TEST REPORT

For

INITIAL COMPLIANCE TESTING

From 

UNIT 5, A 2333 BHP CATERPILLAR MODEL NO. G3520C

GENERATOR ENGINE

In Service at the 

BREVARD COUNTY SOLID WASTE MANAGEMENT 

CENTRAL DISPOSAL FACILITY 

Located in 

COCOA, BREVARD COUNTY, FLORIDA

Prepared for 

BREVARD ENERGY, LLC 

Test Completion Date: September 24th, 2008 

Report Draft Submittal Date: November 3rd, 2008 

TRC Project Number 162189.0000.0000
TABLE OF CONTENTS

INTRODUCTION 1 

 Table 1 Background Data 2 

SUMMARY OF RESULTS 5 

 Table 2: Executive Summary 5 

 Table 3: Summary of Results, Emissions Test Results 8 

 Table 4: Summary of Results, Unit 5, PM Results Table 9 

 Table 5: Summary of Results, Unit 5, HCl Results Table 10 

 

PROCESS DESCRIPTION 11 

ANALYTICAL TECHNIQUES 12 

 Table 6: Analytical Instrumentation 19 

 Figure 1: Instrumental Sample System Diagram 20 

 Figure 2: Particulate Matter Sample System Diagram 21 

 Figure 3: HCl Sample System Diagram 22 

QUALITY ASSURANCE ACTIVITIES 23 

APPENDICES:

 A. Field Data Sheets 

 B. Example Calculations 

 C. Fuel Analysis 

 EPA Method 3C Analysis 

 EPA Method TO-15 Analysis 

 D. Quality Assurance Activities 

 E. Calibration Certifications 

 F. Logged Data Records 

 G. Operational Data 

 PI Operational Data 

 CEMS DAHS Data 

H. Laboratory Results 

 EPA Method 5/202 Analysis 

 EPA Method 18 Analysis 

 EPA Method 26A Analysis 

 I. Opacity Observations 

 J. Florida Department of Environmental Protection 

 Title V Air Operation Permit No. 1050221-014-AV 
1 

INTRODUCTION

 Exhaust emissions tests were conducted on Unit 5, one of six 2333 brake-horsepower 

(BHP) Caterpillar Model No. G3520C landfill gas fired generator engines. These units, used to 

generate power, are in service at the Brevard County Solid Waste Management Central Disposal 

Facility located in Cocoa, Brevard County, Florida. Brevard Energy, LLC (Brevard Energy) 

owns and operates this power generation facility within the landfill. TRC – Air Measurements, 

Gainesville Office (TRC) conducted these tests on September 24th, 2008. 

 The purpose of this testing was to determine the status of initial compliance for Unit 5 

with respect to environmental standards and emission limits. The environmental limits for 

emissions are set forth by the Florida Department of Environmental Protection (FDEP) Air 

Construction Permit No. 0090068-007-AC. The tests followed the procedures set forth in 40 

CFR 60, Appendix A, Methods 1, 2, 3A, 4, 5, 7E, 9, 10, 18 (modified), 19, 25A, 26A (modified), 

and 202. In addition, the landfill gas was sampled and analyzed in accordance with EPA 

Methods 3C and EPA Method Toxic Organic (TO) 15. 

 Emissions from the engine were analyzed for compliance at full load operation in the 

exhaust stack for oxides of nitrogen (NOX), carbon monoxide (CO), total hydrocarbon 

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

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

determining by subtracting the CH4 emissions from the THC emissions. Additional compliance 

testing consisted of collecting filterable and condensable particulate matter (PM10) samples isokinetically and hydrochloric acid (HCl) samples iso-kinetically from the exhaust stack and 

conducting visible emissions (VE) tests on the exhaust stack. The landfill gas fuel used to fire 

the engine was analyzed for permanent gases for use in determination of the fuel heating value of 

the landfill gas and was also analyzed for chlorinated compounds in the landfill gas. Table 1 

summarizes the background information pertinent to these tests. 

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

representatives: 

 

 TRC – Air Measurements Brevard Energy, LLC 
2 

TABLE 1 

BACKGROUND DATA

Source Owner: Brevard Energy, LLC

 29261 Wall Street 

 Wixom, Michigan 48393 

 Attn: Mr. Scott Salisbury, President 

 (248) 380-3920 Phone 

Testing Organization: TRC – Air Measurements, Gainesville Office

 6322 NW 18th Drive, Suite 170 

 Gainesville, Florida 32653 

 Attn: Leonard Brenner, Sr. Project Manager 

 (352) 378-0332 Phone 

 (352) 378-0354 Facsimile 

 Email: lbrenner@trcsolutions.com

Test Participants: TRC – Air Measurements, Gainesville Office 

 Leonard Brenner, Manager – Air Measurements 

 Carl Fink, Senior Project Manager 

 Roger Osier, Environmental Scientist II 

 Chris Hank, Technical Assistant 

 

Test Dates: September 24th, 2008 

Facility Location: The Brevard County Solid Waste Management Central 

Disposal Facility is located at 2250 Adamson Road in 

Cocoa, Brevard County, Florida. The UTM coordinates are 

Zone 17, 516.75 km East and 3140.57 km North. 

Regulatory Application: Florida Department of Environmental Protection (FDEP) 

Air Construction Permit No. 0090068-007-AC applies to 

state regulations for initial compliance testing on the 

generator engine. 

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

of the building roof is approximately 12 feet tall with an 

internal diameter of 15.5 inches. Two 3-inch diameter 

sample ports are located perpendicular to each other in a 

vertical plane of the stack at approximately 2 feet above the 

roof line. See Appendix A for stack diagrams. Access to 

the sample ports was provided by a ladder to the roof. 
3 

Source Description: This site contains six 2333 Hp Caterpillar Model No. 

G3520C landfill gas fired generator engines. Brevard 

Energy designates these sources as Units 1 through 6. 

FDEP designates these units as Emissions Units 004 

through 9. The facility is designed to provide exclusively 

landfill gas fuel from the Central Disposal landfill to each 

generator engine. 

Test Methods: EPA Method 1 was used to select gaseous stratification, 

particulate matter (PM) train, and hydrochloric acid (HCl) 

train sampling point locations. 

 EPA Method 2 was used to measure stack gas differential 

pressures, i.e., velocity measurements, for use in 

determining pollutant mass emission rates and to maintain 

sampling iso-kinetics during PM and HCl sampling. 

EPA Method 3A was used to determine carbon dioxide 

(CO2) and oxygen (O2) emissions. 

 EPA Method 3C was used to determine landfill gas 

composition, used in the determination of landfill gas as 

fuel heating values and fuel specific “F-factors”. 

EPA Method 4 was used for determination of stack gas 

moisture content using gravimetric analysis. 

 EPA Methods 5 and 202 were used to determine filterable 

and condensable particulate matter (PM10) emissions. 

 EPA Method 7E was used for determination of oxides of 

nitrogen (NOX) emissions. 

 EPA Method 9 was used to determine visible emissions 

(VE) measurements determined as opacity by a certified 

observer. 

EPA Method 10 was used for determination of carbon 

monoxide (CO) emissions. 

 EPA Method 18 (modified) was used to collect bag 

samples to determine methane (CH4) emissions used in 

conjunction with EPA Method 25A for the determination 

of VOC emissions. 

 

 EPA Method 19 was used for verification of volumetric 

flow rates by stoichiometric calculations based on O2 and 

CO2 “F Factors”. 
4 

Test Methods (Continued): EPA Method 25A was used to determine total hydrocarbon 

emissions used in conjunction with EPA Method 18 

(modified) for the determination of VOC emissions. 

