0.30 0.55

DAQE-AN161340002-24
Page 5

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Wasatch RNG Processing Facility
II.A.2 One (1) Thermal Recuperative Oxidizer (TRO) Burner Rating: 7.5 MMBtu/hr Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 99%
DAQE-AN161340002-24
Page 6

II.A.3 One (1) Candlestick Flare Burner Rating: 0.1 MMBtu/hr Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 98%
II.A.4 Eight (8) Non-Emergency Engines (New) Rating: 744 HP (500 kW), each Fuel: Diesel
Year: 2023 Tier: 4f
NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.5 One (1) Emergency Engine Generator Rating: 324 HP (205 kW) Fuel: Diesel Year: 2022 NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ II.A.6 Nine (9) Fuel Storage Tanks (New)
Eight (8) 630-Gallon Tanks
One (1) 15,809-Gallon Tank
Content: Diesel Fuel

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Operational Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the TRO and flare to exceed 10% opacity. [R307-401-8]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not combust more than 865,920 million British Thermal Units
(MMBtu) of waste gas in the TRO and flare combined per rolling 12-month period. [R307-401-8]

DAQE-AN161340002-24
Page 7

II.B.1.b.1 The owner/operator shall: A. Determine total heat content of the waste gas to the TRO and flare through use of flow meters and a methane analyzer B. Record total heat content of the waste gas to the TRO and flare on a daily basis C. Use the total heat content of the waste gas data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the total heat content of the waste gas records for all periods the plant is in operation. [R307-401-8] II.B.2 TRO Requirements
II.B.2.a Except for plant outages, process upsets, temperature swing adsorption (TSA) blowdowns, receival of off-specification gas, and startup, shutdown, and malfunction (SSM) situations, the owner/operator shall control emissions with a TRO for all TSA, membrane separation, and pressure swing adsorption (PSA) processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the TRO before being vented to the atmosphere. [R307-401-8]
II.B.2.b The owner/operator shall install a TRO that is certified to meet a VOC control efficiency of no
less than 99%. [R307-401-8]
II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TRO. [R307-401-8] II.B.2.c The owner/operator shall not exceed an H2S concentration of 25 ppmv at the outlet of the H2S
treatment system at all times. [R307-401-8]

II.B.2.c.1 The owner/operator shall monitor and record the waste gas H2S concentration once weekly while the TRO is operating. [R307-401-8]
II.B.2.c.2 The owner/operator shall monitor the H2S concentration at the outlet of the H2S treatment system with equipment located such that an inspector/operator can safely read the output at any time.
[R307-401-8]

II.B.2.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.2.d At all times while operating the TRO, the owner/operator shall maintain a temperature at or above 1,500oF in the thermal oxidizer. [R307-401-8]

II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TRO once each operating day while the TRO is operating. [R307-401-8]
II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an
inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.d.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.2.e The TRO stack height shall measure no less than 60 feet as measured from the elevation of the
base of the stack. [R307-401-8]

DAQE-AN161340002-24
Page 8

II.B.3 Flare Requirements II.B.3.a In the event of plant outages, process upsets, TSA blowdowns, receival of off-specification gas, and SSM situations, the owner/operator shall control emissions with a flare for all TSA, membrane separation, and PSA processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the flare before being vented to the atmosphere. [R307-401-8]
II.B.3.b The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8] II.B.3.c The owner/operator shall install a flare that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8]
II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed flare. [R307-401-8] II.B.3.d The flare stack height shall measure no less than 40 feet as measured from the elevation of the base of the stack. [R307-401-8]
II.B.4 744 HP Engine Limitation and Stack Testing Requirements II.B.4.a The owner/operator shall equip each 744 hp diesel-fired engine with a selective catalytic reduction (SCR) device and a diesel oxidation catalyst (DOC) to control emissions. [R307-401-8]
II.B.4.b The owner/operator shall operate and maintain each 744 hp diesel-fired engine, SCR device, and DOC according to the manufacturer's emission-related written instructions. [R307-401-8] II.B.4.c The owner/operator shall only install Tier 4 744 HP engines that are each certified to meet a CO emission rate of 0.01 lb/hr or less and a VOC emission rate of 0.04 lb/hr or less. [R307-401-8]
II.B.4.c.1 To demonstrate compliance with the above emission rates, the owner/operator shall either A. Own/operate the 744 HP engine, which has obtained Tier 4 certification as defined in 40 CFR 1039.801; B. Conduct an initial performance test according to 40 CFR part 1039; or C. Maintain the manufacturer's emissions guarantee for the installed engine model. [R307-401-8] II.B.4.d The owner/operator shall not emit more than the following rate from each 744 hp engine: Pollutant (g/bhp-hr) NOx 0.31 [R307-401-8]
II.B.4.d.1 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
DAQE-AN161340002-24
Page 9

II.B.4.d.2 Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.4.e The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.4.e.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.4.e.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.4.e.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.4.e.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

II.B.4.e.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.4.f Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.4.f.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.4.f.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

DAQE-AN161340002-24
Page 10

II.B.5 Emergency Engine Requirements II.B.5.a The owner/operator shall not operate the emergency generator engine on site for more than 100
hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendar year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar
year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.b The emergency use generator stack shall measure no less than 7.5 feet as measured from the elevation of the base of the stack. [R307-401-8]
II.B.6 All Diesel-Fueled Engine Requirements
II.B.6.a The owner/operator shall not allow visible emissions from the diesel-fired emergency or non-emergency engine to exceed 20% opacity. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine and non-emergency engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.7 Storage Tank (Storage Vessel) Requirements II.B.7.a The owner/operator shall not exceed a throughput of more than 2,557,920 gallons combined of
diesel fuel through all diesel fuel storage tanks per rolling 12-month period. [R307-401-8]

DAQE-AN161340002-24
Page 11

II.B.7.a.1 The owner/operator shall: A. Determine diesel fuel throughput with supplier billing statements B. Record diesel fuel throughput on a monthly basis C. Use the monthly throughput data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the throughput records for all periods the plant is in operation. [R307-401-8] II.B.7.b The owner/operator shall keep the storage tank thief hatches and other tank openings closed and
sealed except during tank unloading or other maintenance activities. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN161340001-23 dated June 1, 2023 Is Derived From NOI dated June 25, 2024 Incorporates Additional Information dated July 3, 2024 Incorporates Additional Information dated August 16, 2024 Incorporates DAQE-MN161340002-24 dated September 19, 2024
DAQE-AN161340002-24
Page 12

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN161340002-24

October 24, 2024

Nevin Edwards
Lightning Renewables, LLC
201 Helios Way, Floor 6
Houston, TX 77079
[e-mail]

Dear Mr. Edwards:

Re: Intent to Approve: Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8)
Diesel-Fired Engines and Nine (9) Diesel Fuel Storage Tanks
Project Number: N161340002

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Christine Bodell, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell can be reached at
[phone] or [e-mail] if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:CB:jg

cc: Tooele County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN161340002-24
Modification to Approval Order DAQE-AN161340001-23
to Add Eight (8) Diesel-Fired Engines and
Nine (9) Diesel Fuel Storage Tanks

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Lightning Renewables, LLC - Wasatch RNG Processing Facility

Issued On
October 24, 2024

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-IN161340002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Lightning Renewables, LLC Lightning Renewables, LLC - Wasatch RNG Processing Facility

Mailing Address Physical Address
201 Helios Way, Floor 6 8833 North Rowley Road
Houston, TX 77079 Grantsville, UT 84029

Source Contact UTM Coordinates
Name: Nevin Edwards 353,218 m Easting
Phone: [phone],523,252 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas Production/Distribution)

SOURCE INFORMATION
General Description
Lightning Renewables, LLC owns and operates a renewable natural gas (RNG) processing facility in
Tooele County. The RNG plant utilizes landfill gas (LFG) generated from the Wasatch Regional Landfill
as feedstock. The Wasatch Regional Landfill is owned and operated by Republic Services. The Wasatch
RNG processing facility (Wasatch RNG) operates independent of the landfill.

Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm) of LFG from the
Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes processing consisting of
dewatering/moisture removal, sulfur compound removal via media filtration, particulate filtration,
temperature swing adsorption, membrane separation, and pressure swing adsorption. The refined RNG
consists of greater than 95% methane and is compressed and injected into a nearby natural gas
transmission pipeline. Air pollutant-emitting equipment includes two (2) types of thermal oxidizer
pollution control equipment, diesel-fired emergency and non-emergency engine generators, and diesel
fuel storage tanks.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Tooele County
Airs Source Size: B

DAQE-IN161340002-24
Page 4

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
Lightning Renewables is requesting to add the following equipment to its 2023 Approval Order:

1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired engines, each powering a
500-kilowatt (kW) generator;
2. Eight (8) 630-gallon diesel storage belly tanks; and
3. One (1) 15,809-gallon diesel storage tank.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 28877 190181.00
Carbon Monoxide 0.35 30.57
Nitrogen Oxides 17.87 38.23
Particulate Matter - PM10 1.40 9.81
Particulate Matter - PM2.5 1.40 9.81
Sulfur Dioxide 0.32 7.43
Volatile Organic Compounds 1.54 10.21

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 283 292
Generic HAPs (CAS #GHAPS) 144 376
Toluene (CAS #108883) 103 264
Xylenes (Isomers And Mixture) (CAS #1330207) 70 174
Change (TPY) Total (TPY)
Total HAPs 0.30 0.55

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Tooele Transcript on October 30, 2024. During the public
DAQE-IN161340002-24
Page 5
comment period the proposal and the evaluation of its impact on air quality will be available for the
public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

DAQE-IN161340002-24
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 Wasatch RNG Processing Facility
II.A.2 One (1) Thermal Recuperative Oxidizer (TRO) Burner Rating: 7.5 MMBtu/hr Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 99% II.A.3 One (1) Candlestick Flare Burner Rating: 0.1 MMBtu/hr Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 98%
II.A.4 Eight (8) Non-Emergency Engines (New) Rating: 744 HP (500 kW), each Fuel: Diesel Year: 2023 Tier: 4f NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ II.A.5 One (1) Emergency Engine Generator Rating: 324 HP (205 kW) Fuel: Diesel Year: 2022 NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.6 Nine (9) Fuel Storage Tanks (New) Eight (8) 630-Gallon Tanks One (1) 15,809-Gallon Tanks Content: Diesel Fuel

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Operational Requirements II.B.1.a The owner/operator shall not allow visible emissions from the TRO unit and flare to exceed 10% opacity. [R307-401-8]
DAQE-IN161340002-24
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II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not combust more than 865,920 million British Thermal Units (MMBtu) of waste gas in the TRO and flare combined per rolling 12-month period.
[R307-401-8]
II.B.1.b.1 The owner/operator shall: A. Determine total heat content of the waste gas to the TRO and flare through use of flow meters and a methane analyzer. B. Record total heat content of the waste gas to the TRO and flare on a daily basis. C. Use the total heat content of the waste gas data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the total heat content of the waste gas records for all periods the plant is in operation. [R307-401-8] II.B.2 TRO Requirements
II.B.2.a Except for plant outages, process upsets, temperature swing adsorption (TSA) blowdowns, receival of off-specification gas, and startup, shutdown, and malfunction (SSM) situations, the owner/operator shall control emissions with a TRO unit for all TSA, membrane separation, and pressure swing adsorption (PSA) processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the TRO before being vented to the atmosphere. [R307-401-8]
II.B.2.b The owner/operator shall install a TRO that is certified to meet a VOC control efficiency of no
less than 99%. [R307-401-8]
II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TRO. [R307-401-8] II.B.2.c The owner/operator shall not exceed an H2S concentration of 25 ppmv at the outlet of the H2S
treatment system at all times. [R307-401-8]

II.B.2.c.1 The owner/operator shall monitor and record the waste gas H2S concentration once weekly while the TRO is operating. [R307-401-8]
II.B.2.c.2 The owner/operator shall monitor the H2S concentration at the outlet of the H2S treatment system with equipment located such that an inspector/operator can safely read the output at any time.
[R307-401-8]

II.B.2.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.2.d At all times while operating the TRO, the owner/operator shall maintain a temperature at or
above 1,500oF in the thermal oxidizer. [R307-401-8]

II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TRO once each operating day, while the TRO is operating. [R307-401-8]
II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an
inspector/operator can safely read the output at any time. [R307-401-8]

DAQE-IN161340002-24
Page 8

II.B.2.d.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8] II.B.2.e The TRO stack height shall measure no less than 60 feet as measured from the elevation of the base of the stack. [R307-401-8]

II.B.3 Flare Requirements II.B.3.a In the event of plant outages, process upsets, TSA blowdowns, receival of off-specification gas, and SSM situations, the owner/operator shall control emissions with a flare for all TSA,
membrane separation, and PSA processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the flare before being vented to the atmosphere. [R307-401-8]

II.B.3.b The flare shall operate with a continuous pilot flame and be equipped with an auto igniter. [R307-401-8]
II.B.3.c The owner/operator shall install a flare that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8]

II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed flare. [R307-401-8]
II.B.3.d The flare stack height shall measure no less than 40 feet as measured from the elevation of the
base of the stack. [R307-401-8]
II.B.4 744 HP Engine Limitation and Stack Testing Requirements
II.B.4.a The owner/operator shall equip each 744 hp, diesel-fired engine with a selective catalytic
reduction (SCR) device and a diesel oxidation catalyst (DOC) to control emissions. [R307-401-8]

II.B.4.b The owner/operator shall operate and maintain each 744 hp, diesel-fired engine, SCR device, and DOC according to the manufacturer's emission-related written instructions. [R307-401-8]
II.B.4.c The owner/operator shall only install Tier 4 744 HP engines that are each certified to meet a CO
emission rate of 0.01 lb/hr or less and a VOC emission rate of 0.04 lb/hr or less. [R307-401-8]
II.B.4.c.1 To demonstrate compliance with the above emission rates, the owner/operator shall either: A. Own/operate the 744 HP engine which has obtained Tier 4 certification as defined in 40 CFR 1039.801; B. Conduct an initial performance test according to 40 CFR Part 1039; or C. Maintain the manufacturer's emissions guarantee for the installed engine model. [R307-401-8]
II.B.4.d The owner/operator shall not emit more than the following rate from each 744 hp engine:

Pollutant (g/bhp-hr)
NOx 0.31

[R307-401-8]

II.B.4.d.1 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
DAQE-IN161340002-24
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II.B.4.d.2 Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.4.e The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.4.e.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.4.e.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.4.e.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] II.B.4.e.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

II.B.4.e.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.4.f Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.4.f.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K). B. Pressure - 29.92 in Hg (101.3 kPa). C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.4.f.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

DAQE-IN161340002-24
Page 10

II.B.5 Emergency Engine Requirements II.B.5.a The owner/operator shall not operate the emergency generator engine on site for more than 100
hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours
per calendar year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used. B. The duration of operation in hours. C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.5.b The emergency use generator stack shall measure no less than 7.5 feet as measured from the elevation of the base of the stack. [R307-401-8]
II.B.6 All Diesel-Fueled Engine Requirements
II.B.6.a The owner/operator shall not allow visible emissions from the diesel-fired emergency or non-emergency engine to exceed 20% opacity. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in each emergency engine and non-emergency engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.6.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]

II.B.7 Storage Tank (Storage Vessel) Requirements II.B.7.a The owner/operator shall not exceed a throughput of more than 2,557,920 gallons combined of
diesel fuel through all diesel fuel storage tanks per rolling 12-month period. [R307-401-8]

DAQE-IN161340002-24
Page 11

II.B.7.a.1 The owner/operator shall: A. Determine diesel fuel throughput with supplier billing statements. B. Record diesel fuel throughput on a monthly basis. C. Use the monthly throughput data to calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the throughput records for all periods the plant is in operation. [R307-401-8] II.B.7.b The owner/operator shall keep the storage tank thief hatches and other tank openings closed and
sealed except during tank unloading or other maintenance activities. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Incorporates AO DAQE-AN161340001-23 dated June 1, 2023 Is Derived From NOI dated June 25, 2024 Incorporates Additional Information dated July 3, 2024 Incorporates Additional Information dated August 16, 2024 Incorporates DAQE-MN161340002-24 dated September 19, 2024
DAQE-IN161340002-24
Page 12

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Jeree Greenwood <[e-mail]>
Legal Notice to be published October 30, 2024
2 messages
Jeree Greenwood <[e-mail]>Thu, Oct 24, 2024 at 7:30 AM
To: Tooele Transcript Bullentin Chris <[e-mail]>
Please publish the following notice on October 30, 2024. Please also forward to Utahlegals.com.
If you can, reply to this email for my confirmation.
Thank you,
Jeree
--
Jeree Greenwood
Office Technician II | Minor NSR Section
M: [phone]
airquality.utah.gov
DAQE-NN161340002-24.pdf
333K
Chris Nicol <[e-mail]>Thu, Oct 24, 2024 at 10:53 AM
To: Jeree Greenwood <[e-mail]>
Confirmed.
Chris Nicol
Tooele Transcript Bulletin
435-882-0050
On Oct 24, 2024, at 9:04 AM, TBP wrote:
Transcript Bulletin
[e-mail]
[phone]
10/24/24, 11:20 AM State of Utah Mail - Legal Notice to be published October 30, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r-2304379899833563751&simpl=msg-a:r707824636499305…1/2
Begin forwarded message:
[Quoted text hidden]
<DAQE-NN161340002-24.pdf>
10/24/24, 11:20 AM State of Utah Mail - Legal Notice to be published October 30, 2024
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r-2304379899833563751&simpl=msg-a:r707824636499305…2/2
PUBLIC NOTICEA Notice of Intent for the following project submitted in accordance with R307-401-1, UtahAdministrative Code (UAC), has been received for consideration by the Direc-tor:Company Name: Lightning Renewables, LLCLocation: Lightning Renewables, LLC - Wasatch RNG Processing Facility – 8833 North Rowley Road, Grantsville, UTProject Description: Lightning Renewables, LLC owns and operates a renew-able natural gas (RNG) processing facility in Tooele County. The RNG plant utilizes landfill gas (LFG) generated from the Wasatch Regional Landfill as feedstock. The Wasatch Regional Landfill is owned and operated by Repub-lic Services. The Wasatch RNG processing facility (Wasatch RNG) operates independent of the landfill. Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm) of LFG from the Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes processing consisting of dewatering/moisture removal, sulfur compound removal via media filtration, particulate filtration, temperature swing adsorption, membrane separation, and pressure swing adsorption. The refined RNG consists of greater than 95% methane and is compressed and injected into a nearby natural gas transmission pipeline. Lightning Renewables, LLC is requesting to add the following equipment to its 2023 Approval Order:1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired engines, each powering a 500-kilowatt (kW) generator;2. Eight (8) 630-gallon diesel storage belly tanks; and3. One (1) 15,809-gallon diesel storage tank.The completed engineering evaluation and air quality impact analysis showed the proposed project meetsthe requirements of federal air quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public in-spection and comment at the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or before November 29, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with suffi-cient information or documentation to enable the Director to fully consider the substance and significance of the issue.Date of Notice: October 30, 2024(Published in the Tooele Transcript Bulletin October 30, 2024)

DAQE-NN161340002-24

October 24, 2024

Tooele Transcript
Legal Advertising Dept.
58 N Main
Tooele, UT 84074

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Tooele Transcript on
October 30, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Tooele County
cc: Wasatch Front Regional Council

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN161340002-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Lightning Renewables, LLC
Location: Lightning Renewables, LLC - Wasatch RNG Processing Facility – 8833 North
Rowley Road, Grantsville, UT
Project Description: Lightning Renewables, LLC owns and operates a renewable natural gas (RNG)
processing facility in Tooele County. The RNG plant utilizes landfill gas (LFG)
generated from the Wasatch Regional Landfill as feedstock. The Wasatch
Regional Landfill is owned and operated by Republic Services. The Wasatch
RNG processing facility (Wasatch RNG) operates independent of the landfill.

Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm)
of LFG from the Wasatch Regional Landfill. The LFG received at Wasatch RNG
undergoes processing consisting of dewatering/moisture removal, sulfur
compound removal via media filtration, particulate filtration, temperature swing
adsorption, membrane separation, and pressure swing adsorption. The refined
RNG consists of greater than 95% methane and is compressed and injected into a
nearby natural gas transmission pipeline.

Lightning Renewables, LLC is requesting to add the following equipment to its
2023 Approval Order:

1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired
engines, each powering a 500-kilowatt (kW) generator;
2. Eight (8) 630-gallon diesel storage belly tanks; and
3. One (1) 15,809-gallon diesel storage tank.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before November 29, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: October 30, 2024

{{#s=Sig_es_:signer1:signature}}
DAQE-

RN161340002 October 21, 2024 Nevin Edwards Lightning Renewables, LLC 201 Helios Way, Floor 6 Houston, TX 77079
[e-mail] Dear Nevin Edwards,
Re: Engineer Review: Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8) Diesel-Fired Engines
and Nine (9) Diesel Fuel Storage Tanks Project Number: N161340002
The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Lightning Renewables, LLC should complete this review within 10 business days of receipt.
Lightning Renewables, LLC should contact Christine Bodell at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.
If Lightning Renewables, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Lightning Renewables, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction. Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N161340002: Lightning Renewables, LLC- Wasatch RNG Processing Facility October 21, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N161340002 Owner Name Lightning Renewables, LLC Mailing Address 201 Helios Way, Floor 6 Houston, TX, 77079 Source Name Lightning Renewables, LLC- Wasatch RNG Processing Facility Source Location 8833 North Rowley Road Grantsville, UT 84029
UTM Projection 353,218 m Easting, 4,523,252 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12
SIC Code 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas Production/Distribution)
Source Contact Nevin Edwards Phone Number [phone] Email [e-mail]
Billing Contact Dee Anne Alexander Phone Number [phone] Email [e-mail] Project Engineer Christine Bodell, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 25, 2024 Date of Accepted Application September 24, 2024

Engineer Review N161340002: Lightning Renewables, LLC- Wasatch RNG Processing Facility October 21, 2024 Page 2
SOURCE DESCRIPTION General Description
Lightning Renewables, LLC owns and operates a renewable natural gas (RNG) processing facility in Tooele County. The RNG plant utilizes landfill gas (LFG) generated from the Wasatch Regional Landfill as feedstock. The Wasatch Regional Landfill is owned and operated by
Republic Services. The RNG facility (Wasatch RNG) operates independent of the landfill. Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm) of LFG from the
Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes processing, consisting of dewatering/moisture removal, sulfur compound removal via media filtration, particulate filtration, temperature swing adsorption, membrane separation, and pressure swing adsorption.
The refined RNG consists of greater than 95% methane and is compressed and injected into a nearby natural gas transmission pipeline. Air pollutant-emitting equipment includes two (2) types of thermal oxidizer pollution control equipment, diesel-fired emergency and non-emergency
engine generators, and diesel fuel storage tanks. NSR Classification: Minor Modification at Minor Source Source Classification Located in Attainment Area Tooele County
Airs Source Size: B Applicable Federal Standards
NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
Project Proposal Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8) Diesel-Fired Engines
and Nine (9) Diesel Fuel Storage Tanks Project Description Lightning Renewables is requesting to add the following equipment to its 2023 Approval Order:
1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired engines, each powering a 500-kilowatt (kW) generator; 2. Eight (8) 630-gallon diesel storage belly tanks; and
3. One (1) 15,809-gallon diesel storage tank EMISSION IMPACT ANALYSIS
The UDAQ conducted 1-hour NO2 modeling analyses. The results indicated that the highest 1-hour NO2 impact would be 78.7% of the NAAQS levels.

