DAQ-2025-002345

DAQE-AN162430001-25

{{$d1 }}

Richard Peary
Ameresco Wasatch RNG LLC
111 Speen Street, Suite 410
Framingham, MA 01701
[e-mail]

Dear Mr. Peary:

Re: Approval Order: New Layton Renewable Natural Gas Facility
Project Number: N162430001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on December
19, 2024. Ameresco Wasatch RNG 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: Davis 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

Tim Davis
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 25, 2025

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-AN162430001-25
New Layton Renewable Natural Gas Facility

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

Issued to
Ameresco Wasatch RNG LLC - Davis Landfill Renewable Natural Gas
Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 25, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 4
Source Classification .............................................................................................................. 4
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN162430001-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ameresco Wasatch RNG LLC Ameresco Wasatch RNG LLC - Davis Landfill Renewable Natural Gas Facility

Mailing Address Physical Address
111 Speen Street, Suite 410 1997 East 3500 North
Framingham, MA 01701 Layton, UT 84040

Source Contact UTM Coordinates
Name: Richard Peary 421,452 m Easting
Phone: [phone],552,288 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
Ameresco Wasatch RNG LLC (Ameresco) has requested to construct a Renewable Natural Gas (RNG)
Facility, which will treat landfill gas and deliver the treated gas to a natural gas pipeline distribution
system in Layton, Davis County. The landfill gas will come from the adjacent Wasatch Integrated Waste
Management District (WIWMD) Davis Landfill.

The raw landfill gas will be delivered to the feed blowers at the inlet of the new Ameresco facility, where
it will be filtered and compressed. The gas then enters a fixed-bed hydrogen sulfide (H2S) removal unit
utilizing activated carbon media before being sent to a temperature or pressure swing adsorption
technology (TSA or PSA) system, where VOCs are removed from the gas stream.

The conditioned gas will then be sent to a carbon dioxide (CO2) separation system and PSA nitrogen (N2)
removal unit to remove CO2 and N2 from the gas. Oxygen (O2) may also be removed from the gas steam
by use of a catalytic oxidation process in a Deoxo system. Gas will then be dehydrated utilizing a TSA
system. The TSA will have closed-loop regeneration and therefore will not vent off-gases.

The processed gas will then be sent to product compressors, where it will be pressurized to meet pipeline
pressure requirements. Through the processes described above, the gas will be filtered, dewatered, and
compressed, thus meeting the definition of "treatment system" in Federal Code 40 CFR 60.41(f). The
waste gas generated from the above processing and treatment system will be sent to a thermal oxidizer or
an open flare.

DAQE-AN162430001-25
Page 4

NSR Classification
New Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Davis County
Airs Source Size: SM

Applicable Federal Standards
None
Project Description
Ameresco has requested to construct an RNG Facility which will treat landfill gas and deliver the treated
gas to a natural gas pipeline distribution system in Layton, Davis County.

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)
Carbon Monoxide 85.41
Nitrogen Oxides 20.15
Particulate Matter - PM10 6.70
Particulate Matter - PM2.5 6.70
Sulfur Dioxide 19.32
Volatile Organic Compounds 10.54

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 1128
Toluene (CAS #108883) 292
Change (TPY) Total (TPY)
Total HAPs 0.71

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]
DAQE-AN162430001-25
Page 5

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 Layton RNG Facility
II.A.2 Landfill Gas Treatment and Processing Equipment II.A.3 H2S Adsorption Treatment System Type: Non-regenerative Dry Granular Media
II.A.4 Thermal Oxidizer (TO) Burner Rating: 4 MMBtu/hr Maximum Inlet Heat Rating: 20.0 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98% II.A.5 Open Flare Burner Rating: 0.1 MMBtu/hr Maximum Inlet Heat Rating: 50 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98%
II.A.6 Storage Tank Content: Landfill Gas Condensate Liquid Capacity: 5,250 gal
DAQE-AN162430001-25
Page 6

II.A.7 Various Components Valves, Pump Seals, Flanges, Fittings, Compressors, Connectors, etc.

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site 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 according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall not combust more than 613,200 million British Thermal Units (MMBtu) of total gas (including waste gas, treated landfill gas, off-specification gas, depress and purge gas, natural gas, product gas, and propane) in the TO 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 gas to the TO and flare through use of instruments that monitor flow volume and methane content

B. Record total heat content of the gas to the TO and flare on a daily basis
C. Use the total heat content of the 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 gas records for all periods the plant is in
operation.
[R307-401-8]
II.B.1.c The owner/operator shall control all emissions from the landfill gas processing and treatment processes with a TO or open flare. All emissions from the landfill gas processing and treatment processes shall be routed through the TO or open flare before being vented to the atmosphere. [R307-401-8]
II.B.2 TO Requirements
II.B.2.a The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8]
II.B.2.a.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TO. [R307-401-8]
II.B.2.b At all times while operating the TO, excluding periods of startup and shutdown, the owner/operator shall maintain a temperature at or above 1,400oF in the thermal oxidizer. [R307-401-8]
II.B.2.b.1 The owner/operator shall monitor and record the operating temperature of the TO once each operating day while the TO is operating. [R307-401-8]
DAQE-AN162430001-25
Page 7

II.B.2.b.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.b.3 The owner/operator shall install, operate, and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8]

II.B.3 H2S Treatment System Requirements II.B.3.a All emissions from the landfill gas processing and treatment processes shall be routed through the H2S treatment system before being routed to the TO or flare. [R307-401-8]

II.B.3.b The owner/operator shall not exceed an H2S concentration of 150 ppmv at the outlet of the H2S treatment system at all times. [R307-401-8]
II.B.3.b.1 The owner/operator shall monitor and record the H2S concentration at the outlet of the H2S treatment system at least once weekly for all periods the plant is in operation. [R307-401-8]

II.B.3.b.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.3.b.3 The owner/operator shall install, operate, and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8]

II.B.4 Open Flare Requirements
II.B.4.a The owner/operator shall operate the flare with no visible emissions. [R307-401-8]
II.B.4.a.1 Visible emissions determinations shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8] II.B.4.b The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter.
[R307-401-8]

II.B.4.c The owner/operator shall install a flare that is guaranteed to meet a VOC control efficiency of no less than 98%. [R307-401-8]
II.B.4.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.5 Condensate Storage Tank Requirements
II.B.5.a The owner/operator shall load the condensate storage tanks on site by the use of submerged loading. [R307-401-8]

II.B.5.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: Is Derived From NOI Application dated December 19, 2024

DAQE-AN162430001-25
Page 8

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-IN162430001-25

March 13, 2025

Richard Peary
Ameresco Wasatch RNG LLC
111 Speen Street, Suite 410
Framingham, MA 01701
[e-mail]

Dear Mr. Peary:

Re: Intent to Approve: New Layton Renewable Natural Gas Facility
Project Number: N162430001

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: Davis 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

Tim Davis
Interim 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-IN162430001-25
New Layton Renewable Natural Gas Facility

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

Issued to
Ameresco Wasatch RNG LLC - Davis Landfill Renewable Natural Gas
Facility

Issued On
March 13, 2025

{{$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 .................................................................................................................. 4
Source Classification .............................................................................................................. 4
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 ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-IN162430001-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ameresco Wasatch RNG LLC Ameresco Wasatch RNG LLC - Davis Landfill Renewable Natural Gas Facility

Mailing Address Physical Address
111 Speen Street, Suite 410 1997 East 3500 North
Framingham, MA 01701 Layton, UT 84040

Source Contact UTM Coordinates
Name: Richard Peary 421,452 m Easting
Phone: [phone],552,288 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
Ameresco Wasatch RNG LLC (Ameresco) has requested to construct a Renewable Natural Gas (RNG)
Facility that will treat landfill gas and deliver the treated gas to a natural gas pipeline distribution system
in Layton, Davis County. The landfill gas will come from the adjacent Wasatch Integrated Waste
Management District (WIWMD) Davis Landfill.

The raw landfill gas will be delivered to the feed blowers at the inlet of the new Ameresco facility, where
it will be filtered and compressed. The gas then enters a fixed-bed hydrogen sulfide (H2S) removal unit
utilizing activated carbon media before being sent to a temperature or pressure swing adsorption
technology (TSA or PSA) system, where VOCs are removed from the gas stream.

The conditioned gas will then be sent to a carbon dioxide (CO2) separation system and PSA nitrogen (N2)
removal unit to remove CO2 and N2 from the gas. Oxygen (O2) may also be removed from the gas steam
by use of a catalytic oxidation process in a Deoxo system. Gas will then be dehydrated utilizing a TSA
system. The TSA will have closed-loop regeneration and therefore will not vent off-gases.

The processed gas will then be sent to product compressors, where it will be pressurized to meet pipeline
pressure requirements. Through the processes described above, the gas will be filtered, de-watered, and
compressed, thus meeting the definition of "treatment system" in Federal Code 40 CFR 60.41(f). The
waste gas generated from the above processing and treatment system will be sent to a thermal oxidizer
(TO) or an open flare.

DAQE-IN162430001-25
Page 4

NSR Classification
New Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA
Davis County
Airs Source Size: SM

Applicable Federal Standards
None
Project Description
Ameresco has requested to construct a RNG Facility, which will treat landfill gas and deliver the treated
gas to a natural gas pipeline distribution system in Layton, Davis County.

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)
Carbon Monoxide 85.41
Nitrogen Oxides 20.15
Particulate Matter - PM10 6.70
Particulate Matter - PM2.5 6.70
Sulfur Dioxide 19.32
Volatile Organic Compounds 10.54

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 1128
Toluene (CAS #108883) 292
Change (TPY) Total (TPY)
Total HAPs 0.71

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 Ogden Standard Examiner on March 17, 2025. During the
public 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
DAQE-IN162430001-25
Page 5
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-IN162430001-25
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 Layton RNG Facility
II.A.2 Landfill Gas Treatment and Processing Equipment II.A.3 H2S Adsorption Treatment System Type: Non-regenerative Dry Granular Media
II.A.4 TO Burner Rating: 4 MMBtu/hr Maximum Inlet Heat Rating: 20.0 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98% II.A.5 Open Flare Burner Rating: 0.1 MMBtu/hr Maximum Inlet Heat Rating: 50 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98%
II.A.6 Storage Tank Content: Landfill Gas Condensate Liquid Capacity: 5,250 gal II.A.7 Various Components Valves, Pump Seals, Flanges, Fittings, Compressors, Connectors, etc.

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 Site-wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site 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 according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not combust more than 613,200 million British Thermal Units (MMBtu) of total gas (including waste gas, treated landfill gas, off-specification gas, depress and purge gas, natural gas, product gas, and propane) in the TO and flare combined per rolling 12-month period. [R307-401-8]
DAQE-IN162430001-25
Page 7

II.B.1.b.1 The owner/operator shall: A. Determine total heat content of the gas to the TO and flare through use of instruments that monitor flow volume and methane content B. Record total heat content of the gas to the TO and flare on a daily basis C. Use the total heat content of the 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 gas records for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall control all emissions from the landfill gas processing and treatment
processes with a TO or open flare. All emissions from the landfill gas processing and treatment
processes shall be routed through the TO or open flare before being vented to the atmosphere. [R307-401-8]

II.B.2 TO Requirements
II.B.2.a The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8]

II.B.2.a.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed TO. [R307-401-8]
II.B.2.b At all times while operating the TO, excluding periods of startup and shutdown, the
owner/operator shall maintain a temperature at or above 1,400oF in the TO. [R307-401-8]

II.B.2.b.1 The owner/operator shall monitor and record the operating temperature of the TO once each operating day while the TO is operating. [R307-401-8]
II.B.2.b.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.b.3 The owner/operator shall install, operate, and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8] II.B.3 H2S Treatment System Requirements
II.B.3.a All emissions from the landfill gas processing and treatment processes shall be routed through the H2S treatment system before being routed to the TO or flare. [R307-401-8] II.B.3.b The owner/operator shall not exceed an H2S concentration of 150 ppmv at the outlet of the H2S
treatment system at all times. [R307-401-8]

II.B.3.b.1 The owner/operator shall monitor and record the H2S concentration at the outlet of the H2S treatment system at least once weekly for all periods the plant is in operation. [R307-401-8]
II.B.3.b.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.3.b.3 The owner/operator shall install, operate, and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8]
DAQE-IN162430001-25
Page 8

II.B.4 Open Flare Requirements II.B.4.a The owner/operator shall operate the flare with no visible emissions. [R307-401-8]

II.B.4.a.1 Visible emissions determinations shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8]
II.B.4.b The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8]
II.B.4.c The owner/operator shall install a flare that is guaranteed to meet a VOC control efficiency of no less than 98%. [R307-401-8] II.B.4.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.5 Condensate Storage Tank Requirements
II.B.5.a The owner/operator shall load the condensate storage tanks on-site by the use of submerged
loading. [R307-401-8]
II.B.5.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: Is Derived From NOI dated December 19, 2024

DAQE-IN162430001-25
Page 9

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-NN162430001-25

March 13, 2025

Ogden Standard Examiner
Legal Advertising Dept.
P.O. Box 12790332 Standard Way
Ogden, UT 84412

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard
Examiner on March 17, 2025.

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: Davis 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

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN162430001-25
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: Ameresco Wasatch RNG LLC
Location: Ameresco Wasatch RNG LLC - Davis Landfill Renewable Natural Gas Facility –
1997 East 3500 North, Layton, UT
Project Description: Ameresco Wasatch RNG LLC (Ameresco) has requested to construct a
Renewable Natural Gas (RNG) Facility that will treat landfill gas and deliver the
treated gas to a natural gas pipeline distribution system in Layton, Davis County.
The landfill gas will come from the adjacent Wasatch Integrated Waste
Management District (WIWMD) Davis Landfill.

The raw landfill gas will be delivered to the feed blowers at the inlet of the new
Ameresco facility, where it will be filtered and compressed. The gas then enters a
fixed-bed hydrogen sulfide (H2S) removal unit utilizing activated carbon media
before being sent to a temperature or pressure swing adsorption technology (TSA
or PSA) system, where VOCs are removed from the gas stream.

The conditioned gas will then be sent to a carbon dioxide (CO2) separation
system and PSA nitrogen (N2) removal unit to remove CO2 and N2 from the gas.
Oxygen (O2) may also be removed from the gas steam by use of a catalytic
oxidation process in a Deoxo system. Gas will then be dehydrated utilizing a
TSA system. The TSA will have closed-loop regeneration and therefore will not
vent off-gases.

The processed gas will then be sent to product compressors, where it will be
pressurized to meet pipeline pressure requirements. Through the processes
described above, the gas will be filtered, de-watered, and compressed, thus
meeting the definition of "treatment system" in Federal Code 40 CFR 60.41(f).
The waste gas generated from the above processing and treatment system will be
sent to a thermal oxidizer or an open flare.

