AQ_F_0800114_20221006_PRMT_PmtApp

ENGINEERSSCS Environmental Consulting & Contracting
September 30, 2022
File No. 0222204.00
Betsy Huddleston
ECEIVE
Regional Supervisor
North Carolina DEQ - Division of Air Quality OCT 6 2022
943 Washington Square Mall
Washington, North Carolina 27889 nn ry
Subject: Air Construction Permit Application L�AQ A,90 _
Lightning Renewables - East Carolina RNG
Bertie County,Aulander, North Carolina
Enclosed is an application, including necessary forms and explanatory information,for an air quality
permit for the Lightning Renewables - East Carolina RNG plant. As noted in the enclosed
application, the project will be classified as a small source.
If you have any questions related to this submittal, please contact either of the undersigned at either
828-285-8951 or 804-840-5325.
Sincerely,
David Greene, P.E. Lucas Nachman
Project Manager Project Professional
SCS Engineers SCS Engineers
dsg/LSN
cc: Robert Bright - NCDEQ-DAQ
Nevin Edwards - Archaea
Emily Zambuto - Archaea
Ryan Christman - Archaea
Josh Roth - SCS Engineers
Encl. Small Source Air Permit Application
79 Woodfin Place,Suite 101, Asheville, NC 28801 1 828-285-8951 CJ

Small Source Air Permit Application
Lightning Renewables - East Carolina
RNG
Site Address: E C E 6 V E
D
1922B Republican Road
p OCT
6 2022
Aulander, NC 27805
Mailing Address:
Lightning Renewables, LLC
4444 Westheimer Road, Suite G450
Houston, TX 77027
02222204.00 1 September 30, 2022
15521 Midlothian Turnpike
Suite 305
Midlothian, VA 23113
804-378-7440

Table of Contents
Section Page
1 Introduction and Background .........................................................................................................2
2 Process Description and Emission Units........................................................................................2
LFGTreatment....................................................................................................................................2
GasRefining Process.........................................................................................................................2
Air Emission Units/Control Devices ..................................................................................................3
Thermal Recuperative Oxidizer................................................................................................3
CandlestickFlare......................................................................................................................3
Emergency Generator ..............................................................................................................4
Miscellaneous Insignificant Sources ......................................................................................4
3 Project Aggregation..........................................................................................................................4
4 Summary of Plant Potential Emissions...........................................................................................5
List of Tables
Table 1- Insignificant Sources....................................................................................................................4
Table 2 -Summary of Plant Potential Emissions.......................................................................................5
Appendices
Appendix A NC DAQ Permitting Forms
Appendix B Emission Calculations
Appendix C Process Flow Diagram
Appendix D Site Location
Appendix E Technical Specifications & Equipment Information
Appendix F Separate Source Determination
Appendix G Bertie County Zoning Consistency Determination
Air Permit I Application—Lightning Renewables-East Carolina RNG www.scsengineers.com

I INTRODUCTION AND BACKGROUND
On behalf of Lightning Renewables - East Carolina RNG, a subsidiary of Archaea Energy, SCS
Engineers, PC (SCS) prepared this application package in accordance with the applicable
requirements of the North Carolina Department of Environmental Quality - Department of Air
Quality (NCDEQ-DAQ). This application addresses the construction of a renewable natural gas(RNG)
processing facility(the plant)to be located in Aulander, Bertie County, North Carolina.
This application includes the following:
Appendix A NC DAQ Permitting Forms
Appendix B Emission Calculations
Appendix C Process Flow Diagram
Appendix D Site Location
Appendix E Technical Specifications & Equipment Information
Appendix F Separate Source Determination
Appendix G Bertie County Zoning Consistency Determination
The plant will receive landfill gas (LFG) from the East Carolina Regional Solid Waste Landfill
(landfill) and, through an extensive treatment and refining process, will produce renewable natural
gas (RNG) for sale and injection into a nearby pipeline. The plant and landfill are separately owned,
managed and permitted, and the landfill operates and maintains separate emission control
equipment in accordance with its Title V operating permit to control LFG, independent of the RNG
project. A site plan depicting the plant location at the existing landfill is provided in Appendix D.
2 PROCESS DESCRIPTION AND EMISSION UNITS
The plant will be designed to process up to 6,400 standard cubic feet per minute (scfm) of LFG, at an
assumed methane content of 52 percent. A process flow diagram showing the treatment and refining
processes as well as associated emission control equipment is included in Appendix C.
LFG TREATMENT
LFG received at the plant will be initially treated in accordance with applicable Federal requirements,
as follows:
• Filtration. LFG will pass through a series of filters designed to remove particulates and free
moisture in the raw LFG.
• Dewatering. LFG will pass through a series of moisture knockout vessels as well as glycol
chiller for dewatering.
• Compression. Gas blowers/compressors will pressurize the gas for the subsequent RNG
refining process.
GAS REFINING PROCESS
Following treatment, gas will undergo an extensive refining process designed to refine the gas to
pipeline-quality such that it can be transferred to a natural gas pipeline for subsequent sale and
distribution. The refining process involves the following key steps:
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsengineers.com
2

• VOC and H2S Removal. This step involves media vessels containing activated carbon to
remove impurities from the gas prior to being sent to the membrane system.
• Carbon Dioxide (CO2) Removal. This step involves in-line gas processing to remove impurities
from the gas followed by membrane system removal of CO2 from the gas stream.
• Nitrogen/Oxygen (N2/02) Removal. This step involves pressure swing adsorption (PSA)
separation of N2 and 02 from the gas stream.
• Supplemental gas compression and gas dryer for final delivery.
The final product is monitored for gas quality and transferred to a natural gas pipeline for
subsequent sale and distribution.
AIR EMISSION UNITS/CONTROL DEVICES
As a byproduct of the gas refining processes, various waste gas streams are produced. The plant will
incorporate a thermal recuperative oxidizer (TRO) unit and a backup candlestick flare as emission
control devices to handle these waste gases. The air emissions associated with these control devices
will include criteria air pollutants such as carbon monoxide (CO), oxides of nitrogen (NOx), oxides of
sulfur(SOx), and particulate matter(PM)along with volatile organic compounds(VOCs)and hazardous
air pollutants (HAPs) and toxic air pollutants (TAPs).
Emission calculations are provided in Appendix B. Additional information regarding the emission unit
s
is also provided in Appendix E.
Thermal Recuperative Oxidizer
Under normal operation, the waste gases will be directed to a thermal recuperative oxidizer (TRO) for
combustion. The TRO will utilize a supplemental natural gas (NG) fuel stream, as necessary,
to maintain combustion temperatures for control of the waste gases.
Candlestick Flare
In addition to the TRO, the plant will include a backup candlestick flare as a supplemental emission
control device. To ensure safe operation,the candlestick flare will combust treated, off-spec,or waste
gas for limited periods typically during outages of the gas refining system or the TRO. During extended
outage periods,the plant will shut down,and gas will not be accepted by the processing plant; instead,
the collected LFG will be controlled by the landfill, as currently operated with the two utility flares
owned and operated by the Landfill.
The candlestick flare will be equipped with a continuous natural gas pilot to allow for the immediate
flaring of gas during system outages and provide process plant safety requirements. The flare is
expected to operate only under one of the following operational scenarios:
• During an outage of the TRO or the refining process, gas will be directed to the candlestick
flare for limited periods. See Flare Mode 1 on the process flow diagram.
• To combust off-spec process gas that cannot be transferred to the natural gas pipeline. See
Flare modes 2, 3, and 4 on the process flow diagram. Note that in this scenario the flare is
operated simultaneously with the TOX.
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsenaineers.com
3

Emergency Generator
The plant will also include a 200-kW diesel generator to be used only in emergency situations assumed
to total less than 500 hours per year. This generator is an insignificant source and is
expempt for permitting by 15A NCAC 02Q.0903. Emissions for the generator are included herein for
completeness.
Miscellaneous Insignificant Sources
The plant will also incorporate insignificant sources associated with its operations. A summary of these
is provided in Table 1.
Capacity Description
500 gal. Emergency Generator, Diesel Storage Tank
Appx 15,000 gal. Condensate Storage Tank (2)
The VOC emission from these sources is expected to be nominal, less than 50 pounds per year. These
sources are thus insignificant and are included herein for completeness.
3 PROJECT AGGREGATION
As detailed in Archaea Energy's Separate Source Determination request of August 23, 2022,The RNG
plant and the East Carolina Regional Solid Waste Landfill, which sells the LFG, are not considered
aggregated for permitting purposes. To paraphrase from the letter, neither the plant nor the landfill
would "have the power" over each separate facility "to dictate decisions" over safe operation or
environmental compliance.
Note that under the Clean Air Act, for two (or more) facilities to be considered one facility, and the
emissions of these facilities to be aggregated,the facilities must be each of the following:
• Belong to the same industrial grouping: share the same two-digit Standard Industrial
Classification (SIC) Code.
• Are located on one or more adjacent or contiguous properties.
• Under the control of the same person (aka, under common control).
This is commonly referred to as the"three-pronged test";all three stipulations must be met for two(or
more) facilities to be considered to be one facility. In this instance, both the Landfill and the RNG
Plant share the same two-digit SIC Code and are located on adjacent or continuous properties.
However, the Landfill and the RNG Plant are not under the control of the same entity (aka, under
common control). The Separate Source Determination request is provided in Appendix F.
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsenaineers.com
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4 SUMMARY OF PLANT POTENTIAL EMISSIONS
A summary of RNG plant-wide potential emissions is provided in Table 2.
Table 2-Summary of Plant Potential Emissions
Potential Emissions (tons per year)
Scenario 1 Scenario 2
Compound Candlestick Candlestick Facility
TOX Flare- Emergency Scenario Emergency PTE
Flare- Scenario
Mode 2 Generator 1 Total Mode 1 Generator 2 Total
NOx 10.4 34.5 0.5 45.4 35.4 0.5 35.9 45.4
CO 20.8 43.1 0.1 64.0 44.3 0.1 44.4 64.0
PM 7.9 14.5 0.01 22.4 14.8 0.01 14.81 22.4
PM10 7.9 14.5 0.01 22.4 14.8 0.01 14.81 22.4
Sox 6.9 -- 0.2 7.1 6.9 0.2 7.1 7.1
VOC 13.9 4.4 0.2 18.5 4.4 0.2 4.6 18.5
HAPs 0.8 -- 0.2 1.0 0.8 0.2 1.0 1.0
Notes: 1)Sulfur Dioxide and HAP emissions are calculated based on maximum flow rate and the
amount of compound concentrated in the gas stream. Since the maximum flow rate of 6,400 scfm is diverted
to either the TRO or the Flare (or both),the maximum emissions for the Facility is equivalent to the maximum
emissions of the TRO (conservation of mass of H2S).
The plant total emissions presented above assume fulltime (8,760 hours per year) operation of the
TRO, along with fulltime operation of the flare in operating mode 2, and 500 hours of generator
operation. Candlestick Flare Mode 1 assumes fulltime operation of the flare; however, under this
assumption, there would be zero emissions from the TRO, since Flare Mode 1 is only used when the
TRO is not operating.Therefore, even though emissions from the candlestick flare are greater in Flare
Mode 1,the total emissions for the plant are greater when the flare is operating in Flare Mode 2 (since
the TRO is also operational). The emissions from candlestick mode 1 are not added to the plant total
since this would be an impossible scenario, and emissions would be "double counted." Therefore,
since total plant emissions are greatest in the scenario where the TRO and the Flare is operated in
Mode 2,these emissions are used as the Plant Potential Emissions.
As demonstrated herein, the RNG plant qualifies for a small source, Non-Title V, Non-Synthetic Minor
Permit.
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsengineers.com
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Appendix A
NC DAQ Permitting Forms
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsengineers.com

FORM A
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEQIDivision of Air Quality-Application for Air Permit to Construct/Operate A
NOTE-APPLICATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING:
Local Zoning Consistency Determination
(new or modification only)
Appropriate Number of Copies of Application Application Fee(please check one option below)
0 Responsible Official/Authorized Contact Signature 0 P.E.Seal(if required) ❑ Not Required 0 ePayment ❑ Check Enclosed
GENERAL INFORMATION
LegalCorporateGwnerName: Lightning Renewables, LLC
Site Name: Lightning Renewables-East Carolina RNG
Site Address(911 Address)Line t 1922B Republican Road
Site Address Line 2
city Aulander State. North Carolina
Zip Code: 27805 County Bertie
CONTACT INFORMATION
Responsible OfficiaL(Authorized Contact: Invoice Contact.
Name/Title. Derek Kramer/Chief Operating Officer Name/Title. Nevin Edwards/Air Permitting Manager
Mailing Address Line 1 4444 Westheimer Road Mailing Address Line 1 4444 Westheimer Road
Mailing Address Line 2 Suite G450 Mailing Address Line 2 Suite G450
city, Houston State Texas Zip Code 77027 city Houston State Texas Zip code: 77027
Prmary Phone No 404-862-3782 Fax No Primary Phone No 412-860-4550 Fax No.
Secondary Phone No. Secondary Phone No.:
Email Address dkrarnericbarchaea.energy Email Address nedwards0archaea.energy
Facilityrinspecrion Contact Permitrrechnical Contact
Namerritle Nevin Edwards/Air Permitting Manager Nan itie Nevin Edwards/Air Permitting Manager
Mailing Address Line 1 4444 Westheimer Road Mailing Address Line t 4444 Westheimer Road
Mailing Address Line 2 Suite G450 Mailing Address Line 2 Suite G450
city Houston State Texas zip code 77027 city: Houston State Texas Zip Code 77027
Primary Phone No 412-860-4550 Fax No. Primary Phone No 412-860-4550 Fax No.
Secondary Phone No Secondary Phone No.:
Email Address. nedwards(Q7archaea.enerU Email Address. nedvrardsg�archaea.energy
APPLICATION IS BEING MADE FOR
0 New Non-permitted Facility/Greenfield ❑ Modification of Facility(permitted) ❑ Renewal Title V ❑ Renewal Non-Title V
❑ Name Change 0 Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification
FACILITY CLASSIFICATION AFTER APPLICATION(Check Only One)
General Ed Small 13 Prohibitory Small Synthetic Minor Title V
FACILITY(Plant Site)INFORMATION
Describe nature of(plant site)operation(s) Plant to process landfill gas into pipeline-quality natural gas
Facility ID No N/A-new facility
Prmary SIC/NAICS Code 4925 1 Current/Previous Air Permit No N/A Expiration Date. N/A
Facility Coordinates Latitude 36°06'45" Longitude 770 03'55"
Does this application contain —if yes,please contact the DAQ Regional Office prior to submitting this
confidential data.
❑ YES 0 NO application.— (See Instructions)
PERSON OR FIRM THAT PREPARED APPLICATION
Person Name David Greene Firm Name SCS Engineers,PC
Mailing Address Line 1 79 Woodfin Place Mailing Address Line 2 Suite 101
City Asheville State North Carolina Zip Code 28801 County Buncombe
Phone No: 828-285-8951 Fax No Email Address [e-mail]
SIGNATURE OF RESPONSIBLE OFFICIAL/AUTHORIZED CONTACT
Name(typed) Derek Kra_7mrr
y/e^` Tale Chief Operating Officer ��r�
X Signature(&ue Ink). Date: `1 f 1.c1 V D E E a V ppJJ�
E
V Attach Additional Sheets As Necessary Page 1
OCT 6 2022
DAQ WARO
'� I

FORM A (continued, page 2 of 2)
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
SECTION AA1 -APPLICATION FOR NON-TITLE V PERMIT RENEWAL
N/A (Company Name)hereby formally requests renewal of Air Permit No. N/A
There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
Is your facility subject to 40 CFR Part 68"Prevnetion of Accidental Releases"-Section 112(r)of the Clean Air Act? ❑ YES Q NO
If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? Q YES ❑ NO Date Submitted: N/A
Did you attach a current emissions inventory? ❑ YES Q NO
If no,did you submit the inventory via AERO or by mail? ❑ Via AERO ❑ Mailed Date Mailed: N/A
SECTION AA2-APPLICATION FOR TITLE V PERMIT RENEWAL
In accordance with the provisions of Title 15A 20.0513,the responsible official of N/A (Company Name)
hereby formally requests renewal of Air Permit No. N/A (Air Permit No.)and further certifies that.
(1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 2Q.0500
(2) The current air quality permit cits all applicable requirements and provides the method or methods for determing compliance with the applicable
requirements,
(3) The facility is currently in compliance,and shall continue to comply,with all applicable requiremetns. (Note: As provided under 15A NCAC 2Q.0512
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit),
(4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis,
(5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64.
The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief
formed after reasonable inquiry,are true,accurate,and complete.
SECTION AA3-APPLICATION FOR NAME CHANGE
New Facility Name: N/A
Former Facility Name: N/A
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been
modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if ther has been an ownership change
associated with this name change.
SECTION AA4-APPLICATION FOR AN OWNERSHIP CHANGE
By this application we hereby request transfer of Air Quality Permit No. N/A from the former owner to the new owner as described below.
The transfer of permit responsibility,coverage and liability shall be effective N/A (immediately or insert date.) The legal ownership of the
facility described on page 1 of this form has been or will be transferred on N/A (date). There have been no modifications to the originally
permitted facility that would require an air quality permit since the last permit was issued.
Signature of New(Buyer)Responsible Official/Authorized Contact(as typed on page 1).
X Signature(Blue Ink): N/A
Date:
New Facility Name:
Former Facility Name:
Signature of Former(Seller)Responsible Official/Authorized Contact:
Name(typed or print):
Title.
X Signature(Blue Ink): N/A
Date
Former Legal Corporate/Owner Name.
In lieu of the seller's signature on this form,a letter may be submitted with the seller's signature indicating the ownership change
SECTION AA5-APPLICATION FOR ADMINISTRATIVE AMENDMENT
Describe the requested administrative amendment here(attach additional documents as necessary). N/A
Attach Additional Sheets As Necessary Page 2 of 2

FORMS; A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION - A2
112r APPLICABILITY INFORMATION - A3
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A2
EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted
EMISSION SOURCE EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE
ID NO DESCRIPTION ID NO DESCRIPTION
Equipment To Be ADDED By This Application (New, Previously Unperritted,or Replacement)
RNG System-1 RNG Gas Conditioning System TRO-1 Thermal Recuperative Obdizer(6,400 sfcm)
RNG System-1 RNG Gas Conditioning System FLARE-1 Candlestick Flare(7,040 Design Capacity limited to 6,400
scfm by system caapcity)
Existing Permitted Equipment To Be MODIFIED By This Application
N/A N/A N/A N/A
Equipment To Be DELETED By This Application
N/A N/A N/A N/A
112(r)APPLICABILITY INFORMATION A3
Is your facility subject to 40 CFR Part 68"Prevention of Accidental Releases"-Section 112(r)of the Federal Clean Air Act? ❑ Yes 61 No
If No,please specify in detail how your facility avoided applicability: Facility does not store sufficient quantities
If your facility is Subject to 112(r),please complete the following:
A Have you already submitted a Risk Management Plan(RMP)to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150?
❑ Yes ❑ No Specify required RMP submittal date: N/A If submitted,RMP submittal date: N/A
B Are you using administrative controls to subject your facility to a lesser 112(r)program standard?
❑ Yes ❑ No If yes,please specify: N/A
C. List the processes subject to 112(r)at your facility:
PROCESS LEVEL MAXIMUM INTENDED
PROCESS DESCRIPTION (1,2,or 3) HAZARDOUS CHEMICAL INVENTORY(LBS)
N/A N/A N/A N/A
Attach Additional Sheets As Necessary

FORM B
SPECIFIC EMISSION SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate B
EMISSION SOURCE DESCRIPTION: Renewable Natural Gas(RNG)System EMISSION SOURCE ID NO: RNG System-1
CONTROL DEVICE ID NO(S): TRO-1, FLARE-1
OPERATING SCENARIO 1 OF 2 EMISSION POINT(STACK) ID NO(S): TRO-S1, FLARE-S1
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS(ATTACH FLOW DIAGRAM):
Operation of TRO and Flare in Mode#2(emissions inlcude emergency generator at 500hr)
See Appendix C&Narrative(Section 4)
TYPE OF EMISSION SOURCE(CHECK AND COMPLETE APPROPRIATE FORM 131-139 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil,gas, other burner(Form 131) _ Woodworking (Form 134) Manuf. of chemicals/coatings/inks(Form 137)
❑ Int.combustion engine/generator(Form 132) _ Coating/finishing/printing(Form 135) Incineration (Form B8)
❑ Liquid storage tanks(Form B3) - Storage silos/bins(Form 136) Other(Form 139)
START CONSTRUCTION DATE: TBD DATE MANUFACTURED: TBD
MANUFACTURER/MODEL NO.: Various Components 1EXPECTED OP. SCHEDULE: 24 HR/DAY 7 DAY/WK 52 WK/YR
IS THIS SOURCE SUBJECT TO', NSPS(SUBPARTS?): N/A - NESHAP(SUBPARTS?): N/A
PERCENTAGE ANNUAL THROUGHPUT(%) DEC-FEB 25% MAR-MAY 25% JUN-AUG 25% SEP-NOV 25%
CRITERIA AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONS
EMISSION (AFTER CONTROLS/LIMITS) (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
AIR POLLUTANT EMITTED FACTOR Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yr
PARTICULATE MATTER(PM) AP-42 5.1 22.4 5.1 22.4 5.1 22.4
PARTICULATE MATTER<10 MICRONS(PM10) AP-42 5.1 22.4 5.1 22.4 5.1 22.4
PARTICULATE MATTER<2.5 MICRONS(PM2 5) AP-42 5.1 22.4 5.1 22.4 5.1 22.4
SULFUR DIOXIDE(S02) Manf. 1.6 7.1 1.6 7.1 1.6 7.1
NITROGEN OXIDES(NOx) Manf. 10A 45.4 10.4 45.4 10.4 45.4
CARBON MONOXIDE(CO) Manf. 14.6 64 14.6 64 14.6 64
VOLATILE ORGANIC COMPOUNDS(VOC) Manf. 4.2 18.5 4.2 18.5 4.2 18.5
LEAD - - - - - -
OTHER _ I _
HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONS
EMISSION (AFTER CONTROLS/LIMITS) (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
HAZARDOUS AIR POLLUTANT CAS NO. FACTOR Ib/hr tons/yr Ib/hr tons/yr Whir tons/yr
SEE APPENDIX B
TOXIC AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS
EMISSION
TOXIC AIR POLLUTANT CAS NO. FACTOR Ib/hr lb/day Ib/yr
SEE APPENDIX B
Attachments:(1)emissions calculations and supporting documentation,(2)indicate all requested state and federal enforceable permit limits(e.g.hours of operation,emission rates)and
describe how these are monitored and with what frequency,and(3)describe any monitoring devices,gauges,or test ports for this source.
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

FORM B
SPECIFIC EMISSION SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate B
EMISSION SOURCE DESCRIPTION Renewable Natural Gas(RNG)System EMISSION SOURCE ID NO: RNG System-1
CONTROL DEVICE ID NO(S): TRO-1, FLARE-1
OPERATING SCENARIO 2 OF 2 EMISSION POINT(STACK) ID NO(S): TRO-S1, FLARE-S1
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS(ATTACH FLOW DIAGRAM):
Operation of Flare in Mode#1
See Appendix C&Narrative(Section 4)
TYPE OF EMISSION SOURCE(CHECK AND COMPLETE APPROPRIATE FORM B1-B9 ON THE FOLLOWING PAGES):
Coal,wood,oil, gas, other burner(Form 131) ❑ Woodworking(Form B4) Manuf. of chemicals/coatings/inks(Form 67)
C Int.combustion engine/generator(Form B2) ❑ Coating/finishing/printing (Form 135) Incineration(Form 138)
Liquid storage tanks(Form 133) ❑ Storage silos/bins(Form 136) Other(Form 89)
START CONSTRUCTION DATE: TBD DATE MANUFACTURED: TBD
MANUFACTURER/MODEL NO.: Various Components EXPECTED OP. SCHEDULE: 24 HR/DAY 7 DAYMK 52 WK/YR
IS THIS SOURCE SUBJECT TO-, NSPS(SUBPARTS?): N/A NESHAP(SUBPARTS?): N/A
PERCENTAGE ANNUAL THROUGHPUT(%): DEC-FEB 25% MAR-MAY 25% JUN-AUG 25% SEP-NOV 25%
CRITERIA AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONS
EMISSION (AFTER CONTROLS/LIMITS) (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
AIR POLLUTANT EMITTED FACTOR Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yr
PARTICULATE MATTER(PM) AP-42 3.4 14.8 3.4 14.8 3.4 14.8
PARTICULATE MATTER<10 MICRONS(PM10) AP-42 3.4 14.8 3.4 14.8 3.4 14.8
PARTICULATE MATTER<2 5 MICRONS(PM25) AP-42 3.4 14.8 3.4 14.8 3.4 14.8
SULFUR DIOXIDE (S02) Manf. 1.6 6.9 1.6 6.9 1.6 6.9
NITROGEN OXIDES(NOx) Manf. 8.1 35.4 8.1 35.4 8.1 35.4
CARBON MONOXIDE(CO) Manf. 10.1 44.3 10.1 44.3 10.1 44.3
VOLATILE ORGANIC COMPOUNDS(VOC) Manf. 1.0 4.4 1.0 4A 1.0 4.4
LEAD - - - - -
OTHER - - -
HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONS
EMISSION (AFTER CONTROLS/LIMITS) (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
HAZARDOUS AIR POLLUTANT CAS NO. FACTOR Ib/hr tons/yr Ib/hr tans/yr Ib/hr tons/yr
SEE APPENDIX B
TOXIC AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE
SOURCE OF EXPECTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS
EMISSION
TOXIC AIR POLLUTANT CAS NO. FACTOR Ib/hr lb/day Ib/yr
SEE APPENDIX B
Attachments(1)emissions calculations and supporting documentation,(2)indicate all requested state and federal enforceable permit limits(e.g.hours of operation,emission rates)and
describe how these are monitored and with what frequency,and(3)describe any monitoring devices,gauges,or test ports for this source
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

1
FORM B9
EMISSION SOURCE (OTHER)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate 69
EMISSION SOURCE DESCRIPTION: Renewable Natural Gas(RNG)System EMISSION SOURCE ID NO: RNG System-1
CONTROL DEVICE ID NO(S): TRO-1, FLARE-1
OPERATING SCENARIO 1 OF 1 EMISSION POINT(STACK) ID NO(S): TRO-S1, FLARE-S1
DESCRIBE IN DETAIL THE PROCESS(ATTACH FLOW DIAGRAM).
See Appendix C
MATERIALS ENTERING PROCESS-CONTINUOUS PROCESS MAX. DESIGN REQUESTED CAPACITY
TYPE UNITS CAPACITY(UNIT/HR) LIMITATION(UNIT/HR)
Treated Landfill Gas scfm 6,400 scfm (384,000 scf/hr) none
MATERIALS ENTERING PROCESS - BATCH OPERATION MAX. DESIGN REQUESTED CAPACITY
TYPE UNITS CAPACITY(UNIT/BATCH) LIMITATION (UNIT/BATCH)
N/A N/A N/A N/A
MAXIMUM DESIGN(BATCHES/HOUR)
REQUESTED LIMITATION(BATCHES/HOUR) (BATCHES/YR).
FUEL USED: Natural Gas TOTAL MAXIMUM FIRING RATE(MILLION BTU/HR): 23.7 MMBTU/HR
MAX.CAPACITY HOURLY FUEL USE:15.0 MMBtu/Hr(Natural Gas onl REQUESTED CAPACITY ANNUAL FUEL USE: N/A
COMMENTS:
Attach Additional Sheets as Necessary

FORM C3
CONTROL DEVICE (THERMAL OR CATALYTIC)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate C3
AS REQUIRED BY 15A NCAC 2Q.0112,THIS FORM MUST BE SEALED BYA PROFESSIONAL ENGINEER(P.E.)LICENSED IN NORTH CAROLINA.
CONTROL DEVICE ID NO TRO-1 CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): RNG System-1
EMISSION POINT(STACK)ID NO(S) TRO-S1 POSITION IN SERIES OF CONTROLS NO 1 OF 1 UNITS
MANUFACTURER:Gulf Coast Environmental Systems MODEL NO TRO-65-60-100
OPERATING SCENARIO:
1 OF 1
TYPE AFTERBURNER ❑ REGENERATIVE THERMAL OXIDATION ❑ RECUPERATIVE THERMAL OXIDATION CATALYTIC OXIDATION
EXPECTED LIFE OF CATALYST(YRS). N/A METHOD OF DETECTING WHEN CATALYST NEEDS REPLACMENT. N/A
CATALYST MASKING AGENT IN AIR STREAK HALOGEN 7 SILICONE ❑ PHOSPHOROUS COMPOUND I HEAVY METAL
J SULFUR COMPOUND ❑ OTHER(SPECIFY) ❑ NONE
TYPE OF CATALYST. N/A CATALYST VOL(FT'): N/A VELOCITY THROUGH CATALYST(FPS): N/A
SCFM THROUGH CATALYST N/A
DESCRIBE CONTROL SYSTEM,INCLUDING RELATION TO OTHER CONTROL DEVICES AND SOURCES. AND ATTACH DIAGRAM OF SYSTEM.
TRO-1 is a recuperative thermal oxidizer which uses heat to remove VOCs from RNG gas processing exhaust stream. Heat from the TRO-1 combustion is used to pre-
heat incoming processing system to increase system efficiency. Natural gas is used as burner fuel, as needed,to maintain waste gas combustion System diagram is
attached.
POLLUTANT(S)COLLECTED VOC
BEFORE CONTROL EMISSION RATE(LB/HR): 372.13 Whir(max)
CAPTURE EFFICIENCY. 100 % % % %
CONTROL DEVICE EFFICIENCY: 99 % % %
CORRESPONDING OVERALL EFFICIENCY. 99 % %
EFFICIENCY DETERMINATION CODE.
TOTAL AFTER CONTROL EMISSION RATE(LB/HR) 3 7 Ib/hr(at max load)
PRESSURE DROP(IN H20) MIN appx 1 psig MAX appx 1 psig OUTLET TEMPERATURE(°F) 1,500 MIN 1,800 MAX
INLET TEMPERATURE(°F): MIN 68 MAX 473 RESIDENCE TIME(SECONDS): 0.5s
INLET AIR FLOW RATE (ACFM) (SCFM): 10,000 COMBUSTION TEMPERATURE(°F) 1,800
COMBUSTION CHAMBER VOLUME(FT') To Be Determined INLET MOISTURE CONTENT(%) 0-0 5
%EXCESS AIR CONCENTRATION(ppmv) VOC 143-2000 INLET 20(as hexane)OUTLET
AUXILIARY FUEL USED Natural Gas TOTAL MAXIMUM FIRING RATE(MILLION BTU/HR) 23 7 MMBtu/hr(Waste+Natural Gas
DESCRIBE MAINTENANCE PROCEDURES Regular periodic maintenance checks per manufacturer and non-routine maintenance as needed per operational monitoring
DESCRIBE ANY AUXILIARY MATERIALS INTRODUCED INTO THE CONTROL SYSTEM: Ambient air
COMMENTS
Attach Additional Sheets As Necessary