 EPA Method 26A (modified) for acidic absorber impingers 

only was used for the determination of HCl emissions. 

 

 EPA Method TO-15 was used to determine chlorinated 

organic compounds in the landfill gas. 

 
5 

SUMMARY OF RESULTS 

 Brevard Energy, LLC operates a power generation facility at the Brevard County Solid 

Waste Management Central Disposal Facility in Cocoa, Brevard County, Florida. Six landfill 

gas fueled Caterpillar Model No. 3520C generator engines are in service at this facility and are 

used for the production of electricity. Brevard Energy designates these generator engines as Unit 

1 through Unit 6. The State of Florida designates these engines as Emissions Unit Nos. 004 

through 009, respectively. The emissions from one of these engines, Unit 5, are the subject of 

this report. 

Table 2, the executive summary, signifies the performance for the generator engine with 

respect to initial compliance testing. The initial compliance test results are an average of the 

three test runs and are compared to the permit limits set forth in FDEP Air Construction Permit 

No. 0090068-007-AC. NOX, CO, VOC, and PM10 mass emission rates are reported in terms of 

pounds per hour (lbs/hr), tons per year (tons/yr), and grams per brake brake-horsepower hour 

(g/bhp-hr). HCl emission rates are reported in terms of lbs/MMscf of landfill gas burned and 

tons/yr. Visible emissions are reported in terms of percent opacity. 

FDEP

Parameter Unit 5 Results Permit Limits

Engine Horsepower (bhp) 2235 -

NOX (lbs/hr) 2.12 2.95

NOX (tons/yr) 9.30 12.94

NOX (g/bhp-hr) 0.431 0.60

CO (lbs/hr) 11.8 13.54

CO (tons/yr) 51.6 59.30

CO (g/bhp-hr) 2.39 2.75

VOC (lbs/hr) 0.92 1.37

VOC (tons/yr) 4.02 5.99

VOC (g/bhp-hr) 0.186 0.28

PM10 (lbs/hr) 1.18 1.18

PM10 (tons/yr) 5.15 5.17

PM10 (g/bhp-hr) 0.239 0.24

VE (% opacity) 0 10

HCl (lbs/MMSCF) 0.957 10.9

HCl (tons/yr) 0.141 1.66

Executive Summary

TABLE 2
6 

The first step in the test matrix consisted of conducting an initial sampling traverse of the 

engine exhaust stack. The purpose of this sampling traverse was to check for changes in 

emissions concentration (stratification) within the exhaust stack. NOX, CO, O2 and CO2

concentrations were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. 

No significant stratification was observed for the NOX, CO, O2, and CO2 emissions. The 

stratification was less than 5% from the mean concentration. Therefore, sampling during the 

testing was conducted from a single point of average emissions with the probe switched between 

sample ports in the middle of each test run. 

Following the stratification test, TRC conducted six test runs at full load on the unit at the 

exhaust stack. Each test run was 60 minutes in duration. During the first three test runs 

emissions of NOX, CO, THC, CH4, VOC, PM10, and VE were determined. NOX, CO, THC, O2, 

and CO2 were measured using continuous instrumental monitors. CH4 samples were collected 

into Teldar® sample bags. PM10 (filterable + condensable) samples were collected using a 

hot/cold manual sampling train and samples were analyzed at the TRC Gainesville Lab. Landfill 

gas fuel samples were collected during these first three tests for analysis of fuel composition and 

gross heating value. During the second set of three test runs, emissions of HCl were determined. 

HCl emissions were collected using a hot/cold manual sampling train and samples were analyzed 

by an outside laboratory. Landfill gas fuel samples were collected in conjunction with the HCl 

emissions testing for analysis of chlorinated organic compounds. 

Table 3 represents a detailed summary of the initial compliance results for Unit 5. This 

tabular summary contains all pertinent operational parameters, landfill gas fuel data, ambient 

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

CO, CH4, and VOC emissions are reported in units of parts per million (ppmv) on a dry basis. 

THC emissions are reported in units of ppmv on a wet basis as propane and were converted to 

units of ppmv on a dry basis on a dry basis. PM10 emissions are reported in terms of grams of 

PM10 per dry standard cubic foot of stack gas (grams PM10/DSCF of flue gas). Mass emission 

rates for NOX, CO, VOC, and PM10 are reported in terms of lbs/hr, tons/yr, and g/bhp/hr. 

Emission rates for HCl are reported in terms pounds per million standard cubic feet of landfill 

gas burned (lbs/MMSCF) and tons/yr. VE are reported in terms of % opacity. 

Table 4 represents a detailed summary of the PM10 testing for Unit 5. This tabular 

summary contains unit operational data, sampling train data, and individual PM fraction weights 

from the lab analysis. PM10 emissions are reported in terms of grams of PM10 per dry standard 

cubic foot of stack gas (grams PM10/DSCF of flue gas). 

Table 5 represents a detailed summary of the HCl testing for Unit 5. This tabular 

summary contains unit operational data, sampling train data, and results from the lab analysis. 

Emission rates for HCl are reported in terms pounds per million standard cubic feet of landfill 

gas burned (lbs/MMSCF) and tons/yr. Also included in this table are landfill gas chlorinated 

compound content, expressed as ppmv Cl and predicted emissions from the Chlorine in the fuel 

as emissions of HCl in terms pounds per million standard cubic feet of landfill gas burned 

(lbs/MMSCF) 
7 

Volumetric flow and mass emission rates were determined by two different techniques. 

The first technique employed a physical measurement of exhaust flow using EPA Methods 1 

through 4. This technique included measurements of stack gas molecular weight, stack gas 

moisture, stack gas temperature, atmospheric pressure, and stack gas static and differential 

pressures, i.e., velocity measurements. These tests were conducted before and after each test run 

for use in mass emission rate calculations of NOX, CO, VOC, and PM10 emissions and were used 

in lieu of the flow rates measured by the PM train due to the high bias caused by the PM train in 

a small duct. The field data sheets, used for collection of data specific to stack gas moisture and 

velocity, are in Appendix A. 

 The second technique employed a stoichiometric calculation (EPA Method 19) based on 

measurements of diluent gas (O2 or CO2) concentration, "F Factors" determined from fuel 

composition, and the engine's fuel consumption rate. This technique is performed to verify the 

accuracy of the physical measurement technique. Sometimes measuring engine exhaust flow 

with a pitot tube in a location with turbulent, pulsating flow, i.e., before a silencer, can produce 

inaccurate flow rate values. The results of this comparison showed that EPA Method 19 differed 

from the reference method by less than 10%. 

The fuel analysis is contained in Appendix C of this report. This landfill gas analysis 

was obtained from the EPA Method 3C samples collected during the testing. The landfill gas 

fuel composition was determined for use in EPA Method 19 equations as described above. The 

fuel composition and the TRC heating value and “F-factor” worksheet are in Appendix C. 

A certified EPA Method 9 observer performed opacity readings on the engine exhaust 

stack. One 60-minute visible emission test run was conducted during the gaseous and PM 

emissions testing. The testing was conducted when the sun was not directly overhead and with 

daylight present. EPA Method 9 requires the sun angle to be 140 degrees to the observer’s back. 

 Appendix A contains the stack diagrams, the iso-kinetic sampling calculation worksheets, 

and all field data sheets used during these tests. Appendix B contains examples of all 

calculations necessary for the reduction of the data presented in this report. Appendix C contains 

the landfill gas composition analyses, the TRC fuel calculation worksheets used to determine 

custom EPA Method 19 F-factors, and the landfill gas analysis of chlorinated organic 

compounds. Quality assurance activities are documented in Appendix D. Certificates of 

calibrations for TRC equipment and gases are contained in Appendix E of this report. Appendix 

F contains the records of logged data, displayed in one-minute intervals and rolling one-minute 

averages, used to record the reference method NOX, CO, THC, O2, and CO2 concentrations. 

