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Test Completion Date: March 25 th , 2009 Report Submittal Date: April 30 th , 2009 (Draft)

TRC Project Number 166478.0000.0000

### TABLE OF CONTENTS

INTRODUCTION 1 Table 1 Background Data 2

SUMMARY OF RESULTS 4 Table 2: Executive Summary 4 Table 3: Summary of Results, Emissions Test Results, Unit 1 6 Table 4: Summary of Results, Emissions Test Results, Unit 2 7

PROCESS DESCRIPTION 8

ANALYTICAL TECHNIQUES 9 Table 5: Analytical Instrumentation 13 Figure 1: Instrumental Sample System Diagram 14

QUALITY ASSURANCE ACTIVITIES 15

APPENDICES:
A. Field Data Sheets B. Example Calculations C. Landfill Gas Analysis D. Quality Assurance Activities
E. Calibration Certifications F. Logged Data Records G. Operational Data
H. Opacity Observations I. Florida Department of Environmental Protection
Air Construction Permit No. 0830124-006-AC

### 1 INTRODUCTION

Exhaust emissions tests were conducte d on Units 1 and 2, two 1.6 Megawatt (MW) Caterpillar Model No. G3520C landfill gas fired ge nerator engines. These units, used to generate electrical power, are in service at the Marion County Board of County Commissioners (MCBCC) Baseline Landfill located in Ocala, Ma rion County, Florida. G2 Energy, LLC owns this power generation facility which is ope rated by Autotech II personnel. TRC – Air Measurements, Gainesville Office (TRC) conducted these tests on March 24 th and 25 th , 2009.

The purpose of this testing was to determin e the status of initial compliance for Units 1 and 2 with respect to environmental standards and emission limits. The environmental limits for emissions are set forth by the Florida Departme nt of Environmental Protection (FDEP) Air Construction Permit No. 0830124-006-AC. Additionally, the testing satisfied the specific monitoring requirements as set forth in 40 CFR 60, Subpart JJJJ “Standards of Performance for Stationary Spark Ignition Internal Combustion Engines”. The tests followed the procedures set
forth in 40 CFR 60, Appendix A, Methods 1, 3A, 4, 7E , 9, 10, 19, and 25A. In addition, the landfill gas was sampled and analyzed in accordance with EPA Method 3C.

Emissions from the engine were analyzed for compliance at full load operation in the exhaust stack for oxides of nitrogen (NO X ), carbon monoxide (CO), total hydrocarbon compounds (THC), methane (CH 4 ), oxygen (O 2 ), and carbon dioxide (CO 2 ) using continuous instrumental monitors. Volatile organic compound (VOC) emissions were determined by determining by subtracting the CH 4 emissions from the THC emissi ons. In addition, a 30-minute visible emissions (VE) test was conducted on each engine exhaust stack. The landfill gas fuel used to fire the engine was analyzed for perman ent gases for use in determination of the fuel heating value of the landfill gas. Table 1 summarizes the background information pertinent to
these tests.

This test report has been reviewed and approved for submittal to FDEP by the following representatives:

TRC – Air Measurements G2 Energy, LLC

### 2 TABLE 1
B ACKGROUND D ATA

Source Owner: G2 Energy, LLC 400 Perimeter Center Terraces, Suite 900 Atlanta, Georgia 30346 Attention: Nick King, Managing Member (770) 668-0220 Phone (770) 668-9796 Facsimile
Email: n.king@g2energy.com

Testing Organization: TRC – Air Measurements, Gainesville Office
6322 NW 18 th Drive, Suite 170 Gainesville, Florida 32653 Attn: Leonard Brenner, Manager – Air Measurements (352) 378-0332 Phone (352) 378-0354 Facsimile
Email: lbrenner@trcsolutions.com

Test Participants: Florida Department of Environmental Protection Garry Kuberski, Engineer Allen Rainey, Engineer

Autotech II Jerry Brewer, Operator

TRC – Air Measurements, Gainesville Office Leonard Brenner, Manager – Air Measurements Chris Hank, Environmental Technician

Facility Location: Marion County Board of County Commissioners
Baseline Landfill
5601 SE 66 th Street Ocala, Florida 34480 (352) 245-2634 Phone

Regulatory Application: These generator engines are state regulated under FDEP
Air Construction Permit Number 0830124-006-AC. Additionally, these engines ar e federally regulated under 40 CFR 60, Subpart JJJJ “Standards of Performance for Stationary Spark Ignition Internal Combustion Engines”.

Test Dates: March 24 th , and 25 th , 2009

### 3 Emission Sampling Points: Each unit is equipped with a circular stack, located outside of the building roof is approxi mately 32 feet tall with an
internal diameter of 13 inch es. Two 3-inch diameter sample ports are located perpe ndicular to each other in the horizontal ductwork in-side the building before the stack silencer. See Appendix A for stack diagrams. Access to the sample ports was provided by a ladder.

Source Description: Two 1.6 MW Caterpillar Model G3520C internal combustion engine and generator sets are used to produce electrical power. These engines are fueled exclusively with landfill gas generated by the Baseline Landfill.

Test Methods: EPA Method 1 was used to select gaseous stratification sampling point locations.

