# T EST 

# R EPORT

For 

## I NITIAL 

## C OMPLIANCE 

## T ESTING

From 

## U NIT 

## 5, A 2333 BHP C ATERPILLAR 

## M ODEL 

## N O



## . G3520C
G ENERATOR 

## E NGINE

In Service at the



## BREVARD 

# C OUNTY 

# S OLID 

# W ASTE 

# M ANAGEMENT 

# C ENTRAL 

# D ISPOSAL 

# F ACILITY

Located in 

## C OCOA 

## , B REVARD 

## C OUNTY 

## , F LORIDA

Prepared for


# B REVARD 

# E NERGY 

# , LLC

Test Completion Date: September 24 th , 2008 Report Draft Submittal Date: November 3 rd , 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, Flor ida. 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 24 th , 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 Departme nt 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 samp led 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 (NO X ), carbon monoxide (CO), total hydrocarbon compounds (THC), methane (CH 4 ), oxygen (O 2 ), and carbon dioxide (CO 2 ) using continuous instrumental monitors. Volatile organic compound (VOC) emissions were determined by determining by subtracting the CH 4 emissions from the THC emissions. Additional compliance testing consisted of collecting filterabl e and condensable particulate matter (PM 10 ) samples isokinetically and hydrochloric acid (HCl) samples iso-kinetically from the exhaust stack and conducting visible emissions (VE) tests on the exha ust stack. The landfill gas fuel used to fire the engine was analyzed for permanent gases for us e in determination of the fuel heating value of the landfill gas and was also analyzed for chlo rinated 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

B ACKGROUND D ATA

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 18 th 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 24 th , 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 Envi ronmental 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 approxi mately 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 fo r 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) trai n, 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 (CO 2 ) and oxygen (O 2 ) emissions.

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

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

EPA Methods 5 and 202 were used to determine filterable and condensable particulate matter (PM 10 ) emissions.

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

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

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

EPA Method 18 (modified) was used to collect bag samples to determine methane (CH 4 ) 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 O 2 and

CO 2 “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 genera tion 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 e ngines 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 designa tes 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 pe rformance 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. NO X , CO, VOC, and PM 10 mass emission rates are reported in terms of pounds per hour (lbs/hr), tons per year (tons/y r), 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

-
NO X (lbs/hr) 2.12 2.95

NO X (tons/yr) 9.30 12.94

NO X (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

PM 10 (lbs/hr) 1.18 1.18

PM 10 (tons/yr) 5.15 5.17

PM 10 (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 (stratifica tion) within the exhaust stack. NO X , CO, O 2 and CO 2 concentrations were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. No significant stratification was observed for the NO X , CO, O 2 , and CO 2 emissions. The
stratification was less than 5% from the mean concentration. Therefore, sampling during the testing was conducted from a single point of aver age emissions with the probe switched between sample ports in the middle of each test run.

Following the stratification test, TRC conducted si x 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 NO X , CO, THC, CH 4 , VOC, PM 10 , and VE were determined. NO X , CO, THC, O 2 , and CO 2 were measured using continuous instrumental monitors. CH 4 samples were collected into Teldar® sample bags. PM 10 (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 thr ee 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 sample s 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 concen trations, and calculated emission rates. NO X , CO, CH 4 , 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. PM 10 emissions are reported in terms of grams of

PM 10 per dry standard cubic f oot of stack gas (grams PM 10 /DSCF of flue gas). Mass emission
rates for NO X , CO, VOC, and PM 10 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 PM 10 testing for Unit 5. This tabular

summary contains unit operational data, sampling trai n data, and individual PM fraction weights from the lab analysis. PM 10 emissions are reported in terms of grams of PM 10 per dry standard cubic foot of stack gas (grams PM 10 /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 predic ted emissions from the Chlorine in the fuel as emissions of HCl in terms pounds per milli on 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 measur ement 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 pr essure, 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 NO X , CO, VOC, and PM 10 emissions and were used in lieu of the flow rates measured by the PM trai n due to the high bias caused by the PM train in a small duct. The field data sheets, used for coll ection of data specific to stack gas moisture and velocity, are in Appendix A.