Appendix G contains unit operational data reported in thirty-minute intervals. Appendix H 

contains TRC spreadsheets and results of analysis PM10, CH4, and HCl samples. “Visible 

Emissions Observation Forms” and the observer certifications are in Appendix I. The FDEP 

permit is presented in Appendix J for reference purposes. 
TABLE 3: Summary of Results

Unit 5, Emissions Test Results Company: Seminole Energy, LLC

Plant: BCSWM Central Disposal Facility

Location: Cocoa, Florida

Technicians: CFF, RPO, CDH

Source: Unit 5, a Caterpillar G3520C generator engine

Test Number U5-C-1 U5-C-2 U5-C-3

Date 09/24/08 09/24/08 09/24/08

Start Time (24 hour basis) 09:56 11:57 13:56 FDEP

Stop Time (24 hour basis) 11:03 13:03 15:03 Permit

Turbine Operation Averages Limits

Generator Power Output (kW) 1602 1601 1601 1601

Engine Horsepower (bhp) 2235 2235 2234 2235

Air Mainfold Pressure (psia) 47.1 47.0 46.8 47.0

Air Manifold Temperature (°F) 133 133 133 133

Air-to-Fuel Ratio 7.9 7.9 7.9 7.9

Engine Oil Temperature (°F) 201 201 201 201

Turbine Fuel Data

Fuel Heating Value (Btu/SCF, HHV) 480.0 489.1 506.5 491.9

Fuel Specific Gravity 0.9751 0.9773 0.9739 0.9754

O2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9399 9410 9406 9405

CO2 "F-factor" (DSCFex/MMBtu @ 0% excess air ) 1762 1773 1764 1766

Fuel Flow Rate (SCFM) 559.7 561.7 557.0 559.4

Heat Input (MMBtu/hr, Higher Heat Value) 16.12 16.48 16.93 16.51

Ambient Conditions

Atmospheric Pressure ( "Hg) 29.94 29.94 29.94 29.94

Measured Emissions 

NOX (ppmv, dry basis) 65.57 65.18 66.41 65.72

CO (ppmv, dry basis) 600.3 598.6 598.5 599.1

THC (ppmv, wet basis as Propane) 560.8 576.5 563.0 566.77

THC (ppmv, dry basis as Methane, RF = 2.6178) 1715 1747 1708 1723

Methane (ppmv, dry basis per EPA Method 18) 1677 1644 1605 1642

VOC (ppmv, dry basis as Methane) 38.4 102.7 103.0 81.4

PM10 (grams PM10/DSCF flue gas) 0.00187 0.00207 0.00198 0.00197

VE (% opacity) - - 0 0 10

HCl (lbs/MMSCF) (conducted after other runs) 0.973 0.957 0.939 0.957 10.9

O2 (% volume, dry basis) 7.93 8.00 7.97 7.97

CO2 (% volume, dry basis) 11.71 11.73 11.70 11.71

H2O (% volume, from Method 5 sample train) 14.42 13.60 13.71 13.91

Stack Volumetric Flow Rates

via EPA Methods 1-4, pitot tube (SCFH, dry basis) 2.71E+05 2.70E+05 2.71E+05 2.71E+05

via EPA Method 19 O2 "Fd-factor" (SCFH, dry basis) 2.44E+05 2.51E+05 2.57E+05 2.51E+05

via EPA Method 19 CO2 "Fc-factor" (SCFH, dry basis) 2.43E+05 2.49E+05 2.55E+05 2.49E+05

Calculated Emission Rates (from EPA Method 1-4 flow rates)

NOX (lbs/hr) 2.12 2.10 2.15 2.12 2.95

PM10 (lbs/hr) 1.12 1.23 1.18 1.18 1.18

CO (lbs/hr) 11.8 11.7 11.8 11.8 13.54

VOC (lbs/hr) 0.433 1.15 1.16 0.92 1.37

NOX (tons/yr) 9.28 9.20 9.41 9.30 12.94

PM10 (tons/yr) 4.89 5.38 5.17 5.15 5.17

CO (tons/yr) 51.8 51.4 51.7 51.6 59.30

VOC (tons/yr) 1.90 5.05 5.10 4.02 5.99

HCl (tons/yr) (conducted after other runs) 0.144 0.141 0.138 0.141 1.66

NOX (g/bhp-hr) 0.430 0.426 0.436 0.431 0.60

PM10 (g/bhp-hr) 0.227 0.249 0.240 0.239 0.24

CO (g/bhp-hr) 2.40 2.38 2.40 2.39 2.75

VOC (g/bhp-hr) 0.0879 0.234 0.236 0.186 0.28

Testing by TRC - Air Measurements • Gainesville Office

8
TABLE 4: Summary of Results

Unit 5, PM Results Table

Company: Seminole Energy, LLC

Plant: BCSWM Central Disposal Facility

Location: Cocoa, Florida

Technicians: CFF, RPO, CDH

Source: Unit 5, a Caterpillar G3520C generator engine

Test Run Designation U5-C-1 U5-C-2 U5-C-3

Date 09/24/08 09/24/08 09/24/08

Start Time (24 hour basis) 9:56 11:57 13:56

Stop Time (24 hour basis) 11:01 13:03 15:03

Unit Operational Data Averages

Generator Power Output (kW) 1602 1601 1601 1601

Engine Horsepower (bhp) 2235 2235 2234 2235

Landfill Gas Heat Input (MMBtu/hr) 16.12 16.48 16.93 16.51

Stack Gas Sampling Data

Box No. E-2 2 E-2 -

Atmospheric Pressure (" Hg, absolute) 29.94 29.94 29.94 29.94

Sample Volume at STP, dry basis (SCF) 39.411 41.378 41.892 40.894

Stack Velocity (ft/sec @ stack conditions) 179.14 188.06 191.58 186.26

% of Isokinetic Sampling 104.0 103.1 102.1 103.1

Particular Matter Weight Analysis (g)

Filter Number Q-7-16 Q-7-20 Q-7-21

Average Tare Weight 0.42365 0.42305 0.42600 0.42423

Average Final Weight 0.42485 0.42415 0.42735 0.42545

Filter Weight Gain 0.00120 0.00110 0.00135 0.00122

Nozzle (and loose PM) Rinse Beaker Number 17 18 19

Volume (Acetone) 177 143 118 146.0

Average Tare Weight 105.85300 104.86590 105.71140 105.47677

Average Final Weight 105.85590 104.87475 105.71470 105.48178

Front Half Weight Gain 0.00290 0.00885 0.00330 0.00502

Nozzle (and loose PM) Rinse Blank Beaker Number 20 20 20

Volume (Acetone) 140 140 140 140.0

Average Tare Weight 105.47060 105.47060 105.47060 105.4706

Average Final Weight 105.47105 105.47105 105.47105 105.4711

Acetone Blank Residue Concentration (mg/mg) 0.000004 0.000004 0.000004 0.000004

Organic (Methylene Chloride) Condensable Beaker Number 3 810

Volume (Methylene Chloride) 177 174 172 174.3

Average Tare Weight 106.36090 105.29210 105.11755 105.5902

Average Final Weight 106.36100 105.29270 105.11770 105.5905

Organic Weight Gain 0.00010 0.00060 0.00015 0.0003

Organic (Methylene Chloride) Blank Beaker Number 12 12 12

Volume (Methylene Chloride) 250 250 250 250.0

Average Tare Weight 105.89015 105.89015 105.89015 105.89015

Average Final Weight 105.89035 105.89035 105.89035 105.89035

Organic Blank Residue Concentration (mg/mg) 0.000001 0.000001 0.000001 0.000001

Inorganic (Water) Condensable Beaker Number 2, 6, 7 4, 5, 9 1, 11, 14

Volume (Water) 538 564 588 563.3

Avgerage Tare Weight 313.79940 314.17630 316.51770 314.83113

Average Final Weight 313.87045 314.25270 316.59715 314.90677

Inorganic Weight Gain 0.071050 0.076400 0.079450 0.07563

Inorganic (Water) Blank Beaker Number 13 13 13

Volume (Distilled Water) 158 158 158 158

Avgerage Tare Weight 105.35520 105.35520 105.35520 105.3552

Average Final Weight 105.35545 105.35545 105.35545 105.3555

Inorganic Blank Residue Concentration (mg/mg) 0.000002 0.000002 0.000002 0.000002

