## Derenzo and Associates, Inc.

Environmental Consultants

39201 Schoolcraft, Suite B-10

· Livonia, MI 48150

· (734) 464-3880

· FAX (734) 464-4368
4970 Northwind Drive, Suite 201 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409 November 20, 2001

Mr. Michael Laframboise Operations Manager SUMPTER ENERGY ASSOCIATES, INC.

29261 Wall Street Wixom, MI 48393

Subject: Results of nitrogen oxides, carbon monoxi de, non-methane organic compounds, and

hydrogen chloride emissions testing conducted at th e Sumpter Energy Associates, Inc., City Sand and Landfill, Inc. Facility in Sumpter, Michig an

Derenzo and Associates, Inc. (Derenzo and Associate s) is pleased to provide Sumpter Energy Associates, Inc. (Sumpter Energy) with the enclosed report that presents results of compliance emission testing conducted at the City Sand and Landfill, Inc. (City Sand) facility in Sumpter, Michigan. Testing was conducted pursuant to the requirements of Michigan Department of Environmental Quality (MDEQ) Renewable Operating Permit (ROP) No. 199600326.

Testing consisted of: (1) instrumental analyzer mea surements of nitrogen oxides and carbon monoxide, (2) integrated sampling for nonmethane organic carb ons, and (3) integrated sampling for hydrogen chloride from four (4) internal combustion engines at the City Sand and Landfill, Inc. facility.

Testing was conducted September 18 - 21, 2001 by De renzo and Associates personnel Michael Brack, Gregory Graetz, and Andrew Rusnak. Assistance and process coordination was provided by Michael Laframboise, Sumpter Energy Associates Operations M anager, and Mark Balowski, Sumpter Energy Associates Electricity Generation Facility Manager. Mr. Tom Gasloli of the Michigan Department of Environmental Quality, Air Quality Division (MDEQ-A QD), was on site to witness the testing program.

Please find enclosed two file copies of the final r eport, which presents summary tables of the measure d emission rates from each engine, descriptions of th e process tested, sampling methodologies, test conditions, and supporting documentation.

In accordance with the provisions outlined in the R OP No. 199600326, and notification from the MDEQAQD, submission of the City Sand and Landfill, Inc. report should be made as follows:

One copy of the report to: Ms. Wilhemina McLemore District Supervisor, Air Quality Division MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

Detroit District Office 300 River Place, Ste. 3600 Detroit, MI 48207

One copy of the report to: Supervisor, Compliance S upport Unit

### Derenzo and Associates, Inc.

Mr. Michael Laframboise Page 2 Sumpter Energy Associates, Inc. November 20, 2001

39201 Schoolcraft, Suite B-10

· Livonia, MI 48150

· (734) 464-3880

· FAX (734) 464-4368
4970 Northwind Drive, Suite 201 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409 MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY Air Quality Division

3 rd Floor, North Tower Lansing, MI 48933

Derenzo and Associates has forwarded copies of the compliance test report to each of the appropriate MDEQ-AQD offices.

If you have any questions, please contact our offic e at (734) 464-3880.

Sincerely,

DERENZO AND ASSOCIATES, INC.

Gregory J. Graetz Project Engineer

Enclosures (2)

## Derenzo and Associates, Inc.

Environmental Consultants

39201 Schoolcraft, Suite B-10

· Livonia, MI 48150

· (734) 464-3880

· FAX (734) 464-4368
4970 Northwind Drive, Suite 201 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409 RESULTS OF NITROGEN OXIDES, CARBON MONOXIDE, NON-METHANE ORGANIC COMPOUNDS,

AND HYDROGEN CHLORIDE

EMISSIONS TESTING

CONDUCTED

AT THE CITY SAND AND LANDFILL, INC.

FACILITY IN SUMPTER, MICHIGAN

November 20, 2001 Project No. 0106011

### Derenzo and Associates, Inc.

i TABLE OF CONTENTS Page

1.0 INTRODUCTION ..................................

................................................... ........................................ 1

2.0 PROCESS DESCRIPTION ...........................

................................................... ................................. 1

3.0 TESTING AND ANALYSES ..........................

................................................... .............................. 2 3.1 Exhaust Gas Sampling Location, Velocity, Molecu lar Weight, and Moisture Content .................. . 2 3.1.1 Sample and Velocity Traverse ................

................................................... ............................... 2 3.1.2 Stack Gas Velocity and Volumetric Flowrate ..

