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 monoxide, non-methane organic compounds, and 

hydrogen chloride emissions testing conducted at the Sumpter Energy Associates, Inc., City 

Sand and Landfill, Inc. Facility in Sumpter, Michigan 

Derenzo and Associates, Inc. (Derenzo and Associates) 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 measurements of nitrogen oxides and carbon monoxide, 

(2) integrated sampling for nonmethane organic carbons, 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 Derenzo and Associates personnel Michael Brack, 

Gregory Graetz, and Andrew Rusnak. Assistance and process coordination was provided by Michael 

Laframboise, Sumpter Energy Associates Operations Manager, and Mark Balowski, Sumpter Energy 

Associates Electricity Generation Facility Manager. Mr. Tom Gasloli of the Michigan Department of 

Environmental Quality, Air Quality Division (MDEQ-AQD), was on site to witness the testing program. 

Please find enclosed two file copies of the final report, which presents summary tables of the measured 

emission rates from each engine, descriptions of the process tested, sampling methodologies, test 

conditions, and supporting documentation. 

In accordance with the provisions outlined in the ROP 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 Support 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 

 3rd 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 office 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, Molecular 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 (NOX) 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 Methods 1 - 4) ................................................ 5 

3.7.2 CEM Gas Sampling (USEPA Methods 7E, 10, 18, and 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, Engine No. 5 ................................................. 15 

6 Non-methane organic compounds concentrations, Engine No. 6 ................................................. 16 

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

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

9 Hydrogen chloride concentrations and emission rates ................................................................. 19 

10 Non-methane organic compounds concentrations from the 

Combustion temperature engineering study ................................................................................. 20 

LIST OF FIGURES 

Figure Page 

1 Diagram presenting measurement and sampling locations .......................................................... 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) retained Derenzo and Associates, Inc. (Derenzo and 

Associates) to conduct a testing program for the determination of nitrogen oxides (NOX), carbon 

monoxide (CO), non-methane organic compounds (NMOC), and hydrogen chloride (HCl) emissions 

from four (4) internal combustion (IC) engines located 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. 199600326. 

Testing was conducted September 18 - 21, 2001 by Derenzo and Associates personnel Michael Brack, 

Gregory Graetz, and Andrew Rusnak. Assistance and process coordination was provided by Michael 

Laframboise, Sumpter Energy Associates Operations Manager, and Mark Balowski, Sumpter Energy 

Associates Electricity Generation Facility Manager. Mr. Tom Gasloli of the Michigan Department of 

Environmental Quality, Air Quality Division (MDEQ-AQD), 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 performance of the USEPA Method 7E testing for the 

determination of NOX emissions. A non-dispersive infrared (NDIR) analyzer 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 chromatography 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 (CH4) concentrations. 

2.0 PROCESS DESCRIPTION 

The equipment tested consisted of four (4) identical, 800 kilowatt (kW) gensets (electricity generator

driven by a reciprocating internal combustion engine). Each genset, manufactured by Caterpillar Inc.,

Model No. 3516, incorporates state of the art technology in order to fire lean fuel mixtures and produce 

low combustion by-product emissions. Each engine has a power generation rating of 1,138 brakehorsepower (bhp) and a maximum operating fuel requirement that is equivalent to approximately 8.6 

million Btu per hour (MMBtu/hr) heat input at the lower heating value (LHV) of the LFG fuel. At a LFG
Derenzo and Associates, Inc. 

2 

LHV of 450 Btu per standard cubic foot (Btu/scf), each IC engine fires a total of approximately 317 scfm 

and 0.457 million standard cubic feet per day (MMscf/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 uncontrolled into the ambient air through a stack 

connected to the IC engine exhaust manifold and noise control system (noise muffler). 

3.0 TESTING AND ANALYSES 

The emissions testing was conducted using procedures outlined in United States Environmental 

Protection Agency (USEPA) Methods for Stationary Source Sampling. 

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

3.1 Exhaust Gas Sampling Location, Velocity, Molecular Weight, and Moisture Content 

Pollutant emission concentrations and mass emission rate calculations require an accurate determination 

of exhaust gas flowrate (USEPA Methods 1 and 2). Exhaust gas flowrate measurements require (1) 

measurement or estimation of the molecular weight of the exhaust gas (USEPA Method 3), and (2) 

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

3.1.1 Sample and Velocity Traverse

USEPA Method 1, Sample and Velocity Traverses For Stationary Sources, was used to determine the 

number of traverse points required for testing each source. 