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See modeling memorandum DAQE-MN161340002-24, dated September 19, 2024, for more details. [Last updated September 23, 2024]

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SUMMARY OF EMISSIONS The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 28877 190181.00
Carbon Monoxide 0.35 30.57
Nitrogen Oxides 17.87 38.23
Particulate Matter - PM10 1.40 9.81
Particulate Matter - PM2.5 1.40 9.81
Sulfur Dioxide 0.32 7.43 Volatile Organic Compounds 1.54 10.21 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 283 292
Generic HAPs (CAS #GHAPS) 144 376
Toluene (CAS #108883) 103 264
Xylenes (Isomers And Mixture) (CAS #1330207) 70 174 Change (TPY) Total (TPY) Total HAPs 0.30 0.55
Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units 1. BACT review regarding New Diesel-Fired Emergency Engines
NOx, CO, SO2, PM10, PM2.5, VOC, and HAP emissions will be emitted from the proposed eight (8) 744 hp diesel-fired engines NOx The predominant mechanism for NOx formation from internal combustion engines consists of the thermal dissociation and subsequent reaction of nitrogen (N2) and oxygen (O2) molecules in the combustion air. Available pre-combustion controls include air-to-fuel ratio control, ignition system controls, and derating. Diesel engines are inherently lean-burn engines. The air-to-fuel ratio can be adjusted by controlling the amount of fuel that enters each cylinder. By reducing the air-to-fuel ratio to near
stoichiometric, combustion will occur under conditions of less excess oxygen and reduced combustion temperatures. Lower oxygen levels and combustion temperature reduce NOx formation. Derating involves restricting engine operation to lower than normal levels of power
production. Derating reduces cylinder pressure and temperatures which reduces NOx formation. A common post-combustion control for lean-burn engines includes selective catalytic reduction (SCR). SCR systems introduce a liquid reducing agent such as ammonia or urea into the exhaust gas stream before the catalyst. The catalyst reduces the temperature needed to initiate the reaction
between the reducing agent and NOx to form nitrogen and water. This decreases NOx emissions. Therefore, each of the proposed engines will be certified to EPA Tier 4f standards, and be equipped with an SCR treatment system. As per manufacturer's specifications, the SCR system will limit NOx emission rates to 0.31 g/bhp-hr in each 744 HP engine. This emission rate is below
the limit of 3.0 g/hp-hr of NOx specified in 40 CFR 60 Subpart IIII. DAQ is unaware of any other add-on control technologies that can further reduce NOx emissions and agrees that this emission rate is considered BACT for the proposed engines.
CO, VOCs, HAPs CO and VOC occur due to incomplete combustion of the diesel fuel. Many HAP components are emitted through the same process as VOCs and the control technologies for VOCs also control HAPs. CO, VOCs, and HAPs are generated when there is insufficient time at high temperature to complete the final step in hydrocarbon oxidation. Available pre-combustion modifications include air-to-fuel ratio control and ignition system controls. Available post-combustion control options include diesel oxidation catalysts (DOC). The use of a diesel oxidation catalyst can reduce CO
emissions in the range of 60 to 85% and 35 to 50% for VOC emissions. The proposed engines will be certified to EPA Tier 4f standards and will be equipped with a DOC for CO, VOC, and HAP emissions control which is considered BACT.
PM10/PM2.5 Common control options for PM10/PM2.5 emissions from the CI combustion engines include good combustion practices, use of low-sulfur fuels, diesel particulate filters, and diesel oxidation catalysts. Good combustion practices refer to the operation of engines at high combustion
efficiency which reduces the products of incomplete combustion. The proposed diesel engines are designed to achieve maximum combustion efficiency. The use of low sulfur fuels can reduce particulate emissions by 10-20%. The use of diesel particulate filters has been demonstrated to reduce particulate emissions by up to 85%. DOCs are

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commercially available and are reliable for reducing particulate matter emissions up to 20% from diesel engines. Therefore, use of diesel particulate filters, DOC, and the use of ultra-low sulfur
diesel fuel is considered BACT. [Last updated September 24, 2024] 2. BACT review regarding New Diesel-Fired Emergency Engines (Continued) SO2 Sulfur dioxide emissions occur from the reaction of various elements in the diesel fuel. Sulfur in diesel fuel oxidizes during combustion to form SO2 and sulfur trioxide (SO3). In the presence of
water vapor, these hydrolyze to H2SO4. Lightning Renewables will use ultra-low sulfur diesel fuel containing no more than 15 parts per million by weight of sulfur which is considered BACT. BACT Determination Based on information provided above, DAQ recommends the following measures as BACT for the diesel-fired engines: 1. Use of combustion controls with air/fuel ratio and lean burn design. 2. Limit exhaust concentrations, in g/bhp-hr, in each 744 HP engine to 0.31 of NOx. 3. Install 744 HP engines that meet the Tier 4 standards and that are equipped with SCR and DOC devices to reduce VOC and CO emissions to no more than 0.04 lb/hr and 0.01 lb/hr, respectively. 4. Conduct manufacturer recommended maintenance and testing. 5. Limit visible emissions to 20% opacity. [Last updated September 24, 2024] 3. BACT review regarding New Diesel-Fuel Storage Tanks Fixed roof tanks are most often used for high flash point fuels and lower vapor pressure liquids like diesel, kerosene, jet fuel, fuel oils, and asphalt cement. Emissions from storage tanks result from displacement of headspace vapor during filling operations (working losses) and from diurnal
temperature and heating variations (breathing losses). Typically, filling losses constitute 80-90% of the total losses for fixed roof tanks. Emissions from fuel storage tanks could be reduced by placing the tanks underground. Because of asphalt cements low volatility, placing the tanks underground
would be considered cost prohibitive for the amount of emissions it would reduce. Additional control technologies include carbon adoption, incinerations, and best management practices. Both carbon adsorption and incineration are effective control technologies, having greater 95% and 98% control efficiencies, respectively. However, due to the low volatility of the products being stored and high costs of the controls, additional emission controls are considered cost prohibitive. BACT for the storage tanks would be to conduct good operations of the tanks and conducting proper maintenance on the tanks. This will include regular inspection of the tanks and associated piping for leaks and reducing breathing and working losses from the tank. To reduce working losses, the number of tank turnovers per year will be minimized. This is considered BACT. [Last updated September 24, 2024]
SECTION I: GENERAL PROVISIONS

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The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT

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II.A.1 Wasatch RNG Processing Facility
II.A.2 One (1) Thermal Recuperative Oxidizer (TRO) Burner Rating: 7.5 MMBtu/hr Burner Fuel: Natural Gas
Minimum VOC Destruction Efficiency: 99% II.A.3 One (1) Candlestick Flare Burner Rating: 0.1 MMBtu/hr
Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 98%
II.A.4 NEW Eight (8) Non-Emergency Engines (New) Rating: 744 HP (500 kW), each Fuel: Diesel Year: 2023
Tier: 4f NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ II.A.5 One (1) Emergency Engine Generator Rating: 324 HP (205 kW)
Fuel: Diesel Year: 2022 NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.6
NEW
Nine (9) Fuel Storage Tanks (New)
Eight (8) 630-Gallon Tanks One (1) 15,809-Gallon Tanks Content: Diesel Fuel

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Operational Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the thermal recuperative oxidizer
unit (TRO) and flare to exceed 10% opacity. [R307-401-8]

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II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Method 9. [R307-401-8] II.B.1.b NEW The owner/operator shall not combust more than 865,920 million British Thermal Units (MMBtu) of waste gas in the TRO and flare combined per rolling 12-month period. [R307-
401-8] II.B.1.b.1 The owner/operator shall: A. Determine total heat content of the waste gas to the TRO and flare through
use of flow meters and a methane analyzer B. Record total heat content of the waste gas to the TRO and flare on a daily basis C. Use the total heat content of the waste gas data to calculate a new rolling 12-month
total by the 20th day of each month using data from the previous 12 months D. Keep the total heat content of the waste gas records for all periods the plant is in
operation
[R307-401-8]

II.B.2 Thermal Recuperative Oxidizer (TRO) Requirements
II.B.2.a Except for plant outages, process upsets, temperature swing adsorption (TSA) blowdowns,
receival of off-specification gas, and startup, shutdown, and malfunction (SSM) situations, the owner/operator shall control emissions with a thermal recuperative oxidizer unit (TRO) for all TSA, membrane separation, and pressure swing adsorption (PSA) processes. All emissions
from the TSA, membrane separation, and PSA processes shall be routed through the TRO before being vented to the atmosphere. [R307-401-8]
II.B.2.b The owner/operator shall install a TRO that is certified to meet a VOC control efficiency of no
less than 99%. [R307-401-8] II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TRO. [R307-401-8]
II.B.2.c The owner/operator shall not exceed an H2S concentration of 25 ppmv at the outlet of the H2S
treatment system at all times. [R307-401-8] II.B.2.c.1 The owner/operator shall monitor and record the waste gas H2S concentration once weekly, while the TRO is operating. [R307-401-8]

II.B.2.c.2 The owner/operator shall monitor the H2S concentration at the outlet of the H2S treatment
system with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8]
II.B.2.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions
at least once every 12 months. [R307-401-8]

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II.B.2.d At all times while operating the TRO, the owner/operator shall maintain a temperature at or above 1,500oF in the thermal oxidizer. [R307-401-8] II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TRO once each operating day, while the TRO is operating. [R307-401-8]

II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8]
II.B.2.d.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
II.B.2.e The TRO stack height shall measure no less than 60 feet as measured from the elevation of the base of the stack. [R307-401-8]
II.B.3 Flare Requirements
II.B.3.a In the event of plant outages, process upsets, TSA blowdowns, receival of off-specification gas, and SSM situations, the owner/operator shall control emissions with a flare for all TSA,
membrane separation, and PSA processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the flare before being vented to the atmosphere. [R307-401-8]
II.B.3.b The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8]
II.B.3.c The owner/operator shall install a flare that is certified to meet a VOC control efficiency of no
less than 98%. [R307-401-8]
II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed flare. [R307-401-8]
II.B.3.d The flare stack height shall measure no less than 40 feet as measured from the elevation of the
base of the stack. [R307-401-8] II.B.4 NEW 744 HP Engine Limitation and Stack Testing Requirements
II.B.4.a NEW The owner/operator shall equip each 744 hp, diesel-fired engine with a selective catalytic reduction (SCR) device and a diesel oxidation catalyst (DOC) to control emissions. [R307-401-8] II.B.4.b NEW The owner/operator shall operate and maintain each 744 hp, diesel-fired engine, SCR device, and DOC according to the manufacturer's emission-related written instructions. [R307-401-8]

II.B.4.c NEW The owner/operator shall only install Tier 4 744 HP engines that are each certified to meet a CO emission rate of 0.01 lb/hr or less and a VOC emission rate of 0.04 lb/hr or less. [R307-401-8]

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II.B.4.c.1 NEW To demonstrate compliance with the above emission rates, the owner/operator shall either;
A. Own/operate the 744 HP engine which has obtained Tier 4 certification as
defined in 40 CFR 1039.801; B. Conduct an initial performance test according to 40 CFR part 1039; or
C. Maintain the manufacturer's emissions guarantee for the installed engine model.
[R307-401-8]

II.B.4.d
NEW
The owner/operator shall not emit more than the following rate from each 744 hp engine:
Pollutant (g/bhp-hr)
NOx 0.31 [R307-401-8]
II.B.4.d.1 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]

II.B.4.d.2 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.4.e NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]

II.B.4.e.1
NEW
Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8] II.B.4.e.2 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.4.e.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.4.e.4 NEW Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

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II.B.4.e.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.4.f
NEW
Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]

II.B.4.f.1 NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.4.f.2
NEW
NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.5 Emergency Engine Requirements II.B.5.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. The emergency
generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use
of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.b The emergency use generator stack shall measure no less than 7.5 feet as measured from the
elevation of the base of the stack. [R307-401-8] II.B.6 All Diesel-Fueled Engine Requirements

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II.B.6.a The owner/operator shall not allow visible emissions from the diesel-fired emergency or non-emergency engine to exceed 20% opacity. [R307-401-8] II.B.6.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine and non-emergency engine. [R307-401-8]

II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.6.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]
II.B.7 NEW Storage Tank (Storage Vessel) Requirements
II.B.7.a NEW The owner/operator shall not exceed a throughput of more than 2,557,920 gallons combined of diesel fuel through all diesel fuel storage tanks per rolling 12-month period. [R307-401-8]

II.B.7.a.1 NEW The owner/operator shall:
A. Determine diesel fuel throughput with supplier billing statements
B. Record diesel fuel throughput on a monthly basis.
C. Use the monthly throughput data to calculate a new 12-month total by
the 20th day of each month using data from the previous 12 months.
D. Keep the throughput records for all periods the plant is in operation.
[R307-401-8]
II.B.7.b
NEW
The owner/operator shall keep the storage tank thief hatches and other tank openings closed
and sealed except during tank unloading or other maintenance activities. [R307-401-8]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Incorporates AO DAQE-AN161340001-23 dated June 1, 2023
Is Derived From NOI dated June 25, 2024 Incorporates Additional Information dated July 3, 2024 Incorporates Additional Information dated August 16, 2024
Incorporates DAQE-MN161340002-24 dated September 19, 2024
REVIEWER COMMENTS

1. Comment regarding Source Emission Estimates and DAQ Acceptance: Emergency Engine Emission Estimates Emission estimates are based on manufacturer data and EPA guidance as published in AP-42,
Section 3.3, Gasoline and Diesel Industrial Engines. The 324 HP emergency generator engine will operate a maximum of 100 hours per year for maintenance and testing purposes and with no hourly limits on emergency use.
TRO Emission Estimates
CO and NOx emissions from the TRO are quantified based on outlet guarantees from the TRO vendor of 0.20 lb/MMBtu and 0.10 lb/MMBtu, respectively. These emissions guarantees are inclusive of supplemental natural gas used in the TRO. These values are converted to a mass flow
basis by multiplying by the maximum heat content to the TRO of 11.9 MMBtu/hr. Similarly, the vendor guarantee for emissions of VOC, post-TRO, is 20 ppm (as hexane). This is converted to a mass basis using the Ideal Gas Law (IGL) and exhaust flowrate of the TRO. Particulate matter (PM)
emissions are quantified using the 17.0 lbs PM/MMdscf CH4 emission factor in AP-42 Section 2.4 (Municipal Solid Waste Landfills) Table 2.4-5 and converted to a mass basis by multiplying by the maximum inlet flow to the TRO and maximum methane content. Emissions of PM less than 10 microns in diameter (PM10) and 2.5 microns in diameter (PM2.5) are assumed equal to PM. Sulfur dioxide (SO2) emissions are calculated from design parameters of the sulfur removal step of the
RNG process. The sulfur removal process is upstream of all vent points to the TRO and is designed to remove sulfur down to a maximum of 25 ppm of total reduced sulfur (TRS) as H2S. This concentration of TRS is converted to a mass basis of SO2 using the IGL and maximum inlet flowrate
to the facility. As described above, all criteria pollutants are calculated on an uncontrolled basis because the emissions are either based on outlet guarantees from the TRO vendor (CO, NOX, VOC) or calculated as a by-product of combustion (SO2 and PM/PM10/PM2.5). All the lb/hr pollutant
emission rates are converted to a lb/MMscf basis by dividing the maximum inlet flowrate to the TRO. All hazardous air pollutant (HAP) emissions are calculated using LFG site specific sampling results from Wasatch Regional Landfill collected October 24, 2022 by converting the volumetric
concentration of various HAP in the LFG per AP-42 Section 2.4 Table 2.4-1 to a mass basis using the IGL and total LFG flowrate into the facility. The hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions are calculated based on testing of chlorides and fluorides in the LFG and 100%
conversion to HCl and HF respectively using AP-42 Chapter 2.4 Equation 9. All organic HAP are assumed to be controlled by at least 98%. Metal HAP are assumed to be uncontrolled. Additional HAP emissions have been calculated as combustion by-products from supplemental natural gas flow

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in the thermal oxidizers and diesel in the emergency generator. Flare Emission Estimates The emissions at the back-up flare are calculated in a similar manner as described above for the TRO. However, the major differences between the flare emissions calculation methodology and the TRO methodology are that the emission calculations use the flowrate, methane content, and/or heat content of flare as opposed to the waste gas parameters used for the TRO calculations. The control efficiency for the flare is 98%. CO and NOX emissions are based on AP-42, Section 2.4 (Draft 2008), which are 46.0 and 39.0 lbs/MMdscf CH4, respectively. Lastly, VOC emissions are based on the maximum VOC volumetric concentration in LFG of 595 ppm as hexane from AP-42 Section
2.4.4.1. This concentration yields an uncontrolled emission factor, then an 98% control efficiency applied. [Last updated September 23, 2024]
2. Comment regarding Source Emission Estimates and DAQ Acceptance (Continued): Non-Emergency (744 hp) Engine Emission Estimates
Emission estimates are based on manufacturer data and EPA guidance as published in AP-42, Section 3.3, Gasoline and Diesel Industrial Engines. The 744 hp generator engines will operate a maximum of 8,760 hours per year.
New Diesel Fuel Storage Tanks
Emission estimates from the 630-gallon fuel storage tanks were estimated using an engine fuel consumption rate of 36.50 gallons per hour. Eight (8) engines each operating 8,760 hours annually results in a maximum annual diesel fuel throughput of 2,557,920 gallons. Emission estimates are
also based EPA guidance as published in AP-42, Section 5.2 Transportation and Marketing of Petroleum Liquids and the tank emissions calculation software TankESP. Emission estimates from the one 15,809-gallon diesel fuel storage tank were calculated in the same manner as the 630-gallon fuel tanks and also assumed a maximum annual diesel fuel throughput of
2,557,920 gallons. [Last updated July 5, 2024] 3. Comment regarding Federal Subpart Applicability: NSPS Subpart Kb 40 CFR 60 (NSPS) Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984) applies to storage vessels with a capacity greater than or equal to 75 m3 (19,812.9 gallons) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. The diesel
fuel storage tanks on site have capacities of either 630 gallons or 15,809 gallons. Therefore, NSPS Subpart Kb does not apply to this facility. NSPS Subpart IIII 40 CFR 60 (NSPS) Subpart IIII (Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines) applies to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE is manufactured after April 1, 2006. The existing 324 hp engine was constructed in 2022 and the eight (8) proposed 744 hp engines were
manufactured in 2023. Therefore, NSPS Subpart IIII applies. MACT Subpart ZZZZ 40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) is applicable to owners/operators of

Engineer Review N161340002: Lightning Renewables, LLC- Wasatch RNG Processing Facility October 21, 2024 Page 16
stationary RICE at a major or area sources of HAP emissions. MACT Subpart ZZZZ applies to the Wasatch RNG Processing Facility as the emergency engine generator is classified as a CI ICE. The
emergency and non-emergency diesel generator engines on site will meet MACT Subpart ZZZZ by meeting 40 CFR Part 60, Subpart IIII as the Wasatch RNG Processing Facility is an area source of HAP emissions. [Last updated July 5, 2024]
4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 61 (NESHAP) regulations. This facility is subject to 40 CFR 60 (NSPS) Subparts A, and IIII and 40
CFR 63 (MACT) Subparts A and ZZZZ. NSPS Subpart IIII and MACT Subpart ZZZZ each specifically exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. Therefore, this facility is not
a Title V source. [Last updated July 1, 2024]

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ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations
CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard
NSR New Source Review PM10 Particulate matter less than 10 microns in size PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
DAQE-

RN161340002 October 21, 2024 Nevin Edwards Lightning Renewables, LLC 201 Helios Way, Floor 6
Houston, TX 77079 [e-mail]
Dear Nevin Edwards, Re: Engineer Review:
Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8) Diesel-Fired Engines and Nine (9) Diesel Fuel Storage Tanks Project Number: N161340002 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. Lightning Renewables, LLC should complete this review within 10 business days of receipt. Lightning Renewables, LLC should contact Christine Bodell at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.
If Lightning Renewables, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Lightning Renewables, LLC has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

