### 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 Brevard Energy LLC

29261 Wall Street Wixom, Michigan 48393

Subject: Brevard Energy, LLC Compliance Testing T est 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 mon oxide, hydrogen chloride, particulate matter less than 10 microns, volatile organic compound emi ssions and opacity determinations from the Unit #3 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 (n ominal rating) of electricity at the Brevard Energy facility.

Copies of the test report have submitted on your be half 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 #3 Landfill Gas Fuel ed

G3520C Internal Combustion Engine Operated at the B revard Energy, L.L.C., Brevard County Solid Waste Manageme nt Central Disposal Facility, Brevard County, Florida

Report

Date April 28, 2009

Test Date(s) March 19 & 20, 2009

Facility Information

Name Brevard Energy, L.L.C., Brevard County Solid Waste

Management Central Disposal Facility

City, County Cocoa, Brevard

Facility Permit Information

DEP File No.: 0090068-007-AC Permit No.: PSD-FL-378B

Testing Contractor

Company Derenzo and Associates, Inc.
Mailing

Address 39395 Schoolcraft Road

Livonia, MI 48150

Phone (734) 464-3880
Project No. 0901016Derenzo and Associates, Inc.

Brevard 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 Mate rials 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 O perating Conditions ............................. 4

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 (USE PA Method 3A) ................................ 5

4.3 Exhaust Gas Moisture Content Determinations (Me thod 4) ........................................... ..... 6

4.4 NO

x 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 Me thods 25A/25C) ........................... 7

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

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

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

................................................... .................... 7

5.1 NO

x Converter Efficiency Test ........................

................................................... .................. 7

5.2 Sampling System Response Time Determination ...

................................................... .......... 8

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

................................................... ............... 8Derenzo and Associates, Inc.

Brevard 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) Emis sion Rates from the Unit #3 Engine at the Brevard Energy, L.L.C.

- Brevard County Solid Waste Management Central Dispo sal Facility

.................................................. ................................................... ................................................ 11

2 Hydrogen Chloride Emission Rates from the Unit #3 E ngine at the Brevard Energy, L.L.C.

- Brevard County Solid Waste Management Central Dispo sal Facility ............................................ 12

3 Calculation of HCl Emission Factor Based on Influen t Landfill Gas Chlorinated Compounds to the #3 Caterpillar Model G3520C Engine at the Breva rd Energy, L.L.C.

- Brevard County Solid Waste Management Central Disposal Facility

.................................................. ....................... 13

4 Nitrogen Oxides, Carbon Monoxide, and Volatile Orga nic Compound Concentrations, Emission Rates, and Emission Factors from the Unit #3 Caterp illar Model G3520C Engine at the Brevard Energy, L.L.C.

- Brevard County Solid Waste Management Central Dispo sal Facility ................. 14

5 Six-Minute USEPA Method 9 Opacity Averages for the Caterpillar Model G3520C Engine Unit #3 at the Brevard Energy, L.L.C.

- Brevard County Solid Waste Management Central Disposal Facility

. ................................................. ................................................... ................................ 15

LIST OF FIGURE(S)

Figure 1. Brevard Energy Facility Process Flow Dia gram Figure 2. Brevard Energy Source Diagram Figure 3. Brevard Energy Exhaust Sampling Location Figure 4. Instrumental Analyzer Sampling Train Dia gram (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 D ata Sheets Appendix B Equipment Calibration Data and Opacity C ertification Appendix C Laboratory Data Appendix D Sample Calculations Appendix E Process Data Appendix F Detailed Descriptions of Sampling Proced ures

### 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 BREVARD ENERGY, L.L.C.

BREVARD COUNTY SOLID WASTE MANAGEMENT

CENTRAL DISPOSAL FACILITY BREVARD COUNTY, FLORIDA

1.0 SOURCE INFORMATION

Brevard Energy, L.L.C. (Brevard Energy) is located at the Brevard County Solid Waste Management Central Disposal Facility in Brevard Cou nty, Florida. The Facility File No. is

0090068-007-AC and the Permit No. is PSD-FL-378B. At its landfill gas to energy (LFGTE) facility, Brevard Energy is permitted to operate em ission units 004 – 009 which consist of Six (6) Caterpillar G3520C Lean Burn Reciprocating Engines and electricity generator sets. These engines are fueled with methane-rich gas, which is generated at Brevard County Solid Waste Management Central Disposal Facility Landfill, to p ower base load electricity generator operations.

