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PA2022-063_Response-to-Comments
May 2025 | Response to Comments LANDFILL GAS TO ENERGY PLANT PROJECT for City of Newport Beach Prepared for: City of Newport Beach Contact: Joselyn Perez Community Development Department Senior Planner 100 Civic Center Drive, Newport Beach Newport Beach, California 92660 949.644.3312 jperez@newportbeachca.gov Prepared by: PlaceWorks Contact: Dina El Chammas Gass, Senior Associate 3 MacArthur Place, Suite 1100 Santa Ana, California 92707 714.966.9220 info@placeworks.com www.placeworks.com LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Table of Contents May 2025 Page i Section Page 1. RESPONSE TO COMMENTS ...................................................................................................... 1-1 ATTACHMENTS Attachment 1 Greenhouse Gas Emission Table – Coyote Canyon LF Flares Attachment 2 Final Application for Renewable Natural Gas Facility – Coyote Canyon LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Table of Contents Page ii PlaceWorks This page intentionally left blank. May 2025 Page 1-1 1. RESPONSE TO COMMENTS Following is a list of agencies and organizations that submitted comments on the Initial Study/Mitigated Negative Declaration (IS/MND) for the Landfill Gas to Energy Plant Project during the public review period, which extended from November 27, 2024, through January 13, 2025. Comment letters and specific comments are given letters and numbers for reference purposes. Number Reference Commenting Person/Agency Date of Comment Page No. Agencies & Organizations A1 Gabrieleño Band of Mission Indians – Kizh Nation 01/09/2025 1-3 A2 California Department of Transportation 12/13/2024 1-11 A3 South Coast Air Quality Air Management District 01/16/2025 1-17 Organizations O1 Sheila M. Sannadan, Adams, Broadwell Joseph & Cardozo 12/3/2024 1-31 O2 Kelilah D. Federman, Adam Broadwell Joseph and Cardozo 01/13/2025 1-35 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-2 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-3 LETTER A1 – Gabrieleño Band of Mission Indians – KIZH NATION (3 page[s]) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-4 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-5 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-6 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-7 A1. Response to Comments from Gabrieleño Band of Mission Indians – Kizh Nation, dated January 9, 2025. A1-1 The Gabrieleno Band of Mission Indians are requesting mitigation measures related to tribal cultural resources that could be uncovered on the project site during ground- disturbing activities. These mitigation measures have been added to the IS/MND and will be incorporated into the Mitigation Monitoring and Reporting Program. The following text in Section 3.18, Tribal Cultural Resources, of the IS/MND (pages 137 and 138) has been added/revised. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. Less-Than-Significant Impact With Mitigation. Conducting consultation early in the CEQA process allows tribal governments, public lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. The intent of the consultations is to provide an opportunity for interested Native American contacts to work together with the lead agency (in this case, the City) during the project planning process to identify and protect tribal cultural resources. The provisions of CEQA, PRC Sections 21080.3.1 et seq. (or AB 52), require meaningful consultation with California Native American tribes on potential impacts to tribal cultural resources, as defined in PRC Section 21074. Tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either eligible or listed in the California Register of Historical Resources or local register of historical resources (OPR 2017). As part of the AB 52 process, Native American tribes must submit a written request to the relevant lead agency if it wishes to be notified of projects that require CEQA public noticing and are within its traditionally and culturally affiliated geographical area. The lead agency must provide written, formal notification to the tribes that have requested it within 14 days of determining that a project application is complete or deciding to undertake a project. The tribe must respond to the lead agency within 30 days of receipt of the notification if it wishes to engage in consultation on the project, and the lead agency must begin the consultation process within 30 days of receiving the request for consultation. Consultation concludes when either 1) the parties agree to mitigation measures to avoid a significant effect, if one exists, on a tribal cultural resource, or 2) a party, acting in good LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-8 PlaceWorks faith and after reasonable effort, concludes that mutual agreement cannot be reached. AB 52 also addresses confidentiality during tribal consultation per PRC Section 21082.3(c). In accordance with the provisions of AB 52, the City sent formal notifications letters on December 5, 2023, to the following tribes: Juaneño Band of Mission Indians - Acjachemen Nation, Gabrielino-Tongva Tribe, Gabrieleño Band of Mission Indians - Kizh Nation. The 30-day noticing requirement under AB 52 was completed on January 4, 2024, 30 days from the date the City sent the notification letter. The City received no responses. Therefore, the City has complied with its obligation under AB 52, and the consultation process is deemed complete (Appendix M). The project site is heavily developed and has already been subject to similar construction and ground-disturbing activities that would occur under the proposed project. Impacts to tribal cultural resources would be less than significant. Although discovery of resources is unlikely given the previous disturbance of the site, it is recognized that there is some potential for discovery of new resources, therefore Mitigation Measures TCR-1 through TCR-3 are required to reduce impacts to less than significant. Mitigation Measure TCR-1 Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities: The project applicant shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians – Kizh Nation. The monitor shall be retained prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations. “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity. The monitor shall complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs shall identify and describe any discovered tribal cultural resources (TCR), including but not limited to, Native American cultural and historical artifacts, places of significance, etc., as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the project applicant/lead agency upon written request to the Tribe. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant that all ground-disturbing activities and phases that may involve ground-disturbing activities on the LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-9 project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant and lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh TCRs. TCR-2 Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non- Ceremonial): Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Kizh archaeologist. The Kizh shall recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and/or historic purposes. TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects: Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute. If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-10 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-11 LETTER A2 – Scott Shelly, California Department of Transportation (3 page[s]) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-12 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-13 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-14 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-15 A2. Response to Comments from California Department of Transportation, dated December 13, 2024. A2-1 The project site can be accessed from State Route (SR) 73, approximately 0.2 mile to the east, via Newport Coast Drive. The California Department of Transportation (Caltrans) notes that SR-73 is both owned and operated by Caltrans. Therefore, Caltrans is a responsible agency on this project. No response is required. A2-2 The commenter is describing the concept of Complete Street. No response is required. The proposed project does not include offsite roadway improvements therefore, specific complete street requirements to do not apply A2-3 Caltrans is recommending the inclusion of secure and functional short-term bike parking to encourage workers to participate in active transportation practices. This design feature has been added to the proposed project as a Condition of Approval. Short-term bike parking would be provided at a visible location at the project site and will be installed at least 24 feet away from walls and other objects. Bike parking would be designed to accommodate different styles of bikes. A2-4 Mitigation measure TRANS-1 has been updated as shown below to include safety hazards for bicyclists and pedestrian as part of the traffic control plan. The following text in Section 3.17, Transportation, of the IS/MND (page 134) has been added/revised. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less-Than-Significant Impact With Mitigation Incorporated. The proposed project would construct an RNG facility at the CCL to treat LFG from the closed adjacent landfill to be injected into SoCalGas infrastructure. The project would be accessed via Newport Coast Drive and an existing one-lane landfill access roadway (Figure 3). The landfill access roadway would connect to a proposed internal drive aisle, which would also function as a fire access lane. The proposed project could result in a temporary increase in construction traffic associated with hauling activities during the AM peak hours at the SR-73 on- and off-ramps at Newport Coast Drive. Construction traffic may also impact bicyclists and pedestrians accessing the sidewalk and the Class II bikeway on Newport Coast Drive. However, implementation of Mitigation Measures TRANS-1 through TRANS-4 would mitigate potential traffic safety hazards to a less-than- significant level. As described under Section 1.5.2.7, Operational Characteristics, the RNG facility would operate 24 hours per day and employ three operators on site routinely. Therefore, the proposed project would generate minimal daily trips. Therefore, project-related traffic would not result in a substantial LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-16 PlaceWorks number of additional trips to the circulation system that could result in a substantial detriment in the operation of nearby intersections and roadway segments. Impacts would be less than significant. Mitigation Measure TRANS-1 Prior to the initiation of demolition activities at the project site, the applicant shall prepare a traffic control plan for demolition and construction. The traffic control plan shall include the staggering of truck trips throughout the day on Newport Coast Drive, so that the minimum practicable number of truck trips will occur during the AM peak period, to reduce impacts as much as possible to Sage Hill High School and both the State Route 73 on and off-ramps at Newport Coast Drive. The traffic control plan shall also include measures that address safety hazards to bicyclists and pedestrians. A2-5 It is not anticipated that any work would be done within Caltrans right-of-way (R/W). However, any work performed within Caltrans R/W would be reviewed and approved by Caltrans and an encroachment permit would be obtained prior to construction within Caltrans’s R/W. Prior to submitting to Caltrans’s Permit branch, the applicant would fill out the Applicant's Checklist to Determine Applicable Review Process (QMAP List) Form TR-0416 to determine if project oversight/coordination with a Caltrans Project Manager is needed. The applicant would submit a signed Standard Encroachment Permit application form TR-0100 along with a deposit payable to Caltrans. All utility work would be disclosed prior to permit submittal, and utility companies would apply for separate permits for their corresponding work. A2-6 Caltrans notes their mission to provide a safe and reliable transportation network. No response required. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-17 LETTER A3 – Sam Wang, South Coast Air Quality Management District (6 page[s]) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-18 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-19 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-20 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-21 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-22 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-23 A3. Response to Comments from Sam Wang, South Coast Air Quality Management District, dated January 16, 2025. A3-1 Comment is acknowledged. A3-2 For Coyote Canyon Sanitary Landfill (Coyote Canyon), the current permitted control devices at the site are four landfill gas (LFG) enclosed flares, each permitted for 1,500 standard cubic feet per minute (SCFM), for a total capacity of 6,000 SCFM. It should be noted that only three of the four LFG flares are able to operate concurrently at any one time. Table 1 provides the estimated greenhouse gas (GHG) emissions from the existing LFG flares at the landfill, this is the baseline of the GHG generated from LFG from the current operations: Table 1 Existing Flare GHG Emissions Sources1 Activity Rate (MMBTU per hour) Emissions (Metric Tons) Total GHG Emissions (MTCO2e per year) Total Regulated GHG Emissions (MTCO2e per year)3 CO2 CH4 N2O Flare 1 45.54 22,897 1.41 0.28 23,015.05 117.74 Flare 2 45.54 22,897 1.41 0.28 23,015.05 117.74 Flare 3 45.54 22,897 1.41 0.28 23,015.05 117.74 Flare 4 45.54 22,897 1.41 0.28 23,015.05 117.74 Three Flares2 n/a 69,045.15 353.21 Source: SCS Engineers 2025 (Attachment 1). Notes: BTU=British Thermal Unit; MMBTU=million metric BTU; SCFM=standard cubic feet per minute; MTCO2e: metric tons of carbon dioxide equivalent. 1 Four flares are permitted at Coyote Canyon Landfill for no more than 1,500 SCFM at 50 percent methane and heating value of 1,012 BTU, converted to 47.25 MMBTU per hour. 2 Per Coyote Canyon Landfill permit, only three flares are allowed to operate concurrently at any one time. 3 Excludes CO2 emissions, which are biogenic emissions and account for CH4 and N2O emissions only, which are anthropogenic emissions. Emissions of CH4 and N2O are converted to CO2 equivalent emissions based on the Intergovernmental Panel on Climate Change’s Fourth Assessment Report global warming potentials of 25 for CH4 and 298 for N2O. Regarding biogenic and anthropogenic GHGs, Table 9 (pages 94–95) of the IS/MND presents both with- and without-biogenic emissions inventories for the proposed project. The with-biogenic emissions inventory for permitted sources are shown under the “Permitted Sources–Total” inventory. The without-biogenic emissions inventory for the permitted sources are shown under “Permitted Sources–Regulated.” As stated on page 94 of the IS/MND, CO2 generated from combustion of biogas is considered biogenic emissions as it is part of the natural carbon cycle and does not contribute to a net increase in atmospheric CO2. The analysis included the with-biogenic emissions inventory for public disclosure purposes. However, under CEQA, the general framework to analyze potential GHG-related impacts focuses on anthropogenic GHG emissions only, and therefore biogenic GHG emissions are not considered in evaluating project emissions to the District’s 10,000 metric tons of carbon dioxide equivalent per year (MTCO2e/yr) significance threshold for GHG. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-24 PlaceWorks Commenter states that the GHGs from the proposed flare are not included while also noting the inclusion of GHG emissions for the “enclosed RNG flare.” Overall, there is only one flare proposed to be in operation at the RNG plant, and it is the process (off- specification gas) enclosed flare, which is included in Table 9 as “Enclosed RNG Flare.” Therefore, there are no flare GHG emissions missing. In terms of the RNG that is sent to SoCalGas, the RNG is the same composition of natural gas (NG) and is in a closed system that is distributed to SoCalGas. The SoCalGas Point of Receipt (POR) will analyze the product RNG, and the compression of the RNG will occur in the proposed facility prior to the POR facility. If there are any concerns with the product RNG, it will not be routed to the SoCalGas POR and would be combusted as off-specification gas at the RNG flare. This will all occur within the closed system . Additionally, there are no GHG emission sources associated with the RNG. A3-3 As described in Section 1.5.1, Proposed Land Use, of the IS/MND (page 4), the existing landfill gas (LFG) currently generated at the Coyote Canyon Landfill would be diverted to the proposed Renewable Natural Gas (RNG) facility. The proposed RNG facility would treat the current LFG and future quantities of LFG from the landfill. Overall, because the flaring operations would change after implementation of the proposed project, the emissions shown in Table 9 of the IS/MND (pages 94–95) represent a more conservative approach because the results shown do not account for any net reductions in flaring operations as they currently operate today. However, Table 9 of the IS/MND is revised to include the GHG emissions for the existing flaring operations and the net change in emissions after project implementation. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. Table 9 Project-Related Greenhouse Gas Emissions Source MTCO2e/year Percent of Project Total Proposed Land Use Emissions Mobile1 13 <1% Area2 <1 <1% Energy – Electricity3 7,755 99.6% Energy – Natural Gas4 4 <1% Water5 1 <1% Waste 1 <1% Refrigerants <1 <1% Amortized Construction Emissions6 12 <1% Total Land Use Emissions 7,785 100% Proposed Permitted Sources – Total7,8 Thermal Oxidizer – Main 6,120 12% Thermal Oxidizer – Supplemental 4,231 8% Enclosed RNG Flare 39,902 79% Natural Gas-Powered Emergency Generator 0.0327 <1% Total Emissions 50,280 100% LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-25 Table 9 Project-Related Greenhouse Gas Emissions Source MTCO2e/year Percent of Project Total Total Land Use and Permitted Emissions8 Proposed Land Use Emissions 7,785 NA Proposed Permitted Sources Emissions 50,280 NA Total Emissions 58,065 NA Existing Flare Emissions9 69,045 NA Net Change (10,980) NA Proposed Permitted Sources – Regulated7,910 Thermal Oxidizer – Main 31 52% Thermal Oxidizer – Supplemental 4 7% Enclosed RNG Flare 24 40% Natural Gas-Powered Emergency Generator 0.03 <1% Total Emissions 60 100% Total Land Use and Regulated Permitted Emissions Proposed Land Use Emissions 7,785 NA Proposed Regulated Permitted Sources Emissions 60 NA Total Emissions 7,845 NA Existing Regulated Flare Emissions11 353 NA Net Change 7,492 NA South Coast AQMD’s Bright-Line Permitted Sources Threshold1012 10,000 NA Exceeds Bright-Line Threshold No NA Source: CalEEMod Version 2022.1. Notes: MTCO2e: metric tons of carbon dioxide equivalent; RNG = renewable natural gas; South Coast AQMD = South Coast Air Quality Management District; NA = not applicable; CalEEMod = California Emissions Estimator Model; CO2 = carbon dioxide. Summed totals may not equal to totals shown due to rounding. 1 Emissions generated from employee vehicle trips. The quantified emissions are based on six average daily passenger vehicle trip ends generated by three employees and on two average daily truck trip ends generated by one heavy-heavy duty truck. 2 Emissions from landscaping equipment and based on CalEEMod defaults. 3 Based on anticipated electricity demand of 32,000 megawatt hours per year for the proposed facility. 4 As discussed in Section 3.19(a) of this IS/MND, the estimated water demand for the proposed project is 89,222 gallons per year (gpy). However, water sector emissions shown in this table are modeled based on annual water demand of 368,613 gpy and represent a conservative estimate. 5 Emissions from CalEEMod default natural gas demand used for building heating. 6 Construction emissions are amortized over a 30-year project lifetime per recommended South Coast AQMD methodology (South Coast AQMD 2009). 7 Based on information provided by SCS Engineers (see Appendices B1 and B3). 8 Shown for informational purposes only and includes biogenic CO2 emissions generated from combustion of natural gas. 9 Based on annual GHG emissions of 23,015.05 MTCO2e/yr per flare and operation of three flares. Four flares are permitted at Coyote Canyon Landfill for no more than 1,500 SCFM at 50 percent methane and heating value of 1,012 BTU, converted to 47.25 MMBTU per hour. Per Coyote Canyon Landfill permit, only three flares are allowed to operate concurrently at any one time. 10 Excludes biogenic CO2 emissions generated from combustion of natural gas. 11 Based on annual GHG emissions of 117.74 MTCO2e/yr per flare and operation of three flares. 12 South Coast AQMD adopted threshold for permitted/industrial facilities. Because the proposed project is an industrial project that requires a permit from South Coast AQMD, total emissions are compared to South Coast AQMD’s adopted threshold for industrial projects of 10,000 MTCO2e/yr. A3-4 As shown in Table 9 (pages 94–95) of the IS/MND, the GHG analysis quantified both project-related construction and operation emissions. Construction emissions were quantified with the California Emissions Estimator Model (CalEEMod), version 2022, and consist of emissions related to project-related construction activities. For example, project construction emissions account for emissions from operation of off-road LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-26 PlaceWorks construction equipment in addition to mobile-source emissions related to construction worker and vendor vehicle trips. For operation, Table 9 includes emissions associated with both the permitted stationary equipment and the non-permitted sources (i.e., “Land Use Emissions”). The non- permitted sources were quantified using CalEEMod and include emissions from project- related vehicle trips, area sources (e.g., landscaping equipment), energy usage, water demand, wastewater generation, solid waste generation, and refrigerants. For permitted source emissions, Table 9 includes emissions from the following sources: 1) Thermal Oxidizer–Main (“RNG thermal oxidizer”) 2) Thermal Oxidizer–Supplemental (“supplemental fuel used by flare and thermal oxidizer”) 3) Enclosed RNG Flare (“RNG flare”) 4) Natural Gas-Powered Emergency Generator (“emergency generator”). Regarding RNG product gas sent to SoCalGas, the RNG sent to SoCalGas would be in a closed system, and no GHG emissions would be omitted from the transfer of the RNG. Additionally, the capacity of the SoCalGas pipeline system is not increasing with the injection of RNG, so there will not be any increase in GHG emissions. For fugitive emissions, there would be no fugitive emissions associated with the proposed project during normal/planned operations because the only sources would be the point sources listed above. The remainder of the proposed plant would be an all-closed system with no fugitives. A3-5 Please see response to Comment A3-3 and the revised Table 9. As shown in the table, total regulated project GHG emissions when considering the permitted and non- permitted sources would be 7,845 MTCO2e/yr. When compared to the regulated GHG emissions of 353 MTCO2e/yr generated by the existing flare operations, the proposed project would result in an annual net increase of 7,492 MTCO2e/yr. A3-6 The supplemental fuel was not missing from the reporting because there is no supplemental fuel for the off-specification flare. The RNG flare’s design allows for a higher turndown rate, which enables the flare to operate with lower flows and/or lower heating values. Therefore, supplemental fuel is not necessary for the operation of the flare, in contrast to the thermal oxidizer. A3-7 Table 7 (page 72) of the IS/MND has been revised to update the cancer risk values based on commenter’s recommendations. Additionally, the Acute Hazard Index for the “Enclosed RNG Flare” has been revised to reflect the correct value. Furthermore, Appendix B3 is updated to include the latest version of the “Permit to Construction/Permit to Operate for a Renewable Natural Gas Plan for Biofuels Coyote LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-27 Canyon Biogas, LCC Newport Beach, California,” with a revision date of July 2024. The updated Appendix B3 is included in Attachment 2 of this Response to Comments document. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. Table 7 Off-Site Health Risk Assessment Results – Air Toxics Source Residential Cancer Risk (per million) Commercial Cancer Risk (per million) Acute Hazard Index Chronic Hazard Index Thermal Oxidizer 2.41E-072.41E-01 1.74E-081.74E-02 3.23E-03 9.13E-03 Thermal Oxidizer – Supplemental Fuel 8.33E-098.33E-03 4.28E-104.25E-04 4.05E-06 4.04E-04 Enclosed RNG Flare 4.74E-084.74E-02 1.63E-091.63E-03 1.18E-031.37E-05 1.18E-03 Enclosed RNG Flare (Part 2) 1.69E-071.69E-01 9.75E-099.75E-03 2.47E-03 9.95E-03 Natural Gas-Powered Emergency Generator 4.01E-074.01E-01 2.51E-082.51E-02 5.56E-02 7.24E-03 Total 8.66E-078.66E-01 5.43E-085.43E-02 6.13E-02 2.79E-02 South Coast AQMD Threshold 10 10 1.0 1.0 Exceeds Threshold? No No No No Sources: SCS Engineers 2024 (Appendix B3). Notes: RNG = renewable natural gas; South Coast AQMD = South Coast Air Quality Management District. A3-8 The analysis in the IS/MND includes both the installation and operation of a new RNG processing plant and a pipeline interconnection facility (collectively referred to as the RNG facility throughout the IS/MND). The interconnection facility would include a point of receipt (POR) skid to monitor the quality of the RNG and an 8-inch pipeline extension dedicated to transfer the RNG from the POR to the existing fossil natural gas pipeline tie-in point, owned by SoCalGas, in the western part of the site. The transportation route for the RNG fuel from the RNG processing plant to the SoCalGas POR facility and subsequently to the existing fossil natural gas pipeline tie-in point is within the project site surrounded by the existing 12-inch wall. A3-9 The following text in Section 3.3, Air Quality, of the IS/MND (pages 67 and 68) has been added. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. Permitting Thresholds The proposed project would be subject to South Coast Air Quality Management District (AQMD) Regulation XIII. In accordance with South Coast AQMD Rule 1303 (b)(2), Emission Offsets, the project source estimated potential to emit emissions are compared to the offset trigger levels specified in South Coast AQMD Rule 1304(d)(2)(B), Table A. As shown in Table 4, Comparison of Project Emissions to South Coast Air Quality Management District Offset Trigger Levels, the permitted equipment under the proposed project would not exceed the offset trigger levels. Thus, the proposed project would not be required to offset emissions. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-28 PlaceWorks Table 4 Comparison of Project Emissions to South Coast Air Quality Management District Offset Trigger Levels Source Criteria Air Pollutants (tons/year) VOC NOX CO SO2 PM10 PM2.5 Thermal Oxidizer – Main Fuel 2.12 2.60 8.65 2.01 0.92 0.92 Thermal Oxidizer – Supplemental Fuel 0.004 0.54 1.81 0.01 0.06 0.06 Enclosed RNG Flare 0.21 0.85 2.04 0.33 0.25 0.25 Natural Gas-Powered Emergency Generator 0.02 0.01 0.01 0.0001 0.002 0.002 Total Annual Emissions 2.352 3.996 12.515 2.347 1.236 1.236 Rule 1304 Offset Trigger Limits1 4 4 29 4 4 NA Exceeds Limits? No No No No No NA Source: SCS Engineers (see Appendix B1). Notes: VOC = volatile organic compound; NOx = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = coarse inhalable particulate matter; PM2.5 = fine inhalable particulate; RNG = renewable natural gas; NA = not applicable. 1 South Coast AQMD Rule 1304(d)(2)(B). The following discusses the other applicable South Coast AQMD Rules associated with the proposed project: Rule 401 (Visible Emissions): No visible emissions are expected from the proposed RNG Plant with the proper operation of the equipment. Rule 402 (Nuisance): No nuisance complaints are expected from the proposed RNG Plant with the proper operation of the equipment. Rule 403 (Fugitive Dust): No significant fugitive dust emissions are anticipated from the proposed RNG Plant that would cause a violation of Rule 403. Rule 404 (Particulate Matter – Concentration): Particulate matter emissions from the proposed RNG Plant are not expected to exceed the threshold concentrations set forth in District Rule 404, Table 404(a). Rule 405 (Solid Particular Matter – Weight): Solid particulate matter emissions from the proposed RNG Plant are not expected to exceed the threshold process weights set forth in District Rule 405, Table 405(a). Rule 407 (Liquid and Gaseous Air Contaminants): CO and SOX emissions are not expected to exceed 2,000 parts per million volume (ppmv) and 500 ppmv, respectively, from the proposed RNG Plant. Rule 409 (Combustion Contaminants): Combustion contaminants exceeding 0.23 grams per cubic meter of gas calculated to 12 percent (%) of CO2 is not expected to discharge from the proposed RNG Plant. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-29 Rule 429 (Start-Up and Shut Down Exemption Provisions): No significant emissions or changes in emissions during start-up and shutdown are expected from the proposed RNG Plant. Rule 430 (Breakdown Provisions): Adherence to applicable breakdown provision requirements is expected with proper operation of the proposed RNG Plant. Rule 431.1 (Sulfur Content of Gaseous Fuels): The Landfill is currently in compliance with Rule 431.1, and the installation of the proposed RNG Plant will not change the SO2 emissions for the entire landfill; therefore, Landfill will remain in compliance. In addition, the RNG Plant is installing a sulfur treatment system which would further ensure that compliance with the rule is maintained. Rule 466 (Pumps and Compressors): The proposed RNG Plant will maintain compliance with Rule 466 as required through a program of inspection and monitoring for volatile organic compounds (VOC) leaks from pumps and compressors within the proposed system. Rule 474 (Fuel Burning Equipment – Oxides of Nitrogen): The proposed RNG Plant will not emit oxides of nitrogen (measured as nitrogen dioxide) in excess of thresholds set forth in Rule 474. Rule 1118.1 (Control of Emissions from Non-Refinery Flares): The proposed enclosed RNG flare will meet the emission standards per Table 1 of Rule 1118.1. The flare meets the NOX emission limit of 0.025 pounds per million metric British Thermal Units (lb/MMBTU) higher heating value (HHV) under the “other flare gas” category. Rule 1147 (NOx Reductions from Miscellaneous Sources): The proposed thermal oxidizer will meet the NOX requirements under Rule 1147 of 60 ppm or 0.073 lb/MMBTU. Rule 1150.1 (Active Landfills): The proposed RNG Plant would not affect the operation of the existing gas collection or landfill flare systems at Coyote Canyon Landfill. However, landfill flare emissions will be reduced once the RNG Plant is operating. The landfill operator, OC Waste and Recycling, will continue to maintain compliance with Rule 1150.1 for the landfill. The RNG Plant will provide the same level of control for Non-Methane Organic Compounds required under Rule 1150.1, although the plant itself is not subject to the rule. Rule 1173 (Fugitive Emissions of VOCs): The proposed RNG Plant will maintain compliance with Rule 1173 as required through a program of inspection and monitoring for fugitive emissions of volatile organic compounds within the proposed system. A3-10 South Coast AQMD’s is describing its role as a responsible agency under CEQA. No response required. A3-11 This document includes responses to South Coast AQMD’s comments and revises the IS/MND as necessary. Prior to approving the proposed project, the City will consider the IS/MND for adoption together with any comments received during the public review LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-30 PlaceWorks process and this document. The City will notify each public agency when any public hearings are scheduled. The City will also provide South Coast AQMD with this document ten days prior to the Planning Commission Hearing scheduled to consider the proposed project. The Response to Comments will be posted at https://www.newportbeachca.gov/government/departments/community- development/planning-division/projects-environmental-document-download- page/environmental-document-download-page. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-31 LETTER O1 – Sheila M. Sannadan, Adams, Broadwell Joseph & Cardozo, (2 page[s]) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-32 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-33 O1. Response to Comments from Sheila M. Sannadan, Adams, Broadwell Joseph & Cardozo, dated December 3, 2024. O1-1 The City sent all documents referenced, incorporated by reference, and relied upon in the IS/MND via email to Sheila Sannadan, Legal Assistant at Adams Broadwell Joseph and Cardozo, on December 23, 2024. The recipient acknowledged receipt of the email on Dec 24, 2024. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-34 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-35 LETTER O2 – Kelilah D. Federman, Adams, Broadwell Joseph & Cardozo, (69 page[s]) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-36 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-37 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-38 PlaceWorks LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. 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Response to Comments May 2025 Page 1-103 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-104 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-105 O2. Response to Comments from Kelilah D. Federman, Adams, Broadwell Joseph & Cardozo, dated December 3, 2024. O2-1 The commentor is describing the proposed project and notes that the project development is anticipated to take approximately 12 months while the health risk analysis relied on a 9-month completion timeline for its analysis. The construction period for the proposed project would be 9 months as shown on page B1-57 of Appendix B1. The 12- month duration is a discrepancy in the IS/MND. The following text in Section 1.5.4, Project Construction, of the IS/MND (page 38) and Impact 3.3 (a) (page 65) has been added/revised. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. 1.5.4 Project Construction Project development is anticipated to take approximately 12 nine months, from February May 2025 to January 2026. Project development would include demolition and rerouting of water and condensate lines, site preparation and soil haul, rough/fine grading and soil haul, pipeline trenching and installation, building construction, paving, architectural coating, and finishing/landscaping. Installation of the POR and pipeline interconnection facilities would take three to four months, concurrent with installation of the RNG facility. Construction would occur from 7:00 a.m. to 6:30 p.m., Monday through Friday, except on federal holidays, in compliance with Section 10.28.040, Construction Activity: Noise Regulations, of the Newport Beach Municipal Code (NBMC). Neighboring residential community members would be notified by the applicant at least one week prior to the start of construction activities. Broader notifications will be made through various means, including placing signs at road crossings in advance of construction. Regional Short-Term Construction Impacts Construction activities would generate air pollutants. These emissions would primarily be 1) exhaust from offroad diesel-powered construction equipment, 2) dust generated by construction activities, 3) exhaust from onroad vehicles, and 4) off-gassing of VOCs from paints and asphalt. Construction activities associated with the proposed project are expected to disturb approximately 0.88 acre on the project site. The proposed project would involve site preparation, grading, pipeline trenching, pipeline installation, building/facility construction, paving, architectural coating, and finishing/landscaping. Construction would occur for 12 nine months, specifically from February May 2025 to January 2026. Construction emissions were estimated using the California Emissions Estimator Model (CalEEMod), Version 2022.1, and are based on the preliminary construction information provided by the project applicant and CalEEMod default inputs (see Appendix B1) Project-related construction emissions from the modeling have been extracted and are shown in Table 2, Maximum Daily Regional Construction Emissions. As shown, the maximum daily emissions for VOC, NOX, CO, SO2, PM10, and PM2.5 from project-related construction activities would be less than their respective South Coast AQMD regional significance threshold values. Therefore, regional air quality impacts from project- related construction activities would be less than significant, and no mitigation measures are necessary. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-106 PlaceWorks O2-2 The commentor notes that air quality, public health, and greenhouse gas (GHG) impacts were prepared with the assistance of air quality and hazards consultant Komal Shukla, PhD, and that Dr. Shukla’s comments are provided in a separate letter attached as Exhibit A to this letter. Responses to Exhibit A are provided in this document and numbered O2A-1 through O2A-17. The commenter also notes that noise comments were prepared with the assistance of Jack Meighan, and that Mr. Meighan’s comments are provided in a separate letter attached as Exhibit B to this letter. Responses to Exhibit B are provided in this document and numbered O2B-1 through O2B-5. O2-3 The commenter is requesting the preparation of an Environmental Impact Report (EIR) based on issues raised in comments O2-6 through O2-24. The IS/MND fully discloses potential environmental impacts and mitigation, as appropriate, and reduces impacts to below significance. See responses to comments O2-6 through O2-24, which provide detailed responses to the commenter’s specific assertions. O2-4 This comment describes the members, goals, purpose, and concerns of the Orange County Residents for Responsible Industry (Residents) and the California Unions for Reliable Energy (“CURE”). No response is required. O2-5 The commentor describes the legal background related to the preparation of an EIR versus an IS/MND and notes that if no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR. The commenter explains that with respect to this project, the IS/MND fails to adequately disclose, investigate, and analyze the proposed project’s potentially significant impacts and fails to provide substantial evidence to conclude that impacts will be mitigated to a less than significant level. The commenter describes the impacts of concern in comments O2-6 through O2-24. Responses to these comments are provided below. The IS/MND fully discloses potential environmental impacts and mitigation, as appropriate, and reduces impacts to below significance. See responses to comments O2-6 through O2-24, which provide detailed responses to the commenter’s specific assertions. O2-6 The commenter describes the purpose of describing baseline conditions per CEQA. No response required. O2-7 CEQA Guidelines Section 15125(a)(1) states that existing conditions should be based on the “physical environmental conditions at the time of notice of preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, from both a local and regional perspective”. In accordance with this requirement, the baseline conditions identified in the IS/MND are the most recent operating conditions of the CCL. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-107 The site is currently completely disturbed (i.e., paved with concrete and asphalt) from the previous landfill gas-to-energy facility, which operated from 1988 to 2015. The facility was demolished, and after its closure the site was cleared. On the site currently are generators and tanks, 65-foot cell towers, a power panel and switchgear, a blower pad, and the county flare yard. There is a small, operational support building in the center of the site, three existing parking spots west of the building, and a cell tower in the southeast corner of the site. This is the baseline condition considered throughout the IS/MND, not the condition of the site in 1990 as noted in this comment. The baseline used is the current condition of the site post-closure of the gas-to-energy facility that ceased operations in December 2015. The use of unsupported operating conditions from a plant that has been out of service for over 30 years, as the commenter notes, is not how the analysis in the IS/MND was conducted. Table 3, Comparison of Project Emissions to Regional Daily Thresholds, of the IS/MND accounts for existing emissions generated by the four existing LFG flares at the CCL. The daily emissions shown for the existing flares are based on the actual emissions generated by the four existing flares based on the latest available emissions data from calendar years 2021 and 2022, as reported to the South Coast AQMD Annual Emissions Reporting (AER) program. Daily existing emissions shown in Table 3 are derived from the annual average between the annual emissions reported in the AER report for calendar years 2021 and 2022, divided by 365 days per year. The only time the 2015 gas-to-energy plant is mentioned for impact comparison is for the stormwater hydrology analysis. The IS/MND notes that when the site included the landfill gas-to-energy facility, which operated from 1988 to December 2015, the site was completely developed with 100 percent impervious surfaces and the existing storm drainage system had capacity to accommodate the 10- and 25-year flows. Since the project site under proposed conditions would consist of 66.4 percent pervious area, the post- project condition flow rate for the 10-and 25-year flows would be less than the 2015 conditions and the proposed project would not have an adverse impact on the storm drainage system's capacity. O2-8 See response to Comment O2A-5. Additionally, the emergency generators for the cell towers represent existing equipment and operations for the project site. As described in the IS/MND (page 3), they are part of baseline conditions and would not be affected by the proposed project. Any emissions generated from this equipment would not be an increase over existing conditions. The emergency generators operate under an existing South Coast AQMD permit. Because the emergency generators associated with the existing cell tower are not part of the proposed project and would remain unchanged with implementation of the project, these emissions are excluded from the project's emissions analysis. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-108 PlaceWorks O2-9 The commenter is requesting the preparation of an EIR based on issues raised in comments O2-10 through O2-16. Responses to these comments are provided below. O2-10 The project-related construction emissions shown in Table 2 (page 65) and Table 5 (page 69) of the IS/MND were quantified using the California Emissions Estimator Model (CalEEMod) program, which is the recommended emissions modeling program of the South Coast AQMD to quantify emissions generated from project-related construction activities for CEQA-level evaluations. In general, CalEEMod is a statewide computer model developed in collaboration with the various air districts in California, including South Coast AQMD, to quantify criteria air pollutant and greenhouse gas (GHG) emissions from project-related operation and construction activities. Furthermore, CalEEMod was developed using a construction survey overseen by South Coast AQMD to determine the construction profile for each construction phase. The survey included approximately 50 construction sites where information was compiled on the various construction phases, including demolition, site preparation, construction of structures, and other activities. CalEEMod accounts for potential emissions from welding activities through inclusion of a “welder” off-road equipment option to be selected as part of the construction equipment mix for various construction activities. For purposes of this analysis and in accordance with the methodology formulated for CalEEMod, welding equipment was included as part of the pipeline installation activity construction equipment mix to account for emissions associated with pipeline construction welding. Regarding localized air quality impacts from welding emissions, the project site is over 1,000 feet from the nearest sensitive receptor. As discussed on Pages 68 and 69 of the IS/MND, project-related construction activities would not generate emissions that exceed any of the South Coast Air Quality Management District’s localized significance thresholds (LSTs) for construction at the nearest single-family residences 1,200 feet to the south and for students at Sage Hill School High School approximately 1,500 feet to the north. Additionally, pipeline installation during construction, including pipeline welding, would intermittently occur over a brief three-to four-month period (described on Page 38 of the IS/MND). And as discussed on Pages 69 and 70 of the IS/MND, South Coast AQMD does not require the evaluation of long-term excess cancer risk or chronic health impacts from toxic air contaminant emissions for short-term construction projects.1 Lastly, the prevailing wind direction near the project site is toward State Route 73 to the northeast and away from the nearest air quality sensitive receptors to the south (i.e., residences).2 As discussed on Page 70 of the IS/MND, the localized construction emissions analysis, which includes pipeline installation, concludes that construction 1 Note, the terms Toxic Air Contaminants and Hazardous Air Pollutants are used synonymously for the same class of chemical compounds. 2 South Coast Air Quality Management District (South Coast AQMD), 2019–2023. Meteorological data for the John Wayne Airport. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-109 emissions would not pose a health risk to on-site and off-site receptors, and project-related construction health impacts would be less than significant. The intent of CEQA is to address project impacts to the environment and to nearby sensitive receptors, and not specifically to on-site employees of a project. In addition, protections and safety to project-related construction workers from potential hazards associated with welding, such as from toxic fumes, are provided through the federal Occupational Safety and Health Administration (OSHA) regulations (e.g., Standard Number 1926.353). O2-11 The LFG treatment system is a closed-loop, pass-through system; therefore, there would be no pollutant emissions from the treatment process, except for the combustion devices. The only sources associated with the proposed project are the point sources (thermal oxidizer, off-specification RNG flare and emergency generator), which emission potentials were included. Additionally, the IS/MND describes the Emergency Action Plan (EAP) and a draft is included in Appendix H. The EAP describes the roles and responsibilities of trained personal designated to perform process control activities necessary in mitigating leaks. The EAP would be supported by trained operators able to mitigate any potential leaks or emissions. The EAP also describes the inspection and monitoring program, employees training program and preventative maintenance. The RTC also includes revisions to Section 3.3, Air Quality, (see pages 67 and 68) to clearly state that the proposed project will comply with South Coast AQMD's Rule 466 (Pumps and Compressors), as required through a program of inspection and monitoring for VOC leaks from pumps and compressors within the proposed system. Additionally, the Applicant would employ various Lower Explosive Limit (LEL) and H2S sensors throughout the facility. The LEL sensors are used to detect methane gas leaks, which act as a surrogate to hazardous air pollutants (HAPs) emissions. NOx emissions are not generally part of any leaks since they are a combustion by-product. These sensors would cover leaks from joints, valves, and pressure relief systems or methane that is vented during maintenance. The LEL sensors would be located throughout the facility footprint and would signal alarms at specified levels, thus mitigating risks of escalating severity of leaks. The LEL sensors are equipped with a Hi and HiHi alarms. In the event a leak is detected, operators will investigate sources of leaks immediately upon a Hi alarm. The site will automatically shut down and cut off flow of gas to the facility when a HiHi alarm is triggered. The Applicant has a comprehensive program for trained operators to conduct daily rounds of the facility. The daily rounds include performing inspections of facility equipment for signs of equipment leaks through audible, visual, and olfactory observations. O2-12 See response to Comment O2A-7. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-110 PlaceWorks O2-13 The emission potentials from the point sources were estimated on the worst-case scenario for the proposed operations, with the equipment maximum potential operating hours. Emission potentials incorporated transient periods in which the operating scenario is changing or unstable and off-specification in which off-specification gas(es) are routed to the flares. In the event there are unplanned shutdowns, the system is designed so that all valves are closed and the LFG that would be routed to the proposed RNG Plant would be re-routed to the existing LFG enclosed flares, which are separately owned and operated by OC Waste and Recycling. This scenario is the equivalent of reverting back to baseline conditions. The thermal oxidizer and off-specification RNG flare are designed so there are no uncontrolled emissions vented when the sources are shut down or in the rare event of a malfunction; the designs of the systems include programming that prevent free venting. Additionally, safety factors are included at the proposed plant that would signal the equipment to shut down and cease operation to prevent catastrophic events (see discussion on LEL sensors in the response to comment O2-11). Fire hazards to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment are addressed in the IS/MND under impact 3.9(b). A Preliminary Site Consequence Assessment was prepared for the proposed project to outline the potential for flammable vapor clouds, jet fire , and toxic vapor clouds from the proposed project and the possible effect they pose on the surrounding vegetation; public receptors in the surrounding area; the proposed control room on the project site; and the existing OCWR building on the project site. The assessment found no adverse effects to public receptors which included: - Sage Hill Highschool - Car passengers on Newport Coast Drive - Car passengers on SR 73 The assessment found that occupied buildings on the site could be affected by emergency conditions at the proposed RNG facility and included design requirements that would mitigate these impacts. The assessment found that under the worst-case scenario jet fires could affect vegetation up to 10 feet beyond the perimeter wall in the northeast portion of the site. However, the proposed project includes design features such as equipment layout, hazardous area classification , ignition source controls, fire and gas detection systems, process control alarms, process control shutdowns, and emergency shutdown systems. Operators would also be trained to intervene in emergency situations. Strict adherence to all emergency response procedures in the EAP and the Site Severe Weather Response Plan would also be required throughout the duration of the project. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-111 O2-14 See response to Comment O2A-4. O2-15 The determination of offsets that are required for a proposed plant is left to the discretion of the assigned air district. The emission estimates for the proposed plant and point sources were below the South Coast AQMD offset thresholds. In accordance with South Coast AQMD Rule 1303 (b)(2), Emission Offsets, the project’s estimated potential to emit emissions were compared to the offset trigger levels specified in Rule 1304(d)(2)(B), Table A. As shown in Table 4 of the IS/MND, the permitted equipment under the proposed project would not exceed the offset trigger levels even under worse case scenarios. Rule 1304(d)(1)(A) notes that “Any new facility that has a potential to emit less than the amounts in Table A shall be exempt from Rule 1303(b)(2).” Rule 1304 Table A has the following thresholds: NOX: 4 tons per year (tpy) CO: 29 tpy PM10: 4 tpy SOX: 4 tpy VOC: 4 tpy Additionally, NOx emissions are generally not part of any leaks since they are a combustion by-product and there would be no fugitive emissions associated with the proposed project because the only sources would be the point sources (Thermal Oxidizer–Main, Thermal Oxidizer–Supplemental, Enclosed RNG Flare, Natural Gas- Powered Emergency Generator). The remainder of the proposed plant would be an all- closed system with no fugitives. The project’s Permit to Construct is for a New Facility per Sout Coast AQMD rules. South Coast AQMD has issued the facility its own facility number with the application process separate from any landfill operations. O2-16 Regarding the General Plan policies referenced by Commenter, the proposed project would be required to comply with any mandated requirements that may extend from implementation of these referenced policies. Furthermore, the policies were crafted as part of the City’s General Plan adopted in November 2006. Effective on September 1, 2006, ultra low sulfur diesel fuel became required for diesel-powered off-road equipment and on-road vehicles per the California Air Resources Board (CARB) mandate. Compliance with this regulation meets the requirements of Policy NR8.1 of the General Plan. Additionally, off-road equipment have had to comply with increasingly stricter emissions standards established by the United States Environmental Protection Agency, LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-112 PlaceWorks with the strictest Tier 4 standards phased in since 2008. The cleaner fuel requirements and engines contribute to reducing emissions generated from operation of off-road construction equipment. Compliance with these regulations meet the requirements of Policy NR8.1 of the General Plan. Construction contractors would also be required to comply with CARB Rule 2485 (13 CCR Chapter 10, Section 2485, Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling), which limits nonessential idling of off-road equipment to five minutes. Compliance with these rules meet the requirements of Policy NR8.3 of the General Plan. Overall, the South Coast AQMD has established construction-related regional significance thresholds for VOC, NOX, CO, SO2, PM10, and PM2.5. As discussed on Page 65 of the IS/MND, project-related construction activities would not generate emissions that exceed any of the South Coast AQMD’s regional significance thresholds for construction. Thus, per CEQA Guidelines Section 15126.4(3), mitigation is not required. O2-17 The commenter is requesting the preparation of an EIR based on issues raised in comments O2-18 through O2-19. Responses to these comments are provided below. O2-18 See response to Comment O2-11. O2-19 See response to Comment O2A-5. O2-20 Response to Comment O2-10 addresses construction-related health risks. In addition, as discussed in response to Comment O2-1, the construction duration for the proposed project would be 9 months overall and not 12 months, which is consistent with the 9-month duration stated in Section 3.3, Air Quality, of the IS/MND (page 69). The operational health risks associated with the project are discussed on Pages 71 to 72 of the IS/MND. Table 7 on Page 72 of the IS/MND demonstrates that health risks from operation of the project are well below South Coast AQMD’s risk thresholds for the nearest residences to the south and for the Sage Hill School High School to the north. Therefore, health risks for the project’s construction and operational emissions were disclosed in the IS/MND and were determined to be less than significant. O2-21 See response to Comment O2-10. O2-22 The Applicant would employ various LEL and H2S sensors throughout the facility. The LEL sensors are used to detect methane gas leaks, which act as a surrogate to hazardous air pollutants (HAPs) emissions. NOx emissions are not generally part of any leaks since they are a combustion by-product. The LEL sensors would be located throughout the facility footprint and would signal alarms at specified levels, thus mitigating risks of escalating severity of leaks. As part of the refining process, H2S removal equipment, which converts H2S into elemental sulfur, would be located near the front of the plant. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-113 The LEL sensors are equipped with Hi and HiHi alarms. In the event a leak is detected, operators will investigate sources of leaks immediately upon a Hi alarm. The site will automatically shut down and cut off flow of gas to the facility when a HiHi alarm is triggered. Additionally, the Applicant has a comprehensive program for trained operators to conduct daily rounds of the facility. The daily rounds include performing inspections of facility equipment for signs of equipment leaks through audible, visual, and olfactory observations. Furthermore, as described in Impact 3.9(a) of the IS/MND, the Applicant would implement an EAP, supported by trained operators able to mitigate any potential leaks or emissions. A Draft EAP is included as Appendix H of the IS/MND. O2-23 Per South Coast AQMD guidance, the significance thresholds used to evaluate project- specific impacts are also used to evaluate cumulative impacts (South Coast AQMD 2003).3 Thus, projects that exceed the significance thresholds are considered cumulatively considerable, and projects that do not exceed the significance thresholds are not considered cumulatively considerable. As discussed in Section 3.3, Air Quality, of the IS/MND, the proposed project would not result in exceedances of the South Coast AQMD significance thresholds. Therefore, per South Coast AQMD, the proposed project would also not result in cumulative considerable impacts. Regarding greenhouse gas (GHG) emissions, as stated on pages 93 and 94 of the IS/MND, global climate change is not confined to a particular project area, and a single project by itself does not generate enough GHG emissions on its own to result in a measurable increase in global concentrations of GHG. Thus, climate change impacts of a project are considered on a cumulative basis. Therefore, because the proposed project would not exceed South Coast AQMD’s GHG significance threshold, the proposed project’s GHG emissions impacts would not be cumulatively considerable. O2-24 The title for Table N3 in the IS/MND was incorrectly labeled as “Construction Equipment.” The following text in Section 3.13, Noise, of the IS/MND (pages 123 and 124) has been added/revised. Changes to the Initial Study are identified here in strikeout text to indicate deletions and underlined text to signify additions. Applicable Noise Standards The City regulates noise based on the criteria presented in the Noise Element of the General Plan as well as the Municipal Code. To protect City residents from excessive noise, the Noise Element contains the following policies: 3 South Coast Air Quality Management District. 2003, August. Appendix D, White Paper on Potential Control Strategies to Address Cumulative Impacts From Air Pollution. https://www.aqmd.gov/docs/default-source/Agendas/Environmental- Justice/cumulative-impacts-working-group/cumulative-impacts-white-paper-appendix.pdf?sfvrsn=4. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-114 PlaceWorks N 4.1 Stationary Noise Sources: Enforce interior and exterior noise standards outlined in Table N3, and in the City’s Municipal Code to ensure that sensitive noise receptors are not exposed to excessive noise levels from stationary noise sources, such as heating, ventilation, and air conditioning equipment. Table N3 Construction Equipment Exterior and Interior Noise Standards Land Use Categories Allowable Noise Levels (dBA) Categories Uses Interiora,b Exteriora,b Interior Noise Level (Leq dBA) 7 a.m. to 10 p.m. Interior Noise Level (Leq dBA) 10 p.m. to 7 a.m. Exterior Noise Level (Leq dBA) 7 a.m. to 10 p.m. Exterior Noise Level (Leq dBA) 10 p.m. to 7 a.m. Residential Single Family, Two Family, Multiple Family (Zone I) 45 40 50 50 Residential Portions of Mixed-Use Developments (Zone III) 45 40 60 60 Commercial Industrial Commercial (Zone II) NA NA 65 60 Industrial or Manufacturing (Zone IV) NA NA 70 70 Institutional Schools, Day Care Centers, Churches, Libraries, Museums, Healthcare Institutions (Zone I) NA NA 55 50 Source: LSA 2024. Notes: dBA = A-weighted decibels; Leq = equivalent continuous noise level; NA = not applicable. The A-weighting filter deemphasizes the very low and very high frequency components of the sound in a manner similar to the frequency components of the sound in a manner similar to the frequency response of the human ear and correlates well with subjective reactions to noise. Leq = equivalent continuous sound level. The equivalent continuous sound level (Leq) is the total sound energy of time-varying noise over a sample period. This is the metric used by the City Newport Beach for stationary sources. a If the ambient noise level exceeds the resulting standard, the ambient shall be the standard. b It shall be unlawful for any person at any location within the incorporated area of the City of Newport Beach to create any noise or to allow the creation of any noise on property owned, leased, occupied or otherwise controlled by such a person which causes the noise level when measured on any other property, to exceed either of the following: The noise standard for the applicable zone for any fifteen-minute period; A maximum instantaneous noise level equal to the value of the noise standard plus 20 dBA for any period of time (measured using A-weighted slow response). In the event the ambient noise level exceeds the noise standard, the noise standard applicable to said category shall be increased to reflect the maximum ambient noise level. The noise standard for the residential portions of the residential property falling within one hundred feet of a commercial property, if the intruding noise originates from that commercial property. If the measurement location is on a boundary between two different noise zones, the lower noise level standard applicable to the noise zone shall apply. The purpose of these noise standards is to ensure that noise-sensitive receptors are not exposed to excessive noise levels from stationary noise sources such as heating, ventilation, and air conditioning equipment. During the construction phase, there are stationary sources (compressors or generators) and mobile sources (excavators or front- end loaders) of construction noise associated with construction activities. The exterior and interior noise standards shown in Table N3 are applied to stationary sources and not mobile sources, which are the predominant sources of noise during construction. The LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-115 noise standards in Table N3 are intended to be applied to operational project noise and not temporary construction noise. Although the City’s Noise Ordinance limits construction activities to specific days of the week and hours of the day, construction equipment generates high noise levels and may not always be reducible to the levels specified in the City’s Noise Ordinance. Section 10.26.035 of the Municipal Code (Exemptions, exempts “noise sources associated with construction, repair, remodeling, demolition, or grading of any real property.” Section 10.26.035 also states that construction noise should fall under the provisions of Section 10.28 of the Code (Loud and Unreasonable Noise). Thus, construction noise is not subject to the noise standards in the Municipal Code during limited hours of the day and days of the week. The proposed project will be required to comply with the construction hours specified in the City’s Noise Ordinance, which states that construction activities are allowed between 7:00 a.m. and 6:30 p.m., Monday through Friday, and from 8:00 a.m. to 6:00 p.m. on Saturday. No construction is permitted outside of these hours or on Sundays and federal holidays. Regarding off-site uses, construction-related noise impacts would remain below the 80 dBA Leq and 85 dBA Leq 8-hour construction noise level criteria established by the Federal Transit Administration for residential and commercial land uses. Additionally, Table F of Appendix K of the IS/MND (reproduced below) shows existing noise level measurements at three locations. As shown in Figure 1, Ambient Noise Monitoring Locations, of this document, LT-1 is approximately 400 feet north of the residence along Renata Street that is considered the closest residential sensitive receptor to the project site. Both LT-1 and the single-family home along Renata Street are approximately 1,130 feet from Newport Coast Drive and will experience the same ambient noise levels. LT-2 is approximately 270 feet south of the Sage Hill School structure that is considered the closest non-residential sensitive receptor to the project site. Both LT-2 and this structure at the Sage Hill School are approximately 875 feet from SR-73 and 910 feet from Newport Coast Drive and will experience the same ambient noise levels. PlaceWorks Figure 1 - Ambient Noise Monitoring Locations Source: Nearmap 2023. PROPOSED LANDFILL GAS TO ENERGY PLANT 0 Scale (Feet) 430 Newport BeachNewport Beach Project Boundary N e w p o r t C o a s t D r N e w p o r t C o a s t D r 73 CALIFORNIA Sage Hill School Sage H i l l Sage H i l l Residential Arb e l l a Arb e l l a Ma r i s o l Ma r i s o l Re n a t a Re n a t a CITY OF NEWPORT BEACH Long-Term Noise Monitoring Locations (3)LT-X LT-1 LT-2 LT-3 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-117 This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-118 PlaceWorks Table F: Existing Noise Level Measurements Number Location Location Description Daytime Noise Levels1 (dBA Leq) Nighttime Noise Levels2 (dBA Leq) Primary Noise Sources LT-1 Located at the south side of the project site, near hairpin turn of the access road. On chain-link fence north of the channel. 37.6-48.1 36.5-43.3 Very quiet. LT-2 Located at the north side of the project site, just south of Sage Hill School. On chain-link fence north of the access road and channel. 44.0-55.9 36.3-49.5 Faint traffic on SR-73. LT-3 Located at the west side of the project site, approximately 270 feet east of Newport Coast Drive. On sign on the west side of the access road. 49.0-57.5 39.4-53.4 Faint traffic on Newport Coast Drive. Source: Compiled by LSA (June 2022) 1 Daytime Noise Levels = noise levels during the hours of 7:00 a.m. to 10:00 p.m. 2 Nighttime Noise Levels = noise levels during the hours of 10:00 p.m. to 7:00 a.m. dBA = A-weighted decibels ft = foot/feet Leq = equivalent continuous sound level As noted in Attachment B, Construction Noise Calculations, of Appendix K of the IS/MND, pipeline installation will take approximately 4 months 4 . The average noise level experienced during construction was assessed based on the distance of activities to the surrounding sensitive receptors which would be 1,700 feet from the property line of the existing school used to the north and 1,380 feet from the existing single-family homes to the south. At those distances, the combined construction noise levels from pipe installation and equipment installation would be 55 dBA Leq and 56 dBA Leq, respectively. Therefore, the school would experience an increase in ambient noise levels ranging from 1 to 11 dBA Leq for four months. The single-family home would experience an increase in ambient noise levels ranging from 8 to 18 dBa Leq for four months. The change in ambient noise levels at the sensitive receptors would be minimal and would only last for four months. O2-25 The commenter is requesting the preparation of an EIR based on issues raised in comments O2-6 through O2-24. Responses to these comments have been provided in this document, substantiating that the IS/MND, along with changes made to the document as described herein, adequately analyzes and mitigates impacts associated with air quality, GHG, public health, and noise. This document also substantiates that the environmental setting was properly delineated in the IS/MND. 4 It should be noted that the noise study conservatively assumes that equipment installation would take 12 months. This phase would take 9 months. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-119 O2A-1 This comment includes a description of the history of the project site and a description of the proposed project. No response is required. O2A-2 See response to Comment O2-10. O2A-3 As discussed in response to Comment O2-10, project-related construction emissions were quantified using the California Emissions Estimator Model (CalEEMod) software program. CalEEMod is the modeling program recommended by the South Coast AQMD to quantify emission generated from project-related construction activities for CEQA- level evaluations. In general, CalEEMod is a statewide computer model developed in collaboration with the various air districts in California, including South Coast AQMD, to quantify criteria air pollutant and greenhouse gas emissions from project-related operation and construction activities. Furthermore, CalEEMod was developed using a construction survey overseen by South Coast AQMD to determine the construction profile for each construction phase. The survey included approximately 50 construction sites where information was compiled on the various construction phases, including demolition, site preparation, construction of structures, and other activities. While CalEEMod does not include “windblown” generated fugitive dust from construction activities, the CalEEMod Users Guide notes that not including quantification of windblown fugitive dust in CalEEMod “is consistent with approaches taken in other comprehensive models.”5 In addition, CalEEMod does not entirely exclude fugitive dust emissions. It accounts for fugitive dust generated from other types of sources associated with construction. For example, it accounts for fugitive dust generated from operation of off-road construction equipment used in ground-disturbing activities (e.g., grading), truck loading, demolition activities, and travel of on-road vehicles on paved and unpaved roads. The project-related construction emissions of PM10 and PM2.5 shown in Table 2 and Table 5 of the IS/MND (pages 65 and 69) include emissions from these aforementioned sources where applicable (e.g., the proposed project would not require demolition of existing structures and thus, fugitive dust emissions from demolition activities are not included). In general, the total PM10 and PM2.5 emissions shown in these two tables primarily consist of tailpipe exhaust emissions for the construction activities that would not involve using off-road equipment for ground-disturbing activities. Furthermore, as shown in the tables, project-related construction emissions of PM10 and PM2.5 would be substantially below the respective South Coast AQMD significance thresholds (i.e., 5 percent and 7 percent of the PM10 and PM2.5 regional significance thresholds, respectively, and 3 percent and 2 percent of the PM10 and PM2.5 screening-level localized significance thresholds, respectively). Additionally, the project would comply with South Coat AQMD's Rule 403 (Fugitive Dust) and significant fugitive dust emissions that would violate Rule 403 are not anticipated. The proposed project would be located at an existing 5 California Air Pollution Control Officers Association (CAPCOA). 2022, April. California Emissions Estimator Model User Guide. Version 2022.1. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-120 PlaceWorks pad and would not result in off-road travel. Furthermore, project-related vehicle trips would travel on paved roads because the project site is within a well-developed region, and the access road from Newport Coast Drive to the project site is paved. CalEEMod also calculates operation-related fugitive dust emissions generated by project-related on-road vehicle trips. As shown in Table 3 of the IS/MND (page 67), the proposed project would generate nominal mobile-source PM10 and PM2.5 emissions (0.042 and 0.11 pound per day, respectively). And overall, the proposed project would result in net increases of PM10 and PM2.5 emissions that are substantially below the South Coast AQMD significance thresholds (i.e., 10 percent and 27 percent of the PM10 and PM2.5 regional significance thresholds). Regarding fugitive emissions, the proposed project consists of a closed LFG treatment system; therefore, the LFG, from entry to the point of the final product RNG, would be contained within the system as designed. O2A-4 The South Coast AQMD has established construction-related regional significance thresholds for VOC, NOX, CO, SO2, PM10, and PM2.5. VOC and NOX are air pollutant precursors for ozone. As discussed on Page 65 of the IS/MND, project-related construction activities would not generate emissions that exceed any of the South Coast AQMD’s regional significance thresholds for construction. Thus, per CEQA Guidelines Section 15126.4(3), mitigation is not required. Additionally, Best Available Control Technologies (BACTs) are not applicable to construction emission, BACTs are only applicable for permitted equipment that exceeds the South Coast AQMD trigger levels. O2A-5 In general, the purpose of CEQA is to assess potential effects of a project to the environment. Per CEQA Guidelines Section 15360, the “environment” is defined as “…the physical conditions which exist within the area which will be affected by a proposed project….” As stated by Commenter and discussed in Section 1.4.1, Existing Land Use, of the IS/MND (page 3), the cell towers and associated generators are existing equipment on the project site and are part of the existing environment. Additionally, these pieces of equipment would remain and be unaffected by the proposed project. Overall, the cell tower backup generators are not part of the proposed project and thus, any emissions they may generate are not considered for project emissions. Regarding use of construction equipment that meets the Tier 4 emissions standards, see response to Comment O2A-4 as it pertains to air pollutant emissions. For GHG, as discussed in Section 3.8, Greenhouse Gas Emissions, of the IS/MND (pages 93–95), project- related construction GHG emissions were incorporated into the project’s overall emissions inventory consistent with the methodology recommended by the South Coast AQMD. Overall, as shown in Table 9 of the IS/MND (page 95), the proposed project would not generate emissions that exceeds the South Coast AQMD GHG significance threshold. Thus, similar to air quality, mitigation, such as Tier 4 construction equipment, is not warranted. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-121 O2A-6 Per South Coast AQMD guidance, the significance thresholds used to evaluate project- specific impacts are also used to evaluate cumulative impacts (South Coast AQMD 2003).6,7 This is because air quality is regulated at a basin-level and the regional significance thresholds developed by South Coast AQMD reflect the proposed project’s contribution to regional air quality emissions. Thus, projects that exceed the significance thresholds are considered cumulatively considerable while projects that do not exceed the significance thresholds are not considered cumulatively considerable. As discussed in Section 3.3, Air Quality, of the IS/MND, the proposed project would not result in exceedances of the South Coast AQMD significance thresholds. Therefore, per South Coast AQMD, the proposed project would also not result in cumulative considerable impacts. Regarding GHG emissions, global climate change is not confined to a particular project area, and a single project by itself does not generate enough GHG emissions on its own to result in a measurable increase in global concentrations of GHG. Thus, similar to regional air quality impacts, climate change impacts of a project are considered on a cumulative basis. Because the proposed project would not exceed South Coast AQMD Working Group’s GHG significance threshold, the proposed project’s GHG emissions impacts would not be cumulatively considerable. The cumulative impacts of the air quality impacts and GHG emissions were quantified based on the worst-case operating scenarios at full capacity, which still demonstrated less than significant impacts. The emissions were quantified based on the planned operations of the proposed project and planned equipment. Extending beyond the worst-case operating scenarios would be purely speculative in terms of assessing the potential air emission impacts because the system is designed in such a way that there are no fugitive emission sources during normal operations. Therefore, it is expected that the air quality impacts of the actual operation of the proposed project will be far less than these conservative estimates. O2A-7 The South Coast AQMD does not have a regional significance threshold for ozone. However, with respect to ozone precursor emissions (i.e., VOC and NOX), South Coast AQMD has set its operational CEQA significance threshold for NOX and VOC at 10 tons per year (expressed as 55 pounds per day). This is based on the federal Clean Air Act, which defines a major stationary source for extreme ozone nonattainment areas such as the South Coast AQMD as one emitting 10 tons per year. Under the federal Clean Air Act, such sources are subject to enhanced control requirements, thus South Coast AQMD determined that 55 pounds per day is an appropriate threshold for making a CEQA 6 South Coast Air Quality Management District. 2003, August. Appendix D, White Paper on Potential Control Strategies to Address Cumulative Impacts From Air Pollution. https://www.aqmd.gov/docs/default-source/Agendas/Environmental- Justice/cumulative-impacts-working-group/cumulative-impacts-white-paper-appendix.pdf?sfvrsn=4. 7 South Coast Air Quality Management District. 1993. CEQA Air Quality Handbool. https://planning.lacity.gov/eir/8150Sunset/References/4.B.%20Air%20Quality/AQ.19_SCAQMD%20CEQA%20AQ%20Han dbook%201993.pdf. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-122 PlaceWorks significance finding and requiring feasible mitigation. Overall, South Coast AQMD takes the position that a source which does not emit 10 tons/yr of NOX or VOC would not contribute cumulatively to ozone formation, and vice versa. 8 As discussed in Section 3.2, Air Quality, of the IS/MND (pages 65–69), the proposed project would not generate VOC and NOX emissions that would exceed the respective significance thresholds, and mitigation measures would not be required to reduce project- related VOC and NOX emissions. Additionally, because the proposed project would not exceed the VOC and NOX regional emissions thresholds, it would not contribute cumulatively to ozone formation. In addition, as noted in the response to Comment A3- 9, the proposed RNG Plant will not emit oxides of nitrogen (measured as nitrogen dioxide) in excess of thresholds in Rule 474. Also, individual combustion devices will meet the District’s requirement for emissions; including but not limited to Rules 1118.1, 1147, and 1173 (as detailed in the response to Comment A3-9). As the proposed RNG Plant did not trigger further requirements with emission thresholds within the District’s Rules and Requirements, it was determined no further assessment was necessary. Regarding pipeline welding emissions, see response to Comment O2-10. O2A-8 See the response to Comment O2-22 and O2-24. The Applicant would employ various LEL and H2S sensors throughout the facility. LEL sensors are located strategically throughout the site to ensure adequate coverage of the entire facility footprint. These sensors would cover leaks from joints, valves, and pressure relief systems or methane that is vented during maintenance. The plant would be equipped with a gas chromatograph on the RNG product gas line that continuously monitors parameters to ensure gas meets pipeline specifications so that non-compliant gas does not enter the pipeline network. Additionally, the Applicant has a comprehensive EAP plan in place, supported by trained operators able to mitigate any potential leaks or emissions. Environmental training will be provided to operation personnel prior to the facility’s startup and quarterly thereafter. Additionally, the Applicant has a comprehensive program for trained operators to conduct daily rounds of the facility. The daily rounds include performing inspections of facility equipment for signs of equipment leaks through audible, visual, and olfactory observations. The EAP also includes measures related to handling occasional leaks of process fluids like compressor lubricants or odorants would be handled. 8 South Coast Air Quality Management District. 2015, April 6. Application of the South Coast Air Quality Management District for Leave to File Brief of Amicus Curiae in Support of Neither Party and Brief of Amicus Curiae, Sierra Club v. County of Fresno (Friant Ranch, L.P.) (2018) 6 Cal.5th 502, Case No. S21978. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-123 O2A-9 As previously stated, these worst-case operating scenarios include only the point emission sources. Leaks should not be included in the emission estimates because they would not accurately represent the potentials to emit from the proposed project during planned operations; fugitives or leaks may only occur in upset conditions. O2A-10 It was not required for a modeling baseline to be established for the assessment of the proposed project. The detailed modeling that was completed in accordance with South Coast AQMD Rule 1303, Table A-1, is required for facilities that will have combustion sources greater than 40 million BTUs/hr and/or are above any allowable emission rates listed. The enclosed RNG Flare is over 40 MMBTU/hr in capacity; therefore, modeling was required. The United States Environmental Protection Agency (EPA) regulatory model, AERMOD, was used to assess the ground level concentrations (glc) of criteria pollutants and compare those concentrations with significance thresholds. For simplicity, the model was run at 1 pound per hour for each averaging time. The model results are then multiplied by the actual pound per hour emission rate, which is called the Chi over Q method (X/Q). If any significance threshold is exceeded, modeled impact will be compared to the applicable Ambient Air Quality Standards (AAQS). BCCB has demonstrated via the Air Quality Impact Assessment (AQIA) analysis that facility emissions of criteria pollutants comply with applicable AAQS. This AQIA followed the methodology of South Coast AQMD and CARB. O2A-11 As previously stated, the emission estimates include the worst-case operating scenarios for both the thermal oxidizer and off-specification RNG flare. These incorporated transient periods in which the operating scenario is changing or unstable and off-specification gas(es) are routed to the two devices. Additionally, as previously stated, during times of upset or malfunctions, the system is designed so that all valves are closed and LFG is rerouted to the existing LFG flares for control. Additionally, safety factors are included at the proposed plant that would signal the equipment to shut down and cease operation to prevent catastrophic events. O2A-12 The proposed plant has minimal NOX emissions even under the worse-case scenario of the proposed operations. As noted in the response to Comment A3-9, the proposed RNG plant will not emit oxides of nitrogen (measured as nitrogen dioxide) in excess of thresholds in Rule 474. Because the proposed RNG plant did not trigger further requirements with emission thresholds in the District’s Rules and Requirements, it was determined no further assessment was necessary. O2A-13 Modeling of air quality emissions is consistent with South Coast AQMD's CEQA Air Quality Analysis Handbook (1993) and uses the latest mass-emissions modeling tools (e.g., CalEEMod) and approved emissions factors from South Coast AQMD for permitted sources of emissions. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-124 PlaceWorks The South Coast AQMD CEQA significance thresholds are based on the trigger levels for the federal New Source Review (NSR) Program and consider the interaction between pollutants in the atmosphere to create secondary air pollutants, like ozone. The NSR Program was created to ensure projects are consistent with attainment of health-based federal ambient air quality standards. The federal ambient air quality standards establish the levels of air quality necessary, with an adequate margin of safety, to protect the public health of sensitive populations such as asthmatics, children, and the elderly. Therefore, projects that do not exceed the South Coast AQMD regional significance thresholds would not violate any air quality standards or contribute substantially to an existing or projected air quality violation and would not result in a significant finding requiring mitigation. As discussed in Section 3.2, Air Quality, of the IS/MND, the proposed project would not generate emissions that exceed the regional significance thresholds. Thus, per CEQA Guidelines Section 15126.4(3), mitigation is not required. O2A-14 The South Coast AQMD is the primary agency responsible for ensuring the health and welfare of sensitive individuals exposed to elevated concentrations of air pollutants in the South Coast Air Basin and has established construction emissions significance thresholds to determine a project’s cumulative impact on air quality. The thresholds as shown in Table 2 (page 65) of the IS/MND are based on a pounds per day metric, which South Coast AQMD has determined to be appropriate to determine potentially significant air quality impacts from project construction activities. The IS/MND reflects the best available information on peak-day emissions. Modeling was based on CalEEMod, Version 2022.1, and preliminary construction information provided by the project applicant and CalEEMod default inputs (see Appendix B1). Construction emissions modeling includes overlap of construction activities with peak vehicular traffic in order to provide a peak- day emissions analysis for the construction phase. As discussed on Page 65 of the IS/MND, project-related construction activities would not generate emissions that exceed any of the South Coast Air Quality Management District’s regional significance thresholds for construction. Thus, per CEQA Guidelines Section 15126.4(3), mitigation is not required. Additionally, prior to the initiation of construction activities at the project site, the applicant would prepare a traffic control plan. The traffic control plan would include the staggering of truck trips throughout the day on Newport Coast Drive, so that the minimum practicable number of truck trips will occur during the AM peak period, to reduce impacts as much as possible to Sage Hill High School and both the State Route 73 on and off-ramps at Newport Coast Drive. O2A-15 South Coast AQMD is the agency responsible for ensuring monitoring and compliance. As part of the South Coast AQMD air permitting process, the Applicant conducted a BACT analysis for emission control technologies, ensuring effective emission reduction. As part of the Permit Conditions,, the Applicant will be required to conduct performance tests on the emission control equipment and report results to South Coast AQMD. Furthermore, the Applicant conducts routine preventative maintenance on the facility LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments May 2025 Page 1-125 equipment following manufacturer recommendations. This includes extensive maintenance annually while the plant is shut down. The facility would also have a robust maintenance plan to test, calibrate, and replace emission monitoring equipment as needed. The Applicant also deploys various flow meters and gas composition analyzers throughout the process, which are calibrated annually following manufacturer recommendations. Flow meters and gas analyzers measure the volume of gas and methane composition of gas on the inlet to each control device. Like the existing flare onsite, South Coast AQMD maintains an annual emissions inventory of emissions for each source at the CCL and reviews the emissions to ensure that emissions are within the Permit Limits. It should be noted that as a closed landfill, annual emissions would likely decrease overtime as the amount of LFG decreases. Initial performance testing will be conducted on the thermal oxidizer and enclosed flare within 180 days of facility startup. Reports will be submitted to South Coast AQMD within 60 days of testing. After initial performance testing, the compliance demonstration for the thermal oxidizer and enclosed flare is monitoring of combustion temperature on a continuous basis. Records of combustion temperature will be maintained for each control device. Compliance reporting frequency will be dictated by South Coast AQMD.O2A-16 See response to Comment O2-10. O2A-17 This comment summarizes the issues brought up in comments O2A-1 through O2A-16. See responses to these comments above. O2B-1 This comment includes a description of the proposed project and of Wilson Ihrig. No response is required. O2B-2 This comment includes a general description of the adverse impacts of noise. No response is required. O2B-3 Refer to response to Comment O2-24. O2B-4 Refer to response to Comment O2-24. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH 1. Response to Comments Page 1-126 PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Appendix May 2025 Attachment 1 Greenhouse Gas Emission Table – Coyote Canyon LF Flares Fuel Carbon Dioxide (CO2) Methane (CH4) Nitrous Oxide (N2O) LFG 52.07 3.20E-03 6.30E-04 Total GHG Emission 45.54 45.54 45.54 45.54 MMBtu/hr MMBtu/hr MMBtu/hr MMBtu/hr Emissions CO2 22,897 22,897 22,897 22,897 (metric tons)CH4 1.41 1.41 1.41 1.41 N2O 0.28 0.28 0.28 0.28 25,369.72 25,369.72 25,369.72 25,369.72 Regulated Emissions 45.54 45.54 45.54 45.54 MMBtu/hr MMBtu/hr MMBtu/hr MMBtu/hr Emissions CH4 1.41 1.41 1.41 1.41 (metric tons)N2O 0.28 0.28 0.28 0.28 129.78 129.78 129.78 129.78 117.74GHG Emissions (metric ton CO2e) Sources Flare 1*Flare 2*Flare 3 Flare 4 Activity Rate Total 117.74 117.74 Total (short ton CO2e) 117.74 Activity Rate Total Biogenic 23,015.05 23,015.05GHG Emissions (metric ton CO2e) COYOTE CANYON LANDFILL EMISSION CALCULATIONS * For Flares are permitted at Coyote for no more than 1,500 standard cubic feet per minute (SCFM), converted to 47.25 million metric British Thermal Units per hour (MMBTU/Hr). ** Only three flares can concurrently run at any one time. Total GHG Emission for all three Flares (short ton CO2e)**76,109.16 Flare 3 Flare 4 23,015.05 23,015.05 Emission Factors (kilograms/MMBtu) Sources Flare 1 Flare 2 **No more than three flares can operate at any one time. The GHG emissions are compiled on the RNG Facility proposed capacity of 3,000 SCFM at 50% methane, therefore this demonstrates the emissions of three flare operating with a combined flow of 3,000 SCFM. Total GHG Emission for 3,000 SCFM flow** (short ton CO2e) 259.56 * For Flares are permitted at Coyote for no more than 1,500 standard cubic feet per minute (SCFM), converted to 47.25 million metric British Thermal Units per hour (MMBTU/Hr). Total (short ton CO2e) LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Appendix PlaceWorks This page intentionally left blank. LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Appendix May 2025 Attachment 2 Final Application for Renewable Natural Gas Facility – Coyote Canyon Permit to Construct/Permit to Operate for a Renewable Natural Gas Plant for Biofuels Coyote Canyon Biogas, LLC Newport Beach, California Biofuels Coyote Canyon Biogas, LLC 201 Helios Way, Floor 6 Houston, TX 77079 3900 Kilroy Airport Way, Suite 100 Long Beach, CA 90806 562-426-9544 01221270.00 Task 1 | December 11, 2023 Rev. July 22, 2024 Table of Contents Section Page Introduction .......................................................................................................................... 1 Overview ..................................................................................................................... 1 Project Location ......................................................................................................... 1 Background Information ........................................................................................... 1 Applicant Name and Address .............................................................................. 1 Facility Address ....................................................................................................... 1 Nature of Business ................................................................................................... 1 Person to Contact Regarding Application ......................................................... 1 Type of Entitlement ................................................................................................. 2 Operation Schedule............................................................................................... 2 Status of Application .............................................................................................. 2 Facility Status ........................................................................................................... 2 Compliance Certification ..................................................................................... 2 Project Description .............................................................................................................. 3 Reason for Permitting Action .................................................................................... 3 Description of Proposed Equipment ................................................................................. 3 RNG Plant .................................................................................................................... 3 Bulk Hydrogen Sulfide Removal ............................................................................ 3 VOC Removal ......................................................................................................... 4 Thermal Oxidizer ......................................................................................................... 5 Thermal Oxidizer ...................................................................................................... 5 Equipment Specifications for Thermal Oxidizer .................................................. 5 Enclosed RNG Flare.................................................................................................... 5 Enclosed RNG Flare ................................................................................................ 5 Equipment Specifications for Enclosed RNG Flare ............................................ 6 Condensate Storage Tank ........................................................................................ 6 Aboveground Condensate Storage Tank .......................................................... 6 Equipment Specifications for Condensate Tank................................................ 6 Emergency generator ............................................................................................... 7 Standby Emergency Backup Generator ............................................................ 7 Equipment Specifications for Emergency Backup Generator......................... 7 Expected Emissions ............................................................................................................. 8 Air Pollution Emissions ................................................................................................. 8 Criteria Pollutants .................................................................................................... 8 Toxic Emissions ......................................................................................................... 9 Regulatory Analysis ............................................................................................................. 9 Prohibitory Rules .......................................................................................................... 9 Rule 401 (Visible Emissions) .................................................................................... 9 Rule 402 (Nuisance)................................................................................................ 9 Rule 403 (Fugitive Dust) .......................................................................................... 9 Rule 404 (Particulate Matter – Concentration) .................................................. 9 Rule 405 (Solid Particular Matter – Weight) ......................................................... 9 Rule 407 (Liquid and Gaseous Air Contaminants) ............................................. 9 Rule 409 (Combustion Contaminants) ................................................................ 9 Rule 429 (Start-Up and Shut Down Exemption Provisions)................................. 9 Rule 430 (Breakdown Provisions) ........................................................................ 10 Rule 431.1 (Sulfur Content of Gaseous Fuels) ................................................... 10 Rule 466 (Pumps and Compressors) .................................................................. 10 Rule 474 (Fuel Burning Equipment – Oxides of Nitrogen) ................................ 10 Source Specific Requirements ............................................................................... 10 Rule 1118.1 (Control of Emissions from Non-Refinery Flares) ........................... 10 Rule 1147 (NOx Reductions from Miscellaneous Sources) .............................. 10 Rule 1150.1 (Active Landfills) ............................................................................... 10 Rule 1173 (Fugitive Emissions of VOCs) .............................................................. 10 Regulation XIII – New Source Review .................................................................... 10 Best Available Control Technology .................................................................... 11 Emission Offsets ..................................................................................................... 12 Sensitive Zone Requirements .............................................................................. 12 Facility Compliance ............................................................................................. 12 Minor Facility .......................................................................................................... 12 Air Impact Analysis and Modeling ..................................................................... 12 New Source Review for Toxic Air Contaminants – Rule 1401 ......................... 13 Other Regulatory Requirements ......................................................................... 16 Greenhouse Gas Tailoring Rule ....................................................................................... 16 GHG Emissions Estimate........................................................................................... 16 California Environmental Quality Act (CEQA) Information ......................................... 17 Permit Processing Fees and Forms .................................................................................. 17 Figures Figure 1 Site Location Map Tables (within Text) Table 1. Thermal Oxidizer Emission Factors ......................................................................................... 8 Table 2. Enclosed RNG Flare Emission Factors .................................................................................... 8 Table 3. Natural-Gas Fired Emergency Backup Generator Emission Factors .................................... 8 Table 4. List of TACs ............................................................................................................................ 13 Table 5. Risk Summary ....................................................................................................................... 15 Table 6. GHG Emission Factors .......................................................................................................... 16 Table 7. Project Total GHG Emissions ................................................................................................ 16 Table 8. Regulated GHG Emissions .................................................................................................... 17 Tables (attached) Table 8 Potential to Emit Emission Source Estimates for Thermal Oxidizer Main Fuel Table 9 Potential to Emit Emission Source Estimates for Thermal Oxidizer Supplemental Fuel Table 10 Potential to Emit Emission Source Estimates for Enclosed RNG Flare Table 11 Potential to Emit Emission Source Estimates for Emergency Generator Table 12 Proposed Potential to Emits Emissions Summary Table 13 New Source Review Threshold Emission Levels Table 14 Risk Results Appendices Appendix A Facility Plans Appendix B Equipment Specifications/Standards Appendix C Risk Assessment Information Appendix D Permit Application Forms INTRODUCTION OVERVIEW This document was prepared by SCS Engineers (SCS) on behalf of Biofuels Coyote Canyon Biogas, LLC (BCCB) located at the Coyote Canyon Landfill (CCL). This is an application for a Permit to Construct (PTC)/Permit to Operate (PTO) for the new construction and operation of the proposed BCCB facility. The application is for a new Renewable Natural Gas (RNG) Plant (RNG Plant). This information is formatted in accordance with the South Coast Air Quality Management District (SCAQMD) PTC/PTO permit information requirements. PROJECT LOCATION The proposed RNG Plant will be located at the CCL. CCL is located at 20661 Newport Coast Drive in Newport Beach, California. The CCL site location is shown in Figure 1. A map showing the location of the proposed RNG Plant at the CCL site can be found in Appendix A. The RNG Plant will be under separate ownership and control from the CCL. BACKGROUND INFORMATION Applicant Name and Address Biofuels Coyote Canyon, LLC 201 Helios Way, Floor 6 Houston, TX 77079 Facility Address Biofuels Coyote Canyon Biogas, LLC 20661 Newport Coast Drive Newport Beach, CA 92660 Nature of Business Renewable Natural Gas Plant Person to Contact Regarding Application Mr. Nevin Edwards Environmental Data and New Development Manager Biofuels San Bernardino Biogas, LLC 201 Helios Way, Floor 6 Houston, Texas 77079 (724) 776-8388 Ms. Gabrielle Stephens Project Director SCS Engineers 4683 Chabot Drive, Suite 200 Pleasanton, California 94588 (562) 355-6510 Type of Entitlement PTC/PTO Operation Schedule 24 hours per day 7 days per week 52 weeks per year With scheduled shutdowns for maintenance Status of Application This is a revision to the original application for a RNG Plant that was submitted in December 2023 which included a hydrogen sulfide (H2S) treatment system, volatile organic compound (VOC) removal system, gas treatment system, thermal oxidizer (TOX), an enclosed RNG flare and various related equipment. Initial follow up from the SCAQMD was received in January 2024 and responded to in February 2024. This revised application includes all of the original equipment and operating scenarios, yet it includes the use of an emergency backup engine. Facility Status New Compliance Certification “BCCB certifies that all facilities owned or operated by BCCB are in compliance or on approved schedule for compliance with applicable federal, state, and local emission limits and standards.” Certified by: ____Steven Boor, COO________________ Signature: ___________________________________ Date: ___________________________________ A copy of the completed SCAQMD permit application forms for the RNG Plant is provided as an appendix to this report. Docusign Envelope ID: 86C46D8A-99E8-476B-9415-E8B5F0FDD571 7/17/2024 PROJECT DESCRIPTION REASON FOR PERMITTING ACTION BCCB is proposing to divert the current landfill gas (LFG), and future quantities of LFG collected, to a new RNG Plant, and as a result, put the LFG to a more valuable use. The LFG is currently being flared by the Orange County Waste & Recycling (OCWR), who owns and operates the CCL. None of the existing operations at the CCL will be under common ownership or control with the proposed RNG Plant. The RNG Plant will convert LFG into a pipeline quality natural gas equivalent, by removing H2S, VOCs, carbon dioxide (CO2), nitrogen, (N2), and oxygen (O2). A process flow diagram (PFD ) detailing the processes employed in the RNG Plant can be found in Appendix A. The RNG will be injected into the Southern California Gas Company pipeline. The bulk of the H2S contained in the LFG is converted into elemental sulfur. The remaining H2S, nearly all the VOCs, CO2, N2 and oxygen are removed from the LFG and routed to a TOX for destruction. The gas routed to the TOX is referred to as waste gas. The waste gas contains approximately 6 – 8.5 percent (%) methane (CH4) (varies as raw gas composition changes). To ensure stable combustion of the waste gas, at a minimum of 1,500 degrees Fahrenheit (ºF), it is necessary to provide supplemental fuel (conventional natural gas) to the TOX. BCCB also requests to install an enclosed RNG flare to burn off-specification RNG and waste gases from the H2S and VOC removal systems. The pipeline receiving the RNG has a strict minimum requirement for CH4 content and strict upper limits for the content of CO2, N2 and O2. If these limits are exceeded, it will be necessary to divert the RNG to the flare until such time as the RNG quality returns to within the acceptable limits. DESCRIPTION OF PROPOSED EQUIPMENT RNG PLANT Bulk Hydrogen Sulfide Removal The H2S treatment system will be located within the RNG Plant as shown in the Figures attached. After compression to around 30 pounds per square inch gauge (PSIG), the LFG will enter the H2S treatment system. The bulk of the H2S contained in the LFG will be removed via a non-regenerative H2S removal media contained within a vessel. When the media is spent, it will be replaced, and the spent media will be appropriately managed (e.g. landfilled). The concentration of the H2S leaving the vessel is conservatively estimated to be 25 parts per million by volume (ppmv) or less. The dry media system for sulfur removal will employ a non-regenerative granular sulfur removal media, such as Norit Darco BG1 activated carbon, Guild Associates BSR-050, or equivalent. The treatment system is a pass-through, closed-loop system, and there are no sources of air emission from the H2S removal process. The inlet and outlet piping of the treatment vessel will include manual pressure measurement sample ports, visually read temperature gauges, and locations to sample for H2S concentration and other parameters, as necessary. Equipment Specifications for H2S Treatment System Below are some specific details regarding the H2S Treatment System: Type: Non-Regenerative Media: Granular Sulfur Removal Media (e.g., Norit Darco BG1 activated carbon, Guild BSR-050, or equivalent) Vessels: Steel Fluid: LFG Size: 8’ DIA x 15’ S/S Amount: 20,000 pounds (lbs) Media Outlet: < 25 ppmv inlet H2S Changeout: 24 month changeout (or upon breakthrough) VOC Removal The VOC Removal system will be located within the RNG Plant as shown in Figures attached. After first stage compression and H2S removal, the LFG is now considered process gas. The process gas is further compressed to around 200 PSIG, then enters the VOC removal system. The VOC removal process is mainly comprised of gas chilling followed by a regenerative temperature swing adsorption (TSA) system. Gas chilling condenses water as well as some VOCs. The TSA system provides residual water and VOC removal (90+ % removal). When the TSA system is regenerated, the VOCs in the TSA regeneration gas will flow to the enclosed flare and TOX systems. This TSA regeneration gas will also contain a portion of the H2S not removed by the upstream H2S treatment system. Polishing for additional removal of the remaining VOCs (and H2S) is accomplished by non-regenerative media. The regenerative TSA media is designed for years of operation while the non-regenerative media is designed for annual replacement. The TSA unit is regenerated using the membrane reject CO2 stream plus the nitrogen rejection unit waste gas with the resulting effluent sent to the TOX. Carbon Dioxide Removal The CO2 removal system will be located within the RNG Plant as shown in Figures attached. After second stage compression, H2S, VOC, and water removal, the CO2 is removed from the process gas using a two-stage membrane unit. The first stage membrane unit produces a low pressure permeate stream that is rich in CO2 and is heated using waste heat from the TOX. The stage 1 permeate, which contains about 82% CO2, 6% CH4, and similar levels of N2 and O2, is used to regenerate the TSA system. The stage 1 retentate stream (process gas enriched in CH4) enters the second stage membrane unit. The second stage membrane unit also produces a low pressure permeate stream that is rich in CO2 and CH4 (up to 50%). To recover the CH4, the stage 2 permeate is compressed and recycled internally to the membrane process (initially passing through a non-regenerable polisher bed). Nitrogen Removal The N2 removal system will be located within the RNG Plant as shown in Figures attached. After the CO2 removal process, the process gas is now considered intermediate or low heating value product gas. It contains CH4, N2, and O2 with small amounts of CO2 (<1%) and little to no VOCs or H2S. Due to the presence of elevated concentrations of N2 and O2, it cannot yet be considered pipeline quality natural gas. Accordingly, the gas will enter a Pressure-Swing Adsorption (PSA) process that is used to separate the N2 and O2 from the CH4. As the CH4/(N2+O2) separation is not 100% efficient, the N2 reject gas stream from the PSA system routed to TOX will contain CH4. The CH4 reduces the supplemental natural gas requirement of the TOX. THERMAL OXIDIZER Thermal Oxidizer The TOX system will be located within the RNG Plant as shown in Appendix A. The entire system is designed to process up to 1,837 SCFM of dry waste gas. The maximum allowable total process heat release during operation is 12.11 million British Thermal Units per hour at the higher heating value (MMBtu/hr at HHV). The expected waste gas process heat release during normal operating conditions is 9.88 MMBtu/hr (HHV). The TOX system will operate 24 hours per day, 7 days per week, and 52 weeks per year, except during periods of scheduled and unscheduled maintenance. The design throughput of the TOX system is 86,515 MMBtu (HHV) per rolling 12-month period. Equipment Specifications for Thermal Oxidizer Equipment specifications are included in Appendix B. Below are some specific details regarding the TOX system: Quantity: One (1) Type: Thermal Recuperative Oxidizer (TRO) Manufacturer: Conifer Systems Model: TRO-65-60-051 Capacity (operating): 9.88 MMBtu/hr (HHV) Annual Throughput: 86,515 MMBtu/yr (HHV) Stack Height: 60-feet above grade Stack Diameter: 42 inches (“) I.D.; 50” O.D. Waste Gas Stream Flow (maximum): 1,837 SCFM (membrane waste gas/TSA regen + NRU waste gas) Operating Temp (minimum): 1,500 °F Natural Gas Usage (maximum): 7,500 scfh @ 10 psig (startup) Natural Gas Usage (operating): 1,875 scfh @ 10 psig (design) Estimated Power Consumption 70 kW at full capacity Tables 8 and 9 (attached) shows the calculated Potential to Emit (PTE) for toxics and criteria pollutants for the TOX. ENCLOSED RNG FLARE Enclosed RNG Flare The enclosed RNG flare will be located within the RNG Plant as shown in Appendix A. There are several points in the system where off-specification process gas will be routed to the flare during RNG plant startup or transitional operation. The process gas flow delivered to the flare will be measured and totalized on an annual basis. It is anticipated that the process gas will be off- specification no more than 600 hours per year; however, BCCB requests that a conservative 875 hours per year of operation of the enclosed RNG flare be permitted. Equipment Specifications for Enclosed RNG Flare Equipment specifications are included in Appendix B. Below are some specific details regarding the flare: Quantity: One (1) Type: Enclosed Flare System with combustion air blower Manufacturer: John Zink Hamworthy Combustion Model: ZULE Biogas Flare (Ultra Low Emissions) Size (stack): 13’ diameter x 40’ height Capacity (rated): 77.8 MMBtu/hr (HHV) Equivalent Operating Capacity: 77.8 MMBtu/hr (HHV) (875 operating hours/year) Throughput (annual): 68,060 MMBtu/yr (HHV), 66.6 MMSCF Process Gas Flow (maximum): 3,000 SCFM(d) Combustion Air Blower Capacity: 20,000 SCFM Table 10 (attached) shows the calculated PTE for toxics and criteria pollutants for the flare system. CONDENSATE STORAGE TANK Aboveground Condensate Storage Tank LFG supplied to the RNG Project contains water and any cooling below the gas/water dew point in the upgrading process will result in the formation of condensate; with the bulk of the condensate removed after the gas chilling step. Condensate will be collected from various points in the process and sent to two 15,000-gallon aboveground containment tanks that will collect and store condensate. The condensate will be periodically emptied via vac truck, and the condensate will be transported and disposed offsite at a permitted facility. The tanks normal vent will be routed to the Newterra TIGG granular activated carbon. Equipment Specifications for Condensate Tank Equipment specifications are included in Appendix B. Below are some specific details regarding the condensate tank: Quantity: Two (2) Aboveground Storage Tank Size: 15,000 gallons Type: Vertical Double Wall Fluid: RNG Condensate Removal Frequency: Approximately every 7 days, or as needed The condensate tanks are closed-loop, self-contained systems. Collected liquids will be disposed of at a permitted offsite facility. No emissions are expected with the proposed storage tanks. EMERGENCY GENERATOR Standby Emergency Backup Generator An emergency backup generator will be installed to provide temporary power to the RNG Plant in the event of a grid power outage. Temporary power will be used for lighting, administrative/control, and instrument air purposes to safely shutdown