FORM C9
CONTROL DEVICE (OTHER)
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate C9
CONTROL DEVICE ID NO: FLARE-1 CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): RNG System-1
EMISSION POINT(STACK)ID NO(S): FLARE-S1 POSITION IN SERIES OF CONTROLS. NO 1 OF 1 UNITS
OPERATING SCENARIO:
1 OF 1 1P.E SEAL REQUIRED(PER 2Q 0112)? YES NO
DESCRIBE CONTROL SYSTEM: Candlestick(open)flare
POLLUTANT(S)COLLECTED: VOCs
BEFORE CONTROL EMISSION RATE(LB/HR): 12.53 Ibs HAPs/hr
CAPTURE EFFICIENCY: 100 % % % %
CONTROL DEVICE EFFICIENCY: 88-99 % % % %
CORRESPONDING OVERALL EFFICIENCY: 98 % % % %
EFFICIENCY DETERMINATION CODE: Manf.
TOTAL AFTER CONTROL EMISSION RATE(LB/HR): 0.22 lb HAPs/hr
PRESSURE DROP(IN. H20): N/A MIN N/A MAX BULK PARTICLE DENSITY(LB/FT') N/A
INLET TEMPERATURE(°F): <140oF MIN <140oF MAX OUTLET TEMPERATURE(°F): appx 1000oF MIN appx 1000oF MAX
INLET AIR FLOW RATE(ACFM):7,040 scfm(limited by process capacity to OUTLET AIR FLOW RATE(ACFM):7,040 scfm max(limited by process capacity to
6,400 scfm) 6,400 scfm)
INLET AIR FLOW VELOCITY(FT/SEC): N/A OUTLET AIR FLOW VELOCITY(FT/SEC): max 60 FPS
INLET MOISTURE CONTENT(%): N/A ['': FORCED AIR 1 1 INDUCED AIR
COLLECTION SURFACE AREA(FT'): N/A FUEL USED: treated LFG,waste gas FUEL USAGE RATE:varies
DESCRIBE MAINTENANCE PROCEDURES: Periodic equipments checks, monitoring.follow manufactuer maintenance frequencies and procedures
DESCRIBE ANY AUXILIARY MATERIALS INTRODUCED INTO THE CONTROL SYSTEM: None
DESCRIBE ANY MONITORING DEVICES,GAUGES,TEST PORTS, ETC: Thermocouple,flow monitoring,etc
ATTACH A DIAGRAM OF THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See Appendix C
COMMENTS:
Attach manufacturer's specifications,schematics,and all other drawings necessary to describe this control.
Attach Additional Sheets As Necessary

FORM D1
FACILITY-WIDE EMISSIONS SUMMARY
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D1
CRITERIA AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
AIR POLLUTANT EMITTED tons/yr tons/yr tons/yr
PARTICULATE MATTER(PM) 22A 224 22.4
PARTICULATE MATTER<10 MICRONS(PM10) 224 22A 22A
PARTICULATE MATTER<2 5 MICRONS(PM2 5) 22.4 224 224
SULFUR DIOXIDE(SO2) 7 1 7 1 7 1
NITROGEN OXIDES(NOx) 454 454 454
CARBON MONOXIDE(CO) 64 64 64
VOLATILE ORGANIC COMPOUNDS(VOC) 185 18.5 18.5
LEAD - - -
GREENHOUSE GASES(GHG)(SHORT TONS) NR NR NR
OTHER 1 0(HAPs) 1 0(HAPs) 1.0(HAPs)
HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
HAZARDOUS AIR POLLUTANT EMITTED CAS NO tons/yr tons/yr tons/yr
SEE APPENDIX B
TOXIC AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE(TPER)IN 15A
NCAC 2Q.0711 MAY REQUIRE AIR DISPERSION MODELING USE NETTING FORM D2 IF NECESSARY.
Modeling Required?
TOXIC AIR POLLUTANT EMITTED CAS NO Ib/hr lb/day lb/year Yes No
SEE APPENDIX B (NO MODELING REQUIRED)
COMMENTS
Attach Additional Sheets As Necessary

FORM D4
EXEMPT AND INSIGNIFICANT ACTIVITIES SUMMARY
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D4
ACTIVITIES EXEMPTED PER 2Q .0102 OR
INSIGNIFICANT ACTIVITIES PER 2Q .0503 FOR TITLE V SOURCES
SIZE OR
PRODUCTION BASIS FOR EXEMPTION OR INSIGNIFICANT
DESCRIPTION OF EMISSION SOURCE RATE ACTIVITY
Emergency use generator for safe and
orderly shutdowns during power
Emergency Generator (Diesel) 324 BHP interruptions,
15A NCAC 02Q.102(h)(5);
NCDAQ 01/24/07 Letter
(https://deq.nc.gov/media/21948/download)
Diesel Tank (for Emergency Generator) 500 gallons 15A NCAC 02Q.102(g)(7)
15A NCAC 02Q.102(h)(5)
2 Condensate Storage Tanks appx 15,000 15A NCAC 02Q.102(h)(5)
gallons
5.
6.
7
8.
9.
10
Attach Additional Sheets As Necessary

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and B1 through B9)-SHOW CALCULATIONS USED,INCLUDING EMISSION
FACTORS,MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE
DERIVED. INCLUDE CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS
MADE AND PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS.
B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS
APPLICABLE TO INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR
MONITORING REQUIREMENTS)FOR COMPLYING WITH APPLICABLE REGULATIONS,PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS
BASED ON PROCESS RATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS
(PREVENTION OF SIGNIFICANT DETERIORATION(PSD), NEW SOURCE PERFORMANCE STANDARDS(NSPS), NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS(NESHAPS),TITLE V),INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE
APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE
EMISSION RATES CALCULATED IN ITEM"A"ABOVE.DATES OF MANUFACTURE.CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS.
C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY
CONTROL EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE.
INCLUDE PERTINENT OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS
APPLIED FOR IN THIS APPLICATION)CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR
MALFUNCTION POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING
PROPER OPERATION OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED.
D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN
USING PROCESS,OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE
REGULATORY ANALYSIS IN ITEM"B"WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED
TO DEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS.
E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).1"DAVIR t Q� ]E attest that this application for L laf1 r)jw —a-r GRC(-1 C A K""�/
has been reviewed by me and is accurate,complete and consistent with the information supplied
in the engineering plans,calculations,and all other supporting documentation to the best of my knowledge. 1 further attest that to the best of my knowledge the
proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed
by other professionals,inclusion of these materials under my seal signifies that 1 have reviewed this matenal and have judged it to be consistent with the proposed
design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement,representation,or
certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per
violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME: DAV 11, S. glLe E,
DATE iO(031.20.1 2-
COMPANY: SCS �1�GtrJE S�PC cr- to3 ,�A•
ADDRESS: q (ol ANEVWX NC 291i`( �J•'��( ��
b OO-D FpW ur[pG�.c . , 2� Q
TELEPHONE: .28 - PS
SIGNATURE:PAGES CERTIFIED:
QPs..01 �CAuwuinak�5 A x�� • • GI •'• �_
I '''aauu,u►u•a�
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary

Appendix B
Detailed Emissions Calculations
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsengineers.com

POTENTIAL EMISSION CALCULATIONS
Potential emission rates (PTE) for the thermal recuperative oxidizer (TRO), candlestick flare, and
emergency generator are provided herein. The total plant Potential emissions are calculated on the
following general assumptions:
• The thermal oxidizer operates full-time at its maximum heat input rating.
• The Candlestick Flare operates full time in Flare Mode 2
• The emergency generator operates 500 hours per year.
In addition, calculations for the candlestick flare operating full-time in Flare Mode 1 are shown below.
Note that these emissions are not added to the plant total, since they result from an alternative
operating scenario, in which the TRO does not operate. Even though emissions from the Flare itself,
(in the Flare Mode 1 scenario) are greater than those in Flare Mode 2, the plant total is lower in this
operating scenario (Flare Mode 1) because the TRO is not operated during this scenario. Therefore,
the maximum plant-wide PTE comes from the scenario of full time operation of the TRO and full time
operation of the flare in Flare Mode 2.
A summary of potential emissions is provided in Table B-1.
Table B-1-Potential Emissions
Potential Emissions (tons per year)
Scenario 1 Scenario 2
Compound Candlestick Candlestick Facility
TRO Flare- Emergency Scenario Flare- Emergency Scenario PTE
Mode 2 Generator 1 Total Mode 1 Generator 2 Total
NOx 10.4 34.5 0.5 45.4 35.4 0_5 35.9 45.4
CO 20.8 43.1 0.1 64.0 44.3 0.1 44.4 64.0
PM 7.9 14.5 0.01 22.4 14.8 0.01 14.81 22.4
PM 10 7.9 14.5 0.01 22.4 14.8 0.01 14.81 22.4
Sox, 6.9 -- 0.2 7.1 6.9 0.2 7.1 7.1
VOC 13.9 4.4 0.2 18.5 4.4 0.2 4.6 18.5
HAPs' 0.8 -- 0.2 1.0 0.8 0.2 1.0 1.0
Notes:
1)Sulfur Dioxide and HAP emissions are calculated based on maximum flow rate and the
amount of compound concentrated in the gas stream.Since the maximum flow rate of 6,400 scfm is
diverted to either the TRO or the Flare(or both),the maximum emissions for the Facility is equivalent
to the maximum emissions of the TRO (conservation of mass of H2S).
Details regarding potential emission calculations for each of these units is provided in the following
sections.
As demonstrated herein, the RNG plant is a small source, Non-Title V, Non-Synthetic Minor Permit.
Appendix B-Emissions Calculations www.scsengineers.com
1

THERMAL OXIDIZER EMISSIONS
Operating data for the thermal oxidizer is presented in Table B-2.
Table B-2-Thermal Oxidizer Operating Data
Parameter Value
Hours of Operation 8,760 hr/ r
TRO Design Heat Input Capacity 23.7 MMBTU/h
Assumed BTU Content of Natural Gas 1,012 Btu/scf
Maximum LFG Flow Rate 6,400 scfm
Notes:
1. Btu content of waste gas based on higher heating value(HHV)of methane and methane content of the waste
gas streams.
2. Btu content of natural gas based on higher heating value(HHV) per Archaea
3. Design Heat Capacity of the TRO provided by manufacturer specifications
Emission Rate Calculations
Nitrogen Oxide (NOx) Emissions
NOx emissions from the thermal oxidizer are based on a maximum heat rate of 23.7 MMBtu/hr and
the manufacturer guarantee of 0.1 lb NOWMMBtu. Potential NOx emissions calculations are presented
on page one of Attachment B-1.
Note that 23.7 MMBtu/hr is provided as the maximum design heat input capacity of the TRO. This
23.7 MMBtu/hr accounts for the heat energy from both the waste gas and the supplemental (if
needed) natural gas.
Carbon Monoxide (CO) Emissions
CO emissions from thermal oxidizer are based on a maximum heat rate of 23.7 MMBtu/hr and the
manufacturer guarantee of 0.2 lb CO/MMBtu. Potential CO emissions calculations are presented on
page one of Attachment B-1.
Note that 23.7 MMBtu/hr is provided as the maximum design heat input capacity of the TRO. This
23.7 MMBtu/hr accounts for the heat energy from both the waste gas and the supplemental (if
needed) natural gas.
Sulfur Oxide (SOx) Emissions
Sulfur oxides, reported as sulfur dioxide (S02), are emitted as a product of combustion of total sulfur
compounds in the gas combusted in the thermal oxidizer. The emission of S02 from the thermal
oxidizer is estimated using mass-balance methods based on a sulfur content of the LFG at the post
H2S removal.
Emissions are based on an LFG flow to the plant of 6,400 scfm. A conservatively-high sulfur
concentration of 25 ppmv is assumed. Potential SOx emissions calculations are presented on page 2
of Attachment B-1.
Appendix B—Emissions Calculations www.scsenciineers.com
2

Note that since sulfur dioxide emissions are a product of combustion and proportional to the amount
of sulfur in the gas stream, the potential emissions presented in Attachment B-1 for the TRO are
equivalent to maximum total plant emissions for sulfur dioxide, regardless of which destruction
device(s) is/are operational.
Particulate (PM and PM,o) Matter Emissions
Particulate matter emissions are calculated using the PM emission factor for flares published in the
EPA's AP-42 Section 2.4. PM emissions from the thermal oxidizer are calculated on a mass-balance
basis given the total maximum waste gas flow to the plant of 3,200 scfm and assuming an LFG
methane content of 12.2 percent. PM emissions attributable from natural gas were conservatively
added to the waste total at the natural gas burner capacity.These calculations are presented on page
15 of Attachment B-1.
The EPA emissions factor does not distinguish between PM and PM10 emissions. However,AP-42 does
suggest that for this type of combustion process, PM and PM10 emissions are expected to be
equivalent. Thus, the potential emissions herein represent that for both PM and PMio. Potential PM
emissions calculations are presented on page one of Attachment B-1.
Volatile Organic Compounds (VOC) Emissions
VOC emissions from the thermal oxidizer are calculated based on the unit's exhaust flow rate (at full
loading) of 10,336 scfm, a maximum outlet total manufacturer guarantee concentration of 20 ppmv
(corrected to 3% oxygen), and conservatively assuming that 100 percent of TNMOCs are VOCs.
Potential VOC emissions calculations are presented on page three of Attachment B-1.
Hazardous Air Pollutants
The emission of HAPs is calculated using mass-balance methods and concentrations of HAPs found in
raw LFG as shown in AP-42, Table 2.4-1. HAP emissions from the thermal oxidizer are calculated on
a mass-balance basis given the total maximum LFG flow to the plant of 6,400 scfm and conservatively
assume that any HAPs removed by the treatment system are directed to the thermal oxidizer.
Note that similar to the sulfur dioxide emissions, HAP's are a product of combustion and proportional
to the amount of the concentration of the HAP that is in the waste stream. Therefore, the potential
emissions calculated for each HAP for the TRO is equivalent to the potential emissions for each HAP
for the entire plant.A sample HAP calculation is presented on page two of Attachment B-1.The full list
of HAP's and TAP's is presented on page four of Attachment B-1, HCl calculations are presented on
page five of Attachment B-1, and HAP's and TAP's from the combustion of natural gas is presented on
page six of Attachment B-1.
CANDLESTICK FLARE EMISSIONS - FLARE OPERATING MODE 2
Potential emission rates (PTE) for the candlestick flare are based on the operating data presented in
Table B-3. These emissions are based on Flare Operating Mode 2, which would run simultaneously
with the TRO.
Table B-3-Flare Operating Data(Flare Mode 2)
Parameter Value
Appendix B-Emissions Calculations www.scsenaineers.com
3

Hours of Operation Up to 8,760 hour/year
BTU Content of LFG/Waste Gas' 840 Btu/scf
LFG/Waste Gas Rated Flow Capacity 3,905 scfm Flare Mode 2
Continuous Pilot NG Heat Input 0.2 MMBtu/hr @8,760 hrs/ r
Notes:
1. Per Perennial Energy, Btu content based on a higher heating value (HHV) of 1,012 Btu/scf and assumed
LFG/Waste Gas methane content of 83 percent in Flare Mode 2.
Emission Rate Calculations
Nitrogen Oxides (NOx) Emissions
Using the above operating data and the equations presented below, the potential emissions for NOx
at the flare are presented on page seven in Attachment B-1.
Carbon Monoxide (CO) Emissions
Using the above operating data and the equations presented below, the potential emissions for CO at
the flare are presented on page seven in Attachment B-1.
Sulfur Oxide (SOx) Emissions
Sulfur oxides (reported as sulfur dioxide [S02]) are emitted as a product of combustion of total sulfur
compounds in the gas combusted in the candlestick flare. The emission of S02 from the flare is
estimated using mass-balance methods based on a sulfur content of the raw LFG at the plant inlet.
This is conservative because it assumes that all sulfur in the LFG (post-H2S removal) is directed to the
candlestick flare and converted to S02 through combustion during flare operation.
Note that since SOx emissions are a factor of sulfur content mass in the gas stream,the total maximum
plant wide emissions are based on the concentration of sulfur and the quantity of gas entering the
plant and therefore the emissions do not change if the gas is diverted to the flare or diverted to the
TRO (or some combination of both). Therefore, please reference the SOx emissions calculations for
the TRO presented in page two of Attachment B-1.
Particulate (PM and PMIo) Matter Emissions
Particulate matter emissions are calculated using the PM emission factor for flares published in the
EPA's AP-42 Section 2.4. PM emissions from the candlestick flare are calculated on a mass-balance
basis given the total maximum LFG flow to the candlestick flare in flare operating mode 2 of 3,905
scfm and assuming a LFG methane content of 83 percent. The calculations conservatively assume
that any particulate matter removed by the treatment system is directed to the candlestick flare during
flare operation.
The EPA emissions factor does not distinguish between PM and PM10 emissions. However,AP-42 does
suggest that for this type of combustion process, PM and PM10 emissions are expected to be
equivalent. Thus, the potential emissions herein represent that for both PM and PMio. Potential
emissions for PM at the flare are presented in page seven of Attachment B-1.
Appendix B-Emissions Calculations www.scsengineers.com
4

Volatile Organic Compound (VOC) Emissions
The emission of VOCs from the candlestick flare is estimated using mass-balance methods and the
manufacturer's VOC emission factor of minimum 98 percent destruction. Emissions assume a non-
methane organic compound (NMOC) content of the raw LFG at the plant inlet of 595 ppmv (AP-42,
Section 2-4) and conservatively assume that 100 percent of NMOCs are VOCs. Potential emissions
for VOC at the flare are presented on page eight of Attachment B-1.
Hazardous Air Pollutant (HAP) Emissions
The emission of HAPs is calculated using mass-balance methods and concentrations of HAPs found in
raw LFG as shown in AP-42, Table 2.4-1. Note that since HAP emissions are a factor of HAP
concentrations in the gas stream, the total maximum plant wide emissions are based on the
concentration of HAPs and the quantity of gas entering the plant and therefore the emissions do not
change if the gas is diverted to the flare or diverted to the TRO (or some combination of both).
Therefore, please reference the HAP emissions calculations for the TRO presented on pages two,four,
and five of Attachment B-1.
CANDLESTICK FLARE EMISSIONS - FLARE OPERATING MODE 1
Potential emission rates (PTE)for the candlestick flare are based on the operating data presented in
Table B-4. In this scenario, all collected LFG to the plant is routed to the project Flare (NOTE: For
sustained outages, LFG would not be routed to the RNG plant, but would, instead, be flared in the
landfill's separately permitted flare. The emissions presented below should not be added to the
emissions calculated above, rather they should be viewed as emissions from an alternate operating
scenario.While the PTE for Flare Operating Mode 1 are greater than Flare Operating Mode 2,the plant
PTE is lower under this operating scenario,since the TRO would not run.
Table B-4-Flare Operating Data(Flare Mode 1)
Parameter Value
Hours of Operation Up to 8,760 hour/year
BTU Content of LFG1 526 Btu/scf
LFG Rated Flow Capacity 6,400 scfm process capacity limited
Continuous Pilot NG Heat Input 0.2 MMBtu/hr @8,760 hrs/ r
Notes:
1. Btu content based on a methane higher heating value (HHV) of 1,012 Btu/scf and assumed LFG methane
content of 52 percent.
Emission Rate Calculations
Nitrogen Oxides (NOx) Emissions
Using the above operating data and the equations presented below, the potential emissions for NOX
at the flare are presented on page nine of Appendix B-1.
Appendix B-Emissions Calculations vwvw.scsengineers.com
5

Carbon Monoxide (CO) Emissions
Using the above operating data and the equations presented below,the potential emissions for CO at
the flare are presented on page nine of Appendix B-1:
Sulfur Oxide (SOx) Emissions
Sulfur oxides (reported as sulfur dioxide [S02]) are emitted as a product of combustion of total sulfur
compounds in the gas combusted in the candlestick flare. The emission of S02 from the flare is
estimated using mass-balance methods based on a sulfur content of the LFG (post H2S removal) at
the plant inlet. This is conservative because it assumes that all sulfur in the raw LFG is directed to the
candlestick flare and converted to S02 through combustion during flare operation.
Emissions from the candlestick flare are based on design capacity of the flare of 6,400 scfm. A
conservatively-high inlet sulfur concentration of 25 ppmv was assumed. The potential emissions for
SOx at the flare are presented on page 10 of Appendix B-1:
Particulate (PM and PMio) Matter Emissions
Particulate matter emissions are calculated using the PM emission factor for flares published in the
EPA's AP-42 Section 2.4. PM emissions from the candlestick flare are calculated on a mass-balance
basis given the flare design capacity of 6,400 scfm and assuming an LFG methane content of 52
percent. The calculations conservatively assume that any particulate matter removed by the treatment
system is directed to the candlestick flare during flare operation.
The EPA emissions factor does not distinguish between PM and PMio emissions. However,AP-42 does
suggest that for this type of combustion process, PM and PM10 emissions are expected to be
equivalent. Thus, the potential emissions herein represent that for both PM and PMso. The potential
emissions for PM at the flare are presented on page nine of Appendix B-1:
Volatile Organic Compound (VOC) Emissions
The emission of VOCs from the candlestick flare is estimated using mass-balance methods and the
manufacturer's VOC emission factor of minimum 98 percent destruction. Emissions assume a non-
methane organic compound (NMOC) content of the raw LFG at the plant inlet of 595 ppmv (AP-42,
Section 2-4) and conservatively assume that 100 percent of NMOCs are VOCs. The potential
emissions for VOCs at the flare are presented on page 11 of Appendix B-1:
Hazardous Air Pollutant HAP Emissions
The emission of HAPs is calculated using mass-balance methods and concentrations of HAPs found in
raw LFG as shown in AP-42, Table 2.4-1. HAP emissions from the candlestick flare are calculated on
a mass-balance basis given the total design capacity of the flare of 6,400 scfm and conservatively
assume that any HAPs removed by the treatment system are directed to the flare during flare
operation.A sample HAP calculation is presented on page 10 of Attachment B-1. The full list of HAP's
and TAP's is presented on page 12 of Attachment B-1,and HCI calculations are presented on page 13
of Attachment B-1.
Appendix B-Emissions Calculations www.scsenciineers.com
6

EMERGENCY GENERATOR EMISSIONS
Potential emissions from the emergency generator are detailed below. The engine for the emergency
generator is a Cummins diesel engine rated at 324 hp (200 kW). Potential emission estimates are
based on the engine's maximum power rating of 324 hp, emission factors for diesel engines provided
in AP-42, Section 3.3, the engine's emission limits provided by Cummins, and an estimated annual
operating time of 500 hours per year. Potential emissions are summarized below in Table B-5.
Calculations are provided on page 14 of Attachment B-1.
Table B-5-Potential Engine Emissions
Pollutant Emission Factor Potential Emissions
Value Unit (tons/year)
NOx' 3.0 /bh -hr 0.5
COI 0.7 /bh -hr 0.1
SOx2 2.05*10-3 Ib/h -hr 0.2
PM3 0.08 /h -hr 0.01
PM103 0.08 /h -hr 0.01
VOC2 0.00247 Ib/h -hr 0.2
HAP4 0.00247 Ib/h -hr 0.2
Notes:
1. Emission factor provided by Cummins Power Generation.
2. Emission factor provided in AP-42,Section 3.3,Table 3.3-1.
3. Emission factor provided by Cummins Power Generation. PM and PMio emissions assumed to be equal.
4. It is assumed that all VOC emissions are also HAP emissions.
Appendix B-Emissions Calculations www.scsengiineers.com
7

SCS ENGINEERS
SHEET I of 15
CLIENT Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 02222204.02
SUBJECT BY DATE
TRO Potential Emission Calculations-Waste Gas DSG 9/16/2022
NOx,CO,PM CHECKED DATE
LSN 9/27/2022
OBJECTIVE:TRO waste gas emissions based on a maximum MMBTU rate. Bumer Size: 23,700,000 Btu/hr
23.7 MMBtu/hr
APPROACH:Use vendor provided data and AP42 equations and emission factors.
SOLUTION:
(1)NOx Emissions
NOx Emission Factor= 0.10 lb/MMBtu Manufacturer Guarantee
Heat Rate= 24 MMBtulltr
Btu value of Natural Gas: 1,012 Btu/113
Hours of Operation= 8,760 hr/yr
CMNOx=(0.10 lb/MMBtu)*(24 MMBtu/hr)_
CMNO.= 2.4 Ib/hr NOS
CMNO�= 10.38 tons)r NOx
(2)CO Emissions
CO Emission Factor= 0.20 lb/MMBtu Manufacturer Guarantee
Heat Rate= 24 MMBtu/hr
Btu value of Natural Gas: 1,012 Btu/ft3
Hours of Operation= 8,760 hr/yr
CMCO=(0.20 lb/MMBtu)* (24 MMBtu/hr)_
CMCo= 4.7 Ib/hr CO
CMCo= 20.76 tons/crCO
(3)PM Emissions
Use Mass Balance from LFG flow to the plant
PM Emission Factor= 17 lb/106 ft3 CH4 (AP42,Section 2.4,Table 2.4-5)
LFG Flow to the plant 3,200 ft3/min at 12.2%methane(CH4)
Hours of Operation= 8,760 hr/yr
-From Note"a",AP42,Section 2.4,Table 2.4-5,
(17 Ib/106 ft3)/(16,700)= 1.0E-03 Ib/hr-dft'/min
CMpM= (1.0E-03 Ib/hr-dft3/min CH4)*[(0.122)*(3,200 ft3/min)]= 1. 99 Ib/hr PM
CMPM= F 7.42 tons/yr PM

SCS ENGINEERS
SHEET 2 of 15
CLIENT Archaea PROJECT East Carolina-RNG JOB NO. 02222204.00
Energy,Inc
SUBJECT BY DATE
TRO Potential Emission Calculations-Natural Gas DSG 8/3/2022
S02;HAP ex CHECKED DATE
LSN 8/l6/2022
(6)S02 Emissions
Consreatively assume that all S converts to S02
Conservatively assume S concentration=142S concentration
C,=S Concentration= 25 ppmv Post Sulfur treatment value of 6 ppmv with additional margin
Molecular Weight of Sulfur(SO2)= 64 g/gmol
LFG Flow(Design Max)= 6,400 ft3/min at 52%methane(CH4)
Hours of Operation= 8,760 hr/yr
Volumetric flow of Sulfur
(6,400 0/min)*(60 min/hr)*(8,760 hr/yr)*(m3/35.3198 113)*(25 ppmv S/I E+06)= 2,381.0 m3 Sh r
Mass flow of S02
(2381.0 m3/yr)*[(64 g/gmol*1 atm)*(2.2 lb/kg)/(8.205E-5 m3-atm/gmol-K* 1,000 g/kg*(273+25 K))]_
13,711 lb S02/yr
CMS02= 1.57 lb/hr So2
CMS02= 13,711 Ib/yr S02
CMSO2= 6.86 10n sly r SO,
(7) Hazardous Air Pollutant(HAPs)Emissions
HAPs are calculated by using the estimated concentration and molecular weight of
the individual HAPs(which are substituted into the respective equation).
See Exhibit I for a summary of flare HAP emissions.
Example
1,1,1-trichloroethane Molecular Weight= 133.41 g/gmol AP-42 Chapter 2.4 for LFG
Concentration= 0.48 ppmv
Ql j jtnchlo th�= (6,400 113/min)*(525,600 min/yr)*(m3/35.3198 113)*(0.48 ppmv S/1 E+06)= 45.71 M3/yr
CM1,1.1-Mchl—ffi nc= (45.71 m3)*[(133.41 g/gmol* 1 atm)/(8.205E-5 m3-atm/gmol-K* 1,000 g/kg*(273+25 K))]_
CMI_1_i_mchl—th—= 249.43 kg/yrl,l,l-trichloroethane
CM1,1.1.mchiorocd� = (249.43 kg S/yr)*(2.2lb/kg)*(ton/2,000 lb)= 0.27 ton/yr 1,1,1-trichloroethane
I,I,I-trichloroethane= CMI.1,1,khl o,th,r (tons/yr)*(I-Ncpn/]00)
NcNT=98%destruction efficiency for halogen compounds(AP-42 Table 2.4-3)
1,1,1-trichloroethane= 0.27 ton/yr*(1-(98/100))= 5.49E-03 ton/,,r 1,1,1-trichloroethane to atmosphere

