Derenzo and Associates, Inc. 

Environmental Consultants 

39395 Schoolcraft Road • Livonia, MI 48150 • (734) 464-3880 • FAX (734) 464-4368 

4970 Northwind, Suite 213 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409

May 4, 2009 

Mr. Scott Salisbury 

President 

Seminole Energy LLC 

29261 Wall Street 

Wixom, Michigan 48393 

Subject: Seminole Energy, LLC Compliance Testing Test Report 

Mr. Salisbury, 

Derenzo and Associates, Inc. is forwarding a copy (for your records) of the enclosed test report 

for the verification of nitrogen oxides, carbon monoxide, hydrogen chloride, particulate matter 

less than 10 microns, volatile organic compound emissions and opacity determinations from the 

Unit #1 CAT Model No. G3520C 2,233 brake-horsepower landfill gas-fueled engines used for 

the generation of up to a total of 9.6 megawatts (nominal rating) of electricity at the Seminole 

Energy facility. 

Copies of the test report have submitted on your behalf to the appropriate offices of the Florida 

Departmental of Environmental Protection - Emission Monitoring Section. 

 

Derenzo and Associates appreciates the opportunity to be of continued assistance to Landfill 

Energy Systems and its subsidiaries. 

Sincerely, 

Michael Brack 

Field Services Manager 

Enclosures 
Derenzo and Associates, Inc. 

Environmental Consultants 

39395 Schoolcraft Road • Livonia, MI 48150 • (734) 464-3880 • FAX (734) 464-4368 

4970 Northwind, Suite 213 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409

EMISSIONS TEST REPORT 

Title 

Compliance Test Report for the #1 Landfill Gas Fueled 

G3520C Internal Combustion Engine Operated at the 

Seminole Energy, L.L.C., Osceola Road Solid Waste 

Management Facility, Seminole County, Florida 

Report 

Date April 28, 2009 

Test 

Date(s) March 23 & 24, 2009 

Facility Information 

Name Seminole Energy, L.L.C., Osceola Road Solid Waste 

Management Facility 

City, County Geneva, Seminole 

Facility Permit Information 

DEP File No.: 1170084-005-AC Permit No.: PSD-FL-376 

Testing Contractor 

Company Derenzo and Associates, Inc. 

Mailing 

Address 

39395 Schoolcraft Road 

Livonia, MI 48150 

Phone (734) 464-3880 

Project No. 0901015 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 28, 2009 

Compliance Test Report Page i 

TABLE OF CONTENTS 

Page 

1.0 SOURCE INFORMATION ........................................................................................................ 1 

2.0 PLANT AND SAMPLING LOCATION DESCRIPTION ......................................................... 2

2.1 General Process Description ................................................................................................. 2 

2.2 Rated Capacities, Type and Quantity of Raw Materials Used .............................................. 2 

2.3 Emission Control System Description .................................................................................. 2 

2.4 Sampling Locations (USEPA Method 1) ............................................................................. 2 

3.0 SUMMARY AND DISCUSSION OF TEST RESULTS ........................................................... 3 

3.1 Purpose and Objectives of the Tests ..................................................................................... 3 

3.2 Variations from Normal Sampling Procedures or Operating Conditions ............................. 3

3.3 Operating Conditions during Compliance Tests .................................................................. 4 

3.4 Air Pollutant Sampling Results ............................................................................................ 4 

4.0 SAMPLING AND ANALYTICAL PROCEDURES ................................................................. 5 

4.1 Exhaust Gas Velocity and Flowrate Determination (USEPA Method 2) ............................. 5 

4.2 Exhaust Gas Molecular Weight Determination (USEPA Method 3A) ................................ 5 

4.3 Exhaust Gas Moisture Content Determinations (Method 4) ................................................ 6 

4.4 NOx and CO Concentration Measurements (USEPA Method 7E and 10) ........................... 6 

4.5 Particulate Matter Concentration Measurements (USEPA 5/USEPA 202) ......................... 6 

4.6 Volatile Organic Compound Measurement (USEPA Methods 25A/25C) ........................... 7 

4.7 Hydrogen Chloride Measurements (USEPA Method 26A) ................................................. 7 

4.8 Visible Emissions Determinations (USEPA Method 9) ....................................................... 7 

5.0 INTERNAL QA/QC ACTIVITIES ............................................................................................. 7 

5.1 NOx Converter Efficiency Test ............................................................................................. 7 

5.2 Sampling System Response Time Determination ................................................................ 7 

5.3 Determination of Exhaust Gas Stratification ........................................................................ 8 

5.4 Instrumental Analyzer Interference Check ........................................................................... 8 

5.5 Instrument Calibration and System Bias Checks .................................................................. 8 

5.7 Meter Box Calibrations and Percent Isokinetics .................................................................. 8 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 28, 2009 

Compliance Test Report Page ii 

LIST OF TABLES 

 Table Page 

1 Particulate Matter less than 10 Microns (PM10) Emission Rates from the Unit #1 Engine at the 

Seminole Energy, L.L.C. - Osceola Road Solid Waste Facility ............................................................... 11 

2 Hydrogen Chloride Emission Rates from the Unit #1 Engine at the Seminole Energy, L.L.C. - 

Osceola Road Solid Waste Facility .......................................................................................................... 12 

3 Calculation of HCl Emission Factor Based on Influent Landfill Gas Chlorinated Compounds to 

the #1 Caterpillar Model G3520C Engine at the Seminole Energy, LLC - Osceola Road Solid 

Waste Facility ........................................................................................................................................... 13 

4 Nitrogen Oxides, Carbon Monoxide, and Volatile Organic Compound Concentrations, Emission 

Rates, and Emission Factors from the Unit #1 Caterpillar Model G3520C Engine at the 

Seminole Energy, L.L.C. - Osceola Road Solid Waste Facility............................................................... 14 