EPA Method 3A was used to determine carbon dioxide (CO 2 ) and oxygen (O 2 ) emissions.

EPA Method 3C was used to determine landfill gas composition, used in the determination of landfill gas as fuel heating values and fuel specific “F-factors”.

EPA Method 4 was used for de termination of stack gas moisture content using gravimetric analysis.

EPA Method 7E was used for determination of oxides of nitrogen (NO X ) emissions.

EPA Method 9 was used to determine visible emissions (VE) measurements determined as opacity by a certified
observer.

EPA Method 10 was used for determination of carbon monoxide (CO) emissions.

EPA Method 19 was used for verification of volumetric flow rates by stoichiometric calculations based on O 2 and
CO 2 “F Factors”.

EPA Method 25A was used to determine volatile organic compounds (VOC) by using one flame ionization analyzer to determine total hydrocarbon compounds (THC) and by asecond flame ionization analyzer equipped with a nonmethane cutter as described in 40 CFR 1065.265 to determine methane (CH 4 ) concentrations. VOC emissions were calculated by subtracting the methane emissions from the total hydrocarbon emissions.

### 4 SUMMARY OF RESULTS

G2 Energy, LLC operates a power generati on facility at the Marion County Board of County Commissioners – Baseline Landfill in Ocal a, Marion County, Florida. Two landfill gas fueled Caterpillar Model No. G3520C generator engi nes are in service at this facility and are used for the production of electricity. G2 Ener gy designates these generator engines as Unit 1 and Unit 2. The emissions from these engines are the subject of this report.

Table 2, the executive summary, signifies the pe rformance for the generator engines with respect to initial compliance testing. The initial compliance test results are an average of the three test runs for each engine and are compar ed to the permit limits set forth in FDEP Air
Construction Permit No. 0830124-006-AC and EPA 40 CFR 60, Subpart JJJJ performance specifications. NO X , CO, and VOC emission rates are repor ted in terms of parts per million by volume (ppmv) at 15% excess O 2 on a dry basis and grams pe r brake brake-horsepower hour (g/bhp-hr). Visible emissions are reported in terms of percent opacity.

FDEP/ EPA JJJJ

Parameter Unit 1 Results Unit 2 Results Performace Specs

Generator Power Output (kW) 1601 1476

- Unit Load (% of full load = 1.6 MW) 100% 92%

- Engine Horsepower (bhp) 2235 1979

-

NO X (ppmv @ 15% O 2 , dry basis) 86.9 90.9 220

NO X (g/bhp-hr) 1.17 1.24 3.0

CO (ppmv @ 15% O 2 , dry basis) 447 428 610

CO (g/bhp-hr) 3.68 3.54 5.0

VOC (ppmv @ 15% O 2 , dry basis) 8.36 22.4 80

VOC (g/bhp-hr) 0.108 0.293 1.0

VE (% opacity) 0 0 20 

## Executive Summary TABLE 2

The first step in the test matrix consiste d of conducting an initial sampling traverse of each engine exhaust stack. The purpose of this sampling traverse was to check for changes in emissions concentration (stratification) within the exhaust stack. CO, O 2 and CO 2 concentrations

### 5 were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. No significant stratification was observed for the CO, O 2 , and CO 2 emissions from either unit. The stratification was less than 5% from the mean concentration. Therefore, sampling during the testing was conducted from a single point of average emissions from each stack.

Following the stratification test, TRC conducted th ree test runs at full load on each unit.
Each test run was 60 minutes in duration. Emissions of NO X , CO, THC, CH 4 , VOC, and VE
were determined. NO X , CO, THC, CH 4 , O 2 , and CO 2 were measured using continuous instrumental monitors. A landfill gas fuel samp le was collected during the three test runs on each unit for analysis of fuel composition and gross heating value. Co-inc ident with one of the test runs on each engine, a 30-minute VE test was conducted to determine opacity.

Tables 3 and 4 represent detailed summaries of the initial compliance results for Units 1 and 2. This tabular summary contains all pertin ent operational parameters, landfill gas fuel data, ambient conditions, measured emissions, corrected concentrations, and calculated emission rates.
NO X , CO, and VOC emissions are reported in units of parts per million (ppmv) on a dry basis and ppmv, dry corrected to 15% excess O 2 . THC and CH 4 emissions are reported in units of ppmv on a wet basis as propane. Mass emission rates for NO X , CO, and VOC are reported in terms of pounds per hour (lbs/hr) and g/bhp/hr. VE are reported in terms of % opacity.

Volumetric flow and mass emission rates were determined by EPA Method 19. This technique employed a stoichiometric calculati on based on measurements of diluent gas (O 2 or CO 2 ) concentration, "F Factors" determined from fuel composition, and the engine's fuel consumption rate. Examples of emission rate calculations and other calculations necessary for the presentation of the results of this section are contained in Appendix B.

The fuel analyses are contained in Appendix C of this report. These landfill gas analyses were obtained from the EPA Method 3C samples collected during the testing. One sample was collected for each unit over the entire period of testing. The landfill gas fuel composition was determined for use in EPA Method 19 equations as described above. The fuel composition and the TRC heating value and “F-factor” worksheets are in Appendix C.

