Project No. 2755

Ontario Landfill LFG to Energy Facility Engine No. 4 Emission Compliance Test Program

NYSDEC Permit ID 8-3244-00040/00001Prepared for:

Mr. David J. D’Amico Director of Engineering Innovative Energy Systems 2917 Judge Road Oakfield, New York 14125

Submitted to:

Ms. Michele A. Kharroubi, P.E. Environmental Engineer II

Division of Air Resource New York State Department of Environmental Conservation

6274 East Avon-Lima Road Avon, New York 14414-9519

Date Submitted: February 2005Table of Contents

Page

1.0 Introduction..................................................................................1

2.0 Source Description ......................................................................2

3.0 Program Scope ...........................................................................3

4.0 Test Location Description............................................................4

5.0 Test Results Summary ................................................................5

6.0 Test Methodologies .....................................................................7 6.1 Cyclonic Flow...................................................................7

6.2 Volumetric Flow Rate.......................................................7
6.3 Moisture Content .............................................................8 6.4 Gaseous Emissions Sampling System............................8 6.4.1 Nitrogen Oxides ...................................................9

6.4.2 Carbon Monoxide.................................................9 6.4.3 NonMethane Compounds..................................10 6.4.4 Oxygen and Carbon Dioxide..............................11

7.0 Quality Assurance/Quality Control......................................... 13 7.1 S-Type Pitot Tubes........................................................13 7.2 Dry Gas Meters and Orifice ...........................................13 7.3 Thermocouples..............................................................14

7.4 Labels ............................................................................15 7.5 Chain-of-Custody Documentation..................................15

7.6 Calibration Gases ..........................................................15

Appendix A - Field Data Appendix B - Calculations Appendix C - Calibration Data Appendix D - Facility Operational DataInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 1 1.0 Introduction

AirNova, Inc. performed an emission compliance test program for four (4) lean burn

reciprocating engines in operation at the Ontario Landfill LFG to Energy facility located in Stanley,

New York (NYSDEC Permit ID. 8-3244-00040/00001) on February 8, 2005. The emission sampling

was conducted for the purpose of demonstrating compliance with the requirements specified in 40

CFR, Part 60, Subpart WWW - Standards of Performance for Municipal Solid Waste Landfills and

the NYSDEC air permit. The test program was conducted in determination of emissions from one

(1) of the four (4) engines with the most operating hours as of the date of the permit application.

The unit is identified as Engine No. 4. The specific emission parameters determined at the engine

exhaust stack included nitrogen oxides, carbon monoxide and nonmethane hydrocarbon

compounds.

AirNova, Inc. was responsible for all emissi ons testing, sample analysis, data reduction and

final report preparation. This report contains a summary of the test program results in addition to all

field data, sample calculations and supporting information. Any questions regarding the information

contained in this report maybe addressed to:

Mr. Mark D. Daly AirNova, Inc. 5845 Clayton Avenue Pennsauken, New Jersey 08109 Telephone: 856-486-1500

Telefax: 856-486-9896 E-mail: daly@airnova.comInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 2 2.0 Source Description

Facility Name: Ontario Landfill LFG to Energy Facility

Facility Contact: Mr. David J. D’Amico Director of Engineering

Facility Phone: (585) 948-8580

Facility Address: 3555 Post Farm Road Stanley, New York 14561.

Source Identification: One (1 ) Caterpillar Model G3516 lean burn reciprocating engine fired with landfill gas

Permit No.: 8-3244-0040/0001

DEC Facility Code: 8324400040

Applicable Regulation: 40 CFR Part 60, Subpart WWW and NYSDEC Air Permit

The Ontario Landfill LFG to Energy facility operates a total of four (4) Caterpillar Model

G3516 16 cylinder lean burn reciprocating engines at this site. Each unit is of 4-stroke design

equipped with a turbocharger, aftercooler and microprocessor controlled timing. The four

generators produce 3.2 MW of electricity. All units are fired by landfill gas collected from the

adjacent landfill. The landfill gas is conditioned by a glycol scrubber prior to being supplied to the

engines. All emission sampling was conducted at the individual exhaust stack associated with

Engine No. 4.Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 3 3.0 Program Scope