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 April 16, 2025, 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: March 17, 2025
{{#s=Sig_es_:signer1:signature}}
Standard Examiner
Publication Name:
Standard Examiner
Publication URL:
www.standard.net
Publication City and State:
Ogden, UT
Publication County:
Weber
Notice Popular Keyword Category:
Notice Keywords:
ameresco
Notice Authentication Number:
202503170958469843194
2892905420
Notice URL:
Back
Notice Publish Date:
Monday, March 17, 2025
Notice Content
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: Ameresco Wasatch RNG LLC Location: Ameresco Wasatch RNG LLC - Davis
Landfill Renewable Natural Gas Facility - 1997 East 3500 North, Layton, UT Project Description: Ameresco Wasatch RNG LLC (Ameresco) has
requested to construct a Renewable Natural Gas (RNG) Facility that will treat landfill gas and deliver the treated gas to a natural gas pipeline
distribution system in Layton, Davis County. The landfill gas will come from the adjacent Wasatch Integrated Waste Management District
(WIWMD) Davis Landfill. The raw landfill gas will be delivered to the feed blowers at the inlet of the new Ameresco facility, where it will be
filtered and compressed. The gas then enters a fixed-bed hydrogen sulfide (H2S) removal unit utilizing activated carbon media before being
sent to a temperature or pressure swing adsorption technology (TSA or PSA) system, where VOCs are removed from the gas stream. The
conditioned gas will then be sent to a carbon dioxide (CO2) separation system and PSA nitrogen (N2) removal unit to remove CO2 and N2
from the gas. Oxygen (O2) may also be removed from the gas steam by use of a catalytic oxidation process in a Deoxo system. Gas will then
be dehydrated utilizing a TSA system. The TSA will have closed-loop regeneration and therefore will not vent off-gases. The processed gas
will then be sent to product compressors, where it will be pressurized to meet pipeline pressure requirements. Through the processes
described above, the gas will be filtered, de-watered, and compressed, thus meeting the definition of "treatment system" in Federal Code 40
CFR 60.41(f). The waste gas generated from the above processing and treatment system will be sent to a thermal oxidizer or an open flare.
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 April 16, 2025, 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: March 17, 2025 Legal Notice 13834 Published in the Standard Examiner on March 17, 2025
Back
DAQE-

RN162430001 March 6, 2025 Richard Peary
Ameresco Wasatch RNG LLC 111 Speen Street, Suite 410 Framingham, MA 01701
[e-mail] Dear Richard Peary,
Re: Engineer Review: New Layton Renewable Natural Gas (RNG) Facility Project Number: N162430001 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. Ameresco Wasatch RNG LLC should complete this review within 10 business days of receipt. Ameresco Wasatch RNG 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 Ameresco Wasatch RNG LLC does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Ameresco Wasatch RNG 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
Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N162430001 Owner Name Ameresco Wasatch RNG LLC Mailing Address 111 Speen Street, Suite 410
Framingham, MA, 01701 Source Name Ameresco Wasatch RNG LLC- Davis Landfill Renewable
Natural Gas Facility Source Location 1997 East 3500 North Layton, UT 84040
UTM Projection 421,452 m Easting, 4,552,288 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4925 (Mixed, Manufactured, or Liquefied Petroleum Gas Production/Distribution) Source Contact Richard Peary Phone Number [phone] Email [e-mail]
Billing Contact Richard Peary Phone Number [phone] Email [e-mail]
Project Engineer Christine Bodell, Engineer Phone Number [phone]
Email [e-mail] Notice of Intent (NOI) Submitted December 19, 2024 Date of Accepted Application January 14, 2025

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 2
SOURCE DESCRIPTION General Description
Ameresco Wasatch RNG LLC (Ameresco) has requested to construct a Renewable Natural Gas (RNG) Facility which will treat landfill gas and deliver the treated gas to a natural gas pipeline distribution system in Layton, Davis County. The landfill gas will come from the adjacent
Wasatch Integrated Waste Management District (WIWMD) Davis Landfill. The raw landfill gas will be delivered to the feed blowers at the inlet of the new Ameresco facility where it will be filtered and compressed. The gas then enters a fixed-bed hydrogen sulfide (H2S) removal unit utilizing activated carbon media before being sent to a temperature or pressure swing adsorption technology (TSA or PSA) system, where VOCs are removed from the gas stream. The conditioned gas will then be sent to a carbon dioxide (CO2) separation system and PSA nitrogen (N2) removal unit to remove CO2 and N2 from the gas. Oxygen (O2) may also be removed from the gas steam by use of a catalytic oxidation process in a Deoxo system. Gas will
then be dehydrated utilizing a TSA system. The TSA will have closed-loop regeneration and therefore will not vent off-gases.
The processed gas will then be sent to product compressors where it will be pressurized to meet pipeline pressure requirements. Through the processes described above, the gas will be filtered, de-watered and compressed, thus meeting the definition of "treatment system" in Federal Code 40
CFR 60.41(f). The waste gas generated from the above processing and treatment system will be sent to a thermal oxidizer or an open flare. NSR Classification: New Minor Source
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Davis County Airs Source Size: SM Applicable Federal Standards None
Project Proposal New Layton Renewable Natural Gas (RNG) Facility
Project Description Ameresco Wasatch RNG LLC (Ameresco) has requested to construct a Renewable Natural Gas (RNG) Facility which will treat landfill gas and deliver the treated gas to a natural gas pipeline
distribution system in Layton, Davis County. EMISSION IMPACT ANALYSIS
Ameresco does not exceed emission increases in any criteria pollutant or HAPs modeling thresholds outlined in R307-410-4 and R307-410-5, respectively. Therefore, no modeling is required at this time. [Last updated January 14, 2025]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 3

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)
Carbon Monoxide 85.41
Nitrogen Oxides 20.15
Particulate Matter - PM10 6.70 Particulate Matter - PM2.5 6.70 Sulfur Dioxide 19.32
Volatile Organic Compounds 10.54

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 1128 Toluene (CAS #108883) 292 Change (TPY) Total (TPY) Total HAPs 0.71
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding VOC and HAPs Emissions
A maximum daily potential throughput of 90,000 scf/hr of landfill gas flow results in an uncontrolled PTE of 258.04 tpy of VOCs and 12.20 tpy of HAPs. Therefore, a BACT analysis was conducted to reduce VOCS and HAPs emissions. Many HAP components are emitted through the
same process as VOCs and the control technologies for VOCs also control HAPs. Additionally, the new RNG facility is located in the Northern Wasatch Front ozone nonattainment area, which was redesignated from moderate to serious nonattainment in 2025. Therefore, technologies that control ozone "precursor" pollutants like NOx and VOCs, which directly
contribute to the formation of ground-level ozone, are taken into greater account.
Ameresco has elected to install a thermal oxidizer (TO) as the primary control device of routine waste gases generated by the processing of landfill gas into renewable natural gas. A TO was specifically selected instead of an enclosed flare. Enclosed flares and TOs are distinctly different devices due to their design, technology and operational processes. TOs utilize high temperatures to destroy organic compounds by oxidation, and are designed to control gas streams with heat contents insufficient to maintain combustion. The TO will have a manufacturer-provided destruction efficiency of 98% for VOCs and HAPs, reducing VOCs by 247.72 tpy and HAPs by 11.96 tpy. Therefore, except for plant outages, process upsets, purges, receival of off-specification gas, and startup, shutdown, and malfunction situations, BACT is the use of a TO with a minimum VOC and HAP destruction efficiency of 98%. BACT is also limiting visible emissions to 10% opacity.
Ameresco has also elected to install an open flare which will combust intermittent streams of
process waste gases, off-spec gases, startup and shutdown gases, depress and purge gases, treated landfill gas, natural gas, and product RNG. A utility/open flare design is necessary for this application to allow for immediate control of the gas streams in response to system outages or
when off-spec gas is purged from the processing equipment. Open flares are designed to accommodate these scenarios as they can provide control for the wide range of heat contents and flow rates for this application. In contrast, enclosed thermal oxidizers and enclosed flares operate in a much narrower flow range and could not provide control of the anticipated process waste gas streams. The open flare will also have a manufacturer-provided destruction efficiency of 98% for VOCs and HAPs.
Therefore, during plant outages, process upsets, purges, receival of off-specification gas, and
startup, shutdown, and malfunction situations, BACT is the use of a flare with a minimum VOC and HAP destruction efficiency of 98%. BACT is also ensuring there are no visible emissions from the flare.
Use of the thermal oxidizer for routine waste gas and open flare for intermittent streams of process
waste gases, off-spec gases, startup and shutdown gases, depress and purge gases, treated landfill gas, natural gas, and product RNG will create landfill gas and fuel gas combustion air pollutants such as NOx, CO, PM10, PM2.5, VOCs, HAPs, and SO2. Conservatively assuming that both the TO
and flare run 8,760 hours annually, it is estimated that use the TO and flare will result in approximately 20.15 tpy of NOx, 85.41 tpy of CO, 6.70 tpy of PM10, 6.70 tpy of PM2.5, 10.54 tpy of VOCs, 0.24 tpy of HAPs, and 19.32 tpy of SO2.
The facility is also located in a PM2.5 serious nonattainment area. Per 40 CFR 52.21, SO2 and NOx

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 5
are presumed to be precursors to PM2.5. While the use of the flare and TO will emit additional SO2 and NOx, the use of the TO and flare to control VOCs and HAPs is preferable given the drastic
reduction in VOCs. [Last updated February 27, 2025] 2. BACT review regarding Component Fugitive and Condensate Tank Emissions During the processing of renewable natural gas, minimal emissions from component leaks are anticipated. VOC/HAPs emissions associated with equipment leaks are estimated at 0.22 tpy. Due to the relatively low volume of VOC/HAPs emissions, additional add-on control technologies are not technically feasible. Therefore, BACT to control fugitive VOC/HAPs emissions from valves, pump seals, flanges, and fittings is best operating practices. Similarly, VOC emissions associated with the condensate tank and liquid loading operations are anticipated to be <0.01 tpy each of VOCs and HAPs. Therefore, BACT to control VOC and HAPs
emissions from liquid loading operations is submerged loading and best operating practices such as regular inspection of the tanks and ensuring thief hatches are closed. [Last updated February 26, 2025]
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. (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]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 6
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
II.A.1 NEW Layton RNG Facility
II.A.2
NEW
Landfill Gas Treatment and Processing Equipment

II.A.3 NEW Hydrogen Sulfide (H2S) Adsorption Treatment System Type: Non-regenerative Dry Granular Media II.A.4 NEW Thermal Oxidizer Burner Rating: 4 MMBtu/hr Maximum Inlet Heat Rating: 20.0 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98%
II.A.5 NEW Open Flare Burner Rating: 0.1 MMBtu/hr Maximum Inlet Heat Rating: 50 MMBtu/hr Supplemental Fuel: Natural Gas, RNG, or Treated Landfill Gas Minimum VOC Destruction Efficiency: 98%

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 7
II.A.6 NEW Storage Tank Content: Landfill Gas Condensate Liquid Capacity: 5,250 gal

II.A.7 NEW Various Components Valves, Pump Seals, Flanges, Fittings, Compressors, Connectors, etc.
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 NEW Site-wide Requirements
II.B.1.a NEW Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 NEW Unless otherwise specified in this AO, opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b NEW The owner/operator shall not combust more than 613,200 million British Thermal Units (MMBtu) of total gas (including waste gas, treated landfill gas, off-specification gas, depress and purge gas, natural gas, product gas, and propane) in the thermal oxidizer (TO) and flare combined per rolling 12-month period. [R307-401-8] II.B.1.b.1 NEW The owner/operator shall: A. Determine total heat content of the gas to the TO and flare through use of
instruments that monitor flow volume and methane content B. Record total heat content of the gas to the TO and flare on a daily basis C. Use the total heat content of the 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 gas records for all periods the plant is in
operation
[R307-401-8]
II.B.1.c
NEW
The owner/operator shall control all emissions from the landfill gas processing and treatment
processes with a Thermal Oxidizer (TO) or open flare. All emissions from the landfill gas processing and treatment processes shall be routed through the TO or open flare before being vented to the atmosphere. [R307-401-8]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 8
II.B.2 NEW Thermal Oxidizer (TO) Requirements
II.B.2.a NEW The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no less than 98%. [R307-401-8]
II.B.2.a.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the manufacturer's emissions guarantee for the installed TO. [R307-401-8] II.B.2.b NEW At all times while operating the TO, excluding periods of startup and shutdown, the owner/operator shall maintain a temperature at or above 1,400oF in the thermal oxidizer.
[R307-401-8]
II.B.2.b.1 NEW The owner/operator shall monitor and record the operating temperature of the TO once each operating day, while the TO is operating. [R307-401-8]
II.B.2.b.2
NEW
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.b.3 NEW The owner/operator shall install, operate and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8]
II.B.3 NEW H2S Treatment System Requirements
II.B.3.a NEW All emissions from the landfill gas processing and treatment processes shall be routed through the H2S treatment system before being routed to the TO or flare. [R307-401-8]
II.B.3.b NEW The owner/operator shall not exceed an H2S concentration of 150 ppmv at the outlet of the H2S treatment system at all times. [R307-401-8]
II.B.3.b.1 NEW The owner/operator shall monitor and record the H2S concentration at the outlet of the H2S treatment system at least once weekly, for all periods the plant is in operation. [R307-401-8]
II.B.3.b.2
NEW
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.3.b.3 NEW The owner/operator shall install, operate and maintain all monitoring instruments according to the manufacturer's instructions. [R307-401-8] II.B.4 NEW Open Flare Requirements
II.B.4.a NEW The owner/operator shall operate the flare with no visible emissions. [R307-401-8]
II.B.4.a.1 NEW Visible emissions determinations shall be conducted according to 40 CFR 60, Appendix A, Method 22. [R307-401-8]
II.B.4.b NEW The flare shall operate with a continuous pilot flame and be equipped with an auto-igniter. [R307-401-8]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 9
II.B.4.c NEW The owner/operator shall install a flare that is guaranteed to meet a VOC control efficiency of no less than 98%. [R307-401-8]
II.B.4.c.1 NEW 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.5 NEW Condensate Storage Tank Requirements
II.B.5.a NEW The owner/operator shall load the condensate storage tanks on site by the use of submerged loading. [R307-401-8]

II.B.5.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]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 10
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Is Derived From NOI Application dated December 19, 2024
REVIEWER COMMENTS
1. Comment regarding Source Emission Calculations and DAQ Acceptance: TO Emission Estimates CO and NOx emissions from the TO are quantified based on outlet guarantees from the TO vendor of 0.06 lb/MMBtu and 0.20 lb/MMBtu, respectively. These emissions guarantees are inclusive of supplemental natural gas used in the TO. These values are converted to a mass flow basis by multiplying by the maximum heat content to the TO of 20.0 MMBtu/hr. EPA AP-42 Section 2.4, LFG Flare equations 3 & 4 have been used to calculate VOC emissions, along with the manufacturer-provided destruction efficiency of 98% VOC.
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 TO 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 TO and is designed to remove sulfur down to a maximum of 150 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. All hazardous air pollutant (HAP) emissions are calculated using AP-42 Section 2.4 (Municipal Solid Waste Landfills) Table 2.4-5. All organic HAP are assumed to be controlled by at least 98%. Metal HAP are assumed to be uncontrolled.
Flare Emission Estimates
The emissions at the back-up flare are calculated in a similar manner as described above for the TO. However, the major differences between the flare emissions calculation methodology and the TO 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 TO calculations. The control efficiency for the flare is 98%. CO and NOX emissions are based on EPA AP-42 Section 13.5, Industrial Flares. VOCs, PM, SO2, and HAPs were calculated using the same method as the TO.
Tank Emission Estimates Emissions from the new 5,250-gallon condensate liquid storage tank were calculated using EPA TANKS 4.09D. The total VOC emissions from the new tank are expected to be 6.25 lbs/year or 0.003 tpy. This value is too small to be captured in the 'Summary of Emissions' table in the AO.
Component Fugitive Leak Emission Estimates Fugitive Leaks Emissions were calculated based on U.S. EPA's Protocol for Equipment Leak

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 Page 11
Estimates (EPA453/R- 95-017), Table 2-4. The gas VOC concentration was conservatively assumed to be equal to 100% of NMOCs, or 0.2975% per AP-42 Section 2.4 (Municipal Solid Waste
Landfills). Emission estimates are based on the following equipment quantities: 1,500 valves, 1,500 flanges, 20 compressors/treatment skids, 10 open end lines, and 2,000 connectors. [Last updated February 26, 2025]
2. Comment regarding Federal Standard and Title V Applicability: Title V of the 1990 CAA (Title V) applies to the following: A. Any major source B. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources C. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants D. Any Title IV-affected source
This facility is not a major source nor a Title IV source. The facility is not subject to any 40 CFR 60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. Therefore, Title V does not apply to this facility. [Last updated January 24, 2025] 3. Comment regarding Source Classification as a Synthetic Minor (SM):
The major source threshold for the Northern Wasatch. Front Ozone Nonattainment area is 50 tons per year (tpy) each of nitrogen oxides (NOx) and volatile organic compounds (VOCs). The area was redesignated from moderate to serious on January 8, 2025. The new RNG facility has an
uncontrolled PTE of greater than 50 tpy of VOCs.
To ensure Ameresco remains below this threshold, conditions outlined in the AO restrict the PTE from exceeding 50 tpy. Therefore, this source is considered a SM source. [Last updated February 27, 2025]