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10/22/2024

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UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N161340002 Owner Name Lightning Renewables, LLC Mailing Address 201 Helios Way, Floor 6
Houston, TX, 77079 Source Name Lightning Renewables, LLC- Wasatch RNG Processing Facility
Source Location 8833 North Rowley Road Grantsville, UT 84029
UTM Projection 353,218 m Easting, 4,523,252 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas Production/Distribution) Source Contact Nevin Edwards Phone Number [phone] Email [e-mail] Billing Contact Dee Anne Alexander
Phone Number [phone] Email [e-mail]
Project Engineer Christine Bodell, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted June 25, 2024 Date of Accepted Application September 24, 2024
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SOURCE DESCRIPTION General Description
Lightning Renewables, LLC owns and operates a renewable natural gas (RNG) processing facility in Tooele County. The RNG plant utilizes landfill gas (LFG) generated from the Wasatch Regional Landfill as feedstock. The Wasatch Regional Landfill is owned and operated by
Republic Services. The RNG facility (Wasatch RNG) operates independent of the landfill. Wasatch RNG can accept up to 3,200 dry standard cubic feet per minute (dscfm) of LFG from the Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes processing, consisting of dewatering/moisture removal, sulfur compound removal via media filtration, particulate filtration, temperature swing adsorption, membrane separation, and pressure swing adsorption. The refined RNG consists of greater than 95% methane and is compressed and injected into a nearby natural gas transmission pipeline. Air pollutant-emitting equipment includes two (2) types of thermal oxidizer pollution control equipment, diesel-fired emergency and non-emergency engine generators, and diesel fuel storage tanks.
NSR Classification: Minor Modification at Minor Source
Source Classification Located in Attainment Area Tooele County
Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Modification to Approval Order DAQE-AN161340001-23 to Add Eight (8) Diesel-Fired Engines and Nine (9) Diesel Fuel Storage Tanks
Project Description Lightning Renewables is requesting to add the following equipment to its 2023 Approval Order:
1. Four (4) trailers, each equipped with two (2) 744 horsepower (hp) diesel-fired engines, each powering a 500-kilowatt (kW) generator; 2. Eight (8) 630-gallon diesel storage belly tanks; and
3. One (1) 15,809-gallon diesel storage tank EMISSION IMPACT ANALYSIS
The UDAQ conducted 1-hour NO2 modeling analyses. The results indicated that the highest 1-hour NO2 impact would be 78.7% of the NAAQS levels.
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See modeling memorandum DAQE-MN161340002-24, dated September 19, 2024, for more details. [Last updated September 23, 2024]

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SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 28877 190181.00 Carbon Monoxide 0.35 30.57
Nitrogen Oxides 17.87 38.23
Particulate Matter - PM10 1.40 9.81
Particulate Matter - PM2.5 1.40 9.81
Sulfur Dioxide 0.32 7.43
Volatile Organic Compounds 1.54 10.21 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 283 292
Generic HAPs (CAS #GHAPS) 144 376
Toluene (CAS #108883) 103 264
Xylenes (Isomers And Mixture) (CAS #1330207) 70 174
Change (TPY) Total (TPY) Total HAPs 0.30 0.55 Note: Change in emissions indicates the difference between previous AO and proposed modification.
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Review of BACT for New/Modified Emission Units 1. BACT review regarding New Diesel-Fired Emergency Engines
NOx, CO, SO2, PM10, PM2.5, VOC, and HAP emissions will be emitted from the proposed eight (8) 744 hp diesel-fired engines NOx The predominant mechanism for NOx formation from internal combustion engines consists of the thermal dissociation and subsequent reaction of nitrogen (N2) and oxygen (O2) molecules in the combustion air. Available pre-combustion controls include air-to-fuel ratio control, ignition system controls, and derating. Diesel engines are inherently lean-burn engines. The air-to-fuel ratio can be adjusted by controlling the amount of fuel that enters each cylinder. By reducing the air-to-fuel ratio to near stoichiometric, combustion will occur under conditions of less excess oxygen and reduced combustion temperatures. Lower oxygen levels and combustion temperature reduce NOx formation. Derating involves restricting engine operation to lower than normal levels of power production. Derating reduces cylinder pressure and temperatures which reduces NOx formation. A common post-combustion control for lean-burn engines includes selective catalytic reduction (SCR). SCR systems introduce a liquid reducing agent such as ammonia or urea into the exhaust gas stream before the catalyst. The catalyst reduces the temperature needed to initiate the reaction between the reducing agent and NOx to form nitrogen and water. This decreases NOx emissions. Therefore, each of the proposed engines will be certified to EPA Tier 4f standards, and be equipped with an SCR treatment system. As per manufacturer's specifications, the SCR system will limit NOx emission rates to 0.31 g/bhp-hr in each 744 HP engine. This emission rate is below
the limit of 3.0 g/hp-hr of NOx specified in 40 CFR 60 Subpart IIII. DAQ is unaware of any other add-on control technologies that can further reduce NOx emissions and agrees that this emission rate is considered BACT for the proposed engines.
CO, VOCs, HAPs
CO and VOC occur due to incomplete combustion of the diesel fuel. Many HAP components are emitted through the same process as VOCs and the control technologies for VOCs also control HAPs. CO, VOCs, and HAPs are generated when there is insufficient time at high temperature to
complete the final step in hydrocarbon oxidation. Available pre-combustion modifications include air-to-fuel ratio control and ignition system controls. Available post-combustion control options include diesel oxidation catalysts (DOC). The use of a diesel oxidation catalyst can reduce CO
emissions in the range of 60 to 85% and 35 to 50% for VOC emissions. The proposed engines will be certified to EPA Tier 4f standards and will be equipped with a DOC for CO, VOC, and HAP emissions control which is considered BACT.
PM10/PM2.5
Common control options for PM10/PM2.5 emissions from the CI combustion engines include good combustion practices, use of low-sulfur fuels, diesel particulate filters, and diesel oxidation catalysts. Good combustion practices refer to the operation of engines at high combustion
efficiency which reduces the products of incomplete combustion. The proposed diesel engines are designed to achieve maximum combustion efficiency. The use of low sulfur fuels can reduce particulate emissions by 10-20%. The use of diesel particulate filters has been demonstrated to reduce particulate emissions by up to 85%. DOCs are
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commercially available and are reliable for reducing particulate matter emissions up to 20% from diesel engines. Therefore, use of diesel particulate filters, DOC, and the use of ultra-low sulfur
diesel fuel is considered BACT. [Last updated September 24, 2024] 2. BACT review regarding New Diesel-Fired Emergency Engines (Continued) SO2 Sulfur dioxide emissions occur from the reaction of various elements in the diesel fuel. Sulfur in diesel fuel oxidizes during combustion to form SO2 and sulfur trioxide (SO3). In the presence of water vapor, these hydrolyze to H2SO4. Lightning Renewables will use ultra-low sulfur diesel fuel containing no more than 15 parts per million by weight of sulfur which is considered BACT. BACT Determination Based on information provided above, DAQ recommends the following measures as BACT for the diesel-fired engines: 1. Use of combustion controls with air/fuel ratio and lean burn design. 2. Limit exhaust concentrations, in g/bhp-hr, in each 744 HP engine to 0.31 of NOx. 3. Install 744 HP engines that meet the Tier 4 standards and that are equipped with SCR and DOC devices to reduce VOC and CO emissions to no more than 0.04 lb/hr and 0.01 lb/hr, respectively. 4. Conduct manufacturer recommended maintenance and testing. 5. Limit visible emissions to 20% opacity.
[Last updated September 24, 2024] 3. BACT review regarding New Diesel-Fuel Storage Tanks
Fixed roof tanks are most often used for high flash point fuels and lower vapor pressure liquids like diesel, kerosene, jet fuel, fuel oils, and asphalt cement. Emissions from storage tanks result from displacement of headspace vapor during filling operations (working losses) and from diurnal
temperature and heating variations (breathing losses). Typically, filling losses constitute 80-90% of the total losses for fixed roof tanks. Emissions from fuel storage tanks could be reduced by placing the tanks underground. Because of asphalt cements low volatility, placing the tanks underground would be considered cost prohibitive for the amount of emissions it would reduce.
Additional control technologies include carbon adoption, incinerations, and best management practices. Both carbon adsorption and incineration are effective control technologies, having greater 95% and 98% control efficiencies, respectively. However, due to the low volatility of the
products being stored and high costs of the controls, additional emission controls are considered cost prohibitive. BACT for the storage tanks would be to conduct good operations of the tanks and conducting proper maintenance on the tanks. This will include regular inspection of the tanks and associated piping for leaks and reducing breathing and working losses from the tank. To reduce working losses, the number of tank turnovers per year will be minimized. This is considered BACT. [Last updated September 24, 2024]

SECTION I: GENERAL PROVISIONS

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The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
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II.A.1 Wasatch RNG Processing Facility II.A.2 One (1) Thermal Recuperative Oxidizer (TRO) Burner Rating: 7.5 MMBtu/hr Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 99% II.A.3 One (1) Candlestick Flare Burner Rating: 0.1 MMBtu/hr
Burner Fuel: Natural Gas Minimum VOC Destruction Efficiency: 98%
II.A.4 NEW Eight (8) Non-Emergency Engines (New) Rating: 744 HP (500 kW), each Fuel: Diesel Year: 2023
Tier: 4f NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.5 One (1) Emergency Engine Generator Rating: 324 HP (205 kW)
Fuel: Diesel Year: 2022 NSPS Applicability: 40 CFR 60 Subpart IIII MACT Applicability: 40 CFR 63 Subpart ZZZZ

II.A.6 NEW Nine (9) Fuel Storage Tanks (New) Eight (8) 630-Gallon Tanks One (1) 15,809-Gallon Tanks
Content: Diesel Fuel

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Operational Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the thermal recuperative oxidizer
unit (TRO) and flare to exceed 10% opacity. [R307-401-8]
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II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Method 9. [R307-401-8]
II.B.1.b NEW The owner/operator shall not combust more than 865,920 million British Thermal Units (MMBtu) of waste gas in the TRO and flare combined per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Determine total heat content of the waste gas to the TRO and flare through
use of flow meters and a methane analyzer B. Record total heat content of the waste gas to the TRO and flare on a daily basis C. Use the total heat content of the waste gas data to calculate a new rolling 12-month
total by the 20th day of each month using data from the previous 12 months
D. Keep the total heat content of the waste gas records for all periods the plant is in
operation
[R307-401-8]

II.B.2 Thermal Recuperative Oxidizer (TRO) Requirements
II.B.2.a Except for plant outages, process upsets, temperature swing adsorption (TSA) blowdowns,
receival of off-specification gas, and startup, shutdown, and malfunction (SSM) situations, the owner/operator shall control emissions with a thermal recuperative oxidizer unit (TRO) for all TSA, membrane separation, and pressure swing adsorption (PSA) processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the TRO before being vented to the atmosphere. [R307-401-8]
II.B.2.b The owner/operator shall install a TRO that is certified to meet a VOC control efficiency of no
less than 99%. [R307-401-8] II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TRO. [R307-401-8]

II.B.2.c The owner/operator shall not exceed an H2S concentration of 25 ppmv at the outlet of the H2S
treatment system at all times. [R307-401-8] II.B.2.c.1 The owner/operator shall monitor and record the waste gas H2S concentration once weekly, while the TRO is operating. [R307-401-8]

II.B.2.c.2 The owner/operator shall monitor the H2S concentration at the outlet of the H2S treatment
system with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8]
II.B.2.c.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at least once every 12 months. [R307-401-8]
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II.B.2.d At all times while operating the TRO, the owner/operator shall maintain a temperature at or above 1,500oF in the thermal oxidizer. [R307-401-8]
II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TRO once each operating day, while the TRO is operating. [R307-401-8]
II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an inspector/operator can safely read the output at any time. [R307-401-8]
II.B.2.d.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions
at least once every 12 months. [R307-401-8]
II.B.2.e The TRO stack height shall measure no less than 60 feet as measured from the elevation of the base of the stack. [R307-401-8]
II.B.3 Flare Requirements
II.B.3.a In the event of plant outages, process upsets, TSA blowdowns, receival of off-specification gas, and SSM situations, the owner/operator shall control emissions with a flare for all TSA, membrane separation, and PSA processes. All emissions from the TSA, membrane separation, and PSA processes shall be routed through the flare before being vented to the atmosphere. [R307-401-8] II.B.3.b The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8]
II.B.3.c The owner/operator shall install a flare that is certified to meet a VOC control efficiency of no
less than 98%. [R307-401-8] II.B.3.c.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed flare. [R307-401-8]

II.B.3.d The flare stack height shall measure no less than 40 feet as measured from the elevation of the base of the stack. [R307-401-8] II.B.4 NEW 744 HP Engine Limitation and Stack Testing Requirements
II.B.4.a NEW The owner/operator shall equip each 744 hp, diesel-fired engine with a selective catalytic reduction (SCR) device and a diesel oxidation catalyst (DOC) to control emissions. [R307-401-8]
II.B.4.b NEW The owner/operator shall operate and maintain each 744 hp, diesel-fired engine, SCR device, and DOC according to the manufacturer's emission-related written instructions. [R307-401-8]
II.B.4.c NEW The owner/operator shall only install Tier 4 744 HP engines that are each certified to meet a CO emission rate of 0.01 lb/hr or less and a VOC emission rate of 0.04 lb/hr or less. [R307-401-8]

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II.B.4.c.1 NEW To demonstrate compliance with the above emission rates, the owner/operator shall either;
A. Own/operate the 744 HP engine which has obtained Tier 4 certification as
defined in 40 CFR 1039.801; B. Conduct an initial performance test according to 40 CFR part 1039; or
C. Maintain the manufacturer's emissions guarantee for the installed engine model.
[R307-401-8]

II.B.4.d NEW The owner/operator shall not emit more than the following rate from each 744 hp engine:
Pollutant (g/bhp-hr)
NOx 0.31 [R307-401-8] II.B.4.d.1 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2]
II.B.4.d.2 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within three (3) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.4.e NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]

II.B.4.e.1 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] II.B.4.e.2 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.4.e.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.4.e.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]

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II.B.4.e.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.4.f NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.4.f.1 NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.4.f.2
NEW
NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.5 Emergency Engine Requirements II.B.5.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per calendar year for maintenance checks and readiness testing. The emergency generator engine on site may be operated for up to 50 hours per calendrer year in non-emergency situations. Any operation in non-emergency situations shall be counted as part of the 100 hours per calendar year for maintenance and testing. There is no time limit on the use of the engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of the emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.5.b The emergency use generator stack shall measure no less than 7.5 feet as measured from the elevation of the base of the stack. [R307-401-8] II.B.6 All Diesel-Fueled Engine Requirements
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II.B.6.a The owner/operator shall not allow visible emissions from the diesel-fired emergency or non-emergency engine to exceed 20% opacity. [R307-401-8]
II.B.6.b The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine and non-emergency engine. [R307-401-8]
II.B.6.b.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.6.b.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.7 NEW Storage Tank (Storage Vessel) Requirements
II.B.7.a NEW The owner/operator shall not exceed a throughput of more than 2,557,920 gallons combined of diesel fuel through all diesel fuel storage tanks per rolling 12-month period. [R307-401-8]

II.B.7.a.1 NEW The owner/operator shall:
A. Determine diesel fuel throughput with supplier billing statements
B. Record diesel fuel throughput on a monthly basis.
C. Use the monthly throughput data to calculate a new 12-month total by
the 20th day of each month using data from the previous 12 months.
D. Keep the throughput records for all periods the plant is in operation.
[R307-401-8]
II.B.7.b NEW The owner/operator shall keep the storage tank thief hatches and other tank openings closed and sealed except during tank unloading or other maintenance activities. [R307-401-8]
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Engineer Review N161340002: Lightning Renewables, LLC- Wasatch RNG Processing Facility October 21, 2024 Page 14
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Incorporates AO DAQE-AN161340001-23 dated June 1, 2023
Is Derived From NOI dated June 25, 2024 Incorporates Additional Information dated July 3, 2024 Incorporates Additional Information dated August 16, 2024 Incorporates DAQE-MN161340002-24 dated September 19, 2024
REVIEWER COMMENTS
1. Comment regarding Source Emission Estimates and DAQ Acceptance: Emergency Engine Emission Estimates Emission estimates are based on manufacturer data and EPA guidance as published in AP-42, Section 3.3, Gasoline and Diesel Industrial Engines. The 324 HP emergency generator engine will operate a maximum of 100 hours per year for maintenance and testing purposes and with no hourly limits on emergency use.
TRO Emission Estimates
CO and NOx emissions from the TRO are quantified based on outlet guarantees from the TRO vendor of 0.20 lb/MMBtu and 0.10 lb/MMBtu, respectively. These emissions guarantees are inclusive of supplemental natural gas used in the TRO. These values are converted to a mass flow basis by multiplying by the maximum heat content to the TRO of 11.9 MMBtu/hr. Similarly, the vendor guarantee for emissions of VOC, post-TRO, is 20 ppm (as hexane). This is converted to a mass basis using the Ideal Gas Law (IGL) and exhaust flowrate of the TRO. Particulate matter (PM) emissions are quantified using the 17.0 lbs PM/MMdscf CH4 emission factor in AP-42 Section 2.4 (Municipal Solid Waste Landfills) Table 2.4-5 and converted to a mass basis by multiplying by the
maximum inlet flow to the TRO and maximum methane content. Emissions of PM less than 10 microns in diameter (PM10) and 2.5 microns in diameter (PM2.5) are assumed equal to PM. Sulfur dioxide (SO2) emissions are calculated from design parameters of the sulfur removal step of the
RNG process. The sulfur removal process is upstream of all vent points to the TRO and is designed to remove sulfur down to a maximum of 25 ppm of total reduced sulfur (TRS) as H2S. This concentration of TRS is converted to a mass basis of SO2 using the IGL and maximum inlet flowrate
to the facility. As described above, all criteria pollutants are calculated on an uncontrolled basis because the emissions are either based on outlet guarantees from the TRO vendor (CO, NOX, VOC) or calculated as a by-product of combustion (SO2 and PM/PM10/PM2.5). All the lb/hr pollutant
emission rates are converted to a lb/MMscf basis by dividing the maximum inlet flowrate to the TRO. All hazardous air pollutant (HAP) emissions are calculated using LFG site specific sampling results from Wasatch Regional Landfill collected October 24, 2022 by converting the volumetric
concentration of various HAP in the LFG per AP-42 Section 2.4 Table 2.4-1 to a mass basis using the IGL and total LFG flowrate into the facility. The hydrogen chloride (HCl) and hydrogen fluoride (HF) emissions are calculated based on testing of chlorides and fluorides in the LFG and 100%
conversion to HCl and HF respectively using AP-42 Chapter 2.4 Equation 9. All organic HAP are assumed to be controlled by at least 98%. Metal HAP are assumed to be uncontrolled. Additional HAP emissions have been calculated as combustion by-products from supplemental natural gas flow
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Engineer Review N161340002: Lightning Renewables, LLC- Wasatch RNG Processing Facility October 21, 2024 Page 15
in the thermal oxidizers and diesel in the emergency generator. Flare Emission Estimates The emissions at the back-up flare are calculated in a similar manner as described above for the TRO. However, the major differences between the flare emissions calculation methodology and the TRO methodology are that the emission calculations use the flowrate, methane content, and/or heat content of flare as opposed to the waste gas parameters used for the TRO calculations. The control
efficiency for the flare is 98%. CO and NOX emissions are based on AP-42, Section 2.4 (Draft 2008), which are 46.0 and 39.0 lbs/MMdscf CH4, respectively. Lastly, VOC emissions are based on the maximum VOC volumetric concentration in LFG of 595 ppm as hexane from AP-42 Section 2.4.4.1. This concentration yields an uncontrolled emission factor, then an 98% control efficiency applied. [Last updated September 23, 2024]
2. Comment regarding Source Emission Estimates and DAQ Acceptance (Continued): Non-Emergency (744 hp) Engine Emission Estimates Emission estimates are based on manufacturer data and EPA guidance as published in AP-42, Section 3.3, Gasoline and Diesel Industrial Engines. The 744 hp generator engines will operate a maximum of 8,760 hours per year.
New Diesel Fuel Storage Tanks Emission estimates from the 630-gallon fuel storage tanks were estimated using an engine fuel consumption rate of 36.50 gallons per hour. Eight (8) engines each operating 8,760 hours annually results in a maximum annual diesel fuel throughput of 2,557,920 gallons. Emission estimates are
also based EPA guidance as published in AP-42, Section 5.2 Transportation and Marketing of Petroleum Liquids and the tank emissions calculation software TankESP. Emission estimates from the one 15,809-gallon diesel fuel storage tank were calculated in the same manner as the 630-gallon fuel tanks and also assumed a maximum annual diesel fuel throughput of
2,557,920 gallons. [Last updated July 5, 2024] 3. Comment regarding Federal Subpart Applicability: NSPS Subpart Kb 40 CFR 60 (NSPS) Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984) applies to storage vessels with a capacity greater than or equal to 75 m3 (19,812.9 gallons) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. The diesel fuel storage tanks on site have capacities of either 630 gallons or 15,809 gallons. Therefore, NSPS Subpart Kb does not apply to this facility. NSPS Subpart IIII 40 CFR 60 (NSPS) Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines) applies to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE is manufactured after April 1, 2006. The existing 324 hp engine was constructed in 2022 and the eight (8) proposed 744 hp engines were manufactured in 2023. Therefore, NSPS Subpart IIII applies. MACT Subpart ZZZZ 40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) is applicable to owners/operators of
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stationary RICE at a major or area sources of HAP emissions. MACT Subpart ZZZZ applies to the Wasatch RNG Processing Facility as the emergency engine generator is classified as a CI ICE. The
emergency and non-emergency diesel generator engines on site will meet MACT Subpart ZZZZ by meeting 40 CFR Part 60, Subpart IIII as the Wasatch RNG Processing Facility is an area source of HAP emissions. [Last updated July 5, 2024] 4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 61 (NESHAP) regulations. This facility is subject to 40 CFR 60 (NSPS) Subparts A, and IIII and 40
CFR 63 (MACT) Subparts A and ZZZZ. NSPS Subpart IIII and MACT Subpart ZZZZ each specifically exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. Therefore, this facility is not a Title V source. [Last updated July 1, 2024]
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ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
Docusign Envelope ID: A6BF09D9-9D69-494C-AE19-8C6544529B7B

DAQE-MN161340002-24

M E M O R A N D U M

TO: Christine Bodell, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler

DATE: September 19, 2024

SUBJECT: Modeling Analysis Review for the Notice of Intent for Lightening Renewables, LLC –
Wasatch RNG Processing Facility, Tooele County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Lightening Renewables, LLC (Applicant) is seeking an approval order for their Wasatch RNG
Processing Facility located in Tooele County, Utah. The Applicant is requesting to add eight
diesel-fired generator engines, each powering a 500-kW generator.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.