Based on flow disturbance data, the sampling port positions 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 pressure 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 dioxide concentrations were determined using a Fuji 

Model ZRH 2 infrared gas analyzer. Oxygen concentrations were determined using a Horiba Model 

CMA-331A analyzer. 
Derenzo and Associates, Inc. 

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 moisture sampling train consisted of a stainless-steel 

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 simultaneously with the analyzer measurements and 

met the minimum sample volume criteria of 21 standard cubic feet. The majority of the moisture 

determination tests for this emissions study were obtained 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 determinations were performed independent of the Method 26 

sampling events, USEPA Method 4 moisture determinations were performed simultaneous with the 

analyzer sampling events. 

3.2 Nitrogen Oxides (NOX) Testing 

Method 7E, Determination of Nitrogen Oxide Emissions from Stationary Sources (Instrument Analyzer 

Procedure), was used for determining nitrogen oxide (NOX) emissions from the test location. A gas 

sample is continuously extracted from the gas stream through a stainless steel probe, heated sampling 

line, and gas conditioning system to remove the moisture. A portion of the sample stream is conveyed 

via a sampling line to a Thermo Environmental Instruments, Inc., Model 42C-chemiluminescense 

analyzer for determination of NOX concentration. Prior to emissions sampling, the chemiluminescense 

analyzer is 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. 

Certified (USEPA protocol 1) calibration gas and purified nitrogen zero air were used with an STEC, Inc. 

Model SGD-SC-5L five-point sample dilution module to calibrate the Thermo Environmental 

Instruments, Inc., Model 42C NOX 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 connected to a heated Teflon sample line and a KWW MAK-2 sample 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 and recorded the average 

concentration, in parts per million (ppm) values at one-minute intervals throughout the testing periods. 

3.3 Carbon Monoxide (CO) Testing 

USEPA Method 10, Determination of Carbon Monoxide Emissions from Stationary Sources, was used to 

determine the CO concentration of the engine exhaust. Gas samples were continuously extracted from 

the exhaust stack and conveyed to an instrument analyzer (Horiba Model CMA-331A Carbon Monoxide 

Analyzer) for determination of CO concentration. 

Certified (USEPA protocol 1) calibration gas and purified nitrogen zero air were used with an STEC, Inc. 

Model SGD-SC-5L five-point sample dilution module to 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 connected 

to a heated Teflon sample line and a KWW MAK-2 sample 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 and recorded the average concentration, in parts per 

million (ppm) values at one-minute intervals throughout the testing periods. 
Derenzo and Associates, Inc. 

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 detection (GC/FID) analyzer, as approved by the Wayne 

County Department of Environment. USEPA protocol 1 certified methane and propane calibration gases and 

nitrogen zero air, were used with a STEC, Inc. Model SGD-SC-5L dilution module, to calibrate the TECO 

55C GC/FID. A gas sample was continuously extracted from the gas stream through a stainless steel probe 

and heated sampling line. The TECO 55C was used in accordance with USEPA Method 18, Measurement 

of Gaseous Organic Compound Emissions by Gas Chromatography, 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 concentration 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 the 

average concentration at one-minute intervals for the test period. 

Two alternative strategies for the measurement of NMOC exhaust concentration were completed for the 

purpose of engineering comparison: 

 

(1) Method 25A, Determination of Total Gaseous Organic Concentration Using a Flame Ionization 

Analyzer, and Method 18 were used to determine the NMOC concentration of the engine exhaust 

relative to the calibration gas (propane). USEPA protocol 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 continuously extracted from the gas stream through a 

stainless steel probe and heated sampling line. The 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 THC measurements. The methane exhaust 

concentrations measured using the TECO 55C GC/FID were subtracted from the total hydrocarbon 

concentrations measured using the TECO 51 FID in order to calculate exhaust NMOC 

concentrations. 

(2) Integrated 1-hour samples were withdrawn from the engine exhaust stacks for the determination of 

in-stack methane (CH4) concentrations. Samples were obtained using a USEPA Method 18 

evacuated chamber (lung) and preconditioned Tedlar® sampling bags. Each sample was clearly 

identified and shipped, overnight, for the following days analysis. Appendix B provides laboratory 

results for methane analysis. Methane exhaust concentrations as determined through laboratory 

analysis of the integrated bag samples were subsequently subtracted from the THC concentrations 

measured using the TECO 51 FID in order to calculate 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 
Derenzo and Associates, Inc. 