Sampling was performed at the exhaust stack associated with Engine No. 4 in determination

of nitrogen oxides (NO

x ) , carbon monoxide (CO) and nonmethane hydrocarbon compounds

(NMHC) in accordance with EPA Reference Methods 7E, 10, 18 and 25A. The NMHC

determinations were conducted to demonstrate that the emission source meets the emission

standard of 20 ppmV as hexane corrected to 3% oxygen. Triplicate 1-hour test runs were

performed in determination of all emission paramet ers for the engine. All emission determinations

were performed concurrently.Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 4 4.0 Test Location Description

The emission point associated with the engine is an individual 12.25-inch diameter exhaust

stack which terminates at approximately 25 feet above grade. There are two (2) 2-inch diameter

sampling ports located 1.5 diameters upstream and 2.9 diameters downstream from the nearest

flow disturbances. The sampling ports are located on the circumference of the exhaust stack at 90

degrees to one another. These two (2) test ports were utilized for all emission sampling.

The traverse points utilized for all sampling were located as follows:

Table 4-1 Ontario Landfill LFG to Energy Facility

Emission Compliance Test Program

Traverse Point Locations

Point % Stack Diameter Location (inches)

1 3.2 0.5*

2 10.5 1.3

3 19.4 2.4

4 32.3 4.0

5 67.7 8.3

6 80.6 9.9

7 89.5 11.0

8 96.8 11.8*

* Relocated in accordance with EPA Reference Method 2, Section 2.3.1.2.Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 5 5.0 Test Results Summary

A complete summary of results for the test program conducted for Engine No. 4 at the

Ontario Landfill LFG to Energy Facility is provided in tabular format on the following page.

A summary of the average determined emission va lue for Engine No. 4 is provided below in

addition to the respective NSPS Subpart WWW emission limit.

Emission Source Average NonMethane Hydrocarbon Emission

Concentration (EPA Method 18/25A)

Engine No. 4 13.0 ppmV @ 3% O 2

NSPS Subpart WWW Limit 20 ppmV @ 3% O 2Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 6 Table 5-1 Ontario Landfill LFG to Energy Facility

Emission Compliance Test Program Test Data Summary - Engine No. 4

Run No. 1 2 3

Date 02/08/05 02/08/05 02/08/05

Test Period 0910-1010 1025-1125 1137-1237 Average

Temperature ( O F) 825 834 835 831

Moisture Content (%) 8.4 7.7 8.6 8.2

Velocity (FPS) 132 141 137 137

Flow Rate (ACFM) 6,483 6,893 6,718 6,698

Flow Rate (DSCFM) 2,378 2,531 2,442 2,450

Oxygen (% - dry) 8.19 8.25 8.23 8.22

Carbon Dioxide (% - dry) 10.43 10.6 10.64 10.56

NonMethane Hydrocarbons (as Hexane)

Concentration (ppmV) 11.4 13.8 2.4 9.2

Concentration (ppmV@3%) 16 19.5 3.4 13

Emission Rate (lb/hr) 2.02 2.61 0.44 1.54

Emission Rate (g/BHp) 0.811 1.047 0.167 0.675

Nitrogen Oxides (as NO 2 )

Concentration (ppmV) 182 158 154 165

Emission Rate (lb/hr) 3.1 2.87 2.69 2.89

Emission Rate (g/BHp) 1.25 1.15 1.08 1.16

Carbon Monoxide

Concentration (ppmV) 784 766 732 761

Emission Rate (lb/hr) 8.14 8.46 7.8 8.13

Emission Rate (g/BHp) 3.27 3.4 3.13 3.27Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 7 Standard Conditions 68 ° F, 29.92 in Hg 6.0 Test Methodologies

The emission test program was conducted in determination of the following parameters

utilizing the specified methodology:

Table 6-1 Ontario Landfill LPG to Energy Facility

Emission Compliance Test Program Test Methodology Summary

Emission Parameter Sampling and Analytical Methodology

Flow Rate EPA Reference Method 1 and 2

Oxygen/Carbon Dioxide EPA Reference Method 3A

Moisture Content EPA Reference Method 4

Nitrogen Oxides EPA Reference Method 7E

Carbon Monoxide EPA Reference Method 10

NonMethane Hydrocarbon Compounds EPA Reference Method 18/25A

6.1 Cyclonic Flow

The absence of cyclonic flow was demonstrated at the sampling location according to

Section 11.4 of EPA Reference Method 1. An S-type pitot was connected to a manometer. The

pitot tube was placed in such a pos ition that the openings of the pitot tube were perpendicular to the

stack gas flow. An angle finder was placed on the pitot tube which was rotated until a reading of

zero (0) was obtained. The 'yaw' angle was then recorded.