Engineer Review N162430001: Ameresco Wasatch RNG LLC- Davis Landfill Renewable Natural Gas Facility March 6, 2025 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 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
Operating Parameters Thermal Oxidizer (worst case scenario)
Raw Gas
Operating Hours 8760 hrs/yr
50 % raw gas methane content Input 20 MMBtu/hr
150 ppm gas sulfur content 175,200 MMBtu/yr
0.00015 H2S concentration Flow Rate Raw Gas 1,500 scf/min
13.50 scf/hr H2s 90,000 scf/hr
1.97 lb/hr SO2 788,400,000 scr/year
VOC/HAPs efficency 98 %
34 lb/lbmol H2S
64 lb/lbmol SO2
Pollutant lb/MMBtu lb/MMscf CH4
2,975 ppm raw gas VOC content NOx [1]0.06
0.0029750 VOC concentration CO [1]0.2
267.75 scf/hr VOCs VOCs [2]
57.93 lb/hr VOC PM [3]17
253.7485377 SO2
95 lb/lbmol VOC (avg MWs)HAPs [5]
[1] manuacturer guarantee
42 ppm average HAP [2][3][5] AP-42, Vol. I, CH 2.4: Municipal Solid Waste Landf
0.000042 average HAP concentration [4] AP-42 1.4 Natural Gas Combustion
3.78 scf/hr HAP
1.72 lb/hr HAP
7.541752203 Fuel Gas (NG)
200 lb/lbmol HAP (avg MWs)Input 2.2 MMBtu/hr
Heating Value NG 0.00102 MMBTU/scf
Flow Rate 2,157 scf/hr
7.390917159
Pollutant lb/MMBtu lb/MMscf CH4
NOx [1]0
CO [1]0
VOCs [2]5.5
PM [2]1.9
SO2[2]0.6
HAPs[2]0.0038
[1] manuacturer guarantee, already factored into above c
[2] AP-42 1.4 Natural Gas Combustion
Criteria
Pollutant TO
NOX 5.26
CO 17.52
Fuel Gas
Raw Gas
PM10 3.37
PM2.5 3.37
SO2 8.62
VOC 5.13
HAPs 0.15
*condensate tank results in neglig
HAPS
Toluene
Hydrogen Chloride
Xylenes
Generic
Open Flare (worst case scenario)
Operating Hours 8760 hrs/yr
Input 50 MMBtu/hr
438,000 MMBtu/yr
Flow Rate Raw Gas 1,500 scf/min
90,000 scf/hr
788,400,000 scr/year
VOC/HAPs efficency 98 %
lb/hr tpy Pollutant lb/MMBtu lb/MMscf CH lb/hr
1.20 5.26 NOx [1]0.068 3.40
4.00 17.52 CO [1]0.31 15.50
1.16 5.07 VOCs [2]1.16
0.77 3.35 PM [3]17 0.77
1.97 8.62 SO2 1.97
0.03 0.15 HAPs [5]0.03
[1] manuacturer guarantee
fills [2][3][5] AP-42, Vol. I, CH 2.4: Municipal Solid Waste Landfills
[4] AP-42 1.4 Natural Gas Combustion
Fuel Gas (NG)
Input 0.1 MMBtu/hr
Heating Value NG 0.00102 MMBTU/scf
Flow Rate 98 scf/hr
lb/hr tpy Pollutant lb/MMBtu lb/MMscf CH lb/hr
0.00 0.00 NOx [1]0 0.00
0.00 0.00 CO [1]0 0.00
0.01 0.05 VOCs [2]5.5 0.00
0.00 0.02 PM [2]1.9 0.00
0.00 0.01 SO2[2]0.6 0.00
0.00 0.00 HAPs[2]0.0038 0.00
alcs [1] manuacturer guarantee, already factored into above calcs
[2] AP-42 1.4 Natural Gas Combustion
Flare Fugitives Total NOI Difference
14.89 20.15 20.15 0.00
67.89 85.41 85.41 0.00
Fuel Gas
pg. 50 NOI pg. 56 NOI
Raw Gas
3.35 6.72 6.7 -0.02
3.35 6.72 6.7 -0.02
8.62 17.24 19.32 2.08 *NOI is more accurate du
5.08 0.22 10.43 10.54 0.11 range and are accepted b
0.15 0.22 0.53 0.71 0.18
gable emissions (<0.001 tpy) and are therefore excluded from the estimate
TPY lb/yr
0.1458 291.6
0.0616 123.2
0.0518 103.6
0.4508 901.6
Fugitives
Type Count kg/hr/source[1]lb/hr/source
Valves -Gas 1500 0.0045 0.0099
Flanges - Gas 1500 0.00039 0.0009
Connectors - Gas 2000 0.0002 0.0004
[1]SEPA Protocol for Equipment Leak Emissions Estimates, 435/R-93-026, Nov 1995, T
VOC Gas concentration 0.3 %
tpy Pollutant lb/hr tpy
14.89 VOCs 0.05 0.22
67.89 HAPs 0.05 0.22
5.07
3.35
8.62
0.15
tpy
0.00
0.00
0.00
0.00
0.00
0.00
Fugitives

Table 2-4

NOTICE OF INTENT - AIR CONSTRUCTION
PERMIT APPLICATION

AMERESCO WASATCH RNG LLC
1997 EAST 3500 NORTH
LAYTON, UTAH 84040

Prepared by:

Ameresco Wasatch RNG LLC
111 Speen Street, Suite 410
Framingham, Massachusetts 01701

Submitted to:

Utah Department of Environmental Quality
Division of Air Quality
New Source Review Section
195 North 1950 West
Salt Lake City, Utah 84116

December 19, 2024
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 2

TABLE OF CONTENTS
SECTION PAGE
1 EXECUTIVE SUMMARY .......................................................................................................................................... 3
1.1 LANDFILL FACILITY ..................................................................................................................................... 3
1.2 AMERESCO FACILITY .................................................................................................................................. 3
1.2.1 General ........................................................................................................................................................ 3
1.2.2 Location ...................................................................................................................................................... 3
1.2.3 Gas Treatment System ............................................................................................................................ 4
1.2.4 Hydrogen Sulfide Removal .................................................................................................................... 4
1.2.5 Thermal Oxidizer ...................................................................................................................................... 5
1.2.6 Open Flare .................................................................................................................................................. 5
1.2.7 Condensate Tank...................................................................................................................................... 5
1.2.8 Equipment Fugitives ................................................................................................................................... 5
1.3 POTENTIAL EMISSIONS SUMMARY ........................................................................................................ 6
1.4 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) EVALUATION .............................................. 8
1.4.1 Thermal Oxidizer BACT .......................................................................................................................... 8
1.4.2 Open Flare BACT .................................................................................................................................... 10
1.5 PERMIT TYPE ............................................................................................................................................... 13
1.6 EMISSIONS IMPACT ASSESSMENT / EMISSIONS OFFSETS .......................................................... 13
1.7 PROJECT SCHEDULE ................................................................................................................................ 14
1.8 FACILITY CONTACTS ................................................................................................................................. 14
1.9 APPLICATION PROCESSING & FEE ...................................................................................................... 15
1.10 REGULATORY REVIEW ............................................................................................................................. 15
1.10.1 Title V................................................................................................................................................... 15
1.10.2 Prevention of Significant Deterioration (PSD) .......................................................................... 15
1.10.3 New Source Performance Standards (NSPS)............................................................................ 15
1.10.4 National Emissions Standards for Hazardous Air Pollutants ............................................... 16
1.11 STATIONARY SOURCE EVALUATION ................................................................................................... 16
1.11.1 Industrial Grouping .......................................................................................................................... 16
1.11.2 Contiguous / Adjacent Property ................................................................................................... 16
1.11.3 Common Control .............................................................................................................................. 16
2 UTAH DEQ FORMS ................................................................................................................................................ 18
3 EMISSIONS CACLULATIONS .............................................................................................................................. 19
4 PROCESS FLOW DIAGRAM ................................................................................................................................ 20
5 SITE LOCATION MAP AND SITE PLAN ............................................................................................................ 21
6 VENDOR SPECIFICATIONS ................................................................................................................................. 22

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 3

1 EXECUTIVE SUMMARY

1.1 LANDFILL FACILITY

The existing Wasatch Integrated Waste Management District (WIWMD) Davis Landfill (Landfill)
currently operates under Utah Department of Environmental Quality (UDEQ) Title V Air Operating
Permit No. 1100033004 issued effective September 18, 2024. Decomposition of waste in the
Landfill produces landfill gas (LFG) which is composed of approximately 45-55 percent methane,
35-45 percent carbon dioxide, 5-10 percent nitrogen, and 0-3 percent oxygen, as well as other
trace compounds and water vapor. A gas collection and control system (GCCS) is installed and
operational at the Landfill which collects LFG and delivers it to the Landfill’s flare(s) for destruction.

1.2 AMERESCO FACILITY

1.2.1 General

Ameresco Wasatch RNG LLC (Ameresco) plans to install a renewable natural gas (RNG)
processing facility which will receive landfill gas from the Davis Landfill and process it into RNG
which will be piped to a metering station and injected into a natural gas pipeline. The planned
Ameresco facility will process up to approximately 1,500 scfm of landfill gas and produce up to
approximately 700 scfm of renewable natural gas. Waste gases from the Ameresco gas treatment
process are planned to be combusted in a thermal oxidizer and open flare.

Detailed explanations of the various processes and equipment in the Ameresco facility are
explained in the following sections of this Application. The new Ameresco facility will operate
continuously with occasional downtime for maintenance. Ameresco Wasatch RNG LLC is the
planned legal owner, operator and permittee for the new facility. Ameresco, Inc. is the parent
company of Ameresco Wasatch RNG LLC.

Operation of the Ameresco facility will result in significantly less landfill gas burned in the Landfill
flare(s), as much of the generated landfill gas will instead be processed into renewable natural
gas. The Ameresco project allows for beneficial use of landfill gas which would otherwise be
directly flared to the atmosphere. As a result, the project will provide significant public benefits
that are consistent with the goals, directives, and policies of the UDEQ. The environmental
benefits of this type of project have been proven by operation of several existing Ameresco RNG
facilities in the United States.

1.2.2 Location

The new Ameresco facility is planned to be located on the Davis Landfill property at 1997 East
3500 North, Layton, Utah 84040, as shown on the site location map in Section 5. Ameresco will
lease the land from WIWMD.

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 4

1.2.3 Gas Treatment System

Landfill gas will be delivered to the feed blowers at the inlet of the new Ameresco facility where it
will be filtered and compressed to approximately 10 psig. From the feed blowers, the LFG will
enter a fixed-bed hydrogen sulfide (H2S) removal unit utilizing activated carbon media, after which
it will be dehydrated to approximately 50-degree dew point. This treated landfill gas will then be
sent to the feed compressors which will increase the gas pressure to approximately 250 psig
using oil-flooded screw compressors. The compressed gas will then be cooled to approximately
80-degree Fahrenheit prior to it being further dehydrated and then sent to the gas separation
equipment.

Volatile organic compounds (VOCs), nonmethane organic compounds (NMOCs) and siloxane
compounds will be removed from the gas stream with a Siloxane/VOC removal system using
temperature or pressure swing adsorption technology (TSA or PSA). The conditioned gas will
then be sent to a carbon dioxide (CO2) separation system (membrane system or PSA system) to
remove CO2 from the gas. From the CO2 separation system, the gas will be sent to a PSA
nitrogen (N2) removal unit to remove N2 and some amounts of oxygen (O2) remaining in the gas.
The gas will be further conditioned to remove the remaining O2 by using a catalytic oxidation
process in a Deoxo system. Gas leaving the Deoxo system will be dehydrated utilizing a TSA
system. The TSA will have closed-loop regeneration and therefore will not vent off-gases. The
gas will then be sent to product compressors where it will be pressurized to meet pipeline pressure
requirements. Through the processes described above, the gas will be filtered, de-watered and
compressed, thus meeting the definition of “treatment system” in Federal Code 40 CFR 60.41(f).
A process flow diagram is included in this application which depicts the new facility operating
process.

1.2.4 Hydrogen Sulfide Removal

The H2S removal system will employ a non-regenerative dry granular media, such as activated
carbon. As landfill gas passes through the treatment system, H2S will become contained in the
media. Any non-H2S sulfur species may pass through the system and be present in post-
treatment LFG. Once the media is spent, it will be removed and replaced. The H2S system will
be a pass-through, closed system with no emissions to the atmosphere. The system will have the
ability to operate continuously with occasional downtime for maintenance. The treatment system
is expected to reduce the H2S content of the LFG, however it may not reduce the content of other
sulfur species in the LFG.

This application utilizes a concentration of 150 ppm Total Reduced Sulfur (TRS) for calculation of
the Ameresco devices potential SOx emissions. The landfill gas sulfur content is variable
depending on the decomposing waste, which Ameresco has no control over, and can increase
significantly in a relatively short period of time. Therefore, it is necessary to apply a conservative
buffer during air permitting so as not to establish a permit limit which cannot be met. Ameresco
believes that 150 ppm is an appropriate representation of the landfill gas TRS concentration,
accounting for fluctuations and potential future increases in the gas sulfur concentration, and
accounting for non-H2S sulfur species which are not removed by the treatment system and
therefore are present in gas combusted at the facility.

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 5
1.2.5 Thermal Oxidizer
Waste and off-spec gases produced by the processing of landfill gas will be sent to a thermal
oxidizer (TOX) for destruction. Waste gases from the Siloxane/VOC, CO2 and N2 removal units
will be composed primarily of CO2 and N2 and small amounts of O2, H2O, CH4 and traces of
sulfur. The TOX will operate continuously with occasional downtime for maintenance. The TOX
will require use of supplemental treated landfill gas, natural gas and/or product RNG when the
heat input from waste gas is insufficient for proper combustion. The TOX will utilize an intermittent
pilot burning treated landfill gas, natural gas, product RNG or propane. Potential emissions
calculations for thermal oxidizer are included in Section 3.
1.2.6 Open Flare
The Ameresco facility will include an open flare which will combust intermittent streams of
process waste gases, off-spec gases, startup and shutdown gases, depress and purge
gases, treated landfill gas, natural gas, and product RNG. The open flare may require use
of supplemental treated landfill gas, natural gas and/or product RNG when the heat input
from waste gases is insufficient for proper combustion. The open flare will utilize a continuous
pilot of treated landfill gas, natural gas, product RNG or propane. The operating scenarios for
the open flare may include the following:
•Plant initial commissioning phase
•Plant and equipment startups and shutdowns
•Equipment and piping purging and depressurization
•Upset and transient conditions
Potential emissions calculations for the open flare are included in Section 3.
1.2.7 Condensate Tank
Landfill gas entering the Ameresco facility will contain water vapor. Condensate will be removed
from the gas through a dehydration system which chills the gas to below the water/gas dew point
and causes condensation. The removed condensate will be collected in one (1) 5,250-gallon
capacity tank to be located at the Ameresco facility prior to being pumped into the Landfill’s
leachate system. The condensate tank will be closed however may have atmospheric vents which
release emissions due to vapor displacement during tank filling (withdrawal losses) and liquid
adjustment due to temperature changes (standing losses). Potential air emissions from the
condensate tank are expected to be minimal and insignificant. Potential emissions from the tank
have been calculated using the US EPA TANKS 4.09D model. Emission estimates from the tank
are based on the dimensions and throughput, the vapor pressure of the liquid inside, and the
weather conditions of the area. The model input parameters and model report are included in
Section 3.
1.2.8 Equipment Fugitives
During times when various equipment at the facility is not under vacuum, such as when the plant
is down, a slight possibility exists for equipment to release extremely minor amounts of gas
containing VOCs to the atmosphere. Potential fugitive emissions would be extremely minor and
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 6

Ameresco understands that they are exempt under FDEP Rule 62-4.040(b) (Exemptions).
Potential fugitive VOC emissions were estimated by using the emission factors in the USEPA’s
Protocol for Equipment Leak Emissions Estimates, EPA 435/R-93-026, November 1995, Table
2-4. Please note that the equipment component counts used are conservative estimates of the
maximum expected quantity of components. The actual number of components will be determined
once the facility is constructed, and may be less. The fugitive emission calculations are included
in Section 3.