The second technique employed a stoichiome tric calculation (EPA Method 19) based on measurements of diluent gas (O 2 or CO 2 ) concentration, "F Factors" determined from fuel composition, and the engine's fuel consumption rate . 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 th is 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 EP A 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, th e iso-kinetic sampling calculation worksheets, and all field data sheets used during these te sts. 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 fu el calculation worksheets used to determine custom EPA Method 19 F-factors, and the la ndfill gas analysis of chlorinated organic compounds. Quality assurance activities are docum ented in Appendix D. Certificates of calibrations for TRC equipment and gases are cont ained in Appendix E of this report. Appendix F contains the records of logged data, displaye d in one-minute intervals and rolling one-minute averages, used to record the reference method NO X , CO, THC, O 2 , and CO 2 concentrations. Appendix G contains unit operational data reporte d in thirty-minute intervals. Appendix H contains TRC spreadsheets and results of analysis PM 10 , CH 4 , and HCl samples. “Visible
Emissions Observation Forms” and the observer certifications are in A ppendix I. The FDEP permit is presented in Appendix J for reference purposes.

### TABLE 3: Summary of Results Unit 5, Emissions Test Results Com p an y : Seminole Ener gy , LLC

Plant: BCSWM Central Dis p osal Facilit y Location: Cocoa, Florida Technicians: CFF, RPO, CDH Source: Unit 5, a Cater p illar G3520C g enerator en g ine

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

O 2 "F-factor" (DSCFex/MMBtu @ 0% excess air) 9399 9410 9406 9405

CO 2 "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

NO X (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

PM 10 (grams PM 10 /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

O 2 (% volume, dry basis) 7.93 8.00 7.97 7.97

CO 2 (% volume, dry basis) 11.71 11.73 11.70 11.71

H 2 O (% 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 O 2 "F d -factor" (SCFH, dry basis) 2.44E+05 2.51E+05 2.57E+05 2.51E+05

via EPA Method 19 CO 2 "F

c -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)

NO X (lbs/hr) 2.12 2.10 2.15 2.12 2.95

PM 10 (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

NO X (tons/yr) 9.28 9.20 9.41 9.30 12.94

PM 10 (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

NO X (g/bhp-hr) 0.430 0.426 0.436 0.431 0.60

PM 10 (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

### TABLE 4: Summary of Results Unit 5, PM Results Table Compan y : Seminole Ener gy , LLC Plant: BCSWM Central Disposal Facilit y Location: Cocoa, Florida
Technicians: CFF, RPO, CDH Source: Unit 5, a Caterpillar G3520C g enerator en g ine 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 81 0 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, MeCl 2 , H 2 O) 0.00156 0.00149 0.00145 0.0015 Total Collected Sample Weight (Filter, Acetone, MeCl 2 , H 2 O) 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

PM 10 (grams PM/DSCF flue gas) 1.87E-03 2.07E-03 1.98E-03 1.97E-03

Testing by TRC - Air Measurements • Gainesville Office

## 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

O 2 (% volume, dry basis) 8.01 8.04 8.00 8.02

CO 2 (% 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 (ft 2 ) 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, μ g) 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

### 11 PROCESS DESCRIPTION

Brevard Energy owns and operates a power generation facility at the Brevard County Solid Waste Management Facility in Cocoa, Br evard 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 complia nce with the FDEP construction permit. This section of the report provides a brief description of this engine.

The generator engine, Unit 5, was manufact ured by Caterpillar , Model 3520C, and is fueled exclusively with landfill gas generated fr om microbial decomposition of solid waste from the landfill. The engine is a lean burning, fou r-cycle, turbo-charged, generator engine which uses electronic ignition and air-to-fuel ratio contro ls 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 f oot (Btu/scf) and a la ndfill gas useage of 580 standard cubic feet per minute (scfm).