6.2 Volumetric Flow Rate

Traverses for volumetric flow rate determination were conducted in accordance with EPA

Reference Method 2. Stack gas pressure differentials were determined with an S-type pitot tubeInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 8 which was connected to an inclined manometer. The stack gas temperature was determined with a

thermocouple which was connected to a digital temperature indicator. The thermocouple was

attached to the pitot tube. A total of sixteen (16) traverse points were utilized for all sample and

velocity traverses. The traverse points were located as indicated in Table 4-1.

6.3 Moisture Content

The moisture content of the exhaust gas stream was determined in accordance with the

procedures outlined in EPA Reference Method 4. Gas samples were extracted at a constant rate

and passed through a stainless steel probe maintained at 225 ° F. The gas sample then passed

through an impinger train consisting of four (4) gla ss impingers immersed in an ice bath. The first, a

modified Greenburg-Smith contained 100 mil of di stilled water and the second, a Greenburg-Smith

contained 100 ml of distilled water. A third impinger was initially dry. A fourth impinger contained

silica gel for final drying of the gas sample. The sample volume was subsequently measured by

passing it through a calibrated dry gas meter.

The impinger contents were measured for increase in volume after each test run and

discarded. The silica gel was returned to its original tared contained and reweighed to determine

moisture gain.

Minimum sample volumes of 30 DSCF were collected during each test run. All dry gas

meters were calibrated in accordance with EPA Reference Method 5, Section 5.3.

6.4 Gaseous Emissions Sampling System

An extractive sampling system was used to continuously determine O 2 , CO 2 , NO

x , CO, and

total hydrocarbon compounds (THC) concentrations. A representative sample of flue gas is

extracted through a heated (225 ° F) stainless steel probe and filter assembly, and is transported via

a heat-traced Teflon sample line through a heated filter and a Teflon lined diaphragm sample pumpInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 1

AirNova, Inc. 9 to a condensation removal trap locat ed in the mobile laboratory. The condensation trap is cooled to

approximately 37 ° F. The sample exits the trap free of moisture and particulates. The THC sample

bypasses the condensation trap. The sample is introduced into a constant-pressure manifold

constructed of stainless steel and Teflon for metered distribution to the respective analyzers.

6.4.1 Nitrogen Oxides

Nitrogen oxides concentrations were det ermined by EPA Reference Method 7E. The

principle of this method is to continuously extract a gaseous sample of flue gas and introduce a

portion of this sample into a chemiluminescent analyzer for determination of concentration. The

principle of the analyzer is based on the following reaction:

NO + O 3 --> NO 2 + O 2 + a photon

The photons emitted by the reaction are m easured by a photomultiplier tube. The

photomultiplier signal is proportional to the number of NO molecules; therefore, the photomultiplier

signal is recorded as the concentration for NO. The sample flowrate is carefully controlled. NO

x is

comprised of NO and NO 2 . NO 2 present in the sample gas is converted into NO prior to entering

the reaction chamber by a NO 2 to NO converter. The NO 2 to NO converter breaks one (1) of the

two (2) nitrogen-oxygen bonds by passing the sample gas through capillary tubing into an

electronically controlled, heated catalytic converte r. A converter efficiency check was performed

prior to the start of sampling on each day of testing in accordance with Section 5.6.2 of EPA Method

20. Calibration gases were 45-55% and 80-100% of span plus N 2 (zero gas). A zero and midpoint

bias calibration were performed from the sample probe both before and after each test run. Output

signals were stored and processed by a PC based DAS system as well as a strip chart recorder.

The analyzer operating range is specified in Table 6-2.