1.3 POTENTIAL EMISSIONS SUMMARY

As presented in Section 3 of this application, Ameresco has calculated the maximum potential
emissions from the new Ameresco facility. As seen in the attached calculations, Ameresco has
utilized the following key maximum values for the emissions sources:

Thermal Oxidizer:

Potential emissions from the thermal oxidizer have been calculated assuming unrestricted annual
operation of 8,760 hours per 12-months as the device is expected to operate continuously with
minimal downtime.

Thermal Oxidizer Maximum Heat Input:
20.00 MMBtu/hour
480 MMBtu/24-hours
14,880 MMBtu/month
175,200 MMBtu/12-months

Thermal Oxidizer Maximum Flow Rate:
1,500 scfm
90,000 scf/hour
2,160,000 scf/24-hours
66,960,000 scf/month
788,400,000 scf/12-months

Open Flare:

Potential emissions for the open flare have been calculated assuming unrestricted annual
operation at 8,760 hours per 12-months in order to demonstrate that the facility is a true/natural
minor source as opposed to a synthetic minor. However the flare is expected to operate
intermittently for only a fraction of the year, therefore actual flare emissions are expected to be
significantly less than the max PTE emissions shown in this application.

Open Flare Maximum Heat Input:
50.00 MMBtu/hour
1,200 MMBtu/24-hours
37,200 MMBtu/month
438,000 MMBtu/12-months

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 7

Open Flare Maximum Flow Rate:
1,500 scfm
90,000 scf/hour
2,160,000 scf/24-hours
66,960,000 scf/month
788,400,000 scf/12-months

The emissions factors utilized to calculate potential emissions for all pollutants are included in the
emissions calculations in Section 3 of this application.

Table. 1.3.1 Thermal Oxidizer Potential Emissions
Pollutant lb/hour lb/24-hours lb/month lb/12-months ton/12-months
NOx 1.20 28.80 892.80 10,512.00 5.26
CO 4.00 96.00 2,976.00 35,040.00 17.52
VOC 1.18 28.28 876.64 10,321.75 5.16
PM/PM10/PM2.5 0.77 18.36 569.16 6,701.40 3.35
SOx 2.21 52.94 1,641.23 19,324.17 9.66
HAPs 0.06 1.34 41.44 487.88 0.24
GHG as CO2e 5,296 127,108 3,940,346 46,394,393 23,197

Table. 1.3.2 Open Flare Potential Emissions
Pollutant lb/hour lb/24-hours lb/month lb/12-months ton/12-months
NOx 3.40 81.60 2,529.60 29,784.00 14.89
CO 15.50 372.00 11,532.00 135,780.00 67.89
VOC 1.18 28.28 876.64 10,321.75 5.16
PM/PM10/PM2.5 0.77 18.36 569.16 6,701.40 3.35
SOx 2.21 52.94 1,641.23 19,324.17 9.66
HAPs 0.06 1.34 41.44 487.88 0.24
GHG as CO2e 5,296 127,108 3,940,346 46,394,393 23,197

Table. 1.3.3 Condensate Tank Potential Emissions
Pollutant lb/hour lb/24-hours lb/month lb/12-months ton/12-months
VOC 0.001 0.017 0.521 6.25 0.0031
HAPs 0.001 0.017 0.521 6.25 0.0031

Table. 1.3.4 Equipment Fugitives Potential Emissions
Pollutant lb/hour lb/24-hours lb/month lb/12-months ton/12-months
VOC 0.049 1.186 28.466 432.920 0.216
HAPs 0.049 1.186 28.466 432.920 0.216

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 8

Table. 1.3.5 Facility Total Potential Emissions
Pollutant lb/hour lb/24-hours lb/month lb/12-months ton/12-months
NOx 4.60 110.40 3,422.40 40,296.00 20.15
CO 19.50 468.00 14,508.00 170,820.00 85.41
VOC 2.41 57.76 1,782.27 21,082.66 10.54
PM/PM10/PM2.5 1.53 36.72 1,138.32 13,402.80 6.70
SOx 4.41 105.89 3,282.46 38,648.35 19.32
HAPs 0.16 3.88 111.86 1,414.94 0.71
GHG as CO2e 10,592 254,216 7,880,691 92,788,787 46,394

1.4 BEST AVAILABLE CONTROL TECHNOLOGY (BACT) EVALUATION

1.4.1 Thermal Oxidizer BACT

Steps 1 and 2– Identify all control technologies and eliminate technically infeasible options

This planned project will utilize a thermal oxidizer as the primary control device of routine waste
gases generated by the processing of landfill gas into renewable natural gas. A thermal oxidizer
was specifically selected instead of an enclosed flare. Enclosed flares and thermal oxidizers are
distinctly different devices due to their design, technology and operational processes. Thermal
oxidizers utilize high temperatures to destroy organic compounds by oxidation, and are designed
to control gas streams with heat contents insufficient to maintain combustion.

In order to maintain the temperatures necessary for control, thermal oxidizers utilize high-heat
content supplemental fuels. Thermal oxidizers are designed to provide for the variable injection
of supplemental fuel (treated landfill gas, NG or RNG) based on the heat content of the waste gas
stream being controlled. Additionally, thermal oxidizers are designed to provide a sufficient
residence time and turbulence within the combustion zone such that the waste gas, fuel, oxygen,
and heat have thorough contact to provide for complete combustion and waste gas control.
Enclosed flares are designed to maintain temperature solely from combustion of the inlet gas and
are not designed to inject supplemental fuel or to recover heat. The heat content of the various
waste gas streams associated with this process are insufficient to sustain combustion. Therefore,
an enclosed flare is not a technically feasible option for control of the process waste gas streams,
and a thermal oxidizer is necessary for this project.

Ameresco has utilized the following emission factors for the thermal oxidizer in this air permit
application:

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 9

Table 1.4.1 Thermal Oxidizer Emission Factors:
Pollutant Emission
Factor Unit Emission Factor Source
NOx 0.06 lb/MMBtu Manufacturer
CO 0.20 lb/MMBtu Manufacturer
VOC 98% Destruction
efficiency Manufacturer
PM/PM10/PM2.5 17 lb/mmscf CH4 EPA AP-42 Section 2.4 - LFG Flare - Table
2.4-4
SOx 150 ppm TRS Conservative engineering estimate
HAPs 98% Destruction
efficiency
EPA AP-42 Section 2.4 - LFG Flare - Table
2.4-3

NOx:
The thermal oxidizer NOx emission factor of 0.06 lb/MMBtu, provided by the manufacturer, is
believed to be the most representative factor currently available for this device. Ameresco is not
aware of any additional control technologies for a thermal oxidizer for NOx.

CO:
The thermal oxidizer CO emission factor of 0.20 lb/MMBtu, provided by the manufacturer, is
believed to be the most representative factor currently available for this device. Ameresco is not
aware of any additional control technologies for a thermal oxidizer for CO.

VOC:
Ameresco is unaware of an existing US EPA AP-42 section specific to thermal oxidizers, therefore
the EPA AP-42 Section 2.4, LFG Flare equations 3 & 4 have been used to calculate VOC
emissions, along with the manufacturer-provided destruction efficiency of 98% VOC. Ameresco
is not aware of any additional control technologies for a thermal oxidizer for VOC.

PM:
Ameresco is unaware of an existing US EPA AP-42 section specific to thermal oxidizers, therefore
the AP-42 Section 2.4, LFG Flare, Table 2.4-4 factor of 17 lb PM/mmscf CH4 has been used, as
it is believed to be the most representative EPA factor currently available for this device. To
prevent carryover of PM entrained in the raw landfill gas, the gas processed at the Ameresco
facility goes through several steps of submicron filtration and is dehydrated to a dewpoint of
approximately 40 degF prior to being introduced to the process units which generate the waste
gas which is delivered to the TOX. Ameresco is not aware of any additional control technologies
for a thermal oxidizer for PM.

SOx:
The use of an H2S gas treatment system to reduce the H2S content of the landfill gas entering
the Ameresco plant is considered BACT for this project. The H2S removal system will employ a
non-regenerative dry granular media, such as activated carbon. As landfill gas passes through
the treatment system, H2S will become contained in the media. Any non-H2S sulfur species may
pass through the system and be present in post-treatment LFG. Once the media is spent, it will
be removed and replaced. The H2S system will be a pass-through, closed system with no
emissions to the atmosphere. The system will have the ability to operate continuously with
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 10
occasional downtime for maintenance. The treatment system is expected to reduce the H2S
content of the LFG, however it may not reduce the content of other sulfur species in the LFG.
This application utilizes a concentration of 150 ppm Total Reduced Sulfur (TRS) for calculation of
the Ameresco devices potential SOx emissions. The landfill gas sulfur content is variable
depending on the decomposing waste, which Ameresco has no control over, and can increase
significantly in a relatively short period of time. Therefore, it is necessary to apply a conservative
buffer during air permitting so as not to establish a permit limit which cannot be met. Ameresco
believes that 150 ppm is an appropriate representation of the landfill gas TRS concentration,
accounting for fluctuations and potential future increases in the gas sulfur concentration, and
accounting for non-H2S sulfur species which are not removed by the treatment system and
therefore are present in gas combusted at the facility.
HAPs:
Ameresco is unaware of an existing US EPA AP-42 section specific to thermal oxidizers, therefore
the EPA AP-42 Section 2.4 landfill gas HAPs concentrations and equations 3 & 4 have been used
to calculate HAP emissions, along with the AP-42 Section 2.4 Table 2.4-3 destruction efficiency
of 98% VOC. Ameresco is not aware of any additional control technologies for a thermal oxidizer
for HAPs.
Step 3 – Rank remaining control technologies by effectiveness
There are no other available control technologies identified, therefore this step is not applicable.
Step 4 – Evaluate the most effective controls
No additional controls were identified, therefore this step is not applicable.
Step 5 – Select BACT
The USEPA has established that enclosed combustion devices designed and operated with good
combustion practices and maintenance practices achieve a performance appropriate for their
intended purpose, therefore Ameresco believes that this standard is BACT for this project, along
with the emission factors and sulfur treatment explained above. Once the plant is constructed
and operating, Ameresco will be able to source test the thermal oxidizer and produce device-
specific emission factors for CO, NOx, VOC, PM and SOx which will be used to calculate actual
emissions from the unit.
1.4.2 Open Flare BACT
Steps 1 and 2– Identify all control technologies and eliminate technically infeasible options
The Ameresco facility will include an open flare which will combust intermittent streams of
process waste gases, off-spec gases, startup and shutdown gases, depress and purge
gases, treated landfill gas, natural gas, and product RNG. The open flare may require use
of supplemental treated landfill gas, natural gas and/or product RNG when the heat input
from waste gases is insufficient for proper combustion. The open flare will utilize a continuous
pilot of treated landfill gas, natural gas, product RNG or propane.
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 11

An open flare was specifically selected for this aspect of the project instead of a thermal oxidizer
or an enclosed flare. A utility/open flare design is necessary for this application to allow for
immediate control of the gas streams in response to system outages or when off-spec gas is
purged from the processing equipment. The utility flare will be equipped with a continuous pilot to
allow for the immediate control of these gas streams during these instances. In contrast to utility
flares, the startup sequence associated with an enclosed thermal oxidizer or enclosed flare allows
gas to build up within the enclosure, resulting in a potential explosion hazard. As such, enclosed
thermal oxidizers and enclosed flares are not a safe, technically-feasible option for this
application. Furthermore, the different process waste gas streams requiring control have highly
variable heat contents and wide flow ranges. Open flares are designed to accommodate these
scenarios as they can provide control for the wide range of heat contents and flow rates for this
application. In contrast, enclosed thermal oxidizers and enclosed flares operate in a much
narrower flow range and could not provide control of the anticipated process waste gas streams.

Ameresco has utilized the following emission factors for the open flare in this air permit
application:

Table 1.4.2 Open Flare Emission Factors:
Pollutant Emission
Factor Unit Emission Factor Source
NOx 0.068 lb/MMBtu Manufacturer, EPA AP-42 Section 13.5,
Industrial Flares
CO 0.31 lb/MMBtu Manufacturer, EPA AP-42 Section 13.5,
Industrial Flares
VOC 98% Destruction
efficiency EPA AP-42 Section 2.4
PM/PM10/PM2.5 17 lb/mmscf CH4 EPA AP-42 Section 2.4 - LFG Flare - Table
2.4-4
SOx 150 ppm TRS Conservative engineering estimate
HAPs 98% Destruction
efficiency
EPA AP-42 Section 2.4 - LFG Flare - Table
2.4-3

NOx:
The open flare NOx emission factor of 0.068 lb/MMBtu, provided by the manufacturer and also
contained in USEPA AP-42 Section 13.5 for Industrial Flares, is believed to be the most
representative factor currently available for this device. Ameresco is not aware of any additional
control technologies for an open flare for NOx.

CO:
The open flare CO emission factor of 0.31 lb/MMBtu, provided by the manufacturer and also
contained in USEPA AP-42 Section 13.5 for Industrial Flares, is believed to be the most
representative factor currently available for this device. Ameresco is not aware of any additional
control technologies for an open flare for CO.

VOC:
The USEPA Section 2.4, LFG Flare, Table 2.4-3 flare destruction efficiency of 98% VOC has been
used to calculate VOC emissions from the open flare. Ameresco is not aware of any additional
control technologies for an open flare for VOC.

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 12

PM:
The USEPA AP-42 Section 2.4, LFG Flare, Table 2.4-4 factor of 17 lb PM/mmscf CH4 has been
used, as it is believed to be the most representative EPA factor currently available for this device.
To prevent carryover of PM entrained in the raw landfill gas, the gas processed at the Ameresco
facility goes through several steps of submicron filtration and is dehydrated to a dewpoint of
approximately 40 degF prior to being introduced to the process units which generate the gasws
which are delivered to the open flare. Ameresco is not aware of any additional control
technologies for an open flare for PM.

SOx:
The use of an H2S gas treatment system to reduce the H2S content of the landfill gas entering
the Ameresco plant is considered BACT for this project. The H2S removal system will employ a
non-regenerative dry granular media, such as activated carbon. As landfill gas passes through
the treatment system, H2S will become contained in the media. Any non-H2S sulfur species may
pass through the system and be present in post-treatment LFG. Once the media is spent, it will
be removed and replaced. The H2S system will be a pass-through, closed system with no
emissions to the atmosphere. The system will have the ability to operate continuously with
occasional downtime for maintenance. The treatment system is expected to reduce the H2S
content of the LFG, however it may not reduce the content of other sulfur species in the LFG.