A certified EPA Method 9 observer performed opacity readings on each engine exhaust
stack. One 30-minute visible emission test r un was conducted during the gaseous emissions testing. The testing was conducted when the sun was not directly overhead and with daylight present. EPA Method 9 requires the sun angle to be 140 degrees to the observer’s back.

Appendix A contains the stack diagrams, th e stratification results, and all field data sheets used during these tests. Appendix B contai ns examples of all calculations necessary for the reduction of the data presented in this report. Appendix C contains the landfill gas composition analyses and the TRC fuel calculation worksheets used to determine custom EPA Method 19 F-factors. Quality assurance activities are documented in Appendix D. Certificates of calibrations for TRC equipment and gases ar e contained in Appendix E of this report. Appendix F contains the records of logged data , displayed in one-minute intervals and rolling one-minute averages, used to record the reference method NO X , CO, THC, CH 4 , O 2 , and CO 2 concentrations. Appendix G contains unit operationa l data reported in thirty-minute intervals.
“Visible Emissions Observation Forms” and the observer certifications are in Appendix H. The FDEP permit is presented in Appendix I for reference purposes.

### TABLE 3: Summary of Results Unit 1, Emissions Test Results Company: G2 Energy (Baseline Landfill)
Plant: MCBCC Baseline Landfill Location: Ocala, Florida Technicians: LJB, CDH Source: Unit 1, a Caterpillar G3520C generator engine
Test Number U1-C-1 U1-C-2 U1-C-3

Date 03/25/09 03/25/09 03/25/09 Start Time (24 hour basis) 09:33 10:56 12:36 FDEP/EPA Stop Time (24 hour basis) 10:33 11:56 13:36 Performance Engine/Generator Operation Averages Specifications Generator Power Output (kW) 1613 1603 1601 1606 Engine Horsepower (bhp) 2163 2149 2146 2153 Generator Ampera ge (Amps) 221 224 224 223 Generator Voltage (kVolts) 4202 4186 4174 4187 Generator Frequenc y ( H e r t z ) 6 0 6 0 6 0 60

Generator Power Factor 1.0 1.0 1.0 1.0 Fuel Manifold Pressure (psig) 2.5 2.5 2.5 2.5 Jacket Water Temperature (Inlet, °F) 127 143 147 139 Jacket Water Temperature (Outlet, °F) 220 220 220 220 Engine Oil Temperature ( ° F) 195 195 195 195
Landfill Gas Fuel Data Fuel Heating Value (Btu/SCF, HHV) 532.8 532.8 532.8 532.8 Fuel Specific Gravity 0.9783 0.9783 0.9783 0.9783

O 2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9432 9432 9432 9432

CO 2 "F-factor" (DSCFex/MMBtu @ 0% excess air ) 1785 1785 1785 1785

LFG CH 4 Content (% volume, dry basis) 56.5 no data no data 56.5

LFG O 2 Content (% volume, dry basis) 0.5 0.1 0.1 0.3
Wellhead Vacuum ("H 2 O) 11.0 10.3 9.4 10.3
Fuel Flow Rate (SCFM) 513.7 498.3 495.7 502.6 Heat Input (MMBtu/hr, Higher Heat Value) 16.42 15.93 15.85 16.07
Ambient Conditions Atmospheric Pressure ( "Hg) 30.08 30.09 30.07 30.08 Temperature (°F): Dry bulb 69.3 75.3 80.7 75.1 (°F ): Wet bulb 61.5 63.4 64.6 63.2 Humidity (lbs moisture/lb of air) 0.0096 0.0094 0.0090 0.0094
Measured Emissions

NO X (ppmv, dry basis) 201.1 194.4 197.1 197.5

NO X (ppmv @ 15% O 2 , dry basis) 88.3 85.4 87.1 86.9 220 CO (ppmv, dry basis) 1031 1016 1002 1016 CO (ppmv @ 15% O 2 , dry basis) 453 446 443 447 610 THC (ppmv, wet basis as Propane) 488.8 453.0 442.8 461.5 Methane (ppmv, wet basis as Propane) 470.8 432.9 431.8 445.2 VOC (ppmv, dry basis as Propane) 20.8 23.5 12.8 19.0 VOC (ppmv % 15% O 2 , dry basis as Propane) 9.12 10.3 5.64 8.36 80 VE (% opacity) 0

- - 0 20

O 2 (% volume, dry basis) 7.46 7.47 7.55 7.49

CO 2 (% volume, dry basis) 12.21 12.20 12.12 12.18

H 2 O (% volume, from Method 4 sample train) 13.36 14.40 13.80 13.85

Stack Volumetric Flow Rates

via EPA Method 19 O 2 "F d -factor" (SCFH, dry basis) 2.41E+05 2.34E+05 2.34E+05 2.36E+05

via EPA Method 19 CO 2 "F

c -factor" (SCFH, dry basis) 2.40E+05 2.33E+05 2.33E+05 2.36E+05
Calculated Emission Rates (f rom EPA Method 19 flow rates)

NO X (lbs/hr) 5.78 5.43 5.51 5.57 CO (lbs/hr) 18.1 17.3 17.0 17.5 VOC (lbs/hr) 0.573 0.629 0.342 0.514