Sample ports meeting the criteria of EPA Me thod 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 da ta from the engine instrument panels. Data sets were recorded at approximate 30-minut e 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 24 th , 2008 in order to determine the complia nce 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 NO X , CO, THC, O 2 and CO 2 were performed using continuous instrumental m onitors. 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

PM 10 and HCl samples using combined hot/cold sa mpling 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 (stratifica tion) within the exhaust stack. NO X , CO, O 2 and CO 2 concentrations were measured at 12 traverse points using a 6 × 2 sample matrix, within the stack. No significant stratification was observed for the NO X , CO, O 2 , and CO 2 emissions. The
stratification was less than 5% from the mean concentration. Therefore, sampling during the testing was conducted from a single point of aver age emissions with the probe switched between sample ports in the middle of each test run.

Following the stratification test, TRC conducted si x 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 NO X , CO, THC, CH 4 , VOC, PM 10 , and VE were determined. NO X , CO, THC, O 2 , and CO 2 were measured using continuous instrumental monitors. CH 4 samples were collected into Teldar® sample bags. Stack gas flow was measured before and after each test run. PM 10 (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 fu el 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 manua l 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 ga s molecular weight. Landfill gas fuel samples were collected in conjunction with the HCl emissi ons testing for analysis of chlorinated organic compounds.

### 13 Gaseous Emission Testing

Provisions were made to introduce the calibra tion gases to the instrumental monitors via two paths: 1) directly to the instruments via the sample manifold quick-connects and flow meters, and 2) through the complete sampling sy stem including the sample probe, filter, heat trace, condenser, manifold, and flow meters. Th e former method was used for quick, convenient
calibration checks. The latter method was used to demonstrate that the sample was not altered due to leakage, reactions, or adsorption within th e sampling system (sample system bias check).

A NO X standard calibration gas was introduced into the NO X analyzer directly. Then the response from the NO X analyzer was noted as the calibrati on gas was introduced at the probe. Any difference between the two responses in the in strument was attributed to the bias of the sample system. Following the span gas bias ch eck, a zero gas bias check was performed on the

NO X analyzer using nitrogen to check for any zero bias of the sample system. In accordance with EPA Methods 3A and 10 this span and zero bias check procedure was repeated for the CO,

O 2 , and CO 2 analyzers. Although not required by EP A 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 tr ansported via a 120-foot long, 3 / 8 -inch diameter heat-traced Teflon® line into the mobile laboratory using a stainl ess steel/Teflon® diaphragm pump. At the pump exit the pressurized sample was pushed into a h eated sample manifold. The bulk of the gas stream then passed to a stainless steel minimum contact condenser to dry the sample stream and into the (dry) sample manifold. From the mani fold, the sample was partitioned to the analyzers through glass and stainless steel flow meters for flow control of the sample.

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

The stack gas analyses for CO 2 and O 2 concentrations were performed in accordance with procedures set forth in EPA Method 3A. Instrumental analyses were used in lieu of an Orsat or a Fyrite procedure due to the greater accuracy and precision provided by the instruments. The

CO 2 analyzer was based on the principl e of infrared absorption; the O 2 analyzer operated using a paramagnetic cell detector.

NO X emission concentrations were determined in accordance with EPA Method 7E. The

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

### 14 less mass per unit volume (i.e., lbs. of emissions per ppmv concentration) than NO 2

.

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

THC concentrations were quantified during the testing using Method 25A. These THC
emissions and the EPA Method 18 methane emissi ons 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 in cluded 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 CH 4 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 instru ments were logged into a computer file in 1-minute intervals. A data logger with a comput er 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 Appe ndix F of this report for copies of the raw data and Appendix D for the QA data.

Visible emissions as opacity were determ ined via EPA Method 9. A 60-minute opacity test run was performed concurrently with a co mpliance 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 PM 10 traverse point locations. Prior to conducting the tests, a cyclonic flow check wa s 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 lo cation 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 Me thod 5/202 was used for determination of stack gas velocity during each run. An S-type p itot 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) th ermocouple used in conjunction with a digital

thermometer.