Particulate Matter Weight Gain

Total Collected Blank Weight Correction (Acetone, MeCl2, H2O) 0.00156 0.00149 0.00145 0.0015

Total Collected Sample Weight (Filter, Acetone, MeCl2, H2O) 0.07525 0.08695 0.08425 0.0822

Total Collected Particulate Matter, Blank Corrected (g) 0.07369 0.08546 0.08280 0.0806

Measured Emissions

PM10 (grams PM/DSCF flue gas) 1.87E-03 2.07E-03 1.98E-03 1.97E-03

Testing by TRC - Air Measurements • Gainesville Office

9
TABLE 5: Summary of Results

Unit 5, HCl Results Table Company: Seminole Energy, LLC

Plant: BCSWM Central Disposal Facility

Location: Cocoa, Florida

Technicians: CFF, RPO, CDH

Source: Unit 5, a Caterpillar G3520C generator engine

Test Run Designation CT5-HCl-1 CT5-HCl-2 CT5-HCl-3

Date 09/24/08 09/24/08 09/24/08

Start Time (24 hour basis) 16:39 18:06 19:47

Stop Time (24 hour basis) 17:43 19:10 20:54

Unit Operational Data Averages

Generator Power Output (kW) 1602 1602 1601 1602

Engine Horsepower (bhp) 2235 2236 2235 2235

Air Mainfold Pressure (psia) 47.2 47.0 47.3 47.2

Air Manifold Temperature (°F) 133 132 132 132

Air-to-Fuel Ratio 7.9 7.9 7.9 7.9

Fuel Flow Rate (SCFM) 562.0 562.3 560.0 561.4

Average Fuel Heating Value (Btu/SCF - EPA M-3C) 491.9 491.9 491.9 491.9

Landfill Gas Heat Input (MMBtu/hr) 16.59 16.60 16.53 16.57

TO-15 Chlorinated Compound Fuel Data

Concentration of Chloinated compounds (ppmv as Cl) 7.378 7.392 8.390 7.720

Estimated Engine HCl Emissions From Fuel (lbs/hr) 0.0240 0.0240 0.0272 0.0251

Stack Gas Sampling Data

Box No. 3M 2M E2 -

Atmospheric Pressure (" Hg, absolute) 29.94 29.94 29.94 29.94

Sample Volume at STP, dry basis (SCF) 41.139 40.749 39.074 40.321

Moisture (% volume) 14.18 13.98 14.23 14.13

O2 (% volume, dry basis) 8.01 8.04 8.00 8.02

CO2 (% volume, dry basis) 11.56 11.70 11.42 11.56

Stack Gas Molecular Weight, wet basis (lbs./lb-mole) 28.44 28.49 28.42 28.45

Stack Velocity (ft/sec @ stack conditions) 186.04 183.74 177.51 182.43

Stack Flow, dry (SCFH) 2.96E+05 2.93E+05 2.82E+05 2.90E+05

Sample Run Time (minutes) 60 60 60 60

Nozzle Area (ft2

) 0.0001928 0.0001928 0.0001928 0.000193

% of Isokinetic Sampling 94.6 94.7 94.1 94.5

HCl Ion Chromatography Analysis Data

Laboratory Sample ID Number 08-M1209 08-M1210 08-M1211 -

HCl Concentration (μg/ml) 4.86 4.79 4.66 4.77

Total Sample Volume (ml) 427 425 425 426

HCl Concentration (total per sample, μg) 2070 2040 1980 2030

Concentration of HCl in Stack (mg/DSCF) 0.050317 0.050062 0.050673 0.050351

Measured Emissions

HCl (lbs/hr) 0.0328 0.0323 0.0316 0.0322

HCl (tons/yr) 0.144 0.141 0.138 0.141

HCl (lbs/MMSCF of LFG Fuel Burned) 0.973 0.957 0.939 0.957

Testing by TRC - Air Measurements, Gainesville Office

 10
11 

PROCESS DESCRIPTION

 Brevard Energy owns and operates a power generation facility at the Brevard County 

Solid Waste Management Facility in Cocoa, Brevard County, Florida. The station uses six 

landfill gas fueled engines to provide electricity to the local power grid. The exhaust emissions 

from Unit 5 were measured to determine compliance with the FDEP construction permit. This 

section of the report provides a brief description of this engine. 

 The generator engine, Unit 5, was manufactured by Caterpillar , Model 3520C, and is 

fueled exclusively with landfill gas generated from microbial decomposition of solid waste from 

the landfill. The engine is a lean burning, four-cycle, turbo-charged, generator engine which 

uses electronic ignition and air-to-fuel ratio controls to reduce pollutant emissions. The State of 

Florida designates this unit with FDEP E.U. ID No. 0090068-008. 

 The engine is rated for production of 2233 bhp at a speed of 1800 rotations per minute 

(rpm). The operating schedule for this engine is permitted for 8760 hours per year. The power 

generating requirement of 2233 bhp is based upon a minimum landfill gas fuel requirement of 

467 British thermal units per standard cubic foot (Btu/scf) and a landfill gas useage of 580 

standard cubic feet per minute (scfm). 

 Sample ports meeting the criteria of EPA Method 1 were located in a straight vertical 

section of the exhaust pipe. The sample ports were 53 inches or 3.4 stack diameters upstream 

from the nearest flow disturbance, the engine silencer. Sampling ports were 124 inches or 8.0 

stack diameters downstream from the nearest flow disturbance. Access to the stack was made 

available via a safety ladder to the roof of the building. The diameter of the exhaust stack was 

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

locations. 

 Brevard Energy personnel provided operational data from the engine instrument panels. 

Data sets were recorded at approximate 30-minute intervals during each test run; the average of 

this data was recorded in the summary table. Copies of the original data are contained in 

Appendix G of this report. 
12 

ANALYTICAL TECHNIQUES

 Emissions from one generator engine were measured at the Brevard County Solid Waste 

Management Facility located in Auburndale, Polk County, Florida. TRC performed these tests 

on September 24th, 2008 in order to determine the compliance status with regard to permitted 

emission limits on Unit 5. This section of the report describes the analytical techniques and 

procedures used during these tests. 

 The sampling and analysis procedures used during these tests conformed with those 

outlined in The Code of Federal Regulations, 40 CFR 60, Appendix A, Methods 1, 2, 3A, 4, 5, 

7E, 9, 10, 19, 25A, and 26A (modified). The stack gas analyses for NOX, CO, THC, O2 and CO2

were performed using continuous instrumental monitors. Exhaust gas analyses were performed 

on a dry basis for all compounds. Table 6 lists the instruments and detection principles used for 

these analyses. Manual sampling measurements included iso-kinetic sampling for collection of 

PM10 and HCl samples using combined hot/cold sampling trains. Landfill gas fuel sampling and 

analysis was conducted in accordance with EPA Method 3C and EPA Method TO-15 for 

chlorinated compounds. 