5 Six-Minute USEPA Method 9 Opacity Averages for the Caterpillar Model G3520C Engine Unit 

#1 at the Seminole Energy, L.L.C - Osceola Road Solid Waste Management Facility. .......................... 15 

LIST OF FIGURE(S) 

Figure 1. Seminole Energy Facility Process Flow Diagram 

Figure 2. Seminole Energy Source Diagram 

Figure 3. Seminole Energy Exhaust Sampling Location 

Figure 4. Instrumental Analyzer Sampling Train Diagram (USEPA Methods 3A, 7E, and 10) 

Figure 5. Isokinetic Sampling Train Diagram (USEPA Methods 5 and 202) 

Figure 6. Isokinetic Sampling Train Diagram (USEPA Methods 26A) 

LIST OF APPENDICES 

Appendix A Computer Calculated and Field Sampling Data Sheets 

Appendix B Equipment Calibration Data and Opacity Certification 

Appendix C Laboratory Data 

Appendix D Sample Calculations 

Appendix E Process Data 

Appendix F Detailed Descriptions of Sampling Procedures 
Derenzo and Associates, Inc. 

Environmental Consultants 

39395 Schoolcraft Road • Livonia, MI 48150 • (734) 464-3880 • FAX (734) 464-4368 

4970 Northwind, Suite 213 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409

COMPLIANCE TEST REPORT 

FOR THE 

LANDFILL GAS FUELED G3520C INTERNAL COMBUSTION ENGINE 

OPERATED AT THE 

SEMINOLE ENERGY, L.L.C. 

OSCEOLA ROAD SOLID WASTE MANAGEMENT FACILITY 

SEMINOLE COUNTY, FLORIDA 

1.0 SOURCE INFORMATION 

Seminole Energy, L.L.C. (Seminole Energy) is located at Osceola Solid Waste Management 

facility in Osceola County, Florida. The Facility File No. is 1170084-005-AC and the Permit No. 

is PSD-FL-376. At its landfill gas to energy (LFGTE) facility, Seminole Energy is permitted to 

operate emission units 002 – 005 which consist of four (4) Caterpillar G3520C Lean Burn 

Reciprocating Engines and electricity generator sets. These engines are fueled with methane-rich 

gas, which is generated at the Osceola Solid Waste Management Facility Landfill, to power base 

load electricity generator operations. 

The FDEP permit requires performance testing of a representative engine for the determination 

of specified pollutant emissions while the unit is operated at near base load conditions. 

Compliance testing was performed to measure nitrogen oxides (NOX), carbon monoxide (CO), 

particulate with diameters equal to or less than 10 microns (PM-10), volatile organic compound 

(VOC), hydrogen chloride (HCl), and oxygen (O2), concentrations and emission rates and opacity 

from the exhaust of the Unit #1 engine pursuant to the testing requirements specified in the 

FDEP Air Construction Permit. 

The compliance testing was performed on March 23 & 24, 2009 by Derenzo and Associates, Inc., an

environmental consulting and testing company from Livonia, MI. 

The exhaust gas sampling and analysis was performed using procedures specified in the Test 

Protocol dated February 13, 2009. 

Questions regarding this emission test report should be directed to: 

Mr. Michael Brack 

Field Services Manager 

Derenzo and Associates, Inc. 

39395 Schoolcraft Road 

Livonia, MI 48150 

(734) 464-3880 

Mr. Michael Laframboise 

Sr. Vice President - Operations 

Landfill Energy Systems. 

29261 Wall Street 

Wixom, MI 48393 

(248) 380-3920 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 2

2.0 PLANT AND SAMPLING LOCATION DESCRIPTION 

2.1 General Process Description 

Methane-rich landfill gas (LFG) is produced in the Osceola Solid Waste Management Landfill from 

the anaerobic decomposition of disposed waste materials. The methane-rich LFG is collected from 

both active and capped landfill cells using a system of wells that are connected to a central header 

(gas collection system). The collected LFG is directed to the Seminole Energy facility where it is 

treated and used as fuel for the IC engine generators that produce electricity for transfer to the local 

utility. 

The Seminole Energy facility currently consists of four (4) CAT Model No.G3520C IC internal 

combustion engines that are connected to individual electricity generators. 

A process flow diagram for the LFG to electricity process is presented subsequent to the summary 

tables in this report. 

2.2 Rated Capacities, Type and Quantity of Raw Materials Used 

The representative CAT G3520C IC engine generator set was operated at base load conditions (i.e., 

100% of the design capacity of 2,233 brake horsepower) to produce a peak electricity output of 1,600 

kilowatts (kW). Fuel (treated landfill gas) consumption is regulated to maintain the required heat 

input rate to support engine operations and is dependant on the fuel heat value (methane content). 

The average engine fuel consumption rate during the test periods was 594.5 scfm based on data 

recorded from the fuel flow meter installed and operated by Seminole Energy. 

Appendix E provides engine generator process data collected during the compliance test. 

2.3 Emission Control System Description 

The engines incorporate state of the art technology in order to fire lean fuel mixtures and produce 

low combustion by-product emissions. Emissions from the combustion of LFG are released 

uncontrolled into the ambient air through a stack connected to the IC engine exhaust manifold and 

noise control system (noise muffler). 

2.4 Sampling Locations (USEPA Method 1) 

The exhaust stack sampling port for the Model G3520C IC engine satisfied the USEPA Method 1 

criteria for a representative sample location. The inner diameter of the engine exhaust stacks is 15.5 

inches. The stack is equipped with two (2) sample ports, opposed 90°, that provide a sampling 

location 53 inches (3.4 duct diameters) downstream and 124 inches (8 duct diameters) upstream 

from any flow disturbance. 

Velocity pressure traverse locations for the sampling points were determined in accordance with 

USEPA Method 1 for the representative engine. 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 3

Included, following the summary tables is a diagram presenting the performance test sampling 

locations. 