EPA Method 4 in conjunction with EPA Met hod 5/202 was used to measure the moisture content of the stack gases. A chilled water impi ngement 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 conj unction with a digital thermometer to determine the last impinger temperatures in the chilled liqui ds 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 n ecessary for determination of volumetric flow (used for verification of sampling iso-kinetics) a nd 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 us ing the procedures of EPA Method 5/202. Figure 2 depicts the sampling system used for PM 10 measurements. A sample was continuously pulled through an glass or quartz probe and stainle ss 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 suspe nded 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 PM 10 testing. PM 10 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 PM 10 filters were weighed before and after sampling. The PM 10 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 pr obe/nozzle/front half of the filter acetone holder rinse, i.e., the "front half" of the sample tr ain. The condensable PM consisted of the ASTM Type II water back half of the of the sample tr ain, the methylene chloride rinse of the impingers, and the methylene chloride extraction of the wate r 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 frac tion weighing was conducted on an AND Model HR-120 balance. This balance has a 120-gr am (g) capacity and a 0.0001-g sensitivity. The
balance was leveled and zeroed before each wei ghing. Each weighing of filters and beakers were repeated until a “constant weight” was obt ained. A “constant wei ght” 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 betw een measurements used to establish that a constant weight had been obt ained 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 Me thod 26A was used for determination of stack gas velocity during each run. An S-type p itot 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) th ermocouple 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 impi ngement 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) thermoc ouple was used in conjunction with a digital thermometer to determine the last impinger te mperatures in the chilled liquids impingement sampling train. This parameter is measured to ensu re 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 verifi cation of sampling iso-kinetics). EPA Method 4 equations were used to calculate stack moisture content.

HCl testing was conducted using the proce dures 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 dur ing 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 acidi c 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 sa mpling was maintained throughout each test run. Each HCl test run consisted of sampling for 60-mi nutes at six points per port from four sampling ports which allowed for the collection of at least 30 scf of sample during eac h 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 (H 2 SO 4 ) 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 H 2 SO 4 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 omitte d 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 temperatur e 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-cust ody 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 an alysis and the results are contained in Appendix

H.

EPA Methods 1 through 4 were used to calcu late mass emission rates during the testing. Since the iso-kinetic sampling probe caused a high bi as in the flow due to the small stack size,
flow measurements were conducted before and af ter each test run for determination flow rates
for use in the calculation of NO X , CO, VOC and PM 10 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 Me thod 19 were used to verify the stack volumetric flow rates as determined by EPA Me thods 1 through 4. These calculations are based on the heating value and the O 2 and CO 2 “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 rate s. EPA Method 19 was used as the stack flow rate measurement technique for all testing. Appe ndix C also contains TRC fuel calculations for
the O 2 and CO 2 “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 O 2 , CO 2 , CH 4 , and N 2 in accordance with EPA Method 3C. These measurements were necessary to determine LFG heating value and EPA Method 19 “F-factors”. The sampling train consisted of a fl ow controller, absolute pressure gauge, and an evacuated sample tank. The flow controller was attached to the sample tank through the use of stainless steel quick connects. Triangle Environm ental Services, Inc. of Research Triangle Park, North Carolina conducted the analysis. Field sa mpling sheets are in Appendix A. A detailed description of the sample analysis and the resu lts 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 co mpounds in accordance with EPA Method TO-15. The sampling train consisted of a mass flow cont roller 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 th e analysis. Field sampling sheets are in Appendix A. A detailed description of the samp le 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 psychr ometer equipped with a battery-operated fan was used to determine ambient temperature and humidity conditions. An aircraft-type aneroid barometer (altimeter) was used to measure absolute atmospheric pressure.