The first step in the test matrix consisted of conducting an initial sampling traverse of the 

engine exhaust stack. The purpose of this sampling traverse was to check for changes in 

emissions concentration (stratification) within the exhaust stack. NOX, CO, O2 and CO2

concentrations were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. 

No significant stratification was observed for the NOX, CO, O2, and CO2 emissions. The 

stratification was less than 5% from the mean concentration. Therefore, sampling during the 

testing was conducted from a single point of average emissions with the probe switched between 

sample ports in the middle of each test run. 

Following the stratification test, TRC conducted six test runs at full load on the unit at the 

exhaust stack. Each test run was 60 minutes in duration. During the first three test runs 

emissions of NOX, CO, THC, CH4, VOC, PM10, and VE were determined. NOX, CO, THC, O2, 

and CO2 were measured using continuous instrumental monitors. CH4 samples were collected 

into Teldar® sample bags. Stack gas flow was measured before and after each test run. PM10

(filterable + condensable) samples were collected using a hot/cold manual sampling train and 

samples were analyzed at the TRC Gainesville Lab. Landfill gas fuel samples were collected 

during these first three tests for analysis of fuel composition and gross heating value. One 60-

minute VE test was conducted during these tests. 

During the second set of three test runs, emissions of HCl were determined. HCl 

emissions were collected using a hot/cold manual sampling train and samples were analyzed by 

an outside laboratory. In conjunction with the HCl testing, O2 and CO2 emissions were 

monitored for use in determination of stack gas molecular weight. Landfill gas fuel samples 

were collected in conjunction with the HCl emissions testing for analysis of chlorinated organic 

compounds. 
13 

Gaseous Emission Testing

 Provisions were made to introduce the calibration gases to the instrumental monitors via 

two paths: 1) directly to the instruments via the sample manifold quick-connects and flow 

meters, and 2) through the complete sampling system including the sample probe, filter, heat 

trace, condenser, manifold, and flow meters. The former method was used for quick, convenient 

calibration checks. The latter method was used to demonstrate that the sample was not altered 

due to leakage, reactions, or adsorption within the sampling system (sample system bias check). 

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

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

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

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

NOX analyzer using nitrogen to check for any zero bias of the sample system. In accordance 

with EPA Methods 3A and 10 this span and zero bias check procedure was repeated for the CO, 

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

conducted for the THC analyzer to maintain consistency in results reporting. 

Figure 1 shows the set-up for sampling the engine exhaust stack with the continuous 

instrumental monitors. The gas sample was continuously pulled through a 3/4-inch diameter 

stainless steel probe and transported via a 120-foot long, 3/8-inch diameter heat-traced Teflon® 

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

exit the pressurized sample was pushed into a heated sample manifold. The bulk of the gas 

stream then passed to a stainless steel minimum contact condenser to dry the sample stream and 

into the (dry) sample manifold. From the manifold, the sample was partitioned to the analyzers 

through glass and stainless steel flow meters for flow control of the sample. 

 All instruments were housed in an air-conditioned trailer-mounted mobile laboratory. 

Gaseous calibration standards were provided in aluminum cylinders with the concentrations 

certified by the vendor. EPA Protocol No. 1 was used to determine the cylinder concentrations 

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

 The stack gas analyses for CO2 and O2 concentrations were performed in accordance with 

procedures set forth in EPA Method 3A. Instrumental analyses were used in lieu of an Orsat or a 

Fyrite procedure due to the greater accuracy and precision provided by the instruments. The 

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

paramagnetic cell detector. 

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

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

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

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

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

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

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

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

the actual NOX mass emission rates since the majority of NOX is in the form of NO which has 
14 

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

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

EPA Method 10. A continuous non-dispersive infrared (NDIR) analyzer was used for this 

purpose. This reference method analyzer was equipped with a gas correlation filter that removes 

most interference from moisture, CO2, and other combustion products. 

THC concentrations were quantified during the testing using Method 25A. These THC 

emissions and the EPA Method 18 methane emissions were used for determination of VOC 

emissions. Total hydrocarbons were continuously measured throughout each test run using a 

flame ionization detector (FID). The THC continuous analyzer was calibrated on propane 

standards in an air matrix. Thus, the results included in this report were presented on a ppmv as 

propane, wet basis with conversion to a ppmv as methane, dry basis using a response factor 

determined on-site from a methane calibration standard and the measured stack gas moisture 

content. 

Bag samples were collected into Tedlar® sample bags from the gas manifold for 

determination of CH4 emissions per EPA Method 18 (modified). These samples were collected 

on a dry basis from the cold side of the sample manifold with sampling maintained at a constant 

flow rate. Samples were shipped to Enthalpy Analytical, Inc. of Durham, North Carolina for 

analysis using a gas chromatograph equipped with a flame ionization detector. The resultant 

methane concentration was be subtracted from the THC concentrations giving VOC values. The 

VOC values will be used in calculating VOC emission rates from the engine exhaust. 

 All data from the continuous monitoring instruments were logged into a computer file in 

1-minute intervals. A data logger with a computer generated display screen monitored, recorded, 

and averaged the emission concentrations. The program controlling the logging of data was also 

used to log quality assurance (QA) data. See Appendix F of this report for copies of the raw data 

and Appendix D for the QA data. 

 Visible emissions as opacity were determined via EPA Method 9. A 60-minute opacity 

test run was performed concurrently with a compliance test run. A 60-minute opacity test run 

was also performed on one of the cooling tower’s eight exhaust fans. The visual emission 

observer was certified at an FDEP approved smoke school. Appendix I provides both the 

opacity observation sheets as well as observer certification documents. 

Particulate Matter Testing

 EPA Method 1 was used to determine the PM10 traverse point locations. Prior to 

conducting the tests, a cyclonic flow check was conducted. No significant cyclonic flow was 

encountered. Pitot tube measurements were made at 6 separate traverse points in each of 2 

sample ports, i.e., 12 sample points total. The location of the sample ports and the pitot tube 

traverse point distances are denoted in the stack diagram, see Appendix A. 

 EPA Method 2 in conjunction with EPA Method 5/202 was used for determination of 

stack gas velocity during each run. An S-type pitot tube and inclined gauge oil manometer were 
15 

used to measure the differential pressures at each traverse point. The stack gas temperature was 

determined with a K-type (chromel-alumel) thermocouple used in conjunction with a digital 

thermometer. 

 EPA Method 4 in conjunction with EPA Method 5/202 was used to measure the moisture 

content of the stack gases. A chilled water impingement system was used in conjunction with a 

calibrated dry gas meter to pull a sample greater than 30 standard cubic feet (scf). A K-type 

(chromel-alumel) thermocouple was used in conjunction with a digital thermometer to determine 

the last impinger temperatures in the chilled liquids impingement sampling train. This parameter 

is measured to ensure that the gas stream is cooled to a minimum of 68 degrees Fahrenheit as 

required by sampling methodology. Determination of the moisture content was necessary both 

to determine the stack gas molecular weight necessary for determination of volumetric flow 

(used for verification of sampling iso-kinetics) and to convert THC wet concentrations to a dry 

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

 Particulate matter testing was conducted using the procedures of EPA Method 5/202. 