................................................... ...................... 2 3.1.3 Determination of Molecular Weight ...........

................................................... ........................... 2

3.1.4 Determination of Moisture Content ...........

................................................... ............................ 3 3.2 Nitrogen Oxides (NO X ) Testing .........................................

................................................... ............ 3 3.3 Carbon Monoxide (CO) Testing ..................

................................................... .................................. 3 3.4 Non-methane Organic Compounds (NMOC) Testing ..

................................................... ................. 4 3.5 Hydrogen Chloride (HCl) Testing ...............

................................................... .................................. 5 3.6 Hydrogen Chloride (HCl) Testing ...............

................................................... .................................. 5 3.7 Combustion Temperature/NMOC Engineering Study .

................................................... .................. 5 3.7.1 Exhaust Gas Properties and Flowrate (USEPA Me thods 1 - 4) ...................................... .......... 5 3.7.2 CEM Gas Sampling (USEPA Methods 7E, 10, 18, a nd 25A) ........................................... ....... 6 3.7.3 Methane Gas Sampling (USEPA Method 18) ......

................................................... .................. 6 3.7.4 Hydrogen Chloride Testing (USEPA Method 26) .

................................................... ................ 6

4.0 MEASUREMENT RESULTS ...........................

................................................... ............................ 7 4.1 Nitrogen Oxides Emission Rates ................

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

4.2 Carbon Monoxide Emission Rates ................

................................................... ................................. 7 4.3 Non-methane Organic Compounds Concentrations ..

................................................... ..................... 8 4.4 Hydrogen Chloride Emission Rates ..............

................................................... ................................. 9 4.5 Combustion Temperature/NMOC Engineering Study .

................................................... .................. 9 4.6 Operating Parameters ..........................

................................................... ........................................... 9

5.0 SUPPORTING INFORMATION.........................

................................................... .......................... 9

### Derenzo and Associates, Inc.

ii LIST OF APPENDICES

APPENDIX A COMPUTER CALCULATED AND FIELD SAMPLING DATA SHEETS

APPENDIX B LABORATORY ANALYTICIAL RESULTS

APPENDIX C CALIBRATION DATA

APPENDIX D ENGINE OPERATING DATA

LIST OF TABLES

Table Page

1 Nitrogen oxides and Carbon monoxide concentrations and emission rates, Engine No. 5 ......................................

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

2 Nitrogen oxides and Carbon monoxide concentrations and emission rates, Engine No. 6 ......................................

................................................... ........................................ 12

3 Nitrogen oxides and Carbon monoxide concentrations and emission rates, Engine No. 4 ......................................

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

4 Nitrogen oxides and Carbon monoxide concentrations and emission rates, Engine No. 2 ......................................

................................................... ........................................ 14

5 Non-methane organic compounds concentrations, Engin e No. 5 ........................................... ...... 15

6 Non-methane organic compounds concentrations, Engin e No. 6 ........................................... ...... 16

7 Non-methane organic compounds concentrations, Engin e No. 4 ........................................... ...... 17

8 Non-methane organic compounds concentrations, Engin e No. 2 ........................................... ...... 18

9 Hydrogen chloride concentrations and emission rates

.................................................. ............... 19

10 Non-methane organic compounds concentrations from t he Combustion temperature engineering study ..........

................................................... .................... 20

LIST OF FIGURES Figure Page 1 Diagram presenting measurement and sampling loca tions ............................................ .............. 21

## Derenzo and Associates, Inc.

Environmental Consultants

39201 Schoolcraft, Suite B-10

· Livonia, MI 48150

· (734) 464-3880

· FAX (734) 464-4368
4970 Northwind Drive, Suite 201 • East Lansing, MI 48823 • (517) 324-1880 • FAX (517) 324-5409 RESULTS OF NITROGEN OXIDES, CARBON MONOXIDE, NON-METHANE ORGANIC COMPOUNDS,

AND HYDROGEN CHLORIDE

EMISSIONS TESTING

CONDUCTED

AT THE CITY SAND AND LANDFILL, INC.

FACILITY IN SUMPTER, MICHIGAN

1.0 INTRODUCTION

Sumpter Energy Associates, Inc. (Sumpter Energy) re tained Derenzo and Associates, Inc. (Derenzo and Associates) to conduct a testing program for the de termination of nitrogen oxides (NO X ), carbon monoxide (CO), non-methane organic compounds (NMOC) , and hydrogen chloride (HCl) emissions from four (4) internal combustion (IC) engines loca ted at the City Sand and Landfill, Inc. facility in Sumpter, Michigan.