II. APPLICABLE RULE(S)
Utah Air Quality Rules:
R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

III. MODELING METHODOLOGY

A. Applicability
Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a modified approval order. The emission rates for NOx triggered the requirement to model under
R307-410. Modeling was performed by the Applicant.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

JK
DAQE- MN161340002-24
Page 2
B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4250 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12
b. Approximate Location:
UTM (NAD83): 353,218 meters East
4,523,252 meters North
2. Urban or Rural Area Designation
After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is “rural” for air modeling purposes.
3. Ambient Air
It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash
The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology

Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Salt Lake Airport, UT NWS: 2017-2021
Upper Air – Salt Lake Airport, UT NWS: 2017-2021

6. Background
The background concentrations were based on concentrations measured in Tooele, Utah.
7. Receptor and Terrain Elevations

The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis.
DAQE- MN161340002-24
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.

9. Air Pollutant Emission Rates

Lightening Renewables, LLC
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
GEN1E 353307 4522825 0.5100 2.234 8760
GEN1W 353295 4522822 0.5100 2.234 8760
GEN2E 353308 4522819 0.5100 2.234 8760
GEN2W 353297 4522816 0.5100 2.234 8760
GEN4E 353313 4522808 0.5100 2.234 8760
GEN4W 353301 4522805 0.5100 2.234 8760
GEN3E 353311 4522813 0.5100 2.234 8760
GEN3W 353299 4522810 0.5100 2.234 8760
TRO 353286 4522709 0.7100 3.110 8760
FLARE 353277 4522801 3.8100 16.688 8760
GEN 353310 4522722 1.9800 8.672 8760
Total 10.5801 46.3406
USMAG
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
SPRAYD1 353961 4530825 78.3364 343.113 8760
SPRAYD2 353962 4530821 78.3364 343.113 8760
SPRAYD3 353966 4530821 71.1556 311.661 8760
BLR1 353738 4530803 8.2350 36.069 8760
HCL_ACID 354174 4531061 3.7270 16.324 8760
RILEY 354082 4530897 5.4372 23.815 8760
MELTR 353967 4530825 2.7252 11.936 8760
PNORTH 371010 4530832 26.0401 114.056 8760
PEW 367185 4525281 6.9800 30.573 8760
P11 354934 4529147 39.0602 171.084 8760
P10 356290 4518177 26.0401 114.056 8760
DAQE- MN161340002-24
Page 4
BLR2 353737 4530797 6.1760 27.051 8760
LTHEATER 353602 4530808 1.5685 6.870 8760
EVAPOR 353602 4530749 3.1279 13.700 8760
P0 357082 4531193 20.0001 87.600 8760
PGROUP1 360310 4518654 26.9801 118.173 8760
PGROUP2 362843 4514979 20.0001 87.600 8760
SPS 365957 4515851 126.4807 553.985 8760
Total 550.4067 2410.7814 Wasatch Regional Landfill
Source
UTM Coordinates Modeled Emission Rates
Easting Northing NOx
(m) (m) (lb/hr) (tons/yr) hrs/year
FLARE 353277 4522801 3.8100 16.688 8760
Total 3.8100 16.6879
10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (ft)
GEN1E POINT 4247.3 4.1 13.4 720 63.78 0.15
GEN1W POINT 4248.0 4.1 13.4 720 63.78 0.15
GEN2E POINT 4247.2 4.1 13.4 720 63.78 0.15
GEN2W POINT 4247.8 4.1 13.4 720 63.78 0.15
GEN4E POINT 4246.9 4.1 13.4 720 63.78 0.15
GEN4W POINT 4247.6 4.1 13.4 720 63.78 0.15
GEN3E POINT 4247.1 4.1 13.4 720 63.78 0.15
GEN3W POINT 4247.7 4.1 13.4 720 63.78 0.15
TRO POINT 4249.5 18.3 60.0 700 22.95 0.97
FLARE POINT 4249.0 12.2 40.0 922 17.93 0.35
GEN POINT 4248.2 2.3 7.5 783 83.13 0.10
FLARE1 POINT 4249.2 10.7 35.0 1273 15.00 1.63
SPRAYD1 POINT 4226.2 76.2 249.9 335 12.01 2.74
SPRAYD2 POINT 4226.5 76.2 249.9 336 11.79 2.74
SPRAYD3 POINT 4226.0 76.2 249.9 334 12.61 2.74
BLR1 POINT 4226.2 12.2 40.0 472 15.09 0.91
HCL_ACID POINT 4223.3 24.4 80.0 491 6.47 0.61
DAQE- MN161340002-24
Page 5
RILEY POINT 4223.3 15.2 50.0 616 3.48 1.28
MELTR POINT 4225.6 76.2 249.9 319 10.84 0.91
PNORTH POINT 4206.6 4.3 14.0 744 102.59 0.13
PEW POINT 4203.5 4.3 14.0 755 60.52 0.13
P11 POINT 4218.5 4.3 14.0 744 102.59 0.13
P10 POINT 4225.3 4.3 14.0 744 102.59 0.13
BLR2 POINT 4226.3 12.2 40.0 472 11.56 0.91
LTHEATER POINT 4226.1 18.3 60.0 380 5.80 2.74
EVAPOR POINT 4224.0 18.3 60.0 380 6.52 3.66
P0 POINT 4198.3 4.3 14.0 744 60.52 0.13
PGROUP1 POINT 4213.6 4.3 14.0 744 60.52 0.13
PGROUP2 POINT 4209.6 4.3 14.0 744 60.52 0.13
SPS POINT 4208.2 4.3 14.0 744 60.52 0.13

IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the
NAAQS. The predicted total concentrations are less than the NAAQS.
Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
NO2
1-
Hour 129.6 7.5 18.4 0.0 148.0 188 78.7%
JK:jg

Equipment Details
Rating 744 hp = (555.3 kw)
Operational Hours 8,760 hours/year
Sulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Total PER
ENGINE
(tons/year)
Total for ALL
ENGINEs
(tons/year)Reference
NOX 0.311 0.510 2.23 17.87
CO 0.006 0.010 0.04 0.35
PM10 0.022 0.036 0.16 1.26 *source used 0.04 instead - less accuratePM2.5 0.022 0.036 0.16 1.26
VOC 0.026 0.043 0.19 1.49 (roundingSO21.21E-05 0.01 0.04 0.32 AP-42 Table 3.4-1HAP0.01 0.04 0.29 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)ReferenceCO2 (mass basis)1 1.16 863 3,780 30,241
Methane (mass basis)25 6.35E-05 0 0 2CO2e3,785 30,282
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 7.76E-04 4.04E-03 1.77E-02 1.42E-01
Toluene 2.81E-04 1.46E-03 6.41E-03 5.13E-02
Xylenes 1.93E-04 1.01E-03 4.40E-03 3.52E-02
Formaldehyde 7.89E-05 4.11E-04 1.80E-03 1.44E-02
Acetaldehyde 2.52E-05 1.31E-04 5.75E-04 4.60E-03
Acrolein 7.88E-06 4.10E-05 1.80E-04 1.44E-03
Naphthalene 1.30E-04 6.77E-04 2.97E-03 2.37E-02
Acenaphthylene 9.23E-06 4.81E-05 2.11E-04 1.68E-03
Acenaphthene 4.68E-06 2.44E-05 1.07E-04 8.54E-04
Fluorene 1.28E-05 6.67E-05 2.92E-04 2.34E-03
Phenanthrene 4.08E-05 2.12E-04 9.31E-04 7.45E-03Anthracene1.23E-06 6.41E-06 2.81E-05 2.24E-04
Fluoranthene 4.03E-06 2.10E-05 9.19E-05 7.35E-04
Pyrene 3.71E-06 1.93E-05 8.46E-05 6.77E-04
Benz(a)anthracene 6.22E-07 3.24E-06 1.42E-05 1.14E-04
Chrysene 1.53E-06 7.97E-06 3.49E-05 2.79E-04Benzo(b)fluoranthene 1.11E-06 5.78E-06 2.53E-05 2.03E-04
Benzo(k)fluoranthene 2.18E-07 1.14E-06 4.97E-06 3.98E-05
Benzo(a)pyrene 2.57E-07 1.34E-06 5.86E-06 4.69E-05
Indeno(1,2,3-cd)pyrene 4.14E-07 2.16E-06 9.44E-06 7.56E-05
Dibenz(a,h)anthracene 3.46E-07 1.80E-06 7.89E-06 6.31E-05Benzo(g,h,l)perylene 5.56E-07 2.90E-06 1.27E-05 1.01E-04
Previous NOI Calcs
lb/MMscf lb/hr Uncontrolled tpy Controlled tpy
All HAPS 17.755 2.088 9.145 0.252
Benzene 0.294 0.035 0.151 0.004 *page 47 of 85 of previos NOI - Appendix BToluene5.68 0.668 2.926 0.081
Xylene 3.612 0.425 1.861 0.051
Modification
All HAPs 0.32Benzene0.14
Toluene 0.05Xylene0.04
Total HAPs after current Project
All HAPs 0.570
Benzene 0.146
Toluene 0.132Xylene0.087
Generic Haps 0.206
AP-42 Table 3.3-1
& Table 3.4-1
Emission Factor
(lb/MMBtu)
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42
does not list 1,3-
Butadiene for engines
greater than 600 hp.)
Diesel-Fired Engines
Emergency Engines should equal 100
hours of operation per year
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Page 1 of Version 1.1 February 21, 2019
Eight (8) Belly Tanks Max throughput: 2,557,920
VOC 0.05 tpyHAPs0.03 tpy
One (1) 15k gallon tank Max throughput: 2,557,920
VOC 0.00114 tpy
HAPs 0.00076 tpy
Criteria Pollutant Current AO (tpy)Engines(tpy)Belly Tank (tpy)15k gal New PTENOX20.36 17.87 38.23
CO 30.22 0.35 30.57PM108.41 1.26 9.67
PM2.5 8.41 1.26 9.67
VOC 8.67 1.49 0.05 0.00 10.21SO27.11 0.32 7.43
HAP 0.25 0.29 0.03 0.00 0.55
CO2e 161304 30,282 191,586
Previous NOI Calcs
lb/MMscf lb/hr Uncontrolled tpy Controlled tpy
All HAPS 17.755 2.088 9.145 0.252
Benzene 0.294 0.035 0.151 0.004 *page 47 of 85 of previos N
Toluene 5.68 0.668 2.926 0.081
Xylene 3.612 0.425 1.861 0.051
ModificationAll HAPs 0.30
Benzene 0.14
Toluene 0.05
Xylene 0.04
Total HAPs after current ProjectAll HAPs 0.552Benzene0.146Toluene0.132
Xylene 0.087
Generic Haps 0.188
Total 17.87
0.351.26
1.26
1.54 *all within tolerance0.32
0.30
30282.27
NOI - Appendix B
FOR PERMIT HAPS PTE TABLE
Change (lb/yr)Total (lb/yr)Benzene 283 292
Generic HAPs 144 376
Toluene 103 264
Xylenes 70 173
tpy Total (tpy)Benzene 0.142 0.146Generic HAPs 0.072 0.188
Toluene 0.051 0.132
Xylenes 0.035 0.087
0.300 0.552
Appendix B - Emissions Calculations
Table B-1. Lightning Renewables Wasatch RNG Potential to Emit
NOX CO PM10 PM2.5 VOC SO2 CO2e Total HAPs
XQ1140 Gensets 17.87 0.35 1.40 1.40 1.49 0.32 28,877 0.26Belly Tanks ----0.05 --0.03
15K Diesel Tank ----1.14E-03 --7.61E-04
Project Total 17.87 0.35 1.40 1.40 1.54 0.32 28,877 0.30
Currently Permitted PTE1 20.36 30.22 8.41 8.41 8.67 7.11 161,304 0.25
Proposed PTE 38.23 30.57 9.81 9.81 10.21 7.43 190,181 0.55
Major Source Thresholds2 250 250 250 250 250 250 75,000 10/25
Threshold Exceeded? No No No No No No No No
Modeling Limits3 40 100 15 ----40 --See HAPs
Summary
Threshold Exceeded?No No No No No No No No
1. AO DAQE-AN161340001-23.
2. Criteria pollutant major source thresholds defined by 40 CFR 51.165(a)(1)(iv)(A) and 40 CFR 52.21(b)(1)(i)(b).
3. Modeling limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission Rates for New Sources or Emissions Increase.
Emissions Potential Annual Emissions Estimate (tpy)
Archaea Energy, Inc | Wasatch RNG 1 of 7 Trinity Consultants
Appendix B - Emissions Calculations
Table B-2. Potential HAP Emissions
Pollutant Existing HAPS
(lb/hr)
Project HAPS
(lb/hr)
Proposed
sitewide total
(lb/hr)
ETV
(lb/hr)1
Modeling
Required?
Benzene 3.00E-03 6.86E-02 7.2E-02 0.32 No
Toluene 2.30E-02 4.28E-01 4.5E-01 14.92 No
Xylenes 5.80E-04 1.02E+00 1.0E+00 85.97 No
Formaldehyde 5.70E-04 3.18E-03 3.7E-03 0.06 No
Acetaldehyde 0.00E+00 1.02E-03 1.0E-03 6.94 No
Acrolein 0.00E+00 3.18E-04 3.2E-04 0.04 No
Naphthalene 4.60E-06 1.19E-02 1.2E-02 10.38 No
Ethylbenzene 4.60E-03 5.21E-02 5.7E-02 -No
Hexane 1.50E-02 7.69E-03 2.3E-02 34.89 No
Chloromethane 4.70E-05 0 4.70E-05 20.44 No
Vinyl Chloride 8.30E-05 0 8.30E-05 0.17 No
Methanol 1.00E-02 0 1.00E-02 55.13 No
1,3-Butadiene 7.40E-05 0 7.40E-05 0.29 No
Bromomethane 1.60E-05 0 1.60E-05 0.77 No
Chloroethane 6.50E-05 0 6.50E-05 52.25 No
Vinyl Bromide 1.50E-05 0 1.50E-05 0.43 No
Acrylonitrile 7.60E-06 0 7.60E-06 0.86 No
1,1-Dichloroethene 5.20E-05 0 5.20E-05 3.93 No
Methylene Chloride 4.40E-04 0 4.40E-04 34.39 No
Allyl Chloride 2.20E-05 0 2.20E-05 0.62 No
Carbon Disulfide 4.40E-05 0 4.40E-05 0.62 No
trans-1,2-Dichloroethene 1.20E-04 0 1.20E-04 -No
1,1-Dichloroethane 5.40E-05 0 5.40E-05 -No
Methyl Tert Butyl Ether 1.30E-05 0 1.30E-05 35.70 No
Vinyl Acetate 2.50E-05 0 2.50E-05 6.97 No
cis-1,2-Dichloroethene 7.30E-04 0 7.30E-04 -No
Chloroform 1.70E-05 0 1.70E-05 9.67 No
1,2-Dichloroethane 8.30E-04 0 8.30E-04 8.01 No
1,1,1-Trichloroethane 1.90E-05 0 1.90E-05 378.16 No
Carbon Tetrachloride 2.20E-05 0 2.20E-05 2.08 No
Cyclohexane 5.00E-04 0 5.00E-04 -No
1,2-Dichloropropane 1.10E-04 0 1.10E-04 9.15 No
Bromodichloromethane 2.30E-05 0 2.30E-05 -No
1,4-Dioxane 2.50E-05 0 2.50E-05 14.27 No
Trichloroethene 8.00E-04 0 8.00E-04 3.55 No
2,2,4-Trimethylpentane 4.70E-04 0 4.70E-04 -No
Heptane 1.60E-03 0 1.60E-03 -No
cis-1,3-Dichloropropene 1.60E-05 0 1.60E-05 0.90 No
trans-1,3-Dichloropropene 3.00E-04 0 3.00E-04 0.90 No
1,1,2-Trichloroethane 4.30E-05 0 4.30E-05 10.80 No
1,2-Dibromoethane 2.70E-05 0 2.70E-05 -No
Tetrachloroethene 1.40E-03 0 1.40E-03 33.57 No
Chlorobenzene 9.30E-05 0 9.30E-05 9.12 No
m&p-Xylene 1.00E-02 0 1.00E-02 0.02 No
Bromoform 3.60E-05 0 3.60E-05 1.02 No
Styrene 8.60E-04 0 8.60E-04 16.87 No
1,1,1,2-Tetrachloroethane 2.40E-05 0 2.40E-05 -No
o-Xylene 3.60E-03 0 3.60E-03 85.97 No
1,3,5-Trimethylbenzene 5.20E-04 0 5.20E-04 -No
1,2,4Trimethylbenzene 8.80E-04 0 8.80E-04 -No
Benzyl Chloride 1.80E-05 0 1.80E-05 1.03 No
1,3-Dichlorobenzene 2.10E-05 0 2.10E-05 -No
1,4-Dichlorobenzene 1.60E-04 0 1.60E-04 11.91 No
1,2-Dichlorobenzene 2.10E-05 0 2.10E-05 -No
1,2,4-Trichlorobenzene 2.60E-05 0 2.60E-05 5.71 No
Hexachlorobutadiene 3.70E-05 0 3.70E-05 0.04 No
Hydrogen Chloride 4.70E-03 0 4.70E-03 0.46 No
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Appendix B - Emissions Calculations
Pollutant Existing HAPS
(lb/hr)
Project HAPS
(lb/hr)
Proposed
sitewide total
(lb/hr)
ETV
(lb/hr)1
Modeling
Required?
Hydrogen Fluoride 2.50E-04 0 2.50E-04 0.25 No
2-Methylnaphthalene 1.80E-07 0 1.80E-07 -No
3-Methylcholanthrene 1.40E-08 0 1.40E-08 -No
7,12-Dimethylbenz(a)anthracene 1.20E-07 0 1.20E-07 -No
Acenaphthene 1.40E-08 0 1.40E-08 -No
Acenaphthylene 1.40E-08 0 1.40E-08 -No
Anthracene 1.80E-08 0 1.80E-08 -No
Arsenic 1.80E-06 0 1.80E-06 0.00 No
Benz(a)anthracene 1.40E-08 0 1.40E-08 -No
Benzo(a)pyrene 9.10E-09 0 9.10E-09 -No
Benzo(b)fluoranthene 1.40E-08 0 1.40E-08 -No
Benzo(g,h,i)perylene 9.10E-09 0 9.10E-09 -No
Benzo(k)fluoranthene 1.40E-08 0 1.40E-08 -No
Beryllium 9.10E-08 0 9.10E-08 0.00 No
Cadmium 1.10E-05 0 1.10E-05 -No
Chromium 1.10E-05 0 1.10E-05 0.00 No
Chrysene 1.40E-08 0 1.40E-08 -No
Cobalt 6.40E-07 0 6.40E-07 0.00 No
Dibenzo(a,h)anthracene 9.10E-09 0 9.10E-09 -No
Dichlorobenzene 9.90E-06 0 9.90E-06 11.91 No
Fluoranthene 2.30E-08 0 2.30E-08 -No
Fluorene 2.10E-08 0 2.10E-08 -No
Indeno(1,2,3-cd)pyrene 1.40E-08 0 1.40E-08 -No
Lead 3.80E-06 0 3.80E-06 -No
Manganese 2.90E-06 0 2.90E-06 0.04 No
Nickel 1.60E-05 0 1.60E-05 0.01 No
Phenanthrene 1.30E-07 0 1.30E-07 -No
Pyrene 3.80E-08 0 3.80E-08 -No
Selenium 1.80E-07 0 1.80E-07 0.04 No
Mercury 2.60E-06 0 2.60E-06 0.00 No
1. The Emission Threshold Value (ETV) assumes < 50 m distance to the fence line and vertically unrestricted releases.
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Appendix B - Emissions Calculations
Table B-3. XQ1140 Diesel Genset Parameters
Parameter Value
Generator Make Milton CAT
Engine Model Number C18
Annual Hours of Operation (hr/yr)8,760
Total Number of Generators 8
Max Power Output (ekW)1 500
Max Power Output (hp)1 744
Heating Value of Diesel
(MMBtu/gal)2 0.138
Max Fuel Consumption (gal/hr)1 36.50
Max Heat Input (MMBtu/hr)3 5.04
Fuel ULSD
Sulfur Content4 0.0015%
1. Manufacturer specification sheet.
2. Per 40 CFR 98, Table C–1 to Subpart C for Distillate Fuel Oil No. 2.
3. Heat input based on diesel fuel consumption rate and heating value of diesel. Heat Input (MMBtu/hr) = Fuel Consumption Rate (gal/hr) * Heating Value of Diesel (Btu/gal)/10^6.
4. Per 40 CFR 80 Subpart I, maximum sulfur content of ULSD is 15 ppm (i.e. 0.0015%).
Table B-4. Criteria Pollutant Emission Factors
Pollutant 1,2,3,4,5
Percent Load 100 75 50 25
Power hp 744 558 372 186
NOX (lb/hr)0.51 0.50 0.15 0.05
VOC (lb/hr)0.04 0.02 0.02 0.02
PM/PM10/PM2.5 (lb/hr)0.04 0.02 0.01 0.01
CO (lb/hr)0.01 0.01 0.01 0.01SO2(lb/hr)9.03E-03 6.77E-03 4.51E-03 2.26E-03
CO2 (lb/hr)821.30 ---------
CH44 (lb/hr)0.03 ---------
N2O4 (lb/hr)0.01 ---------
CO2e5 (lb/hr)824.12 ---------
1. NOX, VOC, and PM emissions from manufacturer specification sheet.
2. CO emissions conservatively assumed to be 0.01 lb/hr.
4. Assumes hydrocarbons (HC) are equivalent to VOCs.
5. SO2 emissions using equation from AP-42 Table 3.4-1 footnote d: 8.09E-03*S1.
1.21E-05 (lb/hp-hr)
4. Emission factors from 40 CFR 98 Tables C-1 and C-2 (kg/MMBtu):
73.96 CO2
3.00E-03 CH46.00E-04 N2O
5. CO2e is the sum of GHG constituents multiplied by their respective global warming potential per 40 CFR 98 Table A-1.
1 CO2 GWP
25 CH4 GWP
298 N2O GWP
Emission Factors Units
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Appendix B - Emissions Calculations
Table B-5. Total Potential Emissions
Percent Load
Pollutant Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
NOx 2.23 17.87 2.19 17.52 0.66 5.26 0.22 1.75
CO 0.04 0.35 0.04 0.35 0.04 0.35 0.04 0.35
VOC 0.18 1.49 0.09 7.86E-01 0.09 0.79 0.09 0.79
SO2 0.04 0.32 0.03 0.24 0.02 0.16 9.89E-03 0.08
PM/PM10/PM2.5 0.18 1.40 0.09 7.01E-01 0.04 0.35 0.04 0.35
CO2e 3,610 28,877 ------------------
1. VOCs that are HAPs, listed under the Clean Air Act, and that are not NMHC are included in this emission factor.
Table B-6. HAP Potential to Emit
Pollutant1 Emission Factor2 Units All Engines Hourly
Emissions (lb/hr)3
Annual Emissions
per Engine (tpy)4 All Engines Total
HAP (tpy)
Also a VOC, not a
HC?
Benzene 7.76E-04 (lb/MMBtu)3.13E-02 1.71E-02 1.37E-01 NoToluene2.81E-04 (lb/MMBtu)1.13E-02 6.20E-03 4.96E-02 NoXylenes1.93E-04 (lb/MMBtu)7.78E-03 4.26E-03 3.41E-02 NoFormaldehyde7.89E-05 (lb/MMBtu)3.18E-03 1.74E-03 1.39E-02 YesAcetaldehyde2.52E-05 (lb/MMBtu)1.02E-03 5.56E-04 4.45E-03 YesAcrolein7.88E-06 (lb/MMBtu)3.18E-04 1.74E-04 1.39E-03 Yes
Naphthalene 1.30E-04 (lb/MMBtu)5.24E-03 2.87E-03 2.29E-02 Yes
0.14
0.26
1. Additional polycyclic aromatic hydrocarbon may be emitted but for regulatory purposes, this list is only inclusive of HAPs regulated under the Clean Air Act.
2. Criteria and HAP pollutant emission factors per AP-42, Section 3.4 Large Stationary Diesel Engines (> 600 hp), October 1996.
3. Hourly HAP Emissions (lb/hr) = Heat Input (MMBtu/hr) * EF (lb/MMBtu) * Number of Generators.
4. Annual HAP Emissions (tpy) = Hourly HAP Emissions (lb/hr) * Annual Hours of Operation (hr/yr) / 2000 (lb/ton).
Max HAP
Total HAPs
25
Potential Emissions
100 75 50
Archaea Energy, Inc | Wasatch RNG 5 of 7 Trinity Consultants
Appendix B - Emissions Calculations
Table B-7. Tank Throughputs
Engine Tanks Throughput
(gal/yr)1,2
C18 Belly Tank 319,740
Total 2,557,920
36.50 (gal/hr)
2. Annual operating time (hr/yr)8760
3. Number of Tanks:8
Table B-8. Tank VOC Potential to Emit
Loading loss emission factor (lb/103 gal)2 0.04
Loading loss all belly tanks (lb/yr)3 99.68
Loading loss all belly tanks (tpy)0.05
Average hourly total loading loss all belly
tanks (lb/hr)0.01
Where,
LL, loading loss (lb/[103 gal of liquid loaded]) =0.04
S, saturation factora =1.45
P, true vapor pressure of diesel (psia)b =6.00E-03
M, molecular weight of diesel (lb/lb-mol)b = 188.00
T, Temperature (R)b =522.97
eff, overall reduction efficiency =0.00
b) AP 42 Table 7.1-7 (°F):63.3
3. Conversion factors:
1000 gal/Mgal
4. Annual operating time (hr/yr):8760
Table B-9. Tank Annual HAP Potential to Emit
Pollutant Vapor HAP
Composition (wt %)1
Average Total Hourly
Emissions All Belly
Tanks (lb/hr)
Total Annual
Emissions All Belly
Tanks (tpy)
Benzene 1.64%1.87E-04 8.17E-04
Ethylbenzene 2.3%2.58E-04 1.13E-03
Hexane 0.3%3.87E-05 1.69E-04
Naphthalene 0.3%3.30E-05 1.45E-04
Toluene 18.2%2.07E-03 9.07E-03
Xylenes 44.0%5.00E-03 2.19E-02
0.02
0.03
1. Determined from TankESP HAPs speciation.
Total HAPs
1. XQ1140 generator fuel consumption specifications:
VOC Emissions1
1. Includes (1) vapors formed in the empty tank by evaporation of residual product
from previous loads, (2) vapors transferred to the tank in vapor balance systems as
product is being unloaded, and (3) vapors generated in the tank as the new product is
being loaded.
2. AP 42 Section 5.2 Transportation and Marketing of Petroleum Liquids
a) AP 42 Table 5.2-1, for splash loading and dedicated normal service.
Max HAPs
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Appendix B - Emissions Calculations
Table B-10. Tank Parameters1
Parameters Value
Tank Type Horizontal Tank
Length (ft)40.00
Width (ft)8.00
Height (ft)9.50
Volume (gal)15,809
Throughput (gal/yr)2,557,920
1. Manufacturer specifications.
Table B-11. Tank Emissions
Pollutant Emissions1 Units
Benzene 0.04 (lb/hr)
Ethylbenzene 0.05 (lb/hr)
Hexane 7.65E-03 (lb/hr)
Naphthalene 6.63E-03 (lb/hr)
Toluene 0.41 (lb/hr)
Xylenes 1.01 (lb/hr)
Total VOCs 1.14E-03 (tpy)
Total HAPs 7.61E-04 (tpy)
1. Emissions calculated using TankESP.
Archaea Energy, Inc | Wasatch RNG 7 of 7 Trinity Consultants
UTAH DIVISION OF AIR QUALITY - NOTICE
OF INTENT
Lightning Renewables, LLC
Wasatch Renewable Natural Gas Processing Facility
Archaea Energy, Inc.
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Blvd.
Suite 200
Salt Lake City, Utah 84121
[phone]
Submitted on Behalf of:
Archaea Energy, Inc.
201 Helios Way, Floor 6
Houston, TX 77079
May 2024
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Archaea Energy Inc. | Wasatch RNG NOI Trinity Consultants
TABLE OF CONTENTS
1.EXECUTIVE SUMMARY 1-1
2.GENERAL INFORMATION 2-22.1 Source Identification Summary ................................................................................. 2-2 2.2 Source Size Determination ........................................................................................ 2-2 2.3 Notice of Intent Forms .............................................................................................. 2-2
2.4 Notice of Intent Fees ................................................................................................ 2-3
3.DESCRIPTION OF PROJECT AND PROCESS 3-1
3.1 Description of Project ............................................................................................... 3-1
3.2 Description of Process ............................................................................................... 3-1
4.EMISSIONS RELATED INFORMATION 4-1
4.1 Diesel-fired Engines .................................................................................................. 4-1
4.2 Diesel Belly Tanks ..................................................................................................... 4-2
4.2.1 VOC Emissions ........................................................................................................ 4-2
4.3 Diesel Tank ............................................................................................................... 4-3
4.3.1 Standing Storage Loss ............................................................................................. 4-3
Tank Vapor Space Volume, VV ............................................................................................ 4-3
Vapor Space Expansion Factor, KE ..................................................................................... 4-4
Vapor Space Outage, HVO ................................................................................................... 4-5
Vented Vapor Saturation Factor, KS ................................................................................... 4-5
Stock Vapor Density, WV .................................................................................................... 4-5
4.3.2 Working Loss .......................................................................................................... 4-5
4.3.3 Hazardous Air Pollutant Speciation ............................................................................ 4-6
5.BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS 5-15.1 Diesel-Fired Prime Power Engines ............................................................................ 5-1
5.1.1 Step 1 - Identify All Control Technologies .................................................................. 5-1
5.1.2 Step 2 – Eliminate Technically Infeasible Control Options ............................................ 5-1 Good Combustion Practices ............................................................................................... 5-1 Use of an Appropriate Tier Certified Engine ....................................................................... 5-1 Diesel Particulate Filters .................................................................................................... 5-2 Ultra-Low Sulfur Diesel ...................................................................................................... 5-2 Diesel Oxidation Catalyst ................................................................................................... 5-2 Selective Catalytic Reduction ............................................................................................ 5-3
5.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 5-3
5.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 5-3
5.1.5 Step 5 - Select BACT ............................................................................................... 5-3 5.2 Diesel Storage Tanks – BACT Analysis ....................................................................... 5-3
5.2.1 Diesel Tanks VOCs & Volatile HAPs - Steps 1-5 – Identify All Control Technologies ........ 5-3
6.EMISSIONS IMPACT ANALYSIS 6-1
7.NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1
8.APPLICABLE RULES 8-18.1 Utah Regulations ...................................................................................................... 8-1
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Archaea Energy Inc. | Wasatch RNG NOI Trinity Consultants i
8.1.1 UAC R307-101 General Requirements ....................................................................... 8-4
8.1.2 UAC R307-107 General Requirements: Breakdowns .................................................... 8-5
8.1.3 UAC R307-203 Emission Standards: Sulfur Content of Fuels ........................................ 8-5
8.1.4 UAC R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements .... 8-5
8.1.5 UAC R307-401-4 General Requirements .................................................................... 8-5
8.1.6 UAC R307-401-5 Notice of Intent .............................................................................. 8-5
8.1.7 UAC R307-401-8 Approval Order .............................................................................. 8-5
8.1.8 UAC R307-403 New and Modified Sources in Nonattainment Areas and Maintenance Areas
8-6
8.1.9 UAC R307-405 Permits: Major Sources in Attainment or Unclassified Areas ................... 8-6
8.2 Federal Rules: National Emission Standards for Hazardous Air Pollutants ................ 8-6
8.2.1 Subpart A – General Provisions ................................................................................. 8-6
8.2.2 Subpart ZZZZ – Stationary Reciprocating Internal Combustion Engines ......................... 8-7
8.3 Federal Rules: New Source Performance Standards .................................................. 8-7
8.3.1 NSPS Subpart IIII – Stationary Compression Ignition Engines ...................................... 8-7
8.3.2 NSPS Subpart Kb – Storage Tanks ............................................................................ 8-8
8.3.3 NSPS Subpart Kc – Storage Tanks ............................................................................ 8-9
APPENDIX A. NOI FORMS
APPENDIX B. EMISSION CALCULATIONS
A-1
APPENDIX C. DESIGN SPECIFICATIONS C-1
B-1
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6