Figure 2 depicts the sampling system used for PM10 measurements. A sample was continuously 

pulled through an glass or quartz probe and stainless steel nozzle assembly, to a heated filter, and 

then through an iced impinger train charged with ASTM Type II distilled water to trap the stack 

moisture. This sampling assembly was suspended on monorails. The dry gas was then passed 

through a Teflon sample line into a dry gas meter. A stainless steel nozzle and glass probe liner 

was used for all PM10 testing. PM10 was collected onto a quartz fiber filter using a glass filter 

holder equipped with a Teflon frit. Iso-kinetic sampling was maintained throughout each test 

run. Each PM test run consisted of sampling for 60-minutes at six points from each of two ports 

which allowed for the collection of at least 30 scf of sample during each test run. The field data 

sheets used to record the PM sampling data are available in Appendix A. 

 The PM10 filters were weighed before and after sampling. The PM10 weight gain 

included both filterable PM per EPA Method 5 and condensable PM per EPA Method 202. The 

filterable PM consisted of the filter plus the probe/nozzle/front half of the filter acetone holder 

rinse, i.e., the "front half" of the sample train. The condensable PM consisted of the ASTM 

Type II water back half of the of the sample train, the methylene chloride rinse of the impingers, 

and the methylene chloride extraction of the water samples. All beaker boil-downs of the front 

acetone water, and methylene chloride fractions and filter weighing were conducted at the TRC 

Gainesville laboratory. 

 Each EPA Method 5 filter and liquid fraction weighing was conducted on an AND Model 

HR-120 balance. This balance has a 120-gram (g) capacity and a 0.0001-g sensitivity. The 

balance was leveled and zeroed before each weighing. Each weighing of filters and beakers 

were repeated until a “constant weight” was obtained. A “constant weight” is defined by EPA 

Method 5 as a difference of no more than 0.5 mg or 1 percent of the total weight less tare weight, 

whichever is greater. This definition applies to two consecutive weighing with no less than 6 

hours of desiccation time between weighing. The sample recovery data sheets that describe the 

weighing times and dates and the difference between measurements used to establish that a 

constant weight had been obtained are in Appendix H. Calculation worksheets used to 

determine the PM results are also included in Appendix H. 
16 

Hydrochloric Acid Emission Testing

 EPA Method 1 was used to determine the HCl sampling point locations. Pitot tube 

measurements were made at 6 separate traverse points in each of 2 sample ports, i.e., 12 sample 

points total. The location of the sample ports and the pitot tube traverse point distances are 

denoted in a stack diagram, see Appendix A. 

 EPA Method 2 in conjunction with EPA Method 26A was used for determination of 

stack gas velocity during each run. An S-type pitot tube and inclined gauge oil manometer were 

used to measure the differential pressures at each traverse point. The stack gas temperature was 

determined with a K-type (chromel-alumel) thermocouple used in conjunction with a digital 

thermometer. 

 EPA Method 4 in conjunction with EPA Methods 26A was used to measure the moisture 

content of the stack gases. A chilled liquid impingement system was used in conjunction with a 

calibrated dry gas meter to pull a sample greater than 30 standard cubic feet (scf) and for 60 

minutes. A K-type (chromel-alumel) thermocouple was used in conjunction with a digital 

thermometer to determine the last impinger temperatures in the chilled liquids impingement 

sampling train. This parameter is measured to ensure that the gas stream is cooled to a minimum 

of 68 degrees Fahrenheit (°F) as required by sampling methodology. Determination of the 

moisture content was necessary to determine the stack gas molecular weight necessary for 

determination of flow rates (used for verification of sampling iso-kinetics). EPA Method 4 

equations were used to calculate stack moisture content. 

 HCl testing was conducted using the procedures of EPA Method 26A sampling train. 

Figure 2 depicts the sampling system used for HCl measurements. The filter holder and probe 

temperatures were maintained above 248°F during each test run. Samples was continuously 

pulled through a heated filter and probe assembly (suspended on monorails) and then through an 

iced impinger train charged with an aqueous acidic absorber solution to trap the HCl and stack 

moisture. The dry gas was then passed through a dry gas meter. A quartz nozzle and glass or 

quartz probe liner was used for all HCl testing. HCl was collected into an aqueous absorber 

solution placed in the impingers. Iso-kinetic sampling was maintained throughout each test run. 

Each HCl test run consisted of sampling for 60-minutes at six points per port from four sampling 

ports which allowed for the collection of at least 30 scf of sample during each test run. The field 

data sheets, used to record the HCl sampling data, are available in Appendix A. 

EPA Method 26A calls for a filter followed by two Greenberg-Smith impingers 

containing 0.1 N sulfuric acid (H2SO4) then followed by two modified Greenberg-Smith 

impingers with the tip-removed containing 0.1 N sodium hydroxide (NaOH) and then a desiccant 

impinger. The H2SO4 impingers collect the HCl gases for analysis; and, the NaOH impingers are 

designed for collection and measurement of halogens such as chlorine and bromine. Since only 

HCl concentrations were of interest, TRC omitted the NaOH impingers, the third and fourth 

impingers were empty and contained silica gel, respectively as called for in Method 5. The 

probe, nozzle, and PM filter holder rinse was not included in the HCl analysis. The filter holder 

and probe were both maintained at a temperature of greater than 248 °F as required by both EPA 

Methods 26A. 
17 

 HCl concentrations were analyzed by ion chromatography by Chester LabNet of Tigard, 

Oregon. Samples were transferred to leak-tight Nalgene® sample bottles after collection. These 

samples were then shipped with chain-of-custody forms to the lab. Analysis was conducted in 

accordance with EPA Method 26A using a ion chromatograph equipped with a conductivity 

detector. A detailed description of the sample analysis and the results are contained in Appendix 

H. 

 EPA Methods 1 through 4 were used to calculate mass emission rates during the testing. 

Since the iso-kinetic sampling probe caused a high bias in the flow due to the small stack size, 

flow measurements were conducted before and after each test run for determination flow rates 

for use in the calculation of NOX, CO, VOC and PM10 mass emission rates in order to provide 

more accurate test results. These additional flow tests were not used in determination of HCl 

mass emission rates. 

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

volumetric flow rates as determined by EPA Methods 1 through 4. These calculations are based 

on the heating value and the O2 and CO2 “F-factors” (DSCF of exhaust per MMBtu of fuel 

burned) for landfill gas as determined from the fuel analysis. Method 19 flow rate 

determinations are also based on the excess air (as measured from the exhaust diluent 

concentrations) and the landfill gas fuel flow rates. EPA Method 19 was used as the stack flow 

rate measurement technique for all testing. Appendix C also contains TRC fuel calculations for 

the O2 and CO2 “F-factors” and the gross heating value. 

A landfill gas (LFG) fuel sample, collected into a stainless steel canister at less than 500 

milliliters per minute, was analyzed for O2, CO2, CH4, and N2 in accordance with EPA Method 

3C. These measurements were necessary to determine LFG heating value and EPA Method 19 

“F-factors”. The sampling train consisted of a flow controller, absolute pressure gauge, and an 

evacuated sample tank. The flow controller was attached to the sample tank through the use of 

stainless steel quick connects. Triangle Environmental Services, Inc. of Research Triangle Park, 

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

description of the sample analysis and the results are contained in Appendix H. TRC normalized 

all the results supplied by the analytical laboratory. 

A LFG sample, collected into a stainless steel canister at approximately 13 milliliters per 

minute, was analyzed chlorinated organic compounds in accordance with EPA Method TO-15. 

The sampling train consisted of a mass flow controller and an evacuated sample tank. The flow 

controller was attached to the sample tank through the use of stainless steel quick connects. Air 

Toxics, Ltd. of Folsom, California conducted the analysis. Field sampling sheets are in 

Appendix A. A detailed description of the sample analysis and the results are contained in 

Appendix H. 