NO X (g/bhp-hr) 1.21 1.15 1.16 1.17 3.0 CO (g/bhp-hr) 3.79 3.65 3.60 3.68 5.0 VOC ( g /bh p -hr) 0.120 0.133 0.0722 0.108 1.0

Testing by TRC - Air Measurements • Gainesville Office

### TABLE 4: Summary of Results Unit 2, Emissions Test Results Company: G2 Energy (Baseline Landfill)
Plant: MCBCC Baseline Landfill Location: Ocala, Florida Technicians: LJB, CDH Source: Unit 2, a Caterpillar G3520C generator engine
Test Number U2-C-1 U2-C-2 U2-C-3

Date 03/25/09 03/25/09 03/25/09 Start Time (24 hour basis) 14:17 16:10 17:27 FDEP/EPA Stop Time (24 hour basis) 15:17 17:10 18:27 Performance Engine/Generator Operation Averages Specifications Generator Power Output (kW) 1492 1452 1484 1476 Engine Horsepower (bhp) 2001 1948 1990 1979 Generator Ampera ge (Amps) 209 205 206 207 Generator Voltage (kVolts) 4165 4183 4192 4180 Generator Frequenc y ( H e r t z ) 6 0 6 0 6 0 60

Generator Power Factor 1.0 1.0 1.0 1.0 Fuel Manifold Pressure (psig) 2.5 2.5 2.5 2.5 Jacket Water Temperature (Inlet, °F) 143 137 140 140 Jacket Water Temperature (Outlet, °F) 221 220 220 220 Engine Oil Temperature ( ° F) 190 197 197 195
Landfill Gas Fuel Data Fuel Heating Value (Btu/SCF, HHV) 546.5 546.5 546.5 546.5 Fuel Specific Gravity 0.9774 0.9774 0.9774 0.9774

O 2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9389 9389 9389 9389

CO 2 "F-factor" (DSCFex/MMBtu @ 0% excess air ) 1782 1782 1782 1782

LFG CH 4 Content (% volume, dry basis) no data no data no data no data

LFG O 2 Content (% volume, dry basis) 0.1 0.1 0.1 0.1
Wellhead Vacuum ("H 2 O) 8.2 7.2 7.7 7.7 Fuel Flow Rate (SCFM) 465.0 447.3 455.7 456.0 Heat Input (MMBtu/hr, Higher Heat Value) 15.25 14.67 14.94 14.95
Ambient Conditions Atmospheric Pressure ( "Hg) 30.02 29.99 29.97 29.99 Temperature (°F): Dry bulb 79.8 80.0 77.5 79.1 (°F ): Wet bulb 62.3 62.5 61.9 62.2 Humidity (lbs moisture/lb of air) 0.0077 0.0078 0.0080 0.0078
Measured Emissions

NO X (ppmv, dry basis) 203.3 205.8 200.0 203.0

NO X (ppmv @ 15% O 2 , dry basis) 90.8 92.3 89.7 90.9 220 CO (ppmv, dry basis) 965.2 949.9 948.9 954.7 CO (ppmv @ 15% O 2 , dry basis) 431 426 426 428 610 THC (ppmv, wet basis as Propane) 564.8 579.5 569.9 571.4 Methane (ppmv, wet basis as Propane) 527.0 531.7 525.3 528.0 VOC (ppmv, dry basis as Propane) 43.6 55.2 51.5 50.1 VOC (ppmv % 15% O 2 , dry basis as Propane) 19.5 24.7 23.1 22.4 80 VE (% opacity) 0

- - 0 20

O 2 (% volume, dry basis) 7.69 7.74 7.75 7.73

CO 2 (% volume, dry basis) 12.00 11.98 11.96 11.98

H 2 O (% volume, from Method 4 sample train) 13.30 13.38 13.33 13.34

Stack Volumetric Flow Rates

via EPA Method 19 O 2 "F d -factor" (SCFH, dry basis) 2.27E+05 2.19E+05 2.23E+05 2.23E+05

via EPA Method 19 CO 2 "F

c -factor" (SCFH, dry basis) 2.26E+05 2.18E+05 2.23E+05 2.22E+05
Calculated Emission Rates (f rom EPA Method 19 flow rates)

NO X (lbs/hr) 5.50 5.37 5.32 5.40 CO (lbs/hr) 15.9 15.1 15.4 15.5 VOC (lbs/hr) 1.13 1.38 1.31 1.28

NO X (g/bhp-hr) 1.25 1.25 1.21 1.24 3.0 CO (g/bhp-hr) 3.60 3.52 3.51 3.54 5.0 VOC ( g /bh p -hr) 0.256 0.322 0.300 0.293 1.0

Testing by TRC - Air Measurements • Gainesville Office

### 8 PROCESS DESCRIPTION

G2 Energy owns a power generation fac ility, operated by Autotech II, at the MCBCC Baseline Landfill in Ocala Marion County, Florida. The station uses two landfill gas fueled engines to provide electricity to the local power grid. The exhaust emissions from these units were measured to determine compliance with the FDEP construction permit. This section of the report provides a brief description of these engines.

The generator engines, Units 1 and 2, we re manufactured by Caterpillar , Model 3520C, and are fueled exclusively with landfill gas generated from microbial decomposition of solid waste from the landfill. The engines are lean burning, four-cycle, turbo-charged, generator engines which use electronic ignition and air-to-fuel ratio controls to reduce pollutant emissions.