Testing was conducted pursuant to the requirements of Michigan Department of Environmental Quality (MDEQ) Renewable Operating Permit (ROP) No. 1996003 26.

Testing was conducted September 18 - 21, 2001 by De renzo and Associates personnel Michael Brack, Gregory Graetz, and Andrew Rusnak. Assistance and process coordination was provided by Michael Laframboise, Sumpter Energy Associates Operations M anager, and Mark Balowski, Sumpter Energy Associates Electricity Generation Facility Manager. Mr. Tom Gasloli of the Michigan Department of Environmental Quality, Air Quality Division (MDEQ-A QD), was on site to witness the testing program.

USEPA sampling methodologies were followed for the proper execution of this project. A chemiluminescence analyzer was used for the perform ance of the USEPA Method 7E testing for the

determination of NO X emissions. A non-dispersive infrared (NDIR) analy zer was used for the performance of the USEPA Method 10 testing for the determination of CO emissions. Hydrogen chloride sample analysis was performed using ion ch romatography for the modified USEPA Method 26 sampling train. USEPA Methods 25A and 18 were used for the determination of non-methane organic compound (NMOC) and methane (CH 4 ) concentrations.

2.0 PROCESS DESCRIPTION

The equipment tested consisted of four (4) identica l, 800 kilowatt (kW) gensets (electricity generator driven by a reciprocating internal combustion engin e). Each genset, manufactured by Caterpillar Inc., Model No. 3516, incorporates state of the art techn ology in order to fire lean fuel mixtures and produ ce low combustion by-product emissions. Each engine h as a power generation rating of 1,138 brakehorsepower (bhp) and a maximum operating fuel requi rement that is equivalent to approximately 8.6 million Btu per hour (MMBtu/hr) heat input at the l ower heating value (LHV) of the LFG fuel. At a LFG

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LHV of 450 Btu per standard cubic foot (Btu/scf), e ach IC engine fires a total of approximately 317 sc fm and 0.457 million standard cubic feet per day (MMsc f/day) of LFG. All four engines fire a total of approximately 2,222 scfm and 3.2 MMscf/day.

Each IC engine is connected to a separate generator that has the capacity to produce approximately 800 kW of electricity.

Emissions from the combustion of LFG are released u ncontrolled into the ambient air through a stack connected to the IC engine exhaust manifold and noi se control system (noise muffler).

3.0 TESTING AND ANALYSES

The emissions testing was conducted using procedure s outlined in United States Environmental Protection Agency (USEPA) Methods for Stationary So urce Sampling.

Each engine was operated at maximum operating condi tions during the emission-testing project.

3.1 Exhaust Gas Sampling Location, Velocity, Molecu lar Weight, and Moisture Content

Pollutant emission concentrations and mass emission rate calculations require an accurate determinatio n of exhaust gas flowrate (USEPA Methods 1 and 2). E xhaust gas flowrate measurements require (1) measurement or estimation of the molecular weight o f the exhaust gas (USEPA Method 3), and (2)

measurement or estimation of the moisture content o f the exhaust gas (USEPA Method 4).

3.1.1 Sample and Velocity Traverse

USEPA Method 1, Sample and Velocity Traverses For Stationary Source s , was used to determine the number of traverse points required for testing each source.

Based on flow disturbance data, the sampling port p ositions meet the minimum criteria for a "representative measurement" of the gas velocity.

Figure 1 provides a schematic drawing of the tested engine and traverse sampling locations.

3.1.2 Stack Gas Velocity and Volumetric Flowrate

USEPA Method 2, Determination of Stack Gas Velocity and Volumetric Flowrate , was used to determine the average gas velocity. Average velocity pressur e measurements of the exhaust gas were made using an S-type Pitot tube connected to an oil manometer capable of reading pressures from 0.0" to 10" water column. Concurrent temperature measurements of the exhaust gas were made with a type-K thermocouple attached to the Pitot tube.

3.1.3 Determination of Molecular Weight

USEPA Method 3 and 3C, Gas Analysis for the Determination of Dry Molecular Weight, was used to determine the carbon dioxide, oxygen, and molecular weight of the exhaust gas. Integrated gas samples were extracted during the emission test. Carbon di oxide concentrations were determined using a Fuji Model ZRH 2 infrared gas analyzer. Oxygen concentr ations were determined using a Horiba Model CMA-331A analyzer.