the RNG Plant. The emergency generator will operate for no more than 200 hours annually. The generator is a stationary, Large Spark Ignited Engine (LSIE) emergency-standby rated generator. It is natural gas engine-driven that is turbocharged and aftercooled with a 6 cylinder 14.2L engine. It is rated for 200 kW and is both SCAQMD and United States Environmental Protection Agency (EPA) Certified. The generator will be located at the RNG Plant as shown in Appendix A. Equipment Specifications for Emergency Backup Generator Equipment specifications are included in Appendix B. Below are some specific details regarding the emergency backup generator: Quantity: One (1) Power Output: 200 kW Manufacturer: Generac Industrial Power SCAQMD CEP #: 618436 EPA Certificate #: RGNXB14.22C1-031 Size: 10’-10” length x 4’-2” width x 5’-10” height Table 16 (attached) shows the calculated PTE for toxics and criteria pollutants for the emergency backup generator. PTC/PTO Application www.scsengineers.com 8 EXPECTED EMISSIONS AIR POLLUTION EMISSIONS Tables 8 through 10 attached provide estimates of the PTE pollutant emissions that may be expected from the proposed TOX and enclosed RNG flare. Please note that the LFG treatment system is a closed-loop, pass-through system; therefore, there will be no pollutant emissions from the treatment process, except for the combustion devices. Criteria Pollutants Criteria pollutant emissions from the RNG Plant will be generated during combustion, which includes VOCs, NOx, Sulfur Dioxide (SO2), CO, particulate matter (PM) less than 10 microns (PM10), and PM2.5. Criteria pollutants are from manufacturer’s guarantees and/or SCAQMD rule limits. Table 1. Thermal Oxidizer Emission Factors Criteria Pollutant Proposed Emission Factor Data Source NOx 0.06 lbs/MMBtu (HHV) Manufacturer’s Guarantee CO 0.20 lbs/MMBtu (HHV) Manufacturer’s Guarantee SO2 25 ppmv as H2S (inlet) Maximum Expected PM10/PM2.5 0.017 lb/MMBtu AP-42 Table 2.4-5 NMOCs/VOCs 98% Destruction Efficiency or less than 20 ppmv (as hexane)* Manufacturer’s Guarantee *Emissions estimate conservative based on a destruction efficiency of 98% yet manufacturer has guaranteed up to 99% destruction. Table 2. Enclosed RNG Flare Emission Factors Criteria Pollutant Rule 1118.1 Other Flare Gas Proposed Emission Factor* Data Source NOx 0.06 lb/MMBtu (HHV) 0.025 lb/MMBtu (HHV) Manufacturer’s Guarantee CO N/A 0.06 lb/MMBtu (HHV) Manufacturer’s Guarantee SO2 N/A 25 ppmv as H2S (inlet) Maximum Expected PM10/PM2.5 N/A 7.6 lb/MMscf AP-42 Table 1.4-2 VOCs N/A 98% Destruction Efficiency or 0.38 lb/MMBTU (HHV) Manufacturer’s Guarantee Table 3. Natural-Gas Fired Emergency Backup Generator Emission Factors Criteria Pollutant LAER/BACT Emission Factor Data Source NOx 0.12 g/bhp-hr Manufacturer’s Guarantee/BACT CO 0.21 g/bhp-hr Manufacturer’s Guarantee/BACT SO2 5.88E-04 lb/MMBtu AP-42 Table 3.2-2 PM10/PM2.5 9.91E-03 lb/MMBtu AP-42 Table 3.2-2 VOCs 0.24 g/bhp-hr Manufacturer’s Guarantee/BACT PTC/PTO Application www.scsengineers.com 9 Tables 8 through 11 (attached) provides emission estimates of the RNG Plant. Table 12 (attached) provides a summary of the proposed facility-wide emissions. Toxic Emissions Toxic pollutant emissions from the TOX, enclosed flare and emergency backup generator include the toxic air contaminants (TACs) shown in Tables 8 through 11 (attached). REGULATORY ANALYSIS PROHIBITORY RULES Rule 401 (Visible Emissions) No visible emissions are expected from the proposed RNG Plant with the proper operation of the equipment. Rule 402 (Nuisance) No nuisance complaints are expected from the proposed RNG Plant with the proper operation of the equipment. Rule 403 (Fugitive Dust) No significant fugitive dust emissions are anticipated from the proposed RNG Plant that would cause a violation of Rule 403. Rule 404 (Particulate Matter – Concentration) Particulate matter emissions from the proposed RNG Plant are not expected to exceed the threshold concentrations set forth in Table 404(a). Rule 405 (Solid Particular Matter – Weight) Solid particulate matter emissions from the proposed RNG Plant are not expected to exceed the threshold process weights set forth in Table 405(a). Rule 407 (Liquid and Gaseous Air Contaminants) CO and SOx emissions are not expected to exceed 2,000 ppmv and 500 ppmv, respectively from the proposed RNG Plant. Rule 409 (Combustion Contaminants) Combustion contaminants exceeding 0.23 grams per cubic meter of gas calculated to 12% of CO2 is not expected to discharge from the proposed RNG Plant. Rule 429 (Start-Up and Shut Down Exemption Provisions) No significant emissions or changes in emissions during start-up and shutdown are expected from the proposed RNG Plant. PTC/PTO Application www.scsengineers.com 10 Rule 430 (Breakdown Provisions) Adherence to applicable breakdown provision requirements is expected with proper operation of the proposed RNG Plant. Rule 431.1 (Sulfur Content of Gaseous Fuels) The CCL is currently in compliance with Rule 431.1, and the installation of the proposed RNG Plant will not change the SO2 emissions for the entire landfill; therefore, CCL will remain in compliance. In addition, the RNG Plant is installing a sulfur treatment system which would further ensure that compliance with the rule is maintained. Rule 466 (Pumps and Compressors) The proposed RNG Plant will maintain compliance with Rule 466 as required through a program of inspection and monitoring for VOC leaks from pumps and compressors within the proposed system. Rule 474 (Fuel Burning Equipment – Oxides of Nitrogen) The proposed RNG Plant will not emit oxides of nitrogen (measured as nitrogen dioxide) in excess of thresholds set forth in Rule 474. SOURCE SPECIFIC REQUIREMENTS Rule 1118.1 (Control of Emissions from Non-Refinery Flares) The proposed enclosed RNG flare will meet the emission standards per Table 1 of Rule 1118.1. The flare meets the NOx emission limit of 0.025 lb/MMBtu (HHV) under the “other flare gas” category. Rule 1147 (NOx Reductions from Miscellaneous Sources) The proposed TOX will meet the NOx requirements under Rule 1147 of 60 ppm or 0.073 lb/MMBtu. Rule 1150.1 (Active Landfills) The proposed RNG Plant will not affect the operation of the existing gas collection or landfill flare systems at CCL. However, landfill flare emissions will be reduced once the RNG Plant is operating. The landfill operator, OCWR, will continue to maintain compliance with Rule 1150.1 for the landfill. The RNG Plant will provide the same level of control for NMOCs as required under Rule 1150.1, although the plant itself is not subject to the rule. Rule 1173 (Fugitive Emissions of VOCs) The proposed RNG Plant will maintain compliance with Rule 1173 as required through a program of inspection and monitoring for fugitive emissions of VOCs within the proposed system. REGULATION XIII – NEW SOURCE REVIEW Since the RNG Plant will have emissions of VOC, NOx, CO, PM10, PM2.5, and SO2, it will be subject to the SCAQMD’s New Source Review (NSR) for criteria pollutants under Regulation 13. The requirements under NSR include the following: PTC/PTO Application www.scsengineers.com 11 • Best Available Control Technology (BACT) • Emission Offsets • Sensitive Zone Requirements • Facility Compliance • Major Polluting Facilities • Air Impact Assessment and Modeling Best Available Control Technology Thermal Oxidizer After review of SCAQMD and other District BACT determinations, there is not an established BACT level for a TOX handling waste gas from an RNG Plant; however, we are aware of multiple TOX permitted at the limits noted below for NOx, CO, and NMOCs/VOCs. Therefore, the TOX meets the BACT levels per the manufacturer guarantees in Appendix B. • NOx: 0.06 lb/MMBtu (HHV) • CO: 0.20 lb/MMBtu (HHV) • SO2: 25 ppmv as H2S (inlet) • PM10/PM2.5: 17 lb/MMSCF as CH4 • NMOCs/VOCs: 98% destruction efficiency Note: The manufacturer destruction efficiency is guaranteed to be 99% yet the emission calculations were completed with a destruction efficiency of 98%. The above BACT emission values were applied in calculating the PTE estimates for the TOX found in Tables 8 and 9. Enclosed RNG Flare The flare meets the BACT level of SCAQMD’s Rule 1118.1 for NOx under the other flare category [0.06 lb/MMBtu (HHV)]. After review of SCAQMD and other District BACT determinations, there is not an established BACT level for this equipment for the other criteria pollutants. The SCAQMD only had BACT determinations for digester gas-fired flares, landfill gas-fired flare, and process gas flare from oil and gas operations. Therefore, the flare meets the BACT levels per the manufacturer guarantees in Appendix B. • NOx: 0.025 lb/MMBtu (HHV) • CO: 0.06 lb/MMBtu (HHV) • SO2: 25 ppmv as H2S (inlet) • PM10/PM2.5: 7.6 lb/MMSCF • VOCs: 98% destruction efficiency The above BACT emission values were applied in calculating the PTE estimates for the flare system found in Table 10. PTC/PTO Application www.scsengineers.com 12 Emergency Generator The emergency generator meets the BACT levels of SCAQMD’s BACT Guidelines for Non-Major Polluting Facilities for spark ignition engines greater than 130 horsepower (hp) per the manufacturer guarantees in Appendix B. • NOx: 1.5 grams per brake horsepower-hour (g/bhp-hr) • CO: 2.0 g/bhp-hr • PM10/PM2.5: 9.91E-03 pounds per MMBtu (lb/MMBtu) • VOC: 1.0 g/bhp-hr • SO2: 5.88E-04 lb/MMBtu The above BACT emission values were applied in calculating the PTE estimates for the proposed emergency backup generator found in Table 14. Emission Offsets In accordance with SCAQMD Rule 1303 (b)(2)– Emission Offsets, the project source estimated emissions were compared to the offset trigger levels specified in Rule 1304(d)(2)(B), Table A. Rule 1304(d)(1)(A) notes the following: “Any new facility that has a potential to emit less than the amounts in Table A shall be exempt from Rule 1303(b)(2)”. Rule 1304 Table A has the following thresholds: • NOx : 4 tons per year (tpy) • CO: 29 tpy • PM10: 4 tpy • SOx: 4 tpy • VOC: 4 tpy The PTE as shown in Table 12 (attached) are all lower than the Table A values; therefore, offsets are not triggered. Sensitive Zone Requirements The proposed RNG Plant will not be purchasing emission reduction credits (ERCs) in lieu of offsets; therefore, the sensitive zone requirements do not apply. Facility Compliance As stated in Section 1.3.9 above, the proposed RNG Plant will comply with all applicable rules and regulations of the SCAQMD. Minor Facility Based on the emission estimates in Section 4 above and Table 12 (attached), the RNG Plant will be a “minor facility” under SCAQMD regulations. Air Impact Analysis and Modeling In accordance with Rule 1303, Table A-1, a detailed modeling is required for facilities that will have combustion sources greater than 40 million BTUs/hr and/or are above any allowable emission rates listed. The enclosed RNG Flare is over 40 MMBTU/hr in capacity therefore modeling is required. A modeling report will be submitted under separate cover to the SCAQMD. PTC/PTO Application www.scsengineers.com 13 New Source Review for Toxic Air Contaminants – Rule 1401 Since several TACs will be emitted from the proposed RNG Plant, it is subject to the requirements of SCAQMD Rule 1401. The TACs are identified in Table 3 below: Table 4. List of TACs Pollutant Source(s) 1,1,1-Trichloroethane (methyl chloroform) TOX 1,1,2,2-Tetrachloroethane TOX, Emergency Generator 1,1-Dichloroethane (ethylidene dichloride) TOX 1,1-Dichloroethene (vinylidene chloride) TOX 1,2-Dichloroethane (ethylene dichloride) TOX, Emergency Generator 1,2-Dichloropropane (propylene dichloride) TOX 2-Propanol (isopropyl alcohol) TOX Acrylonitrile TOX Benzene TOX, Enclosed RNG Flare, Emergency Generator Benz(a)anthracene Enclosed RNG Flare Benzo(a)pyrene Enclosed RNG Flare Benzo(b)fluoranthene Enclosed RNG Flare Benzo(g,h,i)perylene Enclosed RNG Flare Benzo(k)fluoranthene Enclosed RNG Flare Carbon disulfide TOX Carbon tetrachloride TOX, Emergency Generator Carbonyl sulfide TOX Chlorobenzene TOX, Emergency Generator Chloroethane (ethyl chloride) TOX, Emergency Generator Chloroform TOX, Emergency Generator Chlorodifluoromethane TOX Chrysene Enclosed RNG Flare, Emergency Generator Dibenzo(a,h)anthracene Enclosed RNG Flare Dichlorobenzene (1,4-Dichlorobenzene) TOX Dichlorodifluoromethane TOX Dichloromethane (Methylene Chloride) TOX Ethyl benzene TOX, Emergency Generator Ethylene dibromide (1,2-Dibromoethane) TOX, Emergency Generator Fluorotrichloromethane TOX Hexane TOX, Enclosed RNG Flare, Emergency Generator Hydrochloric acid TOX Hydrogen Sulfide TOX Indeno(1,2,3-cd)pyrene Enclosed RNG Flare PTC/PTO Application www.scsengineers.com 14 Pollutant Source(s) Mercury (total) TOX, Enclosed RNG Flare Methyl ethyl ketone TOX Perchloroethylene (tetrachloroethylene) TOX, Emergency Generator Toluene TOX, Enclosed RNG Flare, Emergency Generator Trichloroethylene (trichloroethene) TOX Vinyl chloride TOX, Emergency Generator Xylenes TOX, Emergency Generator PAH TOX, Emergency Generator Naphthalene TOX, Enclosed RNG Flare Formaldehyde TOX, Enclosed RNG Flare, Emergency Generator Arsenic Enclosed RNG Flare Beryllium Enclosed RNG Flare Cadmium Enclosed RNG Flare Chromium Enclosed RNG Flare Cobalt Enclosed RNG Flare Copper Enclosed RNG Flare Manganese Enclosed RNG Flare Nickel Enclosed RNG Flare Selenium Enclosed RNG Flare Vanadium Enclosed RNG Flare Zinc Enclosed RNG Flare 2-Methylnaphthalene Enclosed RNG Flare 3-Methylchloanthrene Enclosed RNG Flare 7,12-Dimethylben(a)anthracene Enclosed RNG Flare Acenaphthene Enclosed RNG Flare Acenaphthylene Enclosed RNG Flare Anthracene Enclosed RNG Flare Bromodichloromethane Enclosed RNG Flare Butane Enclosed RNG Flare Ethane Enclosed RNG Flare Fluoranthene Enclosed RNG Flare Fluorene Enclosed RNG Flare Barium Enclosed RNG Flare Pentane Enclosed RNG Flare Phenanthrene Enclosed RNG Flare Propane Enclosed RNG Flare Pyrene Enclosed RNG Flare Molybdenum Enclosed RNG Flare 1,1,2-Trichloroethane (Vinyl Trichloride) Emergency Generator PTC/PTO Application www.scsengineers.com 15 Pollutant Source(s) 1,3-Butadiene Emergency Generator Acetaldehyde Emergency Generator Acrolein Emergency Generator Benzo(b)Fluoranthene Emergency Generator Methanol Emergency Generator Phenol Emergency Generator Styrene Emergency Generator PAHs Emergency Generator Rule 1401 specifies that “the cumulative impact of emissions from the new, relocated, or modified permit unit and all other permit units located within a radius of 100 meters owned or operated by the applicant for which applications were submitted on or after June 1, 1990 will not result in a maximum individual cancer risk (MICR) greater than ten in one million (1 x 10-5) at any receptor location where T-BACT is applied or one in one million where T-BACT is not applied.” In addition, the cancer burden (i.e., the increase in cancer cases in the population exposed to a MICR exceeding one in one million) shall not exceed 0.5. Health risk was evaluated using the SCAQMD Rule 1401 health risk calculation tool version 1.03 (RiskTool), except where the RiskTool could not demonstrate that health risk was less than the limits in Rule 1401. Table 2 below shows a summary of results, attached Table 13 includes further details of the results. The target organs for acute and chronic risk were from the eye and respiratory system, respectively. RiskTool outputs are attached in Appendix C. The RiskTool was generated for each of the two sources individually with both under two operating scenarios, one with main waste gas and one with the supplemental fuel for the TOX, and one with the off-specification RNG and one with waste gases for the enclosed RNG flare; and risk results for all were combined for analysis. The Tier 3 AERSCREEN model was used for all sources, as the risk did not pass Tier 1 and 2. The cancer burden was not needed to be calculated for the sources with such a low cancer risk. Table 5. Risk Summary Source Tier Acute HI Chronic HI Residential Cancer Risk Commercial Cancer Risk Thermal Oxidizer 3 3.23E-03 9.13E-03 2.41E-07 1.74E-08 Thermal Oxidizer – Supplemental Fuel 3 4.05E-06 4.04E-04 8.33E-09 4.28E-10 Enclosed RNG Flare 3 1.37E-05 1.18E-03 4.74E-08 1.63E-09 Enclosed RNG Flare (Part 2) 3 2.47E-03 9.95E-03 1.69E-07 9.75E-09 Emergency Generator 3 5.56E-02 7.24E-03 4.01E-07 2.51E-08 Total 6.13E-02 2.79E-02 8.66E-07 5.43E-08 PTC/PTO Application www.scsengineers.com 16 Other Regulatory Requirements The proposed RNG facility, as a treatment facility for the LFG generated from CCL, is not subject to Regulation IX (New Source Performance Standards [NSPS]) (40 Code of Federal Regulations [CFR] Part 60 Subpart XXX) and National Emission Standards for Hazardous Air Pollutants (NESHAPS) (40 CFR Part 63 Subpart AAAA); yet, the facility will be required to maintain a treatment system monitoring plan with the treatment of LFG. Upon issuance of the PTC/PTO, the facility will develop the site specific treatment system monitoring plan and adhere to the recordkeeping and reporting requirements in accordance with NSPS and NESHAP. GREENHOUSE GAS TAILORING RULE GHG EMISSIONS ESTIMATE This application includes greenhouse gas (GHG) emission calculations to determine whether Prevention of Significant Deterioration (PSD) and/or Title V permit requirements from the Tailoring Rule might apply to the Project, if any. Natural gas-derived emissions of CO2 from RNG are considered biogenic, meaning they come from a biofuel and do not contribute to a net increase in atmospheric CO2. Biogenic CO2 should not be counted as part of the regulated GHG emissions from the RNG sources. Methane (CH4) and nitrous oxide (N2O) are combustion byproducts and are GHGs. Even when resulting from the combustion of a biofuel, methane and nitrous oxide are considered anthropogenic. The new GHG sources at the facility are the natural gas equipment, including the TOX and enclosed RNG flare. GHG emission factors are shown below. Table 6. GHG Emission Factors Fuel Emission Factors (kilograms/MMBtu) Carbon Dioxide Methane Nitrous Oxide Natural Gas 53.06 1.0E-03 1.0E-04 Landfill Gas 52.07 3.2E-03 6.3E-04 Current and proposed GHG sources and their non-fugitive anthropogenic GHG emissions are provided below. Fugitive emissions of GHGs are not counted under the Clean Air Act (CAA) for GHG sources. The facility will not have fugitive emissions. Not all GHG have equal impact on the climate, so emissions of methane and N2O have been converted into CO2 equivalent (CO2e) using a global warming potential factor of 25 for CH4 and 298 for N2O. Table 7. Project Total GHG Emissions Sources Thermal Oxidizer Thermal Oxidizer Supplemental Enclosed RNG Flare Emergency Generator Activity Rate 12.11 MMBtu/hr 8.25 MMBtu/hr 77.8 MMBtu/hr 2.32 MMBtu/hr* Emissions (metric tons) CO2 6,089 4,227 39,861 27 CH4 0.37 0.08 0.75 0.0005 N2O 0.07 0.008 0.075 0.0001 PTC/PTO Application www.scsengineers.com 17 Total GHG Emissions (metric ton CO2e) 50,281 Total (short ton CO2e) 55,425 *Emergency generator based on 200 hours/year operation. Table 8. Regulated GHG Emissions Sources Thermal Oxidizer Thermal Oxidizer Supplemental Enclosed RNG Flare Emergency Generator Activity Rate 12.11 MMBtu/hr 8.25 MMBtu/hr 77.8 MMBtu/hr 2.32 MMBtu/hr* Emissions (metric tons) CH4 0.37 0.08 0.08 0.001 N2O 0.07 0.008 0.075 0.0001 Total GHG Emissions (metric ton CO2e) 60 Total (short ton CO2e) 66 *Emergency generator based on 200 hours/year operation. The facility’s GHGs from the project are estimated at 66 tpy of CO2e, well below Title V and PSD thresholds. Note that a facility cannot trigger federal Title V or PSD for GHGs alone. Since the facility is not subject to Title V, no other requirements for GHGs should apply to this application. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) INFORMATION A California Environmental Quality Act (CEQA) review is required for new major constructions that have not already undergone an Environmental Impact Analysis pursuant to CEQA regulations. Presently, the proposed project is under a CEQA review with the City of Newport as the lead agency. BCCB is anticipating preparation of a negative declaration (ND) or a mitigated negative declaration (MND) which will be determined by the City of Newport upon review of the initial study prepared for the proposed project. CEQA Form 400-CEQA is provided and attached with the application forms. PERMIT PROCESSING FEES AND FORMS The permit processing fees for the RNG Plant was calculated based upon Rule 301 Fees, and are enclosed: Landfill Gas, Treatment Permit Processing (H2S Treatment, Schedule E) $5,587.92 Expedited Processing Fee $2,793.96 Afterburner, Direct Flame (TOX, Schedule D) $7,712.27 Expedited Processing Fee $3,856.14 PTC/PTO Application www.scsengineers.com 18 Flare, Other (Enclosed RNG Flare, Schedule C) $8,866.78 Expedited Processing Fee $4,433.39 Storage Tank, Other $2,216.65 Storage Tank, Other (1 Identical) $1,108.33 Expedited Processing Fee $1,662.50 Emergency I.C. Engine (Schedule B) $3,785.55 Expedited Processing Fee $1,892.78 Total $43,916.27 The appropriate fees for this application are enclosed per the Rule 301 dated December 8, 2023. BCCB understands that any additional fees will be invoiced at a later date. Per this revised Application, the additional fees of $5,299.26 for the Emergency I.C. Engine and associated expedited processing fees are enclosed. The following application forms are enclosed with the application and can be found in Appendix D. H2S Treatment System: •Application Form for Permit or Plan Approval - Form 400-A •California Environmental Quality Act Applicability - Form 400-CEQA •Gaseous Emission Control Form Adsorber – Form 400-E-2b Enclosed RNG Flare: •Application Form for Permit or Plan Approval - Form 400-A •California Environmental Quality Act Applicability - Form 400-CEQA •Gaseous Emissions Control Form Flare – Form 400-E-2c •Plot Plan and Stack Information Form – Form 400-PS Thermal Oxidizer: •Application Form for Permit or Plan Approval - Form 400-A •California Environmental Quality Act Applicability - Form 400-CEQA •Gaseous Emissions Control Form Afterburner/Oxidizer – Form 400-E-2a •Plot Plan and Stack Information Form – Form 400-PS Condensate Tank 1: •Application Form for Permit or Plan Approval - Form 400-A •California Environmental Quality Act Applicability - Form 400-CEQA •Plot Plan and Stack Information Form – Form 400-PS •Storage Tank – Form 400-E-18 Condensate Tank 2: •Application Form for Permit or Plan Approval - Form 400-A •California Environmental Quality Act Applicability - Form 400-CEQA •Plot Plan and Stack Information Form – Form 400-PS •Storage Tank – Form 400-E-18 Emergency Backup Generator: •Application Form for Permit or Plan Approval - Form 400-A PTC/PTO Application www.scsengineers.com A-1 Figures LFG FROM LANDFILL BLOWERS FEED COMPRESSOR STAGE 1 (SINGLE) CONDENSATE H2S REMOVAL IMPURITY PRE- TREATMENT CONDENSATE CHILLER HXN CHILLER CO2 REMOVAL RECYCLE COMPRESSOR (SINGLE) CO2 & IMPURITY REJECT TO TRO THERMAL RECUPERATIVE OXIDIZER NITROGEN REMOVAL SALES POINT FEED COMPRESSOR STAGE 2 (SINGLE) CONDENSATE N2 REJECT TO TRO 1 6656 BUFFER TANK WASTE GAS RECOVERY 98 WASTE GAS TO FLARE OF F - S P E C GA S OF F - S P E C GA S 8 OF F - S P E C GA S 90 OF F - S P E C GA S 14 97 CONDENSATE 29 OF F - S P E C GA S 57 ENCLOSED RNG FLARE VOC REMOVAL E U U U U U U 3" CC BIOGAS ENGINEERING SITE PLAN G2.00 LEGENDS HOLD:- HOLD HOLD HOLD HOLD Site Map Planned Stack Locations Biofuels Coyote Canyon Biogas Legend Facility Line Planned Emergency Generator Location Planned Flare Location Planned TOx Location 400 ft N ➤➤ N Data CSUMB SFML, CA OPC Data CSUMB SFML, CA OPC Data CSUMB SFML, CA OPC PTC/PTO Application www.scsengineers.com A-2 Tables CAS Number Compounds HAP? (Yes/No)Molecular Weight (lb/lbmol) Concentration of Compounds Found In Gas to Thermal Oxidizer (ppmv)(b) Uncontrolled Emissions from Thermal Oxidizer (tons/yr)(c) Destruction Efficiency (%) (d) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) Hazardous Air Pollutants (HAPs)(a) 71-55-6 1,1,1-Trichloroethane (methyl chloroform)**Yes 133.41 2.81E-02 7.67E-03 98.0%3.50E-05 8.41E-04 3.07E-01 1.53E-04 79-34-5 1,1,2,2-Tetrachloroethane Yes 167.85 2.02E-04 6.95E-05 98.0%3.17E-07 7.62E-06 2.78E-03 1.39E-06 75-34-3 1,1-Dichloroethane (ethylidene dichloride)**Yes 98.97 3.93E-02 7.97E-03 98.0%3.64E-05 8.73E-04 3.19E-01 1.59E-04 75-35-4 1,1-Dichloroethene (vinylidene chloride)**Yes 96.94 2.81E-02 5.58E-03 98.0%2.55E-05 6.11E-04 2.23E-01 1.12E-04 107-06-2 1,2-Dichloroethane (ethylene dichloride)**Yes 98.96 2.81E-02 5.69E-03 98.0%2.60E-05 6.24E-04 2.28E-01 1.14E-04 78-87-5 1,2-Dichloropropane (propylene dichloride)Yes 112.99 1.91E-04 4.42E-05 98.0%2.02E-07 4.84E-06 1.77E-03 8.84E-07 67-63-0 2-Propanol (isopropyl alcohol)No 60.11 9.86 1.21 98.0%5.54E-03 1.33E-01 4.85E+01 2.43E-02 107-13-1 Acrylonitrile Yes 53.06 4.05E-02 4.39E-03 98.0%2.01E-05 4.82E-04 1.76E-01 8.79E-05 71-43-2 Benzene**Yes 78.11 5.96E-01 0.10 98.0%4.35E-04 1.04E-02 3.81E+00 1.90E-03 75-25-2 Bromodichloromethane*No 163.83 2.25E-04 7.54E-05 98.0%3.44E-07 8.26E-06 3.02E-03 1.51E-06 75-15-0 Carbon disulfide*Yes 76.13 1.42E-02 2.21E-03 98.0%1.01E-05 2.42E-04 8.83E-02 4.41E-05 56-23-5 Carbon tetrachloride**Yes 153.84 2.81E-02 8.85E-03 98.0%4.04E-05 9.70E-04 3.54E-01 1.77E-04 463-58-1 Carbonyl sulfide Yes 60.07 2.06E-01 2.53E-02 98.0%1.15E-04 2.77E-03 1.01E+00 5.06E-04 108-90-7 Chlorobenzene**Yes 112.56 3.20E-02 7.38E-03 98.0%3.37E-05 8.09E-04 2.95E-01 1.48E-04 75-00-3 Chloroethane (ethyl chloride)*Yes 64.52 2.45E-02 3.24E-03 98.0%1.48E-05 3.55E-04 1.29E-01 6.47E-05 67-66-3 Chloroform**Yes 119.39 2.81E-02 6.87E-03 98.0%3.14E-05 7.53E-04 2.75E-01 1.37E-04 75-45-6 Chlorodifluoromethane No 86.47 3.99E-01 7.06E-02 98.0%3.22E-04 7.74E-03 2.83E+00 1.41E-03 74-87-3 Chloromethane (methyl chloride)*Yes 50.49 3.42E-02 3.53E-03 98.0%1.61E-05 3.87E-04 1.41E-01 7.06E-05 106-46-7 Dichlorobenzene (1,4-Dichlorobenzene)**Yes 147.00 2.81E-02 8.46E-03 98.0%3.86E-05 9.27E-04 3.38E-01 1.69E-04 75-43-4 Dichlorodifluoromethane*No 120.91 2.60E-01 0.06 98.0%2.93E-04 7.04E-03 2.57E+00 1.29E-03 75-71-8 Dichlorofluoromethane No 102.92 3.99E-01 8.41E-02 98.0%3.84E-04 9.21E-03 3.36E+00 1.68E-03 75-09-2 Dichloromethane (Methylene Chloride)**Yes 84.94 2.81E-02 4.89E-03 98.0%2.23E-05 5.35E-04 1.95E-01 9.77E-05 64-17-5 Ethanol*No 46.08 22.42 2.12 98.0%9.66E-03 2.32E-01 8.46E+01 4.23E-02 100-41-4 Ethylbenzene*Yes 106.16 4.67 1.01 98.0%4.63E-03 1.11E-01 4.06E+01 2.03E-02 106-93-4 Ethylene dibromide (1,2-Dibromoethane)**Yes 187.88 2.81E-02 1.08E-02 98.0%4.93E-05 1.18E-03 4.32E-01 2.16E-04 75-69-4 Fluorotrichloromethane No 137.40 3.67E-01 1.03E-01 98.0%4.72E-04 1.13E-02 4.13E+00 2.07E-03 110-54-3 Hexane*Yes 86.18 3.05E-01 0.05 98.0%2.45E-04 5.89E-03 2.15E+00 1.07E-03 7647-01-0 Hydrochloric acid (e)Yes 36.50 42.00 3.14 0.0%4.43E-01 1.06E+01 3.88E+03 1.94E+00 2148878 Hydrogen Sulfide (h)No 34.081 25.00 1.74 98.0%7.97E-03 1.91E-01 6.98E+01 3.49E-02 7439-97-6 Mercury (total) (f)Yes 200.61 2.92E-04 1.20E-04 0.0%2.74E-05 6.57E-04 2.40E-01 1.20E-04 78-93-3 Methyl ethyl ketone No 72.11 11.86 1.75 98.0%8.00E-03 1.92E-01 7.01E+01 3.50E-02 108-10-1 Methyl isobutyl ketone*Yes 100.16 1.35 2.77E-01 98.0%1.26E-03 3.03E-02 1.11E+01 5.53E-03 127-18-4 Perchloroethylene (tetrachloroethylene)Yes 165.83 3.90E-02 1.32E-02 98.0%6.05E-05 1.45E-03 5.30E-01 2.65E-04 108-88-3 Toluene**Yes 92.13 1.37 0.26 98.0%1.18E-03 2.83E-02 1.03E+01 5.17E-03 79-01-6 Trichloroethylene (trichloroethene)**Yes 131.40 2.81E-02 7.56E-03 98.0%3.45E-05 8.28E-04 3.02E-01 1.51E-04 75-01-4 Vinyl chloride*Yes 62.50 4.27E-02 5.46E-03 98.0%2.50E-05 5.99E-04 2.19E-01 1.09E-04 1330-20-7 Xylenes**Yes 106.16 1.31 0.29 98.0%1.30E-03 3.13E-02 1.14E+01 5.72E-03 Various PAH (i)Yes --------2.23E-05 5.36E-04 1.96E-01 9.78E-05 91-20-3 Naphthalene (i)Yes 128.17 ------3.17E-05 7.60E-04 2.78E-01 1.39E-04 50-00-0 Formaldehyde (i)Yes 30.03 ------1.07E-01 2.57E+00 9.37E+02 4.68E-01 Totals: TACs 0.59 14.22 5,188.80 2.59 Totals: HAPs 0.56 13.43 4,902.93 2.45 Single HAP 0.44 10.63 3,880.67 1.94 Criteria Air Pollutants Molecular Weight (lb/lbmol) Inlet Concentration of Compound (ppmv)(b) Uncontrolled Pollutant Flow Rate from Thermal Oxidizer (tons/yr) Destruction Efficiency (%) (d) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) 86.18 981.0 106.02 98.0%0.48 11.62 4,240.84 2.12 86.18 981.0 106.02 98.0%0.48 11.62 4,240.84 2.12 Criteria Air Pollutants Molecular Weight (lb/lbmol) Concentration of Compound (ppmv) Emission Factor (lb/MMscf as methane) Emission Factor (lb/MMBtu HHV) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) ----0.06 0.73 17.44 5,190.93 2.60 ----0.20 2.42 58.14 17,303.10 8.65 64.06 25 --0.46 11.01 4,017.11 2.01 ----17 --0.23 5.49 1,836.81 0.92 Volatile Organic Compounds (VOCs)(g) TABLE 8 POTENTIAL TO EMIT EMISSION SOURCE ESTIMATES FOR THERMAL OXIDIZER COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA Total Non-Methane Organics (NMOCs) as Hexane at 3% O2 Nitrogen Oxides (NOX) Carbon Monoxide (CO) Sulfur Oxides (SOx)(h) Particulate Matter (PM10/PM2.5)(j) Notes: PAH(i)Naphthalene(i)Formaldehyde(i) 0.0001240 lb/mmscf 0.000176 lb/mmscf 0.594000 lb/mmscf Variables: MODEL INPUT VARIABLES: Methane Content into RNG Facility 42.7 vol% Max Gas Stream into RNG Facility (dry)3,000 SCFM(d) Waste Gas Flow Rate to Thermal Oxidizer (operating)1,837 SCFM(d) Waste Gas Throughput to the Thermal Oxidizer (operating)965.77 MMSCF/yr Waste Gas Methane Content to Thermal Oxidizer (operating)8.48 vol%(d) Waste Gas Methane Content to Thermal Oxidizer (maximum)12.20 vol% Thermal Oxidizer Process Heat Release (operating)9.88 MMBTU/hr (HHV) Thermal Oxidizer Process Heat Release (maximum)12.11 MMBTU/hr (HHV) Thermal Oxidizer Process Heat Release (operating, annual)86,515 MMBTU/yr (HHV) Criteria pollutant emission factors used for thermal oxidizer: Pollutant Emission Factor Data Source NMOCs/VOCs 98% Destruction Efficiency or 20 ppmv hexane (d)Manufacturer's Guarantee NOx 0.06 lb/MMBtu (HHV)SCAQMD Rule 1147/Manufacturer's Guarantee CO 0.2 lb/MMBtu (HHV)Manufacturer's Guarantee SO2 25 ppmv as H2S Maximum Expected PM10/PM2.5 17 lb/MMSCF as methane AP-42 Table 2.4-5 CONVERSIONS ton conversion 2000 lbs lb conversion 453.6 g hour conversion 60 min day conversion 24 hrs 12 months 365 days mol conversion 24.04 L @ STP cf conversion 28.32 L mmbtu conversion 1,000,000 btu (d) The destruction efficiency of VOCs is 99% per the Manufacturer's Guarantee, however, 98% is conservatively assumed. (a) Gas entering facility from Coyote Canyon Landfill. List of hazardous air pollutants was from Title III Clean Air Act Amendments, 1990, and include compounds found in landfill gas, as determined from a list in AP-42 Tables 2.4-1 ("Default Concentrations for Landfill Gas Constituents, 11/98"). (b) Initial concentrations based on "Waste Industry Air Coalition (WIAC) Comparison of Recent Landfill Gas Analyses. Site-specific data collected from the May 18, 2023 labs adjusted to 42.7% methane, indicated with "**". TGNMO estimated from engineering analysis concentrated up. If ND, detection limit was used. (c) Based on concentrations in Column D and an estimated maximum gas flow of 3,000 scfm (concentrated up). (e) Concentration of HCl is based on AP-42 Section 2.4.4.2. (f) Concentration of Mercury based on the EPA AP-42 Section 2.4 Table 2.4-1 (11/98). (g) VOCs assumed to equal NMOCs. (h) SOx emissions are based on the H2S ppmv into the product gas at 25 ppmv after sulfur treatment. Then, 100% of the H2S is converted to SO2. (i) Based on correspondence between South Coast Air Quality Management District and Orange County Integrated Waste Management Department dated May 18, 2007. SCAQMD confirmed the specific use of emissions factors for formaldehyde, PAH, and naphthalene. (j) Particulate emissions are cited as 17 lbs/1,000,000 scf of methane on AP-42 Table 2.4-5. CAS Number Compounds HAP? (Yes/No) Emission Factor (lb/MMscf) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) Toxic Air Contaminants (a) 91-57-6 2-Methylnaphthalene No 2.40E-05 4.50E-08 1.08E-06 3.94E-04 1.97E-07 54-49-5 3-Methylchloanthrene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 7,12-Dimethylben(a)anthracene No 1.60E-05 3.00E-08 7.20E-07 2.63E-04 1.31E-07 83-32-9 Acenaphthene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 203-96-8 Acenaphthylene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 120-12-7 Anthracene No 2.40E-06 4.50E-09 1.08E-07 3.94E-05 1.97E-08 56-55-3 Benz(a)anthracene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 71-43-2 Benzene Yes 2.10E-03 3.94E-06 9.45E-05 3.45E-02 1.72E-05 50-32-8 Benzo(a)pyrene No 1.20E-06 2.25E-09 5.40E-08 1.97E-05 9.86E-09 205-99-2 Benzo(b)fluoranthene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 191-24-2 Benzo(g,h,i)perylene No 1.20E-06 2.25E-09 5.40E-08 1.97E-05 9.86E-09 207-08-9 Benzo(k)fluoranthene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 106-97-8 Butane No 2.10E+00 3.94E-03 9.45E-02 3.45E+01 1.72E-02 218-01-9 Chrysene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 53-70-3 Dibenzo(a,h)anthracene No 1.20E-06 2.25E-09 5.40E-08 1.97E-05 9.86E-09 25321-22-6 Dichlorobenzene Yes 1.20E-03 2.25E-06 5.40E-05 1.97E-02 9.86E-06 74-84-0 Ethane No 3.10E+00 5.81E-03 1.40E-01 5.09E+01 2.55E-02 206-44-0 Fluoranthene No 3.00E-06 5.63E-09 1.35E-07 4.93E-05 2.46E-08 86-73-7 Fluorene No 2.80E-06 5.25E-09 1.26E-07 4.60E-05 2.30E-08 50-00-0 Formaldehyde Yes 7.50E-02 1.41E-04 3.38E-03 1.23E+00 6.16E-04 110-54-3 Hexane Yes 1.80E+00 3.38E-03 8.10E-02 2.96E+01 1.48E-02 193-39-5 Indeno(1,2,3-cd)pyrene No 1.80E-06 3.38E-09 8.10E-08 2.96E-05 1.48E-08 91-20-3 Naphthalene Yes 6.10E-04 1.14E-06 2.75E-05 1.00E-02 5.01E-06 109-66-0 Pentane No 2.60E+00 4.88E-03 1.17E-01 4.27E+01 2.14E-02 85-01-8 Phenanthrene No 1.70E-05 3.19E-08 7.65E-07 2.79E-04 1.40E-07 74-98-6 Propane No 1.60E+00 3.00E-03 7.20E-02 2.63E+01 1.31E-02 129-00-0 Pyrene No 5.00E-06 9.38E-09 2.25E-07 8.21E-05 4.11E-08 108-88-3 Toluene Yes 3.40E-03 6.38E-06 1.53E-04 5.58E-02 2.79E-05 7440-38-2 Arsenic Yes 2.00E-04 3.75E-07 9.00E-06 3.29E-03 1.64E-06 7440-39-3 Barium No 4.40E-03 8.25E-06 1.98E-04 7.23E-02 3.61E-05 7440-41-7 Beryllium Yes 1.20E-05 2.25E-08 5.40E-07 1.97E-04 9.86E-08 7440-43-9 Cadmium Yes 1.10E-03 2.06E-06 4.95E-05 1.81E-02 9.03E-06 7440-47-3 Chromium Yes 1.40E-03 2.63E-06 6.30E-05 2.30E-02 1.15E-05 7440-48-4 Cobalt Yes 8.40E-05 1.58E-07 3.78E-06 1.38E-03 6.90E-07 7440-50-8 Copper No 8.50E-04 1.59E-06 3.83E-05 1.40E-02 6.98E-06 7439-95-5 Manganese Yes 3.80E-04 7.13E-07 1.71E-05 6.24E-03 3.12E-06 7439-98-7 Molybdenum No 1.10E-03 2.06E-06 4.95E-05 1.81E-02 9.03E-06 7440-02-0 Nickel Yes 2.10E-03 3.94E-06 9.45E-05 3.45E-02 1.72E-05 782-49-2 Selenium Yes 2.40E-05 4.50E-08 1.08E-06 3.94E-04 1.97E-07 7440-62-2 Vanadium No 2.30E-03 4.31E-06 1.04E-04 3.78E-02 1.89E-05 7440-66-6 Zinc No 2.90E-02 5.44E-05 1.31E-03 4.76E-01 2.38E-04 Totals: TACs 0.02 0.51 186.02 0.09 Totals: HAPs 0.004 0.08 31.00 0.02 Single HAP 0.005 0.12 42.71 0.01 Criteria Air Pollutants Molecular Weight (lb/lbmol) Inlet Concentration of Compound (ppmv)(b) Uncontrolled Pollutant Flow Rate from Thermal Oxidizer (tons/yr) Thermal Oxidizer Destruction Efficiency (%) (d) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) 86.18 100.0 0.184 98.0%0.00 0.020 7.35 0.004 Criteria Air Pollutants Molecular Weight (lb/lbmol) Concentration of Compound (ppmv) Emission Factor (lb/MMBtu HHV) Emission Factor (lb/MMSCF) Maximum Emissions from Thermal Oxidizer (lbs/hr) Maximum Emissions from Thermal Oxidizer (lbs/day) Maximum Emissions from Thermal Oxidizer (lbs/yr) Maximum Emissions from Thermal Oxidizer (tons/yr) ----0.06 0.495 11.88 1,084.43 0.54 ----0.20 1.65 39.61 3,614.78 1.81 64.06 8 --0.010 0.24 87.45 0.011 ------7.6 0.01 0.34 124.83 0.06 Nitrogen Oxides (NOX) Carbon Monoxide (CO) Sulfur Oxides (SOx)(c) Particulate Matter (PM10/PM2.5) COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA TABLE 9 POTENTIAL TO EMIT ESTIMATES FOR THERMAL OXIDIZER - NATURAL GAS SUPPLEMENTAL FUEL Volatile Organic Compounds (VOCs) COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA TABLE 9 POTENTIAL TO EMIT ESTIMATES FOR THERMAL OXIDIZER - NATURAL GAS SUPPLEMENTAL FUEL Notes: (a) List of toxic air contaminants and emission factors from AP-42, Tables 1.4-3 and 1.4-4 (Emission Factors from Natural Gas Combustion). (b) Inlet concentration based on engineering estimate for worst-case emissions. (c) SOx emissions are based on the low sulfur natural gas content of 0.5 grain per 100 scf (8 ppm). (d) The destruction efficiency of VOCs is 99% per the Manufacturer's Guarantee, however, 98% is conservatively assumed. (e) Hourly BTU capacity per the maximum rated capacity at 7,500 SCFH, annual BTU capacity based on estimated typical usage at 1,875 SCFH per manufacturer specifications. Variables: MODEL INPUT VARIABLES:Units Heating Value Basis (?)1100 BTU/SCF (HHV) Natural Gas Flow Rate to Thermal Oxidizer (operating) (e)1,875 SCFH Natural Gas Burner Capacity (operating)2.06 MMBTU/HR (HHV) Natural Gas Throughput to Thermal Oxidizer (operating)16.43 MMSCF/yr Natural Gas Burner Capacity (operating)18,074 MMBTU/yr (HHV) Natural Gas Flow Rate to Thermal Oxidizer (maximum)7,500 SCFH Natural Gas Burner Capacity (maximum)8.25 MMBTU/HR (HHV) Criteria pollutant emission factors used for thermal oxidizer: Pollutant Emission Factor Data Source VOCs 98% destruction efficiency Manufacturer's Guarantee NOx 0.06 lb/MMBTU (HHV)Manufacturer's Guarantee CO 0.20 lb/MMBTU (HHV)Manufacturer's Guarantee SO2 8 ppmv as H2S Maximum Expected PM10/PM2.5 7.6 lb/MMscf AP-42 Table 1.4-2 (PM total) CONVERSIONS ton conversion 2000 lbs lb conversion 453.6 g hour conversion 60 min day conversion 24 hrs 12 months 365 days mol conversion 24.04 L @ STP cf conversion 28.32 L mmbtu conversion 1,000,000 btu CAS Number Compounds HAP? (Yes/No) Emission Factor (lb/MMscf) Maximum Emissions from Flare (lbs/hr) Maximum Emissions from Flare (lbs/day) Maximum Emissions from Flare (lbs/yr) Maximum Emissions from Flare (tons/yr) Hazardous Air Pollutants (HAPs)(a) 91-57-6 2-Methylnaphthalene No 2.40E-05 1.82E-07 4.38E-06 1.60E-03 7.99E-07 54-49-5 3-Methylchloanthrene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 7,12-Dimethylben(a)anthracene No 1.60E-05 1.22E-07 2.92E-06 1.06E-03 5.32E-07 83-32-9 Acenaphthene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 203-96-8 Acenaphthylene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 120-12-7 Anthracene No 2.40E-06 1.82E-08 4.38E-07 1.60E-04 7.99E-08 56-55-3 Benz(a)anthracene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 71-43-2 Benzene Yes 2.10E-03 1.60E-05 3.83E-04 1.40E-01 6.99E-05 50-32-8 Benzo(a)pyrene