The engines are rated for production of 2233 brake-horsepower (bhp) and 1.6 MW at a speed of 1200 rotations per minute (rpm). The operating schedule for this engine is permitted for 8760 hours per year. These engines are permitted to operate solely on landfill gas as a fuel

source.

The stack configurations for both engines are identical. Sample ports meeting the criteria of EPA Method 1 were located in a straight horiz ontal section of the exhaust pipe inside the building and before the silencer. The sample ports were 56 inches or 4.3 stack diameters upstream from the nearest flow disturbance, the engine silencer. Sampling ports were 151 inches
or 11.6 stack diameters downstream from the neares t flow disturbance. Access to the stack was made available via a safety ladder. The di ameter of the exhaust stack was 13.0 inches. Appendix A contains a field sketch of the st ack configuration and sample port locations.

G2 Energy personnel provided operational data fr om the engine instrument panels. Data sets were recorded at approximate 30-minute inte rvals during each test run; the average of this data was recorded in the summary tables. Copies of the original data are contained in Appendix G of this report.

### 9 ANALYTICAL TECHNIQUES

Emissions from two generator engines we re measured at the MCBCC Baseline Landfill located in Ocala, Marion County, Florida. TRC performed these tests on March 24 th and 25 th

, 2009 in order to determine the compliance status with regard to permitted emission limits. This section of the report describes the analytical techniques and procedures used during these tests.

The sampling and analysis procedures used during these tests conformed with those outlined in The Code of Federal Regulations , 40 CFR 60, Appendix A, Methods 1, 3A, 4, 7E, 9, 10, 19, and 25A. The stack gas analyses for NO X , CO, THC, CH 4 , O 2 and CO 2 were performed using continuous instrumental monitors. Exhaust gas analyses were performed on a dry basis for all compounds except THC and CH 4 emissions. Table 5 lists the instruments and detection principles used for these analyses. Manual sampling measurements included sampling for moisture content using a chilled water impingeme nt sampling train. Landfill gas fuel sampling and analysis was conducted in accordance with EPA Method 3C.

The first step in the test matrix consiste d of conducting an initial sampling traverse of each engine exhaust stack. The purpose of this sampling traverse was to check for changes in emissions concentration (stratification) within the exhaust stack. CO, O 2 and CO 2 concentrations were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. No significant stratification was observed for the CO, O 2 , and CO 2 emissions. The stratification was less than 5% from the mean concentrati on. Therefore, sampling during the testing was conducted from a single point of average emissions from each engine stack.

Following the stratification test, TRC conducted th ree test runs at full load on each unit.
Each test run was 60 minutes in duration. Emissions of NO X , CO, THC, CH 4 , VOC, and VE
were determined. NO X , CO, THC, CH 4 , O 2 , and CO 2 were measured using continuous instrumental monitors. VOC emissions were determined by subtracting the CH 4 emissions from the THC emissions. A landfill gas fuel sample was collected during the entire period of the three test runs for analysis of fuel composition and gross heating value. One 30-minute VE test was conducted during these tests.

Provisions were made to introduce the calibra tion gases to the instrumental monitors via two paths: 1) directly to the instruments via the sample manifold quick-connects and flow meters, and 2) through the complete sampling sy stem including the sample probe, filter, heat trace, condenser, manifold, and flow meters. Th e former method was used for quick, convenient
calibration checks. The latter method was used to demonstrate that the sample was not altered due to leakage, reactions, or adsorption within th e sampling system (sample system bias check).
A NO X standard calibration gas was introduced into the NO X analyzer directly. Then the response from the NO X analyzer was noted as the calibrati on gas was introduced at the probe. Any difference between the two responses in the in strument was attributed to the bias of the sample system. Following the span gas bias ch eck, a zero gas bias check was performed on the
NO X analyzer using nitrogen to check for any zero bias of the sample system. In accordance with EPA Methods 3A and 10 this span and zero bias check procedure was repeated for the CO,

### 10 O 2 , and CO 2 analyzers. Although not required by EP A Method 25A, this procedure was also
conducted for the THC and CH 4 analyzers to maintain consistency in results reporting.

Figure 1 shows the set-up for sampling the engine exhaust stack with the continuous instrumental monitors. The gas sample was continuously pulled through a 3 / 4 -inch diameter stainless steel probe and tr ansported via a 120-foot long, 3 / 8 -inch diameter heat-traced Teflon® line into the mobile laboratory using a stainl ess steel/Teflon® diaphragm pump. At the pump exit the pressurized sample was pushed into a h eated sample manifold. The bulk of the gas stream then passed to a stainless steel minimum contact condenser to dry the sample stream and into the (dry) sample manifold. From the mani fold, the sample was partitioned to the analyzers through glass and stainless steel flow meters for flow control of the sample.

All instruments were housed in an air-conditioned trailer-mounted mobile laboratory. Gaseous calibration standards were provided in aluminum cylinders with the concentrations certified by the vendor. EPA Protocol No. 1 was us ed to determine the cylinder concentrations where applicable, i.e., NO X calibration gases.