The relatively small stack diameter (15.5 inches) of the engine exhaust is obstructed by the surface 

area of the isokinetic sampling probe, which tends to bias the exhaust velocity measurements on the 

high side. The test results are calculated from pre-test velocity averages. 

3.0 SUMMARY AND DISCUSSION OF TEST RESULTS 

3.1 Purpose and Objectives of the Tests 

Stack testing is required for emission units 002 through 005 to demonstrate compliance with the CO, 

NOX, PM-10, VOC, HCl, and opacity emission limits by permit conditions. The facility is required 

to perform initial, annual and permit renewal testing during a six-year period. This test event 

satisfies the 2009 annual performance test required by the permit. 

The PM-10 emissions were determined by combining the total filterable with the total condensable 

portions of the USEPA Method 5 and USEPA Method 202 sampling trains. 

The VOC emission rate from the tested engine was determined by subtracting the methane 

concentration (laboratory USEPA Method 18 field analysis) from the total hydrocarbon (THC) 

concentration determined by USEPA Method 25A field analysis. 

The exhausts from the LFG-fueled IC engines were monitored for six (6) one-hour test periods 

during which the O2, and CO2 exhaust gas concentrations were measured using instrumental 

analyzers. The engine NOx, and CO measurements consisted of triplicate 60-minute measurements 

using instrumental analyzers, and the PM10, and HCl consisted of triplicate 60-minute 

measurements using isokinetic sampling equipment. 

Exhaust gas moisture content from the representative engine was determined by gravimetric analysis 

of the weight gain in the chilled impingers. Velocity and volumetric flow rates were measured prior 

to each isokinetic sampling test period and during pre-test and post-test time periods. 

Opacity observations were made during one of the PM-10 tests and were observed at the point of 

greatest opacity in the portion of the plume where condensed water vapor is not present, with 

continuous readings taken every 15 seconds for 60 minutes. 

The testing was performed while the IC engine was operated at normal base load conditions (1600 

kW peak electricity output +/- 5%). 

 

3.2 Variations from Normal Sampling Procedures or Operating Conditions 

The testing for all pollutants were performed in accordance with the Test Protocol dated February 13, 

2009 and specified USEPA test methods. Isokinetic sampling rates were determined using pre-test 

velocity measurements. 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 4

Instrument calibrations and sampling period results satisfied the quality assurance verifications 

required by USEPA Methods 3A, 7E, 10,18 and 25A. No variations from the normal operating 

conditions of the IC engine occurred during the testing program. 

3.3 Operating Conditions during Compliance Tests 

The representative LFG-fueled IC engine was operated at base load (100% capacity +/- 5%) 

conditions during the compliance testing. The average kilowatt (kW) output value displayed by the 

engine data management computer (LCD screen) were manually recorded 3 times during each test 

period. LFG flowrate information was obtained similarly (manually recorded readings) from data 

displayed by the fuel flow rate meter installed at the facility. The average LFG consumption rate 

during the testing was 594.5 standard cubic feet per minute (scfm). The average electrical output 

rate during the test event was 1,602.5 kW. 

3.4 Air Pollutant Sampling Results 

The following table presents the engine #1 three-test average emission rates from the initial 

performance evaluation: 

Emission Parameter Unit #1 Emissions Permit Limit 

NOx NOX emissions (lb/hr) 1.95 2.95 

 NOX emissions (g/bhp-hr) 0.40 0.60 

 

CO CO emissions (lb/hr) 13.14 13.54 

 CO emissions (g/bhp-hr) 2.66 2.75 

 

VOC VOC emissions (lb/hr) 0.0 1.37 

 VOC emissions (g/bhp-hr) 0.0 0.28 

 

PM10 PM10 emissions (lb/hr) 3-Test Average 1.25 1.18 

 PM10 emissions (g/bhp-hr) 3-Test Average 0.25 0.24 

 

PM10 PM10 emissions (lb/hr) Test 1& 2 Average 0.69 1.18 

 PM10 emissions (g/bhp-hr) Test 1& 2 Average 0.14 0.24 

 

HCl HCl emissions (lb/hr) 0.03 - 

 HCl emissions (lb/MMscf) 0.81 10.9 

 

O2 Oxygen concentration (%) 7.9 - 

 

Opacity Highest 10 second average (%) 0.0 10 

Notes

(lb/hr) pounds per hour, (g/bhp-hr) grams per brake horsepower hour, (lb/MMscf) pounds per million standard 

cubic foot 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 5

Tables 1 through 5 present measured gas conditions and pollutant emission rates for the 

representative LFG-fueled IC engine. 

Appendix A provides computer calculated and field data sheets for the IC engine tests. 

Appendix A provides raw instrumental analyzer response data for each test period. 

4.0 SAMPLING AND ANALYTICAL PROCEDURES 

A test protocol for the compliance testing was prepared by Derenzo and Associates and reviewed 

by the FDEP. This section provides a summary of the sampling and analytical procedures that 

were used during the test and presented in the test plan. 

Appendix F presents diagrams for the USEPA Methods sampling trains. 

4.1 Exhaust Gas Velocity and Flowrate Determination (USEPA Method 2) 

In order to determine air pollutant emission rates on a mass basis (e.g., pound per hour), IC 

engine exhaust stack gas velocities, and volumetric flow rates were determined using USEPA 

Method 2 prior to conducting tests. An S-type pitot tube connected to a red-oil manometer was 

used to determine velocity pressure. Gas temperature was measured using a K-type 

thermocouple mounted to the heated sample probe. The heated sample probe and connective 

tubing were leak-checked to verify the integrity of the measurement system. 

The absence of cyclonic flow for each sampling location was verified using an S-type Pitot tube 

and oil manometer. The Pitot tube was positioned at all of the velocity traverse points with the 

planes of the face openings of the Pitot tube perpendicular to the stack cross-sectional plane. The 

Pitot tube was then rotated to determine the null angle (rotational angle as measured from the 

perpendicular, or reference, position at which the differential pressure is equal to zero). 