This application utilizes a concentration of 150 ppm Total Reduced Sulfur (TRS) for calculation of
the Ameresco devices potential SOx emissions. The landfill gas sulfur content is variable
depending on the decomposing waste, which Ameresco has no control over, and can increase
significantly in a relatively short period of time. Therefore, it is necessary to apply a conservative
buffer during air permitting so as not to establish a permit limit which cannot be met. Ameresco
believes that 150 ppm is an appropriate representation of the landfill gas TRS concentration,
accounting for fluctuations and potential future increases in the gas sulfur concentration, and
accounting for non-H2S sulfur species which are not removed by the treatment system and
therefore are present in gas combusted at the facility.

HAPs:
The USEPA AP-42 Section 2.4 landfill gas HAPs concentrations and equations 3 & 4 have been
used to calculate HAP emissions, along with the AP-42 Section 2.4 Table 2.4-3 destruction
efficiency of 98% VOC. Ameresco is not aware of any additional control technologies for an open
flare for HAPs.

Step 3 – Rank remaining control technologies by effectiveness

There are no other available control technologies identified, therefore this step is not applicable.

Step 4 – Evaluate the most effective controls

No additional controls were identified, therefore this step is not applicable.

Step 5 – Select BACT

The USEPA has established that open flares designed and operated with good combustion
practices and maintenance practices achieve a performance appropriate for their intended
purpose, therefore Ameresco believes that this standard is BACT for this project, along with the
emission factors and sulfur treatment explained above.

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 13

1.5 PERMIT TYPE

The maximum potential emissions from the planned Ameresco plant are below the major source
significance levels for all pollutants, which are as follows:

Pollutant PTE Major Source Threshold (ton/yr)
NOx: 40
CO: 100
VOC: 100
PM10: 15
PM2.5: 10
SOx: 40

Because the maximum potential emissions are calculated assuming unrestricted (8,760
hours/year) operation, Ameresco understands this project to be a True/Natural Minor facility, and
not a major source or Title V facility.

1.6 EMISSIONS IMPACT ASSESSMENT / EMISSIONS OFFSETS

The proposed Ameresco Wasatch RNG LLC facility does not have potential air emissions at levels
which would trigger an emissions impact assessment to demonstrate compliance with the NAAQS
and PSD increments (R307-410-4). The UDEQ has established minimum emission rate increase
levels for new sources or existing sources, above which air dispersion modeling is required to be
performed by the applicant. The requirement to perform modeling depends on the attainment
status of project area. The area in which the Ameresco plant is to be located is classified
nonattainment for ozone (moderate), and attainment for all other criteria pollutants. For those
pollutants in attainment, project potential emissions are below the levels at which dispersion
modeling is required per R307-410-4, as follows:

Pollutant Emissions Levels Requiring Modeling (tons/year)
SO2 40
NO2 40
PM10 - fugitive emissions 5
PM10 - non-fugitive emissions 15
PM2.5 – combined non-fugitive
emissions, fugitive dust, and
fugitive emissions 10
CO 100

Ameresco understands that UDEQ currently does not require sources to perform dispersion
modeling for pollutants that are not in attainment of the NAAQS if the source is located in an area
that is nonattainment for that pollutant, but that sources are required to meet the following:

1. Meet applicable offsetting requirements per R307-403-4 through 403-7.
2. New or modified sources located outside a nonattainment area having a combined
emissions increase of NO2, SO2, and PM10 greater than 25 TPY are required to submit
a dispersion modeling analysis of the proposed source’s impact on the nonattainment
area. If the source’s combined NO2, SO2, and PM10 impact on the nonattainment area is
greater than 1.0 μg/m3 annually or 3.0 μg/m3 for a 24-hour averaging period, emission
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 14

offsets are required (R307-403-5(1)(e). If a source’s impact is less than the concentration
levels listed above, no emission offsets are required.

Because the project is not a new major source or major modification, ozone offsets are not
required.

1.7 PROJECT SCHEDULE

Ameresco tentatively plans to begin construction of the new facility in Quarter 3 2025 (pending air
permit issuance). Construction is expected to continue for approximately 12 months, with initial
startup of the facility occurring in shortly thereafter. The initial commissioning phase is expected
to take approximately 2 months, with the plant achieving normal operating conditions thereafter.
All schedule estimates above are subject to change.

1.8 FACILITY CONTACTS

The facility contacts relevant to this application are as follows:

Responsible Official:

Mr. Robert Meharg
Vice President – Asset Operations
111 Speen Street, Suite 410
Framingham, MA 01701
[phone]
[e-mail]

Application Contacts:

Mr. Richard Peary
Compliance Director
111 Speen Street, Suite 410
Framingham, MA 01701
[phone]
[e-mail]

Ms. Stevia Smith
Manager – RNG Compliance
111 Speen Street, Suite 410
Framingham, MA 01701
[phone]
[e-mail]

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 15

1.9 APPLICATION PROCESSING & FEE

Ameresco is requesting regular processing of this application under UDEQ’s Notice of Intent
approval process. Ameresco understands that expedited processing is not available, and is not
being requested. Per UDEQ’s current permitted fee schedule, Ameresco understand that the fee
for this application is as follows:

New Minor Source or Minor Modification at Minor or Major Source:
Filing Fee: $575
Review Fee: $2,500
Total: $3,075

Ameresco understands that if additional UDEQ review time beyond 20 hours, Ameresco will be
invoices for such fees by UDEQ. Ameresco has paid this fee online via UDEQ’s permitting
payment portal at the time of application submission.

1.10 REGULATORY REVIEW

1.10.1 Title V

Title V is a Federal program designed to standardize air quality permits and the permitting process
for major sources of emissions. The name "Title V" comes from Title V of the 1990 federal Clean
Air Act Amendments which required that the U.S. Environmental Protection Agency (EPA)
establish a national operating permit program. Accordingly, EPA adopted regulations [Title 40 of
the Code of Federal Regulations, Chapter 1, Part 70 (Part 70)], which required states and local
permitting authorities to develop and submit a federally enforceable operating permit programs
for EPA approval.

1.10.2 Prevention of Significant Deterioration (PSD)

The Prevention of Significant Deterioration (PSD) air quality regulations apply to construction of
a new major stationary source or a project at an existing major stationary source. The planned
Ameresco facility is not a major stationary source as it does not have the potential to emit 250
tons per year or more of a regulated new source review pollutant. Therefore, PSD requirements
do not apply to the planned Ameresco project.

1.10.3 New Source Performance Standards (NSPS)

1.10.3.1 40 CFR 60 Subpart XXX, Municipal Solid Waste Landfills That Commenced
Construction, Reconstruction, or Modification After July 17, 2014

All landfill gas entering the Ameresco facility will be filtered, de-watered and compressed,
therefore the facility Treatment System is subject to the NSPS 40 CFR 60 Subpart XXX. The
facility thermal oxidizer and open flare are not subject to the NSPS Subpart XXX as they will
receive treated landfill gas. In accordance with 40 CFR 60.766, Ameresco will be required to
maintain and operate monitoring systems associated with the treatment system in accordance
with a site-specific treatment system monitoring plan and calibrate, maintain, and operate
according to the manufacturer's specifications a device that records flow to the treatment system
and bypass of the treatment system (if applicable). A treatment system monitoring plan will be
required to include all details specified in 40 CFR 60.768(b)(5)(ii).
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 16

1.10.4 National Emissions Standards for Hazardous Air Pollutants

1.10.4.1 40 CFR 63, Subpart AAAA, Municipal Solid Waste Landfills

All landfill gas entering the Ameresco facility will be filtered, de-watered and compressed,
therefore the facility Treatment System is subject to the NSPS 40 CFR 63 Subpart AAAA. The
facility thermal oxidizer and open flare are not subject to the NESHAP Subpart AAAA as they will
receive treated landfill gas. In accordance with 40 CFR 63.1961, Ameresco will be required to
calibrate, maintain, and operate according to the manufacturer's specifications a device that
records flow to the treatment system and bypass of the treatment system (if applicable), and
maintain and operate all monitoring systems associated with the treatment system in accordance
with the site-specific treatment system monitoring plan. A treatment system monitoring plan will
be required to include all details specified in 40 CFR 63.1983(b)(5)(ii).

1.11 STATIONARY SOURCE EVALUATION

In order to determine regulatory applicability for proposed projects, a stationary source valuation
must be performed. A stationary source means any building, structure, facility, or installation that
emits or may emit any regulated air pollutant or any pollutant listed under section 112(b) of the
Clean Air Act. Ameresco understands that the EPA instructs that three (3) criteria must be met
in determining if multiple emission sources and activities are considered part of the same single
source for air permitting purposes, as follow:

1. Belong to the same industrial grouping,
2. Are located on one or more contiguous or adjacent property, and
3. Are under common control.

The following sections evaluate these three aspects.

1.11.1 Industrial Grouping

The planned Ameresco facility is best described by the Standard Industrial Classification (SIC)
code 4925: Mixed, Manufactured, or Liquefied Petroleum Gas Production and/or Distribution.
Ameresco understands that the Davis Landfill is best described by code 4953: Refuse Systems,
which is typically used for municipal solid waste landfills. Therefore, the Ameresco facility belong
to a different industrial grouping than the Davis Landfill.

1.11.2 Contiguous / Adjacent Property

The Ameresco facility will be physically located onsite at the Davis Landfill on a leased area of
land. Therefore, the Ameresco facility and the Landfill are located on a contiguous property.

1.11.3 Common Control

As stated in a letter from Mr. William Wehrum of the EPA Office of Air and Radiation to the
Honorable Patrick McDonnell of the Pennsylvania Department of Environmental Protection dated
April 30, 2018, the EPA’s assessment of “control” for Title V and NSR permitting purposes focuses
on the “power or authority of one entity to dictate decisions of the other that could affect the
applicability of, or compliance with, relevant air pollution regulatory requirements.” Based on this
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 17

determination by the EPA, Ameresco has further evaluated the relationship between its facility
and the Landfill and has determined that the two are not under common control.

Ameresco, Inc. is the parent company of Ameresco Wasatch RNG LLC, who is the owner and
operator of the new Ameresco facility. The Davis Landfill is owned by the Wasatch Integrated
Waste Management District, which has no relationship to Ameresco, Inc. or Ameresco Wasatch
RNG LLC. Ameresco Wasatch RNG LLC, a commercial entity, and Wasatch Integrated Waste
Management District, a municipal entity, are owned and operated separately. The two entities do
not perform any activities related to operation of each other’s facilities, and do not share
employees, management, administrative functions, equipment, or training activities. Each entity
is also unable to restrict the other’s use of its own facility.

Ameresco Wasatch RNG LLC and the Wasatch Integrated Waste Management District-Davis
Landfill are not dependent on each other for compliance with Federal or State regulatory
emissions limitations and requirements. The Ameresco plant is a voluntary installation which is
not required for emissions compliance. The Landfill includes permitted flare(s) which can combust
all landfill gas collected from the landfill. When the Ameresco facility ceases acceptance of landfill
gas from the Landfill for either planned or unplanned reasons, the Landfill combusts all collected
gas in its flare(s) in the same manner as was done prior to the construction of the Ameresco plant.
Ameresco and the Landfill will hold separate air permits and be subject to individual emissions
limits contained in those permits based on separate potential emissions calculations performed
by both entities. Neither entity bears responsibility for the emissions projections produced by the
other, and neither party has control over the other’s compliance with emissions limits.

Ameresco and the Landfill are subject to different sets of regulatory requirements. The Landfill’s
current air permit contains requirements relevant to a municipal solid waste landfill facility, and
Ameresco’s future air permit will contain requirements applicable to a renewable gas processing
facility, and the compliance obligations for both entities are distinctly different.

Ameresco and the Landfill have a mutually beneficial contractual agreement. However, this
business arrangement provides no power or authority to dictate the decisions of each other.
Common control is not shared by Ameresco Wasatch RNG LLC and the Wasatch Integrated
Waste Management District Davis Landfill and the facilities do not belong to the same industrial
grouping, therefore the Ameresco and Landfill facilities have met only one of the three necessary
criteria, and therefore are not a single source and should maintain regulatory separation.

Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 18

2 UTAH DEQ FORMS
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
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
References/assumptions, SDS, for each calculation and pollutant
All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
Visibility impact analysis, Class I area impact 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.
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information
1. Name of process: 2. End product of this process:
3. Process Description*:
Operating Data
4. Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6. Maximum Hourly production (indicate units.):
_____________
7. Maximum annual production (indicate units):
________________
8. Type of operation:
Continuous Batch Intermittent
9. If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
Utah Division of Air Quality
New Source Review Section Company___________________________
Site/Source__________________________
Form 4 Date_______________________________
Flare Systems
Equipment Information
1. Manufacturer:
Model no.:
if available)
2. Design and operation shall be in accordance with 40CFR63.11. In addition
to the information listed in this form, provide the following: an assembly
drawing with dimensions, interior dimensions and features, flare’s
maximum capacity in BTU/hr.
3.Characteristics of Waste Gas Stream Input
Components Min. Value Expected
scfm @ 68 oF, 14.7 psia)
Ave. Value Expected
scfm @ 68oF, 14.7 psia)
Design Max.
scfm @ 68oF, 14.7 psia)
a.
b.
c.
d.
e.
f.
g.
h.
4. Percent of time this
condition occurs
5. Flow rate: Minimum Expected Design Maximum Temp oF Pressure (psig)
Waste Gas Stream _______________ _______________ _______ ____________
Fuel Added to Gas Stream _______________ _______________ _______ ____________
Heat content of the gas to be flared ______________ BTU/ft3
6. Number of pilots 7. Type of fuel 8. Fuel Flow Rate (scfm @ 68oF & 14.7 psia) per pilot
Page 1 of 3
Ameresco Wasatch RNG LLC
Ameresco Wasatch RNG LLC
Waste gases, off-spec gases, purge gases, depress gases, treated landfill gas, NG, RNG, propane 0 scfm 1,500 scfm 1,500 scfm
Varies Varies Varies
Varies
Varies
1,500 scfm
1,500 scfm
Approx. 1,400 - 2,000
Approx. 1,400 - 2,000
TBD
TBD
Varies
1
Waste gases, off-spec gases, purge gases, depress gases, treatedlandfill gas, NG, RNG, propane 1,500 scfm total gases
MRW or equivalent
Thermal Oxidizer
12/19/2024
Page 2 of 3
Flare Systems
Form 4
Continued)
Steam Injection
9. Steam pressure (psig)
Minimum Expected __________________
Design Maximum __________________
10. Total steam flow Rate (lb/hr)
11. Temperature (oF) 12. Velocity (ft/sec)
13. Number of jet streams 14. Diameter of steam jets (inches)
15. Design basis for steam injected (lb steam/lb hydrocarbon)
Water Injection
16. Water pressure (psig)
Minimum Expected __________________
Design Maximum __________________
17. Total Water Flow Rate (gpm)
Minimum Expected __________________
Design Maximum __________________
18. Number of water jets 19. Diameter of Water jets (inches)
20. Flare height (ft) 21. Flare tip inside diameter (ft)
Emissions Calculations (PTE)
22. Calculated emissions for this device
PM10 _________Lbs/hr_________ Tons/yr PM2.5 __________Lbs/hr________ Tons/yr
NOx __________Lbs/hr_________ Tons/yr SOx ___________Lbs/hr________ Tons/yr
CO __________Lbs/hr_________ Tons/yr VOC ___________Lbs/hr________Tons/yr
CO2 _________Tons/yr CH4 ___________Tons/yr
N2O _________Tons/yr
HAPs_________Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
N/A
N/A
N/A
N/A N/A
N/A N/A
N/A
N/A
N/A
N/A
N/A
N/A N/A
5430
0.77 3.35
1.20 5.26
4.00 17.52
23,079
0.28
0.77 3.35
2.21 9.66
1.18 5.16
1.42
0.06 0.24
Utah Division of Air Quality
New Source Review Section Company___________________________
Site/Source__________________________
Form 4 Date_______________________________
Flare Systems
Equipment Information
1. Manufacturer:
Model no.:
if available)
2. Design and operation shall be in accordance with 40CFR63.11. In addition
to the information listed in this form, provide the following: an assembly
drawing with dimensions, interior dimensions and features, flare’s
maximum capacity in BTU/hr.
3.Characteristics of Waste Gas Stream Input
Components Min. Value Expected
scfm @ 68 oF, 14.7 psia)
Ave. Value Expected
scfm @ 68oF, 14.7 psia)
Design Max.
scfm @ 68oF, 14.7 psia)
a.
b.
c.
d.
e.
f.
g.
h.
4. Percent of time this
condition occurs
5. Flow rate: Minimum Expected Design Maximum Temp oF Pressure (psig)
Waste Gas Stream _______________ _______________ _______ ____________
Fuel Added to Gas Stream _______________ _______________ _______ ____________
Heat content of the gas to be flared ______________ BTU/ft3
6. Number of pilots 7. Type of fuel 8. Fuel Flow Rate (scfm @ 68oF & 14.7 psia) per pilot
Page 1 of 3
Ameresco Wasatch RNG LLC
Ameresco Wasatch RNG LLC
Waste gases, off-spec gases, purge gases, depress gases, treated landfill gas, NG, RNG, propane 0 scfm 1,500 scfm 1,500 scfm
Varies Varies Varies
Varies
Varies
1,500 scfm
1,500 scfm
Approx. 1,400 - 2,000
Approx. 1,400 - 2,000
TBD
TBD
Varies
1
Waste gases, off-spec gases, purge gases, depress gases, treatedlandfill gas, NG, RNG, propane 1,500 scfm total gases
12/19/2024
MRW or equivalent
Open Flare
Page 2 of 3
Flare Systems
Form 4
Continued)
Steam Injection
9. Steam pressure (psig)
Minimum Expected __________________
Design Maximum __________________
10. Total steam flow Rate (lb/hr)
11. Temperature (oF) 12. Velocity (ft/sec)
13. Number of jet streams 14. Diameter of steam jets (inches)
15. Design basis for steam injected (lb steam/lb hydrocarbon)
Water Injection
16. Water pressure (psig)
Minimum Expected __________________
Design Maximum __________________
17. Total Water Flow Rate (gpm)
Minimum Expected __________________
Design Maximum __________________
18. Number of water jets 19. Diameter of Water jets (inches)
20. Flare height (ft) 21. Flare tip inside diameter (ft)
Emissions Calculations (PTE)
22. Calculated emissions for this device
PM10 _________Lbs/hr_________ Tons/yr PM2.5 __________Lbs/hr________ Tons/yr
NOx __________Lbs/hr_________ Tons/yr SOx ___________Lbs/hr________ Tons/yr
CO __________Lbs/hr_________ Tons/yr VOC ___________Lbs/hr________Tons/yr
CO2 _________Tons/yr CH4 ___________Tons/yr
N2O _________Tons/yr
HAPs_________Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
N/A
N/A
N/A
N/A N/A
N/A N/A
N/A
N/A
N/A
N/A
N/A
N/A N/A
35
0.77 3.35
3.40 14.89
15.50 67.89
23,079
0.28
0.77 3.35
2.21 9.66
1.18 5.16
1.42
0.240.06
14
Page 1 of 1
Company___________________________
_____________________________
Form
Emissions Information
Criteria/GHGs/
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
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 19

