TEST REPORT

For

INITIAL COMPLIANCE TESTING

From 

TWO 1.6-MW LANDFILL GAS FUELED

CATERPILLAR MODEL NO. G3520C GENERATOR ENGINES

In Service at the 

MARION COUNTY BASELINE LANDFILL 

Located in 

OCALA, MARION COUNTY, FLORIDA

Prepared for 

G2 ENERGY, LLC 

Test Completion Date: March 25th, 2009 

Report Submittal Date: April 30th, 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 conducted on Units 1 and 2, two 1.6 Megawatt (MW) 

Caterpillar Model No. G3520C landfill gas fired generator 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, Marion County, Florida. G2 Energy, LLC owns 

this power generation facility which is operated by Autotech II personnel. TRC – Air 

Measurements, Gainesville Office (TRC) conducted these tests on March 24th and 25th, 2009. 

 The purpose of this testing was to determine 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 Department 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 (NOX), carbon monoxide (CO), total hydrocarbon 

compounds (THC), methane (CH4), oxygen (O2), and carbon dioxide (CO2) using continuous 

instrumental monitors. Volatile organic compound (VOC) emissions were determined by 

determining by subtracting the CH4 emissions from the THC emissions. 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 permanent 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 

BACKGROUND DATA

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 18th 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 66th 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 are federally regulated under 40 

CFR 60, Subpart JJJJ “Standards of Performance for 

Stationary Spark Ignition Internal Combustion Engines”. 

Test Dates: March 24th, and 25th, 2009 
3 

Emission Sampling Points: Each unit is equipped with a circular stack, located outside 

of the building roof is approximately 32 feet tall with an 

internal diameter of 13 inches. Two 3-inch diameter 

sample ports are located perpendicular 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 

(CO2) and oxygen (O2) 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 determination of stack gas 

moisture content using gravimetric analysis. 

 EPA Method 7E was used for determination of oxides of 

nitrogen (NOX) 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 O2 and 

CO2 “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 a 

second flame ionization analyzer equipped with a nonmethane cutter as described in 40 CFR 1065.265 to 

determine methane (CH4) 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 generation facility at the Marion County Board of 

County Commissioners – Baseline Landfill in Ocala, Marion County, Florida. Two landfill gas 

fueled Caterpillar Model No. G3520C generator engines are in service at this facility and are 

used for the production of electricity. G2 Energy 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 performance 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 compared to the permit limits set forth in FDEP Air 

Construction Permit No. 0830124-006-AC and EPA 40 CFR 60, Subpart JJJJ performance 

specifications. NOX, CO, and VOC emission rates are reported in terms of parts per million by 

volume (ppmv) at 15% excess O2 on a dry basis and grams per 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 -

NOX (ppmv @ 15% O2, dry basis) 86.9 90.9 220

NOX (g/bhp-hr) 1.17 1.24 3.0

CO (ppmv @ 15% O2, dry basis) 447 428 610

CO (g/bhp-hr) 3.68 3.54 5.0

VOC (ppmv @ 15% O2, 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 consisted 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, O2 and CO2 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, O2, and CO2 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 three test runs at full load on each unit. 

Each test run was 60 minutes in duration. Emissions of NOX, CO, THC, CH4, VOC, and VE 

were determined. NOX, CO, THC, CH4, O2, and CO2 were measured using continuous 

instrumental monitors. A landfill gas fuel sample was collected during the three test runs on 

each unit for analysis of fuel composition and gross heating value. Co-incident 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 pertinent operational parameters, landfill gas fuel data, 

ambient conditions, measured emissions, corrected concentrations, and calculated emission rates. 

NOX, CO, and VOC emissions are reported in units of parts per million (ppmv) on a dry basis 

and ppmv, dry corrected to 15% excess O2. THC and CH4 emissions are reported in units of 

ppmv on a wet basis as propane. Mass emission rates for NOX, 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 calculation based on measurements of diluent gas (O2 or 

CO2) 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 run 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, the stratification results, and all field data 

sheets used during these tests. Appendix B contains 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 are 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 NOX, CO, THC, CH4, O2, and CO2

concentrations. Appendix G contains unit operational 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 Amperage (Amps) 221 224 224 223

Generator Voltage (kVolts) 4202 4186 4174 4187

Generator Frequency (Hertz) 60 60 60 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