The FDEP permit requires performance testing of a r epresentative engine for the determination of specified pollutant emissions while the unit is operated at near base load conditions.

Compliance testing was performed to measure nitroge n oxides (NO X ), carbon monoxide (CO), particulate with diameters equal to or less than 10 microns (PM-10), volatile organic compound (VOC), hydrogen chloride (HCl), and oxygen (O 2 ), concentrations and emission rates and opacity from the exhaust of the Unit #3 engine pursuant to the testing requirements specified in the

FDEP Air Construction Permit.

The compliance testing was performed on March 19 & 20, 2009 by Derenzo and Associates, Inc., an environmental consulting and testing company from L ivonia, 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 shoul d 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 Manager, Salt Lake Energy Systems Landfill Energy Systems.

29261 Wall Street Wixom, MI 48393 (248) 380-3920Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 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 Brevard County Solid Waste Management Central Disposal Facility Landfill from the anaerob ic 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 collect ion system). The collected LFG is directed to the Brevard Energy facility where it is treated and use d as fuel for the IC engine generators that produce electricity for transfer to the local utility.

The Brevard Energy facility currently consists of s ix (6) CAT Model No.G3520C IC internal combustion engines that are connected to individual electricity generators.

A process flow diagram for the LFG to electricity p rocess is presented subsequent to the summary tables in this report.

2.2 Rated Capacities, Type and Quantity of Raw Material s Used

The representative CAT G3520C IC engine generator s et was operated at base load conditions (i.e., 100% of the design capacity of 2,233 brake horsepow er) to produce a peak electricity output of 1,600 kilowatts (kW). Fuel (treated landfill gas) consum ption is regulated to maintain the required heat input rate to support engine operations and is depe ndant on the fuel heat value (methane content). The average engine fuel consumption rate during the test periods was 544.0 scfm based on data recorded from the fuel flow meter installed and ope rated by Brevard Energy.

Appendix E provides engine generator process data c ollected 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 fro m the combustion of LFG are released uncontrolled into the ambient air through a stack c onnected 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 G3520 C 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 sampli ng points were determined in accordance with USEPA Method 1 for the representative engine.Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 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) o f the engine exhaust is obstructed by the surface area of the isokinetic sampling probe which tends t o bias the exhaust velocity measurements on the high side. The (PM10 and HCL) tests results are ba sed on the velocity measurements obtained on the isokinetic probe assembly. The gaseous samplin g (NOx, CO, VOC) test results are calculated from pre-test and post-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 004 th rough 009 to demonstrate compliance with the CO,

NO X , PM-10, VOC, HCl, and opacity emission limits by p ermit conditions. The facility is required to perform initial, annual and permit renewal testi ng during a six-year period. This test event satisfies the 2009 annual performance test required by the permit. Sulfur dioxide emission rates wee also determined during the test event as required b y FDEP Permit No. PSD-FL-378A (permit revision).

The PM-10 emissions were determined by combining th e 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 d etermined by subtracting the methane concentration (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 mo nitored for six (6) one-hour test periods during which the O 2, and CO 2 exhaust gas concentrations were measured using ins trumental analyzers. The engine NO

x , and CO measurements consisted of triplicate 60-mi nute 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 representativ e engine was determined by gravimetric analysis of the weight gain in the chilled impingers. Veloc ity 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 m inutes.

Sulfur Dioxide emissions were determined using USEP A Reference Method 19 and ASTM D-5504 for sulfur compound analysis. Fuel gas sampling wa s conducted during the PM-10 test events.

The testing was performed while the IC engine was o perated at normal base load conditions (1600 kW peak electricity output +/- 5%).Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 4

3.2 Variations from Normal Sampling Procedures or Opera ting Conditions

The testing for all pollutants were performed in ac cordance with the Test Protocol dated February 13, 2009 and specified USEPA test methods. Isokinetic sampling rates were determined using pre-test velocity measurements.

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 tes ting program.

3.3 Operating Conditions during Compliance Tests

The representative LFG-fueled IC engine was operate d at base load (100% capacity +/- 5%) conditions during the compliance testing. The aver age kilowatt (kW) output value displayed by the engine data management computer (LCD screen) were m anually recorded 3 times during each test period. LFG flowrate information was obtained simi larly (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 544.0 standard cubic feet pe r minute (scfm). The average electrical output rate during the test event was 1,600 kW.