3 EMISSIONS CACLULATIONS
POTENTIAL AIR EMISSIONS CALCULATIONSPROJECT PROFILE
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
Value Unit Source
1,020 Btu/scf
0.00102 MMBtu/scf
Raw gas methane content:50%%Engineering estimate
Raw gas VOC content:2,975 ppm as hexane EPA AP-42 Section 2.4, VOCs assumed equivalent to NMOCs, with 5x factor applied to account
for potential future increases in landfill gas VOC content.
Gas sulfur content:150 ppm TRS
Estimate which accounts for potential fluctuations and increase in the landfill gas sulfur
concentration, and accounts for non-H2S sulfur species that are not removed by the H2S
treatment system and are released as SO2 from the control devices.
1,500 scf/min
90,000 scf/hour
2,160,000 scf/day
66,960,000 scf/mo
788,400,000 scf/year
Ameresco plant inlet gas capacity:Engineering estimate
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
Methane heat content:EPA AP-42 Section 1.4
12/19/2024
POTENTIAL AIR EMISSIONS CALCULATIONS
FACILITY TOTAL MAXIMUM POTENTIAL EMISSIONS SUMMARY
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
lb/hour lb/24-hours lb/month lb/12-months ton/12-months
1.20 28.80 892.80 10,512.00 5.26
4.00 96.00 2,976.00 35,040.00 17.52
1.18 28.28 876.64 10,321.75 5.16
0.77 18.36 569.16 6,701.40 3.35
2.21 52.94 1,641.23 19,324.17 9.66
0.06 1.34 41.44 487.88 0.24
5,296 127,108 3,940,346 46,394,393 23,197
DEVICE ID:
lb/hour lb/24-hours lb/month lb/12-months ton/12-months
3.40 81.60 2,529.60 29,784.00 14.89
15.50 372.00 11,532.00 135,780.00 67.89
1.18 28.28 876.64 10,321.75 5.16
0.77 18.36 569.16 6,701.40 3.35
2.21 52.94 1,641.23 19,324.17 9.66
0.06 1.34 41.44 487.88 0.24
5,296 127,108 3,940,346 46,394,393 23,197
DEVICE ID:
lb/hour lb/24-hours lb/month lb/12-months ton/12-months
0.001 0.017 0.521 6.25 0.0031
0.001 0.017 0.521 6.25 0.0031
DEVICE ID:
lb/hour lb/24-hours lb/month lb/12-months ton/12-months
0.049 1.186 28.466 432.920 0.216
0.049 1.186 28.466 432.920 0.216
DEVICE ID:Facility Total Maximum Potential
lb/hour lb/24-hours lb/month lb/12-months ton/12-months
4.60 110.40 3,422.40 40,296.00 20.15
19.50 468.00 14,508.00 170,820.00 85.41
2.41 57.76 1,782.27 21,082.66 10.54
1.53 36.72 1,138.32 13,402.80 6.70
4.41 105.89 3,282.46 38,648.35 19.32
0.16 3.88 111.86 1,414.94 0.71
10,592 254,216 7,880,691 92,788,787 46,394
Open Flare
GHG as CO2e
Pollutant
NOx
CO
SOx
HAPs
VOC
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
PM/PM10/PM2.5
Thermal Oxidizer
Pollutant
NOx
CO
VOC
PM/PM10/PM2.5
SOx
HAPs
GHG as CO2e
SOx
Pollutant
NOx
CO
VOC
PM/PM10/PM2.5
HAPs
Condensate Tank
Pollutant
VOC
Equipment Fugitives
Pollutant
VOC
HAPs
HAPs
GHG as CO2e
POTENTIAL AIR EMISSIONS CALCULATIONS
THERMAL OXIDIXER POTENTIAL EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Value Unit Source
1,020 Btu/scf
0.00102 MMBtu/scf
VOC destruction efficiency:98%%Manufacturer
Gas exhaust temperature 25 degC EPA AP-42 Section 2.4
Sulfur molar mass 32 grams-per-mole
24 hours/day
744 hours/month
8,760 hours/year
20.00 MMBtu/hour
480 MMBtu/day
14,880 MMBtu/month
175,200 MMBtu/year
1,500 scf/min
90,000 scf/hour
2,160,000 scf/day
66,960,000 scf/month
788,400,000 scf/year
Pollutant Emission Factor Unit EF Source lb/hr lb/day lb/mo lb/yr ton/yr
NOx 0.06 lb/MMBtu Manufacturer 1.20 28.80 892.80 10,512.00 5.26
CO 0.20 lb/MMBtu Manufacturer 4.00 96.00 2,976.00 35,040.00 17.52
VOC 2,975 ppm as hexane inlet Engineering estimate
98% DE, EPA AP-42 Section 2.4 - Equations 3 & 4 1.18 28.28 876.64 10,321.75 5.16
PM/PM10/PM2.5 17 lb PM/mmscf CH4 inlet EPA AP-42 Section 2.4 - LFG Flare - Table 2.4-4 0.77 18.36 569.16 6,701.40 3.35
SOx 150 ppm TRS Engineering estimate
EPA AP-42 Section 2.4 - Equations 3 & 4 2.21 52.94 1,641.23 19,324.17 9.66
CO2 52.07 kg/MMBtu 40 CFR 98, Subpart C, Table C-1 5,269.07 126,458 3,920,188 46,157,057 23,079
CH4 as CO2e 0.0032 kg/MMBtu 40 CFR 98, Subpart C, Table C-2
GWP = 25 8.10 194.29 6,022.95 70,915 35.46
N2O as CO2e 0.00063 kg/MMBtu 40 CFR 98, Subpart C, Table C-2
GWP = 298 19.00 455.95 14,134.36 166,421 83.21
Total GHG as CO2e 5,296.16 127,108 3,940,346 46,394,393 23,197
Methane heat content:EPA AP-42 Section 1.4
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Thermal Oxidizer
Operating hours:Maxiumum unrestricted
Inlet gas capacity:
Engineering estimate
Engineering estimate
POTENTIAL AIR EMISSIONS CALCULATIONS
OPEN FLARE POTENTIAL EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Value Unit Source
1,020 Btu/scf
0.00102 MMBtu/scf
VOC destruction efficiency:98%%Manufacturer
Gas exhaust temperature 25 degC EPA AP-42 Section 2.4
Sulfur molar mass 32 grams-per-mole
24 hours/day
744 hours/month
8,760 hours/year
50.00 MMBtu/hour
1,200 MMBtu/day
37,200 MMBtu/month
438,000 MMBtu/year
1,500 scf/min
90,000 scf/hour
2,160,000 scf/day
66,960,000 scf/month
788,400,000 scf/year
Pollutant Emission Factor Unit EF Source lb/hr lb/day lb/mo lb/yr ton/yr
NOx 0.068 lb/MMBtu Manufacturer, EPA AP-42 Section 13.5, Industrial
Flares 3.40 81.60 2,529.60 29,784.00 14.89
CO 0.31 lb/MMBtu Manufacturer, EPA AP-42 Section 13.5, Industrial
Flares 15.50 372.00 11,532.00 135,780.00 67.89
VOC 2,975 ppm as hexane inlet Engineering estimate
98% DE, EPA AP-42 Section 2.4 - Equations 3 & 4 1.18 28.28 876.64 10,321.75 5.16
PM/PM10/PM2.5 17 lb PM/mmscf CH4 inlet EPA AP-42 Section 2.4 - LFG Flare - Table 2.4-4 0.77 18.36 569.16 6,701.40 3.35
SOx 150 ppm TRS Engineering estimateEPA AP-42 Section 2.4 - Equations 3 & 4 2.21 52.94 1,641.23 19,324.17 9.66
CO2 52.07 kg/MMBtu 40 CFR 98, Subpart C, Table C-1 5,269.07 126,458 3,920,188 46,157,057 23,079
CH4 as CO2e 0.0032 kg/MMBtu 40 CFR 98, Subpart C, Table C-2
GWP = 25 8.10 194.29 6,022.95 70,915 35.46
N2O as CO2e 0.00063 kg/MMBtu 40 CFR 98, Subpart C, Table C-2
GWP = 298 19.00 455.95 14,134.36 166,421 83.21
Total GHG as CO2e 5,296.16 127,108 3,940,346 46,394,393 23,197
Operating hours:Maxiumum unrestricted
Inlet gas capacity:
Engineering estimate
Engineering estimate
Methane heat content:EPA AP-42 Section 1.4
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Open Flare
POTENTIAL AIR EMISSIONS CALCULATIONS
CONDENSATE TANK POTENTIAL EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Orientation:Vertical
Height (ft):13
Diameter (ft):10
Volume (gal):5,250
Liquid Height Max (ft):9.5
Liquid Height Avg (ft):9
Turnovers (#/yr):185
Throughput (gal/yr):1,032,567
Atmospheric data source - City, State Salt Lake City, Utah
Fuel Type:Distallate Fuel Oil No. 2
Pollutant Notes lb/hr lb/day lb/month lb/yr ton/yr
VOC See attached US EPA TANKS 4.09D
model report 0.001 0.02 0.52 6.25 0.003
HAPs HAPs emissions assumed to be
equivalent to VOCs 0.001 0.02 0.52 6.25 0.003
Note: The vapor pressure and molecular weight of diesel
were conservatively assumed as the properties of LFG
condensate, for lack of better option.
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Condensate Tank
USEPA TANKS 4.09D Model Inputs:
POTENTIAL AIR EMISSIONS CALCULATIONS
EQUIPMENT FUGITIVES POTENTIAL EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Gas VOC Concentration (ppm):2,975 Source: AP-42 Section 2.4, VOCs conservatively estimated equal to 100% of NMOCs
Gas VOC Concentration (%):0.2975%
Maximum Potential VOC and HAP Emissions:
Equipment Emission Factor Unit EF Source Estimated Count lb/hr lb/day lb/mo lb/yr ton/yr
Valves 0.0099 lb/hr 1,500 0.044 1.063 32.938 387.819 0.194
Flanges 0.001 lb/hr 1,500 0.004 0.092 2.855 33.611 0.017
Compressors/Treatment Skids/Other 0.01940 lb/hr 20 0.001 0.028 0.859 10.112 0.005
Open End Lines 0.0053 lb/hr 10 0.000 0.004 0.117 1.379 0.001
Connectors 0.000 lb/hr 2,000 0.003 0.063 1.952 22.982 0.011
Total:5,030 0.05 1.19 28.47 432.92 0.22
Note: HAPs are assumed equivalent to VOCs.
USEPA Protocol for Equipment
Leak Emissions Estimates,
435/R-93-026, Nov 1995, Table
2-4
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Equipment Fugitives
POTENTIAL AIR EMISSIONS CALCULATIONS
THERMAL OXIDIZER POTENTIAL HAZARDOUS AIR POLLUTANT EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Value Unit
1,020 Btu/scf
0.00102 MMBtu/scf
HAP destruction efficiency 98.0%%
Gas exhaust temperature 25 degC
1,500 scf/min
90,000 scf/hr
2,160,000 scf/day
66,960,000 scf/month
788,400,000 scf/year
Pollutant CAS No.Molecular Weight
(g/mol)
Concentration
(ppmv)Concentration Source lb/hr lb/day lb/mo lb/yr ton/yr
1,1,1-Trichloroethane (methyl chloroform)71556 133.42 0.48 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.94E-04 7.06E-03 2.19E-01 2.58E+00 1.29E-03
1,1,2,2-Tetrachloroethane 79345 167.86 1.11 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.56E-04 2.06E-02 6.37E-01 7.50E+00 3.75E-03
1,1-Dichloroethane (ethylidene dichloride)75343 98.96 2.350 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.07E-03 2.57E-02 7.95E-01 9.36E+00 4.68E-03
1,1-Dichloroethene (vinylidene chloride)75354 96.95 0.200 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.91E-05 2.14E-03 6.63E-02 7.81E-01 3.90E-04
1,2-Dichloroethane (ethylene dichloride)107062 98.96 0.41 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.86E-04 4.48E-03 1.39E-01 1.63E+00 8.17E-04
1,2-Dichloropropane (propylene dichloride)78875 112.99 0.180 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)9.35E-05 2.24E-03 6.95E-02 8.19E-01 4.09E-04
Acrylonitrile*107131 53.06 6.330 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.54E-03 3.70E-02 1.15E+00 1.35E+01 6.76E-03
Benzene*71432 78.11 1.91 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)6.86E-04 1.65E-02 5.10E-01 6.01E+00 3.00E-03
Carbon disulfide*75150 76.14 0.58 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.03E-04 4.87E-03 1.51E-01 1.78E+00 8.89E-04
Carbon tetrachloride 56235 153.84 0.004 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.83E-06 6.79E-05 2.10E-03 2.48E-02 1.24E-05
Carbonyl sulfide*463581 60.07 0.490 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.35E-04 3.25E-03 1.01E-01 1.18E+00 5.92E-04
Chlorobenzene 108907 112.56 0.250 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.29E-04 3.10E-03 9.62E-02 1.13E+00 5.66E-04
Chloroethane (ethyl chloride)75003 64.52 1.250 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)3.71E-04 8.90E-03 2.76E-01 3.25E+00 1.62E-03
Chloroform 67663 119.39 0.030 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.65E-05 3.95E-04 1.22E-02 1.44E-01 7.21E-05
Dichlorobenzene 95501 147.00 0.21 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.42E-04 3.40E-03 1.06E-01 1.24E+00 6.21E-04
Dichloromethane (methylene chloride)75092 84.94 14.300 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)5.58E-03 1.34E-01 4.15E+00 4.89E+01 2.44E-02
Ethylbenzene*100414 106.16 4.61 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.25E-03 5.40E-02 1.67E+00 1.97E+01 9.85E-03
Hexane*110543 86.17 6.570 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.60E-03 6.24E-02 1.94E+00 2.28E+01 1.14E-02
Hydrochloric Acid (hydrogen chloride)7647010 36.46 42.0 USEPA AP-42 Section 2.4 (Nov. 1998)7.04E-03 1.69E-01 5.24E+00 6.16E+01 3.08E-02
Mercury (total)*7439976 200.61 0.00029 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.69E-07 6.46E-06 2.00E-04 2.36E-03 1.18E-06
Methyl ethyl ketone*78933 72.11 7.09 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.35E-03 5.64E-02 1.75E+00 2.06E+01 1.03E-02
Methyl isobutyl ketone*108101 100.07 1.87 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.60E-04 2.06E-02 6.40E-01 7.53E+00 3.77E-03
Perchloroethylene (tetrachloroethylene)127184 165.85 3.730 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.84E-03 6.82E-02 2.12E+00 2.49E+01 1.25E-02
Toluene*108883 92.13 39.300 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.66E-02 3.99E-01 1.24E+01 1.46E+02 7.29E-02
Trichloroethylene (trichloroethene)79016 131.39 2.820 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.70E-03 4.09E-02 1.27E+00 1.49E+01 7.46E-03
Vinyl chloride 75014 62.50 7.340 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.11E-03 5.06E-02 1.57E+00 1.85E+01 9.23E-03
Xylenes*1330207 106.16 12.10 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)5.90E-03 1.42E-01 4.39E+00 5.17E+01 2.59E-02
Total HAPs:0.06 1.34 41.44 488 0.24
Single Highest HAP:0.02 0.40 12.38 146 0.07
Inlet gas capacity:Engineering estimate
Source
Methane heat content:EPA AP-42 Section 1.4
AP-42 Section 2.4, Table 2.4-3
EPA AP-42 Section 2.4
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Thermal Oxidizer
POTENTIAL AIR EMISSIONS CALCULATIONS
OPEN FLARE POTENTIAL HAZARDOUS AIR POLLUTANT EMISSIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
DEVICE ID:
Value Unit
1,020 Btu/scf
0.00102 MMBtu/scf
HAP destruction efficiency 98.0%%
Gas exhaust temperature 25 degC
1,500 scf/min
90,000 scf/hr
2,160,000 scf/day
66,960,000 scf/month
788,400,000 scf/year
Pollutant CAS No.Molecular Weight
(g/mol)
Concentration
(ppmv)Concentration Source lb/hr lb/day lb/mo lb/yr ton/yr
1,1,1-Trichloroethane (methyl chloroform)71556 133.42 0.48 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.94E-04 7.06E-03 2.19E-01 2.58E+00 1.29E-03
1,1,2,2-Tetrachloroethane 79345 167.86 1.11 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.56E-04 2.06E-02 6.37E-01 7.50E+00 3.75E-03
1,1-Dichloroethane (ethylidene dichloride)75343 98.96 2.350 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.07E-03 2.57E-02 7.95E-01 9.36E+00 4.68E-03
1,1-Dichloroethene (vinylidene chloride)75354 96.95 0.200 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.91E-05 2.14E-03 6.63E-02 7.81E-01 3.90E-04
1,2-Dichloroethane (ethylene dichloride)107062 98.96 0.41 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.86E-04 4.48E-03 1.39E-01 1.63E+00 8.17E-04
1,2-Dichloropropane (propylene dichloride)78875 112.99 0.180 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)9.35E-05 2.24E-03 6.95E-02 8.19E-01 4.09E-04
Acrylonitrile*107131 53.06 6.330 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.54E-03 3.70E-02 1.15E+00 1.35E+01 6.76E-03
Benzene*71432 78.11 1.91 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)6.86E-04 1.65E-02 5.10E-01 6.01E+00 3.00E-03
Carbon disulfide*75150 76.14 0.58 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.03E-04 4.87E-03 1.51E-01 1.78E+00 8.89E-04
Carbon tetrachloride 56235 153.84 0.004 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.83E-06 6.79E-05 2.10E-03 2.48E-02 1.24E-05
Carbonyl sulfide*463581 60.07 0.490 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.35E-04 3.25E-03 1.01E-01 1.18E+00 5.92E-04
Chlorobenzene 108907 112.56 0.250 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.29E-04 3.10E-03 9.62E-02 1.13E+00 5.66E-04
Chloroethane (ethyl chloride)75003 64.52 1.250 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)3.71E-04 8.90E-03 2.76E-01 3.25E+00 1.62E-03
Chloroform 67663 119.39 0.030 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.65E-05 3.95E-04 1.22E-02 1.44E-01 7.21E-05
Dichlorobenzene 95501 147.00 0.21 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.42E-04 3.40E-03 1.06E-01 1.24E+00 6.21E-04
Dichloromethane (methylene chloride)75092 84.94 14.300 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)5.58E-03 1.34E-01 4.15E+00 4.89E+01 2.44E-02
Ethylbenzene*100414 106.16 4.61 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.25E-03 5.40E-02 1.67E+00 1.97E+01 9.85E-03
Hexane*110543 86.17 6.570 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.60E-03 6.24E-02 1.94E+00 2.28E+01 1.14E-02
Hydrochloric Acid (hydrogen chloride)7647010 36.46 42.0 USEPA AP-42 Section 2.4 (Nov. 1998)7.04E-03 1.69E-01 5.24E+00 6.16E+01 3.08E-02
Mercury (total)*7439976 200.61 0.00029 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.69E-07 6.46E-06 2.00E-04 2.36E-03 1.18E-06
Methyl ethyl ketone*78933 72.11 7.09 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.35E-03 5.64E-02 1.75E+00 2.06E+01 1.03E-02
Methyl isobutyl ketone*108101 100.07 1.87 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)8.60E-04 2.06E-02 6.40E-01 7.53E+00 3.77E-03
Perchloroethylene (tetrachloroethylene)127184 165.85 3.730 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.84E-03 6.82E-02 2.12E+00 2.49E+01 1.25E-02
Toluene*108883 92.13 39.300 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.66E-02 3.99E-01 1.24E+01 1.46E+02 7.29E-02
Trichloroethylene (trichloroethene)79016 131.39 2.820 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)1.70E-03 4.09E-02 1.27E+00 1.49E+01 7.46E-03
Vinyl chloride 75014 62.50 7.340 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)2.11E-03 5.06E-02 1.57E+00 1.85E+01 9.23E-03
Xylenes*1330207 106.16 12.10 USEPA AP-42 Section 2.4, Table 2.4-1 (Nov. 1998)5.90E-03 1.42E-01 4.39E+00 5.17E+01 2.59E-02
Total HAPs:0.06 1.34 41.44 488 0.24
Single Highest HAP:0.02 0.40 12.38 146 0.07
Inlet gas capacity:Engineering estimate
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
Open Flare
Source
Methane heat content:EPA AP-42 Section 1.4
AP-42 Section 2.4, Table 2.4-3
EPA AP-42 Section 2.4
EMISSION SOURCES SPECIFICATIONS
PLANT NAME:
PLANT LOCATION:
PROJECT:
DATE:
Device ID Device Description
Stack Release
Height Above
Ground
(ft)
Stack Release
Internal
Diameter
(in)
Max Exhaust
Flow Rate
(acfm)
Max Exit
Velocity
(ft/sec)
Combustion
Temp
(degF)
Exhaust
Discharge
Orientation
Rain
Cover
TBD Thermal Oxidizer 30 54 1,870 9 Approx. 1,400 -
2,000
Vertical
Unobstructed No
TBD Open Flare 35 14 N/A 45.8 Approx. 1,400 -
2,000
Vertical
Unobstructed No
Ameresco Wasatch RNG LLC
Layton, Utah
Notice of Intent Air Construction Permit Application
12/19/2024
TANKS 4.0.9d
Emissions Report - Detail Format
Tank Indentification and Physical Characteristics
Identification
User Identification: Wasatch RNG 5,250 Gal Condensate Tank
City: Layton
State: UtahCompany: Ameresco Wasatch RNG LLCType of Tank: Vertical Fixed Roof TankDescription: 5,250-Gallon Condensate Tank
Tank DimensionsShell Height (ft): 13.00Diameter (ft): 10.00Liquid Height (ft) : 9.50
Avg. Liquid Height (ft): 9.00
Volume (gallons): 5,250.00
Turnovers: 185.00Net Throughput(gal/yr): 1,032,567.40Is Tank Heated (y/n): N
Paint Characteristics
Shell Color/Shade: White/WhiteShell Condition GoodRoof Color/Shade: White/WhiteRoof Condition: Good
Roof Characteristics
Type: DomeHeight (ft) 0.00Radius (ft) (Dome Roof) 0.00
Breather Vent Settings
Vacuum Settings (psig): -0.03Pressure Settings (psig) 0.03
Meterological Data used in Emissions Calculations: Salt Lake City, Utah (Avg Atmospheric Pressure = 12.64 psia)
Page 1 of 6TANKS 4.0 Report
12/10/2024file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
TANKS 4.0.9d
Emissions Report - Detail Format
Liquid Contents of Storage Tank
Wasatch RNG 5,250 Gal Condensate Tank - Vertical Fixed Roof Tank
Layton, Utah
Daily Liquid Surf.Temperature (deg F)
Liquid
BulkTemp Vapor Pressure (psia)
VaporMol.LiquidMass VaporMass Mol. Basis for Vapor Pressure
Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations
Distillate fuel oil no. 2 All 53.92 47.99 59.86 51.98 0.0053 0.0042 0.0065 130.0000 188.00 Option 1: VP50 = .0045 VP60 = .0065
Page 2 of 6TANKS 4.0 Report
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TANKS 4.0.9d
Emissions Report - Detail Format
Detail Calculations (AP-42)
Wasatch RNG 5,250 Gal Condensate Tank - Vertical Fixed Roof Tank
Layton, Utah
Annual Emission Calcaulations
Standing Losses (lb): 0.6963 Vapor Space Volume (cu ft): 368.0301 Vapor Density (lb/cu ft): 0.0001 Vapor Space Expansion Factor: 0.0416 Vented Vapor Saturation Factor: 0.9987
Tank Vapor Space Volume: Vapor Space Volume (cu ft): 368.0301 Tank Diameter (ft): 10.0000 Vapor Space Outage (ft): 4.6859 Tank Shell Height (ft): 13.0000 Average Liquid Height (ft): 9.0000 Roof Outage (ft): 0.6859
Roof Outage (Dome Roof)
Roof Outage (ft): 0.6859 Dome Radius (ft): 10.0000 Shell Radius (ft): 5.0000
Vapor Density Vapor Density (lb/cu ft): 0.0001 Vapor Molecular Weight (lb/lb-mole): 130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0053 Daily Avg. Liquid Surface Temp. (deg. R): 513.5939
Daily Average Ambient Temp. (deg. F): 51.9625 Ideal Gas Constant R (psia cuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 511.6525 Tank Paint Solar Absorptance (Shell): 0.1700 Tank Paint Solar Absorptance (Roof): 0.1700 Daily Total Solar Insulation Factor (Btu/sqft day): 1,452.1184
Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.0416 Daily Vapor Temperature Range (deg. R): 23.7301 Daily Vapor Pressure Range (psia): 0.0023 Breather Vent Press. Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0053 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 0.0042
Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia): 0.0065 Daily Avg. Liquid Surface Temp. (deg R): 513.5939 Daily Min. Liquid Surface Temp. (deg R): 507.6614 Daily Max. Liquid Surface Temp. (deg R): 519.5264 Daily Ambient Temp. Range (deg. R): 23.3583
Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.9987 Vapor Pressure at Daily Average Liquid:
Surface Temperature (psia): 0.0053 Vapor Space Outage (ft): 4.6859
Working Losses (lb): 5.5540 Vapor Molecular Weight (lb/lb-mole): 130.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.0053 Annual Net Throughput (gal/yr.): 1,032,567.4044 Annual Turnovers: 185.0000 Turnover Factor: 0.3288
Maximum Liquid Volume (gal): 5,250.0000 Maximum Liquid Height (ft): 9.5000 Tank Diameter (ft): 10.0000 Working Loss Product Factor: 1.0000
Total Losses (lb): 6.2503
Page 3 of 6TANKS 4.0 Report
12/10/2024file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
Page 4 of 6TANKS 4.0 Report
12/10/2024file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
TANKS 4.0.9d
Emissions Report - Detail Format
Individual Tank Emission Totals
Emissions Report for: Annual
Wasatch RNG 5,250 Gal Condensate Tank - Vertical Fixed Roof TankLayton, Utah
Losses(lbs)
Components Working Loss Breathing Loss Total Emissions
Distillate fuel oil no. 2 5.55 0.70 6.25
Page 5 of 6TANKS 4.0 Report
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Page 6 of 6TANKS 4.0 Report
12/10/2024file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 20