O2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9432 9432 9432 9432

CO2 "F-factor" (DSCFex/MMBtu @ 0% excess air ) 1785 1785 1785 1785

LFG CH4 Content (% volume, dry basis) 56.5 no data no data 56.5

LFG O2 Content (% volume, dry basis) 0.5 0.1 0.1 0.3

Wellhead Vacuum ("H2O) 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 

NOX (ppmv, dry basis) 201.1 194.4 197.1 197.5

NOX (ppmv @ 15% O2, dry basis) 88.3 85.4 87.1 86.9 220

CO (ppmv, dry basis) 1031 1016 1002 1016

CO (ppmv @ 15% O2, 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% O2, dry basis as Propane) 9.12 10.3 5.64 8.36 80

VE (% opacity) 0 - - 0 20

O2 (% volume, dry basis) 7.46 7.47 7.55 7.49

CO2 (% volume, dry basis) 12.21 12.20 12.12 12.18

H2O (% volume, from Method 4 sample train) 13.36 14.40 13.80 13.85

Stack Volumetric Flow Rates

via EPA Method 19 O2 "Fd-factor" (SCFH, dry basis) 2.41E+05 2.34E+05 2.34E+05 2.36E+05

via EPA Method 19 CO2 "Fc-factor" (SCFH, dry basis) 2.40E+05 2.33E+05 2.33E+05 2.36E+05

Calculated Emission Rates (from EPA Method 19 flow rates)

NOX (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

NOX (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/bhp-hr) 0.120 0.133 0.0722 0.108 1.0

Testing by TRC - Air Measurements • Gainesville Office

6
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 Amperage (Amps) 209 205 206 207

Generator Voltage (kVolts) 4165 4183 4192 4180

Generator Frequency (Hertz) 60 60 60 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

O2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9389 9389 9389 9389

CO2 "F-factor" (DSCFex/MMBtu @ 0% excess air ) 1782 1782 1782 1782

LFG CH4 Content (% volume, dry basis) no data no data no data no data

LFG O2 Content (% volume, dry basis) 0.1 0.1 0.1 0.1

Wellhead Vacuum ("H2O) 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 

NOX (ppmv, dry basis) 203.3 205.8 200.0 203.0

NOX (ppmv @ 15% O2, 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% O2, 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% O2, dry basis as Propane) 19.5 24.7 23.1 22.4 80

VE (% opacity) 0 - - 0 20

O2 (% volume, dry basis) 7.69 7.74 7.75 7.73

CO2 (% volume, dry basis) 12.00 11.98 11.96 11.98

H2O (% volume, from Method 4 sample train) 13.30 13.38 13.33 13.34

Stack Volumetric Flow Rates

via EPA Method 19 O2 "Fd-factor" (SCFH, dry basis) 2.27E+05 2.19E+05 2.23E+05 2.23E+05

via EPA Method 19 CO2 "Fc-factor" (SCFH, dry basis) 2.26E+05 2.18E+05 2.23E+05 2.22E+05

Calculated Emission Rates (from EPA Method 19 flow rates)

NOX (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

NOX (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/bhp-hr) 0.256 0.322 0.300 0.293 1.0

Testing by TRC - Air Measurements • Gainesville Office

7
8 

PROCESS DESCRIPTION

 G2 Energy owns a power generation facility, 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, were 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 horizontal 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 nearest flow disturbance. Access to the stack was 

made available via a safety ladder. The diameter of the exhaust stack was 13.0 inches. 

Appendix A contains a field sketch of the stack configuration and sample port locations. 

 G2 Energy personnel provided operational data from the engine instrument panels. Data 

sets were recorded at approximate 30-minute intervals 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 were measured at the MCBCC Baseline Landfill 

located in Ocala, Marion County, Florida. TRC performed these tests on March 24th and 25th, 

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 NOX, CO, THC, CH4, O2 and CO2 were performed 

using continuous instrumental monitors. Exhaust gas analyses were performed on a dry basis for 

all compounds except THC and CH4 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 impingement sampling train. Landfill gas fuel sampling 

and analysis was conducted in accordance with EPA Method 3C. 

The first step in the test matrix consisted 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, O2 and CO2 concentrations 

were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. No 

significant stratification was observed for the CO, O2, and CO2 emissions. 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 engine stack. 

Following the stratification test, TRC conducted three test runs at full load on each unit. 