6.4.2 Carbon MonoxideInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 10 Carbon monoxide concentrations were determined by gas filter correlation

spectroscopy. A representative sample of stack gas is directed to the analyzer via the sample

transport system described above. The sample enters the analyzer and is passed through the

sample cell. Radiation from an infrared source is chopped then passed through a gas filter which

alternates between CO and N 2 due to the rotation of the filter wheel. The radiation then passes

through a narrow band pass interference filter and enters a multiple optical cell where absorption by

the sample gas occurs. The IR radiation then exits the sample cell and is focused on the detector.

The CO gas filter acts to produce a reference beam which cannot be further attenuated by CO in

the sample cell. The N 2 side of the gas filter is transparent to the IR radiation. This beam is

absorbed by CO present in the sample. Absorption of the IR beam by CO in the sample causes a

proportional difference in the signals from the sample and reference cell beams. This difference is

converted electronically into an output signal that is linearly proportional to the concentration of CO

in the sample. Before and after each sample run, the analyzer was calibrated with NIST traceable

calibration gases. Calibration gases were 20-30%, 45-55% and 80-100% of span plus N 2 (zero

gas). A zero and midpoint bias calibration was performed from the sample probe both before and

after each test run. Output signals were stored and processed by a PC based DAS system as well

as a strip chart recorder. The analyzer operating range is specified in Table 6.2.

6.4.3 NonMethane Hydrocarbon Compounds

NMHC emissions were determined by directing a portion of the sample into a total

hydrocarbon analyzer equipped with a flame ionization detector (FID). With the total hydrocarbon

analyzer, sample gas is transported to the FID via a heated sample train. All hydrocarbon species

present are ionized simultaneously to produce the signal output. The THC-FID was calibrated with

Protocol 1 grade methane calibration gases. Three (3) calibration gases of 20-30%, 45-55% andInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 11 80-100% of span were utilized. A zero and midpoint bias calibration was performed for the

continuous FID both before and after each test run. The concentration of methane and total

hydrocarbons was determined for each test. Output signals from the THC-FID were stored and

processed by a PC based data acquisition system and a strip chart recorder. The analyzer

operating range is specified in Table 6.2.

Utilizing the system described above, a samp le was extracted from the exhaust gas

stream after transport through a condensation trap for determination of methane content. The

sample was collected into a Tedlar bag for analysis by a gas chromatograph with a flame ionization

detector (GC-FID). The difference between the methane and total hydrocarbon concentration is

identified as NMHC for each test period. Output signals from the GC-FID were processed by an

integrator.

6.4.4 Oxygen and Carbon Dioxide

The oxygen and carbon dioxide concentrations in the stack gases were determined

by EPA Reference Method 3A. The sampling system was the same as described above. Oxygen

concentrations were determined using a paramagnetic oxygen analyzer. A non-dispersive infrared

analyzer was utilized to measure carbon dioxide concentrations. Calibration gases included

nitrogen and two (2) upscale span gases of CO 2 /O 2 in nitrogen. The upscale span gases were 45-

55% and 80-100% of span. A zero and midpoint bias calibration was performed both before and

after each test run from the sample probe. Carbon dioxide and oxygen samples were collected

simultaneously with all sampling events. Output signals from the analyzers were stored and

processed via a DAS as well as strip chart recorders. The analyzer operating range is specified in

Table 6-2.Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 12 Table 6-2 Ontario Landfill LPG to Energy Facility

Emission Compliance Test Program Calibration Gas Summary

Parameter: Oxygen Range: 0-25%

Actual Gas Concentration % of Range

Mid Calibration Gas 12.49 50

High Calibration Gas 22.3 89.2

Parameter: Carbon Dioxide Range: 0-15%

Mid Calibration Gas 7.74 51.6

High Calibration Gas 12.53 83.5

Parameter: Nitrogen Oxides Range: 0-500 ppmV

Mid Calibration Gas 246 49.2

High Calibration Gas 447 89.4

Parameter: Carbon Monoxide Range: 0-1000 ppmV

Low Calibration Gas 244.7 24.5

Mid Calibration Gas 444.2 44.4

High Calibration Gas 955.5 95.6

Parameter: Total Hydrocarbons (as CH4) Range: 0-2500 ppmV

Low Calibration Gas 890 35.6

Mid Calibration Gas 1265 50.6

High Calibration Gas 2000 80Innovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 13 7.0 Quality Assurance/Quality Control Procedures