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3

3.1.4 Determination of Moisture Content

USEPA Method 4, Determination of Moisture Content in Stack Gases, was used to determine the

moisture content the exhaust for each test. The mo isture sampling train consisted of a stainless-stee l sampling probe, a length of Tygon® tubing, a set of four Greenburg-Smith impingers, an umbilical, and a metering box. Each moisture sample was obtained si multaneously with the analyzer measurements and met the minimum sample volume criteria of 21 standa rd cubic feet. The majority of the moisture determination tests for this emissions study were o btained in conjunction with the modified USEPA Method 26 testing. The USEPA Method 26 testing was performed in conjunction with the analyzer sampling methodologies. Where moisture determinati ons were performed independent of the Method 26 sampling events, USEPA Method 4 moisture determinat ions were performed simultaneous with the analyzer sampling events.

3.2 Nitrogen Oxides (NO X ) Testing

Method 7 E
, Determination of Nitrogen Oxide Emissions from Stat ionary Sources (Instrument Analyzer Procedure) , was used for determining nitrogen oxide (NO X ) emissions from the test location. A gas sample is continuously extracted from the gas strea m through a stainless steel probe, heated sampling line, and gas conditioning system to remove the moi sture. A portion of the sample stream is conveyed via a sampling line to a Thermo Environmental Instr uments, Inc., Model 42C-chemiluminescense analyzer for determination of NO X concentration. Prior to emissions sampling, the c hemiluminescense analyzer is zeroed and calibrated. Instrumental re sponse was recorded on an ESC Model 8816 Data Logger that determined the average concentration at one-minute intervals for the test period.

Certified (USEPA protocol 1) calibration gas and pu rified nitrogen zero air were used with an STEC, In c. Model SGD-SC-5L five-point sample dilution module t o calibrate the Thermo Environmental Instruments, Inc., Model 42C NO X Analyzer before and after each test run. A contin uous gas sample was

withdrawn from the exhaust stack at a constant rate using a stainless-steel probe open at one end. Th e probe was connected to a heated Teflon sample line and a KWW MAK-2 sample gas conditioner. After conditioning, a Teflon-head pump was used to delive r the sample to the gas analyzer. Instrument response was recorded on an ESC Model 8816 Data Log ger that calculated and recorded the average concentration, in parts per million (ppm) values at one-minute intervals throughout the testing period s.

3.3 Carbon Monoxide (CO) Testing

USEPA Method 10, Determination of Carbon Monoxide Emissions from Sta tionary Sources , was used to determine the CO concentration of the engine exhaus t. Gas samples were continuously extracted from the exhaust stack and conveyed to an instrument ana lyzer (Horiba Model CMA-331A Carbon Monoxide Analyzer) for determination of CO concentration.

Certified (USEPA protocol 1) calibration gas and pu rified nitrogen zero air were used with an STEC, In c. Model SGD-SC-5L five-point sample dilution module t o calibrate the Horiba Model CMA-331A Carbon Monoxide Analyzer before and after each test run. A continuous gas sample was withdrawn from the exhaust stack at a constant rate using a stainless- steel probe open at one end. The probe was connect ed to a heated Teflon sample line and a KWW MAK-2 samp le gas conditioner. After conditioning, a Teflon-head pump was used to deliver the sample to the gas analyzer. Instrument response was recorded on an ESC Model 8816 Data Logger that calculated an d recorded the average concentration, in parts per million (ppm) values at one-minute intervals throug hout the testing periods.

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4

3.4 Non-methane Organic Compounds (NMOC) Testing

Pursuant to the test plan submitted July 10, 2001, the determination of NMOC exhaust concentration was performed using a Thermo Environmental Instruments, Inc., Model 55C (TECO 55C) non-methane hydrocarbon gas chromatography / flame ionization d etection (GC/FID) analyzer, as approved by the Wayn e County Department of Environment. USEPA protocol 1 certified methane and propane calibration gases an d nitrogen zero air, were used with a STEC, Inc. Mode l SGD-SC-5L dilution module, to calibrate the TECO 55C GC/FID. A gas sample was continuously extracte d from the gas stream through a stainless steel pro be and heated sampling line. The TECO 55C was used i n accordance with USEPA Method 18 , Measurement of Gaseous Organic Compound Emissions by Gas Chroma tography , for the in-field determination of methane concentrations in each engine exhaust. The sample stream was conveyed via a sampling line to the analyzer first for determination of methane concent ration by GC, then back-flushed internally for determination NMOC concentration by FID. Prior to emissions sampling, the GC/FID analyzer was zeroed and calibrated. Instrumental response was recorded on an ESC Model 8816 Data Logger that determined t he average concentration at one-minute intervals for t he test period.