3.4 Air Pollutant Sampling Results

The following table presents the engine #3 three-te st average emission rates from the initial performance evaluation:

Emission Parameter Unit #3 Emissions Permit Limit

NOx NO X emissions (lb/hr) 2.24 2.95

NO X emissions (g/bhp-hr) 0.45 0.60

CO CO emissions (lb/hr) 11.84 13.54
CO emissions (g/bhp-hr) 2.40 2.75

VOC VOC emissions (lb/hr) 0.0 1.37
VOC emissions (g/bhp-hr) 0.0 0.28

PM 10 PM 10 emissions (lb/hr) 1.07 1.18

PM 10 emissions (g/bhp-hr) 0.22 0.24

HCl HCl emissions (lb/hr) 0.01 -
HCl emissions (lb/MMscf) 0.34 10.9

O 2 Oxygen concentration (%) 7.58 -

SO 2 SO 2 emissions (lb/hr) 1.63 2.64

Opacity Highest 10 second average (%) 0.0 10

Notes (lb/hr) pounds per hour, (g/bhp-hr) grams per brak e horsepower hour, (lb/MMscf) pounds per million

standard cubic footDerenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 5

Tables 1 through 6 present measured gas conditions and pollutant emission rates for the representative LFG-fueled IC engine.

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

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

4.0 SAMPLING AND ANALYTICAL PROCEDURES

A test protocol for the compliance testing was prep ared by Derenzo and Associates and reviewed by the FDEP. This section provides a summary of th e 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 (US EPA 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 pito t tube connected to a red-oil manometer was used to determine velocity pressure. Gas temperatu re was measured using a K-type thermocouple mounted to the heated sample probe. T he 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 loca tion was verified using an S-type Pitot tube and oil manometer. The Pitot tube was positioned a t all of the velocity traverse points with the planes of the face openings of the Pitot tube perpe ndicular to the stack cross-sectional plane. The

Pitot tube was then rotated to determine the null a ngle (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 M ethod 3A)

CO 2 and O 2 content in the IC engine exhaust gas stream was me asured continuously throughout each one-hour test period in accordance with USEPA Method 3A. The CO 2 content of the exhaust was monitored using a non-dispersive infrar ed (NDIR) gas analyzer. The O 2 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 stee l 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 O 2 and CO 2 concentrations correspond to standard dry gasDerenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 6

conditions. The instrument was calibrated using ap propriate calibration gases to determine accuracy and system bias (described in Section 4.8 of this document).

4.3 Exhaust Gas Moisture Content Determinations (Method 4)

Moisture content of the IC engine exhaust gas was d etermined 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 measurem ent train), which was performed concurrently with the instrumental analyzer sampling methodologi es. 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 w here moisture was removed from the sampled gas stream using impingers that were submersed in a n ice bath, and then determined gravimetrically. At the conclusion of each samplin g period, the moisture gain in the impingers was determined gravimetrically by weighing each imp inger to determine net weight gain.

Appendix F presents detailed gas sampling procedure s for the USEPA sampling trains.

4.4 NO

x and CO Concentration Measurements (USEPA Method 7E and 10)

NO X and CO pollutant concentrations in the exhaust of the IC engine were determined using a

chemiluminescence NO X 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 t he 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 an alyzers. Instrument response for each analyzer was recorded on a data logging system that monitore d 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 u pscale calibration and zero gas to determine analyzer calibration error and system bias. Sampli ng times were recorded on field data sheets.

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

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

stack. The filterable PM emissions were measured w ith the front-half of the sampling system in accordance with USEPA Method 5. The condensible pa rticulate concentrations were measured with the back half of the sampling system in accord ance with USEPA Method 202. The combined

filterable and condensible emission rates constitut e 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. U pon completion of the nitrogen purge, the samples were recovered in accor dance with the applicable methodologies; the samples were clearly and uniquely labeled and readi ed for transport. Gravimetric analysis was conducted by Bureau Veritas, Novi, Michigan. Labor atory data is presented in Appendix C.Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 7

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

The VOC emission rate from the engine was determine d by subtracting the methane concentration from the total hydrocarbon (THC) concentration. TH C concentrations were measured using a flame ionization analyzer in accordance with USEPA Method 25A. Methane concentrations were determined using a Direct Methane, Non-Methane Anal yzer in accordance with USEPA Method 18.

The resultant methane concentrations were subtracte d from the THC concentrations giving NMHC values. The NMHC values were used in calculating V OC 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 withdra wn isokinetically from the IC engine exhaust

stack. The Hydrogen chloride concentrations from the engin e were determined by ion specific electrode analysis of the impinger contents in accordance wit h USEPA Method 26A.