4 PROCESS FLOW DIAGRAM
PROCESS FLOW DIAGRAM - AMERESCO WASATCH RNG LLC
AMERESCO
THERMAL
OXIDIZER
AMERESCO GAS
PROCESSING &
TREATMENT EQUIPMENT
AMERESCO
OPEN FLARE
Treated
landfill gas,
waste gases,
off-spec,
depress &
purge gases
Product gas/RNG PIPELINE
INTERCONNECT
STATION
Ameresco Facility
Product gas
/ RNG
NG
NG
Propane
Emissions
Emissions
DAVIS
LANDFILL
LANDFILL
FLARES
Landfill gas
Propane
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 21

5 SITE LOCATION MAP AND SITE PLAN
SITE LOCATION MAP – AMERESCO WASATCH RNG LLC

Proposed Ameresco
Wasatch RNG LLC
Facility Location
EQUIPMENT LIST
1
REV DATE DESCRIPTION DRN BY CHK BY APRV BY
DRAWING NO.
ENGINEER:
LFG TO RNG UPGRADING
FACILITY
BIOGAS
ENGINEERING
OWNER:
CONFIDENTIAL
3816 STINEMAN CT, SUITE 203
LONG BEACH, CA 90808
EMAIL: [e-mail]
PLOT PLAN
G2.00
4
19
3
2A
227
8 65
5A 6A9A9B
10
21
24 25
11
26
18
15
13
12A
16
17
14A 14B
20
23
12
1A 13A 15A
2B
28
27
Notice of Intent Application – Ameresco Wasatch RNG
December 19, 2024
Page 22

6 VENDOR SPECIFICATIONS

December 9th, 2024
Ameresco
Attention: Scott Hill
Subject: Thermal Oxidizer for Guild 2 stage 1,500 scfm system for
Wasatch project - unpriced
MRW #B-240619-01
Dear Scott:

Thank you for the opportunity to present our proposal for the supply
of an MRW Thermal Oxidizer System. The proposed system
incorporates MRW’s proprietary burner design that allows our
oxidizer to efficiently combust low heating value waste streams that
are mostly CO2. To accomplish this, MRW incorporates a
sophisticated burner design that is proven, versatile, and reliable.