SCS ENGINEERS
SHEET 3 of 15
CLIEN Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 2222204.00
SUBJECT BY DATE
TRO Potential Emission Calculations-Natural Gas DSG 8/4/2022
VOC CHECKED DATE
LSN 8/16/2022
VOC emissions from the thermal oxidizer are calculated based on the unit's exhaust flow rate(at full loading),
a maximum outlet total non-methane organic compound(TNMOC)concentration of 20 ppmv(corrected
to 3%oxygen as Hexane),and conservatively assuming that 100 percent of TNMOCs are VOC
molar weight of VOC as Hexane= 86.18 gVOC/mol
VOC Exhuust= 20 ppmv as Hexane(Manufacturer guarantee)
Oxygen percentage(basis)= 20.9%
Oxygen percentage(for correction)= 3.0%
Exhaust Flow Rate= 10,336 scfm
Cone(3%0 Z)trot=
(86.18 g/gmol)•(20ppmv/10^6)'(2.21b/kg)'[(I atm)/(8.205E-5 m3-atm/gmol-K+1,000 g/kg'(273+25 K))] (20.91/0/(20.9%3%))--
Cone(3%02)voc= 5.13E-06 lbVOC/dscf
Mass Emissions
CM voc= (10,336 sc&n)'(0.00000513 IbVOC/dscf)•(60 min/hr)= 3.18 Ib/hr VOC
CM voc= (3.18 Ib/hr)*(8,760 hr/yr)*(I ton/2,000 lbs)= 13.9 ton/yr VOC

SCS ENGINEERS
SHEET 4 of 15
LU NT Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO.
02222204.00
SUBJECT BY DATE
TRO Potential Emission Calculations-Waste Gas DSG 9/16/2022
Uncombusted HAPs CHECKED DATE
LSN 927/2022
7)HAP Emissions,continued
Waste Gas Flow Rate(tt'/min)= 6,400 Waste Flow to TRO(at 12.2%CH4)
Hourly LFG Consumption(ft'/hr)= 394,000
Hourly LFG Consumption(m'/hr)= 10,872
Landfill Gas Temperature(6C)r= 25
Halogenated Destruction Eff.(%)r= 98.0%
Non-Halogenated Destruction ER.(%)'= 99.7%
Mercury Compound Destruction ER.(%)_= 0.0%
Pollutant Mol.Wt. Couc.' Q(p)4 UM(p)s TRO
(g/8rra1) (pPnty) (m'lhr) (kg/hr) (lb/hr) (lb/hr) (Ib/yr) crM
1,1,1-trichlormdtane TAP,HAP 133.41 0.49 5.22E-03 0.03 0.06 1.26E-03 1.10E+01 5.50E-03
1,1,2-trichb th.ne TAP,a"' 133.41 0.24 2.61E-03 0.01 0.03 6.28E-04 5.50E+00 2.75E-03
I,1,2,2-tevachloroedurte UP'NM 167.85 1.11 1.21E-02 0.08 0.18 3.65E-03 3.20E+01 1.60E-02
1,I dicldoroetham TAP.NAP 98.97 2.35 2.55E-02 0.10 0.23 4.56E-03 3.99E+01 2.00E-02
1,1-0iChimoethen,T"P,n"r 96.94 0.20 2.17E-03 0.01 0.02 3.80E-04 3.33E+00 1.66E-03
1,24chloroctbane T"P,a"P 98.96 0.41 4.46E-03 0.02 0.04 7.95E-04 6.97E+00 348E-03
1,2dichloropropme TAP,HnP 112.99 0.18 1.96E-03 0.009 0.02 3.99E-04 3.49E+00 1.75E-03
1,2,4-trichlorabenarc T"P'HAP1 191.45 0.94 1.02E-02 0.076 0.17 3.34E-03 2.93E+01 1.46E-02
1,3-butadiene T"P,n"' 54.09 0.24 2.61E03 0.006 0.01 2.55E-04 2.23E+00 1.11E-03
1,4-0ioaane T"P,n"P a 98.11 0.93 1.01E-02 0.036 0.08 1.61E-03 11.41E+01 7.04E-03
2,2,4-trimethylperrim T"P'""Ps 114.23 1.30 1.41E-02 0.066 0.15 2.91E-03 2.55E+01 1.28E-02
rylanitrdeTM,HAP 53.06 6.33 6.88E-02 0.15 0.33 9.88E-04 8.65E+00 4.33E-03
T"P,N"P 78.11 1.91 2.08E-02 0.07 0.13 4.39E-04 3.84E+00 1.92E-03
romoformr" "Ps 252.73 0.24 2.61E-03 0.03 0.06 1.78E-04 1.56E+00 7.81E-04
TAP,H"Pa 94.94 0.93 1.01E-02 0.04 0.09 260E-04 2.27E+00 1.14E-03
disulfide TAP.HAP 76.13 0.59 6.31E-03 0.02 0.04 1.30E-04 1.14E+00 5.69E-04
carbon teuacNoride TAP,H"P 153.84 0.004 4.35E-0S 2.74E-04 6.03E-04 1.21E-05 1.06E-0I 5.28E-05
(sulfide T"P,n"P 60.07 0.49 5.33E-03 0.01 0.029 8.66E-05 7.58E-01 3.79E-04
hlombervere TAP,HAP 112.56 0.25 2.72E-03 0.01 0.029 5.52E-04 4.83E+00 2.42E-03
Chior,.Cd,..,,T"P,HAP 64.52 1.25 1.36E-02 0.04 0.079 1.58E-03 1.39E+01 6.93E-03
chloroform TAP.NAP 119.39 0.03 3.26E-04 0.002 0.004 7.02E-05 6.15E-01 3.08E-04
oromedram TAP,HAP 50.49 1.21 1.32E-02 0.03 0.06 1.20E-03 1.05E+0l 5.25E-03
TM,wws I20.19 0.24 2.61E-03 0.01 0.03 5.66E-04 4.95E+00 2.48E-03
chlorcibcn eTAP,HAP I47.00 0.21 2.28E-03 0.01 0.03 6.05E-04 5.30E+00 2.65E-03
chlorodifluo...th.m TM I20.91 15.7 1.71E-01 0.94 1.96 3.72E-02 3.26E+02 1.63E-01
chlorofluorometham TAP 102.92 2.62 2.85E-02 0.12 0.26 5.29E-03 4.63E+01 2.32E-02
chimorrunhaoe T"P'N"P 94.94 14.3 1.55E-01 0.54 1.19 238E-02 2.09E+02 1.04E-01
ethyl me.V-TAP 62.13 2.29 2.48E-02 0.06 0.14 4.17E-04 3.65E+00 1.82E-03
:thylbcr a HM 106.16 4.61 5.01E-02 0.22 0,49 1.44E-03 1.26E+01 6.30E-03
:thyIcnc dibrmnide TAP,Ha' 187.88 0.001 1.09E-05 8.35E-05 1.84E-04 3.68E-06 3.23E-02 1.61E-05
tc.achiciminit.d.TAP,u"a 260.76 0.93 1.01E-02 0.11 024 4.75E-03 4.16E+01 2.08E-02
TAP,HAP 96.18 6.57 7.14E-02 0.25 0.55 1.66E-03 1.46E+01 7.28E-03
rialroclilloric add TAP.HAP6 35.45 2.32 N/A N/A N/A 8.30E-02 7.27E+02 3.64E-01
sulfide TAP 34,08 25 0.27 0.38 0.84 2.51E-03 2.19E+01 I.IOE-02
rumnury and conVounds T"P,x"P 200.61 2.92E-04 3.17E-06 2.60E-0S 5.74E-05 5.74E-05 5.03E-01 2.52E-04
nathyl ethyl ketone TAP 72.11 7.09 7.71E-02 0.23 0.50 1.50E-03 1.32E+01 6.59E-03
wthyl tsobutyl ketone TAP.tuP 100.16 1.87 2.03E-02 0.08 0.18 5.51E-04 4.83E+00 2.41E-03
neflayl rncrcaptan TAP 48.11 2.49 2.71E-02 0.05 0.12 3.52E-04 3.09E+00 1.54E-03
nethy,ten-butyl wirer TAP,111 99.15 0.24 2.61E-03 0.01 0.02 4.15E-04 3.63E+00 1.82E-03
xrchlomethylene rAP.x"P 165.83 3.73 4.06E-02 0.28 0.61 1.21E-02 1.06E+02 5.31E-02
TAP,HAP. 104.15 0.24 2.61E-03 0.01 0.02 4.90E-04 4.29E+00 2.15E-03
luem T".1 92.13 39.3 4.27E-01 1.61 3.55 1.06E-02 9.33E+01 4.66E-02
chloroethyltae rnP.tuP 131.40 2.82 3.07E-02 0.16 0.36 7.26E-03 6.36E+01 3.18E-02
,ay,cNorid.T"P,-7 62.50 0,353 3.83E-03 0.01 0.02 4.32E-04 3.78E+00 1.89E-03
[ems TAR Ha? 106.16 12.1 1.32E-01 0.57 1.26 3.78E-03 3.31E+01 1.65E-02
Total HAPs Only - 1.39 5.68 12.53 0.22 1,549.94 0.77
1.The landfill gas temperance was obad d from AP42 fog,24-5.
.AP42 deswctiou etTiciaay(Table 2A-3).
.Pollutant concentrations usd to eompute the estimated emission are than AP42,Section 2.4,Table 2.4-I.HCI derived fmn sito-specif,-piing(sae attachdk H2S f von process-spsik data
.Q(p)=Volumetnc emission mte of the pollutant.AP-42 Section 2 4 equation(3),
.UM(p)=Unw lld mass emissions of pollutant If no collmfion exists,this is also equal to the fugitive emission rate,FKp)of the pollutant AP42 equation(4).
.HCI emisnoas are a product of the combustion process and are calculated w a uxmter dill t than the other pollutants listed above.See page 5 of the wlcula ioa shons.
F,S.Emissions based on site-specific asmpling data wiN carcnm etion increased by a Ills margin
AP denotes canpamd that arc classified as tonic an pollutants per the North Carolina Department of Envimn W Quality
denotes wmpotmdd that are classified as hasmdous a pollutants pa AP42 and CAA Section 112

SCS ENGINEERS
SHEET 5 of 15
CLIENT PROJECT EastCarolina-RNG JOB NO.
Archaea Energy,Inc 1 02222204.00
SUBJECT BY DATE
TRO Potential Emission Calculations-Natural Gas DSG 8/9/2022
Uncombusted HCl CHECKED DATE
LSN 8/16/2022
(8)HCl Emissions
-Use Equations(3),(4),&(10)from AP42 Section 2.4 to determine HCl emissions.
Total Chloride Concentration= 2.32 ppmv Site-Specific Sample
Molecular Weight of Chlorine(Cl)= 35.453 g/gmol
Max Flow = 6,400 ft3/min
Hours of Operation= 8,760 hr/yr
Eqn(3)
Q Ci= (6,400 ft3/min)*(60 min/hr)*(m3/35.3198 ft3)*(42.0 ppmv Cl/IE+06)= 0.03 m3 Cl/hr
Eqn(4)
UMCI= (0.03 m3/hr)*[(35.453 g/gmol* 1 atm)/(8.205E-5 m3-atm/gmo1-K* 1,000 g/kg*(273+25 K))]_
UMci= 0.037 kg Cl/hr
Eqn(10)
CM HCL= 0.037 kg C1/hr* (NCOL/100)*1.03*(NCNT/100)
NCOL=100%since calc is based on actual flow rate to the flare and not an assumed collection rate.
NCNT=100%Assume the flare is capable of converting 100%of the Cl to HCI.
CM HCL= 0.04 kg/hr Cl*(100/100)*1.03*(100/100)= 0.04 kg/hr
CM HCL= (0.04 kg/hr)*(2.2 Ib/kg) F 0.08 Ib/hr HCI
CM HCL= (0.08 lb/hr)*(8,760 hr/yr)= 727.5 Ib/vr HCI
CM HCL= (727.50 Ib/yr)/(2,000 lb/ton)= 0.36 ton/yr HCI

SCS ENGINEERS
SHEET 6 of 15
CL Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO.
02222204.00
SUBJECT BY DATE
TRO Potential Emission Calculations-Natural Gas DSG 8/9/2022
Uncombusted HAPs(from Nat Gas Combustion) CHECKED DATE
LSN 8/16/2022
(7)HAP Emissions,continued
Bunter Capacity 15,000,000 Btu/hr
15 MMBtu/hr
Pollutant Emission Factorl Emission Factor2 Emissions
Ib/MMscf Ib/MMBtu Ib/hr Ibivr Tonvyr
arsenic HAP.TAP 2.0E-04 2.0E-07 2.94E-06 2.58E-02 119E-05 de-min
benzene TAP.HAP 2.1 E-03
2.IE-06 3.09E-05 2.71E-01 1.35E-04 de-men
TAP
benzo(a)pyreneHAP. 1.2E-06 1.2E-09 1.76E-08 I.55E-04 7.73E-08 de-min
beryllium'' 1.2E-05 1.2E-08 1.76E-07 1.55E-03 7.73E-07 de-min
cadmittmTAP,HAP 1.1E-03 1.1E-06 1.62E-05 1.42E-01 7.09E-05
chromium TAP'HAP 1.4E-03 1.4E-06 2.06E-05 1.80E-01 9.02E-05
cobalt TAP.HAP 8.4E-05 8.2E-08 1.24E-06 1.08E-02 5.41E-06 de-min
dichlorobenzene TAP'HAP 1.2E-03 1.2E-06 1.76E-05 1.55E-01 7.73E-05 de-min
formaldehyde rAP.xAP 7.5E-02 7AE-05 1.10E-03 9.66E+00 4.83E-03 de-min
hexane TAP.HAP 1.8E+00 1.8E-03 2.65E-02 2.32E+02 1.16E-01 de-min
lead TAP.HAP 5.0E-04 4.9E-07 7.35E-06 6.44E-02 3.22E-05 de-min
manganese TAP. 3.8E-04 de-min
3.7E-07 5.59E-06 4.90E-02 2.45E-05
mercury TAP'HAP 2.6E-04 2.5E-07 3.82E-06 3.35E-02 1.67E-05
nickel TA" 2.1E-03 2.1E-06 3.09E-05 2.71E-01 1.35E-04 de-min
selenium TAP.HAP 2.3E-03 2.3E-06 3.38E-05 2.96E-01 1.48E-04 de-men
oluene TAP.HAP 3.4E-03 3.3E-06 5.00E-OS 4.38E-01 2.19E-04 de-min
Notes.
1.The landfill gas temperature was obtained from AP42 Page 2.4-5.
2.AP42 destruction efficienry(Table 2.4-3).
3.Pollutant concentrations used to compute the estimated emissions are then AP42,Section 2.4.Table 2.4-1.HCI derived from site-specific sampling(sec attached):H2S from process-specific data
4.Q(p)=Volumetric emission rate of the pollutant.AP42 Section 2.4 equation(3).
5.UM(p)=Uncontrolled mass emissions of pollutant.If no collection exists.this is also equal to the fugitive emission rate.FM(p)of the pollutant.AP-12 equation(4).
6.HCI emissions area product of the combustion process and are calculated m a monster different than the other pollutants listed above.See page 5 of the calculation sheets.
TAe denotes compounds that are classified as toxic air pollutants per the North Carolina Department of Envimnmern d Quality
"'�denotes compounds that are classified as hazardous air pollutants per AP42 and CAA Section 112.

SCS ENGINEERS
SHEET 7 of 15
CLIENT Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations-Mode 2 DSG 8/16/2022
NOx,CO,PM CHECKED DATE
LSN 8/16/2022
OBJECTIVE:Calculate flare emissions based on a maximum LFG flow rate. 3,905 113/min (@ 83%CH4)
(flare sized above process capacity of 6,400 scf n @52%CH4)
APPROACH:Use vendor provided data and AP-42 equations and emission factors.
SOLUTION:
(1)NOx Emissions
NOx Emission Factor= 0.04 lb/MMBtu Manufacturer Guarantee
LFG Flow(Design Max)= 3,905 ft3/min at 83%methane(CH4)
Heating Value of Fuel: 840 Btu/ft3(at 83%CH4)
Hours of Operation= 8,760 hr/yr
CMNOx=(0.04 lb/MMBtu)*(3,905 113/min)*(840 Btu/113)*(MMBtu/1.0E+06 Btu)*(60 min/hr)_
CMNO�= 1 7.87 Ib/hr NOx
CMNI�= 34.48 tons/yr NOx(Design Max)
(2)CO Emissions
CO Emission Factor= 0.05 lb/MMBtu Manufacturer Guarantee
LFG Flow(Design Max)= 3,905 113/min at 83%methane(CH4)
Heating Value of Fuel: 840 Btu/113(at 52%CH4)
Hours of Operation= 8,760 hr/yr
CMCO=(0.05 lb/MMBtu)*(3,905 113/min)*(840 Btu/113)*(MMBtu/1.0E+06 Btu)*(60 min/hr)_
CMCo= 9.84 Ib/hr CO
CMCo= 43.10 tons/yr CO(Design Max)
(3)PM Emissions
PM Emission Factor= 17 Ib/106 ft3 CH4 (AP-42,Section 2.4,Table 2.4-5)
LFG Flow(Design Max)= 3,905 113/min at 83%methane(CH4)
Hours of Operation= 8,760 hr/yr
-From Note"a",AP-42,Section 2.4,Table 2.4-5,
(17 Ib/106 11)/(16,700)= 1.0E-03 Ib/hr-dft3/min
CMPM= (1.0E-03 Ib/hr-dft3/min CH4)*[(0.83)*(3,905 113/min)]= 3.30 lb/hr PM
CMPM= 14.45 tons/yr PM(Mode 2)

SCS ENGINEERS
SHEET 8 of 15
CLIEN Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations Mode 2 DSG 8/16/2022
VOC CHECKED DATE
LSN 8/16/2022
VOC emissions from the flare are estimated using mass-balance methods and the manufacturer
guarantee, of minimum of 98%destruction and assuming non-methane organic compound(NMOC)
content
of 595 ppmv per AP-42 Section 2.4;conservatively assume NMOC=VOC
Flow Rate 6,400 scfm (@ 83%CH4)
NMOC content 1595 ppmv(AP-42)
VOC percentage of NMOC 100%
Molar weight of VOC as Hexane 86.18
Destruction efficiency 98%
Hours of Operation per year 8,760 hr/yr
Volume Flowrate of VOC
(6,400 scfm)*(1/(35.3 ft3/m3)*(8,760 hr/yr)*(60 min/hr)*(595/10^6)= 56,699 m3 VOC/yr
Mass Flowrate of VOC
(86.18 g/gmol)*(56,699 m3VOC/yr)*(2.2lb/kg)*[(1 atm)/(8.205E-5 m3-atm/gmol-K* 1,000 g/kg*(273+25 K))]*(1-0.98)_
CMvoc= 8,793 lb VOC/yr
CM, 4.40 Tons/yr VOC

SCS ENGINEERS
SHEET 9 of 15
CLIENT Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 022222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations DSG 8/1/2022
NOx,CO,PM CHECKED DATE
LSN 8/16/2022
OBJECTIVE:Calculate flare emissions based on a maximum LFG flow rate. 6,400 ft3/min (@ 52%CH4)
(flare sized above process capacity of 6,400 scf n @52%CH4)
APPROACH:Use vendor provided data and AP-42 equations and emission factors.
SOLUTION:
(1)NOx Emissions
NOx Emission Factor= 0.04 Ib/MMBtu Manufacturer Guarantee
LFG Flow(Design Max)= 6,400 113/min at 52%methane(CH4)
Heating Value of Fuel: 526 Btu/ft3(at 52%CH4)
Hours of Operation= 8,760 hr/yr
CMNOx=(0.04 lb/MMBtu)*(6,400 ft3/min)*(526 Btu/113)*(MMBtu/1.0E+06 Btu)*(60 min/hr)_
CMNOx= 1 8.08 Ib/hr NOx
CMNOX= 35.40 tons/yr NOx(Design Max)
(2)CO Emissions
CO Emission Factor= 0.05 Ib/MMBtu Manufacturer Guarantee
LFG Flow(Design Max)= 6,400 113/min at 52%methane(CH4)
Heating Value of Fuel: 526 Btu/113(at 52%CH4)
Hours of Operation= 8,760 hr/yr
CMCO=(0.05 Ib/M Btu)*(6,400 113/min)*(526 Btu/113)*(MMBtu/1.0E+06 Btu)*(60 min/hr)_
CMco= 10.10 Ib/hr CO
CMcO= 44.25 tons/yr CO(Design Nlax)
(3)PM Emissions
PM Emission Factor= 17 Ib/106 63 CH4 (AP-42,Section 2.4,Table 2.4-5)
LFG Flow(Design Max)= 6,400 113/min at 52%methane(CH4)
Hours of operation= 8,760 hr/yr
-From Note"a",AP-42,Section 2.4,Table 2.4-5,
(17 Ib/106 113)/(16,700)= 1.0E-03 lb/hr-dft3/min
CMPM= (1.0E-03 Ib/hr-dft3/min CH4)*[(0.52)*(6,400 ft3/min)] F 3.39 Ib/hr PM
CMPM= 14.84 tons/yr PM(Design Max)

SCS ENGINEERS
SHEET 10 of I S
CLIENT Archaea Energy PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations DSG 8/2/2022
S02;HAP ex CHECKED DATE
LSN 8/16/2022
(6)S02 Emissions
Consreatively assume that all S converts to S02
Conservatively assume S concentration=H2S concentration
C,=S Concentration= 25 ppmv Post Sulfur treatment value of 25ppmv(design value,above expected conc.)
Molecular Weight of Sulfur(SO2)= 64 g/gmol
LFG Flow(Design Max)= 6,400 ft3/min at 52%methane(CH4)
Hours of Operation= 8,760 hr/yr
Volumetric flow of Sulfur
(6,400 113/min)*(60 min/hr)*(8,760 hr/yr)*(m3/35.3198 113)*(25 ppmv S/1 E+06)= 2,381 m3 S/yr
Mass flow of S02
(2,381 m3/yr)*[(64 g/gmol*1 atm)*(2.2 lb/kg)/(8.205E-5 m3-atm/gmol-K*1,000 g/kg (273+25 K))]_
13,711 lb S02/w
CMsoi= 1.57 Ib/hr SOz
CMS= F 13,711 Ib/yr SO:
CMS= 6.86 Tons/vr SO,
(7) Hazardous Air Pollutant(HAPs)Emissions
HAPs are calculated by using the estimated concentration and molecular weight of
the individual HAPs(which are substituted into the respective equation).
See Exhibit I for a summary of flare HAP emissions.
Example
1,1,1-trichloroethane Molecular Weight= 133.41 g/gmol AP-42 Chapter2.4 for LFG
Concentration= 0.48 ppmv
Q I J J trichlo—thwie= (6,400 ft3/min)*(525,600 min/yr)*(m3/35.3198 ft3)*(0.48 ppmv S/1E+06)= 45.71 m3/yr
CMI_t,1-trichloroethane= (45.71 m3)*[(133.41 g/gmol*1 atm)/(8.205E-5 m3-atm/gmo1-K*1,000 g/kg'(273+25 K))]_
CM1.l.l-trichlorocth, = 249.43 kg/yr 1,1,1-trichloroethane
CMl,l.l-a;chloroethaae= (249.43 kg S/yr)*(2.2 lb/kg)*(ton/2,000 lb) 0.27 ton/vr 1,1,1-trichloroethane to flare
1,1,1-trichloroethane= CMl.l,l-uim (tons/yr)*(1-NCT/100)
NCNT=98%destruction efficiency for halogen compounds(AP-42 Table 2.4-3)
1,1,1-trichloroethane= 0.27ton/yr*(l-(98/l00))= 5.49E-03 ton/vr1,1,1-trichloroethane to atmosphere

SCS ENGINEERS
SHEET I of 15
CLIENT PROJECT East Carolina-RNG JOB NO. 02222204.00
Archaea Energy,Inc
SUBJECT BY DATE
Flare Potential Emission Calculations DSG 8/4/2022
VOC CHECKED DATE
LSN 8/16/2022
VOC emissions from the flare are estimated using mass-balance methods and the manufacturer
guarantee, of minimum of 98%destruction and assuming non-methane organic compound(NMOC)
content
of 595 ppmv per AP-42 Section 2.4;conservatively assume NMOC=VOC
Flow Rate 6,400 scfm(design max)
NMOC content 595 ppmv(AP-42)
VOC percentage of NMOC 100%
Molar weight of VOC as Hexane 86.18
Destruction efficiency 98%
Hours of Operation per year 8,760 hr/yr
Volume Flowrate of VOC
(6,400 scfm)*(1/(35.3 ft3/m3)*(8,760 hr/yr)*(60 min/hr)*(595/10^6)= 56,699 m3 VOC/yr
Mass Flowrate of VOC
(86.18 g/gmol)*(56,699 m3VOC/yr)*(2.21b/kg)*[(1 atm)/(8.205E-5 m3-atm/gmol-K* 1,000 g/kg*(273+25 K))]*(1-0.98)_
CMvoC= 8,793 lb VOC/yr
CMv 4.40 Tons/yr VOC

SCS ENGINEERS
SHEET 12 of 15
CLI Archaea Energa.Inc PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations DSG 8/11/2022
Uncombusted HAPs CHECKED DATE
LSN 8/1612022
(7)HAP Emissions,continued
LFG FImv Rate(ft''/min)= 6AW Preeas Detl(pr Capaeityfiwse tlut/6rP hAwilklelmrtauapoees desiea cap-to,a%W0sf a52%('H4)
Hourly LEG Consumption(ft3/hr)= 384AM
Hourly LEG Consumption(ma/hr)= 10,872
Landfill Gas Temperature(aC)t= 25
Halogenated Destruction ER.(%l"= 980K
Non-Halogenated Destruction Eff.(%/ = 9f.7%
Mercury Compound Destruction ER. OAK
Pollutant Mol.Wt. Comc.3 Q(p)4 UM(p)s Flare
(84111,01) (PPmv) (M34W) (kgthr) (lb/hr) (lb/hr) (Ibtyr) MY)
1,1,1-triddoroethaneT"P'a"P 133.41 0.49 5.22E-03 0.03 0.06 1.26E-03 1.10E+01 5.50E-03
1,1,2-trichloroedmne T"P'a"P s 133.41 0.24 2.61E-03 0.01 0.03 6.28E-04 5.50E+00 2.75E-03
1,1,2,2-tetrachloroethane TAP'a"P 167.95 1.11 1.21E-02 0.08 0.18 3.65E-03 3.20E+01 1.60E-02
1,1-dichloroedme"'t'"P 98.97 2.35 2.35E-02 0.10 0.23 4.56E-03 3.99E+01 2.00E-02
l,l-dWiloroethene T'u''a"P 96.94 0.20 2.17E-03 0.01 0.02 3.80E-04 3.33E+00 1.66E-03
1,2-dichloroethane T"P'a" 98.96 0.41 4.46E-03 0.02 1 0.04 7.95E-04 6.97E+00 3.48E-03
1,2-dichloropropane T"P'11AP 112.99 0.19 1.96E-03 0.009 0.02 3.99E-04 3.49E+00 1.75E-03
1,2,4-trichlorobevene TAP'HAPa 181.43 0.94 L02E-02 0.076 0.17 3.34E-03 2.93E+01 1.46E-02
1,3-butadiene TAe't'"pr 54.09 0.24 2.61E-03 0.006 0.01 2.55E-04 2.23E+00 1.11E-03
1,4-dioxane T'-" 98.11 0.93 LOIE-02 0.036 0.08 1.61E-03 1.41E+01 7.04E-03
2,2,4-trimethylpentane TAP'HAPa 114.23 1.30 1.41E-02 0.066 0.15 2.91E-03 2.55E+01 1.28E-02
acrylonitrile TM.1 53.06 6.33 6.88E-02 0.15 0.33 9.88E-04 8.65E+00 4.33E-03
benzene T"P.- 78.11 1.91 2.08E-02 0.07 0.13 4.39E-04 3.84E+00 1.92E-03
bromofonn TAP'HAPa 252.73 0.24 2.61E-03 0.027 0.06 1.19E-03 1.04E+01 5.21E-03
bromomahane T"P,a"Ps 94.94 0.93 LOIE-02 0.039 0.09 1.73E-03 1.52E+01 7.58E-03
carbon disulfide TAP'NAP 76.13 0.58 6.31E-03 0.02 0.04 1.30E-04 1.14E+00 5.69E-04
carbon tetrachloride TM,ttM 153.94 0.004 4.35E-05 2.74E-04 6.03E-04 1.21E-05 1.06E-01 5.28E-05
carbonyl sulfide TAP,x"P 60.07 0.49 5.33E-03 0.01 0.029 8.66E-05 7.58E-01 3.79E-04
chlorobaUMe T"P,a"P 112.56 0.25 2.72E-03 0.01 0.028 5.52E-04 4.83E+00 2.42E-03
chloroethaie T"P,a"P 64.52 1.25 1.36E-02 0.04 0.079 1.58E-03 1.39E+01 6.93E-03
chloroform T"P'a"P 119.39 0.03 3.26E-04 0.002 0.004 7.02E-05 6.15E-01 3.08E-04
chloromedume T"'w 50.49 1.21 1.32E-02 0.03 0.06 1.20E-03 1.05E+01 5.25E-03
umame TAP.`W. 120.19 0.24 2.61E-03 0.01 0.03 5.66E-04 4.95E+00 2.48E-03
dichlorobenzate TAe,xAP 147.00 0.21 2.28E-03 0.01 0.03 6.05E-04 5.30E+00 2.65E-03
dichlorodi0uoromethaneT"P 120.91 15.7 1.71E-01 0.94 1.96 3.72E-02 3.26E+02 1.63E-0l
dichloro0uoromethaneTM 102.92 2.62 2.85E-02 0.12 0.26 5.29E-03 4.63E+01 2.32E-02
dichloromethane T"P,xAP 84.94 14.3 1.55E-01 0.54 1.19 2.38E-02 2.09E+02 1.04E-01
ethyl mercaptan- 62.13 2.28 2.48E-02 0.06 0.14 4.17E-04 3.65E+00 1.82E-03
ethylbeno,ene it"P 106.16 4.61 5.01E-02 0.22 0.48 1.44E-03 1.26E+01 6.30E-03
ethylene dibromide T"P.trap 187.88 0.001 1.09E-05 8.35E-05 1.84E-04 3.68E-06 3.23E-02 1.61E-05
exachlorobutadiene r"e,iwe 260.76 0.93 1.01E-02 1.08E-01 2.38E-01 4.75E-03 4.16E+01 2.08E-02
hexane r"P,a"P 86.18 6.57 7.14E-02 0.25 0.55 1.66E-03 1.46E+01 7.28E-03
hydrochloric acid TM,a"P 6 35.45 2.32 N/A N/A N/A 8.30E-02 7.27E+02 3.64E-01
hydrogen sulfide"" 34.08 25 0.27 0.38 0.84 2.51E-03 2.19E+01 1.10E-02
mercury and compounds TAP,iuP 200.61 2.92E-04 3.17E-06 2.60E-05 5.74E-05 5.74E-05 5.03E-01 2.52E-04
methyl ethyl ketone TM 72.11 7.09 7.71E-02 0.23 0.50 1.50E-03 1.32E+01 6.59E-03
methyl isobutyl ketone TM,a"P 100.16 1.97 2.03E-02 0.08 0.19 5.51E-04 4.83E+00 2.41E-03
methyl rnerceptan TM 48.11 2.49 2.71E-02 0.05 0.12 3.52E-04 3.09E+00 1.54E-03
ethyl tert-butyl ether T"e,I s 88.15 0.24 2.61E-03 9.41E-03 2.07E-02 4.15E-04 3.63E+00 1.82E-03
perchloroethylene TM.a"P 165.93 3.73 4.06E-02 0.28 0.61 1.21E-02 1.06E+02 5.31E-02
styrene T"P.1W8 104.15 0.24 2.61E-03 1.11E-02 2.45E-02 4.90E-04 4.29E+00 2.15E-03
toluene T"P.1 92.13 39.3 4.27E-01 1.61 3.55 1.06E-02 9.33E+01 4.66E-02
trichloroethylene TAP'a" 131.40 2.82 3.07E-02 0.16 0.36 7.26E-03 6.36E+01 3.18E-02
vinyl chloride TAP,tW T 62.50 0.353 3.83E-03 0.01 0.02 4.32E-04 3.78E+00 1.89E-03
xylenes rAP.xAP 106.16 12.1 1.32E-01 0.57 1.26 3.78E-03 3.31E+01 1.65E-02
Total HAPs Only --- - 139 5.68 12.53 OZ2 11571.68 0.79
Noma:
1.The landfill gas mia peravite was obtained from AP42 Page 2.4-5.
2.AP42 destruction eflictenov('fable 2.4-3).
3.Pollubnt cmcmtrwona med to compute the anuouted emissions are train AP42,Section 2 4,Table 2.4.1.HCI derived fiom siw-Voeific sampling(see etched);H2S fium procossspecific dale
4.Q(p)=Volumetric emission rate ot'the pofla AP42 Section 2 4 equation(3).
5.UM(p)=Uncontrolled mass emissions -'pollutant If no collection exists,tlus m also equal to the fugitive emission rate,FM(p)of the pollutant AP-12 equation(4).
HCI emissions ores prduct of the combustion process and are calculated in a meaner dift t than the other pollutants listed above.See page 5 of the calculation shaeo.
7,8.Emisaom bred m nte-spaific a pluig da with concentration increased by a IOx margin
"P denotes compomrds that are classifid as roue air pollutants per die North CaPeliru Deparonant of Environmental Quality
"'denotes axnpomds that are classified as hawdous in,pollutants per AP42 and CAA Section 112.