5 

A modified version of USEPA Method 26, Determination of Hydrogen Halide and Halogen Emissions from 

Stationary Sources, was used to determine the HCl concentrations at each engine exhaust. Modifications to 

the reference method included using the larger impinger configuration presented in USEPA Method 26A. 

This strategy was incorporated into the sampling program for the following two reasons: (1) Anticipated low 

concentrations of HCl in the engine exhaust required 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 reduce or 

eliminate the amount of non-detectable results (anticipated using Method 26 midget impingers) from the

analytical laboratory (Clayton Group Services, Novi, Michigan) and (2) the anticipated fractional volume of 

moisture in each sample (15%) could have created problems using the midget impingers specified in Method 

26 by potentially requiring frequent change out of the impinger contents. 

Using the modified version of USEPA Method 26, a known volume of exhaust gas was extracted from the 

engine exhaust through a heated, glass lined sampling 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 250o

F 

+/- 25o

F. The sampled exhaust gas was then passed through a series of impingers, filled with an 0.1 

normality acidic solution of Sulfuric Acid absorbing solution and ultimately through a drying agent for the 

collection of the target analyte. HCl concentrations were determined by analysis of the acidic adsorbing 

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. 199600326, Sumpter Energy is required to monitor 

average combustion temperature and to record periods of operation during which the combustion 

temperature was more than 28°C below the observed average during compliance testing. An engineering 

study was conducted along with the compliance testing 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 (engine 

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 recorded 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) procedures were followed during the emissions 

testing program. The following information is a general overview of the QA/QC requirements of the test 

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 Methods 1-4)

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

• Prior to arriving onsite, the instruments used during the source testing to measure the flue gas 

properties, such as the barometer, pyrometer, and pitot tube are calibrated to specifications outlined

in the sampling methods. 
Derenzo and Associates, Inc. 

6 

Flue gas velocity traverses are performed before and after each test run. This procedure is followed to 

ensure that representative pollutant mass flowrates are achieved, when used in conjunction with pollutant 

concentration measurements. 

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

The QA/QC guidelines practiced during the NOX, CO, O2, CO2, CH4, NMOC, and THC analyzer testing 

include: 

• Instrumental analyzer calibration checks are performed 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 drift. The calibration drift is a measure of the 

analyzer's stability during the test period. The calibration is performed to assure that the analyzer is 

functioning properly and that a representative sample 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 sample train inlet and recording the response. 

Unlike the calibration check (which is a check of the analyzer's operation), the bias check is a 

measure of the sampling trains’ potential to introduce erroneous measurements. The system bias 

check is performed to assure that the sample delivered to the analyzer is representative of the 

sampled gas stream. Instrumental analyzer, calibration checks were performed prior to and following 

each test run. Data derived from the pretest and posttest calibrations are incorporated into the final 

concentration value by applying the drift correction 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 the 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 Analytical, 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 handling. Prior to sampling, the individual filters are

inspected for irregularities and flaws or pinhole leaks and placed in a designated filter cassette (for 

protection from contamination and isolation from other filters). 

• A heated glass probe liner assembly and quartz filter were used for this testing program as required 

because of the elevated temperatures of the IC engine exhaust gas stream. 

• Sample recovery procedures. Following the post-test 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 
Derenzo and Associates, Inc. 

7 

holder were rinsed with deionized/distilled water and 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 placed 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 discarded as Cl2

 analysis was not required for this 

emissions study. The fluid level of collected sample and rinsate was marked on each bottle to allow 

for monitoring of leakage. These procedures were followed to minimize error due to sample 

handling activities. Two blank samples were obtained for quality control purposes. The blank 

samples were obtained from the same lot as the rinse material used for the sampling program. Blank 

samples were handled and analyzed in the same manner 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 immediately following the text portion of this report. 

Summary Table Nos. 1 - 9 present test times, flowrates, 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 NOX emission rate for the No. 5 engine exhaust was 3.79 pounds per hour (lb/hr) 

and 16.6 tons per year (TpY) based on 8,760 hours of operation. The three-test average NOX emission 

rate for the No. 6 engine exhaust was 3.64 lb/hr and 16.0 TpY based on 8,760 hours of operation. The 

three-test average NOX emission rate for the No. 4 engine exhaust was 3.39 lb/hr and 14.8 TpY based on 

8,760 hours of operation. The three-test average NOX emission rate for the No. 2 engine exhaust was 

4.03 lb/hr and 17.7 TpY based on 8,760 hours of operation. 