EPA Method 1 procedures were used to dete rmine the stratification test point locations for sampling per the requirements of EPA Methods 3A, 7E, and 10. The locations of the sample ports and traverse point distances for the turbine are denoted in the stack diagram located in Appendix A.

The stack gas analyses for CO 2 and O 2 concentrations were performed in accordance with procedures set forth in EPA Method 3A. Instrumental analyses were used in lieu of an Orsat or a Fyrite procedure due to the greater accuracy and precision provided by the instruments. The
CO 2 analyzer was based on the principl e of infrared absorption; the O 2 analyzer operated using a paramagnetic cell detector.

EPA Method was used to measure the moistu re content of the stack gases. A chilled water impingement system was used in conjunction with a calibrated dry gas meter to pull a sample greater than 21 standard cubic feet (scf ). A K-type (chromel-alumel) thermocouple was used in conjunction with a digital thermometer to determine the last impinger temperatures in the chilled liquids impingement sampling train. This pa rameter is measured to ensure that the gas stream is cooled to a minimum of 68 degrees Fahrenheit as required by sampling methodology.
Determination of the moisture content was necessa ry to convert VOC wet concentrations to a dry basis. EPA Method 5 equations were used to calculate stack moisture content.

NO X emission concentrations were determined in accordance with EPA Method 7E. The
NO X analyzer operated on the principle of chemiluminescence. As required, the NO X analyzer was equipped with a NO to NO 2 converter to allow for measurement of all forms of NO X as per EPA's definition. This analyzer used a high te mperature, approximately 650°C, converter to convert nitrogen dioxide (NO 2 ) in the sample stream to NO. Due to low NO X concentrations in the engine exhaust, a temperature controlled NO X analyzer, equipped with a chiller, was used to
control instrument drift. NO X mass emission rates were calculated as if all the NO X were in the
form of NO 2 . This approach corresponds to EPA's convention, however, it tends to overestimate
the actual NO X mass emission rates since the majority of NO X is in the form of NO which has less mass per unit volume (i.e., lbs. of emissions per ppmv concentration) than NO 2

.

### 11 CO emission concentrations were quantified in accordance with procedures set forth in
EPA Method 10. A continuous non-di spersive infrared (NDIR) analyzer was used for this purpose. This reference method analyzer was equipped with a gas correlation filter that removes most interference from moisture, CO 2 , and other combustion products.

THC emissions were measured using the inst rumental technique of EPA Method 25A for
use in determination of VOC emissions. The FID detector used in this method received a heated wet sample to ensure against the possibility of any heavy hydrocarbon condensing out prior to analysis. Calibration gases were on a propane basis in air.

CH 4 emissions were measured using the in strumental technique of EPA Method 25A equipped with a non-methane cutter as described in 40 CFR 1065.265 for use in determination of VOC emissions. The FID detector used in this method received a heated wet sample to ensure against the possibility of any heavy hydrocarbon c ondensing out prior to analysis. Calibration gases were on a propane basis in air with the analyzer switched from THC mode during
calibrations to CH 4 -only mode during the test runs.

VOC emissions were determined by subtrac ting the methane emissions from the THC emissions for each test run. This approach is described in 40 CFR 60, Subpart JJJJ as a procedure for measuring VOC emissions in the stack of an engine. Additional information regarding this sampling technique may be found in 40 CFR 1065 “Engine Testing Procedures”.

All data from the continuous monitoring instru ments were logged into a computer file in 1-minute intervals and rolling 1-minute averages. A data logger with a computer generated display screen monitored, recorded, and averag ed the emission concentrations. The program controlling the logging of data was also used to log quality assurance (QA) data. See Appendix F of this report for copies of the raw data and Appendix D for the QA data.

Visible emissions as opacity were determ ined via EPA Method 9. A 30-minute opacity test run was performed concurrently with a co mpliance test run on each engine. The visual
emission observer was certified at an FDEP a pproved smoke school. A ppendix H provides both the opacity observation sheets as well as observer certification documents.

The stoichiometric calculations of EPA Me thod 19 were used to calculate the stack
volumetric flow rates and mass emission rates. These calculations are based on the heating value
and the O 2 “F d -factor” (DSCF of exhaust pe r MMBtu of fuel burned) for landfill gas. Method 19
flow rate determinations are also based on the ex cess air, as measured from the exhaust diluent concentrations, and the fuel flow rates. EP A Method 19 was used as the stack flow rate measurement technique for all testing. Appendix C contains this analysis as well as the TRC fuel calculation worksheets used for determination of heating values and diluent F-factors.

A landfill gas (LFG) fuel sample, collected into a stainless steel canister at less than 500 milliliters per minute, was analyzed for O 2 , CO 2 , CH 4 , and N 2 in accordance with EPA Method 3C. These measurements were necessary to determine LFG heating value and EPA Method 19 “F-factors”. The sampling train consisted of a fl ow controller, absolute pressure gauge, and an evacuated sample tank. The flow controller was attached to the sample tank through the use of stainless steel quick connects. Triangle Environm ental Services, Inc. of Research Triangle Park, North Carolina conducted the analysis. Field sa mpling sheets are in Appendix A. A detailed

### 12 description of the sample analysis and the resu lts are contained in Appendix C. TRC normalized all the results supplied by the analytical laboratory.