SCS ENGINEERS
SHEET 13 of 15
CLIEN Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Flare Potential Emission Calculations DSG 8/2/2022
Uncombusted HCl CHECKED DATE
LSN 8/16/2022
(8)HCI Emissions
-Use Equations(3),(4),&(10)from AP-42 Section 2.4 to determine HC1 emissions.
Total Chloride Concentration= 2.32 ppmv Site-Specific Sample
Molecular Weight of Chlorine(Cl)= 35.453 g/gmol
LFG Flow(Design Max)= 6,400 113/min at 52%methane(CH4);
Hours of Operation= 8,760 hr/yr
Eqn(3)
Q C= (6,400 ft3/min)*(60 min/hr)*(m3/35.3198 ft3)*(42.0 ppmv Cl/1E+06)= 0.03 in Cl/hr
Eqn(4)
UMci_ (0.03 m3/hr)*[(35.453 g/gnol* 1 atm)/(8.205E-5 m3-atm/gmol-K* 1,000 g/kg*(273+25 K))]_
UMci= 0.04 kg Cl/hr
Eqn(10)
CM HCL= 0.04 kg Cl/hr* (NCOL/100)* 1.03*(NCNT/100)
NCOL=100%since calc is based on actual flow rate to the flare and not an assumed collection rate.
NCrrr=100%Assume the flare is capable of converting 100%of the Cl to HCI.
CM HCL= 0.04 kg/hr CI*(100/100)* 1.03*(100/100)= 0.04 kg/hr
CM HCL= (0.04 kg/hr)*(2.2 lb/kg)= 0.08 Ib/hr HCI
CM HCL= (0.08 lb/hr)*(8,760 hr/yr)= 727.50 Ib/yr HCI
Annual Emissions at Design Maximum
CM HCL= (727.50 lb/yr)/(2,000 lb/ton)= 0.36 ton/yr HCI

SCS ENGINEERS
SHEET 14 of 15
CLIEN Archaea Energy,Inc PROJECT East Carolina-RNG JOB NO. 02222204.00
SUBJECT BY DATE
Generator Potential Emissions Calculations DSG 8/2/2022
CHECKED DATE
LSN 8/16/2022
The emergency generator is 200-kW,diesel fueled,and will be used in emergency situations only to
allow for safe continuity of operations and provide for orderly shutdown during power interruptions.It
is assumed that the generator will operate for less than 500 hours per year.
(Nitrogen Oxides(NOIX)Emissions3.0 9 l
bhp Nhr)\45316,q/(324 hp)(50yr )( 1 ton 2 000 lb/—0.5 ions NO,
Carbon Monoxide(CO)Emissions J
- 1 /(324 hp)(Soo
0Vr ( 1 ton 2 000 16/—0.1 tyr CO
`bhp hr)(4536 p
Sulfur Oxides(SOX)Emissions
(0.00205 lb SO, 500 hr 1 ton l 0.2 tons SOR
bhp—hr )(324 hp)( yr )(2,0001b/ yr
Particulate Matter(PM and PM10)Emissions
0.08( 9 hr (453`6 p)(324 hp)(500 hr)( 1 ton 2 0001b) —0.01 tons PM
bhp
Volatile Organic Compound(VOC)Emissions
/O.O bhp7 1hVOC)(324 hp)(SOyr )(2,0001bs) —0.2 tons VOC

SCS ENGINEERS
SHEET I5 of 15
CLIENT PROJECT East Carolina-RNG JOB NO.
Archaea Energy,Inc 02222204.00
SUBJECT BY DATE
TRO Potential Emission Calculations-Natural Gas DSG 9/28/2022
PM CHECKED DATE
1'M Emissions
(3)PM Emissions
Conservatively design capacity burner heat rate
Design Heat Rate 15 MMBTU/hr Note: For conservative emission calcualtion purposes only
TRO will not expected to combust natural gas
at 15 MMBTU/hr since combination of waste gas heat
content will exceed design constraints of TRO chamber
PM Emissions Factor 7.6 Ib/MMscf AP42,Section 1.4,Table 1.4-2
0.0075 Ib.MMBTU converted using factor in footnote to Table 1.4-2
CMPM= 0.11 Ib/br PM
CMPM= 0.49 tons/yr PM

Appendix C
Process Flow Diagram
Air Permit Application—Lightning Renewables-East Carolina RNG www.scsengineers.com

East Carolina RNG Block Flow Diagram
Archaea V16,400 SCFM Design
-------------------------
I Stage:I Feed Gas Compression System I I H2S Removal System I I Stage:2 Feed Gas Compression System
I I I I I I
I I I I I I
Comp. I I H2S Removal H2S I I Co Stage:2 Feed
Landfill Gas P 2 Staged Feed _ I I I mp' R I
Flow:6400 wfm @_j Initial Inlet Compressors SEP Skid(Lea&7ag Dust Inlet Compressors
psig.92F Separator comps• 0301 I Filter Aftercoolers
Sep. Afrercoolers i Tanks) i Sep. 00 i
PsiB I I I I I
\ / ` / psig i
--- --------
Condensate
to Landfill Condensate OWS condensate
if
Collection System SEP-I600 —
2
Off-Spec Product Gas Candlestick
Flare
a v
v� m
GCES MODEL FL-196
u (or similar)
Regen � 3
u u m
IWO
sea 2 Stage 1"Stage
Sales Gas to cooler as �Sales Gas Vac/Rinse PSA C ag CO TSA W� Glycol Gas/
coolers Knockout Gasand Sep and Se Comps. N2/0' Removal Removal Vessels HX HX
P S stem Membrane Membrane V-T20
4.726
�1NB"C[;/day ��(r`�
V-T60
Recycle god Stage Permeate Polishing
Comp. Compressor Aftercooler Vessel
Thermal Waste Gas to TRO
Recuperative
Oxidizer Natural Gas Purchased Lightning Renewables,LLC RNG
(TRO) from Pipeline LFG Refining Block Flow Diagram
GCES MODEL TRO-65-60-100 Scale I Sheet I Lightning Renewables,LLC
(or similar) None 1 of 1
Archaea Energy, Inc.

Appendix D
Site Location
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsengineers.com

40.
,w
s
: ► 1 Approximate t
Location of RNG L

Appendix E
Technical Specifications & Equipment Information
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsenaineers.com

ARCHAEA
ENERUY
A GCES Custom Solution Utilizing
A Thermal Recuperative Oxidizer (TRO) System
For the Abatement of Waste Gas
From an Archaea V1 6,400 SCFM
LFG to RNG Plant
To be Located in: TBD
4
1689 Hawthorne Drive
Conroe, Texas 77301
832.476.9024
www.gcesystems.com '
Gulf Coast Environmental
Systems V
J

Confidential GCES Proposal No. 2225-21 Rev.4 Archaea -MODEL TRO-65-60-100
Customer Kevin Weatherford
Address 500 Technology Drive, Upper Floor
Canonsburg, PA 1531
Company I Archaea Holdings, LLC
Telephone 1 +1 [phone]
E-Mail I kweatherford(a-)archaea.energy
Date I October 6th, 2021
Proposal Number 1 2225-21 Rev.4
Proposed Solution I TRO w/ External Heat Recovery
«1
�,►
� r
— a
Reference Only-Actual may Vary
Your Application Engineer Your Sales Representative
James Smith Paula Flowers
Sr. Application Engineer VP — Sales and Marketing
is ith(c)gcesytems.com pflowers _gcesystems.com
832.370.0358 570.540.2425
2
Confidential Information
All drawings, specifications, technical data, including this proposal, and other information we provide, is considered confidential, and the
exclusive and proprietary property of Gulf Coast Environmental Systems LLC (GCES). 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 GCES.

TABLE OF CONTENTS
SECTION 1: EXECUTIVE SUMMARY...........................................................................................4
1.1 THEORY OF OPERATION.........................................................................................................................4
1.2 PROPOSAL OVERVIEW...........................................................................................................................6
SECTION2: COMMERCIAL..........................................................................................................7
2.1 PRICING AND OPTIONS..........................................................................................................................7
2.2 TYPICAL PROJECT SCHEDULE ...................................................................................................................8
SECTION 3: DESIGN CONSIDERATIONS....................................................................................9
3.1 PROCESS DATA....................................................................................................................................9
3.2 OPERATING CONDITIONS...................................................................................................................... 10
3.3 UTILITIES.......................................................................................................................................... 10
3.4 EMISSIONS GUARANTEE....................................................................................................................... 11
3.5 PERFORMANCE GUARANTEE PROVISIONS................................................................................................. 11
SECTION 4: EQUIPMENT SPECIFICATIONS.............................................................................12
4.1 10,000 SCFM THERMAL RECUPERATIVE OXIDIZER.................................................................................... 12
SECTION 5: RESPONSIBILITY MATRIX.....................................................................................17
�I
SECTION 6: DOCUMENTATION, SERVICES, & CLARIFICATIONS..........................................18
6.1 REVIEW&APPROVAL OF DOCUMENTATION............................................................................................. 18
6.2 SURFACE PAINTING&PREPARATION ...................................................................................................... 18
6.3 QUALITY ASSURANCE.......................................................................................................................... 18
6.4 STANDARDS&CODES......................................................................................................................... 18
6.5 GCES PROJECT CLARIFICATIONS-CUSTOMER'S RESPONSIBILITY................................................................... 19
SECTION 7: ATTACHMENTS......................................................................................................20
FIELDSERVICE RATE SHEET............................................................................................................................20
WARRANTYINFORMATION ...........................................................................................................................20
GENERAL TERMS&CONDITIONS OF SALE.........................................................................................................20
PRELIMINARY FLOW SCHEMATIC DRAWING.......................................................................................................20
PRELIMINARY GENERAL ARRANGEMENT DRAWING.............................................................................................20

Confidential GCES Proposal No. 2225-21 Rev.4 (OP
-MODEL TRO-65-60-100
SECTION 1 : EXECUTIVE SUMMARY
1 .1 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.
V
GCES Thermal Recuperative Oxidizer—Actual may Vary
4

Confidential GCES Proposal No. 2225-21 Rev.4 (OP
- MODEL TRO-65-60-100
Application Specific Details
- This oxidizer is intended for use in Archaea's standard V1 6,400 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 (<1% by volume) prevents the waste gas stream from
becoming combustible. GCES 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.
5

Confidential GCES Proposal No. 2225-21 Rev.4 (OP
-MODEL TRO-65-60-100
1.2 Proposal Overview
This proposal details the supply of one (1) Thermal Recuperative Oxidizer with installation supervision
and commissioning services included. The 10,000 SCFM system shall be capable of treating up to
3,200 SCFM total waste gas combined with up to 6,800 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 GCES 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 this revision, Rev. 4 of the proposal, GCES has made the following changes:
• Increased the maximum differential pressure rating of the secondary heat exchanger from 2
psi to 5 psi to allow for additional backpressure from the TSA.
• Added a pressure relief valve to vent gas from the cold side of the secondary heat exchanger
to the oxidizer exhaust in the event that inlet pressure builds up too high.
• Added the maximum process gas inlet pressure to the tables in section 3.1. For clarification
this represents the maximum allowable pressure on start-up only. Pressure during operation
will drop to the remaining resistance of the system for a given flow rate.
• Added additional emissions clarifications to section 3.4
• Updated the equipment price.
6

Confidential GCES Proposal No. 2225-21 Rev.4
Archaea -MODEL TRO-65-60-100 (
SECTION 2: COMMERCIAL
2.1 Pricing and Options
Equipment Price
Item 1: Base Bid
Design and Supply of one (1) Thermal Recuperative Oxidizer, GCES $ 669,000.00 USD
model: TRO-65-60-100 as described in this proposal. FCA-Conroe, TX
Field Services & Freight
Item 2: Site Supervision
GCES onsite supervision for the installation of Item 1. Supervision is Included
limited to 2 weeks onsite at 6 days per week, 8-hour business days.
Additional time shall be billed according to the applicable rates.
Item 3: Commissioning, Start-up, and Training
GCES onsite commissioning, start-up assistance and training for Item 1. Included
Commissioning is limited to 1 week onsite at 6 days per week, 8-hour
business days, including one (1) eight-hour hands on training class for
operations and maintenance personnel. Additional time shall be billed
according to the applicable rates.
Item 4: Freight
Estimated freight to jobsite; Pre-paid and added TBD
Add-Ons
Item 6: Spare Parts Package — Estimated
Exact spare parts list determined during project engineering. Spare parts $ 54,900.00 USD
ordered prior to completion of the Engineering Phase shall be discounted
by 10%. Spare parts ordered at a later date will be offered at the non-
discounted price. Waiting time for recommended spare parts not
purchased by customer shall not be covered under the GCES warranty.
Item 7: Low NOx Burner for Additional Emission Requirements
Replaces the standard burner with a Maxon Kinedizer unit capable of $ 66,400.00 USD
meeting the emissions requirements of <0.06 Ib/MMBTU of NOx and
<0.20 Ib/MMBTU of CO. Includes a modified gas train for the piloted
burner, Maxon Smartlink control system, and an upgraded combustion air
fan for the additional pressure required.
7

Confidential GCES Proposal No. 2225-21 Rev.4 ���
Archaea- MODEL TRO-65-60-100 \�1.�_-
2,2 Typical Project Schedule
Drawings: Submission of Top-Level Drawings (GA, P&ID, & Foundation Loading)
4-6 weeks after receipt of order & initial deposit
Ready to ship: 20-24 weeks after approval of Top-Level Drawings
Installation: 2-3 weeks after delivery to site
Commissioning: 1 additional week after installation
Notes:
• Lead time may vary based on the timing of an order. GCES will confirm project schedule within
two weeks of order placement and deposit.
• Lead time does not consider hold points, document reviews, additional inspections, or any other
customer originated considerations during the execution of the oxidizer design / build process.
• Project expediting options may be available. Consult your sales representative for further details.
• Lead time may be impacted by supply chain disruptions, including production, transportation,
inventories and others related directly or indirectly to COVID-19. Such disruptions shall be
considered Force Majeure. GCES will work diligently to minimize and mitigate the effects of such
disruptions.
8

Confidential GCES Proposal No. 2225-21 Rev.4 ��
Archaea-MODEL TRO-65-60-100
SECTION 3: DESIGN CONSIDERATIONS
3.1 Process Data
Application: Membrane Waste Gas/TSA Re en
Maximum process volume: Up to 2,520 SUM
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
Minimum Total VOC/HAP Load: 0.00 Ib/hr
*Maximum Total VOC/HAP Load: 201.21 ib/hr
*VOC/HAP Mixture Average Heat of Combustion: —21,154 BTU/Ib
*Maximum VOC Heat Release: 4,256,439 BTU/hr or 70,941 BTU/min
**Process Gas Composition at max. Condition:
- Nitrogen, N2 1.48% Vol. or 162.07 lb/hr
- Oxygen, 02 0.64% Vol. or 80.06 lb/hr
- Water Vapor, H2O 0.50% Vol. or 35.21 Ib/hr
- Carbon Dioxide, CO2 94.61% Vol. or 16,276.60 Ib/hr
- Methane, CHa 2.67% Vol. or 167.45 Ib/hr
- Other Non-Corrosive VOCs as Hexane, C6H,4 1,000 ppm, or 33.69 Ib/hr
- ***Hydrogen Sulfide, H2S 6 ppmv or 0.08 Ib/hr
- Total 100.00% Vol. or 16,755.15 Ib/hr
Application: NRU Waste Gas
Maximum process volume: Up to 680 SUM
Process Gas Inlet Temperature: Up to 80OF
Process Gas Inlet Pressure: <0.5 psig at oxidizer inlet
15 psig max. allowable at start-up
Process Volume Turndown Requirement: —4:1
Minimum Total VOC/HAP Load: 0.00 lb/hr
*Maximum Total VOC/HAP Load: 372.13 Ib/hr
*VOC/HAP Mixture Average Heat of Combustion: —21,500 BTU/Ib
*Maximum VOC Heat Release: 8,000,818 BTU/hr or 133,347 BTU/min
**Process Gas Composition at max. Condition:
- Nitrogen, N2 77.10% Vol. or 2,278.29 Ib/hr
- Oxygen, 02 0.91% Vol. or 30.72 Ib/hr
- Water Vapor, H2O 0.00% Vol. or 0.00 Ib/hr
- Carbon Dioxide, CO2 0.00% Vol. or 0.00 Ib/hr
- Methane, CHa 21.99% Vol. or 372.13 Ib/hr
- Other Non-Corrosive VOCs as Hexane, C6H,4 0 ppmv or 0.00 Ib/hr
- ***Hydrogen Sulfide, H2S 0 ppm,or 0.00 Ib/hr
- Total 100.00% Vol. or 2,681.13 Ib/hr
9

Confidential GCES Proposal No. 2225-21 Rev.4 (op
-MODEL TRO-65-60-100
*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 3,200 SCFM of total waste gas at the system inlet, or -971.56 Ib/hr
of total methane.*
**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 1,000°F or less.**
***Any SOX compounds formed as a result of hydrogen sulfide oxidation will not be removed by this
equipment alone. GCES can provide additional post-combustion treatment solutions for the removal
of these compounds if required.***
3.2 Operating Conditions
Minimum Operating Temperature: 1,500°F
Maximum Operating Temperature: 1,800°F
Target Internal Heat Transfer Effectiveness: ^-65% for dilution airpre-heating)
Target External Heat Transfer Effectiveness: ^-60% for TSA heating)
Equipment Location: Outdoors
Control Panel Location Outdoors on the oxidizer skid
Site Location Elevation: <1,000 ft ASL
Electrical Area Classification: Class I Div. II
Wind Load Design: 100 MPH
Seismic Design: Not Specified (no seismic provisions
included
Noise Requirement: <85 dBa @ 5ft from rotating equipment
3.3 Utilities
Natural Gas Requirement (Installed Capacity): 15,000 SCFH @ 10 psig pressure
LHV = -1,000 btu/SCF
Estimated Natural Gas Usage: -3,040 SCFH
At full volume, maximum operating temperature,
and Specified VOC Load, -6.78% CH4 (varies with inlet methane content)
Electrical Supply Voltage: 480V/60Hz/ 3 Phase
Estimated Electrical Power Consumption: -103 kW at maximum capacity
Compressed Air Supply: 80 psig @ -20OF dew point
Estimated Compressed Air Usage: 10 CFM peak; <5 CFM average
120 V/60 Hz/ 1 Ph - power (from
control panel)
Oxygen Analyzer Additional Utilities 0.4% and 8% 02, Balance N2-
Calibration Gas
2 SCFH, 2.5 psig, 20.95% 02-
Reference Air
10

Confidential GCES Proposal No. 2225-21 Rev.4 (op
-MODEL TRO-65-60-100
3.4 Emissions Guarantee
Volatile Organic Compound (VOC) Destruction Removal Efficiency (DRE):
99% or less than 20 ppm,as hexane
Burner NOX Emissions:
Standard— <0.10 Ib/MMBTU as NO2
With Selection of Option #7— <0.06 Ib/MMBTU as NO2
Burner Carbon Monoxide Emissions:
<0.20 Ib/MMBTUH
EPA Method 25A, 7E, & 10 and/or mutually agreed upon test method(s) will be used to
determine/validate VOC, NO, & CO destruction performance respectively.
3.5 Performance Guarantee provisions
- The unit is installed (if applicable), operated and maintained by Buyer in accordance with GCES
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. GCES must be notified in writing 14
days prior to the tests for scheduling purposes.
- GCES reserves the right to adjust the burner chamber operating temperature and any other
settings as required to meet the guarantees.
- If GCES fails to meet the Performance Guarantee, GCES must be given reasonable time to
investigate and take corrective action within the scope of this contract.
11

Confidential GCES Proposal No. 2225-21 Rev.4 (OP
-MODEL TRO-65-60-100
SECTION 4: EQUIPMENT SPECIFICATIONS
This proposal is based on preliminary engineering intended to achieve the performance goals. GCES
reserves the right to alter component selections during project engineering.
4.1 10,000 SCFM Thermal Recuperative Oxidizer
General Requirement I GCES Provision
Dilution Air Fan
Fan Manufacturer New York Blower orequal
Approximate Volume @ Design Conditions 6,800 SCFM
Expected Motor Size 30 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 orequal
Motor Starter Allen Bradley or equal
Located in the Control Panel
Flow Control Pneumatic Modulating Damper
Inlet Screen
Other Features Outlet Flex Joint
Housing Access Door & Drain
Coolin Air Fan
Fan Manufacturer New York Blower orequal
Approximate Volume @ Design Conditions 19,000 SCFM
Expected Motor Size 50 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 orequal
Motor Starter Allen Bradly or equal
Located in the Control Panel
Flow Control Pneumatic Modulating Dampers
Two 2 total
Inlet Screen
Other Features Outlet Flex Joint
Housing Access Door & Drain
12

Confidential GCES Proposal No. 2225-21 Rev.4
Archaea - MODEL TRO-65-60-100
Combustion Air Fan
Fan Manufacturer New York Blower orequal
Approximate Volume @ Design Conditions 2,900 SCFM
Expected Motor Size 20 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 orequal
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 Eclipse Therm,let or GCES approved equal
Quantity of Burners One 1
Maximum Rated Capacity of Each Burner 15,000,000 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 A ollo orequal
Y-Strainer Mueller orequal
Gas Pressure Regulator Sensus orequal
Low and High Gas Pressure Switches United Electric orequal
Fuel Gas Safety Shut-Off Valves Maxon orequal
Pressure Gauges Miljocco or equal
Gas Control Valve Indelec orequal
Adjustable Orifice Valve Eclipse orequal
Shell Material Minimum '/4" 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
P nor orequal
Residence Time (volumetric basis) -0.5 Seconds @ 1,800°F and maximum flow
rate
13

Confidential GCES Proposal No. 2225-21 Rev.4 Archaea-MODEL TRO-65-60-100
Stack Discharge Height 60ft above grade
Stack Diameter 54" I.D. /62" O.D.
Max. Expected Volume 71,075 ACFM @ 800°F
Max. Expected Velocity 4,469 ft/min
Materials of Construction Carbon Steel Shell
Internally Insulated with Ceramic Fiber
Two (2) 3" NPT Threaded Pipe Nipples
Test Ports Set at 90' Apart
Stack Test Platform Not Included
Other Features Free Standing (no guy wires)
Drain at Stack Base
NEMA 4X— Outdoor Rated
Control Panel Type with Weather Hood &A/C
Purged for Class I Div. II
Operator Interface Allen Bradley PanelView orequal
Control Panel Standard UL508a
Programmable Logic Controller PLC Allen Bradley Com actLo ix orequal
Burner Management System (BMS) Siemens orequal
Communications Connection Ethernet Switch
Voltage Main 480 VAC /3 phase/60 Hz
Control 120 VAC / 1 phase/60 Hz (via GCES
supplied transformer
Membrane Gas Process Isolation Valve
Type/Size Wafer Style Butterfly/ 12"0
Two 2 Total
Carbon Steel Body
Materials of Construction Stainless Steel Disk
PTFE Seat
Spring Return Pneumatic/ Fail Closed
Actuator Type / Manufacturer On-Off
Max-Air orequal
TSA Return Process Isolation Valve
Type/ Size Wafer Style Butterfly/ 14"0
Two 2 Total
Carbon Steel Body
Materials of Construction Stainless Steel Disk
PTFE Seat
Spring Return Pneumatic/ Fail Closed
Actuator Type/ Manufacturer One (1) On-Off& One (1) Modulating
Max-Air orequal
14

Confidential GCES Proposal No. 2225-21 Rev.4
Archaea-MODEL TRO-65-60-100
NRU Gas Process Isolation Valve
Type / Size Wafer Style Butterfly/ 6"0
Two 2 Total
Carbon Steel Body
Materials of Construction Stainless Steel Disk
PTFE Seat
Spring Return Pneumatic/ Fail Closed
Actuator Type/ Manufacturer One (1) On-Off& One (1) Modulating
Max-Air orequal
Heat Exchanger Type Crossflow Shell-and-Tube
In-line Tube Bank
Carbon Steel Housing
Materials of Construction Internally Insulated with Ceramic Fiber
304 Stainless Steel Internals
Internal Expansion Joint Included
Cold Side Inlet Design Conditions Flow Rate: 4,400 SUM
Temperature: 70 F
Hot Side Inlet Design Conditions Flow Rate: 14,166 SUM
Tempera ure: 1,200°F
Cold Side Outlet Temperature 805OF clean, nob ass
Hot Side Outlet Temperature 1,0150E clean, nob ass
Maximum Expected Heat Transfer Rate —3,575,000 BTU/hr
Maximum Expected Heat Transfer —65%
Effectiveness
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 1.0 psig (PSV not included or required)
Cold Side to Hot Side
Cold Side Bypass None
Rectangular Louver Dampers
Hot Side Bypass Refractory Lined with 330 Stainless Steel
Metal Internals
15

Confidential GCES Proposal No. 2225-21 Rev.4 070 Archaea-MODEL TRO-65-60-100
Heat Exchanger Type Crossflow Shell-and-Tube
In-line Tube Bank
Carbon Steel Housing
Materials of Construction Internally Insulated with Ceramic Fiber
304 Stainless Steel Internals
Internal Expansion Joint Included
Cold Side Inlet Design Conditions Flow Rate: 2,520 SUM
Temper ture: 65 F
Hot Side Inlet Design Conditions Flow Rate: 18,804 SUM
Tempe ature: 800 F
Cold Side Outlet Temperature 5430E clean, nob ass
Hot Side Outlet Temperature 7220E clean, nob ass
Maximum Expected Heat Transfer Rate -1,879,000 BTU/hr
Maximum Expected Heat Transfer -65%
Effectiveness
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 5.0 psig (PSV included)
Cold Side to Hot Side
Cold Side Bypass Wafer Style Butterfly Valves
Rectangular Louver Dampers
Hot Side Bypass Refractory Lined with 330 Stainless Steel
Metal Internals
Carbon Steel Housing
Flame Arrestor Stainless Steel Element
Prote o orequal
Oxygen Analyzer Rosemount orequal
Area Lighting Not Included
Factory Mounting Pre-piped and Pre-wired to maximum extent
practical for shipping
30ft X 40ft
Approximate Equipment Footprint Note: Footprint dimensions may be altered to
fit available space. Includes all fans and
exhaust stack
Approximate Equipment Total Dry Weight 55,000 Ibs
16