 TRC personnel collected ambient absolute pressure, temperature, and humidity data 

during each test run. A wet bulb/dry bulb psychrometer equipped with a battery-operated fan 

was used to determine ambient temperature and humidity conditions. An aircraft-type aneroid 

barometer (altimeter) was used to measure absolute atmospheric pressure. 
18 

 All emission calculations were conducted by a computer spreadsheet as shown in Tables 

2 through 5 of this report. Example calculations were performed manually using a hand-held 

calculator in order to verify the formulas used in the spreadsheets. Example calculations are 

located in Appendix B of this report. 
TABLE 6

ANALYTICAL INSTRUMENTATION

Parameter Model and Common Sensitivity Response Detection Principle

 Manufacturer Use Ranges Time (sec.)

NOX TECO 0-10 ppm 0.1 ppm 1.7 Thermal reduction of NO2 to NO.  Model 42C 0-25 ppm Chemiluminescence of reaction  0-50, 0-100 ppm of NO with O3. Detection by PMT.  0-200, 500 ppm Inherently linear within 1% of full  0-1,000 ppm scale.  0-5,000 ppm CO TECO 0-1 ppm 0.1 ppm 60 Infrared absorption, gas filter  Model 48 0-10 ppm correlation detector, micro-  0-30, 0-50 ppm processor based linearization.  0-100, 0-200 ppm  0-500, 0-1000 ppm CO2 Servomex 0-5% 0.025% < 10 Non-dispersive infrared absorption,  1440 0-10% 0.05% electronic linearization of a  0-15% 0.075% logarithmic signal (Beer’s Law) O2 Servomex 0-5% 0.02% < 10 Paramagnetic cell detector,  1440 0-10% 0.02% inherently linear.  0-25% 0.02% VOC California 0-10, 0-100, 10 ppb 2.0 Flame ionization of hydrocarbons  Analytical 0-1000, 0-10000 inherently linear within 1% over  Model 300-HFID 0-100,000 ppm the range of the analyzer. PM AND HM-120 0-120 grams 0.0001g n/a Spring loaded pressure plate for  gravimetric analysis  Nutech 2010 0-1SCFM n/a n/a Sample Console with temperature  controllers, sample pump, dry gas  meter, orifice meter, and inclined  ` manometer for isokinetic sampling NOTE: Higher ranges available by sample dilution.  Other ranges available via signal attenuation.

19
SS/Teflon®

Sample

Pump

Sample

Manifold

Calibration Gases

Heat Traced Line

Dry Gas Sample Line

Calibration Line

FIGURE 1

INSTRUMENTAL SAMPLE SYSTEM DIAGRAM

A

A

NOx

Analyzer

Analyzer

O2

Analyzer

Analyzer

A

A

Sample Stream

from Source

Condenser

Ice

Bath

Sample System

Bias Check Line

Quick Connects

Flowmeters

Flowmeters

Duct, Flue,

 or Stack

THC

Analyzer

Analyzer

20
°C

By-passValve

MainValve

DryGas

Meter

VacuumGauge

Inconel

Probe Liner

Glass Frit

Di H2O

Ice Bath

Manometer

and

Digital

Temperature

Guages

Heater Coil

 Temp Probe

Stainless

Sample

Nozzle Thermocouple

S type pitot tube

Ice Bath

Hot Filter Box Cold Sample Impinger Box

Meter Box &

Control Console

Rotary Vane

Vacuum Pump

Orifice

Meter

Stack Gas Flow

Heated Sample Probe

Di H20 Silica Gel

Umbilicle

FIGURE 2

Particulate Matter (PM)

Sample System Diagram

Sample system is composed of a stainless steel sample nozzle connected to an inconel probe with a

stainless steel union. The probe is then connected to a glass filter holder which contains a quartzfiber filter and a Teflon® filter support. From the filter holder, the sample stream passes through

two Greenburg-Smith impingers containing ASTM Type II distilled water, a modified GreenburgSmith impinger containing ASTM Type II distilled water, and then into a modified GreenburgSmith impinger containing silica gel. The dried gas then passes into a standard Method 5 meterbox with a pump, orifice, and calibrated dry gas meter.

Di H2O

26

21
°C

By-passValve

MainValve

DryGas

Meter

VacuumGauge

Quartz or Glass

Probe Liner

Glass Frit

 0.1 N

H2SO4

Ice Bath

Manometer

and

Digital

Temperature

Guages

Heater Coil

 Temp Probe

Quartz

Sample

Nozzle

Thermocouple

S type pitot tube

Ice Bath

Hot Filter Box Cold Sample Impinger Box

Meter Box &

Control Console

Rotary Vane

Vacuum Pump

Orifice

Meter

Stack Gas Flow

Heated Sample Probe

0.1 N 

H2SO4

Silica Gel

Umbilicle

FIGURE 

3

(HCL) Sample System Diagram

The sample system is composed of a one piece quartz sample nozzle in conjunction with a quartz probe. The probe is then connected to a glass filter holder which contains a quartz fiber filter andglass frit filter support. From the filter holder, the sample stream passes through a standardGreenburg-Smith impinger containing 0.1 N H2SO4, a standard Greenburg-Smith impinger

containing 0.1 N H2SO4, an empty modified Greenburg-Smith impinger, and then into a modifiedGreenburg-Smith impinger containing silica gel. The dried gas then passes into a standard Method5 meter box with a pump, orifice, and calibrated dry gas meter.

Empty

Temp: 250 °F

22
23 

QUALITY ASSURANCE ACTIVITIES

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

testing project. This section of the report combined with the documentation in Appendices D 

and E describe each of those activities. 

Gaseous Emission Testing 

 A multi-point calibration was performed for each instrument in the field prior to the 

collection of data. The instrument's linearity was checked by first adjusting the instrument's zero 

and span responses to zero nitrogen and an upscale calibration gas in the range of the expected 

concentrations. The instrument response was then challenged with other calibration gases of 

known concentration. The instrument's response was accepted as being linear if the response of 

the other calibration gases agreed within ±2 percent of the analytical range (high-level 

calibration gas) from the predicted values. For the THC analyzer, the instrument's response was 

accepted as being linear if the response of the other calibration gases agreed within ±5 percent of 

the certified calibration gas value. The response of the infrared absorption type CO and CO2

analyzers is made linear through electronic suppression. 

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

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

the NOX analyzer to a calibration gas (and a zero gas) introduced via two paths as previously 

described in the Analytical Techniques section of this report. This system bias test was 

performed to assure that no alteration of the sample had occurred during the test due to leakage, 

reactions, or absorption. Similarly, system bias checks were performed with THC, CO, O2, and 

CO2 for added assurance of sample system integrity. The results of the system bias checks are 

available in Appendix D. 

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

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

was calibrated and then a NO2 calibration gas was introduced directly to the analyzer. The 

average analyzer response over 5 minutes was recorded and the converter efficiency calculated 

from this average response. If the converter efficiency was at least 90 percent, then the converter 

is acceptable. Appendix D provides the results for the converter efficiency check. 

 The residence time of stack sampling and measurement system were estimated using the 

pump flow rate and the sampling system volume. The pump's rated flow rate is 1.2 scfm at 5 

psig. The sampling system volume was approximately 0.28 scf. Therefore, the system had a 

minimum sample residence time of approximately 14 seconds. 

The NOX, CO, O2 and CO2 sampling and analysis system was checked for response time 

per the procedures outlined in EPA Method 7E, Section 8.2.5 and 8.2.6. The maximum response 

time did not exceed 80 seconds. The minimum sampling time per point selected was at least 
24 

twice the maximum response time as determined during the initial system bias tests. The results 

of these response time tests are contained in Appendix D. 