No 1.20E-06 9.12E-09 2.19E-07 7.99E-05 3.99E-08 205-99-2 Benzo(b)fluoranthene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 191-24-2 Benzo(g,h,i)perylene No 1.20E-06 9.12E-09 2.19E-07 7.99E-05 3.99E-08 207-08-9 Benzo(k)fluoranthene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 106-97-8 Butane No 2.10E+00 1.60E-02 3.83E-01 1.40E+02 6.99E-02 218-01-9 Chrysene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 53-70-3 Dibenzo(a,h)anthracene No 1.20E-06 9.12E-09 2.19E-07 7.99E-05 3.99E-08 25321-22-6 Dichlorobenzene Yes 1.20E-03 9.12E-06 2.19E-04 7.99E-02 3.99E-05 74-84-0 Ethane No 3.10E+00 2.36E-02 5.65E-01 2.06E+02 1.03E-01 206-44-0 Fluoranthene No 3.00E-06 2.28E-08 5.47E-07 2.00E-04 9.98E-08 86-73-7 Fluorene No 2.80E-06 2.13E-08 5.11E-07 1.86E-04 9.32E-08 50-00-0 Formaldehyde Yes 7.50E-02 5.70E-04 1.37E-02 4.99E+00 2.50E-03 110-54-3 Hexane Yes 1.80E+00 1.37E-02 3.28E-01 1.20E+02 5.99E-02 193-39-5 Indeno(1,2,3-cd)pyrene No 1.80E-06 1.37E-08 3.28E-07 1.20E-04 5.99E-08 91-20-3 Naphthalene Yes 6.10E-04 4.63E-06 1.11E-04 4.06E-02 2.03E-05 109-66-0 Pentane No 2.60E+00 1.98E-02 4.74E-01 1.73E+02 8.65E-02 85-01-8 Phenanthrene No 1.70E-05 1.29E-07 3.10E-06 1.13E-03 5.66E-07 74-98-6 Propane No 1.60E+00 1.22E-02 2.92E-01 1.06E+02 5.32E-02 129-00-0 Pyrene No 5.00E-06 3.80E-08 9.12E-07 3.33E-04 1.66E-07 108-88-3 Toluene Yes 3.40E-03 2.58E-05 6.20E-04 2.26E-01 1.13E-04 7440-38-2 Arsenic Yes 2.00E-04 1.52E-06 3.65E-05 1.33E-02 6.66E-06 7440-39-3 Barium No 4.40E-03 3.34E-05 8.02E-04 2.93E-01 1.46E-04 7440-41-7 Beryllium Yes 1.20E-05 9.12E-08 2.19E-06 7.99E-04 3.99E-07 7440-43-9 Cadmium Yes 1.10E-03 8.36E-06 2.01E-04 7.32E-02 3.66E-05 7440-47-3 Chromium Yes 1.40E-03 1.06E-05 2.55E-04 9.32E-02 4.66E-05 7440-48-4 Cobalt Yes 8.40E-05 6.38E-07 1.53E-05 5.59E-03 2.80E-06 7440-50-8 Copper No 8.50E-04 6.46E-06 1.55E-04 5.66E-02 2.83E-05 7439-95-5 Manganese Yes 3.80E-04 2.89E-06 6.93E-05 2.53E-02 1.26E-05 7439-97-6 Mercury Yes 2.60E-04 1.98E-06 4.74E-05 1.73E-02 8.65E-06 7439-98-7 Molybdenum No 1.10E-03 8.36E-06 2.01E-04 7.32E-02 3.66E-05 7440-02-0 Nickel Yes 2.10E-03 1.60E-05 3.83E-04 1.40E-01 6.99E-05 782-49-2 Selenium Yes 2.40E-05 1.82E-07 4.38E-06 1.60E-03 7.99E-07 7440-62-2 Vanadium No 2.30E-03 1.75E-05 4.19E-04 1.53E-01 7.65E-05 7440-66-6 Zinc No 2.90E-02 2.20E-04 5.29E-03 1.93E+00 9.65E-04 TABLE 10 POTENTIAL TO EMIT EMISSION SOURCE ESTIMATES FOR ENCLOSED RNG FLARE COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA CAS Number Compounds HAP? (Yes/No) Molecular Weight (lb/lbmol) Concentration of Compounds Found In Gas to RNG Flare (ppmv)(b) Uncontrolled Emissions from RNG Flare (tons/yr)(c) Destruction Efficiency (%) (d) Maximum Emissions from RNG Flare (lbs/hr) Maximum Emissions from RNG Flare (lbs/day) Maximum Emissions from RNG Flare (lbs/yr) Maximum Emissions from RNG Flare (tons/yr) Hazardous Air Pollutants (HAPs)(a) 71-55-6 1,1,1-Trichloroethane (methyl chloroform)**Yes 133.41 2.81E-02 7.67E-03 98.0%3.50E-05 8.41E-04 3.07E-01 1.53E-04 79-34-5 1,1,2,2-Tetrachloroethane Yes 167.85 2.02E-04 6.95E-05 98.0%3.17E-07 7.62E-06 2.78E-03 1.39E-06 75-34-3 1,1-Dichloroethane (ethylidene dichloride)**Yes 98.97 3.93E-02 7.97E-03 98.0%3.64E-05 8.73E-04 3.19E-01 1.59E-04 75-35-4 1,1-Dichloroethene (vinylidene chloride)**Yes 96.94 2.81E-02 5.58E-03 98.0%2.55E-05 6.11E-04 2.23E-01 1.12E-04 107-06-2 1,2-Dichloroethane (ethylene dichloride)**Yes 98.96 2.81E-02 5.69E-03 98.0%2.60E-05 6.24E-04 2.28E-01 1.14E-04 78-87-5 1,2-Dichloropropane (propylene dichloride)Yes 112.99 1.91E-04 4.42E-05 98.0%2.02E-07 4.84E-06 1.77E-03 8.84E-07 67-63-0 2-Propanol (isopropyl alcohol)No 60.11 9.86 1.21E+00 98.0%5.54E-03 1.33E-01 4.85E+01 2.43E-02 107-13-1 Acrylonitrile Yes 53.06 4.05E-02 4.39E-03 98.0%2.01E-05 4.82E-04 1.76E-01 8.79E-05 71-43-2 Benzene**Yes 78.11 5.96E-01 9.52E-02 98.0%4.35E-04 1.04E-02 3.81E+00 1.90E-03 75-25-2 Bromodichloromethane*No 163.83 2.25E-04 7.54E-05 98.0%3.44E-07 8.26E-06 3.02E-03 1.51E-06 75-15-0 Carbon disulfide*Yes 76.13 1.42E-02 2.21E-03 98.0%1.01E-05 2.42E-04 8.83E-02 4.41E-05 56-23-5 Carbon tetrachloride**Yes 153.84 2.81E-02 8.85E-03 98.0%4.04E-05 9.70E-04 3.54E-01 1.77E-04 463-58-1 Carbonyl sulfide Yes 60.07 0.21 2.53E-02 98.0%1.15E-04 2.77E-03 1.01E+00 5.06E-04 108-90-7 Chlorobenzene**Yes 112.56 0.03 7.38E-03 98.0%3.37E-05 8.09E-04 2.95E-01 1.48E-04 75-00-3 Chloroethane (ethyl chloride)*Yes 64.52 2.45E-02 3.24E-03 98.0%1.48E-05 3.55E-04 1.29E-01 6.47E-05 67-66-3 Chloroform**Yes 119.39 2.81E-02 6.87E-03 98.0%3.14E-05 7.53E-04 2.75E-01 1.37E-04 75-45-6 Chlorodifluoromethane No 86.47 0.40 7.06E-02 98.0%3.22E-04 7.74E-03 2.83E+00 1.41E-03 74-87-3 Chloromethane (methyl chloride)*Yes 50.49 0.03 3.53E-03 98.0%1.61E-05 3.87E-04 1.41E-01 7.06E-05 106-46-7 Dichlorobenzene (1,4-Dichlorobenzene)**Yes 147.00 0.03 8.46E-03 98.0%3.86E-05 9.27E-04 3.38E-01 1.69E-04 75-43-4 Dichlorodifluoromethane*No 120.91 0.26 6.43E-02 98.0%2.93E-04 7.04E-03 2.57E+00 1.29E-03 75-71-8 Dichlorofluoromethane No 102.92 0.40 8.41E-02 98.0%3.84E-04 9.21E-03 3.36E+00 1.68E-03 75-09-2 Dichloromethane (Methylene Chloride)**Yes 84.94 2.81E-02 4.89E-03 98.0%2.23E-05 5.35E-04 1.95E-01 9.77E-05 64-17-5 Ethanol*No 46.08 2.24E+01 2.12E+00 98.0%9.66E-03 2.32E-01 8.46E+01 4.23E-02 100-41-4 Ethylbenzene*Yes 106.16 4.67E+00 1.01E+00 98.0%4.63E-03 1.11E-01 4.06E+01 2.03E-02 106-93-4 Ethylene dibromide (1,2-Dibromoethane)**Yes 187.88 2.81E-02 1.08E-02 98.0%4.93E-05 1.18E-03 4.32E-01 2.16E-04 75-69-4 Fluorotrichloromethane No 137.40 0.37 1.03E-01 98.0%4.72E-04 1.13E-02 4.13E+00 2.07E-03 110-54-3 Hexane*Yes 86.18 0.30 5.37E-02 98.0%2.45E-04 5.89E-03 2.15E+00 1.07E-03 7647-01-0 Hydrochloric acid (e)Yes 36.50 42.00 3.14E+00 0.0%7.23E-01 1.74E+01 6.34E+03 3.17E+00 2148878 Hydrogen Sulfide(f)No 34.081 25.00 1.74E+00 98.0%7.97E-03 1.91E-01 6.98E+01 3.49E-02 7439-97-6 Mercury (total) (g)Yes 200.61 2.92E-04 1.20E-04 0.0%2.74E-05 6.57E-04 2.40E-01 1.20E-04 78-93-3 Methyl ethyl ketone No 72.11 11.86 1.75E+00 98.0%8.00E-03 1.92E-01 7.01E+01 3.50E-02 108-10-1 Methyl isobutyl ketone*Yes 100.16 1.35 2.77E-01 98.0%1.26E-03 3.03E-02 1.11E+01 5.53E-03 127-18-4 Perchloroethylene (tetrachloroethylene)Yes 165.83 0.04 1.32E-02 98.0%6.05E-05 1.45E-03 5.30E-01 2.65E-04 108-88-3 Toluene**Yes 92.13 1.37 2.59E-01 98.0%1.18E-03 2.83E-02 1.03E+01 5.17E-03 79-01-6 Trichloroethylene (trichloroethene)**Yes 131.40 0.03 7.56E-03 98.0%3.45E-05 8.28E-04 3.02E-01 1.51E-04 75-01-4 Vinyl chloride*Yes 62.50 0.04 5.46E-03 98.0%2.50E-05 5.99E-04 2.19E-01 1.09E-04 1330-20-7 Xylenes**Yes 106.16 1.31 2.86E-01 98.0%1.30E-03 3.13E-02 1.14E+01 5.72E-03 Various PAH (i)Yes --------2.23E-05 5.36E-04 1.96E-01 9.78E-05 91-20-3 Naphthalene (i)Yes 128.17 ------3.17E-05 7.60E-04 2.78E-01 1.39E-04 50-00-0 Formaldehyde (i)Yes 30.03 ------1.07E-01 2.57E+00 9.37E+02 4.68E-01 Totals: TACs 0.96 23.01 8397.86 4.20 Totals: HAPs 2.73 20.50 7483.48 3.74 Single HAP 1.80 17.36 6335.90 3.17 Criteria Air Pollutants Molecular Weight (lb/lbmol) Inlet Concentration of Compound (ppmv)(b) Uncontrolled Pollutant Flow Rate to Flare (tons/yr) Flare Destruction Efficiency (%) (k) Maximum Emissions from Flare (lbs/hr) Maximum Emissions from Flare (lbs/day) Maximum Emissions from Flare (lbs/yr) Maximum Emissions from Flare (tons/yr) 86.18 600.0 10.57 98.0%0.483 11.60 422.99 0.21 86.18 600.0 10.57 98.0%0.483 11.60 422.99 0.21 Criteria Air Pollutants Molecular Weight (lb/lbmol) Concentration of Compound (ppmv) Emission Factor (lb/MMBtu HHV) Emission Factor (lb/MMscf) Maximum Emissions from Flare (lbs/hr) Maximum Emissions from Flare (lbs/day) Maximum Emissions from Flare (lbs/yr) Maximum Emissions from Flare (tons/yr) 0.038 2.96 70.94 2,586.26 1.29 ----0.025 1.94 46.67 1,701.49 0.85 ----0.06 4.67 112.01 4,083.57 2.04 64.06 25 --0.75 17.97 655.12 0.33 Particulate Matter (PM10/PM2.5)------7.6 1.37 32.83 505.85 0.25 Nitrogen Oxides (NOX) Carbon Monoxide (CO) Sulfur Oxides (SOx)(d) Volatile Organic Compounds (VOCs) Non-Methane Organic Compounds (NMOCs) Volatile Organic Compounds (VOCs) Notes: and theTitle III Clean Air Act Amendments, 1990, and include compounds found in landfill gas, as determined from a list in AP-42 Tables 2.4-1("Default Concentrations for Landfill Gas Constituents, 11/98"). (c) Inlet concentration based on engineering estimate for worst-case emissions. (d) SOx emissions are conservatively based on 25 ppmv H2S in the maximum waste gas flow to the flare. 100% conversion of H2S to SO2 is assumed to occur at the flare. (h) Flaring operations are estimated at 875 hours per annum, totalized across eight anticipated flaring modes. Select flaring modes may potentially require fuel gas assist (i.e., utility gas). 0.0001240 lb/mmscf 0.000176 lb/mmscf 0.594000 lb/mmscf (j) Flare maximum waste gas heat release (i.e., rated capacity) is 77.8 MMBTU/hr (HHV). Across the eight anticipated flaring modes, the design heat release ranges from 6.0-77.8 MMBTU/hr (HHV). (k) Destruction efficiency of VOCs based on Manufacturer's Guarantee. Variables: MODEL INPUT VARIABLES: Heating Value (d)1,012 BTU/SCF (HHV) Maximum Hours of Operation (h)875 hrs/yr Methane Content into RNG Facility 42.7 vol% Waste Gas Flow Rate to Flare (maximum)3,000 SCFM(d) Waste Gas Flow Rate to Flare (maximum)180,000 SCFH(d) Waste Gas Throughput to the Flare (operating)66.6 MMSCF/yr Flare Waste Gas Heat Release (maximum) (j)77.8 MMBtu/hr (HHV) Flare Waste Gas Heat Release (operating, annual) (h)68,060 MMBtu/yr (HHV) Criteria pollutant emission factors used for the flare: Pollutant Emission Factor Data Source NMOCs/VOCs 98% Destruction Efficiency (k)Manufacturer's Guarantee NOx 0.025 lb/MMBtu (HHV)Manufacturer's Guarantee CO 0.06 lb/MMBtu (HHV)Manufacturer's Guarantee SO2 25 ppmv as H2S Maximum Expected PM10/PM2.5 7.6 lb/MMSCF AP-42 Table 1.4-2 (PM total) CONVERSIONS ton conversion 2000 lbs lb conversion 453.6 g hour conversion 60 min day conversion 24 hrs 12 months 365 days mol conversion 24.04 L @ STP cf conversion 28.32 L mmbtu conversion 1,000,000 btu (d) Waste gas energy content is expected to range between 156-973 BTU/SCF (HHV). Flare maximum heat release based upon 432.1 BTU/SCF (HHV). The heating value of Methane assumed to be 1012 (a) Gas entering facility from Coyote Canyon Landfill. List of hazardous air pollutants was from emission factors for natural gas combustion from AP-42, Tables 1.4-3 and 1.4-4 Naphthalene(k)Formaldehyde(k)PAH(k) (Emission Factors from Natural Gas Combustion) and theTitle III Clean Air Act Amendments, 1990, and include compounds found in landfill gas, as Natural Gas Combustion) (b) Initial concentrations based on "Waste Industry Air Coalition (WIAC) Comparison of Recent Landfill Gas Analyses with Historic AP-42 Values," and site-specific data collection from a May 18, 2023 AccuLabs Analysis at Coyote Canyon Landfill adjusted to 41.68% methane, indicated with "*". If ND, detection limite was used. Site-specific data collected from the May 18, 2023 labs adjusted to 42.7% methane, indicated with "**". TGNMO estimated from engineering analysis concentrated up. (i) Based on correspondence between South Coast Air Quality Management District and Orange County Integrated Waste Management Department dated May 18, 2007. SCAQMD confirmed the specific use of (e) Concentration of HCl is based on AP-42 Section 2.4.4.2. (g) Concentration of Mercury based on the EPA AP-42 Section 2.4 Table 2.4-1 (11/98). (f) Concentration maximum expected. Natural Gas Power (Emergency Backup) Generator for Facility MMBtu/hr bhp g/bhp-hr lb/MMBtu hr/day hrs/yr lb/hr lb/day lb/yr tons/yr CO 0.21 --8 200 0.14 1.13 28.15 0.014 SOx --5.88E-04 8 200 0.0014 0.011 0.27 0.00014 NOx 0.12 --8 200 0.08 0.64 16.08 0.008 VOC 0.24 --8 200 0.16 1.29 32.17 0.016 PM10/PM2.5 --9.91E-03 8 200 0.02 0.18 4.61 0.002 1 Emission factor for CO, NOx, and VOCs from manufacturer. Emission factor for PM/PM10/PM2.5 and SOx from AP-42 Table 3.2-2 for 4-stroke lean-burn engines. 2 Based on estimated maximum usage of 8 hours per day, 200 hours per year. TABLE 11 POTENTIAL TO EMIT EMISSION SOURCE ESTIMATES FOR EMERGENCY GENERATOR COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA Criteria Pollutant Engine Rating Emission Factor1 Operational Hours2 Maximum Emissions 2.3247 304 Engine Rating Emission s Factor MMBtu/hr lb/MMBtu hr/day hrs/yr lb/hr lb/day lb/yr tons/yr 79-34-5 1,1,2,2-Tetrachloroethane 2.3247 4.00E-05 8 200 9.30E-05 7.44E-04 1.86E-02 9.30E-06 79-00-5 1,1,2-Trichloroethane 2.3247 3.18E-05 8 200 7.39E-05 5.91E-04 1.48E-02 7.39E-06 75-34-3 1,1-Dichloroethane 2.3247 2.36E-05 8 200 5.49E-05 4.39E-04 1.10E-02 5.49E-06 107-06-2 1,2-Dichloroethane 2.3247 2.36E-05 8 200 5.49E-05 4.39E-04 1.10E-02 5.49E-06 78-87-5 1,2-Dichloropropane 2.3247 2.69E-05 8 200 6.25E-05 5.00E-04 1.25E-02 6.25E-06 106-99-0 1,3-Butadiene 2.3247 2.67E-04 8 200 6.21E-04 4.97E-03 1.24E-01 6.21E-05 542-75-6 1,3-Dichloropropene 2.3247 2.64E-05 8 200 6.14E-05 4.91E-04 1.23E-02 6.14E-06 91-57-6 2-Methylnaphthalene 2.3247 3.32E-05 8 200 7.72E-05 6.17E-04 1.54E-02 7.72E-06 540-84-1 2,2,4-Trimethylpentane 2.3247 2.50E-04 8 200 5.81E-04 4.65E-03 1.16E-01 5.81E-05 203-96-8 Acenaphthene 2.3247 1.25E-06 8 200 2.91E-06 2.32E-05 5.81E-04 2.91E-07 120-12-7 Acenaphthylene 2.3247 5.53E-06 8 200 1.29E-05 1.03E-04 2.57E-03 1.29E-06 75-07-0 Acetaldehyde 2.3247 8.36E-03 8 200 1.94E-02 1.55E-01 3.89E+00 1.94E-03 107-02-8 Acrolein 2.3247 5.14E-03 8 200 1.19E-02 9.56E-02 2.39E+00 1.19E-03 71-43-2 Benzene 2.3247 4.40E-04 8 200 1.02E-03 8.18E-03 2.05E-01 1.02E-04 205-99-2 Benzo(b)fluoranthene 2.3247 1.66E-07 8 200 3.86E-07 3.09E-06 7.72E-05 3.86E-08 192-97-2 Benzo(e)pyrene 2.3247 4.15E-07 8 200 9.65E-07 7.72E-06 1.93E-04 9.65E-08 191-24-2 Benzo(g,h,i)perylene 2.3247 4.14E-07 8 200 9.62E-07 7.70E-06 1.92E-04 9.62E-08 92-52-4 Biphenyl 2.3247 5.41E-04 8 200 1.26E-03 1.01E-02 2.52E-01 1.26E-04 56-23-5 Carbon Tetrachloride 2.3247 3.65E-05 8 200 8.49E-05 6.79E-04 1.70E-02 8.49E-06 108-90-7 Chlorobenzene 2.3247 3.04E-05 8 200 7.07E-05 5.65E-04 1.41E-02 7.07E-06 75-00-3 Chloroethane 2.3247 1.87E-06 8 200 4.35E-06 3.48E-05 8.69E-04 4.35E-07 67-66-3 Chloroform 2.3247 2.85E-05 8 200 6.63E-05 5.30E-04 1.33E-02 6.63E-06 218-01-9 Chrysene 2.3247 6.93E-07 8 200 1.61E-06 1.29E-05 3.22E-04 1.61E-07 100-41-4 Ethylbenzene 2.3247 3.97E-05 8 200 9.23E-05 7.38E-04 1.85E-02 9.23E-06 106-93-4 Ethylene Dibromide 2.3247 4.43E-05 8 200 1.03E-04 8.24E-04 2.06E-02 1.03E-05 206-44-0 Fluoranthene 2.3247 1.11E-06 8 200 2.58E-06 2.06E-05 5.16E-04 2.58E-07 86-73-7 Fluorene 2.3247 5.67E-06 8 200 1.32E-05 1.05E-04 2.64E-03 1.32E-06 50-00-0 Formaldehyde 2.3247 5.28E-02 8 200 1.23E-01 9.82E-01 2.45E+01 1.23E-02 110-54-3 Hexane 2.3247 1.11E-03 8 200 2.58E-03 2.06E-02 5.16E-01 2.58E-04 67-56-1 Methanol 2.3247 2.50E-03 8 200 5.81E-03 4.65E-02 1.16E+00 5.81E-04 75-09-2 Methylene Chloride 2.3247 2.00E-05 8 200 4.65E-05 3.72E-04 9.30E-03 4.65E-06 91-20-3 Naphthalene 2.3247 7.44E-05 8 200 1.73E-04 1.38E-03 3.46E-02 1.73E-05 218-01-9 PAH 2.3247 2.69E-04 8 200 6.25E-04 5.00E-03 1.25E-01 6.25E-05 85-01-8 Phenanthrene 2.3247 1.04E-05 8 200 2.42E-05 1.93E-04 4.84E-03 2.42E-06 108-95-2 Phenol 2.3247 2.40E-05 8 200 5.58E-05 4.46E-04 1.12E-02 5.58E-06 129-00-0 Pyrene 2.3247 1.36E-06 8 200 3.16E-06 2.53E-05 6.32E-04 3.16E-07 100-42-5 Styrene 2.3247 2.36E-05 8 200 5.49E-05 4.39E-04 1.10E-02 5.49E-06 79-34-5 Tetrachloroethane 2.3247 2.48E-06 8 200 5.77E-06 4.61E-05 1.15E-03 5.77E-07 108-88-3 Toluene 2.3247 4.08E-04 8 200 9.48E-04 7.59E-03 1.90E-01 9.48E-05 75-01-4 Vinyl Chloride 2.3247 1.49E-05 8 200 3.46E-05 2.77E-04 6.93E-03 3.46E-06 1330-20-7 Xylene 2.3247 1.84E-04 8 200 4.28E-04 3.42E-03 8.55E-02 4.28E-05 Total HAPs 0.17 1.35 33.87 0.017 1 Emission factor for HAPs from AP-42 Table 3.2-3 for 4-stroke lean-burn engines. 2 Based on estimated maximum usage of 8 hours per day, 1 day per month. CAS Number Hazardous Air Pollutants (HAPs) Operational Hours2 Maximum Emissions lb/hr lbs/day tons/yr lb/hr lbs/day tons/yr lb/hr lbs/day tons/yr lb/hr lbs/day tons/yr lb/hr lbs/day tons/yr lb/hr lbs/day tons/yr Main Fuel 0.73 17.44 2.60 2.42 58.14 8.65 0.229 5.49 0.92 0.459 11.01 2.01 0.484 11.62 2.12 0.56 13.43 2.45 Supplemental Fuel 0.50 11.88 0.54 1.65 39.61 1.81 0.01 0.34 0.06 0.010 0.24 0.01 0.00 0.02 0.004 0.004 31.00 0.02 1.94 46.67 0.85 4.67 112.01 2.04 1.368 32.83 0.25 0.749 17.97 0.33 0.48 11.60 0.21 2.73 20.50 3.74 0.08 0.64 0.01 0.14 1.13 0.01 0.023 0.18 0.00 0.001 0.01 0.00 0.16 1.29 0.02 0.17 1.35 0.02 3.25 76.64 4.00 8.88 210.88 12.51 1.63 38.85 1.24 1.22 29.23 2.35 1.13 24.53 2.35 3.46 66.29 6.23 Note: Pounds per day are based on 24 hours of operation a day. RNG Flare Thermal Oxidizer Equipment TOTAL EMISSIONS TABLE 12 PROPOSED POTENTIAL TO EMIT EMISSIONS SUMMARY COYOTE CANYON RNG FACILITY NOx VOCsCOPM-10/PM-2.5 SOx HAPs Criteria Pollutant Emissions NEWPORT BEACH, CALIFORNIA Emergency Generator TOX RNG Flare tons/yr tons/yr tons/yr Ratio 1:1.2 lb/day lb/day lb/day TOX/Flare Nitrogen Oxides (NOX)3.996 10.00 No 4.00 No NA 29.32 46.67 1.00 Yes/Yes Carbon Monoxide (CO)12.51 50.00 No 29.00 No NA 97.75 112.01 1.00 Yes/Yes Sulfur Dioxide (SO2)2.35 70.00 No 4.00 No NA 11.25 17.97 1.00 Yes/Yes Volatile Organic Compounds (VOCs)2.35 10.00 No 4.00 No NA 11.64 11.60 1.00 Yes/Yes Particulate Matter (PM10)1.24 70.00 No 4.00 No NA 5.83 32.83 1.00 Yes/Yes Total Hazardous Air Pollutants (HAPs) 6.23 25.00 No N/A N/A NA N/A N/A N/A N/A Single HAP 1.94 10.00 No N/A N/A NA N/A N/A N/A N/A Notes: 1 Major source thresholds were taken from SCAQMD Rule 1302(s) 2 Offset trigger levels were taken from SCAQMD Rule 1304(d)(2) 3 Offset evaluation performed in accordance with SCAQMD Rule 1303 (b)(2) 4 BACT threshold taken from SCAQMD BACT policy TABLE 14 NEW SOURCE REVIEW THRESHOLD EMISSION LEVELS NEWPORT BEACH, CALIFORNIA Major Source Threshold1 Major Source? BACT Threshold4Pollutant Proposed RNG Facility Emissions Offset Trigger Levels2 Offsets Required? Proposed Source Trigger BACT? Offsets Required to Purchase COYOTE CANYON RNG FACILITY PTC/PTO Application www.scsengineers.com A-3 Appendix A Facility Plans 34250-2001-D-PID POINT OF RECEIPT COYOTE CANYON P&ID FROM BIOFUELS NB D.L. 50 PSIG M.A.O.P 46 PSIG MOP 40 PSIG MIN. OP 16 PSIG 3" NO 1"1" TIT TE TW 1" AI 4- 2 0 m A 3" NO 1/ 2 " 1/ 2 " 1/ 2 " HV 1/ 2 " 1/ 2 " PIC 1/4" PCV 1/4" PCV 1/4" 1/4" 1/ 4 " DE DE DO NOTE 4 DO NOTE 5 3/ 4 " 3" NO 3" NC 3/ 4 " FE UIT 1/ 2 " 1/ 2 " TF1 TW TE TW RTD 1" 1" 1" RS-485 N-TRON ETHERNET 3/ 4 " 3/ 4 " AE SAMPLER 1/2" DO J6 1/ 2 " 1/ 2 " HV PIC 1/ 2 " PCV SERVICE 3" HV PIC 1/ 2 " 1/ 2 " 1/ 2 " 1/ 2 " SE N S E L I N E SE N S E L I N E 1/4" 1/4" 1/ 4 " 1/ 4 " PCV 1/ 4 " PCV 1/ 4 " 1/ 4 " 1/ 4 " 1/ 4 " 1/ 4 " PCV PCV 1/ 4 " 1/ 4 " 4" 1/ 2 " 3/ 4 " 1/ 2 " 1/ 2 " 4" NO 3/ 4 " RADIO SPP-1 RS 232 GAS CONTROL CELLULAR CELLULAR SPP-1 SPP-1 CUSTOMER MODBUS TCP ETHERNET FEI PCV → 02 PI → PCV UIT 02SPP-1 RS-485 AI 4-20 mA DI DI UIT H2S 4-20 mAAI → PCV SPP-1 UIT NGC N-TRON DI ETHERNET → FCV RS-485 UIT TF1 RS-485 DI DI DI DI HELIUM PLS PLS CAL SAMPLE GAS 2"2" 2"2" 1/ 2 " 1/ 2 " 2" LI 2"2"2" 1/ 2 " 1/ 2 " LI V-100 LIT LIT AI LI H 4- 2 0 m A AILIH 4- 2 0 m A 1" 2"1" 1/ 2 " 1/ 2 " PDIT 1/4"1/ 4 " 1/ 4 " NC PI1/4" AI PDI H 4- 2 0 m A 4" 3/4" 3" NO 2" 1" LO PSV 1/4" 1" 3" NO 4" 3/4" 1/2"1/2" 3" NC 1/ 4 " 3" 1/ 4 " 1/ 2 " 3" NO 3/ 4 " SU P P L Y T O P U M P & E X P A N S I O N L I N E OD O R A N T I N J E C T I O N 1/ 4 " PCV LO PSV LO PSV PSV LO AI RS485DI DI RS485AI HV COYOTE CANYON * XCOM XCOM 3" 4"x3" LEGEND & PRESSURE BLOCK RETURN LINE 102 102 105 101 104 100 100 101 100 101 103 101 100 100100 100 100 100 100A 100B 001 101 101 101 102 100 100 101 101 100 100 100 101 101B 101A 103 101A 101B 101 102A 102B 102 102101 102 106 3/ 4 " 2" CORROSION COUPON ODORANT TAP 89395.000 8"x4" 4"x3" D.L. XXX PSIG M.A.O.P XXX PSIG MOP XXX PSIG MIN.OP XXX PSIG 4" x 3 " A. JACKSON 09/17/21 D. NGUYEN 09/17/21 I. GHANEM 09/17/21 S. LY 09/17/21 P. PATEL 09/17/21 OVER PRESSURE PROTECTION HOLD XX' OD x XX' S/S XXX XXX XXX FILTER SEPARATOR Cu Ft/Hr. V-100 PSIG °F SIZE: CAPACITY: DESIGN: GALLONS ODORANT INJECTION SYSTEM XXX MODEL: NJEX 6302 CAPACITY: 3/ 4 " 1/4" STORAGE TANK PCV 101 MONITOR 3"3"TO #21027848 * 53% ** 60% V-100 YZ ODORIZER INST. CABINETINST.CABINET 12' x 8' ANALYZER SHELTER 10' x 8'ELECTRICALSHELTER TP XX NEW 8"PIPELINE POINT OF RECEIPT FOR PLOT PLAN SEE DWG: 2450-3002-D-PIP EXISTING 8" SERVICE LINE FUTURE AT&T BACKUP GENERATOR NEW 8'x11' T-MOBILE EQUIPMENT ENCLOSURE NEW VERIZON & T-MOBILE MONOPOLE NEW 8'x10' VERIZON GENERATOR ENCLOSUREEXISTING UNDERGROUND LINES (TYP.) NEW UNDERGROUND COAX JOINT TRENCH EXISTING CONDUIT TRENCH SITE LIMITS NOTES: 1. ALL DIMENSIONS AND ELEVATIONS ARE IN FEET AND INCHES. ISSUED FOR 30% REVIEW 0 5'10' SCALE: 3/16" = 1'-0" PL A N T N 6'-0" 3'-6"75'-0"15'-6" 15 ' - 6 " 15 ' - 0 " SL I D I N G D O O R 29 ' - 6 " 60 ' - 0 " 10' x 8' ELECTRICAL SHELTER 12' x 8' ANALYZER SHELTER INST. CABINET INST. CABINET YZ ODORIZER 2'-6" 7'-0" V-100 16'-10" PCV 102 PCV 101 FE 101 OPP 100 2 TP 1 TP 3 TP 100'-0" 89395.000 POINT OF RECEIPT BIOME RULE 45 - COYOTE CANYON PLOT PLAN 34250-3002-D-PIP G. CASILLAS 09/20/21 G. CASILLAS 09/20/21 B. KIKAWA 09/23/21 P. DISOMMA 09/23/21 S. LY 3/16" = 1'-0"89395.000 *BDWG CLASS: DWG DIST: SCALE: DRAWING NUMBER: REVREV NO DRAWN CHK'D ENG FILE NOPROJ APV SCG ENG APV DESCRIPTIONDATE WOA BY DATE SCG ENG APV: PROJ APV: CHECKED: DRAWN: DESIGNED: ENG FILE NO: WOA: 20662 NEWPORT BEACH DR.NEWPORT BEACH A 09/23/21 GKC BDK PD SQL * ISSUED FOR 10% REVIEW B 10/15/21 GKC BDK PD SQL ISSUED FOR 30% REVIEW*89395.000 PTC/PTO Application www.scsengineers.com C-1 Appendix B Equipment Specifications/Standards PTC/PTO Application www.scsengineers.com C-2 Thermal Oxidizer Proposal Prepared for: A Conifer Custom Solution Utilizing A Thermal Recuperative Oxidizer (TRO) System For the Abatement of Waste Gas From an Archaea LFG to RNG Plant To be Located in: California (Coyote Canyon) 6515 Willowbrook Park Houston, Texas 77066 832.476.9024 www.conifersystems.com Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 2 Confidential Information All drawings, specifications, technical data, including this proposal, and other information we provide, is considered confid ential, and the exclusive and proprietary property of Conifer Systems. The information may be used only for the purpose for which the material was expressly loaned and shall not be reproduced, copied, or used in any way without the written permission of Conifer Systems. Customer I Steve Chafin Address I 500 Technology Drive, Upper Floor Canonsburg, PA 1531 Company I Archaea Holdings, LLC Telephone I +1 (832) 381-4040 E-Mail I steve.chafin@petroexergy.com Date I September 29th, 2023 Proposal Number I 2249-21 Rev.6 Proposed Solution I TRO w/ External Heat Recovery V1 TRO Example – Actual may Vary Your Application Engineer Your Sales Representative James Smith Cary Allen Sr. Application Engineer Technical Director jsmith@conifersytems.com callen@conifersystems.com 832.370.0358 832.374.5089 TABLE OF CONTENTS SECTION 1: EXECUTIVE SUMMARY ........................................................................................... 4 THEORY OF OPERATION ......................................................................................................................... 4 PROPOSAL OVERVIEW ........................................................................................................................... 6 SECTION 2: DESIGN CONSIDERATIONS .................................................................................... 8 PROCESS DATA .................................................................................................................................... 8 OPERATING CONDITIONS........................................................................................................................ 9 UTILITIES ............................................................................................................................................ 9 EMISSIONS GUARANTEE ....................................................................................................................... 10 PERFORMANCE GUARANTEE PROVISIONS ................................................................................................. 10 SECTION 3: EQUIPMENT SPECIFICATIONS ............................................................................. 11 5,000 SCFM THERMAL RECUPERATIVE OXIDIZER – LOW NOX SPECIFICATION .................................................. 11 SECTION 4: RESPONSIBILITY MATRIX ..................................................................................... 16 SECTION 5: DOCUMENTATION, SERVICES, & CLARIFICATIONS .......................................... 17 REVIEW & APPROVAL OF DOCUMENTATION ............................................................................................. 17 SURFACE PAINTING & PREPARATION ...................................................................................................... 17 QUALITY ASSURANCE .......................................................................................................................... 17 STANDARDS & CODES ......................................................................................................................... 17 STANDARD PROJECT CLARIFICATIONS ...................................................................................................... 18 SECTION 6: ATTACHMENTS ...................................................................................................... 19 PRELIMINARY FLOW SCHEMATIC DRAWING ....................................................................................................... 19 FIELD SERVICE RATE SHEET ............................................................................................................................ 19 WARRANTY INFORMATION ........................................................................................................................... 19 GENERAL TERMS & CONDITIONS OF SALE ......................................................................................................... 19 Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 4 SECTION 1: EXECUTIVE SUMMARY Theory of Operation Thermal Recuperative Oxidizer (TRO) The method of reduction of Volatile Organic Compounds in a Thermal Oxidizer revolves around thermal destruction. The chemical process is quite simple; the process air stream temperature is raised to a point that the chemical bonds that hold the volatile organic molecules together are broken. The VOCs in the process air stream are converted to combinations of carbon dioxide and water vapor by the high temperature of the combustion chamber. This exothermic process also releases a substantial amount of additional heat. For gas streams with low levels of oxygen, dilution with additional air may be required to ensure that enough oxygen is present for complete oxidation of the pollutants. Additionally, more air may be added during periods of high VOC loading to protect from overheating of the internal system components. However, this excess heat does have the benefit of reducing demand on the burner. In a recuperative system heat from the exhaust gas is typically recovered and applied to the incoming air stream as a way to reduce fuel consumption. Heat may also be recovered for external use depending on plant requirements. Thermal Recuperative Oxidizer – Actual may Vary Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 5 Application Specific Details - This oxidizer is intended for use in Archaea’s standard V1 3,200 SCFM size RNG plant. - The oxidizer in this application uses two heat exchangers. The primary heat exchanger is used to pre-heat the incoming dilution air in order to minimize fuel consumption. The secondary heat exchanger recovers heat from the oxidizer exhaust for external use. In this case, incoming process gas from the CO2 separation membrane (by others) is heated to a target temperature and sent to the TSA unit (by others) to heat the media. A set of high temperature rated control dampers shall be used to bypass gas around the hot side of the heat exchangers as a means of controlling the temperature. During a TSA cooling cycle the secondary heat exchanger may be bypassed immediately to eliminate any time lost to cooling the heat exchanger. During a heating cycle it may take up to 20 minutes for the gas to fully come back up to temperature before it’s ready to send to the TSA. During this time the gas may be circulated back to the inlet of the oxidizer as long as it is cooled prior to reaching the flame arrestor. This would allow at least a portion, if not all, of the warm-up time to take place while the TSA is depressurizing. The gas coming from the TSA during a depressurization cycle, or at the start of the heating cycle should not be sent to the oxidizer as this would increase the total methane load over maximum design capacity of the system. - After going through the TSA the gas is expected increase in VOC and water vapor content up to the amount specified in section 3.1. No other changes in composition are expected. It is recommended that additional filtration (not included here) be installed upstream of the oxidizer if the additional water vapor and organic compounds have the potential to condense before reaching the oxidizer as this may lead to plugging of the flame arrestor. See section 3.1 for more design clarifications. - When the gas is first passed through the TSA a volume will be displaced that contains a higher concentration of methane (>50% by volume). The oxidizer is not designed to process this high concentration “slug”. The gas should be momentarily directed to a separate flare, oxidizer, or other piece of equipment until methane concentration returns to normal. - The minimal amount of oxygen present prevents the waste gas stream from becoming combustible. Conifer has provided a standard flame arrestor on the unit for flashback protection. However, this may not be sufficient to prevent ignition within the process line upstream of the arrestor if higher levels of oxygen are present. The process gas should always be delivered as oxygen deficient when the methane concentration is near the flammable limits. If greater oxygen content is possible (typically >6% by volume) then design of the feed equipment to the oxidizer may need to change. Customer bears full responsibility for the process conditions shown in section 3.1 as well as any changes which could impact equipment performance or safety. - To help deal with any potential silica buildup due to the combustion of any siloxanes or other silicone bound compounds the heat exchanger has been designed with an in-line tube arrangement to make cleanout easier. The tube bank is also slightly oversized to account for a certain amount of additional resistance to heat transfer due to fouling. However, these are just basic precautionary measures. No silica forming compounds have been specified so no guarantee has been made regarding performance degradation of any part of the system due to fouling. Alternate heat exchanger designs are available if higher amounts of silica forming compounds are expected. Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 6 Proposal Overview This proposal details the supply of one (1) Thermal Recuperative Oxidizer with installation supervision and commissioning services included. The 5,100 SCFM system shall be capable of treating up to 1,700 SCFM total waste gas combined with up to 3,400 SCFM of dilution air for oxygen addition. Additional cooling air may be added downstream of the combustion zone for temperature control. The fresh air source shall be ambient air provided through the Conifer supplied dilution and cooling air fans. The system is assumed to be ground mounted, outdoors, and operated in a Class I Div. II electrical area. All electronic instruments on the oxidizer shall be rated for the classified area. Control panel enclosure is purged with appropriate conduit seal-offs for operation in the classified area when the doors are closed. All burner mounted components shall rated for the classified area. For clarity the burner itself cannot be “classified” due to its inherent function. Burners are not UL approved. In the first revision, Rev.1 of the proposal, the standard unit was slightly modified to better suit different design conditions. Modifications include: • Increased the NRU waste gas line size from 4” to 6”. • Increased the oxidizer inlet line size from 10” to 12”. This includes a larger flame arrestor. • Estimated gas consumption and exhaust stack exit conditions have been updated based on the new design conditions. • Pricing has been updated. In the previous revision, Rev.2 of the proposal, process conditions have been updated as per new information from Archaea. These conditions are reiterated in section 3.1 of the proposal. No changes to the equipment are necessary. Pricing has also been updated based on current vendor quotes for major components. In the previous revision, Rev.3 of the proposal, Conifer has made the following changes: • The emissions guarantee for NOx and CO has been updated. See section 3.4 for more information. • Additional information has also been provided in section 4.1 on the total combustion chamber volume. • Pricing, technical specifications, and the preliminary general arrangement drawing have been updated to include the Low-NOx burner in the base bid. In the previous revision, Rev. 4 of the proposal, process conditions have been updated as per new information from Archaea. These conditions are reiterated in section 3.1 of the proposal. Components changed in Rev.1 have been reverted back to standard size. Pricing has also been updated based on current projected cost of standard V1 TRO systems. In this revision, Rev.5 of the proposal, process conditions have been updated based on Revision C of the process specification dated 7/21/23. Process conditions are reiterated in section 2.1 of this proposal. Conifer confirms that the system as designed is suitable for these conditions. Pricing and schedule have also been removed for this technical proposal. Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 7 In this revision, Rev.6 of the proposal, process conditions have been updated based on revision D of the process specification dated 9/27/23. Process heat release has also been stated on a higher heating value (HHV) and lower heating value (LHV) basis. No changes to the equipment have been made. Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 8 SECTION 2: DESIGN CONSIDERATIONS Process Data Stream #1 Application: Membrane Waste Gas / TSA Regen Maximum process volume: Up to 1,289.6 SCFM (w) / 1286.0 SCFM (d) Process Gas Inlet Temperature: Up to 300°F (return from heating) Process Gas Inlet Pressure: ~2.5 psig at heat exchanger inlet <0.5 psig at oxidizer inlet 15 psig max. allowable at start-up Process Volume Turndown Requirement: ~4:1 *Expected VOC Heat Release: LHV Basis: 4,337,477 BTU/hr HHV Basis: 4,762,898 BTU/hr **Process Gas Composition at max. Condition: - Nitrogen, N2 6.02% Vol. or 343.73 lb/hr - Oxygen, O2 5.88% Vol. or 383.91 lb/hr - Water Vapor, H2O 0.28% Vol. or 10.29 lb/hr - Carbon Dioxide, CO2 82.19% Vol. or 7,375.72 lb/hr - Methane, CH4 5.48% Vol. or 179.35 lb/hr - Other Non-Corrosive VOCs (as Hexane, C6H14) 0.14% or 24.56 lb/hr - ***Hydrogen Sulfide, H2S <0.01% or 0.29 lb/hr - Total 100.00% Vol. or 8,317.84 lb/hr Stream #2 Application: NRU Waste Gas Maximum process volume: Up to 551.4 SCFM (d) Process Gas Inlet Temperature: Up to 100°F Process Gas Inlet Pressure: <0.5 psig at oxidizer inlet 15 psig max. allowable at start-up Process Volume Turndown Requirement: ~4:1 *Expected VOC Heat Release: LHV Basis: 4,642,929 BTU/hr HHV Basis: 5,113,298 BTU/hr **Process Gas Composition at max. Condition: - Nitrogen, N2 82.11% Vol. or 2,005.47 lb/hr - Oxygen, O2 2.44% Vol. or 68.18 lb/hr - Water Vapor, H2O 0.00% Vol. or 0.00 lb/hr - Carbon Dioxide, CO2 <0.01% Vol. or 0.18 lb/hr - Methane, CH4 15.44% Vol. or 216.02 lb/hr - Other Non-Corrosive VOCs (as Hexane, C6H14) 0.00% or 0.00 lb/hr - ***Hydrogen Sulfide, H2S 0.00% or 0.00 lb/hr - Total 100.00% Vol. or 2,289.79 lb/hr *The VOC/HAP load shown represents the expected operating conditions based on information provided by Archaea. For design purposes the oxidizer shall be capable of operating with a combined methane load of 12.2% by vol. in 1,685 SCFM of total waste gas at the system inlet, or ~511.50 lb/hr of total methane. This represents a maximum heat load under any condition of about 10,997,250 Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 9 BTU/hr on a LHV basis or about 12,111,509 BTU/hr on a HHV basis. LHV is defined as the HHV minus the heat of vaporization of any water vapor formed in combustion.* **The process stream composition is limited to the constituents in the above table and does not contain any particulate, acids, halogenated, or additional corrosive compounds. All compounds to be oxidized are expected to have auto-ignition temperatures of approximately 1,000F or less.** ***Any SOx compounds formed as a result of hydrogen sulfide oxidation or silica particulate formed as a result of siloxane combustion will not be removed by this equipment alone. Conifer can provide additional post-combustion treatment solutions for the removal of these compounds if required.*** Operating Conditions Minimum Operating Temperature: 1,500°F Maximum Operating Temperature: 1,800°F Target Internal Heat Transfer Effectiveness: ~65% (for dilution air pre-heating) Target External Heat Transfer Effectiveness: ~60% (for TSA heating) Equipment Location: Outdoors Control Panel Location Outdoors (on the oxidizer skid) Site Location Elevation: ~50 ft ASL Electrical Area Classification: Class I Div. II Wind Load Design: 100 MPH Seismic Design: Category II Site Class C Ss = 1.282 S1 = 0.456 Noise Requirement: <85 dBa @ 5ft from rotating equipment Utilities Natural Gas Requirement (Installed Burner Maximum Capacity): 7,500 SCFH @ 10 psig pressure LHV = ~1,000 btu/SCF Estimated Natural Gas Usage: At full volume, maximum operating temperature, and Specified VOC Load <1,875 SCFH (varies with inlet methane content) Electrical Supply Voltage: 480V / 60Hz / 3 Phase Estimated Electrical Power Consumption: ~70 kW at maximum capacity Compressed Air Supply: 80 psig @ -20F dewpoint Estimated Compressed Air Usage: 10 CFM peak; <5 CFM average Oxygen Analyzer Additional Utilities Power – 120 V / 60 Hz / 1 Ph (from control panel) Calibration Gas – 5 SCFH @ 20 psig, 0.4% and 8% O2, Balance N2 (from canisters, during calibration only) Reference Air – 2 SCFH @ 20 psig (from instrument air, continuous) Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 10 Emissions Guarantee Methane and Volatile Organic Compound (VOC) Destruction Removal Efficiency (DRE): 99% or less than 20 ppmv as hexane Stack NOx Emissions: <0.06 lb/MMBTU (HHV basis) or <10 ppmv as NO2 Stack Carbon Monoxide Emissions: <0.20 lb/MMBTUH (HHV basis) or <50 ppmv EPA Method 25A, 7E, & 10 and/or mutually agreed upon test method(s) will be used to determine/validate VOC, NOx, & CO destruction performance respectively. Emission factors for NOx and CO are applicable as long as the following provisions are recognized: 1. There are no NOx compounds present in the waste gas prior to combustion. 