Confidential GCES Proposal No. 2225-21 Rev.4
Archaea-MODEL TRO-65-60-100
SECTION 5: RESPONSIBILITY MATRIX
Work Item Owner GCES O tional Remarks
Building permits
EPA permits
Taxes
Temporary utilities
Daily job site clean-up With O tional Installation
Building alterations /wall penetrations If required
Temporary storage area on-site If required
Demolition and disposal work If required
Lifting equipment for installation —
cranes, forklifts, etc.
Footings and foundations With arounding arij
Structural support steel N/A
Fuel Gas Piping To connection point on GCES
Equipment
Compressed air piping To connection point on GCES
Equipment
Fire rotection If required
Power feed To connection point on GCES
Equipment
Process interlock wiring to plant
Engineering and fabrication of the
abatement equipment as described in X
the Technical Section
Freight Pre-pay &Add
FCA Conroe, TX
Installation —GCES supplied
equipment only
Installation —outside of battery limits
Installation supervision X
Commissioning & Start-up X
Operator training X
Factory Functional Testing X
Quality Assurance X As defined by GCES Section 7.3
Compliance Testing
Spare parts Defined during the engineering hase
Maintenance and operating manuals X One 1 electronic copy, English only
Record mechanical and electrical X One (1) electronic copy, English only
drawings
17

Confidential GCES Proposal No. 2225-21 Rev-4
Archaea - MODEL TRO-65-60-100 (o
SECTION 6: DOCUMENTATION, SERVICES, & CLARIFICATIONS
6.1 Review & Approval of Documentation
As project activities must continue to progress, in order to meet cost & schedules objectives, project
documentation is considered "Approved As Submitted" if review comments are not received within
seven (7) calendar days of submittal.
6.2 Surface Painting & Preparation
All carbon steel, which is not galvanized or aluminized, shall be treated and coated in the paint system
specified by Archaea utilizing Sherwin William Envirolastic 940 LV basecoat and Sherwin Williams
SW 9035 "Frosted Emerald" color. Stainless steel, plastic, and other finishes shall not be painted.
Purchased components will be coated per the OEM standard paint system and color.
6.3 Quality Assurance
GCES shall assemble the system in the factory to the greatest extent reasonable, considering system
size and configuration, to inspect fit-up of the major structures. A full test of the control panel according
to GCES testing standards is performed before shipment of the equipment. Safeties, controls, and
components which may be pre-wired for shipment are verified through operation as functionally correct
and calibrated during internal pre-commissioning. The customer is always welcome and
recommended to visit during shop pre-commissioning of the control panel.
With standard GCES internal pre-commissioning, the unit may not be operated completely.
Components which cannot be practically pre-wired for shipment will not be operated. Other testing
options, if required, are available. Any additional testing procedures outside of GCES standard
procedures may occur additional costs and impact project schedule.
6.4 Standards & Codes
Equipment manufactured by GCES complies with the U.S. applicable sections of the Occupational
Safety and Health Act (OSHA), National Fire Protection Association (NFPA), National Electric Code
(NEC), and National Electric Manu. Assoc. (NEMA).
18

Confidential GCES Proposal No. 2225-21 Rev.4 (OP
-MODEL TRO-65-60-100
6.5 GCES Project Clarifications — Customer's Responsibility
The following items are excluded from the GCES offering and shall require completion by others
unless otherwise specified:
• Modifications, retrofitting, removal, or cleaning of any equipment or component existing or
provided by others.
• Responsibility and costs associated with unloading, storing, handling, and installing the
equipment on site at final location. This includes providing materials required for site
installation — conduit, wiring, piping, etc. to interconnect the system components once it
reaches final mechanical assembly.
• Purchaser must provide process gas and all utilities to the point of utilization according to
the design drawings — includes, but not limited to, instrument quality and compressed air
(-20°F dew point), main switch gear and power plant distribution, electricity power, Ethernet
/ phone line(s), natural gas, water, and main gas meter and regulator.
• Purchaser is responsible for interconnecting wiring between the Control Panel and Field
Instrumentation, unless GCES is selected for installation. If the panel is to be located far
away from the abetment system please notify GCES as this may require an adjustment to
installation scope.
• Temporary utilities, restrooms, and work area for GCES field service engineer if required.
• Surge and lightning protection or transformers.
• Any and all compliance testing by third party shall be purchaser's responsibility.
• Purchaser shall obtain all the necessary construction and operation permits as may be
required.
• Any VAT, state, local, or federal sales tax, insurance, bonding, or duty associated with the
project or equipment.
• A secured location under lock and key for GCES tools and materials used for installation
and commissioning provided in a convenient area close to the installation location.
• At a minimum GCES must supervise installation and be present for commissioning to verify
proper equipment operation and for validation of the factory warranty.
19

Confidential GCES Proposal No. 2225-21 Rev.4
Archaea- MODEL TRO-65-60-100
SECTION 7: Attachments
Please find and review the following attachments.
Field Service Rate Sheet
Warranty Information
General Terms & Conditions of Sale
Preliminary Flow Schematic Drawing
Preliminary General Arrangement Drawing
20

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A GCES Custom Solution Utilizing
A Candlestick Flare (CSF) System
For the Abatement of Waste Gas
From an Archaea 6,400 SCFM V1 Plant
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1689 Hawthorne Drive
Conroe, Texas 77301 '
832.476.9024
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Gulf Coast Environmental
Systems v •.
h

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea - MODEL FL-196
Customer Emily Zambuto
Scott Beck
Kevin Weatherford
Address 500 Technology Drive, Upper Floor
Canonsburg, PA 1531
Company I Archaea Energy
Telephone 1 +1 [phone]
E-Mail I ezambutot(@archaea.energy
sbeck(c-archaea.energy
kweatherford(cD-archaea.energy
Date I February 25th, 2022
Proposal Number 1 2279-21 Rev.1
Proposed Solution I Candlestick Flare for 6,400 SCFM V1 Plant
i
1r
i
Reference Only-Actual may Vary
Your Application Engineer Your Sales Representative
James Smith Cary Allen
Sr. Application Engineer Technical Director
jsmithCa),gcesytems.com callen(aDgcesystems.com
832.370.0358 832.374.5089
2
Confidential Information
All drawings, specifications, technical data, including this proposal, and other information we provide, is considered confidential, and the
exclusive and proprietary property of Gulf Coast Environmental Systems LLC (GCES). 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 GCES.

TABLE OF CONTENTS
SECTION 1: EXECUTIVE SUMMARY...........................................................................................4
1.1 THEORY OF OPERATION.........................................................................................................................4
1.2 PROPOSAL OVERVIEW...........................................................................................................................5
SECTION2: COMMERCIAL..........................................................................................................6
2.1 PRICING AND OPTIONS..........................................................................................................................6
2.2 TYPICAL PROJECT SCHEDULE ...................................................................................................................7
SECTION 3: DESIGN CONSIDERATIONS....................................................................................8
3.1 PROCESS DATA....................................................................................................................................8
3.2 OPERATING CONDITIONS........................................................................................................................9
3.3 UTILITIES............................................................................................................................................9
3.4 ESTIMATED EMISSIONS........................................................................................................................ 10
3.5 PERFORMANCE GUARANTEE PROVISIONS................................................................................................. 10
SECTION 4: EQUIPMENT SPECIFICATIONS.............................................................................11
4.1 CANDLESTICK FLARE............................................................................................................................ 11
SECTION 5: RESPONSIBILITY MATRIX.....................................................................................13
SECTION 6: DOCUMENTATION, SERVICES, & CLARIFICATIONS ..........................................14
6.1 REVIEW&APPROVAL OF DOCUMENTATION............................................................................................. 14
6.2 SURFACE PAINTING&PREPARATION ...................................................................................................... 14
6.3 QUALITY ASSURANCE.......................................................................................................................... 14
6.4 STANDARDS&CODES......................................................................................................................... 14
6.5 GCES PROJECT CLARIFICATIONS-CUSTOMER'S RESPONSIBILITY...................................................................15
SECTION 7: ATTACHMENTS......................................................................................................16
PRELIMINARY GENERAL ARRANGEMENT........................................................................................................... 16
RADIATIONDIAGRAM..................................................................................................................................16
FIELDSERVICE RATE SHEET............................................................................................................................ 16
WARRANTYINFORMATION ........................................................................................................................... 16
GENERAL TERMS&CONDITIONS OF SALE......................................................................................................... 16

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea- MODEL FL-196
SECTION 1 : EXECUTIVE SUMMARY
1.1 Theory of Operation
Candlestick Flares
The method of reduction of Volatile Organic Compounds (VOCs) in a Flare revolves
around thermal destruction. The VOCs and other flammable substances in the process
stream are converted to various combinations of carbon dioxide (CO2), water vapor
(H20), and thermal energy by the high temperature of the main flame. As process gas is
used to fuel the main flame a natural draft is created in the burner tip that draws in the
required air for combustion. In an open tip "candlestick" flare the main burner is placed
at the top of an elevated stack. The height of the stack is dictated by the maximum
allowable heat radiated by the flame to ground level. A shroud is often included around
the burner tip to provide a degree of protection to the main flame from the wind.
During system start-up the pilot gas solenoid valve is opened to allow natural gas to the
pilot assembly and the spark igniter, located at ground level, is pulsed to light the flame
front generator(FFG). The FFG sends a burst of flame up to the pilot tip to light it. Once
the pilot flame is detected, a signal is sent to the PLC to initiate the main flame light off
sequence. The process gas isolation valve is opened, and the main flame is established
and detected via a thermocouple. The continuous pilot remains on during operation to
help ensure main flame stability under turndown conditions. Upon main flame loss
automatic re-ignition will occur from the continuous pilot. If main flame prove does not oil
occur within a specified period of time the flare will shut down and trigger a system alarm
to notify the operator of shutdown.
WIND
I
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I
I
x
tG A'S
Flare Burner Tip Example (actual may vary)
4

Confidential GCES Proposal No. 2279-21 Rev.1 ��
Archaea -MODEL FL-196
1.2 Proposal Overview
This proposal details the supply of one (1) Candlestick Flare with installation supervision and
commissioning services included. The system shall be capable of treating up to 7,040 SCFM of waste
gas at 52% methane by volume, or—196 MMBTUH of process heat release.
In this revision, Rev.1 of the proposal, the overall flare height has been increased based on
discussions with Archaea. The new height reduces maximum ground level radiation from the flare to
approximately 500 BTUH/ft2 for a maximum allowable surface temperature of 260°F. The inlet
detonation arrestor size & arrangement has also been updated to provide a more economical design.
5

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea- MODEL FL-196
SECTION 2: COMMERCIAL
2.1 Pricing and Options
Equipment Price
Item 1: Base Bid — Each Unit
Design and Supply of one (1) Candlestick Flare system, GCES model: $ 284,700.00 USD
FL-196 as described in this proposal. FCA Houston, TX
Field Services & Freight
Item 2: Site Supervision, Commissioning, & Start-up Assistance
GCES onsite supervision for the installation and commissioning of Item 1. Included
Limited to 3 days onsite, 8-hour business days. Additional time shall be
billed according to the applicable service rates.
Item 3: Freight
Estimated freight to jobsite; Pre-paid and added TBD
Optional Additions
Item 4: Class I Div. II Hazardous Area Upgrade
Upgrade all electrical instrumentation on the unit to be rated for use in a $ 7,000.00 USD
Class I Div. II, Gr. C & D hazardous area or better. Control panel is
expected to be installed off of the main skid and remains unclassified.
6

Confidential GCES Proposal No. 2279-21 Rev.1 ��Archaea -MODEL FL-196
2.2 Typical Project Schedule
Drawings: Submission of Top-Level Drawings (3D Model, General Arrangement, P&ID, &
Foundation Loading Diagram) 4-6 weeks after receipt of order & initial deposit
Ready to ship: 14-16 weeks after approval of Top-Level Drawings
Installation: <1 week after delivery to site
Notes:
• Lead time may vary based on the timing of an order. GCES will confirm project schedule within
two weeks of order placement and deposit.
• Lead time does not consider hold points, document reviews, additional inspections, or any other
customer originated considerations during the execution of the oxidizer design / build process.
• Project expediting options may be available. Consult your sales representative for further details.
• Lead time may be impacted by supply chain disruptions, including production, transportation,
inventories and others related directly or indirectly to COVID-19. Such disruptions shall be
considered Force Majeure. GCES will work diligently to minimize and mitigate the effects of such
disruptions.
7

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea-MODEL FL-196
SECTION 3: DESIGN CONSIDERATIONS
3.1 Process Data
Application: Raw Landfill Gas
Maximum Process Volume: 7,040 SCFM
Process Gas Inlet Temperature: <140°F
Process Gas Inlet Pressure: Up to 16.5 psia -2 si
**Process Gas Maximum Methane Concentration: 52% by volume
Approximate Maximum Heat Release: 195.9 MMBTU/hr
Application: Product Gas
Maximum Process Volume: 3,905 SCFM
Process Gas Inlet Temperature: <140°F
Process Gas Inlet Pressure: Up to 16.5 psia -2 si
**Process Gas Maximum Methane Concentration: 83% by volume
Approximate Maximum Heat Release: 173.4 MMBTU/hr
Application: Off-Spec Gas
Maximum Process Volume: 1,585 SCFM
Process Gas Inlet Temperature: <140°F
Process Gas Inlet Pressure: Up to 16.5 psia -2 si
**Process Gas Maximum Methane Concentration: 97% by volume
Approximate Maximum Heat Release: 164.3 MMBTU/hr
Application: TSA Blowdown
Maximum Process Volume: 400 SCFM
Process Gas Inlet Temperature: <140°F
Process Gas Inlet Pressure: Up to 16.5 psia -2 si
*"Process Gas Maximum Methane Concentration: 52% by volume
Approximate Maximum Heat Release: 11.1 MMBTU/hr
*The overall design is primarily dictated by flare mode #1 as this is when the maximum flow rate and
heat release occur. It is assumed that none of the modes occur simultaneously.*
**For design purposes the balance of composition is assumed to be inert with no oxygen. 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 combusted
are expected to have auto-ignition temperatures of approximately 1,000°F or less.**
***The operating range for a self-sustained flame is 704 - 7,040 SCFM (10% turndown). With
continuous pilot operation lower flow rates are acceptable although the flame may not always be
visible from ground level. Continuous pilot operation is required for consistent operation across the full
range of possible operating conditions.***
8

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea-MODEL FL-196
3.2 Operating Conditions
Equipment Location: Outdoors
Control Panel Location Outdoors on the oxidizer skid
Site Location Elevation: <1,000 ft ASL
Electrical Area Classification: Standard -General Purpose
Optional - Class I Div. II
Wind Load Design: 115 MPH
Category II Site Class D
Seismic Design: SS = 0.474
S 1 = 0.155
Maximum Rated Process Gas Turndown 10% of maximum design flow rate"
Capacity for Self-Sustained Flame:
Maximum Ground Level Radiation from Flare: From Flare: 500 BTUH/ft2
From Solar: 300 BTUH/ft2
Maximum Expected Surface Temperature: 260°F located 27ft from flare with a 20
mph wind
*Note: Lower process gas flow rates are possible with a continuous pilot.
3.3 Utilities
Natural Gas Requirement 400 SCFH @ 10 psig pressure
Installed Capacity for Pilot & FFG : LHV = -1,000 btu/SCF
Estimated Natural Gas Usage 200 SCFH
Continuous Pilot):
Electrical Supply Voltage: 120V/60Hz/ 1 Phase
Estimated Electrical Power Consumption: -2 kW at maximum capacity
Compressed Air Supply: 80 psig @ -20OF dew point
Estimated Compressed Air Usage: 2 CFM peak; <1 CFM average
9

Confidential GCES Proposal No. 2279-21 Rev.1 (op
- MODEL FL-196
3.4 Estimated Emissions
Methane & VOC Destruction Efficiency: 86-99%
Total NOx Emissions (as NO2): 39 lb / 106 DSCF CHa (or -0.04 Ib/MMBTU)
Carbon Monoxide Emissions: 46 lb / 106 DSCF CH4 (or -0.05 Ib/MMBTU)
Estimates are based on AP-42 Section 2.4 references for control efficiency and emission factors for
flares. They are provided for reference only. These factors are acceptable with the following
provisions:
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.
3.5 Performance Guarantee provisions
- The unit is installed (if applicable), operated and maintained by Buyer in accordance with GCES
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. GCES must be notified in writing 14
days prior to the tests for scheduling purposes.
- GCES reserves the right to adjust the burner chamber operating temperature and any other
settings as required to meet the guarantees.
- If GCES fails to meet the Performance Guarantee, GCES must be given reasonable time to
investigate and take corrective action within the scope of this contract.
10

Confidential GCES Proposal No. 2279-21 Rev.1 (OP
-MODEL FL-196
SECTION 4: EQUIPMENT SPECIFICATIONS
This proposal is based on preliminary engineering intended to achieve the performance goals. GCES
reserves the right to alter component selections during project engineering.
4.1 Candlestick Flare
General Requirement GCES Provision
Burner Tipeight: 57 It above grade
Maximum Rated Discharge Velocity: 3,600 ft/min
Shroud Diameter: 32"0
Shroud Overall Height: 36"
Shroud Height Above Tip Discharge: 18"
Stack Diameter: Lower Section: 42"0 X 49ft Tall
Upper Section: 20"0 X 8ft Tall
Lower Stack Section: Carbon Steel
Materials of Construction Upper Stack Section: 304 Stainless Steel
Burner Tip: 310 Stainless Steel
Wind Shroud: 310 Stainless Steel
Other Features Free Standing
Number of Pilots One 1
Capacity of Each Pilot 200,000 BTU/hr continuous
Pilot Ignition 7 Spark Ignited Flame Front Generator(FFG)
Mounted at Ground Level
Flame Detection Type "K" Thermocouple
For Each Pilot & Main Flame
Pilot Fuel Train Design Standard NFPA 86
Pilot Fuel Train Expected Line Size '/2" NPT
FFG Expected Line Size 2" NPT
Connection Size /Type 18" Flanged, ANSI Class 125 or better
Two (2) Total
Process Isolation Valve(s) Butterfly Valve w/SS Disk &Viton Seat
Pneumatic Actuator- On/Off Fail Closed
Two (2)Total— 12" Connection Size Each
Protego or equal
Flame Arrestor Carbon Steel Element
Stainless Steel Element
Dwyer Capsuhelic Differential Pressure
Gauge across the element
Inlet Temperature Measurement Type "K" Thermocouple
Inlet Pressure Measurement Pressure Transmitter
11

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea-MODEL FL-196
Control Panel Type NEMA 4X—Outdoor Rated
To be located off of the main skid
O erator In Allen BradleyPanel View orequal
Control Panel Standard UL508a
Programmable Logic Controller PLC Allen Bradley Com actLo ix orequal
Burner Management System (BMS) Siemens orequal
Communications Connection Ethernet Switch
Voltage Main 480 VAC /3 phase/60 Hz
Control 120 VAC/ 1 phase/60 Hz (via GCES
supplied transformer
Area Lighting Not Included
Factory Mounting Pre-piped and Pre-wired to maximum extent
practical for shipping
1011 X 20R
Approximate Equipment Footprint Note: Footprint dimensions may be altered to
fit available space. Includes stack and inlet
skid.
Approximate Equipment Total Dry Weight 15,000 Ibs
12

Confidential GCES Proposal No. 2279-21 Rev.1 Archaea-MODEL FL-196
SECTION 5: RESPONSIBILITY MATRIX
Work Item Owner GCES O tional Remarks
Building permits
EPA permits
Taxes
Temporary utilities
Daily job site clean-up
Building alterations/wall penetrations If required
Temporary storage area on-site If required
Demolition and disposal work If required
Lifting equipment for installation —
cranes, forklifts, etc.
Footings and foundations With grounding grid
Structural support steel N/A
Fuel Gas Piping To connection point on GCES
Equipment
Compressed air piping To connection point on GCES
Equipment
Fire protection If re uired
Power feed To connection point on GCES
E ui ment
Process interlock wiring to plant
Engineering and fabrication of the
abatement equipment as described in X
the Technical Section
Freight Pre-pay &Add
FCA Houston, TX
Installation —GCES supplied
equipment only
Installation —outside of battery limits
Installation supervision X
Commissioning & Start-up X
O erator training X
Factory Functional Testing X Onl FFG & pilot(s) ignited
Quality Assurance X As defined by GCES Section 6.3
Compliance Testing
Spare parts Defined during the engineering hase
Maintenance and operating manuals X One 1 electronic copy, English only
Record mechanical and electrical X One (1) electronic copy, English only
drawings
13

Confidential GCES Proposal No. 2279-21 Rev.1
Archaea-MODEL FL-196
SECTION 6: DOCUMENTATION, SERVICES, & CLARIFICATIONS
6.1 Review & Approval of Documentation
As project activities must continue to progress, in order to meet cost & schedules objectives, project
documentation is considered "Approved As Submitted" if review comments are not received within
seven (7) calendar days of submittal.
6.2 Surface Painting & Preparation
All carbon steel, which is not galvanized or aluminized, shall be treated and coated in the paint system
specified by Archaea utilizing Sherwin William Envirolastic 940 LV basecoat and Sherwin Williams
SW 9035 "Frosted Emerald" color. Stainless steel, plastic, and other finishes shall not be painted.
Purchased components will be coated per the OEM standard paint system and color.
6.3 Quality Assurance
GCES shall assemble the system in the factory to the greatest extent reasonable, considering system
size and configuration, to inspect fit-up of the major structures. A full test of the control panel according
to GCES testing standards is performed before shipment of the equipment. Safeties, controls, and
components which may be pre-wired for shipment are verified through operation as functionally correct
and calibrated during internal pre-commissioning. The customer is always welcome and
recommended to visit during shop pre-commissioning of the control panel.
With standard GCES internal pre-commissioning, the unit may not be operated completely.
Components which cannot be practically pre-wired for shipment will not be operated. Other testing
options, if required, are available. Any additional testing procedures outside of GCES standard
procedures may occur additional costs and impact project schedule.
6.4 Standards & Codes
Equipment manufactured by GCES complies with the U.S. applicable sections of the Occupational
Safety and Health Act (OSHA), National Fire Protection Association (NFPA), National Electric Code
(NEC), and National Electric Manu. Assoc. (NEMA).
14

Confidential GCES Proposal No. 2279-21 Rev.1 7)
Archaea- MODEL FL-196
6.5 GCES Project Clarifications — Customer's Responsibility
The following items are excluded from the GCES offering and shall require completion by others
unless otherwise specified:
• Modifications, retrofitting, removal, or cleaning of any equipment or component existing or
provided by others.
• Responsibility and costs associated with unloading, storing, handling, and installing the
equipment on site at final location. This includes providing materials required for site
installation — conduit, wiring, piping, etc. to interconnect the system components once it
reaches final mechanical assembly.
• Purchaser must provide process gas and all utilities to the point of utilization according to
the design drawings — includes, but not limited to, instrument quality and compressed air
(-20°F dew point), main switch gear and power plant distribution, electricity power, Ethernet
/ phone line(s), natural gas, water, and main gas meter and regulator.
• Purchaser is responsible for interconnecting wiring between the Control Panel and Field
Instrumentation, unless GCES is selected for installation. If the panel is to be located far
away from the abetment system please notify GCES as this may require an adjustment to
installation scope.
• Temporary utilities, restrooms, and work area for GCES field service engineer if required.
• Surge and lightning protection or transformers.
• Any and all compliance testing by third party shall be purchaser's responsibility.
• Purchaser shall obtain all the necessary construction and operation permits as may be
required.
• Any VAT, state, local, or federal sales tax, insurance, bonding, or duty associated with the
project or equipment.
• A secured location under lock and key for GCES tools and materials used for installation
and commissioning provided in a convenient area close to the installation location.
• At a minimum GCES must supervise installation and be present for commissioning to verify
proper equipment operation and for validation of the factory warranty.
15

Confidential GCES Proposal No. 2279-21 Rev.1 (OP
- MODEL FL-196
SECTION 7: Attachments
Please find and review the following attachments.
Preliminary General Arrangement
Radiation Diagram
Field Service Rate Sheet
Warranty Information
General Terms & Conditions of Sale
16

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FLAME CENTER W/20 mph WIND
�27'
5'
FLAME RADIATION DIAGRAM
FLARE TIP 6400 scfm FLARE DESIGN
GULF COAST ENVIRONMENTAL
END USER — ARCHAEA
57'
20" DIA FLARE
MAX HEAT RELEASE = 195.9 MM BTU/hr
RsolaMAX RADIATION POINT = 500
Rflame lame = 500
AT GROUND LEVEL Rtotal = 800
Tsa 260'F
27'
CUSTOMER: GULFCOAST ENVIRONMENTAL
UCC JOB NO.: TBD
UNIVERSAL COMBUSTION CORPORATION
8312 SOUTH 75th EAST AVENUE
TULSA, OKLAHOMA 74133
FLAME RADIATION DIAGRAM
6400 scfm FLARE DESIGN
7 7P
� 7'2N20
DM 1/zo/22 NTS —FRD-02 1

OCT) Gulf Coast Environmental
Systems
Doc. No. .. GCES-INTFSR
2022 INTERNAL FIELD SERVICE RATES Rev. No. ..2022-0
Date: ........ February 14, 2022
Gulf Coast Environmental Systems is pleased to offer field service on OEM and non-OEM systems. Our highly-trained,
experienced field service staff is ready to service,inspect and maintain your equipment. To schedule service,contact us at:
Phone: .......................+1 [phone] Fax:................+1 [phone]
E-Mail:......................servicena,gcesystems.com
Applicable Field Service Rates
ID Description Rate Comments&Additional Information
1. Normal Service Rates Up to 8 hours per day(M-F, non-holidays)
1.2 Technician _ _- $572.00 per day $107.25 per hour for over 8 hours
1.3 Senior Technician $669.00 per day..--.. $125.50 per hour for over 8 hours
1.4 Engineer $880.00 per day _ $165.00 per hour for over 8 hours
2. Saturday & Emergency Rates Up to 8 hours per day(Saturdays, emergency calls)
2.1 Technician $858:00 per daY $161.09 per hour for over 8 hours
2.2 Senior Technician $1,003 25 per dam________ $188.225 er hour for_over 8 hours
2.3 $Engineer 1,320.00 erda g' _ _ _ per day per hour for over 8 hours
3. Sunday &Holiday Rates Up to 8 hours per day(Sundays, holidays)
3.1 Technician $1,144.00 per day $214.50 per hour for over 8 hours
3.2 Senior Technician $1,337.75 per day $251.00per hour for over 8 hours
3.3 Engineer --------- -._
$1,760.00 per da r� $330.00 Per hour for over 8 hours _
4. Meals& Misc. Expenses
4.1 Per Diem (per man) $100.00 per day (maybe modified higher by location) -
5. Travel
5.1 Travel Time(USA) Per applicable rates
above
5.2 Travel & Duration of Stay Cost+ 10% Airfare, rental car, motel, etc.
Expenses _ Business class will be used for flights over 8 hours
5.3 Mileage Rate $0.645 per mile
6. Other
6.1 Equipment Rentals,Supplies Cost+ 10%
and Buyout Items
Data,prices and terms subject to change without notice.
PROPRIETARY INFORMATION • COMPETITION SENSITIVE DO NOT DUPLICATE By:.... ......................... C. Clark
Gulf Coast Environmental Systems - 1689 Hawthorne,Conroe,TX 77301 USA - 832-476-9024 Page:...............................1 of 2

4�7Gulf Coast Environmental
Systems
Doc. No. ..GCES-INTFSR
2022 INTERNAL FIELD SERVICE RATES Rev. No. ..2022-0
Date: ........February 14, 2022
Special Terms & Conditions for Service Rates
1. Payment Terms: 100%upon completion of Service Work
2. All amounts shown and all payments are in United States Dollars(USD)
3. All payments are due upon receipt of invoice,unless other arrangements are made in advance in writing.
4. The prices presented do not include any taxes(federal,state,and local).
5. Any import and/or customs duties,tariffs, fees,etc.will be the responsibility of the Customer.
6. Upon reasonable start-up notice(minimum two weeks),Gulf Coast Environmental Systems will furnish appropriate field
service personnel at the above rates,plus travel and living expenses.
7. Service with less than reasonable notice will be charged at the Emergency Rates shown above.
8. Service rates are based on the above table and are applicable from the time service personnel leave their home base until
their return thereto.
9. Travel and living expenses will be charged at actual cost plus a 15%handling fee.
10. Extended remote support(e.g.telephone,e-mail,text,etc.and lasting more than an hour and/or 2-3 calls per incident)will
be billed at the rates shown. Reasonable remote support (e.g. typically less than 1 hour per incident) will normally be
provided a no cost.
11. This service is provided with no warranties either expressed or implied; all implied warranties are explicitly disclaimed.
GCES agrees only to provide a competent technician,familiar with the Company's or similar equipment,with no guarantee
of any nature.No liability for any accident,consequential,special,or indirect damage,or loss whatsoever is implied with
this service and the parties agree GCES may and does explicitly disclaim same. Any repaired or replacement component
provided shall be warranted strictly per Section 7, if and as applicable.
12. Customer shall supply equipment in a safe condition,ready for work to commence.This includes cooling down to ambient
temperature,purging the equipment as necessary,necessary lock-out/tag-out of equipment in place and other preparations
as required.
13. Customer shall fully advise of any and all site safety,documentation or other requirements with sufficient advance notice
to reasonably accommodate such requirements.
14. If Customer does not stock recommended spare parts, standby time and/or additional mobilization/demobilization costs
may be charged while waiting on parts,and expedited processing,shipping and handling charges may be applicable.
15. Sharing of expenses when service personnel provide service to more than one customer on a single trip will be at the
GCES' option. The intent of this policy is to permit the GCES to provide the most expedient service possible at the lowest
cost to its customers.
16. These rates and policies described are subject to change at the Company's option and without prior notice. All quotations
for field service will be honored at the quoted prices during the stated life of the quotation, and all contracts in effect are
subject to renegotiation after one year.
17. Warranty service requires prior written authorization from GCES.
18. Reasonable supporting documentation will be provided with invoices for travel and extraordinary expenses such as airfare,
hotel receipts and receipts for rentals or other such expenses. No documentation will be provided for expenses covered
under per diem or miscellaneous per day charges.
19. Customer shall supply reasonable assistance with securing/providing local transportation and lodging.
20. Customer shall provide reasonable protection and provide for the adequate safety of GCES' personnel when in-country.
PROPRIETARY INFORMATION . COMPETITION SENSITIVE . DO NOT DUPLICATE By:.............................. C. Clark
Gulf Coast Environmental Systems . 1689 Hawthorne,Conroe,TX 77301 USA • 832-476-9024 Page:...............................2 of 2

Gulf Coast Environmental Systems LLC
6515 Willowbrook Park
Houston, TX 77066
Phone: [phone]
Gulf Coast Environmental Fax: [phone]
Systems
WARRANTY INFORMATION
LIMITED WARRANTY
All warranties of any nature, express or implied, not explicitly set forth in this Section 7 are hereby explicitly
disclaimed, including, without limit, the implied warranties of merchantability and fitness for a particular
purpose.
Systems manufactured by Gulf Coast Environmental Systems are warranted, to the original user only, to be
free of material defects in material and workmanship for a period of 12 months from the date of shipment. A
written claim for warrantied service and supporting material described herein must be received within such
period to be valid. No warranty herein is transferrable; any attempted transfer will be void ab initio.
Gulf Coast Environmental Systems' liability under this warranty shall be limited to repair or replacement at Gulf
Coast Environmental Systems' option, without charge, of products and/or systems manufactured by Gulf
Coast Environmental Systems. Gulf Coast Environmental Systems shall not be liable for any costs associated
with removal, installation, transportation, insurance, or any other charges which may arise in connection with
the warranty claim unless explicitly provided for herein. Products or components thereof which are not
manufactured by Gulf Coast Environmental Systems are subject to the warranty provided by the manufacturer
of said products, if any, which are hereby assigned to Buyer (if and to the extent permitted thereby) without
recourse to Seller, and not covered by Gulf Coast Environmental Systems' warranty. Gulf Coast
Environmental Systems will not be liable for damage or wear to products caused by abnormal operating
conditions, accident, abuse, misuse, unauthorized alteration or repair, combination with or use alongside
products or components not intended therefor, improper maintenance, or installation or operation not in
accordance with Gulf Coast Environmental Systems' printed installation and operating instructions. Nor shall
Gulf Coast Environmental Systems have any liability for damage arising from normal wear and tear, including
(without limit) corrosion.
To obtain service under this warranty, the defective product or component thereof must be returned to Gulf
Coast Environmental Systems from the original purchaser together with proof of purchase, job number,
installation date, failure date, and supporting installation data. Any defective product to be returned to Gulf
Coast Environmental Systems must be sent freight prepaid along with documentation supporting the warranty
claim and the issued Return Material Authorization.
GULF COAST ENVIRONMENTAL SYSTEMS WILL NOT BE LIABLE FOR ANY INCIDENTAL, INDIRECT,
SPECIAL, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL DAMAGES, LOSSES OR EXPENSES ARISING
FROM DESIGN, MANUFACTURE, ASSEMBLY, INSTALLATION, COMMISSIONING, TRAINING,
TROUBLESHOOTING, WORK PERFORMED PURSUANT TO WARRANTY, USE, PERFORMANCE OR
NON-PERFORMANCE HEREUNDER, OR ANY OTHER CAUSES.
Any attempt to repair, replace, correct, or diagnose any real or alleged defect by any person other than Gulf
Coast Environmental Systems will void the warranty unless authorized in writing in advance by Gulf Coast
Environmental Systems.
Custom-engineered systems manufactured by Gulf Coast Environmental Systems are factory tested. Caution:
Field utilities such as power and gas supplies may differ from those utilized during shop testing. A
GCES field engineer should verify and inspect the final installation and all utilities prior to start-up and
commissioning of the system.