Two alternative strategies for the measurement of N MOC exhaust concentration were completed for the purpose of engineering comparison:

(1) Method 25 A
, Determination of Total Gaseous Organic Concentratio n Using a Flame Ionization Analyzer , and Method 18 were used to determine the NMOC con centration of the engine exhaust relative to the calibration gas (propane). USEPA p rotocol 1 certified calibration gas and nitrogen zero air, were used with a STEC, Inc. Model SGD-SC- 5L dilution module, to calibrate Thermo Environmental Instruments, Inc. Model 51 (TECO 51) total hydrocarbon (THC) flame ionization detection (FID) analyzer. A gas sample is continuo usly extracted from the gas stream through a stainless steel probe and heated sampling line. Th e sample stream is conveyed via a sampling line to the analyzer for determination of THC concentration . Methane concentration measurements using the TECO 55C were gathered concurrently with the TH C measurements. The methane exhaust concentrations measured using the TECO 55C GC/FID w ere subtracted from the total hydrocarbon concentrations measured using the TECO 51 FID in or der to calculate exhaust NMOC

concentrations.

(2) Integrated 1-hour samples were withdrawn from the e ngine exhaust stacks for the determination of in-stack methane (CH 4 ) concentrations. Samples were obtained using a US EPA Method 18 evacuated chamber (lung) and preconditioned Tedlar® sampling bags. Each sample was clearly identified and shipped, overnight, for the followin g days analysis. Appendix B provides laboratory results for methane analysis. Methane exhaust conc entrations as determined through laboratory analysis of the integrated bag samples were subsequ ently subtracted from the THC concentrations measured using the TECO 51 FID in order to calculat e exhaust NMOC concentrations.

NMOC concentrations are presented in Section 4.0 of this report using each of the three measurement strategies detailed above.

3.5 Hydrogen Chloride (HCl) Testing

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5

A modified version of USEPA Method 26, Determination of Hydrogen Halide and Halogen Emissi ons from Stationary Sources, was used to determine the HCl concentrations at ea ch engine exhaust. Modifications to the reference method included using the larger impi nger configuration presented in USEPA Method 26A. This strategy was incorporated into the sampling pr ogram for the following two reasons: (1) Anticipate d low concentrations of HCl in the engine exhaust require d a larger sample volume to meet the instack (and subsequent analytical) limits of detection (LOD). By obtaining a larger sample volume (greater amount of exhaust air through the impingers) the in stack LOD was increased. This strategy was employed to redu ce or eliminate the amount of non-detectable results (ant icipated using Method 26 midget impingers) from the analytical laboratory (Clayton Group Services, Novi , Michigan) and (2) the anticipated fractional volu me of moisture in each sample (15%) could have created pr oblems using the midget impingers specified in Meth od 26 by potentially requiring frequent change out of the impinger contents.

Using the modified version of USEPA Method 26, a kn own volume of exhaust gas was extracted from the engine exhaust through a heated, glass lined sampli ng probe during each test. The gas sample was then passed through a filter for the collection of solid particles. The filter temperature was maintained at 250 o F

+/- 25 o F. The sampled exhaust gas was then passed through a series of impingers, filled with an 0.1 normality acidic solution of Sulfuric Acid absorbin g solution and ultimately through a drying agent fo r the collection of the target analyte. HCl concentratio ns were determined by analysis of the acidic adsorb ing solution and combined nozzle and probe liner rinse solution. Analysis of the adsorbing solutions was conducted using Ion Chromatography (IC).

3.6 Combustion Temperature/NMOC Engineering Study

Pursuant to Section 2.E.III.A.3 of MDEQ ROP No. 199 600326, Sumpter Energy is required to monitor average combustion temperature and to record period s of operation during which the combustion temperature was more than 28 ° C below the observed average during compliance test ing. An engineering study was conducted along with the compliance testi ng program in order to demonstrate that the engine exhaust NMOC concentration does not exceed 20.0 ppm , as hexane and corrected to 3% oxygen, as combustion temperature fluctuates with engine load variance. For this study, two separate units (engi ne Nos. 1 and 4) were set at two engine timings each, and operated at a load range of 25% to 100%.