The MRW Thermal Oxidizer described herein includes the following:

• One (1) MRW Vertical Upfired Thermal Oxidizer.
• Combustion air blowers
• One (1) MRW Pilot monitored via UV flame scanner. MRW pilots are
designed for fast, reliable ignition and use in severe weather
conditions.
• One (1) Rack-Mounted NEMA 4 Automatic Ignition and Control
System capable of automatic ignition of the pilot, automatic
temperature control, and integrated permissive cycle.

MRW manufactures the best custom combustion equipment built.
Our staff has over 250 years of combustion system design and
fabrication experience. We believe our experience and dedication to
customer satisfaction are unmatched in the industry. We offer you
the confidence of hundreds of successful systems and a team
dedicated to meeting your requirements.
The principals of MRW have spent our entire careers designing and
building combustion systems. Our reputations are impeccable and
we have always met the customer’s requirements. We will maintain
this record as we continue to provide the most current combustion
technology to meet customer needs.

Keith Herbert, Principal Engineer, cell 918-740-0540

Ameresco Page 2 of 6

PROCESS SPECIFICATIONS

Table 1: Process Design Basis: per the October 30th, 2024 email both streams combined or BGZ waste gas
only
BGZWaste Gas steady state flow 680 scfm
Base composition 1.43% methane
Steady state heat release 0.53 MM BTU/hr

Eq PSA Tail Gas steady state flow 168 scfm
Base composition 18.3% methane
Steady state heat release 1.7 MM BTU/hr
ESTIMATED FUEL GAS (MMBtu/hr)
As Required – 2.2
MM BTU/hr
expected during
normal operation –
up to 4 MM BTU/hr
for startup
DESIGN TEMPERATURE (oF) 1550 - 1600

Exhaust Flow Rate( scfm) 1870 at 1550F
Exhaust exit velocity ( fps) 9
Exhaust release point I.D ( in) 49.5

General Design Notes:

➢ The design destruction removal efficiency (DRE) for the
thermal oxidizer is 98% of all non-methane hydrocarbons
(NMHC).
➢ We are now designing to meet an ultra low NOX emission
level of 0.06 lb NOX per MM BTU/hr system heat release and a
CO emission level of 0.20 lb CO per MM BTU/hr system heat
release
➢ We have designed for 1550-1600F but we reserve the right to
run at up to 1800F if needed to meet emissions.
➢ Note: the process design envelope is now restricted to the
steady state conditions. The startup/upset conditions are now
diverted to the flare and enriched until the plant lines out and
the streams can be safely/properly directed to the TOX.
➢ Siloxanes, we will want to understand the potential level of
siloxanes and jointly develop a project strategy to address.

Ameresco Page 3 of 6

UTILITIES

Table 2: Combustion System Utilities
SERVICE UTILITIES
Pilot Fuel Gas 0.1 MMBTU/HR of nat gas at 60 psig
Panel Power 110VAC/1/60Hz
Blower Power 480V/3 phase
Inst Air Available at 80 PSIG for Actuators

EQUIPMENT DESCRIPTION – THERMAL OXIDIZER

1. Thermal Oxidizer→ One (1) MRW Thermal Oxidizer complete with the
following features:

1.1. Vertical, cylindrical combustor – 4.5’ dia by 30’ tall
1.2. The firebox shell will be of A-36 or equal
material welded to AWS standards.
1.3. The shell will be lined with Two (2) - 1-inch
layers of ceramic blanket staggered layers) on
pins and keepers. All seams are overlapped in
all directions to compensate for shrinkage of
the blanket after exposure to high
temperatures.
1.4. Nozzles as follows:
1.4.1. One (1) 4-inch flanged sight port.
1.4.2. One (1) UV flame scanner port.
1.4.3. Two (2) 1-inch thermocouple connections.
1.4.4. One (1) MRW waste gas connection.
1.4.5. One (1) MRW pilot assembly.
1.5. Combustor exterior shall receive a shop sandblast and one (1)
coat of inorganic primer.
1.6. Special alloy rain cap/refractory protector to prevent rain end
soak of the refractory.
1.7. Two (2) flanged 4-inch NPS flue gas sample ports orientated 90o
apart and located 1/2 diameter below the stack exit.
1.8. Lifting Lugs to be located at the top of the stack for easy initial
installation.

Ameresco Page 4 of 6

2. Core Gas Burner→ The MRW Core burner will come complete with
the following features:

2.1. Flanged connection.
2.2. One (1) burner tip of stainless steel & high temperature refractory.
2.3. One (1) MRW electrically ignited pilot assembly.

3. Waste Gas Injectors→ MRW Waste Gas Injectors will be located
adjacent to the core burner.

4. Control/Ignition System→ One (1) MRW Control Panel/Ignition
system complete with the following components:

4.1. One (1) carbon steel ignition panel designed to meet
NEMA 4 requirements.
4.2. MRW PLC burner management system.
4.3. Electrical classification is Class 1 div 2
4.4. Pilot Ignition Type:
4.4.1. Flame Front Generator (FFG)
4.4.2. Self-Inspirated Flame Front Generator (SI-FFG)
- No compressed air is required.
4.4.3. Electric Spark Ignition (EFG)
4.5. Ignition:
4.5.1. Manual – The pilot shall be manually ignited
via push-button-activation
4.5.2. Auto Ignition - Spark igniting device and ignition
transformer is included to ignite the pilot.
4.5.3. Auto Re-Ignition - The pilot temperature switches shall
automatically trigger the ignition transformers to re-ignite the
pilots upon loss of flame.
4.5.4. Remote Ignition - system to be capable of automatic
startup and shutdown based on either local or remote
initiation.

Ameresco Page 5 of 6
4.6. Pilot Monitoring Device:
4.6.1. Ultra-violet (UV) flame scanner
4.6.2. Thermocouple - The pilots will be
equipped with Type K thermocouples for
monitoring the pilot flame.
4.6.3. Flame Rod - The pilot shall be equipped
with a flame rod to accurately sense a
pilot flame and not high temperature flue
gases.
4.7. Ignition transformer.
4.8. Control system to be pre-programmed, pre-wired, pre-piped and
mounted on a structural steel rack.
4.9. The operating temperature of the TOX to be automatically
maintained via split-range temperature control via pneumatic fuel
control valve and combustion/quench air control.
4.10. MRW local control panel to include a panel mounted
temperature-indicating controller.
4.11. There is a blower for air to the core burner and a second blower to
provide combustion air to the waste gas both with TEFC motors.
Motors are VFD compatible. VFD’s, enclosure and disconnect all
to be by others

PRICE - BUDGET
Table 3: Equipment Pricing List
ITEM PRICE (USD)
MRW Thermal Oxidizer System as described
Add for optional 6” high temp Protego FA-E flame arrestor
CS housing/SS element
Add for optional 6” CS inlet shutdown BFV

TERMS
The above are prices are budgetary and are for planning purposes.
The above prices are Ex works point of USA manufacture.
Prices are exclusive of all taxes, import-export duties or other duties.
Shipping preparations are for domestic shipping only.

Ameresco Page 6 of 6
DELIVERY SCHEDULE
Table 4: Delivery Schedule
MILESTONE DELIVERY
Submit Drawings for Approval 10 Weeks After Receipt of
Order
Fabrication – Ready to Ship 18 Weeks After Receipt of
Approved Drawings

PAYMENT TERMS

30% at time of order
30% at submittal of approval drawings
30% at start of fabrication
10% upon notice of readiness to ship
Invoices are due net 30 days.

OPERATING AND MAINTENANCE MANUALS
One (1) electronic manual is included in the selling price.

STARTUP AND COMMISSIONING ASSISTANCE

MRW can provide qualified personnel to assist in startup and commissioning of
the thermal oxidizer system. This service is available at a rate of $2,000 per 8-
hour day plus travel and living expenses.

WARRANTY

MRW warrants for a period of one year from readiness to ship that the
equipment is designed in accordance with the customer’s specifications and/or
drawings provided to MRW, and that the equipment is free from defects and
workmanship. MRW’s only responsibility under this warranty is to adjust, repair
or replace faulty equipment at MRW’s sole discretion. MRW will not be
responsible for any other costs or damages of any kind whatsoever, including
removal costs, site labor, lost production, lost sales, lost profits, cost of capital or
any other incidental or consequential damages whatsoever. In no event is
MRW’s liability under this warranty greater that the value of the faulty
equipment.

Warranty is not given on parts or accessories unless manufactured by MRW.
However, the warranty of the actual manufacturer would apply to these parts.

December 12th, 2024

Ameresco

Attention: Scott Hill

Subject: Open Flame Non- Assisted Elevated Flare- 14” Tip - unpriced
Two stage 1500 scfm project, Wasatch
MRW # B-240619-02

Dear Scott:

Thank you for the opportunity to present our proposal for the supply of
a 35’ tall MRW Open Flame Non-Assisted Elevated Flare System. The
system described herein include the following:

One (1) MRW Open Flame Non-Assisted Elevated Flare, complete with the
following:

One (1) MRW Self Supported Flare Stack with an overall height of 35-ft.
Non-assisted Flare Tip designed for stable combustion at high wind
velocities.
Two MRW Pilots with thermocouple for monitoring pilot status.
One (1) MRW Pilot Ignition & Control System to insure the flare will
operate as designed, while monitoring the pilot status

MRW is an Oklahoma company and we manufacture the best flares built.
We believe our experience and dedication to customer satisfaction are
unmatched in the industry. We offer you the confidence of hundreds of
successful systems and a team dedicated to meeting your requirements.

The principals of MRW have spent their entire careers designing and
building flare systems. Our reputations are impeccable and we have
always met the customer’s requirements. We will maintain this record
as we continue to provide the most current combustion technology to
meet customer needs.

Best Regards,

Keith Herbert
Principal Engineer
Cell 918-740-0540

Ameresco Page 2 of 5

PROCESS SPECIFICATIONS

Table 1: Process Design Basis – cases are separate and none are additive
Description Flow Composition
BGZ Product TBD 95.7% methane
EQ PSA Product TBD 97.4 % methane

RAW FEED GAS 1500 scfm 50% methane

NOTE: in addition to the steady state conditions above the flare is also
designed to divert the startup/upset cases with enrichment as required until the
plant lines out and the flow can be safely and properly diverted to the TOX.

Flare emissions for NOX and CO will be per AP-42
VOC Destruction efficiency – 98%
NOX emissions- 0.068 lb /MM BTU heat release
CO emissions – 0.31 lb /MM BTU heat release
Flare tip open area – 0.545 ft2
Exit velocity of the flare gas (1500 scfm) from the flare tip – 45.8 fps.

UTILITIES
Table 2: Flare System Utilities
SERVICE UTILITIES
Pilot Fuel Gas 0.1 MMBTU/HR of Natural Gas at 50 psig ( typ) each pilot
Enrichment Fuel gas As required
Panel Power 120VAC/1/60HZ
Blower Power Not required
Instrument Air Available at 80 psig ( typ)
Purge Gas As Required to Prevent Air Infiltration

EQUIPMENT DESCRIPTION

1. Support Structure→ One (1) MRW Self-Supported Flare Structure
complete with the following features:
1.1 The overall height including the flare tip is
approximately 35 ft
1.2 Material of construction for the flare stack –
carbon steel
1.3 External piping supports for mounting of pilot
piping and conduit.
1.4 Base plate layout shall be provided with
approval drawings.

Ameresco Page 3 of 5

2 Flare Tip→ One 14” Non- assisted MRW Flare Tip complete with the
following features:

2.1 One (1) MRW Flare Tip Assembly - upper portion is stainless steel
2.2 Inlet flange connection
2.3 Stainless steel mounting brackets for easy installation of pilot assemblies.
No field welding is required.
2.4 Lifting lugs installed on the flare tip for easy initial installation.

3 Pilot Burner→ Two continuous and energy efficient pilot burner
assemblies complete with the following features:

3.1 Designed for flame stability in high wind
conditions.
3.2 Pilot burner tip shall be fabricated from stainless
steel, adding extended life to the pilot burner
assembly.
3.3 Strategically placed spark ignition rod in the tip
for rapid ignition of pilot fuel gas.
3.4 Proprietary thermocouple design and location
to accurately and reliably monitor the pilot
flame.
3.5 Air/Fuel Gas mixer attached to pilot burner assembly to allow for a
combustible mixture at the pilot burner tip.
3.6 Dual mounting brackets for easy installation (no field welding required).

4 Control/Ignition System→ One (1) MRW control panel/ignition system
using a PLC complete with the following components:

4.1 One (1) ignition panel designed to meet NEMA 4 requirements.
4.2 Electrical classification is unclassified.

4.3 Pilot Ignition Type:
4.3.1 Flame Front Generator (FFG)
4.3.2 Self-Inspirated Flame Front Generator (SI-FFG).
4.3.3 Electric Spark Ignition (EFG)

Ameresco Page 4 of 5

4.4 Ignition:
4.4.1 Manual – The pilot shall be manually ignited via push-button-
activation
4.4.2 Auto Ignition - Spark igniting device and ignition transformer is
included to ignite the flame front.
4.4.3 Auto Re-Ignition - The flare tip pilot temperature switches shall
automatically trigger the ignition transformers to re-ignite the flare
tip pilots upon loss of flame.
4.4.4 Remote Ignition - Flare system to be capable of automatic
startup and shutdown based on either local or remote initiation.
4.5 Pilot Monitoring Device:
4.5.1 Infra-Red (IR)
4.5.2 Thermocouple - The flare tip pilots will be equipped with One (1)
Type K thermocouple per pilot for monitoring the pilot flame.
4.5.3 Flame Rod - The pilot located below the MRW flare stack shall be
equipped with a flame rod to accurately sense a pilot flame and
not high temperature fume gases.
4.6 Fuel gas/air mixing chamber.
4.7 Ignition mixing chamber with spark igniting device.
4.8 One (1) 120VAC Dongan Ignition transformer.

PRICE - BUDGET

Table 3: Equipment Pricing List
ITEM PRICE (USD)
Flare System per Items 1-4 – 35’ tall

TERMS

The above prices are budgetary and are for planning purposes.
The above price is Ex Works point of manufacture.
Prices are exclusive of all taxes, import-export duties or other duties.
Shipping preparations are for domestic shipping only.

DELIVERY SCHEDULE –

➢ Drawings for approval can be provided 7 weeks after order. We can
then be ready to ship in 16 weeks ADA . If you need an improved
schedule please contact us so we can see what might be arranged.

Ameresco Page 5 of 5

PAYMENT TERMS

20% at time of order
30% at submittal of approval drawings
50% upon notice of readiness to ship
Invoices are due net 30 days

OPERATING AND MAINTENANCE MANUALS

One Electronic Manual is included in the selling price.

TRAINING, STARTUP, AND COMMISSIONING ASSISTANCE

MRW can provide qualified personnel to assist in startup and commissioning of the
flare system. This service is available at a rate of $2,000 per 8-hour day plus travel
and living expenses. Overtime (1.5 x standard hourly rate) will be charged for
holidays, weekends, or normal workdays in excess of 8 hours.

WARRANTY

MRW warrants for a period of twelve months from readiness to ship that the
equipment is designed in accordance with the customer’s specifications and/or
drawings provided to MRW, and that the equipment is free from defects and
workmanship. MRW’s only responsibility under this warranty is to adjust, repair or
replace faulty equipment at MRW’s sole discretion. MRW will not be responsible for
any other costs or damages of any kind whatsoever, including removal costs, site
labor, lost production, lost sales, lost profits, cost of capital or any other incidental or
consequential damages whatsoever. In no event is MRW’s liability under this
warranty greater than the value of the faulty equipment.

Warranty is not given on parts or accessories unless manufactured by MRW.
However, the warranty of the actual manufacturer would apply to these parts.