2. There are no combustible nitrogen bearing compounds present in the waste gas. 3. There is no CO present in the waste gas prior to combustion. 4. There is no combustible particulate present in the waste gas. Performance Guarantee provisions - The unit is installed (if applicable), operated and maintained by Buyer in accordance with Conifer instructions. This includes replacing of consumable or maintenance components by Buyer, as required. - Buyer agrees to operate the system within the system design data as specified in this proposal. - The performance guarantees apply only during normal operation, not during any maintenance procedures. - All functional tests are arranged and paid for by Buyer. Conifer must be notified in writing 14 days prior to the tests for scheduling purposes. - Conifer reserves the right to adjust the burner chamber operating temperature and any other settings as required to meet the guarantees. - If Conifer fails to meet the Performance Guarantee, Conifer must be given reasonable time to investigate and take corrective action within the scope of this contract. Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 11 SECTION 3: EQUIPMENT SPECIFICATIONS This proposal is based on preliminary engineering intended to achieve the performance goals. Conifer Systems reserves the right to alter component selections during project engineering. 5,000 SCFM Thermal Recuperative Oxidizer – Low NOx Specification General Requirement Conifer Provision Fans & Blowers Dilution Air Fan Fan Manufacturer New York Blower or equal Approximate Volume @ Design Conditions 3,400 SCFM Expected Motor Size 15 HP Motor Type TEFC Premium Efficiency Fan Materials of Construction Carbon Steel Housing and Fan Wheel Base & Pedestal are Carbon Steel Safety Pressure Switch Dwyer 1950 Series or equal Motor Starter Allen Bradley or equal Located in the Control Panel Flow Control Pneumatic Modulating Damper Other Features Inlet Screen Outlet Flex Joint Housing Access Door & Drain Cooling Air Fan Fan Manufacturer New York Blower or equal Approximate Volume @ Design Conditions 9,500 SCFM Expected Motor Size 40 HP Motor Type TEFC Premium Efficiency Fan Materials of Construction Carbon Steel Housing and Fan Wheel Base & Pedestal are Carbon Steel Safety Pressure Switch Dwyer 1950 Series or equal Motor Starter Allen Bradly or equal Located in the Control Panel Flow Control Pneumatic Modulating Dampers Two (2) total Other Features Inlet Screen Outlet Flex Joint Housing Access Door & Drain Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 12 Fans & Blowers (continued) Combustion Air Fan Fan Manufacturer New York Blower or equal Approximate Volume @ Design Conditions 2,150 SCFM Expected Motor Size 25 HP Motor Type TEFC Premium Efficiency Fan Materials of Construction Carbon Steel Housing and Fan Wheel Base & Pedestal are Carbon Steel Safety Pressure Switch Dwyer 1950 Series or equal Motor Starter Allen Bradly or equal Located in the Control Panel Flow Control Pneumatic Modulating Damper Other Features Wire Mesh Inlet Filter Housing Access Door & Drain Burner, Gas Train, & Combustion System Burner Fives 4225 or Conifer approved equal Quantity of Burners One (1) Maximum Rated Capacity of Each Burner 7,500,000 BTU/hr Flame Monitoring Self-Scheck UV Scanner Gas Train Design Standard NFPA 86 Expected Gas Line Size 3” NPT Sch. 40 Manual Shut-off Valves Apollo or equal Y-Strainer Mueller or equal Gas Pressure Regulator Sensus or equal Low and High Gas Pressure Switches United Electric or equal Fuel Gas Safety Shut-Off Valves Maxon or equal Pressure Gauges Miljocco or equal Gas Control Valve Maxon or equal Pilot Shut-Off Valves Maxon or equal Combustion Chamber Shell Material Minimum ¼” thick Carbon Steel Internal Insulation (Shop Installed) Ceramic Fiber Modules Combustion Chamber Access Door 30” x 30” minimum opening size Davit Arm Assisted Burner Site Port 2” Dia. Pyrex Glass with Air Purge Temperature Elements Duplex Type “K” Thermocouple Pyromation or equal Residence Time (volumetric basis) ~0.5 Seconds @ 1,800°F and maximum flow rate Total Combustion Chamber Volume (mixing zone & combustion zone) ~277 ft3 Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 13 Controls Control Panel Type NEMA 4X – Outdoor Rated with Weather Hood & A/C Purged for Class I Div. II Operator Interface Allen Bradley PanelView or equal Control Panel Standard UL508a Programmable Logic Controller (PLC) Allen Bradley CompactLogix or equal Burner Management System (BMS) Siemens or equal Communications Connection Ethernet Switch Voltage Main Control 480 VAC / 3 phase / 60 Hz 120 VAC / 1 phase / 60 Hz (via Conifer supplied transformer) Process Valves Membrane Gas Process Isolation Valve Type / Size Wafer Style Butterfly / 8”Ø Two (2) Total Materials of Construction Carbon Steel Body Stainless Steel Disk PTFE Seat Actuator Type / Manufacturer Spring Return Pneumatic / Fail Closed One (1) On-Off & One (1) Modulating Max-Air or equal TSA Return Process Isolation Valve Type / Size Wafer Style Butterfly / 10”Ø One (1) Total Materials of Construction Carbon Steel Body Stainless Steel Disk PTFE Seat Actuator Type / Manufacturer Spring Return Pneumatic / Fail Closed On-Off Max-Air or equal Exhaust Stack Stack Discharge Height 60ft above grade Stack Diameter 38” I.D. / 46” O.D. Materials of Construction Carbon Steel Shell Internally Insulated with Ceramic Fiber Test Ports Two (2) 3” NPT Threaded Pipe Nipples Set at 90° Apart Stack Test Platform Not Included Other Features Free Standing (no guy wires) Drain at Stack Base Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 14 Process Valves (continued) NRU Gas Process Isolation Valve Type / Size Wafer Style Butterfly / 4”Ø Two (2) Total Materials of Construction Carbon Steel Body Stainless Steel Disk PTFE Seat Actuator Type / Manufacturer Spring Return Pneumatic / Fail Closed One (1) On-Off & One (1) Modulating Max-Air or equal Primary Heat Exchanger – Dilution Air Pre-Heat Heat Exchanger Type Crossflow Shell-and-Tube In-line Tube Bank Materials of Construction Carbon Steel Housing Internally Insulated with Ceramic Fiber 304 Stainless Steel Internals Internal Expansion Joint Included Cold Side Inlet Design Conditions Flow Rate: 2,200 SCFM Temperature: 70°F Hot Side Inlet Design Conditions Flow Rate: 7,210 SCFM Temperature: 1,200°F Cold Side Outlet Temperature 805°F (clean, no bypass) Hot Side Outlet Temperature 1,015°F (clean, no bypass) Maximum Expected Heat Transfer Rate ~1,789,000 BTU/hr Maximum Expected Heat Transfer Effectiveness ~65% Expected Cold Side Pressure Drop ~2.0” w.c. (at design flow rate) Expected Hot Side Pressure Drop ~3.0” w.c. (at design flow rate) Maximum Design Differential Pressure from Cold Side to Hot Side 1.0 psig (PSV not included or required) Cold Side Bypass None Hot Side Bypass Rectangular Louver Dampers Refractory Lined with 330 Stainless Steel Metal Internals Confidential Conifer Proposal No. 2249-21 Rev.6 Archaea - MODEL TRO-65-60-051 15 Secondary Heat Exchanger – TSA Heater Heat Exchanger Type Crossflow Shell-and-Tube In-line Tube Bank Materials of Construction Carbon Steel Housing Internally Insulated with Ceramic Fiber 304 Stainless Steel Internals Internal Expansion Joint Included Cold Side Inlet Design Conditions Flow Rate: 1,260 SCFM Temperature: 65°F Hot Side Inlet Design Conditions Flow Rate: 9,410 SCFM Temperature: 800°F Cold Side Outlet Temperature 543°F (clean, no bypass) Hot Side Outlet Temperature 722°F (clean, no bypass) Maximum Expected Heat Transfer Rate ~919,000 BTU/hr Maximum Expected Heat Transfer Effectiveness ~65% Expected Cold Side Pressure Drop ~1.0” w.c. (at design flow rate) Expected Hot Side Pressure Drop ~3.0” w.c. (at design flow rate) Maximum Design Differential Pressure from Cold Side to Hot Side 5.0 psig (PSV included) Cold Side Bypass Wafer Style Butterfly Valves Hot Side Bypass Rectangular Louver Dampers Refractory Lined with 330 Stainless Steel Metal Internals Miscellaneous Flame Arrestor 10” Flanged Connection Carbon Steel Housing Stainless Steel Element Protego or equal Oxygen Analyzer Rosemount or equal Area Lighting Not Included Factory Mounting Pre-piped and Pre-wired to maximum extent practical for shipping Estimated Size Approximate Equipment Footprint 34ft X 42ft Note: Footprint dimensions may be altered to fit available space. Includes all fans and exhaust stack Approximate Equipment Total Dry Weight 40,000 lbs PTC/PTO Application www.scsengineers.com B-3 Enclosed RNG Flare Prepared by: Ben Pernu Applications Engineer, Biogas Systems (918) 234-2718 Ben.Pernu@kes.global Prepared for: Nick Bauer of Archaea Energy For: Coyote Canyon Landfill; Newport Beach, California Date: October 6, 2023 ZULE® Ultra Low Emissions Flare Firm Technical Proposal John Zink reference number: 202203-268235REV11 Prepared by: Ben Pernu Applications Engineer, Biogas Systems (918) 234-2718 Ben.Pernu@kes.global Prepared for: Nick Bauer of Archaea Energy For: Coyote Canyon Landfill; Newport Beach, California Date: October 6, 2023 ZULE® Ultra Low Emissions Flare Firm Technical Proposal John Zink reference number: 202203-268235REV11 Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 1 of 11 Contents EXECUTIVE SUMMARY ...................................................................................... 2 INTRODUCTION ................................................................................................. 2 DESIGN CRITERIA ............................................................................................. 4 EQUIPMENT DETAILS ........................................................................................ 7 PERFORMANCE ............................................................................................... 11 Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 2 of 11 EXECUTIVE SUMMARY Scope: ............................................................. John Zink ZULE® Ultra-Low Emission Flare (technical information and scope of supply follow) Price: .............................................................. Customer Submittal Schedule: ..................... 12 weeks after purchase order acceptance Customer Approval Schedule: ...................... 2 weeks after receipt of submittals Fabrication Schedule: ................................... 30 weeks after receiving approved submittal INTRODUCTION To satisfy your landfill gas flare requirements per your recent request, John Zink Company is pleased to offer a firm quote for our ZULE® Ultra-Low Emissions Flare System. For over 80 years, the John Zink brand has ensured quality, innovative technology, and worldwide service in the combustion industry. John Zink has supplied over 800 flare systems for the biogas industry, giving us unparalleled expertise. Each flare system is made in our own 330,000 square foot manufacturing facility; and we possess the resources to care for your flare at every stage of life: from installation and startup of new flares, to repair and retrofits of existing flares. Our national network of sales representatives and field technicians means you will always have someone available to assist you in any issues that may arise with your flare, and our portable rental units and spare parts inventory can ensure continued compliance and quick turnaround in case of flare shutdown. John Zink offers a range of features and options as listed in this proposal. Our intent is to supply the safest, most reliable and economical system available that will also allow you to customize your system to meet your specific needs. After reviewing the proposal, please let us know if there are any additional options you would like to pursue. We look forward to working with you on this project, and if you require any additional information please do not hesitate to contact me at (918) 234-2718 or our local sales representative, Robert Erdmann, at 1-800-8- LOWNOX. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 3 of 11 Change Log – REV5 • Page 4: Changed title of Stream 2 (Mode 2A) to match RFP verbiage; o Changed flow data and title of Stream 2 (Mode 2B) to match RFP data and verbiage. o Changed for data of Stream 5 (Mode 4A) to match RFP data. • Page 5: Deleted VOCP blowdown and purge streams o Changed Stream 8 to Stream 6 for Modes 3, 5 and 6. o Amended enrichment gas requirements for new natural gas heating value (96.09% methane, 874 BTU/SCF) • Page 7: Replaced provided OIP to reflect new John Zink standard • Page 9: Replaced provided flow meters to reflect RFP verbiage. Change Log – REV6 • Page 4: Added second stage permeate stream. • Page 6: Corrected pilot operation from continuous to intermittent. • Page 9: Replaced previously quoted hydrocarbon analyzer with continuously operating gas analyzer to provide methane and oxygen levels for air blower control. • Page 12: Adjusted price due to material cost increases and scope changes. Change Log – REV7 • Page 4: Increased fuel gas flow on permeate stream for consistent minimum flowrate across streams. • Page 10: Removed one thermal mass flow meter from JZ project scope. Added a pressure transmitter with a low pressure shutdown to the pilot gas spool. Added clarifications regarding signals that will be sent to the John Zink control panel from end user provided monitoring equipment, an ultrasonic flow meter and a pressure transmitter. • Page 13: Price adjustment to reflect removal of flow meter from project scope. Change Log – REV8 • Page 9: Reduced diameter of flame arrester and block valve from 12 to 10 inches. • Page 13: Price adjustment to reflect size reduction of page 9 components. Change Log – REV9 • Page 4: Revised flow data for Stream 2C – second stage permeate gas. Change Log – REV10 • Page 5: Revised flow data for Stream 4A – TSA purge gas; added mode 7, off-spec process gas. • Page 6: Added language reflecting the addition of a second pilot • Page 7: Revised stack diameter and ignition panel quantity, added language for flanged stack • Page 10: Added extra 100 ft of thermocouple wire due to addition of second pilot Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 4 of 11 DESIGN CRITERIA NOTE: One stream to the flare at a time. Stream selection and pressure regulation by others. Flare Gas Stream 1 Type: ............................................................... Mode 1 - process gas Staging: .......................................................... both stages Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 135.3°F Flow Rate: .............................................. 3,000 SCFM (design normalized at 42.7% CH4) Minimum: ....................................................... 1,100 SCFM (design normalized at 42.7% CH4) Heat Release (HHV): ...................................... 77.8 MMBTU/hr (design at 42.7% CH4) Heat Release (LHV): ...................................... 69.9 MMBTU/hr (design at 42.7% CH4) NOTE: Hydrogen sulfide concentrations greater than 3,000 ppm may require special materials with potential commercial impact. Flare Gas Stream 2 Type: ............................................................... Mode 2A - process gas Staging: .......................................................... both stages Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 108.4°F Flow Rate: ...................................................... 3,000 SCFM (design normalized at 42.7% CH4) Minimum: ....................................................... 1,100 SCFM (design normalized at 42.7% CH4) Heat Release (HHV): ...................................... 77.8 MMBTU/hr (design at 42.7% CH4) Heat Release (LHV): ...................................... 69.9 MMBTU/hr (design at 42.7% CH4) . Flare Gas Stream 3 Type: ............................................................... Mode 2B - membrane gas Staging: .......................................................... both stages Composition: .................................................. 70.4% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 712 BTU/SCF (design Lower Heating Value: .................................... 641 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 1,729 SCFM (design normalized at 70.4% CH4) Minimum: ....................................................... 650 SCFM (design normalized at 70.4% CH4) Heat Release (HHV): ...................................... 73.9 MMBTU/hr (design at 70.4% CH4) Heat Release (LHV): ...................................... 66.5 MMBTU/hr (design at 70.4% CH4) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 5 of 11 Flare Gas Stream 4 Type: ............................................................... Mode 2C – second stage permeate gas Staging: .......................................................... First stage only Composition: .................................................. 28.6% CH4 +/- 1% (design) balance CO2, air, inerts, up to 10% O2 Higher Heating Value: ................................... 289 BTU/SCF (design) Lower Heating Value: .................................... 260 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 300 SCFM (design normalized at 28.6% CH4) 100 SCFM (minimum at 28.6% CH4) Initial Heat Release (HHV): ........................... 5.2 MMBTU/hr (design at 28.6% CH4) Initial Heat Release (LHV): ............................ 4.7 MMBTU/hr (design at 28.6% CH4) Fuel Gas Requirements: ............................... 70 SCFM (maximum at 100 SCFM waste gas) Combined Heat Release (HHV): ................... 6.0 MMBTU/hr (design) Combined Heat Release (LHV): .................... 5.4 MMBTU/hr (design) Flare Gas Stream 5 Type: ............................................................... Mode 4 - TSA blowdown Staging: .......................................................... First stage only Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 37.9°F Flow Rate: ...................................................... 419 SCFM decaying to 40 SCFM Initial Heat Release (HHV): ........................... 10.9 MMBTU/hr (design at 42.7% CH4) Initial Heat Release (LHV): ............................ 9.8 MMBTU/hr (design at 42.7% CH4) Fuel Gas Requirements: ............................... 90 SCFM (maximum at 40 SCFM waste gas) Combined Heat Release (HHV): ................... 6.5 MMBTU/hr (design) Combined Heat Release (LHV): .................... 5.8 MMBTU/hr (design) Flare Gas Stream 6 Type: ............................................................... Mode 4A – TSA purge Staging: .......................................................... First stage only Composition: .................................................. 42.7% CH4 (design); 42.7% to 8.4% CH4 (range) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 1,284 SCFM +/- 1% (design at 42.7% CH4) Initial Heat Release (HHV): ........................... 33.3 MMBTU/hr (design at 42.7% CH4) Initial Heat Release (LHV): ............................ 29.9 MMBTU/hr (design at 42.7% CH4) Fuel Gas Requirements: ............................... 290 SCFM at 8.4% CH4 waste gas Combined Heat Release (HHV): ................... 24.2 MMBTU/hr (design) Combined Heat Release (LHV): .................... 21.7 MMBTU/hr (design) NOTE: Low methane concentrations may require auxiliary fuel to initiate combustion and maintain temperature. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 6 of 11 Flare Gas Stream 7 Type: ............................................................... Modes 3, 5 and 6: off-spec product gas Staging: .......................................................... both stages Composition: .................................................. 96.1% CH4 +/- 1% (design) balance CO2, air, inerts, less than 1% O2 Higher Heating Value: ................................... 973 BTU/SCF (design) Lower Heating Value: .................................... 875 BTU/SCF (design) Temperature: ................................................. 97.9°F Flow Rate: ...................................................... 1,178 SCFM (design normalized at 96.1% CH4) Minimum: ....................................................... 500 SCFM (design normalized at 96.1% CH4) Heat Release (HHV): ...................................... 68.8 MMBTU/hr (design at 96.1% CH4) Heat Release (LHV): ...................................... 61.8 MMBTU/hr (design at 96.1% CH4) Flare Gas Stream 8 Type: ............................................................... Mode 7: off-spec process gas Staging: .......................................................... First stage only Composition: .................................................. 15.4% CH4 +/- 1% (design) balance CO2, air, inerts, less than 1% O2 Higher Heating Value: ................................... 156 BTU/SCF (design) Lower Heating Value: .................................... 140 BTU/SCF (design) Temperature: ................................................. 97.9°F Flow Rate: ...................................................... 551 SCFM (design normalized at 15.4% CH4) Heat Release (HHV): ...................................... 5.2 MMBTU/hr (design at 15.4% CH4) Heat Release (LHV): ...................................... 4.6 MMBTU/hr (design at 15.4% CH4) Fuel Gas Requirements: ............................... 74 SCFM Combined Heat Release (HHV): ................... 9.6 MMBTU/hr (design) Combined Heat Release (LHV): .................... 8.7 MMBTU/hr (design) Mechanical Design Wind Speed (ASCE 7-10; EXP C): ..... 110 mph Design Seismic (CBC 1613): ........................ Zone 4 Ambient Temperature: .................................. 29°F to 94 °F Ambient Pressure: ......................................... 14.3 psia Elevation: ....................................................... 750 feet above sea level Electrical Area Classification: ....................... Class 1 Div 2 Group D (flare) Unclassified (panel and air blower) NOTE: Heat tracing and insulating (by others) recommended to protect against freezing. Process Smokeless Capacity: ..................................... 100% Operating Temperature: ................................ 1400 °F to 1800 °F (2000 °F shutdown) Retention Time: ............................................. 0.7 seconds at 1800 °F (minimum) Required Flame Arrester Inlet Pressure: ...... 15 inches of H2O (design) NOTE: Low methane concentrations may require auxiliary fuel to initiate combustion and maintain temperature. Utilities Pilot Gas (intermittent): ................................. 22 SCFH of propane at 7-10 psig (or) 50 SCFH of natural gas at 10-15 psig per pilot Compressed Air (or Nitrogen): ...................... 80 PSIG (regulated, clean and dry) Electricity: ....................................................... 480 V, 3 phase, 60 Hz for motor control; transformer provided for 120 V, single phase for control system components Auxiliary Fuel: ................................................. enrichment gas required as described above Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 7 of 11 EQUIPMENT DETAILS FLARE Quantity: ........................................................ one (1); flanged into two sections for field assembly Material: ......................................................... carbon steel stack Nominal Diameter: ........................................ 13 ft. Nominal Height: ............................................ 40 ft. Interior Protection: Insulation: .............................................. one (1) 1 in. thick 8 lb density ceramic fiber blanket insulation, backed by one (1) 1 in. thick 6 lb density ceramic fiber blanket insulation, each rated 2200 °F minimum; stainless steel rain cap to protect refractory Insulation Anchoring: ............................. Inconel 601 pins and keepers Surface Preparation: ..................................... SSPC-SP-6 sandblast; Primer: .................................................... Sherwin Williams Heat Flex 1200, 5 - 6 mils DFT (two coats) Rigidizer ................................................. KAOWOOL spray-on rigidizer to protect the insulation. External Coating: Surface Preparation: ............................. SSPC-SP-6 sandblast; Primer: .................................................... inorganic rich zinc primer, 2 - 4 mils DFT (one coat) Automatic dampers: ..................................... four (4) (One hinged for easy interior access) Damper actuators:................................. explosion proof Manifold Construction: .................................. carbon steel Inlet Diameter: ............................................... 12 in. Flare Tips: ....................................................... four (4), each with one type K thermocouple Flare Tip Construction: .................................. Portions 304 and 310 stainless; ceramic burner can Burner Staging: .............................................. two stages Second Stage Cooling Fan: ........................... ¾ HP, 700 CFM (shipped loose for field installation) Stack Thermocouple Connections: ............... three (3), each with one type K thermocouple Sample Ports: ................................................. four (4) Sight Ports: ..................................................... two (2) Pilot Ignition (Qty 2): ...................................... electronic spark ignitors; NEMA 7 ignition panels Flame Scanner: .............................................. one (1) Honeywell UV scanner (or equal) Purge Blower: ................................................. continuous purge provided by combustion air blower and cooling fan Structural Anchoring: ..................................... AISC continuous base plate Ladder: ........................................................... one (1) 40 ft. ladder including fall protection with one (1) harness. Lifting Lugs: .................................................... two (2) Premix chamber: ............................................ included with static mixer assembly and manway Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 8 of 11 SHIPPED LOOSE EQUIPMENT Combustion Air Blower: Quantity: ........................................................ one (1) Flowrate: ......................................................... 20,000 SCFM Inlet Suction: .................................................. -5 inches of H2O Outlet Pressure: ............................................. 15 inches of H2O Motor Power: ................................................. 75 HP Motor Control: NEMA 3R variable frequency drive (see below for additional details) Motor Enclosure: ........................................... TEFC (NEMA) Outlet Attachments: ....................................... flexible expansion joint Manufacturer: ................................................ Chicago Blower (or equal) Accessories: Inlet Venturi Style Flow Meter: .............. one (1) included, Aeroacoustics (or equal) Inlet Rainhood & Filter: ......................... one (1) included Silencer: ................................................. one (1) included Pressure Gauge: .................................... one (1) included Combustion Air Blower VFD: Quantity: ......................................................... one (1) Enclosure: ...................................................... NEMA 3R Motor Power: .................................................. 75 HP Power Input: ................................................... 480V, 3ph, 60hz Drive Manufacturer: ...................................... FUJI Automatic Ignition and Control Station: Panel Rack: .................................................... one (1); including the following: Power transformer: ........................................ 480V to 120V Control Panel: Quantity .................................................. one (1) Certification ............................................ Underwriters Laboratory Enclosure ............................................... weatherproof PLC ......................................................... Allen Bradley CompactLogix Communication ..................................... via Ethernet/IP signals: ........................................ remote start/stop (discrete signal) flare status (discrete signal) waste gas flow in SCFM (analog signal) fuel gas flow in SCFM (analog signal) flare temperature in degrees F (analog signal) Operator Touchscreen ........................... 12” Tru-Vue (or equal) Color Operator Interface Panel Flame Scanner Relay ............................ one (1) UV flame scanner control relay Control Panel Weatherhood: ................. included with LED panel light Emergency Stop Button ........................ one (1) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 9 of 11 Flame Arrester: Quantity: ......................................................... one (1) Diameter: ....................................................... 10 in. Style: ............................................................... eccentric Housing material: .......................................... aluminum Internals material: ......................................... stainless steel Internals monitoring: ..................................... one (1) Dwyer differential pressure gauge one (1) type K thermocouple Manufacturer: ................................................ Enardo (or equal) Second Stage Duct Block Valve: Quantity: ......................................................... one (1) Diameter: ....................................................... 36 in. Style: ............................................................... lug Actuator: ......................................................... piston with spring return, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Apollo (or equal) Automatic Block Valve: Quantity: ......................................................... three (3); one for waste gas, two for stage cooling fan Diameter: ....................................................... one (1) 10 in.; two (2) 6 in. Style: ............................................................... lug Actuator: ......................................................... pneumatic, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Xomox (or equal) Pressure Control Valve: Quantity: ......................................................... one (1) Diameter: ....................................................... 10 in. Style: ............................................................... lug Actuator: ......................................................... pneumatic, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Apollo (or equal) Rack Mounted Gas Analyzer: Quantity: ....................................................... one (1), for air blower control Measurement: .............................................. CH4 and O2 Sample Pump: .............................................. included Autocalibration Package: ............................ included Manufacturer: .............................................. QED Environmental (or equal) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 10 of 11 Flow Meter: Quantity: ......................................................... one (1) for fuel gas (ultrasonic flow meter to be provided by end user to provide 4-20 signals for flowrate in SCFM as well as molecular weight of waste gas stream) Type: ............................................................... thermal mass Probe material: .............................................. 316 stainless steel, Teflon coated Manufacturer: ................................................ Endress and Hauser (or equal) Ancillary Equipment: Pressure Transmitter: .................................. two (2), one for mixing chamber monitoring (high pressure shutdown), one for pilot gas monitoring (low pressure shutdown) (additional pressure transmitter for inlet pipe monitoring to be provided by end user; will provide interlock, preventing flare startup if piping pressure is too high) Pilot Gas Spool: ............................................ one (1) including, ½” piping, solenoid valve, pressure regulator with carbon steel body, four manual valves, pressure gauge, two strainers, manual globe valve Fuel Gas Spool: .............................................. one (1) including modulating flow control valve, automated ball valve, two manual valves, pressure regulator with carbon steel body, pressure gauge, strainer Thermocouple Wire: ..................................... 900 ft. Ignition Wire: ................................................ 25 ft. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 11 of 11 PERFORMANCE Expected Flare Pre-Mix Emission Range – Waste Gas Streams 1, 2, 3, 4, 6, 7(Design Flow) Operating Temperature 1600°F 1800°F Smokeless Capacity 100% 100% Methane Destruction Efficiency 99% 99% NOx, lb / MMBTU(1) 0.025 0.025 CO, lb / MMBTU(2) 0.06 0.05 VOC Destruction Efficiency (3) 98% 98% (1) Excludes NOx from fixed nitrogen. (2) Excludes CO contribution present in the gas. (3) VOC Emissions of 0.038 lb/MMBTU is achievable based on a maximum inlet VOC concentration of 5,000 ppm as methane. NOTE: Expected emissions are based on field tests of operating units and the higher heating value (HHV) of the gas. Destruction efficiency, NOx, and CO emissions shown are valid for combustion of specified gas only. Expected emissions are not guaranteed unless expressly stated elsewhere in this proposal. Expected Flare Pre-Mix Emission Range – Waste Gas Streams 5, 8 (Design Flow) Operating Temperature 1600°F 1800°F Smokeless Capacity 100% 100% Methane Destruction Efficiency 99% 99% NOx, lb / MMBTU(1) 0.06 0.08 CO, lb / MMBTU(2) 0.15 0.2 VOC Destruction Efficiency (3) 98% 98% (1) Excludes NOx from fixed nitrogen. (2) Excludes CO contribution present in the gas. (3) VOC Emissions of 0.038 lb/MMBTU is achievable based on a maximum inlet VOC concentration of 5,000 ppm as methane. NOTE: Expected emissions are based on field tests of operating units and the higher heating value (HHV) of the gas. Destruction efficiency, NOx, and CO emissions shown are valid for combustion of specified gas only. Expected emissions are not guaranteed unless expressly stated elsewhere in this proposal. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 1 of 11 Contents EXECUTIVE SUMMARY ...................................................................................... 2 INTRODUCTION ................................................................................................. 2 DESIGN CRITERIA ............................................................................................. 4 EQUIPMENT DETAILS ........................................................................................ 7 PERFORMANCE ............................................................................................... 11 Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 2 of 11 EXECUTIVE SUMMARY Scope: ............................................................. John Zink ZULE® Ultra-Low Emission Flare (technical information and scope of supply follow) Price: .............................................................. Customer Submittal Schedule: ..................... 12 weeks after purchase order acceptance Customer Approval Schedule: ...................... 2 weeks after receipt of submittals Fabrication Schedule: ................................... 30 weeks after receiving approved submittal INTRODUCTION To satisfy your landfill gas flare requirements per your recent request, John Zink Company is pleased to offer a firm quote for our ZULE® Ultra-Low Emissions Flare System. For over 80 years, the John Zink brand has ensured quality, innovative technology, and worldwide service in the combustion industry. John Zink has supplied over 800 flare systems for the biogas industry, giving us unparalleled expertise. Each flare system is made in our own 330,000 square foot manufacturing facility; and we possess the resources to care for your flare at every stage of life: from installation and startup of new flares, to repair and retrofits of existing flares. Our national network of sales representatives and field technicians means you will always have someone available to assist you in any issues that may arise with your flare, and our portable rental units and spare parts inventory can ensure continued compliance and quick turnaround in case of flare shutdown. John Zink offers a range of features and options as listed in this proposal. Our intent is to supply the safest, most reliable and economical system available that will also allow you to customize your system to meet your specific needs. After reviewing the proposal, please let us know if there are any additional options you would like to pursue. We look forward to working with you on this project, and if you require any additional information please do not hesitate to contact me at (918) 234-2718 or our local sales representative, Robert Erdmann, at 1-800-8- LOWNOX. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 3 of 11 Change Log – REV5 • Page 4: Changed title of Stream 2 (Mode 2A) to match RFP verbiage; o Changed flow data and title of Stream 2 (Mode 2B) to match RFP data and verbiage. o Changed for data of Stream 5 (Mode 4A) to match RFP data. • Page 5: Deleted VOCP blowdown and purge streams o Changed Stream 8 to Stream 6 for Modes 3, 5 and 6. o Amended enrichment gas requirements for new natural gas heating value (96.09% methane, 874 BTU/SCF) • Page 7: Replaced provided OIP to reflect new John Zink standard • Page 9: Replaced provided flow meters to reflect RFP verbiage. Change Log – REV6 • Page 4: Added second stage permeate stream. • Page 6: Corrected pilot operation from continuous to intermittent. • Page 9: Replaced previously quoted hydrocarbon analyzer with continuously operating gas analyzer to provide methane and oxygen levels for air blower control. • Page 12: Adjusted price due to material cost increases and scope changes. Change Log – REV7 • Page 4: Increased fuel gas flow on permeate stream for consistent minimum flowrate across streams. • Page 10: Removed one thermal mass flow meter from JZ project scope. Added a pressure transmitter with a low pressure shutdown to the pilot gas spool. Added clarifications regarding signals that will be sent to the John Zink control panel from end user provided monitoring equipment, an ultrasonic flow meter and a pressure transmitter. • Page 13: Price adjustment to reflect removal of flow meter from project scope. Change Log – REV8 • Page 9: Reduced diameter of flame arrester and block valve from 12 to 10 inches. • Page 13: Price adjustment to reflect size reduction of page 9 components. Change Log – REV9 • Page 4: Revised flow data for Stream 2C – second stage permeate gas. Change Log – REV10 • Page 5: Revised flow data for Stream 4A – TSA purge gas; added mode 7, off-spec process gas. • Page 6: Added language reflecting the addition of a second pilot • Page 7: Revised stack diameter and ignition panel quantity, added language for flanged stack • Page 10: Added extra 100 ft of thermocouple wire due to addition of second pilot Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 4 of 11 DESIGN CRITERIA NOTE: One stream to the flare at a time. Stream selection and pressure regulation by others. Flare Gas Stream 1 Type: ............................................................... Mode 1 - process gas Staging: .......................................................... both stages Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 135.3°F Flow Rate: .............................................. 3,000 SCFM (design normalized at 42.7% CH4) Minimum: ....................................................... 1,100 SCFM (design normalized at 42.7% CH4) Heat Release (HHV): ...................................... 77.8 MMBTU/hr (design at 42.7% CH4) Heat Release (LHV): ...................................... 69.9 MMBTU/hr (design at 42.7% CH4) NOTE: Hydrogen sulfide concentrations greater than 3,000 ppm may require special materials with potential commercial impact. Flare Gas Stream 2 Type: ............................................................... Mode 2A - process gas Staging: .......................................................... both stages Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 108.4°F Flow Rate: ...................................................... 3,000 SCFM (design normalized at 42.7% CH4) Minimum: ....................................................... 1,100 SCFM (design normalized at 42.7% CH4) Heat Release (HHV): ...................................... 77.8 MMBTU/hr (design at 42.7% CH4) Heat Release (LHV): ...................................... 69.9 MMBTU/hr (design at 42.7% CH4) . Flare Gas Stream 3 Type: ............................................................... Mode 2B - membrane gas Staging: .......................................................... both stages Composition: .................................................. 70.4% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 712 BTU/SCF (design Lower Heating Value: .................................... 641 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 1,729 SCFM (design normalized at 70.4% CH4) Minimum: ....................................................... 650 SCFM (design normalized at 70.4% CH4) Heat Release (HHV): ...................................... 73.9 MMBTU/hr (design at 70.4% CH4) Heat Release (LHV): ...................................... 66.5 MMBTU/hr (design at 70.4% CH4) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 5 of 11 Flare Gas Stream 4 Type: ............................................................... Mode 2C – second stage permeate gas Staging: .......................................................... First stage only Composition: .................................................. 28.6% CH4 +/- 1% (design) balance CO2, air, inerts, up to 10% O2 Higher Heating Value: ................................... 289 BTU/SCF (design) Lower Heating Value: .................................... 260 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 300 SCFM (design normalized at 28.6% CH4) 100 SCFM (minimum at 28.6% CH4) Initial Heat Release (HHV): ........................... 5.2 MMBTU/hr (design at 28.6% CH4) Initial Heat Release (LHV): ............................ 4.7 MMBTU/hr (design at 28.6% CH4) Fuel Gas Requirements: ............................... 70 SCFM (maximum at 100 SCFM waste gas) Combined Heat Release (HHV): ................... 6.0 MMBTU/hr (design) Combined Heat Release (LHV): .................... 5.4 MMBTU/hr (design) Flare Gas Stream 5 Type: ............................................................... Mode 4 - TSA blowdown Staging: .......................................................... First stage only Composition: .................................................. 42.7% CH4 +/- 1% (design) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 37.9°F Flow Rate: ...................................................... 419 SCFM decaying to 40 SCFM Initial Heat Release (HHV): ........................... 10.9 MMBTU/hr (design at 42.7% CH4) Initial Heat Release (LHV): ............................ 9.8 MMBTU/hr (design at 42.7% CH4) Fuel Gas Requirements: ............................... 90 SCFM (maximum at 40 SCFM waste gas) Combined Heat Release (HHV): ................... 6.5 MMBTU/hr (design) Combined Heat Release (LHV): .................... 5.8 MMBTU/hr (design) Flare Gas Stream 6 Type: ............................................................... Mode 4A – TSA purge Staging: .......................................................... First stage only Composition: .................................................. 42.7% CH4 (design); 42.7% to 8.4% CH4 (range) balance CO2, air, inerts, less than 5% O2 Higher Heating Value: ................................... 432 BTU/SCF (design) Lower Heating Value: .................................... 389 BTU/SCF (design) Temperature: ................................................. 89.0°F Flow Rate: ...................................................... 1,284 SCFM +/- 1% (design at 42.7% CH4) Initial Heat Release (HHV): ........................... 33.3 MMBTU/hr (design at 42.7% CH4) Initial Heat Release (LHV): ............................ 29.9 MMBTU/hr (design at 42.7% CH4) Fuel Gas Requirements: ............................... 290 SCFM at 8.4% CH4 waste gas Combined Heat Release (HHV): ................... 24.2 MMBTU/hr (design) Combined Heat Release (LHV): .................... 21.7 MMBTU/hr (design) NOTE: Low methane concentrations may require auxiliary fuel to initiate combustion and maintain temperature. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 6 of 11 Flare Gas Stream 7 Type: ............................................................... Modes 3, 5 and 6: off-spec product gas Staging: .......................................................... both stages Composition: .................................................. 96.1% CH4 +/- 1% (design) balance CO2, air, inerts, less than 1% O2 Higher Heating Value: ................................... 973 BTU/SCF (design) Lower Heating Value: .................................... 875 BTU/SCF (design) Temperature: ................................................. 97.9°F Flow Rate: ...................................................... 1,178 SCFM (design normalized at 96.1% CH4) Minimum: ....................................................... 500 SCFM (design normalized at 96.1% CH4) Heat Release (HHV): ...................................... 68.8 MMBTU/hr (design at 96.1% CH4) Heat Release (LHV): ...................................... 61.8 MMBTU/hr (design at 96.1% CH4) Flare Gas Stream 8 Type: ............................................................... Mode 7: off-spec process gas Staging: .......................................................... First stage only Composition: .................................................. 15.4% CH4 +/- 1% (design) balance CO2, air, inerts, less than 1% O2 Higher Heating Value: ................................... 156 BTU/SCF (design) Lower Heating Value: .................................... 140 BTU/SCF (design) Temperature: ................................................. 97.9°F Flow Rate: ...................................................... 551 SCFM (design normalized at 15.4% CH4) Heat Release (HHV): ...................................... 5.2 MMBTU/hr (design at 15.4% CH4) Heat Release (LHV): ...................................... 4.6 MMBTU/hr (design at 15.4% CH4) Fuel Gas Requirements: ............................... 74 SCFM Combined Heat Release (HHV): ................... 9.6 MMBTU/hr (design) Combined Heat Release (LHV): .................... 8.7 MMBTU/hr (design) Mechanical Design Wind Speed (ASCE 7-10; EXP C): ..... 110 mph Design Seismic (CBC 1613): ........................ Zone 4 Ambient Temperature: .................................. 29°F to 94 °F Ambient Pressure: ......................................... 14.3 psia Elevation: ....................................................... 750 feet above sea level Electrical Area Classification: ....................... Class 1 Div 2 Group D (flare) Unclassified (panel and air blower) NOTE: Heat tracing and insulating (by others) recommended to protect against freezing. Process Smokeless Capacity: ..................................... 100% Operating Temperature: ................................ 1400 °F to 1800 °F (2000 °F shutdown) Retention Time: ............................................. 0.7 seconds at 1800 °F (minimum) Required Flame Arrester Inlet Pressure: ...... 15 inches of H2O (design) NOTE: Low methane concentrations may require auxiliary fuel to initiate combustion and maintain temperature. Utilities Pilot Gas (intermittent): ................................. 22 SCFH of propane at 7-10 psig (or) 50 SCFH of natural gas at 10-15 psig per pilot Compressed Air (or Nitrogen): ...................... 80 PSIG (regulated, clean and dry) Electricity: ....................................................... 480 V, 3 phase, 60 Hz for motor control; transformer provided for 120 V, single phase for control system components Auxiliary Fuel: ................................................. enrichment gas required as described above Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 7 of 11 EQUIPMENT DETAILS FLARE Quantity: ........................................................ one (1); flanged into two sections for field assembly Material: ......................................................... carbon steel stack Nominal Diameter: ........................................ 13 ft. Nominal Height: ............................................ 40 ft. Interior Protection: Insulation: .............................................. one (1) 1 in. thick 8 lb density ceramic fiber blanket insulation, backed by one (1) 1 in. thick 6 lb density ceramic fiber blanket insulation, each rated 2200 °F minimum; stainless steel rain cap to protect refractory Insulation Anchoring: ............................. Inconel 601 pins and keepers Surface Preparation: ..................................... SSPC-SP-6 sandblast; Primer: .................................................... Sherwin Williams Heat Flex 1200, 5 - 6 mils DFT (two coats) Rigidizer ................................................. KAOWOOL spray-on rigidizer to protect the insulation. External Coating: Surface Preparation: ............................. SSPC-SP-6 sandblast; Primer: .................................................... inorganic rich zinc primer, 2 - 4 mils DFT (one coat) Automatic dampers: ..................................... four (4) (One hinged for easy interior access) Damper actuators:................................. explosion proof Manifold Construction: .................................. carbon steel Inlet Diameter: ............................................... 12 in. Flare Tips: ....................................................... four (4), each with one type K thermocouple Flare Tip Construction: .................................. Portions 304 and 310 stainless; ceramic burner can Burner Staging: .............................................. two stages Second Stage Cooling Fan: ........................... ¾ HP, 700 CFM (shipped loose for field installation) Stack Thermocouple Connections: ............... three (3), each with one type K thermocouple Sample Ports: ................................................. four (4) Sight Ports: ..................................................... two (2) Pilot Ignition (Qty 2): ...................................... electronic spark ignitors; NEMA 7 ignition panels Flame Scanner: .............................................. one (1) Honeywell UV scanner (or equal) Purge Blower: ................................................. continuous purge provided by combustion air blower and cooling fan Structural Anchoring: ..................................... AISC continuous base plate Ladder: ........................................................... one (1) 40 ft. ladder including fall protection with one (1) harness. Lifting Lugs: .................................................... two (2) Premix chamber: ............................................ included with static mixer assembly and manway Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 8 of 11 SHIPPED LOOSE EQUIPMENT Combustion Air Blower: Quantity: ........................................................ one (1) Flowrate: ......................................................... 20,000 SCFM Inlet Suction: .................................................. -5 inches of H2O Outlet Pressure: ............................................. 15 inches of H2O Motor Power: ................................................. 75 HP Motor Control: NEMA 3R variable frequency drive (see below for additional details) Motor Enclosure: ........................................... TEFC (NEMA) Outlet Attachments: ....................................... flexible expansion joint Manufacturer: ................................................ Chicago Blower (or equal) Accessories: Inlet Venturi Style Flow Meter: .............. one (1) included, Aeroacoustics (or equal) Inlet Rainhood & Filter: ......................... one (1) included Silencer: ................................................. one (1) included Pressure Gauge: .................................... one (1) included Combustion Air Blower VFD: Quantity: ......................................................... one (1) Enclosure: ...................................................... NEMA 3R Motor Power: .................................................. 75 HP Power Input: ................................................... 480V, 3ph, 60hz Drive Manufacturer: ...................................... FUJI Automatic Ignition and Control Station: Panel Rack: .................................................... one (1); including the following: Power transformer: ........................................ 480V to 120V Control Panel: Quantity .................................................. one (1) Certification ............................................ Underwriters Laboratory Enclosure ............................................... weatherproof PLC ......................................................... Allen Bradley CompactLogix Communication ..................................... via Ethernet/IP signals: ........................................ remote start/stop (discrete signal) flare status (discrete signal) waste gas flow in SCFM (analog signal) fuel gas flow in SCFM (analog signal) flare temperature in degrees F (analog signal) Operator Touchscreen ........................... 12” Tru-Vue (or equal) Color Operator Interface Panel Flame Scanner Relay ............................ one (1) UV flame scanner control relay Control Panel Weatherhood: ................. included with LED panel light Emergency Stop Button ........................ one (1) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 9 of 11 Flame Arrester: Quantity: ......................................................... one (1) Diameter: ....................................................... 10 in. Style: ............................................................... eccentric Housing material: .......................................... aluminum Internals material: ......................................... stainless steel Internals monitoring: ..................................... one (1) Dwyer differential pressure gauge one (1) type K thermocouple Manufacturer: ................................................ Enardo (or equal) Second Stage Duct Block Valve: Quantity: ......................................................... one (1) Diameter: ....................................................... 36 in. Style: ............................................................... lug Actuator: ......................................................... piston with spring return, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Apollo (or equal) Automatic Block Valve: Quantity: ......................................................... three (3); one for waste gas, two for stage cooling fan Diameter: ....................................................... one (1) 10 in.; two (2) 6 in. Style: ............................................................... lug Actuator: ......................................................... pneumatic, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Xomox (or equal) Pressure Control Valve: Quantity: ......................................................... one (1) Diameter: ....................................................... 10 in. Style: ............................................................... lug Actuator: ......................................................... pneumatic, fail closed Body material: ................................................ carbon steel Disk: ................................................................ 316 stainless steel Seat: ............................................................... PTFE Manufacturer: ................................................ Apollo (or equal) Rack Mounted Gas Analyzer: Quantity: ....................................................... one (1), for air blower control Measurement: .............................................. CH4 and O2 Sample Pump: .............................................. included Autocalibration Package: ............................ included Manufacturer: .............................................. QED Environmental (or equal) Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 10 of 11 Flow Meter: Quantity: ......................................................... one (1) for fuel gas (ultrasonic flow meter to be provided by end user to provide 4-20 signals for flowrate in SCFM as well as molecular weight of waste gas stream) Type: ............................................................... thermal mass Probe material: .............................................. 316 stainless steel, Teflon coated Manufacturer: ................................................ Endress and Hauser (or equal) Ancillary Equipment: Pressure Transmitter: .................................. two (2), one for mixing chamber monitoring (high pressure shutdown), one for pilot gas monitoring (low pressure shutdown) (additional pressure transmitter for inlet pipe monitoring to be provided by end user; will provide interlock, preventing flare startup if piping pressure is too high) Pilot Gas Spool: ............................................ one (1) including, ½” piping, solenoid valve, pressure regulator with carbon steel body, four manual valves, pressure gauge, two strainers, manual globe valve Fuel Gas Spool: .............................................. one (1) including modulating flow control valve, automated ball valve, two manual valves, pressure regulator with carbon steel body, pressure gauge, strainer Thermocouple Wire: ..................................... 900 ft. Ignition Wire: ................................................ 25 ft. Archaea – Coyote Canyon October 6, 2023 202203-268235REV11 PROPRIETARY AND CONFIDENTIAL www.johnzinkhamworthy.com Page 11 of 11 PERFORMANCE Expected Flare Pre-Mix Emission Range – Waste Gas Streams 1, 2, 3, 4, 6, 7(Design Flow) Operating Temperature 1600°F 1800°F Smokeless Capacity 100% 100% Methane Destruction Efficiency 99% 99% NOx, lb / MMBTU(1) 0.025 0.025 CO, lb / MMBTU(2) 0.06 0.05 VOC Destruction Efficiency (3) 98% 98% (1) Excludes NOx from fixed nitrogen. (2) Excludes CO contribution present in the gas. (3) VOC Emissions of 0.038 lb/MMBTU is achievable based on a maximum inlet VOC concentration of 5,000 ppm as methane. NOTE: Expected emissions are based on field tests of operating units and the higher heating value (HHV) of the gas. Destruction efficiency, NOx, and CO emissions shown are valid for combustion of specified gas only. Expected emissions are not guaranteed unless expressly stated elsewhere in this proposal. Expected Flare Pre-Mix Emission Range – Waste Gas Streams 5, 8 (Design Flow) Operating Temperature 1600°F 1800°F Smokeless Capacity 100% 100% Methane Destruction Efficiency 99% 99% NOx, lb / MMBTU(1) 0.06 0.08 CO, lb / MMBTU(2) 0.15 0.2 VOC Destruction Efficiency (3) 98% 98% (1) Excludes NOx from fixed nitrogen. (2) Excludes CO contribution present in the gas. (3) VOC Emissions of 0.038 lb/MMBTU is achievable based on a maximum inlet VOC concentration of 5,000 ppm as methane. NOTE: Expected emissions are based on field tests of operating units and the higher heating value (HHV) of the gas. Destruction efficiency, NOx, and CO emissions shown are valid for combustion of specified gas only. Expected emissions are not guaranteed unless expressly stated elsewhere in this proposal. PTC/PTO Application www.scsengineers.com B-4 H2S Scrubber BSR-20; BSR-50; BSR-60 Safety Data Sheet Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations Date of issue: 03/22/2016 Revision 1.0: 09/18/2017 09/18/2017 BSR-20; BSR-50; BSR-60 Page 1 SECTION 1: Identification of the substance/mixture and of the company/undertaking 1.1. Product identifier Product name : BSR-20; BSR-50; BSR-60 Product form : Mixture 1.2. Relevant identified uses of the substance or mixture and uses advised against Use of the substance/mixture : Filtration media 1.3. Details of the supplier of the safety data sheet Guild Associates Inc. 5750 Shier-Rings Road Dublin, OH 43016 1-614-798-8215 1.4. Emergency telephone number CHEMTREC : 1-800-424-9300 SECTION 2: Hazards identification 2.1. Classification of the substance or mixture GHS-US classification Not classified. 2.2. Label elements GHS-US labeling No labelling applicable 2.3. Other hazards No additional information available 2.4. Unknown acute toxicity (GHS US) No data available SECTION 3: Composition/Information on ingredients 3.1. Substance Not applicable 3.2. Mixture Name Product identifier % Contains no hazardous ingredients at levels requiring disclosure by the OSHA Hazard Communication Standard (29 CFR 1910.1200). Non-hazardous constituents provided voluntarily, below. 100 Zinc Oxide 1314-13-2 20 - 60 Iron Hydroxide Oxide 20344-49-4 20 - 60 Silicon Dioxide 7631-86-9 5 – 30 Water (absorbed) 7732-18-5 <15 *In accordance with paragraph (i) of the OSHA Hazard Communication Standard (29 CFR §1910.1200), the specific chemical identity or exact weight % has been withheld as a trade secret SECTION 4: First aid measures 4.1. Description of first aid measures First-aid measures general : If exposed or concerned, get medical attention/advice. Show this safety data sheet to the doctor in attendance. Wash contaminated clothing before re-use. Never give anything to an unconscious person. First-aid measures after inhalation : IF INHALED: Remove to fresh air and keep at rest in a comfortable position for breathing. First-aid measures after skin contact : IF ON SKIN (or clothing): Remove affected clothing and wash all exposed skin with water for at least 15 minutes. First-aid measures after eye contact : IF IN EYES: Immediately flush with plenty of water for at least 15 minutes. Remove contact lenses if present and easy to do so. Continue rinsing. First-aid measures after ingestion : IF SWALLOWED: rinse mouth thoroughly. Do not induce vomiting without advice from poison control center or medical professional. Get medical attention if you feel unwell. 4.2. Most important symptoms and effects, both acute and delayed Symptoms/injuries : Not expected to present a significant hazard under anticipated conditions of normal use Symptoms/injuries after inhalation : May cause respiratory irritation. BSR-20; BSR-50; BSR-60 Safety Data Sheet Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations 09/18/2017 BSR-20; BSR-50; BSR-60 2/5 Symptoms/injuries after skin contact : May cause skin irritation. Symptoms/injuries after eye contact : Direct contact with the eyes is likely to be irritating. Symptoms/injuries after ingestion : May cause gastrointestinal irritation. 4.3. Indication of any immediate medical attention and special treatment needed No additional information available SECTION 5: Firefighting measures 5.1. Extinguishing media Suitable extinguishing media : Carbon dioxide. Foam. Sand. Dry chemical powder. 5.2. Special hazards arising from the substance or mixture Fire hazard : Not flammable. Explosion hazard : Product is not explosive. Reactivity : No dangerous reactions known under normal conditions of use. 5.3. Advice for firefighters Firefighting instructions : Use water spray or fog for cooling exposed containers. Exercise caution when fighting any chemical fire. Do not dispose of fire-fighting water in the environment. SECTION 6: Accidental release measures 6.1. Personal precautions, protective equipment and emergency procedures 6.1.1. For non-emergency personnel Protective equipment : Wear Protective equipment as described in Section 8. Emergency procedures : Evacuate unnecessary personnel. Keep upwind. 6.1.2. For emergency responders Protective equipment : For further information refer to section 8: "Exposure controls/personal protection". 6.2. Environmental precautions Avoid release to the environment. Prevent entry to sewers and public waters. Notify authorities if product enters sewers or public waters. 6.3. Methods and material for containment and cleaning up For containment : Contain any spills with dikes or absorbents to prevent migration and entry into sewers or streams. Methods for cleaning up : Wear suitable protective clothing. Take up liquid spill into inert absorbent material, e.g: sand, earth, vermiculite. Place in a suitable container for disposal in accordance with the waste regulations (see Section 13). Contain any spills with dikes or absorbents to prevent migration and entry into sewers or streams. 6.4. Reference to other sections No additional information available SECTION 7: Handling and storage 7.1. Precautions for safe handling Precautions for safe handling : Do not handle until all safety precautions have been read and understood. Handle in accordance with good industrial hygiene and safety procedures. Wear recommended personal protective equipment. Wash hands and other exposed areas with mild soap a nd water before eating, drinking, applying cosmetics, or smoking and when leaving work. Avoid dust formation. 7.2. Conditions for safe storage, including any incompatibilities Storage conditions : Keep container tightly closed. Store in a dry, cool and well-ventilated place. SECTION 8: Exposure controls/personal protection 8.1. Control parameters No additional information available. 8.2. Exposure controls Appropriate engineering controls : Provide adequate general and local exhaust ventilation. Use process enclosures, local exhaust ventilation, or other engineering controls to control airborne levels below recommended exposure limits. Ensure adequate ventilation, especially in confined areas. Personal protective equipment : Safety glasses. Gloves. Insufficient ventilation: wear respiratory protection. Hand protection : Use gloves appropriate to the work environment. BSR-20; BSR-50; BSR-60 Safety Data Sheet Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations 09/18/2017 BSR-20; BSR-50; BSR-60 3/5 Eye protection : Use eye protection suitable to the environment. Avoid direct contact with eyes. Skin and body protection : Wear long sleeves, and chemically impervious PPE/coveralls to minimize bodily exposure. Respiratory protection : Use NIOSH-approved dust/particulate respirator. Where vapor, mist, or dust exceed PELs or other applicable OELs, use NIOSH-approved respiratory protective equipment. SECTION 9: Physical and chemical properties 9.1. Information on basic physical and chemical properties Physical state : Solid Appearance : Granular material. Beads. Color : Reddish-yellow. Odor : None. Odor Threshold : No data available pH : No data available Relative evaporation rate (butyl acetate=1) : No data available Melting point : No data available Freezing point : No data available Boiling point : No data available Flash point : No data available Auto-ignition temperature : Does not self-ignite. Decomposition temperature : No data available Flammability (solid, gas) : No data available Vapor pressure : No data available Relative vapor density at 20 °C : No data available Relative density : No data available Solubility : No data available Log Pow : No data available Log Kow : No data available Viscosity, kinematic : No data available Viscosity, dynamic : No data available Explosive properties : Not an explosive solid. Oxidizing properties : Not an oxidizing solid Explosion limits : No data available 9.2. Other information No additional information available SECTION 10: Stability and reactivity 10.1. Reactivity No dangerous reactions known under normal conditions of use. 10.2. Chemical stability Stable. 10.3. Possibility of hazardous reactions None known. 10.4. Conditions to avoid No data available. 10.5. Incompatible materials Strong acids. Strong bases. 10.6. Hazardous decomposition products Cobalt oxide. SECTION 11: Toxicological information 11.1. Information on toxicological effects Acute toxicity : Not classified Skin corrosion/irritation : Not classified Serious eye damage/irritation : Not classified Respiratory or skin sensitization : Not classified BSR-20; BSR-50; BSR-60 Safety Data Sheet Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations 09/18/2017 BSR-20; BSR-50; BSR-60 4/5 Germ cell mutagenicity : Not classified Carcinogenicity : Not classified Reproductive toxicity : Not classified Specific target organ toxicity (single exposure) : Not classified Specific target organ toxicity (repeated exposure) : Not classified Aspiration hazard : Not classified Symptoms/injuries after inhalation : May cause respiratory irritation. Symptoms/injuries after skin contact : May cause skin irritation. Symptoms/injuries after eye contact : Direct contact with the eyes is likely to be irritating. Symptoms/injuries after ingestion : May cause gastrointestinal irritation. SECTION 12: Ecological information 12.1. Toxicity Ecology - general : No data available. 12.2. Persistence and degradability BSR-20; BSR-50; BSR-60 Persistence and degradability No data available. 12.3. Bioaccumulative potential BSR-20; BSR-50; BSR-60 Bioaccumulative potential No data available. 12.4. Mobility in soil BSR-20; BSR-50; BSR-60 Ecology - soil No data available. 12.5. Other adverse effects Other information : No data available. SECTION 13: Disposal considerations 13.1. Waste treatment methods Waste treatment methods : Dispose in a safe manner in accordance with local/national regulations. SECTION 14: Transport information In accordance with DOT Not hazardous for transport Additional information Other information : No supplementary information available. Transport by sea No additional information available Air transport No additional information available SECTION 15: Regulatory information 15.1. US Federal regulations BSR-20; BSR-50; BSR-60 All chemical substances in this product are listed in the EPA (Environment Protection Agency) TSCA (Toxic Substances Control Act) Inventory or are exempt SARA Section 311/312 Hazard Classes None 15.2. International regulations No additional information available. 15.3. US State regulations This product does not contain any substances known to the state of California to cause cancer and/or reproductive harm BSR-20; BSR-50; BSR-60 Safety Data Sheet Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations 09/18/2017 BSR-20; BSR-50; BSR-60 5/5 Zinc Oxide (1314-13-2) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Massachusetts - Right To Know List U.S. - Pennsylvania - RTK (Right to Know) - Environmental Hazard List Silica, amorphous (7631-86-9) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Massachusetts - Right To Know List U.S. - Pennsylvania - RTK (Right to Know) List SECTION 16: Other information Indication of changes : Revision 1.0: : 09/18/2017 Other information : Author: LMG. NFPA health hazard : 0 - Exposure under fire conditions would offer no hazard beyond that of ordinary combustible materials. NFPA fire hazard : 0 - Materials that will not burn. NFPA reactivity : 0 - Normally stable, even under fire exposure conditions, and are not reactive with water. HMIS III Rating Health : 0 Flammability : 0 Physical : 0 Personal Protection : This information is based on our current knowledge and is intended to describe the product for the purposes of health, safety and environmental requirements only. It should not therefore be construed as guaranteeing any specific property of the product PTC/PTO Application www.scsengineers.com B-4 Condensate Tanks ® ® NOTE: ALL RIGHTS RESERVED. THIS DRAWING MUST NOT BE REPRODUCED IN ANY FORM WITHOUT THE WRITTEN PERMISSION OF HIGHLAND TANK • HIGHLAND TANK SHALL BE RESPONSIBLE ONLY FOR ITEMS INDICATED ON THIS FABRICATION DRAWING UNLESS OTHERWISE NOTED. CUSTOMER IS RESPONSIBLE FOR VERIFYING CORRECTNESS OF SIZE AND LOCATION OF FITTINGS, ACCESSORIES, AND COATINGS SHOWN ON THIS DRAWING. TOUCH UP □F FINISHED PAINT IS REQUIRED BY INST ALLA TI □N CONTRACTOR. TOUCH UP PAINT SHIPPED IJITH TANK, SHIPPING LUGS AS NEEDED NOTES 1. SEE PLAN VIEW FOR TRUE ORIENTATION AND LOCATION OF FITTING 2. LIFTING LUGS FOR UNLOADING UNIT & STANDING UNIT UPRIGHT TO BE PLACED AS NEEDED BY F AB RICA TION SHOP 3. A 3x3x¼" STEEL GROUNDING LUG WITH A %"¢ HOLE IN CENTER TO BE PLACED ON SHELL AT BOTTOM OF TANK IN LINE WITH LIFTING LUGS SHIP LOOSE (2) FLAT FLANGED EMERGENCY VENTS 8 OZ. V2,S2l -L3, V1 B~M1 ....... ~~-\ 1 S1 r V3, L1 l -,-------,1+-11---c§] 0 I N ..-- 0 I m F~ 18" I I 8" I c§] ,A ' I n / TI H H 4" TYP. ALL SHELL l -, I FLEANGES ~2, ,{~ ~ 35"G C I / -~ 1,. I I L2 I ,W_ I 18"361 8" -13 = 8" I ...J I 10'-0"¢ INNER I -C01 ELEV A Tl ON VIEW TANK SHELL :r: <( 0 X 0::: 0 w 0::: z 0.... z 0.... -<( c.o I L[) I L[) N c.o N TOP VIEW 1 6 a.. 4" - - ¢Z" 8 HOLES SHELLS~ -ACAP I I I lt=====l===l=;t::::i I I I ~ ,--~~ -f+-1-- DESIGN DATA CAPACITY -15,000 GALLON TYPE -VERTICAL DOUBLE WALL NO. REQ. -ONE OPERATING PRESSURE -ATMOSPHERIC SPECIFIC GRAVITY = 1.0 TANK MATERIAL -MILD CARBON STEEL THICKNESS-TOP -1/4" SHALLOW SLOPE THICKNESS-INNER-SHELL: 1/4" BOTTOM: 1/4" THICKNESS-OUTER-SHELL: 7 GA BOTTOM: 1/4" CONSTRUCTION -INNER-LAP WELD INTERIOR & EXTERIOR SEAMS, OUTER-LAP WELD EXTERIOR ONLY TANK TEST -INNER: 2 PSIG, OUTER:-2 PSIG & FULL VACUUM INT. FINISH -SP10 BLAST, CHEMLINER 4000 EPOXY (6-10 MILS PER COAT/12-20 TOTAL DFT EXT. FINISH -SP6 BLAST, FINISH URETHANE WHITE LABEL -UL 142 LEGEND M1 24" x f PLATE TIGHT BOLT MANWAY W/ FlBERFLEX GRADE A GASKET & DA~T y 1 8" FFSO 150# FLANGE THROUGH OUTER SHELL ONLY, MARK WITH SPECIAL WARNING LABEL - INTERSTITIAL EMERGENCY VENT USE ONLY 24" CLOSE BOLT MANWAY W/ )a" THK NEO MZ CORK GASKET, ~"FLANGE, fNECK, ~"COVER INCLUDES DAVIT L 1 2" INTERSTITIAL MONITOR PIPE yz 8" 150# FFSO FLANGE -PRIMARY EMERGENCY VENT A 4" 150# RFSO FLANGE (OUTLET) CO 1 4" 150# RFSO FLANGE (CLEAN OUT) 8 2" 150# RFSO FLANGE (FILL) V3 4" FNPT FITTING (VENT) C 4" FNPT FITTING (TRUCK HAULING) S 1 4" FNPT FITTING (SPARE) D 4" FNPT FITTING (OUTLET) L2 2" FNPT FITTING (SIGHT GLASS) E 2" 150# RFSO FLANGE (SAMPLING) F 4" 150# RFSO FLANGE (OUTLET) S2 2" 150# RFSO FLANGE (SPARE) S3 4" 150# RFSO FLANGE (SPARE) L3 1.5" PIPE STUB, 6" HIGH (TOE) MNPT G HOLD DOWN LUG PER DETAIL AVLUGB H VERTICAL CLIP PER DETAIL DRAWING 1 OF 2 SHEET-1 TANK DETAILS SHEET-2 DAVIT, HOLD DOWN LUG DETAILS /\ -ADDED MANWAY DAVITS, REV 9 /1 /23 002 ~ MAN WAY CALL OUTS /\ -CORRECTED "H" DIMENSION, 8;31 /23 002 ~ JOB NAME JUNIPER ffi ;~~~D L~~~ND CALL OUTS, 8128123 002 .IDhllldllk UNLESS NOTED, TOLERANCES ARE +/-1' 15,000 GAL 120"¢ OW VERTICAL FLAT FLANGED HEA\ ~ _ 314,, FLAT BOTTO~~, ff 1 ll=======l }, l~c4X7.25 f X 6" X_/ f I CHANNEL CUSTOMER: AHJRLLFG LLC. 6" REPAD '1 12a" 1-----1 I BOTTOM JOINT DETAIU ~ ELEVAT10N] HOUSTON, TX. PROJECT: JUNIPER ALTON, ME. QUOTE ND: 5 4 4 21 2 1 CHK'D BY, ® ® NOTE: ALL RIGHTS RESERVED. THIS DRAWING MUST NOT BE REPRODUCED IN ANY FORM WITHOUT THE WRITTEN PERMISSION OF HIGHLAND TANK • HIGHLAND TANK SHALL BE RESPONSIBLE ONLY FOR ITEMS INDICATED ON THIS FABRICATION DRAWING UNLESS OTHERWISE NOTED. CUSTOMER IS RESPONSIBLE FOR VERIFYING CORRECTNESS OF SIZE AND LOCATION OF FITTINGS, ACCESSORIES, AND COATINGS SHOWN ON THIS DRAWING. TOUCH UP □F FINISHED PAINT IS REQUIRED BY INST ALLA TI □N CONTRACTOR. TOUCH UP PAINT SHIPPED IJITH TANK, 7,, -H 16 - - 3" -r-- -~ -= ..-IN - -CX) N = - - J 5" 16 7" /16" HOLES FOR 1 /2" BOLTS TYP (24) PLCS 2" PIPE\ GUSSET 1" NUT & WASHER 1" S.S. EYEBOL T X 6" LONG McMASTER-CARR #3O69T39 r--- GUSSET PLATES TYP (4) PLCS 2 1 /2" PIPE 2~" GU§SET PLATES TYP. (4 PLCS) 1" DIA. RND BAR (ATTACH EYEBOLT BEFORE WELDING) ROOF DAVIT DETAIL (ITEM-M1) NUT AND WASHER 1" S.S. EYBOL T x 6" LONG MCMASTER-CARR #3O69T39 ------1/8" DIA. ROUND BAR (ATTACH EYBOL T BEFORE WELDING) .. ~::----r-~~~ 9/16" HOLES FOR 3/4" BOLTS ,f/ ~ '\~ TYP ( 48) PLCS t1 1 · · 1 \~ if-tJ-+-➔• (I,\ 6 .. /,} ¢28~" O.D. ' /~-----' / . ~-.!;.