Exhaust gas velocity pressure and temperature were measured during each one-hour isokinetic 

sampling period in accordance with USEPA Method 2. 

4.2 Exhaust Gas Molecular Weight Determination (USEPA Method 3A) 

CO2 and O2 content in the IC engine exhaust gas stream was measured continuously throughout 

each one-hour test period in accordance with USEPA Method 3A. The CO2 content of the 

exhaust was monitored using a non-dispersive infrared (NDIR) gas analyzer. The O2 content of 

the exhaust was monitored using a gas analyzer that utilizes a paramagnetic sensor. 

During each one-hour sampling period, a continuous sample of the IC engine exhaust gas stream 

was extracted from the stack using a stainless steel probe connected to a Teflon® heated sample 

line. The sampled gas was conditioned by removing moisture prior to being introduced to the 

analyzer; therefore, measurement of O2 and CO2 concentrations correspond to standard dry gas 

conditions. The instrument was calibrated using appropriate calibration gases to determine 

accuracy and system bias (described in Section 5.5 of this document). 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 6

4.3 Exhaust Gas Moisture Content Determinations (Method 4) 

Moisture content of the IC engine exhaust gas was determined in accordance with USEPA 

Method 4 using a chilled impinger sampling train as a component of the USEPA sampling 

procedures for PM (i.e., not as a separate measurement train), which was performed concurrently 

with the instrumental analyzer sampling methodologies. Moisture determinations were measured 

similarly during each HCl sampling period. During each sampling period, a gas sample was 

extracted at a predetermined rate from the source where moisture was removed from the sampled 

gas stream using impingers that were submersed in an ice bath, and then determined 

gravimetrically. At the conclusion of each sampling period, the moisture gain in the impingers 

was determined gravimetrically by weighing each impinger to determine net weight gain. 

Appendix F presents detailed gas sampling procedures for the USEPA sampling trains. 

4.4 NOx and CO Concentration Measurements (USEPA Method 7E and 10) 

NOX and CO pollutant concentrations in the exhaust of the IC engine were determined using a 

chemiluminescence NOX analyzer and NDIR CO analyzer. 

Three (3) one-hour sampling periods were performed for the IC engine exhaust testing. Throughout 

each one-hour test period, a continuous sample of the engine exhaust gas was extracted from the 

stack using the Teflon® heated sample line and gas conditioning system described in Section 4.2 of 

this document, and delivered to the instrumental analyzers. Instrument response for each analyzer 

was recorded on a data logging system that monitored the analog output of the instrumental analyzers 

continuously and logged data as one-minute averages. Prior to, and at the conclusion of each test, 

the instruments were calibrated using appropriate upscale calibration and zero gas to determine 

analyzer calibration error and system bias. Sampling times were recorded on field data sheets. 

4.5 Particulate Matter Concentration Measurements (USEPA 5/USEPA 202) 

An integrated sample of the exhaust gas was withdrawn isokinetically from the IC engine exhaust 

stack. The filterable PM emissions were measured with the front-half of the sampling system in 

accordance with USEPA Method 5. The condensible particulate concentrations were measured 

with the back half of the sampling system in accordance with USEPA Method 202. The combined 

filterable and condensible emission rates constitute the PM-10 emission rates. 

Upon completion of the required posttest leak check of the isokinetic sampling train, the impingers 

were transported to the mobile laboratory (trailer) where a nitrogen purge was conducted. The 

nitrogen purge consisted of bubbling reagent grade nitrogen through the impinger train at a rate of 

20 liter per minute for 60 minutes and was conducted on all PM-10 sampling trains. Upon 

completion of the nitrogen purge, the samples were recovered in accordance with the applicable 

methodologies; the samples were clearly and uniquely labeled and readied for transport. 

Gravimetric analysis was conducted by Bureau Veritas, Novi, Michigan. Laboratory data is 

presented in Appendix C. 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 7

4.6 Volatile Organic Compound Measurement (USEPA Methods 25A/18) 

The VOC emission rate from the engine was determined by subtracting the methane concentration 

from the total hydrocarbon (THC) concentration. THC concentrations were measured using a flame 

ionization analyzer in accordance with USEPA Method 25A. Methane concentrations were 

determined using a Direct Methane, Non-Methane Analyzer in accordance with USEPA Method 18. 

The resultant methane concentrations were subtracted from the THC concentrations giving VOC 

values. The VOC values were used in calculating VOC emission rates from the engine exhaust. 

Computer calculated and field data is presented in Appendix A. 

4.7 Hydrogen Chloride Measurements (USEPA Method 26A) 

An integrated sample of the exhaust gas was withdrawn isokinetically from the IC engine exhaust 

stack. The Hydrogen chloride concentrations from the engine were determined by ion specific 

electrode analysis of the impinger contents in accordance with USEPA Method 26A. 

The 0.1 N H2SO4 samples were analyzed by Bureau Veritas, Novi, Michigan. Laboratory data is 

presented in Appendix C. 

4.8 Visible Emissions Determinations (USEPA Method 9) 

Opacity determinations were performed using USEPA Method 9 where 15-second readings 

recorded on an observation report for a total of 60 minutes. 

5.0 INTERNAL QA/QC ACTIVITIES 

5.1 NOx Converter Efficiency Test 

The NO2 – NO conversion efficiency of the Model 42c analyzer was verified prior to the testing 

program. A mixture of NO calibration gas and hydrocarbon free air gas was added to a Tedlar bag. 

The bag was attached to the inlet of the analyzer and the instrument response was monitored as the 

bag emptied. As the conversion efficiency test progresses the NO reacts with O2 to form NO2. The 

analyzer’s NO2 – NO converter uses a catalyst at high temperatures to convert the NO2 to NO for 

measurement. The conversion efficiency of the analyzer is deemed acceptable if the total NOx

concentration decreases no more than 2% of the highest observed concentration over a 30-minute 

time period. 