### 18 All emission calculations were conducted by a computer spreadsheet as shown in Tables 2 through 5 of this report. Example calculati ons were performed manually using a hand-held calculator in order to verify the formulas used in the spreadsheets. Example calculations are located in Appendix B of this report.TABLE6ANALYTICALINSTRUMENTATIONParameterModel and CommonSensitivityResponse Detection PrincipleManufacturerUse RangesTime (sec.)NOXTECO 0-10 ppm 0.1 ppm 1.7 Thermal reduction of NO2to NO.Model 42C 0-25 ppm Chemiluminescence of reaction0-50, 0-100 ppm of NO with O3. Detection by PMT.0-200, 500 ppm Inherently linear within 1% of full0-1,000 ppm scale.0-5,000 ppmCO TECO 0-1 ppm 0.1 ppm 60 Infrared absorption, gas filterModel 48 0-10 ppm correlation detector, micro-0-30, 0-50 ppm processor based linearization.0-100, 0-200 ppm0-500, 0-1000 ppmCO2Servomex 0-5% 0.025% < 10 Non-dispersive infrared absorption,1440 0-10% 0.05% electronic linearization of a0-15% 0.075% logarithmic signal (Beer’s Law)O2Servomex 0-5% 0.02% < 10 Paramagnetic cell detector,1440 0-10% 0.02% inherently linear.0-25% 0.02%VOC California 0-10, 0-100, 10 ppb 2.0 Flame ionization of hydrocarbonsAnalytical 0-1000, 0-10000 inherently linear within 1% overModel 300-HFID 0-100,000 ppm the range of the analyzer.PM AND HM-120 0-120 grams 0.0001g n/a Spring loaded pressure plate forgravimetric analysisNutech 2010 0-1SCFM n/a n/a Sample Console with temperaturecontrollers, sample pump, dry gasmeter, orifice meter, and inclined` manometer for isokinetic samplingNOTE:Higher ranges available by sample dilution.Other ranges available via signal attenuation.Vent

SS/Teflon®

Sample Pump 

### Sample

Manifold

Calibration Gases 

# TRC - Air

Measurements Calibration Line Heat Traced Line
Dry Gas Sample Line 

## FIGURE 1
I NSTRUMENTAL 

## S AMPLE 

## S YSTEM 

## D IAGRAM

Calibraton

Gas

Manifold CO

Analyzer Analyzer Vent

NO x Analyzer Analyzer

O 2

Analyzer Analyzer CO 2

Analyzer Analyzer

Vent

Sample Stream

from Source 

### Condenser Ice Bath Sample System

Bias Check Line

Quick Connects Flowmeters

Flowmeters Duct, Flue,

or Stack THC

Analyzer Analyzer°CBy-passValveMainValveDryGasMeterVacuumGaugeInconelProbe LinerGlass FritDi H2OIce BathManometerandDigitalTemperatureGuagesHeater CoilTemp ProbeStainlessSampleNozzleThermocoupleS type pitot tubeIce BathHot Filter BoxCold Sample Impinger BoxMeter Box &Control ConsoleRotary VaneVacuum PumpOrificeMeterStack Gas Flow Heated Sample ProbeDi H20Silica Gel

UmbilicleFIGURE2Particulate Matter (PM)Sample System DiagramSample system is composed of a stainless steel sample nozzle connected to an inconel probe with astainless 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 throughtwo 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**°CBy-passValveMainValveDryGasMeterVacuumGaugeQuartz or GlassProbe LinerGlass Frit0.1 NH2SO4Ice BathManometerandDigitalTemperatureGuagesHeater CoilTemp ProbeQuartzSampleNozzleThermocoupleS type pitot tubeIce BathHot Filter BoxCold Sample Impinger BoxMeter Box &Control ConsoleRotary VaneVacuum PumpOrificeMeterStack Gas Flow



### Heated Sample Probe0.1 NH2SO4Silica Gel UmbilicleFIGURE3(HCL) Sample System DiagramThe sample system is composed of aone piece quartzsample nozzlein conjunction with aquartzprobe. 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 astandardGreenburg-Smith impinger containing0.1 N H2SO4, a standard Greenburg-Smithimpingercontaining0.1 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.EmptyTemp: 250 °F

### 23 QUALITY ASSURANCE ACTIVITIES

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

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

System bias checks were performed both befo re and after the sampling system was used for emissions testing. The sampling system's inte grity was tested by comparing the responses of
the NO X analyzer to a calibration gas (and a zero ga s) introduced via two paths as previously

described in the Analytical Techniques section of this report. This system bias test was performed to assure that no alteration of the samp le had occurred during the test due to leakage, reactions, or absorption. Similarly, system bi as checks were performed with THC, CO, O 2 , and

CO 2 for added assurance of sample system integrit y. The results of the system bias checks are available in Appendix D.