Exhaust NMOC concentrations were measured and recor ded using the TECO 55C concurrently with the temperature versus load study. Prior to emissions sampling, the TECO 55C was zeroed and calibrated. Instrumental response was recorded on an ESC Model 8816 Data Logger that determined the average

concentration at one-minute intervals for the test period.

3.7 Quality Assurance/Quality Control

USEPA Quality Assurance/Quality Control (QA/QC) pro cedures were followed during the emissions testing program. The following information is a ge neral overview of the QA/QC requirements of the tes t program. Please refer to the individual USEPA test methods, found in 40 CFR Part 60, Appendix A, for detailed information regarding these procedures.

3.7.1 Exhaust Gas Properties and Flowrate (USEPA Me thods 1-4)

The QA/QC guidelines practiced for determination of flue gas properties and flowrates include:

• Prior to arriving onsite, the instruments used duri ng the source testing to measure the flue gas properties, such as the barometer, pyrometer, and p itot tube are calibrated to specifications outlined in the sampling methods.

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6

Flue gas velocity traverses are performed before an d after each test run. This procedure is followed t o ensure that representative pollutant mass flowrates are achieved, when used in conjunction with pollut ant
concentration measurements.

3.7.2 CEM Gas Sampling (USEPA Methods 7E, 10, 18, a nd 25A)

The QA/QC guidelines practiced during the NO X , CO, O 2 , CO 2 , CH 4 , NMOC, and THC analyzer testing

include:

• Instrumental analyzer calibration checks are perfor med prior to and following each test run. The calibration check is performed by introducing a gas of known concentration to the analyzer and recording the response. The difference between the pre-test calibration response and the post-test calibration response is known as the calibration dr ift. The calibration drift is a measure of the analyzer's stability during the test period. The c alibration is performed to assure that the analyzer is functioning properly and that a representative samp le concentration is obtained during the test period.

• An initial system bias check is performed prior to testing. The bias check is performed by introducing a gas of known concentration to the sam ple train inlet and recording the response. Unlike the calibration check (which is a check of t he analyzer's operation), the bias check is a measure of the sampling trains’ potential to introd uce erroneous measurements. The system bias check is performed to assure that the sample delive red to the analyzer is representative of the sampled gas stream. Instrumental analyzer, calibrat ion checks were performed prior to and following each test run. Data derived from the pretest and p osttest calibrations are incorporated into the fina l concentration value by applying the drift correctio n equation of USEPA Method 6C, equation 6.1.

3.7.3 Methane Gas Sampling (USEPA Method 18)

The QA/QC guidelines practiced for determination of methane include:

Methane samples were obtained simultaneously with t he direct read FID THC analyzer. Methane sampling media was preconditioned and leak-checked prior to use in the USEPA Method Sampling Lung. Each bag was clearly marked and shipped to Enthalpy Analytical, Inc. in Raleigh, NC. See Appendix B for the analytical report presented by Enthalpy Ana lytical, Inc.

3.7.4 Hydrogen Chloride Testing (USEPA Method 26)

The QA/QC guidelines practiced during the hydrogen chloride testing include:

• Particulate filter preparation inspection and handl ing. Prior to sampling, the individual filters are inspected for irregularities and flaws or pinhole l eaks and placed in a designated filter cassette (fo r protection from contamination and isolation from ot her filters).

• A heated glass probe liner assembly and quartz filt er were used for this testing program as required because of the elevated temperatures of the IC engi ne exhaust gas stream.

• Sample recovery procedures. Following the post-tes t leak check, the filter media was discarded as no particulate determination were to be made for this emissions study. The probe and front-half filter

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holder were rinsed with deionized/distilled water a nd Teflon brush and added to the recovered impinger adsorbing solution. Contents of the first two impingers and all connecting glassware, including the water rinses were collected and place d in a sample jar wrapped with electrical tape and labeled (front half) for analysis. Contents of the third and fourth impinger and all connecting glassware, including the water rinses were discarde d as Cl 2 analysis was not required for this emissions study. The fluid level of collected samp le and rinsate was marked on each bottle to allow for monitoring of leakage. These procedures were f ollowed to minimize error due to sample handling activities. Two blank samples were obtain ed for quality control purposes. The blank samples were obtained from the same lot as the rins e material used for the sampling program. Blank samples were handled and analyzed in the same manne r as each of the 12 HCl samples.

Analysis was performed using Ion Chromatography to determine the HCl concentrations in the collected samples.