The permitted NOX limit, based on the maximum fuel usage for the facility and an assumed average 

thermal loading of 450 Btu/scf., is 5.04 lb./hr. per engine and 22.1 TpY based on continuous operation of 

one engine (see Renewable Operating Permit No. 199600326, 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 average CO emission rate for the No. 6 engine exhaust was

3.37 lb/hr and 14.7 TpY based on 8,760 hours of operation. The three-test average CO emission rate for 

the No. 4 engine exhaust was 3.15 lb/hr and 13.8 TpY based on 8,760 hours of operation. The three-test 

average CO emission rate for the No. 2 engine exhaust 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 usage for the facility and an assumed average 

thermal loading of 450 Btu/scf., is 5.24 lb./hr. per engine and 23.0 TpY based on continuous operation of 

one engine (see Renewable Operating Permit No. 199600326, 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. 
Derenzo and Associates, Inc. 

8 

4.3 Non-methane Organic Compounds Concentrations

NMOC exhaust concentrations from IC engines were determined by direct measurement of methane and 

NMOC using a TECO 55C GC/FID. 

The three-test average NMOC concentration for the No. 5 engine exhaust was 6.7 ppm. The three-test 

average NMOC concentration for the No. 6 engine exhaust 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 concentrations are presented as hexane, corrected to 3%

O2 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% O2 at the control device exhaust. The testing of four (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 difficulty occurs with relatively high 

concentrations of methane of 1,000 ppm or more exist with relatively low concentrations of NMOC of 

approximately 10 to 20 ppm in an exhaust stream. If the error in methane measurement technique is 

limited to 10.0% or less, the actual measured methane 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 that 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 THC values thereby resulting in a negative NMOC 

concentration. Negative values can not be accurately reported, therefore a value of zero has been 

assigned to the NMOC concentrations and emissions rates where applicable. 

For the purpose of engineering comparison, NMOC concentrations as determined by methane subtraction 

from total hydrocarbon concentrations are presented below. 

Using the TECO 51 FID in accordance with the TECO 55C 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 exhaust 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 concentrations are presented as hexane, corrected to 3% 

O2 at the control device exhaust. 

Using the TECO 51 FID in conjunction with integrated 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 three-test average NMOC concentration for the No. 2 

engine exhaust was 42.8 ppm. Upon examination of the laboratory analysis data for engine No. 2, it 

appears that the bag sample from test run No. 1, with a concentration of 325 ppm, was diluted, resulting 

in an uncharacteristically low concentration. When this data point is eliminated, the two-test average 

NMOC concentration for the No. 2 engine exhaust was 7.5 ppm. All concentrations are presented as 

hexane, corrected to 3% O2 at the control device exhaust. 

4.4 Hydrogen Chloride Emission Rates
Derenzo and Associates, Inc. 

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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 emission 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 engine 

exhaust was 0.011 lb/hr based on 8,760 hours of operation. The three-test average HCl emission rate for 

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. per engine based on continuous operation of one engine 

(see Renewable Operating Permit No. 199600326, 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. 

4.5 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 O2 level of 4.33% to 7.33%, and a 

load of 25% to 100%, at two engine timings. The maximum 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 

O2 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% O2 at the control device exhaust. 

The maximum NMOC exhaust concentration does not exceed 20.0 under any potential engine operating 

scenario. The engines were run as lean and as rich, respectively, as possible without misfiring. Testing 

two (2) IC engines as representative of the remaining engines provides emissions results within the 

established limits for the facility. 

4.6 Operating Parameters 

Operational data was recorded at the facility during 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 this 

emissions test program. 

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

• Appendix B provides copies of laboratory data. 

• Appendix C provides calibration data. 

• Appendix D provides copies of production data. 
Derenzo and Associates, Inc. 

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Report Prepared By: Report Reviewed By: 

Gregory J. Graetz John E Mason, Jr. 

Project Engineer Senior Project Engineer 
INSERT TABLES 1-6 AND FIGURE 1 HERE 
Derenzo and Associates, Inc.

APPENDIX A 

COMPUTER CALCULATED AND FIELD SAMPLING DATA SHEETS 
Derenzo and Associates, Inc.

APPENDIX B 

LABORATORY ANALYTICAL RESULTS 
Derenzo and Associates, Inc.

APPENDIX C 

CALIBRATION DATA 
Derenzo and Associates, Inc.

APPENDIX D 

ENGINE OPERATING DATA
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