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

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

The NO X , CO, O 2 and CO 2 sampling and analysis system was checked for response time per the procedures outlined in EPA Method 7E, Section 8.2.5 and 8.2.6. The maximum response
time did not exceed 80 seconds. The minimum sa mpling time per point selected was at least

### 24 twice the maximum response time as determined duri ng the initial system bias tests. The results of these response time tests are contained in Appendix D.

TRC and/or instrument vendors conducted interference response tests on the NO X , CO,

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

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

As a minimum, before and after each test run, the analyzers were checked for zero and span drift. This allows test runs to be br acketed by calibrations and documents the precision of the data just collected. Calibration gases were introduced to the analyzers through the entire sampling system. Appendix D contains quality assurance tables that summarize the zero and span checks that were performed for each test run. The worksheets also contain the data used to correct the data for drift per EPA Method 7E, Equation 7E-5. NO X , CO, O 2 and CO 2 data were corrected for drift as required by the test met hods. 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 in struments were analyzed and certified by the compressed gas vendors to ±1% accuracy for all calibration gases. EPA Protocol No. 1 was used, where applicable, i.e., NO X gases, to assign the concentration values traceable to the National Institute of Standards and Technology (NIS T), Standard Reference Materials (SRM's). The gas calibration sheets as prepared by the vendor are contained in Appendix E.

Quality assurance procedures for labor atory analysis of the stack gas CH 4 were conducted in accordance with EPA Method 18 prot ocols. 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 sampli ng began during preparation for the tests. All glassware was thoroughly washe d, 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 a nd retained for evaporation and weighing for

contaminants for each test series. A blank filte r 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 c onducted 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 ambien t 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-kineticall y. 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 r un, the nozzle and front half of the filter
holder were washed with acetone to remove adheri ng 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 pr eserved 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 recove red 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 sampli ng began during preparation for the tests. All glassware was thoroughly washe d, rinsed, dried, and packed safely to prevent contamination. American Chemical Society (ACS) reagent gr ade or better acetone, distilled water, and HCl
absorber solution were selected for used. A bl ank of the HCl absorber solution and deionized
water was collected with each set of test runs a nd 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 check ed by demonstrating that it could hold a vacuum greater than the highest sampling vacuum for at least 1 minute with a leakage rate less than 0.02 cubic feet per minute (cfm). A leak te st was conducted before ea ch test run began and after each test run was completed. This leak check was performed in accordance with EPA Methods 26A to ensure that the sample was notdiluted 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-kineticall y. Field checks of the iso-kinetics during at each sampling point and for the entire sampli ng 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 abso rber 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 sa mples were conducted with the inclusion of sample duplicates, spikes, and sample blanks. A ll 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 PM 10 , 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 genera ted using the calibrated orifice procedure. A post-test meter calibration check was performed upon return to the TRC Gainesville Office using

the Y qa 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 cont amination. 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 O 2 , CO 2 , CH 4 , and N 2 were conducted in accordance with EPA Method 3C protocols. Upon return to the TRC office samples were packed into a shipping cont ainer, sealed, and shipped with a chain-ofcustody form to Triangle Environmental Services, Inc. Results of the quality assurance activities are reported with the lab results in Appendix 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 fo r the ancillary equipment used during this testing. An altimeter/barometer was used for determination of barometric pressure. A fanoperated psychrometer with NIST traceable ther mometers was used to determine ambient and dew point temperatures. Other ancillary equipm ent includes analytical balance calibration data, angle finder calibration data, and caliper calibration data.

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