---¢24" I.D. 5/8" RND BAR HAND,LJ~S TYP (2) PLCS ¢27" B. C. 1-1/Bnl!l HOLE SHIP LOOSE SHELL MANWAY DAVIT DETAIL (ITEM-M2) DRAWING 2 OF 2 SHEET-1 TANK DETAILS SHEET-2 DAVIT, HOLD DOWN LUG DETAILS IDhllldllk 3n HOLD DOWN LUG AVLUGB 15,000 GAL 120"¢ OW VERTICAL CUSTOMER: AHJRLLFG LLC. HOUSTON, TX. PROJECT: JUNIPER ALTON, ME. QUOTE ND: 544 21 2 • ,I 124756-2 PRODUCT DATA SHEET TIGG® | 724.703.3020 | newterra.com TIGG® and the Newterra® logo are registered trademarks of Newterra, Ltd. or its af liates in the US and other countries. Copyright © 2023. Newterra, Ltd. 02-23 NIXTOX Steel Drum Adsorbers Modular Activated Carbon Vapor Phase Adsorbers These economical deep bed activated carbon adsorption units may be used as refillable or disposable adsorbers. Rain shields are available and condensate drains are standard. The activated carbon units are constructed of carbon steel and provided with a double epoxy/phenolic lining. All adsorption units feature specially constructed vapor distributors to permit full adsorbent utilization and peak removal efficiency. Custom distributors for high temperature applications are available upon request. NIXTOX Features • Nominal design flow may be conservative. • Desired contact time may allow higher or lower flow rates. • Dry virgin activated or reactivated carbon provided as standard adsorbent. • Adsorbent fill is based on a bed density of 27 lb/ft3. • Adsorbent fill can differ based on variable bed density and alternate adsorbents. • Pressure drops are based on a dense packed bed of activated carbon. About Newterra Newterra offers a broad portfolio of reliable, trouble-free technologies and outsourcing support for global municipal and industrial customers across diverse applications, including drinking water, industrial process water, wastewater, stormwater and remediation. Product Features • May be used as refillable or disposable adsorbers • Constructed of carbon steel and provided • Double epoxy/phenolic lining Modular Activated Carbon Vapor Phase Adsorber Drums Model #Max Temp (ºF)Max Press (PSIG) Diameter/ Height (in) Standard Fill (lbs) N-100 200 6 24.5/37.75 200 PTC/PTO Application www.scsengineers.com C-6 Emergency Backup Generator Part No. A0005031827 Rev. C 3/5/24 STATEMENT OF EXHAUST EMISSIONS 2024 Spark-Ignited Generators Industrial Series - SCAQMD Certified, Stationary Emergency EM I S S I O N D A T A 1 OF 2 Model Engine (L) Engine Emissions Designation EPA Engine Family Fuel Catalyst Required SCAQMD CEP # EPA Certificate Grams/bhp-hr.Rated RPM BHP Fuel Flow (lb/hr)THC NMHC NOx CO Sm a l l S p a r k I g n i t e d E n g i n e ( S S I E ) Sm a O O 2 5 o a d E n g i n e V S 2 5 E QTA25 2.4 A02.4GCN029A0 RGNXB02.4MDI NG No Not Required RGNXB02.4MDI-046 1.40 N/A 4.32 85.00 1,800 38 16.52 QTA25 2.4 A02.4GCV032A0 RGNXB02.4MDI LPG RGNXB02.4MDI-046 N/A 2.11 2.33 92.66 1,800 43 17.59 SG035, 40, 45, 50NA 4.5 C04.5SPN054A0 RGNXB04.5MJJ NG Yes 618432 RGNXB04.5MJJ-043 0.20 0.02 0.05 0.92 1,800 76 23.7 SG035, 40, 45, 50NA 4.5 C04.5SPV054A0 RGNXB04.5MJJ LPG 618432 RGNXB04.5MJJ-043 0.02 0.01 0.17 0.13 1,800 76 26 SG050T, 60, 70, 80 4.5 C04.5SPN099A0 RGNXB04.5MJJ NG 623270 RGNXB04.5MJJ-043 0.11 0.01 0.17 0.16 1,800 132 43.68 SG050T, 60, 70, 80 4.5 C04.5SPV099A0 RRGNXB04.5MJJ LPG 623270 RGNXB04.5MJJ-043 0.03 N/A 0.13 0.20 1,800 132 46.61 La r g e S p a r k I g n i t e d E n g i n e s ( L S I E ) SG080, 100 9.0 E08.9GSN111A1 RGNXB08.92O1 NG 598551 RGNXB08.92O1-047 0.18 0.00 0.01 0.25 1,800 153 53.1 SG080, 100 (LPF)9.0 E08.9MSN116A1 RGNXB08.92O1 NG 598558 RGNXB08.92O1-047 0.11 0.00 0.12 0.03 1,800 153 53.24 SG080, 100 9.0 F08.9GSV106A0 RGNXB08.92O2 LPV 642064 RGNXB08.92O2-028 0.01 N/A 0.21 0.22 1,800 156 54.36 SG080, 100 9.0 F08.9GSV106A0 RGNXB08.92O2 LPL 642064 RGNXB08.92O2-028 0.03 N/A 0.00 0.36 1,800 156 55.27 SG130, 150 9.0 E08.9MSN170A0 RGNXB08.92O3 NG 618434 RGNXB08.92O3-029 0.14 0.00 0.10 0.74 1,800 229 86.37 SG130, 150 9.0 F08.9MSV169A0 RGNXB08.92O4 LPV 606652 RGNXB08.92O4-030 0.02 N/A 0.03 0.09 1,800 230 85.37 SG175 14.2 E14.2MSN227A3 RGNXB14.22C1 NG 618436 RGNXB14.22C1-031 0.24 0.00 0.12 0.21 1,800 304 101.16 SG/MG150, 200 14.2 E14.2MSN227A3 RGNXB14.22C1 NG 618436 RGNXB14.22C1-031 0.24 0.00 0.12 0.21 1,800 304 101.16 SG230, 250 14.2 E14.2MSN279A3 RGNXB14.22C1 NG 618438 RGNXB14.22C1-031 0.15 0.00 0.35 0.41 1,800 374 141.71 SG/MG250 14.2 E14.2MSN279A3 RGNXB14.22C1 NG 618438 RGNXB14.22C1-031 0.15 0.00 0.35 0.41 1,800 374 141.71 SG275,300 14.2 E14.2MSN343A3 RGNXB14.22C1 NG 618440 RGNXB14.22C1-031 0.03 0.00 0.04 0.32 1,800 460 140.33 MG300 14.2 E14.2MSN343A3 RGNXB14.22C1 NG 618440 RGNXB14.22C1-031 0.03 0.00 0.04 0.32 1,800 460 140.33 SG/MG350, 400 21.9 E21.9MSN474A4 RGNXB21.92C1 NG 618441 RGNXB21.92C1-032 0.07 0.00 0.26 0.21 1,800 636 176 SG/MG350,400 (LPF)21.9 E21.9MSN474A5 RGNXB21.92C1 NG 618442 RGNXB21.92C1-032 0.30 0.00 0.06 0.12 1,800 636 214 SG/MG400,450 21.9 E21.9MSN0502A4 RGNXB21.92C3 NG 618441 RGNXB21.92C3-033 0.08 0.00 0.06 0.10 1,800 673 209 SG/MG400,450 (LPF)21.9 E21.9MSN0502A5 RGNXB21.92C3 NG 618441 RGNXB21.92C3-033 0.19 0.00 0.05 0.17 1,800 673 224 SG/MG500 25.8 E25.8MSN580A4 RGNXB21.92C3 NG 593192 RGNXB21.92C3-034 0.16 0.00 0.03 0.60 1,800 778 280 SG/MG500 (LPF)25.8 E25.8MSN580A5 RGNXB25.82C1 NG 606658 RGNXB25.82C1-034 0.19 0.00 0.06 0.57 1,800 778 280 SG/MG625 33.9 E33.9MSN677A0 RGNXB33.92C1 NG 601949 RGNXB33.92C1-035 0.13 0.00 0.01 0.22 1,800 909 325 SG/MG750 33.9 E33.9MSN803A0 RGNXB33.92C1 NG 606655 RGNXB33.92C1-035 0.18 0.00 0.15 0.92 1,800 1077 417 SG/MG1000 49.0 E49.0ASN1100A0 RGNXB49.02C1 NG 625240 RGNXB49.02C1-036 0.11 0.00 0.03 0.65 1,800 1475 427 NG: Natural Gas LPG: Liquid Propane Vapor or Liquid Propane Liquid 1$ 1ot $SSOicaEOe LPV: Liquid Propane Vapor LPF: Units with Optional Low Pressure Fuel System Engine %+3 iV taNen Irom Engine EmiVVionV Certification 5eVXOtV LPL: Liquid Propane Liquid 5eIer to 3age Ior 'efinitionV and $dYiVory 1oteV Generac Power Systems, Inc. | P.O. Box 8 | Waukesha, WI 53187 P: (262) 544-4811 © 2024 Generac Power Systems, Inc. All rights reserved. All specifications are subject to change without notice. Part No. A0005031827 Rev. C 3/5/24 STATEMENT OF EXHAUST EMISSIONS 2024 Spark-Ignited Generators Industrial Series - SCAQMD Certified, Stationary Emergency EM I S S I O N D A T A 2 OF 2 2024 EPA SPARK-IGNITED EXHAUST EMISSIONS DATA (ective since 200 , the (PA has implemented e[haust emissions regulations on stationary sparN-ignited (gaseous) engine generators Ior emergency applications. All Generac sparN-ignited gensets, including SG, 0G, 47A, 47 and 5G series gensets that are built with engines manuIactured in 200 and later meet the reTuirements oI 40&)5 part 60 subpart ---- and are (PA certified. 7hese generator sets are labeled as (PA &ertified with decals aɝ[ed to the enginesȇ valve covers. 7he attached documents summari]e the general inIormation relevant to (PA certification on these generator sets. 7his inIormation can be used Ior submittal data and Ior permitting purposes, iI reTuired. 7hese documents include the Iollowing inIormation: EPA Engine Family 7he (PA (ngine )amily is assigned by the 0anuIacturer under (PA guidelines Ior certification purposes and appears on the (PA certificate. Catalyst Required Indicates whether a three-way catalyst (7:&) and Air)uel 5atio control system are reTuired on the generator set to meet (PA certification reTuirements. Generally, units rated 80N: and smaller do not reTuire a 7:& to meet (PA certification reTuirements. Please note that some units that do not reTuire a 7:& to meet (PA reTuirements do need one iI the &aliIornia S&A40' option is selected. Please see Ȋ&aliIornia S&A40'ȋ below Ior additional inIormation on this option. Combination Catalyst or Separate Catalyst SG and 0G series generator sets typically utili]e a single combination catalystsilencer as part oI meeting (PA certification reTuirements. 0any 47 and 5G series generator sets use the same engines as SG series units, but have dierent e[haust configurations that reTuire the use oI conventional silencers with additional separate catalysts installed. E3$ Certificate 1XmEer 8pon certification by the (PA, a &ertificate 1umber is assigned by the (PA. EmiVVionV $ctXaOV *ramVEKSKr Actual e[haust emission data Ior 7otal +ydrocarbons (7+&), 1itrogen 2[ides (12[) and &arbon 0ono[ide (&2) that were submitted to (PA and are oɝcial data oI record Ior certification. 7his data can be used Ior permitting iI necessary. 9alues are e[pressed in grams per braNe horsepower-hour to convert to gramsN:-hr, multiply by 1.41. Please see advisory notes below Ior Iurther inIormation. California Units, SCAQMD CEP Number A separate low-emissions option is available on many Generac gaseous-Iueled generator sets to comply with the more stringent South &oast Air 4uality 0anagement 'istrict reTuirements that are recogni]ed in certain areas in &aliIornia. Gensets that include this option are also (PA &ertified. General Advisory Note to Dealers 7he inIormation provided here is proprietary to Generac and itsȇ authori]ed dealers. 7his inIormation may only be disseminated upon reTuest, to regulatory governmental bodies Ior emissions permitting purposes or to speciIying organi]ations as submittal data when e[pressly reTuired by project specifications, and shall remain confidential and not open to public viewing. 7his inIormation is not intended Ior compilation or sales purposes and may not be used as such, nor may it be reproduced without the e[pressed written permission oI Generac Power Systems, Inc. $dYiVory 1oteV on EmiVVionV $ctXaOV • 7he stated values are actual e[haust emission test measurements obtained Irom units representative oI the generator types and engines described. • 9alues are oɝcial data oI record as submitted to the (PA and S&A40' Ior certification purposes. 7esting was conducted in accordance with prevailing (PA protocols, which are typically accepted by S&A40' and other regional authorities. • 1o emission values provided are to be construed as guarantees oI emissions levels Ior any given Generac generator unit. • Generac Power Systems, Inc. reserves the right to revise this inIormation without prior notice. • &onsult state and local regulatory agencies Ior specific permitting reTuirements. • 7he emissions perIormance data supplied by the eTuipment manuIacturer is only one element reTuired toward completion oI the permitting and installation process. State and local regulations may vary on a case-by-case basis and must be consulted by the permit applicanteTuipment owner prior to eTuipment purchase or installation. 7he data supplied herein by Generac Power Systems, Inc. cannot be construed as a guarantee oI installability oI the generator set. • 7he emission values provided are the result oI multi-mode, weighted scale testing in accordance with (PA testing regulations, and may not be representative oI any specific load point. • 7he emission values provided are not to be construed as emission limits. SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 1 of 6 DEMAND RESPONSE READY Standby Power Rating 200 kW, 250 kVA, 60 Hz Demand Response Rating 200 kW, 250 kVA, 60 Hz Prime Power Rating 180 kW, 225 kVA, 60 Hz Codes and Standards Not all codes and standards apply to all configurations. Contact factory for details. UL2200, UL6200, UL1236, UL489 CSA C22.2 BS5514 and DIN 6271 SAE J1349 NFPA 37, 70, 99, 110 NEC700, 701, 702, 708 ISO 3046, 7637, 8528, 9001 NEMA ICS10, MG1, 250, ICS6, AB1 ANSI C62.41 IBC 2009, CBC 2010, IBC 2012, ASCE 7-05, ASCE 7-10, ICC-ES AC- 156 (2012) TM ® ® Powering Ahead Generac ensures superior quality by designing and manufacturing most of its generator components, such as alternators, enclosures, control systems and communications software. Generac also makes its own spark-ignited engines, and you’ll find them on every Generac gaseous-fueled generator. We engineer and manufacture them from the block up — all at our facilities throughout Wisconsin. Applying natural gas and LP-fueled engines to generators requires advanced engineering expertise to ensure reliability, durability and necessary performance. By designing specifically for these dry, hotter-burning fuels, the engines last longer and require less maintenance. Building our own engines also means we control every step of the supply chain and delivery process, so you benefit from single- source responsibility. Plus, Generac Industrial Power’s distribution network provides all parts and service so you don’t have to deal with third-party suppliers. It all leads to a positive owner experience and higher confidence level. Generac spark-ignited engines give you more options in commercial and industrial generator applications as well as extended run time from utility-supplied natural gas. *Assembled in the USA using domestic and foreign parts Image used for illustration purposes only SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 2 of 6 DEMAND RESPONSE READY CONTROL SYSTEM Power Zone® Pro Sync Controller Program Functions •NFPA 110 Level 1 Compliant •Engine Protective Functions •Alternator Protective Functions •Digital Engine Governor Control •Digital Voltage Regulator •Multiple Programmable Inputs and Outputs •Remote Display Capability •Remote Communication via Modbus® RTU, Modbus TCP/IP, and Ethernet 10/100 •Alarm and Event Logging with Real Time Stamping •Expandable Analog and Digital Inputs and Outputs •Remote Wireless Software Update Capable •Wi-Fi®, Bluetooth®, BMS and Remote Telemetry •Built-In Programmable Logic Eliminates the Need for External Controllers Under Most Conditions •Ethernet Based Communications Between Generators •Programmable I/O Channel Properties •Built-In Diagnostics Protections •Low Oil Pressure •Low Coolant Level •High/Low Coolant Temperature •Sensor Failure •Oil Temperature •Over/Under Speed •Over/Under Voltage •Over/Under Frequency •Over/Under Current •Over Load •High/Low Battery Voltage •Battery Charger Current •Phase to Phase and Phase to Neutral Short Circuits (I2T Algorithm) 7 Inch Color Touch Screen Display •Resistive Color Touch Screen •Sunlight Readable (1400 NITS) •Easily Identifiable Icons •Multi-Lingual •On Screen Editable Parameters •Key Function Monitoring •Three Phase Voltage, Amperage, kW, kVA, and kVAr •Selectable Line to Line or Line to Neutral Measurements •Frequency •Engine Speed •Engine Coolant Temperature •Engine Oil Pressure •Engine Oil Temperature •Battery Voltage •Hourmeter •Warning and Alarm Indication •Diagnostics •Maintenance Events/Information ENGINE SYSTEM •Oil Drain Extension •Air Cleaner •Fan Guard (Open Set Only) •Stainless Steel Flexible Exhaust Connection •Factory Filled Oil and Coolant •Radiator Duct Adapter (Open Set Only) •Critical Silencer (Enclosed Unit Only) •Oil Temperature Indication and Alarm Fuel System •NPT Fuel Connection on Frame •Primary and Secondary Fuel Shutoff Cooling System •Closed Coolant Recovery System •UV/Ozone Resistant Hoses •Factory-Installed Radiator •50/50 Ethylene Glycol Antifreeze •Radiator Drain Extension Electrical System •Battery Charging Alternator •Battery Cables •Battery Tray •Rubber-Booted Engine Electrical Connections •Solenoid Activated Starter Motor ALTERNATOR SYSTEM •UL2200 GENprotect™ •Main Line Circuit Breaker •Class H Insulation Material •2/3 Pitch •Skewed Stator •Permanent Magnet Excitation •Sealed Bearing •Amortisseur Winding •Full Load Capacity Alternator GENERATOR SET •Internal Genset Vibration Isolation •Separation of Circuits - High/Low Voltage •Separation of Circuits - Multiple Breakers •Wrapped Exhaust Piping •Standard Factory Testing •2 Year Limited Warranty (Standby and Demand Response Rated Units) •1 Year Limited Warranty (Prime Rated Units) •Silencer Mounted in the Discharge Hood (Enclosed Units Only) •Ready to Accept Full Load in <10 Seconds ENCLOSURE (If Selected) •Rust-Proof Fasteners with Nylon Washers to Protect Finish •High Performance Sound-Absorbing Material (Sound Attenuated Enclosures) •Gasketed Doors •Upward Facing Discharge Hood (Radiator and Exhaust) •Stainless Steel Lift Off Door Hinges •Stainless Steel Lockable Handles •RhinoCoat™ - Textured Polyester Powder Coat Paint STANDARD FEATURES SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 3 of 6 DEMAND RESPONSE READYCONFIGURABLE OPTIONS ENGINE SYSTEM ○Engine Coolant Heater ○Baseframe Cover/Rodent Guard ○2 Stage Air Cleaner ○Oil Heater ○Air Filter Restriction Indicator ○Radiator Stone Guard (Open Set Only) ○Level 1 Fan and Belt Guards (Enclosed Units Only) FUEL SYSTEM ○NPT Flexible Fuel Line ELECTRICAL SYSTEM ○10A UL Listed Battery Charger ○Battery Warmer ALTERNATOR SYSTEM ○Alternator Upsizing ○Anti-Condensation Heater ○Tropical Coating CIRCUIT BREAKER OPTIONS ○Main Line Circuit Breaker ○2nd Main Line Circuit Breaker ○3rd Main Line Circuit Breaker ○Shunt Trip and Auxiliary Contact ○Electronic Trip Breakers GENERATOR SET ○Demand Response Rating ○Extended Factory Testing (3-Phase Only) ○12 Position Load Center ○Vapor Recovery Heater ENCLOSURE ○Weather Protected Enclosure ○Level 1 Sound Attenuated ○Level 2 Sound Attenuated ○Level 2 Sound Attenuated with Motorized Dampers ○Steel Enclosure ○Aluminum Enclosure ○Up to 200 MPH Wind Load Rating (Contact Factory for Availability) ○AC/DC Enclosure Lighting Kit ○Enclosure Heaters (with Motorized Dampers Only) ○IBC Certification ○Door Open Alarm Switch CONTROL SYSTEM ○NFPA 110 Level 1 Compliant 21-Light Remote Annunciator ○Remote Relay Assembly (8 or 16) ○Remote E-Stop (Break Glass-Type, Surface Mount) ○Remote E-Stop (Red Mushroom-Type, Surface Mount) ○Remote E-Stop (Red Mushroom-Type, Flush Mount) ○10A Engine Run Relay ○Ground Fault Annunciator ○100 dB Alarm Horn ○120V GFCI and 240V Outlets ○Damper Alarm Contacts (with Motorized Dampers Only) WARRANTY (Standby Gensets Only) ○2 Year Extended Limited Warranty ○5 Year Limited Warranty ○5 Year Extended Limited Warranty ○7 Year Extended Limited Warranty ○10 Year Extended Limited Warranty ENGINEERED OPTIONS ENGINE SYSTEM ○Coolant Heater Ball Valves ○Fluid Containment Pans CONTROL SYSTEM ○Battery Disconnect Switch ALTERNATOR SYSTEM ○3rd Main Line Circuit Breaker ○4th Main Line Circuit Breaker GENERATOR SET ○Special Testing ○Battery Box SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 4 of 6 DEMAND RESPONSE READY General Make Generac Cylinder #6 Type In-line Displacement - in3 (L)864.71 (14.2) Bore - in (mm)5.31 (135) Stroke - in (mm)6.50 (165) Compression Ratio 9.5:1 Intake Air Method Turbocharged/Aftercooled Number of Main Bearings 7 Connecting Rods Steel Alloy Cylinder Head Cast Iron Cylinder Liners Ductile Iron Ignition Electronic Piston Type Aluminum Crankshaft Type Ductile Iron Lifter Type Solid Intake Valve Material Special Heat-Resistant Steel Exhaust Valve Material High Temp Steel Alloy Hardened Valve Seats High Temp Steel Alloy Engine Governing Governor Electronic Frequency Regulation (Steady State) ±0.25% Lubrication System Oil Pump Type Gear Oil Filter Type Full-Flow Cartridge Crankcase Capacity - qt (L)36.2 (34.3) Cooling System Cooling System Type Pressurized Closed Recovery Fan Type Pusher Fan Speed - RPM 1,894 Fan Diameter - in (mm)30 (762) Fuel System Fuel Type Natural Gas Carburetor Down Draft Secondary Fuel Regulator Standard Fuel Shut Off Solenoid Standard Operating Fuel Pressure - in H2O (kPa) 7 - 11 (1.7 - 2.7) Engine Electrical System System Voltage 24 VDC Battery Charger Alternator 57.5 A Battery Size See Battery Index 0161970SBY Battery Voltage 24 VDC Ground Polarity Negative APPLICATION AND ENGINEERING DATA ENGINE SPECIFICATIONS ALTERNATOR SPECIFICATIONS Standard Model K0200124Y21 Poles 4 Field Type Revolving Insulation Class - Rotor H Insulation Class - Stator H Total Harmonic Distortion <5% (3-Phase) Telephone Interference Factor (TIF) <50 Standard Excitation Permanent Magnet Bearings Sealed Ball Coupling Direct via Flexible Disc Prototype Short Circuit Test Yes Voltage Regulator Type Digital Number of Sensed Phases All Regulation Accuracy (Steady State) ±0.25% SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 5 of 6 DEMAND RESPONSE READY ** Refer to “Emissions Data Sheet” for maximum bHP for EPA and SCAQMD permitting purposes. Deration – Operational characteristics consider maximum ambient conditions. Derate factors may apply under atypical site conditions. Please contact a Generac Power Systems Industrial Dealer for additional details. All performance ratings in accordance with ISO3046, BS5514, ISO8528, and DIN6271 standards. Standby - See Bulletin 0187500SSB Demand Response - See Bulletin 10000018250 Prime - See Bulletin 0187510SSB POWER RATINGS - NATURAL GAS Standby/Demand Response Prime Single-Phase 120/240 VAC @1.0pf 200 kW/200 kVA Amps: 833 180 kW/180 kVA Amps: 750 Three-Phase 120/208 VAC @0.8pf 200 kW/250 kVA Amps: 695 180 kW/225 kVA Amps: 625 Three-Phase 120/240 VAC @0.8pf 200 kW/250 kVA Amps: 602 180 kW/225 kVA Amps: 542 Three-Phase 277/480 VAC @0.8pf 200 kW/250 kVA Amps: 301 180 kW/225 kVA Amps: 271 Three-Phase 346/600 VAC @0.8pf 200 kW/250 kVA Amps: 241 180 kW/225 kVA Amps: 217 MOTOR STARTING CAPABILITIES (skVA) skVA vs. Voltage Dip 277/480 VAC 30% 208/240 VAC 30% K0200124Y21 478 K0200124Y21 361 K0250124Y21 630 K0250124Y21 506 K0300124Y21 790 K0300124Y21 609 FUEL CONSUMPTION RATES* Natural Gas – scfh (m3/hr) Percent Load Standby/Demand Response Prime 25%960 (27.2)900 (25.5) 50%1,440 (40.8)1,320 (37.4) 75%1,980 (56.1)1,800 (51.0) 100%2,460 (69.7)2,280 (64.6) * Fuel supply installation must accommodate fuel consumption rates at 100% load. COOLING Standby/Demand Response Prime Air Flow (Fan Air Flow Across Radiator)scfm (m3/min) 9,162 (259.4)9,162 (259.4) Coolant Flow gpm (Lpm)90 (340.7)90 (340.7) Coolant System Capacity gal (L)11 (39.7)11 (39.7) Maximum Operating Ambient Temperature °F (°C)122 (50)122 (50) Maximum Operating Ambient Temperature (Before Derate)See Bulletin No. 0199270SSD Maximum Radiator Backpressure in H2O (kPa)0.5 (0.12)0.5 (0.12) COMBUSTION AIR REQUIREMENTS Standby/Demand Response Prime Flow at Rated Power - scfm (m3/min) 390 (11.0)362 (10.3) ENGINE EXHAUST Standby/Demand Response Prime Standby/Demand Response Prime Rated Engine Speed RPM 1,800 1,800 Exhaust Flow (Rated Output) scfm (m 3/min) 1,327 (38) 1,213 (34) Horsepower at Rated kW** hp 304 274 Max. Backpressure (Post Silencer) inHg (kPa) 0.75 (2.54) 0.75 (2.54) Piston Speed ft/min (m/min) 1,950 (594) 1,950 (594) Exhaust Temp (Rated Output - Post Silencer) °F (°C) 1,378 (748) 1,350 (732) BMEP psi (kPa) 155 (1,065) 139 (959) OPERATING DATA SG200 | 14.2L | 200 kW INDUSTRIAL SPARK-IGNITED GENERATOR SET EPA Certified Stationary Emergency and Non-Emergency SP E C S H E E T 6 of 6 DEMAND RESPONSE READY YOUR FACTORY RECOGNIZED GENERAC INDUSTRIAL DEALER Specification characteristics may change without notice. Please contact a Generac Power Systems Industrial Dealer for detailed installation drawings. * All measurements are approximate and for estimation purposes only. Part No. 10000038976 Rev. B 02/28/2020 Generac Power Systems, Inc. | P.O. Box 8 | Waukesha, WI 53189 P: (262) 544-4811 ©2020 Generac Power Systems, Inc. All rights reserved. All specifications are subject to change without notice. DIMENSIONS AND WEIGHTS* OPEN SET (Includes Exhaust Flex) L x W x H - in (mm)128.0 (3,251) x 52.9 (1,344) x 62.3 (1,582) Weight - lbs (kg)5,281 - 6,031 (2,395 - 2,735) WEATHER PROTECTED ENCLOSURE L x W x H - in (mm)154.4 (3,922) x 54.0 (1,372) x 69.8 (1,773) Weight - lbs (kg)Steel: 6,261 - 7,596 (2,839 - 3,445) Aluminum: 5,795 - 6,786 (2,628 - 3,078) LEVEL 1 SOUND ATTENUATED ENCLOSURE L x W x H - in (mm)179.9 (4,569) x 54.0 (1,372) x 69.8 (1,773) Weight - lbs (kg)Steel: 6,566 - 8,059 (2,978 - 3,655) Aluminum: 5,926 - 7,000 (2,688 - 3,175) LEVEL 2 SOUND ATTENUATED ENCLOSURE L x W x H - in (mm)154.4 (3,922) x 54.0 (1,372) x 93.3 (2,370) Weight - lbs (kg)Steel: 6,801 - 8,632 (3,084 - 3,915) Aluminum: 6,027 - 7,247 (2,733 - 3,287) L L L L W W W W H H H H PTC/PTO Application www.scsengineers.com C-7 Appendix C Risk Assessment Information Thermal Oxidizer Main Ops Thermal Oxidizer Supplement Flare Flare_pt2 Feet ft/m Commercial 1722.44 1722.44 1804.46 1804.46 0.3048 Residential 1492.78 1492.78 1394.36 1394.36 Meters Commercial 525 525 550 550 Residential 455 455 425 425 MICR Total PASS? Commercial 1.74E-08 4.28E-10 1.63E-09 9.75E-09 2.92E-08 YES Residential 2.41E-07 8.33E-09 4.74E-08 1.69E-07 4.66E-07 YES Hazard Index Acute HI 3.85E-03 4.95E-05 2.19E-04 3.00E-03 7.12E-03 YES Chronic HI 1.13E-02 2.24E-03 6.58E-03 1.15E-02 3.16E-02 YES Chronic 8-hr HI 2.07E-03 4.94E-05 1.60E-04 1.48E-03 3.76E-03 YES Acute Alimentary system (liver) - AL 3.19E-08 0.00E+00 2.30E-08 0.00E+00 Bones and teeth - BN Cardiovascular system - CV 2.39E-09 2.81E-06 8.22E-06 0.00E+00 Developmental - DEV 9.29E-05 4.24E-06 3.01E-05 4.94E-05 Endocrine system - END Eye 3.23E-03 4.05E-06 1.37E-05 2.47E-03 Hematopoietic system - HEM 2.41E-05 2.18E-07 1.81E-05 0.00E+00 Immune system - IMM 2.41E-05 2.97E-05 1.04E-04 0.00E+00 Kidney - KID Nervous system - NS 6.89E-05 4.03E-06 1.20E-05 4.94E-05 Reproductive system - REP 9.29E-05 4.24E-06 3.01E-05 4.94E-05 Respiratory system - RESP 3.20E-04 2.39E-07 2.80E-06 3.73E-04 Skin 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Chronic Alimentary system (liver) - AL 8.47E-07 4.80E-07 1.58E-06 4.36E-07 Bones and teeth - BN 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Cardiovascular system - CV 8.33E-09 3.29E-04 9.61E-04 0.00E+00 Developmental - DEV 5.37E-04 3.80E-04 1.11E-03 3.87E-04 Endocrine system - END 3.46E-07 0.00E+00 0.00E+00 2.50E-07 Eye 2.87E-07 0.00E+00 0.00E+00 2.07E-07 Hematopoietic system - HEM 2.17E-05 4.22E-05 1.39E-04 0.00E+00 Immune system - IMM 0.00E+00 4.80E-07 1.40E-06 0.00E+00 Kidney - KID 5.27E-04 3.98E-05 1.17E-04 3.80E-04 Nervous system - NS 5.28E-04 3.38E-04 9.89E-04 3.81E-04 Reproductive system - REP 5.37E-04 3.80E-04 1.11E-03 3.87E-04 Respiratory system - RESP 9.13E-03 4.04E-04 1.18E-03 9.95E-03 Skin 0.00E+00 3.29E-04 9.61E-04 0.00E+00 Chronic 8-hr Alimentary system (liver) - AL 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Bones and teeth - BN 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Cardiovascular system - CV 0.00E+00 3.73E-06 1.09E-05 0.00E+00 Developmental - DEV 6.82E-05 4.95E-06 1.45E-05 4.92E-05 Endocrine system - END 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Eye 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Hematopoietic system - HEM 2.17E-05 1.96E-07 1.62E-05 0.00E+00 Immune system - IMM 0.00E+00 9.80E-06 2.87E-05 0.00E+00 Kidney - KID 6.82E-05 1.21E-06 3.55E-06 4.92E-05 Nervous system - NS 6.82E-05 4.95E-06 1.45E-05 4.92E-05 Reproductive system - REP 6.82E-05 4.95E-06 1.45E-05 4.92E-05 Respiratory system - RESP 1.77E-03 1.59E-05 4.64E-05 1.28E-03 Skin 0.00E+00 3.73E-06 1.09E-05 0.00E+00 TABLE 13 RISK RESULTS COYOTE CANYON RNG FACILITY NEWPORT BEACH, CALIFORNIA PTC/PTO Application www.scsengineers.com C-8 Appendix D Permit Application Forms PTC/PTO Application www.scsengineers.com C-9 Thermal Oxidizer PTC/PTO Application www.scsengineers.com C-9 Enclosed RNG Flare PTC/PTO Application www.scsengineers.com C-10 H2S Scrubber System PTC/PTO Application www.scsengineers.com C-11 Condensate Tanks PTC/PTO Application www.scsengineers.com C-6 Emergency Backup Generator DocuSign Envelope ID: 462D3558-711E-4F40-A4C4-CAA2FF157849 Mail To: Form 400-A Application Form for Permit or Plan Approval AQMD USE ONLY 1. Facility Name : 3. Owner’s Business Name 2. Valid AQMD Facility ID Section A - Operator Information Section B - Equipment Location Address Section C - Permit Mailing Address 4. Equipment Location Is: Fixed Location Various Location , CA 5. Permit and Correspondence Information: , 7a. New Equipment or Process Application: 7c. Equipment or Process with an Existing/Previous Application or Permit: ** * * * * 7b. Facility Permits: 8a. Estimated Start Date of Construction :8b. Estimated End Date of Construction :8c. Estimated Start Date of Operation : 9. Description of Equipment or Reason for Compliance Plan :10. For Identical equipment, how many additional applications are being submitted with this application? 11. Are you a Small Business as per AQMD’s Rule 102 definition? OR 12. Has a Notice of Violation (NOV) or a Notice to Comply (NC) been issued for this equipment? If Yes, provide NOV/NC#: Section D - Application Type 6. The Facility Is: Not In RECLAIM or Title V In RECLAIM In Title V In RECLAIM & Title V Programs 7. Reason for Submitting Application : 13. What type of business is being conducted at this equipment location?14. What is your business primary NAICS Code? 15. Are there other facilities in the SCAQMD jurisdiction operated by the same operator? 16. Are there any schools (K-12) within 1000 feet of the facility property line? Section E - Facility Business Information No Yes No Yes No Yes No Yes No Yes No Yes Section F - Authorization/Signature I hereby certify that all information contained herein and information submitted with this application are true and correct. 17. Signature of Responsible Official: 18. Title of Responsible Official: 19. I wish to review the permit prior to issuance. 20. Print Name: 21. Date:22. Do you claim confidentiality of data? 23. Check List: Authorized Signature/Date Form 400-CEQA Supplemental Form(s) (ie., Form 400-E-xx) Fees Enclosed Existing or Previous Permit/Application Biofuels Coyote Canyon Biogas, LLC 20661 Newport Coast Drive Newport Beach 92657 Nevin Edwards Env.Data and New Dev Mr (724) 766-8388 nedwards@archaea.energy 201 Helios Way, Floor 6 Houston TX 77079 Steven Boor Chief Operating Officer (970) 749-9827 sboor@archaea.energy Emergency Generator Renewable Natural Gas Plant 221117 Chief Operating Officer Steven Boor aocupign bnvelope faW QSOaPRRU-TNNb-QcQM-AQCQ-CAAOccNRTUQV 6/24/2024 DocuSign Envelope ID: 462D3558-711E-4F40-A4C4-CAA2FF157849 6/11/2024 DocuSign Envelope ID: 462D3558-711E-4F40-A4C4-CAA2FF157849 6/24/2024 FORM 400–E–13a Emergency Internal Combustion Engine www.aqmd.gov aocuSign bnvelope Ia: 46Oa3RR8-711b-4c4M-A4C4-CAAOcc1R7849 DocuSign Envelope ID: 462D3558-711E-4F40-A4C4-CAA2FF157849 RULE EVALUATION The internal combustion engine may be subject to the following rules: SCAQMD Rules and Regulations Rule 212 Standards for Approving Permits and Issuing Public Notice Rule 401 Visible Emissions Rule 402 Nuisance Rule 404 Particulate Matter – Concentration Rule 431.1 Sulfur Content of Gaseous Fuels Rule 431.2 Sulfur Content of Liquid Fuels Liquid fuels – sulfur content of 500 ppm by weight or less. Diesel fuel – sulfur content of 0.015% by weight or less. Reg XIII New Source Review Rule 1401 New Source Review of Toxic Air Contaminants Rule 1401.1 Requirements for New and Relocated Facilities Near Schools Rule 1470 Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines Rule 1472 Requirements for Facilities with Multiple Stationary Emergency Standby Diesel- Fueled Internal Combustion Engines Rule 1714 Prevention of Significant Deterioration for Greenhouse Gases Code of Federal Regulations 40 CFR 60 Subpart III Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR 60 Subpart JJJJ Standards of Performance for New Stationary Sources 40 CFR 63 Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) DocuSign Envelope ID: 4SODPRRU-TNNE-4F4M-A4C4-CAAOFFNRTU4V SAMPLE CONDITIONS FOR EMERGENCY INTERNAL COMBUSTION ENGINES (GENERATORS) 1. OPERATION OF THIS EQUIPMENT SHALL BE CONDUCTED IN COMPLIANCE WITH ALL DATA AND SPECIFICATIONS SUBMITTED WITH THE APPLICATION UNDER WHICH THIS PERMIT IS ISSUED. 2. THIS EQUIPMENT SHALL BE PROPERLY MAINTAINED AND KEPT IN GOOD OPERATING CONDITIONS AT ALL TIMES. 3. THE OPERATOR SHALL COMPLY WITH ALL APPLICABLE REQUIREMENTS OF SCAQMD RULE 431.2, SCAQMD RULE 1470, 40CFR PART 60 SUBPART IIII AND 40 CFR PART 63 SUBPART ZZZZ, OR THE OPERATOR SHALL NOT USE ANY DIESEL FUEL UNLESS THE FUEL IS LOW SULFUR DIESEL FOR WHICH THE SULFUR CONTENT SHALL NOT EXCEED 15 PPM BY WEIGHT AS SUPPLIED BY THE SUPPLIER. 4. THIS ENGINE SHALL NOT OPERATE MORE THAN 200 HOURS IN ANY ONE YEAR, WHICH INCLUDES NO MORE THAN 50 HOURS IN ANY ONE YEAR FOR MAINTENANCE AND TESTING. 5. THE OPERATION OF ENGINE BEYOND 50 HOURS PER YEAR ALLOTTED FOR ENGINE MAINTENANCE AND TESTING SHALL BE ALLOWED ONLY IN THE EVENT OF A LOSS OF GRID POWER OR UP TO 30 MINUTES PRIOR TO A ROTATING OUTAGE, PROVIDED THAT THE ELECTRICAL GRID OPERATOR OR ELECTRIC UTILITY HAS ORDERED ROTATING OUTAGES IN THE CONTROL AREA WHERE THE ENGINE IS LOCATED OR HAS INDICATED THAT IT EXPECTS TO ISSUE SUCH AN ORDER AT A CERTAIN TIME, AND THE ENGINE IS LOCATED IN A UTILITY SERVICE BLOCK THAT IS SUBJECT TO THE ROTATING OUTAGE. ENGINE OPERATION SHALL BE TERMINATED IMMEDIATELY AFTER THE UTILITY DISTRIBUTION COMPANY ADVISES THAT A ROTATING OUTAGE IS NO LONGER IMMINENT OR IN EFFECT. 6. AN OPERATIONAL NON-RESETTABLE TOTALIZING TIME METER SHALL BE INSTALLED AND MAINTAINED TO INDICATE THE ENGINE ELAPSED OPERATING TIME. 7. ON OR BEFORE JANUARY 15 TH OF EACH YEAR THE OPERATOR SHALL RECORD IN THE ENGINE OPERATING LOG: A. THE TOTAL HOURS OF ENGINE OPERATION FOR THE PREVIOUS CALENDAR YEAR, AND B. THE TOTAL HOURS OF ENGINE OPERATION FOR MAINTENANCE AND TESTING FOR THE PREVIOUS CALENDAR YEAR. ENGINE OPERATION LOG(S) SHALL BE RETAINED ON SITE FOR A MINIMUM OF FIVE CALENDAR YEARS AND SHALL BE MADE AVAILABLE TO THE EXECUTIVE OFFICER OR REPRESENTATIVE UPON REQUEST. 8. THE OPERATOR SHALL KEEP A LOG OF ENGINE OPERATIONS DOCUMENTING THE TOTAL TIME THE ENGINE IS OPERATED EACH MONTH AND THE SPECIFIC REASON FOR OPERATION AS: A. EMERGENCY USE A. MAINTENANCE AND TESTING C. OTHER (BE SPECIFIC) IN ADDITION, FOR EACH TIME THE ENGINE ISMANUALLY STARTED, THE LOG SHALL INCLUDE: THE DATE OF ENGINE OPERATION, THE START AND STOP TIME OF THE ENGINE, THE SPECIFIC REASON FOR OPERATION, AND THE TOTALIZING HOUR METER READING (IN HOURS AND TENTHS OF HOURS) AT THE BEGINNING AND THE END OF THE OPERATION. 9. THIS ENGINE SHALL NOT BE USED AS PART OF A DEMAND RESPONSE PROGRAM USING INTERRUPTIBLE SERVICE CONTRACT IN WHICH A FACILITY RECEIVES A PAYMENT OR REDUCED RATES IN RETURN FOR REDUCING ITS ELECTRIC LOAD ON THE GRID WHEN REQUESTED TO DO SO BY THE UTILITY OR THE GRID OPERATOR. DocuSign Envelope ID: 4SODPRRU-TNNE-4F4M-A4C4-CAAOFFNRTU4V 10. THIS ENGINE SHALL NOT BE OPERATED MORE THAN 200 HOURS IN ANY ONE YEAR, WHICH INCLUDES NO MORE THAN 50 HOURS IN ANY ONE YEAR FOR MAINTENANCE AND TESTING TO COMPLY WITH REQUIREMENTS OF THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA). ANYTHING IN EXCESS OF 50 HOURS SHALL BE ALLOWED ONLY IN THE EVENT OF AN EMERGENCY FIRE FIGHTING OPERATION. For Fire pumps: 11. THIS ENGINE SHALL NOT BE OPERATED MORE THAN 200 HOURS IN ANY ONE YEAR, WHICH INCLUDES NO MORE THAN 50 HOURS IN ANY ONE YEAR FOR MAINTENANCE AND TESTING TO COMPLY WITH REQUIREMENTS OF THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA). ANYTHING IN EXCESS OF 50 HOURS SHALL BE ALLOWED ONLY IN THE EVENT OF AN EMERGENCY FIRE FIGHTING OPERATION. For Various Locations Equipment: 12. UPON THE FIFTH DAY AFTER PLACEMENT OF THIS EQUIPMENT INTO OPERATION AT A NEW SITE, THE DISTRICT SHALL BE NOTIFIED VIA TELEPHONE AT 877-810-6995 OF THE EXACT NATURE OF THE PROJECT AS FOLLOWS: A. THE PERMIT NUMBER OF THE PORTABLE EQUIPMENT. B. THE NAME AND TELEPHONE NUMBER OF A CONTACT PERSON. C. THE LOCATION WHERE THE PORTABLE EQUIPMENT WILL BE OPERATED. D. THE ESTIMATED TIME THE PORTABLE EQUIPMENT WILL BE LOCATED AT THE SITE. E. DESCRIPTION OF THE PROJECT. F. IF LESS THAN 1/4 MILE, THE DISTANCE TO THE NEAREST SENSITIVE RECEPTOR. SENSITIVE RECEPTORS ARE DEFINED AS LONG-TERM HEALTH CARE FACILITIES, REHABILITATION CENTERS, CONVALESCENT CENTERS, RETIREMENT HOMES, RESIDENCES, SCHOOLS, PLAYGROUNDS, CHILD CARE CENTERS, AND ATHLETIC FACILITIES. 13. THIS ENGINE AND ITS REPLACEMENT UNIT INTENDED TO PERFORM THE SAME OR SIMILAR FUNCTION, SHALL NOT RESIDE AT ANY ONE LOCATION FOR MORE THAN 12 CONSECUTIVE MONTHS. THE PERIOD DURING WHICH THE ENGINE AND ITS REPLACEMENT IS MAINTAINED AT A STORAGE FACILITY SHALL BE EXCLUDED FROM RESIDENCY TIME DETERMINATION. 14. THIS ENGINE SHALL NOT BE REMOVED FROM ONE LOCATION FOR A PERIOD OF TIME, AND THEN IT OR ITS EQUIVALENT ENGINE RETURNED TO THE SAME LOCATION, IN ORDER TO CIRCUMVENT THE PORTABLE ENGINE RESIDENCE TIME REQUIREMENTS. 15. IN ADDITION TO MAINTENANCE AND TESTING OF THIS ENGINE, THIS ENGINE SHALL ONLY BE USED FOR EITHER PROVIDING ELECTRICAL POWER TO PORTABLE OPERATIONS OR EMERGENCY POWER TO STATIONARY SOURCES. PORTABLE OPERATIONS ARE THOSE WHERE IT CAN BE DEMONSTRATED THAT BECAUSE OF THE NATURE OF THE OPERATION, IT IS NECESSARY TO PERIODICALLY MOVE THE EQUIPMENT FROM ONE LOCATION TO ANOTHER. EMERGENCIES AT STATIONARY SOURCES ARE THOSE THAT RESULT IN AN INTERRUPTION OF SERVICE OF THE PRIMARY POWER SUPPLY OR DURING STAGE II OR III ELECTRICAL EMERGENCIES DECLARED BY THE CALIFORNIA INDEPENDENT SYSTEM OPERATOR. aocupign bnvelope faW QSOaPRRUJTNNbJQcQMJAQCQJCAAOccNRTUQV Mail To: Form 400 - XPP Express Permit Processing Request AQMD USE ONLY Section A - Operator Information 1. Facility Name 2. Valid AQMD Facility ID Section B - Equipment Location Address Section C - Permit Mailing Address 3.Fixed Location Various Location , CA 4. Permit and Correspondence Information: , I understand that the Expedited Permit Processing fees must be submitted at the time of application submittal, and that the application may be subject to additional fees per Rule 301. I understand that requests for Express Permit Processing neither guarantees action by any specific date nor does it guarantee permit approval; that Express Permit Processing is subject to availability of qualified staff; and that once Express Permit Processing has commenced, the expedited fees will not be refunded. I hereby certify that all information contained herein and information submitted with the application are true and correct. 5. Signature of Responsible Official:6. Title of Responsible Official: 7. Print Name of Responsible Official:8. Date: 9. Phone #: 10. Fax #: Section D - Authorization/Signature Biofuels Coyote Canyon Biogas, LLC 20661 Newport Coast Drive Newport Beach 92667 Nevin Edwards 20661 Newport Coast Drive Newport Beach CA 92667 Nevin Edwards Air Permitting Manager (724) 766-8388 nedwards@archaea.energy Chief Operating Officer Steven Boor (970) 749-9827 Emergency Back up Generator Docusign Envelope ID: E6CE7395-86BD-42F6-BC22-73A24EEF20FF 8/6/2024 Form 400-PS Plot Plan And Stack Information Form Biofuels Coyote Canyon Biogas, LLC 20661 Newport Coast Drive, Newport Beach, California, 92657 5.55 15 1.50 1,327 1,378 1,835 1,385 aocuSign Envelope fa: 4S2aP558-711E-4c40-A4C4-CAA2cc157849 Form 400-PS Plot Plan And Stack Information Form Project Manager (619) 455-9518 mbowen@scsengineers.com Nevin Edwards (726) 766-8388 nedwards@archaea.energy 6/11/2024 aocuSign Envelope fa: 4S2aP558-711E-4c40-A4C4-CAA2cc157849 Receptor Map Emergency Generator Receptor Distances Biofuels Coyote Canyon Biogas Legend Emergency Generator to Non-Residence - 1,835 ft Emergency Generator to Residence - 1,385 ft Emergency Generator to School - 1,703 ft Facility Line Planned Emergency Generator Location 1000 ft N➤➤N Data CSUMB SFML, CA OPC Data CSUMB SFML, CA OPC Data CSUMB SFML, CA OPC DocuSign Envelope ID: 462D3558-711E-4F40-A4C4-CAA2FF157849 LANDFILL GAS TO ENERGY PLANT PROJECT RESPONSE TO COMMENTS CITY OF NEWPORT BEACH Appendix PlaceWorks This page intentionally left blank.