ITEMS WHICH MAY AFFECT THE SYSTEM WARRANTY INCLUDE, WITHOUT LIMIT:
• Failure to have GCES personnel on site to perform or supervise installation, commissioning, and start-
up services may result in permanent equipment failure and may void the system warranty.
• Use of any system or component thereof in a manner or setting other than as intended by Gulf Coast
Environmental Systems, or with components other than as provided or authorized by Gulf Coast
Environmental Systems, may void any related warranty.
• Field modifications and/or changes made to the system without prior written approval by Gulf Coast
Environmental Systems may void the warranty of the system.
• Any act or omission contrary to this Section 7.
WARRANTY GUIDELINES
Customer must obtain a Return Material Authorization prior to returning any parts or systems as outlined in the
O&M Manual.
Items must be returned freight prepaid to GCES. GCES may not accept any returns freight collect unless we
have given written pre-approval. Return freight will be the responsibility of the customer. Customer shall bear
all risk of loss for any product or component shipped to or from Gulf Coast Environmental Systems, and in its
custody or control, pursuant to any warranty claim. To the extent customer desires insurance coverage during
such period(s), customer may obtain same at its own expense.
Customer must understand that we will evaluate the product in question to determine if it is a warranty
consideration. Equipment not manufactured by GCES is subject to the manufacturer's warranty, if any. Their
specific warranty policy must be followed.
PERFORMANCE WARRANTY
Unless otherwise stated, the equipment proposed is specifically designed for and warranted exclusively in
connection with the design specifications as shown in Gulf Coast Environmental Systems' design
considerations section and only for the attainment of said design specifications. Unless otherwise stated,
performance is based on sea-level conditions.
The Purchaser hereby approves and accepts responsibility for the correctness of the design specifications,
whether furnished by Purchaser, GCES, or a third party, concerning the conditions under which the equipment
is required to perform and upon which GCES has based the operating conditions of the equipment. Proof,
satisfactory to GCES, of failure of the equipment to meet the performance warranty must be made in writing
and delivered by the Purchaser or sent by registered mail to GCES within forty-five (45) calendar days after
the equipment is first installed and in any event, not later than one year from date of shipment by GCES.
In the event that proof, satisfactory to GCES, that the equipment failed to meet GCES's performance warranty,
is timely submitted as above, it is agreed that GCES may at its own expense and with due diligence make any
changes or additions to GCES's equipment which GCES may deem necessary to endeavor to enable the
equipment to meet the performance warranty. Whether any product or component failed to meet its respective
performance warranty shall be determined by the average of three tests thereof under the same or similar
conditions. Purchaser agrees to make the equipment available to GCES, at Purchaser's cost, for purposes of
enabling GCES to make any changes or additions to enable the equipment to meet the performance warranty
and failure of Purchaser to so make the equipment available for changes or additions shall constitute a waiver
of the performance warranty. Failure to furnish within the time specified above proof of failure of equipment to
meet performance warranty or failure to notify GCES of intent to schedule a performance test as hereinafter
specified shall constitute a waiver of the performance warranty.

If GCES, after making such changes, modifications and/or additions to GCES's equipment as it deems
desirable, is then unable to meet the explicitly warrantied specifications, it shall make adjustments with
Purchaser as are fair and mutually agreed to, but in no event shall GCES's obligation under the performance
warranty exceed the amount of the purchase price theretofore paid less expenditures for changes,
modifications and/or additions to GCES's equipment made under this warranty provision. This shall be
Purchaser's sole and exclusive remedy, and the limit of GCES' aggregate liability, for failure of the equipment
to meet the design specifications.
Performance warranty made by GCES shall not be construed so as to require GCES's obtaining of permits,
licenses or approval from or equipment compliance with codes or regulations of any pollution control authority
or other government agency.
GCES SHALL NOT BE LIABLE FOR DAMAGE CAUSED BY AND THE PERFORMANCE WARRANTY
WILL VOIDED DUE TO: abrasion, corrosion or excess temperature, normal wear and tear, condensation of
gases from the process flow passing through the equipment reaching its dew point; improper erection by
others or operation contrary to directions issued by GCES; improper or insufficient maintenance or causes
beyond the control of GCES; vibration due to improper supports supplied by others for any portion of the
equipment; operation of the equipment under conditions different from those stated in the design
specifications; and any act or omission that would invalidate the limited warranty.
PERFORMANCE TEST
In the event that the Purchaser desires a test to determine the performance of the GCES's equipment to
design specifications then:
(a) Purchaser must indicate intent within forty-five (45) days of shipment of the equipment to conduct this
test via writing to GCES,
(b) The Purchaser shall give GCES at least fifteen (15) days notice in writing of the time and place
appointed for the tests, which time and place shall be mutually agreeable to GCES,
(c) Unless otherwise stated in the proposal, all test costs are to be at the Purchaser's expense including,
without limit, the cost of GCES's engineer at the current per diem rate plus traveling and living expenses from
place of residence and until return thereto,
(d) GCES's engineer is to have access to Purchaser's operating records for GCES's equipment at all
times and to have the cooperation of the Purchaser in establishing test guidelines or preliminary tests as are
deemed necessary,
(e) Performance tests shall be made in accordance with the current Federal EPA Test Code, or such other
basis as is mutually agreed upon between the Purchaser and GCES,
(f) If GCES supplies more than one identical unit, then tests are to be conducted on one representative
unit mutually agreed upon and if such tests show that unit meets design specifications, then all of the
equipment supplied shall be considered as meeting design specifications.
ENGINEERING SERVICES
Written instructions for erection, operation and maintenance of GCES's equipment are to be furnished by
GCES to the Purchaser. However, the price quoted herein does not include the services of an Engineer at the
plant of the Purchaser to instruct in either erection or operation, unless expressly stated in the proposal. Upon
reasonable notice, GCES will furnish an Engineer to act in an advisory capacity at the current per diem rate,
plus traveling and living expenses from his place of residence and until his return thereto. Purchaser shall have
complete control of the construction, erection, alteration, maintenance, repair and operation of the equipment
at the sale.

GENERAL TERMS & CONDITIONS OF SALE
1. Acceptance. This Proposal is subject to written acceptance by the Buyer within 30 days from the date hereof, and, if not
accepted within said period of time, this Proposal shall terminate. This Proposal shall become a binding contract if accepted by Buyer
within said period of time.
2. Delivery: Any statement relating to date of delivery or date of completion represents Seller's best estimate, but said date of
delivery or completion is not guaranteed. Delay shall not constitute grounds for cancellation or for damages. Unless otherwise herein
specified, the equipment shall be delivered F.O.B. point of manufacture.
3. Force Majeure:Seller shall not be liable for any loss or damage of any nature whatsoever incurred or suffered as a result of any
failures or delays in performance due to any cause or circumstances beyond its control, including, but not by way of limitation, any
failures or delays in performance caused by any strikes, lockouts or labor disputes, fires, acts of God or the public enemy, riots,
incendiaries, interference by civil or military authorities, compliance with the laws of the United States or with the orders or policies of
any governmental authority, delays in transit or delivery on the part of transportation companies or communication facilities or failures
of sources of raw material which are not due to Seller's neglect in placing orders or seeking alternate sources of raw material. In the
event of such delay, the time for delivery or completion shall be extended by a period of time equal to the period of delay plus such
time as needed for start-up and/or remobilization. In the event the Force Majeure situation shall extend longer than six months, then in
that event Seller shall, at its option, have the privilege of canceling the Contract. In such event, Buyer shall reimburse Seller for all
costs and expenses(including overhead costs)which Seller may have reasonably incurred in closing out the Contract, plus an amount
as reasonable profits on that portion of the Contract which has been completed.
4. Title and Risk of Loss:Title and risk of loss for the equipment shall pass to Buyer upon delivery of the equipment F.O.B. point
of manufacture or upon notice of completion of mechanical erection should Seller be responsible for performing erection. Title to and
risk of loss of the equipment shall pass to Buyer in no other way, notwithstanding any agreement to the contrary, including any
agreement to pay freight, express, or other transportation or insurance charges.
5. Payment: Terms of payment are net 30 days from date of invoice unless otherwise identified in the proposal. In the event
payment by the Buyer is not made when due, Buyer shall pay interest on any overdue amount at the rate of 1.5% per month from the
due date until payment without prejudice to any other rights of the Seller.
6. Taxes: Prices stated herein are exclusive of any taxes, excises, or other governmental charges applicable to the equipment
herein described. Seller's invoices shall include as a separate item, any and all taxes, excises or other governmental charges imposed
upon Seller by reason of its performance hereunder, except taxes based upon net income of Seller and/or privilege taxes. Buyer shall
pay all property and other taxes which may be levied, assessed or charged against or upon the equipment after the date of actual
shipment, or placing into storage for Buyer's account.
7. Warranties:Seller shall not be liable for damages (direct, indirect, consequential, special, punitive, exemplary, or otherwise) or
delay caused by defective material or workmanship; Buyer's sole remedy and Seller's sole aggregate liability therefor shall be
exclusively as set forth in Section 7.
8. Patent Infringement: Except for equipment manufactured by Seller based on specifications or drawings furnished by Buyer,
Seller shall, subject to the limitation of Section 17(c) hereof, defend at its expense any suit, action or proceeding brought against Buyer
based upon any claim that the equipment supplied hereunder infringes any United States patent which has been issued on or before
the date of Seller's Proposal and pay any damages and costs awarded therein against Buyer, if promptly notified by Buyer in writing of
such claim and given authority, information and assistance by Buyer(at Seller's expense)to conduct such defense. In lieu of defending
Buyer in such suit, action or proceeding, Seller may, at its expense and option, either procure for Buyer the right to use the equipment
or modify it so that it no longer infringes or replace it with non-infringing equipment. The foregoing constitutes the entire responsibility
and liability of Seller for patent infringement.

9. Changes: Buyer shall have the right during the progress of the work to request in writing, additional work, or deletion of any
work covered hereunder; provided, however, that such changes do not materially affect the scope of work, and provided that such
changes are not, in the Seller's judgment, inconsistent with sound engineering principals or the Seller's guarantees, warranties, and/or
responsibilities hereunder. If such changes result in any increase or decrease in the work to be performed by Seller, or the cost
thereof, or the cost of equipment and materials to be furnished by the Seller,the resulting change to the contract price shall be agreed
upon in writing before such changes are effected; provided, that Seller shall be entitled to continue the performance of its work
hereunder regardless of any proposed change until such agreement in writing is made. If such requests for changes and/or such
changes result in any delay in the completion of the Seller's work hereunder,the estimated time of completion shall be correspondingly
extended by written agreement between the parties before the changes are effected.
10. Termination:Buyer may terminate the contract for convenience upon notifying Seller in writing of such fact and paying Seller
for all costs and expenses(including overhead)incurred by it in performing its work and closing out the same, plus a reasonable profit
based on the total price of the Contract.
11. Indemnification: If Seller's work under the Contract requires its presence on Buyer's premises, Seller shall indemnify and
save Buyer harmless against all losses or claims for bodily injury(including death)and property damage the proximate cause of which
is Seller's willful or wanton acts or its active negligence. Seller's liability to indemnify and save Buyer harmless shall be limited to and
co-extensive with Seller's insurance.
12. Compliance with laws,codes,standards and regulations:
a) In the event that the performance required of Seller hereunder violates any applicable law, ordinance or regulation, Seller
shall, upon Buyer's written direction, modify its performance hereunder so as to comply therewith, but any additional cost incurred
thereby shall be borne by Buyer
b) Seller shall follow industrial codes and standards (in effect as of the date of Seller's Proposal), which are referenced in
Buyer's specifications, insofar as said code or standard is customary within the air pollution control industry.
c) Buyer has full responsibility for obtaining any licenses, permits and inspections required with respect to installation and use of
the equipment herein described.
13. Drawings:All drawings or technical data furnished to Buyer by Seller hereunder shall remain the property of the Seller and
Buyer shall have the use of said drawings or technical data for the limited purpose of maintaining and operating the equipment sold
hereunder.
14. Waivers:Seller's waiver of any breach or failure to enforce any of the terms,conditions and specifications of the Contract shall
not in any way affect, limit or waive Seller's right thereafter to enforce and compel strict compliance with every term, condition and
specification hereof.
15. Assignment: Neither party may assign the Contract, without the other party's prior written consent, except either party may
assign said contract, without consent, to any corporation owned or controlled by said party or to any corporation into which said
party is consolidated or to which the business of said party directly related to the Contract is sold or conveyed.
16. Governing Law:The Contract and the obligations thereby imposed on Seller and Buyer shall be governed by and construed
according to the laws of the State of Texas.
17. Liability.
a) THERE ARE NO WARRANTIES ESTABLISHED HEREIN, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING THE
WARRANTY OR MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE (BOTH OF WHICH ARE HEREBY
EXPRESSLY DISCLAIMED), EXCEPT THOSE EXPRESSLY STATED IN THE PERFORMANCE WARRANTY SECTION ABOVE.

b) IN NO EVENT BE IT DUE TO BREACH OF ANY WARRANTY HEREUNDER OR ANY OTHER CAUSE ARISING OUT OF
PERFORMANCE OR NONPERFORMANCE OF THE OBLIGATIONS HEREIN, WHETHER ANY SUCH BREACH OR CAUSE BE OR
SOUND IN TORT, CONTRACT OR OTHERWISE, SHALL SELLER BE LIABLE FOR INDIRECT, SPECIAL, OR CONSEQUENTIAL
DAMAGES, SUCH AS, BUT NOT LIMITED TO, LOSS OF PROFITS, PLANT DOWNTIME, COST OF REPLACEMENT POWER, OR
SUITS BY THIRD PARTIES AGAINST BUYER, EXCLUDING SUITS REGARDING TITLE TO THE EQUIPMENT FURNISHED
HEREUNDER, PATENTS UNDER SECTION 8 HEREOF, OR PERSONAL INJURIES OR PROPERTY DAMAGE UNDER SECTION
11 HEREOF; NOR SHALL SELLER BE LIABLE TO BUYER FOR ANY EXEMPLARY, PUNITIVE, OR LIKE DAMAGES,
REGARDLESS OF HOW OR WHY ARISING.
c) SELLER'S TOTAL CUMULATIVE LIABILITY HEREUNDER FOR ANY AND ALL REASONS, EXCLUDING ONLY
SELLER'S LIABILITY PURSUANT TO SECTION 11 HEREOF, SHALL NOT EXCEED AN AMOUNT EQUAL TO THE CONTRACT
PRICE.
18. Entire Agreement: This Proposal, together with such other sheets and documents as may be attached as may be attached
hereto or referred to herein, when approved by Seller, shall constitute the entire agreement between the parties. No change in,
addition to, or waiver of the terms, conditions and specifications contained herein shall be a binding obligation on Seller unless
approved in writing by its authorized representation.
Agreed:
By
Title
Date
Gulf Coast Environmental Systems LLC:
By
Title
Date

2022 EPA Tier 3 Exhaust Emission
C� Compliance Statement
C200D6D
Stationary Emergency
60 Hz Diesel Generator Set
Compliance Information:
The engine used in this generator set complies with Tier 3 emissions limit of U.S.EPA New Source Performance
Standards for stationary emergency engines under the provisions of 40 CFR 60 Subpart IIII.
Engine Manufacturer: Cummins Inc.
EPA Certificate Number: NCEXL0409AAD-007
Effective Date: 06/16/2021
Date Issued: 06/16/2021
EPA Engine Family(Cummins Emissions Family): NCEXL0409AAD
Engine Information:
Model: QSB7-G5 NR3 Bore: 4.21 in.(106.9 mm)
Engine Nameplate HP: 324 Stroke: 4.88 in.(124 mm)
Type: 4 Cycle, In-line,6 Cylinder Diesel Displacement: 408 cu. in. (7 liters)
Aspiration: Turbocharged and Charge Air Cooled Compression ratio: 17.2:1
Emission Control Device: Exhaust stack diameter. 4 in. (101.6)
Diesel Fuel Emission Limits
D2 Cycle Exhaust Emissions Grams per BHP-hr Grams per kWm-hr
_�
CO PM CO PM
NMHC NMHC
Test Results 3.0 0.7 0.08 4.0 1.0 0.11
EPA Emissions Limit 3.0 2.6 0.15 1 4.0 3.5 0.20
Test methods: EPA emissions recorded per 40 CFR Part 60, 89, 1039, 1065 and weighted at load points prescribed in the
regulations for constant speed engines.
Diesel fuel specifications:Cetane number:40-50, Reference:ASTM D975 No. 2-D, 300-500 ppm Sulphur
Reference conditions:Air Inlet Temperature:25°C(77°F), Fuel Inlet Temperature:40°C(104°F). Barometric Pressure:
100 kPa(29.53 in Hg), Humidity: 10.7 g/kg(75 grains H2O/lb)of dry air, required for NOx correction, Restrictions: Intake
Restriction set to a maximum allowable limit for clean filter; Exhaust Back Pressure set to a maximum allowable limit..
Tests conducted using alternate test methods, instrumentation,fuel or reference conditions can yield different results.
Engine operation with excessive air intake or exhaust restriction beyond published maximum limits, or with improper
maintenance, may result in elevated emission levels.
Cummins Inc. Data and specification subject to change without notice EPA-2035e
(12/21)

Appendix F
Separate Source Determination
Air Permit Application-Lightning Renewables-East Carolina RNG www.scsenaineers.com
I

DocuSign Envelope ID:DB75C1 E3-6843-43B7-926A-139DABAEC2C9
A R C H A E A Archaea Operating, LLC
4444 Westheimer Road, Suite G450
ENERGY Houston, Texas 77027
August 23, 2022
ELECTRONIC SUBMITTAL
North Carolina Department of Environmental Quality
Division of Air Quality
217 West Jones Street, Suite 4000
Raleigh,NC 27603
RE: Lightning Renewables, LLC—East Carolina RNG
Request for Separate Source Determination
Dear Permitting Section,
Lightning Renewables, LLC ("Lightning Renewables") is interested in developing a Renewable Natural
Gas("RNG")facility(the"RNG Facility")at the East Carolina Environmental Landfill("Landfill")located
in Aulander, Bertie County,North Carolina. On behalf of Lightning Renewables, Archaea Operating,LLC
("Archaea") submits this Letter in support of a Separate Source Determination for the planned RNG
Facility.
The Landfill is privately owned and operated by Republic Services of North Carolina, LLC, which is an
indirect subsidiary of Republic Services, Inc. ("Republic Parent"). The operation of the landfill produces
landfill gas("LFG")which consists primarily of methane,carbon dioxide,and small amounts of other gases
produced by the anaerobic decomposition of solid waste. LFG is regulated by the New Source Performance
Standards for municipal solid waste landfills. The Landfill has been issued a Title V Operating Permit and
uses flares to control the collected landfill gas in compliance with its Title V Permit and applicable
regulations. The LFG currently generated at the Landfill is sent to a flare system for control.
Lightning Renewables, LLC—East Carolina is a wholly owned subsidiary of Lightning Renewables, LLC
("Lightning Renewables"). Lightning Renewables is a joint venture between Zeus Renewables, LLC, a
wholly owned indirect subsidiary of Archaea Energy Inc. ("Archaea Parent") who owns 60 percent, and
Republic Services Renewables Energy, LLC, a wholly owned indirect subsidiary of Republic Parent who
owns 40 percent. Please refer to the enclosed Organizational Chart provided in Exhibit A for additional
clarification.
The LFG produced by the Landfill has not historically been controlled, collected, and sent, for beneficial
use. This is a missed opportunity. The proposed RNG Plant will result in a reduction to onsite flaring, and
a reduction in local air emissions, while providing our commercial partners a reliable, non-intermittent,
sustainable decarbonizing solution to displace fossil fuels(i.e. traditional natural gas).
It is our desire to maintain a distinction between the Landfill and the RNG Plant. Given the relationships
and various agreements between the entities involved with the site, Archaea is seeking concurrence from
North Carolina Department of Environmental Quality ("NCDEQ") that the Landfill and the planned East
Carolina RNG plant are determined to be separate sources for the purposes of the air permit program.
In support of our assertion, we would refer to the traditional practice of regulatory agencies considering
three factors in determining whether or not a grouping of separately housed operations should be considered

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Separate Source Determination Request August 23,2022
Archaea Operating,LLC Page 2
a single source for Clean Air Act emissions purposes: (1) do the facilities belong to the same industrial
grouping: sharing the same two-digit Standard Industrial Classification(SIC)Code;(2)are they located on
one or more adjacent or contiguous properties; and (3) and are they under the control of the same person
(or persons under common control).
Archaea acknowledges that the facilities belong to the same industrial grouping,sharing the same two-digit
Standard Industrial Classification(1). Based on the information and analysis provided herein as it relates
to the second(2) and third (3) criteria, Archaea is requesting written confirmation from NCDEQ that the
planned East Carolina RNG Plant be deemed a separate source from the Landfill for purposes of air
permitting.
We assert that the proximity of the two facilities alone should not be construed as indicative of one parry's
ability to direct the operations of the other. The"adjacency"test is more specifically designed to examine
the artificial segmenting of what would otherwise logically be considered a single plant into smaller
components,presumably to stay below regulatory emissions thresholds. The adjacency of the landfill and
the proposed RNG Facility is more a matter of convenience and cost than a necessity in operations,let alone
an inherent interconnectedness. In fact, the pipelines that deliver LFG from the landfill to the proposed
RNG Facility can be of any length, and a similar connection would be possible across a much greater
geographical distance.
Regarding the business relationship between the Landfill,and the proposed East Carolina RNG Plant,the
operations, though linked, do not constitute a "single source" as the facilities are not under "common
control," which is the touchpoint for the Single Source determination. This transaction is similar to that
examined by the United States Environmental Protection Agency ("USEPA") in connection with its
evaluation of Meadowbrook Energy LLC's single source determination.' Archaea Parent and Republic
Services Parent have entered into a mutually beneficial arms-length agreement (the "Gas Rights
Development Agreement"), pursuant to which Archaea is to develop a RNG Facility to process and treat
the LFG delivered by East Carolina Environmental Landfill to manufacture pipeline quality RNG, and
Renewable Natural Gas Environmental Attributes which are marketed and sold to third party(ies)on arms-
length terms.
Under the terms of the Master LFG Development Agreement,Lightning Renewables will own the planned
RNG Facility,and under the terms of the Master Engineering,Procurement and Construction Management
Agreement and the Master Operating and Asset Management Agreement(the"Management Agreement"),
Archaea will construct and operate the planned RNG Facility and equipment to process the LFG that is
collected,conveyed,and delivered by the Landfill.The RNG Facility,under the direction of Archaea as the
operator will receive the LFG at the demarcation point and process the LFG in various steps to beneficially
recover the methane portion of the gas, and to remove the carbon dioxide, oxygen, nitrogen, and other
impurities to produce pipeline quality RNG for injection into a natural gas distribution system for resale to
offtake customers. Tail gas from the processing consisting of carbon dioxide,volatile organic compounds,
siloxanes,nitrogen,and lesser amounts of methane will be sent to a thermal oxidizer for proper destruction.
NCDEQ's analysis should consider the lack of agency that the Landfill has in exercising actual control over
the operations of the proposed RNG Facility, with respect to air quality compliance, and vice versa. The
delineation of the rights and responsibilities of the Landfill and Lightning Renewables,LLC—East Carolina
is clearly defined in the Gas Rights Development Agreement,the Landfill has agreed to deliver LFG in an
amount not to exceed the Design Capacity of the RNG Facility to the Delivery Point. Archaea has agreed
'Letter from William L Wehrum,Assistant Administrator,U.S.Environmental Protection Agency,Office of Air and Radiation,to Hon.Patrick
McDonnell,Sec'y of the Pennsylvania Department of Environmental Protection(April 30,2018)(the"Meadowbrook Analysis").