Each test run was 60 minutes in duration. Emissions of NOX, CO, THC, CH4, VOC, and VE 

were determined. NOX, CO, THC, CH4, O2, and CO2 were measured using continuous 

instrumental monitors. VOC emissions were determined by subtracting the CH4 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 calibration 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 system including the sample probe, filter, heat 

trace, condenser, manifold, and flow meters. The 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 the sampling system (sample system bias check). 

A NOX standard calibration gas was introduced into the NOX analyzer directly. Then the 

response from the NOX analyzer was noted as the calibration gas was introduced at the probe. 

Any difference between the two responses in the instrument was attributed to the bias of the 

sample system. Following the span gas bias check, a zero gas bias check was performed on the 

NOX 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 

O2, and CO2 analyzers. Although not required by EPA Method 25A, this procedure was also 

conducted for the THC and CH4 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 transported via a 120-foot long, 3/8-inch diameter heat-traced Teflon® 

line into the mobile laboratory using a stainless steel/Teflon® diaphragm pump. At the pump 

exit the pressurized sample was pushed into a heated 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 manifold, 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 used to determine the cylinder concentrations 

where applicable, i.e., NOX calibration gases. 

 EPA Method 1 procedures were used to determine 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 CO2 and O2 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 

CO2 analyzer was based on the principle of infrared absorption; the O2 analyzer operated using a 

paramagnetic cell detector. 

 EPA Method was used to measure the moisture 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 parameter 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 necessary to convert VOC wet concentrations to a dry 

basis. EPA Method 5 equations were used to calculate stack moisture content. 

NOX emission concentrations were determined in accordance with EPA Method 7E. The 

NOX analyzer operated on the principle of chemiluminescence. As required, the NOX analyzer 

was equipped with a NO to NO2 converter to allow for measurement of all forms of NOX as per 

EPA's definition. This analyzer used a high temperature, approximately 650°C, converter to 

convert nitrogen dioxide (NO2) in the sample stream to NO. Due to low NOX concentrations in 

the engine exhaust, a temperature controlled NOX analyzer, equipped with a chiller, was used to 

control instrument drift. NOX mass emission rates were calculated as if all the NOX were in the 

form of NO2. This approach corresponds to EPA's convention, however, it tends to overestimate 

the actual NOX mass emission rates since the majority of NOX is in the form of NO which has 

less mass per unit volume (i.e., lbs. of emissions per ppmv concentration) than NO2. 
11 

 CO emission concentrations were quantified in accordance with procedures set forth in 

EPA Method 10. A continuous non-dispersive 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, CO2, and other combustion products. 

THC emissions were measured using the instrumental 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. 

CH4 emissions were measured using the instrumental 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 condensing out prior to analysis. Calibration 

gases were on a propane basis in air with the analyzer switched from THC mode during 

calibrations to CH4-only mode during the test runs. 

VOC emissions were determined by subtracting 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 instruments 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 averaged 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 determined via EPA Method 9. A 30-minute opacity 

test run was performed concurrently with a compliance test run on each engine. The visual 

emission observer was certified at an FDEP approved smoke school. Appendix H provides both 

the opacity observation sheets as well as observer certification documents. 

The stoichiometric calculations of EPA Method 19 were used to calculate the stack 

volumetric flow rates and mass emission rates. These calculations are based on the heating value 

and the O2 “Fd-factor” (DSCF of exhaust per MMBtu of fuel burned) for landfill gas. Method 19 

flow rate determinations are also based on the excess air, as measured from the exhaust diluent 

concentrations, and the fuel flow rates. EPA 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 O2, CO2, CH4, and N2 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 flow 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 Environmental Services, Inc. of Research Triangle Park, 

North Carolina conducted the analysis. Field sampling sheets are in Appendix A. A detailed 
12 

description of the sample analysis and the results 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 psychrometer 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 calculations 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. 
TABLE 5

ANALYTICAL INSTRUMENTATION

Parameter Model and Common Sensitivity Response Detection Principle

 Manufacturer Use Ranges Time (sec.)