4.0 MEASUREMENT RESULTS

Emission results are presented in tabular form imme diately following the text portion of this report. Summary Table Nos. 1 - 9 present test times, flowra tes, concentrations, emission rates with emission limits and other supplemental data from the testing program for each of the four engines, respectively

.

4.1 Nitrogen Oxide Emission Rates

The three-test average NO X emission rate for the No. 5 engine exhaust was 3.7 9 pounds per hour (lb/hr) and 16.6 tons per year (TpY) based on 8,760 hours o f operation. The three-test average NO X emission rate for the No. 6 engine exhaust was 3.64 lb/hr an d 16.0 TpY based on 8,760 hours of operation. The three-test average NO X emission rate for the No. 4 engine exhaust was 3.3 9 lb/hr and 14.8 TpY based on 8,760 hours of operation. The three-test average N O X emission rate for the No. 2 engine exhaust was 4.03 lb/hr and 17.7 TpY based on 8,760 hours of ope ration.

The permitted NO X limit, based on the maximum fuel usage for the fac ility and an assumed average thermal loading of 450 Btu/scf., is 5.04 lb./hr. pe r engine and 22.1 TpY based on continuous operation of one engine (see Renewable Operating Permit No. 1996 00326, issued May 25, 2001). Testing four (4) IC engines as representative of the remaining engines provides emissions results within the established limits for the facility.

4.2 Carbon Monoxide Emission Rates

The three-test average CO emission rate for the No. 5 engine exhaust was 4.33 lb/hr and 19.0 TpY based on 8,760 hours of operation. The three-test averag e CO emission rate for the No. 6 engine exhaust was 3.37 lb/hr and 14.7 TpY based on 8,760 hours of ope ration. The three-test average CO emission rate fo r the No. 4 engine exhaust was 3.15 lb/hr and 13.8 Tp Y based on 8,760 hours of operation. The three-tes t average CO emission rate for the No. 2 engine exhau st was 3.42 lb/hr and 15.0 TpY based on 8,760 hours of operation.

The permitted CO limit, based on the maximum fuel u sage for the facility and an assumed average thermal loading of 450 Btu/scf., is 5.24 lb./hr. pe r engine and 23.0 TpY based on continuous operation of one engine (see Renewable Operating Permit No. 1996 00326, issued May 25, 2001). Testing four (4) IC engines as representative of the remaining engines provides emissions results within the established limits for the facility.

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4.3 Non-methane Organic Compounds Concentrations

NMOC exhaust concentrations from IC engines were de termined by direct measurement of methane and NMOC using a TECO 55C GC/FID.

The three-test average NMOC concentration for the N o. 5 engine exhaust was 6.7 ppm. The three-test average NMOC concentration for the No. 6 engine exh aust was 6.4 ppm. The three-test average NMOC concentration for the No. 4 engine exhaust was 7.9 ppm. The three-test average NMOC concentration for the No. 2 engine exhaust was 6.5 ppm. All conc entrations are presented as hexane, corrected to 3%

O 2 at the control device exhaust. Pursuant to 40 CFR 60.752(b)(2)(iii)(B), NMOC emissions compliance is 20.0 ppm as hexane, corrected to 3% O 2 at the control device exhaust. The testing of fou r (4) IC engines as representative of the remaining engines provides emissions results within the established limits for the facility.

When using the recommended Methods 25A and 18, a di fficulty occurs with relatively high concentrations of methane of 1,000 ppm or more exis t with relatively low concentrations of NMOC of approximately 10 to 20 ppm in an exhaust stream. I f the error in methane measurement technique is limited to 10.0% or less, the actual measured metha ne concentration would be 1,000 ppm ± 100 ppm, (or from 900 to 1,100 ppm). When correcting the error in the methane measurement from 100 ppm to 33.3 ppm on an as propane basis, it is not improbable th at an estimated negative NMOC value would occur.

To date, USEPA advocates the use of Method 25A for THC measurement with Method 18 used for methane subtraction (where outlet concentrations of NMOC are less than 50 ppm as carbon), realizing fully that methane values may be greater than the T HC values thereby resulting in a negative NMOC concentration. Negative values can not be accurate ly reported, therefore a value of zero has been assigned to the NMOC concentrations and emissions r ates where applicable.

For the purpose of engineering comparison, NMOC con centrations as determined by methane subtraction from total hydrocarbon concentrations are presented below.