All of the source sampling and analytical procedures were performed in accordance with the

US EPA's 'Good Laboratory Practice' guidelines. AirNova, Inc. followed the requirements of the

individual test methods to ensure the precision and accuracy of the source testing procedures. In

addition, AirNova, Inc. followed the procedures pr ovided in the 'Quality Assurance Handbook for Air

Pollution Measurement Systems, Volume III, Stationary Sources'. Sampling equipment that was

utilized in the test program was calibrated prior to the test performance. The following procedures

were utilized.

7.1 S-Type Pitot Tubes

The S-type pitot tubes were visually inspected to verify dimension requirements. Pitot tubes

meeting requirements were assigned a pitot tube coeffi cient of 0.84. Pitot tubes which did not meet

the requirements were not utilized.

7.2 Dry Gas Meters and Orifice

All dry gas meters used in the field were calibrated against a transfer standard dry gas meter

that is maintained in AirNova's calibration data. The transfer standard gas meter is calibrated

annually and certified against an NIST traceable Bell-type Prover which operates by liquid

displacement.

Field dry gas meters and orifice meters are calibrated at two month intervals at the following

orifice meter settings:

• 0.5 in. H 2 O

• 1.0 in. H 2 O

• 2.0 in. H 2 O

• 3.0 in. H 2 O

• 4.0 in. H 2 O

• 5.0 in. H 2 OInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 14 The initial and final volume readings and temperature readings were recorded for the dry

gas meter and the secondary standard test meter at each orifice meter setting. A dry gas meter

correction factor (DGMCF) was calculated for each setting and the average DGMCF was recorded.

All calibration documentation is stored in a designated filing cabinet for future reference. All

repair and maintenance documentation for each meter is stored in files that provide a history of

each meter and aid in our preventative maintenance program.

AirNova, Inc. also participates in the EPA Method 5 dry Gas Meter Audit Program.

7.3 Thermocouples

Thermocouples and thermometers utilized in the sampling program were calibrated

according to section 3.4.2 of the "Quality A ssurance for Air Pollution Measurement Systems:

Volume III" every two months. The calibration method includes comparing each field thermometer

and thermocouple at different temperatures to an ASTM certified mercury-in-glass thermometer.

The temperatures must agree within the tolerances mentioned for the type of sampling equipment

being calibrated. All the calibration data is stored in a designated filing cabinet for future reference.

1. Stack Gas and Filter Housing Thermocouples and Thermometers Three temperatures are measured and extrapolated over the range of temperatures encountered in field operations. The three temperatures used for calibration are:

1. Ice bath 2. Boiling point of water 3. Boiling point of cooking oil (or equivalent in solid salt bath)

2. Impinger Thermometers and Thermocouples Two temperatures are required to calibrate:

1. Ice bath 2. Stabilized room temperature

3. Dry Gas Thermometers Two temperatures are required to calibrate: 1. Stabilized hot water bath at approximately 104 - 122 ° F (40 - 50 ° C) 2. Stabilized room temperatureInnovative Energy Systems, Inc. Project No. 2755 February 2005 Revision No. 0

AirNova, Inc. 15 7.4 Labels

All samples collected as part of the sampling program (silica gel desiccant samples) were

affixed with labels which identify the following: 1) Project No., 2) Date, 3) Type of sample, 4) Run

No., 5) Sample location, and 6) Sample fraction.

7.5 Chain-of-Custody Documentation

Chain-of-custody documentation for all samples was implemented at the completion of

sampling and sample clean-up and was documented until the samples were received by the

laboratory for analysis.

7.6 Calibration Gases

• NIST Traceable Protocol 1 grade (  1%) gas standards were utilized for

calibration of the NO

x , O 2 , CO 2 , THC and CO analyzers.Appendix A

Field DataAppendix B

CalculationsAppendix C

Calibration DataAppendix D

Facility Operating Data