The 0.1 N H 2 SO 4 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 M ethod 9 where 15-second readings recorded on an observation report for a total of 60 minutes.

4.9 Sulfur Dioxide Measurements (USEPA Method 19)

An integrated sample of the fuel used in the IC eng ine was sampled using a Tedlar bag and analyzed for sulfur bearing compounds by Columbia A nalytical Services using ASTM D-5504-

01.

5.0 INTERNAL QA/QC ACTIVITIES

5.1 NO

x Converter Efficiency Test

The NO 2 – NO conversion efficiency of the Model 42c analyz er was verified prior to the testing program. A mixture of NO calibration gas and hydro carbon free air gas was added to a Tedlar bag. The bag was attached to the inlet of the analyzer a nd the instrument response was monitored as the bag emptied. As the conversion efficiency test pro gresses the NO reacts with O 2 to form NO 2 . The analyzer’s NO 2 – NO converter uses a catalyst at high temperature s to convert the NO 2 to NO for measurement. The conversion efficiency of the anal yzer is deemed acceptable if the total NO

x concentration decreases no more than 2% of the high est observed concentration over a 30-minute time period.

The NO 2 – NO conversion efficiency test satisfied the USEP A Method 7E criteria (measured NO X concentration decreased by less than 2% over a 30-m inute time period).Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 8

5.2 Sampling System Response Time Determination

The response time of the sampling system was determ ined prior to the compliance test program by introducing upscale gas and zero gas, in series, in to the sampling system using a tee connection at th e 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 stopw atch.

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 i n accordance with USEPA Method 1.

5.4 Instrumental Analyzer Interference Check

The instrumental analyzers used to measure NOx, CO, O 2 and CO 2 have had an interference response test performed prior to their use in the f ield, pursuant to the interference response test procedures specified in USEPA Method 7E. The appro priate interference test gases (i.e. gases that would be encountered in the exhaust gas stream) wer e 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 f or all measured interferent gases. No major analytical components of the analyzers have been re placed since performing the original interference

tests.

5.5 Instrument Calibration and System Bias Checks

At the beginning of each day, initial three-point i nstrument 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 sa mpling period by introducing the appropriate upscale calibration gas and zero gas into the sampl ing 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 CO 2 , O 2 , NO X , CO, THC and zeroed using pure nitrogen or hydrocarb on 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 t he critical orifice calibration technique presented in USEPA Method 5. The metering consol calibration ex hibited 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.Derenzo and Associates, Inc.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 9

Appendix B presents test equipment quality assuranc e data (NO 2 – NO conversion efficiency test data, instrument calibration and system bias check records, calibration gas certifications, interference test results, meter box calibration re cords, cyclonic flow determinations sheets, pitot tube and probe assembly calibration records, nozzle calibration data, and opacity observation

certification.

Equipment calibration and certifications are presen ted 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.

Brevard Energy, L.L.C. G3520C IC Engine April 28, 2009 Compliance Test Report Page 10

Report Certification

I certify that all data required and provided to th e person conducting the test are true and correct to my knowledge.

Report Certified By:

Scott Salisbury

President Brevard Energy, L.L.C.APPENDIX A

COMPUTER CALCULATED AND FIELD DATAAPPENDIX B

CALIBRATION DATAAPPENDIX C

LABORATORY DATAAPPENDIX D

SAMPLE CALCULATIONSEXAMPLE 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-B ws ) + 18.0(B ws )

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:

B ws = 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 Ba sis): Qstd(dry) = Qstd(1-B ws )

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 0.075 24/28950000

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-(%CO 2 /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 co nsumption

SYMBOL IDENTIFICATION

Ad = Area of duct (ft 2 ) bHp = Brake-horse Power

B ws = Water vapor in gas stream, proportional by volu me COC = Carbon monoxide concentration (ppmvd) COER = Carbon monoxide emission rate (lb/hr) Cp = Pitot tube calibration factor (unitless) K1 = Constant (0.04715 ft 3 /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 ( o R) Ts = Absolute temperature of duct gas ( o R) Tstd = Standard temperature (528 o R) Vd = Duct velocity at a traverse point (ft/s) Vm = Dry test meter volume (cf) Vm(std) = Dry test meter volume at standard conditi ons (scf) Vwc(std) = Volume of water vapor condensed at stand ard 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 DATAAPPENDIX F

DETAILED DESCRIPTIONS OF

SAMPLING PROCEDURESINSTRUMENT 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 b etween the sample probe and a stainless steel particulate filter to allow the introduction of calibration gases into the sampling system. The threeway valve is turned toward the desired gas flow dir ection during this sampling. During system bias checks, excess calibration gas exits the sampling p robe tip to avoid the introduction of process gas o r ambient air during calibration.