DocuSign Envelope ID:DB75C1E3-6843-43B7-926A-139DABAEC2C9
Separate Source Determination Request August 23,2022
Archaea Operating, LLC Page 3
to accept gas from the Delivery Point, at which point title and legal ownership pass from the Landfill to
Lightning Renewables. Importantly,the Gas Rights Agreement provides that Archaea may reject Landfill
Gas delivered to Delivery Point if it is determined in good faith that such action is warrantedZ.
Although the RNG Facility is dependent upon the Landfill to provide a certain quantity of landfill gas to
operate,this does not constitute the ability of the Landfill to control the compliance or other operations of
the RNG Facility. This dependency is more akin to the manner in which any operation is dependent on its
suppliers of raw material to be able to produce its end product. It is important to note that in the event the
RNG Facility were to close or become inoperable,the Landfill's compliance with its applicable air quality
requirements would not be impacted as it could divert the landfill gas to its existing flares for destruction,
consistent with its Operating Permit. Similarly, should the Landfill cease operations, the RNG Facility
could continue to operate on the available LFG twenty(20)or more years until it's depleted. Additionally,
Lightning Renewables would be able to utilize other sources of biogas(e.g. dairy digester gas,wastewater
treatment plants,etc.)in the manufacturing of renewable natural gas. Archaea's Commercial Development
Team is actively looking to partner with nearby owners of biogas.
Also,within the Gas Rights Development Agreement,Lightning Renewables acknowledges and agrees that
the Landfill's primary interest and obligation is the safe, efficient, and responsible management and
operation of the Landfill in compliance with all applicable laws and regulations. These rights and interests
supersede any responsibility to the RNG Plant.At no time may Lightning Renewables' rights and interests
unreasonably interfere with the Landfill or Landfill Gas Collection System in any manner that may affect
compliance by the Landfill with applicable laws,operation,construction,expansion,maintenance,closure,
or post-closure care of the Landfill. Archaea Operating may not operate the RNG Plant in any way that
would result in drawing a vacuum on the collection system apart or in addition to that managed by the
Landfill. The highest priority shall be given to the control and collection of LFG and management and
mitigation of any odors or hazards associated with LFG.'
The commercial interests of Lightning Renewables,LLC—East Carolina would not, at any time,have the
power to dictate decisions over any aspect of the Landfill operations or their ability to operate in a safe and
legal fashion.The Landfill retains the full ability to comply with its regulatory obligations.In the event that
landfill gas cannot be sent to the planned RNG Facility, for safety, maintenance, or other circumstances,
the Landfill will still have the ability to flare the LFG in full compliance with its own air permit and the
related regulations.
Similarly,the interests of the Landfill cannot dictate operations or compliance at the planned RNG Facility.
NCDEQ should note that while the Republic Parent & Archaea Parent each indirectly owns a stake in
Lightning Renewables, pursuant to the Management Agreement and the Master Construction Agreement,
the RNG Facility will be operated, designed, and constructed by Archaea. Permitting and regulatory
compliance will also be managed by Archaea. Pursuant to the terms of the Management Agreement,
Archaea has the sole authority on behalf of Lightning Renewables,LLC—East Carolina RNG to"[m]onitor
and maintain responsibility for all air pollution control equipment at[the RNG Facility] with respect to all
LFG processing equipment, including thermal oxidizers and off-specification flare systems (emissions
control equipment)."
Most importantly,the Archaea Parent and the Republic Parent are two wholly separate organizations, and
there is no connection between the two parties except through the transactional relationship established
'Landfill Gas Development Rights Agreement,Between Republic Lightning,LLC.and Lightning Renewables,LLC(May 2022)("Master LFG
Development Agreement",Section 2.1 Purchase and Sale of Landfill Gas.
3 Landfill Gas Development Rights Agreement,Between Republic Lightning,LLC and Lightning Renewables,LLC(May 2022)("Master LFG
Development Agreement",Section 2.8 Priority of Landfill Operations.
l

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Archaea Operating, LLC Page 4
under the operating agreement for Lightning Renewables. Although Republic Parent is an investor and part
owner of Lightning Renewables,the operations of the planned RNG Facility are squarely and contractually
vested in Archaea Operating, LLC and the Landfill cannot exercise direct control over the RNG plants'
operations.
Included with this letter is an aggregation analysis(see Exhibit B),which we believe supports the assertion
that no common control exists between the planned RNG Facility, and the Landfill.
Should you have any questions or need additional information, please do not hesitate to contact Emily
Zambuto via phone at(585)948-4616 or e-mail at [e-mail].
Sincerely,
Archaea Operating, LLC
DocuSigned py:
�F At "u
DD289162159iME9_
John(J.P.)McNeil
Sr. VP of Operations, Archaea Energy
cc: Emily Zambuto,Archaea Energy, Inc.
Nevin Edwards,Archaea Energy, Inc.
Kristen Fan, Archaea Energy, Inc.
1

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Appendices
Exhibit A — Organizational Structure

DocuSign Envelope ID:DB75C1E3-6843-4387-926A-139DABAEC2C9
Organizational Structure
Republic Services of North
Archaea Energy,Inc. Republic Services,Inc. Carolina,LLC(subsrdioryaJ
Republic Services,Inc.)
Indirect Subsidiary Indirect Subsidiary
Zeus Renewables,LLC(60%) Republic Services Renewables Energy,LLC(40%)
East Carolina Landfill Gos
Collection&Control System
-Gas Blowers/tFG
Treatment&Flore(s)
Lightning Renewables LLC,a
Delaware Rmited liability company
Archaea Operating,LLC
Lightning as Operator,&
Renewables,LLC- - - Construction Manager
East Carolina irect subsidiary of
NfG Proce Rty(Feed
Compressors,Processing Skids
including-leod-lag H2S Removal,CO2
Removal,N2102 Removal,Thermal
Recuperative Oxidizer,Candlestick
Flare,and Cummins Standby
Emergency Generator)

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Page 6
Exhibit B— Aggregation Analysis
i

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Appendices
Aggregation Analysis
On April 30, 2018, the USEPA issued a letter to the Secretary of the Pennsylvania Department of
Environmental Protection that disclosed USEPA's modified analysis of determining "common control" in
the Title V and New Source Review regulations,a copy of which is attached at Exhibit C(the"EPA Letter").
The following aggregation analysis is premised on Archaea's application of the criteria used by USEPA
("Single Source Determination").
A. CONTROL MEANS THE POWER OR AUTHORITY TO DICTATE DECISIONS.
Archaea Parent and Republic Parent have entered into a mutually beneficial arms-length agreement
("Master LFG Development Agreement"), pursuant to which Archaea is to develop,construct and operate
a RNG Facility to process and treat the landfill gas("LFG")collected at the Landfill to generate Renewable
Natural Gas and Renewable Natural Gas Attributes("RNG").
Under the terms of the Gas Rights Development Agreement, Lightning Renewables("Company")will own
the RNG Facility and equipment to process the LFG collected, conveyed, and delivered by the Landfill to
at the demarcation point ("Delivery Point").The Landfill Owner will continue to operate its collection and
control system under its exclusive ownership and operation; therefore, Lightning Renewables (including
any of its affiliates) are not able to make decisions regarding the operation of the Landfill Owner's
pollution control equipment. The Landfill and the RNG Facility have a single point of connection, the
Delivery Point, at which location the two separately owned systems become interconnected to facilitate
the flow of LFG. However,the two systems remain under separate ownership, and control at all times.
The structure of the arms-length Master Development Agreement, Master Engineering, Procurement and
Construction Management Agreement, and the Master Operating and Asset Management Agreement do
not amount to"control".The concept of'control' includes only the power to dictate a particular outcome
and does not include the mere ability to influence.'The Board has agreed to delegate all Construction &
O&M obligations to the Operator,Archaea Operating, LLC which is a wholly owned subsidiary of Archaea
Energy, Inc.
The Landfill and the RNG Facility are owned by separate entities, Republic Services of North Carolina, LLC
("Landfill Owner")and the Lightning Renewables, LLC—East Carolina ("RNG Owner"), respectively.These
entities and their respective Parent Companies(Republic Parent&Archaea Parent),do not share common
payroll activities, employee benefits, health plans, retirement funds, insurance coverage or other
administrative functions.
Archaea Parent holds indirectly sixty percent(60%) ownership, and Republic Parent holds indirectly forty
percent (40%) interest in the Company. However, the Company has entered into an arms-length Master
Operating and Asset Management Agreement ("Management Agreement") and a Master Construction
Management Agreement(the "Construction Agreement"),whereby Archaea Operating LLC("Operator"),
a wholly owned indirect subsidiary of Archaea Parent, has been delegated the authority on behalf of the
Company to construct and operate the RNG Facility, including all personnel, legal, administrative and
'Letter from William L Wehrum,Assistant Administrator, U.S.Environmental Protection Agency, Office of Air and
Radiation,to Hon. Patrick McDonnell,Sec'y of the Pennsylvania Department of Environmental Protection(April 30,
2018)(the"Meadowbrook Analysis"). Page 8

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Appendices
regulatory functions associated with the RNG Facility.Therefore, neither the Landfill Owner nor Republic
Parent (including any of its affiliates) have decision-making authority relating to the operation of the RNG
Facility's pollution control equipment, which authority has been delegated to the Operator.
The Landfill and the RNG Facility do not share any equipment or pollution control equipment. Under the
terms of the Gas Rights Development Agreement,the Operator is solely responsible for air emissions and
the maintenance of the RNG Facility and all associated equipment,which authority has been delegated to
the Operator pursuant to the Management LFG Development Agreement, to perform all services, acts
and things necessary, requisite,or proper for the efficient and safe operation, management, maintenance
and repair of the RNG Facility.s The Company and Operator are expressly prohibited from interfering with
the Landfill Owner's operation of the Landfill.
B. FOCUS SHOULD BE ON CONTROL OVER DECISIONS THAT AFFECT THE APPLICABILITY
OF, OR COMPLIANCE WITH, RELEVANT AIR POLLUTION REGULATORY REQUIREMENTS.
The Landfill Owner and Landfill operate independently today without Company as an end-user. This
independence is a critical factor in EPA's analysis in the EPA Letter:that the Landfill Owner could continue
air quality compliant operations regardless of the presence or operating capacity of the RNG facility in
that matter. At the Landfill, Landfill Owner manages a comprehensive landfill gas collection and control
system, that extracts the LFG from within the Landfill through a series of wells, and through a series of
subsurface pipes, transports that gas to the pollution control equipment (i.e., flaring system) for
destruction (collectively,the"Collection System").The Landfill Owner will continue to exclusively manage
and maintain the Collection System with the flare, which will eventually become a backup control device
for use in the event the RNG Facility does not operate or cannot take all of the LFG generated by the
Landfill. However, NCDEQ would not have permitted the Landfill for operation without a robust existing
LFG Collection System,and thus must have satisfied itself that the flaring system at the Landfill is sufficient
to control emissions.
Under the current Master Gas Rights Development Agreement, the Operator shall expressly be
responsible for the permitting,installation,operation,and maintenance of all air pollution control devices
associated with all Recovered Landfill Gas processing equipment required by any Permit, including the
Title V Permit, in connection with the RNG Project Facility. The Operator, on behalf of the Company, will
[m]onitor and maintain responsibility for all air pollution control equipment at the RNG Plant.
Notwithstanding, Section 3.2(a)(vi) of the Master Operating Agreement, the Parties acknowledge and
agree that the Landfill Owner, shall be solely responsible for all air pollution control associated with the
Landfill and its operations in accordance therewith.
Under the current Gas Rights Development Agreement, the Company could not control any aspect of the
LFG collection process at the Landfill.The Company's rights thereunder commence at the Delivery Point,
the end point of the Collection System at which title to the LFG transfers from the Landfill Owner to the
Company. The Gas Rights Development Agreement dictates that the Landfill Owner retains exclusive
control and responsibility of the Collection System, including, without limitation, compliance with all
applicable laws and permits relating to emissions on the Landfill and the Collection System. The Landfill
5 Master Operating and Asset Management Agreement between Archaea Operating, LLC as Operator and Lightning
Renewables, LLC dated May 2022. Section 3.1

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Appendices
Owner retains its ability to divert the LFG to its flares for compliance purposes.The Landfill Owner shall
have responsibility for any and all other aspects of the ownership, operation, management and
maintenance of the Landfill Owner Facilities and emissions sources other than those related to the RNG
Facilities6.The Gas Rights Development Agreement provides the Company with no authority to direct the
Landfill Owner in its Collection System operations.
h Master Gas Rights Development Agreement as well as under the pertinent
Under the terms of the a g p g (
regulations), the Landfill Owner is required to construct and maintain sufficient flare capacity to destroy
100%of the LFG being generated at the Landfill through the life of the Landfill and the RNG Facility, or at
the very least to have the flare capacity permitted. Under the Master Gas Rights Development Agreement,
the Landfill Owner would deliver the LFG to the Company's RNG Facility, which receives the LFG as a
feedstock for refinement and processing to renewable natural gas. The Company will obtain its own
equipment and air permits and will not affect the obligations of the Landfill Owner to meet the conditions
of its permits. As the EPA Letter discusses as a reason to keep the facilities as two sources, it becomes a
problematic burden for the Landfill Owner to attest to the adequacy and performance of the Company's
pollution control equipment and emissions inventory, just as it is for the Company to make a similar
attestation with respect to that of the Landfill Owner.That is,were these two sources aggregated neither
source could fully attest with respect to compliance with the full Title V permit,and any imposed emission
ca ps.
That the Operating Agreement contains language allowing for cooperation and consultation among the
Landfill Owner and the Company does not erode the separation of the enterprises.The EPA Letter
expressly differentiates between the capacity to influence, which would be akin to consultation,from the
contractual right to control, which is not present in this arrangement. It would be unrealistic to imagine
operating a refinery of this magnitude without conferring with the Landfill Owner to ensure mutual
understanding of operating conditions and possible upcoming events. The ultimate obligation for the
operation and maintenance the RNG Facility including, without limitation, all air pollution control
equipment, remains with the Company and Operator(a wholly owned subsidiary of Archaea Parent)
through the Management Agreement. The Operator is also responsible for maintaining all permits in the
name of Company required for the operation of the RNG Facility.
C. DEPENDENCY RELATIONSHIPS SHOULD NOT BE PRESUMED TO RESULT IN COMMON
CONTROL.
Pursuant to the EPA Letter,entities can be economically or operationally interconnected or mutually
dependent through contracts or other business arrangements without having the power or au
thority to
direct the relevant activities of each other.
While the Operating Agreement of Lightning Renewables interconnects the two Parent companies,it does
not provide either entity the power or authority to dictate the outcome of decisions regarding relevant
air-pollution related aspects of each other's operations.
6 Master Landfill Gas Development Agreement, Between Republic Lightning, LLC and Lightning Renewables, LLC
(May 2022).Section 2.8.

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Appendices
D. Single Source Factors: Common Control
i. Same parent—the Company does not have the same parent company as the Landfill Owner. The
Company is indirectly owned 40% by the Republic Parent, and 60% by the Archaea Parent, which
is wholly unrelated to the Landfill and its affiliates.
ii. Contractual Relationship — The Master Gas Rights Development Agreement between the
Republic and Company dictates the separation of functions and establishes that the Landfill and
Company are to operate separately. Further,there is a Master Operating and Asset Management
Agreement providing that an Archaea affiliate will operate, maintain, and permit the RNG Facility
including the associated pollution control units.
iii. Financial Co-Dependency - The Landfill and Landfill Owner do not depend upon the Company
financially. The Company does require landfill gas from the Landfill in order to operate, but can
also seek other sources of feedstock biogas for its RNG Facility.
iv. Joint Ownership of Facilities—There is no joint ownership of the Landfill and the Company
facilities, but Republic Parent will indirectly own 40%of the Company.
V. Voting Interest-Although the Republic Parent will have 40%voting rights, it is not a controlling
share, and the RNG Facility will be operated by the Operator,which is a subsidiary of the Archaea
Parent who will have 60%voting rights.
vi. Shared Liability - Each party in the Lightning Renewables joint venture retains liability for the
operations and compliance of their respective equipment and systems; neither party assumes
liability for the operations and compliance of the other party's equipment and systems.
vii. Shared Managerial Hierarchy—None

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Separate Source Determination Request August 23, 2022
Archaea Operating, LLC Page 11
Exhibit C — Meadowbrook Analysis

DocuSign Envelope ID: DB75C1E3-6843-4367-926A-139DABAEC2C9
A% :z UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i Rr� e WASHINGTON, D C 20460
F'tjc PROtE'G1
April 30. 2019
OFFICE OF
AIR AND RAD ATtON
The Honorable Patrick McDonnell
Secretary of the Pennsylvania Department
of Environmental Protection
Rachel Carson Office Building
Post Box 2063
Harrisburg, Pennsylvania 1710>
Dear Mr. McDonnell:
On February 14. 2018. the Pennsylvania Department of Environmental Protection
(PADEP)requested that the U.S. Environmental Protection Agency review a document submitted
on behalf of Meadowbrook Energy LLC (Meadowbrook) concerning whether emissions from a
biogas processing facility under development by Meadowbrook should be aggregated with an
existing landfill owned by Keystone Sanitary Landfill, Inc. (KSL) for Clean Air Act (CAA)
permitting purposes.
EPA understands this request to relate to the question of whether these two entities should
be considered part of the same "major source" under the operating permit program under title V
of the CAA, andlor part of the same "stationary source" for the New Source Review (NSR) pre-
construction permit programs under title I of the CAA.I EPA commonly refers to these types of
questions as "source'determinations." Under the federal rules governing these permitting
programs, entities may be considered part of the same "stationary source" or "major source" if
they (1) belong to the same industrial grouping; (2) are located on one or more contiguous or
adjacent properties; and (3) are under the control of the same person (or persons under common
control).3 Meadowbrook's analysis.as supplemented by additional analysis dated March 16.2018-
primarily asserts that the Meadowbrook and KSL facilities are not under"common control.-
' Although it appears that Mcadowbrook's anahsis only directly implicates title V permitting,the discussion in this
letter and the Attachment is relevant to NSR permitting actions as well. In the NSR regulations.the definitions of
-stationary source"use the term-buildine.structure. facility.or installation."which is separately defined.
References to-major source"in this letter or Attachment are intended to refer only to the portions of the title V
definitions of-major source"that relate to Nhich activities should be considered part of the same"major source.-
'See42 U.S.C. §7661(2)(title V statutory definition);40 C.F.R.§§70.2& 71.2(title V regulations);40 C.F.R.
§§52.21(bx5)&(6).51.165(aX I X i)& (ii).and 51.166(bxS)&(6)(NSR regulations). PADEP's permitting
regulations either incorporate EPA's prevention of significant deterioration(PSD)regulations or contain similar
provisions.See,e.g..25 Pa.Code 127.83(PSD regulations incorporating EPA's regulations in 40 C.F.R. §52 21).
Internet Address lURl1-t1up rhwww epa gov
RecycledlRecyctaWe-P+.M4K7 W to vegetaae al Baud Inks on itri)"6 PCWOnSumfr ProcesS Chlonne F ree Retytted Par

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As described more fully in the Attachment below, EPA has long recognized that common
control determinations should be made on a case-by-case basis. In making such determinations.
and in offering its views to other permitting authorities, EPA has previously interpreted the term
"common control'in a manner that may support viewing the Meadowbrook and KSL facilities as
a single"stationary source"or"major source"by virtue of the support or dependency relationships
between the two entities that might be viewed as providing each entity with some degree of
influence over the operations of the other.
However, the potential for that interpretation to produce inconsistent and impractical
outcomes in this and other cases has caused EPA to re-evaluate and revise its interpretation of the
term "common control" in the title V and NSR regulations. For the reasons discussed further in
the Attachment, the agency believes clarity and consistency can be restored to source
determinations if the assessment of"control' for title V and NSR permitting purposes focuses on
the power or authority of one entity to dictate decisions of the other that could affect the
applicability of, or compliance with, relevant air pollution regulatory requirements. Under this
revised interpretation, EPA agrees with Meadowbrook that PADEP may conclude that the
Meadowbrook and KSL facilities are not under common control and thus not a single "stationary
source" or "major source" for title V or NSR purposes. However, given that Pennsylvania's title
V and NSR programs have been approved by EPA, PADEP has primary responsibility to make
source determinations involving the Meadowbrook and/or KSL facilities based on its EPA-
approved rules. EPA believes that the following Attachment, in explaining EPA's revised
interpretation and other factors that EPA recommends considering when determining if there is
"common control," should be helpful to PADEP as it makes its final permitting decision with
respect to Meadowbrook.
If you have an additional uestions tease contact
Y Y questions. p t ct Anna Marie Wood in the Office of Air
Quality Planning and Standards at [phone] or [e-mail].
Sin erely,
William L. Wehrum
Assistant Administrator
Attachment
cc: Krishnan Ramamurthy, Director of Air Quality, PADEP
Mark Wejkszner, Air Quality Program Manager, PADEP, Region 2
see also 25 Pa.Code 121.1 (general air quality definition of"facility");25 Pa.Code 127?04(a)(nonattainment NSR
regulations discussing aggregation).

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Letter: William L. Wehrum, Assistant Administrator, Office of Air and Radiation,
U.S. Environmental Protection Agency, to the Honorable Patrick McDonnell, Secretary,
Pennsylvania Department of Environmental Protection (April 30,2018)
Attachment
I. Meadowbrook and KSL Background
Meadowbrook Energy LLC (Meadowbrook) has indicated that it plans to construct a biogas
processing facility that will convert landfill gas (LFG) and other potential biogas feedstocks into
pipeline-quality natural gas for injection into the interstate natural gas pipeline system, to be used
as a transportation fuel. Meadowbrook has entered into an agreement with Keystone Sanitary
Landfill, Inc. (KSL),4 whereby KSL will deliver LFG to Meadowbrook via a pipeline running
between the two facilities. This pipeline will be owned by KSL up to a demarcation point, at
which point the remainder of the pipeline will be separately owned by Meadowbrook.
Meadowbrook explains that KSL controls its own landfill gas collection activities and delivers
untreated landfill gas to the demarcation point. After the demarcation point, Meadowbrook
conducts all processing of the gas necessary to create the renewable natural gas product that it
injects into the pipeline for market sale. Meadowbrook represents that the two entities have no
cross-ownership or direct control over operations at the other facility. In other words, each entity
has no ability to control, operate, close, or restrict the use of the other's facility.s Meadowbrook
characterizes the relationship between the two facilities as arms-length arrangements between
independent commercial entities. Meadowbrook therefore believes that Meadowbrook and KSL
should not be considered under"common control," and thus their facilities should not be
considered a single source.
More specifically, Meadowbrook maintains that KSL is not dependent on Meadowbrook for
compliance with any portion of the requirements associated with the control of the emission of
KSL's LFG. Meadowbrook indicates that KSL will retain full responsibility for compliance with
all air pollutant control obligations (e.g.,New Source Performance Standards (NSPS) Subpart
WWW requirements for LFG) until the LFG is delivered to the demarcation point(i.e., until the
gas is delivered to Meadowbrook). If Meadowbrook cannot accept LFG, shutoff valves in the
pipeline between LFG and Meadowbrook will redirect all of the LFG to KSL's flares for
4 Meadowbrook indicates that this agreement is subject to future revisions.The information provided to PADEP by
Meadowbrook in its initial draft analysis and its updated March 16,2018,analysis apparently reflects the mutual
understandings of Meadowbrook and KSL as of the date of these analyses.
5 Meadowbrook acknowledges that Meadowbrook will provide either labor(likely through a third-party)or
financing associated with modifying or optimizing KSL's landfill gas collection system in order to set up the
pipeline between Meadowbrook and KSL. However,Meadowbrook claims that KSL would direct any
Meadowbrook personnel,or third-party personnel provided by Meadowbrook,in these efforts,and that
Meadowbrook would not have any rights to direct or control the operation of the LFG collection system.
Additionally,Meadowbrook indicates that it is currently considering the possibility of interconnecting with KSL's
leachate,condensate,and wastewater treatment systems to dispose of certain Meadowbrook products at market
prices.
1

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destruction. KSL is required to construct and maintain sufficient flare capacity to destroy 100%
of KSL's LFG, and Meadowbrook states this flare capacity exists and is currently permitted.'
Thus, Meadowbrook concludes that even the closure of the Meadowbrook facility would not
have environmental consequences to KSL's operations, nor would it affect the ability of KSL to
comply with environmental regulatory requirements related to its LFG.
Meadowbrook also maintains that it is not dependent on KSL for its supply of LFG.
Meadowbrook acknowledges that it has the right to purchase, and expects to purchase, all of the
LFG produced by KSL to serve as a feedstock, and that Meadowbrook will rely on KSL for its
first supply of LFG to produce a natural gas product for commerce. However, Meadowbrook
represents that it is only required to accept as much LFG as Meadowbrook can process.
Meadowbrook also indicates that its processing capacity exceeds KSL's LFG production, and
that Meadowbrook is actively seeking additional suppliers of LFG and other types of biogas in
order to serve as a regional refining and processing facility. Moreover, Meadowbrook claims that
even if KSL were to shut down, and even if this resulted in the eventual shutdown of
Meadowbrook itself, this shutdown would have no environmental consequences. Based on this,
Meadowbrook asserts that it retains sole responsibility for environmental regulatory
requirements (related to LFG, or otherwise) arising after the demarcation point, and that its air
emissions are in no way influenced by KSL's landfill operations.
Meadowbrook emphasizes the separate compliance responsibilities of each entity, and the fact
that neither entity would be able to operate the other's facility to ensure that the other's facility
complies with relevant environmental requirements. First, Meadowbrook briefly discusses its
own practical difficulties in having to assure its customers or potential suppliers that it is not
liable for KSL's operations. Additionally, Meadowbrook highlights practical difficulties with
aggregating the two entities for permitting purposes: specifically, difficulties with including
Meadowbrook's operations within KSL's existing title V permit for title V compliance
certification purposes. Meadowbrook notes that, if Meadowbrook's operations were incorporated
into KSL's existing title V permit, KSL's responsible official would be required to certify the
accuracy of such a permit modification application with respect to Meadowbrook's operations,
as well as certify Meadowbrook's compliance with relevant requirements. See 25 Pa. Code §§
127.402(d), 127.205(2).' Meadowbrook argues that the responsible official at KSL would have
no way to accurately certify permit applications pertaining to Meadowbrook's facility, nor could
KSL's responsible official certify Meadowbrook's compliance, because KSL has no information
about or access to proprietary equipment or operations at the Meadowbrook facility. Thus,
Meadowbrook argues that it would be unrealistic to expect that KSL could effectively discharge
KSL's title V compliance certification requirements (with the potential for criminal liability) if
the two sources were aggregated.
6 Meadowbrook acknowledges that KSL's title V permit will likely be modified to add an option to divert LFG to
Meadowbrook,but claims that this will not affect KSL's ability to maintain title V compliance(presumably,
compliance with subpart WWW requirements)through use of its existing LFG collection system and flares.
Meadowbrook also references KSL's obligation to certify ongoing compliance and suggests that KSL could be
held liable for Meadowbrook's operations.See 25 Pa.Code§§ 127.511(c)(1), 127.411(a)(1).
2

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II. Background on EPA Interpretations of Common Control
When determining which pollutant-emitting activities should be considered part of the same
"major source" under the title V operating permit program, and/or part of the same "stationary
source" under the New Source Review(NSR) program, permitting authorities should assess the
three factors contained in EPA's title V and NSR regulations—same industrial grouping,
location on contiguous or adjacent property, and common control—on a case-by-case basis. In
the title V regulations, these criteria are reflected in the definition of"major source." 40 C.F.R.
§§ 70.2 & 71.2. The NSR regulations define a"stationary source" as a"building, structure,
facility, or installation"and then provide a separate definition for that phrase which reflects these
three criteria. 40 C.F.R. §§ 52.21(b)(5) & (6), 51.165(a)(1)(i) & (ii), and 51.166(b)(5) & (6).
In the original promulgation of these three factors in the NSR program regulations, EPA was
mindful of a decision from the U.S. Court of Appeals for the District of Columbia Circuit
holding that the "source"for NSR permitting purposes should comport with the "common sense
notion of a plant."45 Fed. Reg. 52676, 52694 (Aug. 7, 1980) (citing Alabama Power Co. V.
Costle, 636 F.2d 323 (D.C. Cir. 1979)). When EPA first established the current three-part test in
the Prevention of Significant Deterioration (PSD)NSR rules adopted in 1980,the agency
explained that this test would comply with Alabama Power by reasonably carrying out the
purposes of the PSD program, approximating a"common sense notion of a plant," and avoiding
the aggregation of pollutant-emitting activities that would not fit within the ordinary meaning of
"building," "structure," "facility,"or"installation."45 Fed. Reg. at 52694-95. When EPA
subsequently promulgated the title V definitions for Part 71 using the same three criteria,the
agency said that it intended these provisions to be consistent with the language and application of
the PSD definitions. 61 Fed. Reg. 34202, 34210 (July 1, 1996).
Neither the Clean Air Act(CAA),EPA's regulations, nor Pennsylvania Department of
Environmental Protection's(PADEP's) regulations define "common control."Acknowledging
that"[c]ontrol can be a difficult factual determination, involving the power of one business entity
to affect the construction decisions or pollution control decisions of another business entity,"
EPA has long recognized that common control determinations should be made on a case-by-case
basis. 45 Fed. Reg. 59874, 59878 (September 11, 1980).
In an early action implementing the Nonattainment NSR program, EPA explained that it would
be guided by a definition of control established by the Securities and Exchange Commission
(SEC), which states the following: "the possession, direct or indirect, of the power to direct or
cause the direction of the management and policies of a person(or organization or association)
whether through the ownership of voting shares, contract, or otherwise." 45 Fed. Reg. at 59878
(quoting 17 C.F.R. § 210.1-02(g)).8 In a 1996 memorandum concerning source determinations
on Federal military installations, EPA further explained:
8 EPA has also pointed to a definition of"control"found in Webster's Dictionary,including"to exercise restraining
or directing influence over,""to have power over,""power or authority to guide or manage,"and"the regulation of
economic activity."Letter from William A. Spratlin,Director,Air,RCRA,and Toxics Division,EPA Region 7,to
Peter R. Hamlin,Chief,Air Quality Bureau,Iowa Department of Natural Resources(September 18, 1995)(the
Spratlin Letter).
3