Archaea Energy Inc. | Wasatch RNG NOI Trinity Consultants 1-1
1. EXECUTIVE SUMMARY
Lightning Renewables, LLC (Lightning Renewables), an indirect subsidiary of Archaea Energy, Inc, owns and
operates a Wasatch Renewable Natural Gas (Wasatch RNG) processing facility located 10 miles north of exit
77 on Interstate 80 in Tooele, Utah. The Wasatch RNG facility utilizes landfill gas (LFG) generated from the
Wasatch Regional Landfill as feedstock. The Wasatch Regional Landfill is owned and operated by Republic
Services. The Wasatch RNG facility operates independently of the landfill under current Approval Order (AO)
DAQE-AN161340001-23.

Lightning Renewables is submitting this Notice of Intent (NOI) air permit application to the Utah Division of
Air Quality (UDAQ) for the Wasatch RNG facility to obtain an updated approval order (AO). Lightning
Renewables, LLC is proposing to install the following emission sources:

► Four (4) trailers each equipped with two (2) 744 horsepower (HP) diesel-fired engines, each
powering a 500 kilowatt (kW) generator;
► Eight (8) 630 gallon diesel storage belly tanks; and
► One (1) 15,809 gallon diesel storage tank.

The addition of this equipment will represent a minor modification of the Wasatch RNG facility’s existing AO.

The project will result in an increase of the potential to emit (PTE) for particulate matter (PM) with an
aerodynamic diameter of 10 microns or less (PM10), PM with an aerodynamic diameter of 2.5 microns or less
(PM2.5), oxides of nitrogen (NOX), carbon monoxide (CO), sulfur dioxide (SO2), volatile organic compounds
(VOCs), hazardous air pollutants (HAPs), and greenhouse gases (GHGs). The change in PTE associated with
this NOI air permit application is: PM10 = 1.40 tons per year (tpy), PM2.5 = 1.40 tpy, NOX = 17.87 tpy, CO =
7.72E-04 tpy, SO2 = 0.32, VOCs = 1.54 tpy, HAPs = 0.30 tpy, and GHGs = 28,877 tpy.

The Wasatch RNG facility is located in Tooele County. The facility is located outside of the serious
nonattainment area for 24-hour PM2.5. It is also currently located outside the Northern Wasatch Front (NWF)
moderate 8-hour Ozone nonattainment area. UDAQ is proposing a change to the non-attainment area
boundary with the anticipation of the serious nonattainment designation in 2025 at which time the Wasatch
RNG facility will be located within the NWF ozone nonattainment area. At this time, the facility is currently in
attainment area for all criteria pollutants.
This NOI air permit application has been developed pursuant to Utah Administrative Code (UAC) R307-401-5
and Utah’s application guidance, and includes, but is not limited to:

► NOI Forms and Fees;
► Process Description;
► Site Plan;
► Potential Emission Calculations (PTE) Calculations;
► Best Available Control Technology (BACT) Analysis;
► Applicable Requirements; and
► Emission Impact Analysis.
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6

Archaea Energy Inc. | Wasatch RNG NOI Trinity Consultants 2-2
2. GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist.
2.1 Source Identification Summary
► Company Name: Lightning Renewables, LLC – Wasatch RNG Processing Facility
► Physical Address: 10 Miles North of Exit 77-I-80 on Rowley, Rd Skull Valley, UT
► County: Tooele
► UTM Coordinates: Easting: 353,218 m Northing: 4,523,252 m
► Primary SIC Code: 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas
Production)
► Area Designation: Attainment for all criteria pollutants.
► Source Size Determination: Minor Stationary Source
► Current AO: DAQE-AN161340001-23

All correspondence regarding this submission should be addressed to:
Nevin Edwards
Manager, Air Permitting
Lightning Renewables, LLC
Phone: [phone]
Email: [e-mail]
Corporate Office
201 Helios Way, Floor 6
Houston, TX 77079
2.2 Source Size Determination
As presented in Appendix B, Table B-1, site-wide emissions are below the major source threshold (MST) for
all criteria pollutants, GHGs, and HAPs. This application is a minor modification to a minor source.
2.3 Notice of Intent Forms
The following UDAQ forms have been included with the NOI air permit application:

► Form 1 – Notice of Intent Application Checklist;
► Form 2 – Source Identification Information;
► Form 3 – Process Information;
► Form 4 – Project Information;
► Form 5 – Emissions Information Criteria/GHGs/ HAPs; and
► Form 11 – Internal Combustion Engine
► Form 20 – Organic Liquid Storage Tank
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2.4 Notice of Intent Fees
Archaea will send a check to UDAQ’s mailing address to prepay the following UDAQ NOI air permit
application fees associated with this submittal:

► “Application Filing Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category = $500
► “Application Review Fee” for the “New Minor Source or Minor Modification at Minor or Major Source”
category = $2,300
► Total UDAQ fees = $2,800

Lightning Renewables understands that the total permit review fee is based on the total actual time spent
by UDAQ staff processing this NOI air permit application. Upon issuance of the AO, if the total review time is
more than 20 standard hours, UDAQ will invoice Lightning Renewables at $115 per hour for the additional
time above 20 standard hours.
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3. DESCRIPTION OF PROJECT AND PROCESS
3.1 Description of Project
Lightning Renewables is proposing to install eight (8) diesel-fired reciprocating internal combustion engines
(RICE) each with 500 kilowatt (kW) prime power generators. The proposed equipment configuration
includes two (2) engines and two (2) generators in a trailer with a total of four (4) trailers onsite. These
generators would be used for at least eighteen (18) months, to supply power to the facility until utility
power is available. As result, Archaea proposes to modify its existing AO DAQE-AN161340001-23 for the
Lightning Renewables facility in Skull Valley, Utah by adding eight (8) diesel-fired 744 HP RICE to supply
two (2) Megawatts (MW) of prime power. The proposed diesel-fired RICE are US Environmental Protection
Agency (EPA) Tier 4 final (Tier 4f) certified engines. The engines are equipped with the following integrated
controls:

► Selective Catalytic Reduction (SCR);
► Diesel Oxidation Catalyst (DOC); and
► Diesel Particulate Filter (DPF).

Additionally, Lightning Renewables is proposing to install eight (8) 630-gallon diesel belly tanks and one (1)
15,809-gallon diesel storage tank.
3.2 Description of Process
The permitted Wasatch RNG facility utilizes landfill gas (LFG) generated from the Wasatch Regional Landfill
as feedstock. Wasatch RNG is designed to accept approximately 3,200 dry standard cubic feet per minute
(dscfm) of LFG from the Wasatch Regional Landfill. The LFG received at Wasatch RNG undergoes
processing, consisting of dewatering/moisture removal, sulfur compound removal via media filtration,
particulate filtration, temperature swing adsorption, membrane separation, and pressure swing adsorption.
The refined RNG consists of greater than 95% methane and is then compressed and injected into a nearby
natural gas transmission pipeline. This process was covered under an existing AO previously issued and is
under construction. However, power cannot be provided by the utility to meet Archaea’s commitments to
operate the RNG processing plant.

The process and product throughputs currently permitted will remain the same as those listed in the AO
after the changes proposed in this NOI air permit application have been incorporated.
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4. EMISSIONS RELATED INFORMATION
This section details the methodology used to calculate controlled and uncontrolled emissions for criteria
pollutants, greenhouse gases, and HAPs associated with each new unit and its associated fugitives as
regulated by R307-401-5(2)(b). Detailed emission calculation tables are included in Appendix B.
4.1 Diesel-fired Engines
PTE calculations for each of the criteria pollutants are based on the annual hours of operation at the
maximum power output of each engine. Each of the 500 kw engines will not run at full power and/or are
sequenced, to supply two (2) MW of power to the Wasatch RNG facility. Therefore, the total PTE calculated
is a very conservative approach because all eight (8) 744 HP RICE will not be operating at full power at the
same time. Emission factors (EF) for diesel-fired operation were obtained using the engine supplier’s
emission factors.

The following calculations were carried out for each generator for NOX, CO, PM10, PM2.5, and VOCs.
Annual Emission Rate (tpy)=Emission Factor �lbshr�× Hours of Operation �hrsyr�× �1 ton2000 lbs�

The RICE used to supply power to the Wasatch RNG facility will be using ultra-low sulfur diesel (ULSD) fuel.
The emission factor for SO2 is based on a fuel sulfur content of 0.0015% for ultra-low sulfur diesel fuel, as
defined under 40 CFR 80, Subpart I, Section 80.510(c)(1). The SO2 emission factor from AP 42, Section 3.4
Table 3.4-1 is used in the emission calculations and accounts for the fuel sulfur content. SO2 hourly
emissions are calculated using the following equation.
SO2 Hourly Emission Rate �lbshr�=Emission Factor �lbshp-hr�× Power Output (hp)
SO2 Annual Emission Rate (tpy)=Hourly Emissions �lbshr�× Hours of Operation�hrsyr�
× Conversion �1 ton2000 lbs�

GHG pollutants expected to be emitted from the generators include carbon dioxide (CO2), methane (CH4),
and nitrous oxide (N2O). Standard emission factors for CO2, N2O and CH4 are provided in 40 CFR Part 98,
Subpart C, Table C-1 and Table C-2. The global warming potential for each relevant pollutant is obtained
from 40 CFR Part 98, Subpart A, Table A-1. Calculations for GHG pollutants are based on the emission factor
for each GHG pollutant, relevant global warming potential, annual hours of operation, and the maximum
heat input.
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Carbon Dioxide Equivalent (CO2e) Annual Emission Rate (tpy)=�Emission Factor CO2 �kgMMBtu�+Emission Factor CH4 �kgMMBtu�× GWP CH4+Emission Factor N2O �kgMMBtu�× GWP N2O�× �2.20462 lbkg�× Rated Capacity (hp)× Conversion Factor �0.0025425 MMBtuhp−hr �×Hours of Operation�hrsyr�× �tons2000 lb�

HAP emissions were determined using the maximum heat input and annual hours of operation. Emission
factors for HAPs are obtained from AP-42, Section 3.4, Tables 3.4-3 and 3.4-4.
HAP Annual Emission Rate (tpy)=Emission Factor �lbsMMBtu�× Heat Input �MMBtuhr�×Hours of Operation �hrsyr�× �tons2000 lb�
4.2 Diesel Belly Tanks
The proposed engines are each equipped with a diesel belly tank. There are two (2) engines per trailer and
accompanying two (2) diesel storage belly tanks, resulting in a total of eight (8) belly tanks. Emission from
the diesel tanks include VOCs and HAPs and are dependent on fuel throughput. Conservatively assuming
year-round use, a throughput of 2,557,920 gallons per year was used.
4.2.1 VOC Emissions
Emissions for each belly tank were calculated per AP-42, Section 5.2: Transportation and Marketing of
Petroleum Liquids. Specifically, equations contained in Section 5.2.2.1.1 (Loading Losses) are utilized.
LL �lb103gal�=12.46SPMT �1 −eff100�
LL = loading loss
S = saturation factor for “splash loading: dedicated normal service” (Table 5.2-1)
P = true vapor pressure of diesel (Table 7.1-2)
M = molecular weight of gasoline vapors (Table 7.1-2)
T = temperature of diesel
eff = overall reduction efficiency

The loading loss was then multiplied by the belly tank diesel throughput in the following equation:
VOC Annual Emission Rate (tpy)= LL �lb103gal�× Diesel Usage�galyr�× Conversion �103 gal1,000 gal�× Conversion �1 ton2,000 lbs�
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4.3 Diesel Tank
Annual VOC emissions from the fixed-roof storage tank were calculated using the methodology provided in
the Fifth Edition (2020) of AP-42 Chapter 7: Liquid Storage Tanks, last updated in March of 2020; all
equations, tables, and figures referenced here refer to AP-42, Section 7.1.