TRC and/or instrument vendors conducted interference response tests on the NOX, CO, 

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

responses for H2O, C3H8, CO, CO2 and O2 is less than 2 percent of the applicable full-scale span 

value. The instruments used for the tests meet the performance specifications for EPA Methods 

3A, 7E, and 10 as written prior to the method updates. All of the analyzers predate the 

methodology updates as effective on August 14th, 2006. The results of the interference tests are 

available in Appendix D of this report. 

 Each sampling system was leak checked by demonstrating that it could hold a vacuum 

greater than 15 inches of mercury ("Hg) for at least 1 minute with a decline of less than 1 "Hg. 

A leak test was conducted after each sample system was set up, i.e., before testing began, at the 

beginning and end of each test day, and before the system was dismantled, i.e., after testing was 

completed. This test was conducted to insure that ambient air was not diluting the sampling 

system. No leakage was detected. 

 As a minimum, before and after each test run, the analyzers were checked for zero and 

span drift. This allows test runs to be bracketed by calibrations and documents the precision of 

the data just collected. Calibration gases were introduced to the analyzers through the entire 

sampling system. Appendix D contains quality assurance tables that summarize the zero and 

span checks that were performed for each test run. The worksheets also contain the data used to 

correct the data for drift per EPA Method 7E, Equation 7E-5. NOX, CO, O2 and CO2 data were 

corrected for drift as required by the test methods. Additionally, THC data was corrected for 

drift in order to be more consistent and accurate in the reporting of results. 

 The control gases used to calibrate the instruments were analyzed and certified by the 

compressed gas vendors to ±1% accuracy for all calibration gases. EPA Protocol No. 1 was 

used, where applicable, i.e., NOX gases, to assign the concentration values traceable to the 

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

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

Quality assurance procedures for laboratory analysis of the stack gas CH4 were 

conducted in accordance with EPA Method 18 protocols. Upon return to the TRC office 

samples were packed into a shipping container, sealed, and shipped with a chain-of-custody form 

to Enthalpy Analytical, Inc. A sample spike was additionally conducted and was within method 

specification. Results of the quality assurance activities are reported with the lab results in 

Appendix H. 

Particulate Matter Emission Testing 

 Quality assurance activities for the PM sampling began during preparation for the tests. 

All glassware was thoroughly washed, rinsed, dried, and packed safely to prevent contamination. 

American Chemical Society (ACS) reagent grade or better chemicals were used for recovering of 

the sampling train. A blank of the acetone, ASTM Type II water, and methylene chloride was 
25 

treated in the same manner as the samples and retained for evaporation and weighing for 

contaminants for each test series. A blank filter was also weighed after treating it in the same 

manner as the filters used during sampling for each test series. 

 The PM sampling system was leak checked by demonstrating that it could hold a vacuum 

greater than the highest sampling vacuum for at least 1 minute with a leakage rate less than 0.02 

cubic feet per minute (cfm). A leak test was conducted before each test run began and after each 

test run was completed. This leak check was performed in accordance with EPA Method 17 to 

ensure that the sample was not diluted by ambient air. Leak checks were conducted at a vacuum 

higher than that used during sampling. No leaks greater than 0.02 cfm were detected. 

 All PM sampling was conducted iso-kinetically. Field checks of the iso-kinetics during 

each test run were conducted to ensure strict adherence to EPA Method 5. Documentation of the 

iso-kinetics is presented in Appendix A of this report. 

 After leak checks were conducted for each run, the nozzle and front half of the filter 

holder were washed with acetone to remove adhering particulate matter. The front half acetone 

rinse were preserved for evaporation and stored into EPA pre-cleaned 250-milliliter glass jars. 

Also, blanks of acetone were kept for analysis of residue. The quartz fiber filters were carefully 

removed from the filter holders after each test run, placed in containers, and sealed against 

contamination. The back half fractions were preserved for evaporation. Also, blanks of the 

ASTM Type II water and the methyene chloride were kept for residue analysis. The ASTM 

Type II water samples were recovered and stored into EPA pre-cleaned 1-liter glass jars. The 

methylene chloride rinse samples were recovered and stored into EPA pre-cleaned 250-milliliter 

glass jars. All samples were carefully sealed to protect against contamination. 

HCl Emission Testing 

 Quality assurance activities for the HCl sampling began during preparation for the tests. 

All glassware was thoroughly washed, rinsed, dried, and packed safely to prevent contamination. 

American Chemical Society (ACS) reagent grade or better acetone, distilled water, and HCl 

absorber solution were selected for used. A blank of the HCl absorber solution and deionized 

water was collected with each set of test runs and put into an impinger and allowed to sit for 1-

hour before being packaged and shipped to the lab for analyses with the samples. 

 The HCl sampling system was leak checked by demonstrating that it could hold a 

vacuum greater than the highest sampling vacuum for at least 1 minute with a leakage rate less 

than 0.02 cubic feet per minute (cfm). A leak test was conducted before each test run began and 

after each test run was completed. This leak check was performed in accordance with EPA 

Methods 26A to ensure that the sample was not diluted by ambient air. Leak checks were 

conducted at a vacuum higher than that used during sampling. No leaks greater than 0.02 cfm 

were detected. 

 All HCl sampling was conducted iso-kinetically. Field checks of the iso-kinetics during 

at each sampling point and for the entire sampling test run were conducted to ensure strict 

adherence to EPA Methods 26A. Documentation of the iso-kinetics is presented in Appendix A 
26 

of this report. 

After each test run, the impingers of absorber solution and required sections of 

connecting glassware were rinsed and stored in HDPE plastic sample bottles. Each sample was 

rinsed with a specified volume of distilled water. Sample bottles were labeled, sealed and stored 

in a sample container. Upon return to the TRC office samples were packed into a shipping 

container, sealed, and shipped with a chain-of-custody form to Chester LabNet. 

Ion chromatographic analyses of the HCl samples were conducted with the inclusion of 

sample duplicates, spikes, and sample blanks. All duplicates and sample blanks fell within the 

requirements of the analytical method. Results of the quality assurance procedures conducted by 

the laboratory are located with the results in Appendix H. 

 The dry gas meter of the PM10, HCl, and moisture train was calibrated prior to testing in 

accordance with EPA Method 5. The dry gas meter in each control box was calibrated and a 

flow curve and dry gas meter factor was generated using the calibrated orifice procedure. A 

post-test meter calibration check was performed upon return to the TRC Gainesville Office using 

the Yqa check. The pitot tubes tips were inspected on-site prior to testing and assigned the 

default calibration factor. All sampling nozzles were measured prior to sampling and after 

completion of sampling to determine precise nozzle areas. All glassware was thoroughly 

washed, rinsed, dried, and stored to prevent contamination. The calibration certifications of the 

sampling system (dry gas meter, orifice curve, nozzle calibrations, and pitot tube calibrations) 

are found in Appendix E of this report. 

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

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

office samples were packed into a shipping container, sealed, and shipped with a chain-ofcustody form to Triangle Environmental Services, Inc. Results of the quality assurance activities 

are reported with the lab results in Appendix H. 

Quality assurance procedures for laboratory analysis of the landfill gas for chlorinated 

organic compounds were conducted in accordance with EPA Method TO-15 protocols. Upon 

return to the TRC office samples were packed into a shipping container, sealed, and shipped with 

a chain-of-custody form to Air Toxics, Ltd. Results of the quality assurance activities are 

reported with the lab results in Appendix H. 

 Appendix E also contains calibration data for the ancillary equipment used during this 

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

dew point temperatures. Other ancillary equipment includes analytical balance calibration data, 

angle finder calibration data, and caliper calibration data. 

 TRC collected and reported the enclosed test data in accordance with the procedures and 

quality assurance activities described in this test report. TRC makes no warranty as to the 

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

the test data by others.