The NO2 – NO conversion efficiency test satisfied the USEPA Method 7E criteria (measured NOX

concentration decreased by less than 2% over a 30-minute time period). 

5.2 Sampling System Response Time Determination 

The response time of the sampling system was determined prior to the compliance test program by 

introducing upscale gas and zero gas, in series, into the sampling system using a tee connection at the 

base of the sample probe. The elapsed time for the analyzer to display a reading of 95% of the 

expected concentration was determined using a stopwatch. 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 8

5.3 Determination of Exhaust Gas Stratification 

Gaseous sample extraction was performed at sampling points corresponding to the predetermined 

measurement points used for velocity measurements in accordance with USEPA Method 1. It was 

determined that no stratification was present in the stack at the sampling location. 

5.4 Instrumental Analyzer Interference Check 

The instrumental analyzers used to measure NOx, CO, O2 and CO2 have had an interference 

response test performed prior to their use in the field, pursuant to the interference response test 

procedures specified in USEPA Method 7E. The appropriate interference test gases (i.e. gases that 

would be encountered in the exhaust gas stream) were introduced into each analyzer, separately and 

as a mixture with the analyte that each analyzer is designed to measure. All of analyzers exhibited a

composite deviation of less than 3.0% of the span for all measured interferent gases. No major 

analytical components of the analyzers have been replaced since performing the original interference 

tests. 

5.5 Instrument Calibration and System Bias Checks 

At the beginning of each day, initial three-point instrument calibrations were performed by injecting 

calibration gas directly into the inlet sample port for each instrument. System bias checks were 

preformed prior to and at the conclusion of each sampling period by introducing the appropriate 

upscale calibration gas and zero gas into the sampling system (at the base of the stainless steel 

sampling probe prior to the particulate filter and Teflon® heated sample line) and verifying the 

instrument response against the initial instrument calibration readings. 

The instruments were calibrated with USEPA Protocol 1 certified concentrations of CO2, O2, NOX, 

CO, THC, and methane, and were zeroed using pure nitrogen or hydrocarbon free air. 

5.7 Meter Box Calibrations and Percent Isokinetics 

The isokinetic sampling console, which was used for isokinetic testing, was calibrated prior to and 

after the testing program. This calibration uses the critical orifice calibration technique presented in 

USEPA Method 5. The metering consol calibration exhibited no data outside the acceptable ranges 

presented in USEPA Method 5. 

All tests were within the required +-10% isokinetic sampling rate required by USEPA Methods 

5/202 and 26A. 

Appendix B presents test equipment quality assurance data (i.e., NO2 – NO conversion efficiency 

test data, instrument calibration and system bias check records, calibration gas certifications, 

interference test results, meter box calibration records, cyclonic flow determinations sheets, pitot 

tube and probe assembly calibration records, nozzle calibration data, and opacity observation 

certification). 
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 9

Equipment calibration and certifications are presented in Appendix B. 

I hereby certify that the information given in this report is correct to the best of my knowledge. 

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

representatives: 

Report Prepared By: 

Michael J. Brack 

Field Services Manager 

Derenzo and Associates, Inc.
Derenzo and Associates, Inc.

Seminole Energy, L.L.C. G3520C IC Engine April 30, 2009 

Compliance Test Report Page 10

Report Certification

I certify that all data required and provided to the person conducting the test are true and correct 

to my knowledge. 

Report Certified By: 

Scott Salisbury 

President 

Seminole Energy, L.L.C.
APPENDIX A 

COMPUTER CALCULATED AND FIELD DATA 
APPENDIX B 

CALIBRATION DATA 
APPENDIX C 

LABORATORY DATA 
APPENDIX D 

SAMPLE CALCULATIONS 
EXAMPLE CALCULATIONS 

Equation 1a - Dry Molecular Weight: 

 MWd = 0.440(%CO2) + 0.320(%O2) + 0.280(%N2 + %CO) 

Equation 1b - Wet Molecular Weight: 

 MWw = MWd(1-Bws) + 18.0(Bws) 

Equation 2a - Meter Volume at Standard Conditions: 

 Vm(std) = VmY (Tstd)(Pbar + PH/13.6)

 (Tm)(Pstd) 

Equation 2b - Volume of Water Vapor Condensed: 

 Vwc(std) = K1(Wf-Wi) 

Equation 2c - Moisture Content: 

 Bws = Vwc(std)/(Vwc(std) + Vm(std)) 

Equation 3a - Velocity at a Traverse Point: 

 Vd = KpCp(TsPP/PsMWw)1/2

Equation 3b - Volumetric Flow Rate (Actual Basis): 

 Q = Vd(avg)Ad 60 

Equation 3c - Volumetric Flow Rate (Standard Basis): 

 Qstd = Q (Tstd)(Ps)

 (Ts)(Pstd) 

Equation 3d - Volumetric Flow Rate (Standard Dry Basis): 

 Qstd(dry) = Qstd(1-Bws) 

Equation 4a – Particulate Matter Concentration: (gr/dscf) 

 PMC (gr/dscf) = (mg*0.01543)/Vm 

Equation 4b – Particulate Matter Emission Rate: (lb/hr) 

 PMER (lb/hr) = PMC*0.00858*Qstd 

Equation 4c – Particulate Matter Emission Rate: (g/bHp-hr) 

 PMER (g/bHp-hr) = PMER(lb/hr) * 453.6 * 0.7457 / (kW/0.96) 

Equation 4d – PM-10 Emission Rate: (lb/hr) 

 PM10 (lb/hr) = PMER(lb/hr) + Condensible ER(lb/hr) 

Equation 4e – PM-10 Emission Rate: (g/bHp-hr) 

 PM10 ER (g/bHp-hr) = PMER(g/bHp-hr) + Condensible ER(g/bHp-hr) 

Equation 5a – Nitrogen Oxides Concentration (ppmvd)