The potential VOC emission estimates account for the working and standing losses associated with changes
in temperature, pressure, and liquid level. A throughput of 2,557,920 gallons per year was used.

Per Equation 1-1, the total routine losses form the fixed roof tanks are equal to the sum of the standing loss
and working loss: 𝐿𝐿𝑇𝑇=𝐿𝐿𝑆𝑆+𝐿𝐿𝑊𝑊
Where: LT = total losses, lb/yr
LS = standing storage losses, lb/yr
LW = working losses, lb/yr
The standing storage loss and working loss components of the total loss equation are discussed in the
subsections below.
4.3.1 Standing Storage Loss
Annual fixed roof standing losses can be estimated using Equation 1-2:
𝐿𝐿𝑠𝑠=365 (𝑉𝑉𝑣𝑣)( 𝑊𝑊𝑉𝑉)(𝐾𝐾𝐸𝐸)(𝐾𝐾𝑆𝑆)
Where: LS = standing storage loss, lb/yr
VV = vapor space volume, ft3
Wv = stock vapor density, lb/ft3 KE = vapor space expansion factor, dimensionless
KS = vented vapor saturation factor, dimensionless
365 = constant, the number of daily events in a year, days/yr
Tank Vapor Space Volume, VV
The tank vapor space volume (VV) is calculated using Equation 1-3:
𝑉𝑉𝑉𝑉=�𝜋𝜋4 𝐷𝐷2�𝐻𝐻𝑉𝑉𝑉𝑉
Where:
VV = vapor space volume, ft3
D = internal tank diameter, ft
HVO = vapor space outage, ft

The standing loss equation can be simplified by combining Equation 1-2 with Equation 1-3 to derive
Equation 1-4:
𝐿𝐿𝑠𝑠=365𝐾𝐾𝐸𝐸�𝜋𝜋4 𝐷𝐷2�(𝐻𝐻𝑉𝑉𝑉𝑉)(𝐾𝐾𝑆𝑆)( 𝑊𝑊𝑉𝑉)
Where:
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LS = standing storage loss, lb/yr KE = vapor space expansion factor, dimensionless
D = internal tank diameter, ft
HVO = vapor space outage, ft
KS = vented vapor saturation factor, dimensionless
Wv = stock vapor density, lb/ft3
365 = constant, the number of daily events in a year, days/yr
Vapor Space Expansion Factor, KE
The calculation of the vapor space expansion factor, KE, depends upon the properties of the liquid in the
tank and the breather vent settings, and is represented by Equation 1-5:
𝐾𝐾𝐸𝐸=∆𝑇𝑇𝑉𝑉𝑇𝑇𝐿𝐿𝐿𝐿+ ∆𝑃𝑃𝑉𝑉− ∆𝑃𝑃𝐵𝐵𝑃𝑃𝐿𝐿− 𝑃𝑃𝑉𝑉𝐿𝐿
Where:
TV = average daily vapor temperature range, OR
∆PV = average daily vapor pressure range, psi
∆PB = breather vent pressure setting range, psi
PA = atmospheric pressure, psia
PVA = vapor pressure at average daily liquid surface temperature, psia
TLA = average daily liquid surface temperature, OR

For an uninsulated tank, the average daily vapor temperature range is calculated using Equation 1-6:
∆𝑇𝑇𝑉𝑉=�1 −0.82.2 �𝐻𝐻𝑠𝑠𝐷𝐷�+ 1.9
�∆𝑇𝑇𝐿𝐿+0.042 ∝𝑅𝑅𝐼𝐼+ 0.026�𝐻𝐻𝑆𝑆𝐷𝐷�∝𝑆𝑆𝐼𝐼2.2 �𝐻𝐻𝑆𝑆𝐷𝐷�+ 1.9

Where:
∆TV = average daily vapor temperature range, OR HS = tank shell height, ft
D = internal tank diameter, ft
∆TA = average daily ambient temperature range, OR
αR = tank roof surface solar absorptance, dimensionless
αS = tank shell surface solar absorptance, dimensionless
I = average daily total insolation factor, Btu/ft2 day

API assigns a default value of HS/D = 0.5 and an assumption of αR = αS, resulting in the simplified equation
for an uninsulated tank:
∆𝑇𝑇𝑉𝑉= 0.7∆𝑇𝑇𝐿𝐿+ 0.02𝛼𝛼 𝐼𝐼
Where:

α = average tank surface solar absorptance, dimensionless

The vapor pressure range (∆PV) is calculated from Equation 1-9:
∆𝑃𝑃𝑉𝑉=𝑃𝑃𝑉𝑉𝑉𝑉− 𝑃𝑃𝑉𝑉𝑉𝑉
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Where:
PVX and PVN are the vapor pressures at TLX and TLN; respectively.
Vapor Space Outage, HVO
For horizontal tanks, the vapor space outage (HVO) is estimated as:
𝐻𝐻𝑉𝑉𝑉𝑉=𝐻𝐻𝐸𝐸2
Where: HE = effective height of an equivalent upright cylinder, ft
𝐻𝐻𝐸𝐸 =𝜋𝜋4 𝐷𝐷

D = diameter of a vertical cross-section of the horizontal tank, ft
Vented Vapor Saturation Factor, KS
The vented vapor saturation factor (KS) is calculated using Equation 1-21:
𝐾𝐾𝑆𝑆=11 + 0.053𝑃𝑃𝑉𝑉𝐿𝐿𝐻𝐻𝑉𝑉𝑉𝑉
Where: KS = vented vapor saturation factor, dimensionless
PVA = vapor pressure at average daily liquid temperature, psia
HVO = vapor space outage, ft
Stock Vapor Density, WV
The density of the vapor (WV) is calculated using Equation 1-22:
𝑊𝑊𝑉𝑉=𝑀𝑀𝑉𝑉𝑃𝑃𝑉𝑉𝐿𝐿𝑅𝑅𝑇𝑇𝑉𝑉
Where:
WV = vapor density, lb/ft3
MV = vapor molecular weight, lb/l-mol
R = the ideal gas constant, 10.731 psia ft3/lb-mole OR PVA = vapor pressure at daily average liquid surface temperature, psia
TV = average vapor temperature, OR
4.3.2 Working Loss
Annual fixed roof tank working losses are estimated using Equation 1-35:
𝐿𝐿𝑤𝑤=𝑉𝑉𝑄𝑄𝐾𝐾𝑉𝑉𝐾𝐾𝑃𝑃𝑊𝑊𝑉𝑉𝐾𝐾𝐵𝐵
Where: Lw = working loss, lb/yr
VQ = net working loss throughput, ft3/yr
KN = working loss turnover (saturation) factor, dimensionless
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For turnovers > 36, KN = (180 + N)/6N
N = number of turnovers per year, dimensionless
N = Q/V
Q = annual net throughput, gal/yr
V = working volume, gal KP = working loss product factor, dimensionless
Kp = 1 for organic liquids except crude oils
WV = vapor density, lb/ft3
KB = vent setting correction factor, dimensionless, KB = 1

When the breather vent settings are greater than the typical values of ±0.03 psig, and the condition
expressed in Equation 1-40 is met, a vent setting correction factor, KB, must be determined using equation
1-41. This value of KB will be used in Equation 1-25 to calculate working losses.

Therefore, when Equation 1-40:
𝐾𝐾𝑉𝑉�𝑃𝑃𝐵𝐵𝑃𝑃+𝑃𝑃𝐿𝐿𝑃𝑃𝐼𝐼+𝑃𝑃𝐿𝐿�> 1.0
Then, Equation 1-41 becomes: 𝐾𝐾𝐵𝐵=�𝑃𝑃𝐼𝐼+𝑃𝑃𝐿𝐿𝐾𝐾𝑉𝑉− 𝑃𝑃𝑉𝑉𝐿𝐿𝑃𝑃𝐵𝐵𝑃𝑃+𝑃𝑃𝐿𝐿− 𝑃𝑃𝑉𝑉𝐿𝐿�
Where:
KB = vent setting correction factor, dimensionless
PI = pressure of the vapor space at normal operating conditions, psig
PA = atmospheric pressure, psia
KN = working loss turnover (saturation) factor, dimensionless
PVA = vapor pressure at the average daily liquid surface temperature, psia
PBP = breather vent pressure setting, psig
N = number of turnovers per year
𝑁𝑁=𝑄𝑄𝐶𝐶
Where:
Q = annual tank throughput, gal/yr
C = tank capacity, gal
4.3.3 Hazardous Air Pollutant Speciation
The individual HAP emissions from fixed roof storage tanks are estimated by multiplying the total loss by the
weight fraction in the vapor phase of the desired component using Equation 40-1:
𝐿𝐿𝑇𝑇𝑇𝑇= (𝑍𝑍𝑉𝑉𝑇𝑇)(𝐿𝐿𝑇𝑇)
Where:
LTi = emission rate of component i, lb/yr
ZVi = weight fraction of component i in the vapor phase, lb/lb
LT = total losses, lb/yr

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The partial pressure (Pi) of a component can be determined using Raoult’s Law which states that the mole
fraction of the component in the liquid (xi) multiplied by the vapor pressure of the pure component (P) is
equal to the partial pressure, Pi, of that component:
𝑃𝑃𝑇𝑇= (𝑃𝑃)(𝑋𝑋𝑇𝑇)
Where:
Pi = partial pressure of component i, psia
P = vapor pressure of pure component i at the average daily liquid surface temperature,
psia
xi = liquid mole fraction, lb-mole/lb-mole

The vapor pressure of each component can be calculated from Antoine’s equation:
𝑥𝑥𝑇𝑇=�𝑍𝑍𝐿𝐿𝑇𝑇𝑀𝑀𝐿𝐿𝑀𝑀𝑇𝑇�
Where:
xi = liquid mole fraction of component i, lb-mol/lb-mole
ZLi = weight fraction of component i in the liquid, lb/lb
ML = molecular weight of liquid stock, lb/lb-mole
Mi = molecular weight of component i, lb/lb-mole
The vapor mole fraction of the component can be determined from using Equation 40-5:
𝑦𝑦𝑇𝑇=𝑃𝑃𝑇𝑇𝑃𝑃𝑉𝑉𝐿𝐿
Where:
yi = vapor mole fraction of component i, lb-mol/lb-mol
Pi = partial pressure of component i, psia
PVA = total vapor pressure of liquid mixture, psia

The weight fractions in the vapor phase are calculated from the mole fractions in the vapor phase:
𝑍𝑍𝑉𝑉𝑇𝑇=�𝑦𝑦𝑇𝑇𝑀𝑀𝑇𝑇𝑀𝑀𝑣𝑣�
Where:
ZVi = vapor weight fraction of component i, lb/lb
yi = vapor mole fraction of component i, lb-mole/lb-mole
Mi = molecular weight of component i, lb/lb-mole
MV = molecular weight of vapor stock, lb/lb-mole

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5. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS
5.1 Diesel-Fired Prime Power Engines

In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant, must consider the best available control
technology (BACT) for the proposed activity. The BACT analysis below was performed pursuant to this rule.
It only addresses units which will be modified, installed, or otherwise altered according to this NOI.
5.1.1 Step 1 - Identify All Control Technologies
The following sources were reviewed to identify available control technologies for the diesel-powered prime
power engines:
► EPA’s RACT, BACT, LAER Clearinghouse (RBLC) Database for Diesel Engines;
► EPA’s Air Pollution Control Technology Fact Sheets; and
► South Coast Air Quality Management District Example Permits.

Available control technologies for diesel-fired non-emergency engines include the following:

► Good Combustion Practices;
► Use of a Tier Certified Engine;
► Engine Design;
► Diesel Particulate Filter;
► Ultra-Low Sulfur Fuel;
► Diesel Oxidation Catalyst; and
► Selective Catalyst Reduction (SCR).

The following step evaluates the technical feasibility of each of these options.

5.1.2 Step 2 – Eliminate Technically Infeasible Control Options
Good Combustion Practices
Good combustion practices refer to the operation of engines at high combustion efficiency, which reduces
the products of incomplete combustion. The proposed prime power engines are designed to achieve
maximum combustion efficiency. The manufacturer has provided operation and maintenance manuals that
detail the required methods to achieve the highest levels of combustion efficiency. Good combustion
practices are considered technically feasible.
Use of an Appropriate Tier Certified Engine
EPA noted that non-road engines were a significant source of emissions and began adopting emission
standards for these emission units in 1994. Today, engines are required to meet certain emission limits, or
tier ratings, based on the size and model year. Archaea’s requested prime power engines meet EPA Tier 4f
certification requirements.
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Diesel Particulate Filters
This simple technology is placed in the exhaust pathway to prevent the release of particulate matter and
may be coated with a catalyst to further capture hydrocarbon emissions.

According to EPA’s Response to Public Comments on Notice of Reconsideration of NESHAP for RICE and NSPS for Stationary ICE, “Diesel particulate filters are also proven, commercially available technology for
retrofit applications to stationary engines…and are capable of reducing diesel PM by 90 percent or
more.”1 Additionally the CA ARB was able to determine that this technology was technically feasible for emergency and prime engines through obtaining several vendor quotes.2
However, EPA remained concerned with the installation of a catalyzed particulate filter, citing technical
issues, including the fact that many older engines are not electronically controlled, PM emissions are often
too high for efficient operation, and, in some cases, engine exhaust temperatures are not high enough for
filter substrate regeneration.3

While a catalytic diesel particulate filter is not considered to be technically feasible, a simple diesel
particulate filter is included on the Tier 4f engines proposed for prime power.
Ultra-Low Sulfur Diesel
Ultra-low sulfur diesel (ULSD) contains less than 0.0015% sulfur by weight. The reduced sulfur content of
ULSD reduces the production of SO2 emissions. Additionally, its low sulfur content results in a lower
potential for aggregation of sulfur-containing compounds and thus reduces PM2.5 emissions. Archaea will
continue the use of ULSD fuel for these proposed diesel fired engines.
Diesel Oxidation Catalyst
A diesel oxidation catalyst (DOC) utilizes a catalyst such as platinum or palladium to further oxidize an
engine’s exhaust, which includes hydrocarbons (HC) (e.g., VOC), carbon dioxide (CO2), and water. Use of a
diesel oxidation catalyst can result in an approximately 90 percent reduction in HC/VOC emissions.4 In
addition to controlling HC/VOC, a DOC also has the potential to reduce PM emissions by 30 percent (based
on the concentration of soluble organics) and CO emissions by 50 percent if low sulfur diesel fuel is used.5

1 Response to Public Comments on Notice of Reconsideration of National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal
Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, June 16, 2014
2 Response to Public Comments on Notice of Reconsideration of National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal
Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, June 16, 2014
3 Response to Public Comments on Notice of Reconsideration of National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal
Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, June 16, 2014
4 U.S. EPA, Alternative Control Techniques Document: Stationary Diesel Engines, March 5, 2010, p. 41.
(https://www.epa.gov/sites/production/files/2014-02/documents/3_2010_diesel_eng_alternativecontrol.pdf).
5 Response to Public Comments on Notice of Reconsideration of National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and New Source Performance Standards for Stationary Internal Combustion Engines, EPA Docket EPA-HQ-OAR-2008-0708, June 16, 2014.
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The use of a DOC reduces the effective power output of RICE and results in a solid waste
stream. However, for the purposes of identifying technical feasibility, no formal consideration of these
adverse energy and environmental impacts is presented. A DOC is considered technically feasible, and the
proposed engines are equipped with DOC.
Selective Catalytic Reduction
Selective catalytic reduction (SCR) systems introduce a liquid reducing agent such as ammonia or urea into
an engine’s flue-gas stream prior to a catalyst. The catalyst reduces the temperature needed to initiate the
reaction between the reducing agent and NOX to form nitrogen and water. For SCR systems to function
effectively, exhaust temperatures must be high enough (250°C to 427°C)6 to enable catalyst activation,
which will be accounted for in operation. In summary, as the hot flue gas and reagent diffuse through the
catalyst and contact activated catalyst sites, NOX in the flue gas chemically reduces to nitrogen and
water. The heat of the flue gas provides energy for the reaction. The nitrogen, water vapor,
and any other flue gas constituents then flow out of the SCR reactor. The engines proposed for prime
power are Tier 4f, and they are equipped with an integrated SCR on the engine.
5.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Effective control technologies for diesel engines include good combustion practices, use of tier-certified
engines, diesel particulate filters, ultra-low sulfur diesel, DOCs, and SCRs. All control technologies considered effective are currently implemented.
5.1.4 Step 4 – Evaluate Most Effective Controls and Document Results
Because the highest ranked controls have been applied as BACT for this source, no detailed economic,
energy, and environmental impact evaluations were conducted.
5.1.5 Step 5 - Select BACT
As defined under R307-401-5(2)(d), “Best available control technology shall be at least as stringent as any
published US Environmental Control Technology Guideline (CTG) that is applicable to the source,” and
considering Tier 4f emission standards are the most stringent, Wasatch RNG proposes that the proposed
Tier 4f certified generator engines meet BACT with the controls proposed including SCR, DOC, and diesel
particulate filters. Additionally, the proposed engines will be operated and maintained in accordance with
good combustion practices and combust only ultra-low sulfur diesel.
5.2 Diesel Storage Tanks – BACT Analysis
Archaea is proposing to permit eight (8) diesel tanks and one (1) 15,809 gallon diesel storage tank for a
combined capacity of approximately 21,129 gallons. The combined PTE of VOCs from the diesel tanks is less
than 0.1 tpy and the total HAP PTE is 0.0007 tpy.
5.2.1 Diesel Tanks VOCs & Volatile HAPs - Steps 1-5 – Identify All Control
Technologies
6 EPA’s Air Pollution Control Technology Fact Sheet for Selective Catalytic Reduction. EPA-452/F-03-032.
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Emissions from fixed-roof storage tanks result from displacement of headspace vapor during filling
operations (working losses) and from diurnal temperature and heating variations (breathing losses). While a
variety of technologies may be considered, due to the size and minimal throughput anticipated for the
proposed tanks, VOC emissions from the tanks are minimal, as demonstrated in the emission calculations.
Each belly tank stands at a shallow ~30 inches high, meaning that splashing will be minimized during filling
operations, as the distance that the fuel falls from the feed to the surface of the fuel oil in each tank is
minimal. Per AP-42 5.2, Transportation And Marketing of Petroleum Liquids, higher levels of turbulence
during splash loading results in increased amounts of vapor generation and loss. Because of the shallow
nature of the belly tanks, turbulence during filling operations will be minimized, thus reducing emissions,
especially compared to standard horizontal fixed-roof or vertical fixed-roof tanks.

Because of these various considerations – namely, low throughput, shallow depth, reduced splashing, and
the involatile nature of No. 2 fuel oil – emissions from these belly tanks are minimal, and BACT is considered
to be the use of best management and operational practices.
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6. EMISSIONS IMPACT ANALYSIS
The changes with the proposed engines do not exceed SERs or UDAQ’s modeling thresholds, therefore
criteria pollutant or HAPs modeling is not required under R307-410-4 and R307-410-5, respectively.
Appendix Table B-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds
contained in R307-403-4 through 7, and R307-410-4. Appendix Table B-2 contains a comparison of HAPs
emission rate to the emission threshold values consistent with R307-410-5.

Although not required, Archaea requested Trinity to perform an air quality impact analysis (i.e., air
dispersion modeling) for 1-hour and annual NO2 accounting for all NO2 sources at the Wasatch RNG facility.
An air dispersion modeling report will be submitted under a separate cover to demonstrate that 1-hour and
annual NO2 NAAQS can be achieved with the proposed diesel-fired generator engines.
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7. NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING
Lightning Renewables is located in Tooele County, Utah. The area of Tooele County in which the facility is
located is currently classified as an attainment area for all criteria pollutants. The UDAQ offset requirements
in R307-403, R307-420, and R307-421 are not applicable for the proposed modifications.

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8. APPLICABLE RULES
Per UDAQ’s Form 1 NOI Checklist, the NOI air permit application must include a discussion of State and
Federal requirements and their applicability to the project. Regulations can include NAAQS, SIP, NSPS,
MACT and Utah Air Quality Regulations.