TRC personnel collected ambient absolute pressure, temperature, and humidity data during each test run. A wet bulb/dry bulb psychr ometer equipped with a battery-operated fan was used to determine ambient temperature and humidity conditions. An aircraft-type aneroid barometer (altimeter) was used to measure absolute atmospheric pressure.

All emission calculations were conducted by a computer spreadsheet as shown in Tables 2 through 4 of this report. Example calculati ons were performed manually using a hand-held calculator in order to verify the formulas used in the spreadsheets. Example calculations are located in Appendix B of this report.TABLE5ANALYTICALINSTRUMENTATIONParameterModel and CommonSensitivityResponse Detection PrincipleManufacturerUse RangesTime (sec.)NOXTECO 0-10 ppm 0.1 ppm 1.7 Thermal reduction of NO2to NO.Model 42C 0-25 ppm Chemiluminescence of reaction0-50, 0-100 ppm of NO with O3. Detection by PMT.0-200, 500 ppm Inherently linear within 1% of full0-1,000 ppm scale.0-5,000 ppmCO TECO 0-1 ppm 0.1 ppm 60 Infrared absorption, gas filterModel 48 0-10 ppm correlation detector, micro-0-30, 0-50 ppm processor based linearization.0-100, 0-200 ppm0-500, 0-1000 ppmCO2Servomex 0-5% 0.025% < 10 Non-dispersive infrared absorption,1440 0-10% 0.05% electronic linearization of a0-15% 0.075% logarithmic signal (Beer’s Law)O2Servomex 0-5% 0.02% < 10 Paramagnetic cell detector,1440 0-10% 0.02% inherently linear.0-25% 0.02%VOC California 0-10, 0-100, 10 ppb 2.0 Flame ionization of hydrocarbonsAnalytical 0-1000, 0-10000 inherently linear within 1% overModel 300-HFID 0-100,000 ppm the range of the analyzer.PM AND HM-120 0-120 grams 0.0001g n/a Spring loaded pressure plate forgravimetric analysisNutech 2010 0-1SCFM n/a n/a Sample Console with temperaturecontrollers, sample pump, dry gasmeter, orifice meter, and inclined` manometer for isokinetic samplingNOTE:Higher ranges available by sample dilution.Other ranges available via signal attenuation.Vent

SS/Teflon®

Sample Pump 

### Sample

Manifold

Calibration Gases 

# TRC - Air

Measurements Calibration Line Heat Traced Line Dry Gas Sample Line 

## FIGURE 1
I NSTRUMENTAL 

## S AMPLE 

## S YSTEM 

## D IAGRAM

Calibraton
Gas
Manifold CO
Analyzer Analyzer Vent

NO x Analyzer Analyzer

O 2
Analyzer Analyzer CO 2
Analyzer Analyzer

Vent

Sample Stream

from Source 

### Condenser Ice Bath Sample System
Bias Check Line

Quick Connects Flowmeters

Flowmeters Duct, Flue,

or Stack THC
Analyzer Analyzer

### 15 QUALITY ASSURANCE ACTIVITIES

A number of quality assurance activities were undertaken before, during, and after this testing project. This section of the report co mbined with the documentation in Appendices D
and E describe each of those activities.

A multi-point calibration was performed for each instrument in the field prior to the collection of data. The instrument's linearity wa s checked by first adjusting the instrument's zero and span responses to zero nitrogen and an upscale calibration gas in the range of the expected concentrations. The instrument response was th en challenged with other calibration gases of known concentration. The instrument's response was accepted as being linear if the response of the other calibration gases agreed within ±2 percent of the analytical range (high-level calibration gas) from the predicted values. For the THC and CH 4 analyzers, the instrument's response was accepted as being linear if the respons e of the other calibration gases agreed within ±5 percent of the certified calibration gas value. The response of the infrared absorption type
CO and CO 2 analyzers is made linear through electronic suppression.

System bias checks were performed both befo re and after the sampling system was used for emissions testing. The sampling system's inte grity was tested by comparing the responses of
the NO X analyzer to a calibration gas (and a zero ga s) introduced via two paths as previously
described in the Analytical Techniques section of this report. This system bias test was performed to assure that no alteration of the samp le had occurred during the test due to leakage, reactions, or absorption. Similarly, system bias checks were performed on the THC, CH 4 , CO,
O 2 , and CO 2 analyzers for added assurance of sample sy stem integrity. The results of the system bias checks are available in Appendix D.

Prior to testing, a NO X converter efficiency check was conducted as required by EPA Method 7E. The procedures used are detailed in Method 7E, Section 8.2.4. The NO X analyzer
was calibrated and then a NO 2 calibration gas was introduced directly to the analyzer. The average analyzer response over 5 minutes was recorded and the converter efficiency calculated from this average response. If the converter effi ciency was at least 90 percent, then the converter is acceptable. Appendix D provides the results for the converter efficiency check.

The residence time of stack sampling and measurement system were estimated using the pump flow rate and the sampling system volume. The pump's rated flow rate is 1.2 scfm at 5 psig. The sampling system volume was approxima tely 0.28 scf. Therefore, the system had a minimum sample residence time of approximately 14 seconds.