 NOxC = ((NOx ppmvd-avg. zero) x Cal. Gas conc.)) / Avg. cal. – 

Avg. zero) 
Equation 5b – Nitrogen Oxides Emission Rate: (lb/hr) 

 NOxER (lb/hr) = NOxC x Qstd(dry) x 46.01 x 0.07524/28950000 

Equation 5c – Nitrogen Oxides Emission Rate: (g/bHp-hr) 

 NOxER (g/bHp-hr) = NOxER (lb/hr) *( 453.6 g/lb) 0.7457 kW/bHp) / (kW /0.96) 

Equation 6a – Carbon Monoxide Concentration (ppmvd)

 COC (ppmvd) = (ppmCO x (1-(%CO2/100)))-avg. zero) x Cal. Gas conc.))/ 

 Avg. cal. – Avg. zero) 

Equation 6b – – Carbon Monoxide Emission Rate: (lb/hr) 

 COER (lb/hr) = COC x Qstd(dry) x 28.20 x 0.07524/28950000 

Equation 6c – Carbon monoxide Emission Rate: (g/bHp-hr) 

 COER (g/bHP-hr) = (COER (lb/hr) *( 453.6 g/lb) 0.7457 kW/bHp) / (kW /0.96) 

Equation 7a – Brake-horse Power (bHp) 

 bHp = (kW/0.96) * bHp/0.7457kW 

Equation 8a – Hydrogen Chloride Concentration: (gr/dscf) 

 HClC (gr/dscf) = (mg*0.01543)/Vm 

Equation 8b – Hydrogen Chloride Emission Rate: (lb/hr) 

 HClER (lb/hr) = HClC*0.00858*Qstd 

Equation 8c – Hydrogen Chloride Emission Rate: (lb/MMscf) 

 HClER (lb/MMscf) = HClER(lb/hr) / MMscf/hr fuel consumption 

SYMBOL IDENTIFICATION 

Ad = Area of duct (ft2

) 

bHp = Brake-horse Power 

Bws = Water vapor in gas stream, proportional by volume 

COC = Carbon monoxide concentration (ppmvd) 

COER = Carbon monoxide emission rate (lb/hr) 

Cp = Pitot tube calibration factor (unitless) 

K1 = Constant (0.04715 ft3

/g) 

Kp = Constant (85.49) 

kW = Kilowatt 

lb/MMscf = pounds per million standard cubic foot 

MWd = Duct gas dry molecular weight (lb/lb-mole) 

MWw = Duct gas wet molecular weight (lb/lb-mole) 

NOxC = Nitrogen Oxides Concentration (ppmvd) 

NOxER = Nitrogen Oxides Emission Rate (g/bHp-hr) 

Pbar = Barometric pressure ("Hg) 

PMC = Particulate matter concentration (gr/dscf) 

PMER = Particulate matter emission rate (lb/hr) 

PM10ER = PM-10 emission rate (g/bHp-hr) 
Ps = Absolute stack pressure ("Hg) 

Pstd = Standard pressure (29.92"Hg) 

Q = Duct volumetric flow rate (actual cfm) 

Qstd = Duct volumetric flow rate (scfm) 

Qstd(dry) = Duct volumetric flow rate (dscfm) 

Tm = Absolute temperature at meter (oR) 

Ts = Absolute temperature of duct gas (oR) 

Tstd = Standard temperature (528oR) 

Vd = Duct velocity at a traverse point (ft/s) 

Vm = Dry test meter volume (cf) 

Vm(std) = Dry test meter volume at standard conditions (scf) 

Vwc(std) = Volume of water vapor condensed at standard conditions (scf) 

Wf = Final weight of impinger/absorber train (g) 

Wi = Initial weight of impinger/absorber train (g)

Y = Dry test meter calibration factor (unitless) 

%CO2 = Duct gas carbon dioxide content (%volume) 

%CO = Duct gas carbon monoxide content (%volume) 

%N2 = Duct gas nitrogen content (%volume) 

%O2 = Duct gas oxygen content (%volume) 

∆H = Pressure drop across orifice ("H2O) 

∆P = Pressure drop across pitot tube ("H2O) 
APPENDIX E 

PROCESS DATA 
APPENDIX F 

DETAILED DESCRIPTIONS OF 

SAMPLING PROCEDURES 
INSTRUMENT SAMPLING AND CALIBRATION PROCEDURES 

1.0 Extractive Gas Sampling System for Instrumental Analyzers 

The extractive gas sampling system that serves the instrumental analyzers used for Methods 3A, 

7E, 10 18 and 25A was configured as described below. 

Sample probe - Stainless steel single opening probe located at predetermined sampling locations 

within the exhaust stack cross-section. 

Three-way valve - A stainless steel three-way valve is installed between the sample probe and a 

stainless steel particulate filter to allow the introduction of calibration gases into the sampling 

system. The three-way valve is turned toward the desired gas flow direction during this 

sampling. During system bias checks, excess calibration gas exits the sampling probe tip to 

avoid the introduction of process gas or ambient air during calibration. 

Heated sample line – A heated Teflon® line is used to transport the sample gas from the stack to 

the instrument rack. The heated Teflon® line is equipped with a temperature controller which 

maintains the temperature of the sample line at approximately 250°F to prevent moisture 

condensation. 

Sample pump and flow control valve – A single head 100% oil-free vacuum pump fitted with a 

stainless steel flow control valve is used to transfer sampled gases from the heated sample line to 

the instrumental analyzer. The vacuum pump is leak-free and non-reactive to the gases being 

sampled. Subsequent sample transport lines and fittings are either stainless steel or Teflon®. 

Gas Conditioner - A refrigerant-based condenser equipped with a peristaltic pump is used to 

remove moisture from the sampled gas stream that is directed to the instrumental analyzers, 

which require a conditioned (or dry) gas samples. From the moisture removal system, a sample 

gas manifold constructed of Teflon® transport lines and stainless steel Tee fittings is used to 

continuously deliver the sampled gas to the instrumental analyzers. Since the instrumental 

analyzers are equipped with internal sampling pumps, the end of the sample gas manifold is 

equipped with an atmospheric dump (or bypass discharge vent) to avoid over pressurization of 

the instrumental analyzers. 