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In general, the controlling entity is the highest authority that exercises restraining
or directing influence over a source's economic or other relevant, pollutant-
emitting activities. In considering interactions among facilities, what must be
determined is who has the power of authority to guide, manage, or regulate the
pollutant-emitting activities of those facilities,including"the power to make or veto
decisions to implement major emission-control measures" or to influence
production levels or compliance with environmental regulations.9
In other guidance documents and letters, EPA has identified a number of factors that should be
considered when assessing whether two entities are under common control, including but not
limited to shared workforces, shared management, shared administrative functions, shared
equipment, shared intermediates or byproducts, shared pollution control responsibilities, and
support/dependency relationships.10 In the discussion that follows, we will refer to this as the
"multi-factor" approach of evaluating common control.
Regarding the support/dependency relationship factor, in several case-specific source
determinations, EPA relied upon the presence of support or dependency relationships between
two or more entities that resulted in one entity either directing or influencing the operations of
another entity." These situations often involved a primary facility that was wholly or partially
dependent on a supporting facility for a critical aspect of its operations, such as the supply of raw
materials. These relationships were often characterized by mutually beneficial contractual
arrangements, including output contracts (where one entity was obligated to purchase all, or a
portion, of another entity's output) and requirement contracts(where one entity was obligated to
produce all, or a portion, of a product that another entity requires). As a result of these
relationships, in certain cases EPA has found common control due to only the influence that
these economically or operationally interconnected entities exert (or have the ability to exert) on
one another(e.g., the ability to influence production levels).
9
r Determinations f r
Memorandum from John S. Seitz, Director,OAQPS,to EPA Regional Offices,Mato Source o
Military Installations under the Air Toxics,New Source Review,and Title V Operating Permit Programs of the
Clean Air Act,9-10(August 2, 1996)(the Seitz Memorandum)(citation omitted).Although this memorandum
specifically concerned military installations,many of the statements contained therein are illustrative of EPA's past
common control interpretations and policies more broadly.
10 See,e.g.,Spratlin Letter at 1-2.Other EPA guidance and correspondence regarding common control can be found
at:https://www.epa.gov/title-v-operating-permits/title-v-operating-permit policy-and-guidance-document-index and
https:llwww.epa.govinsr/new-source-review policy-and-guidance-document-index.
"See,e.g.,Letter from Kathleen Cox,Associate Director,Office of Permits&Air Toxics,EPA Region 3 to Troy
D. Breathwaite,Air Permits Manager,Virginia Department of Environmental Quality, Re: GPC/SPSA-
Suffolk/BASF(January 10,2012);Letter from Gregg M. Worley,Chief,Air Permits Section,EPA Region 4,to
James Capp,Chief,Air Protection Branch,Georgia Department of Natural Resources,Re:
PowerSecure/FEMC/Houston County Landfill(December 16,2011);Letter from Richard R. Long,Director,Air
Program, EPA Region 8,to Julie Wrend,Legal Administrator,Air Pollution Control Division,Colorado Department
of Public Health and Environment,Re: TriGen/Coors(November 12, 1998);see also Seitz Memorandum at 10-13
(discussing control via leases and contract-for-service relationships where a supporting entity is integral to or
contributes to the operations of another entity).
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III. Need for Revision to EPA's Approach to Common Control Assessments
These latter precedents might be construed to suggest that EPA and PADEP should consider
Meadowbrook and KSL to be under common control because of two elements of the relationship
between these entities, both related to the support/dependency concept. First, the fact that KSL
plans to dispose of its LFG by sending it to Meadowbrook via pipeline indicates that KSL will,
in most circumstances, effectively rely on Meadowbrook as the mechanism by which it controls
its LFG emissions in order to comply with Subpart WWW NSPS requirements applicable to the
landfill. Second, the fact that KSL is expected to supply Meadowbrook with a potentially large
proportion of the LFG that Meadowbrook processes implies that KSL could influence production
levels at Meadowbrook, and thus,to some extent, Meadowbrook's emissions resulting from
processing KSL's LFG. If Meadowbrook and KSL were determined to be under common control
based on these facts, they would then be treated as a single source for title V and NSR
purposes.12
On the other hand, the reasoning of other EPA source determinations involving similar facts
could be followed to support the contrary conclusion that Meadowbrook and KSL are not under
common control. Using the multi-factor approach to evaluating common control, one could
weigh more heavily the fact that neither facility is entirely dependent on the other for
operation.13 KSL can control its LFG emissions via flaring without Meadowbrook, and
Meadowbrook plans to receive gas from other entities. Additionally, Meadowbrook and KSL do
not share workforces, management, administrative functions, equipment, or pollution control
responsibilities. Under the multi-factor approach, these considerations suggest a lack of control.
Thus, during EPA's review of Meadowbrook's request, it became clear that the large number of
different factual considerations implicated by prior EPA common control determinations, in
addition to the agency's historically broad view of the types of relationships that can establish
control (e.g., support/dependency),has resulted in the potential for inconsistent outcomes in
source determinations and an overall lack of clarity and certainty for sources and permitting
authorities. Additionally,this particular scenario demonstrates practical difficulties that could
result from considering these operations to be a single source, including the potential for
inequitable outcomes.14 Moreover, it was not obvious that treating Meadowbrook and KSL as a
single source would reflect a"common sense notion of a plant." The potential for inconsistent
outcomes under EPA's broad-ranging prior interpretations, as well as these other concerns
regarding the facts at hand, have prompted EPA to reevaluate and narrow the agency's
interpretation of"common control." The next section explains EPA's narrowed interpretation
12 In its March 16,2018,submission,Meadowbrook states that its facility will be located on a property contiguous to
the KSL landfill,and that the two operations will share the same two-digit SIC code.Although Meadowbrook
suggests that"shared two-digit SIC codes are unlikely to contribute any meaningful information to any aggregation
analysis,"this is nonetheless a criterion currently included in EPA's source determination rules.
"See Letter from Judith M. Katz,Director,Air Protection Division,EPA Region 3,to Gary E.Graham,
Environmental Engineer,Commonwealth of Virginia Department of Environmental Quality,Re:
Maplewood/INGENCO(May 1,2002)(Maplewood/INGENCO letter).
14 In particular,the agency's prior approach could lead to the impractical and potentially inequitable result of
holding otherwise separate business entities responsible for each other's actions,even if they do not have the power
or authority to dictate such actions.
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and other considerations EPA currently views as most relevant to determining common control.
The last section applies these principles in an examination of whether the Meadowbrook and
KSL facilities are under common control.
IV. Refining EPA's Interpretation and Policy Concerning"Common Control"
Consistent with EPA's longstanding practice and view, determinations of common control are
fact-specific and should continue to be made by permitting authorities on a case-by-case basis.
However, after re-evaluating the concept of common control, EPA believes it should realign its
approach to common control determinations in order to better reflect a"common sense notion of
a plant," and to minimize the potential for entities to be held responsible for decisions of other
entities over which they have no power or authority. For the reasons discussed further below, the
agency believes clarity and consistency can be restored to source determinations if the
assessment of"control" for title V and NSR permitting purposes focuses on the power or
authority of one entity to dictate decisions of the other that could affect the applicability of, or
compliance with, relevant air pollution regulatory requirements.
This document reflects EPA's interpretation of"control" in the context of EPA's title V and
NSR regulations and EPA's policy regarding how to best apply this interpretation in source
determinations. However, states with EPA-approved title V and NSR permitting programs retain
the discretion to determine whether specific entities are under common control.15
A. Control means the power or authority to dictate decisions.
For purposes of source determinations, EPA considers"control"to be best understood to
encompass the power or authority to dictate the outcome of decisions of another entity. This
concept includes only the power to dictate a particular outcome and does not include the mere
ability to influence. Thus, control exists when one entity has the power or authority to restrict
another entity's choices and effectively dictate a specific outcome, such that the controlled entity
lacks autonomy to choose a different course of action. This power and authority could be
exercised through various mechanisms, including common ownership or managerial authority
(the chain of command within a corporate structure, including parent/subsidiary relationships),
contractual obligations (e.g., where a contract gives one entity the authority to direct specific
activities of another entity), and other forms of control where, although not specifically
delineated by corporate structure or contract, one entity nonetheless has the ability to effectively
direct the specific actions of another entity. Thus, control can be established: (1) when one entity
has the power to command the actions of another entity (e.g., Entity A expressly directs Entity B
to "do X"); or(2) when one entity's actions effectively dictate the actions of another entity (e.g.,
Entity A's actions force Entity B to do X, and Entity B cannot do anything other than X). The
15 What follows is a discussion of those factors that EPA advises states to consider(and not to consider)when
determining whether two entities are under common control. The general direction provided here by EPA should not
be understood as controlling the outcome of any particular situation,which must be judged based on its individual
facts and circumstances. This document is not a rule or regulation,and the statements herein are not binding on state
or local permitting authorities.This discussion reflects a change in how EPA interprets the term"common control"
in it regulations but does not change or substitute for any law,regulation,or other legally binding requirement.
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second scenario that can establish control should not be confused with the broader concept, as
historically articulated, embracing the "ability to influence." While distinguishing control from
the ability to merely influence will necessarily be a fact-specific inquiry, the key difference is
that EPA interprets "control"to exist at the point where one entity's influence over another entity
effectively removes the autonomy of the controlled entity to decide whether or how to pursue a
particular course of action.16 Ultimately, the focus is not on how control is established(through
ownership, contract, or otherwise),but on whether control is established—that is, whether one
entity can expressly or effectively force another entity to take a specific course of action, which
the other entity cannot avoid through its own independent decision-making.
This narrower interpretation of the meaning of"control"in most respects traces back to, and is
consistent with, definitions of"control" on which EPA previously relied that emphasized the
"power to direct,"17 as well as a common sense understanding of"control." However,this
interpretation differs from definitions that EPA has cited more recently, as well as EPA's prior
interpretation of those definitions, which extended"control"to include the ability to influence.18
For the following reasons, EPA is no longer following these broader definitions and
interpretations. Certainly, business relationships and external market forces can constrain the
ability of an entity to make decisions with complete autonomy, and it is indeed rare that an entity
is fully insulated from such external influences. However, the fact that an entity is influenced,
affected, or somewhat constrained by contractual relationships that it negotiated at arm's length,
or by external market forces, does not necessarily mean that one entity is actually controlled or
governed by these influences in making a given decision. After consideration of the inconsistent,
impractical, and inequitable outcomes that could have resulted in this case under the previous
interpretation that extended control to include the ability to influence, EPA has concluded that a
narrower interpretation is better. A narrower interpretation avoids the potential for entities to be
held responsible for actions over which they have no power or authority, but which instead they
could merely have some influence over due to of market conditions or a business relationship
that was negotiated on the open market or otherwise at arm's length. Thus, EPA will from this
point forward interpret the term"control" in its title V and NSR regulations to require more than
the ability to merely influence.
16 For example,where Entity A is required to accept and process 100%of a raw material or intermediate produced
by Entity B,decisions that Entity B makes with respect to the amount of raw material produced will likely affect
Entity A's production levels,which could affect Entity A's emissions. However,provided that Entity A has the
ability to independently decide how it operates its pollution-generating and pollution-controlling equipment,and to
independently decide whether it expands its operations or not,this level of influence would not amount to"control."
17 The common thread between definitions of"control"that EPA has relied upon is the"power to direct."See,e.g.,
17 C.F.R. §210.1-02(g)(SEC definition of control,"power to direct or cause the direction of the management and
policies of a person")(emphasis added);Spratlin Letter(citing Webster's definition of control,including"to have
power over")(emphasis added).
"See,e.g., Spratlin Letter(Webster's definition of control,including"power or authority to guide or manage,"
"restraining or directing influence over");Seitz Memorandum at 9("restraining or directing influence");see also id.
at 10-13.
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B. Focus should be on control over decisions that affect the applicability of, or
compliance with, relevant air pollution regulatory requirements.
To promote clarity, consistency, and more practical outcomes in source determinations, EPA
intends to focus on control (power or authority) over operations relevant to air pollution, and
specifically control over such operations that could affect the applicability of, or compliance
with, permitting requirements. EPA intends to examine whether the control exerted by one entity
would determine whether a permitting requirement applies or does not apply to the other entity,
or whether the control exerted by one entity would determine whether the other entity complies
or does not comply with an existing permitting requirement. Thus, if"control" represents the
power or authority of one entity to dictate a specific outcome at another entity (as described
above), EPA considers the most relevant outcome to be the applicability of, or compliance with,
air permitting requirements.
EPA considers this to be a reasonable policy, and a better approach, when determining common
control in light of the applicable regulatory context. To start with, EPA's regulations reference
air pollution-emitting activities when defining what constitutes a single source.19 Definitions
should not be read in isolation, however. Source determinations are made in the context of the
NSR and title V permitting programs and their respective requirements pertaining to the control
and monitoring of air pollution emissions. It logically follows, therefore, that the type of
"control" most relevant to this inquiry is control over air pollution-emitting activities that trigger
permitting requirements and affect compliance with those requirements. EPA therefore considers
it appropriate to focus this inquiry on control over air pollution-emitting activities that could
affect the applicability of, or compliance with,title V and NSR requirements.20 If the authority
one entity has over another cannot actually affect the applicability of, or compliance with,
relevant permitting requirements,then the entities cannot control what permit requirements are
applicable to each other, or whether another entity complies with its respective requirements.
Effectively, this means that each entity has autonomy with respect to its own permitting
obligations. It is more logical for such entities to be treated as separate sources, rather than being
artificially grouped together for permitting purposes. EPA expects that any benefit that might be
thought to be gained from the aggregation of entities that are effectively autonomous for
permitting purposes would not"carry out reasonably the purposes" of the title V or NSR
program. See 45 Fed. Reg. at 525694-95.21
19 See,e.g.,40 C.F.R. § 52.21(b)(6)(defining"building,structure,facility,or installation"as"all of the pollutant-
emitting activities"that are under common control,among other criteria(emphasis added));40 C.F.R. §70.2
(clarifying that for the definition of"major source,"considerations of major industrial group(SIC code)should
focus on"all of the pollutant emitting activities at such source or group of sources"(emphasis added));id. (defining
"stationary source"as"any building,structure,facility,or installation that emits or may emit any regulated air
pollutant or any pollutant listed under section 112(b)of the[CAA]")(emphasis added);40 C.F.R. 52.21(b)(5)
(similar definition of"stationary source"for NSR).
20 EPA has previously articulated the importance of similar considerations,including"the power to make or veto
decisions to implement major emission-control measures,"and the power to influence"compliance with
environmental regulations."Seitz Memorandum at 10(citations omitted).
21 First,although a more expansive reading of control could result in more sources being subject to title V,the
purpose of the title V program is not to indiscriminately maximize the number of sources required to obtain
operating permits—such as by requiring small sources that would otherwise not be subject to title V to obtain a
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Moreover, aggregating entities that cannot control decisions affecting applicability or
compliance with permitting and other requirements would create practical difficulties and
inequities. For title V purposes, it may be impossible for the responsible official of one entity to
accurately certify the completeness of a permit application for a permit modification (e.g., to
incorporate requirements that are applicable to a new unit) that is entirely within the control of
another entity, or to certify that the other entity has complied with existing permit requirements,
as required by title V. See 40 C.F.R. § 70.5(a)(2), (c)(9)(i), (d). Similar problematic scenarios can
arise under the NSR program as well. For instance, in order to determine whether a proposed
physical or operational change would result in a"significant net emissions increase" and thus
constitute a"major modification"at the source, an entity is required to identify and take account
of all creditable emissions increases and decreases that had occurred source-wide during the
relevant 5-year"contemporaneous" period. See, e.g., 40 C.F.R. § 52.21(b)(3)(i)(b). It is not clear
how it would even be possible for one entity to identify the creditable emissions increases and
decreases that had occurred at that portion of the source under the control of another entity, much
less determine whether NSR would be triggered by the proposed change.
More broadly, for both title V and NSR, an entity could face liability for the actions of another
entity that were entirely outside the first entity's control if both entities were treated as part of the
same source. This result would clearly be inequitable. Put simply, an entity that cannot"direct"
or"cause the direction of a specific decision or action by another entity does not have "control"
and should not be subject to the consequences of that decision.22 Focusing on control over
decisions that could affect applicability or compliance with air quality permitting obligations
avoids this potentially impractical and inequitable result while reasonably carrying out the
purposes of the title V and NSR permitting programs.
In practice, evaluating common control will necessarily be a fact-specific inquiry. However,
EPA believes the most relevant considerations should be whether entities have the power to
direct the actions of other entities to the extent that they affect the applicability of and
compliance with permitting requirements: e.g.,the power to direct the construction or
modification of equipment that will result in emissions of air pollution; the manner in which such
emission units operate; the installation or operation of pollution control equipment; and
permit simply because of their business relationships with a title V source. Second,the purpose of the NSR program
is not to maximize the number of sources subject to PSD requirements(e.g.,BACT)by aggregating multiple entities
until their combined emissions exceed major source thresholds. That said,it would also not be appropriate to rely on
EPA's current approach to artificially separate a source into multiple sources in order to evade major source status
or otherwise circumvent title V or NSR requirements. Third,the purposes of the NSR program would not be
fulfilled by allowing entities to intentionally(or unintentionally)over-aggregate,in order to share the benefits of
emissions reductions(e.g.,accounting for emission reductions in determining a significant net emissions increase)at
sources that do not have any control over each other's permitting obligations. EPA's current approach is intended to
avoid these outcomes that are incongruent with the purposes of the title V and NSR programs by aggregating only
those activities that accurately reflect a"common sense notion of a plant"from a permitting standpoint.
22 For example,if Entity A has no ability to dictate the relevant decisions of Entity B that would subject Entity B to
new regulatory requirements or that would affect Entity B's compliance with existing requirements,it would be
inequitable to subject Entity A to such new requirements or hold Entity A responsible for Entity B's compliance
with existing requirements.Only if Entity A has the ability to dictate an action by Entity B that could result in
permitting-related liability for either entity, should Entity A be held responsible for Entity B's action(by virtue of
being considered the same source).
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monitoring, testing, recordkeeping, and reporting obligations. On the other hand, common
control considerations should not focus on the power to direct aspects of an entity's operations
that are wholly unrelated to air pollution permitting requirements. If one entity has power or
authority over some aspect of another entity's operations that would have no impact on pollutant-
emitting activities of the stationary source subject to permitting requirements, EPA does not
consider that fact to be relevant to determining whether the two entities should be considered a
single source for air quality permitting purposes (e.g., one entity providing security for both its
facility and for an adjacent facility belonging to another entity).
Overall, focusing on the power to direct decisions over air pollution-related activities that could
affect permitting obligations (i.e., applicability or compliance) is reasonable, and a better
approach to determining whether there is common control in the context of title V and NSR
permitting. EPA expects that this approach will produce more consistent and sensible outcomes.
Accordingly, EPA will generally view common control to exist in situations where entities lack
the power or authority to make independent decisions that could affect the applicability of, or
compliance with, relevant regulatory requirements concerning air pollution.
C. Dependency relationships should not be presumed to result in common control.
It is important, in evaluating whether common control might be said to exist due to the existence
of a dependency relationship between entities, not to confuse this evaluation with the altogether
separate issue of whether one entity is a"support facility" for another entity. Questions arising
out of the consideration of the latter issue are directly accommodated within a distinct element of
the source determination framework: the industrial grouping (2-digit SIC code) prong.21 EPA has
previously stated that"a support facility analysis is only relevant under the SIC-code
determination."In the Matter of Anadarko Petroleum Corp., Frederic Compressor Station,
Order on Petition no. VIII-2010-4 at 16 (February 2, 2011). This important distinction aside, a
dependency relationship should not be presumed to result in common control. While mutually
beneficial arrangements that give rise to dependency relationships could give one facility
influence over the operations of another, entities can be economically or operationally
interconnected or mutually dependent through contracts or other business arrangements without
having the power or authority to direct the relevant activities of each other. To the extent that the
same underlying facts should be weighed in evaluating common control, these considerations
should generally be evaluated as outlined above to determine whether one entity has the power
or authority to dictate the decisions of another entity (and not simply to determine whether a
dependency relationship exists).
2s As EPA has explained,both primary and support facilities are to be assigned the same 2-digit SIC code.45 Fed.
Reg. at 52695;see also 1987 SIC Code Manual at 16-17("Each operating establishment is assigned an industry
code on the basis of its primary activity . . . .Auxiliary establishments are assigned four-digit industry codes on the
basis of the primary activity of the operating establishments they serve."). In the PSD rulemaking process conducted
from 1979 to 1980,EPA decided to accommodate considerations of support or functional interrelatedness as part of
the major industrial grouping(2-digit SIC code)prong,as opposed to establishing this as an independent component
of the source determination analysis.See 45 Fed. Reg. 52676,52695(August 7, 1980). In so doing,EPA did not
indicate that support or functional interrelatedness considerations should be made in the context of other discrete
elements of the source determination framework(i.e.,the common control or adjacency prongs).
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A number of practical considerations support this separation. First, the fact that economic
conditions are such that one entity depends on another facility does not necessarily mean that it
has the power or authority to direct the decisions of, or that its decisions are directed by, that
other facility on which it depends. Second,the fact that one facility would not profitably exist but
for the existence of another entity does not necessarily mean that, at some point after beginning
operation, the entities will have the power or authority to dictate the outcome of decisions
regarding relevant air-pollution related aspects of each other's operations. These situations
should be evaluated in light of the principles discussed above, and inquiries concerning common
control should not be sidestepped by presuming control based on the presence of a dependency
relationship.
V. Evaluation of Meadowbrook and KSL Under Revised Interpretation and Policy for
Common Control
Applying the interpretation of"common control" and the policy of focusing on air permitting
requirements described above, based on the information provided by Meadowbrook,24 EPA
would not view the Meadowbrook and KSL facilities to be under common control. First,
regarding control over KSL's landfill, it does not appear that Meadowbrook has power or
authority to dictate decisions over any aspect of KSL's operations that could affect the
applicability of, or compliance with, permitting requirements. Specifically, Meadowbrook does
not have the power or authority to determine whether KSL complies with regulatory
requirements associated with its LFG (Le., the Subpart WWW NSPS)that are applicable
requirements within KSL's title V permit. Of course, Meadowbrook can indirectly affect KSL's
operations by declining to take delivery of all of KSL's LFG at the demarcation point(or by
ceasing operations). This means that Meadowbrook's actions (accepting or not accepting the
LFG) would effectively dictate whether KSL does or does not destroy its LFG via its flares.
Because Meadowbrook can effectively dictate this outcome at KSL,this could arguably be
considered a form of control over this aspect of KSL's operations. However, this limited amount
of control would not be over operations that EPA finds most relevant. Importantly,
Meadowbrook will not affect KSL's ability to comply with its regulatory obligations since KSL
retains the ability to redirect its LFG to flares operated exclusively by KSL and Meadowbrook
has no power or authority over how KSL operates such flares.2' Because Meadowbrook
therefore has no power or authority over KSL's operations of the sort that EPA deems most
relevant, i.e., KSL's ability to comply with relevant permitting requirements, EPA's view is that
"EPA notes that some of the analysis initially provided by Meadowbrook and supplemented in its March 16,2018,
analysis is based on an agreement between Meadowbrook and KSL that is subject to revision.EPA's analysis below
is based on the representations provided by Meadowbrook,and should not be interpreted as a complete evaluation of
all facts that may be relevant to the question of common control. PADEP,as the permitting authority, is responsible
for making a source determination based on all relevant facts,which may extend to current factual considerations
that were not included in Meadowbrook's analysis,or to facts that eventually differ from those that Meadowbrook
predicted at the time of its March 16,2018,submittal.
21 This situation is no different from a landfill that utilizes flares as a control device and naturally has no other
options to dispose of its LFG(e.g.,no ability to send the LFG to a treatment facility or energy generating facility). In
either case,even if the landfill has only one general option to dispose of its gas(flaring),it would nonetheless likely
retain complete control over whether and how it does so(including whether it complies with relevant regulatory
requirements when doing so).
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Meadowbrook does not control KSL simply because KSL will ordinarily rely on Meadowbrook
as a means of disposing of its LFG.26 There is no indication that Meadowbrook has any power or
authority over other activities occurring at KSL.27
Second, regarding control over Meadowbrook's operations, although KSL supplies
Meadowbrook with a potentially large percentage of the feedstock(LFG) that Meadowbrook
processes into a product for market(pipeline-quality renewable natural gas), it does not appear
that this arrangement gives KSL power or authority over Meadowbrook's operations. Operations
at KSL could ultimately affect the amount of LFG available to Meadowbrook, and thus, could
indirectly affect the air emissions that ultimately occur at Meadowbrook in the course of
processing the LFG. But it does not appear that Meadowbrook is contractually obligated to
purchase the full output of KSL (although this may typically be the case).28 Moreover,
Meadowbrook indicated that it is actively pursuing other suppliers of feedstock, such that KSL
will likely not be the only supplier of LFG(or other gas feedstock)to KSL. Thus, KSL does not
have the power or authority to determine the amount of gas received (and therefore processed)
by Meadowbrook. To the extent that decisions by KSL could indirectly impact air emissions at
Meadowbrook,there is no indication that this would give KSL power or authority over any of
Meadowbrook's air pollution-related operations, much less affect any permitting obligations
applicable to Meadowbrook. At most,this amounts to.influence, not control. Therefore, it would
be appropriate to conclude that KSL does not control Meadowbrook in the sense relevant for
determining whether the two entities' facilities constitute a single source. KSL simply supplies a
feedstock product to Meadowbrook through an arm's length contract. KSL has no power or
authority to direct other aspects of Meadowbrook's operations, including the means by which
Meadowbrook generates and controls emissions.
Although Meadowbrook and KSL have at least influence over each other's operations, neither
has "control" (as this term is interpreted above) over decisions that could affect air permitting
obligations of the other. Rather, this appears to be, as Meadowbrook claimed, a mutually
beneficial arms-length arrangement between two wholly-separate business entities. Therefore,
EPA does not recommend that Meadowbrook and KSL be considered to be part of the same
stationary source or major source on the basis of common control. However, as the permitting
authority, PADEP retains the ultimate discretion to make source determinations based on its
EPA-approved title V and NSR rules.
"This conclusion is premised on Meadowbrook's representation that KSL's permit would not be modified in such a
manner that Meadowbrook would have the power or authority to dictate whether KSL complies with its permit
terms.
27 Although Meadowbrook may supply funding or other resources to KSL for purposes of optimizing KSL's landfill
gas recovery system,Meadowbrook's representations suggest that KSL would nonetheless retain complete control
over this optimization process,and that Meadowbrook would not control any aspect of the LFG collection process.
Additionally,the limited information presented by Meadowbrook regarding its potential future use of KSL's
leachate,condensate,and wastewater treatment systems at market prices does not indicate that this would result in
Meadowbrook's control over this aspect of KSL's operations.However,this arrangement may warrant further
evaluation as Meadowbrook and KSL finalize their plans.
28 As noted above,Meadowbrook indicated that it is only required to accept as much LFG as Meadowbrook can
process.
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Appendix G
Bertie County Zoning Consistency Determination
Air Permit Application—Lightning Renewables-East Carolina RNG www.scsenaineers.com

ENGINEERSSCS Environmental Consulting & Contracting
September 30, 2022
File No. 02222204.00
Traci White
Bertie County Planning and Inspections
PO Box 530
106 Dundee Street.
Windsor, NC 27983
Subject: Zoning Consistency Determination
Lightning Renewables - East Carolina RNG
Traci White:
On behalf of Lightning Renewables, LLC, I am writing to inform you that we intend to construct and
operate a renewable natural gas plant(Lightning Renewables - East Carolina RNG) at 1922
Republican Road in Aulander, Bertie County. I hereby certify that to the best of my knowledge, Bertie
County is the only local government having relevant jurisdiction over any part of the land on which
the facility and its appurtenances are to be located.
In accordance with § 143-215.108(f) of the North Carolina General Statutes, we hereby request that
you issue a determination as to whether your municipality has in effect a zoning or subdivision
ordinance that is applicable to the proposed facility. Additionally, please issue a determination as to
whether the proposed use would be consistent with applicable zoning or subdivision ordinances. For
your convenience, I have included a form with which you may remit your determination and a copy of
the draft air permit application. As a means of demonstrating proof of transmittal, please sign, title,
stamp, and date the enclosed form and mail to both the facility mailing address and the checked air
quality office at your earliest convenience.
Thank you for your prompt attention to this matter. If you have any questions regarding this request,
please contact me at]
Sincerely,
David Greene Lucas Nachman
Project Manager Project Professional
SCS Engineers SCS Engineers
dsg/LN
cc: Ryan Christman - Archaea Energy
Encl. DAQ Zoning Form
79 Woodfin Place, Suite 101, Asheville, NC 28801 1 828-285-8951 Z,�

Zoning Consistency Determination
Facility Name Lightning Renewables—East Carolina RNG
Facility Street Address 1922B Republican Road
Facility City Aulander
Description of Process Renewable Natural Gas Plant
SICNAICS Code 4925
Facility Contact Nevin Edwards
Phone Number 412-860-4550
Mailing Address 4444 Westheimer Road, Suite G450
Mailing City, State Zip Houston, TX 77027
Based on the information given above:
r I have received a copy of the air permit application(draft or final) AND...
r- There are no applicable zoning ordinances for this facility at this time
f- The proposed operation IS consistent with applicable zoning ordinances
r The proposed operation IS NOT consistent with applicable zoning ordinances
(please include a copy of the rules in the package sent to the air quality office)
f The determination is pending further information and can not be made at this time
F- Other:
Agency
Name of Designated Official
Title of Designated Official
Signature
Date
Please forward to the facility mailing address listed above and the air quality office
at the appropriate address as checked on the back of this form.
Courtesy of the Small Business Environmental Assistance Program
sb.ncdenr. ov 877-623-6748

All PSD and Title V Applications
F_ Attn: Supervisor
DAQ—Permitting Section
1641 Mail Service Center
Raleigh,NC 27699-1641
Local Programs
I— Attn: Air Quality Director
Asheville-Buncombe Air Quality Agency
P.O. Box 2749
Asheville,NC 28802
[phone]
F_ Attn: Air Quality Director I— Attn: Air Quality Director
Mecklenburg County Air Quality Forsyth County Office of Environmental
2145 Suttle Avenue Assistance and Protection
Charlotte,NC 28208 201 N. Chestnut Street
[phone] Winston-Salem,NC 27101
[phone]
Division of Air Quality Regional Offices
F_ Attn: Regional Supervisor Attn: Regional Supervisor
Asheville Regional Office Washington Regional Office
2090 U.S. Highway 70 943 Washington Square Mall
Swannanoa, NC 28778 Washington,NC 27889
[phone] [phone]
F_ Attn: Regional Supervisor F_ Regional Supervisor
Fayetteville Regional Office Wilmington Regional Office
225 Green Street, Suite 714 127 Cardinal Drive Extension
Fayetteville,NC 28301 Wilmington,NC 28405
[phone] [phone]
F_ Attn: Regional Supervisor F_ Attn: Regional Supervisor
Mooresville Regional Office Winston-Salem Regional Office
610 East Center Avenue, Suite 301 450 West Hanes Mill Road, Suite 300
Mooresville,NC 28115 Winston-Salem,NC 27105
[phone] [phone]
F_ Attn: Regional Supervisor
Raleigh Regional Office
1628 Mail Service Center
Raleigh,NC 27699-1628
[phone]
Courtesy of the Small Business Environmental Assistance Program
sb.ncdenr.gov 877-623-6748
Y

Zoning Consistency Determination
Facility Name Lightning Renewables—East Carolina RNG
Facility Street Address 1922B Republican Road
Facility City Aulander E C E Q V E
lit
jd %1 0
Description of Process Renewable Natural Gas Plant
SIC/NAICS Code 4925
Facility Contact Nevin Edwards
Phone Number 412-860-4550
Mailing Address 4444 Westheimer Road, Suite G450
Mailing City, State Zip Houston, TX 77027
Base n the information given above:
I have received a copy of the air permit application(draft or final) AND...
There are no applicable zoning ordinances for this facility at this rime
F The proposed operation IS consistent with applicable zoning ordinances
r- The proposed operation IS NOT consistent with applicable zoning ordinances
(please include a copy of the rules in the package sent to the air quality office)
F- The determination is pending further information and can not be made at this time
r Other:
II
Agency e ern C- a-)(A► -ry al,"K1!KI 6 4- I a5Pe&r 10&t5
Name of Designated Official -T,�(�CI P) . W -r C
Title of Designated Official
Signature
Date 10 13 aoaa.
Please forward to the facility mailing address listed above and the air quality office
at the appropriate address as checked on the back of this form.
Courtesy of the Small Business Environmental Assistance Program
sb.ncdenr.gov 877-623-6748
ICI -