Archaea has evaluated the applicability of the regulatory measures associated with the project described in
this NOI application. Applicable regulatory measures associated with the projects described in this NOI will
be discussed in the subsequent sections.
8.1 Utah Regulations
Archaea has determined that the following rules under the Utah Administrative Code (UAC) Title R307 will
apply to this project:
Table 5 - Evaluation of Utah Air Quality Rules
Reference Regulation Name Applicability
Yes No
R307-101 General Requirements X
R307-102 General Requirements: Broadly Applicable
Requirements X
R307-103 Administrative Procedures X
R307-104 Conflict of Interest X
R307-105 General Requirements: Emergency controls X
R307-107 General Requirements: Breakdowns X
R307-110 General Requirements: State Implementation Plan X
R307-115 General Conformity X
R307-120 General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121 General Requirements: Clean Air and Efficient Vehicle Tax Credit X
R307-122 General Requirements: Heavy Duty Vehicle Tax Credit X
R307-123 General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124 General Requirements: Conversion to Alternative Fuel
Grant Program X
R307-125 Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 General Penalty Policy X
R307-135 Enforcement Policy for Asbestos Hazard Emergency
Response Act X
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Reference Regulation Name Applicability
Yes No
R307-150 Emission Inventories X
R307-165 Emission Testing X
R307-170 Continuous Emission Monitoring Program X
R307-201 Emission Standards: General Emission Standards X
R307-202 Emission Standards: General Burning X
R307-203 Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205 Emission Standards: Fugitive Emissions and Fugitive
Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207 Residential Fireplaces and Solid Fuel Burning Devices X
R307-208 Outdoor Wood Boilers X
R307-210 Standards of Performance for New Stationary Sources X
R307-214 National Emission Standards for Hazardous Air
Pollutants X
R307-220 Emission Standards: Plan for Designated Facilities X
R307-221 Emission Standards: Emission Controls for Existing Municipal Solid Waste Landfills X
R307-222 Emission Standards: Existing incinerator for Hospital,
Medical, Infectious Waste X
R307-223 Emission Standards: Existing Small Municipal Waste
Combustion Units X
R307-224 Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230 NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250 Western Backstop Sulfur Dioxide Trading Program X
R307-301 Utah and Weber Counties: Oxygenated Gasoline Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304 Solvent Cleaning X
R307-305 Nonattainment and Maintenance Areas for PM10:
Emission Standards X
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Reference Regulation Name Applicability
Yes No
R307-306 PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307 Road Salting and Sanding X
R307-309 Nonattainment and Maintenance Areas for PM10 and
PM2.5: Fugitive Emissions and Fugitive Dust X
R307-310 Salt Lake County: Trading of Emission Budgets for
Transportation Conformity X
R307-311 Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312 Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-320 Ozone Maintenance Areas and Ogden City: Employer
Based Trip Reduction X
R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327 Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328 Gasoline Transfer and Storage X
R307-335 Degreasing X
R307-341 Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342 Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351 Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X
R307-354 Automotive Refinishing Coatings X
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Reference Regulation Name Applicability
Yes No
R307-355 Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361 Architectural Coatings X
R307-401 Permit: New and Modified Sources X
R307-403 Permits: New and Modified Sources in Nonattainment
and Maintenance Areas X
R307-405 Permits: Major Sources in Attainment or Unclassified
Areas (PSD) X
R307-406 Visibility X
R307-410 Permits: Emission Impact Analysis X
R307-414 Permits: Fees for Approval Orders X
R307-415 Permits: Operating Permit Requirements X
R307-417 Permits: Acid Rain Sources X
R307-420 Permits: Ozone Offset Requirements in Salt Lake
County and Utah County X
R307-421 Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424 Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to 511 Oil and Gas Industry X
R307-801 Utah Asbestos Rule X
R307-840 Lead-Based Paint Program Purpose, Applicability, and
Definitions X
R307-841 Residential Property and Child-Occupied Facility
Renovation X
R307-842 Lead-Based Paint Activities X
Each of the regulations and how they apply to the facility as a result of the project are described below.
UAC R307-210 and R307-214 are incorporated into Utah regulations by referencing the federal statutes. As
such, applicability and requirements for these standards are discussed in the following Section.
8.1.1 UAC R307-101 General Requirements
With this project, Archaea will comply with those general requirements that are applicable to this project as
addressed in the definitions, terms, abbreviations, and references used in the UAC R307-101, and 40 CFR.
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8.1.2 UAC R307-107 General Requirements: Breakdowns
Archaea will report breakdowns within 24 hours via telephone, electronic mail, fax, or other similar methods
and provide a detailed written description within 14 days of the onset of the incident to UDAQ. A breakdown
is defined in UAC R307-101-2 as “"Breakdown" means any malfunction or procedural error, to include but
not limited to any malfunction or procedural error during start-up and shutdown, which will result in the
inoperability or sudden loss of performance of the control equipment or process equipment causing
emissions in excess of those allowed by approval order or Title R307.”
8.1.3 UAC R307-203 Emission Standards: Sulfur Content of Fuels
Archaea will utilize diesel in the generator engine. Recordkeeping and reporting regulations in this rule will
be met. The sulfur content of diesel fuel will be verified using vendor test records.
8.1.4 UAC R307-325 Ozone Nonattainment and Maintenance Areas: General
Requirements
This rule provides assurance that sources will minimize emissions of VOC using reasonable controls. VOC
containing materials must be handled and stored in a manner to prevent spills and excess emissions. Storing
VOC containing materials in open containers is prohibited.
8.1.5 UAC R307-401-4 General Requirements
Archaea complies with the general requirements set forth for new and modified installations. All equipment
is adequately and properly maintained.
8.1.6 UAC R307-401-5 Notice of Intent
Wasatch RNG is satisfying the requirements by submitting this NOI application.
8.1.7 UAC R307-401-8 Approval Order
(1) The director will issue an AO if the conditions have been met.
(a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust,
is at least best available control technology. When determining best available control technology
for a new or modified source in an ozone nonattainment or maintenance area that will emit
volatile organic compounds or nitrogen oxides, best available control technology shall be at least
as stringent as any Control Technique Guidance document that has been published by EPA that
is applicable to the source.
(b) The proposed installation will meet the applicable requirements of:
(i) R307-403, Permits: New and Modified Sources in Nonattainment Areas and Maintenance
Areas;
(ii) R307-405, Permits: Major Sources in Attainment or Unclassified Areas (PSD);
(iii) R307-406, Visibility;
(iv) R307-410, Emissions Impact Analysis;
(v) R307-420, Permits: Ozone Offset Requirements in Davis and Salt Lake Counties;
(vi) R307-210, National Standards of Performance for New Stationary Sources;
(vii) National Primary and Secondary Ambient Air Quality Standards;
(viii) R307-214, National Emission Standards for Hazardous Air Pollutants;
(ix) R307-110, Utah State Implementation Plan; and
(x) All other provisions of R307.
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(2) The approval order will require that all pollution control equipment be adequately and properly
maintained.
(3) Receipt of an approval order does not relieve any owner or operator of the responsibility to
comply with the provisions of R307 or the State Implementation Plan.
As documented in Section 5 of this NOI, BACT provisions specified in UAC R307-401 have been applied
through proposed control equipment.
8.1.8 UAC R307-403 New and Modified Sources in Nonattainment Areas and
Maintenance Areas
This rule implements the federal nonattainment area permitting program for major sources as required by
40 CFR 51.165. In addition, the rule contains new source review provisions for some non-major sources in
PM10 nonattainment areas. The Wasatch RNG facility is in an attainment area for all criteria pollutants. The
proposed facility’s PTE does not exceed the major source thresholds for these pollutants and is therefore
not subject to NNSR review.
8.1.9 UAC R307-405 Permits: Major Sources in Attainment or Unclassified Areas
This rule implements the federal PSD permitting program for major sources and major modifications in
attainment areas and maintenance areas as required by 40 CFR 51.166. The Lightning Renewables facility is
currently an attainment area for all pollutants. Lightning Renewables’ potential emission impacts are below
major source thresholds of these pollutants. The proposed facility’s PTE does not exceed the major source
thresholds for these pollutants and is therefore not subject to PSD review for this modification. Greenhouse
gases (GHGs) from this proposed source are not subject to regulation pursuant to R307-405-3 because the
proposed source is not a new major stationary source for a regulated NSR pollutant that is not a GHG.
8.2 Federal Rules: National Emission Standards for Hazardous Air
Pollutants
The NESHAP federal regulations found in Title 40 Part 61 and 63 of the CFR are emission standards for
HAPs. NESHAP are applicable to both major sources of HAPs (facilities that exceed the major source
thresholds of 10 tpy of a single HAP and 25 tpy of any combination of HAPs from stationary sources) as well
as non-major sources (termed “minor sources”). NESHAP apply to sources in specifically regulated industrial
source classifications (Clean Air Act Section 112(d)) or on a case-by-case basis (Clean Air Act Section
112(g)) for facilities not regulated as a specific industrial source type.
The facility is a minor source under the NSR program. As such, this document only addresses regulatory
applicability for area sources and does not include standards for major sources.
8.2.1 Subpart A – General Provisions
NESHAP Subpart A, General Provisions, contains national emissions standards for HAPs defined in Section
112(b) of the Clean Air Act. All affected sources, which are subject to another NESHAP are subject to the
general provisions of NESHAP Subpart A, unless specifically excluded by the source specific NEHSAP.
Subpart A requires initial notification, performance testing, recordkeeping, and monitoring, provides
reference methods, and mandates general control device requirements for all other subparts. The following
sections detailing each subpart requirements also include requirements that are referenced to Subpart A.
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8.2.2 Subpart ZZZZ – Stationary Reciprocating Internal Combustion Engines
NESHAP Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines, applies to stationary reciprocating internal combustion engines
(RICE) at major and area sources of HAPs. Per 40 CFR 63.6590(a)(2)(iii), a stationary RICE at an area
source of HAPs is new if construction commenced after June 12, 2006. Thus, the proposed engines are
considered a new stationary RICE under NESHAP Subpart ZZZZ. Per 40 CFR 63.6590(c) and 40 CFR
63.6590(c)(1), new stationary RICE located at an area source of HAP may show compliance with NESHAP
ZZZZ by complying with NSPS IIII.7 The Facility is not a major source of HAPs, as total HAP emissions
amount to less than 10 tons per year for an individual HAP and less than 25 tons per year of total HAPs. By
maintaining compliance with NSPS IIII, Archaea can demonstrate compliance with NESHAP ZZZZ.
8.3 Federal Rules: New Source Performance Standards
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable by the
best demonstrated technology as specified in the applicable provisions. Moreover, any source subject to
NSPS is also subject to the general provisions of NSPS Subpart A, except as noted. The following section
details the applicability of NSPS regulations to the facility’s operations.
8.3.1 NSPS Subpart IIII – Stationary Compression Ignition Engines
NSPS Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines, establishes requirements for stationary CI internal combustion engines for which construction,
modification, or reconstruction commenced after July 11, 2005.
The provisions of this subpart are applicable to owners and operators of compression ignition internal
combustion engines which commenced construction after July 11, 2005, and were manufactured after April
1, 2006. The construction date is the date the engine was ordered by the owner or operator. The generator
engine proposed to be added was constructed after the specified construction dates. NSPS IIII is applicable
to these engines.
8.3.1.1 Emission Limitation
►Owners and operators of 2007 model year and later non-emergency stationary CI ICE with a
displacement of less than 30 liters per cylinder must comply with the emission standards for new CI
engines in § 60.4201 for their 2007 model year and later stationary CI ICE, as applicable.8
8.3.1.2 Fuel Requirements
►Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this subpart with a
displacement of less than 30 liters per cylinder that use diesel fuel must use diesel fuel that meets
the requirements of 40 CFR 1090.305 for nonroad diesel fuel, except that any existing diesel fuel
purchased (or otherwise obtained) prior to October 1, 2010, may be used until depleted.9
►The requirements of 40 CFR 1090.305 are as follows:
•15 ppm sulfur; and
•Minimum cetane index of 40 or maximum aromatic content of 35 volume percent.
7 NESHAP Subpart 40 CFR 63.6675
8 40 CFR 60.4204(b)
9 40 CFR 60.4207(b).
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8.3.1.3 Monitoring Requirements
► If you are an owner or operator of a stationary CI internal combustion engine equipped with a diesel
particulate filter to comply with the emission standards in § 60.4204, the diesel particulate filter
must be installed with a backpressure monitor that notifies the owner or operator when the high
backpressure limit of the engine is approached.10
8.3.1.4 Compliance Requirements
► Operate, maintain, install, and configure the stationary CI internal combustion engine and control
device according to the manufacturer's emission-related written instructions;11
► Change only those emission-related settings that are permitted by the manufacturer;12
► Meet the requirements of 40 CFR 89, and/or 1068;13
8.3.1.5 Recordkeeping
► Submit an initial notification as required in § 60.7(a)(1).The notification must include the following:14
• Name and address of the owner or operator;
• The address of the affected source;
• Engine information including make, model, engine family, serial number, model year, maximum
engine power, and engine displacement;
• Emission control equipment; and
• Fuel used.
► Records of the following information must be kept:15
• All notifications submitted to comply with this subpart and all documentation supporting any notification;
• Maintenance conducted on the engine;
• If the stationary CI internal combustion is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards;
• If the stationary CI internal combustion is not a certified engine, documentation that the engine
meets the emission standards.
► The owner or operator must keep records of any corrective action taken after the backpressure
monitor has notified the owner or operator that the high backpressure limit of the engine is
approached.16
8.3.2 NSPS Subpart Kb – Storage Tanks
NSPS, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels, is the current
standard for storage tanks. NSPS, Subpart Kc was proposed on October 4, 2023 and, if finalized, will
retroactively apply to tanks constructed, reconstructed, or modified after October 4, 2023. NPSP, Subpart Kc
is described in the following section.

10 40 CFR 60.4209(b).
11 40 CFR 60.4211(a)(1).
12 40 CFR 60.4211(a)(2).
13 40 CFR 60.4211(a)(3).
14 40 CFR 60.4214(a)(i)(ii)(iii)(iv)(v)
15 40 CFR 60.4214(b)(i)(ii)(iii)(iv)
16 40 CFR 60.4214(c)
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NSPS, Subpart Kb, regulates storage vessels with a design capacity greater than or equal to 75 cubic meters
(m3) that store volatile organic liquids.17 The standards are effective for all facilities for which construction,
reconstruction, or modification commenced after July 23, 1984. Storage vessels with a capacity greater than
or equal to 151 cubic meters (m3) storing a liquid with a maximum true vapor pressure, excluding water,
less than 3.5 kilopascals (kPa) or with a capacity greater than or equal to 75 m3 but less than 151 m3
storing a liquid with a maximum true vapor pressure less than 15.0 kPa are exempt from the requirements
of this rule.18 Tanks that are subject to this rule must be equipped with sealing systems or closed vent
systems and are subject to recordkeeping and reporting requirements.19

All proposed storage tanks at the Wasatch RNG facility are less than 75 m3 in volume or store diesel fuel
which has a maximum true vapor pressure less than 3.5 kPa at all operating temperatures. NSPS Subpart Kb
is therefore not applicable to the Wasatch RNG facility.
8.3.3 NSPS Subpart Kc – Storage Tanks
NSPS, Subpart Kc, Volatile Organic Liquid Storage Vessels (Including Petroleum Liquide Storage Vessels),
was proposed by the EPA on October 4, 2023. This rule proposes requirements for storage tanks with
capacities between 20,000 and 40,000 gallons which store liquids with a maximum true vapor pressure
greater than or equal to 1.5 psia and storage tanks with capacity greater than or equal to 40,000 gallons
which store liquids with a maximum true vapor pressure greater than or equal to 0.5 psia. The diesel
storage tanks at the Wasatch RNG facility are all below 20,000 gallon capacities with vapor pressures below
0.5 psia. This rule is not applicable to the Wasatch RNG facility.

17 40 CFR 60.110b(a)
18 40 CFR 60.110b(b) 19 40 CFR 60.112b
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APPENDIX A. NOI FORMS
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Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
May 2024
Lightning Renewables, LLC
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Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
X
May 2024
4
Lightning Renewables, LLC
8833 N Rowley Rd.
Grantsville, UT 84029
[phone]
Nevin Edwards
[phone]
[e-mail]
201 Helios Way, Floor 6
Houston, TX 77079
Tooele
12
353306.00 m E
4522757.00 m N
4925
AN161340001-23 06 01 2023
The project proposes to modify its current AO by adding eight (8) diesel-fired engines to be utilized for
primary power.
4
Chief Operating Officer
Steven Boor [phone]
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
6/24/2024
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1. Permit Number____________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4.Does new emission unit affect existing
permitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Addition of eight (8) diesel-fired generator engines, to be utilized for primary power until utility power is
available.
DAQE-AN161340001-23
Lightning Renewables, LLC
Wasatch RNG

Diesel-fired RICE for primary power 4
4
See NOI for emission calculations
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
See NOI Appendix B
See NOI Appendix B
See NOI Appendix B
Lightning Renewables, LLC
Wasatch RNG
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Utah Division of Air Quality
New Source Review Section Company_______________________
Site/Source_____________________
Form 11 Date___________________________
Internal Combustion Engines
Equipment Information
1.Manufacturer: _________________________
Model no.: __________________________
The date the engine was constructed or
reconstructed ________________________
2. Operating time of Emission Source:
average maximum
______ Hours/day ______ Hours/day
Days/week Days/week
______ Weeks/year ______ Weeks/year
3. Manufacturer's rated output at baseload, ISO hp or Kw
Proposed site operating range _____________________________ hp or Kw
Gas Firing
4. Are you operating site equipment on pipeline quality natural gas: □ Yes □ No
5. Are you on an interruptible gas supply:
□Yes □ No
If "yes", specify alternate fuel:
_______________________________
6. Annual consumption of fuel:
_____________________________ MMSCF/Year
7. Maximum firing rate:
_____________________________ BTU/hr
8. Average firing rate:
_____________________________ BTU/hr
Oil Firing
9. Type of oil:
Grade number □ 1 □ 2 □ 4 □ 5 □ 6 Other specify ___________
10. Annual consumption: ______________ gallons 11. Heat content:______________ BTU/lb or
______________ BTU/gal
12. Sulfur content:___________% by weight 13.
14. Average firing rate: gal/hr 15. Maximum firing rate: gal/hr
16. Direction of firing: □ horizontal □ tangential □ other: (specify)
Page 1 of 4 
&DWHUSLOODU
&
0D\
:DVDWFK51*
/LJKWQLQJ5HQHZDEOHV//&




2FWREHU




(per engine)
(Fuel use for all 8 engines, Safety factor of 2)
Ash content:____% tby weigh
138,000
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Page 2 of 4 
Internal Combustion Engine
Form 11 (Continued)
Operation
17. Application:
□Electric generation
______ Base load ______ Peaking
□Emergency Generator
□Driving pump/compressor
□Exhaust heat recovery
□Other (specify) ________________________
18. Cycle
□Simple cycle
□Regenerative cycle
□Cogeneration
□Combined cycle
Emissions Data
19.Manufacturer’s Emissions in grams per hour (lb/hr): _______ NOX _______ CO ______ VOC
_3.18 E-03____
20. Attach manufacturer's information showing emissions of NOx, CO, VOC, SOx, CH2O, PM10, PM 2.5 , CO2, CH4 and N2O
for each proposed fuel at engine loads and site ambient temperatures representative of the range of proposed
operation. The information must be sufficient to determine maximum hourly and annual emission rates. Annual
emissions may be based on a conservatively low approximation of site annual average temperature. Provide emissions
in pounds per hour and except for PM10 and PM2.5 parts per million by volume (ppmv) at actual conditions and corrected
to dry, 15% oxygen conditions.
Method of Emission Control:
□Lean premix combustors □Oxidation catalyst □ Water injection □ Other (specify)____________
□Other low-NOx combustor □SCR catalyst □Steam injection
Additional Information
21. On separate sheets provide the following:
A. Details regarding principle of operation of emission controls. If add-on equipment is used, provide make and
model and manufacturer's information. Example details include: controller input variables and operational
algorithms for water or ammonia injection systems, combustion mode versus engine load for variable mode
combustors, etc.
B. Exhaust parameter information on attached form.
C. All calculations used for the annual emission estimates must be submitted with this form to be deemed
complete.
D. All formaldehyde emissions must be modeled as per Utah Administrative Code R307-410-5 using
SCREEN3.
E. If this form is filled out for a new source, forms 1 and 2 must be submitted also.