Data Logger – A data logging system is used to record 1-minute average data from the analog 

output of the instrumental analyzers. 

2.0 Instrumental Analyzer Quality Assurance / Calibration Procedures 

Upon site arrival, the instrumental analyzers are set-up in accordance with the manufacturer’s 

written recommended procedures. Upon setting the appropriate range for the instrument, zero 

and appropriate span gases are introduced sequential order to verify instrument accuracy (threepoint analyzer calibration error test). 
Prior to the first test run, appropriate upscale and low-range (zero) span gases are introduced in 

series at the three-way valve in the sampling system. This dynamic calibration procedure is the 

sampling system bias check, and the analyzer's response time is recorded. 

The start of the test run occurs when the calibration gases are cleared from the sampling system 

and the data acquisition system records a consistent instrumental analyzer response on the stack 

gas sample (at least twice the system response time is allowed to verify representative readings). 

At the conclusion of the sampling period, appropriate upscale and low-range (zero) gases are reintroduced in series at the three-way valve in the sampling system to check against the method’s 

performance specifications for calibration drift and zero drift error. If the drift error is within 3% 

of the span over the period of the test run, the test run is considered acceptable 

3.0 Isokinetic Sampling System and Procedures for PM-10 

PM-10 concentrations are equal to the sum of the USEPA Method 5 sampling train (filterable) 

and the USEPA Method 202 sampling train (condensible) measured values. Therefore, 

combining the results of the 5 and 202 sampling train was performed for the determination of 

PM-10 concentrations and emission rates from the engine exhaust. 

A preliminary traverse of the duct was performed to determine duct velocity head and 

temperature distributions, as well as duct static pressure. Preliminary Method 3 and 4 runs were 

performed to determine duct moisture and fixed gas content. Based on this information, a 

sample nozzle of appropriate inside diameter was selected, and the impinger train charged as 

described below. Traverse points were marked on the probe. Sample time per traverse point was 

calculated based on the total anticipated sampling time. 

A "goose-neck" nozzle constructed of stainless steel was connected via stainless steel 

Swagelok® fitting to a borosilicate glass probe liner within a stainless steel probe. Attached to 

the sample probe was a Stausscheibe (Type S) pitot tube and type K thermocouple which was 

used to measure duct velocity head pressure and temperature. The probe liner was attached to a 

glass filter holder containing a glass fiber filter. The back half of the filter holder was connected

via connecting glassware, with temperature monitoring probe, to the impinger train. 

The impinger train consisted of a set of impingers, connected in series and immersed in an ice 

bath. Crushed ice was placed around the impingers to keep the temperatures of the gases leaving 

the last impinger at 68 °F or less. The train was constructed and charged as follows: 

Standard Greenberg-Smith (G-S) impinger containing 100 ml of DI H2O; 

Standard G-S impinger containing 100 ml of DI H2O; 

Modified G-S impinger containing 100 ml of DI H2O; 

Modified G-S impinger containing approximately 200 - 300 grams of pre-dried silica gel and 

glass fiber. 

The sampling train was followed in series by an umbilical line, dry gas meter and calibrated 

orifice connected to an inclined manometer. Type-K thermocouples were used to measure the 

stack, impinger outlet, and dry gas meter inlet and outlet temperatures. A carbon vane pump was 

used to provide the necessary vacuum for the sampling train. 
Prior to performing the PM-10 sampling, preliminary flowrate measurements were obtained for 

the proper operation of the metering console. The preliminary traverse velocity pressure values 

were used during the isokinetic testing rather than concurrent measurements of the velocity 

pressures. This approach was necessary to eliminate high biased flow rate measurements 

encountered when concurrent measurements are conducted. The high bias is caused by the high 

static pressure encountered at the sampling locations within the ductwork because of the close 

proximity to the muffler. Sample time per traverse point was calculated based on the total 

anticipated sampling time (60 minutes). 

The sample train was assembled as completely as possible in the staging area and transported to 

the sampling site. Openings were sealed with aluminum foil to prevent potential contamination 

of the sample train prior to final assembly. Once in the sampling area, each train was assembled 

and each apparatus leak checked. Upon successful completion of the leak check, the initial dry 

gas meter reading was recorded. The engine exhaust sampling locations were selected based on 

the availability of straight duct, which meet the requirements of USEPA Method 1. 

The dry gas meter temperatures were recorded on the data sheets. The isokinetic-sampling rate 

in terms of pressure drop across the calibrated orifice were calculated and recorded on the data 

sheets. The pump and timer was turned on, and the sample rate adjusted to correspond to the 

calculated isokinetic rate. 

 

Once the sample rate is set, the following data was recorded: 

 - Dry gas meter inlet and outlet temperatures 

 - Sample vacuum 

- Probe temperature 

 - Impinger outlet temperature 

 - Filter holder outlet temperature 

 - Orifice differential pressure 

 - Sample volume (dry gas meter readings) 

At the end of the sample time for the first point, the probe was moved to the next point; sampling 

and recording of data was repeated. Upon completion of sampling (each traverse), the probe, and 

nozzle was removed from the port. The sampling train assembly was placed into the next 

traverse port and the previously described sampling procedures were repeated. 

When the sample run was complete, the final, dry gas meter reading was recorded. The probe 

and filter assembly were removed from the sampling port and allowed to cool. A post-test leak 

check was performed on the sampling train at a vacuum at least as great as that of the highest 

sample vacuum measured during each sample run. The final leak rate was recorded on the data 

sheets. The sample train was sealed from contamination and transported to the staging area for 

recovery. Recovery consisted of; performing triplicate rinse and brush technique using acetone 

on the nozzle, probe liner, and the front half of the filter holder. The acetone rinse combined 

with the filter are regarded as the sampling train front half and net weight gains are used to 

calculate the filterable PM portion of the sampling train. 