NOX TECO 0-10 ppm 0.1 ppm 1.7 Thermal reduction of NO2 to NO.  Model 42C 0-25 ppm Chemiluminescence of reaction  0-50, 0-100 ppm of NO with O3. Detection by PMT.  0-200, 500 ppm Inherently linear within 1% of full  0-1,000 ppm scale.  0-5,000 ppm CO TECO 0-1 ppm 0.1 ppm 60 Infrared absorption, gas filter  Model 48 0-10 ppm correlation detector, micro-  0-30, 0-50 ppm processor based linearization.  0-100, 0-200 ppm  0-500, 0-1000 ppm CO2 Servomex 0-5% 0.025% < 10 Non-dispersive infrared absorption,  1440 0-10% 0.05% electronic linearization of a  0-15% 0.075% logarithmic signal (Beer’s Law) O2 Servomex 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 hydrocarbons  Analytical 0-1000, 0-10000 inherently linear within 1% over  Model 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 for  gravimetric analysis  Nutech 2010 0-1SCFM n/a n/a Sample Console with temperature  controllers, sample pump, dry gas  meter, orifice meter, and inclined  ` manometer for isokinetic sampling NOTE: Higher ranges available by sample dilution.  Other ranges available via signal attenuation.

13
SS/Teflon®

Sample

Pump

Sample

Manifold

Calibration Gases

Heat Traced Line

Dry Gas Sample Line

Calibration Line

FIGURE 1

INSTRUMENTAL SAMPLE SYSTEM DIAGRAM

A

A

NOx

Analyzer

Analyzer

O2

Analyzer

Analyzer

A

A

Sample Stream

from Source

Condenser

Ice

Bath

Sample System

Bias Check Line

Quick Connects

Flowmeters

Flowmeters

Duct, Flue,

 or Stack

THC

Analyzer

Analyzer

14
15 

QUALITY ASSURANCE ACTIVITIES

 A number of quality assurance activities were undertaken before, during, and after this 

testing project. This section of the report combined 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 was 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 then 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 CH4 analyzers, the instrument's 

response was accepted as being linear if the response of the other calibration gases agreed within 

±5 percent of the certified calibration gas value. The response of the infrared absorption type 

CO and CO2 analyzers is made linear through electronic suppression. 

 System bias checks were performed both before and after the sampling system was used 

for emissions testing. The sampling system's integrity was tested by comparing the responses of 

the NOX analyzer to a calibration gas (and a zero gas) 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 sample had occurred during the test due to leakage, 

reactions, or absorption. Similarly, system bias checks were performed on the THC, CH4, CO, 

O2, and CO2 analyzers for added assurance of sample system integrity. The results of the system 

bias checks are available in Appendix D. 

Prior to testing, a NOX converter efficiency check was conducted as required by EPA 

Method 7E. The procedures used are detailed in Method 7E, Section 8.2.4. The NOX analyzer 

was calibrated and then a NO2 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 efficiency 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 approximately 0.28 scf. Therefore, the system had a 

minimum sample residence time of approximately 14 seconds. 

The NOX, CO, O2 and CO2 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 sampling time per point selected was at least 

twice the maximum response time as determined during 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 NOX, CO, 

O2, and CO2 analyzers. For the NOX, CO, and O2 analyzers, the sum of the interference 

responses for H2O, C3H8, CO, CO2 and O2 is less than 2 percent of the 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 14th, 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 least 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 the 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 bracketed 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. NOX, CO, O2 and CO2 data were 

corrected for drift as required by the test methods. Additionally, THC and CH4 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 instruments 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., NOX gases, to assign the concentration values traceable to the 

National Institute of Standards and Technology (NIST), Standard Reference Materials (SRM's). 

The gas calibration sheets as prepared by the vendor are contained in Appendix E. 

Additional quality assurance activities were performed on the two THC analyzers, used 

for determination of VOC emissions. Both THC 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 analyzers 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-methane cutter was tested against an ethane and a 

propane standard. Breakthrough of VOC as ethane 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 test was conducted before each 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 diluted by ambient air. Leak checks were conducted 

at a vacuum higher than that used during sampling. 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 calibrated orifice procedure. A post-test meter 

calibration check was performed upon return to the TRC Gainesville Office using the Yqa check. 

All glassware was thoroughly washed, rinsed, dried, and stored to prevent contamination. The 

calibration certifications of the dry gas meter are found in Appendix E of this report. 

Quality assurance procedures for laboratory analysis of the landfill gas for O2, CO2, CH4, 

and N2 were conducted in accordance with EPA Method 3C protocols. Upon return to the TRC 

office samples were packed into a shipping container, 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 for the ancillary equipment used during this 

testing. An altimeter/barometer was used for determination of barometric pressure. A fanoperated psychrometer with NIST traceable thermometers was used to determine ambient and 

dew point temperatures. Other ancillary equipment 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 test report. TRC makes no warranty as to the 

suitability of the test methods. TRC assumes no liability relating to the interpretation and use of 

the test data by others.