Formaldehyde
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Page 3 of 4 
INSTRUCTIONS – Form 11 Internal Combustion Engine
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to help!
1. Indicate the manufacturer, the model number and the date the engine was constructed or reconstructed.
2. Complete the fuel burning equipment's average and maximum operating schedule in hours per day, days per
week, and weeks per year.
3. Specify the manufacturer's rated output and heat rate at baseload corresponding to International Standard
Organization (ISO) conditions in megawatts (MW) or horsepower (hp). Also indicated what the proposed site
operating range is in megawatts or horsepower.
4.Indicate the origin of the gas used in the engine.
5.Indicate if the gas supply can be interrupted and what the backup fuel is in case this happens.
6. Specify what the annual consumption of fuel is in million standard cubic feet (MMscf).
7. Supply the maximum firing rate in BTU/hr.
8.Supply the average firing rate in BTU/hr.
9. Indicate the grade of oil being used.
10. Supply the annual consumption calculated in gallons of oil.
11. Indicate the heat content of the oil in BTU/lb or BTU/gal.
12.Indicate the sulfur content of the oil in percent by weight.
13. Indicate the ash content of the oil.
14. Supply the average firing rate of oil.
15. Supply the maximum firing rate of oil.
16. Indicate what the firing direction is.
17. Indicate what the engine will be used for.
18. Indicate what type of cycle the engine will have.
19. Indicate the manufacturer’s emissions rate in grams/hp-hr
20.Provide manufacturer's emission information for the engine. Also indicate what method of emission control to
be used.
21. Provide details of the operation of emission controls and exhaust parameter information.
f:\aq\ENGINEER\GENERIC\Forms 2010\Form11 Internal Combustion Engines.doc
Revised 12/20/10
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Page 1 of 2
New Source Review Section
________
Utah Division of Air Quality
Company: _________________________
Site/Source:________________________
Form 20
rganic Liquid Storage Tank O
Equipment
1. Tank manufacturer: ___________________________2. Identification number: _____________________
3. Installation date: ______________________________4. Volume: __________________________ gallons
5. Inside tank diameter: ______________________ feet 6. Tank height: ________________________ feet
7. True vapor pressure of liquid: _______________ psia 8. Reid vapor pressure of liquid: ____________ psi
9. Outside color of tank: __________________________10. Maximum storage temperature: __________ FO
11.Average throughput: _______________ gals per year 12. Turnovers/yearly ____ Monthly ____ Weekly ___
13. Average liquid height (feet): _____________________ Yes No Number ______14. Access hatch: □ □
15. T
a. P
r
b.S
Type: ________________________________
16. D
ll Yes No Number_____
ll
ak
ype of Seals:
rimary seals:
□Mechanical shoe
□Resilient filled
□Liquid filled
□Vapor mounted
□Liquid mounted
□ Flexible wipe
econdary seal:
eck Fittings:
□Gauge float we □
Gauge hatch/
sample we □ Yes □ No Number_____
Roof drains □ Yes □ No Number_____
Rim vents □ Yes □ No Number_____
Vacuum bre □ Yes □ No Number_____
Roof leg □ Yes □ No Number_____
Ladder well □ Yes □ No Number_____
Column well □ Yes □ No Number_____
Other:_________________________________
17. S
Deck Fitting Category: ________________________
18. T
______________________________________
hell Characteristics:
Condition: _________________________________
Breather Vent Settings: ________________________
Tank Construction: ___________________________
Roof Type: __________________________________
Deck Construction: ___________________________
ype of Construction:
□Vertical Fixed Roof
□Horizontal Fixed Roof
□Internal Floating Roof
□External Floating Roof
□Other (please specify)
19. Additional Controls:
Gas Blanket Venting Carbon Adsorption Thermal Oxidation Other:_______________□□ □□□
20.Single Liquid Information
Liquid Name: __________________________________
CAS Number: __________________________________
Avg. Temperature: ______________________________
Vapor Pressure: ________________________________
Liquid Molecular Weight: ________________________ Liquid Molecular Weight: ________________________
Liquid Name: __________________________________
CAS Number: __________________________________
Avg. Temperature: ______________________________
Vapor Pressure: ________________________________
15809
9.5
Western Global
6.3
Diesel
8
,506LWHZLGH
77
0.009
Lighting Renewables, LLC
0D\ 2024Date: _____________________
Wasatch RNG
68 F
0.009 psia
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Page 2 of 2
Form 20 - Organic Liquid Storage Tank
(Continued)
21.Chemical Components Information
Chemical Name: ________________________________
Percent of Total Liquid Weight: _____________________
Molecular Weight: _______________________________
Avg. Liquid Temperature: _________________________
Vapor Pressure: ________________________________ Vapor Pressure: ________________________________
Chemical Name: ________________________________
Percent of Total Liquid Weight: _____________________
Molecular Weight: _______________________________
Avg. Liquid Temperature: _________________________
Emissions Calculations (PTE)
22. C
Submit calculations as an appendix. Provide Material Safety Data Sheets for products being stored.
alculated emissions for this device:
VOC _________Lbs/hr_____ Tons/yr
HAPs_________Lbs/hr (speciate)______Tons/yr (speciate)
Instructions
Note: 1. Submit this form in conjunction with Form 1 and Form 2.
2. or questions in filling out this form.
Ask to speak with a New Source Review engineer. We will be glad to help!
on number that will appear on the tank.
s or barrels.
r in feet.
liquid (psi).
ach during storage (degrees Fahrenheit).
emptied and refilled per year, month or week.
ss hatches and the number.
17. Specify condition of the tank, also include the following:
d roof tanks
el construction sizes and seam length
olled, or detail
22.ations for all criteria pollutants and HAPs. Use AP-42 or manufacturers’ data to complete your
calculations.
ENERIC\Forms 2010\Form20 Organic Liquid Storage Tanks.doc
Revised 12/20/10
Call the Division of Air Quality (DAQ) at [phone] if you have problems
1.Indicate the tank manufacturer's name.
2.Supply the equipment identificati
3. Indicate the date of installation.
4.Indicate the capacity of the tank in gallon
5.Specify the inside tank diamete
6. Specify the tank height in feet.
7. Indicate the true vapor pressure of the liquid (psia).
8.Indicate the Reid vapor pressure of the
9. Indicate the outside color of the tank.
10.Supply the highest temperature the liquid will re
11. Indicate average annual throughput (gallons).
12.Specify how many times the tank will be
13. Specify the average liquid height (feet).
14.Indicate whether or not the tank has acce
15. Indicate what type of seals the tank has.
16. Indicate what types of deck fittings are installed.
Breather vent settings in (psig) for fixe
Tank construction, welded or riveted
Roof type; pontoon, double deck, or self-supporting roof
Deck construction; bolted or welded, sheet or pan
Deck fitting category; typical, contr
18. Indicate the type of tank construction.
19.Indicate other types of additional controls which will be used.
20.Provide information on liquid being stored, add additional sheets as necessary.
21.Provide information on chemicals being stored, add additional sheets as necessary.
Supply calcul
f:\aq\ENGINEER\G
1.63E-03
1.09E-03
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6

Archaea Energy Inc. | Wasatch RNG NOI B-1 Trinity Consultants
APPENDIX B. EMISSION CALCULATIONS
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Appendix B - Emissions Calculations
Table B-1. Lightning Renewables Wasatch RNG Potential to Emit
NOX CO PM10 PM2.5 VOC SO2 CO2e Total HAPs
XQ1140 Gensets 17.87 7.72E-04 1.40 1.40 1.49 0.32 28,877 0.26Belly Tanks ----0.05 --0.03
15K Diesel Tank ----1.14E-03 --7.61E-04
Project Total 17.87 7.72E-04 1.40 1.40 1.54 0.32 28,877 0.30
Currently Permitted PTE1 20.36 30.22 8.41 8.41 8.67 7.11 161,304 0.25
Proposed PTE 38.23 30.22 9.81 9.81 10.21 7.43 190,181 0.55
Major Source Thresholds2 250 250 250 250 250 250 75,000 10/25
Threshold Exceeded? No No No No No No No No
Modeling Limits3 40 100 15 ----40 --See HAPs
Summary
Threshold Exceeded?No No No No No No No No
1. AO DAQE-AN161340001-23.
2. Criteria pollutant major source thresholds defined by 40 CFR 51.165(a)(1)(iv)(A) and 40 CFR 52.21(b)(1)(i)(b).
3. Modeling limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission Rates for New Sources or Emissions Increase.
Emissions Potential Annual Emissions Estimate (tpy)
Archaea Energy, Inc | Wasatch RNG 1 of 7 Trinity Consultants
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Appendix B - Emissions Calculations
Table B-2. Potential HAP Emissions
Pollutant Existing HAPS
(lb/hr)
Project HAPS
(lb/hr)
Proposed
sitewide total
(lb/hr)
ETV
(lb/hr)1
Modeling
Required?
Benzene 3.00E-03 6.86E-02 7.2E-02 0.32 No
Toluene 2.30E-02 4.28E-01 4.5E-01 14.92 No
Xylenes 5.80E-04 1.02E+00 1.0E+00 85.97 No
Formaldehyde 5.70E-04 3.18E-03 3.7E-03 0.06 No
Acetaldehyde 0.00E+00 1.02E-03 1.0E-03 6.94 No
Acrolein 0.00E+00 3.18E-04 3.2E-04 0.04 No
Naphthalene 4.60E-06 1.19E-02 1.2E-02 10.38 No
Ethylbenzene 4.60E-03 5.21E-02 5.7E-02 -No
Hexane 1.50E-02 7.69E-03 2.3E-02 34.89 No
Chloromethane 4.70E-05 0 4.70E-05 20.44 No
Vinyl Chloride 8.30E-05 0 8.30E-05 0.17 No
Methanol 1.00E-02 0 1.00E-02 55.13 No
1,3-Butadiene 7.40E-05 0 7.40E-05 0.29 No
Bromomethane 1.60E-05 0 1.60E-05 0.77 No
Chloroethane 6.50E-05 0 6.50E-05 52.25 No
Vinyl Bromide 1.50E-05 0 1.50E-05 0.43 No
Acrylonitrile 7.60E-06 0 7.60E-06 0.86 No
1,1-Dichloroethene 5.20E-05 0 5.20E-05 3.93 No
Methylene Chloride 4.40E-04 0 4.40E-04 34.39 No
Allyl Chloride 2.20E-05 0 2.20E-05 0.62 No
Carbon Disulfide 4.40E-05 0 4.40E-05 0.62 No
trans-1,2-Dichloroethene 1.20E-04 0 1.20E-04 -No
1,1-Dichloroethane 5.40E-05 0 5.40E-05 -No
Methyl Tert Butyl Ether 1.30E-05 0 1.30E-05 35.70 No
Vinyl Acetate 2.50E-05 0 2.50E-05 6.97 No
cis-1,2-Dichloroethene 7.30E-04 0 7.30E-04 -No
Chloroform 1.70E-05 0 1.70E-05 9.67 No
1,2-Dichloroethane 8.30E-04 0 8.30E-04 8.01 No
1,1,1-Trichloroethane 1.90E-05 0 1.90E-05 378.16 No
Carbon Tetrachloride 2.20E-05 0 2.20E-05 2.08 No
Cyclohexane 5.00E-04 0 5.00E-04 -No
1,2-Dichloropropane 1.10E-04 0 1.10E-04 9.15 No
Bromodichloromethane 2.30E-05 0 2.30E-05 -No
1,4-Dioxane 2.50E-05 0 2.50E-05 14.27 No
Trichloroethene 8.00E-04 0 8.00E-04 3.55 No
2,2,4-Trimethylpentane 4.70E-04 0 4.70E-04 -No
Heptane 1.60E-03 0 1.60E-03 -No
cis-1,3-Dichloropropene 1.60E-05 0 1.60E-05 0.90 No
trans-1,3-Dichloropropene 3.00E-04 0 3.00E-04 0.90 No
1,1,2-Trichloroethane 4.30E-05 0 4.30E-05 10.80 No
1,2-Dibromoethane 2.70E-05 0 2.70E-05 -No
Tetrachloroethene 1.40E-03 0 1.40E-03 33.57 No
Chlorobenzene 9.30E-05 0 9.30E-05 9.12 No
m&p-Xylene 1.00E-02 0 1.00E-02 0.02 No
Bromoform 3.60E-05 0 3.60E-05 1.02 No
Styrene 8.60E-04 0 8.60E-04 16.87 No
1,1,1,2-Tetrachloroethane 2.40E-05 0 2.40E-05 -No
o-Xylene 3.60E-03 0 3.60E-03 85.97 No
1,3,5-Trimethylbenzene 5.20E-04 0 5.20E-04 -No
1,2,4Trimethylbenzene 8.80E-04 0 8.80E-04 -No
Benzyl Chloride 1.80E-05 0 1.80E-05 1.03 No
1,3-Dichlorobenzene 2.10E-05 0 2.10E-05 -No
1,4-Dichlorobenzene 1.60E-04 0 1.60E-04 11.91 No
1,2-Dichlorobenzene 2.10E-05 0 2.10E-05 -No
1,2,4-Trichlorobenzene 2.60E-05 0 2.60E-05 5.71 No
Hexachlorobutadiene 3.70E-05 0 3.70E-05 0.04 No
Hydrogen Chloride 4.70E-03 0 4.70E-03 0.46 No
Archaea Energy, Inc | Wasatch RNG 2 of 7 Trinity Consultants
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Appendix B - Emissions Calculations
Pollutant Existing HAPS
(lb/hr)
Project HAPS
(lb/hr)
Proposed
sitewide total
(lb/hr)
ETV
(lb/hr)1
Modeling
Required?
Hydrogen Fluoride 2.50E-04 0 2.50E-04 0.25 No
2-Methylnaphthalene 1.80E-07 0 1.80E-07 -No
3-Methylcholanthrene 1.40E-08 0 1.40E-08 -No
7,12-Dimethylbenz(a)anthracene 1.20E-07 0 1.20E-07 -No
Acenaphthene 1.40E-08 0 1.40E-08 -No
Acenaphthylene 1.40E-08 0 1.40E-08 -No
Anthracene 1.80E-08 0 1.80E-08 -No
Arsenic 1.80E-06 0 1.80E-06 0.00 No
Benz(a)anthracene 1.40E-08 0 1.40E-08 -No
Benzo(a)pyrene 9.10E-09 0 9.10E-09 -No
Benzo(b)fluoranthene 1.40E-08 0 1.40E-08 -No
Benzo(g,h,i)perylene 9.10E-09 0 9.10E-09 -No
Benzo(k)fluoranthene 1.40E-08 0 1.40E-08 -No
Beryllium 9.10E-08 0 9.10E-08 0.00 No
Cadmium 1.10E-05 0 1.10E-05 -No
Chromium 1.10E-05 0 1.10E-05 0.00 No
Chrysene 1.40E-08 0 1.40E-08 -No
Cobalt 6.40E-07 0 6.40E-07 0.00 No
Dibenzo(a,h)anthracene 9.10E-09 0 9.10E-09 -No
Dichlorobenzene 9.90E-06 0 9.90E-06 11.91 No
Fluoranthene 2.30E-08 0 2.30E-08 -No
Fluorene 2.10E-08 0 2.10E-08 -No
Indeno(1,2,3-cd)pyrene 1.40E-08 0 1.40E-08 -No
Lead 3.80E-06 0 3.80E-06 -No
Manganese 2.90E-06 0 2.90E-06 0.04 No
Nickel 1.60E-05 0 1.60E-05 0.01 No
Phenanthrene 1.30E-07 0 1.30E-07 -No
Pyrene 3.80E-08 0 3.80E-08 -No
Selenium 1.80E-07 0 1.80E-07 0.04 No
Mercury 2.60E-06 0 2.60E-06 0.00 No
1. The Emission Threshold Value (ETV) assumes < 50 m distance to the fence line and vertically unrestricted releases.
Archaea Energy, Inc | Wasatch RNG 3 of 7 Trinity Consultants
DocuSign Envelope ID: 1DE2657A-C24F-4C34-9455-50CE530E1CC6
Appendix B - Emissions Calculations
Table B-3. XQ1140 Diesel Genset Parameters
Parameter Value
Generator Make Milton CAT
Engine Model Number C18
Annual Hours of Operation (hr/yr)8,760
Total Number of Generators 8
Max Power Output (ekW)1 500
Max Power Output (hp)1 744
Heating Value of Diesel
(MMBtu/gal)2 0.138
Max Fuel Consumption (gal/hr)1 36.50
Max Heat Input (MMBtu/hr)3 5.04
Fuel ULSD
Sulfur Content4 0.0015%
1. Manufacturer specification sheet.
2. Per 40 CFR 98, Table C–1 to Subpart C for Distillate Fuel Oil No. 2.
3. Heat input based on diesel fuel consumption rate and heating value of diesel. Heat Input (MMBtu/hr) = Fuel Consumption Rate (gal/hr) * Heating Value of Diesel (Btu/gal)/10^6.
4. Per 40 CFR 80 Subpart I, maximum sulfur content of ULSD is 15 ppm (i.e. 0.0015%).
Table B-4. Criteria Pollutant Emission Factors
Pollutant 1,2,3,4,5
Percent Load 100 75 50 25
Power hp 744 558 372 186
NOX (lb/hr)0.51 0.50 0.15 0.05
VOC (lb/hr)0.04 0.02 0.02 0.02
PM/PM10/PM2.5 (lb/hr)0.04 0.02 0.01 0.01
CO (lb/hr)0.01 0.01 0.01 0.01SO2(lb/hr)9.03E-03 6.77E-03 4.51E-03 2.26E-03
CO2 (lb/hr)821.30 ---------
CH44 (lb/hr)0.03 ---------
N2O4 (lb/hr)0.01 ---------
CO2e5 (lb/hr)824.12 ---------
1. NOX, VOC, and PM emissions from manufacturer specification sheet.
2. CO emissions conservatively assumed to be 0.01 lb/hr.
4. Assumes hydrocarbons (HC) are equivalent to VOCs.
5. SO2 emissions using equation from AP-42 Table 3.4-1 footnote d: 8.09E-03*S1.
1.21E-05 (lb/hp-hr)
4. Emission factors from 40 CFR 98 Tables C-1 and C-2 (kg/MMBtu):
73.96 CO2
3.00E-03 CH46.00E-04 N2O
5. CO2e is the sum of GHG constituents multiplied by their respective global warming potential per 40 CFR 98 Table A-1.
1 CO2 GWP
25 CH4 GWP
298 N2O GWP
Emission Factors Units
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Appendix B - Emissions Calculations
Table B-5. Total Potential Emissions
Percent Load
Pollutant Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
Emissions per
Engine (tpy)
All Engines Total
(tpy)
NOx 2.23 17.87 2.19 17.52 0.66 5.26 0.22 1.75
CO 9.66E-05 7.72E-04 9.66E-05 7.72E-04 9.66E-05 7.72E-04 9.66E-05 7.72E-04
VOC 0.18 1.49 0.09 7.86E-01 0.09 0.79 0.09 0.79
SO2 0.04 0.32 0.03 0.24 0.02 0.16 9.89E-03 0.08
PM/PM10/PM2.5 0.18 1.40 0.09 7.01E-01 0.04 0.35 0.04 0.35
CO2e 3,610 28,877 ------------------
1. VOCs that are HAPs, listed under the Clean Air Act, and that are not NMHC are included in this emission factor.
Table B-6. HAP Potential to Emit
Pollutant1 Emission Factor2 Units All Engines Hourly
Emissions (lb/hr)3
Annual Emissions
per Engine (tpy)4 All Engines Total
HAP (tpy)
Also a VOC, not a
HC?
Benzene 7.76E-04 (lb/MMBtu)3.13E-02 1.71E-02 1.37E-01 NoToluene2.81E-04 (lb/MMBtu)1.13E-02 6.20E-03 4.96E-02 NoXylenes1.93E-04 (lb/MMBtu)7.78E-03 4.26E-03 3.41E-02 NoFormaldehyde7.89E-05 (lb/MMBtu)3.18E-03 1.74E-03 1.39E-02 YesAcetaldehyde2.52E-05 (lb/MMBtu)1.02E-03 5.56E-04 4.45E-03 YesAcrolein7.88E-06 (lb/MMBtu)3.18E-04 1.74E-04 1.39E-03 Yes
Naphthalene 1.30E-04 (lb/MMBtu)5.24E-03 2.87E-03 2.29E-02 Yes
0.14
0.26
1. Additional polycyclic aromatic hydrocarbon may be emitted but for regulatory purposes, this list is only inclusive of HAPs regulated under the Clean Air Act.
2. Criteria and HAP pollutant emission factors per AP-42, Section 3.4 Large Stationary Diesel Engines (> 600 hp), October 1996.
3. Hourly HAP Emissions (lb/hr) = Heat Input (MMBtu/hr) * EF (lb/MMBtu) * Number of Generators.
4. Annual HAP Emissions (tpy) = Hourly HAP Emissions (lb/hr) * Annual Hours of Operation (hr/yr) / 2000 (lb/ton).
Max HAP
Total HAPs
25
Potential Emissions
100 75 50
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Appendix B - Emissions Calculations
Table B-7. Tank Throughputs
Engine Tanks Throughput
(gal/yr)1,2
C18 Belly Tank 319,740
Total 2,557,920
36.50 (gal/hr)
2. Annual operating time (hr/yr)8760
3. Number of Tanks:8
Table B-8. Tank VOC Potential to Emit
Loading loss emission factor (lb/103 gal)2 0.04
Loading loss all belly tanks (lb/yr)3 99.68
Loading loss all belly tanks (tpy)0.05
Average hourly total loading loss all belly
tanks (lb/hr)0.01
Where,
LL, loading loss (lb/[103 gal of liquid loaded]) =0.04
S, saturation factora =1.45
P, true vapor pressure of diesel (psia)b =6.00E-03
M, molecular weight of diesel (lb/lb-mol)b = 188.00
T, Temperature (R)b =522.97
eff, overall reduction efficiency =0.00
b) AP 42 Table 7.1-7 (°F):63.3
3. Conversion factors:
1000 gal/Mgal
4. Annual operating time (hr/yr):8760
Table B-9. Tank Annual HAP Potential to Emit
Pollutant Vapor HAP
Composition (wt %)1
Average Total Hourly
Emissions All Belly
Tanks (lb/hr)
Total Annual
Emissions All Belly
Tanks (tpy)
Benzene 1.64%1.87E-04 8.17E-04
Ethylbenzene 2.3%2.58E-04 1.13E-03
Hexane 0.3%3.87E-05 1.69E-04
Naphthalene 0.3%3.30E-05 1.45E-04
Toluene 18.2%2.07E-03 9.07E-03
Xylenes 44.0%5.00E-03 2.19E-02
0.02
0.03
1. Determined from TankESP HAPs speciation.
Total HAPs
1. XQ1140 generator fuel consumption specifications:
VOC Emissions1
1. Includes (1) vapors formed in the empty tank by evaporation of residual product
from previous loads, (2) vapors transferred to the tank in vapor balance systems as
product is being unloaded, and (3) vapors generated in the tank as the new product is
being loaded.
2. AP 42 Section 5.2 Transportation and Marketing of Petroleum Liquids
a) AP 42 Table 5.2-1, for splash loading and dedicated normal service.
Max HAPs
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Appendix B - Emissions Calculations
Table B-10. Tank Parameters1
Parameters Value
Tank Type Horizontal Tank
Length (ft)40.00
Width (ft)8.00
Height (ft)9.50
Volume (gal)15,809
Throughput (gal/yr)2,557,920
1. Manufacturer specifications.
Table B-11. Tank Emissions
Pollutant Emissions1 Units
Benzene 0.04 (lb/hr)
Ethylbenzene 0.05 (lb/hr)
Hexane 7.65E-03 (lb/hr)
Naphthalene 6.63E-03 (lb/hr)
Toluene 0.41 (lb/hr)
Xylenes 1.01 (lb/hr)
Total VOCs 1.14E-03 (tpy)
Total HAPs 7.61E-04 (tpy)
1. Emissions calculated using TankESP.
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APPENDIX C. DESIGN SPECIFICATIONS

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