Heated sample line – A heated Teflon® line is used to transport the s ample gas from the stack to the instrument rack. The heated Teflon® line is equipp ed with a temperature controller which maintains th e 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 w ith a stainless steel flow control valve is used to transfer sample d gases from the heated sample line to the instrume ntal analyzer. The vacuum pump is leak-free and non-rea ctive to the gases being sampled. Subsequent sample transport lines and fittings are either stai nless steel or Teflon®.

Gas Conditioner

- A refrigerant-based condenser equipped with a pe ristaltic pump is used to remove moisture from the sampled gas stream that is direct ed to the instrumental analyzers, which require a conditioned (or dry) gas samples. From the moistur e removal system, a sample gas manifold constructed of Teflon® transport lines and stainless steel Tee fittings is used to continuously deliver the sample d gas to the instrumental analyzers. Since the instrumen tal analyzers are equipped with internal sampling pumps, the end of the sample gas manifold is equipp ed with an atmospheric dump (or bypass discharge vent) to avoid over pressurization of the instrumen tal 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 / Calib ration Procedures

Upon site arrival, the instrumental analyzers are s et-up in accordance with the manufacturer’s written recommended procedures. Upon setting the appropria te range for the instrument, zero and appropriate span gases are introduced sequential order to verif y instrument accuracy (three-point analyzer calibra tion error test).

Prior to the first test run, appropriate upscale an d low-range (zero) span gases are introduced in ser ies at the three-way valve in the sampling system. This d ynamic calibration procedure is the sampling system bias check, and the analyzer's response time is rec orded.

The start of the test run occurs when the calibrati on gases are cleared from the sampling system and t he data acquisition system records a consistent instru mental analyzer response on the stack gas sample (a t least twice the system response time is allowed to verify representative readings).At the conclusion of the sampling period, an approp riate 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 an d 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 P M-10

PM-10 concentrations are equal to the sum of the US EPA Method 5 sampling train (filterable) and the USEPA Method 202 sampling train (condensible) measu red 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. Pr eliminary Method 3 and 4 runs were performed to determine duct moisture and fixed gas content. Bas ed on this information, a sample nozzle of appropriate inside diameter was selected, and the i mpinger train charged as described below. Traverse points were marked on the probe. Sample time per t raverse point were calculated based on the total anticipated sampling time.

A "goose-neck" nozzle constructed of stainless stee l was connected via stainless steel Swagelok® fitti ng to a borosilicate glass probe liner within a stainl ess steel probe. Attached to the sample probe was a Stausscheibe (Type S) pitot tube and type K thermoc ouple which was used to measure duct velocity head pressure and temperature. The probe liner was atta ched to a glass filter holder containing a glass fi ber

filter. The back half of the filter holder was con nected 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 construct ed and charged as follows:

Standard Greenberg-Smith (G-S) impinger containing 100 ml of DI H 2 O; Standard G-S impinger containing 100 ml of DI H 2 O; Modified G-S impinger containing 100 ml of DI H 2 O; 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 umb ilical line, dry gas meter and calibrated orifice connected to an inclined manometer. Type-K thermoc ouples were used to measure the stack, impinger outlet, and dry gas meter inlet and outlet temperat ures. 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 prel iminary traverse velocity pressure values were used during the isokinetic testing rather than concurren t measurements of the velocity pressures. This approach was necessary to eliminate high biased flo w rate measurements encountered when concurrent measurements are conducted. The high bias is cause d by the high static pressure encountered at the sampling locations within the ductwork because of t he close proximity to the muffler. Sample time per traverse point was calculated based on the total an ticipated sampling time (60 minutes).

The sample train was assembled as completely as pos sible 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 readi ng was recorded. The engine exhaust sampling location s were selected based on the availability of straig ht 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 term s

of pressure drop across the calibrated orifice were calculated and recorded on the data sheets. The p ump and timer was turned on, and the sample rate adjust ed 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 wa s removed from the port. The sampling train assembly was placed into the next traverse port and the previously described sampling procedures was repeat ed.