The NO X , CO, O 2 and CO 2 sampling and analysis system was checked for response time per the procedures outlined in EPA Method 7E, Section 8.2.5 and 8.2.6. The maximum response
time did not exceed 80 seconds. The minimum sa mpling time per point selected was at least twice the maximum response time as determined duri ng the initial system bias tests. The results of these response time tests are contained in Appendix D.

### 16 TRC and/or instrument vendors conducted interference response tests on the NO X , CO,
O 2 , and CO 2 analyzers. For the NO X , CO, and O 2 analyzers, the sum of the interference responses for H 2 O, C 3 H 8 , CO, CO 2 and O 2 is less than 2 percent of th e applicable full-scale span
value. The instruments used for the tests meet the performance specifications for EPA Methods 3A, 7E, and 10 as written prior to the method updates. All of the analyzers predate the methodology updates as effective on August 14 th , 2006. The results of the interference tests are available in Appendix D of this report.

Each sampling system was leak checked by demonstrating that it could hold a vacuum greater than 15 inches of mercury ("Hg) for at l east 1 minute with a decline of less than 1 "Hg. A leak test was conducted after each sample system was set up, i.e., before testing began, at the beginning and end of each test day, and before th e system was dismantled, i.e., after testing was completed. This test was conducted to insure that ambient air was not diluting the sampling system. No leakage was detected.

As a minimum, before and after each test run, the analyzers were checked for zero and span drift. This allows test runs to be br acketed by calibrations and documents the precision of the data just collected. Calibration gases were introduced to the analyzers through the entire sampling system. Appendix D contains quality assurance tables that summarize the zero and span checks that were performed for each test run. The worksheets also contain the data used to correct the data for drift per EPA Method 7E, Equation 7E-5. NO X , CO, O 2 and CO 2 data were corrected for drift as required by the test methods. Additionally, THC and CH 4 data were corrected for drift in order to be more consistent and accurate in the reporting of results.

The control gases used to calibrate the in struments were analyzed and certified by the compressed gas vendors to ±1% accuracy for all calibration gases. EPA Protocol No. 1 was used, where applicable, i.e., NO X gases, to assign the concentration values traceable to the National Institute of Standards and Technology (NIS T), Standard Reference Materials (SRM's). The gas calibration sheets as prepared by the vendor are contained in Appendix E.

Additional quality assurance activities were pe rformed on the two THC analyzers, used
for determination of VOC emissions. Both TH C analyzers were calibrated using the same propane gases in air. A comparison against a methane standard was used to verify the consistency of the responses of the two an alyzers to a different hydrocarbon. An 895 ppmv standard was used and both analyzers responses were within ±2% of each other and within ±5% of the anticipated response based upon analytical theory. TRC has proposed using a 200 to 300 ppmv standard in the test protocol, but the stack emissions were closer to the 895 ppmv gas and therefore, more representative. In addition, on the THC analyzer used for determination of methane emissions, the efficiency of the non-meth ane cutter was tested against an ethane and a propane standard. Breakthrough of VOC as et hane was 10.7% and breakthrough as propane was -0.4%; i.e., there was no breakthrough for propane. Since ethane is not classified by EPA as a VOC and propane is classified as a VOC, it was determined that no adjustments were necessary to correct for ethane emission breakthrough.

The moisture train sampling system was leak checked by demonstrating that it could hold a vacuum greater than the highest sampling vacuum for at least 1 minute with a leakage rate less than 0.02 cubic feet per minute (cfm). A leak te st was conducted before ea ch test run began and after each test run was completed. This leak check was performed in accordance with EPA

### 17 Method 4 to ensure that the sample was not dilu ted by ambient air. Leak checks were conducted at a vacuum higher than that used during sa mpling. No leaks greater than 0.02 cfm were
detected.

The dry gas meter of the moisture train was calibrated prior to testing in accordance with EPA Method 5. The dry gas meter in the control box was calibrated and a flow curve and dry gas meter factor was generated using the calib rated orifice procedure. A post-test meter calibration check was performed upon return to the TRC Gainesville Office using the Y qa check. All glassware was thoroughly washed, rinsed, drie d, and stored to prevent contamination. The calibration certifications of the dry gas mete r are found in Appendix E of this report.

Quality assurance procedures for laboratory analysis of the landfill gas for O 2 , CO 2 , CH 4 , and N 2 were conducted in accordance with EPA Method 3C protocols. Upon return to the TRC office samples were packed into a shipping cont ainer, sealed, and shipped with a chain-ofcustody form to Triangle Environmental Services, Inc. Results of the quality assurance activities are reported with the lab results in Appendix C.

Appendix E also contains calibration data fo r the ancillary equipment used during this testing. An altimeter/barometer was used for determination of barometric pressure. A fanoperated psychrometer with NIST traceable ther mometers was used to determine ambient and dew point temperatures. Other ancillary equipm ent includes analytical balance calibration data, angle finder calibration data, and caliper calibration data.

TRC collected and reported the enclosed test data in accordance with the procedures and quality assurance activities described in this te st report. TRC makes no warranty as to the suitability of the test methods. TRC assumes no lia bility relating to the interpretation and use of the test data by others.