Back-half recovery consisted of performing water and methylene chloride rinses of the filter 

holder back section, the glass connector, the first three impingers and connecting glassware as 

well as the impinger contents. The impinger contents were collected in a sample bottle and pH 
paper will used to verify the pH of the contents. If the verified pH was less than 4.5 after each 

test then a nitrogen purge was performed. 

The samples were recovered into appropriate, pre-cleaned jars with Teflon liners. The samples 

were clearly and uniquely marked prior to shipment. Shipment was performed in accordance 

with the prescribed procedures of the International Air Transport Association for dangerous 

goods if applicable. 

4.0 Isokinetic Sampling System and Procedures for HCl 

Hydrogen chloride concentrations and emission rates are determined by isokinetically drawing 

stack gas from the source through a filter and a 0.1 Normality of Sulfuric acid (O.1 N H2SO4) 

absorbing solution. The filter collects particulate matter including halide salts but is not 

routinely recovered or analyzed. Acidic and alkaline absorbing solutions collect the gaseous 

hydrogen halides and halogens, respectively. 

A preliminary traverse of the duct was performed to determine duct velocity head and 

temperature distributions, as well as duct static pressure. Preliminary Method 3 and 4 runs were 

performed to determine duct moisture and fixed gas content. Based on this information, a 

sample nozzle of appropriate inside diameter was selected, and the impinger train charged as 

described below. Traverse points were marked on the probe. Sample time per traverse point was 

calculated based on the total anticipated sampling time. 

A "goose-neck" nozzle constructed of borosilicate glass was connected via stainless steel 

Swagelok® fitting to a borosilicate glass probe liner within a stainless steel probe. Attached to 

the sample probe was a Stausscheibe (Type S) pitot tube and type K thermocouple which was 

used to measure duct velocity head pressure and temperature. The probe liner was attached to a 

glass filter holder containing a quartz filter. The back half of the filter holder was connected via 

connecting glassware, with temperature monitoring probe, to the impinger train. 

The impinger train consisted of a set of impingers, connected in series and immersed in an ice 

bath. Crushed ice was placed around the impingers to keep the temperatures of the gases leaving 

the last impinger at 68 °F or less. The train was constructed and charged as follows: 

Standard Greenberg-Smith (G-S) impinger containing 100 ml of 0.1 N H2SO4; 

Standard G-S impinger containing 100 ml of 0.1 N H2SO4; 

Modified G-S impinger empty; 

Modified G-S impinger containing approximately 200 - 300 grams of pre-dried silica gel and 

glass fiber. 

The 0.1 N NaOH impingers required by USEPA Method 26A were replaced with an empty 

knockout impinger, as chloride concentrations are not required for this compliance emissions 

testing event. 

The sampling train was followed in series by an umbilical line, dry gas meter and calibrated 

orifice connected to an inclined manometer. Type-K thermocouples were used to measure the 

stack, impinger outlet, and dry gas meter inlet and outlet temperatures. A carbon vane pump was 

used to provide the necessary vacuum for the sampling train. 
The sample train was assembled as completely as possible in the staging area and transported to 

the sampling site. Openings were sealed with aluminum foil to prevent potential contamination 

of the sample train prior to final assembly. Once in the sampling area, each train was assembled 

and each apparatus was leak checked. Upon successful completion of the leak check, the initial 

dry gas meter reading was recorded. The engine exhaust sampling locations were selected based 

on the availability of straight duct, which meet the requirements of USEPA Method 1. 

Prior to performing the HCl sampling, preliminary flowrate measurements were obtained for the 

proper operation of the metering console. The preliminary traverse velocity pressure values were 

used during the isokinetic testing rather than concurrent measurements of the velocity pressures. 

This approach was necessary to eliminate high biased flow rate measurements encountered when 

concurrent measurements are conducted. The high bias is caused by the high static pressure 

encountered at the sampling locations within the ductwork because of the close proximity to the 

muffler. 

The dry gas meter temperatures were recorded on the data sheets. The isokinetic-sampling rate 

in terms of pressure drop across the calibrated orifice were calculated and recorded on the data 

sheets. The pump and timer was turned on, and the sample rate adjusted to correspond to the 

calculated isokinetic rate. 

Once the sample rate is set, the following data was recorded: 

 - Dry gas meter inlet and outlet temperatures 

 - Sample vacuum 

- Probe temperature 

 - Impinger outlet temperature 

 - Filter holder outlet temperature 

 - Orifice differential pressure 

 - Sample volume (dry gas meter readings) 

At the end of the sample time for the first point, the probe was moved to the next point; sampling 

and recording of data was repeated. Upon completion of sampling (each traverse), the probe, and 

nozzle was removed from the port. The sampling train assembly was placed into the next 

traverse port and the previously described sampling procedures were repeated. 

When the sample run was complete, the final, dry gas meter reading was recorded. The probe 

and filter assembly were removed from the sampling port and allowed to cool. A post-test leak 

check was performed on the sampling train at a vacuum at least as great as that of the highest 

sample vacuum measured during each sample run. The final leak rate was recorded on the data 

sheets. The sample train was sealed from contamination and transported to the staging area for 

recovery. 

Recovery consisted of the measurement of the liquid in the acid impingers to +1 ml by using a 

graduated cylinder or by weighing it to +0.5 g by using a balance. The impinger contents were 

quantitatively transferred to a leak-free sample storage container. A rinse of the impingers and 

connecting glassware including the back portion of the filter holder (and flexible tubing, if used) 

was conducted with water and was added to the storage container. The container was sealed, 
shaken to mix, and labeled. The fluid level was marked so that if any sample is lost during 

transport, a correction proportional to the lost volume can be applied. 

The Alkaline impinger (or empty knockout impinger) catch was measured and recorded for the 

determination of the stack gas moisture content.