Using the TECO 51 FID in accordance with the TECO 5 5C for methane analysis by in-field GC, the three-test average NMOC concentration for the No. 5 engine exhaust was 30.1 ppm. The three-test average NMOC concentration for the No. 6 engine exh aust was 20.3 ppm. The three-test average NMOC concentration for the No. 4 engine exhaust was 23.2 ppm. The three-test average NMOC concentration for the No. 2 engine exhaust was 15.0 ppm. All con centrations are presented as hexane, corrected to 3 %

O 2 at the control device exhaust.

Using the TECO 51 FID in conjunction with integrate d bag sampling for methane, the three-test average NMOC concentration for the No. 5 engine exhaust was 12.2 ppm. The three-test average NMOC concentration for the No. 6 engine exhaust was 7.4 ppm. The three-test average NMOC concentration for the No. 4 engine exhaust was 1.2 ppm. The thre e-test average NMOC concentration for the No. 2 engine exhaust was 42.8 ppm. Upon examination of t he laboratory analysis data for engine No. 2, it appears that the bag sample from test run No. 1, wi th a concentration of 325 ppm, was diluted, resulti ng in an uncharacteristically low concentration. When this data point is eliminated, the two-test averag e NMOC concentration for the No. 2 engine exhaust was 7.5 ppm. All concentrations are presented as hexane, corrected to 3% O 2 at the control device exhaust.

4.4 Hydrogen Chloride Emission Rates

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The three-test average HCl emission rate for the No . 5 engine exhaust was 0.011 lb/hr based on 8,760 hours of operation. The three-test average HCl emi ssion rate for the No. 6 engine exhaust was 0.012 lb/hr based on 8,760 hours of operation. The three -test average HCl emission rate for the No. 4 engin e exhaust was 0.011 lb/hr based on 8,760 hours of ope ration. The three-test average HCl emission rate f or the No. 2 engine exhaust was 0.012 lb/hr based on 8 ,760 hours of operation.

The permitted HCl limit, based on the maximum fuel usage for the facility and an assumed average thermal loading of 450 Btu/scf., is 0.251 lb./hr. p er engine based on continuous operation of one engi ne (see Renewable Operating Permit No. 199600326, issu ed May 25, 2001). Testing four (4) IC engines as representative of the remaining engines provides em issions results within the established limits for t he facility.

4.5 Combustion Temperature/NMOC Engineering Study

The maximum NMOC exhaust concentration for the No. 4 engine was 10.41 ppm, over a combustion temperature range of 841 ° F to 865 ° F (449 ° C to 463 ° C), combustion O 2 level of 4.33% to 7.33%, and a load of 25% to 100%, at two engine timings. The ma ximum NMOC concentration for the No. 1 engine was 17.27 ppm, over a combustion temperature range of 840 ° F to 920 ° F (449 ° C to 493 ° C), combustion

O 2 level of 6.18% to 7.34%, and a load of 25% to 100% , at two engine timings. All concentrations are presented as hexane, corrected to 3% O 2 at the control device exhaust.

The maximum NMOC exhaust concentration does not exc eed 20.0 under any potential engine operating scenario. The engines were run as lean and as rich , respectively, as possible without misfiring. Tes ting two (2) IC engines as representative of the remaini ng engines provides emissions results within the established limits for the facility.

4.6 Operating Parameters

Operational data was recorded at the facility durin g the testing program. See Appendix D for a presentation operating data for the September 18 - 21, 2001 test date which includes; date, times, temperature, and power generation.

Testing was conducted under near maximum operating conditions of approximately 317 standard cubic feet per minute (scfm) landfill gas consumption for each Caterpillar Inc., Model 3516 internal combustion engine.

5.0 SUPPORTING INFORMATION

Please find under the following listed appendices, the supporting information and data gathered for th is emissions test program.

• Appendix A provides copies of the computer generate d and field-sampling data sheets.

• Appendix B provides copies of laboratory data.

• Appendix C provides calibration data.

• Appendix D provides copies of production data.

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Report Prepared By: Report Reviewed By:

Gregory J. Graetz John E Mason, Jr. Project Engineer Senior Project EngineerINSERT TABLES 1-6 AND FIGURE 1 HERE

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APPENDIX A

COMPUTER CALCULATED AND FIELD SAMPLING DATA SHEETS

### Derenzo and Associates, Inc.

APPENDIX B

LABORATORY ANALYTICAL RESULTS

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APPENDIX C

CALIBRATION DATA

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APPENDIX D

ENGINE OPERATING DATA8