When the sample run was complete, the final, dry ga s meter reading was recorded. The probe and filter assembly were removed from the sampling port and al lowed to cool. A post-test leak check was performed on the sampling train at a vacuum at leas t as great as that of the highest sample vacuum measured during each sample run. The final leak ra te was recorded on the data sheets. The sample tra in was sealed from contamination and transported to th e staging area for recovery. Recovery consisted of ; performing triplicate rinse and brush technique usi ng acetone on the nozzle, probe liner, and the fron t
half of the filter holder. The acetone rinse combi ned with the filter are regarded as the sampling tr ain front half and net weight gains are used to calcula te the filterable PM portion of the sampling train.

Back-half recovery consisted of performing water an d methylene chloride rinses of the filter holder ba ck section, the glass connector, the first three impin gers and connecting glassware as well as the imping er contents. The impinger contents were collected in a sample bottle and pH paper will used to verify th e pH of the contents. If the verified pH was less th an 4.5 after each test then a Nitrogen purge was performed.

The samples were recovered into appropriate, pre-cl eaned jars with Teflon liners. The samples were clearly and uniquely marked prior to shipment. Shi pment was performed in accordance with the prescribed procedures of the International Air Tran sport Association for dangerous goods if applicable

.

4.0 Isokinetic Sampling System and Procedures for H Cl

Hydrogen chloride concentrations and emission rates are determined by isokinetically drawing stack gas from the source through a filter and a 0.1 Normalit y of Sulfuric acid (0.1 N H 2 SO 4 ) absorbing solution. The filter collects particulate matter including ha lide salts but is not routinely recovered or analyz ed. Acidic and alkaline absorbing solutions collect the gaseous hydrogen halides and halogens, respectivel y.

A preliminary traverse of the duct was performed to determine duct velocity head and temperature distributions, as well as duct static pressure. Pr eliminary Method 3 and 4 runs were performed to determine duct moisture and fixed gas content. Bas ed on this information, a sample nozzle of appropriate inside diameter was selected, and the i mpinger train charged as described below. Traverse points were marked on the probe. Sample time per t raverse point was calculated based on the total anticipated sampling time.A "goose-neck" nozzle constructed of borosilicate g lass was connected via stainless steel Swagelok®

fitting to a borosilicate glass probe liner within a stainless steel probe. Attached to the sample pr obe was a Stausscheibe (Type S) pitot tube and type K therm ocouple which was used to measure duct velocity head pressure and temperature. The probe liner was attached to a glass filter holder containing a qua rtz
filter. The back half of the filter holder was con nected 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 construct ed and charged as follows:

standard Greenberg-Smith (G-S) impinger containing 100 ml of 0.1 N H 2 SO 4 ; standard G-S impinger containing 100 ml of 0.1 N H 2 SO 4 ; 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 2 6A were replaced with an empty knockout impinger, as chloride concentrations are not requir ed for this compliance emissions testing event.

The sampling train was followed in series by an umb ilical line, dry gas meter and calibrated orifice connected to an inclined manometer. Type-K thermoc ouples were used to measure the stack, impinger outlet, and dry gas meter inlet and outlet temperat ures. A carbon vane pump was used to provide the necessary vacuum for the sampling train.

The sample train was assembled as completely as pos sible 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 comple tion of the leak check, the initial dry gas meter reading was recorded. The engine exhaust sampling locations were selected based on the availability o f straight duct, which meet the requirements of USEPA Method 1.

Prior to performing the HCl sampling, preliminary f lowrate 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 measu rements of the velocity pressures. This approach w as necessary to eliminate high biased flow rate measur ements encountered when concurrent measurements are conducted. The high bias is caused by the high static pressure encountered at the sampling locati ons 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 term s of pressure drop across the calibrated orifice were calculated and recorded on the data sheets. The p ump and timer was turned on, and the sample rate adjust ed 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 wa sremoved from the port. The sampling train assembly was placed into the next traverse port and the previously described sampling procedures were repea ted.

When the sample run was complete, the final, dry ga s meter reading was recorded. The probe and filter assembly were removed from the sampling port and al lowed to cool. A post-test leak check was performed on the sampling train at a vacuum at leas t as great as that of the highest sample vacuum measured during each sample run. The final leak ra te was recorded on the data sheets. The sample tra in was sealed from contamination and transported to th e staging area for recovery.

Recovery consisted of the measurement of the liquid in the acid impingers to +1 ml by using a graduate d cylinder or by weighing it to +0.5 g by using a bal ance. The impinger contents were quantitatively transferred to a leak-free sample storage container . A rinse of the impingers and connecting glasswar e including the back portion of the filter holder (an d flexible tubing, if used) was conducted with wate r 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 duri ng 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.